ANTARCTIC WALLET PLATFORM TERMS OF USE

Contents

Preamble

This document is a public offer of Antarctic Wallet LLC, a legal entity incorporated and operating under the legislation of the Kyrgyz Republic, with its registered address at: Kyrgyz Republic, Bishkek, Sverdlovsky District, 429 Frunze Street, registration number 315372-3301-ООО, taxpayer identification number 02104202510171, holding virtual asset exchange operator license No. 167 dated 20 May 2025 issued by the Financial Market Regulation and Supervision Service under the Ministry of Economy and Commerce of the Kyrgyz Republic (the “Company”).

The Offer is addressed to any individual who meets the requirements of Section 5 of the Offer (the “User”) and contains all the terms of the agreement concluded between the User and the Company (the “Agreement”).

The Agreement is a contract of adhesion (Article 387 of the Civil Code of the Kyrgyz Republic). The User accepts its terms as a whole, without exceptions or reservations, by performing the actions specified in Section 3 of the Offer. The Agreement is deemed concluded from the moment of such acceptance.

The Company recommends that the User read the Agreement carefully before starting to use the Antarctic Wallet platform and pay particular attention to Section 4 (Risk Disclosure), Section 6 (Identification, Compliance and Monitoring), Section 8 (Trades in Virtual Assets), including the time frame for execution of Orders (clause 8.3), clause 1.6 and Section 11, which establish the procedure for unilateral amendment of the Agreement, the Fee Schedule and limits, Section 15 (Suspension and Termination), including the procedure for termination of the Agreement by the Company, Section 17 (Personal Data and Information Exchange), including consent to the processing of personal data, and Section 18 (Warranties and Liability). If the User does not agree with any term of the Agreement, the User should refrain from using the Platform.

An extract from the Unified State Register of Legal Entities and information on the Company’s license are available via the links posted on the Platform.

1. General Provisions

1.1. Subject Matter. This Offer sets out the terms on which the Company provides the User with access to the Platform and renders the Services, as well as the terms on which the Company and the User enter into transactions in virtual assets.

1.2. Legal Status of the Company. The Company is a virtual asset exchange operator and operates on the basis of the license specified in the preamble. The Company enters into transactions for the purchase, sale and exchange of virtual assets with the User in its own name and in its own interest, acting as the User’s counterparty in each such transaction.

The Company is not a bank or other credit institution, a payment system, a money transfer operator, a broker, a trustee, or an investment, financial or tax advisor. The Company does not open bank accounts, does not carry out banking operations, does not carry out money transfers, and does not accept or disburse cash.

The Company does not act as the User’s agent, attorney or representative, does not accept funds or virtual assets as deposits, and does not carry out trust management of the User’s property.

1.3. Services of Service Providers. Certain functions of the Platform expressly listed in Section 9 are provided by Service Providers. In respect of such functions, the Company only ensures information and technology interaction between the User and the Service Provider and is not a party to the User’s transaction with the Service Provider.

1.4. Allocation of Responsibility. The parties proceed from the following allocation of responsibility: (i) the Company is the User’s counterparty in transactions for the purchase, sale and exchange of virtual assets (Section 8) and is responsible for the operation of the Platform to the extent established by Section 18; (ii) Service Providers independently and in their own name provide the User with the services listed in Section 9, including the issuance and servicing of cards, the execution of payments and the transfer of funds, and such services fall within the exclusive responsibility of the relevant Service Providers; (iii) Developers are independently responsible for the Mini Apps they have placed on the Platform (Section 10), including their content, operability and the performance of obligations to the User; (iv) the User is responsible for the accuracy of the information provided, the lawful origin of the funds used, the security of access to the Account, the correctness of transaction details, and compliance with the legislation applicable to the User; (v) Participants independently determine the terms of Reassignment and are responsible for the accuracy of their representations, and the Company is responsible only for executing the Reassignment Request in accordance with its content (Section 13).

1.5. Composition of the Agreement. The Agreement consists of this Offer and the following annexes, each of which forms an integral part of this Offer: (i) Annex No. 1 “Fee Schedule”; (ii) Annex No. 2 “Prohibited Jurisdictions”; (iii) Annex No. 3 “Risk Disclosure”; (iv) Annex No. 4 “Referral Program Terms.”

The annexes are posted on the Platform. In the event of a conflict between the Offer and an annex, the Offer prevails, except for the amounts of the Company’s fees and the spread, which are determined by the Fee Schedule.

The current amounts of the Company’s fees, limits, minimum and maximum transaction amounts, the list of Supported Assets and supported blockchain networks, the range of available Services, the time frames for execution of Orders and other parameters of the provision of Services are displayed in the Platform interface and on the relevant pages of the Company’s website https://antarcticwallet.com. Such information constitutes terms of the Agreement and applies in the version in effect at the time the relevant Order is confirmed. The parameters applicable to a transaction are communicated to the User before the Order is confirmed. The amounts of the Company’s fees are changed in accordance with clause 11.3, and limits in accordance with clause 11.5. The Company stores information on the parameters in effect at the time of each transaction for the period established by clause 6.11 and provides it to the User upon request.

1.6. Amendment of the Agreement. The Company may unilaterally amend the Agreement at any time by posting a new version on the Platform. The new version takes effect from the moment it is posted, unless a later date is specified in it. The User undertakes to monitor amendments to the Agreement independently. The Company may, but is not obliged to, additionally notify the User of amendments by email or by other means provided for in Section 17. Continued use of the Platform after the amendments take effect constitutes the User’s consent to them; if the User disagrees with the amendments, the User may terminate the Agreement in accordance with clause 15.3. An Order accepted before the amendments take effect is governed by the version of the Agreement in effect at the time of its acceptance.

Amendments are not deemed material if they: (i) improve the User’s position; (ii) are required under legislation, requirements of authorized bodies, or rules of payment systems or other third parties; (iii) relate to a new function of the Platform; (iv) clarify wording without changing the substance of the terms. Such amendments take effect from the moment of posting.

An Order accepted by the Company before the amendments take effect is governed by the version of the Agreement in effect at the time the Order was accepted.

Continued use of the Platform after the amendments take effect constitutes the User’s consent to the new version. If the User does not agree with the amendments, the User may terminate the Agreement in accordance with clause 15.3.

1.7. Interpretation. Headings are for convenience only and do not affect interpretation. The words “including,” “among other things” and “in particular” mean “including without limitation” and do not limit the general provision preceding them. A reference to a regulatory legal act means a reference to such act as amended and in effect. Periods calculated in days are calendar days unless expressly stated otherwise.

2. Terms and Definitions

The following terms are used in the Agreement:

“Account” means the User’s account on the Platform.

“Agreement” means this Offer and its annexes, as accepted by the User in accordance with Section 3.

“Antarctic Card” means a payment card (electronic means of payment) provided by the Issuer to the User upon the User’s application submitted via the Platform interface, in accordance with clause 9.3. An Antarctic Card may be provided without a physical medium (virtual Antarctic Card) or with a physical medium (physical Antarctic Card).

“Authorized Body” means the state body of the Kyrgyz Republic that regulates and supervises the circulation of virtual assets.

“Balance” means the records in the Company’s information system that reflect the quantity of Supported Assets belonging to the User and confirm that they belong to the User.

“Competent Authority” means the Authorized Body, the Financial Intelligence Unit, a court, or a law enforcement or other state authority acting within its powers.

“Consent” means the User’s consent to the processing of personal data provided for in clause 17.2.

“Developer” means a person who has placed a Mini App on the Platform. A Developer is not a Service Provider.

“EDD” means enhanced due diligence measures in respect of the User and the User’s transactions.

“Fee Schedule” means Annex No. 1, including the amounts of the Company’s fees displayed in the Platform interface and in the relevant sections of the Company’s website.

“Financial Intelligence Unit” means the State Financial Intelligence Service under the Ministry of Finance of the Kyrgyz Republic.

“High-Risk Country” means a state or territory included in the list of high-risk countries approved by the Financial Intelligence Unit (Section II of Annex No. 2).

“Issuer” means a bank or other organization that holds the necessary permits and issues and services the Antarctic Card or the Third-Party Issuer Card. The Company may interact with the Issuer either directly or through a Service Provider that has engaged the Issuer.

“KYC” means identification and verification of the User.

“Mini App” means a software product of a third party that is placed on the Platform and accessible to the User via its interface, in accordance with Section 10.

“Order” means an instruction generated by the User in the Platform interface to enter into a Trade or other transaction.

“PEP” means a politically exposed person, as well as a member of such person’s family and a person close to such person (close relative, business partner, official representative) within the meaning of the legislation of the Kyrgyz Republic on countering the financing of criminal activities and the legalization (laundering) of criminal proceeds.

“Platform” means the set of Antarctic Wallet software and services, including mobile applications for the iOS and Android operating systems, the web application, the Telegram Mini App, the bot in the Telegram app, the website https://antarcticwallet.com, and other access channels that the Company may make available in the future.

“Prohibited Activity” means the activities and transactions listed in Section 14.

“Prohibited Jurisdiction” means a jurisdiction in which the provision of the Platform or access to it is prohibited by applicable law, a jurisdiction that is the subject of comprehensive sanctions or an embargo, and a jurisdiction listed in Section I of Annex No. 2. Jurisdictions in which certain Services are unavailable (clause 9.10) and High-Risk Countries are not in themselves Prohibited Jurisdictions.

“Prohibited Person” means a person who: (i) is included in the sanctions lists maintained by the United Nations, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC), the European Union or HM Treasury of the United Kingdom, or in a sanctions list determined by the legislation of the Kyrgyz Republic; (ii) is located in a Prohibited Jurisdiction or is a citizen or resident thereof; (iii) is controlled by a person referred to in sub-clause (i) or acts in the interests of such person; (iv) is a person with whom the establishment of business relations is prohibited by the legislation of the Kyrgyz Republic or by a requirement of the Authorized Body.

“Quote” means the rate at which the Company offers the User to enter into a Trade, communicated to the User before the Order is confirmed, and, in respect of a Trade executed automatically in accordance with clause 9.3, the rate in effect at the time of its execution and reflected in the transaction history.

“Reassignment” means a change in the assignment of a Referral in accordance with Section 13.

“Referral Program” means the program conducted by the Company in accordance with Section 12 and Annex No. 4. The terms “Participant” and “Referral” are used as defined in Annex No. 4.

“Scoring” means an automated assessment of the risk level of a Virtual Asset, a virtual wallet address or a transaction, carried out using the software of a provider of AML/KYT services.

“Screening Report” means the result of Scoring provided to the User upon the User’s request in accordance with clause 9.8.

