BilderPay Terms and Conditions

Important Notice – Please Read Carefully

These Terms and Conditions (the “Terms”) govern your relationship with us in connection with your Account and the Services (each as defined herein). They contain legally significant information and form the basis upon which we provide access to and use of such Services. You are strongly advised to review these Terms in full before proceeding.

Please note that certain Services offered by us may be subject to supplementary terms and conditions. Such supplementary terms shall apply in addition to, and shall be deemed incorporated into, these Terms to the extent relevant.

Nothing in these Terms, nor any statements contained herein, shall be construed as legal, tax, or financial advice. We do not act in the capacity of a financial, legal, or tax advisor, and no part of our communications or documentation should be interpreted as such. You are solely responsible for seeking independent professional advice from qualified legal, tax, or financial advisors prior to engaging in any transaction. You should enter into a transaction only upon ensuring that you fully understand its nature, the contractual obligations involved, and all applicable terms and conditions.

DEFINITIONS

Term	Definition
Account	Refers to the account established by the user in connection with the Services, which may include, as applicable, a Custodian Account, a Self-Custody Wallet, and/or a Virtual Account.
Acceptable Tokens	(i) In respect of a Custodian Account, means any virtual assets accepted by the Group for deposit, including but not limited to Bitcoin (BTC), Ethereum (ETH), Tether (USDT), and USD Coin (USDC), or any other virtual assets as may be accepted from time to time; (ii) In respect of a Self-Custody Wallet, means any virtual assets accepted by the Group for locking within the Smart Contract Vault, including USD Coin (USDC) or such other assets as may be accepted; (iii) In the context of Swap Transactions, means any virtual assets accepted by the Group for such purposes, including BTC, ETH, USDT, and USDC, or any others as designated by the Group. The list of Acceptable Tokens may be amended at the sole discretion of the Group without prior notice.
AML/CTF	Refers to anti-money laundering and counter-terrorist financing.
App	Means the proprietary mobile application software developed and distributed by the Group, available for download on Android and iOS platforms and web version, including all content, services, updates, upgrades, supplements, releases, and versions thereof.
Applicable Law	Means any domestic or foreign law, statute, regulation, ordinance, rule, order, decree, directive, code, policy, guideline, treaty, or judicial, arbitral, administrative, ministerial or governmental judgment, whether current or future, applicable to any person, property, transaction, or activity, and includes requirements issued by any competent regulatory or governmental authority.
ATM	Means automated teller machines.
ATM Withdrawal Services	Shall be as described under Clause 31.
Authorised Person	Means any individual designated and approved by you and accepted by us to act on your behalf, including providing Instructions, executing Swap Transactions, or engaging in any activity under these Terms.
BilderPay Card	Means the crypto payment card issued by the Group or its Partners, available in both virtual and physical form, which enables users to execute payment transactions.
BilderPay Trust	Means BilderPay Trust Limited or any successor or additional service provider appointed by the Group.
BIN Sponsor	Means a third-party service provider that offers card issuance services to the Group and acts as the issuing entity for the BilderPay Card.
Card Balances	Shall have the meaning ascribed to the term in Clause 27.1.
Card Data	Means the primary account number (PAN), expiration date, and security code associated with the BilderPay Card.
Card Issuance Services	Refers to services provided by the BIN Sponsor to enable issuance of BilderPay Cards through the applicable Card Network.
Card Limits	Shall have the meaning ascribed to the term in Clause 27.3.
Card Network	Means any international credit, debit and prepaid card network which is applicable in respect of your BilderPay Card.
Card Network Rules	Refers to the bylaws, rules, regulations, and operating procedures of the applicable Card Network, including updates thereto, that govern card issuance, usage, acceptance, and dispute processes.
Card Transactions	Means any payment or withdrawal transaction conducted using a BilderPay Card or PIN.
Chargeback	Means a transaction dispute initiated by the Group through the applicable Card Network in accordance with its rules and procedures.
Confirmation	Means a trade confirmation (or similar) relating to a Swap Transaction.
Converted Assets	Shall have the meaning ascribed to the term in Clause 27.2.
Custodian Account	Means the account maintained by a user with the Custodian, comprising both Credit and Debit Accounts.
Custodian	Means BilderTrust or any successor or additional custodial service provider appointed by the Group.
Debit Account	Means the account maintained by the user with the Custodian, including hosted wallets used for the custody of fiat currency and Acceptable Tokens.
Enabled Device	Refers to any mobile or electronic device successfully registered by the user for use in connection with the App and the Services.
Event of Default	Shall have the meaning ascribed to the term in Clause 13.1.
Fees	Means all fees and charges imposed by the Group, BIN Sponsor, Custodian, Smart Contract, Card Network, or other relevant party in relation to the Services, including but not limited to those relating to the BilderPay Card, Custodian Account(s), Smart Contract Vault, and/or Virtual Account.
Group/we/us/our	Means the Bilder group, including but not limited to BilderPay, Bilder Limited, BilderTrust Limited, Bananatech Solutions OÜ as a trademark owner, and their affiliates. Each entity in the Group acts independently and is not jointly liable for actions or omissions of another entity within the Group.
Instructions	Means any written, electronic, or oral communication, directive, order, or message provided by you or an Authorized Person (or any person reasonably believed to be such by the Custodian), transmitted in accordance with the prescribed authentication and verification procedures.
KYC	Means "Know Your Customer" - the verification procedures to confirm the identity of users in accordance with applicable laws.
KYT	Means "Know Your Transaction" - procedures for monitoring and verifying user transactions.
Merchant	Means any business, vendor, or service provider that accepts payments made using a card, card number, PIN, or card with signature.
Other Third-Party Services	Shall have the meaning ascribed to the term in Clause 40
Personal Data	Means any data relating to an identifiable individual, whether true or not, and whether recorded in material form or not, as defined by applicable data protection legislation.
PIN	Means the personal identification number or code used for transaction verification and access to Services.
Pooled Account	Shall have the meaning ascribed to the term in Clause 24.9.
Proscribed Address	Means (a) any blockchain address identified on sanctions lists published by the United Nations, U.S. Department of the Treasury (e.g., OFAC’s SDN List), or other relevant authority; or (b) any address forming part of a group of addresses that is collectively sanctioned or otherwise restricted under Applicable Law.
Proscribed Person	Means any person who (a) is in breach of AML/CTF or sanction requirements; (b) appears on any applicable sanctions list; or (c) is known to be acting on behalf of a person described in (a) or (b).
Self-custody Wallet	Means a cryptocurrency wallet over which the user maintains full control via possession of the private keys, except as otherwise provided under these Terms.
Service Content	Means all materials, data, content, text, software, graphics, audio, video, and other intellectual property accessible via the Site or App.
Services	Means the Site, App, Service Content, and all related features, functionalities, and offerings made available to you by the Group, including as described in Clause 3.1.
Settlement Amount	In respect of a Card Transaction, means the sum of (i) the transaction value, (ii) applicable fees, and (iii) any buffer amount determined at the Group’s discretion.
Settlement Assets	Shall have the meaning ascribed to the term in Clause 27.2.
Site	Means the official website located at: https://bilderpay.io .
Smart Contract	Means the blockchain-based programmable agreement between the Group and the user that governs the operation of the Services via the Self-Custody Wallet, executing actions automatically based on predefined logic.
Smart Contract Vault	Means the secure repository within the Self-Custody Wallet used to lock Acceptable Tokens via smart contract functionality.
Smart Contract Vault Balance	Means the aggregate balance of Locked Tokens held in the Smart Contract Vault, subject to adjustment in accordance with these Terms.
Transaction History	Means the historical record of activity associated with the user’s Account, including Custodian Account(s), Smart Contract Vault, and/or Virtual Account, as applicable.
User Termination	Shall have the meaning ascribed to the term in Clause 13.7.
Virtual Account	Shall have the meaning ascribed to the term in Clause 34
Virtual Account Balance	Means the aggregate balance of Virtual Account Deposits, adjusted in accordance with these Terms.
Wallet Balance	Means the total amount of virtual assets held in the user’s Custodian Account(s), subject to fluctuations based on activity under these Terms.
You/your	Means, jointly and severally, the individual(s) who register for and use the Services provided by the Group.

2. SCOPE

2.1 General Scope

These Terms and Conditions (the “Terms”) govern the operation of your Account and your use of the Services provided by the Group. You are advised to read these Terms carefully and in their entirety prior to utilizing any of the Services, so that you are fully informed of your rights and obligations. By using any part of the Services and/or completing the registration process, you acknowledge and agree that you are entering into a legally binding agreement with the Group and are deemed to have read, understood, and accepted these Terms in full.

2.2 Components of the Terms

These Terms consist of the following components, all of which shall form an integral part of the legal agreement between you and the Group:

• These terms and conditions, which govern your Account and the Services, Custodian and Virtual Account(s), Cards, Other Third-Party Services in general;

• The Group’s published Privacy Policy;

• Any document(s) setting out fees, charges, or costs applicable to a Service, Instruction, and/or Swap Transactions;

• Any additional rules, guidelines, notices, or agreements published by the Group from time to time and designated as forming part of these Terms; and

• Any supplements, annexures, or documents incorporated by reference, including any Confirmations issued by the Group.

2.3 Conflicts and Precedence

Subject to any non-waivable requirements under Applicable Law, in the event of any inconsistency or conflict:

• Between the English version and any translation of the Terms, the English version shall prevail;

• Between specific terms applicable to a Service and any general provision of the Terms, the specific terms shall prevail; and

• Between a Confirmation and any other part of these Terms, the Confirmation shall prevail, except in the case of a manifest error.

3. THE SERVICES

3.1 Description of Services

The Services provided under these Terms may include, but are not limited to, the following:

• Custodian Account(s);

• BilderPay Card and associated Card Issuance Services;

• Swap Transactions;

• Use and management of Self-Custody Wallet and Smart Contract Vault;

• Provision and use of Virtual Accounts;

• Access to and use of Other Third-Party Services.

3.2 Right to Modify or Discontinue

The Group reserves the right, at its sole discretion and at any time, to update, modify, suspend, disable, restrict, or permanently discontinue the Services or any part thereof, including any features, functionalities, or content. The Group shall not be liable to you or any third party for any such modification or discontinuation. No representation or warranty is given that any Service or feature will be made available on a continuous or uninterrupted basis.

