Terms and Conditions (Virtual Asset Services)

TERMS AND CONDITIONS

VIRTUAL ASSET SERVICES

These Terms and Conditions (the “Terms and Conditions”) exclusively govern the virtual asset services offered by D.A. SOCIEDADE PRESTADORA DE SERVIÇOS DE ATIVOS VIRTUAIS LTDA., a company registered with the CNPJ/MF under No. 61.469.681/0001-26, with its registered office at Avenida Brigadeiro Faria Lima, 4055, 1st Floor, Room 01-110, ZIP Code 04538-133 (“ARQ PSAV,” “ARQ,” “we,” “us,” or “our”). ARQ PSAV is a virtual asset service provider operating in Brazil in accordance with the regulatory framework of the Central Bank of Brazil (“Central Bank”) and Federal Law No. 14,478, dated December 21, 2022.

For the purposes of these Terms and Conditions: (i) any reference to “we,” “our,” “us,” and/or similar terms shall be interpreted as a reference to ARQ PSAV; and (ii) any reference to “you,” “your,” and/or similar terms shall be interpreted as a reference to you, the Client. Capitalized terms used in this document have the meanings assigned to them in Annex B.

You agree and understand that, in order to use the services provided by ARQ PSAV, you must agree to the Terms and Conditions governing the prepaid account service provided by Atlas Brasil, which are available at https://www.arqfinance.com/pt-BR/legal, since Atlas Brasil provides Banking-as-a-Service services to ARQ PSAV, allowing you to access a payment account through the ARQ Platform.

BY USING THE VIRTUAL ASSET SERVICES, YOU AUTOMATICALLY AGREE TO ALL THE RULES SET FORTH IN THESE TERMS AND CONDITIONS. IF YOU DO NOT AGREE, YOU MUST NOT USE THE SERVICES. BY CLICKING “ACCEPT,” YOU REPRESENT THAT YOU HAVE READ, UNDERSTOOD, AND ACCEPTED THESE TERMS AND CONDITIONS, THE PRIVACY POLICY, AND THE OTHER LEGAL DOCUMENTS MADE AVAILABLE TO YOU, WHICH MUST BE READ TOGETHER.

These Terms and Conditions may be modified, amended, or updated by us from time to time. Any amendment will be displayed on the Platform or communicated to you in accordance with Applicable Law. By continuing to access or use the Services following any amendment, you indicate your consent to and acceptance of such amendment.

1. REGULATORY FRAMEWORK AND NATURE OF ARQ PSAV

ARQ PSAV is a virtual asset service provider (“PSAV”) and organizes its activities in accordance with the regulatory framework issued by the Central Bank of Brazil, particularly:

BCB Resolution No. 519 of 2025 (“BCB Resolution 519”), which governs the procedures for authorization to operate, cancellation of authorization, transfers of control, and corporate reorganizations of PSAVs and other institutions subject to the supervision of the Central Bank in connection with virtual assets;

BCB Resolution No. 520 of 2025 (“BCB Resolution 520”), which provides for the incorporation, authorization, and operation of PSAVs, as well as their governance, risk management, asset segregation, transparency, and client protection, establishing the following categories of PSAVs: virtual asset intermediary, custodian, and broker; and

BCB Resolution No. 521 of 2025 (“BCB Resolution 521”), which classifies certain PSAV activities as foreign exchange market transactions, including, among others: (a) international payments and transfers carried out through virtual assets; (b) the use of virtual assets to settle expenses abroad; (c) transfers of virtual assets to or from self-hosted wallets; and (d) the purchase, sale, or exchange of virtual assets referenced to fiat currency (“stablecoins”).

You acknowledge that ARQ PSAV activities that qualify as foreign exchange market transactions under BCB Resolution 521 are subject to the applicable foreign exchange rules, including the identification, registration, purpose-code classification, and reporting obligations described in these Terms and Conditions.

You further acknowledge that the performance of PSAV activities is subject to an authorization process and ongoing supervision by the Central Bank and that, while its regulatory adaptation process remains pending or in progress, ARQ PSAV will comply with the transitional regime and deadlines established by the applicable regulations.