“Service Provider” means a legal entity engaged by the Company and holding the necessary statuses, permits or licenses that ensures the operation of certain services of the Platform or independently provides the User with services available through the Platform.

“Services” means the services and functions provided to the User by the Company or Service Providers on or through the Platform.

“Simple Electronic Signature” means a one-time code sent by the Company to the User in accordance with Section 3.

“Supported Asset” means a Virtual Asset available for transactions on the Platform. The list of Supported Assets and supported blockchain networks is displayed in the Platform interface and on the Company’s website. The list of Supported Assets includes only Virtual Assets in which transactions are permitted by the legislation of the Kyrgyz Republic.

“Third-Party Issuer Card” means a payment card of a third-party issuer without a physical medium, usually with a predetermined face value, which the User orders via the Platform interface in accordance with clause 9.4. A Third-Party Issuer Card is not an Antarctic Card.

“Trade” means a transaction for the purchase, sale or exchange of Virtual Assets entered into between the Company and the User.

“Transaction” means any operation performed using the Platform, including a Balance top-up, transfer, withdrawal, payment and Trade.

“User” means an individual who has accepted the Offer.

“Verification Level” means the KYC level completed by the User in accordance with clause 6.1.

“Virtual Asset” means a virtual asset within the meaning given by the legislation of the Kyrgyz Republic on the circulation of virtual assets, including cryptocurrencies and stablecoins.

3. Acceptance of the Offer and Electronic Signature

3.1. Acceptance of the Offer. Acceptance of the Offer means the performance by the User of any of the following actions: (i) ticking the box confirming agreement with the Agreement upon registration; (ii) clicking the button that completes the registration of the Account, provided that a link to the Offer was made available to the User before the button was clicked; (iii) commencing use of the Services after registration of the Account. Acceptance is full and unconditional; acceptance of the Offer with reservations or in part is not permitted.

By performing an action specified in sub-clause (i) or (ii), the User simultaneously gives the Company Consent on the terms of clause 17.2. If the Account was created without the performance of such actions, Consent is given when the User first confirms a transaction with a simple electronic signature.

3.2. Acceptance of Individual Trades. Each Trade and each transaction requiring confirmation is entered into on the terms of the Agreement and is confirmed by the User separately in accordance with clause 8.1. No separate document is drawn up for each Trade.

3.3. Simple Electronic Signature. The parties acknowledge that the User’s entry of a one-time code sent by the Company to the phone number, email address or other verified communication channel linked to the Account constitutes the User’s simple electronic signature and is recognized as equivalent to the User’s handwritten signature. The Agreement constitutes an agreement of the parties on the use of a simple electronic signature.

Procedure for verifying a simple electronic signature: the Company sends the User a one-time code valid for a limited time displayed in the interface; the signature is deemed confirmed if the code entered matches the code sent before its validity period expires. The fact that the code was sent and correctly entered is recorded in the logs of the Company’s information systems.

3.4. Evidence. Records of the Company’s information systems, including event logs and information on access sessions and on the parameters of Orders and Trades, constitute proper and sufficient evidence of the User’s expression of will and of the content of the transactions performed, unless the User proves otherwise.

3.5. Legal Capacity. By accepting the Offer, the User confirms that the User has the legal capacity necessary to enter into the Agreement and to perform the transactions provided for therein.

4. Risk Disclosure

4.1. Risk Warning. Virtual assets are not a monetary unit or legal tender, are not backed by the state and are not guaranteed by the Company. The acquisition of virtual assets may result in the total loss of the funds and other objects of civil rights transferred in exchange for virtual assets, including as a result of the volatility of the value of virtual assets, technical failures (errors) and unlawful acts, including theft.

4.2. Acknowledgment. Before entering into the first Trade, the User confirms that the User has read the risk warning by ticking a separate box in the Platform interface. The fact and date of confirmation are recorded by the Company and stored for the periods established by clause 6.11. The Risk Disclosure (Annex No. 3) is also posted in the Platform interface and on the home page of the Company’s website or via a link posted on that page.

4.3. Specific Risks. The User accepts, in particular, the following risks: (i) volatility: the value of Virtual Assets may change sharply, including down to zero; (ii) irreversibility: transactions in blockchain networks are, as a rule, irreversible, and funds sent to incorrect details cannot be recovered; (iii) regulatory risk: changes in legislation may restrict or terminate access to certain Services or to the Platform as a whole; (iv) technology risk: failures, updates and overloads of networks and of Service Providers’ systems may cause delays in, or make it impossible to perform, transactions; (v) cyber risk: Virtual Assets are an attractive target for fraud and cyberattacks; (vi) third-party risk: non-performance of obligations by Service Providers, banks and payment systems; (vii) asset risk: termination of support, delisting, a split (fork) of the network, depreciation or cessation of circulation of a Supported Asset; (viii) restrictive measures risk: suspension of transactions and freezing of assets on the grounds provided for in Section 6; (ix) jurisdictional risk: the legal regime of virtual assets and transactions with them differs depending on the jurisdiction and may change, and the User independently determines whether use of the Platform is permissible under the law applicable to the User and independently fulfills the obligations applicable to the User, including tax and reporting obligations; (x) assessment risk: the results of automated risk assessment are probabilistic, differ among providers of analytical services and may not coincide with the decisions of third parties receiving the funds; (xi) Mini App risk: Developers may fail to perform their obligations to the User, and anything transferred to a Developer may prove non-refundable (Section 10); (xii) counterparty risk: the execution of Trades and the safekeeping of Supported Assets recorded on the Balance depend on the Company’s performance of its obligations, and Supported Assets are not insured and are not covered by a deposit protection scheme (clause 7.3).

4.4. No Recommendations. The Company does not provide Users with advice that may induce them to acquire or dispose of specific types of Virtual Assets. Any information posted on the Platform is for reference purposes only and does not constitute an investment, legal or tax recommendation, offer or guarantee. The User makes decisions on transactions independently and at the User’s own risk.

4.5. User’s Level of Knowledge. Before granting access to certain Services, the Company may invite the User to confirm a sufficient level of knowledge (competence) to perform transactions with Virtual Assets by completing a questionnaire (test) posted in the Platform interface or on a separate page of the Company’s website, a link to which is communicated to the User.

Where completion of the questionnaire is required by the legislation of the Kyrgyz Republic, it is a mandatory condition for entering into the relevant Trades. The Company may make the performance of certain transactions conditional on completion of such questionnaire and refuse to perform them in the event of a negative result. The result is recorded by the Company and stored for the periods established by clause 6.11. The Company may invite the User to complete the questionnaire again when the range of transactions available to the User is expanded or after 12 months have elapsed.

Completion of the questionnaire does not constitute a recommendation by the Company and does not indicate that transactions with Virtual Assets are suitable for the User.

5. Access to the Platform and Account

5.1. User Requirements. A User may be an individual who: (i) has reached 18 years of age; (ii) is not a Prohibited Person and is not located in a Prohibited Jurisdiction; (iii) has provided accurate and up-to-date information and contact details; (iv) does not use software or hardware to circumvent restrictions established by the Company, including location spoofing tools; (v) does not engage in Prohibited Activity; (vi) has not had an Account previously blocked or deleted by the Company for breach of the Agreement.

5.2. User Representations. The User represents to the Company that, as of the date of acceptance of the Offer and as of the date of each transaction: (i) the User is not a Prohibited Person, is not controlled by a Prohibited Person and does not act in the interest of a Prohibited Person; (ii) the User is not a PEP or has notified the Company of its PEP status; (iii) the User acts in its own name, in its own interest and for its own account, and not on the instructions of, in the interest of or for the account of a third party, and does not conceal or misrepresent information about the beneficial owner or about the person in whose interest transactions are carried out; (iv) the funds and Virtual Assets used by the User on the Platform were obtained lawfully and belong to the User on a lawful basis; (v) the User complies with the legislation of the state of its citizenship and permanent residence, including currency and tax legislation.

These representations are material to the Company. If any of them is untrue, the Company is entitled to apply the measures provided for in clause 6.8 and to terminate the Agreement in accordance with clause 15.4.

5.3. Politically Exposed Persons. A relationship with a User who is a PEP may be established and continued only on the basis of written approval of an authorized officer of the Company. Enhanced due diligence measures apply to such a User, including establishing the source of funds and ongoing enhanced monitoring of transactions. The User shall notify the Company without delay upon acquiring or losing PEP status.

5.4. One Account. The User may create and use only one Account. The Company takes measures to prevent any one person from creating two or more Accounts. Creating or using multiple Accounts constitutes a breach of the Agreement.

5.5. Access Security. The User shall keep secure the means of access to the Account, including passwords, one-time codes and the devices on which the application is installed, and shall not disclose them to third parties. Transactions confirmed with the User’s Simple Electronic Signature are deemed to have been carried out by the User.

The Company is not liable for the consequences of unauthorized access to the Account unless such access was caused by a breach of obligations on the part of the Company. The User shall notify the Company without delay through the support service of any suspected unauthorized access or of any loss of the means of access; from the moment such notice is received, the Company takes the measures available to it to restrict transactions.

5.6. Telegram Identifier. Where the Platform is accessed via Telegram, the Account and the Balance are linked to the Telegram identifier (Telegram ID), which is unique. If a Telegram account is deleted and a new one is created, including with the same username, the identifier changes, and such account is treated as a new account unrelated to the previous one.

For Users who have completed KYC and/or have a Balance, linking the Account to an email address is mandatory; where technically feasible, two-factor authentication is also mandatory. If the Account is linked to an email address, access may be restored even after the Telegram ID has changed; if it is not, deletion of the Telegram account may result in irreversible loss of access to the Account and the Balance.

To restore access, the User shall provide verifiable evidence that the former Account belongs to the User. The Company decides on restoration provided that the evidence submitted is sufficient and verifiable. Restoration of access does not replace KYC procedures: rights to the Balance are confirmed on the basis of the information obtained in the course of identification.

5.7. Personal Use. The Services are provided to the User solely for personal needs not related to business activities. It is prohibited to use the Account and the Services to provide services to third parties, to operate as an exchange office, payment agent or payment processor, or to carry out transactions on behalf of, on the instructions of or in the interest of third parties. For transactions related to business activities, the Company offers separate products under separate agreements.

6. Identification, Compliance and Monitoring

6.1. Customer Due Diligence. As a virtual asset exchange operator, the Company applies customer due diligence measures in accordance with the legislation of the Kyrgyz Republic on countering the financing of criminal activities and the legalization (laundering) of criminal proceeds, the legislation on the circulation of virtual assets and the terms of its license.

