Consumer Terms of Service

Overview of Services

1.1 Technology Platform

Paymenture provides software and technology services that facilitate access to financial services offered by regulated third-party financial institutions, sponsor banks, card issuers, payment processors, virtual asset service providers ("VASPs"), and other service providers ("Service Providers").

Paymenture itself is not a bank unless expressly stated otherwise.

1.2 Third-Party Services

Certain Consumer Services are provided by third-party Service Providers subject to their own:

• disclosures;
• cardholder agreements;
• deposit agreements;
• wallet terms;
• privacy policies; and
• regulatory requirements.

You may be required to accept additional agreements before accessing certain Consumer Services.

1.3 No Guarantee of Availability

Consumer Services may not be available in all jurisdictions or to all users.

Paymenture may add, modify, suspend, restrict, or discontinue Consumer Services at any time.

Eligibility & Account Registration

2.1 Eligibility

To use the Consumer Services, you must:

• be at least 18 years old;
• have legal capacity to enter into agreements;
• not be prohibited from using the Services under applicable law;
• not be located in a prohibited jurisdiction; and
• successfully complete required onboarding and verification

procedures.

2.2 Account Registration

You agree to provide:

• accurate;
• complete; and
• current

information during onboarding and throughout your use of the Consumer Services.

You are responsible for maintaining the security and confidentiality of your account credentials.

2.3 Identity Verification

Paymenture and its Service Providers may require:

• identity verification;
• sanctions screening;
• biometric verification;
• liveness checks;
• wallet ownership verification;
• enhanced due diligence; and
• ongoing compliance reviews.

Failure to provide requested information may result in delayed access, restricted functionality, or account termination.

Digital Asset Services

3.1 Digital Asset Terms

Access to any cryptocurrency, stablecoin, blockchain, wallet, exchange, or digital asset-related functionality is subject to the Paymenture Digital Asset & Blockchain Terms.

3.2 Blockchain Risks

You acknowledge that blockchain transactions:

• may be irreversible;
• may be delayed;
• may fail;
• may be affected by network congestion;
• may be affected by forks;
• may involve substantial volatility; and
• may expose you to loss of digital assets.

3.3 Restricted Activity

You may not use the Consumer Services in connection with:

• mixers or tumblers;
• sanctioned wallets;
• unlawful blockchain activity;
• darknet marketplaces;
• fraud;
• ransomware;
• sanctions evasion; or
• prohibited digital asset activity.

Paymenture and its Service Providers may utilize blockchain analytics and transaction monitoring technologies.

Cards, Wallets & Virtual Accounts

4.1 Card Services

Card products may be issued by third-party issuing banks or licensed issuers.

Use of card products may be subject to separate:

• cardholder agreements;
• network rules;
• disclosures; and
• regulatory requirements.

4.2 Wallets & Virtual Accounts

Wallets, virtual accounts, or account balances may be provided by regulated third-party Service Providers.

Availability, functionality, and protections applicable to wallets or accounts may vary by jurisdiction and provider.

4.3 No FDIC Insurance Unless Expressly Disclosed

Funds or digital assets accessible through the Consumer Services are not deposits and are not insured by the FDIC unless expressly stated otherwise in writing by the applicable Service Provider.

Compliance, Monitoring & Account Restrictions

5.1 Compliance Monitoring

Paymenture and its Service Providers may monitor:

• account activity;
• transaction activity;
• blockchain activity;
• wallet interactions;
• counterparties;
• device information;
• login activity; and
• behavioral indicators.

5.2 Compliance Authority

Paymenture reserves the right, at its sole discretion or at the direction of any Service Provider, regulator, banking partner, card network, sanctions authority, or law enforcement agency, to:

• reject transactions;
• delay or reverse transactions where permitted;
• freeze or restrict assets;
• place holds or reserves on accounts;
• request additional information;
• restrict functionality;
• suspend Services;
• terminate accounts; or
• prohibit access to certain jurisdictions, counterparties, wallets,

protocols, or activities.

