General Term of Use - Exclusive Offer The Heights Bali

TABLE OF CONTENTS

1     Definitions

2     Purpose

3     Conditions of Acceptance and Application

4     Description of the Exclusive Offers Service

5     Conflicts of Interest

6     Reference to the Provisions of the General Terms of Use

GENERAL TERMS OF USE FOR EXCLUSIVE OFFERS

The present General Terms of Use for Exclusive Offers, which may be updated from time to time (the "GTUO"), govern the conditions under which the Companies (as defined below) provide you (the "User") directly or indirectly with the Exclusive Offers Service (as defined below).

Please read these GTUO carefully before using the Exclusive Offers Service. These GTUO explain who we are, how we provide the Exclusive Offers Service, how to modify or terminate the agreement, and other important information.

These GTUO are entered into between:

• Automata France SAS, a simplified joint-stock company with its registered office at 965, avenue Roumanille, COLOFT - Arteparc Sophia Antipolis Bâtiment A, 06410 Biot, France, registered with the Antibes Trade and Companies Register under number 902 498 617, an outsourced service provider for Modulr B.V. (81852401), which is authorized by De Nederlandsche Bank as an Electronic Money Institution, and operates under the commercial name Vancelian ("VANCELIAN"); and
• The Heights Bali SAS, a simplified joint-stock company with its registered office at 965, avenue Roumanille, COLOFT - Arteparc Sophia Antipolis Bâtiment A, 06410 Biot, France, registered with the Antibes Trade and Companies Register under number 984 121 749 ("THE HEIGHTS BALI");

together referred to as the "Companies",

duly represented for the purposes of this agreement by their respective legal representatives, and, on the other hand, the User, a natural or legal person using the Exclusive Offers Service, as defined in the section "Definitions" of these GTUO, made available through the VANCELIAN website at https://vancelian.com (the "Website") and/or the mobile application (the "Mobile Application", and collectively with the Website, the "Platform"), both published by VANCELIAN.

The digital asset services, as defined in Article L. 54-10-2 of the French Monetary and Financial Code, are provided exclusively to the User by VANCELIAN.

For more information about VANCELIAN, the publisher of the Website, the User is invited to consult the legal notices on the Website.

These GTUO are specific to the Exclusive Offers Service, as defined below, jointly provided by the Companies. This service constitutes a "Service" within the meaning of the General Terms of Use of the Platform ("Main GTU"), which are available in the dedicated section of the Platform. All other Services provided by VANCELIAN on the Platform are governed by the provisions of the Main GTU. In case of any conflict between these GTUO and the Main GTU, the provisions of these GTUO shall prevail concerning the Exclusive Offers Service.

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 Regulations of the French Financial Markets Authority ("RG AMF"), VANCELIAN confirms that, prior to providing a digital asset service, the User was informed and entered into two written agreements, upon acceptance and signature of these GTUO. These agreements, provided in Annex 1 and Annex 2, have been made available on a durable medium in compliance with Article 314-5 of the RG AMF.

1. Definitions

Unless otherwise defined in these GTUO, 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 GTUO shall have the meanings assigned to them in the Main GTU, which are incorporated by reference into these GTUO.

• 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.

• Exclusive Offers Service: Refers to the Service provided by the Companies to Users via the Mobile Application, as defined in the section "Description of the Exclusive Offers Service" in these GTUO. The Exclusive Offers Service is an integral part of the Mobile Application. Any components of the Exclusive Offers 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 GTUO by the User; Any other reason specified in these GTUO. 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 Exclusive Offers Service, which is the subject of these GTUO and is only available via the Mobile Application.

These GTUO are intended to define the Exclusive Offers 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 Exclusive Offers Service. In case of any conflict between the provisions of these GTUO and those of the Main GTU, the provisions of these GTUO shall prevail with respect to the Exclusive Offers 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 GTUO establish the conditions for accessing the Exclusive Offers 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 GTUO specifically govern the provision of the Exclusive Offers 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 Exclusive Offers 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 GTUO, 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 GTUO and the content of these sections may also be provided by the Companies via email upon request to support@vancelian.com.

These GTUO are formally accepted by the User upon subscription to the Exclusive Offers 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.

