IA TECH PAY — PLATFORM TERMS OF USE

These Terms of Use ("Terms") govern access to and use of the payments and virtual asset services platform operated by IA TECH PAY ("IA TECH PAY", "Platform", "we") by any natural or legal person who completes registration ("User", "Customer", "you").

By selecting the acceptance option in the registration flow, the User declares, for all legal purposes, that they have read, understood and fully agree with these Terms, with the Anti-Money Laundering and Counter-Terrorism Financing Policy ("AML/CFT Policy") and with the Privacy Policy of IA TECH PAY, documents that become part of this instrument by reference, as if fully set forth herein. Electronic acceptance is a condition for access to the Platform and has full legal validity, under article 425 et seq. of the Brazilian Civil Code and applicable e-commerce legislation.

If the User does not agree with any provision of these Terms, the User must not complete registration or use IA TECH PAY's services.

IA TECH PAY:

The company responsible for operating the Platform, acting as the master distributor (Master-Distributor) and country operator of the ETHER Exchange infrastructure in Paraguay, Uruguay and Argentina, and directly in Brazil.

Platform:

The set of systems, applications, interfaces and services made available by IA TECH PAY to the User, including payment and virtual asset transactions.

ETHER Exchange / Infrastructure Partner:

DEX Ether Crypto Exchange Corporation and other companies of its group, providers of the Banking-as-a-Service ("BaaS") infrastructure, the BRT stablecoin, and the payment rails ("DEX") used by IA TECH PAY to provide part of its services.

Authorized Institution:

[Corporate name and CNPJ to be confirmed prior to publication], a company incorporated in Brazil and a member of the ETHER group, authorized by the Central Bank of Brazil to operate as a Virtual Asset Service Provider Company ("VASP"), under BCB Resolutions No. 519, 520 and 521/2025, for which IA TECH PAY is the country correspondent, under CMN Resolution No. 4,935/2021, for the provision of virtual asset services in Brazil.

Virtual Assets / Crypto-Assets:

Digital representations of value, including the BRT stablecoin and other crypto-assets supported by the Platform, which do not constitute legal tender.

Account:

The User's individual registration on the Platform, following approval of the identity verification process.

AML/CFT:

Anti-Money Laundering and Counter-Terrorism Financing and Financing of the Proliferation of Weapons of Mass Destruction.

PEP:

Politically Exposed Person, as defined by the applicable AML/CFT regulations in each territory.

Travel Rule:

The obligation of traceability and identification of the originator and beneficiary in virtual asset transfers, set out in FATF Recommendations and applicable local regulations.

Restrictive Lists:

Sanctions lists and lists of prohibited persons and entities maintained by bodies such as the UN, OFAC, the European Union and competent national authorities.

Territory of Operation:

Brazil, Paraguay, Uruguay and Argentina, the countries in which IA TECH PAY offers its services as of the date of these Terms.

IA TECH PAY provides a payments and virtual asset transaction orchestration platform, being the sole services provider to the User. Through the Platform, IA TECH PAY offers, depending on the territory and current commercial availability: PIX receipt and payment, bank slip (boleto) payment, foreign exchange transactions ("FX"), over-the-counter transactions ("OTC"), and the purchase, sale, transfer and exchange ("swap") of virtual assets, integrating multiple payment rails into a single User experience.

For the execution of part of these services — in particular virtual asset transactions and OTC transactions — IA TECH PAY uses the technological infrastructure, the BRT stablecoin and the payment rails ("DEX") made available by ETHER Exchange (DEX Ether Crypto Exchange Corporation), an infrastructure provider engaged by IA TECH PAY. The User expressly acknowledges and agrees that:

