Terms and conditions: account and platform

This document contains the Terms and Conditions applicable to the use of, access to, and other activities related to THE SERVICES offered under the VIIO brand (hereinafter, THE AGREEMENT), and comprehensively governs the legal relationship arising between VIIO and the natural person or legal entity that registers for, accesses, or uses THE SERVICES (hereinafter, THE USER).

For purposes of THE AGREEMENT and all of its annexes, the following equivalence of names is established once and for all, and shall be deemed in effect throughout the entirety of the text:

a) VIIO means Quinate Technologies LLC, a company incorporated and existing under the laws of the State of Delaware, United States of America, domiciled in Dover, Delaware, United States, in its capacity as owner and operator of THE PLATFORM and as execution agent of THE USER pursuant to Section 5 of THE AGREEMENT. Any reference to "VIIO" in the body of THE AGREEMENT, without further qualification, shall be understood to refer to Quinate Technologies LLC.

b) VIIO Colombia means Persimon S.A.S., a commercial company incorporated and existing under the laws of the Republic of Colombia, identified with NIT (Tax Identification Number) 901.682.358-5, in its capacity as operator of the VIIO Card, a product that is not governed by THE AGREEMENT but by the separate and independent contract that THE USER enters into with VIIO Colombia for such purpose.

THE AGREEMENT constitutes an adhesion contract entered into by electronic means, which is perfected upon the expression of acceptance that THE USER manifests when registering, activating THE PROFILE, or using THE SERVICES, and which shall be deemed given with full legal effect pursuant to Annex 1. Anyone using THE SERVICES is advised to read THE AGREEMENT, its annexes, and the warnings preceding it in full and with care, and to keep them on a durable medium, before expressing acceptance.

Terms appearing in all capital letters have the meaning assigned to them in Section 1 (Definitions). The order of the sections does not affect their enforceability; all of them, together with the annexes, form a single contractual body.

The purpose of this block of warnings is to enable anyone using THE SERVICES to make an informed decision to engage. It does not constitute a disclaimer of liability, a regime set forth in Section 16, but rather a disclosure of risks that THE USER declares to know, understand, and accept upon engaging.

A. Nature of DIGITAL ASSETS.

DIGITAL ASSETS are not legal tender in the Republic of Colombia or in any other jurisdiction in which THE USER is domiciled, unless expressly determined by the competent authority; they do not constitute foreign currency; they are not securities within the meaning of public securities market regulations; and they do not represent a deposit, a claim against a financial institution, or a personal credit right against the State. Their recognition and their legal, tax, and accounting treatment vary across jurisdictions and may be modified at any time by decision of the competent authorities, with effects that may be adverse to THE USER.

B. Nature of the BALANCE and of the VIIO Account.

THE USER acknowledges and accepts that THE PROFILE and the so-called "VIIO Account" constitute a profile and access interface to THE SERVICES, and not a bank account, a deposit account, or a savings account in its name. BALANCES, values, or amounts denominated or displayed on THE PLATFORM in "USD" or in "dollars" do not necessarily correspond to legal tender dollars deposited with a financial institution. Depending on the functionality, they represent positions in one or more ELIGIBLE ASSETS held in custody by a third party (such as USDC, USDT, EURC, COPM, or PAXG, according to those that VIIO has enabled on THE PLATFORM) or funds in transit managed by THE SUB-AGENTS. THE USER may simultaneously hold positions in different ELIGIBLE ASSETS, subject to their operational availability on THE PLATFORM, and the BALANCE may display its consolidated position with respect to such assets. An ELIGIBLE ASSET may be referenced or linked to the United States dollar, the euro, the Colombian peso, gold, or another reference or underlying asset; therefore, the denomination of a BALANCE in USD may constitute merely a display unit calculated using the rate or methodology indicated on THE PLATFORM. The enablement of an ELIGIBLE ASSET is exclusively operational and does not constitute an investment decision, recommendation, advice, or discretionary management by VIIO, which does not make decisions on behalf of THE USER. VIIO is neither an issuer nor a custodian of ELIGIBLE ASSETS, nor an entity that receives funds, and the display of a BALANCE does not constitute a claim against VIIO or VIIO Colombia. Before confirming each OPERATION, THE PLATFORM will identify the asset or currency involved, its respective reference or underlying asset and, where applicable, the applicable conversion rate or methodology, so that THE USER knows the nature of what it acquires, holds, or transfers.

C. Absence of state guarantee.

Operations carried out through THE SERVICES are not covered by the deposit insurance administered by the Financial Institutions Guarantee Fund (FOGAFÍN), nor by the Cooperative Entities Guarantee Fund (FOGACOOP), nor by any other state guarantee, insurance, or backing mechanism, whether of legal or contractual source. Consequently, in no scenario of loss, unavailability, insolvency, operational failure, or third-party fraud shall there be any state coverage whatsoever over THE USER's BALANCES.

D. Volatility and risk of loss.

The value of DIGITAL ASSETS is determined by supply and demand in unregulated markets that operate continuously and have global reach, and may experience sudden, significant, and unpredictable fluctuations, even over very short periods. THE USER may lose the entire economic value of the DIGITAL ASSETS it acquires, holds, or transacts, without any compensation, stabilization, or reimbursement mechanism. No return, preservation of value, liquidity, or result is promised, guaranteed, or suggested by VIIO, and no communication, informational material, educational content, or market data made available through THE SERVICES constitutes financial, investment, legal, accounting, or tax advice, nor a recommendation to acquire, hold, or dispose of any asset.

E. Irreversibility.

Operations transmitted to a blockchain network are, by the design of such technology, irreversible, irrevocable, and final. Once a transaction is confirmed on the corresponding network, there is no technical or legal mechanism that allows VIIO, THE CUSTODIAN, THE SUB-AGENTS, or any third party to reverse, cancel, stop, or redirect it. Sending to an incorrect address or to an incompatible network, or omitting a required label or tag, may result in the irrecoverable loss of the DIGITAL ASSETS.

F. Absence of financial supervision.

VIIO is not, under Colombian law, a credit institution, a financial services company, a company specialized in electronic deposits and payments, a foreign exchange market intermediary, an insurance company, a securities market entity, or a solidarity economy entity, nor is it subject to the inspection, supervision, and control of the Financial Superintendency of Colombia. THE SUB-AGENTS act under the regime applicable to them in their own jurisdiction. VIIO's activities under THE AGREEMENT do not constitute the raising of funds from the public, financial intermediation, or an activity reserved to supervised entities.

G. Dependence on third parties.

The material provision of THE SERVICES depends on THE SUB-AGENTS, THE CUSTODIAN, the financial and payment institutions involved in each operation, the technology infrastructure providers, and the underlying blockchain networks. Failures, interruptions, congestion, cyberattacks, regulatory decisions, operational restrictions, or insolvency of any of such third parties may affect the availability of THE SERVICES, delay or prevent the execution of instructions, and cause losses to THE USER.

H. Security of credentials and devices.

The safekeeping of access credentials, authentication factors, verification codes, and the devices from which THE PROFILE is accessed is the sole responsibility of THE USER. Unauthorized access resulting from the disclosure, lending, loss, or theft of such credentials, from the installation of malicious software or ransomware, from impersonation or social engineering schemes, or from failure to update devices, is a risk assumed by THE USER and against which VIIO has no reversal mechanisms.

I. Regulatory and access risk.

The conditions of access to THE SERVICES may vary for regulatory, compliance, or risk policy reasons. VIIO may be required to restrict, suspend, or terminate the provision of THE SERVICES in certain jurisdictions or with respect to certain users, with the effects set forth in Sections 8, 13, and 25.

Anyone who does not understand or is not willing to assume the risks described in this block must refrain from accepting THE AGREEMENT and from using THE SERVICES.

For all purposes of THE AGREEMENT and its annexes, the following terms, written in all capital letters and used in the singular or plural, shall have the meaning indicated below, unless the context unequivocally indicates otherwise:

"DIGITAL ASSETS" refers to digital representations of value recorded on a blockchain network or analogous distributed ledger technology, capable of being transferred, stored, and traded by electronic means, that are available through THE SERVICES from time to time, including digital assets referenced to a fiat currency or to other references or underlying assets. DIGITAL ASSETS are not legal tender or foreign currency.

"ELIGIBLE ASSETS" means the DIGITAL ASSETS issued, administered, or supported by third parties unrelated to VIIO and VIIO Colombia that VIIO enables from time to time, for exclusively operational reasons, for the execution of OPERATIONS or to reflect positions in THE PROFILE. ELIGIBLE ASSETS may include digital assets referenced or linked to fiat currencies, precious metals, or other assets, indices, rights, or reference mechanisms, as well as other DIGITAL ASSETS that VIIO determines may be operationally admitted into THE SERVICES. They may include, without limitation, USD Coin (USDC), Tether (USDT), Euro Coin (EURC), COP Minteo (COPM), a digital asset issued by a third party and referenced to the Colombian peso, PAX Gold (PAXG), and any other DIGITAL ASSETS that VIIO may enable in the future. The actual availability of each ELIGIBLE ASSET is reported on THE PLATFORM. The enablement of an asset as an ELIGIBLE ASSET is exclusively operational and does not constitute an investment decision by VIIO, nor a recommendation, advice, offer, guarantee, administration, or discretionary management; VIIO does not select investments or make decisions on behalf of THE USER. Each ELIGIBLE ASSET is subject, as applicable, to the risks of its issuer or administrator, of its reserves, collateral, stabilization mechanism, or reference asset, of the market, and of the blockchain networks on which it circulates. VIIO does not guarantee its value, liquidity, convertibility, stability, parity, or correspondence with its respective reference or underlying asset. No ELIGIBLE ASSET constitutes legal tender, foreign currency, a deposit, a security, a savings account, or a claim against VIIO or VIIO Colombia.

"THE AGREEMENT" means this Terms and Conditions document, together with its annexes, addenda, policies incorporated by reference, and the updates published pursuant to Section 21, all of which form a single and indivisible contractual body.

"BACKUP WALLET" means the DIGITAL ASSETS wallet address, external to THE PLATFORM and owned by THE USER, that THE USER registers in THE PROFILE to receive DIGITAL ASSETS in the cases provided for in Section 13.10.

"COPM" means COP Minteo, a stablecoin-type digital asset issued by Minteo and referenced to the Colombian peso on a one-to-one (1:1) basis, according to the information published by its issuer, which states that it maintains reserves in liquid assets denominated in Colombian pesos. COPM is not the Colombian peso, nor legal tender, nor a digital currency issued by the Banco de la República.

"BACKUP ACCOUNT" means the bank or deposit account in Colombian pesos, opened in Colombia in the name of THE USER, that THE USER registers in THE PROFILE to receive funds in the cases provided for in Section 13.10.

"THE CUSTODIAN" means the third party of recognized suitability, unrelated to VIIO and VIIO Colombia, responsible for the technical custody of the DIGITAL ASSETS reflected on THE PLATFORM.

"EURC" means Euro Coin, a stablecoin-type digital asset issued by Circle, referenced on a one-to-one (1:1) basis to the euro and backed, according to the information published by its issuer, by reserves of cash and highly liquid cash equivalents, redeemable with the issuer by its eligible customers.

"OPERATION" means any instruction given by THE USER through THE PLATFORM and transmitted by VIIO to the competent sub-agent, including those for the acquisition, disposal, or conversion of DIGITAL ASSETS, receipt of funds, outgoing transfer of funds or DIGITAL ASSETS, and other operations enabled from time to time.

"PAXG" means PAX Gold, a digital asset issued by Paxos, each unit of which represents, according to the information published by its issuer, ownership of one fine troy ounce of London Good Delivery physical gold held in custody on behalf of the holders. The value of PAXG is referenced to the price of gold and not to a fiat currency.

"THE PROFILE" means the personal, unique, and non-transferable record created by THE USER on THE PLATFORM, through which THE USER accesses THE SERVICES, gives instructions, and consults the BALANCES and the status of its operations.

"THE PLATFORM" refers to the set of web and mobile applications, interfaces, computer programs, databases, developments, and technology infrastructure owned by VIIO or its licensors, through which THE SERVICES are made available.

"PSPA" has the meaning assigned to it in Section 3.2.

"BALANCE" means the informational representation that THE PLATFORM displays in THE PROFILE, in USD, in another reference currency, or in units of the corresponding asset, of the position attributable to THE USER according to the information reported by THE SUB-AGENTS. The BALANCE may display THE USER's consolidated position with respect to the different ELIGIBLE ASSETS held in THE PROFILE or in the so-called "VIIO Account", and THE USER may simultaneously hold positions in different ELIGIBLE ASSETS, subject to their operational availability on THE PLATFORM. The BALANCE may be composed of or correspond to one or more ELIGIBLE ASSETS held in custody by a third party or, depending on the functionality, to funds in transit managed by THE SUB-AGENTS. The display of a BALANCE does not constitute a bank account, a deposit or savings account, a negotiable instrument, or a claim against VIIO or VIIO Colombia; nor does it imply that VIIO receives, holds in custody, or owns the assets or funds reflected. When a BALANCE groups or converts positions in different ELIGIBLE ASSETS or reference currencies, THE PLATFORM will identify the applicable composition and the information necessary for THE USER to know the nature of the assets or funds involved before confirming each OPERATION.