Customer due diligence measures include, in particular: (i) identification and verification of the User; (ii) obtaining information on the purpose and intended nature of the business relationship; (iii) identification of the beneficial owner and, where applicable, identification of the representative and verification of the representative’s authority; (iv) documenting the information obtained; (v) conducting due diligence on an ongoing basis throughout the business relationship, including analysis of whether the transactions carried out are consistent with the information about the User, the User’s financial position and source of funds.

The Company establishes the following Verification Levels: (i) “Basic”: confirmation of a phone number, submission of an identity document and passing a facial image check, including a check that the image is obtained from a live person; (ii) “Extended”: in addition to “Basic”, submission of the information required to provide Services offered in particular states or using the payment infrastructure of particular states, including a phone number and identity document details issued by the relevant state; (iii) “Advanced”: in addition to “Extended”, confirmation of information about the User through a state information system of the relevant state accessible to the Company or a Service Provider.

The list of accepted documents, as well as the Services and limits available at each Verification Level, are displayed in the Platform interface. Completion of a Verification Level does not limit the Company’s right to request additional information and documents and to apply EDD and the measures provided for in clause 6.8.

6.2. User Obligations. The User shall provide accurate, complete and up-to-date information and documents requested by the Company for the purposes of customer due diligence, keep them up to date and provide additional information and documents at the Company’s request, including after a transaction has been carried out.

The Company may request information and documents required by Service Providers, Issuers, banks and payment systems to perform the obligations imposed on them, and may transfer such information and documents to those persons. Failure to provide such information and documents constitutes grounds for refusal to provide the relevant Service.

6.3. Consequences of Failure to Provide Information. If the User fails to provide the information and/or documents required for customer due diligence, the Company takes one of the following decisions: (i) not to establish a business relationship with the User and to refuse to accept the User for service; (ii) to suspend or terminate the business relationship and terminate the Agreement; (iii) not to carry out the transaction. The Company reports the decision taken to the Financial Intelligence Unit in the manner and within the time limits established by law.

6.4. Risk Category. The Company assigns the User a risk category (level) in accordance with the legislation of the Kyrgyz Republic and the Company’s internal rules. The risk category determines the scope and frequency of the information and documents requested, the transaction monitoring parameters and the applicable limits.

The Company may review the risk category throughout the business relationship, including based on analysis of the transactions carried out, and may apply simplified customer due diligence measures where permitted by law.

6.5. Enhanced Due Diligence and Source of Funds. The Company applies EDD, in particular, in the case of large transaction amounts, unusual transactions, signs of transaction splitting, information that funds originate from cash, classification of the User as high-risk, and in other cases of increased risk. EDD may include requesting additional documents, confirmation of the source of funds and source of wealth, video identification and entry into a separate written agreement.

The scope of due diligence depends on the amount and nature of the transaction. Threshold values are determined by law and the Company’s internal rules and are displayed in the Platform interface. The Company may refuse to carry out a transaction if the lawful origin of the funds has not been confirmed.

6.6. Sanctions Screening and High-Risk Countries. The Company screens Users and their counterparties against sanctions lists and lists of persons involved in the financing of criminal activities and the legalization (laundering) of criminal proceeds, as well as against the list of high-risk countries approved by the Financial Intelligence Unit. With respect to persons from high-risk countries, the Company applies the measures provided for by law, including enhanced due diligence measures, refusal to establish relationships and to carry out transactions, and reporting such transactions to the Financial Intelligence Unit regardless of their amount.

6.7. Scoring. Users’ transactions with Virtual Assets are checked using the software of an AML/KYT service provider designated by the Authorized Body. Percentage scoring values are determined by the Authorized Body.

The User acknowledges and agrees that the Scoring result is a probabilistic assessment of the level of risk and not the establishment of a fact, and that the Company may rely on such assessment when making decisions, including when refusing to carry out a transaction and when freezing assets.

6.8. Measures Applied by the Company. For the purpose of complying with legal requirements and the terms of its license, the Company may at any time, with or without prior notice to the User: (i) request documents and explanations and suspend a transaction, withdrawal of funds or access to the Platform until they are provided and the review is completed; (ii) refuse to accept or execute an Order, or to provide a Service; (iii) suspend or block the Account; (iv) freeze (block) the User’s Supported Assets and funds payable to the User; (v) block related Transactions; (vi) send a report to the Financial Intelligence Unit and other competent authorities.

These measures are applied, in particular, in the event of suspected Prohibited Activity, inconsistency of a transaction with the User’s declared profile, failure to provide the requested information, a sanctions screening or Scoring hit, or receipt of a demand from a competent authority.

A transaction in respect of which a decision has been made to recognize it as suspicious is suspended immediately, and a report is sent to the Financial Intelligence Unit within the time limits established by law. The decision on whether the suspended transaction may proceed is made by the Financial Intelligence Unit, not by the Company.

If the User, its counterparty, a transaction or a virtual wallet address matches the lists of persons subject to targeted financial sanctions, the Company applies the measures provided for by the legislation of the Kyrgyz Republic, including freezing funds and Virtual Assets and informing the authorized bodies. Such measures may be lifted only in the manner and on the grounds established by law.

The legislation of the Kyrgyz Republic prohibits the Company and its employees from disclosing to the User or to third parties the fact that a suspicious transaction report or other requested information has been sent to the Financial Intelligence Unit. For this reason, the Company does not disclose the grounds for the measures taken unless such disclosure is permitted by law.

The measures are lifted and the assets are unblocked once the grounds for applying them cease to exist, including when the person is removed from the relevant list or when the User submits all requested accurate documents, unless otherwise follows from a demand of a competent authority or a decision of the Financial Intelligence Unit. No interest accrues on the amounts withheld.

6.9. Review Period. The period of a review in connection with which the measures provided for in clause 6.8 have been applied is determined by the Company’s internal documents, taking into account the requirements of the legislation of the Kyrgyz Republic, the nature of the review and the need to obtain additional information or documents, including from the User, Service Providers, banks and payment systems. If the decision to carry out or suspend a transaction is made by the Financial Intelligence Unit or another competent authority, the review period is determined by such decision.

This period does not apply to measures taken at the demand of a competent authority or by decision of the Financial Intelligence Unit: such measures remain in effect until lifted by the relevant authority.

6.10. Information Accompanying Transfers. For transfers of Virtual Assets, the Company is required to obtain, store and transmit information on the originator and the beneficiary of the transfer to the extent established by applicable law and international standards. The User is informed that such information is transmitted to the virtual asset service providers, banks and payment systems involved in the transfer to the extent necessary to execute the transfer and to perform the Company’s obligations, and that similar information about the User may be received by the Company from such persons. The Company may refuse to carry out a transfer if the necessary information cannot be obtained or transmitted.

6.11. Record Keeping. The Company keeps the documents and information obtained in the course of identification, verification and due diligence, questionnaires, knowledge level confirmation results, transaction records and business correspondence with the User for at least 5 (five) years from the day the business relationship is terminated or the relevant transaction is carried out.

6.12. Recording of Communications. The User is informed that communications with the Company by means of telecommunication are subject to audio (video) recording and that correspondence with the User is retained. Recordings and correspondence are kept for the period specified in clause 6.11 and may be used to confirm the circumstances of interaction with the User and provided to competent authorities upon their demand.

7. Balance, Assets and Top-Ups

7.1. Balance. The Balance reflects the quantity of Supported Assets belonging to the User. Information on transactions and the remaining balance is available to the User in the Platform interface.

7.2. Ownership of Assets. Supported Assets recorded on the Balance belong to the User. The Company may hold Users’ Supported Assets at pooled virtual wallet addresses, while maintaining records that make it possible at any time to determine which assets belong to a specific User. The Company records Users’ assets separately from its own property.

7.3. Not a Deposit or Means of Payment. The Account is not a bank account. The Balance and the Supported Assets recorded on it are not money, non-cash or electronic money, a bank deposit or any other means of payment. Currency designations used to display the value of the Balance are used for information purposes only.

Supported Assets recorded on the Balance are not covered by the deposit protection system and are not insured, and no interest or other income accrues on them.

7.4. Balance Top-Up. The Balance may be topped up by the methods available in the Platform interface. Certain top-up methods are subject to additional review and are considered on a case-by-case basis.

7.5. Non-Cash Settlements Only. The Company does not accept cash. The User deposits cash on its own through the cash desk of its servicing bank, followed by a non-cash transfer.

7.6. Top-Up in Own Name Only. The Balance may be topped up only from bank accounts, payment cards, electronic wallets and virtual wallet addresses belonging to the User. Funds received from third parties may be returned to the sender less the Company’s actual expenses, and the transaction may be rejected.

7.7. Withdrawal of Supported Assets. Supported Assets are withdrawn to a virtual wallet address external to the Platform upon the User’s Order, to the address specified by the User in a supported blockchain network. The address must belong to the User or to an identified person whose details the User provides in accordance with clause 6.10. The Company may request confirmation of ownership of the address and refuse the withdrawal if the necessary information is not provided, as well as in the cases provided for in clause 6.8 and Section 14. The User is responsible for the correctness of the address and the transfer network (clause 8.5).

8. Trades in Virtual Assets

8.1. Trade Procedure. A Trade is made in the following order: (i) the User creates an Order in the Platform interface, specifying the type and quantity of the Virtual Asset and other necessary parameters; (ii) the Company provides the User with the Quote, the total cost of the transaction including all fees withheld, the amount to be received, and information as to whether the relevant Virtual Asset is backed or unbacked; (iii) the User confirms the Order with its Simple Electronic Signature, from which moment the Order becomes irrevocable and the Trade is concluded; (iv) the parties perform the Trade in accordance with this Section.

A Trade may be made only after completion of the applicable procedures provided for in clause 4.5 and Section 6.

8.2. Quote Validity Period. The Quote is fixed at the time the Order is created and remains valid for 15 minutes or such other period as is displayed in the Platform interface. If the User’s consideration has not been received by the Company in full within the Quote validity period, the Company may unilaterally, out of court, refuse to perform the Trade, and the Order is canceled.

Consideration received after cancellation of the Order is, at the User’s option, either returned to the User less the Company’s actual expenses or credited toward a new Order created at the Quote in effect at the time of such receipt. If the User makes no choice within 5 calendar days, the Company returns the consideration.

8.3. Execution and Confirmation. The Company executes the Trade within the period displayed in the Platform interface before the Order is confirmed, calculated from the moment the User’s consideration is received in full, except in the cases provided for in clause 8.4. The Company records the date and time of the Trade to the minute. Immediately after the Trade is made, the Company sends the User an electronic confirmation containing the type of Trade, the date and time, the type and quantity of the Virtual Asset, information as to whether it is backed or unbacked, the purchase, sale or exchange rate, the amount and volume of the trade, the amount of fees withheld, the crediting details and the blockchain network transaction identifier (if any).