2. VIRTUAL ASSET SERVICES

Through the ARQ Platform, ARQ PSAV allows you to carry out transactions involving virtual assets, including the purchase, sale, exchange, and transfer of virtual assets such as USDc and EURc, using blockchain-based technology to provide speed, predictability, and stability in transactions.

The virtual asset infrastructure allows Clients to send and receive virtual assets through the ARQ Entities. Virtual assets acquired through the application may be held in custody by ARQ PSAV itself or by a regulated foreign entity, whether or not part of the same economic group, as further detailed in Clause 4.

You acknowledge that holding and transferring virtual assets will require you to have a digital wallet (the “Digital Wallet”), governed by specific terms and conditions made available on the ARQ Platform and accepted by you before accessing such services.

3. ARQ PSAV’S ACTIVITIES AS A DIRECT SERVICE PROVIDER

ARQ PSAV provides the virtual asset Services as a direct service provider, in its own name, in its capacity as a PSAV supervised by the Central Bank of Brazil, pursuant to BCB Resolutions 519, 520, and 521.

In accordance with the restrictions established by BCB Resolution 520, ARQ PSAV does not raise funds from the public, except in the circumstances expressly permitted under the regulations applicable to PSAVs.

4. PROVISION OF SERVICES IN BRAZIL AND ENGAGEMENT OF ESSENTIAL SERVICES ABROAD

You acknowledge and agree that all virtual asset Services are provided in Brazil by ARQ PSAV, which is your counterparty and the entity responsible for its relationship with you, in accordance with applicable Brazilian laws and regulations.

The fact that ARQ PSAV engages Relevant Service Providers abroad—including the custody of virtual assets provided by a regulated foreign entity belonging to the same economic group, as well as technological infrastructure, liquidity provision, and market-making services—does not change the characterization of the Services as being provided in Brazil or transfer the service relationship maintained with you abroad. The engagement of such services complies with the regulatory requirements applicable to the engagement of relevant services by PSAVs, including ARQ PSAV’s due diligence, continuity, and responsibility obligations toward you.

When the custody of virtual assets is outsourced to a foreign custodian, ARQ PSAV will comply with the requirements of BCB Resolution 520, ensuring, among other requirements, the asset segregation of Virtual Assets.

ARQ PSAV remains responsible to you and to the Brazilian authorities for the services provided, even when such services are performed, in whole or in part, by Relevant Service Providers engaged abroad.

5. SELECTION, LISTING, AND DELISTING OF VIRTUAL ASSETS

The offering of virtual assets on the Platform follows clear, transparent, and technical selection and listing criteria, which are subject to periodic review. ARQ PSAV may suspend or discontinue the offering of a particular virtual asset by delisting it and providing notice to you in accordance with Applicable Law. The list of virtual assets offered and the applicable criteria will be publicly disclosed.

Additional requirements regarding backing, reserves, issuers, audits, and risk assessments apply to virtual assets referenced to fiat currency, or stablecoins. Assets that use algorithmic reserve control mechanisms are prohibited.

6. CLIENT RISK PROFILE

ARQ PSAV will assess your risk profile based on factors including your familiarity with virtual assets, your objectives, and your risk tolerance.

Should you seek to carry out a transaction that is inconsistent with your risk profile, ARQ PSAV may condition the execution of the transaction upon obtaining your specific and documented acknowledgement of the risks involved and may reject or restrict the transaction if such acknowledgement is not obtained.

7. REGISTRATION AND ELIGIBILITY

You represent that: (i) you are a resident of Brazil and have sufficient capacity to accept these Terms and Conditions; (ii) you acknowledge that the Services are available to residents of Brazil; (iii) you are registering exclusively in your own name and are not acting in the name of or on behalf of any third party; and (iv) you agree to the terms and conditions and rules of the other ARQ Entities. The Services are intended for your personal use.

To be eligible to use the Services, you must be at least 18 years old and have the full legal right, power, and capacity to enter into these Terms and Conditions. You must also comply with the qualification requirements established in this document and by our Partners, as applicable.

Following registration, we will conduct an identity verification process (“KYC”) to the extent necessary to comply with all applicable anti-money laundering (“AML”), counter-terrorist financing and counter-proliferation financing (“CTF/PF”), sanctions, and related regulatory requirements.