3.3 Conditions for Access and Provision

Access to the Services is subject to the Group’s discretion. You must establish and maintain an Account (and, where applicable, Custodian Account(s)) to use the Services. The Group may, at its discretion, refuse to provide any Service if:

• An Event of Default has occurred and remains outstanding;

• You have submitted false, incomplete, or misleading information, or made misrepresentations;

• You have failed to provide documentation or fulfil pre-conditions required by the Group;

• You have not demonstrated compliance with the Group’s eligibility criteria.

In addition, the Group may refuse or suspend Services if it reasonably determines that:

• The Service does not comply with Applicable Law, including AML/CTF obligations;

• The Service may be used to circumvent Applicable Law;

• The Service may involve jurisdictions subject to sanctions or restrictions determined by the Group;

• The Service may expose the Group to dealings with Proscribed Persons or Addresses.

4. ONBOARDING

4.1 Account Opening

In order to access the Services, you are required to open an Account (and, where applicable, a Custodian Account). To establish such an account, you must complete the application process and provide any information and documentation reasonably requested by the Group. All information submitted must be accurate, complete, and current.

4.2 Discretionary Control Over Accounts

The opening, operation, and closure of Accounts (including Custodian Accounts) are subject to the sole discretion of the Group. The Group may, without liability, at any time:

• Suspend, vary, or terminate your Account;

• Adjust the scope of Services permitted through the Account;

• Determine or change the supported fiat currencies or virtual assets;

• Apply, remove, or amend limits or conditions on your Account or Services.

4.3 Nature of Accounts

Accounts are established solely for the purpose of enabling access to and use of the Services. Accounts do not constitute bank accounts or stored value facilities and shall not be interpreted or relied upon as such.

4.4 Representations and Warranties

By registering for an Account and using the Services, you represent and warrant that:

• You understand that the marketing or distribution of Services outside of Hong Kong may be subject to regulatory licensing, and you access the Services voluntarily and without solicitation by the Group or its affiliates;

• You are an approved user who has completed the required onboarding process and received confirmation of approval;

• You have read and understood the Group’s Privacy Policy;

• You are of legal age and capacity under all applicable laws;

• You have full authority to enter into these Terms;

• You are the rightful user of the registered Enabled Device;

• You understand and accept the risks associated with the Services, including those involving Self-Custody Wallets;

• You do not already possess a BilderPay Card under any identity; and

• You are not impersonating another individual or concealing your identity.

4.5 Provision of Information

You agree to promptly provide any information or documentation reasonably requested by the Group for compliance, operational, or regulatory purposes.

4.6 Cooperation and Verification

You agree to cooperate with any verification or authentication procedures required by the Group or its service providers, including identity verification, validation of ownership over devices or funding instruments, and confirmation through third-party databases or other means.

4.7 Right to Reject or Terminate Access

The Group reserves the right to reject any application, suspend or terminate your access to the Services, or revise eligibility criteria, at its sole discretion and at any time, without obligation to provide a reason.

4.8 Consent to Background Verification

You consent to the Group, or a third-party acting on its behalf, performing background and identity verifications using secure databases, including the collection and assessment of data provided by you.

4.9 Obligation to Maintain Accurate Information

You are responsible for ensuring that all information provided remains true, complete, and up to date. Should the Group determine that your information is outdated or incorrect, it may request corrections or require re-verification. Failure to comply may result in restricted access to, or termination of, the Services.

5. THE APP

5.1 Functionalities

The mobile application (the “ App ” ) is provided by the Group for your use in connection with the Services. The features and functionalities of the App may be amended, added to, suspended, or withdrawn at any time and from time to time, at the sole discretion of the Group and without prior notice. Subject to the availability of features and your continued compliance with these Terms, the App may enable you to perform one or more of the following actions, without limitation:

• Submit requests for the issuance of BilderPay Cards;

• Modify settings associated with your BilderPay Cards, including configuring or updating your BilderPay PIN;

• Initiate and conduct Swap Transactions;

• Access and review your Transaction History on a monthly basis (note: no physical statements will be issued by the Group);

• Request the activation, deactivation, or blocking of Services;

• Load funds into your Custodian Account(s), including any linked Debit Account;

• Deposit Virtual Account Deposits into your Virtual Account;

• Top-up or withdraw virtual assets or fiat currency to or from your Custodian Account(s);

• Withdraw fiat proceeds from your Virtual Account or resulting from Swap Transactions;

• Access and use services provided by Third Party Service Providers via the App.

5.2 License Grant

Subject always to your ongoing compliance with these Terms, the Group hereby grants you a limited, non-exclusive, non-transferable, revocable license to download, install, and use the App on your Enabled Device solely for your personal and lawful use in connection with the Services, and strictly in accordance with these Terms. All rights not expressly granted to you herein are reserved by the Group.

5.3 Open-Source Components

Certain software components incorporated into the App may be licensed to you under open source or other third-party licensing terms. In the event of any inconsistency between the terms of such licences and the provisions of these Terms, the relevant third-party license terms shall prevail, but solely with respect to those specific components.

5.4 Conditional Use

You acknowledge and agree that your use of the App, your Account, and all related Services is strictly subject to your ongoing compliance with these Terms and any other terms and policies that may be applicable from time to time.

6. YOUR DEVICE

6.1 Responsibility for Equipment and Security

You acknowledge and agree that it is your sole responsibility, at your own cost, to ensure that your device (the “Enabled Device”) meets the necessary technical and security requirements for use of the App and Services. Without limitation, this includes:

• Procuring, maintaining, and configuring all necessary hardware, software, and telecommunications services required to access and use the App;

• Installing and maintaining updated antivirus, anti-malware, and other relevant security software on your Enabled Device;

• Promptly installing all software updates, patches, and upgrades for both the App and your Enabled Device to address known security vulnerabilities and maintain compatibility.

6.2 Responsibility for Access

You shall be solely responsible and liable for any and all access to, and use of, the App and the Services via your Enabled Device, whether or not such access was authorized, known, or intended by you. The Group disclaims any and all liability for any loss, damage, or unauthorized activity resulting from the use of the App via your Enabled Device.

6.3 Security Breach and Notification

In the event that your Enabled Device is lost, stolen, or you become aware of any unauthorized access to or use of your Enabled Device or the App, you must notify the Group immediately through designated contact channels. In addition, where such unauthorized access is suspected or confirmed, you are responsible for promptly resetting your device passwords and taking all reasonable steps to secure your device and access credentials.

7. FEES

7.1 Applicability and Payment

Your access to and use of the Services may be subject to fees, charges, commissions, or other costs (collectively, the “ Fees ” ), as applicable. Such Fees may be deducted from your Wallet Balance held in the Custodian Account(s), your Smart Contract Vault Balance, or your Virtual Account Balance (as applicable), or may be settled at the time of card balance settlement, Swap Transaction execution, or charged separately. You hereby agree to promptly settle all Fees when due. Failure to do so may result in the suspension or restriction of your access to the Services until all outstanding amounts are fully discharged. The current schedule of applicable Fees is published on the App, the Site, or in separate documentation as made available by the Group. The Group reserves the right, in its sole and absolute discretion, to introduce new Fees or amend existing Fees at any time.

7.2 Taxes

All Fees listed in any applicable fee schedule, on the App, or on the Site are exclusive of any applicable taxes, duties, or governmental levies. Any such taxes shall be charged in addition to the stated Fees, and the final amount payable by you shall be inclusive of such applicable taxes.

7.3 Non-Refundability

All Fees paid in connection with the Services are strictly non-refundable under any circumstances, unless otherwise required by Applicable Law.

7.4 Independent Payment Obligations

Each payment obligation under these Terms shall be construed as separate and independent. Payment of one obligation does not relieve you from any other payment obligation under these Terms.

8. RIGHTS OF NETTING, SET-OFF, AND LIEN

8.1 Netting of Obligations

Where both you and the Group have obligations for payment or delivery in the same fiat currency or Acceptable Token on any given day with respect to multiple transactions, the Group may elect, in its sole discretion, to effect payment or delivery on a net basis. In such case, the respective obligations shall be automatically discharged by way of net settlement. The party owing the greater amount shall be obliged to pay the difference between the respective obligations.

8.2 Rights of Set-Off

In addition to the netting rights set forth in Clause 8.1, the Group reserves the right, at any time and without prior notice, to set off any obligations, whether matured, unmatured, actual, or contingent, owed by you (individually or jointly, if more than one person constitutes the client) against any sums due or owing to you by the Group, regardless of the currency, type of asset, or place of payment. Where a balance remains payable by you after such set-off:

• You hereby authorize the Group to (i) liquidate any or all of your fiat or Acceptable Tokens held by the Group; or (ii) apply such assets (including those held in any Custodian Account, Self-Custody Wallet (subject to applicable Smart Contract Vault terms), or Virtual Account) toward the satisfaction of the outstanding amount; and

• In the event of a shortfall following such application, you shall immediately pay the remaining balance due to the Group in full and without delay.

8.3 General Lien

The Group shall have a general lien over any of your assets or property in its possession or control, except to the extent such lien may give rise to a disclosure obligation under Applicable Law. The Group may sell or dispose of such assets and apply the net proceeds, after deducting reasonable costs and expenses, to discharge any amounts owed by you.

8.4 Currency and Asset Conversion

For purposes of exercising any of its rights under this Clause 8, the Group may perform conversions between currencies or assets at such rates as it, acting reasonably, determines to be appropriate at the time of conversion.

8.5 Additional Rights

The rights granted to the Group under this Clause 8 are without prejudice to and in addition to any other rights of set-off, combination, lien, retention, or withholding available to the Group under these Terms, contract, equity, or Applicable Law.

9. INTELLECTUAL PROPERTY RIGHTS

You acknowledge and agree that:

• All trademarks, logos, service marks, product names, and proprietary identifiers used in connection with the App or the Services (collectively, the “ Trademarks ” ) are the property of the Group, its affiliates, or applicable third-party licensors;

• All intellectual property rights in and to the App and the Services are owned by, or duly licensed to, the Group;

• Except as expressly granted under these Terms, no license, right, or interest is conferred upon you in respect of the Trademarks, the App, or the Services;

• You shall not copy, reproduce, republish, broadcast, hyperlink, transmit, display, distribute, modify, adapt, create derivative works of, or otherwise exploit any part of the App, Services, or related content in any manner or by any means without the prior written consent of the Group.