5.3 Fraud Prevention

Paymenture may conduct fraud prevention and cybersecurity monitoring activities including:

• device analysis;
• IP analysis;
• behavioral monitoring;
• transaction analysis;
• credential abuse monitoring; and
• suspicious activity detection.

Fees & Transactions

6.1 Fees

You agree to pay applicable:

• transaction fees;
• blockchain fees;
• network fees;
• FX fees;
• wallet fees;
• card fees; and
• other disclosed fees.

Applicable fees may be disclosed:

• within the platform;
• in product-specific disclosures;
• in cardholder agreements; or
• at the time of the transaction.

6.2 Transaction Finality

Certain transactions, including blockchain transactions, may be irreversible once submitted or confirmed.

6.3 Transaction Delays

Transactions may be delayed, restricted, or canceled due to:

• compliance reviews;
• fraud investigations;
• sanctions screening;
• blockchain congestion;
• Service Provider outages;
• network interruptions; or
• operational requirements.

Privacy & Data Use

Use of the Consumer Services is subject to the Paymenture Privacy Policy.

You acknowledge that Paymenture and its Service Providers may:

• collect and process personal information;
• conduct identity verification;
• conduct sanctions screening;
• conduct blockchain analytics;
• cooperate with regulators and law enforcement; and
• disclose information where required by law.

Prohibited Use

You may not use the Consumer Services in connection with:

• unlawful activity;
• fraud;
• sanctions evasion;
• money laundering;
• deceptive conduct;
• prohibited blockchain activity;
• prohibited gambling;
• counterfeit goods;
• prohibited weapons;
• identity theft;
• account misuse; or
• any activity prohibited by Paymenture policies.

Additional restrictions are set forth in the Acceptable Use Policy and Digital Asset & Blockchain Terms.

Suspension & Termination

Paymenture may suspend or terminate your access to the Consumer Services immediately where:

• required by law;
• required by Service Providers;
• suspicious activity is detected;
• sanctions concerns arise;
• fraud risk exists;
• Paymenture determines unacceptable risk exists; or
• you violate these Consumer Terms or incorporated policies.

Paymenture may maintain freezes, reserves, restrictions, or delayed settlement after termination where reasonably necessary to:

• comply with law;
• complete investigations;
• comply with sanctions obligations;
• manage disputes; or
• protect Paymenture and its Service Providers.

Disclaimers & Limitation of Liability

10.1 No Warranty

THE CONSUMER SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE." PAYMENTURE DISCLAIMS ALL WARRANTIES TO THE MAXIMUM EXTENT PERMITTED BY LAW.

10.2 Third-Party Dependency Disclaimer

Paymenture is not responsible for delays, failures, interruptions, or restrictions caused by:

• banks;
• card issuers;
• blockchain networks;
• Service Providers;
• payment networks;
• sanctions actions;
• regulatory actions;
• network congestion;
• stablecoin depegging;
• cyberattacks; or
• force majeure events.

10.3 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, PAYMENTURE SHALL NOT BE LIABLE FOR:

• INDIRECT DAMAGES;
• CONSEQUENTIAL DAMAGES;
• LOSS OF PROFITS;
• LOSS OF DIGITAL ASSETS;
• NETWORK FAILURES;
• MARKET VOLATILITY; OR
• THIRD-PARTY ACTIONS.

Nothing in these Consumer Terms limits rights that cannot be waived under applicable consumer protection laws.

Dispute Resolution

Any dispute arising from these Consumer Terms or the Consumer Services shall be resolved in accordance with applicable law and any arbitration or dispute resolution provisions separately provided by Paymenture or applicable Service Providers.

Certain consumer rights may vary by jurisdiction and cannot be waived.

Changes to These Terms

Paymenture may modify these Consumer Terms from time to time to:

• comply with law;
• comply with regulatory obligations;
• address emerging risks;
• improve Services; or
• reflect operational changes.

Updated versions will be posted on the Paymenture website.

Continued use of the Consumer Services constitutes acceptance of the updated Consumer Terms.