Terms of Use

1. About ETFLens

ETFLens (“we”, “us”, “our”) is an Australian financial information platform operated as a sole trader business. ETFLens provides research tools, data, and calculators to help investors understand exchange-traded funds (ETFs) listed on the Australian Securities Exchange (ASX).

By accessing or using ETFLens, you agree to these Terms of Use. If you do not agree, do not use the platform.

Eligibility. You must be at least 18 years of age to use ETFLens. By using the service, you represent that you are 18 or older.

Account security. You are responsible for maintaining the security of your account credentials. You must notify ETFLens immediately at hello@etflens.com.au if you suspect unauthorised access to your account. ETFLens is not liable for any loss arising from unauthorised use of your account.

2. General information only, not financial advice

All content, tools, calculators, scores, estimates, and outputs on ETFLens are provided for general information purposes only. Nothing on ETFLens constitutes:

• personal financial advice within the meaning of the Corporations Act 2001 (Cth);
• a recommendation to acquire or dispose of any financial product;
• an assessment of whether any investment is suitable for your individual circumstances; or
• a financial plan or statement of advice.

ETFLens does not hold an Australian Financial Services (AFS) licence and is not authorised to provide personal financial advice. Before making any investment decision, you should consider your own financial situation and objectives and seek advice from a licensed financial adviser.

3. Tool names and output framing

ETFLens tools, including Portfolio Snapshot, Portfolio Builder, ETF Watchlist, ETF Switch Calculator, Income Estimator, CGT & Cost Base Calculator, Distribution Calendar, Stock X-Ray, Fee Analyser, Overlap Checker, and Saved Portfolios, provide illustrative outputs based solely on the data you enter. These outputs:

• are estimates only and may not reflect your actual investment outcomes;
• do not account for your tax position, income, risk tolerance, or investment horizon;
• are based on historical or user-provided data and do not predict future performance; and
• should be used as a starting point for further research, not as a basis for investment decisions.

Portfolio Snapshot scores in particular.The Portfolio Snapshot tool provides a numeric score (0 to 100) derived from a weighted average of four mechanical dimensions: Cost Efficiency, Diversification, Overlap Control, and Concentration Risk. This score is a factual calculation based on your inputs. It is not a recommendation to change, maintain or switch any investment. The score describes where a portfolio falls within ETFLens's internal scoring scale only. It is not an investment recommendation, suitability assessment, statement of advice, or financial product advice. In particular:

• The score does not account for your investment objectives, financial situation, tax position, risk tolerance, or investment horizon.
• A higher score does not guarantee positive investment outcomes. A lower score does not indicate that your portfolio will underperform.
• The scoring methodology reflects ETFLens's internal design choices and is not derived from any regulatory standard or third-party benchmark.

Portfolio Snapshot outputs are intended to give you a structured starting point for your own research and for conversations with a licensed financial adviser, not to substitute for professional advice.

4. Data accuracy

ETF holdings, fees (MERs), yields, and other data displayed on ETFLens are sourced from publicly available fund-manager endpoints and refreshed automatically. Each ETF carries its own data vintage date (e.g. “as at Q2 2026”) reflecting when the source file we last ingested was stamped by the provider. ETFLens makes no warranty, express or implied, that the data is accurate, complete, current, or suitable for any purpose.

Management expense ratios and holdings compositions can change. Always verify current fees and holdings directly with the fund provider's Product Disclosure Statement (PDS) before making any investment decision.

5. Limitation of liability

To the maximum extent permitted by law, ETFLens and its operator exclude all liability for any loss or damage, including financial loss, loss of profits, or consequential loss, arising from:

• your reliance on any information, tool output, or content on ETFLens;
• any inaccuracy, incompleteness, or error in data displayed on ETFLens;
• any investment decision made using ETFLens tools or content; or
• any interruption, delay, or unavailability of the ETFLens platform.

Where liability cannot be excluded by law, our total liability to you for any claim arising out of your use of ETFLens is limited to the greater of AUD $100 or the total subscription fees paid by you in the 12 months preceding the claim.

Nothing in these terms excludes, restricts, or modifies any right or remedy you may have under the Australian Consumer Law (Schedule 2 of the Competition and Consumer Act 2010 (Cth)) that cannot be excluded by agreement.

6. Subscriptions and billing

ETFLens Pro is available on a monthly ($19/month) or annual ($119/year) subscription, billed in Australian dollars. ETFLens is not registered for GST, so no GST is charged on these prices. Subscriptions are processed via Stripe. You may cancel at any time, cancellation takes effect at the end of your current billing period.