10. USER CONDUCT

Without prejudice to any other provisions of these Terms, you shall not (and shall not permit, facilitate, or encourage any third party to):

• Use the App or Services to engage in spamming or other unsolicited communications;

• Use the App for any unlawful, fraudulent, or immoral purposes, including money laundering or terrorist financing;

• Upload, transmit, or distribute any material containing viruses, malicious code, or illegal or offensive content;

• Modify, alter, reverse-engineer, disassemble, decompile, or otherwise attempt to extract or access the source code of the App;

• Incorporate or combine the App, or any part thereof, into any other software or system without authorization;

• Infringe or misappropriate the intellectual property rights of the Group or any third party;

• Use the App in a manner that could damage, impair, disable, or compromise the App, the Services, or the Group’s systems and networks, or interfere with other users;

• Engage in conduct that may damage the reputation of the Group or its affiliates;

• Violate any Applicable Law; or

• Behave abusively, aggressively, or in a threatening or violent manner toward the Group’s personnel.

11. DATA PROTECTION

By accessing or using the Services, you confirm that you have read, understood, and agreed to the Group’s privacy policy, and consent to the collection, use, processing, and disclosure of your Personal Data by the Group, its authorized service providers, and relevant third parties, for the purposes of administering and facilitating your use of the Services. Such purposes are set out in greater detail in the Group’s privacy policy, which may be amended from time to time in accordance with Applicable Law.

12. ELECTRONIC COMMUNICATIONS

12.1 Assumption of Authenticity

You agree and acknowledge that you bear full responsibility for the security, accuracy, and authenticity of all communications and instructions (collectively, “Instructions”) submitted via the App or from your designated official email address. You shall be bound by all such Instructions, and the Group shall be entitled to act upon and rely on any Instructions received from your Enabled Device or official email address without any obligation to verify their authenticity, origin, or accuracy.

12.2 Transmission Risks

You acknowledge that communications transmitted through the App or email are generally conveyed over the Internet and may pass through publicly accessible, transnational networks which are not subject to specific protections. As such, the Group cannot and does not guarantee the security, integrity, or confidentiality of such transmissions, and you expressly accept the inherent risks, including the potential for interception, unauthorized access, or alteration by third parties.

12.3 Receipt of Instructions

Instructions submitted by you shall only be deemed received by the Group when they have been successfully retrieved from the relevant system and the Group has duly acknowledged such receipt. Instructions directed to third parties (including network merchants) shall be governed by such third parties’ own terms and conditions and shall be deemed received in accordance therewith.

12.4 Liability for Internet Risks

Without prejudice to any other provision of these Terms, you shall be solely liable for any loss, damage, or delay resulting from the use of the Internet, including but not limited to transmission errors, data corruption, delays, unauthorized access, or duplication of Instructions.

12.5 Evidentiary Value

In the event of any dispute concerning your use of the Services, you acknowledge and agree that the Group’s records - including electronic, computer-based, or microfilm records—shall constitute conclusive evidence of the content, timing, and authenticity of such usage. You further agree that such records shall be admissible in any legal proceeding without further requirement of proof of their authenticity or accuracy, to the fullest extent permissible under applicable evidentiary rules or laws.

13. LIMITATION, SUSPENSION AND TERMINATION OF ACCOUNT AND SERVICES

13.1 Right to Suspend or Terminate

The Group reserves the right, in its sole and absolute discretion and at any time, to suspend, restrict, or terminate your access to or use of your Account (including, where applicable, your Custodian Account(s), Virtual Account, and/or Smart Contract Vault) or any Service, in whole or in part, without prior notice. This includes, but is not limited to, freezing or closing accounts, refusing or reversing Card Transactions, suspending deposits or withdrawals, and/or halting Swap Transactions. Grounds for such action (each an “ Event of Default ” ) may include:

• Breach of these Terms or any other applicable terms or conditions;

• Requirement to comply with Applicable Laws or regulatory obligations;

• Suspicion of involvement in unlawful or prohibited activities (including money laundering, terrorism financing, or fraud);

• Activities inconsistent with the expected user profile under the Group’s internal risk assessment policies;

• Insolvency or commencement of any insolvency, liquidation, or restructuring proceeding;

• Fraudulent, dishonest, or misleading conduct;

• Repudiation or disavowal of these Terms, any Confirmation, or any Virtual Asset Transaction;

• Violation of any Applicable Law;

• Seizure, enforcement, or compulsory acquisition of your assets;

• Conviction for tax or other criminal offences in any jurisdiction;

• Use of the Account or Services in a manner deemed improper, irregular, or abusive by the Group;

• Any circumstance which, in the Group’s opinion, materially impairs your ability or intent to comply with your obligations under these Terms;

• Failure to make timely payments or deliveries due under these Terms or under any other agreement with the Group.

13.2 Exclusion from Incentive Programs

The Group reserves the right to cancel, reverse, or disqualify your participation in any incentive, reward, cashback, or referral programme if you are found, directly or indirectly, to be in breach of these Terms.

13.3 Continuing Liability

Your obligations under these Terms shall survive termination of Services. The Group shall remain entitled to debit your Wallet Balance of the Custodian Account(s), Smart Contract Vault Balance, or Virtual Account Balance for any Fees or charges incurred in relation to Services or Card Transactions carried out prior to or following termination. You remain liable to settle all such amounts in full.

13.4 No Compensation

You shall not be entitled to any compensation, damages, or payment of any kind in the event of suspension, restriction, or termination of Services. Any such action shall not release you from any accrued liabilities existing at the time of suspension or termination.

13.5 Entitlement to Refunds

Upon termination of Services, you shall be entitled to request a refund of your Wallet Balance of the Custodian Account(s), the release of any Smart Contract Vault Balance, and/or a withdrawal of your Virtual Account Balance, subject to Clauses 13.6 through 13.13 below.

13.6 Cumulative Rights

The Group’s rights under this Clause 13 are in addition to, and do not prejudice, any other rights or remedies available to it under these Terms, at law, or in equity.

13.7 User-Initiated Termination

You may request termination of your Services at any time ( “ User Termination ” ) and seek a full refund or release of any balances. Such requests must be submitted through the App or via email.

13.8 Identity Verification

In order to process a User Termination, the Group may require you to submit photographic identification or other verification documentation, in compliance with Applicable Laws.

13.9 Delay or Reduction of Refunds

The Group reserves the right to delay, reduce, or deny any refund or release if necessary to prevent your balances from becoming negative as a result of such transaction.

13.10 Method and Recipient of Refunds

The Group shall determine, in its sole discretion, the method of disbursement (e.g., on-chain transfer, bank transfer, cheque) for any refund or release. Refunds will only be issued to the verified holder of the respective Custodian Account(s), Self-Custody Wallet, and/or Virtual Account.

13.11 Expiration of Refund Claims

Refunds or releases not claimed or accepted within three (3) years from the date of issuance may be forfeited without prior notice, at the sole discretion of the Group.

13.12 Fees for Processing Refunds

The Group may impose a reasonable administrative fee for processing any refund, withdrawal, or release of balances to cover associated costs.

13.13 Maintenance Fee Post-Termination

In the event that your Account or any associated Custodian Account becomes ineligible, suspended, or terminated, the Group may impose a maintenance fee on any remaining Wallet Balance of the Custodian Account(s), Smart Contract Vault Balance, and/or Virtual Account Balance.

14. LIMITATION OF LIABILITY

14.1 Disclaimer of Warranties

Except as expressly provided in these Terms, and to the fullest extent permitted by Applicable Law, the Group disclaims all representations, warranties, guarantees, and conditions, whether express, implied, statutory or otherwise, made to you, your affiliates, or any third party, including but not limited to any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, or suitability for any purpose, and any warranties arising out of course of dealing, usage, or trade.
To the extent any warranty may not be lawfully excluded, the Group’s liability shall be limited, at its sole option, to either:
(i) the re-performance, replacement, or repair of the relevant Service; or
(ii) payment of the cost of re-performing, replacing, or repairing such Service.

14.2 Exclusion of Liability

Notwithstanding any other provision of these Terms and to the maximum extent permitted by law, the Group and its officers, directors, agents, employees, representatives, and affiliates shall not be liable to you for any losses, damages, costs, claims, liabilities, or expenses (whether in contract, tort, equity, statute or otherwise), including without limitation:

• arising from any Force Majeure event or other circumstances beyond the Group’s reasonable control (including war, civil unrest, natural disaster, government actions, strikes, lockouts, and telecommunications failures);

• arising from any delay, interruption, failure, or suspension of the App, Services, or any part thereof;

• refusal, rejection, or reversal of any Card Transaction or other transaction for any reason;

• inability to access the App or complete transactions due to system maintenance, downtime, technical malfunctions, or third-party service failures;

• unauthorized or improper use of the Services or your Enabled Device, whether by you or any third party (with or without your consent);

• loss, theft, or unauthorized access to your Enabled Device;

• actions taken by the Group to comply with Applicable Laws, court orders, or card network rules.

Under no circumstances shall the Group be liable for any indirect, incidental, special, exemplary, punitive, or consequential losses or damages, including but not limited to lost profits, lost revenue, loss of business opportunity, even if the Group has been advised of the possibility of such damages.

14.3 Liability Cap

To the extent any liability of the Group arises in connection with the Services or these Terms, the aggregate liability of the Group shall in no event exceed the aggregate value of your Wallet Balance in the Custodian Account(s), Smart Contract Vault Balance, and/or Virtual Account Balance (as applicable) as at the date the relevant claim arises.

14.4 Third-Party Service Providers

The Group shall not be liable for any loss, damage, or failure arising from the conduct or services of any third-party service provider engaged by the Group. The Group’s sole responsibility in such cases shall be limited to exercising reasonable care in the selection, appointment, and instruction of such providers. The Group shall not be liable for the acts or omissions of any subcontractors engaged by such third-party providers.

14.5 Non-Excludable Liability

Nothing in these Terms shall operate to exclude or limit any liability that cannot be excluded or limited under Applicable Law, including liability for death or personal injury caused by negligence, or for fraud or fraudulent misrepresentation.

15. INDEMNIFICATION

You agree to fully indemnify, defend, and hold harmless the Group, its affiliates, and their respective officers, directors, employees, agents, representatives, joint venturers, and third-party service providers (collectively, the “Indemnified Parties”) from and against any and all claims, demands, losses, liabilities, damages, costs, and expenses (including legal fees, regulatory fines, penalties, and enforcement actions) arising from or related to:

• your breach of these Terms;

• your use or misuse of the App or the Services;

• your violation of any Applicable Law, regulation, rule, or third-party rights; and

• any transaction executed as a result of your willful misconduct, fraud, gross negligence, or default under these Terms.

