TERMS OF USE

BRIEF SUMMARY

These Terms govern access to and use of the Neocex platform. The Platform is intended for transactions in Virtual Assets by individual users and for internal ledger accounting of their balances. The Operator is registered with the National Commission of Digital Assets of El Salvador (CNAD) under registry entry PSAD-0038 and applies a risk-based compliance approach, including KYC, AML/CFT, KYT and sanctions screening. The Platform does not accept or pay out fiat money, does not offer peer-to-peer trading, does not extend credit and does not support bitcoin.

Contacts: legal notices - [email protected]; support - [email protected]. [TO CONFIRM: mailboxes]

PART I. GENERAL PROVISIONS

1. Parties and Subject Matter

1.1. These Terms of Use (the "Terms") govern access to and use of the platform available at neocex.com and related services, including the web interface, the public API and other interfaces where applicable (the "Platform").

1.2. Platform Operator: Boulder Tech, Sociedad por Acciones Simplificada de Capital Variable, abbreviated Boulder Tech, S.A.S. de C.V. Tax identification number (NIT) 0528-281024-101-6. Registered with the Registro de Comercio of the Republic of El Salvador under entry No. 981, Book 4904, on 28 October 2024. Registered address: 7 Calle Oriente, Poligono 2, Urbanizacion Santa Monica, No. 1, Distrito de Santa Tecla, Municipio de La Libertad Sur, Departamento de La Libertad, Republic of El Salvador. Legal representative: the sole administrator, Ruslans Grabaruks (the "Operator", the "Company").

1.3. The Operator is a digital asset service provider registered with the National Commission of Digital Assets (Comision Nacional de Activos Digitales, CNAD) under registry entry No. PSAD-0038, granted by Resolution CNAD-CD-001-2025 of 6 January 2025 under the Digital Asset Issuance Law (Ley de Emision de Activos Digitales, LEAD). The activities available on the Platform are limited to those authorised under the registry entry as in force from time to time. Where a feature depends on an authorisation that has not yet been granted, the feature is not made available to Users.

1.4. "User" means a natural person who has created an Account on the Platform or who uses the Platform without registration to the extent permitted by its functionality. The Platform does not onboard legal entities.

1.5. The Operator provides custody, exchange, transfer and settlement services related to Virtual Assets through the Platform, and operates the order book on which Users' orders are matched, subject to Clause 1.3.

1.6. Nothing in these Terms creates between the Parties any relationship of agency, partnership, joint venture, employment or trust management.

2. Acceptance, Electronic Form and Amendments

2.1. The User accepts these Terms by (a) registering an Account, (b) confirming consent in the interface, or (c) actual use of the Platform, including deposits and withdrawals of assets, placing orders or using the API.

2.2. Electronic acceptance of these Terms and actions performed on the Platform are equivalent to written form to the maximum extent permitted by applicable law.

2.3. The Operator may amend these Terms and the documents incorporated by reference (the Privacy Policy, the Risk Warning, the AML Policy, the Fee Schedule and the Acceptable Use Policy). A new version enters into force upon publication on the Platform unless the text specifies a later date. Material changes to fees are announced at least 7 calendar days in advance.

2.4. Continued use of the Platform after publication constitutes consent to the new version. A User who disagrees must stop using the Platform and close the Account, subject to compliance requirements and completion of outstanding obligations.

3. Definitions

Account: a User's account on the Platform.

Authentication: verification of access by password, two-factor authentication (2FA), trusted devices and similar means.

Virtual Assets / Digital Assets: crypto-assets (tokens, coins and other digital units) transactions in which are available on the Platform. Bitcoin is not a supported asset.

Internal Ledger: the Platform's records of the User's balances, rights and obligations.

Omnibus Custody: a custody model where Users' assets may be held at shared addresses and allocated through the Internal Ledger.

On-chain: data recorded on the relevant blockchain.

Off-chain: Platform data (internal journals, statements, logs, notifications).

KYC: identification and verification of the User.

AML/CFT: anti-money laundering and counter-terrorist financing measures.

