Terms & Conditions

Group Services and Acceptance of Terms

These Joint Terms and Conditions (the "Framework Terms") govern the provision of services by the emoni group of companies (the "emoni Group"), which includes, without limitation:

• iLedgends B.V., a licensed Electronic Money Institution established in the Netherlands;
• iLedgends s.r.o., a company established in the Czech Republic and registered or authorised as a Virtual Asset Service Provider; and
• Ledgends Inc., a company established in Canada and operating as a money services business,

together with any entity directly or indirectly controlling, controlled by, or under common control with them.

For the purposes of these Framework Terms:

• the "emoni Group" means all entities listed above; and
• the "Relevant Group Entity" means the specific emoni Group entity that provides, performs, or is responsible for a particular service or part of the Client relationship.

Multi-Entity Service Model

The Client acknowledges and agrees that services may be rendered, supported, coordinated, or operationally enabled by one or more entities within the emoni Group, depending on:

• the nature of the services provided;
• the Client's jurisdiction and regulatory requirements;
• the product, payment flow, or asset type involved; and
• the applicable operational and legal framework.

Where more than one emoni Group entity is involved in servicing the Client, each entity shall act strictly within its own legal and regulatory perimeter and shall be responsible only for the services it provides. The Relevant Group Entity shall be determined based on the specific service, product, account structure, and operational booking model, as communicated to the Client in onboarding documentation, transaction flows, or service-specific disclosures.

The Client acknowledges that, where services involve multiple Relevant Group Entities, the overall service may be delivered in a coordinated manner, while each entity remains contractually and regulatory responsible only for its own part.

Acceptance of Terms

By entering into a business relationship with any emoni Group entity and using the services made available, the Client acknowledges and agrees that:

• these Framework Terms apply to the overall relationship with the emoni Group;
• the Client may receive services from one or more Relevant Group Entities; and
• only the Relevant Group Entity providing a specific service shall be considered the contracting party and bear responsibility for that service, unless explicitly agreed otherwise in writing.

Regulatory Separation and Liability

Each emoni Group entity:

• operates independently within its own legal and regulatory framework;
• remains solely responsible for compliance with laws and regulations applicable to its licensed or registered activities; and
• shall not be deemed to assume responsibility for services provided by another emoni Group entity.

The commencement of services by each Relevant Group Entity shall be determined independently, in accordance with its own onboarding, risk acceptance, and regulatory requirements.

No emoni Group entity relies on another emoni Group entity's licence or regulatory status for the provision of regulated services, unless expressly required and documented in accordance with applicable law.

Each Relevant Group Entity shall be responsible for client onboarding, customer due diligence, transaction monitoring, and regulatory reporting in respect of the services it provides, unless otherwise required by law.

Nothing in these Framework Terms shall be construed as:

• creating a partnership, joint venture, or agency relationship between emoni Group entities;
• establishing joint or several liability between emoni Group entities;
• creating a single regulated entity across the emoni Group; or
• extending any licence, authorisation, or regulatory status from one emoni Group entity to another.

No Cross-Entity Use of Client Assets

To the extent applicable under law:

• client funds, safeguarded funds, electronic money, crypto-assets, or other client assets shall be held, processed, and controlled only by the Relevant Group Entity responsible for those services;
• such assets shall not be pooled, commingled, or transferred between emoni Group entities except where explicitly permitted by law and clearly disclosed to the Client; and
• no emoni Group entity shall use client assets held within another entity's regulatory perimeter.

Schedule 1 — iLedgends B.V. Terms and Conditions

1. General provisions

1.1 Terms and Conditions

These Terms and Conditions apply to the legal relationship / Agreement between you and emoni for the provision of Services by iLedgends B.V., a licensed Electronic Money Institution. The Terms and Conditions govern, among other things, your application for the provision of Services by emoni (the phase when no Agreement has yet been formed) and the phase following written confirmation of acceptance by emoni (the phase when an Agreement has become effective). The Terms and Conditions additionally provide rules for terminating your Agreement with emoni.

Important: Each emoni Group operating entity provides services within its own regulatory and contractual perimeter. If you use services of iLedgends s.r.o. (Czech Republic) or Ledgends inc (Canada), the applicable Service Schedule or entity-specific provisions shall apply to the relevant services.

1.2 Other general conditions

Other general conditions such as your general conditions or third party's general conditions, are not applicable to the (legal) relationship between you and emoni, unless otherwise agreed in writing.

2. Definitions and Interpretations

2.1 Definitions

In these Terms and Conditions the following capitalised words shall have the following meaning:

Agreement, Merchant Agreement or Client Agreement means the agreement between you and emoni, comprising the merchant agreement, this Terms and Conditions, The Fee Schedule, including the specific conditions to the Payment Methods.

Applicable Data Protection Law: the General Data Protection Regulation (GDPR; Regulation (EU) 2016/679), any local law of EU member states implementing the GDPR, or any other (local) law(s), or (local) regulations, policies, instructions, or recommendations of any competent supervisory authority applicable to the processing of personal data in connection with the performance of the Agreement, including any amendments, replacements, updates, or later versions of these laws and regulations.

Application Form means the document provided by emoni to the Merchant for onboarding of this Merchant.

Balance means the amount held in a Bank Account of the Merchant with emoni at a certain given time and as presented by emoni.

Bank Account means the bank account in your name that you maintain with emoni and/or with a banking partner or credit institution designated by emoni in connection with the Services.

Banking Partner means a financial institution, Credit Institution, bank or EMI with whom emoni has entered into a contract allowing clients of emoni to operate bank accounts provided by such Bank Partner.

Electronic Money Institution (EMI) means an institution authorised or registered to issue electronic money and provide related payment services in accordance with laws and regulations as applicable in the Netherlands.

Safeguarding means the statutory protection mechanism applicable to customer funds received in exchange for electronic money or in connection with payment services, whereby such funds are segregated from the own funds of iLedgends B.V. and held separately in accordance with applicable law and regulation.

Stichting Derdengelden iLedgends means the foundation established for the sole purpose of holding safeguarded customer funds separately from the assets of iLedgends B.V.

Customer means your customer, this can also be referred to as end-customer.

Customer Data means all personal data which is provided to emoni (or any processor engaged by emoni Group to process such personal data) by you in connection with the Agreement or in connection with the services provided by emoni under the Agreement involving you and / or your Customer, that is processed in accordance with data protection laws and regulations.

emoni Systems mean all those facilities automated or otherwise that emoni utilizes in the delivery of the Services including means of communication.

Merchant or Client means any party that is entering the Agreement with emoni for the purposes of making use of the services of emoni. Also referred to as "you" in these Terms and Conditions.

Merchant Account or Client Account means your account with emoni for the settling of Transactions.

Merchant Systems or Client System means any systems or facilities applied by the Merchant in connecting to and/or communicating with emoni.

Multi-currency means a multi currency account allows you to make and receive payments in foreign currencies.

Partner means any party emoni engages with in the execution of the Services.

Party means you or emoni and Parties means you and emoni collectively, and in respect of applicable articles, the banking partner is deemed a Party and to be deemed to fall within the scope of Parties. The banking partner may be from time to time amended, with the consent of all Parties.

Payment Data means all data specified on or linked to a Payment Instrument, including the Customer Data.

Payment Instrument means a physical or digital tool, offered by emoni to the Client, as part of its services, — such as a credit card, debit card, e-wallet, or bank transfer procedure — used to initiate payments and transfer funds without using physical cash.

Payment Method means a method used by a Customer to pay, such as a SWIFT, SEPA, Direct SEPA or any other methods which is offered and approved by emoni.

Recall a reversal request for a wire transfer issued by a counterparty to a transaction.

Refund means a repayment by or on behalf of you made to a counterparty in relation to a transaction.

Reserve means the acceptable collateral provided by Merchant to emoni.

Services means the activities performed by emoni for authorising, clearing, electronic money issuing and settling your Transactions, including any additional services that iLegends may have agreed with you in your Merchant Agreement.

SEPA (Single Euro Payments Area) is a payment-integration initiative of the European Union for simplification of bank transfers denominated in euro.

SWIFT The Society for Worldwide Interbank Financial Telecommunication (SWIFT), legally S.W.I.F.T.

Terms and Conditions means these terms and conditions of emoni.

Transaction means the payment transaction between you and a counterparty in connection with or as a consequence of a legal relationship with that counterparty and serving a legitimate purpose including for instance the supply of goods and/or services, donations, contributions or other ways of exchanging value.

Transaction Data means all details related to the Transaction including the value of the Transaction.

Transaction Service Fee means the fee that you have to pay to emoni for processing Transactions.

User means any person gaining access via the emoni Systems operating the Bank Account on the part of and as a representative of the Merchant / Client.

3. Formation Agreement

3.1 Client acceptance process

3.1.1 The Application Form Merchant Agreement / Fee Schedule mentions the Payment Method(s) and Services that you apply for. emoni decides which of the Payment Methods or Services it shall offer to you because emoni (i) has to take into account its risk and acceptance policy and (ii) is bound by legal requirements and statutory rules for client acceptance.

3.1.2 In order to fulfil the client acceptance process, emoni relies on the data and documents as provided by you and as can be specified in the Merchant Agreement, questionnaires and any exchanges you may have with emoni from time to time inclusive of any materials, documents and data that are publicly available or made available to emoni at its request.

3.2 Written Acceptance

3.2.1 Upon you signing (physically or by electronic signature) the Merchant Agreement, the terms and conditions as mentioned in this Agreement become final. The delivery of services by emoni only becomes legally binding when emoni allows you to use one or more Payment Methods or Services, which will be confirmed to you in writing.

