Last Updated: April 20, 2026
Article 1 - General Presentation
EMC Insights SARL-S, is a simplified private limited liabilitycompany governed by the laws of the Grand Duchy of Luxembourg, with registeredoffice located at 8, Rue de l’Ordre de la Couronne de Chêne, L-1361 Luxembourg, registered with the Luxembourg Trade and Companies’ Register under number B293278(EC). EC provides its Services (as defined below)from the Grand Duchy of Luxembourg. These general terms and conditions of use of the Services (T&Cs) are intended to define the framework under which EC offers to its clients the Services set out below.The T&Cs are complementary to, and shall be read in conjunction with, the engagement letter executed between the client and EC (the Engagement Letter), which sets out the specific terms and conditions applicable to the engagement.The applicable T&Cs are those published on EC’s website. EC reserves the right to modify, suspend or update, in whole or in part, at any time, the T&Cs. These modifications come into force as soon as they are published on EC’s website. The client is invited to consult the T&Cs prior to each use of the services. In case of conflict between the T&Cs and the Engagement Letter, the Engagement Letter shall prevail.
Article 2 - Services
EC provides consulting and coaching services, which are designed to address a broad range of wealth-related topics (the Services). The Services encompass practical aspects such as planning and preparing for transitions in life, support on emotional and relational aspects of wealth, including reflecting on personal values in connection with wealth-related matters and fostering constructive family dynamics through facilitated discussions on sensitive matters. The Services are performed exclusively in person or through direct interaction (including where applicable, meeting or videoconference individually agreed), through specific consulting session(s) (the Session(s)), the duration of which is agreed upon by EC and the client under the terms of the Engagement Letter. The purpose ofthe Session is to support the client in creating a structured overview of their personal and/or family financial situation, which may include assets, liabilities, structures, jurisdictions, and relevant stakeholders. The Session isanalytical, educational, and facilitative in nature and is intended to support reflection, organization, and preparation for discussions with third-party professional advisers.
Article 3 - Non-Advisory Nature of the Services
The Services consist solely of high-level informational and educational discussions, organizational and descriptive mapping exercises. The Services do not constitute advice in wealth management organization, wealth management planning, administrative or financial wealth management. No recommendations are made regarding specific financial products, transactions, legal structures, or tax strategies. At EC’s discretion, and solely where considered appropriate, EC may provide a non-binding summary document reflecting the information provided by the client and the topics discussed during the Session(s). Such document shall be descriptive only and shall not constitute advice, recommendations or conclusions of any kind. The client remains solely responsible for all decisions and actions taken.
Article 4 - Exclusionof Regulated Activities
The Services provided by EC do not constitute, and shall not be construed as constituting, any regulated financial activity requiring authorisation, registration or supervision by the Commission de Surveillance du Secteur Financier (CSSF) or any equivalent financial supervisory authority under Luxembourg or European Union law. In particular,EC does not provide: i) services of a professional of the financial sector (PFS) within the meaning of the Luxembourg law of 5 April 1993 on the financialsector, as amended, in particular and without limitation, portfolio management,investment advice or family office activities; ii) investment services oractivities within the meaning of the law of 30 May 2018 on markets in financialinstruments, as amended, transposing in particular Directive 2014/65/EU of theEuropean Parliament and of the Council of 15 May 2014 on markets in financialinstruments (MiFID II) and legal instruments related to MiFID II adopted at thelevel of the European Union, including without limitation, portfolio managementand investment advice; iii) undertakings for collective investments intransferable securities (UCITs) management services within the meaning of thelaw of 17 December 2010 relating to undertakings for collective investment, asamended, transposing Directive 2009/65/EC of the European Parliament and of theCouncil of 13 July 2009 on the coordination of laws, regulations andadministrative provisions relating to UCITS, and relevant UCITS legislation; iv)alternative investment fund (AIF) managementservices within the meaning of the law of 12 July 2013 on alternativeinvestment fund managers, as amended, transposing Directive 2011/61/EU of theEuropean Parliament and of the Council of 8 June 2011 on alternative investmentfund managers (AIFM) and relevant AIFM legislation; v) crypto-asset serviceswithin the meaning of Regulation (EU) 2023/1114 of the European Parliament andof the Council of 31 May 2023 on markets in crypto-assets (MiCAR), inparticular and without limitation, advice on crypto-assets and portfoliomanagement in crypto-assets; and vi) any other activity which, by its nature,would require a CSSF license, registration or prudential supervision.No authorization, registration or supervision by the CSSF or any other authority is required for the provision of the Services. The above is without prejudice to any general legal or administrative requirements that may apply to EC as a business established in Luxembourg, including, as the case maybe, the requirement to hold an authorisation of establishment and to comply with generally applicable rules (including consumer law, AML/CFT obligationswhere applicable, and data protection). The client shall seek independent advice from appropriately licensed legal, financial, or tax professionals for matters requiring such expertise.
