General Term of Use - Exclusive Offer Mining Program

TABLE OF CONTENTS

1     Definitions

2     Purpose

3     Conditions of Acceptance and Application

4     Description of the Mining Service

5     Conflicts of Interest

6     Reference to the Provisions of the General Terms of Use

GENERAL TERMS OF USE FOR MINING PROGRAM

The present General Conditions of Use of the Mining Program, as they may be updated from time to time (the “CGUPM”), govern the terms under which the Companies (as defined below) directly or indirectly provide you (the “User”) with the Mining Service (as defined below).

Please read these CGUPM carefully before using the Mining Service. These CGUPM explain who we are, how we provide the Mining Service, how you can amend or terminate the agreement, and other important information.

These CGUPM are entered into between, on the one hand:

• Automata France SAS, a simplified joint-stock company with its registered office at 965, avenue Roumanille, COLOFT - Arteparc Sophia Antipolis Building A, 06410 Biot, registered with the Trade and Companies Register of Antibes under number 902 498 617, registered with the Autorité des Marchés Financiers as (i) a Digital Asset Service Provider under number E2023-087 for digital asset custody services, buying/selling digital assets against fiat currency, and exchanging digital assets against other digital assets, and (ii) an external service provider of Modulr B.V. (81852401), which is authorized by De Nederlandsche Bank as an Electronic Money Institution, and operating under the trade name Vancelian (“VANCELIAN”); and
• Vancelian Ltd, a private company limited by shares in the United Arab Emirates, whose registered office is at 1133Register28, 11th Floor, Al Maqam Tower, Abu Dhabi Global Market Square, Abu Dhabi, Al Maryah Island, United Arab Emirates, registered at the Abu Dhabi Global Market under number 23815 (“VANCELIAN LTD”);

(together referred to as the “Companies”)

duly represented herein by their legal representatives, and, on the other hand, the User, an individual or legal entity using the Mining Service, as defined in the “Definitions” section of these CGUPM, offered on VANCELIAN’s website at https://vancelian.com (the “Site”) and/or its mobile application (the “Mobile App” and, collectively with the Site, the “Platform”), both published by VANCELIAN.

Digital asset services within the meaning of Article L. 54-10-2 of the French Monetary and Financial Code are exclusively provided to the User by VANCELIAN.

For more information about VANCELIAN, the company publishing the Site, the User is invited to review the legal notices available on the Site.

These CGUPM are specific to the Mining Program, as defined below, jointly offered by the Companies, which constitutes a “Service” as referred to in the Platform’s primary General Conditions of Use (the “Main CGU”) available in the Platform’s dedicated section. As for the other Services provided by VANCELIAN on the Platform, they are governed by the provisions of the Main CGU. In the event of a conflict between the provisions of these CGUPM and the Main CGU, the specific provisions of these CGUPM will prevail for all matters relating to the Mining Program.

The Companies and the User are hereinafter referred to individually as a “Party” and collectively as the “Parties.”

In accordance with Articles 721-1-2, 721-1-3, 721-14, and 722-4 of the General Regulation of the Autorité des marchés financiers (“GR AMF”), VANCELIAN confirms that, prior to providing a digital asset service, it has informed the User and entered into two written agreements, as detailed in Annex 1 and Annex 2, on a durable medium as defined in Article 314-5 of the GR AMF, following the acceptance and signing of these CGUPM by the User in question.

1. Definitions

Unless otherwise defined in these GTUMP, capitalized terms shall have the meanings set forth below, whether used in the singular or plural.

Additionally, capitalized terms used but not defined in these GTUMP shall have the meanings assigned to them in the Main GTU, which are incorporated by reference into these GTUMP.

