Terms and Conditions

BIZPAY TERMS & CONDITIONS - GLOBAL 

Last Updated: 10th April 2026

This document outlines the terms and conditions (“Terms”) that govern the use of the Services provided by TransFi. These Terms apply specifically to End Users of Customers and/or Merchants (“you/your”) . By using our Services, You agree to these Terms, including our Privacy Policy, AML/KYC Policy and TransFi Payments (Platform) Terms and conditions of Use . If You do not agree to any part of these Terms, You are not permitted to use the Services. These Terms shall include these Terms & Conditions, our Privacy Policy, and our AML/KYC Policy and TransFi Payments (Platform) Terms and conditions of Use

By accessing or using the Services in any manner, You expressly acknowledge and represent that You have read, understood, and agree to be legally bound by all provisions of these Terms, as amended from time to time.

Please read these Terms carefully, as they set out the Terms on which TransFi will provide You the Services.The Services enable You, subject to applicable laws and the terms herein, to (i) make payments to other authorised recipients through supported payment methods, including QR code-based payment mechanisms and other collection instruments; (ii) receive funds from businesses, individuals, or other permitted sources; (iii) initiate or authorise payouts to vendors, service providers, freelancers, employees, and other designated beneficiaries; (iv) receive payroll, reimbursements, or similar disbursements where You are identified as a beneficiary; and (v) initiate or receive domestic and, where permitted, cross-border remittances. All transactions are subject to availability of the Services, applicable regulatory requirements, and successful processing by relevant banking, payment network, third-party service providers or other Third Party Operators.

If You do not agree to these Terms or any subsequent modification to them, You must not use the Services. TransFi may suspend or terminate Your access to the Services and close Your Account in such circumstances. Continued use of the Services constitutes acceptance of any updated Terms. If You do not agree, You must stop using the Services immediately.

NOTICE: Please read these Terms carefully, as they govern Your use of the Services and affect Your legal rights. BY USING OUR SERVICES OR CLICKING "I ACCEPT" BELOW OR CLICKING A BOX INDICATING YOUR ACCEPTANCE, YOU CONFIRM THAT YOU READ, UNDERSTAND AND AGREE TO BE BOUND BY THESE TERMS , INCLUDING ALL POLICIES, TERMS, AND CONDITIONS INCORPORATED BY REFERENCE..

If You accept these Terms on behalf of a company or other legal entity by accessing or using the Services,clicking "Agree" below or clicking a box indicating acceptance, You represent and warrant that You have the legal authority to bind that entity to these Terms. In such cases, “You” and “Your” (except as used in this paragraph) will refer to that entity. . If You do not have such authority or do not agree to these Terms, then neither you nor that entity may access or use the Services. You are advised to retain a copy of these Terms for Your records.

TransFi may, at its sole discretion, modify , amend, or update these Terms from time to time. When we do so, we will post the updated Terms on the Website and revise the "Last Updated" date. Changes to these Terms become effective on the date they are posted. Your continued access to or use of our Services after the updated Terms are posted constitute Your binding acceptance of the changes. If You do not agree to any revised Terms, You must stop accessing or using the Services immediately.

These Terms constitute a legally binding agreement between You, as an end user of a Customer’s or Merchant’s platform, and TransFi governing Your access to and use of the Services. TransFi provides technical facilitation of payment and Digital Tokens –related transactions made available to You through such platforms.

The Services may involve the use of Digital Tokens ; however, TransFi does not promote or market Digital Tokens as an investment product and does not encourage speculative activity.

In providing the Services, TransFi may rely on licensed or authorized third-party service providers, including custodians, payment processors, liquidity providers, or settlement partners. TransFi is not responsible for errors, delays, failures, or losses caused by such third parties, except to the extent required by applicable law.

TransFi operates subject to applicable legal and regulatory requirements. Your access to the Services and the availability of Your funds may be restricted, delayed, frozen, or otherwise impacted as a result of compliance obligations, legal orders, regulatory actions, or risk management measures.

1. INTRODUCTION

1.1 These Terms constitute a legally binding agreement between You and TransFi Inc. (“TransFi”). By accessing or using the Services, You agree to be bound by these Terms and any other supplemental terms that apply to specific Services and are presented to You in the relevant user flow.

2. DEFINITIONS

• Account: The registered profile by You with TransFi, or created for You in connection with Your use of the Services, through which You access and use the Services.
  
  
• AML (Anti-Money Laundering): The checks and processes implemented by financial institutions and regulated entities to detect, prevent, and report money laundering activities. This includes transaction monitoring (for both fiat and Digital Tokens), risk assessments, and adherence to Applicable Law.
  
  
• Applicable Law: All applicable laws, statutes, statutory instruments, rules, regulations, judgments, decrees, regulatory guidelines, codes of practice, or other requirements of regulatory authorities in any jurisdiction, as amended from time to time, and legally binding on a party.
• Business Day: means any day other than a Saturday, Sunday, or public holiday and the day on which banks are open for business in the country where TransFi operates the relevant Services.
  
  
• Chargeback/Fraud Recall: The reversal of a transaction or request for repayment in respect of a previously settled and/or remitted transaction initiated by the issuing bank, payment networks, payment service providers, or other financial institutions.
  
  
• Customer: A business or platform through which You access the Services. TransFi is not responsible for the operations, products, or obligations of such Customers.
  
  
• Third Party Operator: Any third-party service provider engaged or used by TransFi in connection with the Services, including, without limitation, payment processors, acquirers, banks, liquidity providers, exchanges, custodians, or settlement agents. TransFi is not responsible for any errors, delays, or losses caused by Third-Party Operators
• CTF (Counter-Terrorist Financing): Laws and regulations that aim to prevent the financing of terrorism and terrorist-related activities.
  
  
• Digital Tokens : Any digital representation of value that can be digitally traded, transferred, or stored, including stablecoins (e.g., USDT, USDC), cryptocurrencies (e.g., Bitcoin, Ethereum), and other digital tokens. Digital Tokens are not promoted by TransFi as investments, and TransFi does not provide investment advice.
  
  
• Compliance Checks: The risk-based customer verification and monitoring measures conducted by TransFi or its Third Party Operators in connection with the onboarding and ongoing use of the Services. Compliance Checks may be carried out at different levels depending on the risk profile of the end user and applicable transaction limits, and may include:

• Basic Screening, involving the collection of minimal end-user information and sanctions or watchlist screening without submission of identity documents, with restricted transaction limits;
• Standard Due Diligence, involving submission of identification documents and completion of identity verification procedures, including liveliness or similar checks, following which transaction limits may be increased; and
• Enhanced Due Diligence, involving additional verification measures for higher-risk users or higher transaction thresholds, including submission of proof of funds, source of wealth information, or other supporting documentation, following which maximum transaction limits may be permitted.

• End User/ You/ Your: An individual or legal entity that accesses or uses the Services, either via a Customer platform or a Merchant platform.
  
  
• KYB (Know Your Business): A process of identification under AML/CTF requirements, including additional checks, such as email age verification, internet profiling, adverse media screening, and sanctions screening.
  
  
• Merchant: A business or individual that offers products or services through a Customer’s platform, which allows You to use the Services. TransFi is not responsible for the operations, products, or obligations of such Merchants.
  
  
• PEP (Politically Exposed Person): Individuals who are or have been entrusted with prominent public functions and are subject to enhanced due diligence requirements.
  
  
• Services: The BizPay Services enable You, subject to Applicable Laws, these Terms and the availability of the Services, to (i) make payments to, and receive payments from,Merchants, businesses, and other authorised recipients through supported payment methods, including QR code-based payments, cards, alternative payment methods, and other collection mechanisms made available through the Services; (ii) initiate or authorise payouts to vendors, service providers, freelancers, trade partners, employees, and other designated beneficiaries, and to receive payroll, reimbursements, or similar disbursements where you are identified as a beneficiary; and (iii) initiate or receive domestic and, where permitted, cross-border remittances. The Services may further include, where applicable, the processing, settlement, and conversion of funds between fiat currencies and supported Digital Tokens and may provide access to features such as multi-currency accounts for holding and transacting in supported currencies or Digital Tokens, issuance of IBANs or equivalent account identifiers, and functionality supporting one-to-many or many-to-one payments, recurring transactions, notifications, and other ancillary services. All transactions are processed through the TransFi’s technology infrastructure and may involve one or more regulated banking partners, payment system providers, liquidity providers, or other Third Party Operators, and are subject at all times to Applicable Law, regulatory requirements, network rules, and successful processing by such Third Party Operators.
  
  
• TransFi/us/we/our: means and shall include, without limitation, all of its current and future subsidiaries, affiliates, holding companies, group entities, successors, permitted assigns, and any entity that directly or indirectly controls, is controlled by, or is under common control with TransFi, whether existing or formed, established, acquired, or reorganised thereafter. For ease of reference, the indicative list of such entities is provided in Annexure A, which may be updated from time to time and shall include all subsidiaries and affiliates of TransFi, whether or not expressly listed therein. Any reference to “TransFi” shall be deemed to include all such entities, and all rights, obligations, protections, and limitations applicable to TransFi shall apply equally and collectively to each of them.
  
  
• TransFi Wallet: A custodial digital wallet offered by TransFi for the purpose of storing and managing Digital Tokens . TransFi’s Third Party Operators manage and hold the wallet’s End User’s private keys.

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DISCLAIMER: The risk of loss in trading or holding Digital Tokens can be substantial. You should be aware that the price or value of Digital Tokens, including, but not limited to, cryptocurrencies, NFTs, can change rapidly, decrease, and potentially even fall to zero. Therefore, You should carefully consider whether trading or holding Digital Tokens is appropriate for You in light of Your financial circumstances.

You acknowledge that if You use Your own custodial digital wallet not offered by TransFi ("third party wallet”) to access the Services, TransFi is not responsible for and does not hold the private keys for your Digital Tokens wallet or any other security information to access your Digital Tokens and TransFi is not responsible for any loss of Digital Tokens resulting from theft, loss, or mishandling of private keys or other security information outside its control.

Every purchase and sale of Digital Tokens is executed on and confirmed by the respective network of that Digital Token . The confirmation process takes time (typically less than one hour, but potentially one day or more). An order is not complete until it is confirmed. Digital Tokens associated with orders that are pending will be designated accordingly.

A transaction between a buyer and a seller occurs peer-to-peer on a public blockchain. TransFi does not guarantee that You will receive Your Digital Token, as transactions may fail for a variety of reasons, including but not limited to, network congestion, technical issues with blockchain, or another buyer completing the purchase of the Digital Token before Your transaction is confirmed. If your transaction fails, TransFi will use reasonable efforts to facilitate a refund of any applicable fees, but TransFi is not responsible for any losses, delays, or damages arising from failed transactions.

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3. LEGAL RELATIONSHIP BETWEEN TRANSFI AND THE MERCHANT, CUSTOMER

3.1 These Terms form a contract between TransFi and End Users. Where an End User accesses the Services through a Customer or Merchant, this does not prevent the End User from having separate rights and obligations as against the Customer or Merchant under their own terms.

3.2 The Services are provided to You via a Customer or Merchant platform. You must read and accept these Terms before using the Services. By accessing or using the Services through a Customer or Merchant platform, You agree to be bound by these Terms.

3.3 We may assign or transfer our rights in these Terms to any member of our Group company or any affiliate without your consent, listed under Annexure A and as may be amended from time to time by TransFi.. You may not assign these Terms without our prior written consent of TransFi.

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4. ACCOUNT CREATION

4.1 To use the Services, You must create an Account. To register as an End User for the first time, You will be required to submit certain personal information, such as your name, email address, contact number, street address, and zip code if You are an individual. For business End Users, the registered name, email address, business registration date, and registration number of the legal entity shall be required . TransFi may also request additional documentation to verify Your date of birth, identification number (such as a social security number), and country of residence/nationality as part of our Compliance Checks . If TransFi is unable to authenticate Your identity, You may not have access to our Services. By creating an Account, You represent and warrant that all information You provide is accurate, current, and complete, and You agree to maintain and promptly update Your information as necessary.

4.2 By creating an Account, You represent and warrant that You: (a) are at least 18 years of age (or the age of majority in your jurisdiction) and have legal capacity to enter into these Terms , but not older than 70 years, beyond which TransFi restricts the usage by an End User.; (b) are an individual, legal person, or a legal entity with the full legal capacity and authority to enter into these Terms; and (c) have not previously been suspended or removed from using our Services.

4.4 You authorize Us, directly or through Third-Party Operators , to make any inquiries We deem necessary to validate Your information. This may include requesting further information and/or documentation regarding Your use of the Services or identity, requiring You to take steps to confirm ownership of Your email address, mobile phone number, or bank accounts, credit or debit cards, digital wallets, payment accounts (e.g. local wallets), prepaid cards or other financial assets used for transactions, and verifying Your information against third-party databases or through other sources.

4.5 We reserve the right to reject Your application to create an Account or to terminate an existing Account, for any reason, at Our sole discretion, subject to Applicable Law. However, the termination of Your Account will not affect any rights You may have related to your Digital Tokens held in a TransFi Wallet, any Third Party Wallet and You remain responsible for any obligations, liabilities, or fees incurred prior to termination.

4.6 Where We suspend or restrict an Account for compliance, fraud, or security reasons, we may delay or prevent withdrawals or transactions as required by Applicable Law, regulatory guidance, or risk management. Where permitted, We will provide You with information on available options to withdraw or transfer remaining balances, subject to verification and applicable holds.

4.7 You must not impersonate any other person or entity to access our Services or access the Account of any other End User without that person’s prior permission, We may request proof of such permission. You must not create any Accounts by automated means or under false or fraudulent pretenses.

4.8 You agree that You will use the Services only in a manner that complies with Applicable Laws and that you are solely responsible for any improper or unlawful activity in connection with the registration or use of your Account, including any misrepresentations made in connection with the creation of Your Account.

4.9 We will share Your information and transaction details with Third-Party Operators who fulfill transaction requests in accordance with our Privacy Policy TransFi Privacy Policy.

4.10 You are responsible for maintaining the security of Your Account. If You become aware of any unauthorized use of Your Account credentials for Our Services, you must immediately notify Us at compliance@transfi.com.

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5. RISK, LIABILITY AND SERVICE DISCLAIMERS

5.1 The Services involve Digital Tokens , including cryptocurrencies, stablecoins . TransFi does not promote, recommend, or provide advice on the purchase, sale, or holding of Digital Tokens for speculative or investment purposes. Trading or holding Digital Tokens carries a high risk of loss, including the potential loss of Your entire investment. You are solely responsible for evaluating whether using the Services is appropriate for Your financial situation and risk tolerance.

5.2 Some Services are facilitated by Third-Party Operators, such as payment processors, banks, liquidity providers, exchanges, and custodians. TransFi does not control these third parties and is not responsible for any errors, delays, or losses caused by them, except as required by Applicable Law. You acknowledge and accept that reliance on Third-Party Operators carries inherent risks.

5.3 TransFi is subject to Applicable Law and regulatory obligations.Regulatory actions, compliance measures, or changes in law may affect Your ability to access or use the Services and may impact Your funds or Digital Tokens . You acknowledge and accept that TransFi is not liable for any such impact arising from compliance with Applicable Law or regulatory measures.

5.4 TransFi does not guarantee the performance, security, or success of any transaction or investment in Digital Tokens . Transactions may fail due to network congestion, blockchain issues, or other factors beyond TransFi’s control. In such cases, TransFi will use reasonable efforts to facilitate refunds of applicable fees, but is not liable for losses or damages resulting from failed or delayed transactions.

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6. TRANSACTIONS LIMITS AND COMPLIANCE CHECKS

5.1 TransFi adheres to high standards of compliance with policies and procedures designed to prevent money laundering, criminal activities, market abuse, and conflicts of interest. All TransFi employees are committed to the highest ethical standards.

5.2 The use of our Services is subject to transaction thresholds that apply to the volume You may transact or transfer within a given period (e.g., per transaction limit, daily transaction limit, or monthly transaction limit). You can view your specific transaction limits by logging into your Account. These limits may vary depending on Your payment method, Compliance Checks, geography, KYC levels, and other factors, as determined by TransFi’s internal risk assessment and compliance policies. We reserve the right to modify applicable limits as We deem necessary to comply with Our risk management and regulatory obligations. If You wish to request an increase to your transaction limits beyond the posted amounts, You may submit a request to compliance@transfi.com.

5.3 We may require you to submit additional information about yourself and provide supporting documentation if you request an increase to your transaction limits. TransFi, in its sole discretion, may refuse to grant an increase to Your limits, or We may lower Your limits at a later time, even if You have previously completed Compliance Checks.

5.4 Our compliance program is based on the following pillars:

• Know Your Customer (KYC) and Know Your Business (KYB): We conduct KYC/KYB checks to determine if any Customers, Merchants, or End Users are subject to sanctions, are PEPs, or have any adverse media reporting.
  
  
• Transaction Monitoring: All fiat transactions are monitored for potential AML risks across all payment methods. This monitoring covers risks associated with geographic location, transaction size, and Customer behavior. All Digital Token transactions are monitored for risks related to sanctioned jurisdictions, dark web activity, child abuse, compromised assets, or other criminal activity. For Digital Token transaction monitoring, we employ a range of rules to assess transaction hash and Digital Token wallet risks.
  
  
• Fraud Monitoring: Our fraud monitoring processes include name matching, internet and social media risk profiling, device and IP checks, transaction behavior analysis, and browsing behavior checks.
  
  
• Travel Rule Compliance: We comply with travel rule Compliance, and are working on expanding the control to all geographies
• Data Storage and Management: Data, including payer and recipient information, payment methods, transaction details, and browsing behavior, are stored in local clouds in accordance with applicable data localization requirements.

5.5 Our compliance processes also include:

• Risk limits on End Users, such as per-transaction, and daily and monthly transaction limits.
  
  
• Prohibitions on certain business types: For a current and complete list of prohibited business types, please refer to TransFi’s AML/KYC Policy, which is subject to change.
  
  
• Compliance Checks requirements for End Users presenting a higher risk, which may involve requests for additional documents and verification. High-risk businesses include but are not limited to: (a) custodial crypto-asset services; (b) other non-custodial crypto-asset services; (c) money services/payments/other financial services; (d) licensed gambling services; and (e) any End User with a PEP beneficial owner.
• Prohibited Jurisdictions: For a current list of prohibited jurisdictions, please refer to TransFi’s internal AML/KYC Policy, which is subject to change AML/KYC Policy.

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6. PURCHASE, SALE, AND TRANSFER OF DIGITAL TOKENS

6.1 The Services may include, either directly by TransFi or through Third-Party Operators, as applicable:

(a) facilitating the exchange of fiat currency to Digital Tokens and Digital Tokens to fiat;
(b) facilitating the exchange of one Digital Token for another Digital Token; and
(c) enabling the custody or administration of Digital Tokens through a TransFi Wallet, where offered.

The availability of any Service depends on the applicable TransFi entity, Your jurisdiction, and applicable regulatory permissions. TransFi is not responsible for delays, errors, or failures caused by Third-Party Operators or regulatory restrictions.

6.2 When You submit an order or instruction through the Services, You authorise TransFi to process that order or instruction and to engage Third-Party Operators as necessary to execute, route, or settle the transaction. TransFi does not act as Your fiduciary, investment advisor, or broker, and does not provide investment advice or recommendations..

6.3 For each transaction You make using Our Services, you will be required to: (a) provide all relevant transaction information, including fiat currency, Digital Token type, transaction value, sender information, and recipient information; (b) provide fiat account information, which may include bank account, credit card, debit card, or other payment method details, such as identification numbers and associated details; (c) indicate whether you are making a one-time transaction; and (d) provide the relevant digital wallet address.

6.4 We charge a fee for using Our Services, which may be a percentage of the Digital Token purchase price or a fixed fee (the “Fee”). The applicable Fee will be displayed to You before You confirm the transaction.

6.5 While We may provide a price indication for the Digital Token being purchased, We do not control the entire transaction process. The final price may differ from the indicated price due to factors such as network fees, foreign exchange conversion rates, liquidity, or market fluctuations. You acknowledge and accept that the final transaction price may vary from any initial price indication.

DISCLAIMER: While TransFi strives to process payments within the estimated processing times, circumstances beyond Our reasonable control, such as banking system issues or regulatory checks, may cause delays. TransFi will use reasonable efforts to minimize such delays and keep You informed, but We will not be responsible for any resulting loss, delay, damages or inconvenience caused by events beyond Our control.

7. CANCELLATIONS AND REFUNDS

7.1 Except as expressly provided herein, all transactions are final once executed . However, transactions may be reversed, delayed, cancelled, or refunded where required by Applicable Law, payment network rules (including chargebacks or recalls), compliance checks, suspected fraud, sanctions screening, technical failures, or Third-Party Operator reversals.

7.2 Due to the volatile nature of Digital Token markets, orders cannot be recalled or retrieved under any circumstances once executed.

7.3 Upon delivery of the Digital Token to Your designated wallet or the fiat funds to Your designated account, TransFi's obligations to You are fully discharged, and You will have no further claim or right against TransFi related to that specific transaction.

7.4 Where we cancel or refund a transaction for compliance, fraud, or technical reasons, We may deduct fees and costs reasonably incurred (including Third-Party Operator fees) and will refund the remaining amount to the original source of funds where possible, or otherwise as required by Applicable Law.