4. Services

4.1 emoni and Partners

4.1.1 emoni provides the Services to you as a registered Electronic Money Institution in case of services delivered from iLedgends B.V., as a CryptoCurrency company in case of services delivered by iLedgends SRO and as Money Service Business in case of services delivered by Ledgends INC. emoni may also make use of other suppliers, service providers, banking partners and financial institutions in order to provide the Services to you.

4.1.2 In connection with the provision of its Services, emoni may cooperate with one or more banking partners and other regulated financial institutions. Where required by law or by operational setup, customer funds received in exchange for electronic money or in connection with payment services shall be held in accordance with requirements applicable to these banking partners or other regulated financial institutions.

4.1.3 iLedgends B.V. is required to safeguard relevant customer funds in accordance with applicable Dutch and European laws and regulations. This means that such customer funds are held separately from the own funds of iLedgends B.V. and may not be used for the operational or corporate purposes of iLedgends B.V. or any other emoni Group company.

4.1.4 Relevant customer funds of iLedgends B.V. are held in segregated accounts in the name of Stichting Derdengelden iLedgends with ClearBank Europe N.V., a Dutch credit institution. These arrangements are intended to ensure that safeguarded customer funds remain separated from the assets of iLedgends B.V. or any other emoni Group Company.

4.1.5 Customer funds safeguarded in this manner are not deposits and are therefore not protected under any deposit guarantee scheme, unless explicitly provided otherwise by applicable law.

4.2 Website

4.2.1 You may only use the Services for the sales website(s), in the Merchant Agreement, or any other document or system accepted by emoni. Any use of the Services for any other website requires the prior written approval of emoni. emoni can withhold its approval on the basis of its risk and acceptance policy or to otherwise protect itself from any actual or potential risk. emoni may decide to withdraw its approval for the use of the Services for a sales venue at a later stage where circumstances change, such as the introduction of another product range.

4.3 Payment Methods and Services

4.3.1 At any time during the Agreement, you may (i) indicate that you no longer would like to use one or more Payment Methods or Services or (ii) apply for one or more additional Payment Methods or Services. For the use of additional Payment Methods or Services, emoni shall decide whether or not to allow such use, and inform you in writing.

4.3.2 A Partner may decide (i) that you are not or no longer eligible to use a specific Payment Method or (ii) to cease offering a specific Payment Method. emoni acts only as an intermediary for you with such a Partner and is therefore neither responsible nor liable to you for such decisions made and implemented by the Partner.

4.3.3 emoni may (i) also decide to cease offering a specific Payment Method or Service and/or (ii) cease or restrict your use of a Payment Method or Service if it believes there are good faith reasons for doing so, or if emoni is required to do so under any national and international law and regulations or other conditions that apply to emoni and its partners. In these cases, emoni shall notify you accordingly.

4.4 Availability

4.4.1 emoni shall use its reasonable efforts to ensure that the Services are available to you. As the availability of the Services is also dependent on other parties, emoni cannot guarantee full availability of the Services.

4.5 Your general obligations

4.5.1 When entering into and during the term of the Agreement you must always provide emoni with full and accurate details needed for our onboarding process and continuous rendering of services.

4.5.2 You must promptly notify emoni of any changes in the data and documents provided by you during the onboarding or client (re)acceptance process, as part of the transaction monitoring performed by emoni or as specified in the Merchant Agreement. You must also provide all information requested by emoni from time to time. emoni's right to request information includes for instance financial information (such as financial statements, annual management accounts and tax forms) and other information about your business (such as bank references). emoni may use this information for any legal or other purpose as imposed on emoni or in determining whether additional agreements or amendments to the Agreement are necessary, for instance where there has been or may be a change in your financial status.

4.5.3 You must for the duration of this Agreement continuously hold all permits and authorisations you are required to have by national and international law and regulations to the conduct of your business and its related activities. You will inform emoni forthwith of any changes, suspensions, fines or penalties imposed on you by a relevant authority. The fact that emoni provides services to you does not imply that all of your required permits and authorisations are in place and/or that emoni has verified such.

4.5.4 In the conduct of your business and the performance of your obligations under the Agreement, you must comply with applicable national and international laws and regulations, the Agreement, Regulations, instructions of national and international authorities (including supervising authorities) and any reasonable instructions given by emoni. It is your responsibility to acquaint yourself with all of your obligations under the applicable law and regulations. emoni is under no obligation to notify you of any changes that may arise in relation to any applicable law or regulations.

5. Technical connection and Security

5.1 Connection

5.1.1 You may integrate your access to the emoni System with your own Merchant Systems. emoni is not responsible for having your Merchant Systems connecting with and/or operating in conjunction with the emoni System. You are responsible for such integration and the related costs.

5.1.2 You agree that the emoni System may be modified at any time by emoni. emoni is not responsible nor liable for any modifications to the emoni System and any consequences or changes this may require on your Merchant Systems.

5.2 Security

5.2.1 You shall ensure that the connections between your Merchant Systems and the emoni systems are secure. You shall only gain access to the emoni Systems in a secure internet environment.

5.2.2 You shall ensure that the Merchant Systems use sufficient security features and you must implement sufficient security measures.

5.2.3 The costs of the security features and security measures shall be your own financial responsibility. You shall act in compliance with our security instructions which are part of the connection process with the emoni System.

5.2.4 You warrant that you shall regularly check all software and electronic files for viruses, using the most recent version of a reputable anti-virus programme and the most recent virus database.

5.2.5 You shall handle the security features with care and keep these confidential.

5.2.6 You shall immediately notify emoni if you or one of your employees (or other people working for you) becomes aware or suspects that any of the security features is compromised. In addition, you are required to change the security features immediately should a compromise arise.

5.3 Means of authentication

5.3.1 You are at all times personally responsible and liable for the use of the means of authentication provided or allocated to you for access to and use of the emoni Systems, such as passwords or authentication codes.

5.3.2 emoni may trust that any user identifying himself or herself as your specific contact person via means of authentication is indeed the person he or she professes to be and that he or she is authorised to represent you. You shall be bound by any messages that are sent to emoni using the means of authentication provided or allocated to you by emoni.

5.3.3 emoni may trust that any User is authorised to operate the Bank Account or wallet in accordance with the account settings as implemented in the system as provided by emoni and emoni is not obligated to any extent to check the authority of that person or any limitations imposed on that person's authority.

5.3.4 You shall promptly notify emoni if you become aware or have reason to suspect that unauthorised persons have obtained access to the means of authentication to use the emoni Systems or that these means of authentication have been abused in any other way. In addition, you shall immediately take effective steps yourself to address such unauthorised access or abuse.

6. Transactions

6.1 Permitted transactions

6.1.1 You may only use a Payment Method for the Transactions that are agreed upon with emoni, as specified in the Merchant Agreement, or any other document or system accepted by emoni. Using Payment Methods for other purposes, requires the written approval of emoni. You are not permitted to use a Payment Method on behalf of a third party.

6.1.2 You may not offer any goods and/or services and Transactions that are contrary to national and international law and regulations, public morality and/or public order and/or that may damage the reputation of emoni.

7. Processing Transactions

7.1 Acceptance and non-acceptance

7.1.1 You are not allowed to accept a payment using a Payment Instrument if you suspect abuse of the Payment Instrument. You have a duty to investigate any suspicious activities relating to a Payment Instrument in accordance with AML/CTF regulations.

7.2 Submitting Transaction Data

7.2.1 You must submit Transaction Data to emoni for each Transaction that you submit to emoni. You guarantee that all submitted Transaction Data are accurate and complete. You also guarantee that the Transaction has been completed in accordance with the conditions of this Agreement and the applicable Regulations.

7.3 Retaining Transaction Data

7.3.1 You must at all times be able to offer proof that the Customer has approved a Transaction. To this end you are to retain the originals and/or copies of the Transaction Data.

7.3.2 When asked by emoni, you shall produce evidence and underlying documents of any Transaction disputed by a Customer. If you had not yet received the amount in relation to the disputed Transaction, emoni shall not be required to pay out such amount to you.

7.4 Additional requirements

7.4.1 emoni may stipulate additional requirements for the Transactions that you can submit to emoni under this Agreement. An example is setting a limit on Transactions (minimum and maximum amounts, but also the number of Transactions per unit of time). emoni may implement and/or amend these requirements upon notice to you. If urgent circumstances demand immediate implementation, emoni may implement and/or amend such requirements prior to notification to you.

8. Recalls

8.1 Eligibility for Recall

8.1.1 Only your authorized representatives are eligible to request a Recall.

8.1.2 You must provide sufficient evidence and documentation to support the Recall request, including but not limited, Transaction Data, beneficiary or counterparty information, and any other relevant evidence as required by emoni.

8.1.3 emoni reserves the right to assess each Recall request on a case-by-case basis and may deny the request if the provided evidence is insufficient or if the Customer fails to meet the eligibility criteria.

8.2 Recall Process (outgoing payments)

8.2.1 To initiate a Recall, you must notify emoni through the contact functionality on the emoni website after the wire transfer has been executed.

8.2.2 emoni will use its best efforts to process Recall requests promptly; however, the success of the Recall depends on various factors, including but not limited to the speed of communication with correspondent banks and the receiving institution.

8.2.3 You acknowledge that emoni cannot guarantee a successful Recall and will not be liable for any losses or damages resulting from an unsuccessful Recall.

8.3 Fees and Charges

8.3.1 You shall bear all costs associated with the Recall process, including but not limited to fees charged by correspondent banks or any other intermediaries involved in the Recall.