• AKTIO Token: Refers to a decentralized peer-to-peer currency designed for settling international transactions, issued by AUTOMATA ICO LIMITED, an Irish company headquartered at 3rd Floor Ormond Building, 31-36 Ormond Quay Upper, Dublin 7, D07 EE37, Ireland, registered under number 690280. The AKTIO Token facilitates or grants access to benefits related to Services offered on the Mobile Application.
• Blockchain: Refers to the technology enabling the representation and transfer of Digital Assets, while maintaining a transaction history. The Blockchain does not have a unique legal definition, but generally possesses the following characteristics:
  • Cryptographic identification of each party involved;
  • Transactions are transmitted to a distributed network of computers (the "nodes") with geographically dispersed locations;
  • Each node hosts a copy of the database containing the history of all transactions. All stakeholders can access this data simultaneously;
  • A security system based on consensus, requiring agreement from all or part of the nodes whenever new information is added. Transactions are validated by data centers or miners, then recorded into the database as encrypted data blocks, forming the "blockchain";
  • Decentralized security management, which serves as a strong protection against transaction tampering. Each new block is linked to the previous one, and a copy is distributed to all network nodes. The integration process is chronological, presumed immutable, and tamper-proof.
• Companies: Refers to VANCELIAN and VANCELIAN LTD.
• Credentials: Refers to the User's login information, consisting of: A personal identifier (e.g., phone number); Passwords with two-factor authentication (e.g., a code sent via SMS) and a personal PIN code, ensuring secure access to the User Account and the Services.
• Custody: Refers to the Service allowing the User to store Digital Assets in one or more User Digital Wallets or the Master Exchange Digital Wallet, which is provided by VANCELIAN through Fireblocks infrastructure.
• Digital Assets or Cryptos: Refers to any digital representation of value that is not issued or guaranteed by a central bank or public authority, is not necessarily pegged to a legal currency, and does not hold the legal status of currency, but is accepted by individuals or entities as a means of exchange and can be transferred, stored, or exchanged electronically.

For the purpose of this definition, a "token" is an intangible asset that represents, in digital form, one or more rights, which can be issued, recorded, stored, or transferred through a shared electronic recording system (DEEP or Blockchain) that enables the direct or indirect identification of the asset owner.

• Mining Service: Refers to the Service provided by the Companies to Users via the Mobile Application, as defined in the section "Description of the Mining Service" in these GTUMP. The Mining Service is an integral part of the Mobile Application. Any components of the Mining Service that fall under the legal definition of Digital Asset Services, as per Article L. 54-10-2 of the French Monetary and Financial Code, are provided exclusively by VANCELIAN.
• Fees: Refers to the amount in Fiat Currency owed by the User to the Companies for using the Services available on the Mobile Application.
• Fiat Currency: Refers to legal tender managed by a Central Bank and controlled by a State. The Mobile Application allows Users to conduct Transactions exclusively in euros (€) or British pounds (£), depending on their country of residence. 
• Fireblocks: Refers to Fireblocks Inc., a U.S. company headquartered at 500 7th Ave, New York, NY 10018, providing Digital Asset storage, custody, and transfer services. VANCELIAN relies on Fireblocks to offer secure storage of private keys, direct blockchain interaction, deposits, withdrawals, Digital Asset transactions, and balance tracking. User Digital Wallets and the Master Wallet are created within Fireblocks for custody purposes.

VANCELIAN reminds Users that Fireblocks acts as a sub-custodian, and any failure or default by Fireblocks does not release VANCELIAN from its responsibility toward the User regarding this Service.

• Intervention Fees: Refers to an amount in Fiat Currency or Digital Assets owed by the User to the Company for any intervention required or requested by the User, related directly or indirectly to: A User error in using the Services; A breach of these GTUMP by the User; Any other reason specified in these GTUMP. The Intervention Fee is 0.3% of the Transaction amount, with a minimum charge of €1.50 (or GBP equivalent).
• Platform: Refers to the website accessible at https://vancelian.com ("Website") and/or the associated Mobile Application ("Mobile Application"), both operated by VANCELIAN.
• Services: Refers to all Services offered by VANCELIAN to Users via the Mobile Application, as defined in the Main GTU under the section "Description of Services". These Services are an integral part of the Mobile Application. Any Services falling under the legal definition of Digital Asset Services, as per Article L. 54-10-2 of the French Monetary and Financial Code, are provided exclusively by VANCELIAN to Users.
• Transaction: Refers to any operation performed at the User’s request via their User Account, involving: Digital Assets, AKTIO Tokens, or Fiat Currency.
• User Account: Refers to the User’s account(s) on the Platform, accessible via the Website and/or Mobile Application using their Credentials. User Accounts are an integral part of the Platform.

