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USER AGREEMENT

Revision date — 23.09.2026

1. Company Information

This User Agreement governs the use of the service provided by SoftVision Innovations S.A. (hereinafter, the "Company").

Company details:

Name: SoftVision Innovations S.A.

Address: 10th Floor, Plaza 2000 Tower, 50th Street, Panama, Republic of Panama

Registration number (RUC): 155765203 (date of registration — 1 April 2025)

Email: info@crypto-office.com

Phone: +971 52 725 0099

The Company provides services through the Crypto Office service, which includes the Telegram Mini App (@officeapp), the Telegram bot (@office_app_bot), the support bot (@office_app_support_bot) and the web interface https://crypto-office.com (hereinafter jointly, the "Service" or the "Platform").

The Company provides software and technical (IT) services by granting Users access to specialised software. The Company is not a bank, licensed financial institution, investment fund or payment system under the laws of the Republic of Panama and does not carry out licensable financial activities.

Access to certain third-party functional modules within the Service (including the Card Service — Office Card) is provided to engaged independent operators in accordance with clause 6.3 of this Agreement.

2. General Glossary

The AML/KYC Policy and the Privacy Policy form an integral part of this Agreement.

The terms and definitions used and established in this document have integral meanings and apply uniformly across all documents of the Company published on the website.

  • Custodial Service — a model of service provision by the Company under which the User's virtual assets are stored using Custodial Wallets, and the private keys thereto are generated and stored by the Company on behalf of the User.
  • Custodial Wallet — a wallet whose private keys are generated and stored by the Company on behalf of the User, used for storing virtual assets and for performing sending and exchange operations within the Service. The User may be provided with several Custodial Wallets; the legal regime of all such wallets is identical.
  • Independent (External) Wallet — a wallet controlled by the User independently and located outside the Company's infrastructure.
  • Partner Exchange/Liquidity Provider — a licensed third party that ensures the execution of virtual asset exchange operations.
  • Technology Intermediary — the Company, which provides technical support for cryptocurrency exchange operations and transmits Users' orders to Partner Exchanges or Liquidity Providers for execution.
  • AML/CFT — countering the laundering of proceeds of crime and the financing of terrorism.
  • AML (Anti-Money Laundering) — a set of measures, procedures and requirements aimed at preventing the use of the financial system and virtual assets for the legalisation (laundering) of proceeds of crime.
  • Referral Partner — a user who participates in the Company's referral programme and receives remuneration from the fees on actual operations of Users invited by them.
  • Card Service (Office Card module) — a third-party functional module within the Platform, provided by the independent company Financial Services LTD (England and Wales), which provides the User with a software interface for applying for, topping up and managing payment cards of independent Issuing Partners.

3. Introduction

PLEASE READ THIS AGREEMENT CAREFULLY BEFORE USING THE PLATFORM OR ANY SERVICE PROVIDED BY THE COMPANY.

By using the Service via Telegram or the website, you (hereinafter, the "User") confirm that you have read this User Agreement (hereinafter, the "Agreement"), the Privacy Policy and the AML/KYC Policy , understand their terms and agree to comply with them.

This Agreement governs the relations between the User and the Company arising in connection with access to and use of the Service.

4. Eligibility

By accessing the Company's Service, the User represents and warrants that:

  • they have reached the age of 18, the age of majority or full legal capacity under the laws of their jurisdiction;
  • they have full legal capacity and the legal right to enter into this Agreement;
  • they act in their own name and in their own interests;
  • all data provided by them is accurate and up to date;
  • all cryptocurrency assets and funds provided by them for carrying out operations through the Company belong to them by right of ownership and have been obtained exclusively by lawful means.

5. Status of the Service

5.1. The Platform is a Custodial Service solely in respect of funds held in the User's Custodial Wallets, and a Technology Intermediary with regard to cryptocurrency exchange.

The Company creates cryptocurrency wallets and stores the private keys relating to them on behalf of the User. The User is not provided with the seed phrase or private keys and cannot dispose of funds bypassing the Company's infrastructure.

When initiating the exchange procedure, the User gives the Company a direct instruction to withdraw the target funds from custodial storage and transfer them to the Partner. The custodial storage regime in respect of such funds terminates at the moment of their transfer to the Partner Exchange or Liquidity Provider, as determined in accordance with clause 10.2 of this Agreement. The actual execution of exchange operations is carried out by licensed Partner Exchanges and Liquidity Providers, and not by the Company.

