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 OF THE MINING PROGRAM

These Mining Program General Terms and Conditions of Use, as they may be updated from time to time (the "CGUPM"), govern the terms under which VANCELIAN LTD (as defined below) directly or indirectly provides you (the “User”) with the Mining Service (as defined below), as well as the terms under which VANCELIAN (as defined below) provides you with the digital asset services necessary for the implementation of the Mining Service.

Please read these CGUPM carefully before using the Mining Service. These CGUPM explain who we are, how VANCELIAN LTD provides you with the Mining Service, how VANCELIAN delivers the digital asset services necessary for implementing the Mining Service, how to modify or terminate the agreement, as well as 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, 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 VANCELIAN LTD, 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.

• 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).
• Mining Program: refers to the combination of the Mining Service and the digital asset services required for the operation of the Mining Service. The Mining Service is provided to Users by VANCELIAN LTD, while the components of the Mining Program that fall under the definition of digital asset services as per article L. 54-10-2 of the French Monetary and Financial Code are provided to the User by VANCELIAN.
• Mining Service: refers to the service offered by VANCELIAN LTD to users via the Mobile App, as defined in the “Description of the Mining Service” section of these CGUPM. The Mining Service is an integral part of the Mobile App, the Services, and is a component of the Mining Program. The Mining Service is not provided by VANCELIAN, which only delivers the components of the Mining Program that fall under the definition of digital asset services as per article L. 54-10-2 of the French Monetary and Financial Code.
• 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 improvement 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 provides the Mining Service as described in these CGUPM. Consequently, VANCELIAN now only provides the digital asset services necessary for the implementation of the Mining Service, which is entirely provided by VANCELIAN LTD.

These GTUMP are intended to define the Mining Service, which is jointly provided by VANCELIAN LTD. 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 tab of the Mobile Application, or indirectly via the Allocation of the Flexible and Avenir Solution Services as defined in the Main GCU, is required to take cognizance of the present GTUMP, accessible and downloadable via the heading ‘General Terms and Conditions of Use of the Mining Programme’ on all the pages of the Platform and must respect the terms thereof.  

The GTUMP and the content of these sections may also be communicated by the Companies by e-mail at the User's request to support@vancelian.com.  

These GTUMP are formally and expressly accepted by the User (i) when subscribing to the Mining Programme either directly via the dedicated tab of the Mobile Application, or indirectly via the Allocation of Flexible and Avenir Solution Services as defined in the Main GCU or, (ii) for Users who have subscribed to the mining programme as defined in the Main GTU prior to the implementation of these specific GTU, upon acceptance of the present, which will be expressly collected via the Mobile Application or by any other means of communication.  

In the absence of express acceptance, adherence to these General Terms and Conditions by Users who subscribed to the mining programme as described in the Main Terms and Conditions between 24 September 2024 and 31 December 2024 is based on their tacit acceptance of these General Terms and Conditions in accordance with the Main Terms and Conditions updated to 25 April 2025.  

Users who subscribed to the mining programme as described in the Main TOU prior to 24 September 2024 and who do not expressly agree to the present TOU will remain subject to the provisions that were applicable to them under the Main TOU.  

The Companies reserve the right to adapt or modify these UGC at any time, without prior notice. Any new version posted online will take precedence over any previous version, whether printed or saved on a digital or paper medium by the User. The User is therefore invited to consult and read these GCUPM on a regular basis. The applicable version of the GTUMP is the one accessible online when the User visits and uses the Platform. 

The Companies reserve the right to make changes to these General Terms and Conditions of Use at their sole discretion. Your continued use of the Site after such modifications, with or without your explicit acceptance of the new GTUMP, constitutes your consent to such modifications.  

If you do not accept these modifications, you are not entitled to obtain information, to use the Mining Service or to access the Site and you must immediately cease using it.  

The User declares and acknowledges that he/she remains responsible for regularly checking these GTUMP in their current version in force from time to time, an updated version of which may be retrieved from the Site at any time. 

Users who do not wish to accept the new GTUMP may repudiate them and delete their User Account, under the conditions indicated in the Main GTUMP. 

The User declares and acknowledges that he/she is of legal age (i.e. at least 18 years old) and that he/she has full legal capacity to enter into commitments under these GTUMP. 

These GTUMP are entered into for an indefinite period. 

The User acknowledges that he/she is aware of the nature, purpose and characteristics of the Platform and the Mining Service, as well as the prerequisites for their use, in particular the conditions relating to the creation of a User Account. The User acknowledges that he/she has requested and obtained all necessary information, in particular on the quantitative and qualitative characteristics of the Mining Service, enabling him/her to assess the suitability of the Mining Service for his/her needs and to enter into the GTUMP with full knowledge of the facts. The User is solely responsible for the decision to use the Platform and the Mining Service, and to carry out Transactions, and the Companies may under no circumstances be held liable in this respect. 