The confirmation is sent via the Platform and is available to the User in the transaction history. For Trades made automatically under clause 9.3, a confirmation is generated for each such Trade and is shown in the transaction history together with information on the relevant Antarctic Card transaction. If the User has raised no objections within 5 calendar days of the date of receipt of the confirmation, the information contained therein is deemed confirmed by the User unless proven otherwise. This provision does not limit the User’s right to submit a claim within the period established by clause 19.2.

8.4. Refusal to Accept or Execute an Order. The Company accepts and executes an Order that meets the requirements of the Agreement, provided that the Company is able to execute it. The Company may refuse to accept or execute an Order, in particular, if: (i) the Balance has insufficient funds to execute the Order and pay the fees; (ii) the User has not completed the applicable KYC, EDD or knowledge level confirmation procedures; (iii) a sanctions screening or Scoring hit has occurred; (iv) the transaction exceeds the established limits; (v) there are grounds to believe that the transaction is related to Prohibited Activity; (vi) execution is impossible for technical reasons or due to the unavailability of Service Providers’ systems.

If a transaction is refused on compliance-related grounds, the Company may return the Virtual Assets received to the virtual wallet address from which they were received, less the Company’s actual expenses, including blockchain network fees and the cost of the checks performed.

8.5. Finality of Transactions. An executed transaction is final and may not be reversed. The Company cannot reverse a transaction confirmed in the blockchain network or return Virtual Assets sent by the User to the details specified by the User. The User is responsible for the correctness of the details, the transfer network and other transaction parameters.

8.6. Erroneous Credits and Reversals. If, as a result of a technical error, malfunction, Quote error, or error of the Company, a Service Provider or a payment provider, Supported Assets to which the User has no rights are credited to the User’s Balance, the Company may, without the User’s consent and without prior notice to the User, cancel (reverse) the relevant transaction and debit the erroneously credited amount of Supported Assets from the Balance, and may also deem the relevant trade not concluded or adjust its rate to the actual market value at the time it was made. The User gives the Company its consent (advance acceptance) to such debit.

If the debit is technically impossible, including due to an insufficient Balance, the User shall return to the Company the corresponding amount or volume of Virtual Assets within 5 calendar days from the day of receipt of the Company’s demand. The User shall immediately notify the Company upon discovering an erroneous credit and may not dispose of the erroneously credited funds.

8.7. Disputed Payments. If a payment used to execute a transaction is subsequently disputed, recalled or canceled by a bank, a payment system or the issuer of a payment card, or is recognized as made without the cardholder’s consent, the Company may block the Account, debit from the Balance the amount of such payment and the related expenses, including fees and penalties of payment systems, and, if the Balance is insufficient, demand reimbursement from the User within 5 calendar days.

The User undertakes not to initiate chargebacks in respect of transactions duly executed by the Company. A breach of this obligation entitles the Company to terminate the Agreement in accordance with clause 15.4 and to claim compensation for losses.

9. Services Provided by Service Providers

9.1. General Terms. The Platform functions listed in this Section are provided by Service Providers. With respect to such functions, the Company provides the User with an interface and ensures information and technology interaction between the User and the Service Provider. The Company does not render the relevant services itself, is not a party to the User’s transaction with the Service Provider and does not hold the permits required to render such services.

The terms on which the Service Provider renders its services are communicated to the User and accepted by the User when arranging access to the relevant function. If the User breaches these terms or fails to meet the Service Provider’s requirements, the relevant function may be refused.

Certain Services are provided only to Users who meet the requirements of the relevant Service Provider or Issuer, including requirements as to citizenship, place of residence, age and the extent of identification completed. Such requirements are set by the Service Provider or Issuer, may change and are communicated to the User when arranging the relevant Service. The Company may refuse access to a Service if the User does not meet such requirements.

9.2. Service Provider Representations. The Company engages as Service Providers only those persons who have provided the Company with representations that they hold all licenses, permits, registrations and other legal grounds required under the law applicable to them to render the relevant services, and that the rendering of such services does not violate the legislation applicable to them. These representations are included in the Company’s agreements with Service Providers, extend to third parties engaged by them and are subject to periodic confirmation.

The Company relies on these representations and vets Service Providers with reasonable care. The Company does not confirm or guarantee to the User the accuracy of the Service Providers’ representations and is not liable for their inaccuracy beyond the obligation to act reasonably and with due care when selecting a Service Provider.

9.3. Antarctic Card. The Antarctic Card is provided by the Issuer upon the User’s application submitted through the Platform interface. The type of electronic means of payment, its functionality, limits, validity period and the list of available transactions are determined by the Issuer and communicated to the User upon application.

The Antarctic Card may be provided without a physical medium (virtual Antarctic Card) or with a physical medium (physical Antarctic Card). The type of Antarctic Card, the possibility and conditions of obtaining it, and the cost of issue, delivery and reissue are determined by the Issuer and communicated to the User when the application is submitted. Certain types of Antarctic Cards may not be available in all jurisdictions or to all Users.

The Antarctic Card is provided after the User has completed identification to the extent established by the Company and the Issuer, including, where technically feasible, by means of remote identification provided for by the applicable legislation and the Issuer’s documents; the Antarctic Card is not provided without such identification. The extent of identification completed may affect the limits applicable to the Antarctic Card and the list of available transactions. The Company does not provide, or arrange the provision of, anonymous or unidentified payment instruments.

The Company does not charge its own fee for the issue and servicing of the Antarctic Card. The fee for issue and servicing, if any, is set and charged by the Issuer in accordance with its tariffs and is communicated to the User when the Antarctic Card is arranged. No such fee is charged for certain Antarctic Cards.

The Company is not a credit institution, does not issue Antarctic Cards or provide them in its own name, is not the Issuer of the Antarctic Card, is not a participant in settlements between the Issuer, the payment system and the payee, does not ensure the operation of the Antarctic Card and does not use Antarctic Cards in its own business. The Company provides an interface solution for arranging the Antarctic Card and for generating the User’s instructions. The Company does not process or store full payment card details.

Legal relations regarding the issue and servicing of the Antarctic Card, including the terms of its use, limits, the procedure for disputing transactions and the procedure for resolving disputes, arise between the User and the Issuer on the basis of the Issuer’s documents, which the User reviews and accepts when arranging the Antarctic Card.

Settlements under the Antarctic Card are made as follows: the User enters into a Trade with the Company to sell to the Company a quantity of Supported Assets equivalent to the transaction amount, in accordance with Section 8; on the User’s instruction, the Company transfers the monetary consideration under such Trade to the Issuer toward execution of the Antarctic Card transaction. The Company does not open or maintain any cash accounts for the User.

If the Platform interface provides for such Trade to be made automatically at the time of an Antarctic Card transaction, the User gives the Company advance acceptance for making it and for debiting the corresponding quantity of Supported Assets from the Balance. Such Trade is made at the Quote in effect at the time of the transaction, without confirmation by simple electronic signature (clause 3.2 and sub-clause (iii) of clause 8.1 do not apply to it), a confirmation is sent to the User in accordance with clause 8.3, and the User may at any time withdraw such acceptance by disabling the relevant function in the Platform interface.

The amount of an Antarctic Card transaction may be reserved at the time of its authorization, with final settlement made upon receipt of the final transaction details from the Issuer or the payment system. If the final amount differs from the reserved amount, including due to currency conversion, the difference is processed as a separate Trade at the Quote in effect at the time of final settlement and is reflected in the transaction history.

An Antarctic Card transaction is not executed if the Balance holds insufficient Supported Assets to execute it and pay the fees. If, owing to the specifics of settlements for payment card transactions, a change in the exchange rate or delayed receipt of transaction details, the User nevertheless becomes indebted to the Company, the User shall repay such debt within 5 calendar days from the day of receipt of the Company’s demand. Until the debt is repaid, the Company may suspend transactions under the Antarctic Card and the Account.

Virtual Assets are not used as a means of payment, are not transferred to the payee and are not the subject of settlements with the payee. Only money is transferred to the Issuer and the payee.

Fees for the issue, servicing, delivery and reissue of the Antarctic Card, as well as amounts sent to top up the Antarctic Card, are not refundable by the Company once transferred to the Issuer. This rule also applies where the Antarctic Card has not been used by the User, has not been activated, or has been blocked or closed on any grounds, as well as upon its expiry. The Company is not the recipient of such amounts and may not dispose of them.

To receive a physical Antarctic Card, the User provides a delivery address and other information required by the Issuer or a person engaged by it. Delivery is carried out by the Issuer or a carrier engaged by it; the Company does not carry out delivery and is not liable for delivery times, delays, or loss of or damage to the shipment. The User is responsible for the delivery address provided being accurate and up to date.

The User shall keep the physical Antarctic Card and its details safe and shall not transfer them to third parties. The User shall immediately notify the Issuer, in the manner established by the Issuer’s documents, and the Company, through the support service, of the loss or theft of the physical Antarctic Card and of any transactions made without the User’s consent.

Obligations relating to transactions using the Antarctic Card, including refunds by the seller of goods, disputing of transactions, blocking and closing of the card, refund of the unused remaining amount and refund of the issue and servicing fee, are performed by the Issuer in accordance with its documents. The User submits a claim for refund of the unused remaining amount to the Issuer in the manner established by the Issuer’s documents. The User’s requests relating to the Antarctic Card are handled in accordance with clause 9.5.

9.4. Third-Party Issuer Cards. The Platform interface may allow the User to place an order for the provision of a Third-Party Issuer Card. A Third-Party Issuer Card is provided to the User by a third-party Issuer or by a Service Provider engaged by it and is not linked to the Antarctic Card. The Company ensures information and technology interaction between the User and such person, including transmission of the User’s order and instruction and display of order information.

The Company does not issue Third-Party Issuer Cards, does not provide them in its own name, does not participate in settlements for transactions made with them, does not process or store full details of such cards and does not use Third-Party Issuer Cards in its own business.

A Third-Party Issuer Card is assigned to an identified User. Anonymous or unidentified payment instruments are not provided.

The terms of use of a Third-Party Issuer Card, including its face value, currency, validity period, territory and methods of acceptance, available transactions and limits, are determined by the Issuer and communicated to the User when the order is placed. The User independently verifies whether the use of the Third-Party Issuer Card is permitted in the jurisdiction where the User is located and at the place of the transaction.

The price of a Third-Party Issuer Card and its face value are not refundable by the Company once the order has been fulfilled. This rule also applies where the Third-Party Issuer Card has not been used or activated by the User, has been blocked, has not been accepted at the place of the transaction or has expired. The Company is not the recipient of such amounts and may not dispose of them.