KYT: monitoring and analysis of blockchain transactions, including address scoring.

Sanctions: international sanctions regimes applicable to the Operator or its counterparties.

Restricted Jurisdiction: a country or territory the servicing of which the Operator restricts or prohibits (Appendix E).

Prohibited Person: a person subject to sanctions or restrictions, or a person using the Platform for prohibited purposes.

Fees: payments charged by the Operator or third parties for services, including network fees.

Derivatives: USDT-margined perpetual futures contracts, available only after the corresponding authorisation is granted and only to Users who meet the requirements of Section 20.

Force Majeure: events beyond the Operator's reasonable control (Section 30).

3.2. In case of discrepancy between translations, the English version prevails.

4. Legal Status of the Platform and Nature of Services

4.1. The Platform is a digital asset service infrastructure operated by the Company for custody, exchange, transfer, settlement and internal accounting of Virtual Assets.

4.2. The Operator is not a bank, does not open bank accounts, does not conduct banking operations and does not guarantee deposit insurance of assets.

4.3. The Operator is not an investment adviser, does not provide personalised investment recommendations, does not guarantee returns and does not act as a fiduciary of the User.

4.4. No information on the Platform constitutes investment, legal, tax or other professional advice.

4.5. The Operator may engage third parties for certain functions, including identity verification, blockchain analytics, infrastructure and liquidity. The order book on which Users' orders are matched is shared with the Operator's technology partner, so that Users' orders may be matched against orders placed on a related venue. Such arrangements are disclosed in the Operator's Outsourcing and Third-Party Management Policy. The User agrees that some functions may depend on such third parties.

4.6. The Operator may change Platform functionality, suspend features, introduce limits and fees, and set access requirements.

PART II. ELIGIBILITY, ACCOUNT AND SECURITY

5. Eligibility, Age and Jurisdictional Restrictions

5.1. The User confirms that they are at least 18 years of age, have reached the age of majority in their jurisdiction and have full legal capacity to accept these Terms and to transact in Virtual Assets.

5.2. The Operator does not provide services to residents of, or persons located in, Restricted Jurisdictions listed in Appendix E. The Operator may change the list at any time.

5.3. The User is responsible for assessing the legality of using the Platform in their jurisdiction and for compliance with applicable law, including currency control, tax, sanctions and other regulations.

5.4. The Operator applies geo-blocking, IP and device restrictions, citizenship and residency restrictions and other access control measures.

5.5. The User must not use VPN, proxy or other methods to bypass access restrictions set by the Operator. Circumvention is a material breach of these Terms.

5.6. The Operator may refuse service to persons who, in the Operator's opinion, pose an unacceptable risk (sanctions, reputational, legal, fraud or other).

6. Registration, Data Accuracy and Security

6.1. To access the core functionality of the Platform the User creates an Account with an email address and a password and provides accurate, complete and current information. The User keeps such information current.

6.2. The User keeps confidential their login, password, 2FA codes, access to email and other authentication means.

6.3. Two-factor authentication is mandatory before the first deposit and before the first order. The Operator may require additional confirmations and restrict functionality until security requirements are met.

6.4. All actions performed using the User's credentials are deemed performed by the User unless the Operator determines otherwise.

6.5. The User immediately notifies the Operator of any suspected compromise of the Account. The Operator may apply emergency blocking and additional checks.

6.6. The User is responsible for the security of their own devices, software and communication channels. The Operator is not responsible for damage caused by malware, SIM swap, email compromise or other actions of third parties where the Operator applied reasonable security measures.

6.7. The Operator may implement additional security mechanisms, including device analysis, geolocation, behavioural factors, withdrawal address whitelists and session controls. The User can view active sessions and terminate them in the Account.

7. API Access

7.1. The Operator may provide API access subject to additional terms (Appendix C), limits, access keys and security requirements.

7.2. The User keeps API keys confidential, does not transfer them to third parties and implements security measures (key rotation, least privilege, IP whitelist).

7.3. The Operator may limit request frequency, disable the API in case of suspected abuse and change API specifications with notice published in the documentation.