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 and assignement of debt

In order to optimise the management and transparency of the Mining Programme, all pre-existing variants of the Mining Programme, regardless of the initial subscription conditions, are now merged into a single programme for Users who have expressly subscribed to the present Terms and Conditions, with the exception of Users who subscribed to the Mining Programme as described in the Main Terms and Conditions before 24 September 2024, who will benefit from a special feature described in article 4.3 as a reward for their early subscription to the said programme.  

All Users who subscribed to the Mining Programme before 24 September 2024, between 24 September and 31 December 2024, or after 31 December 2024, and who have agreed to these UGCM, either expressly or tacitly under the Main UGC, will have their participation integrated into this single programme. This unification entails a change in the rights and obligations of Users, who will henceforth be governed by these GCUPM. 

Adherence to these GCUPM constitutes express consent to this unification and to the modification of Users' rights and obligations. A specific notice will be sent to this effect via the Mobile Application or by any other means of communication in order to obtain the Users' express consent to these GCUPM. 

In addition, the Mining Programme has been restructured, involving the assignment of debts (i.e. the obligation to repay the Calculation Power Price and to pay the related rewards) within the meaning of article 1327 of the French Civil Code, assignments to which the User expressly consents by adhering to these GCUPM.  

As part of these transactions, the User also consents to the original debtor being released from its obligation to repay the debt assigned. 

In other words, by accepting these Terms and Conditions, the User authorises VANCELIAN LTD to transfer the monetary claim that it holds under the Mining Programme to VANCELIAN LTD as part of the development and improvement of the Mining Programme, and to release its initial debtor from its obligation to pay the transferred debt. 

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:

1. if you join the Mining Program by taking over an existing subscription through the Queue Mechanism, you will remain committed until the date shown in the App at the time of that takeover,
2. 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 acceptance of these CGUPM,
3. in the case of subscription to the mining program between September 24, 2024, and December 31, 2024, Users are committed for a period of forty-eight (48) months starting from the date of the initial deposit into the Mining Program – in other words, this forty-eight (48) month commitment runs from the initial subscription date, thereby maintaining the history and continuity of the User’s initial commitment taken during the period from September 24, 2024, to December 31, 2024,
4. In the case of subscription to the Mining Program after these CGUPM come into effect, Users are committed for a period of forty-eight (48) months starting from the date of their first deposit into the Mining Program.

The User acknowledges that the funds will be released on the first day of the month following the expiry date of the forty-eight (48) month commitment period.

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 any request to exit the Mining Program is subject to these terms, and that resubscription to the Mining Program depends on the availability of new incoming investors during exit windows. The Companies do not guarantee the liquidity of the Digital Assets outside of these specific periods and the compliance with the Queue Mechanism. The Companies are not liable for any malfunction or failure of the Queue. The Companies do not guarantee that the Mining Program will attract a sufficient number of new Users and therefore 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 its Term. The lack of appeal of the Mining Program may be due to various factors, including market conditions making the Mining Program unattractive 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 Programs

The Companies may expand their range of Mining Programs 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

Pursuant to applicable regulations, we inform you that VANCELIAN LTD, which provides the Mining Service, is effectively managed by Mr. Xavier Gomez, who also holds the same position at VANCELIAN. Additionally, VANCELIAN LTD is owned by Automata Group Ltd, a UK Private Limited Company with its registered office at 80 Coleman Street, London, EC2R 5BJ, registered under number 12268715, which is also a shareholder of VANCELIAN.
The shared links between these entities could give rise to a conflict of interest, which we will strive to mitigate.
In this context, VANCELIAN implements measures aimed at ensuring full transparency for Users of the Mining Program. These measures include:

• Establishing internal governance mechanisms to ensure objectivity and independence in managing the Mining Program;
• Examining any situation that may create a conflict of interest to identify corrective measures to implement; and
• Communicating to Users any significant developments that could impact the impartiality of the Mining Program Service.

By subscribing to the Mining Program, each User acknowledges having been informed of these elements and agrees to use the Mining Program fully informed of the circumstances.

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 Primary Terms of Use, the User expressly accepts and acknowledges that the responsibilities of the Companies within the scope of the Mining Service are allocated as follows: VANCELIAN is responsible for all digital asset services provided under the Mining Program, as well as maintaining the Platform interface, while VANCELIAN LTD, solely responsible for providing the Mining Service, assumes responsibility for reimbursing the Computing Power Fee, which remains separate from VANCELIAN’s assets from the time of subscription to the Mining Program. In other words, in the event that VANCELIAN LTD fails to fulfill its obligation to reimburse the Computing Power Fee, VANCELIAN cannot be held responsible by the User.

Last Updated: May 15, 2025

Annex 1

CLIENT AGREEMENT

In accordance with the provisions of Articles 721-1-2 and 721-14 of the RG AMF, VANCELIAN 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 VANCELIAN 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 VANCELIAN, 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.