"THE SERVICES" refers to the mobile applications, products, software, web pages, APIs, and other functionalities and services that VIIO offers or makes available to THE USER through THE PLATFORM or THE SITE, as well as those of other providers that THE PLATFORM presents as part of its offering. They include the opening and maintenance of THE PROFILE, the capture and transmission of instructions to THE SUB-AGENTS, the display of BALANCES and of the status of OPERATIONS, the rendering of accounts for the management entrusted, and others enabled from time to time, with the scope and limitations set forth in THE AGREEMENT. The VIIO Card is not part of THE SERVICES.

"THE SITE" means VIIO's official website available at https://viio.me/, as well as any other domain or subdomain that VIIO officially designates for THE SERVICES.

"THE SUB-AGENTS" means the third parties to whom VIIO delegates the material execution of THE USER's instructions, designated and accepted by THE USER pursuant to Section 5 and described by their functional scope in Section 3.2.

"VIIO Card" means the product operated by VIIO Colombia under its own contract, pursuant to the Preamble and Section 2.4.

"RESTRICTED TERRITORY" has the meaning assigned to it in Section 8.

"COMPLETED TRANSACTION" means any movement actually carried out and reflected as such in THE PROFILE, including OPERATIONS instructed by THE USER, the receipt of funds or DIGITAL ASSETS from third parties pursuant to Section 7.7, and debits to the BALANCE to cover purchases with the VIIO Card. Rejected, canceled, or pending transactions, as well as debits ordered by VIIO pursuant to Section 5.10, do not constitute a COMPLETED TRANSACTION, except for those corresponding to purchases, withdrawals, payments, and other transactions carried out with the VIIO Card.

"USD IN VIIO" or "DOLLARS IN VIIO" means the unit of denomination, display, and value reference used on THE PLATFORM to display certain amounts and BALANCES. An amount displayed in USD or in dollars may correspond, depending on the functionality and the time of the OPERATION, to a position in one or more ELIGIBLE ASSETS, even if these are referenced or linked to a fiat currency other than the United States dollar, to a precious metal, or to another reference or underlying asset, or to funds in transit managed by THE SUB-AGENTS. When the ELIGIBLE ASSET has a reference or underlying asset other than the dollar, the value displayed in USD shall correspond to the informational conversion resulting from the rate or methodology indicated on THE PLATFORM. The denomination in USD or in dollars does not mean that THE USER holds legal tender dollars deposited in a bank account, nor does it alter the legal nature of the underlying asset or funds in transit. Before confirming each OPERATION, THE PLATFORM will identify the ELIGIBLE ASSET or currency involved, its respective reference or underlying asset and, where applicable, the applicable conversion rate or methodology.

"USDC" means USD Coin, a stablecoin-type digital asset issued by Circle, referenced on a one-to-one (1:1) basis to the United States dollar and backed, according to the information published by its issuer, by reserves of cash and highly liquid cash equivalents, redeemable with the issuer by its eligible customers.

"USDT" means Tether, a stablecoin-type digital asset issued by Tether, referenced on a one-to-one (1:1) basis to the United States dollar and backed, according to the information published by its issuer, by reserves comprising cash, cash equivalents, and other assets, redeemable with the issuer by its eligible customers.

"THE USER" means the natural person of legal age or the legal entity that, with full legal capacity, registers on THE PLATFORM, accepts THE AGREEMENT, and is the holder of THE PROFILE. References to "anyone using THE SERVICES" further include any person who accesses THE PLATFORM or THE SITE, whether or not they have completed their registration.

"THE CONSUMER USER" means THE USER who qualifies as a consumer under Law 1480 of 2011.

"THE NON-CONSUMER USER" means THE USER who does not so qualify.

"VIIO" means Quinate Technologies LLC, pursuant to the Preamble.

"VIIO Colombia" means Persimon S.A.S., pursuant to the Preamble.

The individual definitions of USDC, USDT, EURC, COPM, and PAXG are illustrative. Any other ELIGIBLE ASSET that VIIO enables is governed by the definition of ELIGIBLE ASSETS, even if it does not have an individual definition in THE AGREEMENT. The descriptions of reserves, backing, redemption, or underlying asset of each ELIGIBLE ASSET are based on the information published by its issuer or administrator, which VIIO does not verify or guarantee and which may change at any time.

2.1. Purpose.

The purpose of THE AGREEMENT is to govern the conditions under which VIIO makes THE PLATFORM and THE SERVICES available to THE USER, as well as the terms of the mandate of execution that THE USER grants to VIIO and of the designation of THE SUB-AGENTS that materially execute the OPERATIONS.

2.2. Scope of application.

THE AGREEMENT applies to all relationships arising from the registration, access and use of THE SERVICES, regardless of the device, channel or interface used, and covers both THE CONSUMER USER and THE NON-CONSUMER USER, without prejudice to the provisions of Section 2.5.

2.3. Exclusions.

The following do not form part of the purpose of THE AGREEMENT and are therefore expressly excluded from its scope: (i) the issuance, administration, activation and use of the VIIO Card, which is governed by the separate contract entered into with VIIO Colombia; (ii) any service that THE USER contracts directly with a third party, even if THE USER learned of it through THE PLATFORM, unless it concerns other providers that THE PLATFORM presents as part of its offering; and (iii) the particulars of the services provided to legal entity clients that are agreed upon in a separate contract pursuant to Section 2.5.

2.4. Coordination with the VIIO Card contract.

The VIIO Card is a separate product, operated by VIIO Colombia under its own contract, its own fees and its own personal data processing policy. THE AGREEMENT does not govern its conditions of issuance, use, blocking, replacement, disputes or charges. With respect to the VIIO Card, the card contract prevails over THE AGREEMENT in accordance with the order of precedence established in Section 24.1.

2.5. Services to legal entities and business clients.

Where THE USER is a legal entity or uses THE SERVICES in the context of a business activity, the particulars of the business services (including, without limitation, the functional scope, operating limits, specific fees, service levels, technical integration schemes and agreed guarantees) shall be specifically defined in the separate contract that such client has entered into with VIIO for that purpose, which shall prevail over THE AGREEMENT with respect to the matters expressly governed therein. In the absence of a separate contract, the relationship is governed entirely by THE AGREEMENT.

2.6. Sales and collection tools.

VIIO may enable, at its discretion and subject to a prior compliance assessment, sales and collection tools that allow THE USER to carry out collection operations (pay-in) in fiat currency or in DIGITAL ASSETS through various methods and technological gateways, including, without limitation, payment buttons, payment links or checkout. The specific conditions of such tools are disclosed through THE SERVICES and, in the case of business clients, are agreed upon in the separate contract referred to in Section 2.5.

3.1. VIIO as operator of THE PLATFORM and agent of execution.

VIIO is the owner and operator of THE PLATFORM and acts, vis-à-vis THE USER, exclusively as agent of execution: it receives the instructions that THE USER issues through THE PLATFORM, formally validates them and channels them to the competent sub-agent for material execution, subsequently reflecting on THE PLATFORM the BALANCES and the status of the OPERATIONS as they are reported to it. VIIO does not materially execute payment operations, does not hold DIGITAL ASSETS in custody, does not convert assets or currencies, does not issue means of payment, and does not manage THE USER's funds.

3.2. THE SUB-AGENTS.

The material execution of the OPERATIONS is the responsibility of THE SUB-AGENTS, each within its own functional scope and under the terms and conditions governing its own activity, namely: (i) Sphere Laboratories, Inc., a Delaware corporation, United States of America, responsible for fiat currency operations outside Colombia, the provision of virtual accounts denominated in United States dollars and in euros, on-ramp and off-ramp operations, and international disbursement; (ii) the designated aggregator payment service provider (the "PSPA"), responsible for the collection and disbursement of Colombian pesos within the national territory; and (iii) THE CUSTODIAN, responsible for the technical custody of the DIGITAL ASSETS, pursuant to Section 6. Conversions between DIGITAL ASSETS and fiat currency that do not fall within the scope of Sphere Laboratories, Inc. are executed through whomever VIIO designates for such purpose, pursuant to Section 7.2.

3.3. Power to modify THE SUB-AGENTS and partners.

VIIO reserves the right to make any modification, substitution, addition or removal of THE SUB-AGENTS and of their operating partners, without prior notice to THE USER and without such modification constituting an amendment to THE AGREEMENT. Where the relevant sub-agent is listed in Annex 3, updating said Annex shall suffice, and said Annex is deemed incorporated by reference. Such power is exercised in the interest of the continuity, security and efficiency of THE SERVICES, and in no event alters the nature of the mandate or the non-waivable rights of THE CONSUMER USER. Likewise, and under the terms of Section 21, VIIO may update THE AGREEMENT without the authorization of THE USER, through the notice and publication provided for in Section 21.3.

3.4. Non-financial nature of VIIO.

Under Colombian law, VIIO is not a credit institution, financial services company, company specialized in electronic deposits and payments, foreign exchange market intermediary, insurance entity, securities market entity or solidarity economy entity, nor is it subject to the inspection, supervision and control of the Financial Superintendency of Colombia. THE SUB-AGENTS act under the regime applicable to them in their own jurisdiction. Accordingly, and without this list being exhaustive, it is expressly stated for the record that VIIO: (i) does not take funds from the public on a massive and habitual basis, whether directly or indirectly; (ii) does not receive demand, time or savings deposits; (iii) does not grant credit to the public on a massive and habitual basis, nor does it carry out active credit operations; (iv) does not carry out foreign exchange operations or act as a foreign exchange market intermediary; (v) does not manage or dispose of THE USER's funds or DIGITAL ASSETS, nor use them for its own operations, to secure its own or third-party obligations, or to grant financing; (vi) does not provide investment, portfolio management, brokerage or financial advisory services; (vii) does not recognize, promise or pay interest, yields, profits or returns of any kind on THE USER's funds or DIGITAL ASSETS, regardless of the length of time they remain reflected in THE PROFILE; and (viii) does not carry out any activity subject to legal reserve or subject to the inspection, supervision and control of the Financial Superintendency of Colombia.

3.5. Essential nature of the representations.

The representations contained in Section 3.4 are essential and determinative of the consent of both parties. THE USER represents that it accepts THE SERVICES with full knowledge of such nature and that it has not received from VIIO, or from its officers, employees, partners or communication channels, any promise, offer, suggestion or expectation of profitability, preservation of value, insurance or guarantee on its BALANCES.

3.6. Absence of advice.

The information that VIIO provides, directly or through THE SERVICES, is for informational purposes only. VIIO does not solicit, induce or recommend the execution of any OPERATION based on such information, nor does it issue any opinion on the advisability of carrying out operations of any kind with DIGITAL ASSETS. Accordingly, anyone who uses THE SERVICES, by the mere fact of doing so, acknowledges and accepts that VIIO does not provide investment advice or financial, legal, accounting or tax advice.

3.7. Sphere disclosure.

Certain services available through VIIO, including the processing and international disbursement of payments to the United States, Europe and, occasionally, other jurisdictions through the SWIFT network, the provision of virtual accounts denominated in United States dollars and in euros, the connection with liquidity providers and the on-ramp and off-ramp functionalities, are not provided by VIIO. Such services are provided by Sphere Laboratories, Inc. ("Sphere"), a corporation organized under the laws of the State of Delaware, United States of America, in its capacity as VIIO's delegated provider. By accepting THE AGREEMENT, THE USER acknowledges that part of THE SERVICES may be delegated to Sphere and that the use of such delegated services is also governed by Sphere's Terms of Service, available at https://spherepay.co/terms, which THE USER may consult and accepts by reference. THE USER represents that it is aware of Sphere's activity as operator of the delegated services. Where an OPERATION is processed through an additional provider of Sphere, THE USER accepts the terms of such provider, as presented to THE USER by Sphere. VIIO and Sphere are not jointly and severally liable to THE USER. VIIO is liable exclusively for the services it provides directly; Sphere is liable exclusively for the delegated services it provides, in accordance with its own terms.

4.1. Creation of THE PROFILE.

Access to THE SERVICES requires the creation of THE PROFILE, which is personal, unique and non-transferable. To create it, anyone who uses THE SERVICES must provide the information that THE PLATFORM requires, accept THE AGREEMENT and its annexes, grant the applicable personal data processing authorizations and satisfactorily complete the identity verification and due diligence process.

4.2. Capacity and ownership.

Only natural persons of legal age with full legal capacity to contract and duly incorporated and represented legal entities may hold THE PROFILE. Anyone who registers a PROFILE on behalf of a legal entity represents, under their own responsibility, that they have sufficient authority to bind it. THE PROFILE does not admit joint ownership; accordingly, the BALANCES reflected therein are deemed to be exclusively owned by the registered USER.