5.2. When the User creates an instruction to top up the third-party Card Service (via the Office Card module), the User's digital assets are sent from the Custodial Wallet to CEX exchanges for their immediate automatic conversion into fiat currency. The Platform's custodial storage regime in respect of such assets terminates at the moment they are sent for conversion (the sending of the transaction to the blockchain network to the address of the CEX exchange). The actual crediting, accounting and storage of fiat funds are carried out exclusively on the side of independent Issuing Partners.

6. Scope of Services

6.1. Management Tools

The Company provides tools for professional cryptocurrency management, including:

  • AML checks of cryptocurrency wallets;
  • routing and technical support of cryptocurrency exchange operations through Partner Exchanges;
  • creation and management of Custodial Wallets;
  • tools for recording operations and generating reports;
  • purchase of energy in the TRON network;
  • bulk transfers and automated payouts;
  • wallet monitoring services;
  • cheques and invoices;
  • contact management;
  • a referral system.

Cryptocurrency exchange is carried out with the assistance of the Company acting as a Technology Intermediary. The actual execution of the exchange operation is performed by licensed Partner Exchanges or Liquidity Providers in accordance with their own regulatory requirements, based on the relevant jurisdictions.

The list of services and related fees is dynamic and subject to change. Current limits, fees and available features are always visible in the "Settings" section of the bot or on the website.

6.2. Specifics of Virtual Asset Storage

The User understands and agrees that the Company provides the User with Custodial Wallets, in the use of which private keys are generated and stored by the Company. Use of the Service constitutes the User's consent to this method of storing and managing virtual assets.

6.3. Integration of Third-Party Modules and Payment Card Service:

The Platform may provide the User with access to third-party software modules and integrations, including the Card Service — Office Card. The User understands and agrees that the Card Service is provided by an independent company — Financial Services LTD (England and Wales). The terms of use of this module and the procedure for processing data when using it are governed by the User Agreement of the Office Card Service and the Privacy Policy of the Office Card Service, which the User undertakes to review before starting to use the module.

The Company provides solely the technical infrastructure (Telegram Mini App / Bot) for access to the said module and is not a card issuer or a payment service provider.

7. Compliance and AML/KYC

The Company complies with applicable AML/CFT rules and cooperates with certified third-party providers of blockchain analysis and wallet screening services.

The Company does not carry out regular KYC verification upon registration and by default does not collect or store the User's identity documents. In exceptional cases — upon a Freeze or blocking of funds by a Partner Exchange or Liquidity Provider, upon Blocking of a Custodial Wallet in accordance with clause 10.6 of this Agreement, and at the request of competent public authorities — the Company may request minimal identification information from the User solely for the purpose of resolving the relevant situation. Such data, if collected, is processed confidentially and stored in the manner set out in Section 5 of the Privacy Policy. The procedure for AML/KYC checks is determined by the AML/KYC Policy.

The Company provides software and technical services (software) and is not a licensed bank or financial institution in Panama.

8. Login Methods, Security and Confidentiality

8.1. Authentication Methods

The Platform supports several login methods:

  • Telegram Mini App (@officeapp) and Telegram bot (@office_app_bot) — the main method of registration and login;
  • email + 2FA — available via the web version after activation;
  • API key.

The User may choose the most convenient method for further use.

8.2. The User may:

  • use the Platform's functionality for operations (exchanges, payments, sending);
  • withdraw funds to an Independent (External) Wallet after an operation;
  • independently determine the volume of virtual assets placed in Custodial Wallets, guided by their own financial risk management standards.

8.3. User's Responsibility

The User bears full responsibility for the security of:

  • their Telegram account (for login via the bot);
  • their email (for login via the web version);
  • their 2FA codes;
  • preventing third-party access to any of these methods.

8.4. Company's Responsibility

The Company takes reasonable organisational and technical measures to protect Users' data and virtual assets, including encryption of data transmission, control of access to information systems and ensuring the security of Custodial Wallets managed within the Platform.

At the same time, the Company does not guarantee absolute protection against unauthorised access, cyberattacks, technical failures or other circumstances beyond its reasonable control.

8.5. Limitations

The Company cannot guarantee protection against:

  • technical failures of the Telegram platform itself;
  • failures of blockchain infrastructure;
  • compromise of the User's device (viruses, keyloggers).