8.3.2 emoni may charge a processing fee for handling Recall requests, the amount of which shall be communicated to you at the time of initiating the Recall.

8.4 Client Responsibilities (outgoing recall requests)

8.4.1 You shall promptly provide all necessary information and documentation required to process the Recall.

8.4.2 You acknowledge that emoni relies on the accuracy and completeness of the information provided for processing the Recall and shall not be responsible for any delays or errors caused by inaccurate or incomplete information.

8.4.3 You shall indemnify and hold emoni harmless from any claims, losses, or damages arising from providing incorrect or misleading information related to the Recall.

8.5 Incoming Recall Requests (Funds Received into Your Account)

8.5.1 Where emoni receives a recall request, return of funds request, or similar instruction from a sending institution, correspondent bank, or payment scheme in respect of funds credited to your account, emoni shall notify you without undue delay, unless legally restricted from doing so.

8.5.2 You acknowledge and agree that emoni may, without prior notice where necessary, temporarily restrict, block, or earmark the relevant funds in your account pending investigation of the recall request, including for the purposes of fraud prevention, compliance with legal obligations, or cooperation with payment service providers.

8.5.3 You shall promptly (and in any event within the timeframe communicated by emoni):

• confirm whether you consent to the return of funds;
• provide any information or documentation reasonably requested by emoni in relation to the transaction; and
• where applicable, you may dispute the recall request, provided that such dispute is supported by sufficient evidence demonstrating your entitlement to the funds, including but not limited to contractual documentation, proof of delivery of goods or services, or other relevant supporting materials.

8.5.4 Where you consent to the return of funds, emoni is authorized to debit your account and return the funds to the originating institution without further instruction.

8.5.5 Where you do not respond within the specified timeframe, emoni may, acting reasonably and in accordance with applicable laws and scheme rules:

• Treat such non-response as refusal; or
• Proceed with further actions as required under legal or regulatory obligations.

8.5.6 Notwithstanding any dispute raised by you, emoni reserves the right, at its sole discretion, to return the funds subject to the recall request and debit your account where emoni determines that:

• the recall request is valid or justified;
• there are indications of fraud, error, or unauthorized transaction;
• emoni is required or requested to do so under applicable law, regulation, or by a competent authority; or
• such action is required or supported under applicable payment scheme rules or safeguarding obligations.

You acknowledge that emoni is not required to adjudicate disputes between you and the originating party.

8.5.7 You acknowledge that, in certain circumstances, emoni may be legally required to return funds without your consent, including but not limited to:

• Proven fraud or unauthorized transactions
• Orders or instructions from competent authorities
• Obligations under anti-money laundering laws, including the Dutch WWFT
• Applicable payment scheme rules

8.5.8 You shall ensure that sufficient funds remain available in your account to enable the return of funds subject to a recall request. emoni shall not be liable where funds are unavailable due to prior withdrawal, transfer, or use.

8.5.9 If funds subject to a recall request have already been withdrawn or transferred, you shall:

• Immediately reimburse emoni upon request; and
• Cooperate fully in any recovery efforts.

8.5.10 emoni reserves the right to debit your account without prior consent where:

• You have previously consented to such debit; or
• emoni is required to do so by law, court order, regulatory authority, or binding payment scheme rules.

8.5.11 You acknowledge that refusal to return funds that are proven to be fraudulent, erroneous, or unlawfully received may result in:

• Account restrictions or suspension
• Reporting to competent authorities,
• Termination of the business relationship

8.6 Limitation of Liability

8.6.1 emoni shall not be liable for any losses or damages, whether direct, indirect, incidental, or consequential, arising from or related to the Recall, including but not limited to loss of funds, business interruptions, or reputational damage.

8.6.2 emoni' liability, if any, shall be limited to the amount of the original wire transfer subject to the Recall.

9. Financial Arrangements

9.1 Fees

9.1.1 You shall be liable to emoni for all the fees for all the Services provided to you. The fees are set out in the Fee Schedule signed by the Merchant and all payment conditions for the Services provided to you by emoni are set out in the Merchant Agreement, as agreed by emoni and the Merchant in writing.

9.1.2 emoni is entitled to revise its fees at all times. emoni shall notify the Merchant of revisions at least 30 days before they come into effect. If a change in a fee is detrimental to you, you may terminate the Agreement by notice in writing to iLedfends within 30 days after the notification. If you have not terminated the Agreement within such period, you will be deemed to have accepted the revision. emoni is entitled to revise its fees with retroactive effect for a period of 12 months. emoni may only invoke this right to revise the fees if the turnover, as a total or at a per Payment Method level, deviates at least 10% during any period of 3 months from what was expected (as indicated by you in the Merchant Agreement, Application Form, or any other document or system accepted by emoni).

9.2 Your payment obligations

9.2.1 Under the Agreement, you are obliged to pay emoni, among other things, the following amounts:

9.2.1.1 The fees relating to Services.

9.2.1.2 All amounts which you owe to emoni due to fines or charges that have been imposed on emoni and/or amounts that have been claimed by emoni by way of compensation because you have acted in breach of the Agreement.

9.2.1.3 The reasonable costs which emoni incurs in managing the Merchant Account.

9.2.1.4 Any other costs as mentioned in the Agreement and/or Fee Schedule.

9.3 Collateral

9.3.1 Upon request of emoni, you are obliged to provide additional collateral for your obligations under the Agreement. The additional collateral may also relate to any future amounts you may owe (for instance fines, adjustments and liability for damage). emoni shall decide about the form of the collateral, such as a parent guarantee. emoni shall also decide the amount of the collateral for example based on your risk profile.

9.3.2 If, when concluding the formation of the Agreement, emoni stipulates collateral, emoni shall only be obliged to provide Services after it has actually received this collateral.

9.3.3 emoni can also demand and hold a Reserve. The Reserve can be a fixed amount, but can also vary depending on the total of Transactions processed for you. Any credit, or other amount payable by emoni to you under the Agreement, may be used by emoni to establish and maintain a Reserve.

9.3.4 The Balance shall be blocked for the amount of the Reserve. The balance less the Reserve is the available balance for the Merchant. If at any time the Balance drops below the amount of the Reserve, you are obliged to top back up the Bank Account immediately to at least the amount of the Reserve.

9.4 Safeguarding of customer funds

9.4.1 To the extent required under applicable law and regulation, funds received from or for you in exchange for electronic money issued by iLedgends B.V., or otherwise in connection with regulated payment services, shall be safeguarded.

9.4.2 Safeguarded funds shall be held separately from the own funds of iLedgends B.V in segregated accounts in the name of Stichting Derdengelden iLedgends with ClearBank Europe N.V., a Dutch credit institution.

9.4.3 You acknowledge and agree that safeguarded funds are held solely for the purpose of complying with applicable safeguarding requirements and that such funds shall not form part of the general assets of iLedgends B.V.

9.4.4 Nothing in the Agreement shall be interpreted as creating a deposit relationship with iLedgends B.V. or any other emoni Group company. Funds held in connection with the Services are safeguarded in accordance with applicable law, but are not protected as bank deposits.

For the avoidance of doubt, nothing in these Terms permits the pooling, commingling, or cross-entity use of safeguarded client funds or crypto-assets between emoni Group entities.

10. Suspension by emoni

10.1 Suspension

10.1.1 emoni may suspend payments, the processing of Transactions, issuance of electronic money, its Services and/or its obligations, wholly or in part, with immediate effect if:

10.1.1.1 Your assets held by emoni are seized in pre-judgment attachment or attachment in execution;

10.1.1.2 You or a Customer have been involved or emoni suspects your involvement in fraudulent acts or in any other way of acting in contravention of law and regulations and/or the regulations;

10.1.1.3 emoni knows that you have failed or suspects that you may have failed to comply with one or more of your obligations under the agreement, for example in case of Recalls;

10.1.1.4 emoni believes this is necessary in order to ensure the security and integrity of emoni systems or emoni' reputation;

10.1.1.5 emoni believes there are other good faith reasons to do so, such as unauthorised use of means of authentication or instructions of a regulator and/or other authorities to suspension;

10.1.1.6 The level of Recalls is excessive, as defined by emoni internal policy, which is communicated to you, and can be changed from time to time.;

10.1.1.7 Any transaction is or may be subject to fraudulent or other unlawful activity; and/or

10.1.1.8 emoni shall notify you as soon as possible after any of these instances occur, stating the reasons (if possible). emoni may make the ending of the suspension subject to conditions. emoni shall not be obliged to pay any compensation for any suspension by emoni under the agreement.

11. The Agreement

11.1 Duration and termination

11.1.1 Unless otherwise stipulated in the Merchant Agreement, the agreement is concluded for an indefinite period of time. You or emoni can terminate the agreement without cause by giving 30 days prior written notice to the other Party.

11.2 Termination in special cases

11.2.1 Either you or emoni may at all times terminate the agreement by written notice if:

11.2.1.1 The other party fails to perform one or more material obligations under the agreement despite a notice of default with a 30 days cure-period. If the default is not curable within that period, it is considered a non-curable default.

11.2.1.2 The other party is declared bankrupt, is granted moratorium or if comparable insolvency proceedings are applicable to the other party;

11.2.1.3 It has reasonable grounds to assume that the other party may be declared bankrupt, may be granted moratorium or insolvency proceedings may become applicable to the other party.

11.2.2 Additionally, emoni may at all times terminate the agreement by written notice if:

11.2.2.1 You do not comply with instructions received from emoni in connection to the performance of your obligations under the agreement, including instructions about (sensitive) payment data;

11.2.2.2 Circumstances occur that in emoni (and/or partners of emoni) opinion may increase the risk of recalls or may present a financial, reputational, or security risk for emoni for any other reasons;

11.2.2.3 You have during a period of 30 days a negative Balance in your merchant account or the amount of the Reserve is not met.