• IA TECH PAY is the sole contracting party and the sole party responsible to the User for all services offered on the Platform, regardless of which infrastructure is used to execute them;
• ETHER Exchange is not a party to these Terms, has no direct contractual relationship with the User, and does not assume, before the User, any obligation of service, support or liability — all communications, billing, support and any complaints must be directed exclusively to IA TECH PAY;
• the identification of ETHER Exchange in these Terms is solely for the purpose of transparency regarding the infrastructure actually used and the liability regime for third-party failures described in Section 12, and does not confer on ETHER Exchange any commercial, contractual or service role before the User;
• specifically with regard to virtual asset transactions offered in Brazil, IA TECH PAY provides them in its capacity as country correspondent of the Authorized Institution, as detailed in Section 10, without this altering the fact that IA TECH PAY remains solely responsible for commercial service to the User.

These Terms do not create any relationship of exclusivity, partnership, agency or employment between IA TECH PAY and the User, nor between ETHER Exchange and the User.

To register and use the Platform, the User represents and warrants that:

• the User is a natural person with full legal capacity, at least 18 (eighteen) years of age, or a validly incorporated legal entity, represented by a person with sufficient powers;
• the User does not appear on any Restrictive List and is not controlled, directly or indirectly, by any sanctioned person or entity;
• the User does not reside or is not established in a jurisdiction in which the provision of IA TECH PAY's services is prohibited by law;
• the information provided during registration is true, complete and up to date, and the funds handled have a lawful origin;
• the User will use the Platform in their own name, and registration on behalf of third parties without express authorization and proof of legal representation is prohibited.

IA TECH PAY may refuse, suspend or cancel the registration of any person, at its sole discretion, upon identifying legal, reputational or AML/CFT risk, or non-compliance with these conditions, without this giving rise to any right to compensation.

Access to the services is conditional on completion of the identity verification process ("Know Your Customer" — KYC), which may include, among others: an official photo identification document, proof of address, biometric/liveness verification, data on legal entities and their representatives and beneficial owners, and the source of funds.

The level of documentation required is proportional to the risk assigned to the User and the transaction, according to the risk classification methodology described in IA TECH PAY's AML/CFT Policy. IA TECH PAY may, at any time, request additional documentation, including after initial registration approval, without needing to justify the specific reason for the request in advance, and may condition the continuity or release of transactions on compliance with such request within the informed deadline.

Users classified as Politically Exposed Persons (PEP), or who present other high-risk factors (risk jurisdiction, nature of the activity, atypical volume or pattern of transactions), will be subject to an Enhanced Due Diligence ("EDD") process, with approval at a senior hierarchical level, in accordance with the AML/CFT Policy.

It is the User's duty to keep their registration data up to date, notifying IA TECH PAY of any relevant change within 30 (thirty) days of its occurrence.

The services offered, subject to availability by territory, include:

• PIX: receipt (PIX IN) and sending (PIX OUT) of funds via the Brazilian Instant Payment System;
• Bank Slip (Boleto Bancário): issuance and settlement of bank slips;
• Virtual Asset Transactions: purchase, sale, transfer and swap of supported crypto-assets, including the BRT stablecoin;
• Foreign Exchange (FX): conversion between fiat currencies, between crypto-asset and fiat currency, and between different fiat currencies (e.g., EUR/USDC).

The fees applicable to each service are set out in a specific table, made available to the User on the Platform and/or through an official communication channel ("Fee Schedule"), which becomes part of these Terms by reference. IA TECH PAY may amend the Fee Schedule upon at least 15 (fifteen) days' prior notice through an official channel, except for changes resulting from a regulatory determination or the direct pass-through of third-party infrastructure costs, in which case the notice period may be shortened, always with timely communication to the User.

In over-the-counter transactions ("OTC") and other virtual asset transactions carried out through the ETHER Exchange infrastructure, IA TECH PAY acts exclusively as an intermediary: the User's order is passed directly to the ETHER Exchange order book for matching and execution. IA TECH PAY does not take a proprietary market position, nor does it maintain its own inventory of virtual assets for trading purposes with the User, and does not act as a counterparty ("dealer") to the transactions.