Use of the Services is subject to the successful completion of this process. To complete your registration as an individual, you must provide at least: (i) your full name; (ii) CPF number; (iii) contact information, including your email address and telephone number; (iv) residential address; (v) date of birth; (vi) a government-issued photo identification document, such as an RG identity card, CNH driver’s license, or passport; and (vii) a photograph or selfie.

We reserve the right to reject any registration request: (i) if the information provided is inconsistent or indicates suspicious or fraudulent activity under the applicable AML/CTF/PF regulations; (ii) if you fail to provide the requested information or documents; or (iii) for any reasonable commercial reason. Only one registration per CPF number will be permitted.

For monthly transactions involving amounts considered material at our discretion, we must receive evidence of the source of funds and, where applicable, supporting evidence before the Brazilian Federal Revenue Service before completing the intended transaction.

8. DIGITAL WALLETS AND WALLET MONITORING

Transfers of virtual assets may involve wallets held in custody by ARQ Entities and self-hosted, or non-custodial, wallets owned by you or by third parties.

You acknowledge that transfers to or from self-hosted wallets may qualify as foreign exchange market transactions pursuant to BCB Resolution 521 and are subject to the controls described in this document.

For transfers involving self-hosted wallets, ARQ PSAV will identify the owner of the wallet and implement and record the processes necessary to verify the origin and destination of the virtual assets, in accordance with BCB Resolution 521.

ARQ PSAV uses virtual asset wallet and address monitoring mechanisms (“wallet monitoring”), including the analysis of blockchain transactions, screening addresses against sanctions and risk lists, assessing exposure to addresses associated with unlawful activities, and assigning risk scores.

Based on this monitoring, ARQ PSAV may request additional information, reject, suspend, or reverse transactions, block addresses, and take any other measures required by Applicable Law.

You represent that the addresses and wallets identified by you are legitimately owned by you or that you are authorized to use them, and that you will not use the Services to transfer virtual assets from or to addresses associated with unlawful activities.

9. FOREIGN EXCHANGE MARKET TRANSACTIONS

ARQ PSAV activities that qualify as foreign exchange market transactions pursuant to BCB Resolution 521 will comply with the applicable foreign exchange rules.

10. TRAVEL RULE

In compliance with applicable international standards, particularly Recommendation 16 of the Financial Action Task Force (“FATF”), and Brazilian AML/CTF/PF regulations, ARQ PSAV complies with the “Travel Rule” in connection with transfers of virtual assets.

For this purpose, ARQ PSAV securely collects, retains, and transmits to the counterparties and virtual asset service providers involved in the transaction, where applicable, information regarding the originator and beneficiary of the transfer, such as their names, account or wallet identifiers, and any other information required by the applicable regulations.

By using the Services, you authorize ARQ PSAV to collect, process, and transmit such information to the extent necessary to comply with the Travel Rule and other regulatory obligations, in accordance with the Privacy Policy and the Brazilian General Data Protection Law, Federal Law No. 13,709/2018.

If the information required under the Travel Rule is not provided or cannot be validated, ARQ PSAV may reject, suspend, or hold the transaction until the matter has been resolved.

11. ANTI-MONEY LAUNDERING, COUNTER-TERRORIST FINANCING, AND SANCTIONS

You represent that you are aware of and will comply with Brazilian AML/CTF/PF regulations, including, without limitation:

Federal Law No. 9,613, dated March 3, 1998, which provides for money laundering offenses and the prevention of the use of the financial system for such unlawful activities;

Federal Law No. 13,260, dated March 16, 2016, which governs the fight against terrorism and terrorist financing;

Federal Law No. 13,810, dated March 8, 2019, which provides for compliance with sanctions imposed by resolutions of the United Nations Security Council;

BCB Circular No. 3,978, dated January 23, 2020 (“Circular 3978”), which establishes the AML/CTF/PF policies, procedures, and internal controls to be adopted, including client identification and know-your-customer obligations, internal risk assessments, the monitoring and selection of suspicious transactions and situations, and reporting to the Council for Financial Activities Control (“COAF”); and

Any other regulations issued by the Central Bank and COAF that are applicable to PSAVs, as issued and amended from time to time.

ARQ PSAV maintains an AML/CTF/PF policy, an internal risk assessment, KYC procedures, continuous transaction and wallet monitoring, and mechanisms for detecting and reporting suspicious transactions, in accordance with Circular 3978 and other applicable regulations.