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8. RESPONSIBILITIES AND OBLIGATIONS

8.1. END USER RESPONSIBILITIES AND OBLIGATIONS

You must ensure that by using TransFi's Services You accept and acknowledge to the following responsibilities:

• Accurate Information: Providing accurate, complete, and up-to-date information when using the Services.You must promptly update Your information if it changes.
  
  
• Compliance with Laws and Regulations: You must comply with all Applicable Laws and ensure that Your r use of Services does not involve or facilitate any illegal, unethical, or prohibited activities, including but not limited to money laundering, terrorist financing, sanctions evasion, or other criminal activity..
  
  
• Security and Confidentiality: You are responsible for maintaining the security and confidentiality of Your Account credentials and any other sensitive information related to Your transactions. You must not share Your login credentials or allow others to use Your Account.
  
  
• Transaction Validity: You must ensure that all transactions You initiate or receive through the Services are properly authorized,intended and accurately reflect the intended recipient, amount, and Digital Token or fiat currency.

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• Notification Obligations: You must promptly notify TransFi if You become aware of any unauthorized access, suspicious activity, or errors affecting Your Account or transactions.
  
  
• Prohibited Activities: You must not:
  
  • Attempt to gain unauthorized access to TransFi systems, other users’ Accounts, or Third-Party Operator systems;
  • Interfere with the operation, security, or integrity of the Services;
  • Use the Services in violation of these Terms or any applicable regulatory or contractual restrictions.
• Responsibilities for Compliance: You must understand and comply with any legal obligations that apply to Your use of Services, including but not limited to Compliance Checks, AML/KYC requirements and any transaction limits imposed by TransFi or applicable regulators.

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• Device and Software Security: You must ensure that any device, software, or network used to access the Services is secure, free from malware, and compatible with the Services.
  
  
• Cooperation with Compliance and Audits: You must cooperate with TransFi, regulators, or Customers in any investigations, audits, or compliance checks related to Your Account or transactions.
• Taxes and Reporting: You are solely responsible for any taxes, reporting obligations, or other governmental requirements arising from Your transactions using the Services.
• Acknowledgment of Risk: You acknowledge that Digital Token transactions carry inherent risks, including volatility, potential loss, network or blockchain failures, and reliance on Third-Party Operators. You accept these risks and are responsible for evaluating whether using the Services is appropriate for Your financial situation and risk tolerance.
• Additional Responsibilities: You must respond promptly to any communication or requests for information from TransFi, the Merchant, or the Customer regarding Your transactions or Account.

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9. OUR RIGHTS

We reserve the following rights, which are not obligations of TransFi:

(a) to modify, substitute, eliminate, or add to any of our Services where such changes are necessary due to legal, regulatory, security, or operational requirements, with reasonable notice provided to You where feasible;

(b) to suspend, restrict or terminate Your Account or accesses to the Services if You violate these Terms, Applicable Law or any compliance requirements, , or where required for regulatory, fraud-prevention, or security purposes; ;

(c) to monitor, review, modify, filter, disable, delete, and remove content, data or information associated with Your use of the Services, where necessary to protect the integrity, security, or lawful operation of the Services; t;

(d) to automatically update, patch or modify any software, systems or components used to Provide the Services ;

(e) to cooperate with any law enforcement, court, regulators or government investigation or order, or any Third Party Operator requesting or directing that You disclose information or content that You provide to Us

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10. CONDUCT

10.1 By way of example, and not as a limitation, You shall not:

(a) breach these Terms or any other terms and conditions, and any agreement incorporated by reference herein;

(b) violate any Applicable Law, statute, ordinance, or regulation;

(c) infringe any TransFi’s intellectual property (IP) or any third party’s copyright, patent, trademark, trade secret, or other intellectual property rights, or rights of publicity or privacy;

(d) create or maintain more than one Account for yourself without our express written authorization, including, but not limited to, using a name that is not your own, using a temporary email address or phone number, or providing any other falsified personal information;

(e) act in any way that is unlawful, libelous, defamatory, harassing, abusive, fraudulent, obscene, or otherwise objectionable (including, without limitation, displaying any content on our solution or APIs or using our Services to transmit content that contains any hate-related or violent content);

(f) provide false, inaccurate, or misleading information;

(g) send or receive Digital Tokens that could reasonably be believed (by us or by others) to have been potentially fraudulently acquired;

(h) use our Services or the services of our partners and/or customers in a manner that results in or may result in complaints, disputes, claims, reversals, Chargebacks, fees, fines, penalties, or losses to us or any of our partners;

(i) distribute or facilitate the distribution of viruses, worms, defects, Trojan horses, corrupted files, hoaxes, or any other items of a destructive or deceptive nature, or otherwise interfere with, circumvent, disable, or attempt to interfere with, circumvent, or disable the solution or APIs, or our Services, the proper working of the solution or APIs or our Services, security features of the solution or APIs, or our Services, or the equipment connected to the solution or APIs or our Services;

(j) take any action that may cause Us to lose any of the services from our internet service providers, payment processors, or other suppliers or Third Party Operators ;

(k) transmit or otherwise make available through our Services any unsolicited commercial messages (i.e., spam), junk mail, pyramid schemes, chain letters, or similar materials or information;

(l) interfere with other users enjoyment of our Services;

(m) exploit our Services for any unauthorized commercial purpose;

(n) reformat or frame any portion of the solution or APIs, or Services;

(o) use any robot, spider, site search/retrieval application, or other device to retrieve or index any portion of our solution or APIs or content on our Services, or to collect information about our Customers for any unauthorized purpose;

(p) use any metatags or any other “hidden text” using any of our marks;

(q) access or use our Services for the purpose of creating a product or service that is competitive with any of our products or services, including, without limitation, our Services; or

(r) engage in any other activity that we, at our sole discretion, deem to be harmful to TransFi, Our business, or Third Party Operators.

10.2 If You engage in any of the activities prohibited by Section 9.1, We may, at our sole and absolute discretion, without notice to you and without limiting any of our other rights or remedies at law or in equity, immediately suspend or terminate Your Account and/or prevent you from accessing our Services. If We prevent you from accessing our Services, you will be responsible for all losses, liabilities or obligations that result from or arising from Your use of the Services prior to or resulting from the prohibited conduct. . You are further prohibited from using the Services in any manner that is not expressly and unambiguously authorized under these Terms.

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11. TERMINATION

Subject to your compliance with these Terms and all Applicable Laws, You may terminate your acceptance of these Terms at any time by ceasing to be a End User with Us and discontinuing all access to and use of Our Services by sending us an email at compliance@transfi.com. We, at our sole discretion and for any reason or no reason, may terminate your acceptance of these Terms and suspend and/or terminate Your Account and access to all or any portion of Our Services, subject to Applicable Law. Any suspension or termination of Your access to your Account and/or our Services may be without prior notice, and We will not be liable to You or to any third party for any such suspension or termination. If we terminate these Terms or suspend or terminate your access to or use of Our Services due to Your breach of these Terms or any suspected fraudulent, abusive, or illegal activity, then termination of these Terms will be in addition to any other remedies We may have at law or in equity. Upon any termination or expiration of these Terms, whether by You or Us, you may no longer have access to information that You may have provided in connection with our Services or that is related to your Account, and You acknowledge that we will have no obligation to maintain any such information in Our databases or to forward any such information to You or to any third party.

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12. INTELLECTUAL PROPERTY OWNERSHIP

12.1 We retain all rights, title, and interest in all of our intellectual property, including, without limitation, inventions, ideas, concepts, code, discoveries, processes, marks, methods, software, visual interfaces, graphics, designs, systems, services, "look and feel," organization, compositions, formulae, techniques, information, and data (collectively, the "TransFi IP"). The TransFi IP is protected by copyright, trade dress, patent, and trademark laws, international conventions, and other relevant intellectual property and proprietary rights and applicable laws. You may not use any of the TransFi IP for any reason without our prior written consent. We reserve all rights in and to the TransFi IP not expressly granted to you in these Terms.

12.2 Subject to these Terms and any applicable Business Services Agreement:

1. You are granted a limited, revocable, non-exclusive licence to access and use the Services for Your own lawful use.
2. You agree not to remove, alter, or obscure any proprietary notices provided in or with the material on the Product or any other TransFi IP. You will not modify, alter, convert, adapt, clone, replicate, duplicate, copy, translate, reverse engineer, or otherwise manipulate any portion of our Services or the TransFi IP. All rights not expressly granted in these Terms are reserved.

12.3 You may choose to submit comments, bug reports, ideas, or other feedback about our Services, including, without limitation, suggestions for improving our Services (collectively, "Feedback"). By submitting any Feedback, You agree that we are free to use such Feedback at our discretion and without additional compensation to You and to disclose such Feedback to third parties (whether on a non-confidential basis or otherwise). If necessary under Applicable Law, You hereby grant Us a perpetual, irrevocable, non-exclusive, transferable, worldwide license under all rights necessary for us to incorporate and use Your Feedback for any purpose.

13. THIRD-PARTY SERVICE OPERATORS

13.1 The Services, including the TransFi Wallet, may operate through or rely on Third Party Operators (including, without limitation, payment processors, exchanges, liquidity providers, and settlement agents). Third Party Operators may require you to agree to separate terms and conditions, which you must review and accept directly with them .You are responsible for complying with all applicable Third-Party Operator terms when using the Services. TransFi is not a party to any agreements between You and Third-Party Operators and does not control their actions, operations, products, services, or financial condition. Nothing in these Terms creates a contractual relationship between You and any Third-Party Operator. You acknowledge and agree that TransFi is solely responsible for the Services provided directly by TransFi and for maintenance and support of those Services only . Fees related to services offered by Third-Party Operators are governed by separate terms and conditions, as well as agreements between you and the respective Third Party Operator . You acknowledge that the use of such third-party services may involve settlement, technology, liquidity, operational, and counterparty risks which You accept

13.2 You expressly agree that TransFi shall not be responsible or liable for any delays, losses, or damages (including any loss of funds) arising from the acts, omissions, insolvency, liquidity issues, or bankruptcy of any Third Party Operators ,. Such risks are inherent in the use of Third-Party Operators and are accepted by You. Any such risks shall be borne solely by You.

13.3 TransFi provides no warranties with respect to services provided by Third-Party Operators. Any warranties applicable to third-party services are provided solely by the relevant Third-Party Operator, if at all.

13.4 Third-Party Service Providers are solely responsible for the Services they provide to You including, but not limited to: (a) product liability claims; (b) any claim that the services fail to conform to any applicable legal or regulatory requirement; (c) claims arising under consumer laws, privacy laws, or similar legislation; and (d) intellectual property claims. Such claims must be directed to the relevant Third-Party Operator, not to TransFi.

13.5 TransFi does not guarantee the availability, timeliness, or completion of any transaction or settlement executed through Third-Party Operators , and assumes no liability for any disruption, delay, or failure in settlement arising therefrom.

15. PROMOTIONS AND REFERRALS

We may, from time to time, operate contests, promotions, referral programs, or other similar activities (“Promotions and Referrals”) that may require you to submit material or information about yourself. Any Promotions and Referrals may be governed by separate rules that may contain certain eligibility requirements, such as restrictions on age or geographic location. You are responsible for reading all applicable rules relating to the Promotions and Referrals to determine whether you are eligible to participate. If you enter or participate in any Promotions and Referrals, you agree to abide by and comply with all rules of the respective Promotions and Referrals. All Promotions and Referrals will be optional, and you should not enter or participate in such Promotions and Referrals if you do not agree to abide by and comply with all applicable rules.

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16. USER REPRESENTATIONS AND WARRANTIES

By using our Services, You represent and warrant that:

16.1 Authority. You have all requisite power and authority to execute and deliver these Terms, to purchase and use our Services, and to carry out and perform your obligations under these Terms. If you are an individual, you are at least eighteen (18) years old and of sufficient legal age and capacity to purchase and use our Services. If you are an entity, you are duly organized, validly existing, and in good standing under the laws of your domiciliary jurisdiction and each jurisdiction where you conduct business.

16.2 No Conflict. The execution, delivery, and performance of these Terms will not result in any violation of, be in conflict with, or constitute a material default under, with or without the passage of time or the giving of notice: (a) any provision of your governing documents, if applicable; (b) any provision of any judgment, decree, or order to which you are a party, by which you are bound, or to which any of your material assets are subject; (c) any material agreement, obligation, duty, or commitment to which you are a party or by which you are bound; or (d) any laws, regulations, or rules applicable to you.

16.3 No Consents or Approvals. The execution and delivery of, and performance under, these Terms require no approval or other action from any governmental authority or person other than You.

16.4 Lawful Purpose. You will use the Services solely for lawful purposes and in compliance with all Applicable Laws, including sanctions, anti-money laundering, counter-terrorist financing, tax, foreign exchange, and securities laws.

16.5 Sanctions Status. You are not located in, organized under the laws of, or ordinarily resident in any jurisdiction subject to comprehensive sanctions, nor are you listed on any sanctions or restricted-party list maintained by any governmental authority.

16.6 Source of Funds. All funds and Digital Assets used in connection with the Services are derived from lawful sources, and you are the legal and beneficial owner or are duly authorized to transact on behalf of the beneficial owner.

16.7 No Reliance / Risk Understanding. You understand the risks associated with Digital Assets, including volatility, loss of value, technology risks, and regulatory uncertainty, and you are not relying on TransFi for investment, legal, tax, or financial advice.

16.8 Accurate Information. All information you provide to TransFi is true, accurate, and complete, and you will promptly update such information as needed.

16.9 No Prohibited Activity. You are not using the Services on behalf of any person or entity engaged in illegal, fraudulent, deceptive, or prohibited activity.

16.10 Tax Responsibility. You are solely responsible for determining and fulfilling any tax obligations arising from your use of the Services.

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17. SANCTIONS

Your use of the Services is subject to all applicable export controls and economic sanctions laws and regulations (“Sanction Laws”) . By sending, buying, or selling Digital Tokens through the Services, You agree that you will comply with those Sanction Laws . You represent, warrant and undertake that you are not and will be not :

• located in, under the control of, or a national or resident in, or operating from, under the control of, or a national or resident of any jurisdiction subject to comprehensive economic sanctions or embargoes under Sanction Laws; or
• listed on, owned or controlled by, or acting on behalf of any person or entity listed on any sanctions-related restricted party list maintained by the United Nations, United States (including OFAC), the European Union, the United Kingdom, or any other relevant governmental authority;
• You further represent, warrant, and undertake that:
  
  • you will not use the Services, directly or indirectly, for the benefit of, or in connection with, any person, entity, or jurisdiction subject to Sanctions Laws;
  • you will not use the Services to conduct, facilitate, or support any transaction that could cause TransFi or any Third-Party Operator to violate Sanctions Laws;
• TransFi may monitor, screen, and restrict access to the Services at any time to comply with Sanctions Laws. TransFi may, where required by law or its compliance obligations, refuse to process, block, freeze, or reverse transactions, suspend or terminate your Account, or restrict access to the Services without prior notice.
• TransFi may request additional information or documentation at any time to verify your identity and compliance with this Section, and failure to provide such information may result in suspension or termination of the Services.

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18. RECOVERY OF LOSSES

TransFi reserves the right to deduct from your Account or any balances held with TransFi any financial losses suffered due to your initiation of a Chargeback procedure with your bank, financial institution, or any other party. These losses may include, but are not limited to, administration fees levied by the card acquirer and card schemes, as well as the monetary value of the Digital Tokens ordered or purchased.

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19. DISCLAIMERS

19.1 "AS IS" AND "AS AVAILABLE." YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOUR ACCESS TO AND USE OF OUR SERVICES IS AT YOUR SOLE RISK, AND THAT OUR SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, TRANSFI AND ITS MEMBERS, MANAGERS, OFFICERS, EMPLOYEES, ADVISORS, REPRESENTATIVES, AFFILIATES, AND AGENTS (THE "COMPANY PARTIES") MAKE NO EXPRESS WARRANTIES AND HEREBY DISCLAIM ALL IMPLIED WARRANTIES REGARDING OUR SERVICES AND ANY PART OF THEM (INCLUDING, WITHOUT LIMITATION, OUR SERVICES OR ANY EXTERNAL WEBSITES), INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, CORRECTNESS, ACCURACY, OR RELIABILITY. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, THE COMPANY PARTIES DO NOT REPRESENT OR WARRANT TO YOU THAT (A) YOUR ACCESS TO OR USE OF OUR SERVICES WILL MEET YOUR REQUIREMENTS, (B) YOUR ACCESS TO OR USE OF OUR SERVICES WILL BE UNINTERRUPTED, TIMELY, RISK-FREE, OR FREE FROM ERROR, (C) USAGE DATA PROVIDED THROUGH OUR SERVICES WILL BE ACCURATE, (D) OUR SERVICES OR ANY CONTENT, SERVICES, OR FEATURES MADE AVAILABLE ON OR THROUGH OUR SERVICES ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR (E) DATA WILL BE COMPLETELY SECURE OR IMMUNE FROM UNAUTHORIZED ACCESS.

19.2 PERSONAL RISKS. YOU ACCEPT THE INHERENT SECURITY RISKS OF PROVIDING INFORMATION AND DEALING ONLINE OVER THE INTERNET AND AGREE THAT WE HAVE NO LIABILITY OR RESPONSIBILITY FOR ANY BREACH OF SECURITY UNLESS IT IS DUE TO TRANSFI’S GROSS NEGLIGENCE. YOU WILL IMPLEMENT REASONABLE AND APPROPRIATE MEASURES DESIGNED TO SAFEGUARD ACCESS TO (A) ANY DEVICE ASSOCIATED WITH YOU AND UTILIZED IN CONNECTION WITH YOUR PURCHASE OR USE OF OUR SERVICES; AND (B) ANY OTHER USERNAME, PASSWORDS, OR OTHER LOGIN OR IDENTIFYING CREDENTIALS.

19.3 THIRD-PARTY OPERATORS DISCLAIMER. TRANSFI FACILITATES THE CREATION AND MANAGEMENT OF TRANSFI WALLET FOR USERS AND END USERS THROUGH THIRD-PARTY OPERATORS , WHO ARE SOLELY RESPONSIBLE FOR KEY MANAGEMENT, WALLET SECURITY, AND COMPLIANCE WITH APPLICABLE REGULATIONS RELATED TO WALLETS. TRANSFI IS NOT LIABLE FOR ANY LOSSES ARISING FROM WALLET SERVICES PROVIDED BY THIRD-PARTY SERVICE PROVIDERS, INCLUDING KEY MANAGEMENT FAILURES, AS THEY ARE SOLELY RESPONSIBLE FOR THE MANAGEMENT AND SECURITY OF THE TRANSFI WALLET. TRANSFI DISCLAIMS ALL LIABILITY FOR ANY LOSS, BREACH, OR FAILURE ARISING FROM THE THIRD-PARTY OPERATORS MANAGEMENT OF TRANSFI WALLET. TO THE MAXIMUM EXTENT PERMITTED BY LAW, TRANSFI IS NOT RESPONSIBLE FOR DELAYS, FAILURES, INSOLVENCY, CYBER INCIDENTS, OR OPERATIONAL ERRORS OF THIRD-PARTY PROVIDERS.