16. AMENDMENT AND VARIATION

These Terms may be updated, amended, or otherwise modified from time to time at the sole discretion of the Group. Any such updates will be published on the App and/or the Site and shall become effective immediately upon posting. It is your responsibility to regularly review the App and the Site for any amendments. Continued use of the App or the Services following such publication shall constitute your acceptance of the amended Terms.
The Group may also, at its discretion and without prior notice, add, remove, or modify any features, functionalities, or components of the App. If you do not agree to be bound by any amendments or modifications, you must immediately cease use of the App and the Services.

17. ASSIGNMENT AND SUBCONTRACTING

These Terms, and any rights or licences granted herein, are personal to you and may not be transferred, assigned, or sublicensed by you without the prior written consent of the Group. The Group may assign, transfer, subcontract, or otherwise deal with its rights or obligations under these Terms at any time and to any party, including its affiliates, subsidiaries, or any successor to its business, without restriction or notice. Any purported assignment in breach of this Clause shall be null and void.

18. SEVERABILITY

If any provision of these Terms is held to be illegal, invalid, or unenforceable by a court or authority of competent jurisdiction, such provision shall be deemed severed from these Terms, but the validity, legality, and enforceability of the remaining provisions shall remain unaffected. Any such invalid or unenforceable provision shall be replaced with a provision that most closely reflects the original intent and commercial purpose of the invalid provision to the extent permitted under Applicable Law.

19. ENTIRE AGREEMENT AND LANGUAGE

19.1 Entire Agreement

These Terms constitute the entire agreement between you and the Group in relation to the subject matter herein and supersede all prior or contemporaneous agreements, communications, negotiations, understandings, and representations - whether oral or written, express or implied - relating to the same subject matter. Each party acknowledges that in entering into these Terms, it has not relied on any representation, warranty, statement, or promise other than those expressly set forth herein.

19.2 Language

These Terms are concluded in the English language, and all notices, communications, disclosures, and documentation required or permitted under these Terms shall be provided in English. In the event these Terms are translated into any language other than English for any purpose (including legal proceedings or convenience), the English language version shall prevail in the event of any inconsistency or conflict.

19.3 Precedence

Notwithstanding any other provisions, in the event of any inconsistency between the content of these Terms and any Service Content, these Terms shall prevail.

20. WAIVER

20.1 Written Waiver

No waiver of any provision of these Terms shall be valid or binding unless made in writing and signed by an authorized representative of the Group.

20.2 No Implied Waiver

The failure or delay of the Group to enforce any provision of these Terms shall not be deemed a waiver of its rights under such provision or any other provision. No single or partial exercise of any right, power, or remedy shall preclude any further exercise of that or any other right, power, or remedy. All rights, powers, and remedies provided under these Terms are cumulative and not exclusive of any rights or remedies provided by law or in equity.

21. NOTICES AND COMMUNICATIONS

21.1 Communications from the Group

By using the Services, you consent to receive all communications, notices, disclosures, and other information relating to the Services electronically from the Group, its affiliates, service providers, agents, contractors, or subcontractors, via one or more of the following means:

• Email to the address you have provided;

• SMS or telephone to the number you have provided;

• Notifications posted on the Site or within the App.

Any notice sent by email shall be deemed received on the date of transmission unless proven otherwise.

21.2 Communications to the Group

The Group prefers to receive notices electronically via its designated email address. You agree to this mode of communication for any formal notice, request, or instruction.

22. THIRD PARTY RIGHTS

22.1 Enforcement by Indemnified Parties

Subject to the Contracts (Rights of Third Parties) Ordinance (Cap. 623 of the Laws of Hong Kong), these Terms, together with any related agreements or instruments, are intended to confer rights or benefits only on the Indemnified Parties, who shall be entitled to enforce the relevant provisions hereof. No other person shall have any rights to enforce or benefit from any term under these Terms by virtue of that Ordinance.

Notwithstanding the foregoing, these Terms (and any agreement governed by or subject to these Terms) may be amended, modified, rescinded, or waived by the Group and you at any time without the consent of any Indemnified Party.

23. GOVERNING LAW AND DISPUTE RESOLUTION

23.1 Governing Law

These Terms and any non-contractual obligations arising out of or in connection with them shall be governed by, and construed in accordance with, the laws of the Hong Kong Special Administrative Region.

23.2 Arbitration

Any dispute, controversy, difference, or claim arising out of or in connection with these Terms, including any question regarding their existence, validity, interpretation, performance, breach, or termination, as well as any dispute concerning non-contractual obligations arising therefrom, shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (“HKIAC”) in accordance with the HKIAC Administered Arbitration Rules in force at the time the Notice of Arbitration is submitted.

23.3 Arbitration Procedure

The parties agree that:

• The governing law of this arbitration clause shall be the laws of Hong Kong;

• The seat (legal place) of arbitration shall be Hong Kong;

• Unless otherwise agreed by the parties, the arbitral tribunal shall consist of a sole arbitrator with appropriate legal and technological expertise;

• If the parties are unable to agree on the appointment of the arbitrator within fifteen (15) business days from the commencement of arbitration, the arbitrator shall be appointed by the HKIAC;

• The language of the arbitration shall be English.

23.4 Right to Seek Urgent Relief

Notwithstanding the foregoing, nothing in these Terms shall prevent the Group from seeking urgent interim, injunctive, or equitable relief in any jurisdiction as it may deem necessary to protect its rights or interests.

24. CUSTODIAN ACCOUNT(S) – GENERAL

24.1 Establishment and Appointment

Upon the creation of an Account with the Group, you shall enter into a contractual relationship with the designated custodian (the “ Custodian ” ) for the custody of your fiat currencies, virtual assets, and other applicable assets. You hereby appoint the Custodian, and the Custodian accepts such appointment, to act as custodian with respect to all fiat currency, securities, virtual assets, and other assets or property deposited or delivered by you from time to time.

24.2 Custodian’s Obligations

The Custodian agrees to hold in safekeeping all assets received from you, in accordance with the terms set forth herein and Applicable Law, and to perform its custodial duties as specifically provided in these Terms. The Custodian shall not be responsible for any duties except those expressly assumed herein.

24.3 Delivery of Assets

You agree to deliver, or cause to be delivered, to the Custodian all relevant assets and any income, capital, or principal distributions arising therefrom. Securities may be delivered in physical or book-entry form.

24.4 Custodian Wallets

As part of its custodial services, the Custodian shall allocate one or more individual on-chain wallet addresses dedicated to you (each, a “Custodian Wallet”) for the storage of supported virtual assets. Custodian Wallets are secured and administered by the Custodian. All such assets held to your credit are segregated from the Custodian’s own assets and from those of other users. Wallet access keys are managed solely by the Custodian’s authorized personnel. You may maintain multiple deposit wallet addresses, each of which shall be viewable via your Custodian Account.

24.5 Virtual Asset Risk

By maintaining virtual assets in a Custodian Wallet, you acknowledge and accept the risks associated with market fluctuations, including depreciation in asset value. You waive any claims against the Custodian in respect of such value fluctuations.

24.6 Asset Management

Where the Custodian Account(s) is used in connection with the Services, the Group shall manage fiat currency, virtual assets, and other applicable assets on your behalf and in accordance with these Terms.

24.7 Assumed Risks

You acknowledge the inherent risks associated with the Custodian Account(s), including:

• System Risks: related to platform and system performance;

• Market Risks: due to price volatility of virtual assets;

• Regulatory Risks: related to evolving legal and compliance standards;

• Security Risks: arising from cyberattacks, data breaches, or theft;

• Operational Risks: including internal processing failures or disruptions.

24.8 Instructions from the Group

The Group may, as necessary to facilitate settlement of transactions (including Card Balances), issue binding instructions to the Custodian, which may include freezing, converting, or transferring your assets. The Custodian is contractually obligated to comply with such instructions.

24.9 Pooled Account Structure

Your Custodian Account(s) consists of individual accounts designated for each user. All such assets are subsequently swept into a ring-fenced pooled omnibus vault account (“Pooled Account”) maintained by the Custodian and segregated from the Custodian’s proprietary assets. The Custodian will maintain:

• Accurate records of your individual account and corresponding Wallet Balance; and

• Your identifiable share of the assets within the Pooled Account.

24.10 Nature of the Custodian Account

The Custodian Account is not a bank account, savings account, or checking account. No interest shall accrue or be payable on any assets held therein.

24.11 Authorization for Asset Management

By using the Custodian Account(s) in connection with the Services, including the BilderPay Card, you expressly authorize the Group to manage assets therein for purposes of security, functionality, and compliance with Applicable Law.

24.12 No Deposit Insurance

The Custodian Account is not a deposit account, and assets held therein are not protected by the Deposit Protection Scheme under the Deposit Protection Scheme Ordinance (Cap. 581, Laws of Hong Kong).

24.13 Acknowledgements and Authorizations

You acknowledge and warrant that:

• The Group may make adjustments to the Custodian Account(s), including the handling of forks in virtual assets or modifications to pooled arrangements;

• The Group does not act as a trustee, fiduciary, or escrow agent for your assets;

• The Custodian serves solely as a custodian;

• You authorize the Group to freeze, convert, or transfer assets as required; and

• All assets deposited are of lawful origin and in compliance with Applicable Law.

24.14 Transaction Processing Times

Virtual asset receipt and transfer times depend on third-party network performance. Transactions remain pending until confirmed by the applicable blockchain. Balances may reflect unconfirmed transactions but are not final until confirmation.

24.15 Custodian’s Scope of Responsibility

The Custodian shall not be liable for any property not delivered to it or properly transferred pursuant to instructions, nor for property held or delivered by third parties.

24.16 Instructions and Verification

The Custodian is entitled to rely on instructions transmitted via agreed authentication methods. Oral Instructions must be promptly confirmed in writing. Any inconsistency between Oral and Written Instructions obligates the Custodian only to notify the user, without invalidating the underlying transaction.

24.17 Disbursement of Assets

Upon receipt of proper Instructions, the Custodian shall disburse assets as directed, including standing instructions as permitted under these Terms.

24.18 Delegation of Duties

The Custodian may appoint one or more qualified banks or trust companies as agents. Such delegation shall not relieve the Custodian of its responsibilities hereunder.

24.19 Non-Discretionary Actions

Without express authorization, the Custodian may:

• Convert temporary securities into definitive form;

• Endorse instruments for collection;

• Attend to administrative matters related to user assets.

24.20 Recordkeeping and Communications

The Custodian shall maintain records as required by Applicable Law and permit inspection during business hours. You elect to receive communications electronically and accept all associated risks.

