TERMS AND CONDITIONS OF USE OFORBICHAIN

1.1. These Terms and Conditions (the "Terms") constitute a legally binding contract between NOVACODIFY S.A.S., a simplified joint-stock company incorporated under the laws of the Republic of Colombia, identified with NIT 901.915.046-4, with principal domicile in Medellín, Antioquia (hereinafter "NOVACODIFY"), and the natural person who registers and uses the Platform (hereinafter, the "User").

1.2. "Orbichain" is a trademark and a technological ecosystem exclusively owned by NOVACODIFY. Orbichain is not a legal entity, has no assets of its own, and is not a party to this contract. The only party obligated to the User under these Terms is NOVACODIFY.

1.3. These Terms govern access to and use of the mobile application and the website orbichain.com (collectively, the "Platform") and of the functionalities described in Clause 5.

1.4. The User declares that they have read, understood, and fully accepted these Terms by checking the acceptance box during registration. Acceptance is prior, express, and informed, and is recorded with date, time, document version, IP address, and device identifier, as a manifestation of will pursuant to Law 527 of 1999.

1.5. Integral documents. The following form an inseparable part of this contract: (a) NOVACODIFY’s Personal Data Processing Policy, available at orbichain.com; (b) the current Fee Schedule; and (c) the Direct Referral Program Rules. In the event of conflict, these Terms shall prevail.

1.6. Territorial scope. Orbichain is offered exclusively and solely in the Republic of Colombia, to natural persons over eighteen (18) years of age with residence in Colombia and a valid Colombian identity document. Access from outside Colombia is prohibited and may be technically restricted. The User who accesses from another jurisdiction does so at their own risk and is solely responsible for compliance with the rules applicable to them.

Virtual Asset: digital representation of value that may be digitally traded or transferred, that is not legal tender and is not issued or backed by any authority. It is used as a commercial synonym for "cryptoasset" and "digital asset".

Orbichain Wallet: technological environment administered by NOVACODIFY in which the User’s Position in Virtual Assets is reflected pursuant to Clause 6.

Blockchain or Network: decentralized distributed ledger infrastructure on which each Virtual Asset exists. NOVACODIFY does not control it, does not operate it, and is not liable for its operation.

Orbichain Fee Credit: commercial discount applicable exclusively against future Technological Use Fees. It is not money, is not a Virtual Asset, is not transferable, and is not withdrawable or redeemable for cash.

Orbichain Account: personal, unique, and non-transferable record of the User on the Platform, protected by access credentials and authentication factors.

External Send: instruction by the User to transfer Virtual Assets from their Orbichain Wallet to an external wallet address on the corresponding Network.

Orbichain Level (OrbiRanks): User progression category, determined exclusively by their own activity pursuant to the applicable Rules.

OrbiTag: unique alphanumeric identifier assigned to each User, which enables routing of internal transfers between Users within the Platform’s database, without recording on the Blockchain.

Exchange (Swap): operation whereby the User delivers a determined quantity of one Virtual Asset and receives a determined quantity of another enabled Virtual Asset, under the terms of article 1955 et seq. of the Civil Code and article 905 of the Commercial Code.

Platform: the Orbichain mobile application and the website orbichain.com.

Position in Virtual Assets: quantity of each Virtual Asset that, according to NOVACODIFY’s internal record, corresponds to the User. It does not constitute a monetary balance, a deposit, or a credit right in money against NOVACODIFY.

Liquidity Provider: one or more international virtual asset liquidity providers of recognized standing, with which NOVACODIFY contracts for price formation and hedging of its positions for the execution of Exchanges.

Referral Reward: unique and immediate promotional payment in Virtual Assets, regulated in Clause 11.

Conversion Service: service of purchase and sale of Virtual Assets against Colombian pesos, provided by an authorized third-party provider, which the User accesses through the Platform interface pursuant to Clause 7.

Technological Use Fee: consideration that NOVACODIFY charges for the use of its software infrastructure, pursuant to Clause 10.

Network Fee: cost charged by the corresponding Blockchain for processing a transaction. It is not received by NOVACODIFY and is borne entirely by the User.

UIAF: Unidad de Información y Análisis Financiero.