19.4 RISK DISCLOSURES, ASSUMPTION OF RISKS, AND RELEASE OF TRANSFI. OTHER THAN AS EXPRESSLY SET FORTH IN THIS AGREEMENT, TRANSFI SHALL NOT BE LIABLE FOR ANY RISKS INHERENT IN THE SERVICES OR RELATED TRANSACTIONS, INCLUDING WALLET TRANSACTIONS, THAT MAY BE INCURRED BY THE END USER OR THE CUSTOMER AND THEIR MERCHANTS AS A RESULT THEREOF. THE END USER, CUSTOMER, AND THEIR MERCHANT AGREE TO AND DO HEREBY: (I) RELEASE TRANSFI FROM ANY AND ALL LIABILITY RELATED TO OR ARISING FROM RISKS INHERENT IN THE SERVICES AND RELATED TRANSACTIONS, INCLUDING WALLET TRANSACTIONS, EXCEPT AS EXPRESSLY SET FORTH IN THIS AGREEMENT; AND (II) ASSUME ALL RISKS INHERENT IN THE SERVICES AND RELATED TRANSACTIONS, INCLUDING BUT NOT LIMITED TO THE FOLLOWING:

• THE RISK THAT ANY THIRD-PARTY SERVICE PROVIDERS OF TRANSFI CEASE TO OPERATE, RENDERING A TRANSACTION IMPOSSIBLE AND ENTIRELY WITHOUT USE.
• THE MARKET FOR DIGITAL TOKENS MAY COLLAPSE WITHOUT WARNING OR DISCERNIBLE LOGIC.
• THERE IS A RISK THAT CHANGES IN APPLICABLE LAW COULD ADVERSELY AFFECT THE CUSTOMER’S RIGHT TO LEGALLY USE, TRANSFER, EXCHANGE, AND/OR OBTAIN VALUE FROM DIGITAL TOKENS . IT MAY BE ILLEGAL, NOW OR IN THE FUTURE, TO OWN, HOLD, SELL, OR USE DIGITAL TOKENS IN ONE OR MORE COUNTRIES.
• TRANSACTIONS IN DIGITAL TOKENS ARE, AS A RULE, IRREVERSIBLE. CONSEQUENTLY, LOSSES DUE TO FRAUDULENT OR ACCIDENTAL TRANSACTIONS ARE GENERALLY NOT RECOVERABLE. ONCE A TRANSACTION HAS BEEN RECORDED ON THE APPROVED NETWORK, IT IS NOT REVERSIBLE. THE CUSTOMER ACKNOWLEDGES THAT IT IS POSSIBLE THAT, THROUGH COMPUTER OR HUMAN ERROR OR THROUGH THEFT OR FRAUD, DIGITAL TOKENS COULD BE TRANSFERRED IN INCORRECT AMOUNTS OR TO UNAUTHORIZED THIRD PARTIES.
• SOME TRANSACTIONS SHALL BE DEEMED TO BE MADE WHEN RECORDED ON THE APPROVED NETWORK, WHICH IS NOT NECESSARILY THE DATE OR TIME THAT THE CUSTOMER INITIATED THE TRANSACTION.
• DIGITAL TOKENS MAY BE TARGETS OF FRAUD AND CYBER-ATTACKS. ON DEVICES AND WALLETS, SUCH FRAUD AND ATTACKS CAN RESULT IN TOTAL LOSS TO THE CUSTOMER. IN THE WALLET, TRANSFI MAKES COMMERCIALLY REASONABLE EFFORTS TO VERIFY THAT THE CUSTOMER IS THE TRUE INITIATOR OF TRANSACTIONS, BUT WHERE THE CUSTOMER’S ACCOUNT IS COMPROMISED, SUCH EFFORTS MAY FAIL AND COULD RESULT IN TOTAL LOSS OF DIGITAL TOKENS IN THE WALLET. ATTACKS ON TRANSFI MAY ALSO RESULT IN UNPLANNED AND SIGNIFICANT UNSCHEDULED DOWNTIME DURING WHICH TRANSACTIONS WILL NOT BE EXECUTED. ABSENT FRAUD OR INTENTIONAL WRONGDOING ON THE PART OF TRANSFI, TRANSFI SHALL NOT BE LIABLE FOR CUSTOMER LOSSES ON ACCOUNT OF ANY OF THE FOREGOING CIRCUMSTANCES OR COMPROMISED ACCOUNT CREDENTIALS. AS A GOOD FAITH HOLDER OF DIGITAL TOKENS IN THE WALLET, THERE IS A RISK THAT THE CUSTOMER WILL LOSE POSSESSION THEREOF IF TRANSFI DETERMINES THAT IT WAS PREVIOUSLY TRANSFERRED BY FRAUDULENT MEANS OR TRANSFERRED OTHERWISE IN VIOLATION OF THIS AGREEMENT, EVEN IF THE CUSTOMER HAD NO PART IN THE WRONGDOING.
• THE SERVICES AND DIGITAL TOKENS RELY ON THE INTERNET, WHICH INCLUDES THIRD-PARTY HARDWARE, SOFTWARE, AND INTERNET CONNECTIONS, ALL OF WHICH MAY SUFFER COMMUNICATION FAILURES, DISRUPTIONS, ERRORS, DISTORTIONS, OR DELAYS THAT MIGHT AFFECT THE CUSTOMER’S ABILITY TO ACCESS AND USE SERVICES SUCH AS THE ACCOUNT AND WALLET.
• TRANSFI MAY FREEZE, BLOCK, DELAY, OR RESTRICT FUNDS OR ACCOUNTS IF REQUIRED BY LAW, COURT ORDER, OR REGULATORY INSTRUCTION, AND SHALL NOT BE LIABLE FOR RESULTING LOSSES OR DELAYS.

THE CUSTOMER SHALL ENSURE THAT ALL MERCHANTS AND END USERS CARRY OUT THEIR OWN INDEPENDENT ANALYSIS AND ASSESSMENT OF THE RISKS SPECIFIC TO THE SERVICES AND RELATED TRANSACTIONS.

19.5 LIMITATIONS ON THE SCOPE OF OUR SERVICES:

• OUR SERVICES DO NOT INCLUDE INVESTMENT ADVICE, PERSONAL RECOMMENDATIONS, OR ANY FORM OF GUIDANCE ON THE MERITS OR SUITABILITY OF ENGAGING IN ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE.
• WE DO NOT PROVIDE ANY REPRESENTATIONS, ASSURANCES, OR GUARANTEES AS TO THE SUITABILITY OR APPROPRIATENESS OF ANY OF OUR SERVICES FOR YOUR SPECIFIC NEEDS.
• YOU ARE SOLELY RESPONSIBLE FOR OBTAINING ANY LEGAL, ACCOUNTING, FINANCIAL, OR TAX ADVICE YOU MAY REQUIRE TO DETERMINE WHETHER ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE IS SUITABLE FOR YOUR REQUIREMENTS OR THE REQUIREMENTS OF YOUR BUSINESS.
• ANY INFORMATION PROVIDED TO YOU IN RELATION TO THIS AGREEMENT, INCLUDING BUT NOT LIMITED TO MARKET INFORMATION, RESEARCH FORECASTS, OR OTHER DATA SHARED WITH YOU REGARDING ANY PROPOSED TRANSACTION OR OTHERWISE, IS FOR INFORMATIONAL PURPOSES ONLY. SUCH INFORMATION IS NOT INTENDED TO BE RELIED UPON AS FINANCIAL OR PROFESSIONAL ADVICE FOR PLACING AN ORDER OR ENTERING INTO ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE.
• INSOFAR AS IS PERMISSIBLE UNDER APPLICABLE LAWS AND REGULATIONS, TRANSFI DOES NOT OWE YOU ANY FIDUCIARY DUTY OR SIMILAR OBLIGATION UNDER THIS AGREEMENT.
• THE FOREIGN EXCHANGE RATES USED FOR THE PURPOSES OF PROVIDING THE SERVICES WILL BE DETERMINED BY TRANSFI AND MAY INCLUDE OUR COSTS, FEES, AND CHARGES. THESE RATES MAY DIFFER FROM PUBLISHED INTERBANK RATES OR OTHER PUBLICLY AVAILABLE BENCHMARKS.

20. LIMITATION OF LIABILITY

20.1 YOU UNDERSTAND AND AGREE THAT TRANSFI WILL BE LIABLE TO YOU OR TO ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES THAT YOU MAY INCUR, HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY, INCLUDING, WITHOUT LIMITATION, ANY LOSS OF PROFITS (WHETHER INCURRED DIRECTLY OR INDIRECTLY), LOSS OF GOODWILL OR BUSINESS REPUTATION, LOSS OF DATA, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR ANY OTHER INTANGIBLE LOSS, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

20.2 YOU UNDERSTAND AND AGREE THAT TRANSFI WILL NOT BE LIABLE AND DISCLAIMS ALL LIABILITY TO YOU IN CONNECTION WITH ANY FORCE MAJEURE EVENT, INCLUDING ACTS OF GOD; LABOR DISPUTES OR OTHER INDUSTRIAL DISTURBANCES; ELECTRICAL, TELECOMMUNICATIONS, HARDWARE, SOFTWARE, OR OTHER UTILITY FAILURES; SOFTWARE OR SMART CONTRACT BUGS OR WEAKNESSES; EARTHQUAKES, STORMS, OR OTHER NATURE-RELATED EVENTS; PANDEMICS; BLOCKAGES; EMBARGOES; RIOTS; ACTS OR ORDERS OF GOVERNMENT; ACTS OF TERRORISM OR WAR; TECHNOLOGICAL CHANGE; AND CHANGES IN INTEREST RATES OR OTHER MONETARY CONDITIONS.

20.3 YOU AGREE THAT OUR TOTAL, AGGREGATE LIABILITY TO YOU FOR ANY AND ALL CLAIMS ARISING OUT OF OR RELATING TO THESE TERMS, OR YOUR ACCESS TO OR USE OF (OR YOUR INABILITY TO ACCESS OR USE) ANY PORTION OF OUR SERVICES, WHETHER IN CONTRACT, TORT, STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, IS LIMITED TO THE GREATER OF (A) THE F FEES YOU PAID TO TRANSFI IN THE SIX (6) MONTH PERIOD PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED DOLLARS ($100), WHICHEVER IS LOWER.

20.4 YOU ACKNOWLEDGE AND AGREE THAT WE HAVE MADE OUR SERVICES AVAILABLE TO YOU AND YOU HAVE AT YOUR SOLE DISCRETION ENTERED INTO THESE TERMS IN RELIANCE UPON THE WARRANTY DISCLAIMERS AND LIMITATIONS OF LIABILITY SET FORTH HEREIN, WHICH REFLECT A REASONABLE AND FAIR ALLOCATION OF RISK BETWEEN THE PARTIES AND FORM AN ESSENTIAL BASIS OF THE BARGAIN BETWEEN TRANSFI AND YOU.

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21. NO RESPONSIBILITY FOR TRANSACTIONS WITH THIRD-PARTY OPERATORS

We are not responsible for any transaction between you and Third-Party Operators . If a Third-Party Operator fails to complete a purchase on Your behalf on time or in the correct amount, or if any loss occurs with respect to any transaction conducted through a Third-Party Operator we will not be liable for Your losses or damages.

22. INDEMNIFICATION

To the fullest extent permitted by Applicable Law, you agree to indemnify, defend, and hold harmless and reimburse TransFi from and against any and all actions, proceedings, claims, damages, demands, and actions (including without limitation fees and expenses of counsel), incurred by a TransFi arising from or relating to:

(a) your use of the Product, Website, or our Services;

(b) your responsibilities or obligations under the Terms;

(c) your breach of or violation of the Terms;

(d) any inaccuracy in any of your representations or warranties;

(e) your violation of any rights of any other person or entity, including any proprietary or privacy rights;

(f) your violation of any Applicable law ; and/or

(g) any of your acts or omissions that are negligent, unlawful, or constitute willful misconduct.

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TransFi reserves the right to exercise sole control over the defense, at your expense, of any claim subject to indemnification under this section 22. TransFi will notify you of any claim and you will cooperate.This indemnity is in addition to, and not in lieu of, any other indemnities set forth in a written Business Service Agreement between Customer and TransFi.

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23. GOVERNING LAW AND DISPUTE RESOLUTION

23.1 In the event of any dispute or claim between the Parties hereto arising from or relating to this Agreement, including any question regarding its existence, validity, or termination (a “Dispute”), then, the Parties shall first use good faith efforts to resolve it through negotiation by providing the other Party notice in writing describing the nature of the Dispute. Each Party will appoint a designated representative to endeavour to resolve such dispute. The designated representatives will be executives with sufficient authority to engage in good faith negotiations and bind the Party they represent.

If the designated representatives are unable to resolve the dispute within a reasonable period (but in no event more than thirty (30) days from the date of receipt of written request) after using their best efforts to do so, then the Dispute shall be finally resolved by binding arbitration. Any dispute, controversy, or claim arising out of or in connection with this Agreement, including any question regarding its existence, validity, interpretation, performance, breach, or termination, shall be referred to and finally resolved by arbitration under the Rules of the London Court of International Arbitration (LCIA), which Rules are deemed to be incorporated by reference into this clause.

The seat (legal place) of arbitration shall be London, England.
The tribunal shall consist of one arbitrator, unless the LCIA Court determines otherwise in accordance with the LCIA Rules.
The language of the arbitration shall be English.

The arbitration award shall be final and binding on the Parties and may be enforced in any court of competent jurisdiction

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24. EXTERNAL SITES

The solution or APIs or our Services may include hyperlinks or redirect you to other websites or resources (collectively, "External Sites") that are provided solely as a convenience to you. We have no control over any External Sites. You acknowledge and agree that we are not responsible for the availability of any External Sites and that we do not endorse any advertising, products, services, or other materials on or made available from any External Sites. Furthermore, you acknowledge and agree that we are not liable for any loss or damage that may be incurred as a result of the availability or unavailability of the External Sites or as a result of any reliance placed by you upon the completeness, accuracy, or existence of any advertising, products, services, or other materials on, or made available from, any External Sites.

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25. ENTIRE AGREEMENT

These Terms, including the Privacy Policy, Business Services Agreement (where applicable) and any other terms and conditions referenced herein constitute the entire agreement between you and TransFi with respect to the subject matter hereof, including the Services. These Terms, including the Privacy Policy, supersede all prior or contemporaneous written and oral agreements, communication, and other understandings relating to the subject matter of the Terms. These Terms do not alter any agreement you may have with any Third Party Operators but shall supersede any such agreements in the event of a conflict between these Terms and any agreement with Third Party Operators s.

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26. DATA PROTECTION AND PRIVACY POLICY

Our Privacy Policy, which is incorporated herein by reference, describes how we collect, use, store, and disclose your personal information. You agree to the collection, use, storage, and disclosure of your data in accordance with the Privacy Policy. We are committed to keeping your personal information safe and processing it in accordance with applicable data protection legislation. Please review our Privacy Policy to understand how we use and protect the information you provide to us.

The End User acknowledges and agrees that TransFi may collect, access, process, store, and retain the End User’s profile information, account details, transactional data, and any other data relating to the End User (“End User Data”) for the purposes of providing, operating, monitoring, and improving its services, including for internal analytics, risk management, fraud prevention, and the development and offering of enhanced or targeted products and services. TransFi shall be entitled to retain End User Data for such period as it deems necessary to fulfil the purposes set out herein, including to comply with Applicable Laws, regulatory requirements, and its internal compliance and audit obligations.

Notwithstanding anything to the contrary, the End User expressly acknowledges and agrees that TransFi may, without further notice or consent, disclose, share, or transfer End User Data to any governmental, regulatory, supervisory, or judicial authority, law enforcement agency, or any financial institution, payment network, or other third-party service provider, where such disclosure is required or deemed necessary by TransFi to comply with Applicable Laws, regulation, legal process, or any request, order, or directive having the force of law.

The End User further consents to the use of End User Data, on an aggregated or individual basis, for internal analytics, research, and commercial purposes, including to optimize, personalize, and improve TransFi’s products, services, and user experience.

By accessing or using the Services, the End User provides informed, explicit, and unconditional consent to the collection, use, retention, and disclosure of End User Data in accordance with this Clause.

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27. CONTACT INFORMATION

If you have any feedback, questions, or complaints, you may contact us via our help center on our website or at compliance@transfi.com.

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Annexure A - List of TransFi Entities

This list is indicative only and may be updated without notice

Trans-Fi Inc.

TransFi UAB

Neomoney INC.

TransFi PTE. LTD.

TransFi Technology LLC

TransFi Innovation Limited

Trans-Fi India Private Limited

TransFi Bahamas Limited

Pt. TransFi Indonesia Merdeka

TransFi Digital Limited

TRANSFI VIRTUAL ASSETS SOLUTIONS FZCO

TRANSFI AUSTRALIA PTY LTD

MAXSERVICE24 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

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CHECKOUT TERMS & CONDITIONS - GLOBAL ‍

Last Updated: 10th April 2026

This document outlines the terms and conditions (“Terms”) that govern the use of the Services provided by TransFi. These Terms apply specifically to End Users of Customers (“you/your”) . By using our Services, You agree to these Terms, including our Privacy Policy, AML/KYC Policy and TransFi Payments (Platform) Terms and conditions of Use . If You do not agree to any part of these Terms, You are not permitted to use the Services. These Terms shall include these Terms & Conditions, our Privacy Policy, and our AML/KYC Policy and TransFi Payments (Platform) Terms and conditions of Use

By accessing or using the Services in any manner, You expressly acknowledge and represent that You have read, understood, and agree to be legally bound by all provisions of these Terms, as amended from time to time.

Please read these Terms carefully, as they set out the Terms on which TransFi will provide You the Services.

The Services enables You to make payments to Customers and to pay for products and/or services purchased through the Customers’ digital platforms which may include any website, application, or other interface operated by such Customers, and to complete transactions through the Services made available on such Customer platforms that have integrated TransFi’s Services via its APIs or Checkout Widget.

By initiating, submitting, or authorizing any payment through the Services, You irrevocably and unconditionally authorize TransFi and its Third Party Operators to (i) process, route, and execute the transaction in accordance with applicable network rules and operational requirements, (ii) debit, charge, or otherwise utilize your designated payment method, including but not limited to cards, alternative payment methods, cryptocurrencies, and stablecoins, for the full transaction amount together with any applicable fees, charges, or conversions, and (iii) facilitate the transfer and settlement of funds to the relevant Customer.

You acknowledge and agree that such authorization constitutes Your express consent to the movement of funds and, to the maximum extent permitted by Applicable Law, is final and irrevocable upon submission. Without limiting the foregoing, You agree that (a) transactions may be subject to foreign exchange conversions, blockchain confirmations, and Third Party Operator dependencies; (b) TransFi may, at its sole discretion, delay, suspend, reject, or reverse any transaction where required for compliance with applicable laws, sanctions, anti-money laundering obligations, risk management, fraud prevention, or upon suspicion of unauthorized or unlawful activity; and (c) TransFi shall not be liable for any delays, failures, or errors attributable to Third Party Operators, payment networks, or underlying blockchain protocols.

If You do not agree to these Terms or any subsequent modification to them, You must not use the Services. TransFi may suspend or terminate Your access to the Services. Continued use of the Services constitutes acceptance of any updated Terms. If You do not agree, You must stop using the Services immediately.

NOTICE: Please read these Terms carefully, as they govern Your use of the Services and affect Your legal rights. BY USING OUR SERVICES OR CLICKING "I ACCEPT" BELOW OR CLICKING A BOX INDICATING YOUR ACCEPTANCE, YOU CONFIRM THAT YOU READ, UNDERSTAND AND AGREE TO BE BOUND BY THESE TERMS , INCLUDING ALL POLICIES, TERMS, AND CONDITIONS INCORPORATED BY REFERENCE..

If You accept these Terms on behalf of a company or other legal entity by accessing or using the Services,clicking "Agree" below or clicking a box indicating acceptance, You represent and warrant that You have the legal authority to bind that entity to these Terms. In such cases, “You” and “Your” (except as used in this paragraph) will refer to that entity. . If You do not have such authority or do not agree to these Terms, then neither you nor that entity may access or use the Services. You are advised to retain a copy of these Terms for Your records.

TransFi may, at its sole discretion, modify , amend, or update these Terms from time to time. When we do so, we will post the updated Terms on the Website and revise the "Last Updated" date. Changes to these Terms become effective on the date they are posted. Your continued access to or use of our Services after the updated Terms are posted constitute Your binding acceptance of the changes. If You do not agree to any revised Terms, You must stop accessing or using the Services immediately.

These Terms constitute a legally binding agreement between You, as an end user of a Customer’s platform, and TransFi governing Your access to and use of the Services. TransFi provides technical facilitation of payment and Digital Tokens –related transactions made available to You through such platforms.

The Services may involve the use of Digital Tokens ; however, TransFi does not promote or market Digital Tokens as an investment product and does not encourage speculative activity.

In providing the Services, TransFi may rely on licensed or authorized third-party service providers, including custodians, payment processors, liquidity providers, or settlement partners. TransFi is not responsible for errors, delays, failures, or losses caused by such third parties, except to the extent required by applicable law.

TransFi operates subject to applicable legal and regulatory requirements. Your access to the Services and the availability of Your funds may be restricted, delayed, frozen, or otherwise impacted as a result of compliance obligations, legal orders, regulatory actions, or risk management measures.

1. INTRODUCTION

1.1 These Terms constitute a legally binding agreement between You and TransFi Inc. (“TransFi”). By accessing or using the Services, You agree to be bound by these Terms and any other supplemental terms that apply to specific Services and are presented to You in the relevant user flow

2. DEFINITIONS

• AML (Anti-Money Laundering): The checks and processes implemented by financial institutions and regulated entities to detect, prevent, and report money laundering activities. This includes transaction monitoring (for both fiat and Digital Tokens), risk assessments, and adherence to Applicable Law.
  
  
• Applicable Law: All applicable laws, statutes, statutory instruments, rules, regulations, judgments, decrees, regulatory guidelines, codes of practice, or other requirements of regulatory authorities in any jurisdiction, as amended from time to time, and legally binding on a party.
• Business Day: means any day other than a Saturday, Sunday, or public holiday and the day on which banks are open for business in the country where TransFi operates the relevant Services.
  
  
• Chargeback/Fraud Recall: The reversal of a transaction or request for repayment in respect of a previously settled and/or remitted transaction initiated by the issuing bank, payment networks, payment service providers, or other financial institutions.
  
  
• Customer: A business or platform through which You access the Services. TransFi is not responsible for the operations, products, or obligations of such Customers.
  
  
• Third Party Operator: Any third-party service provider engaged or used by TransFi in connection with the Services, including, without limitation, payment processors, acquirers, banks, liquidity providers, exchanges, custodians, or settlement agents. TransFi is not responsible for any errors, delays, or losses caused by Third-Party Operators
• CTF (Counter-Terrorist Financing): Laws and regulations that aim to prevent the financing of terrorism and terrorist-related activities.
  
  
• Digital Tokens : Any digital representation of value that can be digitally traded, transferred, or stored, including stablecoins (e.g., USDT, USDC), cryptocurrencies (e.g., Bitcoin, Ethereum), and other digital tokens. Digital Tokens are not promoted by TransFi as investments, and TransFi does not provide investment advice.
  