2. Purpose

VANCELIAN has developed the Platform to present the Services it offers, particularly by making available to Users, through this interface, the Website and/or the Mobile Application, which is open to the general public. This Platform enables Users to deposit and withdraw Fiat Currency, conduct Transactions, as well as acquire, deposit, and exchange Digital Assets and AKTIO Tokens, all within the Platform. These Services, which are described in the Main GTU, include the Mining Service, which is the subject of these GTUMP and is only available via the Mobile Application.

As part of the development and enhancement of the Mining Service offered on the Platform, a new company dedicated to this activity has been established as a company registered in the United Arab Emirates, VANCELIAN LTD, which participates in the provision of the Mining Service as described in these Mining Service General Terms and Conditions.

These GTUMP are intended to define the Mining Service, which is jointly provided by the Companies. They must be read in conjunction with the Main GTU, which they complement in their specific provisions concerning the Mining Service. In case of any conflict between the provisions of these GTUMP and those of the Main GTU, the provisions of these GTUMP shall prevail with respect to the Mining Service.

Additionally, the Platform is designed to provide Users with information about the Companies' activities, their latest updates (events, publications, etc.), and tutorials to help them navigate the Platform. It also offers functionalities and/or information that allow Users to contact the Companies. The Platform occasionally provides educational content and resources, which are strictly for informational purposes and do not constitute financial advice.

These GTUMP establish the conditions for accessing the Mining Service. To understand the terms of access to the Platform, its usage conditions, the online content it provides, and its functionalities, Users are encouraged to consult the Main GTU. The GTUMP specifically govern the provision of the Mining Service to the User via the Mobile Application, in exchange for the User’s compliance with the obligations and warranties set forth herein

3. Conditions of Acceptance and Application

Any User accessing the Platform and wishing to benefit from the Mining Service, either directly via the dedicated section in the Mobile Application or indirectly via the allocation of the Flexible Solution and Futuro Services as defined in the Main GTU, must read these GTUMP, which are available and downloadable under the "General Terms of Use of Exclusive Offers" section on all pages of the Platform. The User must comply with their terms.

The GTUMP and the content of these sections may also be provided by the Companies via email upon request to support@vancelian.com.

These GTUMP are formally accepted by the User upon subscription to the Mining Service, either directly through the Mobile Application’s dedicated section or indirectly via the allocation of the Flexible Solution and Futuro Services as defined in the Main GTU.

Users who subscribed to the mining program before the implementation of these specific Mining Service General Terms and Conditions, and who do not explicitly accept them, will remain subject to the provisions that previously applied to them under the General Terms and Conditions.

The Companies reserve the right to adapt or modify these GTUMP at any time without prior notice. Any newly published version shall prevail over any prior version, whether printed or saved on digital or paper support by the User. Therefore, the User is encouraged to regularly consult and read these GTUMP. The applicable version of the GTUMP is the one available online at the time of the User's visit and use of the Platform.

The Companies reserve the right to make changes to these GTUMP at their sole discretion. By continuing to use the Website after such modifications, whether or not the User has explicitly accepted the new GTUMP, the User agrees to be bound by the modifications.

If the User does not accept these modifications, they are not entitled to access any information, use the Mining Service, or access the Website and must immediately stop using it.

The User acknowledges that they are responsible for regularly verifying these GTUMP in their current and applicable version, which can be accessed at any time on the Website.