In these cases, responsibility lies with the User or third parties (Telegram Inc., blockchain networks), and not with the Platform.

9. Acceptable Use

The User agrees not to use the Platform for:

  • money laundering, terrorist financing or other illegal activities;
  • conducting illegal gambling or high-risk operations;
  • circumventing sanctions or committing fraudulent acts;
  • performing actions that may disrupt the provision of services.

The Company reserves the right to restrict, suspend or terminate the User's access to the Platform in the event of violations.

10. Disclaimer of Liability

10.1. The Company shall not be liable for the following circumstances and their consequences:

  • failures, delays or unavailability of Telegram, blockchain networks, third-party APIs, Partner Exchanges, Liquidity Providers and other external services;
  • changes in the market value of virtual assets (volatility), including changes in their value during AML/KYC checks, the processing of operations or the execution of an exchange;
  • errors, inability to execute operations or losses arising as a result of the User providing incorrect, incomplete or inaccurate data, including incorrect wallet addresses, details or other instructions;
  • the origin, legal purity and history of virtual assets provided by the User;
  • suspension, blocking, Freeze, withholding or refusal to execute operations by a Partner Exchange, Liquidity Provider or other third party in accordance with their internal compliance procedures or the requirements of applicable law;
  • non-performance or improper performance of obligations due to force majeure circumstances, including changes in legislation, the imposition of sanctions, decisions of public authorities, military actions, terrorist acts, mass riots, natural disasters, accidents, communication outages and other circumstances beyond the Company's reasonable control;
  • any indirect, incidental, special or consequential damages, including loss of profit, loss of income or other financial losses, unless otherwise provided by applicable law;
  • claims, demands or lawsuits brought against the User or the Company by competent public authorities, Partner Exchanges/Liquidity Providers or other third parties in connection with the User's operations, unless such claims are caused by culpable acts or omissions of the Company.

10.2. Line of Responsibility by Stage of Operation

1 — the funds are held in the User's Custodial Wallet. The Company is responsible for the security of their storage within the limits of reasonable measures; responsibility for the origin and legal purity of the funds lies with the User.

2 — the funds have been transferred to a Partner Exchange or Liquidity Provider for the execution of the exchange (including card top-up operations in the Office Card module): from the moment the transactions are sent to the blockchain network, the funds leave the control and custodial storage of the Company. The compliance procedures, rules and restrictions of the relevant CEX exchanges and card Issuing Partners apply to conversion operations and the subsequent crediting of fiat funds. Cancellation or reversal of the operation by the Company is technically impossible; the Company shall not be liable for delays, blocking, Freeze or refusal to credit funds on the side of CEX exchanges or Issuing Partners.

3 — the exchange has been executed, and the result has been credited or withdrawn according to the User's instruction. After confirmation on the blockchain, the operation is final and non-refundable.

In the event of Suspension of an operation by the Company itself (for example, following an AML check), when the funds are still held in the User's Custodial Wallet and are not withheld by third parties, the User may request the return of the funds to the Independent (External) Wallet less network and service fees.

The moment of transfer of funds to a Partner Exchange or Liquidity Provider shall be deemed to be: where the operation is executed by means of a transfer in the blockchain network — the formation and sending of the transaction to the wallet address of the Partner Exchange or Liquidity Provider; where the operation is executed by means of an API without a transfer in the blockchain network — confirmation by the Partner Exchange or Liquidity Provider of receipt of the API exchange request.

The Company assists in transmitting the User's requests to the Partner but does not act as a respondent in disputes between the User and the Partner Exchange.

Where sanctions risks are identified (including the presence of the address of the counterparty to the operation on the OFAC, EU, UN and other sanctions lists), the Company reserves the right to refuse to provide the Service in respect of a specific transaction. In such case, the exchange operation is not created, and the funds remain in the User's Custodial Wallet. The refusal to carry out the operation does not in itself entail Blocking of the Custodial Wallet; withdrawal of funds to an Independent (External) Wallet remains available unless Blocking has been imposed on that Custodial Wallet in accordance with clause 10.6 of this Agreement. The Company shall not be liable for any losses of the User caused by the refusal to carry out such operation.

10.3. AML Check and Intermediary Status

The Company gives priority attention to compliance with AML/CFT requirements and carries out AML checks of wallets and transactions using certified third-party blockchain analysis tools on the basis of the principle of reasonable and sufficient efforts.