7.4. The Operator is not liable for losses arising from incorrect integration by the User, coding errors, third-party libraries or compromise of API keys.

PART III. KYC, AML/CFT, SANCTIONS AND COMPLIANCE

8. General Compliance Principles

8.1. The Operator applies a risk-based AML/CFT approach in accordance with the LEAD, the regulations issued by CNAD, the anti-money laundering legislation of the Republic of El Salvador and the FATF Recommendations, as set out in the AML Policy published on the Platform.

8.2. The Operator monitors transactions, including KYT checks based on blockchain data, behavioural scoring and device monitoring.

8.3. The Operator may require documents and explanations confirming identity, address, source of funds and source of wealth, and proof of ownership of assets.

8.4. The Operator may restrict functionality until requested data is received. Failure to provide documents or provision of inaccurate information is grounds to refuse services, freeze assets and close the Account.

8.5. The Operator applies Travel Rule measures where applicable and may exchange required information with other virtual asset service providers.

8.6. Compliance checks may delay the processing of transactions and withdrawals.

9. Identification (KYC) and Access Levels

9.1. The Operator applies the following verification levels. Limits are published on the Platform and may be changed.

9.2. The Operator may conduct re-verification at any time, including requesting additional documents, selfie or video verification, proof of address and confirmation of control over contacts and devices.

9.3. The Operator may refuse verification or reduce the User's access level without stating reasons where necessary for compliance.

10. Sanctions, Prohibitions and Refusal of Service

10.1. The User represents and warrants that they are not a Prohibited Person and do not act on behalf of a Prohibited Person.

10.2. The Operator may refuse or restrict services without stating reasons where necessary to comply with sanctions, AML/CFT requirements, counterparty requirements or risk assessment.

10.3. The Operator applies sanctions and geographic screening, including through third-party databases, and assesses links between transactions and sanctioned or high-risk addresses.

10.4. The User does not attempt to circumvent sanctions or restrictions, including through transaction splitting, intermediaries, mixers or high-risk services.

10.5. The Operator may require confirmation that transactions are performed in the User's own interest and for the User's own account.

10.6. The Operator may apply compliance measures to linked accounts, devices, IP addresses and other identifiers.

11. Freezing, Holds, Reversals and Response Measures

11.1. Where there are signs of violations, sanctions exposure or criminal risk, the Operator may restrict functionality, suspend transactions, freeze assets and hold them until completion of checks.

11.2. The Operator may adjust the Internal Ledger upon detection of errors, technical failures, abuse, fraud, manipulation or other violations.

11.3. The Operator may cancel or review transactions and trades if (a) the transaction occurred due to a system error, (b) signs of compromise are detected, (c) the transaction violates these Terms, (d) a mandatory request from a competent authority is received, or (e) the assets are linked to high-risk sources.

11.4. The Operator cooperates with competent authorities, including CNAD and the Financial Investigation Unit of El Salvador (Unidad de Investigacion Financiera, UIF), within applicable law and the Privacy Policy.

11.5. Compliance decisions may be taken without disclosure of specific reasons where disclosure would harm an investigation, breach legal or counterparty requirements or create security risks.

11.6. Where assets are credited in error, the Operator may take corrective action, including debiting the erroneously credited amount, to the extent permitted by applicable law.

PART IV. ASSET ACCOUNTING, CUSTODY AND TECHNICAL OPERATIONS

12. Internal Accounting and Evidence

12.1. The Operator maintains internal accounting of Users' balances. Internal Ledger records are primary for determining the User's rights on the Platform unless mandatory provisions of applicable law provide otherwise.

12.2. On-chain data (transaction hashes, addresses, signatures) and off-chain confirmations (Account statements, notifications, logs) may be used by the Parties as evidence in disputes.

12.3. In case of discrepancy between the display of a transaction in the interface and its confirmation on the blockchain, the final state is determined by the Operator's reconciliation, taking into account network rules, compliance restrictions and internal logs.

12.4. Transactions may be aggregated (batched) and routed through technical paths that do not match the addresses displayed in the interface.