11.2.3 This is demanded of emoni (and/or partner of emoni) under the Regulations, by a (supervisory) authority, such as the Dutch Central Bank;

11.2.4 If you do not use the services for a period of at least 3 months; and/or

11.2.5 There is another material reason of such nature that emoni can no longer reasonably be required to continue the Agreement.

11.3 Termination of the agreement

11.3.1 In order to terminate the agreement, you must send a notification via regular mail to emoni' address or via e-mail to the e-mail address dedicated for this purpose as designated by emoni. emoni will confirm receipt of such notification within 3 business days upon receipt thereof.

11.3.2 If you would like to terminate the agreement, the agreement ends 30 days after emoni confirms receipt of your notification of termination.

11.3.3 If emoni would like to terminate the agreement, the agreement ends 30 days after written notice is given to the address as indicated by you in the Application Form.

11.4 Effects of the termination of the Agreement

11.4.1 As soon as the agreement ends, you shall cease doing everything you are allowed to do under the agreement.

11.4.2 After termination of the agreement, the mutual obligations that exist at the time of termination continue in force. Specifically, recalls, fees, claims, fines and collateral. Confidentiality in storing data shall continue in effect.

11.4.3 emoni shall not be obliged to pay any compensation for any damage that arises when emoni has validly terminated the agreement.

11.4.4 Access to Transaction Data after the end of the agreement shall be provided by emoni at your request.

11.4.5 The following applies to the reserve and any other collateral granted by you:

11.4.5.1 After termination of the agreement, the Reserve and other collateral shall remain at the disposal of emoni until all of your liabilities have been discharged under the agreement and there is no risk that, for instance because of Recalls, you will have any payment obligations towards emoni;

11.4.5.2 Release of the Reserve and other collateral shall in no event be earlier than 60 days after the ending of the agreement;

11.4.5.3 emoni may at its sole discretion release a part of the Reserve and/or other collateral, for example in circumstances where your existing and future liabilities under the Agreement have significantly decreased or if you have provided sufficient replacing collateral;

11.4.5.4 If, at any time, the Reserve or other collateral appears to be insufficient to fulfil your payment obligations, you are obliged to pay the difference, plus any associated costs made by emoni, immediately to emoni;

11.4.5.5 As soon as there is no risk that you will have any payment obligation towards emoni, for example because of a Recall, and all of your liabilities have been discharged under the Agreement, emoni will release the amount of the Reserve and other collateral available as soon as possible;

11.4.5.6 After termination of the agreement, emoni shall be entitled to communicate the termination and the reasons thereto to any authority, supervisory authorities or any other law enforcement or investigating body;

11.4.6 emoni does not owe you compensation for the early termination if you exercise this right.

12. Assignments of rights and obligations

12.1 You are not allowed to assign your rights and obligations under the Agreement, wholly or in part, to third parties or to pledge them, without the prior written approval of emoni.

12.2 emoni may assign its rights and obligations under the agreement to third parties. emoni must inform you in writing about such assignment a reasonable time prior to the effectuation of such assignment, stating the date on which it shall take place. Such prior notification is not required if emoni assigns its rights and obligations under the agreement to an affiliate. If an assignment takes place, you shall reasonably cooperate to effectuate the assignment. If you do not agree with the assignment, you shall be entitled to terminate the agreement.

13. Revisions and additions

13.1 emoni may at all times revise and/or supplement the Agreement.

13.2 Any revisions and additions to the agreement shall be binding on you within 30 days after written notification to you.

13.3 If you do not accept the revisions and/or additions, you will inform emoni accordingly in writing within 30 days after emoni' notification in order to terminate the agreement. If you have not terminated the agreement within such a period, you will be deemed to have accepted the revisions and/or additions.

14. Continued effect of provisions and validity

14.1 If any of the provisions of the agreement are null and void or declared invalid, the other provisions of the agreement shall remain fully applicable. In this event, emoni shall make a proposal to substitute provision(s) that is/are valid and that coincide(s) with the purport of the substituted provision(s) as closely as possible.

14.2 The termination, expiration, or cancellation of the Agreement for any reason shall not affect any rights, obligations, or liabilities of the Parties which:

• have accrued prior to such termination; or
• are expressly or by their nature intended to survive termination.

14.3 Without limitation, the following provisions shall survive termination of the Agreement:

• Fees, costs, and payment obligations (including outstanding balances);
• Liability, indemnity, and limitation of liability provisions;
• Confidentiality and data protection obligations;
• Compliance with applicable laws and regulations, including anti-money laundering obligations under applicable legislation;
• Record-keeping and audit rights;
• Complaints handling and dispute resolution provisions;
• Governing law and jurisdiction;
• Any provisions relating to safeguarding, reconciliation, and return of funds;
• Any provisions relating to Recalls and recovery of funds.

14.4 Following termination, emoni shall be entitled to:

• Retain and process relevant data as required to comply with legal and regulatory obligations, including obligations under anti-money laundering laws and reporting requirements to competent authorities;
• Retain records for statutory retention periods;
• Take any actions necessary to safeguard funds, complete pending transactions, or return funds to the Customer or rightful beneficiaries.

14.5 Termination of the Agreement shall not release you from any obligations or liabilities incurred prior to termination, including obligations arising from unauthorized transactions, Recalls, or misuse of the Services.

15. Liability

15.1 Liability, fines, levies and damage

15.1.1 You shall be liable to emoni for any damage suffered by emoni as a result of your acts or omissions including without limitation all losses arising from or in (i) connection with any transaction or any other dealing between you and a Customer; (ii) any (regulatory) authority imposing a fee, fine, penalty or charge on emoni which is attributable to you; (iii) any loss of payment data or Transaction Data by you; (iv) Customer Data use; (v); Any act or omission of any of your agents, suppliers or any other third party including, without limitation, any a payment service provider engaged by you; and (vi) any breach of applicable laws by you.

15.1.2 You shall be similarly liable for the acts or omissions of your employees, auxiliary staff and other third parties engaged by you. You agree to indemnify emoni against any third-party claims that are in any way related to the Agreement, including claims of third parties which relate to infringement of intellectual property rights. You are liable for all damage suffered by emoni for such claims, including lawyer's fees and all other costs and expenses which are arise as a result of legal proceedings.

15.1.3 The liability of emoni shall in any event be limited to (i) twenty thousand euros (€20,000) or, if less, (ii) the amount of the fees received by emoni under the agreement in the immediately preceding twelve months.

15.1.4 emoni shall only be liable for failures on its part that are intentional or due to gross negligence. Any other liability is excluded. emoni shall never be liable for any increased costs, loss of profit, loss of business, loss of goodwill, loss of data, consequential loss, loss of revenue and anticipated savings. emoni shall also never be liable to you for the acts of third parties.

15.1.5 The liability of emoni to you shall lapse if you have not held emoni liable in writing within two months after you have become aware of the damage, unless an authorised person has admitted liability on behalf of emoni in writing prior to end of this two months' period.

15.1.6 A Partner may impose fines and/or levies on emoni or claim damages, among other things, if you act in breach of the provisions of the agreement. These fines, levies, and damages shall be immediately due and payable by you to emoni. The same applies if a regulator and/or authorities seeks to recover fines and levies from emoni or claims damages if you act in breach of the provisions of the agreement.

16. Force Majeure

16.1 emoni shall not be liable for any failure to perform its obligations in the event of force majeure. Events of force majeure include failures with third parties or Partners where emoni relies on to fulfil their obligations towards emoni. If new and/or amended law, regulations and/or regulations prevent the execution of Transactions, this shall be considered an event of force majeure affecting emoni.

16.2 In the event of force majeure, emoni shall take every measure it may reasonably be expected to take to limit the adverse effects thereof for you.

17. Complaints

17.1 Customer Complaints

17.1 emoni is not a party to the agreement concluded between you and your Customer. You shall settle any complaints about delivered or undelivered goods and/or services by you to your customer directly with the Customer, without the intervention of emoni.

17.2 Disputes with customers

17.2.1 If a Customer submits a claim against emoni, you agree to indemnify emoni in respect of all related costs and damages. This indemnification does not apply to the extent that the costs and damage are the result of gross negligence by emoni with respect to meeting its obligations under the Agreement.

17.2.2 emoni may at its own discretion decide whether or not to put forward defences against a claim submitted by a Customer against emoni. emoni may also at its own discretion decide to settle with the Customer. These decisions shall be binding on you and you shall indemnify emoni.

17.3 Your complaints

17.3.1 Your complaints will be handled by emoni provided that emoni' complaints procedure is followed. The complaints procedure can be found on the website of emoni.

18. Questions about safeguarding

18.1 If you have any questions regarding the safeguarding of customer funds, you may contact emoni through the contact details published on its website.

19. Inspections

19.1 By emoni

19.1.1 emoni may subject you to an unannounced audit. emoni may instruct a third party to conduct the audit. You shall cooperate in the conduct of the audit, which includes you granting access to the relevant premises, information and Merchant Systems.

19.1.2 If it appears that you have materially failed to fulfil any of your obligations under the agreement, emoni may charge you the reasonable costs of the audit.

19.1.3 Upon request of emoni, you shall cooperate with any investigation to establish whether a transaction was or may have been completed using illegal sources.