As a result of this intermediation model, the User acknowledges that:

• the price quoted at the time of the quotation is subject to change until the actual execution and confirmation of the transaction on the ETHER Exchange order book, and may be updated according to market conditions at the time the order is matched;
• IA TECH PAY will use its best efforts to pass through and confirm the transaction instantly, but does not guarantee that the quoted price will be maintained in scenarios of extreme volatility, momentary unavailability or latency of the ETHER Exchange infrastructure;
• execution risk (the difference between the quoted price and the price actually executed), settlement risk and market counterparty risk related to the trading infrastructure are inherent to the intermediation model and are subject to the third-party infrastructure failure liability regime set out in Section 12;
• high-value transactions may be subject to additional confirmation periods, operational limits and enhanced due diligence requirements, in accordance with the AML/CFT Policy.

IA TECH PAY remains fully responsible to the User for the correct transmission of the order, the transparency of the quotation, and the provision of information on the progress of the transaction, even though final execution depends on ETHER Exchange's order book.

The User expressly acknowledges and accepts that:

• virtual assets are not legal tender, are not backed by any government guarantee, by the Credit Guarantee Fund (FGC) or equivalent, and may experience significant and sudden price fluctuations;
• IA TECH PAY does not guarantee profitability, appreciation, future liquidity or any financial outcome resulting from the acquisition, custody or trading of virtual assets;
• blockchain-recorded transactions are, by their technological nature, generally irreversible; errors in entering addresses or destination data are the sole responsibility of the User;
• the provision of the services depends on third-party infrastructure (including ETHER Exchange, banking institutions and technology providers), whose unavailability, failure or modification may impact the execution, timing or cost of transactions;
• in OTC transactions and other virtual asset transactions, IA TECH PAY acts as an intermediary before ETHER Exchange's order book, without a proprietary market position, under the terms of Section 6;
• the regulatory environment applicable to virtual assets is developing in all countries of the Territory of Operation and may undergo changes that affect the provision, cost or feasibility of the services.

Nothing in these Terms or in any IA TECH PAY material constitutes investment recommendations or financial, accounting, tax or legal advice. The User should seek independent professional guidance before making financial decisions.

IA TECH PAY maintains an Anti-Money Laundering and Counter-Terrorism Financing program, governed by its publicly available AML/CFT Policy, which establishes the governance, risk assessment, KYC/KYP/KYE procedures, transaction monitoring, Enhanced Due Diligence criteria for PEPs, duties of reporting to competent authorities and record-keeping controls adopted by the company. This Policy forms an integral part of these Terms.

For the execution of this program, the User acknowledges that IA TECH PAY has the right, at any time and without needing the User's prior consent, to:

• monitor, record and analyze transactions carried out on the Platform, including through automated systems for detecting atypical patterns;
• request additional documents and clarifications regarding the origin, nature and destination of funds and virtual assets transferred;
• suspend, hold or temporarily freeze transactions, amounts or Accounts suspected of money laundering, terrorism financing or any other illicit practice, for as long as necessary for the analysis;
• refuse to execute specific transactions, terminate the relationship with the User, or report to the competent authority (Council for Financial Activities Control — COAF, in Brazil; SEPRELAD, in Paraguay; SENACLAFT/Banco Central del Uruguay, in Uruguay; Unidad de Información Financiera — UIF, in Argentina; or equivalent body), whenever required by applicable law;
• apply originator and beneficiary identification procedures (Travel Rule) to virtual asset transfers to and from external wallets, and may condition the execution of the transaction on the identification of the holder of the wallet involved.

Under applicable AML/CFT legislation, IA TECH PAY is not required to inform the User, before or during the course of a report to a competent authority, of the existence, content or reasons for such report ("tipping-off" prohibition). The User's refusal, delay or failure to comply with AML/CFT-related documentation requests constitutes just cause for suspension or termination of the Account.

