TERMS AND CONDITIONS OF USEORBICHAIN LABS S.A.S.

Last updated: April 23, 2026

Operator: ORBICHAIN LABS S.A.S. Tax ID (NIT): 901.877.187-0 Registered Address: Medellín, Antioquia, Colombia.

These Terms and Conditions (hereinafter, the “Terms”) constitute a legally binding contract between the User (hereinafter, the “Principal” or “User”) and ORBICHAIN LABS S.A.S. (hereinafter, the “Agent” or “Orbichain”), a Colombian commercial company identified with Tax ID (NIT) 901.877.187-0, registered under economic activity CIIU 6201 (Computer systems development).

By accessing, downloading, or using the Orbichain mobile application and/or web platform, the User declares that they have read, understood, and fully accepted these Terms.

CLAUSE ONE: LEGAL NATURE AND TECHNOLOGICAL MANDATE

Orbichain is a technology services company and not a financial entity. By accepting these Terms, the User and Orbichain enter into a Civil and Commercial Mandate Agreement (Art. 1262 of the Commercial Code and Art. 2142 of the Civil Code), by virtue of which the User authorizes Orbichain to carry out technical actions on virtual assets on the User’s behalf and at the User’s own risk.

Orbichain acts exclusively as a technological execution interface; at no time does it acquire ownership, use, enjoyment, or disposal rights over the User’s digital assets. Such assets remain at all times within the User’s patrimony, and Orbichain only executes automated instructions issued by the Principal through the software.

CLAUSE TWO: SCOPE OF SERVICES (VASP)

Orbichain is defined as a Virtual Asset Service Provider (VASP) in accordance with Resolution 314 of 2021 issued by the UIAF. Its services are limited to the provision of technological infrastructure for:

Technical Custody Administration: Provision of a software environment for the management of digital assets.

Execution of Exchanges (Swaps): Technical management for the exchange of intangible assets (BTC, ETH, SOL, BNB, USDT) under the User’s express orders.

OrbiTag Protocol: Transfer of personal rights over virtual assets between users within the Orbichain infrastructure database.

4. PARAGRAPH: Orbichain expressly declares that it does not manage legal tender (fiat currency). The services described herein do not constitute securities intermediation under Law 964 of 2005, nor mass and habitual collection of funds from the public.

CLAUSE THREE: REGISTRATION AND SECURITY (KYC/AML)

Access to Orbichain technology requires prior registration and the completion of identity verification protocols. The User agrees to: ● Provide truthful and verifiable information.

● Undergo biometric validations and proof-of-life checks.

● Maintain the confidentiality of their access credentials.

● Orbichain uses third-party infrastructure for authentication and screening against restrictive lists (OFAC, UN, etc.) in order to prevent fraud and identity theft.

CLAUSE FOUR: ECONOMIC REGIME AND TECHNICAL FEES

Orbichain does not obtain financial returns from users’ assets. Its revenue comes from Technology Usage Fees. ● Triggering Event: The use of the software infrastructure for executing swaps or withdrawals to external networks.

● Nature: These fees are the consideration for the development, maintenance, and technical support services of the platform.

● Transparency: The fee amount will be communicated to the User before confirming each transaction.

CLAUSE FIVE: TAX REGIME (DIAN)

According to Concept 20466 of 2019 issued by the DIAN, virtual assets on the Platform are considered intangible goods or intangible assets. ● The fees charged by Orbichain correspond to the provision of software services and are subject to the current tax regulations in Colombia.

● The User is solely responsible for declaring and paying taxes arising from the holding, possession, or occasional gain resulting from price fluctuations of their virtual assets.

CLAUSE SIX: COMPLIANCE AND REPORTING (UIAF)

Orbichain applies a risk-based approach for the prevention of Money Laundering and Terrorism Financing (ML/TF), in accordance with Resolution 314 of 2021 issued by the UIAF. ● The User expressly authorizes the technical monitoring of their transactions.

● Orbichain reserves the right to report Suspicious Operations (ROS) and to preventively freeze access to the technology in the presence of risk alerts, without this generating civil liability for breach of the mandate.

CLAUSE SEVEN: LIMITATION OF LIABILITY AND RISKS

The User acknowledges and accepts that:

Volatility: Virtual assets are highly volatile and their value may decrease to zero.

Irreversibility: Transactions on blockchain networks are final and cannot be reversed by Orbichain.

Limited Liability: Orbichain’s liability is limited exclusively to due diligence in the provision of the technological service. It shall not be responsible for failures in decentralized protocols, 51% attacks on external networks, or the loss of credentials due to the User’s negligence.

CLAUSE EIGHT: PROHIBITED USES

It is strictly prohibited to use Orbichain technology to: ● Carry out illegal activities under the Colombian Penal Code.

● Access the platform through unauthorized automated systems (bots).

● Attempt to breach, decompile, or perform reverse engineering on the software.

CLAUSE NINE: INTELLECTUAL PROPERTY

The software, algorithms, logos, the trademarks “Orbichain” and “OrbiTag”, and any associated developments are the exclusive property of ORBICHAIN LABS S.A.S. The User receives a personal, revocable, and non-transferable license of use, subject to compliance with these Terms.

CLAUSE TEN: PERSONAL DATA PROCESSING

Orbichain acts as the data controller in accordance with Law 1581 of 2012. The collected data are used strictly for the provision of the service and regulatory compliance. For further details, please consult our Privacy Policy.

CLAUSE ELEVEN: MODIFICATIONS

Orbichain may modify these Terms at any time in order to adapt them to regulatory or technical changes. The modifications will be notified through the application. Continued use of the platform after a modification implies acceptance of the new Terms.

CLAUSE TWELVE: APPLICABLE LAW AND JURISDICTION

This contract is governed by the laws of the Republic of Colombia. Any dispute arising from the interpretation or execution of these Terms shall initially be resolved through direct conciliation. If no agreement is reached, the dispute shall be submitted to the competent judges in the city of Medellín, Antioquia.

USER ACCEPTANCE: By clicking “Accept” or by using the services, the User ratifies their consent and becomes legally bound under the clauses of this Technological Mandate.

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