Auto-renewal: Subscriptions automatically renew at the end of each billing period at the same price unless cancelled before the renewal date. You will receive an email reminder before your annual subscription renews. You can cancel at any time through your account settings.

Refund policy: If you are not satisfied within the first 7 days of your initial subscription payment date, you may request a full refund by emailing hello@etflens.com.au. Refunds apply to the initial subscription period only and are not available for renewal payments. After 7 days, refunds are not provided for partial billing periods, except where required by Australian Consumer Law. This voluntary refund policy does not limit any rights you may have under the Australian Consumer Law.

7. Termination

You may cancel your subscription at any time through your account settings or by contacting us. Cancellation takes effect at the end of your current billing period. Access to Pro features continues until the end of the paid period.

ETFLens may suspend or terminate your access to the service immediately and without prior notice if you:

• (a) breach these Terms of Use;
• (b) engage in fraudulent activity, including misuse of the refund or money-back guarantee;
• (c) use the service in a way that causes harm to ETFLens or other users; or
• (d) fail to pay applicable subscription fees.

Where termination is due to your breach, no refund will be provided for any unused portion of a prepaid subscription period. Where ETFLens terminates your access for reasons other than your breach, a pro-rata refund of any prepaid subscription fees will be provided.

ETFLens reserves the right to discontinue the service entirely on 30 days written notice to your registered email address.

8. Acceptable Use

You agree not to:

• (a) use automated tools, bots, scrapers, or scripts to access or extract data from ETFLens without written permission;
• (b) reproduce, resell, or redistribute ETFLens data or content without written permission;
• (c) attempt to circumvent any access controls or subscription restrictions;
• (d) use the service for any unlawful purpose or in violation of these Terms.

9. Referral and affiliate arrangements

ETFLens does not currently hold any referral arrangements with third-party platforms. If this changes it will be disclosed on our How We Make Money page. Should ETFLens include a referral link to a brokerage in future, the following would apply:

• ETFLens may receive a commission if you open an account via a referral link. This commission is paid by the brokerage, not by you.
• Referral links are always clearly labelled on the site with an adjacent commission disclosure.
• This referral arrangement is structured as a “mere referral” under Corporations Regulations 7.6.01AB and does not constitute financial product advice.
• Our research and tool outputs are not influenced by any commercial relationship with brokerage partners.
• We do not recommend any specific brokerage. The existence of a referral link indicates only that you can purchase ETFs through that platform.

Full details of how ETFLens is funded are available on our How we make money page.

10. Intellectual property

All content on ETFLens, including written analysis, tool interfaces, and design, is owned by ETFLens and protected by Australian copyright law. You may not reproduce, distribute, or commercialise any content without our written permission.

11. Governing law and disputes

These Terms of Use are governed by the laws of Victoria, Australia. Any dispute arising from your use of ETFLens that cannot be resolved informally will be referred to the Victorian Civil and Administrative Tribunal (VCAT) or a court of competent jurisdiction in Victoria.

12. Changes to these terms

ETFLens may modify these Terms at any time. For material changes, we will provide at least 14 days notice by email to your registered address before the changes take effect. Your continued use of the service after the notice period constitutes acceptance of the updated Terms. If you do not accept the changes, you may cancel your subscription before the changes take effect and receive a pro-rata refund of any prepaid fees.

13. Severability and entire agreement

Severability: If any provision of these Terms is found to be unenforceable, the remaining provisions continue in full force and effect.

Entire Agreement: These Terms, together with our Privacy Policy, constitute the entire agreement between you and ETFLens regarding your use of the service and supersede all prior agreements.

14. Contact and complaints

Questions about these terms? Email us at hello@etflens.com.au.

ETFLens is operated as an Australian sole trader business. ABN: 82 934 239 964.

Complaints

If you have a complaint about ETFLens, including about a subscription charge, a refund request, or the accuracy of information provided, please contact us at hello@etflens.com.au with the subject line Complaint. Please include your account email address and a description of the issue.

We will acknowledge your complaint within 2 business days and aim to provide a substantive response within 14 business days. Where a complaint requires more time to investigate, we will notify you of the expected resolution timeframe.

If your complaint is not resolved to your satisfaction, you may contact an external body:

• Australian Competition and Consumer Commission (ACCC) - accc.gov.au
• Consumer Affairs Victoria - consumer.vic.gov.au
• Victorian Civil and Administrative Tribunal (VCAT) for disputes that cannot be resolved informally - vcat.vic.gov.au