  
• Compliance Checks: The risk-based customer verification and monitoring measures conducted by TransFi or its Third Party Operators in connection with the onboarding and ongoing use of the Services. Compliance Checks may be carried out at different levels depending on the risk profile of the end user and applicable transaction limits, and may include:

• Basic Screening, involving the collection of minimal end-user information and sanctions or watchlist screening without submission of identity documents, with restricted transaction limits;
• Standard Due Diligence, involving submission of identification documents and completion of identity verification procedures, including liveliness or similar checks, following which transaction limits may be increased; and
• Enhanced Due Diligence, involving additional verification measures for higher-risk users or higher transaction thresholds, including submission of proof of funds, source of wealth information, or other supporting documentation, following which maximum transaction limits may be permitted.
  
  

• End User/ You/ Your: An individual or legal entity that accesses or uses the Services, either via a Customer platform.
  
  
• KYB (Know Your Business): A process of identification under AML/CTF requirements, including additional checks, such as email age verification, internet profiling, adverse media screening, and sanctions screening.

• Payment and/ or Transaction: Any payment, transfer, or other transaction initiated by You through the Services for the purchase of goods and/or services from a Customer via such Customer’s digital platform, including its website, application, or other interfaces, using any supported payment method. A Payment or Transaction includes, without limitation, the initiation, authorization, processing, routing, validation, transfer (including fiat currency, cryptocurrencies, stablecoins, or alternative payment methods), and shall be deemed to occur upon submission of a payment instruction through the Services, regardless of whether such Payment or Transaction is completed, declined, reversed, or otherwise unsuccessful.

• Checkout Widget: TransFi-provided embedded payment interface made available to the Customer in connection with the Services on the Customer’s digital platforms, which enables You to select and initiate payments via supported payment methods, including UPI, credit cards, debit cards, net banking, and APMs.

• Checkout APIs: The application programming interfaces made available by TransFi that enable the Customer to integrate and access the Services within its platform, website, application for offering such Services to You.
  
  
• PEP (Politically Exposed Person): Individuals who are or have been entrusted with prominent public functions and are subject to enhanced due diligence requirements.
  
  
• Services: TransFi’s Services enables You, subject to Applicable Laws, these Terms, and the availability of the Services, to:

(a) make payments for products, goods and/or services, including checkout of shopping carts, through the Customers digital platforms (including websites, applications, and other interfaces) operated by the Customers, using supported payment methods, including cryptocurrencies and stablecoins, alternative payment methods (“APMs”), and card-based payment instruments;

(b) initiate payment transactions through checkout functionality integrated on such Customer platforms, which TransFi processes, routes, authorizes, and facilitates;

(c) authorize the transfer of funds from your selected payment method for settlement to the relevant Customer in connection with your transaction;

(d) access and use checkout interfaces, including hosted and/or embedded and white-labelled payment experiences, made available on the relevant Customer’s platform; and

(e) access certain ancillary features made available in connection with the Services, including transaction notifications and status updates.

You acknowledge and agree that TransFi acts solely as a payment facilitation provider and is not a party to the underlying transaction between you and the Customer. TransFi does not control or assume responsibility for the products, goods and/or services provided by the Customer. TransFi reserves the right, at its sole discretion and without liability, to modify, suspend, restrict, or discontinue any part of the Services, including the availability of any payment method or functionality, at any time to comply with Applicable Laws, partner requirements, Third Party Operator dependency or requirements, or its internal risk, compliance, and fraud prevention policies.

• TransFi/us/we/our: means and shall include, without limitation, all of its current and future subsidiaries, affiliates, holding companies, group entities, successors, permitted assigns, and any entity that directly or indirectly controls, is controlled by, or is under common control with TransFi, whether existing or formed, established, acquired, or reorganised thereafter. For ease of reference, the indicative list of such entities is provided in Annexure A, which may be updated from time to time and shall include all subsidiaries and affiliates of TransFi, whether or not expressly listed therein. Any reference to “TransFi” shall be deemed to include all such entities, and all rights, obligations, protections, and limitations applicable to TransFi shall apply equally and collectively to each of them.
  
  

DISCLAIMER: The risk of loss in trading or holding Digital Tokens can be substantial. You should be aware that the price or value of Digital Tokens, including, but not limited to, cryptocurrencies, NFTs, can change rapidly, decrease, and potentially even fall to zero. Therefore, You should carefully consider whether trading or holding Digital Tokens is appropriate for You in light of Your financial circumstances.

TransFi is not responsible for and does not hold any security information to access your Digital Tokens and TransFi is not responsible for any loss of Digital Tokens resulting from theft, loss, or mishandling of private keys or other security information outside its control.

Every purchase and sale of Digital Tokens is executed on and confirmed by the respective network of that Digital Token . The confirmation process takes time (typically less than one hour, but potentially one day or more). An order is not complete until it is confirmed. Digital Tokens associated with orders that are pending will be designated accordingly.

A transaction between a buyer and a seller occurs peer-to-peer on a public blockchain. TransFi does not guarantee that You will receive Your Digital Token, as transactions may fail for a variety of reasons, including but not limited to, network congestion, technical issues with blockchain, or another buyer completing the purchase of the Digital Token before Your transaction is confirmed. If your transaction fails, TransFi will use reasonable efforts to facilitate a refund of any applicable fees, but TransFi is not responsible for any losses, delays, or damages arising from failed transactions.

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3. LEGAL RELATIONSHIP BETWEEN TRANSFI AND THE CUSTOMER

3.1 These Terms form a contract between TransFi and End Users. Where an End User accesses the Services through a Customer this does not prevent the End User from having separate rights and obligations as against the Customer under their own terms.

3.2 The Services are provided to You via a Customer platform. You must read and accept these Terms before using the Services. By accessing or using the Services through a Customer platform, You agree to be bound by these Terms.

3.3 We may assign or transfer our rights in these Terms to any member of our Group company or any affiliate without your consent, listed under Annexure A and as may be amended from time to time by TransFi. You may not assign these Terms without our prior written consent of TransFi.

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4 . RISK, LIABILITY AND SERVICE DISCLAIMERS

4.1 The Services involve Digital Tokens , including cryptocurrencies, stablecoins . TransFi does not promote, recommend, or provide advice on the purchase, sale, or holding of Digital Tokens for speculative or investment purposes. Trading or holding Digital Tokens carries a high risk of loss, including the potential loss of Your entire investment. You are solely responsible for evaluating whether using the Services is appropriate for Your financial situation and risk tolerance.

4.2 Some Services are facilitated by Third-Party Operators, such as payment processors, banks, liquidity providers, exchanges, and custodians. TransFi does not control these third parties and is not responsible for any errors, delays, or losses caused by them, except as required by Applicable Law. You acknowledge and accept that reliance on Third-Party Operators carries inherent risks.

4.3 TransFi is subject to Applicable Law and regulatory obligations.Regulatory actions, compliance measures, or changes in law may affect Your ability to access or use the Services and may impact Your funds or Digital Tokens . You acknowledge and accept that TransFi is not liable for any such impact arising from compliance with Applicable Law or regulatory measures.

4.4 TransFi does not guarantee the performance, security, or success of any transaction or investment in Digital Tokens . Transactions may fail due to network congestion, blockchain issues, or other factors beyond TransFi’s control. In such cases, TransFi will use reasonable efforts to facilitate refunds of applicable fees, but is not liable for losses or damages resulting from failed or delayed transactions.

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5. TRANSACTIONS LIMITS AND COMPLIANCE CHECKS

5.1 TransFi adheres to high standards of compliance with policies and procedures designed to prevent money laundering, criminal activities, market abuse, and conflicts of interest. All TransFi employees are committed to the highest ethical standards.

5.2 The use of our Services is subject to transaction thresholds that apply to the volume You may transact These limits may vary depending on Your payment method, Compliance Checks, geography, KYC levels, and other factors, as determined by TransFi’s internal risk assessment and compliance policies. We reserve the right to modify applicable limits as We deem necessary to comply with Our risk management and regulatory obligations. If You wish to request an increase to your transaction limits beyond the posted amounts, You may submit a request to compliance@transfi.com.

5.3 We may require you to submit additional information about yourself and provide supporting documentation if you request an increase to your transaction limits. TransFi, in its sole discretion, may refuse to grant an increase to Your limits, or We may lower Your limits at a later time, even if You have previously completed Compliance Checks.

5.4 Our compliance program is based on the following pillars:

• Know Your Customer (KYC) and Know Your Business (KYB): We conduct KYC/KYB checks to determine if any Customers or End Users are subject to sanctions, are PEPs, or have any adverse media reporting.
  
  
• Fraud Monitoring: Our fraud monitoring processes include name matching, internet and social media risk profiling, device and IP checks, transaction behavior analysis, and browsing behavior checks.
  
  
• Travel Rule Compliance: We comply with travel rule Compliance, and are working on expanding the control to all geographies

5.5 Our compliance processes also include:

• Risk limits on End Users, such as per-transaction, and daily and monthly transaction limits.
  
  
• Prohibitions on certain business types: For a current and complete list of prohibited business types, please refer to TransFi’s AML/KYC Policy, which is subject to change.
  
  
• Compliance Checks requirements for End Users presenting a higher risk, which may involve parameters as determined solely by TransFi
• Prohibited Jurisdictions: For a current list of prohibited jurisdictions, please refer to TransFi’s internal AML/KYC Policy, which is subject to change AML/KYC Policy.

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6. PAYMENT THROUGH DIGITAL TOKENS

The Services enable You to make payments for goods and/or services to Customers using supported digital tokens, including cryptocurrencies and stablecoins (“Digital Tokens”), through checkout functionality integrated on the Customer’s digital platform.

By initiating a payment using Digital Tokens, you irrevocably authorize TransFi and its Third-Party Operators to process, validate, and transmit the transaction, including facilitating the transfer of Digital Tokens, or designated endpoint specified by the relevant Customer.

You acknowledge and agree that Digital Token transactions are subject to blockchain network protocols, validation processes, and third-party dependencies, and may be delayed, declined, or not completed due to network conditions, technical limitations, or compliance, fraud prevention, or risk management requirements.

You further acknowledge that transactions involving Digital Tokens are irreversible once submitted to the relevant blockchain network and confirmed, and TransFi shall have no obligation or ability to reverse, cancel, or recover such transactions, except as required by Applicable Law. You expressly acknowledge that Digital Token transactions, once initiated and submitted to the relevant blockchain network, are irreversible and cannot be cancelled, recalled, or modified

DISCLAIMER: While TransFi strives to process payments within the estimated processing times, circumstances beyond Our reasonable control, such as banking system issues or regulatory checks, may cause delays. TransFi will use reasonable efforts to minimize such delays and keep You informed, but We will not be responsible for any resulting loss, delay, damages or inconvenience caused by events beyond Our control.

7. CANCELLATIONS AND REFUNDS

7.1 Except as expressly provided herein, all transactions are final once executed . However, transactions may be reversed, delayed, cancelled, or refunded where required by Applicable Law, payment network rules (including chargebacks or recalls), compliance checks, suspected fraud, sanctions screening, technical failures, or Third-Party Operator reversals.

7.2 Due to the volatile nature of Digital Token markets, orders cannot be recalled or retrieved under any circumstances once executed.

7.3 Upon delivery of the Digital Token for payment of products, goods and/or services through Customers Platform TransFi's obligations to You are fully discharged, and You will have no further claim or right against TransFi related to that specific transaction.

7.4 Where We cancel or refund a transaction for compliance, fraud, or technical reasons, We may deduct fees and costs reasonably incurred (including Third-Party Operator fees) and will refund the remaining amount to the original source of funds where possible, or otherwise as required by Applicable Law.

8. RESPONSIBILITIES AND OBLIGATIONS

8.1. END USER RESPONSIBILITIES AND OBLIGATIONS

You must ensure that by using TransFi's Services You accept and acknowledge to the following responsibilities:

• Accurate Information: Providing accurate, complete, and up-to-date information when using the Services, if and as required. .You must promptly update Your information if it changes.
  
  
• Compliance with Laws and Regulations: You must comply with all Applicable Laws and ensure that Your use of Services does not involve or facilitate any illegal, unethical, or prohibited activities, including but not limited to money laundering, terrorist financing, sanctions evasion, or other criminal activity..
  
  
• Security and Confidentiality: You are responsible for maintaining the security and confidentiality and any other sensitive information related to Your transactions.
  
  
• Transaction Validity: You must ensure that all transactions You initiate through the Services are properly authorized and legal in compliance with Applicable Law .

• Notification Obligations: You must promptly notify TransFi if You become aware of any unauthorized access, suspicious activity, or errors affecting Your transaction or payment
  
  
• Prohibited Activities: You must not:
  
  • Attempt to gain unauthorized access to TransFi systems, or Third-Party Operator systems;
  • Interfere with the operation, security, or integrity of the Services;
  • Use the Services in violation of these Terms or any applicable regulatory or contractual restrictions.
• Responsibilities for Compliance: You must understand and comply with any legal obligations that apply to Your use of Services, including but not limited to Compliance Checks, AML/KYC requirements and any transaction limits imposed by TransFi, Applicable Law or applicable regulators.

• Device and Software Security: You must ensure that any device, software, or network used to access the Services is secure, free from malware, and compatible with the Services.
  
  
• Cooperation with Compliance and Audits: You must cooperate with TransFi, regulators, or Customers in any investigations, audits, or compliance checks related to Your transactions.
• Taxes and Reporting: You are solely responsible for any taxes, reporting obligations, or other governmental requirements arising from Your transactions using the Services.
• Acknowledgment of Risk: You acknowledge that Digital Token transactions carry inherent risks, including volatility, potential loss, network or blockchain failures, and reliance on Third-Party Operators. You accept these risks and are responsible for evaluating whether using the Services is appropriate for Your financial situation and risk tolerance.
• Additional Responsibilities: You must respond promptly to any communication or requests for information from TransFi or the Customer regarding Your transactions done in connection to the Services

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9. OUR RIGHTS

We reserve the following rights, which are not obligations of TransFi:

(a) to modify, substitute, eliminate, or add to any of our Services where such changes are necessary due to legal, regulatory, security, or operational requirements, with reasonable notice provided to You where feasible;

(b) to suspend, restrict or terminate a transaction initiated by You if You violate these Terms, Applicable Law or any compliance requirements, , or where required for regulatory, fraud-prevention, or security purposes; ;

(c) to monitor, review, modify, filter, disable, delete, and remove content, data or information associated with Your use of the Services, where necessary to protect the integrity, security, or lawful operation of the Services;

(d) to automatically update, patch or modify any software, systems or components used to provide the Services;

(e) to cooperate with any law enforcement, court, regulators or government investigation or order, or any Third Party Operator requesting or directing that You disclose any information in relation to Your use of Services

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10. CONDUCT

10.1 By way of example, and not as a limitation, You shall not:

(a) breach these Terms or any other terms and conditions, and any agreement incorporated by reference herein;

(b) violate any Applicable Law, statute, ordinance, or regulation;

(c) infringe any TransFi’s intellectual property (IP) or any third party’s copyright, patent, trademark, trade secret, or other intellectual property rights, or rights of publicity or privacy;

(d) act in any way that is unlawful, libelous, defamatory, harassing, abusive, fraudulent, obscene, or otherwise objectionable (including, without limitation, displaying any content on our solution or APIs or using our Services to transmit content that contains any hate-related or violent content);

(e) provide false, inaccurate, or misleading information;

(f) send or receive Digital Tokens that could reasonably be believed (by us or by others) to have been potentially fraudulently acquired;

(g) use our Services or the services of our partners and/or customers in a manner that results in or may result in complaints, disputes, claims, reversals, Chargebacks, fees, fines, penalties, or losses to us or any of our partners;

(h) distribute or facilitate the distribution of viruses, worms, defects, Trojan horses, corrupted files, hoaxes, or any other items of a destructive or deceptive nature, or otherwise interfere with, circumvent, disable, or attempt to interfere with, circumvent, or disable the solution or APIs, or our Services, the proper working of the solution or APIs or our Services, security features of the solution or APIs, or our Services, or the equipment connected to the solution or APIs or our Services;

(i) take any action that may cause Us to lose any of the services from our internet service providers, payment processors, or other suppliers or Third Party Operators ;

(k) transmit or otherwise make available through our Services any unsolicited commercial messages (i.e., spam), junk mail, pyramid schemes, chain letters, or similar materials or information;

(j) interfere with other users enjoyment of our Services;

(k) exploit our Services for any unauthorized commercial purpose;

(l) reformat or frame any portion of the solution or APIs, or Services;

(m) use any robot, spider, site search/retrieval application, or other device to retrieve or index any portion of our solution or APIs or content on our Services, or to collect information about our Customers for any unauthorized purpose;

(n) use any meta tags or any other “hidden text” using any of our marks;

(o) access or use our Services for the purpose of creating a product or service that is competitive with any of our products or services, including, without limitation, our Services; or

(p) engage in any other activity that we, at our sole discretion, deem to be harmful to TransFi, Our business, or Third Party Operators.

10.2 If You engage in any of the activities prohibited by Section 8.1, We may, at our sole and absolute discretion, without notice to you and without limiting any of our other rights or remedies at law or in equity, immediately suspend, block or blacklist You from accessing our Services. If We prevent you from accessing our Services, you will be responsible for all losses, liabilities or obligations that result from or arising from Your use of the Services prior to or resulting from the prohibited conduct. You are further prohibited from using the Services in any manner that is not expressly and unambiguously authorized under these Terms.

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11. TERMINATION

Subject to your compliance with these Terms and all Applicable Laws, You may terminate your acceptance of these Terms at any time by ceasing to be an End User with Us and discontinuing all access to and use of Our Services by sending us an email at compliance@transfi.com. We, at our sole discretion and for any reason or no reason, may terminate your acceptance of these Terms and suspend and/or terminate Your to all or any portion of Our Services, subject to Applicable Law. Any suspension or termination of Your access to use of our Services may be without prior notice, and We will not be liable to You or to any third party for any such suspension or termination. If we terminate these Terms or suspend or terminate your access to or use of Our Services due to Your breach of these Terms or any suspected fraudulent, abusive, or illegal activity, then termination of these Terms will be in addition to any other remedies We may have at law or in equity. Upon any termination or expiration of these Terms, whether by You or Us, You may no longer have access to information that You may have provided in connection with our Services or that is related to your transaction made through the Services , and You acknowledge that we will have no obligation to maintain any such information in Our databases or to forward any such information to You or to any third party.

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12. INTELLECTUAL PROPERTY OWNERSHIP

12.1 We retain all rights, title, and interest in all of our intellectual property, including, without limitation, inventions, ideas, concepts, code, discoveries, processes, marks, methods, software, visual interfaces, graphics, designs, systems, services, "look and feel," organization, compositions, formulae, techniques, information, and data (collectively, the "TransFi IP"). The TransFi IP is protected by copyright, trade dress, patent, and trademark laws, international conventions, and other relevant intellectual property and proprietary rights and applicable laws. You may not use any of the TransFi IP for any reason without our prior written consent. We reserve all rights in and to the TransFi IP not expressly granted to you in these Terms.

12.2 Subject to these Terms and any applicable Business Services Agreement:

1. You are granted a limited, revocable, non-exclusive licence to access and use the Services for Your own lawful use.
2. You agree not to remove, alter, or obscure any proprietary notices provided in or with the material on the Product or any other TransFi IP. You will not modify, alter, convert, adapt, clone, replicate, duplicate, copy, translate, reverse engineer, or otherwise manipulate any portion of our Services or the TransFi IP. All rights not expressly granted in these Terms are reserved.

12.3 You may choose to submit comments, bug reports, ideas, or other feedback about our Services, including, without limitation, suggestions for improving our Services (collectively, "Feedback"). By submitting any Feedback, You agree that we are free to use such Feedback at our discretion and without additional compensation to You and to disclose such Feedback to third parties (whether on a non-confidential basis or otherwise). If necessary under Applicable Law, You hereby grant Us a perpetual, irrevocable, non-exclusive, transferable, worldwide license under all rights necessary for us to incorporate and use Your Feedback for any purpose.

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13. THIRD-PARTY SERVICE OPERATORS

13.1 The Services, may operate through or rely on Third Party Operators (including, without limitation, payment processors, exchanges, liquidity providers, and settlement agents). Third Party Operators may require you to agree to separate terms and conditions, which you must review and accept directly with them .You are responsible for complying with all applicable Third-Party Operator terms when using the Services. TransFi is not a party to any agreements between You and Third-Party Operators and does not control their actions, operations, products, services, or financial condition. Nothing in these Terms creates a contractual relationship between You and any Third-Party Operator. You acknowledge and agree that TransFi is solely responsible for the Services provided directly by TransFi and for maintenance and support of those Services only . Fees related to services offered by Third-Party Operators are governed by separate terms and conditions, as well as agreements between you and the respective Third Party Operator . You acknowledge that the use of such third-party services may involve settlement, technology, liquidity, operational, and counterparty risks which You accept

13.2 You expressly agree that TransFi shall not be responsible or liable for any delays, losses, or damages (including any loss of funds) arising from the acts, omissions, insolvency, liquidity issues, or bankruptcy of any Third Party Operators ,. Such risks are inherent in the use of Third-Party Operators and are accepted by You. Any such risks shall be borne solely by You.

13.3 TransFi provides no warranties with respect to services provided by Third-Party Operators. Any warranties applicable to third-party services are provided solely by the relevant Third-Party Operator, if at all.

13.4 Third-Party Service Providers are solely responsible for the Services they provide to You including, but not limited to: (a) product liability claims; (b) any claim that the services fail to conform to any applicable legal or regulatory requirement; (c) claims arising under consumer laws, privacy laws, or similar legislation; and (d) intellectual property claims. Such claims must be directed to the relevant Third-Party Operator, not to TransFi.