4.3. Identity verification and due diligence.

VIIO, directly or through specialized third parties, carries out identity verification, document validation, biometric verification, restrictive list screening and due diligence processes on THE USER, prior to the enabling of THE PROFILE and, where applicable, on an ongoing basis during the term of THE AGREEMENT. Successful completion of such processes is a condition for the provision of THE SERVICES, and failure to complete them, failure to keep them current, or refusal to provide the required information entitles VIIO to refrain from enabling THE PROFILE or to suspend or terminate it pursuant to Section 13.

4.4. Single verification process.

Where THE USER additionally accesses products operated by VIIO Colombia, the identity verification process may be carried out only once and relied upon by both entities within the ecosystem, in accordance with the data processing authorizations granted by THE USER and under the terms of Section 18, without this implying the unification of the contracts or of the responsibilities of each entity.

4.5. Types of PROFILE and operating limits.

VIIO may establish different types or levels of PROFILE, with differentiated functionalities and limits on amount, frequency and scope, based on the level of verification achieved, the risk profile, the jurisdiction of residence and the applicable regulatory requirements. VIIO may modify such limits at any time for reasons of security, risk or compliance, disclosing them through THE SERVICES.

4.6. Accuracy and updating of information.

THE USER undertakes to provide accurate, complete, truthful and current information, and to keep it updated throughout the term of THE AGREEMENT, informing VIIO, through the channels provided, of any relevant change within a reasonable period. Inaccuracy, falsity or failure to update the information constitutes a breach of THE AGREEMENT and triggers the measures provided for in Section 13, without prejudice to any civil and criminal liability arising therefrom for THE USER. THE USER may, optionally, register a BACKUP ACCOUNT and a BACKUP WALLET in THE PROFILE, and must keep updated those it registers.

4.7. Security of credentials.

THE USER is solely responsible for the safekeeping and confidentiality of its access credentials, authentication factors and verification codes, as well as for the security of the devices from which it accesses THE PROFILE. Any instruction issued with THE USER's credentials is deemed to have been issued by THE USER and has full effect, and VIIO is not required to carry out verifications in addition to those provided for in its authentication protocols. THE USER must immediately inform VIIO, through the channels provided, of any loss, theft, unauthorized use or suspected compromise of its credentials, so that the appropriate blocking measures may be adopted; such measures operate prospectively and do not allow the reversal of OPERATIONS already executed.

5.1. Grant of the mandate.

By accepting THE AGREEMENT, THE USER grants VIIO a specific, remunerated mandate of execution with representation and with express power of delegation, by virtue of which VIIO is authorized, always acting in the name, on behalf and at the risk of THE USER and solely on the basis of the instructions THE USER issues through THE PLATFORM, to: (i) receive, record and formally validate such instructions; (ii) transmit them to the competent sub-agent according to the nature of the OPERATION; (iii) instruct the corresponding sub-agent, or whomever VIIO designates pursuant to Section 7.2, to receive, collect, disburse, convert, transfer or hold in custody funds or DIGITAL ASSETS, as applicable; (iv) enter into, before THE SUB-AGENTS, in the name and on behalf of THE USER, the acts necessary for the execution of each OPERATION; (v) reflect on THE PLATFORM the BALANCES and the status of the OPERATIONS as they are reported to it; (vi) order THE SUB-AGENTS to make the debits from the BALANCE that THE USER instructs and authorizes in Section 5.10, and order the conversions and transfers that THE USER instructs in advance in Section 13.10; and (vii) render accounts of its management under the terms of Section 5.6.

5.2. Scope of the engagement and absence of discretion.

The mandate granted to VIIO is specific and entirely non-discretionary: VIIO does not make investment decisions, does not select assets, does not determine times of market entry or exit, does not manage portfolios, and does not dispose of THE USER's funds or DIGITAL ASSETS on its own initiative. VIIO acts exclusively upon an instruction from THE USER, including the advance instructions THE USER issues in Sections 5.10 and 13.10, and its action is limited to the diligent transmission of such instruction and the reflection of its result. VIIO may enable the ELIGIBLE ASSETS admissible for operating or reflecting positions for reasons of technology, availability, liquidity, compliance, network or integration; such operational enabling does not constitute the selection of an investment, a recommendation, advice, management or discretionary management, and VIIO does not make decisions on behalf of THE USER. The choice and authorization of each OPERATION rest with THE USER, based on the information THE PLATFORM displays before THE USER confirms it.

5.3. Designation and acceptance of THE SUB-AGENTS by THE USER.

By accepting THE AGREEMENT and its annexes, THE USER expressly designates, accepts and approves THE SUB-AGENTS through which the OPERATIONS are materially executed, as well as those that may be incorporated in the future pursuant to Section 3.3. Such designation is an essential element of the contractual structure and produces the following effects, which THE USER represents that it understands and accepts: (i) THE SUB-AGENTS act as direct agents of THE USER within the functional scope corresponding to each of them, having been designated by THE USER; (ii) liability for the material execution of the OPERATIONS rests with the sub-agent that executes them, and VIIO is liable for diligence in selecting it and in transmitting the instructions, pursuant to Section 5.5, without prejudice to the provisions of Section 5.9; (iii) claims associated with the material execution carried out by a sub-agent identified in Annex 3 are submitted to VIIO, which handles them and pursues them before such sub-agent, without THE USER having to address the latter; liability for such execution is governed by the terms of that sub-agent; and (iv) VIIO does not guarantee, endorse or assume joint and several liability for the obligations of THE SUB-AGENTS, as set forth in Section 16, without prejudice to the provisions of Section 5.9.

5.4. Substitution of THE SUB-AGENTS.

The power to substitute THE SUB-AGENTS is deemed granted to VIIO broadly and permanently, and is exercised pursuant to Section 3.3. The designation made by THE USER extends, without the need for ratification, to the sub-agents resulting from such substitution, who shall be subject to the same liability regime described in Section 5.3.

5.5. Obligation of means.

The obligations VIIO assumes under the mandate are obligations of means and not of result. Accordingly, VIIO undertakes to exercise the diligence of a professional technology operator in order to: (i) keep THE PLATFORM available and operational, under the terms and with the exceptions of Section 16; (ii) transmit THE USER's instructions to the competent sub-agent diligently and without unjustified delay; (iii) faithfully reflect on THE PLATFORM the BALANCES and the status of the OPERATIONS reported to it by THE SUB-AGENTS; (iv) adopt reasonable information security measures; and (v) render accounts of its management. VIIO does not undertake that the OPERATIONS will actually be executed, or that they will be executed within a specific period, or that any particular economic result will be achieved, since this depends on third parties, blockchain networks, financial institutions and circumstances beyond its control.

5.6. Rendering of accounts.

VIIO renders accounts of its management on a permanent and automated basis, by making available to THE USER, through THE PROFILE, the history of OPERATIONS, the BALANCES reflected and the receipts or supporting documents reported by THE SUB-AGENTS. Such information is deemed accepted by THE USER if THE USER does not raise an objection through the channels provided within fifteen (15) business days following the date on which the respective OPERATION is reflected in THE PROFILE, without prejudice to the non-waivable rights of THE CONSUMER USER and to the legal statutes of limitation.

5.7. Irrevocability with respect to OPERATIONS in progress.

The mandate is agreed to be irrevocable with respect to OPERATIONS in progress, as it has also been granted in the interest of VIIO, THE SUB-AGENTS and third parties involved in its execution. Accordingly, the revocation of the mandate, the cancellation of THE PROFILE or the termination of THE AGREEMENT does not affect the execution of instructions already transmitted to the competent sub-agent, which shall be carried out as issued. The foregoing is without prejudice to the non-waivable rights that the law grants to THE CONSUMER USER.

5.8. Remunerated mandate.

The mandate is remunerated in accordance with the costs and commissions established in THE AGREEMENT and disclosed through THE SERVICES pursuant to Section 11. In OPERATIONS for the acquisition, disposal or conversion of DIGITAL ASSETS, the current fees disclosed on THE PLATFORM shall apply and, if there is a difference between such fees and the final price of the operation with the relevant third party, such difference shall be deemed VIIO's remuneration. VIIO's remuneration is collected pursuant to Section 5.10. The rate or price that THE PLATFORM displays to THE USER before confirming each OPERATION, pursuant to Section 7.1, already includes such remuneration.

5.9. Claims relating to sub-agents not identified in Annex 3.

In the case of OPERATIONS whose material execution is the responsibility of a sub-agent, or of whomever VIIO designates pursuant to Section 7.2, that is not listed in Annex 3, VIIO shall directly handle THE USER's claims and shall be liable to THE USER for any failure in the material execution of its instructions, without THE USER having to address such sub-agent or designee, and VIIO may seek recovery from such sub-agent or designee of any amount it pays on that account. This liability does not cover the risks that THE USER assumes pursuant to Section 16.9, including those inherent to custody described in Section 6.5, and is subject to the other provisions of Section 16.

5.10. Debits pre-authorized by THE USER.

THE USER expressly instructs and authorizes VIIO, in execution of the mandate provided for in Section 5, to order the corresponding sub-agent, according to the functional scope in which the funds or DIGITAL ASSETS are located, to debit the BALANCE reflected in THE PROFILE for the following items: (i) the fees and commissions accrued pursuant to Section 11, including VIIO's remuneration provided for in Section 5.8; (ii) all amounts generated by the use of the VIIO Card, including, without limitation, purchases, withdrawals, payments and other transactions or operations carried out with it, as well as its fees, commissions, installments, charges, taxes, adjustments, chargebacks and reversals, in accordance with the VIIO Card contract entered into with VIIO Colombia, and their payment to VIIO Colombia; (iii) the inactivity maintenance fee, pursuant to Sections 13.4 and 13.5; (iv) the amounts of chargebacks, reversals and disputed transactions, pursuant to Section 7.8; and (v) amounts credited in error or improperly, pursuant to Section 7.10. Each debit is limited to the item, amount and timing resulting from THE AGREEMENT, the VIIO Card contract, the published fees and the instruction issued by THE USER in each OPERATION or each use of the VIIO Card. VIIO may not order debits for items other than those provided for in this Section 5.10, nor allocate THE USER's funds or DIGITAL ASSETS to a different purpose, except for the conversions and transfers that THE USER instructs in advance in Section 13.10. The competent sub-agent materially executes each debit, and its record is reflected in THE PROFILE pursuant to Section 5.6.

6.1. Custody is not provided by VIIO.

The technical custody of the DIGITAL ASSETS is not provided by VIIO or by VIIO Colombia, but by THE CUSTODIAN, a third party of recognized suitability specialized in the safekeeping of digital assets, designated and accepted by THE USER under the terms of Section 5.3.

6.2. Function of THE PLATFORM.

With respect to the DIGITAL ASSETS, THE PLATFORM performs a merely informational and interface function: it reflects the BALANCES held in custody and the status of the OPERATIONS as they are reported to it, and it enables THE USER to issue instructions regarding them. The display of a BALANCE in THE PROFILE does not constitute a deposit, a claim against VIIO or a negotiable instrument, but rather the representation of the BALANCE that THE USER holds in the custody of THE CUSTODIAN.

6.3. Absence of title and of power of disposition.

VIIO does not acquire any title, ownership, property, possession or power of disposition whatsoever over the DIGITAL ASSETS of THE USER, which remain at all times owned by THE USER. VIIO does not use the DIGITAL ASSETS for its operations, does not lend them, does not encumber them, does not offer them as collateral, does not allocate them to the granting of credit, does not commingle them with its own assets for its own purposes, and does not carry out any operation with them other than those instructed by THE USER. Accordingly, the DIGITAL ASSETS do not form part of the general pledge of creditors of VIIO.

6.4. Absence of yield.

The holding of the DIGITAL ASSETS or of the BALANCES in custody does not, under any circumstances, generate interest, yields, profits or returns in favor of THE USER, nor does VIIO recognize, promise or pay any such amounts.

6.5. Risks inherent to custody.

THE USER acknowledges that custody by a third party entails risks that do not depend on VIIO, including those arising from technical failures, security incidents, regulatory decisions, operational restrictions or insolvency of THE CUSTODIAN, as well as the risks inherent to the underlying blockchain networks. VIIO shall make reasonable efforts to select custodians of recognized suitability and to require adequate security standards, without this implying any guarantee of result or any assumption of liability for the acts of THE CUSTODIAN, in accordance with Section 16.

6.6. Segregation of assets.

The DIGITAL ASSETS of THE USER are held by THE CUSTODIAN for the benefit of the users and segregated from the proprietary assets and the equity of VIIO and of VIIO Colombia. Accordingly, VIIO may not lend, pledge, encumber or use such assets for its own account, and they do not form part of the general pledge of creditors of VIIO in accordance with Section 6.3. Ownership of the DIGITAL ASSETS remains, at all times, with THE USER. Protection in the event of a potential insolvency scenario depends on the law and the structure applicable to THE CUSTODIAN; no insurance or government guarantee covers the DIGITAL ASSETS, in accordance with the block of warnings that precedes THE AGREEMENT.