Claims relating to the issue, servicing, blocking, refund of the unused remaining amount and disputing of transactions under a Third-Party Issuer Card are addressed to the Issuer. The User’s requests are submitted and handled in accordance with clause 9.5.

9.5. Engagement of Third Parties and Request Procedure. The Company may have no direct contractual relationship with the Issuer or another person actually providing the Service. The relevant Service may be provided through a Service Provider that engages the Issuer and other persons for this purpose. The range of such persons and the allocation of functions among them are determined by agreements to which the User is not a party.

Information about the person providing the card or other Service and the terms applicable to it are communicated to the User upon arrangement to the extent available to the Company. The Company does not disclose information about the Issuer and other engaged persons if such disclosure is restricted by contract or by applicable legislation.

The User’s requests relating to Services rendered by Service Providers are submitted through the Company’s support service. The Company forwards such a request to the Service Provider within 5 calendar days and communicates the response received to the User. If the Service Provider or the Issuer has disclosed contact details for the User to contact them directly, the Company provides those details to the User.

The time limits for considering a request and the decision taken on it are determined by the Service Provider or the Issuer. The Company does not control such time limits, does not influence the decision and does not guarantee its outcome. The Company’s obligation is limited to forwarding the request and providing the transaction information available to it.

If, following consideration of a request, the Service Provider or the Issuer has actually returned to the Company funds or other amounts due to the User, the Company credits them to the User less actual expenses and third-party fees. This provision does not create an obligation of the Company to make refunds from its own funds.

9.6. QR Code Payments and Top-Up of Third-Party Services. The functions of payment by QR code and topping up accounts with telecom operators, gaming and other third-party services are implemented through Service Providers. The User enters into a Trade with the Company in accordance with Section 8, and the funds received by the User are, on the User’s instruction, sent to the Service Provider to execute the relevant payment in favor of the payee specified by the User.

Virtual Assets are not used as a means of payment, are not transferred to the payee and are not the subject of settlements with the payee. The Company is not the payee, does not carry out money transfers and is not liable for the performance of obligations by the payee, including the delivery of goods, performance of work and rendering of services paid for, or for the refund of such payments. The User brings claims relating to the performance of obligations by the payee directly against the payee. Requests relating to the execution of a payment by the Service Provider are handled in accordance with clause 9.5.

9.7. Withdrawal of Funds. When withdrawing funds, the User enters into a Trade with the Company in accordance with Section 8, and the transfer of funds to the details specified by the User is carried out by a Service Provider that has the necessary infrastructure and permits. The recipient’s details must belong to the User; a mismatch between the recipient’s data and the User’s data is grounds for refusing the transaction.

The transfer of funds to the details specified by the User is final and may not be canceled. If the funds are not credited to the recipient because the User specified incorrect or outdated details, their return depends on the recipient’s bank and the Service Provider and is not guaranteed by the Company. The Company assists the User in tracing such transfer in accordance with clause 9.5.

The time for crediting funds is determined by the recipient’s bank, the payment system and the Service Provider. The Company may suspend or refuse a withdrawal if the Service Provider, the Issuer, a bank or a payment system has requested documents or information that the User has not provided.

9.8. Address Screening and Screening Reports. At the User’s request, the Company may provide a Screening Report on a virtual wallet address, a transaction or a Virtual Asset. The report is generated on the basis of data from the AML/KYT service provider as at the time of its generation. The cost of the service, if it is paid, is determined by the Fee Schedule.

The Screening Report is for information purposes only. It is a probabilistic assessment of the risk level rather than a finding of fact, and is not: a confirmation of the lawful origin of funds; an opinion on the lawfulness of a transaction or on the ownership of an address; a recommendation to make or refrain from a transaction; investment, legal or tax advice. The User makes the decision to carry out a transaction independently and at the User’s own risk.

The Screening Report is not a guarantee of execution of a transaction. The Company does not guarantee that a transaction made with regard to the Screening Report will be accepted, executed or not restricted. Likewise, the absence of risk indicators in the Screening Report does not mean that the funds were obtained lawfully, and the presence of such indicators does not mean the opposite.

The Company has no information about the rules of third parties. The criteria, methodologies and internal policies of exchanges, exchange services, banks, payment systems and other persons accepting funds are unknown to the Company and are not controlled by it. Different analytics providers apply different methodologies, and therefore the assessment results for the same address or transaction may differ, including in opposite directions.

The Company bears no liability for decisions taken by third parties based on the results of their own checks, including refusal to accept funds, restriction or suspension of transactions, withholding of funds, and the charging of fees, charges and deductions in connection with risk assessment. The User brings claims relating to such decisions directly against the relevant person.

The Screening Report does not predetermine the Company’s decisions. Providing the User with a Screening Report, including one that contains no risk indicators, does not constitute approval of a transaction, does not confirm completion of the procedures provided for in Section 6 and does not limit the Company’s right to apply the measures provided for in clause 6.8.

9.9. New Functions. The Company develops the Platform, and new functions may become available to the User. Descriptions of new functions and how they work are posted in the relevant sections of the Platform. The Company specifies separately whether a new function is provided by the Company itself or by a Service Provider.

9.10. Territorial Restrictions. The range of available Services varies by jurisdiction. The Company may restrict or suspend access to the Platform or to certain Services, in whole or in part, in certain markets, at its own discretion or due to legal requirements. The list of jurisdictions in which certain Services are available and the applicable restrictions are shown in the Platform interface.

The User is solely responsible for complying with the legislation of the state of the User’s citizenship, permanent residence and actual location when using the Platform.

10. Mini Apps

10.1. General Provisions. The Company may provide the User with access to Mini Apps. A Mini App is a software product of the Developer. The Company provides the Developer with the technical ability to place the Mini App on the Platform, and provides the User with access to it through the Platform interface. The Company is not the developer, right holder, seller or performer in respect of a Mini App. The exclusive rights to a Mini App and its content belong to the Developer or its licensors.

The requirements of Section 14 apply to the use of Mini Apps. The User may not use Mini Apps to circumvent restrictions established by the Agreement.

10.2. Developer Terms. Before the User starts using a Mini App, the User is provided with information about the Developer and the terms of use of the Mini App set by the Developer. Starting to use the Mini App constitutes the User’s acceptance of these terms. Relations between the User and the Developer are governed by the Developer’s terms; the Company is not a party to these relations and is not liable for their performance.

10.3. No Access to User Funds. A Mini App has no access to the User’s Balance, Account or access credentials, may not initiate transactions on the Balance and does not participate in settlements between the User and the Company. Any transaction is made by the User independently, using the Platform functions and with confirmation in the manner provided for by the Agreement.

The Company does not accept funds or Virtual Assets for the benefit of Developers, does not hold or escrow them and does not carry out settlements between the User and the Developer. Functions under which the Company accepts funds for the benefit of Developers may be introduced in the future on terms that will be established separately and communicated to the User before such functions are used.

10.4. Financial Relations with the Developer. If a Mini App provides for payment, a transfer of Virtual Assets or funds, the provision of other property or the assumption by the User of property obligations, the relevant relations arise between the User and the Developer and are governed by the Developer’s terms.

The User makes the decision to carry out any such transaction independently and at the User’s own risk. The Company is not a party to such relations, does not act as agent, intermediary, surety or guarantor for either party, does not hold in escrow what is transferred and does not ensure the performance of the Developer’s obligations to the User.

The Company does not verify or confirm: the economic model of a Mini App; the accuracy of the terms, returns, timeframes and results declared by the Developer; whether the Developer has the funds and assets required to perform its obligations; the possibility of returning what has been transferred. Placement of a Mini App on the Platform does not constitute confirmation or approval by the Company of the said circumstances.

A transaction made by the User is final in accordance with clause 8.5. Return of what has been transferred to the Developer is made by the Developer in accordance with its terms; the Company does not make or guarantee such return.

The User is warned that promises of income, guaranteed returns or any other benefit from the use of a Mini App relate to the risks specified in clause 4.3 and may be an indication of Prohibited Activity (Section 14).

10.5. Information Transferred to the Developer. The scope of information transferred to the Developer is limited to the minimum necessary for the operation of the Mini App and is communicated to the User before the User starts using it. For each Mini App, the Company uses a separate User identifier that does not match the identifiers used in other Mini Apps and in the Account.

The Company does not transfer to Developers the User’s identity documents or the information contained therein. Information on the User’s completion of verification may be transferred to the Developer to the extent necessary to provide access to the Mini App and its functions.

Any other information about the User is transferred to the Developer only with the User’s consent, given separately before the User starts using the Mini App, and to the extent communicated to the User when such consent is given. In the absence of such consent, access to the Mini App may not be granted.

The Company does not control information that the User provides to the Developer in the Mini App on the User’s own initiative. The terms of processing of personal data by the Developer and the allocation of liability for such processing are determined by the Developer’s terms; the Company processes personal data in accordance with Section 17. The Consent does not extend to the transfer of information to Developers, which is carried out only in accordance with this clause.

10.6. Liability and Requests. The Company is not liable for the content of a Mini App, its operability and security, the accuracy of information posted in it, the performance by the Developer of its obligations to the User, or the property consequences of the User’s relationship with the Developer. The User shall bring claims relating to a Mini App against the Developer.

User requests relating to a Mini App may be submitted through the Company’s support service and are forwarded to the Developer in the manner provided for in clause 9.5.

10.7. Suspension and Removal. The Company may at any time, with or without prior notice to the User, restrict access to a Mini App, suspend its operation or remove it from the Platform, including where the Developer breaches the Company’s requirements or the law, upon receipt of complaints from Users, upon receipt of a demand from a competent authority, or where there is a risk to Users or to the Platform.

The Company does not guarantee the continuous availability of Mini Apps and is not liable for the consequences of the termination of access to a Mini App, including the loss of information and results created by the User in the course of its use.

10.8. Measures in Case of Violations; Disputes. The Company may, upon complaints from Users or based on the results of its own review, apply measures against both the Developer and the User, including: (i) restricting access to the Mini App, suspending its operation and removing it from the Platform; (ii) suspending settlements with the Developer and withholding amounts due to it in accordance with the Company’s agreement with the Developer; (iii) the measures provided for in clause 6.8 in respect of the User’s Account; (iv) transferring information to competent authorities.

Such measures are a right and not an obligation of the Company. The Company does not undertake to resolve disputes between the User and the Developer, to establish the circumstances of their relationship, to recover for the benefit of the User what was transferred to the Developer, or to compensate the User for losses. The application of a measure in one case does not create an obligation to apply it in another case.

This clause does not limit the User’s right to bring a claim directly against the Developer.