19.2 By third parties

19.2.1 You must cooperate with any investigations conducted by or on behalf of supervisory authorities and/or Partners of emoni. If you are approached for such investigation, you shall immediately notify emoni thereof unless such is prohibited by law. You shall follow all reasonable instructions given to you by emoni in these circumstances.

20. Intellectual property, confidentiality, and privacy

20.1 Intellectual property; right of use

20.1.1 All intellectual property rights to the services, the emoni systems and other programmes, websites, databases, materials, such as documentation, reports are reserved to emoni, its Partners or its licensors.

20.2 Confidentiality; storing data

20.2.1 The Parties undertake to keep confidential all information they obtain about the other Party or a Customer that is of a confidential nature, except where necessary for the performance of the agreement or within the scope of the purposes authorised in the Agreement. Information of a confidential nature includes, for example, information in relation to the organisation, business operations and financial affairs of your enterprise or those of emoni, or information in relation to the Customer. You have to observe all statutory and other applicable rules in this regard.

20.2.2 You shall immediately, and in any case within 12 hours, notify emoni of any (potential) accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, access to, or theft of personal data, payment data, Transaction Data or other payment security breaches. You shall provide all information requested by emoni and follow all directions and instructions given by emoni or other authorised parties, including the supervisory authorities, and Partners of emoni to limit further damage and risks, including the prevention of new incidents.

20.2.3 You shall take all steps to ensure compliance with the confidentiality obligations under this article by your employees and/or other people working for you as well. You are liable if these people act in breach of these confidentiality obligations.

20.2.4 You shall not retain payment data any longer than is strictly necessary. You shall destroy the data as soon as legal obligations no longer require retention of these data.

20.2.5 This article shall not apply in a case where a Party has a statutory or legal obligation to provide information, if a competent authority has requested to provide information or if the information is already public.

20.3 Customer data use

IntraGroup Data Sharing. Where necessary for the provision of the Services, compliance with legal and regulatory obligations (including AML/CTF and transaction monitoring), and group-level risk management and governance, personal data, client information, due-diligence data and transaction-related information may be shared within the emoni Group of companies, including iLedgends B.V., Ledgends Inc. (Canada) and iLedgends s.r.o. (Czech Republic). Such intra-group data sharing is governed by a group-wide intra-group data-sharing and governance arrangement, under which each emoni Group entity remains independently responsible for compliance within its own legal and regulatory perimeter.

20.3.1 Each emoni Group company acts as a data controller as defined in the GDPR, processing customer data. Each of the Parties warrant that it shall process the personal data processed within the context of the performance of the Agreement in compliance with applicable data protection law. This means, inter alia, that you shall implement adequate security measures to prevent loss of or unauthorised access to Customer data or any other form of unlawful processing, and inform Customers, your employees and other persons working for you, on the processing of their customer data by emoni in the context of the performance of the Agreement. You shall be solely responsible for obtaining the consent of the Customers, employees and other persons working for you, and relevant ultimate beneficiary owners, if required, for the collection or use of Customer data, including payment data and Transaction Data, in accordance with applicable data protection law.

20.3.2 Each Party will provide the other Party with such assistance and co-operation as that Party reasonably requests to enable the requesting Party to comply with any obligations imposed on it by applicable data protection law in relation to the processing of the customer data. A Party will be entitled to refuse or limit its assistance where the requesting Party is in the position to fulfil the obligations without that Party's assistance.

20.3.3 You, as the Merchant, are the party that has direct contact with your customer, employee or other persons working for you. Therefore, you shall, also on behalf of emoni, provide your Customer and, where relevant and if any, employee, other persons working for you, and your business' ultimate beneficiary owners whose data are provided to emoni for entering into or the performance of the agreement, with all necessary information on the processing of their data in accordance with applicable data protection law. You will inform the Customer, employee or other persons working for you, or ultimate beneficiary owners of your business inter alia that (i) emoni is a controller in relation to the processing of their data, (ii) which data will be processed, (iii) what the purposes are for the data processing activities, and (iv) any other information necessary under applicable data protection law, including the information referred to in articles 13 and 14 of the GDPR. You will follow our reasonable instructions in respect of the processing of customer data by emoni and will bring emoni' privacy notice, as published on emoni' website, to the attention of the customers, employees or other persons working for you and ultimate beneficiary owners of your business.

20.3.4 You shall inform emoni without undue delay if a Customer, or your employee or other persons working for you, an ultimate beneficiary owner or other data subject exercises, or seeks to exercise, its rights of access, rectification, erasure, objection, the right to restriction of processing, the data portability right, or the right to object an automated individual decision-making, as well as other rights recognised by applicable data protection law, or files a complaint or claim that is related to the processing of their personal data by emoni. You will also follow emoni' reasonable instructions in the context of handling such requests, complaints, or claims.

20.3.5 Unless expressly stated otherwise in the Agreement, in the event of any conflict between the other provisions of the Agreement and the section 20.3 of these terms, the section 20.3 prevails.

20.3.6 All notices and other communications between the parties in respect of this article must be provided by email to: (a) in the case of emoni, the e-mail address dedicated by emoni (support@emoni.io) for this purpose and (b) in the case of you, via your e-mail address known to emoni, except formal notices in legal proceedings or termination which must be provided in accordance with the notice provisions in the Terms and Conditions.

20.4 Data use

20.4.1 Any information that you provide to emoni may be used by emoni (or any of its affiliates or emoni Group entities) for one or more of the following purposes:

20.4.1.1 To assess applications for services that you have requested;

20.4.1.2 To extend the scope of services you may request from emoni and make available to you from time to time;

20.4.1.3 To manage accounts and to make decisions on questions arising from any application, agreement or correspondence which you may have with emoni;

20.4.1.4 To conduct, monitor and analyse the business relationship with you;

20.4.1.5 Any assessment by emoni or any of its affiliates of your risk profile, or the financial or operational condition of your business. In respect of customer data, the privacy notice provides for which purposes emoni may use such data.

20.4.2 Any information that you provide to emoni (other than customer data) may be disclosed to the following:

20.4.2.1 emoni or its respective employees or affiliates (or any employees of its affiliates);

20.4.2.2 Any agents or subcontractors of emoni;

20.4.2.3 Anyone to whom emoni proposes to transfer any of their respective rights and/or responsibilities under any agreement they may have with you;

20.4.2.4 Anyone in order to comply with any applicable statutory or regulatory requirements applicable to emoni Group or their affiliates;

20.4.2.5 Anyone to whom you have consented to disclose such information to. In respect of customer data, the privacy notice provides to which parties the data may be disclosed.

20.4.3 emoni (and its respective employees and affiliates) may use the data provided by you to search the records of credit reference agencies and fraud prevention agencies on you and people financially linked to your enterprise. emoni is doing so with a view to making credit and/or business decisions about you and/or managing the Merchant Account and with a view to fraud prevention, debtor tracing, debt collection and credit claims.

20.4.4 emoni may also disclose any information provided by you (other than customer data) to its respective agents, to its affiliates, the police, partners, supervisory authorities, or any other law enforcement or investigating body for use in the prevention or detection of fraud or other criminal activity, or to any credit reference agency which emoni also use(s) as a source of information. In respect of customer data, the privacy notice provides to which parties the data may be disclosed.

21. Representation

21.1 Representation

21.1.1 If emoni receives a notice from you (irrespective the form of such notice), emoni may verify whether the sender of such notice is authorised to represent you. emoni can verify this among other things via information filed with the relevant trade register, such as the Dutch Chamber of Commerce (Kamer van Koophandel), power of attorney or any similar organisation. Or via a list of authorised individuals that has been provided to emoni by you. emoni may assume that a power of attorney circulated to emoni remains in full force and effect, until emoni receives a written notice that such power of attorney has been withdrawn. emoni may also assume that all individuals listed as authorised individuals remain authorised to represent you, until you inform emoni otherwise in writing. A written notice in respect of a withdrawn power of attorney or an amended list of authorised individuals will have effect once emoni confirms receipt of such notice and change in writing.

21.1.2 If emoni receives a notice from an individual of which emoni may assume that he is authorised to represent you, emoni may act on such notice.

22. Amendments to the Terms and Conditions

22.1 Right to Amend

emoni reserves the right to amend, modify, or update these Terms and Conditions, as well as any related policies or documents forming part of the Agreement, from time to time, including where such amendments are required to:

• comply with applicable laws, regulations, or regulatory guidance;
• reflect changes to the Services, systems, or operational processes;
• address security, risk management, or fraud prevention requirements; or
• improve clarity or customer experience.

22.2 Notification of Changes

emoni shall notify you of any material amendments in advance through appropriate communication channels, including but not limited to:

• email;
• notification via the emoni platform; or
• publication on the emoni website.

22.3 Notice Period

Unless a shorter period is required by law or regulatory obligation, amendments shall enter into force one month after notification to the Customer.

23. Final provisions

23.1 General

23.1.1 The Agreement constitutes the entire agreement between you and emoni for the Services. The Agreement replaces all previous agreements and arrangements between you and emoni.

23.1.2 The Agreement may be implemented by the parties (or one of them) by means of an electronic signature (both digital and encrypted), which shall have the same validity as a written signature.

23.1.3 An electronic signature constitutes any form of electronic authentication, symbol, or process made available or otherwise approved by emoni for the purpose of signing the Agreement.

23.2 Applicable law; competent court

23.2.1 The Agreement is subject to Dutch law. In the first instance, only the court of Amsterdam has exclusive jurisdiction to hear disputes between the parties arising from the Agreement. However, iLegends can also initiate legal proceedings against you before the court where you are established or where your office is registered.