13. Omnibus Custody

13.1. Virtual Assets are stored under an omnibus model, including hot and cold storage. The majority of client assets are held in cold storage. Client assets are recorded separately from the Operator's own funds in accordance with the Client Asset Segregation and Proof of Reserves Policy.

13.2. The User does not hold title to specific coins or UTXOs at a specific address; the User's right is a claim against the Operator for delivery of an equivalent amount of assets, subject to Fees and compliance checks.

13.3. The Operator may perform batching, use shared addresses, change transfer routing and perform internal transfers for security and operational efficiency, and may change its custody infrastructure (wallet structure, multi-signature setup, key management) at its discretion.

13.4. Custody of Virtual Assets involves risks including cyberattacks, protocol errors, forks and insolvency of counterparties; see the Risk Warning.

13.5. In the event of insolvency of an infrastructure provider, access to assets may be restricted; the Operator uses reasonable efforts to protect Users' interests but does not guarantee the outcome.

14. Deposits and Withdrawals of Virtual Assets

14.1. Deposits are made by sending assets to an address, memo or tag specified by the Platform. Blockchain transfer is the only funding method. The Operator does not accept cash, bank transfers, payment cards or top-up codes. The User is responsible for the correct network, address and transfer parameters.

14.2. The Platform requires a minimum number of network confirmations. Until the threshold is reached, assets are shown as pending and are unavailable for transactions.

14.3. Every deposit is screened by the Operator's blockchain analytics provider before it is credited. A deposit whose risk score exceeds the Operator's threshold is held for review by a compliance analyst; the User is informed that the deposit is under review.

14.4. Withdrawals are made to the User's address provided that (i) the balance is sufficient, (ii) Fees are paid, (iii) the User's verification level permits the amount, (iv) the destination address has passed screening, and (v) no restrictions or freezes apply.

14.5. The User verifies compatibility of the address with the network and token standard. Sending to the wrong network or address may result in irreversible loss.

14.6. The Operator may suspend deposits and withdrawals in case of Force Majeure, network failures, hard forks, elevated security risk, investigations, regulator demands or provider demands.

14.7. The Operator may set minimum amounts, limits, delays, whitelist requirements and other security conditions.

14.8. The Operator may refuse to process a withdrawal if the destination address or a related transaction is, in the Operator's opinion, associated with high risk (sanctions, fraud, stolen funds or similar).

15. Network Fees, Forks and Airdrops

15.1. Network fees are set by the blockchain network and may change. The Operator passes network fees through at cost and may charge a processing fee published in the Fee Schedule.

15.2. The Operator does not guarantee support for forks, airdrops, token migrations or protocol upgrades. Support is at the Operator's discretion taking into account security and compliance.

15.3. In case of a fork or airdrop, the Operator may (a) not support the new asset, (b) credit the asset in whole or in part, (c) set conditions for receipt, or (d) determine processing timeframes.

15.4. The Operator may suspend operations for an asset in case of suspected protocol vulnerability, attacks, chain reorganisations, lack of liquidity or sanctions risk.

PART V. TRADING, LISTING AND MARKET INTEGRITY

16. Trading Features

16.1. The Platform provides an order book for spot trading of Virtual Assets against USDT and USDC, and, subject to Section 20, Derivatives.

16.2. Availability of features depends on region, verification level, limits, technical condition and compliance assessment.

16.3. The Operator may introduce trading restrictions (minimum order sizes, tick sizes, limits on cancellation frequency, measures to ensure market integrity).

17. Orders, Execution and Obvious Errors

17.1. The Platform supports market, limit and stop-limit orders. Specific order types and parameters are described in the interface and documentation.

17.2. The order ticket displays the Fee and, for market orders, the estimated execution price including slippage across the order book, before the order is submitted. Where market data is stale or the connection is degraded, the terminal displays the condition and blocks order submission.

17.3. The User is responsible for the correctness of order parameters. Placing an order does not guarantee execution.

17.4. The Operator does not guarantee best price, absence of slippage, continuity of quotes or availability of a specific trading pair.