3.1. Technological ecosystem. NOVACODIFY is a commercial company dedicated to software development and technological solutions. Orbichain is a technological ecosystem that provides its Users with software tools for the management, exchange, and transfer of Virtual Assets. NOVACODIFY acts exclusively as a technological infrastructure provider and, regarding prevention of money laundering and terrorist financing, voluntarily and diligently applies customer knowledge, monitoring, and reporting controls: it is registered with the UIAF in the Online Reporting System (SIREL) under entity code 19149, has formally designated a Compliance Officer, and handles the reports applicable to it under current regulations.

3.2. What NOVACODIFY is not. The User expressly acknowledges and accepts that NOVACODIFY:

● a) Is not a banking establishment, financial corporation, financing company, financial cooperative, or entity supervised by the Superintendencia Financiera de Colombia; ● b) Does not raise funds from the public on a massive and habitual basis, whether directly or indirectly; ● c) Does not receive money deposits or administer savings accounts, checking accounts, CDTs, or equivalent products; ● d) Does not grant credit of any nature; ● e) Does not provide payment services or operate as a low-value payment system; ● f) Does not intermediate securities or act as a stockbroker, within the terms of Law 964 of 2005; ● g) Is not a financial, tax, legal, or investment advisor, and does not offer investment recommendations; ● h) Does not administer any collective portfolio, investment fund, or autonomous estate; ● i) Does not manage legal tender belonging to the User.

3.3. Warning regarding Virtual Assets. The User acknowledges that Virtual Assets, including BTC, ETH, SOL, BNB, and USDT: (a) do not constitute legal tender or money for legal purposes, and have no liberatory power; (b) do not constitute deposits of the financial system and are not covered by FOGAFÍN; (c) have no supervision, endorsement, guarantee, or authorization from the Superintendencia Financiera de Colombia; and (d) are not means of payment under Colombian regulations. Consequently, the User fully assumes the risk of total or partial loss of their value.

3.4. Tax treatment. Pursuant to Concept 20466 of 2019 of the DIAN, Virtual Assets are considered intangible goods or intangible assets. The User is solely responsible for determining, declaring, and paying the taxes derived from the holding, possession, disposal, or appreciation of their Virtual Assets. NOVACODIFY does not withhold taxes on behalf of the User, except under express legal mandate, and does not provide tax advice.

4.1. Requirements. Only a natural person who simultaneously: is over eighteen (18) years of age; has full legal capacity; resides in Colombia and holds a valid Colombian identity document; acts in their own name, for their own account, and at their own risk; and completes the identification process, may be a User.

4.2. Know your customer. The User must complete an identification process that may include provision of data, validation of identity document, biometric validation and liveness proof, declaration of source of funds and economic activity, screening against national and international restrictive lists, and verification of Politically Exposed Person (PEP) status.

4.3. Restricted access without identification. While the User has not completed and approved the identification process, access to the Platform will be restricted and NOVACODIFY may limit the available functionalities at its sole discretion, pursuant to its internal risk management policies.

4.4. Truthfulness and updating. The User guarantees that all information provided is complete, accurate, truthful, and current, and assumes exclusive responsibility for its truthfulness. The User undertakes to update it within five (5) business days following any change, or when NOVACODIFY so requires.

4.5. Reservation of the right to request information. NOVACODIFY reserves the right to request at any time, before or after any operation, additional information and documentation regarding the User’s identity, the origin of their funds, the origin and destination of their Virtual Assets, or any other aspect it deems relevant to verify compliance with these Terms and its policies for prevention of money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction (SAGRILAFT), as well as to respond to requests from competent authorities. Failure to timely respond to the request entitles NOVACODIFY to restrict, suspend, or terminate access pursuant to Clause 16.

4.6. Strictly personal use. The Orbichain Account is personal, unique, and non-transferable. It is prohibited to operate in the name of, for the account of, in the interest of, or at the risk of a third party. The User declares that they are the ultimate beneficial owner of all Virtual Assets they manage. Violation of this obligation is grounds for immediate termination and is the exclusive responsibility of the User.

4.7. Custody of credentials — User responsibility. The User is solely responsible for the custody of their access credentials and authentication factors, and for all activities that occur in their Account. NOVACODIFY will never request the User’s password through any channel. Every operation authenticated with the User’s credentials shall be presumed to have been performed by them, as it constitutes an electronic signature mechanism pursuant to Law 527 of 1999, unless fault or willful misconduct by NOVACODIFY is proven.

4.8. Discretionary rejection. NOVACODIFY may refrain from onboarding any applicant, without need to state a reason and without generating any liability whatsoever.