Schedule 2 — iLedgends s.r.o. Terms & Conditions

This Agreement constitutes a legally binding contract between you ("User", "You") and iLedgends s.r.o. "emoni", a Virtual Asset Service Provider (VASP) registered in the Trade Licensing Register, managed by the Czech Ministry of Industry and Trade, under registration number 19560630 for providing services related to virtual assets in the Czech Republic. emoni is supervised by the Financial Analytical Office (FAÚ), the financial intelligence unit responsible for overseeing compliance with obligations under the Czech AML Act.

iLedgends s.r.o (a company established under the laws of the Czech Republic, registered under code 19560630, with its registered office located at Pobřežní 620/3, Czech Republic) ("emoni", "Exchange," "we," or "our"). By using emoni and its services, you acknowledge that you have read, understood, and agreed to the terms outlined in this Agreement, as well as the accompanying Privacy Policy and Cookie Policy.

Important: Each emoni Group operating entity provides services within its own regulatory and contractual perimeter. If you use services of iLedgends B.V. (Netherlands) or Ledgends inc (Canada), the applicable Service Schedule or entity-specific provisions shall apply to the relevant services.

Scope of the Agreement

This Agreement applies to the use of:

(A) The emoni website (www.iledgends.io) and any associated mobile applications or hosted sites (collectively, the "emoni Site").

(B) Any services provided by emoni, including but not limited to cryptocurrency transactions and related features ("emoni Services").

By registering an account or using any of the emoni Services, you agree to be bound by this Agreement, governed by the laws of the Czech Republic. All communications regarding the use of our services will be conducted in English.

If you have any questions or do not fully agree with any part of this Agreement, please contact us at support@emoni.io before proceeding.

Acceptance of Terms

By registering on emoni or using its services, you confirm your acceptance of these terms and conditions. Please read them carefully before proceeding.

Description of Services

emoni provides users with a platform to buy, sell and exchange cryptocurrencies via the internet and designated service points. Transactions initiated from your crypto wallet are irreversible. If you send cryptocurrency to an incorrect address or transfer an incorrect amount, those funds cannot be recovered.

Market Risks

The cryptocurrency market is highly volatile and subject to rapid price fluctuations.

The value of cryptocurrencies may significantly decrease or even become worthless over time.

Cryptocurrencies are not backed by any entity, and neither emoni nor any third party is obligated to repurchase them.

Before trading, ensure you fully understand these risks and only invest funds that you can afford to lose. For more information, visit reliable sources.

Legal Restrictions

Your ability to access emoni services may be subject to the legal framework of your jurisdiction. emoni is not responsible if you are unable to access or use certain features due to local regulations.

Service Access and Limitations

Upon agreeing to these terms, emoni grants you a personal, non-exclusive, non-transferable, and limited right to access and use our platform and services. However, emoni is not liable for:

• Financial losses due to blockchain technical issues, natural disasters, or service disruptions caused by third-party providers.
• Delays in trade execution due to AML/KYC verification, which may take up to 120 hours after transaction confirmation by the payment provider.

Fees and Transaction Execution

Orders will be executed at the final exchange rate at the time of trade execution.

Until execution, all orders remain pending and are not binding on emoni.

Any payments made to you (fiat or cryptocurrency) will be subject to applicable fees, as per the fee schedule signed between You and the emoni. emoni fees may change periodically at emoni's discretion and will be disclosed before placing an order. If a transaction cannot be completed, and the exchange cannot be funded, refunds will be issued minus a fee.

By using emoni, you agree to these terms. If you have any concerns, please contact support@emoni.io.

If a transaction is processed using a credit or debit card, no withdrawal fee will be applied. Please note that cryptocurrencies are a high-risk investment. The value of a cryptocurrency may fluctuate between the time of purchase and the time it is received in your wallet, resulting in a higher or lower value than at the time of payment.

We are not obligated to:

• Repurchase cryptocurrency from you.
• Sell additional cryptocurrency to you.

If you enter an incorrect wallet address, we will not be able to recover your funds. If you do not agree to these terms, please refrain from using our website (www.iledgends.io) or its services.

Account Registration

By opening an account on this site, you confirm that:

• You agree to the Terms of Use.
• You are at least 18 years old.
• You have the legal capacity to enter into this Agreement and perform cryptocurrency transactions.

Acknowledgment of Compliance

By initiating a transaction, you acknowledge that:

• The cryptocurrency being sold does not originate from illegal or illicit activities.
• The sale of cryptocurrency is not intended for money laundering purposes.
• You are the authorized account holder or have permission to use the account for bank transfers or credit card purchases.

You declare under oath that the funds used for purchasing cryptocurrency do not originate from fraudulent activities. If proven otherwise, you agree to bear any resulting losses and legal consequences.

Cookies & Tracking Policy

We use various types of cookies and web trackers to enhance website performance and provide analytical insights. These trackers collect statistical data regarding your use of the website.

You can manage or block cookies through your browser settings. However, disabling cookies may negatively impact your browsing experience. Please refer to your browser's help menu for guidance on managing cookie preferences.

Privacy Policy

emoni acts as a data controller within the meaning of applicable data protection law in respect of the personal data it processes in connection with the provision of its services.

The User acknowledges that, where necessary, personal data and compliance-related information may be shared within the emoni Group of companies for the purposes of client onboarding, AML/CTF compliance, fraud prevention, transaction monitoring, and compliance with applicable legal and regulatory obligations.

Such intra-group data sharing is governed by a group-wide intra-group data-sharing and governance arrangement and is carried out in accordance with applicable data protection law and the Czech AML Act. Each emoni Group entity remains independently responsible for compliance with its own data protection and regulatory obligations within its respective legal and regulatory perimeter.

For further details on how personal data is processed, including the rights of data subjects, please refer to our Privacy Policy: https://www.emoni.io/privacy-policy/

Services Offered

emoni, through its online platform (www.iledgends.io), enables users to buy, sell and exchange cryptocurrencies. The exchange rate is determined by emoni at the moment the user's transferred funds are received in emoni's bank account.

Due to market volatility, particularly when the price fluctuates by more than 1.00% between order initiation and settlement, emoni reserves the right to complete the transaction at the best available price once the funds have been received in emoni's bank accounts. Transactions are processed during emoni's working hours (Monday to Friday, excluding official public holidays).

In cases of high market volatility, customers may experience a recalculation of the purchase price when emoni executes the trade and delivers the cryptocurrency.

Important Conditions:

• Initiating a trade (purchase) without transferring funds may result in account cancellation on emoni's platform.
• Cash deposits are not accepted at the bank. Clients must transfer funds from a bank account registered in their name to emoni's designated bank account for the respective currency.
• Transaction approval times vary from a few minutes to up to five business days, depending on factors such as fund availability, transaction value, account history, and market conditions.
• Blockchain confirmations are required for cryptocurrency transactions. The confirmation time depends on network congestion and liquidity.
• Cryptocurrency transactions are irreversible, and purchased crypto assets cannot be returned without explicit confirmation from emoni.

Registration

Each user is allowed to open only one account on the emoni trading platform. Any attempt to open multiple accounts may result in the suspension or closure of additional accounts at emoni's discretion.

To access emoni services, users must first complete the registration process, which includes providing a valid email address and password. Upon successful registration, emoni will create an account for the user.

To complete the account verification process, users must submit:

For individuals: A valid proof of identification (ID or passport) and proof of address (e.g., a utility bill or bank statement issued within the last three months, displaying the user's name).

For legal entities: A valid commercial registry extract, along with additional documents specified in the Application Form. Individuals granted access to the account on behalf of the legal entity must also provide proof of identification (ID or passport) and proof of address (a utility bill or bank statement not older than three months).

Document verification may take up to five business days.

emoni reserves the right to decline any account application at its sole discretion. Additionally, users may be required to submit additional information periodically to continue using emoni's services.

If a user wishes to convert local currency into cryptocurrency or vice versa or exchange crypto currencies, emoni (directly or through third parties) may request further identity validation. This may include providing:

• Full name
• Date of birth
• Email address
• Physical address
• Tax identification number
• National identification number
• Bank account details (such as financial institution name, account type, and account number)

These measures ensure compliance with regulatory requirements and allow users to fully access emoni's services.

emoni may request additional information or take necessary measures to verify your identity in compliance with legal requirements. When providing sensitive information, you must ensure its accuracy and authenticity. Additionally, you agree to notify emoni of any changes to the requested personal details.

If you use a credit or debit card to purchase cryptocurrencies, emoni may periodically require verification to confirm that you are the authorized cardholder or account owner.

For regulatory and compliance purposes, emoni reserves the right to retain your registration information even after your account has been closed.

Password Security and Maintaining Updated Contact Information

You are responsible for safeguarding the security and proper control of your ID, passwords, personal identification numbers (PINs), and any other credentials used to access emoni services.

Any loss or compromise of this information may result in unauthorized access to your emoni account by third parties. To ensure you receive important notifications and alerts, you must keep your email address up to date in your account settings.

emoni is not liable for any loss or damage caused by failure to secure your account information or for neglecting to act on notifications we send. If you suspect that your account has been compromised, you should immediately contact emoni Support.

emoni is not responsible for any damage or disruption caused by computer viruses, spyware, malware, phishing, spoofing, or other cyberattacks. We strongly recommend using reliable antivirus and malware protection software. If you ever doubt the authenticity of a communication claiming to be from emoni, always log in directly through the official website rather than clicking links in emails.