You acknowledge and agree that we will report to COAF, the Central Bank, and any other competent authorities, without prior notice to you and without this constituting a breach of any confidentiality obligation, any transactions or situations that may constitute the unlawful activities described in Law No. 9,613/1998 and the related regulations.

You represent, on your own behalf, that: (i) you are not, directly or indirectly, subject to Sanctions and are not located, established, or ordinarily resident in a Sanctioned country or territory; (ii) your use of the Services will not directly or indirectly involve any person or entity subject to Sanctions; and (iii) the funds and virtual assets used are not directly or indirectly derived from unlawful activities or from persons or entities subject to Sanctions.

“Sanctions” include sanctions administered or imposed by the United Nations Security Council, the Office of Foreign Assets Control (“OFAC”) of the United States Department of the Treasury, the European Union, and His Majesty’s Treasury of the United Kingdom (“HMT”).

ARQ PSAV may, at any time and without liability, refuse to provide the Services or process transactions that do not comply with its policies, procedures, and internal controls. ARQ PSAV may also suspend or terminate the provision of the Services in the event of a breach of AML/CTF/PF or Sanctions requirements.

You agree to notify us immediately of any violation and to provide the information and supporting documentation demonstrating the lawful nature of your activities.

12. REGULATORY REPORTING OF TRANSACTIONS — ACAM 212

You acknowledge and agree that all transactions carried out through the Services are subject to reporting to the competent authorities where applicable, including reporting to the Central Bank through ACAM 212, Document C212 — Provision of Virtual Asset Services in the Foreign Exchange Market, in accordance with the reporting regulations issued by the Central Bank.

Reporting through ACAM 212, where applicable, includes, among others, the following transactions: (i) international payments and transfers carried out through virtual assets; (ii) the loading and unloading of virtual assets onto or from cards or other payment instruments intended for international use; (iii) transfers of virtual assets to or from self-hosted wallets; and (iv) monthly totals for purchases, sales, and exchanges of virtual assets referenced to fiat currency.

The information reported includes, where applicable, the Client’s identification information obtained through KYC, the type of virtual asset, the foreign counterparty, the transaction value, and its economic purpose. Such information is submitted to the Central Bank at the frequency and within the deadlines established by the applicable regulations.

By using the Services, you authorize ARQ PSAV to collect and report such information to the competent authorities, where applicable, in accordance with the Privacy Policy.

14. FEES

In consideration for the Services provided through the Platform, you agree to pay us the fees set forth in our fee schedule available on the Platform, or on another page specified by us.

We may revise or update the fee schedule at our sole discretion from time to time. Any amendments will become effective on the date specified in the revised fee schedule and will apply prospectively.

The fees payable to us and our Partners for providing the Services will be included in the fee schedule.

15. TAXES

You are solely responsible for any taxes that may apply to the Services provided and to transactions involving virtual assets, as well as for any ancillary obligations and reporting requirements imposed by the competent authorities, including any reporting obligations before the Brazilian Federal Revenue Service.

ARQ PSAV and its Partners will not be responsible for any taxes that you may be required to pay as a result of your use of the Services.

16. VIRTUAL ASSET RISKS AND NO FINANCIAL ADVICE

You acknowledge that virtual assets are subject to risks, including significant price volatility, technological and operational risks, liquidity risks, and regulatory risks.

Any information provided by us in connection with virtual assets does not constitute financial, investment, or other professional advice and must not be treated as a substitute for specific professional advice.

You are solely responsible for any decision to hold, purchase, sell, or exchange virtual assets, and such decisions must take your risk profile into account.

17. CLIENT RESPONSIBILITY AND DISCLAIMER OF LIABILITY

WE ARE NOT RESPONSIBLE FOR ANY RISKS OR ADVERSE OUTCOMES RELATING TO TRANSACTIONS REQUESTED AND CARRIED OUT BY YOU. EXCEPT TO THE EXTENT REQUIRED BY APPLICABLE LAW, WE WILL NOT BE LIABLE FOR ANY DIRECT, PUNITIVE, SPECIAL, INDIRECT, CONSEQUENTIAL, OR INCIDENTAL DAMAGES IN CONNECTION WITH THESE TERMS AND CONDITIONS OR YOUR USE OF THE SERVICES.