A User who does not wish to accept the new GTUMP may reject them and delete their User Account, under the conditions specified in the Main GTU.

The User declares and acknowledges that they are of legal age (at least 18 years old) and have full legal capacity to enter into these GTUMP.

These GTUMP are concluded for an indefinite duration.

The User acknowledges having understood the nature, purpose, and characteristics of the Platform and the Mining Service, as well as the prerequisites for their use, particularly those related to the creation of a User Account. They confirm having requested and obtained all necessary information, including the quantitative and qualitative characteristics of the Mining Service, allowing them to assess its suitability for their needs and to enter into these GTUMP with full knowledge of the facts. The User is solely responsible for their decision to use the Platform and the Mining Service, as well as for executing Transactions, and as such, the Companies cannot be held liable in any way.

4. Description of the Mining Service

4.1 General Overview of the Mining Program

The Companies offer a blockchain vault service (called the "Mining Program") on the Mobile App. This program leverages Bitcoin mining to allow Users to invest in mining infrastructure and receive rewards from mining activities alongside the Companies. Funds deposited in the Mining Program are allocated to renting cutting-edge mining machines, which are hosted in various mining facilities around the world.

When a User accesses the Mining Program via the dedicated section of the Mobile App, all of the funds deposited by the User are allocated to the Mining Program.

The Mining Program may involve various Digital Assets.

For informational purposes, Bitcoin mining is a process of creating new Bitcoins by using computers to solve complex mathematical problems through a method known as proof of work ("PoW"). This process requires significant computing power and electricity consumption.

The Mining Program allows Users to earn daily rewards through Bitcoin mining via a mechanism known as “cloud mining.” Cloud mining enables Users to pool their capital to purchase computing power from mining facilities (the “Computing Power Fee”), allowing them to earn Digital Asset rewards on their investment.

4.2 Unification of the Mining Program

To optimize the management and transparency of the Mining Program, all previously existing variations of the mining program, regardless of their initial subscription terms, are now consolidated into a single program—except for Users who subscribed to the mining program as described in the General Terms and Conditions before September 24, 2024. These Users will retain a specific benefit described in Section 4.3, recognizing their early subscription to the program.

All Users who subscribed to the Mining Program before September 24, 2024, between September 24 and December 31, 2024, or after December 31, 2024, and who have agreed to these General Terms of the Mining Program will have their participation integrated into this unified program. This unification results in changes to the Users' rights and obligations, which will now be governed by these General Terms of the Mining Program.

Acceptance of these General Terms of the Mining Program constitutes express consent to this unification and to the modification of the Users' rights and obligations. A specific notification will be sent via the Mobile App or other communication means to gather the Users' express consent to these General Terms of the Mining Program.

4.3 Characteristics of the Mining Program

Terms of Enrollment in the Mining Program. The current Mining Program is accessible only by resuming a subscription to the Mining Program via the Queue Mechanism (as defined below) or by converting an earlier version of the mining program through express acceptance of these CGUPM.

Depending on the entry conditions into this Mining Program, the Users’ commitment period (“Duration”) will vary:
(i) if subscribing to the Mining Program by resuming a subscription through the Queue Mechanism, the new User has the option to assume the entirety of the initial subscriber’s commitments, including the remaining duration of their commitment, which continues until its originally scheduled end;
(ii) if subscribing to the Mining Program before September 24, 2024, and upon express acceptance of these CGUPM, Users expressly agree to be committed for a period of forty-eight (48) months from the effective date of enrollment in the Mining Program;
(iii) if subscribing to the Mining Program between September 24, 2024, and December 31, 2024, Users are committed for a 48-month period from the date of the initial deposit into the Mining Program. In other words, this 48-month commitment begins from the initial subscription date, preserving the history and continuity of the commitment initially made by the User over the period from September 24, 2024, to December 31, 2024;
(iv) if subscribing to the Mining Program after the effective date of these CGUPM, Users are committed for a 48-month period from the date of the first deposit into the Mining Program.