13.5 TransFi does not guarantee the availability, timeliness, or completion of any transaction or settlement executed through Third-Party Operators , and assumes no liability for any disruption, delay, or failure in settlement arising therefrom.

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15. PROMOTIONS AND REFERRALS

We may, from time to time, operate contests, promotions, referral programs, or other similar activities (“Promotions and Referrals”) that may require you to submit material or information about yourself. Any Promotions and Referrals may be governed by separate rules that may contain certain eligibility requirements, such as restrictions on age or geographic location. You are responsible for reading all applicable rules relating to the Promotions and Referrals to determine whether you are eligible to participate. If you enter or participate in any Promotions and Referrals, you agree to abide by and comply with all rules of the respective Promotions and Referrals. All Promotions and Referrals will be optional, and you should not enter or participate in such Promotions and Referrals if you do not agree to abide by and comply with all applicable rules.

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16. USER REPRESENTATIONS AND WARRANTIES

By using our Services, You represent and warrant that:

16.1 Authority. You have all requisite power and authority to execute and deliver these Terms, to purchase and use our Services, and to carry out and perform your obligations under these Terms. If you are an individual, you are at least eighteen (18) years old and of sufficient legal age and capacity to purchase and use our Services. If you are an entity, you are duly organized, validly existing, and in good standing under the laws of your domiciliary jurisdiction and each jurisdiction where you conduct business.

16.2 No Conflict. The execution, delivery, and performance of these Terms will not result in any violation of, be in conflict with, or constitute a material default under, with or without the passage of time or the giving of notice: (a) any provision of your governing documents, if applicable; (b) any provision of any judgment, decree, or order to which you are a party, by which you are bound, or to which any of your material assets are subject; (c) any material agreement, obligation, duty, or commitment to which you are a party or by which you are bound; or (d) any laws, regulations, or rules applicable to you.

16.3 No Consents or Approvals. The execution and delivery of, and performance under, these Terms require no approval or other action from any governmental authority or person other than You.

16.4 Lawful Purpose. You will use the Services solely for lawful purposes and in compliance with all Applicable Laws, including sanctions, anti-money laundering, counter-terrorist financing, tax, foreign exchange, and securities laws.

16.5 Sanctions Status. You are not located in, organized under the laws of, or ordinarily resident in any jurisdiction subject to comprehensive sanctions, nor are you listed on any sanctions or restricted-party list maintained by any governmental authority.

16.6 Source of Funds. All funds and Digital Assets used in connection with the Services are derived from lawful sources, and you are the legal and beneficial owner or are duly authorized to transact on behalf of the beneficial owner.

16.7 No Reliance / Risk Understanding. You understand the risks associated with Digital Assets, including volatility, loss of value, technology risks, and regulatory uncertainty, and you are not relying on TransFi for investment, legal, tax, or financial advice.

16.8 Accurate Information. All information you provide to TransFi is true, accurate, and complete, and you will promptly update such information as needed.

16.9 No Prohibited Activity. You are not using the Services on behalf of any person or entity engaged in illegal, fraudulent, deceptive, or prohibited activity.

16.10 Tax Responsibility. You are solely responsible for determining and fulfilling any tax obligations arising from your use of the Services.

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17. SANCTIONS

Your use of the Services is subject to all applicable export controls and economic sanctions laws and regulations (“Sanction Laws”) . By sending, buying, or selling Digital Tokens through the Services, You agree that you will comply with those Sanction Laws . You represent, warrant and undertake that you are not and will be not :

• located in, under the control of, or a national or resident in, or operating from, under the control of, or a national or resident of any jurisdiction subject to comprehensive economic sanctions or embargoes under Sanction Laws; or
• listed on, owned or controlled by, or acting on behalf of any person or entity listed on any sanctions-related restricted party list maintained by the United Nations, United States (including OFAC), the European Union, the United Kingdom, or any other relevant governmental authority;
• You further represent, warrant, and undertake that:
  
  • you will not use the Services, directly or indirectly, for the benefit of, or in connection with, any person, entity, or jurisdiction subject to Sanctions Laws;
  • you will not use the Services to conduct, facilitate, or support any transaction that could cause TransFi or any Third-Party Operator to violate Sanctions Laws;
• TransFi may monitor, screen, and restrict access to the Services at any time to comply with Sanctions Laws. TransFi may, where required by Applicable Law or its compliance obligations, refuse to process, block, freeze, or reverse transactions, suspend or terminate or restrict access to the Services without prior notice.
• TransFi may request additional information or documentation at any time to verify your identity and compliance with this Section, and failure to provide such information may result in suspension or termination of the Services.

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18. RECOVERY OF LOSSES

In respect of payments made using card-based payment methods, you acknowledge that such transactions may be subject to chargebacks, reversals, or disputes in accordance with the applicable card network rules and the policies of the issuing bank or payment provider. Any such chargebacks or reversals shall be handled in accordance with those rules, and TransFi shall have no control over, or liability for, the outcome of such processes.

For payments made using Digital Tokens, You acknowledge that such transactions are final and irreversible once initiated and confirmed on the relevant network, and are not subject to chargebacks, reversals, or cancellation.

For alternative payment methods (“APMs”), transactions may be subject to the terms, conditions, and dispute mechanisms of the relevant payment provider and/or Third Party Operator, and TransFi does not guarantee the availability of chargeback or reversal rights.

TransFi reserves the right to recover from You any amounts associated with chargebacks, reversals, refunds, or disputes, including any fees, penalties, or costs imposed by payment networks or Third-Party Operators, to the extent applicable.

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19. DISCLAIMERS

19.1 "AS IS" AND "AS AVAILABLE." YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOUR ACCESS TO AND USE OF OUR SERVICES IS AT YOUR SOLE RISK, AND THAT OUR SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, TRANSFI AND ITS MEMBERS, MANAGERS, OFFICERS, EMPLOYEES, ADVISORS, REPRESENTATIVES, AFFILIATES, AND AGENTS (THE "COMPANY PARTIES") MAKE NO EXPRESS WARRANTIES AND HEREBY DISCLAIM ALL IMPLIED WARRANTIES REGARDING OUR SERVICES AND ANY PART OF THEM (INCLUDING, WITHOUT LIMITATION, OUR SERVICES OR ANY EXTERNAL WEBSITES), INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, CORRECTNESS, ACCURACY, OR RELIABILITY. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, THE COMPANY PARTIES DO NOT REPRESENT OR WARRANT TO YOU THAT (A) YOUR ACCESS TO OR USE OF OUR SERVICES WILL MEET YOUR REQUIREMENTS, (B) YOUR ACCESS TO OR USE OF OUR SERVICES WILL BE UNINTERRUPTED, TIMELY, RISK-FREE, OR FREE FROM ERROR, (C) USAGE DATA PROVIDED THROUGH OUR SERVICES WILL BE ACCURATE, (D) OUR SERVICES OR ANY CONTENT, SERVICES, OR FEATURES MADE AVAILABLE ON OR THROUGH OUR SERVICES ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR (E) DATA WILL BE COMPLETELY SECURE OR IMMUNE FROM UNAUTHORIZED ACCESS.

19.2 PERSONAL RISKS. YOU ACCEPT THE INHERENT SECURITY RISKS OF PROVIDING INFORMATION AND DEALING ONLINE OVER THE INTERNET AND AGREE THAT WE HAVE NO LIABILITY OR RESPONSIBILITY FOR ANY BREACH OF SECURITY UNLESS IT IS DUE TO TRANSFI’S GROSS NEGLIGENCE. YOU WILL IMPLEMENT REASONABLE AND APPROPRIATE MEASURES DESIGNED TO SAFEGUARD ACCESS TO (A) ANY DEVICE ASSOCIATED WITH YOU AND UTILIZED IN CONNECTION WITH YOUR PURCHASE OR USE OF OUR SERVICES; AND (B) ANY OTHER USERNAME, PASSWORDS, OR OTHER LOGIN OR IDENTIFYING CREDENTIALS.

19.3 THIRD-PARTY OPERATORS DISCLAIMER. TRANSFI PROVIDES THE SERVICES BY INTEGRATING WITH AND RELYING ON THIRD PARTY OPERATORS. YOU ACKNOWLEDGE AND AGREE THAT THIRD PARTY OPERATORS ARE INDEPENDENT ENTITIES AND ARE SOLELY RESPONSIBLE FOR THEIR RESPECTIVE SERVICES, INCLUDING TRANSACTION PROCESSING, AUTHORIZATION, SETTLEMENT, NETWORK OPERATIONS, AND COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS. TRANSFI DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR THE PERFORMANCE, AVAILABILITY, SECURITY, OR RELIABILITY OF ANY THIRD PARTY OPERATOR. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, TRANSFI DISCLAIMS ALL LIABILITY FOR ANY LOSS, DAMAGE, DELAY, FAILURE, OR ERROR ARISING OUT OF OR RELATING TO THE ACTS OR OMISSIONS OF ANY THIRD-PARTY OPERATOR, INCLUDING BUT NOT LIMITED TO TRANSACTION FAILURES, PROCESSING DELAYS, SETTLEMENT ISSUES, NETWORK CONGESTION, SYSTEM OUTAGES, CYBER INCIDENTS, INSOLVENCY, OR REGULATORY ACTIONS AFFECTING SUCH THIRD PARTY OPERATORS. WITHOUT LIMITING THE FOREGOING, TRANSFI SHALL NOT BE LIABLE FOR ANY FAILURE OR DELAY IN THE PROCESSING OR COMPLETION OF ANY PAYMENT TRANSACTION CAUSED BY THIRD PARTY OPERATORS OR UNDERLYING PAYMENT SYSTEMS, INCLUDING CARD NETWORKS, BANKING SYSTEMS, ALTERNATIVE PAYMENT METHODS, OR BLOCKCHAIN PROTOCOLS.

19.4 RISK DISCLOSURES, ASSUMPTION OF RISKS, AND RELEASE OF TRANSFI. OTHER THAN AS EXPRESSLY SET FORTH IN THIS AGREEMENT, TRANSFI SHALL NOT BE LIABLE FOR ANY RISKS INHERENT IN THE SERVICES OR RELATED TRANSACTIONS OR PAYMENTS THAT MAY BE INCURRED BY THE END USER OR THE CUSTOMER AS A RESULT THEREOF. THE END USER, CUSTOMER AGREE TO AND DO HEREBY: (I) RELEASE TRANSFI FROM ANY AND ALL LIABILITY RELATED TO OR ARISING FROM RISKS INHERENT IN THE SERVICES AND RELATED TRANSACTIONS EXCEPT AS EXPRESSLY SET FORTH IN THIS TERM ; AND (II) ASSUME ALL RISKS INHERENT IN THE SERVICES AND RELATED TRANSACTIONS, INCLUDING BUT NOT LIMITED TO THE FOLLOWING:

• THE RISK THAT ANY THIRD-PARTY SERVICE PROVIDERS OF TRANSFI CEASE TO OPERATE, RENDERING A TRANSACTION IMPOSSIBLE AND ENTIRELY WITHOUT USE.
• THE MARKET FOR DIGITAL TOKENS MAY COLLAPSE WITHOUT WARNING OR DISCERNIBLE LOGIC.
• THERE IS A RISK THAT CHANGES IN APPLICABLE LAW COULD ADVERSELY AFFECT THE CUSTOMER’S RIGHT TO LEGALLY USE, TRANSFER, EXCHANGE, AND/OR OBTAIN VALUE FROM DIGITAL TOKENS . IT MAY BE ILLEGAL, NOW OR IN THE FUTURE, TO OWN, HOLD, SELL, OR USE DIGITAL TOKENS IN ONE OR MORE COUNTRIES.
• TRANSACTIONS IN DIGITAL TOKENS ARE, AS A RULE, IRREVERSIBLE. CONSEQUENTLY, LOSSES DUE TO FRAUDULENT OR ACCIDENTAL TRANSACTIONS ARE GENERALLY NOT RECOVERABLE. ONCE A TRANSACTION HAS BEEN RECORDED ON THE APPROVED NETWORK, IT IS NOT REVERSIBLE. THE CUSTOMER ACKNOWLEDGES THAT IT IS POSSIBLE THAT, THROUGH COMPUTER OR HUMAN ERROR OR THROUGH THEFT OR FRAUD, DIGITAL TOKENS COULD BE TRANSFERRED IN INCORRECT AMOUNTS OR TO UNAUTHORIZED THIRD PARTIES.
• SOME TRANSACTIONS SHALL BE DEEMED TO BE MADE WHEN RECORDED ON THE APPROVED NETWORK, WHICH IS NOT NECESSARILY THE DATE OR TIME THAT THE CUSTOMER INITIATED THE TRANSACTION.
• DIGITAL TOKENS MAY BE TARGETS OF FRAUD AND CYBER-ATTACKS. ON DEVICES SUCH FRAUD AND ATTACKS CAN RESULT IN TOTAL LOSS TO THE CUSTOMER. TRANSFI MAKES COMMERCIALLY REASONABLE EFFORTS TO VERIFY THAT THE CUSTOMER IS THE TRUE INITIATOR OF TRANSACTIONS, SUCH EFFORTS MAY FAIL AND COULD RESULT IN TOTAL LOSS OF DIGITAL TOKENS ATTACKS ON TRANSFI MAY ALSO RESULT IN UNPLANNED AND SIGNIFICANT UNSCHEDULED DOWNTIME DURING WHICH TRANSACTIONS WILL NOT BE EXECUTED. ABSENT FRAUD OR INTENTIONAL WRONGDOING ON THE PART OF TRANSFI, TRANSFI SHALL NOT BE LIABLE FOR CUSTOMER LOSSES ON ACCOUNT OF ANY OF THE FOREGOING CIRCUMSTANCES. AS A GOOD FAITH HOLDER OF DIGITAL TOKENS THERE IS A RISK THAT THE CUSTOMER WILL LOSE POSSESSION THEREOF IF TRANSFI DETERMINES THAT IT WAS PREVIOUSLY TRANSFERRED BY FRAUDULENT MEANS OR TRANSFERRED OTHERWISE IN VIOLATION OF THIS AGREEMENT, EVEN IF THE CUSTOMER HAD NO PART IN THE WRONGDOING.
• THE SERVICES AND DIGITAL TOKENS RELY ON THE INTERNET, WHICH INCLUDES THIRD-PARTY HARDWARE, SOFTWARE, AND INTERNET CONNECTIONS, ALL OF WHICH MAY SUFFER COMMUNICATION FAILURES, DISRUPTIONS, ERRORS, DISTORTIONS, OR DELAYS THAT MIGHT AFFECT THE CUSTOMER’S ABILITY TO PERFORM TRANSACTIONS.
• TRANSFI MAY FREEZE, BLOCK, DELAY, OR RESTRICT FUNDS OR PAYMENTS IF REQUIRED BY LAW, COURT ORDER, OR REGULATORY INSTRUCTION, AND SHALL NOT BE LIABLE FOR RESULTING LOSSES OR DELAYS.

THE CUSTOMER SHALL ENSURE THAT ALLEND USERS CARRY OUT THEIR OWN INDEPENDENT ANALYSIS AND ASSESSMENT OF THE RISKS SPECIFIC TO THE SERVICES AND RELATED TRANSACTIONS.

19.5 LIMITATIONS ON THE SCOPE OF OUR SERVICES:

• OUR SERVICES DO NOT INCLUDE INVESTMENT ADVICE, PERSONAL RECOMMENDATIONS, OR ANY FORM OF GUIDANCE ON THE MERITS OR SUITABILITY OF ENGAGING IN ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE.
• WE DO NOT PROVIDE ANY REPRESENTATIONS, ASSURANCES, OR GUARANTEES AS TO THE SUITABILITY OR APPROPRIATENESS OF ANY OF OUR SERVICES FOR YOUR SPECIFIC NEEDS.
• YOU ARE SOLELY RESPONSIBLE FOR OBTAINING ANY LEGAL, ACCOUNTING, FINANCIAL, OR TAX ADVICE YOU MAY REQUIRE TO DETERMINE WHETHER ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE IS SUITABLE FOR YOUR REQUIREMENTS OR THE REQUIREMENTS OF YOUR BUSINESS.
• ANY INFORMATION PROVIDED TO YOU IN RELATION TO THIS AGREEMENT, INCLUDING BUT NOT LIMITED TO MARKET INFORMATION, RESEARCH FORECASTS, OR OTHER DATA SHARED WITH YOU REGARDING ANY PROPOSED TRANSACTION OR OTHERWISE, IS FOR INFORMATIONAL PURPOSES ONLY. SUCH INFORMATION IS NOT INTENDED TO BE RELIED UPON AS FINANCIAL OR PROFESSIONAL ADVICE FOR PLACING AN ORDER OR ENTERING INTO ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE.
• INSOFAR AS IS PERMISSIBLE UNDER APPLICABLE LAWS AND REGULATIONS, TRANSFI DOES NOT OWE YOU ANY FIDUCIARY DUTY OR SIMILAR OBLIGATION UNDER THIS AGREEMENT.
• THE FOREIGN EXCHANGE RATES USED FOR THE PURPOSES OF PROVIDING THE SERVICES WILL BE DETERMINED BY TRANSFI AND MAY INCLUDE OUR COSTS, FEES, AND CHARGES. THESE RATES MAY DIFFER FROM PUBLISHED INTERBANK RATES OR OTHER PUBLICLY AVAILABLE BENCHMARKS.

20. LIMITATION OF LIABILITY

20.1 YOU UNDERSTAND AND AGREE THAT TRANSFI WILL BE LIABLE TO YOU OR TO ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES THAT YOU MAY INCUR, HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY, INCLUDING, WITHOUT LIMITATION, ANY LOSS OF PROFITS (WHETHER INCURRED DIRECTLY OR INDIRECTLY), LOSS OF GOODWILL OR BUSINESS REPUTATION, LOSS OF DATA, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR ANY OTHER INTANGIBLE LOSS, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

20.2 YOU UNDERSTAND AND AGREE THAT TRANSFI WILL NOT BE LIABLE AND DISCLAIMS ALL LIABILITY TO YOU IN CONNECTION WITH ANY FORCE MAJEURE EVENT, INCLUDING ACTS OF GOD; LABOR DISPUTES OR OTHER INDUSTRIAL DISTURBANCES; ELECTRICAL, TELECOMMUNICATIONS, HARDWARE, SOFTWARE, OR OTHER UTILITY FAILURES; SOFTWARE OR SMART CONTRACT BUGS OR WEAKNESSES; EARTHQUAKES, STORMS, OR OTHER NATURE-RELATED EVENTS; PANDEMICS; BLOCKAGES; EMBARGOES; RIOTS; ACTS OR ORDERS OF GOVERNMENT; ACTS OF TERRORISM OR WAR; TECHNOLOGICAL CHANGE; AND CHANGES IN INTEREST RATES OR OTHER MONETARY CONDITIONS.

20.3 YOU AGREE THAT OUR TOTAL, AGGREGATE LIABILITY TO YOU FOR ANY AND ALL CLAIMS ARISING OUT OF OR RELATING TO THESE TERMS, OR YOUR ACCESS TO OR USE OF (OR YOUR INABILITY TO ACCESS OR USE) ANY PORTION OF OUR SERVICES, WHETHER IN CONTRACT, TORT, STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, IS LIMITED TO THE GREATER OF (A) THE F FEES YOU PAID TO TRANSFI IN THE SIX (6) MONTH PERIOD PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED DOLLARS ($100), WHICHEVER IS LOWER.

20.4 YOU ACKNOWLEDGE AND AGREE THAT WE HAVE MADE OUR SERVICES AVAILABLE TO YOU AND YOU HAVE AT YOUR SOLE DISCRETION ENTERED INTO THESE TERMS IN RELIANCE UPON THE WARRANTY DISCLAIMERS AND LIMITATIONS OF LIABILITY SET FORTH HEREIN, WHICH REFLECT A REASONABLE AND FAIR ALLOCATION OF RISK BETWEEN THE PARTIES AND FORM AN ESSENTIAL BASIS OF THE BARGAIN BETWEEN TRANSFI AND YOU.

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21. NO RESPONSIBILITY FOR TRANSACTIONS WITH THIRD-PARTY OPERATORS

We are not responsible for any transaction between you and Third-Party Operators . If a Third-Party Operator fails to complete a purchase on Your behalf on time or in the correct amount, or if any loss occurs with respect to any transaction conducted through a Third-Party Operator we will not be liable for Your losses or damages.

You acknowledge that payment transactions initiated through the checkout Service may be subject to authorization, verification, and processing by your payment provider, banking institution, card network, or other payment partners. As a result, a transaction may be declined, delayed, reversed, or otherwise not successfully processed due to reasons including, but not limited to, insufficient funds, incorrect payment details, suspected fraud, compliance requirements, technical errors, or restrictions imposed by the relevant financial institution or payment network.

TransFi does not guarantee that any payment transaction will be successfully processed and shall not be responsible for any loss, delay, or inconvenience arising from a transaction that is declined, delayed, or otherwise not completed. TransFi reserves the right to suspend, refuse, or cancel any transaction where it reasonably believes such action is necessary to comply with applicable laws, regulatory obligations, or internal risk and fraud prevention policies.