17.5. In case of an obvious quote error, technical failure, manipulation or other anomaly, the Operator may cancel or adjust trades and restore the correct account state in accordance with the Market Conduct and Order Handling Policy.

17.6. In case of partial execution, the remainder stays in the order book or is cancelled depending on order type and settings.

17.7. The Operator may cancel orders and restrict trading in emergencies (matching engine issues, suspected attack, incorrect data).

18. Listing and Delisting

18.1. Listing and delisting decisions are taken under the Operator's Asset Listing Policy on the basis of legal character of the asset in El Salvador and in the markets served, liquidity, network security and blockchain analytics exposure. Listing requires the approval of the Compliance Officer and the administrator.

18.2. The Operator may suspend trading, deposits and withdrawals for an asset at any time to protect Users, comply with law, remediate vulnerabilities or control sanctions risk.

18.3. Upon delisting the Operator sets a withdrawal period of at least 30 calendar days unless a shorter period is required by law or by a compliance decision. After the period the Operator may disable withdrawals of the asset or apply other measures.

19. Market Integrity and Prohibition of Manipulation

19.1. Market manipulation is prohibited, including wash trading, spoofing, layering, pump-and-dump, use of insider information and other abuses.

19.2. The Operator uses market surveillance, investigates suspicious activity, restricts trading and voids trades upon detection of violations.

19.3. The Operator may impose measures (higher fees, API restrictions, cancellation restrictions) to protect market integrity.

20. Derivatives

20.1. Derivatives are made available only after the Operator obtains the authorisation required under Article 19 literals f.3) and f.4) LEAD. Until then no Derivatives feature is offered and no statement on the Platform is to be read as an offer of Derivatives.

20.2. Access to Derivatives requires all of the following: (a) Advanced verification level, (b) a passed knowledge test on leverage, margin, liquidation and funding, and (c) acceptance of the Derivatives risk disclosure.

20.3. Leverage is limited to 20x. The User selects the margin mode (isolated or cross) and leverage before opening a position. The estimated liquidation price is displayed before the position is opened.

20.4. Open positions display unrealised profit and loss, margin and liquidation price in real time. The Operator notifies the User when the margin approaches the maintenance level and upon liquidation, stating the price, the loss and the Fees applied.

20.5. Funding is paid between Users holding opposite positions at the intervals published on the Platform. The Operator does not retain funding.

20.6. The Operator may reduce leverage, restrict new positions or close positions in the circumstances set out in the Market Conduct and Order Handling Policy, including extreme volatility, illiquidity or a compliance decision.

PART VI. FEES, PROHIBITED USE, DATA AND LIABILITY

21. Fees, Limits and Taxes

21.1. Trading fees, withdrawal fees, network fees and limits are published in the Fee Schedule (Appendix A) and may vary by verification level and product. Fees are deducted at the moment of execution and recorded in the User's history.

21.2. The Operator may change fees and limits. Changes are announced at least 7 calendar days in advance unless an immediate change is required for security or compliance.

21.3. The User is responsible for taxes and duties applicable to their transactions and obtains professional advice independently.

21.4. Where tax withholding or reporting obligations arise, the Operator acts in accordance with applicable law.

22. Prohibited Activities and Acceptable Use

22.1. The User does not use the Platform for illegal activity, sanctions violations, AML violations, fraud, market manipulation or to harm the Operator or third parties. The Acceptable Use Policy (Appendix B) forms part of these Terms.

22.2. Upon violation the Operator may block the Account, freeze assets, cancel transactions, notify authorities and recover damages.

23. Intellectual Property

23.1. The Platform, its software, design, databases, trademarks and other elements belong to the Operator or its licensors.

23.2. The User is granted a limited, non-exclusive, revocable licence to use the Platform for its intended purpose. Any other use requires the Operator's written consent.

23.3. The User does not decompile, reverse engineer, extract source code, circumvent technical limitations or create derivative products based on the Platform, except as expressly permitted by law.