11. Exchange Rate, Fees and Limits

11.1. Cost of Transactions. The cost of a transaction to the User consists of: (i) the Company’s fee set by the Fee Schedule; (ii) blockchain network fees; (iii) fees and charges of Service Providers, Issuers, banks and payment systems, including charges for the issuance and servicing of cards; (iv) the difference between the Company’s Quote and the quotes of external sources (spread). The amounts specified in sub-clauses (ii) and (iii) are not included in the Company’s Fee Schedule, the Company is not their recipient and does not refund them. The full cost of the transaction and the amount to be received by the User are displayed in the Platform interface before the Order is confirmed.

11.2. Determination of the Quote. The Quote is determined by the Company at its own discretion based on data from external sources, taking into account the spread, liquidity, volatility and the Company’s costs. The Company does not guarantee that the Quote will match the quotes of exchanges, exchange services or other external venues.

11.3. Fee Schedule. The types of the Company’s fees are set out in Annex No. 1, and their amounts are displayed in the Platform interface before the Order is confirmed and may be posted in the relevant sections of the Company’s website. The Company may unilaterally change the amounts of fees at any time. Changed fee amounts take effect from the moment they are displayed in the Platform interface or posted on the Company’s website, unless a later date is specified by the Company. The Company may notify the User of changes in fee amounts after the changes take effect. An Order accepted before the changes take effect is subject to the fee amounts in effect at the time the Order was accepted.

11.4. Withholding of Fees. Fees are withheld from the transaction amount or debited from the User’s Balance at the time the relevant transaction is made. The User gives the Company its advance acceptance of such debit.

11.5. Limits. The Company sets limits on the amount and number of transactions, including minimum and maximum limits per transaction, day, week and month. The applicable limits are displayed in the Platform interface and on the relevant pages of the Company’s website and are communicated to the User before the Order is confirmed. Limits may vary depending on the Service, the User’s risk category and the extent of identification the User has completed. The Company may change limits and may make a change of limits conditional upon completion of additional KYC or EDD procedures. Changed limits apply from the moment they are displayed in the Platform interface.

11.6. Taxes. The Company does not prepare tax reports and does not pay taxes on behalf of Users. The User shall independently ensure the performance of its tax obligations, including reporting and payment of taxes, in accordance with the legislation applicable to the User.

12. Referral Program

12.1. General Terms. The Company may run a Referral Program, the terms of which are determined by Annex No. 4 and the Platform interface. Participation in the program is voluntary. Reassignment of Referrals is carried out in accordance with Section 13.

12.2. Nature of the Reward. A Participant’s reward is paid out of a share of the fee income actually received by the Company from transactions of Referrals. The reward is not income from the placement of funds, investment income, or a guaranteed or periodic payment, is not paid for the mere fact of attracting persons, and is calculated solely on the basis of the Company’s fee on transactions actually made by Referrals. The Company does not guarantee any amount of reward.

12.3. Amendment and Termination. The Company may at any time amend the terms of the program, suspend or terminate it, and refuse to accrue or pay a reward upon detection of abuse, including the creation of multiple Accounts, self-referral schemes, fictitious transactions, transactions made solely to obtain a reward, provision of false information, and the abuses specified in clause 13.11.

12.4. Requirements for Disseminated Information. A Participant disseminating information about the Platform undertakes to comply with the requirements of the legislation on advertising of virtual assets and not to post materials containing: (i) promises or guarantees of returns or of the effectiveness of transactions with virtual assets; (ii) information about luxury goods, bonuses and discounts; (iii) the presentation of transactions with virtual assets as an easy way to get rich; (iv) claims that such transactions are significant for achieving public recognition or personal or professional success; (v) images of minors; (vi) statements exaggerating the likelihood of earning income or understating the risk of total loss of funds; (vii) statements condemning non-participation in the circulation of virtual assets.

Materials containing advertising of virtual assets or of the Company’s activities are subject to prior written approval by the Company. The Participant also undertakes not to distribute materials about the Platform in jurisdictions where the provision of services related to Virtual Assets is prohibited or requires an authorization that the Company does not hold, not to address such materials to persons located in such jurisdictions, and not to present Virtual Assets as a means of payment for goods, works and services.

The Company may demand that the distribution of materials cease, suspend or terminate the payment of rewards, refuse to accrue rewards on transactions of Referrals attracted in breach of this clause, and claim compensation for losses caused by a breach of this clause.

13. Reassignment of Referrals

13.1. Definition. A Participant (the “Transferring Participant”) may post, in the section of the Platform interface intended for Reassignment (the “Marketplace”), an offer to assign one or more of its First-Level Referrals to another Participant, specifying the amount of consideration (the “Reassignment Listing” and the “Price”, respectively). The Participant that has accepted a Reassignment Listing (the “Receiving Participant”) and the Transferring Participant jointly instruct the Company to carry out the Reassignment on the terms of the Reassignment Listing.

If the Platform interface provides for the posting on the Marketplace of offers by Participants to accept the assignment of Referrals, the provisions of this Section apply to such offers mutatis mutandis.

13.2. Legal Nature. Reassignment is a change, made by the Company on the joint instruction of the Transferring Participant and the Receiving Participant, to the parameters of their Accounts in the Referral Program and to the entries on their Balances. From the date of Reassignment, the right to a reward on transactions of the reassigned Referral terminates for the Transferring Participant and arises for the Receiving Participant on the basis of its Agreement and in the amount determined by its rank.

Reassignment is not an assignment of a claim, a transfer of debt or a transfer of a contract, and is not a Trade.

13.3. Agreement between Participants. The terms of Reassignment, including the list of Referrals and the Price, are determined by the Participants. The Reassignment Listing and its acceptance constitute an agreement between the Transferring Participant and the Receiving Participant (the “Participants’ Agreement”). The Company is not a party to the Participants’ Agreement, does not act as agent, intermediary, attorney, surety or guarantor of any of the Participants, does not determine or verify the Price, does not acquire or transfer the assignment of Referrals in its own name, and does not guarantee the activity of the reassigned Referral, the amount of future reward or the preservation of the Referral’s Account.

The Company’s functions with respect to Reassignment are limited to providing the Marketplace as a technical means of posting Reassignment Listings and executing the Reassignment Request in accordance with clauses 13.4 and 13.8.

13.4. Settlements. The Price is specified in a Supported Asset determined by the Company and displayed in the Platform interface. Upon acceptance of a Reassignment Listing, the Company reserves the Price on the Receiving Participant’s Balance; the reserved Supported Assets may not be used by the Receiving Participant until the Reassignment Request is executed or its execution is refused.

Upon execution of the Reassignment Request, the Company simultaneously: (i) debits the Price from the Receiving Participant’s Balance; (ii) credits the Price, less the Company’s fee (clause 13.13), to the Transferring Participant’s Balance; (iii) assigns the Referrals specified in the Reassignment Listing to the Receiving Participant. If execution of the Reassignment Request is refused, the reservation terminates.

Settlements under the Participants’ Agreement are made exclusively in accordance with this clause. Providing consideration by any other means, including outside the Platform, is not permitted. The Platform does not provide for any other transfers of Supported Assets between Users’ Balances. Entries on Balances made upon execution of the Reassignment Request are subject to the measures provided for in Section 6.

13.5. Reassignment Request. A Reassignment Listing confirmed by the simple electronic signature of the Transferring Participant and its acceptance confirmed by the simple electronic signature of the Receiving Participant together constitute the joint instruction of the Participants to the Company (the “Reassignment Request”). The Reassignment Request contains: (i) the anonymized identifiers allocated by the Company to the Referrals being reassigned; (ii) the Price; (iii) a representation by each Participant that it acts in its own name, in its own interest and for its own account, and that the Participants’ Agreement is not aimed at transferring value on grounds unrelated to the Referral Program or at circumventing the restrictions of the Agreement. Reassignment Listings and acceptances thereof sent by other means, including through the support service or through a representative, are not accepted.

13.6. Conditions of Reassignment. Reassignment is permitted subject to simultaneous compliance with the following conditions: (i) both Participants have completed KYC at a Verification Level not lower than “Basic” (clause 6.1), and no measures provided for in clause 6.8 are applied to their Accounts; (ii) the Participants’ Accounts are not related, including that they do not belong to the same person, are not controlled by the same person and do not use common devices, network addresses or payment details; (iii) the Referral has been assigned to the Transferring Participant for no less than the period set by the Company; (iv) as a result of the Reassignment, the Referral is not assigned to itself or to a person attracted by it directly or through other Referrals; (v) the Price is within the limits set by the Company; (vi) the restrictions set by the Company on the number and frequency of Reassignments are complied with.

Periods, Price limits, restrictions on the number and frequency of Reassignments and other parameters of Reassignment are set by the Company and displayed in the Platform interface.

13.7. Review and Refusal. The Company may request from either Participant information and documents regarding the Participants’ Agreement and the source of funds, decline to post a Reassignment Listing on the Marketplace or remove it from the Marketplace, and refuse to execute a Reassignment Request without giving reasons, including in the event of non-compliance with the conditions of clause 13.6, where there are grounds provided for in Section 6, or where there are signs of abuse. Such actions of the Company do not entail its liability and do not give rise to any obligations on its part under the Participants’ Agreement.

13.8. Execution and Irrevocability. The Company executes the Reassignment Request within the period displayed in the Platform interface and notifies the Participants of the execution via the Platform. The Transferring Participant may withdraw a Reassignment Listing before it is accepted.

An executed Reassignment is irrevocable, and the Price is non-refundable, including where the reassigned Referral ceases to be active, its Account is closed, or the amount of reward or the terms of the Referral Program change. The assignment of a Referral may be changed only by a new Reassignment or by a decision of the Company in the cases provided for in clause 13.11.

13.9. Reward and Rank. Reassignment is permitted in respect of any First-Level Referral of the Transferring Participant, including one that has its own Referrals. The reward accrued to the Transferring Participant on transactions of the reassigned Referral before the date of Reassignment remains with the Transferring Participant; any write-off of such reward on the grounds provided for in Annex No. 4 is made from the Transferring Participant’s Balance.

The reassigned Referral is assigned to the Receiving Participant together with the persons attracted by it directly or through other persons. From the date of Reassignment, the levels of the Referrals of the Transferring Participant, of the Receiving Participant and of the Participants to whom they are assigned are determined taking into account the new assignment (clause 1.3 of Annex No. 4).

Each Participant agrees to the change in the composition of its Second-Level and Third-Level Referrals resulting from Reassignments made by other Participants; such change does not constitute a breach of the Agreement.