Suspension and Closure of Account

At our sole discretion, and without liability to you or any third party, emoni reserves the right to refuse account opening, suspend, or close your account, or limit access to one or more services. These actions may be taken due to account inactivity, failure to respond to customer support requests, initiating transactions without completing them within the specified time, or violations of this Agreement. Additionally, actions may be taken if required by a valid subpoena or court order, or if emoni reasonably suspects your account is being used for illegal activities (including, but not limited to, opening multiple accounts or abusing promotions).

If your account is suspended or closed while you have unsettled trades, you will still be able to recover your funds unless prohibited by law or court order. emoni, at its discretion, will allow you to:

(i) withdraw these funds to a previously known bank account, or
(ii) send funds to an external cryptocurrency wallet address.

We reserve the right to request additional identifying information before processing such withdrawals and may delay or refuse transactions if emoni suspects fraudulent or illegal activity. If you're unable to access your account, please contact our support team for assistance.

You may terminate this Agreement at any time by ceasing to use emoni's services. Upon termination and suspension of your account, you will remain responsible for all transactions conducted while the account was active.

Right to Suspend or Delay Transactions and Settlements

emoni reserves the right to refuse to process or cancel any transaction or cryptocurrency exchange involving your local currency at emoni, or any associated services, as required by law, or in response to a subpoena, court order, or other binding legal requirements. emoni cannot reverse a settlement of cryptocurrency once it has been confirmed by the relevant cryptocurrency network.

emoni also reserves the right to refuse, process, or cancel any cryptocurrency purchase, sale, or transfer at its sole discretion. If emoni suspects that a transaction involves, or carries a high risk of involving, money laundering, terrorist financing, fraud, or any other financial crime, or if it is subject to a subpoena, court order, or other government directive, emoni may suspend or cancel the transaction. This includes transactions that may be related to restricted activities.

We reserve the right to modify, suspend, or discontinue any aspect of the Service at any time, including changes to operating hours or the availability of certain features, without prior notice and without any liability. We may refuse to process any transaction or settlement without notice and have the right to limit or suspend your access to one or more services at our sole discretion. Suspension of your use of services will not affect your rights and obligations under this Agreement.

In our sole discretion, we may delay transactions or agreements if we suspect the transaction is suspicious, may involve fraud or irregularities, violate laws, or breaches the terms of this Agreement. If a technical issue causes system errors or disruptions, emoni may temporarily suspend access to your account until the issue is resolved.

At the customer's request, emoni may hold their cryptocurrency indefinitely until the client requests its return, either verbally or in writing. Payment will be made to the client's designated bank account. emoni is not responsible for a lack of communication with the client and does not assume responsibility for any customer intent in these circumstances.

In cases of high market volatility, unforeseen economic situations, or natural disasters, transactions and payments may experience delays. emoni is not liable for such delays, as it has no control over these events. emoni reserves the right to authorize transactions and settle amounts only after the product is delivered.

Withdrawing from a Trade

Once you initiate a transaction to buy or sell cryptocurrency with emoni, you do not have the legal right to withdraw from the process. This is because cryptocurrency prices fluctuate based on financial market conditions, which are beyond emoni's control.

Taxes

It is your sole responsibility to determine whether any taxes apply to cryptocurrency transactions conducted through emoni. You must also ensure that taxes are withheld, collected, reported, and remitted to the appropriate tax authorities as required by law.

Restriction of Usage

You may view, print, and/or download a copy of the materials from the website to one computer for personal, informational, non-commercial use, provided that you retain all copyright and legal notices. Trademarks, service marks, logos, and other similar elements on the site are the property of emoni or its owners. All software, text, images, data, prices, charts, diagrams, video, and audio materials on this site are the exclusive property of emoni.

Copying, reproducing, modifying, republishing, exhibiting, or transmitting any part of this site is strictly prohibited. Additionally, collecting or distributing any materials from this site in any form is not allowed. Using materials from this site on any other website or networked computer environments for any purpose is also prohibited. Unauthorized use that violates copyrights, trademarks, or other laws may result in civil or criminal penalties.

Termination of Collaboration

You may terminate this agreement with emoni and close your account at any time, after resolving any pending transactions. emoni may also cancel your access to the site and close your account at any time, without prior notice, at its sole discretion. We have the right to:

• Cancel or terminate accounts and services
• Restrict access to the site, its content, services, and tools
• Remove or stop content

Take technical and legal actions to close an account if we suspect any issues that could disrupt emoni's operations and integrity, such as:

• Violations of third-party intellectual property rights
• Actions inconsistent with these terms and conditions
• Unauthorized access attempts
• Assisting others in fraudulent activities
• Security breaches or limitations on the use of content
• Use of services for illegal activities such as money laundering, financing illegal operations, or illegal gambling
• Breach of terms, non-payment, or fraudulent transactions

emoni may close accounts or restrict access without notice for any of the above reasons.

Email

Emails sent over the Internet are not secure, and emoni is not liable for any damages arising from their transmission. We recommend sending emails in an encrypted format and encourage the use of encrypted variations, such as PGP format.

Limitation of Liability

To the extent permitted by law, emoni is not responsible for any injury, damage, loss of profits, business, data, opportunities, or other direct or indirect losses, unless the damage results from negligence, intentional misinformation, or fraudulent activities. However, nothing in this agreement limits or excludes liability for fraud, death, physical injury caused by recklessness, breach of legal obligations, or any other liability that cannot be limited or excluded by law.

Dispute Policy

The parties agree to make a good faith effort to negotiate a settlement for any claim or dispute arising from or related to this Agreement. If the parties cannot reach a settlement, the dispute shall fall under the jurisdiction of the courts in the Czech Republic.

Complaints Policy

During registration, you will be required to provide specific identification information. You are responsible for the security of your login credentials and password with emoni. You are solely accountable for any damage resulting from improper or illegal use of your account. You agree to provide accurate and complete information during the registration process, and you agree not to impersonate any other person or entity, nor hide your identity for any reason with emoni. If registering as a commercial entity, you confirm that you have the authority to bind the entity to this Agreement.

emoni takes your information seriously, handling it in accordance with the privacy policy and registration disclosure. We also maintain effective and transparent procedures for promptly addressing complaints from existing and potential retail clients. We keep records of complaints and the steps taken to resolve them, ensuring fair and consistent treatment while striving to provide the highest level of customer service.

Governing Law

You expressly acknowledge and agree that any legal issues arising from the Terms and Conditions, or your use of the website will be governed by the laws of the Czech Republic, regardless of its conflict of laws provisions. You also agree to the exclusive personal jurisdiction of the Czech Republic courts and waive any objections to such jurisdiction or venue.

Cardholder Responsibility

The use of certain services offered on our website may be prohibited in certain countries. It is your responsibility to determine whether the use of the website and services complies with the applicable laws in your jurisdiction. You warrant that using our services is not illegal in your current location, and you agree to adhere to all relevant laws, regulations, and statutes related to our website and the services provided.

Refund Policy

iLedgends s.r.o., with registration number 19560630 ("We," "our", "emoni"), reserves the right, in rare cases, to either cancel your order or offer an alternative price for the services. If we cancel your order and we have already received FIAT Currency from you for that order, we will, subject to applicable law and regulations, refund the funds to you.

Refunds will be issued to the same source from which they originated, after deducting any costs or expenses incurred during the transfer, including but not limited to wire transfer fees, currency exchange fees, and payment processing charges. At emoni's sole discretion, funds may be refunded to a different account belonging to you, provided you supply the required documentation and information to verify ownership of the account.

To comply with anti-money laundering, terrorist financing regulations, and other legal requirements, as well as to prevent prohibited activity, emoni may verify all payments and refund-related information. In such cases, emoni may request additional documentation and information, including, but not limited to, identification documents, a copy of your credit card (front: visible name, expiration date, and the first 6 and last 4 digits of the card number, with the middle 6 digits covered; back: visible signature with CVV covered), bank details, and/or any other proof necessary to process the refund. If you fail to provide the requested documents or if there are concerns about the authenticity of the information provided, emoni reserves the right to suspend the refund process until the requested information is provided.

This refund policy applies similarly to any return of Cryptocurrency already received before the cancellation of your order, with the deduction of the corresponding costs and expenses. Due to Cryptocurrency price volatility, we cannot refund the exact amount of Cryptocurrency received; the refund will be based on its EUR or USD equivalent value at the time of the transaction, minus any applicable costs or expenses.

Notwithstanding the above, emoni reserves the right to cancel your order without any refund or decline any refund request if it suspects fraudulent or illegal activity. Refunds will be processed promptly and in any event within 7 (seven) business days from the cancellation of the order, provided you have complied with the necessary documentation and information requirements.

Contact

If you have any concerns or questions regarding these "Terms and Conditions," including the rights and obligations arising from them, or any issues related to the use of the site, service account, or any other matter, please reach out to us at support@emoni.io.

Schedule 3 — Ledgends Inc. Terms and Conditions

1. Parties, Purpose and Scope

These Terms and Conditions ("Terms") form a legally binding contract between you ("User", "you") and Ledgends Inc. ("emoni", "we", "us", "our"), an Ontario corporation with OCN 1001258825 and its registered office at 30 Wertheim Court, Unit 12, Suite 201, Richmond Hill, Ontario, L4B1B9, Canada.

These Terms govern your access to and use of our website and any associated platforms (the "Platform") and the services we offer as a money services business ("MSB Services"), including (as applicable): (i) foreign exchange dealing ("FX Services"), (ii) remitting or transmitting funds ("Payment Services"), and (iii) dealing in virtual currency and related services ("Crypto-Asset Services").

Important: Each emoni Group operating entity provides services within its own regulatory and contractual perimeter. If you use services of iLedgends B.V. (Netherlands) or iLedgends s.r.o. (Czech Republic), the applicable Service Schedule or entity-specific provisions shall apply to the relevant services.