24.21 Payment Administration

When making payments to service providers (including the Group) pursuant to proper Instructions, the Custodian acts solely in an administrative or ministerial capacity and not as payor for tax purposes.

24.22 Interest on Balances

To the extent permitted by law, the Custodian may retain interest earned on cash balances and shall not be required to account for such interest to you.

24.23 Segregation of Non-Cash Property

The Custodian shall hold and segregate all non-cash property on your behalf.

24.24 Fees and Expenses

The Custodian shall be entitled to compensation for its services and reimbursement of expenses, as may be agreed in writing from time to time.

24.25 Standard of Care and Limitation of Liability

The Custodian shall perform its duties with reasonable care, prudence, and diligence customary for custodians of similar services. The Custodian shall not be liable for any damages except to the extent arising from its gross negligence, willful misconduct, bad faith, or breach of these Terms. In no event shall the Custodian be liable for special, indirect, consequential, or punitive damages, including lost profits.

24.26 Title and Force Majeure

The Custodian is not responsible for verifying title or authenticity of assets. It shall not be liable for losses arising from events beyond its reasonable control, including natural disasters, war, terrorism, or infrastructural failures.

24.27 Sub-Custodian Insolvency

The Custodian shall not be liable for losses caused by the insolvency of any sub-custodian not majority-owned by the Custodian.

24.28 Reliance on Legal Advice

The Custodian may seek written Instructions or legal advice in connection with its duties and shall not be liable for any action taken in good faith reliance on such advice, provided such opinion is shared with the user within a reasonable timeframe.

24.29 Indemnification

You shall indemnify and hold harmless the Custodian from all claims, liabilities, losses, costs (including legal fees), and expenses arising from actions taken or omissions made in accordance with these Terms, except to the extent arising from the Custodian’s own wilful misconduct, negligence, bad faith, or breach of these Terms.

25. DEPOSITS TO YOUR CUSTODIAN ACCOUNT(S)

25.1 Deposit Procedure

To deposit virtual assets or, where applicable, other assets including fiat currency into your Custodian Account(s), you must strictly follow the deposit instructions provided via the App or the Site. Only Acceptable Tokens, or other permitted assets as defined in these Terms, shall be accepted for custody.

25.2 Compliance and Due Diligence

Both the Group and the Custodian reserve the right to conduct know-your-customer (KYC), know-your-transaction (KYT), anti-money laundering and counter-terrorist financing (AML/CTF) procedures, as well as any other due diligence measures deemed necessary in relation to all assets and transactions associated with your Custodian Account(s). You agree to provide, upon request, accurate, complete, and up-to-date information and supporting documentation to facilitate such checks.

25.3 Asset Freezing

The Group may, in its sole discretion and in accordance with these Terms, freeze part or all of the assets held in your Custodian Account(s). During the period of such freeze, you shall be restricted from accessing, transferring, or transacting with the affected assets until the freeze is lifted.

25.4 Representations and Warranties

You represent and warrant that all assets deposited into your Custodian Account(s) are legally and beneficially owned by you, free of any liens, encumbrances, or third-party claims, and are not derived from, nor connected to, any illicit or unlawful activities.

25.5 Right to Refuse Deposits

The Group and/or the Custodian reserve the right, in their sole discretion, to reject any deposit of assets into your Custodian Account(s), particularly where there are concerns regarding the legality, authenticity, or source of such assets, or where due diligence and compliance checks are not satisfactorily completed.

25.6 Regulatory Cooperation

You acknowledge and agree that the Group and the Custodian are legally obligated to report any suspicious transactions or activity to relevant regulatory authorities. You undertake to fully cooperate with the Group, the Custodian, and the relevant authorities in connection with any such investigations.

25.7 Responsibility for Asset Type

You are solely responsible for ensuring that only Acceptable Tokens or other authorized assets (as applicable) are transmitted to your Custodian Account(s). Any assets sent in error or in contravention of these Terms may be permanently lost and shall not be recoverable or refundable by the Group or the Custodian.

26. WITHDRAWALS FROM YOUR CUSTODIAN ACCOUNT(S)

26.1 Withdrawal and Transfer Rights

Subject to the terms of this Agreement and any applicable restrictions (including freezes or holds), you may withdraw assets from your Custodian Account(s) from time to time. You may also transfer assets internally between your own Custodian Accounts (e.g., between a Debit Account and Credit Account), or to the Custodian Account(s) or Smart Contract Vaults of other users. All such withdrawals or transfers must be executed in accordance with the applicable instructions and procedures set out in these Terms or as published on the App or the Site.

26.2 Accuracy of Transfer Instructions

You are solely responsible for ensuring the accuracy and validity of any recipient wallet address, bank account, or financial institution account used for withdrawals or transfers. Neither the Group nor the Custodian (where relevant) shall be liable for any losses, damages, or liabilities (including tax implications) arising from the use of incorrect or incompatible destination details.

26.3 Fees and Charges

You shall bear all fees, charges, and costs associated with withdrawals, transfers, or releases of assets from your Custodian Account(s), including but not limited to network and transaction fees. Such fees may be deducted from your Custodian Account(s) at the time of transaction or charged separately, as determined by the Group or the Custodian.

26.4 Right to Decline Requests

The Group and/or the Custodian may decline any request for withdrawal, transfer, or release of assets at their sole discretion and for any reason, including but not limited to compliance with Applicable Law, regulatory directives, or internal policy.

26.5 Transaction Limits

Withdrawals, transfers, and releases from your Custodian Account(s) are subject to such transaction limits as may be imposed by the Group and/or the Custodian from time to time, at their sole discretion.

27. CARD ISSUANCE AND PRE-AUTHORISATION OF CARD TRANSACTIONS

27.1 Card Usage and Credit Line

The Group may provide you with a line of credit in connection with the use of the BilderPay Card, which may be utilized for the following purposes, subject to these Terms:

• The purchase of goods and services from merchants worldwide that accept cards issued under the applicable Card Network Rules;

• The settlement of card balances arising from Card Transactions ("Card Balances");

• Cash withdrawals from automated teller machines (ATMs), subject to applicable terms and availability;

• Other authorized transactions as may be permitted under these Terms.

27.2 Card Issuance and Pre-Authorization

• Issuance: The BilderPay Card is issued as part of the Card Issuance Services and may be used for purchases at merchants and cash withdrawals at ATMs that accept cards issued under the relevant Card Network, including those outside of Hong Kong.

• Pre-Authorization: You authorize the Group to:

(i) Freeze an amount of your Acceptable Tokens held in your Custodian Account(s) or Locked Tokens in your Smart Contract Vault (as applicable); and/or
(ii) Freeze an equivalent amount of your Virtual Account Deposits, in each case equivalent to the Settlement Amount of the pending Card Transaction.

• Conversion and Settlement: Upon execution of a Card Transaction, you authorize the Group to convert and deduct the applicable amount of:

(i) Acceptable Tokens from your Custodian Account(s); or
(ii) Locked Tokens from your Smart Contract Vault; and/or
(iii) Virtual Account Deposits from your Virtual Account,

(collectively, “Settlement Assets”) into a fiat currency or stablecoin (“Converted Assets”), at prevailing market exchange rates determined at the Group’s discretion. The Converted Assets shall be used to settle the relevant Card Balances.

27.3 Card Limits

Use of the BilderPay Card shall be subject to limits prescribed by the Group, including:

• A maximum credit limit;

• A maximum per-transaction limit;

• Daily and monthly aggregate transaction limits (collectively, "Card Limits").

The applicable Card Limits will be published via the App or the Site and may be varied by the Group at any time, with or without prior notice. Transactions exceeding any applicable Card Limits shall be declined. You agree not to initiate any transaction that exceeds such Card Limits.

27.4 Request and Issuance

You may submit a request via the App for issuance of a BilderPay Card. Issuance is subject to approval by the Group. Activation of the BilderPay Card must be completed through the App. The Group reserves the right to reject any application for issuance or revoke any issued BilderPay Card at its sole discretion and without liability.

27.5 Cardholder Obligations

You acknowledge that each physical BilderPay Card remains the property of the Group or its partners. You agree to:

• Exercise due care and diligence in its use and safekeeping;

• Refrain from tampering with the card;

• Prevent unauthorized use or sharing of the card;

• Avoid defacing, damaging, or altering the card; and

• Not affix, print, or attach any material to the card or otherwise modify any element of its design.

27.6 Card Expiry and Renewal

Each BilderPay Card shall remain valid until the expiry date indicated on the App, unless earlier terminated. If the card is used within one (1) month before its expiry, the Group will notify you via email of its intention to automatically renew the card. The Group may impose a renewal fee, which may be debited from your Wallet Balance, Smart Contract Vault Balance, or Virtual Account Balance, deducted during settlement of your Card Balances, or otherwise charged separately. These Terms shall continue to apply to any renewed card. If you do not wish to renew the card, you must notify the Group via the App or by email.

27.7 Liability for Card Transactions

You are solely responsible for all transactions carried out using your BilderPay Card, including any arising from loss, theft, or misuse. You agree not to use the card for any unlawful purpose or in contravention of Applicable Law. You accept full liability for any unauthorized use of the BilderPay Card, regardless of whether such use was with or without your knowledge or consent.

27.8 Card Data Security

You shall keep your BilderPay Card details (“Card Data”) strictly confidential and must not disclose them except as necessary to complete legitimate transactions. You agree to take all reasonable precautions when sharing Card Data, including refraining from transmitting such data via unsecure channels (e.g., email, fax, unencrypted media). Neither the Group nor its affiliates shall be liable for unauthorized transactions resulting from your failure to maintain the confidentiality and security of Card Data.

27.9 Notification of Security Breaches

You agree to immediately notify the Group upon becoming aware of:

• Any unauthorized or inappropriate use or disclosure of your PIN or Card Data; and/or

• Any unauthorized access to or use of the Services using your PIN or Card Data.

You shall follow all instructions provided by the Group in response, including updating your PIN and other security credentials where required.

28. CHARGEBACK

28.1 Notification of Disputes

In the event of a dispute concerning the validity of any Card Transaction, you must notify the Group via email without undue delay, and in any case no later than sixty (60) days from the date of the disputed transaction. Upon receipt, the Group will either assist in resolving the dispute or forward your request to the relevant Merchant or Card Network for further processing.

28.2 Documentation and Compliance

You must comply with the applicable Card Network Rules in connection with any dispute or Chargeback request. This may include the submission of:

• A written explanation of the dispute;

• A copy of the sales receipt or transaction record; and

• Any additional documentation or information reasonably requested by the Group and/or the Card Network.

