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USER AGREEMENT

Revision date — 10 August 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 incorporation — 1 April 2025)

Email: info@crypto-office.com

Phone: +971 52 725 0099

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

2. General glossary

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

The terms and definitions set out in this document are binding and apply consistently across all Company documents published on the website.

  • Custodial service — the service model under which the Company stores the User's virtual assets using Custodial Wallets, with the private keys thereto created and held by the Company on behalf of the User.
  • Custodial Wallet — a wallet the private keys to which are created and held by the Company on behalf of the User, used for storing virtual assets and for carrying out send and exchange transactions within the Service. A 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 themselves, residing outside the Company's infrastructure.
  • Partner Exchange / Liquidity Provider — a licensed third party that executes virtual asset exchange transactions.
  • Technology Intermediary (broker) — the Company, providing technical support for cryptocurrency exchange transactions and routing Users' orders to Partner Exchanges or Liquidity Providers for execution.
  • AML/CFT — anti-money laundering and countering the financing of terrorism.
  • AML (Anti-Money Laundering) — the set of measures, procedures and requirements aimed at preventing the use of the financial system and of virtual assets for the laundering of proceeds of crime.
  • Referral Partner — a user participating in the Company's referral programme and receiving remuneration out of the fees on actual transactions of the Users they have invited.

3. Introduction

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

By using the Service through Telegram or the website, you (hereinafter — the "User") confirm that you have read this User Agreement (hereinafter — the "Agreement"), understand its terms and agree to be bound by them.

This Agreement governs the relationship 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 attained the age of 18, the age of majority or full legal capacity under the laws of their jurisdiction;
  • have full legal capacity and the legal right to enter into this Agreement;
  • act on their own behalf and in their own interests;
  • have provided data that is accurate and up to date;
  • hold title to all cryptocurrency assets and funds provided by them for transactions through the Company, and such assets and funds have been obtained solely by lawful means.

5. Status of the Service

The Platform acts as a Custodial service solely in respect of funds held in the User's Custodial Wallets, and as a Technology Intermediary (broker) in respect of cryptocurrency exchange.

The Company creates cryptocurrency wallets and holds the private keys relating thereto on behalf of the User. The User is not provided with the seed phrase or the private keys and may not deal with the funds otherwise than through the Company's infrastructure.

Upon initiating an exchange, the User gives the Company an express instruction to release the relevant funds from custodial storage and transfer them to the Partner. Custodial storage of such funds ceases upon their transfer to a Partner Exchange or a Liquidity Provider, as determined in accordance with clause 10.2 of this Agreement. Exchange transactions are executed by licensed Partner Exchanges and Liquidity Providers, and not by the Company.

6. Scope of services

6.1. Management tools

The Company provides tools for the professional management of cryptocurrency, including:

  • AML screening of cryptocurrency wallets;
  • routing and technical support of cryptocurrency exchange transactions through Partner Exchanges;
  • creation and management of Custodial Wallets;
  • accounting and bookkeeping;
  • purchase of energy on the TRON network;
  • bulk transfers and automated payouts;
  • wallet monitoring services;receipts and invoices;
  • contact management;
  • referral system.

Cryptocurrency exchange is carried out with the assistance of the Company acting as a Technology Intermediary (broker). The exchange transaction itself is executed by licensed Partner Exchanges or Liquidity Providers in accordance with their own regulatory requirements in their respective jurisdictions.

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

6.2. Virtual asset storage arrangements

The User understands and agrees that the Company provides the User with Custodial Wallets, the private keys to which are created and held by the Company. Use of the Service constitutes the User's consent to such method of storage and management of virtual assets.

7. Compliance and AML/KYC

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

The Company does not carry out regular KYC verification upon registration and does not by default collect or store identity documents of the User. In exceptional cases — where funds are frozen or blocked by a Partner Exchange or a Liquidity Provider, where a Custodial Wallet is blocked in accordance with clause 10.6 of this Agreement, or upon the demand of competent state 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 deleted once the situation has been resolved.

For further details, see the "AML/KYC Policy".

8. Login methods, security and confidentiality

8.1. Authentication methods

The Platform supports several login methods:

  1. Telegram Mini App (@officeapp) and Telegram bot (@office_app_bot) — the primary method of registration and login;
  2. email + 2FA — available through the web version once enabled;
  3. API key.

The User may choose whichever method is most convenient for ongoing use.

8.2. The User may

  • use the Platform's functionality for transactions (exchanges, payments, sending);
  • withdraw funds to an Independent (external) wallet following a transaction;
  • refrain from leaving large amounts in permanent storage within the Service. This is a more secure approach. The Platform supports it.