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22. INDEMNIFICATION

To the fullest extent permitted by Applicable Law, you agree to indemnify, defend, and hold harmless and reimburse TransFi from and against any and all actions, proceedings, claims, damages, demands, and actions (including without limitation fees and expenses of counsel), incurred by a TransFi arising from or relating to:

(a) your use of the Product, Website, or our Services;

(b) your responsibilities or obligations under the Terms;

(c) your breach of or violation of the Terms;

(d) any inaccuracy in any of your representations or warranties;

(e) your violation of any rights of any other person or entity, including any proprietary or privacy rights;

(f) your violation of any Applicable law ; and/or

(g) any of your acts or omissions that are negligent, unlawful, or constitute willful misconduct.

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TransFi reserves the right to exercise sole control over the defense, at your expense, of any claim subject to indemnification under this section 22. TransFi will notify you of any claim and you will cooperate.This indemnity is in addition to, and not in lieu of, any other indemnities set forth in a written Business Service Agreement between Customer and TransFi.

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23. GOVERNING LAW AND DISPUTE RESOLUTION

23.1 In the event of any dispute or claim between the Parties hereto arising from or relating to this Agreement, including any question regarding its existence, validity, or termination (a “Dispute”), then, the Parties shall first use good faith efforts to resolve it through negotiation by providing the other Party notice in writing describing the nature of the Dispute. Each Party will appoint a designated representative to endeavour to resolve such dispute. The designated representatives will be executives with sufficient authority to engage in good faith negotiations and bind the Party they represent.

If the designated representatives are unable to resolve the dispute within a reasonable period (but in no event more than thirty (30) days from the date of receipt of written request) after using their best efforts to do so, then the Dispute shall be finally resolved by binding arbitration. Any dispute, controversy, or claim arising out of or in connection with this Agreement, including any question regarding its existence, validity, interpretation, performance, breach, or termination, shall be referred to and finally resolved by arbitration under the Rules of the London Court of International Arbitration (LCIA), which Rules are deemed to be incorporated by reference into this clause.

The seat (legal place) of arbitration shall be London, England.
The tribunal shall consist of one arbitrator, unless the LCIA Court determines otherwise in accordance with the LCIA Rules.
The language of the arbitration shall be English.

The arbitration award shall be final and binding on the Parties and may be enforced in any court of competent jurisdiction

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24. EXTERNAL SITES

The solution or APIs or our Services may include hyperlinks or redirect you to other websites or resources (collectively, "External Sites") that are provided solely as a convenience to you. We have no control over any External Sites. You acknowledge and agree that we are not responsible for the availability of any External Sites and that we do not endorse any advertising, products, services, or other materials on or made available from any External Sites. Furthermore, you acknowledge and agree that we are not liable for any loss or damage that may be incurred as a result of the availability or unavailability of the External Sites or as a result of any reliance placed by you upon the completeness, accuracy, or existence of any advertising, products, services, or other materials on, or made available from, any External Sites.

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25. ENTIRE AGREEMENT

These Terms, including the Privacy Policy, Business Services Agreement (where applicable) and any other terms and conditions referenced herein constitute the entire agreement between you and TransFi with respect to the subject matter hereof, including the Services. These Terms, including the Privacy Policy, supersede all prior or contemporaneous written and oral agreements, communication, and other understandings relating to the subject matter of the Terms. These Terms do not alter any agreement you may have with any Third Party Operators but shall supersede any such agreements in the event of a conflict between these Terms and any agreement with Third Party Operators s.

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26. DATA PROTECTION AND PRIVACY POLICY

Our Privacy Policy, which is incorporated herein by reference, describes how we collect, use, store, and disclose your personal information. You agree to the collection, use, storage, and disclosure of your data in accordance with the Privacy Policy. We are committed to keeping your personal information safe and processing it in accordance with applicable data protection legislation. Please review our Privacy Policy to understand how we use and protect the information you provide to us.

The End User acknowledges and agrees that TransFi may collect, access, process, store, and retain the End User’s profile information, account details, transactional data, and any other data relating to the End User (“End User Data”) for the purposes of providing, operating, monitoring, and improving its services, including for internal analytics, risk management, fraud prevention, and the development and offering of enhanced or targeted products and services. TransFi shall be entitled to retain End User Data for such period as it deems necessary to fulfil the purposes set out herein, including to comply with Applicable Laws, regulatory requirements, and its internal compliance and audit obligations.

Notwithstanding anything to the contrary, the End User expressly acknowledges and agrees that TransFi may, without further notice or consent, disclose, share, or transfer End User Data to any governmental, regulatory, supervisory, or judicial authority, law enforcement agency, or any financial institution, payment network, or other third-party service provider, where such disclosure is required or deemed necessary by TransFi to comply with Applicable Laws, regulation, legal process, or any request, order, or directive having the force of law.

The End User further consents to the use of End User Data, on an aggregated or individual basis, for internal analytics, research, and commercial purposes, including to optimize, personalize, and improve TransFi’s products, services, and user experience.

By accessing or using the Services, the End User provides informed, explicit, and unconditional consent to the collection, use, retention, and disclosure of End User Data in accordance with this Clause.

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27. CONTACT INFORMATION

If you have any feedback, questions, or complaints, you may contact us via our help center on our website or at compliance@transfi.com.

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Annexure A - List of TransFi Entities

This list is indicative only and may be updated without notice

Trans-Fi Inc.

TransFi UAB

Neomoney INC.

TransFi PTE. LTD.

TransFi Technology LLC

TransFi Innovation Limited

Trans-Fi India Private Limited

TransFi Bahamas Limited

Pt. TransFi Indonesia Merdeka

TransFi Digital Limited

TRANSFI VIRTUAL ASSETS SOLUTIONS FZCO

TRANSFI AUSTRALIA PTY LTD

MAXSERVICE24 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

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GAMING, FX AND CFD TERMS & CONDITIONS - GLOBAL

Last Updated: 10th April 2026

This document outlines the terms and conditions (“Terms”) that govern the use of the Services provided by TransFi. These Terms apply specifically to End Users of Customers and/or Merchants (“you/your”) . By using our Services, You agree to these Terms, including our Privacy Policy, AML/KYC Policy and TransFi Payments (Platform) Terms and conditions of Use . If You do not agree to any part of these Terms, You are not permitted to use the Services. These Terms shall include these Terms & Conditions, our Privacy Policy, and our AML/KYC Policy and TransFi Payments (Platform) Terms and conditions of Use.

By accessing or using the Services in any manner, You expressly acknowledge and represent that You have read, understood, and agree to be legally bound by all provisions of these Terms, as amended from time to time.

Please read these Terms carefully, as they set out the Terms on which TransFi will provide You the Services. The Services enable you to send, receive, hold, convert, and manage funds in supported fiat currencies and digital tokens, including collecting payments for goods or services through the platform of the Customer or Merchant you are using, and to carry out related payment and settlement transactions made available through such platform.

If You do not agree to these Terms or any subsequent modification to them, You must not use the Services. TransFi may suspend or terminate Your access to the Services and close Your Account in such circumstances. Continued use of the Services constitutes acceptance of any updated Terms. If You do not agree, You must stop using the Services immediately.

NOTICE: Please read these Terms carefully, as they govern Your use of the Services and affect Your legal rights. BY USING OUR SERVICES OR CLICKING "I ACCEPT" BELOW OR CLICKING A BOX INDICATING YOUR ACCEPTANCE, YOU CONFIRM THAT YOU READ, UNDERSTAND AND AGREE TO BE BOUND BY THESE TERMS , INCLUDING ALL POLICIES, TERMS, AND CONDITIONS INCORPORATED BY REFERENCE..

If You accept these Terms on behalf of a company or other legal entity by accessing or using the Services,clicking "Agree" below or clicking a box indicating acceptance, You represent and warrant that You have the legal authority to bind that entity to these Terms. In such cases, “You” and “Your” (except as used in this paragraph) will refer to that entity. . If You do not have such authority or do not agree to these Terms, then neither you nor that entity may access or use the Services. You are advised to retain a copy of these Terms for Your records.

TransFi may, at its sole discretion, modify , amend, or update these Terms from time to time. When we do so, we will post the updated Terms on the Website and revise the "Last Updated" date. Changes to these Terms become effective on the date they are posted. Your continued access to or use of our Services after the updated Terms are posted constitute Your binding acceptance of the changes. If You do not agree to any revised Terms, You must stop accessing or using the Services immediately.

These Terms constitute a legally binding agreement between You, as an end user of a Customer’s or Merchant’s platform, and TransFi governing Your access to and use of the Services. TransFi provides technical facilitation of payment and Digital Tokens –related transactions made available to You through such platforms.

The Services may involve the use of Digital Tokens ; however, TransFi does not promote or market Digital Tokens as an investment product and does not encourage speculative activity.

In providing the Services, TransFi may rely on licensed or authorized third-party service providers, including custodians, payment processors, liquidity providers, or settlement partners. TransFi is not responsible for errors, delays, failures, or losses caused by such third parties, except to the extent required by applicable law.

TransFi operates subject to applicable legal and regulatory requirements. Your access to the Services and the availability of Your funds may be restricted, delayed, frozen, or otherwise impacted as a result of compliance obligations, legal orders, regulatory actions, or risk management measures.

1. INTRODUCTION

1.1 These Terms constitute a legally binding agreement between You and TransFi Inc. (“TransFi”). By accessing or using the Services, You agree to be bound by these Terms and any other supplemental terms that apply to specific Services and are presented to You in the relevant user flow

2. DEFINITIONS

• Account: The registered profile by You with TransFi, or created for You in connection with Your use of the Services, through which You access and use the Services.
  
  
• AML (Anti-Money Laundering): The checks and processes implemented by financial institutions and regulated entities to detect, prevent, and report money laundering activities. This includes transaction monitoring (for both fiat and Digital Tokens), risk assessments, and adherence to Applicable Law.
  
  
• Applicable Law: All applicable laws, statutes, statutory instruments, rules, regulations, judgments, decrees, regulatory guidelines, codes of practice, or other requirements of regulatory authorities in any jurisdiction, as amended from time to time, and legally binding on a party.
• Business Day: means any day other than a Saturday, Sunday, or public holiday and the day on which banks are open for business in the country where TransFi operates the relevant Services.
  
  
• Chargeback/Fraud Recall: The reversal of a transaction or request for repayment in respect of a previously settled and/or remitted transaction initiated by the issuing bank, payment networks, payment service providers, or other financial institutions.
  
  
• Customer: A business or platform through which You access the Services. TransFi is not responsible for the operations, products, or obligations of such Customers.
  
  
• Third Party Operator: Any third-party service provider engaged or used by TransFi in connection with the Services, including, without limitation, payment processors, acquirers, banks, liquidity providers, exchanges, custodians, or settlement agents. TransFi is not responsible for any errors, delays, or losses caused by Third-Party Operators
• CTF (Counter-Terrorist Financing): Laws and regulations that aim to prevent the financing of terrorism and terrorist-related activities.
  
  
• Digital Tokens : Any digital representation of value that can be digitally traded, transferred, or stored, including stablecoins (e.g., USDT, USDC), cryptocurrencies (e.g., Bitcoin, Ethereum), and other digital tokens. Digital Tokens are not promoted by TransFi as investments, and TransFi does not provide investment advice.
  
  
• Compliance Checks: The risk-based customer verification and monitoring measures conducted by TransFi or its Third Party Operators in connection with the onboarding and ongoing use of the Services. Compliance Checks may be carried out at different levels depending on the risk profile of the end user and applicable transaction limits, and may include:

• Basic Screening, involving the collection of minimal end-user information and sanctions or watchlist screening without submission of identity documents, with restricted transaction limits;
• Standard Due Diligence, involving submission of identification documents and completion of identity verification procedures, including liveliness or similar checks, following which transaction limits may be increased; and
• Enhanced Due Diligence, involving additional verification measures for higher-risk users or higher transaction thresholds, including submission of proof of funds, source of wealth information, or other supporting documentation, following which maximum transaction limits may be permitted.

• End User/ You/ Your: An individual or legal entity that accesses or uses the Services, either via a Customer platform or a Merchant platform.
  
  
• KYB (Know Your Business): A process of identification under AML/CTF requirements, including additional checks, such as email age verification, internet profiling, adverse media screening, and sanctions screening.
  
  
• Merchant: A business or individual that offers products or services through a Customer’s platform, which allows You to use the Services. TransFi is not responsible for the operations, products, or obligations of such Merchants.
  
  
• PEP (Politically Exposed Person): Individuals who are or have been entrusted with prominent public functions and are subject to enhanced due diligence requirements.
  
  
• Services: TransFi services related to its Gaming, FX and CFD product, including, but not limited to:
  
  • access wallet functionality for storing and transferring supported fiat funds or Digital Assets;
  • initiate deposits, withdrawals, or transfers; and
  • convert between supported fiat currencies and Digital Assets.

TransFi’s role is strictly limited to providing software, systems connectivity, and transaction orchestration that facilitate the transmission of your instructions to the Platform and its financial institutions, payment service providers, and Digital Asset service partners.

TransFi does not provide custody, safeguarding, or control of your fiat funds or Digital Assets, does not operate a bank, exchange, brokerage, or financial institution, does not provide investment, trading, gaming, FX, or CFD services, and does not act as the buyer, seller, broker, intermediary, agent, fiduciary, or counterparty in any transaction.

Fiat payment services, Digital Asset execution, custody, settlement, and safeguarding are performed by the Platform and/or regulated Third-Party Operators, as applicable.

TransFi does not operate or manage any Gaming, FX, CFD, betting, or trading products and is not a counterparty to any such activity. Your use of services made available through the Platform is also subject to the Platform’s terms and policies. TransFi is not a party to those agreements and is not responsible for the licensing, operation, compliance, availability, or performance of services provided by the Platform or other third parties.

• TransFi/us/we/our: means and shall include, without limitation, all of its current and future subsidiaries, affiliates, holding companies, group entities, successors, permitted assigns, and any entity that directly or indirectly controls, is controlled by, or is under common control with TransFi, whether existing or formed, established, acquired, or reorganised thereafter. For ease of reference, the indicative list of such entities is provided in Annexure A, which may be updated from time to time and shall include all subsidiaries and affiliates of TransFi, whether or not expressly listed therein. Any reference to “TransFi” shall be deemed to include all such entities, and all rights, obligations, protections, and limitations applicable to TransFi shall apply equally and collectively to each of them.
  
  
• TransFi Wallet: A custodial digital wallet offered by TransFi for the purpose of storing and managing Digital Tokens . TransFi’s Third Party Operators manage and hold the wallet’s End User’s private keys.

DISCLAIMER: The risk of loss in trading or holding Digital Tokens can be substantial. You should be aware that the price or value of Digital Tokens, including, but not limited to, cryptocurrencies, NFTs, can change rapidly, decrease, and potentially even fall to zero. Therefore, You should carefully consider whether trading or holding Digital Tokens is appropriate for You in light of Your financial circumstances.

You acknowledge that if You use Your own custodial digital wallet not offered by TransFi ("third party wallet”) to access the Services, TransFi is not responsible for and does not hold the private keys for your Digital Tokens wallet or any other security information to access your Digital Tokens and TransFi is not responsible for any loss of Digital Tokens resulting from theft, loss, or mishandling of private keys or other security information outside its control.

Every purchase and sale of Digital Tokens is executed on and confirmed by the respective network of that Digital Token . The confirmation process takes time (typically less than one hour, but potentially one day or more). An order is not complete until it is confirmed. Digital Tokens associated with orders that are pending will be designated accordingly.

A transaction between a buyer and a seller occurs peer-to-peer on a public blockchain. TransFi does not guarantee that You will receive Your Digital Token, as transactions may fail for a variety of reasons, including but not limited to, network congestion, technical issues with blockchain, or another buyer completing the purchase of the Digital Token before Your transaction is confirmed. If your transaction fails, TransFi will use reasonable efforts to facilitate a refund of any applicable fees, but TransFi is not responsible for any losses, delays, or damages arising from failed transactions.

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3. LEGAL RELATIONSHIP BETWEEN TRANSFI AND THE MERCHANT, CUSTOMER

3.1 These Terms form a contract between TransFi and End Users. Where an End User accesses the Services through a Customer or Merchant, this does not prevent the End User from having separate rights and obligations as against the Customer or Merchant under their own terms.

3.2 The Services are provided to You via a Customer or Merchant platform. You must read and accept these Terms before using the Services. By accessing or using the Services through a Customer or Merchant platform, You agree to be bound by these Terms.

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3.3 We may assign or transfer our rights in these Terms to any member of our Group company or any affiliate without your consent, listed under Annexure A and as may be amended from time to time by TransFi.. You may not assign these Terms without our prior written consent of TransFi.

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4. ACCOUNT CREATION

4.1 To use the Services, You must create an Account. To register as an End User for the first time, You will be required to submit certain personal information, such as your name, email address, contact number, street address, and zip code if You are an individual. For business End Users, the registered name, email address, business registration date, and registration number of the legal entity shall be required . TransFi may also request additional documentation to verify Your date of birth, identification number (such as a social security number), and country of residence/nationality as part of our Compliance Checks . If TransFi is unable to authenticate Your identity, You may not have access to our Services. By creating an Account, You represent and warrant that all information You provide is accurate, current, and complete, and You agree to maintain and promptly update Your information as necessary.

4.2 By creating an Account, You represent and warrant that You: (a) are at least 18 years of age (or the age of majority in your jurisdiction) and have legal capacity to enter into these Terms , but not older than 70 years, beyond which TransFi restricts the usage by an End User.; (b) are an individual, legal person, or a legal entity with the full legal capacity and authority to enter into these Terms; and (c) have not previously been suspended or removed from using our Services.

4.4 You authorize Us, directly or through Third-Party Operators , to make any inquiries We deem necessary to validate Your information. This may include requesting further information and/or documentation regarding Your use of the Services or identity, requiring You to take steps to confirm ownership of Your email address, mobile phone number, or bank accounts, credit or debit cards, digital wallets, payment accounts (e.g. local wallets), prepaid cards or other financial assets used for transactions, and verifying Your information against third-party databases or through other sources.

4.5 We reserve the right to reject Your application to create an Account or to terminate an existing Account, for any reason, at Our sole discretion, subject to Applicable Law. However, the termination of Your Account will not affect any rights You may have related to your Digital Tokens held in a TransFi Wallet, any Third Party Wallet and You remain responsible for any obligations, liabilities, or fees incurred prior to termination.

4.6 Where We suspend or restrict an Account for compliance, fraud, or security reasons, we may delay or prevent withdrawals or transactions as required by Applicable Law, regulatory guidance, or risk management. Where permitted, We will provide You with information on available options to withdraw or transfer remaining balances, subject to verification and applicable holds.

4.7 You must not impersonate any other person or entity to access our Services or access the Account of any other End User without that person’s prior permission, We may request proof of such permission. You must not create any Accounts by automated means or under false or fraudulent pretenses.

4.8 You agree that You will use the Services only in a manner that complies with Applicable Laws and that you are solely responsible for any improper or unlawful activity in connection with the registration or use of your Account, including any misrepresentations made in connection with the creation of Your Account.

4.9 You confirm that the Services shall not be used for any unlawful gambling, betting, or wagering activity, and that all gaming activities conducted by You comply with applicable gaming laws and licensing requirements.

4.10 You agree and confirm that Services shall not be used in jurisdictions where online gaming, betting, or CFD trading is restricted or unlawful.

4.11 You agree and acknowledge that gaming or trading activities involve financial risk and agree to participate responsibly.

4.12 We will share Your information and transaction details with Third-Party Operators who fulfill transaction requests in accordance with our Privacy Policy TransFi Privacy Policy.

4.13 You are responsible for maintaining the security of Your Account. If You become aware of any unauthorized use of Your Account credentials for Our Services, you must immediately notify Us at compliance@transfi.com.

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5. RISK, LIABILITY AND SERVICE DISCLAIMERS

5.1 The Services involve Digital Tokens , including cryptocurrencies, stablecoins . TransFi does not promote, recommend, or provide advice on the purchase, sale, or holding of Digital Tokens for speculative or investment purposes. Trading or holding Digital Tokens carries a high risk of loss, including the potential loss of Your entire investment. You are solely responsible for evaluating whether using the Services is appropriate for Your financial situation and risk tolerance.

5.2 Some Services are facilitated by Third-Party Operators, such as payment processors, banks, liquidity providers, exchanges, and custodians. TransFi does not control these third parties and is not responsible for any errors, delays, or losses caused by them, except as required by Applicable Law. You acknowledge and accept that reliance on Third-Party Operators carries inherent risks.

5.3 TransFi is subject to Applicable Law and regulatory obligations.Regulatory actions, compliance measures, or changes in law may affect Your ability to access or use the Services and may impact Your funds or Digital Tokens . You acknowledge and accept that TransFi is not liable for any such impact arising from compliance with Applicable Law or regulatory measures.

5.4 TransFi does not guarantee the performance, security, or success of any transaction or investment in Digital Tokens . Transactions may fail due to network congestion, blockchain issues, or other factors beyond TransFi’s control. In such cases, TransFi will use reasonable efforts to facilitate refunds of applicable fees, but is not liable for losses or damages resulting from failed or delayed transactions.

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6. TRANSACTIONS LIMITS AND COMPLIANCE CHECKS

5.1 TransFi adheres to high standards of compliance with policies and procedures designed to prevent money laundering, criminal activities, market abuse, and conflicts of interest. All TransFi employees are committed to the highest ethical standards.

