No, deals on Uniborn are shared within a close network and do not constitute a public offering.
In accordance with the Regulation (EU) 2017/1129 of the European Parliament and of the Council, offerings on Uniborn cannot be considered public offerings, since:
an offer of securities is always addressed to fewer than 150 natural or legal persons per EU Member State, other than qualified investors (Article 1(4b));
the total amount of each particular offer under Estonian SPVs is less than EUR 1,000,000, which limit is calculated over a period of 12 months (Article 1(3)).