The procedure for AML checks and the limitations of AML monitoring are determined by Section 3 of the AML/KYC Policy.

10.4. Acknowledgement and Agreement

Taking into account the Company's status as a Technology Intermediary and the objective limitations of AML monitoring systems, the Parties agree as follows:

  • Responsibility for assets: Successful completion of an AML check on the Platform is not an absolute guarantee of the legality of the funds. The performance of an AML check by the Company does not release the User from the obligation to provide funds of lawful origin and does not transfer to the Company responsibility for their origin. The User bears sole responsibility for the legal purity and lawful origin of the assets provided.
  • Settlement of claims: In the event of blocking, Freeze of funds or claims by Partner Exchanges/Liquidity Providers or competent authorities, the User undertakes to settle such disputes independently and to undergo the necessary KYC/AML procedures at the request of the withholding party. In such cases, the Company shall not be financially liable, but provides the User with reasonable informational and technical assistance to resolve the situation. The procedure for Blocking of Custodial Wallets by the Company is set out in clause 10.6 of this Agreement.

10.5. Interaction with Public Authorities

The Company provides information about Users and their operations to public authorities in the manner and on the grounds set out in clause 4.4 of the Privacy Policy.

10.6. Blocking of Custodial Wallets

The Company may temporarily block the User's Custodial Wallet if its address is included in sanctions lists, high-risk lists or other restrictive lists, including upon notification from a Partner Exchange or Liquidity Provider, as well as upon an official request or order of a competent public authority, or where an AML check reveals indications of a connection between the virtual assets held in the wallet and unlawful activity.

Blocking applies to the entire Custodial Wallet concerned and to all virtual assets held in it, regardless of their origin; sending, exchange and withdrawal operations from it are unavailable for the period of Blocking. Blocking does not affect the User's other Custodial Wallets.

Blocking is imposed for the period necessary to clarify the circumstances and is lifted once the circumstances that served as its grounds have been eliminated. The Company notifies the User of the imposition of Blocking and, where possible, of its grounds, except where the disclosure of such information is prohibited by applicable law or by the terms of the competent authority's request.

Blocking does not entail the transfer of rights to the virtual assets to the Company; the User's rights to them are retained unless otherwise follows from a decision of a competent authority. The Company shall not be liable for the User's losses caused by Blocking on the said grounds, including losses from changes in the exchange rate of virtual assets during the period of Blocking.

10.7. The aggregate financial liability of the Company for any lawsuits, claims or demands related to this Agreement or the use of the Service is limited to the greater of the following amounts:

a) USD 2,000 (two thousand US dollars); or

b) the aggregate amount of fees actually paid by the User to the Company for the 3 (three) months preceding the occurrence of the grounds for the claim, regardless of which operation they relate to.

This limitation does not apply to the Company's obligation to return to the User the virtual assets held in their Custodial Wallet.

10.8. Nothing in this Agreement excludes or limits the Company's liability for wilful misconduct or gross negligence, or any other liability the limitation of which is expressly prohibited by mandatory provisions of applicable law.

11. Fees and Refunds

A fee is charged for all actions in the bot that require a service charge, such as transfers, wallet operations or other Platform functions. It is always displayed in advance, before confirmation, and does not change after it. There are no hidden or background payments.

All transaction fees are displayed before confirmation. After confirmation on the blockchain, transactions become final and non-refundable. The current fee structure and limits can always be viewed in the "Settings" section of the Platform.

Two rate options are available for currency exchange:

  • Fixed Rate: the exact amount to be debited is displayed before the transaction is confirmed. The rate is fixed at the moment of the exchange, which ensures a predictable result.
  • Floating Rate: the rate is dynamic and may change depending on market conditions.

This option usually involves a slightly lower fee but may result in minor fluctuations in the final exchange amount.