The Companies reserve the right to adapt or modify these GTUO 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 GTUO. The applicable version of the GTUO 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 GTUO at their sole discretion. By continuing to use the Website after such modifications, whether or not the User has explicitly accepted the new GTUO, 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 Exclusive Offers Service, or access the Website and must immediately stop using it.

The User acknowledges that they are responsible for regularly verifying these GTUO 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 GTUO 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 GTUO.

These GTUO are concluded for an indefinite duration.

The User acknowledges having understood the nature, purpose, and characteristics of the Platform and the Exclusive Offers 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 Exclusive Offers Service, allowing them to assess its suitability for their needs and to enter into these GTUO with full knowledge of the facts. The User is solely responsible for their decision to use the Platform and the Exclusive Offers Service, as well as for executing Transactions, and as such, the Companies cannot be held liable in any way.

4. Description of the Exclusive Offers Service

4.1 Overview of the Exclusive Offers Service

The Companies wish to provide Users with an exclusive offers service that allows them to lend BTC to THE HEIGHTS BALI, which will be used to carry out a specific Project (the "Project") as part of the Exclusive Offers Service.

The User will be able to browse the different loan requests available on the Platform and access details about the Project being financed by the loan and THE HEIGHTS BALI, the company managing it (the "Exclusive Offers").

Once an Exclusive Offer is selected, the User can choose the amount of Digital Assets or Fiat Currency they wish to allocate to the Project ("Locked Assets"), which will remain locked until the end of the Lock-up Period as specified on the Platform. The User retains ownership of the Locked Assets during this Lock-up Period.

By agreeing to lock their Assets, the User expressly authorizes VANCELIAN, to execute the following actions at the end of the Lock-up Period, in their name and on their behalf:

• Exchange the Locked Assets into BTC, if necessary, and then
• Transfer the newly converted BTC to THE HEIGHTS BALI.

After the execution of these two operations by VANCELIAN, the User will have officially subscribed to the loan requested by THE HEIGHTS BALI (the "Loan").

The loan amount, even though held in BTC, will be denominated in Euros ("Loan Amount").

Within the framework of the Exclusive Offers Service, VANCELIAN acts as a facilitator, enabling Users to subscribe to the Loan proposed by THE HEIGHTS BALI.

The Loan Duration ("Duration") will be specified in the Platform's dedicated interface.

The User acknowledges and accepts that they cannot unilaterally withdraw from their participation in the Loan before the end of the Duration, except in accordance with the Exit Mechanism described below.

Throughout the Duration, the User participating in the Exclusive Offers Service will have access to their User Account, which contains a Digital Wallet where monthly interest earnings in Digital Assets from the Loan will be deposited. These earnings can be withdrawn at any time, and their storage is ensured by VANCELIAN (the "Interest"). The fixed interest rate applicable to the Loan will be displayed on the Platform and accessible via the User Account.

Subject to compliance with the Queue Mechanism (as described below), the User has the ability to terminate their participation in an Exclusive Offer early.

Operation of Exit Windows and the Queue Mechanism. Early exits are subject to compliance with the Exit Windows and the Queue Mechanism. 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 have subscribed to an Exclusive Offer to request the reassignment of their loan subscription, providing a liquidity opportunity for Users who wish to end their participation in the Exclusive Offers Service early.

General Principle. Any exit from an Exclusive Offer is subject to compliance with a Queue Mechanism. Under this mechanism, an exit will only be authorized if there is a simultaneous new liquidity entry from another User into the same Exclusive Offer being exited. In other words, an exit is only possible if another User joins the said Exclusive Offer by paying the Loan Amount.

Processing of Exit Requests. Exit requests from an Exclusive Offer are processed on a "first-come, first-served" basis. Users wishing to exit an Exclusive Offer must submit a request for the reassignment of all or part of their loan subscription to the Companies. Each request is placed in a queue in the order of receipt. The User who submitted the first exit request will be served first, provided that a new incoming investor joins at the same time.

Partial or Complete Reassignment. In the event that an incoming User only takes over a portion of the amount proposed by an exiting User, only the reassigned portion will be processed. The remaining part of the contract will remain in the Queue, awaiting a new assignee during the next exit window.

Queue Management. The management of the Queue is automated and handled by the Companies' technological infrastructure. Reassignments are carried out in strict accordance with the priority order of exit requests. Each transaction, whether a partial or complete reassignment, is recorded in real time to ensure transparency and the integrity of the process.