5.2 The use of our Services is subject to transaction thresholds that apply to the volume You may transact or transfer within a given period (e.g., per transaction limit, daily transaction limit, or monthly transaction limit). You can view your specific transaction limits by logging into your Account. These limits may vary depending on Your payment method, Compliance Checks, geography, KYC levels, and other factors, as determined by TransFi’s internal risk assessment and compliance policies. We reserve the right to modify applicable limits as We deem necessary to comply with Our risk management and regulatory obligations. If You wish to request an increase to your transaction limits beyond the posted amounts, You may submit a request to compliance@transfi.com.

5.3 We may require you to submit additional information about yourself and provide supporting documentation if you request an increase to your transaction limits. TransFi, in its sole discretion, may refuse to grant an increase to Your limits, or We may lower Your limits at a later time, even if You have previously completed Compliance Checks.

5.4 Our compliance program is based on the following pillars:

• Know Your Customer (KYC) and Know Your Business (KYB): We conduct KYC/KYB checks to determine if any Customers, Merchants, or End Users are subject to sanctions, are PEPs, or have any adverse media reporting.
  
  
• Transaction Monitoring: All fiat transactions are monitored for potential AML risks across all payment methods. This monitoring covers risks associated with geographic location, transaction size, and Customer behavior. All Digital Token transactions are monitored for risks related to sanctioned jurisdictions, dark web activity, child abuse, compromised assets, or other criminal activity. For Digital Token transaction monitoring, we employ a range of rules to assess transaction hash and Digital Token wallet risks.
  
  
• Fraud Monitoring: Our fraud monitoring processes include name matching, internet and social media risk profiling, device and IP checks, transaction behavior analysis, and browsing behavior checks.
  
  
• Travel Rule Compliance: We comply with travel rule Compliance, and are working on expanding the control to all geographies
• Data Storage and Management: Data, including payer and recipient information, payment methods, transaction details, and browsing behavior, are stored in local clouds in accordance with applicable data localization requirements.

5.5 Our compliance processes also include:

• Risk limits on End Users, such as per-transaction, and daily and monthly transaction limits.
  
  
• Prohibitions on certain business types: For a current and complete list of prohibited business types, please refer to TransFi’s AML/KYC Policy, which is subject to change.
  
  
• Compliance Checks requirements for End Users presenting a higher risk, which may involve requests for additional documents and verification. High-risk businesses include but are not limited to: (a) custodial crypto-asset services; (b) other non-custodial crypto-asset services; (c) money services/payments/other financial services; (d) licensed gambling services; and (e) any End User with a PEP beneficial owner.
• Prohibited Jurisdictions: For a current list of prohibited jurisdictions, please refer to TransFi’s internal AML/KYC Policy, which is subject to change AML/KYC Policy.

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6. PURCHASE, SALE, AND TRANSFER OF DIGITAL TOKENS

6.1 The Services may include, either directly by TransFi or through Third-Party Operators, as applicable:

(a) facilitating the exchange of fiat currency to Digital Tokens and Digital Tokens to fiat;
(b) facilitating the exchange of one Digital Token for another Digital Token; and
(c) enabling the custody or administration of Digital Tokens through a TransFi Wallet, where offered.

The availability of any Service depends on the applicable TransFi entity, Your jurisdiction, and applicable regulatory permissions. TransFi is not responsible for delays, errors, or failures caused by Third-Party Operators or regulatory restrictions.

6.2 When You submit an order or instruction through the Services, You authorise TransFi to process that order or instruction and to engage Third-Party Operators as necessary to execute, route, or settle the transaction. TransFi does not act as Your fiduciary, investment advisor, or broker, and does not provide investment advice or recommendations..

6.3 For each transaction You make using Our Services, you will be required to: (a) provide all relevant transaction information, including fiat currency, Digital Token type, transaction value, sender information, and recipient information; (b) provide fiat account information, which may include bank account, credit card, debit card, or other payment method details, such as identification numbers and associated details; (c) indicate whether you are making a one-time transaction; and (d) provide the relevant digital wallet address.

6.4 We charge a fee for using Our Services, which may be a percentage of the Digital Token purchase price or a fixed fee (the “Fee”). The applicable Fee will be displayed to You before You confirm the transaction.

6.5 While We may provide a price indication for the Digital Token being purchased, We do not control the entire transaction process. The final price may differ from the indicated price due to factors such as network fees, foreign exchange conversion rates, liquidity, or market fluctuations. You acknowledge and accept that the final transaction price may vary from any initial price indication.

DISCLAIMER: While TransFi strives to process payments within the estimated processing times, circumstances beyond Our reasonable control, such as banking system issues or regulatory checks, may cause delays. TransFi will use reasonable efforts to minimize such delays and keep You informed, but We will not be responsible for any resulting loss, delay, damages or inconvenience caused by events beyond Our control.

7. CANCELLATIONS AND REFUNDS

7.1 Except as expressly provided herein, all transactions are final once executed . However, transactions may be reversed, delayed, cancelled, or refunded where required by Applicable Law, payment network rules (including chargebacks or recalls), compliance checks, suspected fraud, sanctions screening, technical failures, or Third-Party Operator reversals.

7.2 Due to the volatile nature of Digital Token markets, orders cannot be recalled or retrieved under any circumstances once executed.

7.3 Upon delivery of the Digital Token to Your designated wallet or the fiat funds to Your designated account, TransFi's obligations to You are fully discharged, and You will have no further claim or right against TransFi related to that specific transaction.

7.4 Where we cancel or refund a transaction for compliance, fraud, or technical reasons, We may deduct fees and costs reasonably incurred (including Third-Party Operator fees) and will refund the remaining amount to the original source of funds where possible, or otherwise as required by Applicable Law.

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8. RESPONSIBILITIES AND OBLIGATIONS

8.1. END USER RESPONSIBILITIES AND OBLIGATIONS

You must ensure that by using TransFi's Services You accept and acknowledge to the following responsibilities:

• Accurate Information: Providing accurate, complete, and up-to-date information when using the Services.You must promptly update Your information if it changes.
  
  
• Compliance with Laws and Regulations: You must comply with all Applicable Laws and ensure that Your r use of Services does not involve or facilitate any illegal, unethical, or prohibited activities, including but not limited to money laundering, terrorist financing, sanctions evasion, or other criminal activity..
  
  
• Security and Confidentiality: You are responsible for maintaining the security and confidentiality of Your Account credentials and any other sensitive information related to Your transactions. You must not share Your login credentials or allow others to use Your Account.
  
  
• Transaction Validity: You must ensure that all transactions You initiate or receive through the Services are properly authorized,intended and accurately reflect the intended recipient, amount, and Digital Token or fiat currency.

• Notification Obligations: You must promptly notify TransFi if You become aware of any unauthorized access, suspicious activity, or errors affecting Your Account or transactions.
  
  
• Prohibited Activities: You must not:
  
  • Attempt to gain unauthorized access to TransFi systems, other users’ Accounts, or Third-Party Operator systems;
  • Interfere with the operation, security, or integrity of the Services;
  • Use the Services in violation of these Terms or any applicable regulatory or contractual restrictions.
• Responsibilities for Compliance: You must understand and comply with any legal obligations that apply to Your use of Services, including but not limited to Compliance Checks, AML/KYC requirements and any transaction limits imposed by TransFi or applicable regulators.

• Device and Software Security: You must ensure that any device, software, or network used to access the Services is secure, free from malware, and compatible with the Services.
  
  
• Cooperation with Compliance and Audits: You must cooperate with TransFi, regulators, or Customers in any investigations, audits, or compliance checks related to Your Account or transactions.
• Taxes and Reporting: You are solely responsible for any taxes, reporting obligations, or other governmental requirements arising from Your transactions using the Services.
• Acknowledgment of Risk: You acknowledge that Digital Token transactions carry inherent risks, including volatility, potential loss, network or blockchain failures, and reliance on Third-Party Operators. You accept these risks and are responsible for evaluating whether using the Services is appropriate for Your financial situation and risk tolerance.
• Additional Responsibilities: You must respond promptly to any communication or requests for information from TransFi, the Merchant, or the Customer regarding Your transactions or Account.

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9. OUR RIGHTS

We reserve the following rights, which are not obligations of TransFi:

(a) to modify, substitute, eliminate, or add to any of our Services where such changes are necessary due to legal, regulatory, security, or operational requirements, with reasonable notice provided to You where feasible;

(b) to suspend, restrict or terminate Your Account or accesses to the Services if You violate these Terms, Applicable Law or any compliance requirements, , or where required for regulatory, fraud-prevention, or security purposes; ;

(c) to monitor, review, modify, filter, disable, delete, and remove content, data or information associated with Your use of the Services, where necessary to protect the integrity, security, or lawful operation of the Services; t;

(d) to automatically update, patch or modify any software, systems or components used to Provide the Services ;

(e) to cooperate with any law enforcement, court, regulators or government investigation or order, or any Third Party Operator requesting or directing that You disclose information or content that You provide to Us

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10. CONDUCT

10.1 By way of example, and not as a limitation, You shall not:

(a) breach these Terms or any other terms and conditions, and any agreement incorporated by reference herein;

(b) violate any Applicable Law, statute, ordinance, or regulation;

(c) infringe any TransFi’s intellectual property (IP) or any third party’s copyright, patent, trademark, trade secret, or other intellectual property rights, or rights of publicity or privacy;

(d) create or maintain more than one Account for yourself without our express written authorization, including, but not limited to, using a name that is not your own, using a temporary email address or phone number, or providing any other falsified personal information;

(e) act in any way that is unlawful, libelous, defamatory, harassing, abusive, fraudulent, obscene, or otherwise objectionable (including, without limitation, displaying any content on our solution or APIs or using our Services to transmit content that contains any hate-related or violent content);

(f) provide false, inaccurate, or misleading information;

(g) send or receive Digital Tokens that could reasonably be believed (by us or by others) to have been potentially fraudulently acquired;

(h) use our Services or the services of our partners and/or customers in a manner that results in or may result in complaints, disputes, claims, reversals, Chargebacks, fees, fines, penalties, or losses to us or any of our partners;

(i) distribute or facilitate the distribution of viruses, worms, defects, Trojan horses, corrupted files, hoaxes, or any other items of a destructive or deceptive nature, or otherwise interfere with, circumvent, disable, or attempt to interfere with, circumvent, or disable the solution or APIs, or our Services, the proper working of the solution or APIs or our Services, security features of the solution or APIs, or our Services, or the equipment connected to the solution or APIs or our Services;

(j) take any action that may cause Us to lose any of the services from our internet service providers, payment processors, or other suppliers or Third Party Operators ;

(k) transmit or otherwise make available through our Services any unsolicited commercial messages (i.e., spam), junk mail, pyramid schemes, chain letters, or similar materials or information;

(l) interfere with other users enjoyment of our Services;

(m) exploit our Services for any unauthorized commercial purpose;

(n) reformat or frame any portion of the solution or APIs, or Services;

(o) use any robot, spider, site search/retrieval application, or other device to retrieve or index any portion of our solution or APIs or content on our Services, or to collect information about our Customers for any unauthorized purpose;

(p) use any metatags or any other “hidden text” using any of our marks;

(q) access or use our Services for the purpose of creating a product or service that is competitive with any of our products or services, including, without limitation, our Services; or

(r) engage in any other activity that we, at our sole discretion, deem to be harmful to TransFi, Our business, or Third Party Operators.

10.2 If You engage in any of the activities prohibited by Section 9.1, We may, at our sole and absolute discretion, without notice to you and without limiting any of our other rights or remedies at law or in equity, immediately suspend or terminate Your Account and/or prevent you from accessing our Services. If We prevent you from accessing our Services, you will be responsible for all losses, liabilities or obligations that result from or arising from Your use of the Services prior to or resulting from the prohibited conduct. . You are further prohibited from using the Services in any manner that is not expressly and unambiguously authorized under these Terms.

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11. TERMINATION

Subject to your compliance with these Terms and all Applicable Laws, You may terminate your acceptance of these Terms at any time by ceasing to be a End User with Us and discontinuing all access to and use of Our Services by sending us an email at compliance@transfi.com. We, at our sole discretion and for any reason or no reason, may terminate your acceptance of these Terms and suspend and/or terminate Your Account and access to all or any portion of Our Services, subject to Applicable Law. Any suspension or termination of Your access to your Account and/or our Services may be without prior notice, and We will not be liable to You or to any third party for any such suspension or termination. If we terminate these Terms or suspend or terminate your access to or use of Our Services due to Your breach of these Terms or any suspected fraudulent, abusive, or illegal activity, then termination of these Terms will be in addition to any other remedies We may have at law or in equity. Upon any termination or expiration of these Terms, whether by You or Us, you may no longer have access to information that You may have provided in connection with our Services or that is related to your Account, and You acknowledge that we will have no obligation to maintain any such information in Our databases or to forward any such information to You or to any third party.

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12. INTELLECTUAL PROPERTY OWNERSHIP

12.1 We retain all rights, title, and interest in all of our intellectual property, including, without limitation, inventions, ideas, concepts, code, discoveries, processes, marks, methods, software, visual interfaces, graphics, designs, systems, services, "look and feel," organization, compositions, formulae, techniques, information, and data (collectively, the "TransFi IP"). The TransFi IP is protected by copyright, trade dress, patent, and trademark laws, international conventions, and other relevant intellectual property and proprietary rights and applicable laws. You may not use any of the TransFi IP for any reason without our prior written consent. We reserve all rights in and to the TransFi IP not expressly granted to you in these Terms.

12.2 Subject to these Terms and any applicable Business Services Agreement:

1. You are granted a limited, revocable, non-exclusive licence to access and use the Services for Your own lawful use.
2. You agree not to remove, alter, or obscure any proprietary notices provided in or with the material on the Product or any other TransFi IP. You will not modify, alter, convert, adapt, clone, replicate, duplicate, copy, translate, reverse engineer, or otherwise manipulate any portion of our Services or the TransFi IP. All rights not expressly granted in these Terms are reserved.

12.3 You may choose to submit comments, bug reports, ideas, or other feedback about our Services, including, without limitation, suggestions for improving our Services (collectively, "Feedback"). By submitting any Feedback, You agree that we are free to use such Feedback at our discretion and without additional compensation to You and to disclose such Feedback to third parties (whether on a non-confidential basis or otherwise). If necessary under Applicable Law, You hereby grant Us a perpetual, irrevocable, non-exclusive, transferable, worldwide license under all rights necessary for us to incorporate and use Your Feedback for any purpose.

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13. THIRD-PARTY SERVICE OPERATORS

13.1 The Services, including the TransFi Wallet, may operate through or rely on Third Party Operators (including, without limitation, payment processors, exchanges, liquidity providers, and settlement agents). Third Party Operators may require you to agree to separate terms and conditions, which you must review and accept directly with them .You are responsible for complying with all applicable Third-Party Operator terms when using the Services. TransFi is not a party to any agreements between You and Third-Party Operators and does not control their actions, operations, products, services, or financial condition. Nothing in these Terms creates a contractual relationship between You and any Third-Party Operator. You acknowledge and agree that TransFi is solely responsible for the Services provided directly by TransFi and for maintenance and support of those Services only . Fees related to services offered by Third-Party Operators are governed by separate terms and conditions, as well as agreements between you and the respective Third Party Operator . You acknowledge that the use of such third-party services may involve settlement, technology, liquidity, operational, and counterparty risks which You accept

13.2 You expressly agree that TransFi shall not be responsible or liable for any delays, losses, or damages (including any loss of funds) arising from the acts, omissions, insolvency, liquidity issues, or bankruptcy of any Third Party Operators ,. Such risks are inherent in the use of Third-Party Operators and are accepted by You. Any such risks shall be borne solely by You.

13.3 TransFi provides no warranties with respect to services provided by Third-Party Operators. Any warranties applicable to third-party services are provided solely by the relevant Third-Party Operator, if at all.

13.4 Third-Party Service Providers are solely responsible for the Services they provide to You including, but not limited to: (a) product liability claims; (b) any claim that the services fail to conform to any applicable legal or regulatory requirement; (c) claims arising under consumer laws, privacy laws, or similar legislation; and (d) intellectual property claims. Such claims must be directed to the relevant Third-Party Operator, not to TransFi.

13.5 TransFi does not guarantee the availability, timeliness, or completion of any transaction or settlement executed through Third-Party Operators , and assumes no liability for any disruption, delay, or failure in settlement arising therefrom.

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15. PROMOTIONS AND REFERRALS

We may, from time to time, operate contests, promotions, referral programs, or other similar activities (“Promotions and Referrals”) that may require you to submit material or information about yourself. Any Promotions and Referrals may be governed by separate rules that may contain certain eligibility requirements, such as restrictions on age or geographic location. You are responsible for reading all applicable rules relating to the Promotions and Referrals to determine whether you are eligible to participate. If you enter or participate in any Promotions and Referrals, you agree to abide by and comply with all rules of the respective Promotions and Referrals. All Promotions and Referrals will be optional, and you should not enter or participate in such Promotions and Referrals if you do not agree to abide by and comply with all applicable rules.

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16. USER REPRESENTATIONS AND WARRANTIES

By using our Services, You represent and warrant that:

16.1 Authority. You have all requisite power and authority to execute and deliver these Terms, to purchase and use our Services, and to carry out and perform your obligations under these Terms. If you are an individual, you are at least eighteen (18) years old and of sufficient legal age and capacity to purchase and use our Services. If you are an entity, you are duly organized, validly existing, and in good standing under the laws of your domiciliary jurisdiction and each jurisdiction where you conduct business.

16.2 No Conflict. The execution, delivery, and performance of these Terms will not result in any violation of, be in conflict with, or constitute a material default under, with or without the passage of time or the giving of notice: (a) any provision of your governing documents, if applicable; (b) any provision of any judgment, decree, or order to which you are a party, by which you are bound, or to which any of your material assets are subject; (c) any material agreement, obligation, duty, or commitment to which you are a party or by which you are bound; or (d) any laws, regulations, or rules applicable to you.

16.3 No Consents or Approvals. The execution and delivery of, and performance under, these Terms require no approval or other action from any governmental authority or person other than You.

16.4 Lawful Purpose. You will use the Services solely for lawful purposes and in compliance with all Applicable Laws, including sanctions, anti-money laundering, counter-terrorist financing, tax, foreign exchange, and securities laws.

16.5 Sanctions Status. You are not located in, organized under the laws of, or ordinarily resident in any jurisdiction subject to comprehensive sanctions, nor are you listed on any sanctions or restricted-party list maintained by any governmental authority.

16.6 Source of Funds. All funds and Digital Assets used in connection with the Services are derived from lawful sources, and you are the legal and beneficial owner or are duly authorized to transact on behalf of the beneficial owner.

16.7 No Reliance / Risk Understanding. You understand the risks associated with Digital Assets, including volatility, loss of value, technology risks, and regulatory uncertainty, and you are not relying on TransFi for investment, legal, tax, or financial advice.

16.8 Accurate Information. All information you provide to TransFi is true, accurate, and complete, and you will promptly update such information as needed.

16.9 No Prohibited Activity. You are not using the Services on behalf of any person or entity engaged in illegal, fraudulent, deceptive, or prohibited activity.

16.10 Tax Responsibility. You are solely responsible for determining and fulfilling any tax obligations arising from your use of the Services.

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17. SANCTIONS

Your use of the Services is subject to all applicable export controls and economic sanctions laws and regulations (“Sanction Laws”) . By sending, buying, or selling Digital Tokens through the Services, You agree that you will comply with those Sanction Laws . You represent, warrant and undertake that you are not and will be not :

• located in, under the control of, or a national or resident in, or operating from, under the control of, or a national or resident of any jurisdiction subject to comprehensive economic sanctions or embargoes under Sanction Laws; or
• listed on, owned or controlled by, or acting on behalf of any person or entity listed on any sanctions-related restricted party list maintained by the United Nations, United States (including OFAC), the European Union, the United Kingdom, or any other relevant governmental authority;
• You further represent, warrant, and undertake that:
  
  • you will not use the Services, directly or indirectly, for the benefit of, or in connection with, any person, entity, or jurisdiction subject to Sanctions Laws;
  • you will not use the Services to conduct, facilitate, or support any transaction that could cause TransFi or any Third-Party Operator to violate Sanctions Laws;
• TransFi may monitor, screen, and restrict access to the Services at any time to comply with Sanctions Laws. TransFi may, where required by law or its compliance obligations, refuse to process, block, freeze, or reverse transactions, suspend or terminate your Account, or restrict access to the Services without prior notice.
• TransFi may request additional information or documentation at any time to verify your identity and compliance with this Section, and failure to provide such information may result in suspension or termination of the Services.

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18. RECOVERY OF LOSSES

TransFi reserves the right to deduct from your Account or any balances held with TransFi any financial losses suffered due to your initiation of a Chargeback procedure with your bank, financial institution, or any other party. These losses may include, but are not limited to, administration fees levied by the card acquirer and card schemes, as well as the monetary value of the Digital Tokens ordered or purchased.