The User acknowledges and accepts that they cannot unilaterally terminate their participation in the Mining Program before the end of its Duration, while maintaining the same exit terms from the Mining Program as outlined below.

The Mining Program User will have access to two separate User Digital Wallets within their User Account: (i) the first User Digital Wallet is used to pay the Computing Power Price, which will remain vested in VANCELIAN LTD (in EURC tokens, as defined in the Main CGU) for the entire Duration of the Mining Program, and (ii) the second User Digital Wallet is intended to hold daily rewards in Digital Assets (in EURC tokens, as defined in the Main CGU) derived from the Mining Program, which can be withdrawn by the User at any time, and are safeguarded by VANCELIAN. VANCELIAN will also be responsible for managing the Platform interface.

Exit Terms for the Mining Program. Subject to the conditions outlined below, the User may end their participation in the Mining Program early, either without fees at least twenty-four (24) months after paying the Computing Power Price, or by paying Early Exit Fees at least six (6) months after paying the Computing Power Price.

Thus, any exit from the Mining Program before the end of its Duration (as outlined above) will be subject to the following conditions:

Less than six (6) months from the initial Computing Power Price payment: the User cannot terminate their participation in the Mining Program.

Between six (6) months and twenty-four (24) months from the initial Computing Power Price payment: the User may request an early exit from the Mining Program by (i) paying a fee of 5% of the total amount of the Computing Power Price subject to the refund request (the “Early Exit Fees”) and (ii) adhering to the Queue Mechanism (as described below).

Between twenty-four (24) months and forty-eight (48) months from the initial Computing Power Price payment: the User may request an early exit from the Mining Program without fees, provided they adhere to the Queue Mechanism (as described below).

By exception to the above rules, Users who subscribed to the Mining Program before September 24, 2024, and who have expressly accepted these CGUPM may, in any case, request an early exit from the Mining Program without fees, provided they adhere to the Queue Mechanism (as described below) starting from November 2025.

Operation of exit windows and the Queue Mechanism. Early exits are subject to exit windows and the Queue Mechanism. These exit windows are specific periods, open for two (2) weeks each year—once in May and once in November—at the sole discretion of the Companies. They allow Users who subscribed to the Mining Program to request the resumption of their subscription, providing a liquidity opportunity for Users who wish to terminate their participation in the Mining Program early.

General principle. Any exit from the Mining Program is subject to the Queue Mechanism. According to this mechanism, exits are only allowed if new liquidity from another User enters the Mining Program concurrently, meaning another User joins the Mining Program by paying the Computing Power Price.

Processing exit requests. Exit requests from the Mining Program are handled on a “first-come, first-served” basis. Users wishing to leave the Mining Program must submit a request to the Companies to resume all or part of their Mining Program subscription. Each request is placed in a queue in the order it was received. The User who submitted the first exit request will be served first, subject to a new incoming investor’s participation.

Partial or complete resumption. If an incoming User only resumes part of the amount offered by a leaving User, only the resumed portion will be processed. The remaining portion of the contract will remain in the Queue awaiting a new participant during the next exit window.

Queue Management. The Queue is managed automatically by the Companies’ technological infrastructure. Resumptions are carried out strictly in accordance with the priority order of exit requests. Each transaction, whether it involves a partial or complete resumption, is recorded in real-time to ensure the transparency and integrity of the process.

Obligations of the Parties. The User acknowledges and agrees that all exit requests from the Mining Program are subject to these conditions and that resumption of the Mining Program subscription depends on the availability of new incoming investors during the exit windows. The Companies do not guarantee the liquidity of Digital Assets outside these specific periods or compliance with the Queue Mechanism. The Companies are not responsible for any malfunction or failure of the Queue. They do not guarantee that the Mining Program will attract sufficient new Users, and therefore, they do not guarantee that the Queue Mechanism will generate the expected liquidity for existing Mining Program subscriptions wishing to exit early before the end of their Term. The lack of appeal of the Mining Program could be due to various factors, including a market environment that makes the Mining Program less attractive in terms of returns.