Article 5 - Duration of Engagement
The Services may be provided either in the form of a single Session or of multiple Sessions, the number, duration and frequency of which shall be determined on a case-by-case basis. The specific modalities of the engagement, including without limitation the duration of the engagement, the number of Sessions, their individual duration, their frequency and, where applicable, any renewal or extension, shall be expressly defined in the Engagement Letter. Unless expressly provided otherwise in the Engagement Letter, no automatic renewal shall be deemed agreed.
Article 6 - Scheduling and Cancellation of Session(s)
Session times are scheduled by mutual agreement between the client and EC during an initial conversation or via email to EC. The client shall provide a minimum of 24 hours’ notice by email to EC for rescheduling or cancellation. Sessions missed without appropriate notice shall be counted as completed sessions. Rescheduling due to unforeseen circumstances may be arranged by mutual agreement.In the event of illness, force majeure, or other exceptional circumstances that prevent the completion of the Session(s) within the agreed period, the client and EC agree to discuss and mutually determine a suitable extension for the completion of the remaining Session(s).
Article 7 - Fee and Payment
The fees applicable to the Services are agreed between EC and the client and are set forth in the Engagement Letter. The fees are subject to value added tax (VAT), as applicable, at the rate in force under Luxembourg law. All payments shall be made in advance, prior to the commencement of any scheduled Session or service period, using one of the following payment methods:- bank transfer to EC’sdesignated bank account,- secured payment linkprovided by email with detailed instructions,- secured subscription-based payment link provided by email with detailed instructions. All payments are non-refundable, irrespective of whether the client makes full or partial use of the Services during the relevant period or fails to attend any scheduled Session. In any case, late payment interest shall apply as provided by applicable law, to any amount remaining unpaid after its due date.
Article 8 - Mutual Commitments and Ethical Standards
EC is committed to delivering its Services with discretion, trust and professionalism. EC adheres to the ethical standards and professional conduct set out by the International Coaching Federation for coaching engagements and applies the same principles of integrity, professionalism, and discretion to all coaching and consulting services. All Services are delivered with due care, in good faith, and in accordance with applicable professional standards. The client shall engage in the coaching or consulting process with honesty, openness, and commitment. This includes a willingness to receive constructive feedback and to invest the necessary time, attention, and responsibility to benefit fully from the engagement. The client shall possess full legal capacity to access and benefit from the Services and shall not be subject to any legal guardianship, conservatorship, or other restrictions affecting their ability to contract or to participate meaningfully in coaching and consulting services.
Article 9 - Confidentiality
EC shall treat as strictly confidential all information and documents communicated by the client in the context of the Services, except where disclosure is required by law or authorized in writing by the client.
Article 10 - Protection of Personal Data
As part of the provision of the Services, EC may need to use and/or process the personal data of the client. The processing of personal data is carried out in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and the free movement of such data (GDPR). The client has a right of access (Article 15 GDPR), rectification (Article16 GDPR) and erasure (Article 17 GDPR) of information concerning them. The client may also object to the processing of their data under the conditions provided for by Article 21 GDPR and obtain the restriction of the processing under the conditions provided for by Article 18 GDPR. Further details regarding the processing of personal data are defined in EC’s Privacy Policy, available on EC’s website.