7.1. Issuance of instructions.

OPERATIONS originate exclusively from instructions issued by THE USER through THE PROFILE, by means of the authentication mechanisms provided by THE PLATFORM. Before each OPERATION is confirmed, THE PLATFORM makes its essential information available to THE USER, including, as applicable, the amount, the asset, the network, the recipient, the applicable rate or price and the fees. Confirmation of the instruction by THE USER makes it enforceable, final and executable, and authorizes VIIO to transmit it to the competent sub-agent without the need for additional verification or subsequent consultation.

7.2. Acquisition, disposal and conversion.

OPERATIONS for the acquisition, disposal or conversion of DIGITAL ASSETS, including those carried out against Colombian pesos or any other currency, are executed in the name and on behalf of THE USER through the party designated by VIIO for such purpose, at the prices, rates or quotes in effect at the time of their processing, which are dynamic and may vary between the moment they are displayed and the moment the OPERATION is actually executed. THE USER accepts that such variations are inherent to the market, that they do not constitute a breach, and that the price actually applied shall be the one reflected in the receipt of the OPERATION.

7.3. Accuracy of beneficiary data: critical warning.

THE USER is solely and exclusively responsible for the accuracy, completeness, validity and compatibility of the information provided for the execution of each OPERATION, including, without limitation, the name and identification of the beneficiary, the financial institution, the account number, the wallet address, the selected blockchain network and the labels or tags required by the network. If such information is incorrect, incomplete, incompatible with the selected network or corresponds to a recipient other than the intended one, the funds or the DIGITAL ASSETS may be transferred to an incorrect destination and be irrecoverably lost, with THE USER assuming the entirety of that risk and of its economic consequences, without VIIO having any liability for their recovery, reversal or refund, and without prejudice to VIIO providing such reasonable cooperation as is within its reach, which does not constitute an obligation of result.

7.4. Irrevocability of OPERATIONS on the blockchain network.

Outgoing transfers of DIGITAL ASSETS, once transmitted to the underlying blockchain network, cannot be reversed, cancelled, stopped or modified by any means. VIIO does not control the blockchain network, does not participate in the validation of its transactions, and cannot guarantee that the network will successfully confirm or transfer any transfer, nor the reversal of any OPERATION. Accordingly, THE USER must carefully verify each instruction before confirming it. Every instruction issued with the credentials of THE USER is deemed to have been issued by THE USER and shall have full effect, in accordance with Section 4.7. If the DIGITAL ASSETS are technically recoverable, VIIO may, at its sole discretion and as an obligation of means and not of result, make reasonable efforts to attempt their recovery, without such efforts being guaranteed in any way or committing to any result. The provisions of this Section 7.4 do not limit the right of THE USER to file claims for unauthorized operations, fraud or VIIO's own failure under the terms of Section 16, it being understood that the technical irreversibility of an OPERATION on the blockchain network does not, in and of itself, constitute grounds for exonerating VIIO from a breach attributable to it.

7.5. Transfer of liability for errors in instructions.

THE USER fully assumes, and releases VIIO from all liability for, the consequences arising from: (i) errors, omissions, inaccuracies or duplications in the instructions THE USER issues; (ii) the selection of a blockchain network that is not compatible with the asset or with the destination address; (iii) sending to wallet addresses of smart contracts, exchanges or third parties that do not support the asset or the network used; (iv) the omission of required labels, memos or tags; (v) instructions issued as a result of deception, fraudulent schemes, impersonation or social engineering of which THE USER is a victim; and (vi) delay, rejection or impossibility of execution attributable to the beneficiary, to its financial institution or to the risk policies of third parties. None of the foregoing circumstances gives rise to any obligation of refund, reversal, re-execution or indemnification on the part of VIIO.

7.6. Execution times.

The execution times of OPERATIONS are estimates and depend on THE SUB-AGENTS, the participating financial institutions, clearing schedules, blockchain network congestion and applicable compliance controls. VIIO does not guarantee execution times and is not liable for delays arising from such factors, without prejudice to its duty to transmit instructions without undue delay.

7.7. Funds and assets received by THE USER.

Funds or DIGITAL ASSETS transferred by third parties in favor of THE USER shall be reflected in THE PROFILE once confirmed by the competent sub-agent and once the applicable compliance controls have been passed. VIIO may instruct the competent sub-agent to withhold, preventively freeze or return to origin any funds or assets whose origin cannot be substantiated, that come from restricted jurisdictions or counterparties, that are inconsistent with the transactional profile declared by THE USER, or that trigger alerts of risk of money laundering, terrorist financing or financing of the proliferation of weapons of mass destruction, in accordance with Sections 13 and 25.

7.8. Chargebacks, reversals and disputes received.

When the party that transferred funds or DIGITAL ASSETS to THE USER initiates a chargeback, a dispute, a payment reversal, an objection before its financial institution or any similar claim, and such claim succeeds or the corresponding sub-agent is required to honor it, VIIO shall order the debit of the respective amounts from the BALANCE reflected in THE PROFILE, in accordance with Section 5.10. If the available BALANCE is insufficient, THE USER expressly and irrevocably instructs and authorizes VIIO to order the debit of such amounts from the funds or DIGITAL ASSETS that are credited to THE PROFILE in the future, and to set them off against any sum that VIIO owes to THE USER. Failing that, THE USER undertakes to pay them within five (5) business days following VIIO's demand, in the manner VIIO indicates, together with the costs, expenses and commissions associated with handling the chargeback.

7.9. Evidence and collection.

The payment obligation of THE USER described in Section 7.8, as well as any other overdrawn BALANCE owed by THE USER, may be collected by VIIO through legal channels. The certification issued by VIIO and the statement of the OPERATIONS reflected in THE PROFILE may be submitted as evidence of the obligation, without prejudice to the right of THE USER to contest them. In the case of THE NON-CONSUMER USER, such obligation shall become enforceable without the need for prior demand or notice of default, which THE NON-CONSUMER USER expressly waives, to the extent such waiver is admissible under applicable law. With respect to THE CONSUMER USER, the demands, time periods and guarantees that the law mandatorily establishes in their favor shall be observed.

7.10. Resolution of errors and adjustments.

VIIO may make adjustments to the BALANCES reflected in THE PROFILE when recording errors, duplications, improper credits, technical failures or inconsistencies in the information reported by THE SUB-AGENTS are identified. THE USER acknowledges that amounts credited in error do not belong to THE USER, undertakes to refrain from disposing of them, and instructs and authorizes VIIO to order their immediate debit in accordance with Section 5.10; the knowing disposal of funds credited in error gives rise to THE USER's civil and criminal liability.

7.11. Inapplicability of the right of withdrawal.

THE USER acknowledges that, in accordance with the exception provided in Law 1480 of 2011 for goods and services whose price depends on fluctuations in financial markets that the provider does not control, and in view of the nature of the DIGITAL ASSETS and the irreversibility of OPERATIONS once executed in accordance with Section 7.4, the right of withdrawal does not apply to OPERATIONS for the acquisition, disposal, conversion or transfer of DIGITAL ASSETS, nor to those which, by their nature, do not admit reversal. The foregoing is without prejudice to the rights that mandatorily correspond to THE CONSUMER USER in the events in which the law recognizes the right of withdrawal as non-waivable.

8.1. Definition of RESTRICTED TERRITORY.

RESTRICTED TERRITORY means, and accordingly access to and use of THE SERVICES is prohibited for, those who are in any of the following situations: (i) natural or legal persons domiciled, resident, incorporated or located in jurisdictions subject to comprehensive economic or financial sanctions imposed by the Office of Foreign Assets Control of the United States Department of the Treasury (OFAC), by the United Nations Security Council, by the European Union or by the United Kingdom; (ii) persons included in restrictive lists, sanctions lists, designated persons lists or blocking lists administered by any of such authorities, as well as in the lists binding on Colombia; (iii) persons acting on behalf of, for the benefit of or under the control of any of the foregoing; and (iv) natural or legal persons domiciled or resident in, or having the status of taxpayers of, the United States of America.

8.2. Declaration of eligibility.

By accepting THE AGREEMENT, THE USER declares, under oath and with binding effect, that THE USER does not fall within any of the cases set forth in Section 8.1, that THE USER does not act on behalf of any person who falls within them, and that THE USER undertakes to inform VIIO immediately if THE USER's situation changes during the term of THE AGREEMENT. The falsity of this declaration constitutes a serious and material breach.

8.3. Prohibition of circumvention.

The use of virtual private networks (VPN), proxy servers, IP address masking services, third-party documentation, straw men or any other mechanism aimed at concealing the actual location, residence or identity of the person accessing THE SERVICES, or at circumventing the restrictions of Section 8.1, is expressly prohibited. The detection of any such conduct entitles VIIO to suspend or terminate THE AGREEMENT immediately and unilaterally, without the need for prior notice, and to adopt the withholding, blocking and reporting measures that may be appropriate in accordance with Section 25.

8.4. Geographic verification.

VIIO may use automated mechanisms for location verification and access consistency, and may at any time require additional documentation evidencing the residence, domicile or tax status of THE USER. Refusal to provide it enables the measures set forth in Section 13.

9.1. Compliant use.

THE USER undertakes to use THE SERVICES lawfully, in good faith, in accordance with THE AGREEMENT, the acceptable use policy and all the rules applicable to THE USER in THE USER's jurisdiction of residence and in those with which THE USER's activity is related.

9.2. Prohibited conduct.

Without prejudice to the list set forth in Annex 2, it is prohibited to use THE SERVICES, directly or indirectly, for: (i) unlawful activities of any nature, or to conceal, transform, manage or give the appearance of legality to funds derived from unlawful activities; (ii) terrorist financing or financing of the proliferation of weapons of mass destruction; (iii) the evasion of international sanctions or foreign exchange controls; (iv) the trade of controlled substances, weapons, ammunition, explosives or restricted-use materials; (v) activities related to sexual exploitation, child sexual abuse material, human trafficking or forced labor; (vi) pyramid schemes, multilevel fundraising schemes, promises of returns, unauthorized taking of funds from the public or any form of financial fraud; (vii) unauthorized games of chance; (viii) identity theft, document forgery or the use of third-party information without authorization; (ix) the infringement of intellectual property rights; (x) the performance of penetration testing, reverse engineering, automated data extraction, denial-of-service attacks or any act aimed at compromising the security, integrity or availability of THE PLATFORM; (xi) the unauthorized provision, on behalf of third parties, of foreign exchange, remittance, collection or custody services using THE PROFILE, except with the express contractual authorization of VIIO; and (xii) any conduct that exposes VIIO, VIIO Colombia or THE SUB-AGENTS to disproportionate legal, reputational, operational or compliance risks.

9.3. Acceptable use policy.

The acceptable use policy is permanently published on VIIO's website, forms an integral part of THE AGREEMENT and is incorporated into it by reference. Its updates are notified, published and become effective in accordance with Section 21.3. In the event of any discrepancy between the acceptable use policy and Annex 2, the version published on the website shall prevail, as it is the most recently updated.

9.4. Consequences of breach.

Any infringement of this Section or of the acceptable use policy entitles VIIO to suspend, restrict or terminate THE AGREEMENT immediately in accordance with Section 13, to order the withholding of OPERATIONS in progress, to report to the competent authorities when legally required, and to claim the indemnity provided for in Section 17.

10.1. Sole responsibility of THE USER.

THE USER is solely responsible for determining, declaring and complying with all foreign exchange and tax obligations arising from its OPERATIONS before the competent authorities of its country of residence and of any other jurisdiction applicable to it. VIIO does not advise on, determine, assess or certify the foreign exchange or tax treatment of THE USER's OPERATIONS, and assumes no liability whatsoever for the consequences of any non-compliance therewith.

10.2. Foreign exchange duties in Colombia.

It is exclusively incumbent upon THE USER, with respect to the OPERATIONS it carries out and based on its own situation: (i) to determine whether such OPERATIONS constitute foreign exchange operations and, in particular, whether they are among those that must mandatorily be channeled through the foreign exchange market pursuant to the international exchange regime set forth in External Resolution 1 of 2018 of the Board of Directors of Banco de la República and in the regulations that amend, supplement or replace it; (ii) to register and report clearing accounts where applicable; (iii) to file the corresponding foreign exchange declarations and information reports; and (iv) to retain the supporting documentation of its operations for the legally required period. THE USER acknowledges that non-compliance with the foreign exchange regime gives rise to administrative sanctions for which it shall be exclusively liable.

10.3. No status as a foreign exchange market intermediary.

VIIO is not, under Colombian law, a foreign exchange market intermediary, nor is it authorized to act as such, nor does it carry out purchase and sale operations of foreign currency, nor does it channel foreign exchange operations on behalf of THE USER. The existence of BALANCES denominated in DIGITAL ASSETS referenced to a foreign currency does not constitute a holding of foreign currency or a foreign exchange operation.