24. Personal Data and Confidentiality

24.1. Personal data is processed in accordance with the Privacy Policy published on the Platform and applicable law.

24.2. Data may be transferred to identity verification providers, blockchain analytics providers, hosting providers, the Operator's technology partner and competent authorities in the cases provided by law and the Privacy Policy.

25. Risks and Disclaimer of Warranties

25.1. Transactions in Virtual Assets involve high risk. The Risk Warning is an integral part of these Terms.

25.2. The Platform is provided "as is" and "as available". The Operator gives no warranty of uninterrupted operation, accuracy of information, fitness for a particular purpose or absence of errors.

26. Limitation of Liability

26.1. The Operator is not liable for losses from volatility, erroneous transfers by the User, Account compromise due to the User's fault, or actions of third parties outside the Operator's control.

26.2. To the maximum extent permitted by applicable law, the Operator is not liable for indirect damages, lost profits, loss of data, reputational harm or other consequential losses.

26.3. The Operator's aggregate liability for any claims arising in a 12-month period is limited to the total Fees paid by the User to the Operator in that period, unless prohibited by applicable law.

26.4. Nothing in these Terms limits liability to the extent it cannot be limited under applicable law, including liability for the Operator's fraud or wilful misconduct.

27. Indemnity

27.1. The User indemnifies the Operator for losses, fines, expenses and third-party claims arising from (i) breach of these Terms, (ii) violation of law or sanctions, (iii) use of the Platform for illegal purposes, or (iv) infringement of third-party rights.

28. Termination and Account Closure

28.1. The User may close the Account subject to completion of obligations, completion of necessary checks and withdrawal of available assets.

28.2. The Operator may restrict or close the Account in case of breach of these Terms, AML risk, legal requirements, security threats or other compliance grounds.

28.3. Upon Account closure the Operator sets the procedure for withdrawal of available assets where permissible and not prohibited by a compliance decision.

28.4. Certain assets may remain frozen until completion of an investigation or fulfilment of mandatory authority requirements.

28.5. If the Operator ceases operations, client assets are returned in accordance with the Wind-Down Plan filed with CNAD.

29. Governing Law and Dispute Resolution

29.1. These Terms are governed by the law of the Republic of El Salvador.

29.2. Pre-trial procedure: a claim is sent to [email protected]. Response time: 30 calendar days unless otherwise provided by law. The Complaints Policy (Appendix D) applies.

29.3. Disputes not resolved through the pre-trial procedure are referred to arbitration seated in San Salvador, Republic of El Salvador, conducted in English. To the maximum extent permitted by law, the User agrees to individual proceedings. Nothing in this Section deprives the User of rights that cannot be waived under mandatory consumer protection law of the User's jurisdiction.

30. Force Majeure

30.1. The Operator is not liable for non-performance due to events beyond its reasonable control, including actions of authorities, sanctions, wars, emergencies, provider outages, infrastructure shutdowns, forks and attacks.

30.2. During Force Majeure the Operator may temporarily restrict or disable Platform features without liability to the User.

31. Miscellaneous

31.1. Severability: if any provision is found invalid, the remaining provisions remain in force.

31.2. Assignment: the Operator may assign rights and obligations under these Terms to an affiliate or successor with notice to the User; the User may not assign without the Operator's consent.

31.3. Entire agreement: these Terms together with the documents incorporated by reference constitute the entire agreement between the Parties.

31.4. Survival: provisions on compliance, liability, dispute resolution and data survive termination of use of the Platform.

32. Notices and Communications

32.1. The Operator sends notices through the Platform interface, email, push notifications and other channels specified by the User.

32.2. The User keeps contact details current. A notice is deemed delivered when sent to the last known contact.

32.3. The Operator may record and store communications with the User for security, service quality and dispute resolution purposes, unless prohibited by applicable law.

APPENDICES

Appendix A. Fee Schedule

Appendix B. Acceptable Use Policy

Appendix C. API Terms

Appendix D. Complaints Policy

Appendix E. Restricted Jurisdictions

APPENDIX A. FEE SCHEDULE

Current fees and limits are published in the Platform interface. Fees are charged in the quote asset of the pair.

[Rates marked in this schedule are the rates in force at the effective date; the interface prevails.]