From the date of Reassignment, the reassigned Referrals are taken into account in determining the rank of the Receiving Participant and are not taken into account in determining the rank of the Transferring Participant. A change in a Participant’s rank and in the amount of its reward resulting from a Reassignment does not constitute a breach of the Agreement.

13.10. Information about Referrals. On the Marketplace and in the Reassignment Request, information about Referrals is provided only in anonymized form, including the identifier allocated by the Company, the activity status and the amount of reward accrued on the Referral’s transactions for a period determined by the Company. Such information is for reference only and does not constitute a representation by the Company as to the future activity of the Referral or the amount of reward. Each User who has registered via a referral link or using a referral code has been notified of the possibility of Reassignment and agrees that the User’s assignment may be changed in accordance with this Section; Reassignment does not change the terms of the Agreement for the Referral. The Company may notify the Referral of the Reassignment.

13.11. Abuse. It is prohibited: (i) to offer Reassignment and to post advertisements for the acquisition or disposal of Referrals outside the Marketplace, including in public channels and communities, and to accompany Reassignment Listings with promises of income, representations about the Referral’s activity or statements exaggerating the likelihood of receiving a reward; (ii) to carry out Reassignment between related Accounts; (iii) to use Reassignment to transfer value on grounds unrelated to the Referral Program, including by setting a Price that clearly does not correspond to the information about the Referral; (iv) to carry out Reassignment solely for the purpose of changing rank; (v) to attract Referrals, including by using fictitious Accounts, solely for the purpose of subsequent Reassignment; (vi) to post or accept a Reassignment Listing using another person’s Account or the means of access to it.

Upon detection of abuse, the Company may remove the Reassignment Listing from the Marketplace, cancel the Reassignment, restoring the previous assignment of the Referral and making reversing entries on the Participants’ Balances within the limits of the Supported Assets recorded on them, refuse to accrue a reward or write off an accrued reward, exclude the Participants from the Referral Program and apply the measures provided for in clause 6.8.

13.12. Liability. The Company is not liable for the validity of the Participants’ Agreement, for the correspondence of the Price to the information about the Referral, for the activity of the reassigned Referral, for any change in the amount of the Participants’ reward resulting from Reassignment, or for losses arising from relations between the Participants. Disputes relating to the Participants’ Agreement are resolved between the Participants without the participation of the Company. The Company’s liability is limited to the execution of the Reassignment Request in accordance with its content and is determined by Section 18.

13.13. Fee, Taxes and Amendment of Terms. For the execution of a Reassignment Request, the Company charges a fee in the amount set by the Fee Schedule, which is withheld from the Price when it is credited to the Transferring Participant’s Balance. The Company’s fee for the execution of a Reassignment Request is not taken into account when calculating the reward under the Referral Program. Each Participant shall independently perform the tax obligations related to the Participants’ Agreement (clause 11.6). The Company may at any time change the terms of Reassignment, suspend or terminate the operation of the Marketplace and the acceptance of Reassignment Requests; such changes do not affect executed Reassignments.

14. Prohibited Activity and Prohibited Transactions

14.1. Prohibited Activity. The User undertakes not to use the Platform and the Account for Prohibited Activity, which includes: (i) unlawful financial activity: the legalization (laundering) of criminal proceeds, the financing of terrorist and extremist activities, the financing of organized groups and criminal communities, the financing of the proliferation of weapons of mass destruction, Ponzi schemes and financial pyramids, market manipulation, fraud, transactions on darknet platforms; (ii) unlicensed regulated activity: the provision, without the required authorizations, of money and value transfer services, payment, exchange, brokerage and other financial services, as well as participation in such activity; (iii) dealing in prohibited and restricted goods: narcotic drugs, psychotropic substances and their precursors, human trafficking and related activities, weapons, ammunition and military goods, nuclear materials and technologies, counterfeit goods, goods restricted in circulation, including tobacco and nicotine-containing products, pharmaceutical and prescription drugs, age-restricted goods and hazardous materials; (iv) infringement of rights and unfair practices: infringement of intellectual property rights, deceptive marketing and false advertising, adult content and services, gambling; (v) other activity that, in the Company’s reasonable opinion, involves an unacceptably high level of risk.

14.2. Prohibited Transactions. Due to legal requirements, the Company does not carry out or facilitate transactions: (i) using enhanced-privacy virtual asset wallets, if the owners (holders) of such wallets are not identified; (ii) with tokens that have unique characteristics (NFT); (iii) using illegal and unidentified (anonymous) prepaid cards; (iv) related to the activities of online casinos and virtual casinos; (v) with virtual assets and wallets that have a high level of risk based on the results of Scoring; (vi) with virtual assets included by the Authorized Body in the list of virtual assets prohibited for use; (vii) that are anonymous, as well as transactions on accounts opened in fictitious names.

14.3. User Obligations. The User undertakes not to take any action aimed at: (i) gaining unauthorized access to the Platform, its infrastructure, the Accounts of other Users or related systems; (ii) interfering with the operation of the Platform, or intercepting or misappropriating any part of it, its data or information; (iii) transmitting malicious software; (iv) collecting information about other Users; (v) misleading the Company, other Users or Service Providers, including by providing false information or impersonating another person.

14.4. Consequences. A breach of this Section constitutes a material breach of the Agreement and entitles the Company to apply the measures provided for in clause 6.8 and to terminate the Agreement in accordance with clause 15.4.

15. Suspension and Termination

15.1. Term. The Agreement is effective from the moment of acceptance of the Offer until its termination in accordance with this Section.

15.2. Prolonged Failure to Provide Information. If the User has not provided the requested information or documents or has not responded to a request of the Company within 14 calendar days from the day it was sent, and within the same period has not notified the Company of a valid reason for the delay, the Company may apply the measures provided for in clause 6.8 and terminate the Agreement unilaterally. Valid reasons may include, in particular, illness of the User, the User’s inpatient hospital treatment, a natural disaster and other circumstances objectively preventing a response to the request. Whether a reason is recognized as valid, and any additional period granted to the User, are determined by the Company at its discretion.

15.3. Termination by the User. The User may at any time terminate the Agreement and delete the Account by using the relevant function of the Platform or by contacting the support service. No termination fee is charged.

The Company may refuse to delete the Account and terminate the Agreement until the relevant circumstances have been eliminated if: (i) a request or demand of a competent authority has been received in respect of the User; (ii) there is an incomplete transaction or an unresolved dispute; (iii) the User has outstanding debt to the Company; (iv) assets belonging to the User have been frozen on the grounds provided for in clause 6.8.

15.4. Termination by the Company. The Company may terminate the Agreement unilaterally out of court by sending the User a notice at least 10 calendar days in advance. The Company may terminate the Agreement without prior notice in the event of: (i) a breach of the Agreement by the User; (ii) the representations provided for in clause 5.2 being untrue; (iii) the application of the measures provided for in clause 6.8; (iv) a failure to provide information in accordance with clause 6.3; (v) receipt of a demand of a competent authority; (vi) the termination or restriction of the provision of the Services in the relevant jurisdiction.

15.5. Remaining Balance upon Termination of the Agreement. The remaining Balance is withdrawn to the User by the methods available on the Platform after completion of the checks provided for in Section 6 and settlement of the Company’s counterclaims, provided that the withdrawal is not prohibited by applicable law, a demand of a competent authority or a decision of the Financial Intelligence Unit.

The withdrawal is made to payment details that belong to the User and have passed verification, less fees and the User’s debt to the Company. The User is given the ability to initiate a withdrawal within 14 calendar days from the date of the notice of termination of the Agreement or, if the checks have not been completed by that date, from the date of their completion.

The Company does not undertake to complete the checks or make the withdrawal within any particular period. No interest accrues on the remaining Balance or on any amounts withheld.

15.6. Inactive Accounts. An Account is deemed inactive if no transactions have been made by the User on it for 6 consecutive months. The Company may, but is not obliged to, send the User a notice inviting the User to withdraw the remaining Balance within 14 calendar days from the date of the notice.

The Company may terminate the Agreement unilaterally without notice upon expiry of the period specified in the notice or, if no notice was sent, at any time after the Account has been deemed inactive. Any unclaimed balance is recorded by the Company and paid out to the User upon the User’s request in the manner and within the time limits established by the legislation of the Kyrgyz Republic.

15.7. Consequences of Termination. From the moment the Agreement is terminated, the User loses the right of access to the Platform and the Services, except for the access necessary to withdraw the remaining Balance in accordance with clause

15.5. Information and documents obtained by the Company are retained for the period established by clause 6.11, regardless of the termination of the Agreement.

16. Intellectual Property

16.1. License. The User is granted a limited, non-exclusive, non-transferable, non-sublicensable and revocable license to access and use the Platform solely for personal purposes in the manner provided for in the Agreement. The license does not grant the User any rights to the Platform or its content.

16.2. Rights of the Company. The exclusive rights to the Platform, its software, design, content, trademarks, logos and other means of individualization belong to the Company or its licensors. The designations “Antarctic Wallet” and “antarcticwallet.com”, as well as the related logos and elements of the corporate identity, are trademarks of the Company or third parties.

16.3. Restrictions. The User is prohibited from: (i) copying, reproducing, distributing or transferring the content of the Platform without the written permission of the Company; (ii) modifying the Platform, creating derivative works, or reverse engineering, decompiling or disassembling it; (iii) using the Platform to create a similar or competing product; (iv) commercially exploiting the Platform, including by selling, renting or providing access to it to third parties.

16.4. Notice of Infringement. A person who believes that its rights are infringed by content of the Platform may send the Company a notice describing such content, indicating its location on the Platform and stating the claimant’s contact details. The Company may remove infringing content and block the Accounts of Users who repeatedly commit such infringements.

17. Personal Data and Information Exchange

17.1. Processing of Personal Data. The Company processes the User’s personal data in accordance with the legislation of the Kyrgyz Republic on personal data, this Section and the Privacy Policy. The Privacy Policy and the Cookie Policy are separate documents of the Company, are posted on the Platform and do not form part of the Agreement; in the event of a conflict between them and this Section, this Section prevails.

Processing of personal data necessary for the conclusion and performance of the Agreement, including registration and maintenance of the Account, the execution of Trades and other transactions, KYC, EDD, sanctions screening, Scoring, the transfer of information in accordance with clause 6.10, the retention of information in accordance with clause 6.11 and the handling of requests, is carried out on the basis of the Agreement, in performance of the obligations imposed on the Company by law, and in the legitimate interests of the Company in preventing fraud and ensuring the security of the Platform. Such processing does not depend on the Consent, and withdrawal of the Consent does not terminate it.