5.1. Catalog. NOVACODIFY provides through Orbichain the following technological functionalities:

1. Orbichain Wallet — Technological environment for Virtual Asset management — NOVACODIFY’s role: Software provider 2. Exchange (Swap) between enabled Virtual Assets — Exchange contract — NOVACODIFY’s role: Counterparty 3. Internal transfer (OrbiTag) — Routing between Users within the Platform — NOVACODIFY’s role: Record operator 4. External Send to third-party wallets — Execution of technical instruction — NOVACODIFY’s role: Executor 5. Access to the Conversion Service — Interface to an authorized third-party provider — NOVACODIFY’s role: Interface only

Any functionality not listed does not form part of Orbichain, even if it appears in promotional materials or in prior versions of these Terms.

5.2. Enabled Virtual Assets. Orbichain operates exclusively with BTC (Bitcoin network), ETH (Ethereum/ERC-20 network), SOL (Solana network), BNB (BNB Smart Chain network), and USDT (networks indicated on the Platform). NOVACODIFY may enable or discontinue support for Virtual Assets or Networks at its discretion; if it discontinues support for one, it will give thirty (30) calendar days’ prior notice and will enable during that period its External Send or Exchange.

5.3. Send to incorrect network — User responsibility. The User is solely responsible for correctly selecting the Network and destination address. Sending to an unsupported Network, to an erroneous address, or to an incompatible contract results in the definitive and irrecoverable loss of the assets. NOVACODIFY cannot recover them and is not liable for them.

5.4. Functionalities not included. NOVACODIFY does not provide through Orbichain: management of legal tender; savings services; payment of interest or returns; staking, farming, or return products; loans or credit; debit or credit cards; peer-to-peer exchange (P2P); raffles or drawings; or investment, legal, or tax advice.

5.5. Educational content (Orbichain Academy). Educational content is for informational purposes only. It does not constitute advice, an investment recommendation, or a promise of results.

6.1. Technological environment. The Orbichain Wallet is a software tool that reflects the User’s Position in Virtual Assets and allows the User to instruct Exchanges, transfers, and External Sends. NOVACODIFY maintains the technical infrastructure necessary to execute the User’s instructions and to return their Virtual Assets when requested.

6.2. User ownership. Economic ownership of the Virtual Assets reflected in the Wallet remains with the User. Such assets do not constitute NOVACODIFY’s own resources and do not respond for its obligations to third parties. NOVACODIFY keeps an internal record that allows determination of each User’s Position.

6.3. Third-party infrastructure. For the technical conservation of assets and the efficient execution of operations, NOVACODIFY may rely on international infrastructure, custody, and liquidity providers of recognized standing. The User acknowledges that these providers are third parties that NOVACODIFY does not control, and that their availability may affect the execution of operations. NOVACODIFY selects and supervises these providers with reasonable diligence.

6.4. NOVACODIFY’s commitments. NOVACODIFY undertakes to: (a) keep a record that allows individualization of each User’s Position; (b) not allocate Users’ Virtual Assets to finance its own operations or proprietary yield operations; (c) dispose of a User’s Virtual Assets only upon that User’s instruction, by order of a competent authority, or to deduct accrued Fees; and (d) maintain sufficient availability to fulfill Users’ External Send instructions under normal operating conditions.

6.5. No yield. Holding Virtual Assets in the Orbichain Wallet does not generate interest, yield, or any economic benefit. Any variation in the Position is due exclusively to the market price of the Virtual Assets.

6.6. Restitution. The User may at any time instruct the External Send of all or part of their Position, subject to the applicable Network Fee, the Network’s technical minimums, and the security and compliance controls of these Terms.

6.7. Risks assumed by the User. The User acknowledges and assumes the risks inherent to blockchain technology and dependence on infrastructure providers, including those described in Clause 14. NOVACODIFY is liable only under the terms of Clause 15.

7.1. Provided by a third party. Conversion between Colombian pesos and Virtual Assets is provided by an authorized third-party provider, independent of NOVACODIFY, and not by NOVACODIFY.

7.2. NOVACODIFY does not manage the User’s pesos.

NOVACODIFY DOES NOT RECEIVE, DOES NOT CUSTODY, DOES NOT ADMINISTER, DOES NOT TRANSFER, AND DOES NOT DISPOSE OF, AT ANY TIME, LEGAL TENDER BELONGING TO THE USER.