28.3 Investigations

The Group reserves the right to investigate any disputed transaction. In the course of such investigation, you agree to cooperate fully by providing any information or documents requested by the Group or relevant authorities.

28.4 Liability for Improper Transactions

If it is reasonably determined that the disputed transaction was the result of your willful misconduct, fraud, or negligence, or was otherwise compliant with these Terms, you authorize the Group to deduct the disputed amount, including any applicable charges or fees, from your Custodian Account(s), Smart Contract Vault (via Smart Contract), or Virtual Account.

28.5 Chargeback Fees

Any fees imposed by the Group and/or the Card Network in connection with the processing of a dispute or Chargeback request may be deducted from your Wallet Balance, Smart Contract Vault Balance, or Virtual Account Balance (as applicable), or otherwise charged to you. Such fees shall be non-refundable under all circumstances.

28.6 Finality of Decisions

You acknowledge and agree that:

• The Group and/or the relevant Card Network may, but are under no obligation to, assist with or process a Chargeback request; and

• The decisions of the Group and/or the Card Network concerning any Chargeback or related dispute shall be final, binding, and conclusive, unless otherwise specified in the applicable Card Network Rules or guidelines.

You further acknowledge that any reversal of a charge to your BilderPay Card is subject to the relevant Card Network’s applicable rules, procedures, and conditions.

28.7 Limitation of Liability

Under no circumstances shall the Group or the Card Network be liable to you for any loss or claim arising out of or in connection with a Chargeback request or related dispute.

29. CARD USAGE

29.1 Legal Classification and Jurisdictional Treatment

The BilderPay Card operates as a credit card and is classified as such under the laws and regulations of Hong Kong. Your usage of the BilderPay Card is therefore subject to the credit limit and other Card Limits determined by the Group. In other jurisdictions, the classification of the BilderPay Card may differ in accordance with local law. Such classification shall not affect the functionality or operational terms of the BilderPay Card.

29.2 Acceptance and Authorization

The BilderPay Card is accepted only by Merchants that participate in the applicable Card Network. The Group will not approve any transaction that exceeds your assigned credit limit or other applicable Card Limits.

29.3 Use at Merchants

You may use your BilderPay Card to make purchases either online or at point-of-sale (POS) terminals that accept such cards. To complete a transaction, you must follow the instructions provided by the relevant Merchant or terminal, which may require input of your card number, expiry date, CVC code, or PIN.

30. CARD BENEFITS

30.1 Discretionary Benefits

The Group may, at its sole and absolute discretion, offer certain benefits to BilderPay Card users from time to time. The Group reserves the right to introduce new benefits, modify existing benefits, or withdraw any benefit at any time without prior notice. The Group may also determine, limit, or exclude which Accounts are eligible for such benefits.

30.2 Types of Benefits

Card benefits may include, but are not limited to:

• Mobile or contactless payment functionality;

• Loyalty rewards, cashback, or other privileges;

• Instalment payment plans for purchases from designated Merchants;

• Any additional benefits as may be communicated by the Group.

30.3 Separate Applications

Certain benefits may require you to submit a separate application in order to be eligible. The Group may impose specific eligibility criteria or additional terms and conditions in respect of such benefits.

31. ATM WITHDRAWAL SERVICES

31.1 Use of ATM Services

You may use your BilderPay Card to withdraw cash at ATMs that accept such cards (“ATM Withdrawal Services”). You must follow the on-screen instructions at the ATM, which may include entering your BilderPay Card PIN. All such withdrawals are subject to limits as prescribed by the Group or the ATM provider.

31.2 Fees

ATM Withdrawals may be subject to fees imposed by the Group, which may be amended from time to time at the Group’s sole discretion without prior notice. Third-party ATM operators may also impose their own fees, which are beyond the control of the Group and for which the Group assumes no liability.

31.3 Limitation of Liability

The Group shall not be liable to you or any third party for any loss, damage, or liability (including tax consequences) arising from or in connection with the use of ATM Withdrawal Services, including any associated digital asset or currency conversions.

32. SINGAPORE CARDS FOR NON-SINGAPORE RESIDENTS

32.1 Eligibility and Residency Representation

By opting to apply for and use a BilderPay Card issued under Singapore jurisdiction, you represent, warrant, and undertake that:

• You are not a citizen or permanent resident of Singapore;

• You are not ordinarily resident in Singapore;

• You do not maintain any habitual residence, legal domicile, or business operations in Singapore; and

• You are not acting on behalf of any Singapore resident or entity.

You agree to promptly notify the Group in the event of any change to your residency or citizenship status that would render the above representations inaccurate or misleading.

32.2 No Local Promotion or Solicitation

You acknowledge and agree that:

• The BilderPay Card, the Services, the Custodian's wallet services, the Smart Contract Vault, and the App (collectively, the "BilderPay Offering") may be subject to regulatory requirements in various jurisdictions;

• You are accessing, registering for, and using the BilderPay Offering entirely on your own initiative and not as a result of any direct or indirect solicitation, marketing, or promotion carried out by the Group, its affiliates, agents, or representatives;

• Neither the Group nor any of its affiliates, partners, or related parties have conducted, nor shall be deemed to have conducted, any regulated activity in Singapore in relation to your use of the BilderPay Offering.

32.3 Card Classification and Legal Treatment

You acknowledge that the Singapore Card is categorized and operates as a debit card, and is issued by the Group as part of its Card Issuance Services in accordance with the requirements of the relevant Card Network and applicable Singapore regulatory framework. The Singapore Card does not constitute or operate as a credit facility or credit product under Singapore law.

32.4 Permitted Uses

The Singapore Card may be used by you, subject to the applicable limits and fees, for:

• The purchase of goods and services at merchants worldwide that accept cards issued under the relevant Card Network; and

• Cash withdrawals from ATMs located outside of Singapore that are compatible with the relevant Card Network, subject to availability and applicable terms.

All such usage shall be subject to these Terms and any specific terms imposed by the Card Network, ATM operators, or relevant financial institutions.

32.5 Restrictions and Compliance

You understand and agree that:

• The Group reserves the right, in its sole discretion and without liability, to suspend, revoke, or decline to issue a Singapore Card to any user if it becomes aware that such user is or has become a Singapore citizen, resident, or is otherwise ineligible;

• You remain solely responsible for ensuring that your use of the Singapore Card and the BilderPay Offering complies with the laws, regulations, and tax obligations of your country of residence;

• The Group shall not be liable for any consequences arising from your breach of local legal or regulatory requirements in connection with the Singapore Card.

33. SELF-CUSTODY WALLET AND SMART CONTRACT VAULT

33.1 General Structure and User Responsibility

If you use a Self-Custody Wallet in conjunction with the Services, including the BilderPay Card, you acknowledge and agree that the Group shall have no access to or control over the virtual assets contained in your Self-Custody Wallet, except as expressly provided under these Terms. You may, at your discretion, designate specific Acceptable Tokens (the "Locked Tokens") to be held in a Smart Contract Vault for the purpose of securing settlement obligations in connection with Card Transactions. You hereby authorize the Smart Contract to automatically deduct Locked Tokens from your Smart Contract Vault to settle any Card Balances or related charges in accordance with these Terms.

33.2 Use and Function of the Smart Contract Vault

Following the successful completion of all required know-your-customer (KYC) and other due diligence checks, you may designate Locked Tokens in your Self-Custody Wallet to be secured in the Smart Contract Vault. Upon the occurrence of a Card Transaction or other authorized transaction under the Services, you authorize the Smart Contract to deduct the corresponding amount of Locked Tokens from your Smart Contract Vault to satisfy:

• The purchase price or consideration; and

• Any associated fees, taxes, or charges as may be determined by the Group at its sole discretion.

33.3 Control and Risk Acknowledgement

You acknowledge that the Group has no control over the virtual assets maintained in your Self-Custody Wallet and assumes no responsibility for the custody, management, or security of such assets. You remain solely responsible for securing and managing your Self-Custody Wallet and its contents.

33.4 Nature of the Vault

The Smart Contract Vault:

• Does not constitute a debit card or banking facility;

• Is not linked to any savings or checking account; and

• Will not accrue or pay any interest on virtual assets held therein.

33.5 Regulatory Status

The Smart Contract Vault is not a deposit account. Virtual assets locked in the Smart Contract Vault are not protected under the Deposit Protection Scheme established pursuant to the Deposit Protection Scheme Ordinance (Cap. 581) in Hong Kong.

33.6 Responsibility and Authorization

You remain fully responsible for managing and securing your Self-Custody Wallet. However, you acknowledge that Locked Tokens within the Smart Contract Vault may be frozen, converted, and deducted for settlement purposes through automated execution by the Smart Contract, in accordance with these Terms.

33.7 Representations and Warranties

You represent, warrant, and agree that:

• The Group may unilaterally amend or modify the Smart Contract or Smart Contract Vault arrangement as necessary for operational, security, legal, or compliance reasons;

• The Group does not act as a trustee, fiduciary, or escrow agent in respect of the Locked Tokens;

• You authorize the Group to freeze, convert, and deduct Locked Tokens through the Smart Contract as necessary to fulfil obligations under these Terms;

• All assets designated as Locked Tokens are legally and beneficially owned by you, originate from lawful sources, and comply with all Applicable Law.

33.8 Operational Mechanics

When using the Smart Contract Vault:

• Locking of Assets: You consent to the locking of specified Tokens in the Smart Contract Vault to secure future transactions. These assets are inaccessible for other purposes while locked.

• Automatic Execution: Upon a Card Transaction or other Service usage, the Smart Contract will automatically freeze and deduct the equivalent value of Locked Tokens to settle the relevant obligations.

• Control: The Group retains no access to or control over your Self-Custody Wallet, except as to Locked Tokens governed by the Smart Contract.

• User Understanding: You confirm that you understand and accept the operational and technical mechanics of the Smart Contract, including all associated costs and obligations.

33.9 Amendments to the Smart Contract

The Group reserves the right to modify the Smart Contract at any time, including for purposes of improving functionality, addressing security concerns, or ensuring compliance with Applicable Law. Continued use of the Services following any such amendment shall constitute your acceptance of the revised Smart Contract.

33.10 Unlocking of Assets

Subject to full settlement of all outstanding Card Balances, fees, and related charges, you may request to terminate the control of the Smart Contract over specific Locked Tokens. Following such termination, the relevant tokens will be released, net of any blockchain or network-related fees.