17.2. Consent to the Processing of Personal Data. By performing the action specified in sub-clause (i) or (ii) of clause 3.1, the User, freely, of the User’s own will and in the User’s own interest, gives Antarctic Wallet LLC (429 Frunze Street, Sverdlovsky District, Bishkek, Kyrgyz Republic) consent to the processing of the User’s personal data on the terms of this clause. The Consent is set out in this clause separately from the other terms of the Agreement and is expressed by an affirmative action of the User.

The Consent is given for the following purposes, to the extent that applicable law requires the consent of the personal data subject for the relevant processing: (i) remote identification and verification of the User, including processing of an image of the User’s face, matching such image against the image in the identity document, and checking that the image was obtained from a live person, including with the use of biometric data; (ii) entrusting the processing of personal data to persons carrying it out on behalf of the Company, including providers of identification and verification services, AML/KYT services, hosting, communication tools and support services; (iii) cross-border transfer of personal data to such persons, as well as to Service Providers, Issuers, banks and payment systems to the extent necessary for the provision of the relevant Services, including to states that may not ensure adequate protection of the rights of personal data subjects; (iv) sending the User informational and advertising messages about the Company’s Services to the contact details specified in the Account and in the Platform interface; (v) analysis of the use of the Platform, including with the use of cookies and similar technologies, for the purpose of improving it; (vi) providing Participants with information about the User as a Referral in anonymized form, and processing related to Reassignment.

The Consent covers the following personal data: surname, first name and patronymic; date and place of birth; citizenship; details of the identity document and its image; residential address; telephone number and email address; facial image and video recording obtained during identification, and biometric data; Telegram identifier, device identifiers, network address and information about access sessions; information about transactions, virtual wallet addresses, source of funds and source of wealth; information about participation in the Referral Program.

The Consent covers the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision, access), anonymization, blocking, deletion and destruction of personal data, performed with or without the use of automated means. Dissemination of personal data to an indefinite range of persons is not covered by the Consent.

The list of persons processing personal data on behalf of the Company, indicating their names and addresses, as well as the list of states to which cross-border transfer is carried out, are posted on the Company’s website and communicated to the User upon request.

The Consent is valid for the term of the Agreement and for 5 (five) years after its termination and, with respect to the purpose specified in sub-clause (iv), until it is withdrawn. The User may withdraw the Consent in full or with respect to any of the purposes by sending a notice through the support service or by using the relevant function of the Platform interface; the Consent with respect to the purpose specified in sub-clause (iv) may also be withdrawn via the link contained in each advertising message. The procedure for withdrawing the Consent is no more complicated than the procedure for giving it. Withdrawal of the Consent does not affect the lawfulness of processing carried out before the withdrawal or processing carried out on the grounds specified in clause 17.1. Withdrawal of the Consent with respect to the purposes specified in sub-clauses (i)-(iii) may make it impossible to carry out identification and to provide the Services for which identification is mandatory, unless the Company has another available method of identification.

The Company may additionally request confirmation of the Consent or of individual parts of it in the Platform interface, including before identification is undergone. The transfer of information to Developers is not covered by the Consent and is carried out in accordance with clause 10.5.

17.3. Cross-Border Transfer. For the purpose of providing the Services, personal data may be transferred outside the Kyrgyz Republic to the persons specified in clause

17.2. Such transfer is carried out on the basis of the Agreement, the Company’s agreements with the recipients obliging them to ensure the confidentiality and security of personal data, and the Consent, if required by applicable law.

17.4. Rights of the User. The User may obtain information about the processing of the User’s personal data and demand that such data be clarified, blocked or deleted if they are incomplete, inaccurate or processed without a lawful basis, subject to the Company’s obligations to retain information established by clause 6.11. Requests are sent through the support service or to the email address specified in Section 20.

17.5. Electronic Communication. The parties acknowledge that communication between them is carried out in electronic form. The Company sends the User messages, notices, agreements, documents and confirmations by posting them on the Platform or by sending in-app notifications, email, SMS or messenger messages. Documents and messages in electronic form have the same legal force as paper documents.

17.6. Contact Details. The User undertakes to keep the contact details specified in the Account up to date, to check incoming notices regularly and to notify the Company immediately of any change in the contact details. The Company is not liable for the User’s failure to receive notices for reasons beyond the Company’s control, including the provision of incorrect or outdated contact details and the classification of messages as spam.

18. Warranties and Liability

18.1. Provision of the Platform. The Platform and the Services are provided on an “as is” and “as available” basis. The Company does not guarantee uninterrupted, error-free and continuous operation of the Platform, that the Services will meet the User’s expectations, or any particular transaction processing times, since these depend on factors beyond the Company’s control, including the condition of blockchain networks and the systems of Service Providers.

Access to the Platform may be suspended or restricted due to maintenance, technical failures, network congestion and other circumstances. The Company takes reasonable measures to restore the operability of the Platform as soon as possible.

18.2. Liability of the Company. The Company is liable to the User for documented actual damage caused through the fault of the Company. The aggregate liability of the Company for claims relating to a specific transaction may not exceed the amount of such transaction, unless otherwise established by mandatory rules of applicable law.

The Company is not liable for losses arising as a result of: (i) acts and omissions of Service Providers, banks, payment systems and other third parties, except where the Company failed to exercise reasonable care in selecting them; (ii) failures, delays and specific features of the operation of blockchain networks; (iii) unlawful acts of third parties, including unauthorized access to the Account not caused by a breach of obligations by the Company; (iv) errors by the User in the payment details, transfer network and other parameters of a transaction; (v) changes in the exchange rate of Virtual Assets, including during the period of checks; (vi) unavailability or restricted operation of third-party services, including Telegram; (vii) non-compliance by the User with the legislation of the state of the User’s citizenship, permanent residence or actual location; (viii) decisions of third parties made on the basis of their own checks, including refusal to accept funds, restriction of transactions, withholding of funds and the charging of fees and charges in connection with a risk assessment.

18.3. Anti-Money Laundering Measures. In accordance with the legislation of the Kyrgyz Republic, the freezing of funds and transactions (deals), the suspension of transactions (deals), a refusal to establish a business relationship or to carry out a transaction (deal), as well as the suspension or termination of a business relationship and the termination of an agreement with a client, do not entail civil or other liability. The Company, its managers and employees are not liable for sending a report to the Financial Intelligence Unit or for damage caused in connection with the proper performance of the obligations provided for by such legislation.

18.4. Excluded Losses. The Company does not compensate lost profit, indirect losses, reputational harm, losses caused by loss of or damage to data, costs of procuring substitute goods, works and services, or losses caused by changes in the exchange rate of Virtual Assets.

18.5. Indemnification of Losses of the Company. The User shall compensate the Company for documented losses, expenses and amounts of sanctions arising as a result of a breach by the User of the Agreement or applicable law, or as a result of the information and representations provided by the User being untrue, including fines and other measures imposed on the Company by competent authorities in connection with such breach. This clause does not apply to losses and sanctions arising for reasons unrelated to breaches on the part of the User.

18.6. Force Majeure. The parties are not liable for non-performance or delayed performance of obligations caused by force majeure, that is, circumstances that are extraordinary and unavoidable under the given conditions and beyond the reasonable control of a party, including natural disasters, military operations, acts of public authorities, changes in legislation, restrictions on access to communication networks, power supply and telecommunications failures, as well as mass failures of and attacks on public infrastructure and blockchain networks. For the duration of such circumstances, performance of the relevant obligations is suspended. The affected party, where possible, notifies the other party.

19. Claims and Dispute Resolution

19.1. Pre-Trial Claim Procedure. Before applying to a court, the parties must comply with the pre-trial claim procedure. A claim is sent in writing to the Company’s address specified in Section 20 or through the support service and must set out the substance of the demand, the circumstances on which it is based, information about the transaction and the claimant’s contact details.

19.2. Time Limits. The Company considers a claim within 30 calendar days from the day of its receipt. The Company may extend the period for considering a claim by notifying the claimant thereof before its expiry, including where consideration of the claim requires obtaining information from Service Providers, banks, payment systems or blockchain analytics service providers.

A claim in respect of a transaction must be filed no later than 6 months from the date of such transaction.

19.3. Jurisdiction. Disputes not settled through the pre-trial claim procedure are subject to consideration by the courts of the Kyrgyz Republic at the location of the Company.

19.4. Governing Law. The Agreement and any obligations arising out of or in connection with it are governed by the law of the Kyrgyz Republic, without regard to its conflict-of-law rules.

19.5. Mandatory Rules of the User’s Law. If the User has consumer status and the mandatory rules of the law of the country of the User’s habitual residence grant the User protection that cannot be derogated from by agreement of the parties, the provisions of this Section apply to the extent they do not conflict with such rules.

20. Miscellaneous

20.1. Language. The Agreement is executed in the Russian language. The Company may post translations of the Agreement into other languages for the convenience of Users; in the event of any discrepancy between the Russian text and a translation, the Russian text prevails.

20.2. Assignment. The User may not transfer or assign its rights and obligations under the Agreement, in whole or in part, without the prior written consent of the Company, except for Reassignment in accordance with Section 13. The Company may transfer its rights and obligations under the Agreement, including to affiliates and legal successors, subject to compliance with the requirements of the law.

20.3. Severability. If any provision of the Agreement is held invalid or unenforceable, this does not render the remaining provisions invalid or unenforceable. An invalid provision shall be replaced by a provision closest in meaning that is permissible under the law.

20.4. No Waiver. Any failure or delay by the Company in exercising any right under the Agreement does not constitute a waiver of such right and does not preclude its further exercise.

20.5. Entire Agreement. The Agreement constitutes the entire agreement between the parties with respect to its subject matter and supersedes all prior arrangements, statements and correspondence on the same subject matter.

20.6. Survival. The provisions of the Agreement which by their nature are intended to remain in effect after its termination, including Sections 6, 14, 16, 17, 18, 19 and 20, as well as clauses 3.4, 8.6, 8.7, 11.4, 13.8, 13.12 and 15.5-15.7, survive the termination of the Agreement.

20.7. Details and Contacts.

• Antarctic Wallet LLC

• Address: 429 Frunze Street, Sverdlovsky District, Bishkek, Kyrgyz Republic

• Registration number: 315372-3301-ООО; TIN: 02104202510171

• Virtual asset exchange operator license No. 167 dated 20 May 2025

• Email: info@antarcticwallet.com

• Support service: https://t.me/Antarcticwalletsupport_bot

Annexes

The Annexes form an integral part of the Agreement and are posted on the Platform. Each Annex indicates the date of its version. An archive of previous versions is maintained on the Platform.

• Annex No. 1 - Fee Schedule

• Annex No. 2 - Prohibited Jurisdictions

• Annex No. 3 - Risk Disclosure

• Annex No. 4 - Referral Program Terms