Colombian pesos that the User allocates to acquire Virtual Assets, or that the User receives from their sale, are received and delivered by the third-party provider through its own channels, accounts, and payment methods. No Colombian peso of the User enters NOVACODIFY’s accounts.

7.3. NOVACODIFY’s role. NOVACODIFY limits itself to making available to the User the interface to issue their instruction to the third-party provider, transmitting said instruction, and reflecting the status of the operation on the Platform.

7.4. Direct relationship. The legal relationship arising from the Conversion Service is formed between the User and the third-party provider. The User must accept that provider’s terms and conditions and data policy, and submit to the identification processes that the provider independently requires.

7.5. Absence of liability. NOVACODIFY is not liable for the conversion price, execution or disbursement times, rejection of operations, or suspension or termination of the relationship between the third-party provider and the User. Such claims must be directed directly to the third-party provider.

7.6. Substitution. NOVACODIFY may change or add the Conversion Service provider at any time, informing of it through the Platform.

8.1. Nature. The Exchange is a contract whereby the User delivers to NOVACODIFY a quantity of one Virtual Asset and receives a quantity of another enabled Virtual Asset. NOVACODIFY acts as direct counterparty, not as agent, commission agent, or representative of the User.

8.2. Liquidity Provider. For price formation and hedging of its positions, NOVACODIFY contracts with one or more Liquidity Providers. The User acknowledges that: there is no contractual relationship between the User and the Liquidity Provider; NOVACODIFY is the only party obligated to the User for each Exchange; and unavailability of the Liquidity Provider may temporarily prevent execution of Exchanges.

8.3. Formation of the contract. Before confirming, the Platform will inform the Asset delivered and its quantity, the exact quantity to be received, the Technological Use Fee, and the Network Fees. The quote is valid for thirty (30) seconds; the Exchange is perfected upon pressing "Confirm" within that period. Once the period expires, the quote lapses.

8.4. Price and spread. The price incorporates a differential (spread) that forms part of NOVACODIFY’s consideration and is already included in the exact quantity informed before confirmation. The User accepts that Orbichain’s price may differ from that observable on other platforms.

8.5. Irrevocability. Once confirmed, the Exchange is firm, definitive, and irrevocable. The User fully assumes the risk of price variation after confirmation.

8.6. Execution period. NOVACODIFY will execute the Exchange immediately. If for a technical cause not attributable to its fault or willful misconduct it is not possible within the following forty-eight (48) hours, the User may choose between restitution of the delivered Asset (minus accrued Network Fees) or deferred execution at the quote in force when service resumes.

8.7. Scheduled orders. When the Platform enables it, the User may schedule an Exchange conditioned on a price. NOVACODIFY does not guarantee its execution even if the price is reached, as it depends on available liquidity; the order does not generate a Fee while not executed; it may be canceled before execution; and it does not constitute a promise of profitability or an investment recommendation.

8.8. Origin restriction. NOVACODIFY may reject Virtual Assets originating from addresses associated, according to its analysis tools, with mixers, sanctions, illicit markets, or criminal activity, proceeding pursuant to its compliance obligations.

9.1. The OrbiTag allows the User to transfer Virtual Assets to another User of the Platform through their identifier, as a modification of the internal Position records, without recording on the Blockchain.

9.2. User responsibility. OrbiTag transfers are immediate and irreversible once confirmed. The User is solely responsible for verifying the recipient’s OrbiTag before confirming. NOVACODIFY cannot reverse a transfer sent to an incorrect OrbiTag.

9.3. OrbiTag transfers are subject to monitoring, to limits by Orbichain Level, and to the obligations of Clause 12.

9.4. It is prohibited to use the OrbiTag to transfer on behalf of third parties, to fractionate operations to evade controls, or to develop outside the Platform activities of purchase and sale of Virtual Assets against money.

10.1. Taxable event. NOVACODIFY charges the Technological Use Fee for the use of its software infrastructure, which accrues upon execution of Exchanges and External Sends.

10.2. No charge for. NOVACODIFY does not charge a management fee, administration fee, inactivity fee, minimum balance fee, or any fee for holding Virtual Assets in the Wallet.

10.3. Prior transparency. The exact value of every Fee will be informed before confirming the operation. No Fee not previously informed shall be enforceable.

10.4. Network Fees. Network Fees are imposed by the Blockchain, not by NOVACODIFY; are borne by the User; vary according to Network congestion; and are informed before each operation. Every External Send must exceed the Network Fee in force.