34. VIRTUAL ACCOUNT

34.1 Structure and Purpose

The Group may provide eligible users with access to a Virtual Account, which functions as a sub-ledger within the Group’s main account ("BilderPay Main Account") maintained with a licensed Virtual Account Service Provider. Users may deposit fiat currency into their Virtual Account to conduct transactions with the Group, including:

• Settlement of Card Balances;

• ATM cash withdrawals; and

• Execution of Swap Transactions.

34.2 Segregation and Record-Keeping

While all fiat funds are pooled in the BilderPay Main Account, your Virtual Account:

• Will be recorded and tracked separately in the Group’s internal ledger;

• Will remain segregated from the Group’s own proprietary funds;

• Shall not be accessible to satisfy any obligation unrelated to your specific account.

The Group maintains records attributing specific Virtual Account Deposits to you, and your balance does not confer rights to funds associated with other users’ Virtual Accounts.

34.3 Regulatory Relationship

The Group maintains a contractual relationship with the Virtual Account Service Provider for the secure custody and management of fiat deposits. You acknowledge that:

• The Group is not a bank and does not provide banking services;

• Your deposits are subject to systemic, operational, regulatory, and cybersecurity risks;

• You accept these risks and waive any claims against the Group in respect of failures or breaches by the Virtual Account Service Provider.

34.4 Authority and Control

The Group may issue instructions to the Virtual Account Service Provider to:

• Freeze, convert, or transfer Virtual Account Deposits for purposes of fulfilling your obligations;

• Settle Card Balances or other transaction types described in these Terms.

The Service Provider shall be bound to act upon such instructions.

34.5 Appointment and Replacement of Service Providers

The Group may appoint, replace, or engage additional Virtual Account Service Providers at its sole discretion. You hereby authorize the Group to transfer your Virtual Account Deposits to any newly appointed provider as necessary for continued provision of the Services.

34.6 Liability and Security

The Virtual Account Service Provider is solely responsible for safeguarding your deposits. The Group and its affiliates shall not be liable for any losses, damages, or liabilities (including tax implications) resulting from the actions or omissions of the Service Provider.

34.7 No Interest

No interest shall accrue or be payable on Virtual Account Deposits maintained in the Virtual Account.

34.8 Management and Compliance

You acknowledge that your Virtual Account Deposits will be managed by the Group in accordance with these Terms, for purposes including transaction facilitation, security, and compliance with Applicable Law.

34.9 No Deposit Protection

The Virtual Account is not a deposit account, and the funds held therein are not covered by the Deposit Protection Scheme under the Deposit Protection Scheme Ordinance (Cap. 581) in Hong Kong.

34.10 Additional Acknowledgements

You represent and warrant that:

• The Group may revise the operational structure of the Virtual Account or BilderPay Main Account;

• The Group does not serve as trustee, fiduciary, or escrow agent in respect of your Virtual Account Deposits;

• You authorize the Group to act on your behalf in administering such deposits;

• You are not a party to the Group’s contract with the Virtual Account Service Provider and have no rights thereunder; and

• All Virtual Account Deposits originate from lawful sources and comply with all Applicable Law.

35. DEPOSIT TO YOUR SMART CONTRACT VAULT

35.1 Deposit Procedure

To deposit virtual assets into your Smart Contract Vault, you must comply with the instructions provided through the App, Site, or Smart Contract interface. Only Acceptable Tokens shall be permitted for such deposits.

35.2 Compliance Checks

The Group reserves the right to conduct KYC, KYT, AML/CTF, and other regulatory or risk-related checks with respect to all deposits and transactions involving the Smart Contract Vault. You agree to provide accurate, complete, and timely information upon request.

35.3 Freezing of Assets

The Group may, in its sole discretion and pursuant to these Terms, freeze part or all of your assets in the Smart Contract Vault. While frozen, you shall have no access to, or ability to transact with, the affected assets.

35.4 Representations

You represent and warrant that:

• All virtual assets deposited into the Smart Contract Vault are legally and beneficially owned by you;

• Such assets are free of liens, encumbrances, or disputes;

• The assets are not derived from any illegal activity.

35.5 Right to Refuse Deposits

The Group reserves the right to refuse any deposit into the Smart Contract Vault if:

• The assets are suspected to be illicit or non-compliant;

• Compliance or due diligence checks are incomplete or unsatisfactory.

35.6 Regulatory Cooperation

You acknowledge the Group’s legal obligation to report suspicious activities to regulatory authorities and agree to cooperate fully in the event of any investigation.

35.7 Responsibility for Asset Type

You bear full responsibility for ensuring only Acceptable Tokens are deposited. Assets that do not qualify as Acceptable Tokens may be irretrievably lost, and the Group shall bear no responsibility for such loss.

36. DEPOSITS TO YOUR VIRTUAL ACCOUNT

36.1 Deposit Instructions

To deposit fiat currency (“Virtual Account Deposits”) into your Virtual Account, you must strictly follow the instructions provided through the App or the Site. Only such deposits that constitute Acceptable Virtual Account Deposits, as defined by the Group, shall be valid for credit to your Virtual Account.

36.2 Compliance and Due Diligence

Both the Group and, where applicable, the Virtual Account Service Provider, reserve the right to perform enhanced due diligence measures, including know-your-customer (KYC), know-your-transaction (KYT), anti-money laundering and counter-terrorist financing (AML/CTF) screening in respect of all Virtual Account Deposits and related transactions. You agree to promptly provide all requested information and documentation to facilitate such compliance reviews.

36.3 Right to Freeze

The Group may, at its sole discretion and in accordance with these Terms, freeze part or all of the Virtual Account Deposits in your Virtual Account. During such period, the affected funds shall be inaccessible and unavailable for withdrawal or transaction purposes until the freeze is lifted.

36.4 Representations and Warranties

You represent and warrant that all Virtual Account Deposits made by you:

• Are legally and beneficially owned by you;

• Are free of any lien, encumbrance, or third-party claim; and

• Are not derived from or connected to any unlawful activity.

36.5 Right to Reject Deposits

The Group and/or the Virtual Account Service Provider may, at their sole discretion, reject any deposit into your Virtual Account, particularly in cases involving suspicious or potentially unlawful activity, or where due diligence checks cannot be satisfactorily completed.

36.6 Regulatory Cooperation

You acknowledge that both the Group and the Virtual Account Service Provider are legally obligated to report any suspicious activities or transactions to the appropriate regulatory or governmental authorities. You agree to fully cooperate with all related investigations and disclosure obligations.

36.7 Asset Type Responsibility

You bear sole responsibility for ensuring that only Acceptable Virtual Account Deposits are transferred to your Virtual Account. Any transfer of non-permissible assets may result in irreversible loss, for which neither the Group nor the Virtual Account Service Provider shall bear any liability.

37. RELEASE FROM YOUR SMART CONTRACT VAULT

37.1 Release and Transfer Requests

Subject to the absence of any applicable freeze or restriction, you may request the release of virtual assets from your Smart Contract Vault. You may also transfer such assets to another Custodian Account or Smart Contract Vault operated by another user, in accordance with these Terms and any relevant instructions as set out via the App, Site, or Smart Contract interface.

37.2 Accuracy of Instructions

You are solely responsible for ensuring the accuracy of any destination wallet address provided. The Group shall bear no liability for any loss, damage, or liability (including tax consequences) arising from inaccurate or incompatible withdrawal or transfer instructions.

37.3 Fees and Charges

You are responsible for any blockchain network fees or other transaction-related charges associated with a release or transfer of virtual assets from your Smart Contract Vault. Such fees may be deducted directly from your Vault balance or otherwise charged to you.

37.4 Right to Decline Requests

The Group reserves the right, in its sole discretion, to decline any request to release or transfer assets from the Smart Contract Vault, including where necessary to ensure compliance with Applicable Law or internal policy.

37.5 Limits

Withdrawals and transfers from your Smart Contract Vault are subject to such limits (including daily, monthly, or per-transaction thresholds) as the Group may establish or amend from time to time.

38. WITHDRAWALS AND TRANSFERS FROM YOUR VIRTUAL ACCOUNT

38.1 Withdrawal to Bank or Financial Accounts

You may request withdrawal of fiat funds (i.e., Virtual Account Deposits) from your Virtual Account to a bank or similar financial institution account in your own name. Such withdrawals may be processed:

• Directly by the Virtual Account Service Provider; or

• Through a Third-Party Payment Provider, selected at the Group’s sole discretion.

Unless otherwise approved by the Group, withdrawals to third-party recipients are not permitted.

38.2 Relationship and Responsibility

Withdrawals are facilitated by the Group solely for your convenience. However, the actual withdrawal service is provided by the Virtual Account Service Provider or Third-Party Payment Provider, who act as direct service providers to you. The Group’s role is limited to integrating the App and Services with those third parties to enable withdrawal functionality. You understand that all withdrawal instructions are ultimately directed to and executed by those providers.

38.3 Data Sharing Consent

You consent to the sharing of your personal data and transaction details (including your name, identification data, contact details, recipient information, and transaction amount) between:

• The Group;

• The Virtual Account Service Provider;

• Any relevant financial institution or bank; and

• Any applicable Third Party Payment Provider,

for the purpose of effecting and facilitating your withdrawal.

38.4 Ongoing Data Updates

You also consent to the Group transmitting your updated personal information to the Virtual Account Service Provider and/or relevant payment providers whenever changes are made to your records.

38.5 Third Party Data Handling

Collection, processing, and retention of your personal information by any third-party provider is subject to their respective privacy policies and terms of service. The Group bears no responsibility for the privacy practices of such parties.

38.6 Withdrawal Authorization

By submitting a withdrawal request, you:

• Instruct the Virtual Account Service Provider or relevant Third-Party Payment Provider to process the withdrawal; and

• Authorize the Group to deduct the requisite amount from your Virtual Account and to instruct the appropriate transfer of funds on your behalf.

38.7 Unauthorized Transactions

You must notify the Group immediately if you become aware of an unauthorized withdrawal from your Virtual Account.

38.8 Limits

The Group may impose, vary, or remove withdrawal limits, including limits on frequency, amount, or transaction type, at any time.

38.9 Liability and Third-Party Terms

Your rights and liabilities with respect to withdrawals shall be governed by the applicable terms of the Virtual Account Service Provider and/or Third-Party Payment Provider, as applicable. The Group disclaims all responsibility and liability in relation to deficiencies in third-party services.

38.10 Return of Funds

If a payment is rejected or returned by a financial institution or provider, the returned funds will be credited back to your Virtual Account.