8.3. User 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 responsibility

The Company takes reasonable organisational and technical measures to protect Users' data and virtual assets, including encryption of data in transit, access controls over information systems, and safeguarding the Custodial Wallets managed within the Platform.

At the same time, the Company does not warrant 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 such cases liability rests with the User or with 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 unlawful activity;
  • unlawful gambling or high-risk operations;
  • circumventing sanctions or committing fraud;
  • any acts that may disrupt the provision of the services.

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

10. Disclaimer of liability

10.1. The Company shall not be liable for the following circumstances or 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 screening, transaction processing or execution of an exchange;
  • errors, failure to execute transactions or losses arising from the User providing incorrect, incomplete or inaccurate data, including incorrect wallet addresses, details or other instructions;
  • the origin, lawfulness and history of the virtual assets provided by the User;
  • suspension, blocking, freezing, withholding or refusal to execute transactions by a Partner Exchange, a Liquidity Provider or any other third party in accordance with their internal compliance procedures or the requirements of applicable law;
  • failure to perform or improper performance of obligations due to force majeure, including changes in legislation, the imposition of sanctions, decisions of state authorities, military action, acts of terrorism, civil unrest, natural disasters, accidents, communications outages and other circumstances beyond the Company's reasonable control;
  • any indirect, incidental, special or consequential losses, including lost profits, loss of revenue or other financial losses, unless otherwise provided by applicable law;
  • claims, demands or actions brought against the User or the Company by competent state authorities, Partner Exchanges / Liquidity Providers or other third parties in connection with the User's transactions, where such claims do not arise from the Company's culpable acts or omissions.

10.2. Allocation of liability by transaction stage

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 lawfulness of the funds rests with the User.

2 — the funds have been transferred to a Partner Exchange or a Liquidity Provider for execution of the exchange. From that moment the funds cease to be under the Company's control, the compliance procedures and policies of the relevant Partner apply, and cancellation or reversal of the transaction by the Company is technically impossible. The Company is not responsible for any suspension, delay, blocking or freezing of funds on the side of the Partner Exchange or Liquidity Provider.

3 — the exchange has been executed and the proceeds credited or withdrawn in accordance with the User's instruction. Once confirmed on the blockchain, the transaction is final and irreversible.

If the transaction is suspended by the Company itself (for example, following an AML check), while the funds are still held in the User's Custodial Wallet and have not been seized or held by any third party, the User shall have the right to request a refund of the funds to the original address, less any applicable network and service fees.

The moment of transfer of funds to a Partner Exchange / Liquidity Provider is deemed to be the creation and broadcast of the transaction on the relevant blockchain network to the Partner's wallet address / confirmation of receipt of the API request for the exchange.

The Company assists in routing the User's requests to the Partner but is not a party respondent in disputes between the User and the Partner Exchange.

Where sanctions risks are identified (including where the address of the counterparty to the transaction appears on the sanctions lists of OFAC, the EU, the UN and others), the Company reserves the right to refuse to provide the Service in respect of a specific transaction. In such case the exchange transaction is not created and the funds remain in the User's Custodial Wallet. A refusal to carry out a transaction does not of itself entail the blocking of the Custodial Wallet; withdrawal of funds to an Independent (external) wallet remains available unless the Custodial Wallet in question has been blocked in accordance with clause 10.6 of this Agreement. The Company shall not be liable for any losses of the User arising from the refusal to carry out such a transaction.

10.3. AML screening and intermediary status

The Company treats AML/CFT compliance as a priority and screens wallets and transactions using certified third-party blockchain analytics tools on a reasonable efforts basis.

10.4. Acknowledgement and agreement

Having regard to the Company's status as a Technology Intermediary and to the inherent limitations of AML monitoring systems, the Parties agree as follows:

  • Responsibility for assets: Successful AML screening on the Platform does not constitute an absolute guarantee of the lawfulness of the funds. The Company's AML screening does not release the User from the obligation to provide funds of lawful origin and does not transfer responsibility for their origin to the Company. The User bears sole responsibility for the lawfulness and lawful origin of the assets provided.
  • Resolution of claims: In the event of blocking or freezing of funds, or of claims brought by Partner Exchanges / Liquidity Providers or competent authorities, the User undertakes to resolve such disputes independently and to complete the necessary KYC/AML procedures as required by the withholding party. The Company bears no financial liability in such cases but shall provide the User with reasonable informational and technical assistance in resolving the matter. The procedure for the blocking of Custodial Wallets by the Company is set out in clause 10.6 of this Agreement.

10.5. Dealings with state authorities

The Company discloses information on Users and their transactions to competent authorities solely upon a legally binding and duly issued request from the authorised bodies of the Republic of Panama, or under formal mutual legal assistance procedures (subject to the terms of the Privacy Policy).