10.5. Form of payment. Fees accrue in Colombian pesos as a unit of reference and are paid by dation in payment with the Virtual Asset involved, at the reference price in force. NOVACODIFY is authorized to deduct them from the Asset subject to the operation.

10.6. Invoicing. NOVACODIFY, as electronic invoicer, will issue the invoice within three (3) business days following accrual, to the registered email.

10.7. Modification. NOVACODIFY may modify its Fees by informing thereof on the Platform with fifteen (15) calendar days’ prior notice. Current Fees are available at orbichain.com.

11.1. Direct referrals only. The benefit is generated exclusively by the User’s own direct referrals.

11.2. Prohibition of multilevel structure. The Program does not recognize any benefit derived from referrals of referrals or from any descending level. Orbichain is not, and will not operate as, a multilevel marketing or pyramid scheme. No benefit depends on recruiting persons or on the depth of a network.

11.3. Orbichain Levels. Progression between Levels depends exclusively on the User’s own activity (seniority, complete identification, Exchange volume). The number of referrals never determines the Level.

11.4. Referral Reward. The benefit consists of a unique promotional payment that: (a) accrues only once per direct referral, when such referral completes their identification and their first Exchange; (b) is paid in Virtual Assets (USDT), immediately and unconditionally; (c) is of immediate free disposal, without lock-up or waiting period; (d) does not constitute interest or yield, but a promotional payment for a specific commercial action; and (e) is subject to the antifraud controls of numeral 11.5.

11.5. Antifraud controls. NOVACODIFY may deny or revoke Rewards in cases of self-referrals, multiple accounts, device or IP coincidence between referrer and referred, false identities, or any improper maneuver, in addition to terminating the relationship pursuant to Clause 16.

11.6. Fee Credit. NOVACODIFY may grant Fee Credits in campaigns: discount against future Fees; it is not money or a Virtual Asset; not withdrawable, transferable, or redeemable; consumed automatically; validity of twelve (12) months; extinguished upon Account closure.

11.7. Discretion. The Program is a liberality subject to budget. NOVACODIFY may modify or terminate it going forward with fifteen (15) days’ prior notice, respecting Rewards already accrued.

12.1. Commitment. NOVACODIFY diligently applies controls for prevention of money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction, administered by its Compliance Officer, pursuant to applicable Colombian regulations and industry best practices.

12.2. Authorization of monitoring. The User expressly authorizes NOVACODIFY to permanently and automatically monitor their operations, perform chain analysis on the origin and destination addresses of their Virtual Assets, and consult databases and restrictive lists, directly or through third parties.

12.3. Reports. The User acknowledges that NOVACODIFY may submit to the UIAF the reports applicable to it, including suspicious transaction reports, without prior notice to the User and without requiring certainty as to the existence of a crime.

12.4. Legal confidentiality. Reports to the UIAF are subject to legal confidentiality. NOVACODIFY may not inform the User of their existence, content, or processing, and the User waives any claim therefor.

12.5. Preventive measures. NOVACODIFY may, preventively and without prior notice, freeze totally or partially the User’s Position, restrict or suspend the Account, reject an operation, or require additional supporting documents, upon risk alerts, authority requests, or indications of unusual or suspicious operation. These measures will be maintained for the time necessary for verification or until a pronouncement by the competent authority.

12.6. Cooperation with authorities. NOVACODIFY will respond to requests from competent judicial and administrative authorities, including the provision of information and the blocking or delivery of Virtual Assets when legally ordered.

12.7. User declaration. The User declares under oath that their Virtual Assets and resources come from lawful activities, that they are not under investigation for money laundering or related crimes, and that they do not appear on restrictive lists. This declaration is deemed reiterated with each operation.

It is prohibited for the User to:

(a) use Orbichain for illicit activities (money laundering, terrorist financing, corruption, smuggling, tax evasion, fraud, extortion, among others);

(b) operate for the account or in the interest of a third party;

(c) create or use more than one Account, or access another User’s Account;

(d) provide false information or altered documents;

(e) participate in pyramid schemes, Ponzi schemes, or unauthorized fundraising;

(f) use bots or automated interfaces not provided by NOVACODIFY;

(g) breach or circumvent security measures, or perform unauthorized vulnerability testing;

(h) decompile or reverse engineer the software;

(i) develop third-party applications that interact with the Platform without written authorization;

(j) manipulate prices or orders;

(k) access from outside Colombia or through a VPN to circumvent geographic restrictions;

(l) present unfounded claims or chargebacks regarding executed operations.