Miscellaneous provisions regarding the Mining Program. The User acknowledges and agrees that the Mining Program involves inherent risks, including the volatility of Digital Assets, changes in regulations and technology, as well as the availability and security of mining operation infrastructures.

The User expressly accepts and acknowledges that only VANCELIAN LTD commits to refunding the Computing Power Price at the end of the Mining Program. However, the User recognizes that the Mining Program does not guarantee Digital Asset rewards or potential future earnings. Mining rewards will depend on the prevailing market conditions within the Mining Program’s framework and will not be guaranteed to the User.

All information presented on the Site is purely for illustrative purposes and subject to many factors.

Please note that the rate applicable to the Mining Program may change during its entire Term.

The Companies are not liable for losses incurred by the User due to the volatility of Digital Assets. The User alone is responsible for deciding to participate in the Mining Program.

To ensure the provision of the Mining Program at a reasonable standard, the Companies will make reasonable efforts to maintain all necessary facilities in good working condition, with the same level of diligence applied to their own operations.

The Companies reserve the right to suspend or terminate the Mining Program for legal, technological, or technical reasons.

The fees applicable to the Mining Program are available on the Platform in the following section: https://vancelian.com/memberships.

Loyalty Points may be awarded to Users who subscribe to the Mining Program at the Companies’ sole discretion. The details of these Loyalty Points will be visible in the dedicated section of the Mobile Application.

4.4 General Provisions Applicable to the Custody Service

In accordance with the provisions of articles 721-1-3 and 722-4 of the RG AMF, VANCELIAN states that prior to providing the Custody Service for Digital Assets, it has informed and concluded with the concerned User a written agreement provided in Annex 2, on a durable medium as defined in article 314-5 of the RG AMF, outlining the operational principles of the Custody Service for Digital Assets and identifying the respective rights and obligations of the parties.

4.5 New Mining Services

The Companies may expand their range of Mining Services by introducing new services on the Mobile Application, whether these services are accessible to all Users or solely through the User’s Account. These new services are considered an integral part of the Mining Services as defined in the “Definitions” section of these GTUMP and will be governed by these GTUMP. Unless otherwise stated, the new Mining Services can be used by the User as soon as they become available on the Mobile Application, subject to the prior creation of a User Account, if applicable.

Users expressly agree to receive communications of any kind from the Companies regarding new Mining Services available on the Mobile Application, whether by email or phone.

4.6 Evolution of Mining Services

The Companies may, at any time and without notice, develop, improve, or adapt the Platform and the Mining Services, and more generally the offered Mining Services, to enhance the features provided through the Mobile Application or the Mining Services framework. This may include deploying updates, new versions, new Mining Services, or other Mining Services, or discontinuing existing Mining Services.

In the event of the permanent discontinuation of an existing Mining Service, the Companies will make reasonable efforts to notify Users of this change in advance and propose alternative solutions (e.g., alternative Transactions, transfers to a third-party Service, etc.). If all Mining Services are permanently discontinued, the Companies will terminate these terms in accordance with the conditions and provisions set forth in the “Termination” section of the General Terms and Conditions.

Moreover, the Companies may at any time and without notice supplement or modify the Platform, its content, and the Mining Services available through it, depending on technological developments. In such cases, the User must ensure that the resources of their computer/phone are compatible with the modifications made to the Platform and the Mining Services.

4.7 Support

The Companies provide technical support to Users to offer information or assistance regarding the technical aspects and features of the Platform and the Mining Services.

The User remains solely responsible for their decisions, including whether to use the Mining Services. Technical support does not address inquiries regarding the advisability of using the Mining Services and does not offer any financial or strategic advice of any kind.