10.4. Operations with fiat currency abroad.

Operations with fiat currency outside Colombia, the provision of virtual accounts denominated in United States dollars or in euros, and international disbursement are materially executed by Sphere Laboratories, Inc. outside Colombian territory, in its capacity as sub-agent designated by THE USER. Such circumstance does not alter, mitigate or transfer the foreign exchange and tax obligations incumbent upon THE USER pursuant to this Section, nor does it imply that VIIO carries out any reserved activity in Colombia.

10.5. Taxes.

Taxes, levies, contributions, withholdings and other fiscal charges arising from the use of THE SERVICES or from THE USER's OPERATIONS are its exclusive responsibility, to the extent applicable to it under the applicable law. Where VIIO or THE SUB-AGENTS are required by law to make withholdings or to file information reports, they shall do so in accordance with the applicable regulations, and THE USER undertakes to provide the information required of it for such purpose.

11.1. Fees.

VIIO may charge fees and commissions for all services it provides through THE PLATFORM, including the OPERATIONS and other services requested by THE USER, in the manner and at the time VIIO deems appropriate in accordance with industry practices. The fees and commissions in force are published at viio.me/es/tasasytarifas and are disclosed to THE USER before it confirms the OPERATION or requests the respective service; those applicable to each OPERATION are expressly accepted in its authorization flow. THE USER expressly instructs and authorizes VIIO, in execution of the mandate provided for in Section 5, to order the debit from the BALANCE reflected in THE PROFILE of the VIIO Card fees accrued under the VIIO Card agreement entered into with VIIO Colombia, in the amounts published at viio.me/es/tasasytarifas, and their payment to VIIO Colombia, pursuant to Section 5.10. Such debit does not make VIIO an issuer or operator of the VIIO Card, nor does it imply that THE AGREEMENT governs its terms or charges, which are governed by Section 2.4. The inactivity maintenance fee is governed by Section 13.

11.2. Acceptance and accrual.

The confirmation of an OPERATION or the request for a service implies acceptance of the fees disclosed for such OPERATION or service. Fees accrue upon execution of the OPERATION or upon the effective provision of the service in question, and their debit is ordered pursuant to Section 5.10.

11.3. Modification of fees.

VIIO may modify the fees published pursuant to Section 11.1 at any time, in accordance with Section 21. Modifications to the fees published pursuant to Section 11.1 are notified and published through the mechanism provided for in Section 21.3 and apply to OPERATIONS confirmed after their entry into force. In any event, the price, rate and commissions applicable to each OPERATION are shown to THE USER and accepted by it before confirming such OPERATION, pursuant to Section 7.1. THE USER who does not accept the new fees may refrain from carrying out OPERATIONS and cancel THE PROFILE pursuant to Section 14, without penalty.

11.4. Third-party costs.

Commissions, network costs (gas fees), price spreads, bank charges and any other costs charged by third parties unrelated to VIIO are passed on to THE USER and may vary without prior notice because they depend on market or network conditions. The foregoing is without prejudice to the provisions of Section 5.8 regarding the price difference that constitutes VIIO's remuneration.

11.5. Associated taxes.

Taxes levied on fees and commissions, where applicable, are assessed and incorporated in accordance with the law, without THE AGREEMENT governing their treatment, which is governed by the tax regulations in force and by the provisions of Section 10.5.

12.1. Ownership.

THE PLATFORM, THE SITE, the software, the source and object code, the databases, the interfaces, the designs, the graphic elements, the texts, the contents, the manuals, the technical documentation, the trade names, the trademarks, the logos and other distinctive signs used in THE SERVICES are the exclusive property of their owner or of its licensors, and are protected by the applicable industrial property, copyright and unfair competition laws.

12.2. License of use.

VIIO grants THE USER a limited, personal, revocable, non-transferable, non-exclusive and non-sublicensable license to access THE PLATFORM and use THE SERVICES in accordance with THE AGREEMENT, during its term and exclusively for the purposes provided therein. Such license does not entail any transfer of ownership whatsoever and terminates by operation of law upon the termination of THE AGREEMENT. The services of other providers that THE PLATFORM presents as part of its offering are governed, as regards their license, by the terms of such providers.

12.3. Prohibitions.

THE USER is prohibited, without the prior, express and written authorization of the owner, from: copying, reproducing, distributing, publicly communicating, transforming, decompiling, disassembling, reverse engineering, systematically extracting or reusing the content of the databases, creating derivative works, removing proprietary notices, or using the trademarks and distinctive signs on any medium, channel or domain.

12.4. Feedback.

Comments, suggestions, error reports or improvement ideas voluntarily submitted by THE USER may be freely used and implemented by VIIO, without territorial or temporal restriction and without giving rise to any consideration, recognition of authorship or right whatsoever in its favor.

13.1. Grounds for suspension, restriction or termination.

VIIO may suspend or totally or partially restrict the use of THE PROFILE, limit functionalities, order the withholding of OPERATIONS in progress or unilaterally terminate THE AGREEMENT, without giving rise to any indemnification whatsoever in favor of THE USER, when: (i) there is a breach of THE AGREEMENT, of the acceptable use policy or of the applicable law; (ii) unusual or suspicious operations, or operations inconsistent with the declared transactional profile, are identified; (iii) THE USER, its ultimate beneficial owners or its counterparties are included in restrictive lists or linked to the RESTRICTED TERRITORY; (iv) it is not possible to verify identity, update information or evidence the origin of the funds or of the DIGITAL ASSETS; (v) indications of fraud, impersonation, unauthorized access or compromise of credentials are detected; (vi) there is an order from a competent authority; (vii) there are technical or security reasons that justify it; or (viii) the continuation of the relationship exposes VIIO or the entities of the ecosystem to disproportionate legal, reputational or compliance risks.

13.2. Effects and communication.

The measures provided for in Section 13.1 may be adopted without prior notice when advance notification would compromise the purpose of the measure, the security of THE SERVICES or compliance with legal obligations, in particular in matters of prevention of money laundering and terrorist financing, in respect of which the legal duty of confidentiality applies. In all other cases, VIIO shall inform THE USER through the registered channels. While the measure is in force, THE USER may not have access to its BALANCES, without this implying any disregard of its ownership thereof.

13.3. Termination without cause.

VIIO may terminate THE AGREEMENT for reasons of commercial or risk policy, by notice to THE USER given no less than fifteen (15) calendar days in advance, during which period THE USER may dispose of its BALANCES, unless there is a legal impediment, an order from an authority or a compliance measure restricting it.

13.4. Inactivity of THE PROFILE: suspension and maintenance fee.

THE PROFILE shall be deemed inactive when no COMPLETED TRANSACTION has been recorded therein for a continuous period of six (6) months, counted from the date of the last COMPLETED TRANSACTION or, if there is none, from the enablement of THE PROFILE. Once inactivity has occurred, VIIO may suspend THE PROFILE for security and compliance reasons, and the inactivity maintenance fee provided for in Section 13.5 shall accrue, intended to cover the administrative, custody, infrastructure and compliance costs associated with maintaining an inactive PROFILE. The fee constitutes consideration for a service actually rendered and does not entail appropriation of THE USER's BALANCE.

13.5. Amount and limits of the inactivity maintenance fee.

The inactivity maintenance fee shall accrue monthly from the time inactivity occurs pursuant to Section 13.4 and for as long as it persists, in the fixed monthly amount published at viio.me/es/tasasytarifas, which may in no event exceed fifteen United States dollars (USD 15). The setting of the amount and any subsequent change within such cap shall be notified to THE USER through THE PLATFORM or the email address associated with THE PROFILE, no less than ten (10) calendar days prior to its application, and shall be published at viio.me/es/tasasytarifas; no fee shall accrue for an amount that has not been previously published, nor for periods of inactivity prior to the notified application date. When the BALANCE consists of ELIGIBLE ASSETS other than a dollar-referenced asset, the charge shall be settled at its equivalent according to the rate or methodology indicated on THE PLATFORM. The debit of the fee is ordered pursuant to Section 5.10. The fee is subject to the following guarantees: a) it shall in no event exceed the available BALANCE; if such BALANCE is lower than the monthly amount, the fee shall be charged up to the available amount, without generating a negative balance, debt, interest or any charge whatsoever payable by THE USER; b) it ceases to accrue once a COMPLETED TRANSACTION is recorded or, if THE PROFILE is suspended due to inactivity, once THE USER requests its reactivation pursuant to Section 13.6; c) once the BALANCE is exhausted by the successive application of the fee, the sole consequence shall be the deactivation of THE PROFILE, without any obligation whatsoever on the part of THE USER; d) VIIO shall not appropriate the BALANCE nor dispose of it by any other means; and e) the USD 15 cap may only be increased pursuant to Section 21.

13.6. Right to claim remains intact.

For as long as there is a BALANCE, THE USER retains at all times the right to claim it and to request the reactivation of THE PROFILE, and such right shall not prescribe, lapse or be extinguished by the mere passage of time or by inactivity. For such purpose, THE USER must complete identity verification again and satisfy the compliance requirements in force at the time of the request. VIIO does not allocate inactive BALANCES to any fund, entity or purpose other than that corresponding to their owner.

13.7. Effects of termination.

Upon termination of THE AGREEMENT for any reason, THE USER must instruct the withdrawal of its BALANCES within the period that VIIO informs it of, subject to prior compliance with the applicable verification requirements. OPERATIONS in progress shall be carried to completion pursuant to Section 5.7. Pending payment obligations, the provisions on limitation of liability, indemnity, intellectual property, data processing, governing law and dispute resolution, and all others that by their nature must survive, shall survive termination.

13.8. Residual balances.

BALANCES of small amounts shall remain reflected in the name of THE USER and at its disposal, and their permanence shall not generate any yield whatsoever. VIIO may at any time refrain from charging the inactivity maintenance fee on such BALANCES or cease its accrual. The collection of the inactivity maintenance fee accrued pursuant to Sections 13.4 and 13.5 does not constitute appropriation; apart from such fee, VIIO shall in no event appropriate such BALANCES or allocate them to any purpose other than that corresponding to their owner, whose right to claim them is preserved under the terms of Section 13.6, and shall not prescribe, lapse or be extinguished by the passage of time.

13.9. Dissolution or liquidation of VIIO.

If VIIO enters into dissolution or liquidation, it shall so inform THE USER pursuant to Section 23.5. THE USER shall have a period of thirty (30) calendar days, counted from such communication, to instruct the sale, conversion or transfer of its DIGITAL ASSETS and the withdrawal of its BALANCES, in accordance with THE AGREEMENT and the fees in force. Upon expiration of such period, Section 13.10 shall apply.

The provisions of this Section do not apply when, prior to dissolution, THE AGREEMENT is assigned pursuant to Section 22 to an entity that assumes the operation of THE PLATFORM, in which case Section 22.3 shall govern.

13.10. Disposition of BALANCES not withdrawn.

In the case of Section 13.9, if upon expiration of the period provided for therein BALANCES remain in the name of THE USER, THE USER hereby gives VIIO the advance instruction to order the competent sub-agent, or whoever VIIO designates pursuant to Section 7.2: (i) if THE USER has registered a BACKUP ACCOUNT, the conversion into Colombian pesos of the DIGITAL ASSETS and of the other funds reflected in THE PROFILE, at the rate available on THE PLATFORM on the day the period expires, and the transfer of the proceeds to such account; (ii) if it has not registered a BACKUP ACCOUNT but has registered a BACKUP WALLET, the transfer to such wallet of the DIGITAL ASSETS, without conversion, and of the other funds reflected in THE PROFILE, following their conversion into the ELIGIBLE ASSET that VIIO enables for such purpose pursuant to Section 5.2, on the network that THE PLATFORM has enabled for each asset; and (iii) in all other cases, and with respect to whatever cannot be transferred pursuant to items (i) and (ii), the transfer in accordance with the instructions given by THE USER or to the competent authority, as applicable. The published fees and the network costs applicable to the conversion and transfer are debited pursuant to Section 5.10.

Until their transfer, the funds and DIGITAL ASSETS shall be held by the competent sub-agent in the name and on behalf of THE USER. THE USER grants VIIO a specific mandate to order that they be kept available until they can be transferred pursuant to this Section. The provisions of Sections 6.3 and 6.4 apply to them, and THE USER's right to claim them is preserved pursuant to Section 13.6.

The transfer is subject to identity verification and to the compliance requirements of Section 25. The accuracy of the BACKUP ACCOUNT and BACKUP WALLET details, and the compatibility of the latter with each asset and network, are governed by Sections 7.3 to 7.5. BALANCES subject to a legal impediment, an order from an authority or a compliance measure shall be treated in accordance with the provisions thereof. The advance instruction and the mandate provided for in this Section survive the dissolution of VIIO until the transfer of all BALANCES is completed.

14.1. Right of cancellation.

THE USER may request at any time, through the channels provided, the cancellation of THE PROFILE and the termination of THE AGREEMENT, without any penalty whatsoever, provided that it has no pending payment obligations or obligations of any other nature towards VIIO or the entities of the ecosystem, nor OPERATIONS in progress.