IA TECH PAY screens Users and, when technically feasible, transaction counterparties, against Restrictive Lists maintained by bodies such as the United Nations, the Office of Foreign Assets Control (OFAC) of the United States, the European Union, and competent national authorities in each Territory of Operation.

The identification of a match, even a partial one, with a person, entity, jurisdiction or virtual asset listed on a Restrictive List authorizes IA TECH PAY to block the transaction, hold the amounts involved and, when applicable, report to the competent authority, regardless of prior notice to the User.

The provision of virtual asset services in Brazil is subject, among other rules, to Law No. 9,613/1998, Law No. 13,260/2016, Law No. 14,478/2022 (Crypto-Assets Legal Framework), and BCB Resolutions No. 519, 520 and 521, of November 10, 2025, which established the prudential regime for Virtual Asset Service Provider Companies ("VASP"/"SPSAV"), in effect since February 2, 2026.

In Brazil, IA TECH PAY provides virtual asset services in its capacity as country correspondent, under CMN Resolution No. 4,935/2021, of the Authorized Institution, a company incorporated in Brazil, member of the ETHER group and duly authorized by the Central Bank of Brazil to operate as a Virtual Asset Service Provider Company, under BCB Resolutions No. 519, 520 and 521/2025. The correspondent agreement between IA TECH PAY and the Authorized Institution has been formalized, as required by applicable regulations. In this capacity, the Authorized Institution is responsible, before the Central Bank of Brazil, for the regulatory supervision of the virtual asset activity carried out through the Platform — without prejudice to IA TECH PAY remaining directly responsible to the User for service, commercial execution and the quality of the services provided, under these Terms.

In the other countries of the Territory of Operation, the User acknowledges that: (i) in Paraguay, virtual asset activity is monitored by the Secretaría de Prevención de Lavado de Dinero o Bienes (SEPRELAD), without a specific law on the licensing of virtual asset service providers yet in force; (ii) in Uruguay, a specific regulatory proposal is underway before SENACLAFT and the Banco Central del Uruguay, still under consultation; and (iii) in Argentina, UIF Resolution No. 49/2024 applies. The correspondent structure described in this Section refers exclusively to the activity regulated by the Central Bank of Brazil, and does not, by itself, extend to the other jurisdictions of the Territory of Operation. IA TECH PAY monitors these regulatory developments and may update these Terms, the Fee Schedule, or the availability of services in a given territory to comply with new legal requirements, at any time.

Without prejudice to other obligations set out in these Terms, the User agrees to:

• maintain the confidentiality of their access credentials and immediately notify IA TECH PAY in the event of suspected unauthorized access;
• use the Platform exclusively for lawful purposes, and its use for money laundering, terrorism financing, fraud, tax evasion or any other illicit activity is prohibited;
• not attempt to circumvent, manipulate or test the Platform's risk, KYC or AML/CFT controls;
• comply with their tax obligations related to the transactions carried out, with the calculation and payment of taxes being their sole responsibility;
• not assign, transfer or share their Account with third parties.

Failure to comply with any of these obligations authorizes IA TECH PAY to suspend or terminate the Account, without prejudice to any other legally applicable measures.

IA TECH PAY will use its best efforts to keep the Platform available, secure and in compliance with applicable regulations, in accordance with market standards for services of the same nature.

IA TECH PAY will not be liable for: (i) indirect damages, loss of profits or loss of opportunity; (ii) price fluctuations of virtual assets; (iii) unavailability, delay or failure resulting from third-party infrastructure, including ETHER Exchange, partner financial institutions, internet or cloud providers; (iv) events of fortuitous case or force majeure; and (v) acts or omissions of the User, including errors in entering transaction data. In OTC transactions and other virtual asset transactions described in Section 6, IA TECH PAY's liability is limited to the correct transmission of the order, the transparency of the quotation, and diligence in intermediation before ETHER Exchange, and does not extend to price fluctuations or execution and settlement failures occurring on ETHER Exchange's order book. Nothing in these Terms excludes liability in cases where applicable law prohibits such limitation, including instances of willful misconduct or gross negligence by IA TECH PAY.