2. Definitions and Interpretation

Agreement: Your contract with emoni consisting of these Terms, the Fee Schedule, the Commercial Policy (if applicable), and any additional written agreements or order confirmations.

Affiliate: Any entity that controls, is controlled by, or is under common control with another entity.

Banking Partner: A bank, credit institution, payment service provider, custodian, or other regulated financial institution we use to provide all or part of the Services.

Crypto-Assets: Digital representations of value (including virtual currency) that may be transferred and stored electronically using distributed ledger technology or similar technology.

Custody Services: Safekeeping or controlling, on your behalf, of Crypto-Assets and/or the means of access to such Crypto-Assets, where offered by us.

Fees: All fees and charges payable by you as described in the Fee Schedule and/or displayed in the Platform before you place an order or instruction.

Restricted Data: Highly sensitive information (e.g., full AML/transaction monitoring narratives, suspicion reasoning, criminal-offence related material, biometric outputs) that is subject to elevated controls and is not shared routinely.

Services: Collectively, the MSB Services we provide to you as described in these Terms and on the Platform.

Tier 1 / Tier 2 / Tier 3 Data: The three-tier intra-group sharing model described in Section 12 (Privacy and Intra-Group Sharing) and our internal governance framework.

3. Formation of the Agreement

3.1 Application phase. Your submission of an application, registration, or onboarding information is an application to use our Services. We may accept or decline applications in line with applicable law, our risk appetite, and compliance requirements.

3.2 Acceptance. The Agreement becomes effective only when we confirm your onboarding and enable you to use one or more Services (including by enabling relevant features in the Platform).

4. Eligibility, Registration and KYC/AML

To access the Services, you must: (a) have legal capacity; (b) provide complete and accurate information; (c) complete identity verification and KYC/AML screening; (d) comply with applicable sanctions and AML/CTF requirements; and (e) use the Services only for lawful purposes.

We may request additional information at onboarding and periodically thereafter (including source-of-funds/source-of-wealth information) and may retain onboarding records as required by law.

You may hold only one profile unless we approve otherwise. We may refuse to open, suspend, or close a profile where permitted by law and these Terms.

5. Services and Third Parties

We may provide Services directly or through Banking Partners and other service providers. Where we rely on a Banking Partner, the Banking Partner may impose its own requirements (including transaction limits and compliance checks). We are not responsible for decisions taken by Banking Partners within their regulatory perimeter.

6. Instructions, Execution, and Availability

You must submit instructions through the Platform or other official channels we designate. Instructions become binding once confirmed by us. We may delay, refuse, or cancel an instruction where required by law, court order, regulatory request, or where we reasonably suspect fraud, AML/CTF risk, sanctions exposure, or other prohibited activity.

We use reasonable efforts to keep the Platform available but do not guarantee uninterrupted availability and may perform maintenance or upgrades.

7. Payment Services (Remittance / Funds Transfer)

7.1 Permitted use. Payment Services may be used only for lawful transactions and for the purposes agreed in the Agreement. You must not use Payment Services on behalf of unauthorised third parties.

7.2 Transaction data. You must retain evidence supporting payment instructions and underlying transactions and provide such evidence to us upon request.

8. Recalls, Returns, and Reversals

8.1 Outgoing recalls. Where you request a recall/return of a payment, you must provide sufficient evidence and documentation. We will use reasonable efforts to assist, but we do not guarantee success and may charge fees passed through by intermediaries.

8.2 Incoming recall/return requests. If we receive a recall/return request or similar instruction from a sending institution or payment scheme concerning funds credited to you, we may temporarily restrict or earmark relevant funds pending investigation and may return funds where required by law or scheme rules.

9. FX Services

FX rates and any spreads/fees will be disclosed before you confirm an exchange. Once executed, FX transactions may be final and irreversible, subject to applicable law and error correction procedures.

10. Crypto-Asset Services (Exchange, Orders, Custody)

10.1 Risk disclosure. Crypto-Assets are volatile and high risk. Blockchain transactions are generally irreversible. You are responsible for your tax and reporting obligations. We do not provide investment, legal, or tax advice.

10.2 Exchange and order handling. Orders are executed at the rate available at execution time. We may cancel an instruction where market conditions or risk controls require, or where the transaction cannot be funded. Confirmation times can vary depending on funding, network conditions, and compliance checks.

10.3 Custody. Where we provide Custody Services, we may use hot wallets and apply additional verification for withdrawals. Fiat withdrawals are remitted only to accounts in your name. We may require additional information and may delay withdrawals where required by law or AML/CTF controls.

11. Fees, Charges and Changes

Fees are set out in the Fee Schedule and/or disclosed in the Platform before you place an order. We may amend Fees and the Fee Schedule by providing advance notice through the Platform or email. If a change is materially detrimental, you may terminate the Agreement in accordance with Section 16.

12. Privacy and Intra-Group Sharing

12.1 Privacy documents. Our Privacy Policy describes how we collect, use and disclose personal information. These Terms should be read together with our Privacy Policy and Cookie Policy.

Privacy Policy references in these Terms refer to the Privacy Policy applicable to the emoni Group entity providing the services, as published on the official emoni websites (including https://www.emoni.io/privacy-policy/), as amended from time to time.

12.2 Intra-Group Sharing of Client Data

The Client acknowledges and agrees that, where necessary, personal data and client-related information may be shared within the emoni Group of companies (the "emoni Group"), which includes, without limitation, Ledgends Inc. (Canada), iLedgends B.V. (Netherlands), iLedgends s.r.o. (Czech Republic), and their respective affiliates.

Such intra-group sharing may take place solely for the following purposes:

(a) rendering, supporting, or coordinating services requested by the Client, including where services involve more than one group entity or require internal referrals;

(b) client onboarding, due diligence, AML/CTF, sanctions screening, transaction monitoring, fraud prevention, complaints handling, and incident management;

(c) compliance with applicable legal and regulatory requirements, supervisory requests, audits, investigations, or reporting obligations to competent authorities; and

(d) group-level governance, risk management, internal controls, and regulatory compliance oversight.

Intra-group data sharing is carried out in accordance with a group-enabled but entity-accountable model, under which:

• each emoni Group entity remains independently responsible for compliance with the data protection, confidentiality, and regulatory obligations applicable within its own legal and regulatory perimeter; and
• client data is shared only on a need-to-know and minimum-necessary basis, subject to appropriate technical and organisational safeguards.

The emoni Group applies a tiered data-sharing approach, under which:

• baseline identification and referral data may be shared to facilitate service delivery;
• verification and due-diligence documentation may be re-used between group entities only where legally permitted and strictly necessary for onboarding or ongoing compliance; and
• highly sensitive or restricted data (including detailed AML assessments or suspicion rationales) is not routinely shared and is disclosed only following documented escalation and approval.

The Client acknowledges that, as a result of this intra-group model, client data may be accessed or processed from jurisdictions outside Canada, including within the European Union. In such cases, appropriate contractual, organisational, and security measures are applied to protect the data, as further described in the applicable privacy notice(s).

Further information on how personal data is collected, used, disclosed, and protected — including details of cross-border access and client rights — is set out in the emoni Inc. Privacy Policy, which forms an integral part of these Terms.

12.4 Cross-border and foreign access. Where your personal information may be accessed or processed from outside Canada (including by group entities or support personnel), we will describe the jurisdictions involved and safeguards in our privacy disclosures, and maintain appropriate contractual and security controls.

13. Security, Credentials, and Acceptable Use

You must maintain the confidentiality of your credentials, enable and use multi-factor authentication where available, and promptly notify us of any suspected compromise. You must not attempt to bypass security controls, engage in market manipulation, or use the Services for unlawful purposes.

14. Suspension and Restriction

We may suspend, restrict, delay or refuse Services where required by law, regulatory instruction, court order, or where we reasonably suspect fraud, AML/CTF risk, sanctions exposure, security compromise, or breach of these Terms.

15. Liability and Disclaimers

To the extent permitted by law, we exclude liability for indirect or consequential losses and do not guarantee uninterrupted or error-free operation of the Platform. Nothing in these Terms limits liability that cannot be limited or excluded by law.

16. Term and Termination

Either party may terminate the Agreement by giving at least 14 days' notice, unless a longer notice period is required by applicable law or your specific service agreement. We may terminate immediately where required by law, where continued provision of Services creates material risk, or where you materially breach these Terms.

On termination, you remain responsible for obligations accrued prior to termination, and we may retain records as required by law and to resolve disputes, recalls, investigations or regulatory requests.

17. Intellectual Property

All intellectual property rights in the Platform and Services are owned by us or our licensors. You receive a limited, non-exclusive, non-transferable right to access and use the Platform for the purpose of using the Services.

18. Complaints and Dispute Resolution

We handle complaints in accordance with our complaints process (available on request or via the Platform). The parties will first attempt to resolve disputes in good faith.

19. Amendments

We may amend these Terms to reflect regulatory changes, security requirements, or changes to the Services. Material changes will be notified in advance (typically at least 14 days, unless a shorter period is required by law or for urgent risk/security reasons).

20. Governing Law

These Terms are governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein, unless mandatory consumer protection rules require otherwise.

Annex 1 — Risk Disclosures (Crypto-Assets)

Crypto-Assets carry significant risks, including the risk of loss of your entire invested capital. Key risks include market volatility, legal/regulatory changes, custody and counterparty risks, and technical/blockchain risks. Transactions may be irreversible and network congestion or software issues may delay execution or settlement. You should seek independent professional advice where appropriate.