38.11 Disclaimer of Liability

To the maximum extent permitted by Applicable Law, the Group shall not be liable for any losses or damages incurred in connection with your use of withdrawal services, or any failure, delay, or deficiency in the provision of services by the Virtual Account Service Provider or any Third-Party Payment Provider.

38.12 Suspension of Access

The Group may suspend your ability to access withdrawal services at any time, including in cases of suspected fraudulent, illegal, or non-compliant conduct. Notification of such suspension may be made after the fact, and the Group may notify the relevant provider(s) accordingly.

38.13 Handling Fees

The Group reserves the right to impose a handling fee for processing withdrawals, in accordance with its prevailing fee schedule. You authorize the Group to deduct such fees from the withdrawal amount or from your Virtual Account Balance.

38.14 Amendments

The Group may amend the terms governing withdrawals at any time by notice. Where applicable, and subject to legal requirements, the Group will provide at least thirty (30) calendar days' prior notice of any material changes affecting fees, liabilities, or obligations. Your continued use of withdrawal services following the effective date of any such change constitutes acceptance.

38.15 Transfers to Other Users

Subject to the provisions of these Terms, you may request that Virtual Account Deposits be transferred to the Virtual Account of another user who maintains an account with the Group. By doing so, you:

• Instruct the Virtual Account Service Provider (via the Group) to process the transaction; and

• Authorize the Group to debit the relevant amount from your Virtual Account and credit it to the recipient’s Virtual Account.

39. BALANCES AND SETTLEMENT OF CARD BALANCES AND OTHER TRANSACTIONS

39.1 Balance Types and Limits

Your Wallet Balance held in your Custodian Account(s), your Smart Contract Vault Balance held in the Smart Contract Vault, and your Virtual Account Balance maintained in the Virtual Account (collectively, the “Account Balances”) may each be subject to minimum or maximum thresholds established by the Group and/or the relevant service providers (including the Custodian and Virtual Account Service Provider). Such limits shall be detailed on the App or the Site and may be amended from time to time at the sole discretion of the Group or the relevant third-party service provider.

39.2 Authorized Deductions and Conversions

You hereby expressly authorize the Group, upon the execution of a Card Transaction or any other transaction under the Services, to:

• Deduct the relevant amount from any of your Account Balances;

• Convert such amounts, as necessary, into stablecoins, fiat currency, or virtual assets, at the prevailing exchange rate determined by the Group; and

• Apply such converted or deducted amounts to settle any Card Balances or other obligations arising under the Services.

This authorization includes the use of your Custodian Account(s), Smart Contract Vault (via the Smart Contract), and/or Virtual Account for the satisfaction of obligations including but not limited to: settlement of transactions, payment of service fees, and security deposits required by the BIN Sponsor or other financial counterparties.

39.3 Regulatory and Risk Management Actions

You further authorize the Group to deduct from any of your Account Balances such fees, costs, or expenses that the Group may incur in connection with:

• Risk management or fraud prevention measures;

• Compliance with Applicable Law; or

• Other regulatory or administrative actions undertaken in good faith to safeguard your assets or the integrity of the Services.

39.4 Right to Manage Assets

The Group expressly reserves the right to manage your Account Balances to facilitate the final settlement of any Card Balances or Service-related obligations. Such rights include, without limitation:

• Freezing all or part of your assets;

• Imposing restrictions on the transfer or conversion of such assets;

• Converting assets into one or more stablecoins, fiat currencies, or other virtual assets.

These measures may be taken as deemed necessary by the Group to ensure compliance with these Terms and proper performance of its obligations.

39.5 Applicable Fees

You acknowledge and agree that any deduction or conversion of your Account Balances may incur fees, charges, or other costs, including but not limited to:

• Blockchain or network fees;

• Third-party processor or service provider charges;

• Foreign exchange rate variations and spreads;

• Other customary transactional or administrative charges.

Such fees shall be clearly itemized and disclosed, where applicable, through the App or the Site.

39.6 Notification of Actions

The Group will provide you with notice - via the App, email, or the Site - of any action taken to freeze, deduct, or convert your Account Balances. Such notice will include:

• The type and amount of assets affected;

• The exchange rate or conversion value applied (if applicable); and

• Any related fees or deductions incurred.

39.7 Responsibility and Liability

You accept full and sole responsibility for any and all consequences, liabilities, or losses (including tax liabilities) arising from the deduction, conversion, or freezing of your Account Balances pursuant to this Clause. You acknowledge that the Group shall bear no liability to you or any third party in connection with any such actions, provided that such actions are taken in good faith and in accordance with these Terms.

40. OTHER THIRD PARTY SERVICES

40.1 Provision and Scope

In addition to the Custodian Account(s), Self-Custody Wallet and Smart Contract Vault, and the Virtual Account, the Group may, at its sole discretion, make available to you certain ancillary services provided by third-party service providers (“Third Party Service Providers”), which may be accessible via the App (“Other Third Party Services”).

These services are facilitated by the Group solely for your convenience. However, you acknowledge that all Other Third Party Services are provided directly by the relevant Third Party Service Provider, and not by the Group.

40.2 Access and Integration

Where you hold an account with a Third Party Service Provider (“TPSP Account”), you may link and access your TPSP Account through the App and provide instructions in respect of the Other Third Party Services, in lieu of accessing the TPSP Account directly. If you choose to open a TPSP Account via the App, you enter into a direct contractual relationship with the relevant Third Party Service Provider.

The Group acts solely as an integration service provider, facilitating technical access to and interaction with the Third Party Service Providers through the App, but does not itself provide the Other Third Party Services.

40.3 Data Sharing and Consent

By using the Other Third Party Services, whether through an existing or newly created TPSP Account, you expressly authorise the Group to share your personal and transaction information (e.g., name, contact details, identification data, and transaction amounts) with the relevant Third Party Service Provider, as necessary:

• To create, link, or update your TPSP Account;

• To process transactions initiated through the App;

• To comply with the Third Party Service Provider’s operational, regulatory, or technical requirements.

You further agree that updates to your personal information held by the Group may be shared with the relevant Third Party Service Provider for continued service provision.

Collection and use of personal data by any Third Party Service Provider is subject to that party’s privacy policy and terms and conditions. The Group is not responsible for the handling of your data by such third parties.

40.4 Transaction Processing

When you initiate a transaction involving Other Third Party Services via the App:

• You instruct either the Group or the Third Party Service Provider (as applicable) to process the transaction;

• You authorise the Group to debit or credit your Custodian Account(s), Self-Custody Wallet (subject to the Smart Contract Vault), and/or Virtual Account as required to complete the transaction;

• You are responsible for ensuring sufficient funds (in fiat or Acceptable Tokens) are available and that all transaction information is accurate and complete.

The Group is not obligated to process transactions if sufficient funds are unavailable or if doing so would, in its reasonable view, result in regulatory breach or financial risk.

40.5 Authorisation, Limits, and Liability

You must immediately notify the Group of any unauthorised transactions related to Other Third Party Services. The Group may impose, vary, or remove limits on transaction amounts, frequency, or features related to such services at its discretion.

Your rights and obligations with respect to any transaction instructions are governed by the terms of the relevant Third Party Service Provider. If a Third Party Service Provider returns any funds to the Group, those funds will be re-credited to your Account.

To the fullest extent permitted by Applicable Law:

• The Group disclaims all liability for losses, damages, or deficiencies arising from your use of, or reliance on, Other Third Party Services;

• The Group is not responsible for any errors, delays, or failures in the provision of such services by the Third Party Service Providers;

• You acknowledge and accept that the Third Party Service Providers are solely responsible for service performance and outcomes.

40.6 Suspension and Termination

The Group reserves the right to suspend or terminate access to Other Third Party Services or any TPSP Account access through the App, with immediate effect and without prior notice, if:

• Your Account is suspended or closed;

• You are suspected of fraudulent or illegal activity;

• Such action is necessary to comply with Applicable Law or the Group’s internal policies.

Suspension or termination of access through the Group does not affect your separate relationship with the Third Party Service Provider. The Group will use reasonable efforts to notify you and/or the Third Party Service Provider following any such action.

The provision of Other Third Party Services shall terminate upon the earliest of:

• Closure or termination of your Account;

• Suspension of the service for a period exceeding twelve (12) consecutive months (or such other period as the Group may determine);

• Termination by notice issued by the Group via the App or other designated communication channels.

You remain liable for all obligations and liabilities accrued prior to such termination.

40.7 Fees and Amendments

The Group may charge handling or processing fees for Other Third Party Services as specified in its prevailing fee schedule available via the App or the Site. You authorise the Group to deduct such fees and any associated charges from the relevant transaction proceeds or any of your Accounts.

The Group may amend these terms governing Other Third Party Services at any time by notice. Where required under Applicable Law, at least thirty (30) calendar days’ prior notice shall be given for changes affecting fees, your liabilities, or your obligations. Continued use of the services following the effective date of any amendment constitutes acceptance thereof.

41. REGIONAL AVAILABILITY AND SERVICE LIMITATIONS

Please be advised that the availability, scope, and functionality of the Services referenced in these Terms may vary depending on your jurisdiction, region of residence, or applicable regulatory framework. As such:

1. Service Restrictions by Region
   Certain features, functionalities, or complete service offerings may be restricted, limited, modified, or entirely unavailable to you based on your geographic location. The Group reserves the right, at its sole discretion and subject to Applicable Laws, to determine which Services or functions are made available in specific jurisdictions. Access to some Services may be disabled, hidden, or otherwise rendered inaccessible to users in certain regions without notice.

2. Variations in User Experience
   You acknowledge and accept that the Services and user interface presented to you whether via the App, Site, or any other platform may differ from those offered to users in other regions or jurisdictions. Such variations may include, but are not limited to, access to specific products, supported payment methods, integrations with Third Party Service Providers, or regulatory disclosures.

3. Forward-Looking Service Provisions
   Certain provisions of these Terms may describe or reference Services, features, functionalities, or integrations that are under development, in a pilot phase, or otherwise not yet deployed or made available to all users or to users in your jurisdiction. Inclusion of such references in these Terms does not constitute a representation, warranty, or undertaking by the Group that such Services or functionalities will become available to you, or to users generally, within any specific timeframe or at all.

4. Regulatory and Technical Limitations
   The Group may be required to withhold or modify access to certain Services in your region due to legal, regulatory, technical, or operational constraints. The Group shall bear no liability for any such limitations or for any loss, damage, or inconvenience you may incur as a result of Services not being made available in your jurisdiction.