14.2. Scope of cancellation.

Cancellation results in the closure of THE USER's entire relationship with VIIO and with any related company involved in the provision of THE SERVICES, including the deactivation of THE PROFILE, the revocation of the operational authorizations granted and the termination of access to THE PLATFORM, without prejudice to the retention of information that is legally mandatory pursuant to Section 18.

14.3. Cases in which cancellation is not available.

The cancellation request shall not proceed, and VIIO may defer it, when: (i) there are pending obligations on the part of THE USER; (ii) there are OPERATIONS in progress or chargebacks being processed; (iii) the purpose of the request is to evade an enforceable and determined obligation on the part of THE USER, of which VIIO shall inform THE USER upon deferring the cancellation; or (iv) THE USER's activity is the subject of an internal investigation, of a request from a competent authority or of analysis within the framework of the system for the prevention of money laundering and terrorist financing.

14.4. Withdrawal of BALANCES.

Prior to cancellation, THE USER must instruct the withdrawal of all of its BALANCES, for which purpose its identity verification must be up to date. Cancellation does not extinguish THE USER's ownership of the BALANCES it has not withdrawn, the treatment of which is governed by Section 13.6.

15.1. Advance consent.

By accepting THE AGREEMENT, THE USER gives its express and informed consent for VIIO, once its death has been duly evidenced, to suspend THE PROFILE in order to preserve the integrity of the BALANCES and to access the information necessary to manage the transfer of the DIGITAL ASSETS and other BALANCES to those who evidence their status as successors.

15.2. Evidence of death and of entitlement.

Once THE USER's death has been evidenced by means of the appropriate documents, VIIO shall transfer the BALANCE of the DIGITAL ASSETS and the other BALANCES reflected in THE PROFILE to the legitimate survivors (heirs or legatees) who evidence their entitlement, following completion of an adequate validation and due diligence process and upon submission of all documents that VIIO requires under the applicable succession law, including, as applicable, the civil death certificate, the public deed of settlement of the estate or the court order allocating the assets, the identification documents of the interested parties and any powers of attorney that may be necessary.

15.3. Due diligence on successors.

The heirs or legatees who receive the BALANCES must submit to the identity verification and due diligence processes applied by VIIO, under the same conditions required of any user, including screening against restrictive lists. VIIO may refrain from making the transfer until such processes have been satisfactorily completed, or when there is a dispute among those claiming rights over the BALANCE, in which event VIIO shall keep the BALANCES suspended until a final decision of a competent authority or a written agreement of all interested parties is evidenced to it.

15.4. Custody and absence of yield during the process.

While the process described in this Section is being carried out, THE CUSTODIAN maintains technical custody of the DIGITAL ASSETS and VIIO retains the BALANCES reflected in THE PROFILE, and their permanence shall not generate any interest, yield or return whatsoever in favor of the estate.

15.5. Discharging effect.

The transfer made pursuant to this Section to those who have duly evidenced their entitlement fully discharges VIIO vis-a-vis the estate and third parties, without prejudice to any actions they may bring against one another.

16.1. "As is" provision.

THE SERVICES and THE PLATFORM are provided "as is" and "as available," without any warranty, express or implied, of continuity, uninterrupted operation, absence of errors, fitness for a particular purpose, compatibility with certain devices, or specific results. VIIO does not warrant that THE SERVICES will be permanently available or that they will be free from failures, interruptions, suspensions for maintenance, cyberattacks, or performance degradation. With respect to THE CONSUMER USER, the provisions of this Section 16.1 do not limit the warranties of quality, fitness, and safety that the law grants to THE CONSUMER USER in connection with THE SERVICES.

16.2. VIIO's own obligations.

VIIO is liable to THE USER for the diligent performance of its own obligations, which comprise: (i) keeping THE PLATFORM available under reasonable operating conditions, without prejudice to the interruptions provided for in THE AGREEMENT; (ii) transmitting THE USER's instructions diligently and accurately to the competent sub-agent; (iii) adopting reasonable security measures over THE PLATFORM and over the information it processes; (iv) maintaining an adequate technical integration with THE SUB-AGENTS; (v) reconciling and faithfully reflecting in THE PROFILE the BALANCES and the status of the OPERATIONS as reported by THE SUB-AGENTS; (vi) providing THE USER with truthful, sufficient, and timely information about THE SERVICES and the OPERATIONS; (vii) diligently selecting and monitoring THE SUB-AGENTS; and (viii) handling requests, complaints and claims under the terms of Section 19. The material execution of the OPERATIONS is the responsibility of THE SUB-AGENTS in accordance with Section 5.

16.3. Exclusion of liability for acts of third parties and external causes.

VIIO is not liable for damages or losses arising from: (i) acts, omissions, failures, breaches, security incidents, insolvency, or cessation of operations of THE SUB-AGENTS, THE CUSTODIAN, financial institutions, payment gateways, or any third party; (ii) failures, congestion, forks, attacks, or protocol changes of blockchain networks; (iii) errors by THE USER in the instructions, under the terms of Section 7.5; (iv) unauthorized access to THE PROFILE resulting from THE USER's breach of its duties to safeguard credentials; (v) failures of THE USER's connectivity, devices, or software; (vi) decisions of authorities, regulatory changes, or compliance measures; (vii) the volatility or loss of value of DIGITAL ASSETS; and (viii) events of force majeure or fortuitous events in accordance with Section 24.5. VIIO is not liable for the acts or omissions of THE SUB-AGENTS, THE CUSTODIAN, blockchain networks, financial institutions, or other third parties beyond its control, except to the extent that the damage results from VIIO's breach of its own obligations set forth in Section 16.2, in particular in the selection, integration, monitoring, security, transmission, reconciliation, or information, and except as provided in Section 5.9.

16.4. No joint and several liability.

VIIO, VIIO Colombia, and THE SUB-AGENTS, including Sphere Laboratories, Inc., the PSPA, and THE CUSTODIAN, are not jointly and severally liable among themselves or to THE USER. Each entity is liable autonomously, separately, and independently for its own functional scope and under the contractual regime governing its activities. Belonging to the same ecosystem, the use of a common brand, or the technological integration among them does not give rise to joint and several liability, commingling of assets, business unity, or subsidiary liability of any nature. The foregoing is without prejudice to any joint and several liability that a mandatory legal provision may impose with respect to specific facts. The foregoing is without prejudice to the liability that VIIO assumes toward THE USER in accordance with Section 5.9.

16.5. Exclusion of indirect damages.

Without prejudice to the provisions of Section 16.7, VIIO shall not be liable for indirect, incidental, consequential, special, punitive, or exemplary damages, nor for lost profits, loss of opportunity, loss of data, loss of customers, reputational damage, or loss of value of DIGITAL ASSETS, even if VIIO has been advised of the possibility of their occurrence.

16.6. Scope of compensable damages.

VIIO shall be liable for direct damages that were reasonably foreseeable at the time THE AGREEMENT was entered into and that are caused to THE USER as a direct consequence of VIIO's breach of its own obligations set forth in Section 16.2.

16.7. Limits of the exclusions.

The exclusions and limitations of liability set forth in this Section do not apply in cases of wilful misconduct or gross negligence by VIIO, nor do they limit the liability that VIIO bears by law toward THE CONSUMER USER with respect to the rights that the law grants to THE CONSUMER USER on a non-waivable basis.

16.8. Allocation of risk.

THE USER acknowledges that the limitations in this Section constitute an essential element of the allocation of risks between the parties and that, without them, the economic terms of THE SERVICES would be substantially different.

16.9. Assumption of risk.

Anyone who uses THE SERVICES, by the mere fact of doing so, acknowledges and accepts that: (i) they are aware of the risks associated with operations involving DIGITAL ASSETS described in the block of warnings preceding THE AGREEMENT and in its other provisions; (ii) they assume the risks arising from the use of THE SERVICES, including those inherent to DIGITAL ASSETS, blockchain networks, and custody described in Section 6.5; and (iii) VIIO shall not be liable for any risk or adverse result associated with the failure or interruption of the technology used for the operation of THE SERVICES, unless it corresponds to an action or omission directly attributable to VIIO. The provisions of this Section 16.9 are without prejudice to Sections 5.9 and 16.7.

17.1. Scope.

THE USER shall hold harmless VIIO, VIIO Colombia, and THE SUB-AGENTS, as well as their respective directors, employees, and agents, solely against third-party claims and against direct, reasonable, and duly documented losses, damages, costs, or expenses arising directly from an act or omission attributable to THE USER consisting of: (i) a breach of THE AGREEMENT, its annexes, or the acceptable use policy; (ii) a violation of applicable law or of third-party rights; (iii) the inaccuracy, falsity, or material omission of the information or representations provided; (iv) the improper, fraudulent, or unauthorized use of THE PROFILE or THE SERVICES when attributable to THE USER; or (v) a breach attributable to THE USER of its foreign exchange or tax obligations.

17.2. Exclusions and limits.

The indemnification obligation shall not extend to the ordinary consequences of OPERATIONS validly instructed by THE USER where there is no breach or other act attributable to THE USER, nor to the portion of a claim or loss caused by the breach, wilful misconduct, gross negligence, negligence, or own fault of any of the indemnified persons or of a third party under their control. In no event shall this Section limit non-waivable rights granted to THE CONSUMER USER by applicable law.

17.3. Management of the defense.

VIIO shall promptly inform THE USER of any covered claim and shall provide THE USER with reasonable information for its evaluation. VIIO may assume the defense with counsel of its choice; the costs that may be passed on to THE USER must be reasonable, documented, and relate exclusively to an actually covered claim. THE USER may participate in the defense with advisors at its own cost. No settlement imposing on THE USER an admission of liability, a non-monetary obligation, or an uncovered payment may be entered into without THE USER's prior consent, which shall not be unreasonably withheld.

17.4. Survival.

The indemnification obligation shall survive the termination of THE AGREEMENT solely with respect to events occurring during its term and within the scope set forth in this Section.

18.1. Data controller with respect to THE AGREEMENT.

The data controller of the personal data collected and processed for the provision of the account and platform services governed by THE AGREEMENT is VIIO (Quinate Technologies LLC), in its capacity as operator of THE PLATFORM and party to this contractual relationship. VIIO determines the purposes and essential means of such processing and is accountable for it to the data subjects and to the data protection authority, in accordance with Law 1581 of 2012, its regulatory decrees, and External Circular 001 of September 18, 2025 of the Superintendency of Industry and Commerce.

18.2. Segregated responsibility of VIIO Colombia.

VIIO Colombia (Persimon S.A.S.) is the data controller of the personal data it processes directly in connection with the provision of the services associated with the VIIO Card, an operation governed by its own contract and its own information processing policy. VIIO Colombia's responsibility is limited exclusively to that scope and does not extend to the processing governed by THE AGREEMENT, for which the data controller is VIIO. Each entity has its own processing policy, which THE USER must consult depending on the product in question. The foregoing is without prejudice to VIIO Colombia acting as data processor on behalf of VIIO with respect to the personal data processed in connection with THE AGREEMENT, under the terms of the Privacy and Personal Data Processing Policy.

18.3. Free, prior, express, and informed authorization.

Prior to the commencement of processing, VIIO informs THE USER of the personal data it collects and the purposes for which it does so, and obtains THE USER's authorization in a free, prior, express, and informed manner, through mechanisms that allow its retention and subsequent consultation. Registration on THE PLATFORM and acceptance of THE AGREEMENT do not replace such authorization where the law requires it to be given separately.

18.4. Purposes.

THE USER's personal data are processed for the following purposes: (i) the creation, administration, and maintenance of THE PROFILE and the provision of THE SERVICES; (ii) identity verification and due diligence, including document and biometric validation and screening against restrictive lists and legitimate information sources; (iii) the prevention, detection, and investigation of fraud, money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction; (iv) compliance with legal, regulatory, and contractual obligations and responding to requests from competent authorities; (v) the security of THE PLATFORM, the traceability of OPERATIONS, and incident management; (vi) handling requests, complaints, claims, and support requests; (vii) the preparation of internal analyses, statistics, and service improvements; and (viii) sending commercial communications, advertising, promotions, and offers, the latter being an ancillary purpose under the terms of Section 18.5.

18.5. Differentiated consent: necessary and ancillary purposes.

A distinction is made between: a) the purposes necessary for the performance of THE AGREEMENT, the provision of THE SERVICES, and compliance with legal obligations, for which processing is an indispensable condition of the service, such that refusal or revocation of the authorization prevents the provision of the service; and b) ancillary purposes, such as advertising, marketing, sending offers, or creating commercial profiles, for which THE USER may refuse or revoke the authorization at any time, without affecting the provision of the main service or giving rise to any adverse consequence. The channels for exercising such refusal or revocation are set out in the processing policy and in THE SERVICES.