Article 11 - No Intermediation or Representation
EC does not act as an intermediary, broker, agent or representative of the client. EC does not receive, hold, safeguard, manage or transfer funds, securities, crypto-assets or any other assets on behalf of the client, nor does it intermediate, arrange, facilitate or execute transactions of any nature. EC does not contact, negotiate with or communicate with financial institutions, advisers, counterparties, authorities or any third parties on behalf of the client, and does not assist in the execution, implementation or completion of any transaction or legal arrangement. EC does not coordinate the third-party professional advisors intervening in wealth management, monitoring or assessment of their performance for or on behalf of the client. Nothing in the provision of the Services shall be construed as creating an agency relationship, a fiduciary duty or any form of ongoing representation.
Article 12 - Limitation of Liability
EC is subject to an obligation of means (obligation de moyens) as to the proper execution of its Services. EC does not express any view as to the suitability, appropriateness, legality, structure, risks or expected performance of any transaction, asset, investment, arrangement or course of action. EC makes no guarantees or warranties regarding outcomes or results deriving from the provision of the Services. EC shall not be liable for i) decisions made by the client following the Session(s), ii) actions taken or omitted based on the information or document(s)shared, iii) advice, opinions or services provided by third-party professionals, and iv) indirect, consequential or economic losses. EC’s liability shall be limited to cases of wilful misconduct (dol) or gross negligence (faute lourde). The Services are not intended to substitute advice provided by duly authorised and licensed professionals. Any decision taken by the client following the Session(s) is taken independently and under the client’s sole responsibility. EC does not monitor, update or follow up on the client’s situation after the provision of the Services and assumes no ongoing obligation of assistance, vigilance or reporting.
Article 13 - Indemnification
The client expressly agrees to indemnify, defend, and hold harmless EC, its partners, employees, and agents from and against any and all claims, demands, liabilities, damages, losses, costs, expenses, fees, fines, or proceedings of any kind (including reasonable legal fees), arising directly or indirectly out of or in connection with the Session(s). This indemnification expressly covers, without limitation, any claims brought by third parties, including heirs, successors, or beneficiaries, who may allege damages or losses resulting from decisions or actions taken by the client out of or in connection with the Session(s).
Article 14 - Termination of Engagement
In the case of multiple Sessions, the engagement may be terminated by the client in accordance with the terms, conditions and notice periods provided for in the Engagement Letter.EC reserves the right to terminate the engagement at any time, with immediate effect, by written notice to the client, where: i) EC reasonably determines that the continuation of the Services is no longer appropriate, effective or aligned with the client’s goals or best interests; ii) the client breaches any material obligations under the T&Cs or the Engagement Letter; or iii) the continuation of the Services would, in EC’s reasonable judgment, conflict with applicable ethical rules, professional standards or legal requirements. Where reasonably practicable, EC may inform the client in advance of its intention to terminate and, where appropriate, may refer the client to other resources or professionals. Fees due for Services rendered up to the date of termination shall remain payable.
Article 15 - Validity of Clauses
The fact that EC does not avail itself at a given time of any of the clauses of these T&Cs cannot be interpreted as a waiver to subsequently rely on any of said clauses. The nullity, lapsing or non-enforceable nature of all or part of one of the provisions herein will not result in the nullity of all of these T&Cs. The provision wholly or partially null, void or unenforceable shall be deemed unwritten.
Article 16 - Governing Law and Jurisdiction
Any conflict, dispute or claim arising on the grounds of the existence, validity, interpretation, performance or compliance with these T&Cs will be governed by Luxembourg law, to the exclusion of its rules of conflicts of laws and subject to the exclusive jurisdiction of the competent Courts of the judicial district of Luxembourg.Any questions relating to these T&Cs should be sent by email to contact@eva-crone.com or by post to EMC Insights SARL-S, 8, Rue de l’Ordre de la Couronne de Chêne, L-1361 Luxembourg, Grand Duchy of Luxembourg.