12. Withdrawal of Virtual Assets

  • The User may at any time submit a request to withdraw virtual assets from the Custodial Wallet to an Independent (External) Wallet belonging to them, unless otherwise provided by this Agreement, including clause 10.6, the AML/KYC Policy or the requirements of applicable law.
  • Before executing a withdrawal, the Company may carry out the necessary security checks, including AML/KYC checks.
  • In the absence of restrictions, the withdrawal is carried out within a reasonable time after confirmation of the operation and completion of the necessary checks.
  • Applicable blockchain network fees and Service fees are deducted from the withdrawal amount.
  • The Company may temporarily suspend a withdrawal in the cases provided for by this Agreement, including Blocking of a Custodial Wallet in accordance with clause 10.6, by the AML/KYC Policy, by the requirements of competent public authorities or by the rules of a Partner Exchange or Liquidity Provider.
  • The User is responsible for correctly specifying the address of the Independent (External) Wallet. The Company shall not be liable for the inability to execute the operation or the loss of virtual assets caused by the User providing an incorrect or invalid address.

13. Referral Programme

Referral Partners receive remuneration solely from a portion of the fee received by the Company from operations actually performed by Users invited by them. In the absence of such operations, no remuneration is accrued.

The Platform uses a three-level remuneration system:

  • first level — 15%;
  • second level — 5%;
  • third level — 2%.

The Company may at any time change the terms of participation, the amounts of remuneration or the structure of the referral programme.

The referral programme is intended solely to reward Users for attracting new users to the Service. The Company does not accept funds or virtual assets into trust management, does not offer investment products, does not guarantee income and does not pay remuneration for the storage of funds or for the mere fact of participation in the programme.

Any User may participate in the referral programme subject to compliance with the terms of this Agreement. The Company does not control the methods by which third parties disseminate information about the Service and shall not be liable for statements, promises or guarantees made by Users or other persons on their own behalf who are not authorised to act on behalf of the Company.

14. Data and Confidentiality

The Company stores the data necessary for the functioning of the Custodial Service and compliance with requirements: the Telegram ID, the linking of Custodial Wallets to the User, transaction history, and technically protected private keys to wallets under the Company's management.

The Company does not store identity documents on a permanent basis and does not collect excessive Personal Data beyond what is necessary to provide services and to comply with AML/legal requirements.

The procedure for the collection, Processing, storage and transfer of Users' Personal Data is determined by the Privacy Policy.

15. Governing Law and Dispute Resolution

15.1. The Company is registered in the Republic of Panama and provides services in strict compliance with the applicable laws of that jurisdiction.

15.2. Dispute Resolution

  • Before applying to court, the User undertakes to send a request (claim) via the Service's support service or to the Company's email.
  • The Company considers the request and provides a response, as a rule, within 30 (thirty) calendar days from the date of its receipt, unless a different period is required due to an additional review.
  • The Parties seek to settle disputes and disagreements arising between the Company and the User through negotiations and through pre-trial consideration of requests.
  • If the dispute cannot be settled through pre-trial settlement (by negotiations), it shall be subject to consideration by the competent courts of the Republic of Panama at the Company's location, applying the substantive law of the Republic of Panama, unless otherwise mandatorily provided by applicable law.
  • The official communication channels for submitting requests are the Company's email info@crypto-office.com and the Service's support in Telegram @office_app_support_bot.

15.3. Prevailing Language of the Document

This Agreement has been drawn up in the English language. Versions in other languages are provided solely for the convenience of Users. In the event of any discrepancies or contradictions between the English version and a version in another language in the resolution of property, custodial or contractual disputes, the English version shall prevail.

16. Amendments

The Company may make amendments to this Agreement. The new version is published on the Website indicating the revision date.

Scheduled amendments take effect upon the expiry of 7 (seven) calendar days from the date of publication. Before they take effect, a User who does not agree with the amendments may stop using the Service and withdraw their assets.

Amendments arising from the requirements of applicable law, orders of competent public authorities, requirements of Partner Exchanges or Liquidity Providers, changes in blockchain network fees, as well as the need to eliminate threats to the security of the Service, take effect from the moment of publication. In this case, a User who does not agree with the amendments may stop using the Service and withdraw their assets, except in the cases provided for in clause 10.6 of this Agreement.

Continued use of the Service after the amendments take effect constitutes the User's acceptance of the new version.

17. Contacts

For all questions related to the use of the Service, the User may contact the Company using the following contact details:

Legal name: SoftVision Innovations S.A.

Registered address: 10th Floor, Plaza 2000 Tower, 50th Street, Panama, Republic of Panama

Registration number (RUC): 155765203

Phone: +971 52 725 0099

Email: info@crypto-office.com

Website: https://crypto-office.com

Support: via Telegram bot @office_app_support_bot

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