Breach entitles NOVACODIFY to terminate the relationship immediately, without prejudice to civil and criminal actions and reports to the authorities.

The User declares that they know and assume under their exclusive responsibility the following risks:

14.1. Volatility. The value of Virtual Assets may vary abruptly, even to zero.

14.2. Irreversibility. Transactions on the Blockchain are definitive and cannot be reversed.

14.3. User error. An error in the address, the Network, the OrbiTag, or the amount results in the definitive loss of the assets, which is the exclusive responsibility of the User.

14.4. Network risk. Congestion, increase in Network Fees, forks, majority attacks, protocol failures, or interruptions may affect the availability, value, or utility of Virtual Assets.

14.5. Third-party risk. The operation depends on infrastructure, liquidity, conversion, identity verification, cloud, financial entities, and telecommunications providers that NOVACODIFY does not control, and whose unavailability may affect the service.

14.6. Stablecoin risk. USDT is issued by a private third party; its parity with the dollar is not guaranteed by NOVACODIFY or by any authority and may be lost.

14.7. Regulatory risk. The regulatory framework for Virtual Assets is evolving and may restrict or prevent the provision of the services. NOVACODIFY does not guarantee their future availability.

14.8. Fraud risk. NOVACODIFY will never request passwords, verification codes, or the sending of Virtual Assets to external addresses. Except for fault or willful misconduct by NOVACODIFY, the fraud risk derived from breach of the duty to custody credentials is assumed by the User.

14.9. Autonomy of decision. All decisions to acquire, exchange, hold, or transfer Virtual Assets are self-directed and the exclusive responsibility of the User. NOVACODIFY does not issue recommendations.

15.1. Standard. NOVACODIFY shall be liable to the User only for damages caused by willful misconduct or proven fault in the performance of its obligations under these Terms. It is for the User to prove the damage, the fault or willful misconduct, and the causal relationship.

15.2. Legal limit. Pursuant to article 43 of Law 1480 of 2011, no provision of these Terms shall be interpreted as an exemption from NOVACODIFY’s liability for willful misconduct or gross negligence, nor as a waiver by the User of the rights recognized by the Consumer Statute.

15.3. Exclusions. Except for willful misconduct or proven fault by NOVACODIFY, it shall not be liable for: (a) variation in the market value of Virtual Assets; (b) User errors in addresses, networks, OrbiTag, or amounts; (c) failures, forks, attacks, or unavailability of Blockchains; (d) acts or omissions of the conversion provider, infrastructure providers, the Liquidity Provider, or other independent third parties; (e) loss of credentials or unauthorized access due to breach of the User’s custody duties; (f) lost profits, loss of opportunity, indirect or consequential damages.

15.4. Nature of the obligation. NOVACODIFY’s obligations relating to the execution of operations are of means and not of result, inasmuch as they depend on third-party infrastructure and decentralized networks that NOVACODIFY does not control.

15.5. Duty to mitigate. The User undertakes to inform NOVACODIFY of any incident, error, or unauthorized access within twenty-four (24) hours following knowledge thereof, and to adopt reasonable measures to mitigate the damage.

16.1. By the User. The User may terminate the relationship at any time and at no cost, by requesting closure of their Account. As a condition, the User must previously instruct the External Send of the entirety of their Position and pay pending Fees.

16.2. By NOVACODIFY. NOVACODIFY may restrict, suspend, or terminate the relationship, in whole or in part, when the User breaches these Terms; the information proves false or unverifiable; the User fails to respond to requests; there are risk or fraud alerts; the User appears on restrictive lists; an authority so requires; or a regulatory change prevents provision of the service.

16.3. Prior notice. When termination is not based on compliance, security, or authority-request grounds, NOVACODIFY will give thirty (30) calendar days’ prior notice.

16.4. Restitution. Upon termination of the relationship, and except for an order of a competent authority or an active compliance alert, NOVACODIFY will grant the User a period of no less than thirty (30) calendar days to instruct the External Send of their Position, minus accrued Network Fees and Technological Use Fees. Termination does not affect the User’s right over their Virtual Assets.

16.5. Retention. Closure of the Account does not release NOVACODIFY from its legal duty to retain identification information and the record of operations for the term required by applicable regulations.