Obligations of the Parties. The User acknowledges and accepts that any exit request from an Exclusive Offer is subject to these conditions and that the reassignment of the subscription to an Exclusive Offer depends on the availability of new incoming investors during the exit windows. The Companies do not guarantee liquidity outside of these specific periods or beyond compliance with the Queue Mechanism. The Companies are not responsible for any malfunction or failure of the Queue. Furthermore, the Companies do not guarantee that an Exclusive Offer will attract a sufficient number of new Users and therefore do not guarantee that the Queue Mechanism will generate the expected liquidity for existing subscribers wishing to exit an Exclusive Offer early before the end of its Term.

Miscellaneous Provisions Regarding Exclusive Offers. The User acknowledges and accepts that the Exclusive Offers Service involves inherent risks, including but not limited to the volatility of Digital Assets, regulatory changes, and technological developments.

The User expressly agrees that only THE HEIGHTS BALI is responsible for repaying the Loan Amount at the end of the Duration.

All information on the Website is indicative and subject to multiple variables.

The Companies are not liable for losses incurred by the User due to Digital Asset volatility. The User is solely responsible for deciding to participate in an Exclusive Offer.

The Companies reserve the right to suspend or terminate an Exclusive Offer or the Exclusive Offers Service as a whole due to legal, technological, or technical reasons.

Applicable fees for the Exclusive Offers Service can be found on the Platform at: https://vancelian.com/memberships.

Loyalty Points may be granted at the Companies’ sole discretion to Users who subscribe to the Exclusive Offers Service. The details of these Loyalty Points will be visible in the Mobile Application's dedicated section.

4.2 General Provisions Applicable to the Custody Service

In accordance with Articles 721-1-3 and 722-4 of the AMF General Regulation (RG AMF), VANCELIAN states that prior to providing the Digital Asset Custody Service, and upon the User's acceptance and signature of these CGUOE, it has informed and entered into a written agreement with the User, provided in Annex 2, on a durable medium as defined in Article 314-5 of the RG AMF. This agreement outlines the principles of operation of the Digital Asset Custody Service and identifies the rights and obligations of both parties.

4.3 New Exclusive Offers Services

The Companies may expand their range of Exclusive Offers Services by introducing new services on the Mobile Application, whether these services are available to all Users or only through their User Account. These new services will be considered an integral part of the Exclusive Offers Services, as defined in the "Definitions" section of these CGUOE, and will be governed by these CGUOE. Unless stated otherwise, Users may start using the new Exclusive Offers Services as soon as they are made available on the Mobile Application, subject to the creation of a User Account, if required.

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

4.4 Evolution of Exclusive Offers Services

The Companies may, at any time and without prior notice, develop, improve, or modify the Platform and the Exclusive Offers Services, as well as other Exclusive Offers Services, in order to enhance Mobile Application functionalities or the Exclusive Offers Services themselves. This may include the deployment of updates, new versions, additional services, or the removal of existing services.

Permanent Discontinuation of an Exclusive Offers Service

If an Exclusive Offers Service is permanently discontinued, the Companies will make reasonable efforts to notify Users in advance and offer alternative solutions (e.g., alternative Transactions, transfers to a third-party service, etc.). If all Exclusive Offers Services are permanently discontinued, the Companies will terminate these CGUOE in accordance with the conditions outlined in the “Termination” section of the CGU Principales.

Additionally, the Companies may, at any time and without prior notice, update or modify the Platform, its content, and the Exclusive Offers Services in response to technological advancements. In such cases, the User must ensure that their computer or mobile device is compatible with these changes.

4.5 Customer Support

The Companies provide technical support with technical aspects and functionalities of the Platform and the Exclusive Offers Services.

The User remains solely responsible for their choices, particularly the decision to use the Exclusive Offers Services. Technical support does not provide financial or strategic advice regarding the use of the Exclusive Offers Services.

The Companies will endeavor to respond to the User's request as promptly and appropriately as possible. However, the Companies do not commit to any specific response time, nor to the relevance or completeness of the response provided, nor to the guarantee that the response will effectively resolve the User's request or provide a suitable solution.