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19. DISCLAIMERS

19.1 "AS IS" AND "AS AVAILABLE." YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOUR ACCESS TO AND USE OF OUR SERVICES IS AT YOUR SOLE RISK, AND THAT OUR SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, TRANSFI AND ITS MEMBERS, MANAGERS, OFFICERS, EMPLOYEES, ADVISORS, REPRESENTATIVES, AFFILIATES, AND AGENTS (THE "COMPANY PARTIES") MAKE NO EXPRESS WARRANTIES AND HEREBY DISCLAIM ALL IMPLIED WARRANTIES REGARDING OUR SERVICES AND ANY PART OF THEM (INCLUDING, WITHOUT LIMITATION, OUR SERVICES OR ANY EXTERNAL WEBSITES), INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, CORRECTNESS, ACCURACY, OR RELIABILITY. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, THE COMPANY PARTIES DO NOT REPRESENT OR WARRANT TO YOU THAT (A) YOUR ACCESS TO OR USE OF OUR SERVICES WILL MEET YOUR REQUIREMENTS, (B) YOUR ACCESS TO OR USE OF OUR SERVICES WILL BE UNINTERRUPTED, TIMELY, RISK-FREE, OR FREE FROM ERROR, (C) USAGE DATA PROVIDED THROUGH OUR SERVICES WILL BE ACCURATE, (D) OUR SERVICES OR ANY CONTENT, SERVICES, OR FEATURES MADE AVAILABLE ON OR THROUGH OUR SERVICES ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR (E) DATA WILL BE COMPLETELY SECURE OR IMMUNE FROM UNAUTHORIZED ACCESS.

19.2 PERSONAL RISKS. YOU ACCEPT THE INHERENT SECURITY RISKS OF PROVIDING INFORMATION AND DEALING ONLINE OVER THE INTERNET AND AGREE THAT WE HAVE NO LIABILITY OR RESPONSIBILITY FOR ANY BREACH OF SECURITY UNLESS IT IS DUE TO TRANSFI’S GROSS NEGLIGENCE. YOU WILL IMPLEMENT REASONABLE AND APPROPRIATE MEASURES DESIGNED TO SAFEGUARD ACCESS TO (A) ANY DEVICE ASSOCIATED WITH YOU AND UTILIZED IN CONNECTION WITH YOUR PURCHASE OR USE OF OUR SERVICES; AND (B) ANY OTHER USERNAME, PASSWORDS, OR OTHER LOGIN OR IDENTIFYING CREDENTIALS.

19.3 THIRD-PARTY OPERATORS DISCLAIMER. TRANSFI FACILITATES THE CREATION AND MANAGEMENT OF TRANSFI WALLET FOR USERS AND END USERS THROUGH THIRD-PARTY OPERATORS , WHO ARE SOLELY RESPONSIBLE FOR KEY MANAGEMENT, WALLET SECURITY, AND COMPLIANCE WITH APPLICABLE REGULATIONS RELATED TO WALLETS. TRANSFI IS NOT LIABLE FOR ANY LOSSES ARISING FROM WALLET SERVICES PROVIDED BY THIRD-PARTY SERVICE PROVIDERS, INCLUDING KEY MANAGEMENT FAILURES, AS THEY ARE SOLELY RESPONSIBLE FOR THE MANAGEMENT AND SECURITY OF THE TRANSFI WALLET. TRANSFI DISCLAIMS ALL LIABILITY FOR ANY LOSS, BREACH, OR FAILURE ARISING FROM THE THIRD-PARTY OPERATORS MANAGEMENT OF TRANSFI WALLET. TO THE MAXIMUM EXTENT PERMITTED BY LAW, TRANSFI IS NOT RESPONSIBLE FOR DELAYS, FAILURES, INSOLVENCY, CYBER INCIDENTS, OR OPERATIONAL ERRORS OF THIRD-PARTY PROVIDERS.

19.4 RISK DISCLOSURES, ASSUMPTION OF RISKS, AND RELEASE OF TRANSFI. OTHER THAN AS EXPRESSLY SET FORTH IN THIS AGREEMENT, TRANSFI SHALL NOT BE LIABLE FOR ANY RISKS INHERENT IN THE SERVICES OR RELATED TRANSACTIONS, INCLUDING WALLET TRANSACTIONS, THAT MAY BE INCURRED BY THE END USER OR THE CUSTOMER AND THEIR MERCHANTS AS A RESULT THEREOF. THE END USER, CUSTOMER, AND THEIR MERCHANT AGREE TO AND DO HEREBY: (I) RELEASE TRANSFI FROM ANY AND ALL LIABILITY RELATED TO OR ARISING FROM RISKS INHERENT IN THE SERVICES AND RELATED TRANSACTIONS, INCLUDING WALLET TRANSACTIONS, EXCEPT AS EXPRESSLY SET FORTH IN THIS AGREEMENT; AND (II) ASSUME ALL RISKS INHERENT IN THE SERVICES AND RELATED TRANSACTIONS, INCLUDING BUT NOT LIMITED TO THE FOLLOWING:

• THE RISK THAT ANY THIRD-PARTY SERVICE PROVIDERS OF TRANSFI CEASE TO OPERATE, RENDERING A TRANSACTION IMPOSSIBLE AND ENTIRELY WITHOUT USE.
• THE MARKET FOR DIGITAL TOKENS MAY COLLAPSE WITHOUT WARNING OR DISCERNIBLE LOGIC.
• THERE IS A RISK THAT CHANGES IN APPLICABLE LAW COULD ADVERSELY AFFECT THE CUSTOMER’S RIGHT TO LEGALLY USE, TRANSFER, EXCHANGE, AND/OR OBTAIN VALUE FROM DIGITAL TOKENS . IT MAY BE ILLEGAL, NOW OR IN THE FUTURE, TO OWN, HOLD, SELL, OR USE DIGITAL TOKENS IN ONE OR MORE COUNTRIES.
• TRANSACTIONS IN DIGITAL TOKENS ARE, AS A RULE, IRREVERSIBLE. CONSEQUENTLY, LOSSES DUE TO FRAUDULENT OR ACCIDENTAL TRANSACTIONS ARE GENERALLY NOT RECOVERABLE. ONCE A TRANSACTION HAS BEEN RECORDED ON THE APPROVED NETWORK, IT IS NOT REVERSIBLE. THE CUSTOMER ACKNOWLEDGES THAT IT IS POSSIBLE THAT, THROUGH COMPUTER OR HUMAN ERROR OR THROUGH THEFT OR FRAUD, DIGITAL TOKENS COULD BE TRANSFERRED IN INCORRECT AMOUNTS OR TO UNAUTHORIZED THIRD PARTIES.
• SOME TRANSACTIONS SHALL BE DEEMED TO BE MADE WHEN RECORDED ON THE APPROVED NETWORK, WHICH IS NOT NECESSARILY THE DATE OR TIME THAT THE CUSTOMER INITIATED THE TRANSACTION.
• DIGITAL TOKENS MAY BE TARGETS OF FRAUD AND CYBER-ATTACKS. ON DEVICES AND WALLETS, SUCH FRAUD AND ATTACKS CAN RESULT IN TOTAL LOSS TO THE CUSTOMER. IN THE WALLET, TRANSFI MAKES COMMERCIALLY REASONABLE EFFORTS TO VERIFY THAT THE CUSTOMER IS THE TRUE INITIATOR OF TRANSACTIONS, BUT WHERE THE CUSTOMER’S ACCOUNT IS COMPROMISED, SUCH EFFORTS MAY FAIL AND COULD RESULT IN TOTAL LOSS OF DIGITAL TOKENS IN THE WALLET. ATTACKS ON TRANSFI MAY ALSO RESULT IN UNPLANNED AND SIGNIFICANT UNSCHEDULED DOWNTIME DURING WHICH TRANSACTIONS WILL NOT BE EXECUTED. ABSENT FRAUD OR INTENTIONAL WRONGDOING ON THE PART OF TRANSFI, TRANSFI SHALL NOT BE LIABLE FOR CUSTOMER LOSSES ON ACCOUNT OF ANY OF THE FOREGOING CIRCUMSTANCES OR COMPROMISED ACCOUNT CREDENTIALS. AS A GOOD FAITH HOLDER OF DIGITAL TOKENS IN THE WALLET, THERE IS A RISK THAT THE CUSTOMER WILL LOSE POSSESSION THEREOF IF TRANSFI DETERMINES THAT IT WAS PREVIOUSLY TRANSFERRED BY FRAUDULENT MEANS OR TRANSFERRED OTHERWISE IN VIOLATION OF THIS AGREEMENT, EVEN IF THE CUSTOMER HAD NO PART IN THE WRONGDOING.
• THE SERVICES AND DIGITAL TOKENS RELY ON THE INTERNET, WHICH INCLUDES THIRD-PARTY HARDWARE, SOFTWARE, AND INTERNET CONNECTIONS, ALL OF WHICH MAY SUFFER COMMUNICATION FAILURES, DISRUPTIONS, ERRORS, DISTORTIONS, OR DELAYS THAT MIGHT AFFECT THE CUSTOMER’S ABILITY TO ACCESS AND USE SERVICES SUCH AS THE ACCOUNT AND WALLET.
• TRANSFI MAY FREEZE, BLOCK, DELAY, OR RESTRICT FUNDS OR ACCOUNTS IF REQUIRED BY LAW, COURT ORDER, OR REGULATORY INSTRUCTION, AND SHALL NOT BE LIABLE FOR RESULTING LOSSES OR DELAYS.

THE CUSTOMER SHALL ENSURE THAT ALL MERCHANTS AND END USERS CARRY OUT THEIR OWN INDEPENDENT ANALYSIS AND ASSESSMENT OF THE RISKS SPECIFIC TO THE SERVICES AND RELATED TRANSACTIONS.

19.5 LIMITATIONS ON THE SCOPE OF OUR SERVICES:

• OUR SERVICES DO NOT INCLUDE INVESTMENT ADVICE, PERSONAL RECOMMENDATIONS, OR ANY FORM OF GUIDANCE ON THE MERITS OR SUITABILITY OF ENGAGING IN ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE.
• WE DO NOT PROVIDE ANY REPRESENTATIONS, ASSURANCES, OR GUARANTEES AS TO THE SUITABILITY OR APPROPRIATENESS OF ANY OF OUR SERVICES FOR YOUR SPECIFIC NEEDS.
• YOU ARE SOLELY RESPONSIBLE FOR OBTAINING ANY LEGAL, ACCOUNTING, FINANCIAL, OR TAX ADVICE YOU MAY REQUIRE TO DETERMINE WHETHER ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE IS SUITABLE FOR YOUR REQUIREMENTS OR THE REQUIREMENTS OF YOUR BUSINESS.
• ANY INFORMATION PROVIDED TO YOU IN RELATION TO THIS AGREEMENT, INCLUDING BUT NOT LIMITED TO MARKET INFORMATION, RESEARCH FORECASTS, OR OTHER DATA SHARED WITH YOU REGARDING ANY PROPOSED TRANSACTION OR OTHERWISE, IS FOR INFORMATIONAL PURPOSES ONLY. SUCH INFORMATION IS NOT INTENDED TO BE RELIED UPON AS FINANCIAL OR PROFESSIONAL ADVICE FOR PLACING AN ORDER OR ENTERING INTO ANY FOREIGN EXCHANGE TRANSACTION OR SERVICE.
• INSOFAR AS IS PERMISSIBLE UNDER APPLICABLE LAWS AND REGULATIONS, TRANSFI DOES NOT OWE YOU ANY FIDUCIARY DUTY OR SIMILAR OBLIGATION UNDER THIS AGREEMENT.
• THE FOREIGN EXCHANGE RATES USED FOR THE PURPOSES OF PROVIDING THE SERVICES WILL BE DETERMINED BY TRANSFI AND MAY INCLUDE OUR COSTS, FEES, AND CHARGES. THESE RATES MAY DIFFER FROM PUBLISHED INTERBANK RATES OR OTHER PUBLICLY AVAILABLE BENCHMARKS.

19.6 CUSTOMER PLATFORM DISCLAIMER

TransFi’s role is as per the Services. TransFi does not provide, sponsor, endorse, operate, control, or assume responsibility for any products, services, or activities offered by any Customer.

TransFi is not a party to the underlying commercial, financial, gaming, trading, FX, CFD, or other service relationship between End User and any Customer. TransFi does not set the terms of those services, determine outcomes, hold itself out as the provider of such services, or assume any obligations relating to their performance.

TransFi does not control, supervise, or manage the Customer’s business operations, service delivery, customer onboarding, product design, trading decisions, gaming outcomes, pricing, or contractual commitments.

TransFi makes no representation or warranty regarding any Customer, including its identity, financial standing, solvency, licensing status, regulatory authorization, or legal compliance.

The End User acknowledges that TransFi does not provide advice or assurances regarding any Customer or its services and that any decision to engage with a Customer is made at the End User’s own risk.

Any disputes, complaints, claims, or refund requests relating to a Customer’s services must be addressed directly to the Customer by the End User. Fees, charges, pricing, or commissions relating to Customer services are determined solely by the Customer, even if processed through TransFi’s systems.

20. LIMITATION OF LIABILITY

20.1 YOU UNDERSTAND AND AGREE THAT TRANSFI WILL BE LIABLE TO YOU OR TO ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES THAT YOU MAY INCUR, HOWEVER CAUSED AND UNDER ANY THEORY OF LIABILITY, INCLUDING, WITHOUT LIMITATION, ANY LOSS OF PROFITS (WHETHER INCURRED DIRECTLY OR INDIRECTLY), LOSS OF GOODWILL OR BUSINESS REPUTATION, LOSS OF DATA, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR ANY OTHER INTANGIBLE LOSS, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

20.2 YOU UNDERSTAND AND AGREE THAT TRANSFI WILL NOT BE LIABLE AND DISCLAIMS ALL LIABILITY TO YOU IN CONNECTION WITH ANY FORCE MAJEURE EVENT, INCLUDING ACTS OF GOD; LABOR DISPUTES OR OTHER INDUSTRIAL DISTURBANCES; ELECTRICAL, TELECOMMUNICATIONS, HARDWARE, SOFTWARE, OR OTHER UTILITY FAILURES; SOFTWARE OR SMART CONTRACT BUGS OR WEAKNESSES; EARTHQUAKES, STORMS, OR OTHER NATURE-RELATED EVENTS; PANDEMICS; BLOCKAGES; EMBARGOES; RIOTS; ACTS OR ORDERS OF GOVERNMENT; ACTS OF TERRORISM OR WAR; TECHNOLOGICAL CHANGE; AND CHANGES IN INTEREST RATES OR OTHER MONETARY CONDITIONS.

20.3 YOU AGREE THAT OUR TOTAL, AGGREGATE LIABILITY TO YOU FOR ANY AND ALL CLAIMS ARISING OUT OF OR RELATING TO THESE TERMS, OR YOUR ACCESS TO OR USE OF (OR YOUR INABILITY TO ACCESS OR USE) ANY PORTION OF OUR SERVICES, WHETHER IN CONTRACT, TORT, STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, IS LIMITED TO THE GREATER OF (A) THE F FEES YOU PAID TO TRANSFI IN THE SIX (6) MONTH PERIOD PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED DOLLARS ($100), WHICHEVER IS LOWER.

20.4 YOU ACKNOWLEDGE AND AGREE THAT WE HAVE MADE OUR SERVICES AVAILABLE TO YOU AND YOU HAVE AT YOUR SOLE DISCRETION ENTERED INTO THESE TERMS IN RELIANCE UPON THE WARRANTY DISCLAIMERS AND LIMITATIONS OF LIABILITY SET FORTH HEREIN, WHICH REFLECT A REASONABLE AND FAIR ALLOCATION OF RISK BETWEEN THE PARTIES AND FORM AN ESSENTIAL BASIS OF THE BARGAIN BETWEEN TRANSFI AND YOU.

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21. NO RESPONSIBILITY FOR TRANSACTIONS WITH THIRD-PARTY OPERATORS

We are not responsible for any transaction between you and Third-Party Operators . If a Third-Party Operator fails to complete a purchase on Your behalf on time or in the correct amount, or if any loss occurs with respect to any transaction conducted through a Third-Party Operator we will not be liable for Your losses or damages.

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22. INDEMNIFICATION

To the fullest extent permitted by Applicable Law, you agree to indemnify, defend, and hold harmless and reimburse TransFi from and against any and all actions, proceedings, claims, damages, demands, and actions (including without limitation fees and expenses of counsel), incurred by a TransFi arising from or relating to:

(a) your use of the Product, Website, or our Services;

(b) your responsibilities or obligations under the Terms;

(c) your breach of or violation of the Terms;

(d) any inaccuracy in any of your representations or warranties;

(e) your violation of any rights of any other person or entity, including any proprietary or privacy rights;

(f) your violation of any Applicable law ; and/or

(g) any of your acts or omissions that are negligent, unlawful, or constitute willful misconduct.

TransFi reserves the right to exercise sole control over the defense, at your expense, of any claim subject to indemnification under this section 22. TransFi will notify you of any claim and you will cooperate.This indemnity is in addition to, and not in lieu of, any other indemnities set forth in a written Business Service Agreement between Customer and TransFi.

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23. GOVERNING LAW AND DISPUTE RESOLUTION

23.1 In the event of any dispute or claim between the Parties hereto arising from or relating to this Agreement, including any question regarding its existence, validity, or termination (a “Dispute”), then, the Parties shall first use good faith efforts to resolve it through negotiation by providing the other Party notice in writing describing the nature of the Dispute. Each Party will appoint a designated representative to endeavour to resolve such dispute. The designated representatives will be executives with sufficient authority to engage in good faith negotiations and bind the Party they represent.

If the designated representatives are unable to resolve the dispute within a reasonable period (but in no event more than thirty (30) days from the date of receipt of written request) after using their best efforts to do so, then the Dispute shall be finally resolved by binding arbitration. Any dispute, controversy, or claim arising out of or in connection with this Agreement, including any question regarding its existence, validity, interpretation, performance, breach, or termination, shall be referred to and finally resolved by arbitration under the Rules of the London Court of International Arbitration (LCIA), which Rules are deemed to be incorporated by reference into this clause.

The seat (legal place) of arbitration shall be London, England.
The tribunal shall consist of one arbitrator, unless the LCIA Court determines otherwise in accordance with the LCIA Rules.
The language of the arbitration shall be English.

The arbitration award shall be final and binding on the Parties and may be enforced in any court of competent jurisdiction

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24. EXTERNAL SITES

The solution or APIs or our Services may include hyperlinks or redirect you to other websites or resources (collectively, "External Sites") that are provided solely as a convenience to you. We have no control over any External Sites. You acknowledge and agree that we are not responsible for the availability of any External Sites and that we do not endorse any advertising, products, services, or other materials on or made available from any External Sites. Furthermore, you acknowledge and agree that we are not liable for any loss or damage that may be incurred as a result of the availability or unavailability of the External Sites or as a result of any reliance placed by you upon the completeness, accuracy, or existence of any advertising, products, services, or other materials on, or made available from, any External Sites.

25. ENTIRE AGREEMENT

These Terms, including the Privacy Policy, Business Services Agreement (where applicable) and any other terms and conditions referenced herein constitute the entire agreement between you and TransFi with respect to the subject matter hereof, including the Services. These Terms, including the Privacy Policy, supersede all prior or contemporaneous written and oral agreements, communication, and other understandings relating to the subject matter of the Terms. These Terms do not alter any agreement you may have with any Third Party Operators but shall supersede any such agreements in the event of a conflict between these Terms and any agreement with Third Party Operators s.

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26. DATA PROTECTION AND PRIVACY POLICY

Our Privacy Policy, which is incorporated herein by reference, describes how we collect, use, store, and disclose your personal information. You agree to the collection, use, storage, and disclosure of your data in accordance with the Privacy Policy. We are committed to keeping your personal information safe and processing it in accordance with applicable data protection legislation. Please review our Privacy Policy to understand how we use and protect the information you provide to us.

The End User acknowledges and agrees that TransFi may collect, access, process, store, and retain the End User’s profile information, account details, transactional data, and any other data relating to the End User (“End User Data”) for the purposes of providing, operating, monitoring, and improving its services, including for internal analytics, risk management, fraud prevention, and the development and offering of enhanced or targeted products and services. TransFi shall be entitled to retain End User Data for such period as it deems necessary to fulfil the purposes set out herein, including to comply with Applicable Laws, regulatory requirements, and its internal compliance and audit obligations.

Notwithstanding anything to the contrary, the End User expressly acknowledges and agrees that TransFi may, without further notice or consent, disclose, share, or transfer End User Data to any governmental, regulatory, supervisory, or judicial authority, law enforcement agency, or any financial institution, payment network, or other third-party service provider, where such disclosure is required or deemed necessary by TransFi to comply with Applicable Laws, regulation, legal process, or any request, order, or directive having the force of law.

The End User further consents to the use of End User Data, on an aggregated or individual basis, for internal analytics, research, and commercial purposes, including to optimize, personalize, and improve TransFi’s products, services, and user experience.

By accessing or using the Services, the End User provides informed, explicit, and unconditional consent to the collection, use, retention, and disclosure of End User Data in accordance with this Clause.

27. CONTACT INFORMATION

If you have any feedback, questions, or complaints, you may contact us via our help center on our website or at compliance@transfi.com.

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Annexure A - List of TransFi Entities

This list is indicative only and may be updated without notice

Trans-Fi Inc.

TransFi UAB

Neomoney INC.

TransFi PTE. LTD.

TransFi Technology LLC

TransFi Innovation Limited

Trans-Fi India Private Limited

TransFi Bahamas Limited

Pt. TransFi Indonesia Merdeka

TransFi Digital Limited

TRANSFI VIRTUAL ASSETS SOLUTIONS FZCO

TRANSFI AUSTRALIA PTY LTD

MAXSERVICE24 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

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