It is strictly prohibited to use the Platform in violation of these Terms and Conditions or for any unlawful purpose.

You will be responsible for any losses, expenses, or costs incurred by us, including attorneys’ fees, arising from: (i) your intentional, reckless, or negligent use of the Services; (ii) your failure or willful misconduct in complying with data protection rules; and/or (iii) any misuse of a service available through the Platform.

Transactions will only be carried out upon your request, and you assume full responsibility for the information provided. You must verify all information before submitting it, acknowledging that virtual asset Transactions are generally irreversible once executed.

You are solely responsible for managing and maintaining the security of your access credentials and keys and must immediately notify us of any security breach by email at help.br@arqfinance.com.

18. INTELLECTUAL PROPERTY

The Services, including all Content, belong at all times to the ARQ Entities or to the parties that license such Content to us and are protected by applicable copyright laws.

The ARQ Marks are owned by the ARQ Entities and may not be used without prior express consent.

You do not acquire any rights in the Content or the ARQ Marks, except as expressly permitted under this document.

19. TERMINATION

These Terms and Conditions will remain in effect until terminated by either party.

You may cease using the Services and terminate these Terms and Conditions at any time, without any termination fee, by notifying us by email at help.br@arqfinance.com.

We reserve the right to terminate these Terms and Conditions without cause by providing you with at least thirty (30) days’ prior notice.

Regardless of prior notice, we may terminate, cancel, or reverse a virtual asset order, restrict, freeze, or terminate your access to the Services, and take any other necessary measures in the following circumstances:

(i) A violation or suspected failure to comply with any Applicable Law, including AML/CTF/PF and Sanctions regulations;

(ii) A failure to make any payment owed to the ARQ Entities;

(iii) A material breach of these Terms and Conditions that is not remedied within thirty (30) days; or

(iv) The execution of transactions considered unlawful or fraudulent.

Upon termination of these Terms and Conditions, and subject to Applicable Law and applicable AML/CTF/PF and reporting obligations, you will be entitled to redeem or transfer the virtual assets and any available balance in the manner made available through the Platform.

20. AMENDMENTS AND REVISIONS

We may unilaterally introduce innovations, improvements, and new functionalities or change the names, logos, and features of the Platform by notifying you by email or through the Platform.

We may also amend these Terms and Conditions to reflect changes to applicable laws and regulations, including BCB Resolutions 519, 520, and 521 and the applicable AML/CTF/PF and reporting regulations.

21. COMMUNICATIONS AND NOTICES

All information will be made available to you in Portuguese and in an easily accessible manner.

You agree that we may send notices and communications through the Platform, by email, or through other reasonable means.

All communications addressed to us must be sent to help@arqfinance.com.

22. GENERAL PROVISIONS

We will not be responsible for any failure or delay in performing our obligations resulting from a force majeure event beyond our reasonable control.

We may assign any of our rights and obligations under these Terms and Conditions upon prior notice to you, provided that the assignee continues to comply with the obligations assumed herein.

If any provision is deemed invalid or unenforceable, the remaining provisions will remain in full force and effect.

Any tolerance of a breach will not constitute a waiver of rights.

23. GOVERNING LAW AND JURISDICTION

The interpretation and scope of these Terms and Conditions will be governed by the laws of the Federative Republic of Brazil.

Any dispute arising from the use of the Services will be submitted to the courts of the Judicial District of São Paulo, State of São Paulo, and the parties waive any other jurisdiction, regardless of how privileged it may be.

YOU REPRESENT THAT YOU HAVE READ AND ACCEPT THE ENTIRE CONTENT OF THESE TERMS AND CONDITIONS AND THAT YOU WILL BE BOUND BY AND SUBJECT TO THE RIGHTS AND OBLIGATIONS SET FORTH HEREIN WHEN REQUESTING THE SERVICES.

ANNEX A

Rewards Program

1. PURPOSE

ARQ PSAV may establish, maintain, modify, or discontinue a rewards program (the “Rewards Program”), under which it may credit certain Clients, as a bonus, with amounts in Virtual Assets (each, a “Reward”). This Annex A forms an integral part of the Terms and Conditions for all purposes and exclusively governs the Rewards Program.