18.6. Legitimate purpose, minimization, and time limitation.

VIIO collects only the data that are suitable, relevant, and necessary for the stated purposes, which are legitimate, specific, and previously communicated to the data subject. The data are retained for the time necessary to fulfill such purposes and, in any event, for the periods imposed by the applicable legal retention obligations, after which they are deleted or anonymized in accordance with the processing policy.

18.7. Biometric data: enhanced processing.

The processing of biometric data for identity verification and fraud prevention requires THE USER's explicit and separate authorization, which is requested independently of the other authorizations, informing THE USER of the specific purpose and the consequences of refusal. Such data are subject to enhanced security measures and are deleted once the contractual relationship ends or the purpose that justified their collection ceases, unless a legal obligation requires their retention for a longer period.

18.8. Device permissions.

THE USER freely decides whether to grant access to information on THE USER's device, such as location, camera, or notifications. Such permissions are requested only when necessary for a specific functionality, explaining their purpose at the time of the request, and may be revoked at any time from the device settings, with the consequent limitation of the associated functionality. VIIO does not access the image gallery or the contact list of THE USER's device for purposes of collection, location, or pressure to pay.

18.9. Automated decisions.

Certain processes, including identity verification, risk assessment, and fraud detection, may involve automated decisions that significantly affect THE USER, such as the rejection of a registration or of an OPERATION. THE USER has the right to obtain a clear and understandable explanation of such decisions, including information on the main criteria used, as well as to request review of the decision by a natural person, through the channels provided for in Section 18.12.

18.10. Rights of the data subject.

THE USER, in its capacity as data subject, has the right to: know, update, and rectify its personal data; request proof of the authorization granted, except in cases where the law exempts such duty; be informed of the use made of its data; file complaints with the Superintendency of Industry and Commerce for violations of the data protection regime; revoke the authorization and request the deletion of the data when there is no legal or contractual duty preventing it; and access its personal data free of charge.

18.11. International transfer and transmission of data.

THE USER acknowledges and accepts that the provision of THE SERVICES involves flows of personal data to entities located outside Colombian territory, in particular to VIIO in the United States of America, to THE SUB-AGENTS, and to the other providers that THE PLATFORM presents as part of its offering, to the extent necessary for the performance of the engagement and for its provision. Such flows are based on (i) the express and informed authorization granted by the data subject and (ii) the necessity of the processing for the performance of THE AGREEMENT. Where the recipient country does not have an adequate level of protection in accordance with the standards set by the Superintendency of Industry and Commerce, the operation is supported by personal data transmission agreements and by contractual safeguards that guarantee levels of protection equivalent to those provided for under Colombian law, in application of the principle of demonstrated accountability. Likewise, THE USER authorizes the transfer of its personal data to the assignee of THE AGREEMENT in accordance with Section 22, whatever its jurisdiction, which shall assume the capacity of data controller under the terms of the Privacy and Personal Data Processing Policy, which shall be communicated to THE USER with the notice provided for in Section 22.2.

18.12. Service channel and incident management.

For the exercise of the data subject's rights, the submission of inquiries and claims regarding personal data, and the reporting of information security incidents, VIIO provides the channel soporte@viio.me, which is handled in accordance with the legal time limits. VIIO also has a local point of contact for handling incidents and requests from the data protection authority, identified in the processing policy.

18.13. Definition of roles.

The roles of VIIO and VIIO Colombia in the processing of personal data are those set forth in Sections 18.1 and 18.2, and are further developed in the Privacy and Personal Data Processing Policy, together with the identification of the data processors.

18.14. Reference to the Processing Policy.

The detailed development of the processing (including the internal procedures for handling inquiries and claims, the detailed retention periods, the technical, human, and administrative security measures, and the details of the data processors) is set out in the Privacy and Personal Data Processing Policy available at https://viio.me/, which forms an integral part of THE AGREEMENT and is incorporated into it by reference.

19.1. Single point of contact.

VIIO provides a single point of contact for receiving and handling requests, complaints and claims related to THE SERVICES, available at soporte@viio.me and through the service channel within THE PLATFORM. The submission and processing of requests, complaints and claims is free of charge; no charge, fee, or amount of any kind is collected for their filing or handling.

19.2. Content and procedure.

The request must identify THE USER, describe the facts and, where applicable, the OPERATION that is the subject of the claim, and be accompanied by the available supporting documents. VIIO shall acknowledge receipt and provide a substantive response within fifteen (15) business days following its filing; where it is not possible to address it within such period, VIIO shall inform THE USER of the reasons for the delay and the date on which the request will be addressed.

19.3. Claims regarding material execution.

In the case of claims whose subject matter is the material execution of an OPERATION: (i) if it corresponds to a sub-agent identified in Annex 3, VIIO shall handle the claim and manage it before such sub-agent, without THE USER having to contact the sub-agent, and liability for the execution is governed by the terms of such sub-agent; and (ii) in all other cases, VIIO shall handle it and respond directly in accordance with Section 5.9. In both cases, the terms of Section 19.2 apply.

19.4. Rights of THE CONSUMER USER.

The provisions of this Section are without prejudice to the non-waivable right of THE CONSUMER USER to resort to the Superintendency of Industry and Commerce or to the ordinary courts, in accordance with Section 20.

20.1. Governing law and express submission.

THE AGREEMENT is governed by and construed in accordance with Colombian law. VIIO (Quinate Technologies LLC), notwithstanding being a company incorporated abroad, expressly and irrevocably submits to Colombian law and jurisdiction for all purposes arising from THE AGREEMENT with respect to users domiciled in Colombia, and waives the right to invoke any other forum or law that may correspond to it by reason of its nationality or domicile.

20.2. Direct settlement.

Before resorting to the mechanisms provided for in Sections 20.3 and 20.4, the parties shall endeavor to resolve their differences through direct settlement, via the channel provided for in Section 19, for a period of thirty (30) calendar days from the written notice of the dispute. This requirement is not enforceable against THE CONSUMER USER and does not suspend THE CONSUMER USER's legal time limits.

20.3. Arbitration with THE NON-CONSUMER USER.

Disputes arising between VIIO and THE NON-CONSUMER USER shall be finally resolved by arbitration administered by the Arbitration and Conciliation Center of the Bogotá Chamber of Commerce, in accordance with its rules and Law 1563 of 2012. The tribunal shall consist of one (1) arbitrator appointed in accordance with the center's rules, shall decide in accordance with law, shall sit in the city of Bogotá D.C., and the proceedings shall be conducted in the Spanish language. The award shall be final and binding on the parties.

20.4. Non-waivable rights of THE CONSUMER USER.

THE CONSUMER USER retains, on a non-waivable basis, the right to resort to the Superintendency of Industry and Commerce, in the exercise of its jurisdictional or administrative powers, and to the Colombian ordinary courts, in accordance with Law 1480 of 2011. The arbitration clause provided for in Section 20.3 is not enforceable against THE CONSUMER USER and does not limit, restrict, or condition the exercise of such rights.

20.5. Class and popular actions.

Nothing in this Section restricts THE USER's right to bring or join class actions, popular actions, or any other mechanism for the protection of collective rights recognized by Colombian law.

21.1. Adhesion nature.

THE AGREEMENT is an adhesion contract, the conditions of which are established uniformly by VIIO for users generally and are not subject to individual negotiation, without prejudice to the application of the consumer protection regime.

21.2. Power to amend.

VIIO may amend, update, supplement or replace THE AGREEMENT, its annexes, the acceptable use policy and the fees published pursuant to Section 11.1 at any time, for operational, technical, commercial, security, risk or regulatory compliance reasons, without the authorization of THE USER being required.

21.3. Notice and entry into force.

VIIO shall notify THE USER of the amendments through THE PLATFORM or the email address associated with THE PROFILE, and shall publish them permanently on THE SITE, indicating the version and the effective date. The amendments shall enter into force from the moment of their notification, without the need for prior notice or the express acceptance of THE USER.

21.4. Acceptance by continued use.

The use of THE SERVICES after notification of an amendment constitutes full acceptance of the new version, which shall govern the OPERATIONS carried out from that moment onward.

21.5. Free exit at no cost.

THE USER who does not agree with an amendment may cease using THE SERVICES and request the cancellation of THE PROFILE pursuant to Section 14, with full freedom and without penalty. The cancellation of THE PROFILE and the exercise of the right of exit carry no cost whatsoever, without prejudice to the fees and commissions accrued previously pursuant to Sections 11 and 13. The exercise of this right is the means provided for expressing disagreement with the amendments.

21.6. Changes required by regulation.

When an amendment is necessary to comply with the law, regulation or an order of a competent authority, or to manage a regulatory risk, VIIO shall limit it to what is objectively required and shall communicate it to THE USER in advance, provided that the law and the circumstances so permit.

21.7. Changes to THE SUB-AGENTS.

The replacement, addition or removal of THE SUB-AGENTS and partners does not constitute an amendment of THE AGREEMENT and is governed by Section 3.3.

21.8. Non-waivable rights.

No amendment may affect the non-waivable rights of THE CONSUMER USER, pursuant to Law 1480 of 2011 and other applicable regulations.

22.1. Pre-authorized assignment.

THE USER authorizes in advance, by this act and for all legal purposes, VIIO to assign, novate, subrogate or transfer THE AGREEMENT, as well as the rights and obligations arising therefrom, in whole or in part, to a company of its business group duly authorized in the corresponding jurisdiction, to its successors in any capacity or to any entity that assumes the operation of THE PLATFORM, without any additional authorization, acceptance or approval of THE USER being required.

22.2. Notice of the assignment.

The assignment shall be notified to THE USER through the mechanism provided for in Section 21.3 and shall take effect from its notification. When the assignment entails an amendment of THE AGREEMENT, it shall be governed entirely by Section 21.

22.3. Effects and guarantees for THE USER.

The assignee shall be subrogated to the entirety of VIIO's contractual position and shall assume all of its obligations under THE AGREEMENT. The assignment may not worsen the conditions of THE USER, nor affect its rights under THE AGREEMENT, nor the non-waivable rights of THE CONSUMER USER. THE USER who does not agree with the assignment may exercise its right of free exit at no cost pursuant to Sections 14 and 21.5.

22.4. Change of the service provider.

THE USER accepts that the change of the entity providing THE SERVICES or of its jurisdiction shall be carried out through the assignment provided for in this Section and shall be communicated pursuant to Section 22.2, without requiring the execution of a new contract.

22.5. Subcontracting and replacement.

VIIO may likewise subcontract, in whole or in part, the performance of its obligations and replace THE SUB-AGENTS and partners under the terms of Sections 3.3 and 5.4, without this constituting an assignment or requiring the authorization of THE USER.

22.6. Assignment by THE USER.

THE USER may only assign its contractual position, its rights or its obligations under THE AGREEMENT with the prior, express and written authorization of VIIO. Any assignment made in contravention of the foregoing shall be ineffective and shall produce no effect whatsoever vis-à-vis VIIO. THE PROFILE is personal and non-transferable and may not be sold, leased, lent, assigned for use or managed by third parties.

22.7. Successors and assigns.

THE AGREEMENT binds and benefits the parties and their respective successors and assigns authorized pursuant to this Section.

23.1. Consent to electronic contracting.

THE USER expressly consents to the entirety of the contractual relationship being documented, entered into, performed and amended by electronic means, and acknowledges that the data messages, electronic records and documents generated through THE PLATFORM have full validity, evidentiary effect and binding force, pursuant to Law 527 of 1999 and the principle of functional equivalence.

23.2. Expression of will.

The acceptance of THE AGREEMENT and its annexes, the authorization for data processing, the confirmation of OPERATIONS and any other expression of will made through the authentication mechanisms provided by THE PLATFORM (including username and password, one-time codes, two-factor authentication factors, biometric validation or acceptance through interaction with the interface) constitute the electronic signature of THE USER, are fully attributable to THE USER and produce the same effects as a handwritten signature.

23.3. Validity and evidence.

The parties acknowledge that the data messages and electronic signatures used within the framework of THE AGREEMENT have the legal validity and evidentiary force recognized to them by Law 527 of 1999. VIIO retains technical evidence of the acceptance of THE AGREEMENT and of the instructions given, which includes, without being limited to, the identification records of THE USER, the timestamps, the accepted version and the mechanisms that allow the integrity of such messages to be verified.

23.4. Integrity and retention.

VIIO retains the electronic records of the expressions of will and of the OPERATIONS under conditions that allow their integrity, their authorship and the moment of their issuance to be verified, and shall make them available to THE USER or to the competent authority when appropriate. Such records constitute evidence of the OPERATIONS and of the instructions given, without prejudice to the right of THE USER to contest them.

23.5. Communications.

Communications from VIIO to THE USER shall be deemed validly made when sent to the email address or telephone number registered in THE PROFILE, or when published or notified within THE PLATFORM. It is the burden of THE USER to keep such data updated and to periodically check its channels, including spam folders. Communications from THE USER to VIIO shall be directed to the channels provided for in Sections 19.1 and 18.12.