17.1. Foreign cause means any supervening, unforeseeable, and irresistible event, beyond the control of the affected party, that prevents it from fulfilling its obligations. It suspends the affected obligations while the impossibility is temporary and extinguishes them when it is definitive.

17.2. Events. Provided there is no fault or willful misconduct by NOVACODIFY, the following may constitute foreign cause: suspension or termination of services of infrastructure, liquidity, conversion, verification, cloud, telecommunications, or financial service providers; regulatory changes that prevent operation; forks or protocol failures of Blockchains; and cyberattacks that exceed reasonably required security measures.

17.3. Notice. The affected party shall communicate the foreign cause within the following fifteen (15) business days.

17.4. Limit. Foreign cause does not extinguish NOVACODIFY’s obligation to return to the User their Virtual Assets, without prejudice to temporary suspension of enforceability while the impediment persists.

18.1. NOVACODIFY acts as Data Controller pursuant to Law 1581 of 2012 and Decree 1074 of 2015. Details are set out in the Personal Data Processing Policy available at orbichain.com, which the User declares to have accepted in a prior, express, and informed manner.

18.2. Biometric data. They are sensitive data; their provision is optional; without them NOVACODIFY cannot fulfill its identification obligations and will not be able to provide the service.

18.3. Retention. NOVACODIFY will retain identification information and the record of operations for the legally required term, even after Account closure, during which period the right of erasure shall not apply and the data shall remain blocked.

18.4. Habeas data: legal@orbichain.com.

19.1. The software, code, algorithms, databases, interfaces, designs, contents, and the trademarks "Orbichain", "OrbiTag", "OrbiRanks", and "Novacodify" are the exclusive property of NOVACODIFY S.A.S. or of third parties that authorized their use.

19.2. NOVACODIFY grants the User a personal, limited, revocable, non-exclusive, and non-transferable license of use, restricted to use of the Platform pursuant to these Terms.

19.3. Reproduction, distribution, transformation, or commercial exploitation of the contents without prior written authorization from NOVACODIFY is prohibited.

20.1. Withdrawal. The User may not exercise the right of withdrawal (art. 47, Law 1480 of 2011) with respect to Exchanges or operations on Virtual Assets, as they are services whose price is subject to market fluctuations that NOVACODIFY does not control and whose execution begins with the User’s agreement.

20.2. Reversal. Virtual Assets do not constitute electronic payment instruments; the operations are not covered by the right of reversal of article 51 of Law 1480 of 2011.

20.3. Legal warranty. NOVACODIFY is liable for the quality and suitability of the technological service under the terms of Law 1480 of 2011. The warranty does not cover variation in the market value of Virtual Assets.

20.4. PQR. The User may submit petitions, complaints, and claims to soporte@orbichain.com, with a response within the following fifteen (15) business days.

20.5. Authority. The User may resort to the Superintendencia de Industria y Comercio in the exercise of their rights as a consumer.

21.1. NOVACODIFY may amend these Terms to adapt them to regulatory, technical, or operational changes.

21.2. Prior notice. Amendments will be notified through the Platform and the registered email with fifteen (15) calendar days’ prior notice, unless a regulatory change imposes immediate effectiveness.

21.3. Right of withdrawal. If the User does not accept the amendments, they may terminate the relationship at no cost before they take effect. Continued use implies acceptance of the new version.

21.4. Versions. NOVACODIFY will keep historical versions of these Terms available at orbichain.com.

22.1. Assignment. The User may not assign their contractual position or their Account. NOVACODIFY may assign its position upon prior notice of thirty (30) days.

22.2. Severability. The nullity of one provision does not affect the validity of the others.

22.3. Notices. To NOVACODIFY: Carrera 43B # 16-41, Office 806, Medellín, or soporte@orbichain.com. To the User: to the registered email and mobile phone, which must be kept updated.

22.4. Language. Official and binding version in Spanish.

22.5. Entire agreement. These Terms and their integral documents constitute the complete agreement and supersede any prior version.

22.6. Applicable law. Laws of the Republic of Colombia.

22.7. Jurisdiction. Disputes shall first be attempted to be resolved by direct settlement within thirty (30) calendar days following the written claim; if no agreement is reached, they shall be submitted to the courts of the Republic of Colombia. This does not restrict the consumer User’s right to resort to the Superintendencia de Industria y Comercio or to the judge of their domicile, pursuant to Law 1480 of 2011.