Furthermore, the Companies will not provide any advice regarding the use of the Exclusive Offers Services or, more broadly, the execution of Transactions/operations involving Digital Assets. Any information provided by the Companies should not be interpreted as investment advice, financial advice, strategic advice, business advice, or any other type of advisory service.

Unless otherwise stated in these CGUOE, Transactions are executed solely based on the instructions provided by the User, without the Companies ever verifying their relevance, interest, or quality. Therefore, as a reminder, the User is solely responsible for determining the suitability of an investment, an investment strategy, or the execution of a Transaction based on their personal investment objectives, financial situation, and risk tolerance. The User shall bear full responsibility for any partial or total loss, damage, prejudice, or liability resulting from their decisions. The User is encouraged to consult professionals specialized in financial, legal, or tax advisory services before carrying out any Transaction involving Digital Assets.

4.6 Superperformance Bonus

At the end of the contractual term of the Exclusive Offer, a potential performance bonus (the “Superperformance Bonus”) may be awarded, at the sole discretion of the Company, to Users who have maintained their participation until maturity without requesting early exit.

This Superperformance Bonus is an additional, non-guaranteed and non-contractual payment, which may be granted only if the resale of the financed assets results in a significant capital gain, as solely assessed by THE HEIGHTS BALI. It shall only apply if the net capital gain exceeds the initial economic assumptions communicated at the time of the project listing.

The amount, calculation method, triggering criteria and distribution terms of the Superperformance Bonus are entirely subject to the Companies’ discretion and shall not give rise to any claim, entitlement or binding obligation in favour of the User.

5. Conflicts of Interest

In accordance with the provisions of these CGUOE and the applicable regulations, we inform you that THE HEIGHTS BALI SAS, the entity carrying the project financed through this Exclusive Offer, is presided over and owned by Mr. Gaël Itier, who is also the beneficial owner of Automata France SAS (Vancelian). The shared links between these two companies could potentially create a conflict of interest, which we strive to mitigate.

In this context, VANCELIAN has implemented measures to ensure full transparency for Users of the Exclusive Offers Service. These measures include:

• The establishment of internal governance mechanisms to ensure objectivity and independence in the management of the Exclusive Offers Service;
• The review of any situation that may give rise to a conflict of interest, in order to identify the appropriate corrective measures;
• The communication to Users of any significant changes that may impact the impartiality of the Exclusive Offers Service.

By subscribing to an Exclusive Offer, the User acknowledges that they have been informed of these elements and agrees to use the Exclusive Offers Service with full knowledge of the potential conflict.

6. Reference to the Provisions of the Main Terms and Conditions

The User is expressly referred to Articles 5 and subsequent of the Main Terms and Conditions (CGU Principales), to which they adhere by using the Services, including the Exclusive Offers Service. For all intents and purposes, it is specified that any reference to "the Company" shall be understood as referring to the Companies, as defined herein. Similarly, any reference to "CGU" shall be understood as "CGUOE".

By exception to the provisions of the Main Terms and Conditions, the User expressly agrees and acknowledges that the responsibility of the Companies within the framework of the Exclusive Offers Service is divided as follows: VANCELIAN is responsible for all digital asset services provided under the Exclusive Offers Service, as well as the maintenance of the Platform's interface. THE HEIGHTS BALI is responsible for interest payments and the repayment of the Loan Amount, which it retains from the moment of subscription to the Loan via an Exclusive Offer and which remains separate from VANCELIAN’s assets. In other words, in the event that THE HEIGHTS BALI fails to meet its obligation to pay Interest or repay the Loan Amount, VANCELIAN shall under no circumstances be held liable by the User, regardless of the method of subscription to the Exclusive Offers Service, whether: Directly via the dedicated tab in the Mobile Application, or Indirectly via the Allocation of Services of Flexible and Future Solution, as defined in the Main Terms and Conditions.

Last Updated: March 8, 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 CGUOE 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 CGUOE therefore include the following provisions, where applicable by reference to the Main Terms and Conditions (CGU Principales):

i. A description of the essential rights and obligations of the Company and Users, outlined in Article 4 "Description of the Exclusive Offers Service" of these CGUOE, 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 CGUOE.

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 CGUOE 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 CGUOE 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 CGUOE include, in particular, the following provisions, where applicable by reference to the Main Terms and Conditions (CGU 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 CGUOE.)

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 CGUOE 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.