2. NATURE OF THE REWARD — GRATUITOUS BENEFIT

The granting of Rewards constitutes a gratuitous benefit granted at ARQ PSAV’s sole discretion and is occasional, optional, free of charge, and non-compensatory in nature. It does not arise from any legal or contractual obligation undertaken toward you.

Each Reward is exclusively a bonus and expressly: (i) does not constitute consideration, compensation, a discount, rebate, or reimbursement for the Services; (ii) does not constitute interest, monetary adjustment, earnings, remuneration on balances, returns, or any promise or guarantee of returns, nor does it constitute an investment product or offering; (iii) does not constitute the taking of funds from the public or any activity prohibited for PSAVs under BCB Resolution No. 520; and (iv) does not modify the fee schedule referred to in Clause 14.

The granting of one or more Rewards does not create any vested right, expectation of a right, established practice, right to repetition or future grants, nor does it require ARQ PSAV to grant Rewards under equal or similar conditions at any other time or to any other Client.

3. ELIGIBILITY AND AVAILABILITY TO SPECIFIC CLIENTS

The Rewards Program may be offered only to specific Clients selected at ARQ PSAV’s sole discretion, including based on campaign, product, channel, segment, region, length of relationship, volume or frequency of use of the Services, a specified period, or any other criterion that ARQ PSAV may adopt. ARQ PSAV is not required to provide any justification, nor is it required to extend the Rewards Program to other Clients.

Any eligibility is personal and non-transferable. A Reward may not be assigned or transferred to third parties, exchanged, or converted into cash unless otherwise expressly provided by ARQ PSAV in the terms of the applicable campaign.

Eligibility requires an active account in good standing, completion of the KYC process, and compliance with the AML/CFT and Sanctions rules set forth in Clauses 8 and 12. Any Client whose account is suspended, blocked, or under review, or who is subject to Sanctions, will not be eligible.

4. TERMS OF EACH CAMPAIGN

The calculation criteria, amounts, minimum and maximum limits, validity period, method and date of credit, and all other terms applicable to each Reward will be determined by ARQ PSAV and disclosed on the ARQ Platform or communicated directly to the eligible Client in accordance with Clause 21. In the event of any conflict between the specific terms of a campaign and this Annex A, this Annex A will prevail with respect to the nature of the Reward, ARQ PSAV’s discretion in granting it, and ARQ PSAV’s right to modify, suspend, or terminate the Rewards Program.

5. METHOD OF CREDIT, VOLATILITY, AND RISKS

Rewards will be credited in Virtual Assets, such as USDc or EURc, to the Client’s Digital Wallet, subject to the Terms and Conditions, including the rules applicable to Virtual Asset transactions, the Travel Rule, and foreign exchange market transactions, where applicable.

You acknowledge that the value of the Reward is subject to volatility and the other risks described in Clause 16. ARQ PSAV provides no guarantee regarding the maintenance of value, convertibility, liquidity, or results, nor does it provide investment advice or recommendations.

6. MODIFICATION, SUSPENSION, AND TERMINATION AT ANY TIME

ARQ PSAV may, at any time and at its sole discretion, modify, restrict, reduce, suspend, interrupt, or terminate, in whole or in part, the Rewards Program or any campaign, as well as exclude Clients, groups of Clients, products, or jurisdictions from its scope, without being required to provide any justification and without giving rise to any right of the Client to indemnification, compensation, penalties, remedies, maintenance of existing terms, or continuation of the Rewards Program.

Any modification, suspension, or termination will be communicated through the ARQ Platform or by email in accordance with Clause 21 and will take effect upon such communication, except for immediate measures required to comply with Applicable Law, an order issued by a competent authority, or AML/CFT and Sanctions obligations.

Termination of the Rewards Program will not affect Rewards duly credited and available in the Digital Wallet before the effective date of the communication, subject to the circumstances described in Section 7 of this Annex A.

7. MISUSE, CANCELLATION, AND REVERSAL

ARQ PSAV may cancel, withhold, suspend, or reverse a Reward, even if it has already been credited, and exclude the Client from the Rewards Program in the event of fraud, abuse, manipulation, creation of multiple accounts, provision of false or inaccurate information, use of automated means, collusion, artificial transactions or transactions lacking economic substance, or any violation of these Terms and Conditions or Applicable Law, without prejudice to the other measures set forth in Clauses 12, 17, and 19.