At the same time, the Company acts in defence of Users' interests and reserves the right to reject or challenge requests from any (including foreign) state, law enforcement or judicial authorities where such requests are excessive, unfounded or lack proper legal basis under applicable law.

10.6. Blocking of Custodial Wallets

The Company may temporarily block a User's Custodial Wallet where its address appears on sanctions lists, high-risk lists or other restrictive lists, including upon notification from a Partner Exchange or a Liquidity Provider, as well as upon an official request or order of a competent state authority, or where AML screening identifies indicators linking the virtual assets held in the wallet to unlawful activity.

The block applies to the whole of such Custodial Wallet and to all virtual assets held in it irrespective of their origin; send, exchange and withdrawal transactions from it are unavailable for the duration of the block. The block does not affect the User's other Custodial Wallets.

The block is imposed for the period necessary to establish the circumstances and is lifted once the grounds for it have ceased to apply. The Company shall notify the User of the imposition of the block and, where possible, of its grounds, except where disclosure of such information is prohibited by applicable law or by the terms of the request of a competent authority.

The block does not transfer title to the virtual assets to the Company; the User's rights in them are preserved, unless otherwise required by a decision of a competent authority. The Company shall not be liable for any losses of the User arising from a block imposed on the above grounds, including losses resulting from changes in the exchange rate of the virtual assets during the block.

11. Fees and refunds

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

All transaction fees are displayed before confirmation. Once confirmed on the blockchain, transactions become final and non-refundable. The current fee structure and limits may be viewed at any time 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 locked in at the time of the exchange, which ensures a predictable outcome.
  • Floating rate: the rate is dynamic and may change in line with market conditions.

This option usually carries 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 a Custodial Wallet to an Independent (external) wallet belonging to them, unless otherwise provided by this Agreement, including clause 10.6, by the AML/KYC Policy or by the requirements of applicable law.
    Before executing a withdrawal, the Company may carry out the necessary security checks, including AML/KYC screening.
  • Absent any restrictions, the withdrawal is executed within a reasonable time after confirmation of the transaction 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 the blocking of a Custodial Wallet under clause 10.6, by the AML/KYC Policy, by the requirements of competent state authorities or by the rules of a Partner Exchange or Liquidity Provider.
  • The User is responsible for the accuracy of the Independent (external) wallet address provided. The Company shall not be liable for failure to execute a transaction or for the loss of virtual assets caused by the User providing an incorrect or invalid address.

13. Referral programme

Referral Partners receive remuneration solely out of a share of the fees earned by the Company on transactions actually carried out by the Users they have invited. Where no such transactions take place, no remuneration accrues.

Referral Partners receive remuneration exclusively from a portion of the fees received by the Company from transactions actually carried out by the Users they have referred. In the absence of such transactions, no remuneration shall be accrued.

The Platform operates a three-tier remuneration structure:

  • tier one — 15%;
  • tier two — 5%;
  • tier three — 2%.

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

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

Any User may take part in the referral programme subject to compliance with the terms of this Agreement. The Company does not control how information about the Service is disseminated by third parties and shall not be liable for statements, promises or guarantees made by Users or other persons acting on their own behalf and not authorised to act on behalf of the Company.

14. Data and confidentiality

The Company retains the data necessary for the operation of the Custodial service and for compliance purposes: the Telegram ID, the mapping of Custodial Wallets to the User, transaction history, and securely encrypted private keys to the wallets under the Company's management.

The Company does not retain identity documents on a permanent basis and does not collect personal data beyond what is necessary for the provision of services and for AML and statutory compliance.

15. Governing law and dispute resolution

15.1. The Company is incorporated and operates in accordance with the applicable law of its jurisdiction of incorporation and complies with the requirements applicable to the services it provides under the laws of the Republic of Panama.

15.2. Dispute resolution

  • Before commencing court proceedings, the User undertakes to submit a complaint through the Service's support channel or by email to the Company.
  • The Company will consider the complaint and provide a response, as a rule, within 30 (thirty) calendar days of receipt, unless a longer period is required in connection with additional checks.
  • The Parties shall seek to resolve any disputes and disagreements arising between the Company and the User through negotiation and pre-action complaint handling.
  • If a dispute cannot be resolved amicably, it shall be determined in accordance with the applicable law of the Republic of Panama.
  • The official channels for submitting complaints are the Company's email info@crypto-office.com and the Service's support channel on Telegram @office_app_support_bot.

16. Amendments

The Company reserves the right to amend this User agreement. Updates take effect immediately upon publication on the official website. Continued use of the Platform constitutes the User's acceptance of the updated version of this User Agreement.

17. Contacts

For all matters relating 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 service: via the Telegram bot @office_app_support_bot

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