APPENDIX B. ACCEPTABLE USE POLICY

Violation of this Policy is a material breach of the Terms.

B1. Prohibited activities

• Any activity violating applicable law, including financial, sanctions, tax and consumer law.
• Money laundering, terrorism financing, sanctions evasion, facilitation of criminal activity.
• Fraud, theft, misappropriation, extortion, sale of stolen data or assets.
• Trafficking in illegal goods or services, prohibited content, exploitation of minors.

B2. Prohibited technical actions

• Unauthorised access, hacking, exploitation of vulnerabilities, denial-of-service attacks, interference with infrastructure.
• Malware, phishing, page spoofing, social engineering.
• Circumvention of restrictions (geo-blocking, limits, KYC) through VPN, proxy, nominees or other schemes.
• API abuse: exceeding rate limits, scraping in circumvention of rules, automation causing service degradation.
• Transferring an Account to third parties, selling Accounts, granting access without the Operator's consent.

B3. Prohibited market practices

• Market manipulation: wash trading, spoofing, layering, pump-and-dump, mark-the-close and similar practices.
• Use of insider information, collusion to distort price or volume.
• Exploitation of obvious quote or order errors and other technical anomalies.

B4. Measures upon breach

• Warning, restriction of features, suspension of transactions, freezing of assets, request for documents, cancellation of transactions where grounds exist, Account closure, notification of competent authorities.

APPENDIX C. API TERMS

The API is provided on an as-is basis. The Operator may change or discontinue the API with notice in the documentation, or without notice where required for security, compliance or system stability.

C1. Licence and restrictions

• The API is provided for integration with the Platform and automation of the User's own actions within the Terms.
• The API is not used to bypass limits, scrape data in circumvention of rules, manipulate markets or engage in other prohibited activity.
• The API is not provided to third parties as a service without the Operator's written consent.

C2. Key security

• Keys are stored in secure vaults. Least privilege, IP restrictions and key rotation are applied. Keys are revoked immediately upon suspected compromise.

C3. Rate limits and stability

• The Operator sets rate limits and other technical restrictions. Requests exceeding limits are rejected. The Operator does not guarantee continuous availability of the API.

C4. Liability

• The User is responsible for the results of algorithmic trading and for correct integration. The Operator is not responsible for errors in the User's code, third-party libraries or the User's infrastructure.

APPENDIX D. COMPLAINTS POLICY

D1. A request or complaint is submitted to [email protected]; a legal notice to [email protected].

D2. The User describes the issue and specifies the Account identifier, date and time, transaction hash where applicable, screenshots and other evidence.

D3. The Operator acknowledges receipt within 2 business days and may request additional information.

D4. The review period is up to 30 calendar days unless otherwise required by law or the complexity of the investigation. The User is informed of any extension.

D5. In AML and sanctions cases the Operator does not disclose details of the review where disclosure is prohibited by law.

D6. If the User disagrees with the response, the User may submit a follow-up request with additional data or use the dispute resolution procedure in Section 29. The User may also address a complaint to CNAD in accordance with its procedures.

APPENDIX E. RESTRICTED JURISDICTIONS

The list is updated by the Operator. The current list on the Platform prevails.

E1. The Operator does not provide services to residents of, or persons located in:

• the United States of America and its territories;
• the United Kingdom;
• the member states of the European Union and the European Economic Area, until the Operator obtains an authorisation under the Markets in Crypto-Assets Regulation;
• the Russian Federation;
• jurisdictions on the FATF list of high-risk jurisdictions subject to a call for action;
• jurisdictions and territories subject to comprehensive international sanctions.

E2. The Operator does not provide services to persons listed on sanctions lists, politically exposed persons with unacceptable risk, or other Prohibited Persons.

E3. The Operator may restrict service to residents of other jurisdictions where local law requires an authorisation the Operator does not hold.

[The list is confirmed by counsel before the Platform opens to clients.]

Boulder Tech, S.A.S. de C.V.

Sole Administrator and Legal Representative

Ruslans Grabaruks ________________________