8. TAXES

Pursuant to Clause 15, you are solely responsible for any taxes and ancillary tax obligations that apply or may become applicable to a Reward, including its reporting to the Brazilian Federal Revenue Service, where applicable. If Applicable Law requires ARQ PSAV to withhold or pay any such amount, the value of the Reward may be adjusted accordingly.

9. FINAL PROVISIONS

All provisions of the Terms and Conditions apply to the Rewards Program, particularly Clauses 17, 20, 22, and 23. Capitalized terms not defined in this Annex A have the meanings assigned to them in Annex B.

ANNEX B

Definitions

“Virtual Asset” means any virtual asset, as defined under Federal Law No. 14,478/2022, that constitutes a digital representation of value based on the cryptographic protocol of a computer network, including stablecoins referenced to fiat currency.

“Central Bank” means the Central Bank of Brazil.

“Self-Hosted Wallet” means a non-custodial Virtual Asset wallet whose private keys are under the exclusive control of its owner and not a PSAV.

“Digital Wallet” means the digital wallet maintained by an ARQ Entity for the storage of your Virtual Assets and governed by specific terms and conditions.

“Circular 3978” means BCB Circular No. 3,978, dated January 23, 2020, which provides for AML/CTF/PF policies, procedures, and internal controls.

“COAF” means the Council for Financial Activities Control.

“Content” means all information and content, including text, software, scripts, graphics, photographs, and interactive features made available as part of the provision of the Services.

“CPF” means the Individual Taxpayer Registry maintained by the Brazilian Ministry of Finance.

“ARQ Entities” means all entities belonging to ARQ’s economic group, including the regulated foreign entity responsible for the custody of Virtual Assets.

“Applicable Law” means any and all laws, rules, regulations, orders, or determinations of any regulatory or governmental authority applicable to you or ARQ PSAV from time to time.

“ARQ Marks” means the “ARQ” trademarks and the other trademarks, icons, logos, and designs of the ARQ Entities.

“Partners” means any entities selected to enable the provision of all or part of the Services and that must hold the appropriate authorization from the competent authority.

“Risk Profile” means the set of Client characteristics considered by ARQ PSAV, including familiarity with virtual assets, objectives, and risk tolerance.

“ARQ Platform” means the website and/or application through which Clients access the Services.

“AML” means anti-money laundering, and “CTF/PF” means counter-terrorist financing and counter-proliferation financing.

“Relevant Service Providers” means third parties engaged in Brazil or abroad whose services may affect the performance of ARQ PSAV’s activities or the exercise of Clients’ rights, including custody, technology provision, liquidity provision, and market making.

“Proof of Reserves” means the verification, through an independent audit report, of the Virtual Assets held by ARQ PSAV and its Clients, publicly disclosed in accordance with the applicable regulations.

“PSAV” means a virtual asset service provider under Law No. 14,478/2022 and BCB Resolutions 519, 520, and 521.

“Travel Rule” means the obligation to collect, retain, and transmit information regarding the originator and beneficiary of Virtual Asset transfers, in accordance with FATF Recommendation 16 and the applicable regulations.

“BCB Resolution 519” means BCB Resolution No. 519 of 2025, which governs the authorization procedures applicable to PSAVs.

“BCB Resolution 520” means BCB Resolution No. 520 of 2025, which provides for the incorporation and operation of PSAVs and their categories.

“BCB Resolution 521” means BCB Resolution No. 521 of 2025, which classifies certain PSAV activities as foreign exchange market transactions.

“ACAM 212” means Document C212 — Provision of Virtual Asset Services in the Foreign Exchange Market, the periodic reporting file submitted to the Central Bank regarding Virtual Asset transactions in the foreign exchange market.

“Sanctions” means sanctions administered or imposed by the United Nations Security Council, OFAC in the United States, the European Union, and His Majesty’s Treasury in the United Kingdom.

“Services” means the virtual asset services described in these Terms and Conditions.

“Terms and Conditions” means these terms and conditions governing the use of the virtual asset services provided by ARQ PSAV.

Updated: July 20, 2026