This support is available through a chatbot on the Platform, 24/7 (phone support is only available Monday through Friday from 9:00 AM to 5:00 PM UTC and closed on Sundays). The Companies will strive to respond to the User’s request as quickly and appropriately as possible. However, the Companies make no commitment regarding response times, the relevance or completeness of the response, or the likelihood that the response will resolve the User’s issue or provide a solution.

Furthermore, the Companies will not offer any advice on using the Mining Services or on conducting Transactions involving Digital Assets. No information provided by the Companies should be interpreted as investment advice, financial advice, strategic advice, commercial advice, or any other type of advice.

Unless otherwise stated in these GTUMP, Transactions are carried out solely based on the instructions provided by the User, without any verification by the Companies of their relevance, merit, or quality. As a reminder, the User alone is responsible for determining the suitability of an investment, an investment strategy, or executing a Transaction based on their personal investment objectives, financial situation, and risk tolerance, and the User will bear sole responsibility for any resulting loss or damage, whether partial or total, injury, or liability. The User is encouraged to consult professionals specializing in financial, legal, or tax advice before engaging in Transactions involving Digital Assets.

5. Conflicts of Interest

In accordance with these General Terms of Use (CGU) and applicable regulations, we inform you that VANCELIAN LTD, which participates in providing the Mining Service, is managed by Mr. Xavier Gomez, who also serves in the same role at Automata France SAS. Additionally, VANCELIAN LTD is owned by Automata Group Ltd, which is also a shareholder in Automata France SAS.
The shared ties between these entities could give rise to a conflict of interest, which we will strive to mitigate.
In this context, VANCELIAN implements measures to ensure complete transparency for users of the Mining Program Service. These measures include:

• Establishing internal governance mechanisms to ensure objectivity and independence in managing the Mining Program Service;
• Examining any situations that might create a conflict of interest in order to identify corrective measures;
• Informing users of any significant developments that may affect the impartiality of the Mining Program Service.

By subscribing to the Mining Program, the user acknowledges being informed of these elements and agrees to use the Mining Program Service with full knowledge of the situation.

6. References to the Main CGU Provisions

The User is expressly referred to the provisions of Articles 5 and following of the Main CGU, to which they adhere by using the Services, including the Mining Service. For all practical purposes, it is clarified that any reference to “the Company” should be understood as referring to the Companies as defined herein. Similarly, any reference to “CGU” should be understood as “CGUPM.”

As an exception to the provisions of the Main CGU, the User expressly accepts and acknowledges that the Companies’ responsibility within the framework of the Mining Service is distributed as follows: VANCELIAN is responsible for all digital asset services provided under the Mining Program, as well as for maintaining the Platform interface, while VANCELIAN LTD is responsible for the repayment of the Computing Power Price, which remains the property of VANCELIAN LTD from the subscription to the Mining Program and is separate from the assets of VANCELIAN. In other words, if VANCELIAN LTD fails to fulfill its obligation to refund the Computing Power Price, VANCELIAN’s liability cannot, in any case, be invoked by the User—whether directly via the dedicated tab in the Mobile Application or indirectly via the Allocation of Flexible and Future Solution Services as defined in the Main CGU.

Last Updated: March 28, 2025

Annex 1

CLIENT AGREEMENT

In accordance with the provisions of Articles 721-1-2 and 721-14 of the RG AMF, the Companies specify that, prior to the provision of Digital Asset Services, through the acceptance and signing of these GTUMP by the concerned User, an agreement has been concluded in writing and provided on a durable medium within the meaning of Article 314-5 of the RG AMF.

These GTUMP therefore include the following provisions, where applicable by reference to the Main Terms and Conditions (GTU Principales):

i. A description of the essential rights and obligations of the Company and Users, outlined in Article 4 "Description of the Mining Service" of these GTUMP, and by reference in Articles 5.4 "Availability of the Platform and Services", 5.7 "General Principles Applicable to Services", 8 "Respective Obligations of the Parties", and 9 "Civil Liability" of the Main Terms and Conditions.

ii. The nature of the Services provided and the types of Digital Assets covered by these Services.