23.6. Language.

Communications and contractual documents are issued in the Spanish language, which is the language of THE AGREEMENT pursuant to Section 24.8.

24.1. Order of precedence.

In the event of a contradiction between the documents governing the relationship, the order of precedence shall be as follows: (i) the mandatory rules of Colombian law, in particular those on consumer protection and personal data protection; (ii) the VIIO Card agreement, in all matters relating to that product; (iii) the separate agreement entered into with legal entity clients pursuant to Section 2.5, with respect to what is expressly regulated therein; (iv) the annexes of THE AGREEMENT and the acceptable use policy; and (v) the body of THE AGREEMENT. In all matters not provided for in the documents of higher precedence, THE AGREEMENT shall govern in its entirety.

24.2. Entire agreement.

THE AGREEMENT, together with its annexes and the documents incorporated by reference, constitutes the entire understanding between the parties with respect to its subject matter and supersedes any prior agreement, offer, communication, advertising or understanding, whether oral or written, without prejudice to the legal regime on information and advertising vis-à-vis the consumer. With respect to the OPERATIONS confirmed as of its entry into force, this version supersedes the previous versions of THE AGREEMENT.

24.3. Severability.

If any provision of THE AGREEMENT is declared null, ineffective, unenforceable against third parties or unenforceable by a competent authority, such declaration shall affect only the respective provision, which shall be deemed replaced by one that, being valid, best reflects the original intention of the parties, with the remaining provisions continuing in full force.

24.4. No waiver.

The abstention, tolerance or delay of either party in exercising a right or power arising from THE AGREEMENT does not constitute a waiver thereof, and its partial exercise does not prevent its subsequent exercise or the exercise of other rights. Any waiver must be express and in writing, and does not tacitly amend THE AGREEMENT.

24.5. Force majeure and fortuitous event.

Neither party shall be liable for the non-performance or delay in the performance of its obligations when this is due to force majeure or a fortuitous event, understood as unforeseeable and irresistible events beyond its control, including, by way of illustration: natural disasters, internal unrest, acts of authority, regulatory changes that prevent the provision of the services, widespread failures of telecommunications or electricity supply, large-scale cyberattacks, massive outages of technology infrastructure providers, suspension of services by financial institutions or structural failures of blockchain networks. The affected party shall report the occurrence of the event as soon as possible and shall make reasonable efforts to mitigate its effects.

24.6. Survival.

The provisions relating to limitation of liability, indemnity, intellectual property, processing of personal data, outstanding payment obligations, governing law and dispute resolution, Sections 13.9 and 13.10, and the other provisions that by their nature must remain in effect, survive the termination of THE AGREEMENT for any reason.

24.7. No partnership.

THE AGREEMENT does not create between the parties any partnership, association, employment contract, commercial agency, distribution, joint venture or relationship of representation other than the mandate of execution expressly agreed upon in Section 5.

24.8. Language.

THE AGREEMENT is executed in the Spanish language, which version shall prevail for all purposes of interpretation and performance. Any translation is provided solely for convenience purposes and has no interpretive value.

24.9. Headings and cross-references.

The section headings are included to facilitate reading and do not affect the interpretation of their content. Cross-references to sections shall be understood as made to those of THE AGREEMENT, unless expressly indicated otherwise.

24.10. Retention.

VIIO shall keep available to THE USER, on THE SITE, the current version of THE AGREEMENT and may make available the history of previous versions.

24.11. Effectiveness and term.

THE AGREEMENT is effective from the effective date indicated in its heading, applies to THE SERVICES provided and to the OPERATIONS confirmed from that date, and is of indefinite duration, without prejudice to its termination pursuant to Sections 13 and 14. Its amendments are governed by Section 21.

25.1. Compliance commitment.

VIIO, directly or through the entities of the VIIO ecosystem and THE SUB-AGENTS, maintains policies, procedures and controls aimed at preventing THE SERVICES from being used as an instrument for money laundering, terrorist financing, financing of the proliferation of weapons of mass destruction or the evasion of international sanctions, and applies them on an ongoing basis.

25.2. Representations of THE USER.

THE USER represents, under oath and as an essential condition for the perfection of THE AGREEMENT, that: (i) its funds and the DIGITAL ASSETS it uses come from lawful activities; (ii) it will not allow third parties to make deposits in its favor with funds from unlawful activities, nor will it carry out OPERATIONS intended for such activities or in favor of persons related to them; (iii) it acts in its own name and on its own behalf, unless it has expressly declared otherwise and VIIO has accepted it; (iv) the information provided regarding its identity, economic activity, source of funds and ultimate beneficial owners is truthful and verifiable; and (v) neither it, nor its ultimate beneficial owners, nor its counterparties are included in restrictive lists or fall within the circumstances of the RESTRICTED TERRITORY.

25.3. Ongoing due diligence and supporting documents.

VIIO may require at any time, and THE USER undertakes to provide, the information and supporting documents that make it possible to evidence its identity, its economic activity, the source and destination of the funds and of the DIGITAL ASSETS, the identification of its ultimate beneficial owners and the nature of its counterparties. Refusal, unjustified delay or the provision of inaccurate information entitle VIIO to adopt the measures provided for in Section 13. In the case of transfers of DIGITAL ASSETS, THE USER undertakes to provide, in the form and at the time THE PLATFORM requires, the originator and beneficiary information required by applicable law and international standards on transfers of virtual assets, including, as applicable, the identity of the holder of the originating or destination wallet or account and its relationship with THE USER, and represents that such information is truthful and complete.

25.4. Authorization for inquiries and reporting.

THE USER expressly authorizes VIIO to consult its information in restrictive lists, public and private databases, credit bureaus and legitimate information sources, as well as to file, when required by law, the corresponding reports with the competent authorities. THE USER acknowledges that such reports are protected by the legal duty of confidentiality, by virtue of which VIIO is not obliged to inform THE USER of their existence or content, and that filing them gives rise to no liability whatsoever on the part of VIIO. THE USER likewise authorizes VIIO to transmit the information referred to in Section 25.3 to THE SUB-AGENTS, to virtual asset service providers and to the other entities involved in the transfer, to the extent required by applicable law or such standards. VIIO may refrain from transmitting the instruction or order the withholding or the return to origin of a transfer when such information is not provided, is incomplete or cannot be verified, pursuant to Section 25.5.

25.5. Freezing measures and return to origin.

When so required by law, an order of a competent authority or the applicable risk policies, VIIO may refrain from transmitting the corresponding instruction or order THE SUB-AGENTS to withhold, preventively freeze, not execute or return to their origin the funds or DIGITAL ASSETS involved in an OPERATION, without this constituting a breach of THE AGREEMENT or giving rise to any liability, indemnification or recognition of damages whatsoever in favor of THE USER.

25.6. Termination due to compliance risk.

The materialization of a risk of money laundering, terrorist financing, financing of the proliferation of weapons of mass destruction or non-compliance with international sanctions, or the mere impossibility of reasonably mitigating it, constitutes grounds for the immediate and unilateral termination of THE AGREEMENT, without prior notice and without indemnification.

1. Purpose.

This Annex 1 sets forth the express consent of THE USER to enter into, perform, amend and terminate the contractual relationship by electronic means, as well as to receive by such means all communications, notices, documents, receipts and notifications related to THE SERVICES.

2. Functional equivalence.

THE USER acknowledges that, pursuant to Law 527 of 1999, data messages satisfy the requirements of writing, signature and original, and that they shall not be denied legal effect, validity or binding force solely on the grounds that they are in the form of a data message.

3. Accepted electronic signature methods.

The following, among others and without limitation, constitute the electronic signature of THE USER: (i) entry of username and password; (ii) one-time codes sent to the registered channels; (iii) two-factor authentication factors; (iv) facial or fingerprint biometric validation; (v) acceptance by means of a checkbox, swipe or tap on the controls enabled on THE PLATFORM; and (vi) a signature drawn on touch-screen devices when THE PLATFORM requires it. THE USER declares that such methods are reliable and appropriate for the purposes for which they are intended.

4. Attribution.

Every expression of will issued through the methods described is deemed to have been made by THE USER, unless proven otherwise, the burden of which lies with THE USER, and produces full legal effects, including the confirmation of irreversible OPERATIONS pursuant to Section 7.

5. Technical requirements.

In order to receive and retain electronic communications, THE USER requires a device with an internet connection, an active email account and the ability to view and store files in commonly used formats. THE USER undertakes to keep such means operational and up to date.

6. Revocation of consent.

THE USER may at any time revoke its consent to electronic contracting and communications; however, THE USER acknowledges that such revocation prevents the provision of THE SERVICES, as they are entirely digital in nature, and that it produces the effects of a cancellation request pursuant to Section 14.

7. Retention and access.

VIIO retains the electronic records of the expressions of will and makes available to THE USER, through THE PROFILE, the history of its OPERATIONS and the corresponding receipts, which THE USER may download and store on a durable medium.

1. Incorporation and reference.

VIIO's acceptable use policy is permanently published on VIIO's website https://viio.me/ and forms an integral part of THE AGREEMENT. This Annex 2 sets out the categories of prohibited uses and businesses, and such enumeration is not exhaustive.

2. Unlawful and high regulatory risk activities.

The use of THE SERVICES is prohibited in connection with: activities constituting a crime under applicable law; money laundering and related activities; terrorist financing and financing of the proliferation of weapons of mass destruction; corruption, transnational bribery and influence peddling; evasion of international economic sanctions; and smuggling or customs fraud.

3. Restricted goods and services.

The use of THE SERVICES is prohibited for the purchase, sale, brokerage or financing of: narcotic or psychotropic substances or controlled chemical precursors; weapons, ammunition, explosives, war materiel and their components; cultural property, fauna, flora or minerals whose trade is prohibited or not certified; controlled-sale medicines without authorization; identity documents, credentials or third-party information; and goods or services that infringe intellectual property rights.

4. Exploitation activities and activities against human dignity.

The use of THE SERVICES is strictly prohibited in connection with sexual exploitation, child sexual abuse material, human trafficking, migrant smuggling, forced labor or any activity that violates human dignity.

5. Prohibited financial schemes.

The use of THE SERVICES is prohibited for: pyramid schemes, multilevel fund-raising schemes or unauthorized "libranzas" (payroll-deduction loans); massive and habitual raising of funds from the public without authorization; offering yields or returns to third parties charged against the BALANCES reflected in THE PROFILE; management of third-party funds without express contractual authorization from VIIO; and any form of financial fraud, including impersonation maneuvers and investment scams.

6. Gaming, betting and activities subject to special authorization.

The use of THE SERVICES is prohibited in games of chance, betting or lotteries that lack the authorization of the competent authority in the corresponding jurisdiction.

7. Conduct against THE PLATFORM.

The following are prohibited: accessing or attempting to access without authorization THE PLATFORM, its systems or the profiles of other users; introducing malware, ransomware or harmful code; performing reverse engineering, decompilation or automated data extraction; carrying out denial-of-service attacks; circumventing security controls, operational limits or geographic restrictions; and creating multiple profiles for the purpose of circumventing limits or measures adopted by VIIO.

8. Use on behalf of third parties.

It is prohibited to use THE PROFILE to provide, on behalf of third parties and without express contractual authorization from VIIO, exchange, remittance, collection, disbursement, custody or brokerage services, as well as to allow third parties to use THE PROFILE or its credentials.

9. Consequences.

The breach of any of the prohibitions of this Annex 2 or of the acceptable use policy entitles VIIO to adopt, immediately and without prior notice, the measures provided for in Sections 13 and 25, and gives rise to the indemnity obligation provided for in Section 17.

1. Purpose.

This Annex 3 identifies the named sub-agent through which certain OPERATIONS instructed by THE USER are materially executed, designated and accepted by THE USER pursuant to Section 5.3, and the entity that operates the VIIO Card. The other members of THE SUB-AGENTS, including the PSPA and THE CUSTODIAN, are described by their functional scope in Section 3.2.

2. List.

Functional scope	Entity	Capacity
Fiat currency operations outside Colombia; virtual accounts denominated in United States dollars and in euros; on-ramp and off-ramp; international disbursement	Sphere Laboratories, Inc. (a Delaware corporation, United States of America)	Sub-agent. Materially executes the instructions relating to fiat currency abroad and the provision of virtual accounts, outside Colombian territory
Operation of the VIIO Card	VIIO Colombia (Persimon S.A.S.), a Colombian company	Operator of the VIIO Card, under its own contract.

3. Updates.

VIIO may update this Annex 3 without prior notice to THE USER and without this implying an amendment to THE AGREEMENT, pursuant to Sections 3.3 and 5.4. The designation made by THE USER extends to the sub-agents resulting from such update.

4. Liability regime.

Each entity is liable autonomously and independently for its corresponding scope, under its own terms and conditions. There is no joint and several liability among VIIO, VIIO Colombia and THE SUB-AGENTS, pursuant to Section 16.4. The foregoing is without prejudice to the liability that VIIO assumes toward THE USER pursuant to Section 5.9.