IA TECH PAY may suspend, preventively block or terminate the User's Account, in whole or in part, in the following cases, among others: reasonable suspicion of AML/CFT violations; non-compliance with these Terms or the AML/CFT Policy; identification on a Restrictive List; order of a judicial, administrative or regulatory authority; indications of fraud; and prolonged Account inactivity, under terms to be defined in a specific policy.

Whenever legally permitted, IA TECH PAY will notify the User of the reason for the measure adopted and the means of contesting it through the customer service channel. In cases where notification to the User is prohibited by an AML/CFT rule (tipping-off prohibition) or by order of a competent authority, IA TECH PAY may adopt the measure without prior or concurrent notice.

The IA TECH PAY brand, its logo, layout, software, content and other elements of the Platform are owned by IA TECH PAY or its licensors, protected by applicable intellectual property legislation. These Terms do not grant the User any license to use such elements beyond what is strictly necessary for personal, non-commercial use of the Platform.

The processing of the User's personal data complies with the General Data Protection Law (Law No. 13,709/2018 — LGPD) and applicable data protection legislation in the other countries of the Territory of Operation, as detailed in IA TECH PAY's Privacy Policy, an integral part of these Terms.

The User acknowledges and authorizes that personal and transactional data be shared with competent regulatory and AML/CFT authorities, with the ETHER Exchange infrastructure partner, and with other service providers necessary for the execution of transactions, strictly to the extent required for compliance with a legal obligation or for the performance of the contracted services.

Questions, requests and complaints may be directed to IA TECH PAY's official customer service channel: [email/phone/channel to be defined by the Board of Directors]. Requests related to AML/CFT, including requests for clarification about Account blocking, must be directed to the compliance channel: [channel to be defined by the Board of Directors].

IA TECH PAY may amend these Terms at any time, by publishing the updated version on the Platform and notifying the User through an official channel, with at least 15 (fifteen) days' notice prior to the effective date of the changes, except when the change results from a legal or regulatory requirement of immediate application. Continued use of the Platform after the notice period constitutes tacit acceptance of the new version. The User is advised to periodically review these Terms.

• These Terms, the AML/CFT Policy and the Privacy Policy constitute the entire agreement between the parties regarding their subject matter.
• The invalidity of any clause does not affect the validity of the remaining clauses, which remain in full force and effect.
• Leniency regarding any non-compliance with any provision does not constitute a novation or waiver of the right to demand compliance at any time.
• The User may not assign or transfer their contractual position without IA TECH PAY's prior written consent.
• The Portuguese-language version of these Terms prevails over any translations made available for the convenience of Users in other countries of the Territory of Operation.

These Terms are governed by the laws of the Federative Republic of Brazil. The courts of [city to be defined by the Board of Directors] are hereby elected, with waiver of any other, however privileged, to settle disputes arising from these Terms, except for the application of jurisdiction or mandatory consumer protection rules that may be in force in the User's jurisdiction of residence, when they cannot be excluded by contractual election.

For Users domiciled in Paraguay, Uruguay or Argentina, the mandatory consumer protection and antitrust rules in force in each country additionally apply, to the extent they do not conflict with the Brazilian legislation applicable to IA TECH PAY.

Acceptance of these Terms occurs electronically, by selecting the corresponding option in the Platform's registration flow. IA TECH PAY will record the date, time and IP address associated with the acceptance, for purposes of evidencing the User's manifestation of intent, under article 10, paragraph 2 of Provisional Measure No. 2,200-2/2001 and applicable legislation.

By completing registration, the User declares to have had full opportunity to read and understand these Terms, the AML/CFT Policy and the Privacy Policy before expressing their acceptance.