To this end, the Companies detail the nature of the Services provided within Article 4 of these GTUMP.

Additionally, the User is informed that while most types of Digital Assets are accepted on the Mobile Application, some may not be. The list of accepted Digital Assets is available in the dedicated section of the Platform and may be updated at any time.

iii. The pricing of the services provided by the digital asset service provider and its compensation model.

VANCELIAN provides services for the custody of Digital Assets, the purchase and sale of Digital Assets against legal tender, as well as the exchange of Digital Assets for other Digital Assets for a fee. Accordingly, VANCELIAN is compensated in accordance with the provisions of Article 7 "Financial Conditions" of the Main Terms and Conditions.

iv. The validity period of the agreement (as set out in Article 3 of these GTUMP and Article 10 of the Main Terms and Conditions).

v. The confidentiality obligations imposed on the digital asset service provider, in accordance with applicable laws and regulations regarding professional secrecy.

To this end, VANCELIAN states that, in compliance with the confidentiality obligations imposed by laws and regulations on professional secrecy, it treats all information concerning Users, as well as all data related to their Transactions, with the utmost confidentiality. VANCELIAN protects this information and does not disclose it in any form, except where required by law, regulation, or a competent authority, in accordance with its personal data management policy or with the explicit consent of the User.

Annex 2

CUSTODY AGREEMENT

In accordance with the provisions of Articles 721-1-3 and 722-4 of the RG AMF, VANCELIAN specifies that, prior to the provision of the Digital Asset Custody Service, through the acceptance and signing of these GTUMP by the concerned User, an agreement has been concluded in writing, on a durable medium within the meaning of Article 314-5 of the RG AMF, defining the operational principles of said Digital Asset Custody Service and identifying the respective rights and obligations of the parties.

These GTUMP include, in particular, the following provisions, where applicable by reference to the Main Terms and Conditions (GTU Principales):

i. The contracting party(ies) involved in this agreement (i.e., the legal entity described at the beginning of this document, its information procedures, and the authorized persons acting on behalf of VANCELIAN).

ii. Nature and detailed description of the Services provided (As outlined in Article 4 of these GTUMP.)

iii. Conditions under which VANCELIAN sends information related to events mentioned in Article 722-1 (4°) of the RG AMF (e.g., blockchain fork events) and, where applicable, any restrictions imposed by the initiator of such events.

In this regard, VANCELIAN informs Users as soon as the following information is available:

- Information related to Transactions that require a response from the User.

- Information related to Transactions that result in changes to the User's account balance.

- Information regarding a blockchain fork that has affected the User's Digital Assets. Such communications inform the User of the impact of a fork on the affected Digital Assets. In the event of a fork, Users are deemed to have rights to the Digital Assets resulting from the fork, based on their holdings at the time of the event. However, specific actions may be required from the Users to retrieve these new Digital Assets. If a User is requested to perform a Transaction or a specific action to claim forked Digital Assets, the User must comply. Failure to act within a given time frame may result in the User permanently losing access to these newly created Digital Assets.

- Information necessary for the completion of tax declarations.

iv. Security measures for assets held by VANCELIAN

VANCELIAN relies on the services of Fireblocks for the Digital Wallet infrastructure.

VANCELIAN has undergone an audit of its digital asset custody infrastructure by a certified auditor, who did not report any significant weaknesses.

VANCELIAN commits to implementing all reasonable measures to mitigate operational risks.

v. User authentication mechanisms used by VANCELIAN (As specified in Article 6.2 of the Main Terms and Conditions).

vi. Pricing of the Custody Services provided by VANCELIAN Details regarding fees and charges applicable to the Custody Service.

vii. Validity period of the agreement (As specified in Article 3 of these GTUMP and Article 3 of the Main Terms and Conditions).

viii. Applicable law (As outlined in Article 17 of the Main Terms and Conditions).

ix. A detailed overview of VANCELIAN’s policies regarding the safekeeping, management, and security of Digital Assets.