Globen App and Platform Terms and Conditions of use

This document consists of three books:

• Book One. General Terms, applicable to all Users in all jurisdictions where the GLOBEN Platform operates, drafted in accordance with the laws of the United States of America and payments industry standards.
• Book Two. Jurisdictional Annexes, containing the rules specific to the United States of America (primary jurisdiction), Ecuador, El Salvador, Guatemala, Nicaragua and all other countries.
• Book Three. Operational and Product Annexes, containing the specific terms of the modules that the User voluntarily activates (for example, Subscriptions and Recurring Billing).

In the event of a conflict between Book One and a Jurisdictional Annex, the Jurisdictional Annex prevails with respect to Users in that jurisdiction. Nothing in these Terms limits non-waivable rights granted by mandatory public-order laws of the User's jurisdiction.

1.1 Purpose

These Terms and Conditions of Use (the "Terms") set forth the contractual framework governing access to and use of the mobile application, web portal, application programming interfaces and other channels of the payments technology platform identified by the GLOBEN brand (collectively, the "Platform") by any individual or legal entity that registers on it (the "User").

1.2 Platform Owner and Contracting Entity

The Platform is owned by Payphone Global Inc., a corporation organized under the laws of the State of Wyoming, United States of America ("Payphone Global"), which operates it under the GLOBEN brand. Payphone Global heads an international corporate group made up of its subsidiaries and affiliates (the "Group"), through which the Platform is offered in jurisdictions other than the United States of America.

The entity with which the User contracts (the "Contracting Entity") is determined exclusively by the User's country of residence, domicile or incorporation and by the country from which the User accesses the service, in accordance with the corresponding Jurisdictional Annex. In these Terms, "GLOBEN", "we", "us" and "our" refer to the Contracting Entity providing the service to the User.

Contracting Entity by jurisdiction

User's Jurisdiction	Contracting Entity	Annex
United States of America (primary jurisdiction)	Payphone Global Inc.	Annex A
Ecuador	ECUAPAYPHONE C.A.	Annex B
El Salvador	Payphone El Salvador S.A. de C.V.	Annex C
Guatemala	Payphone Guatemala S.A.	Annex D
Nicaragua	Payphone Nicaragua S.A. de C.V.	Annex E
Rest of Latin America and other countries	Payphone Global Inc. or the Group entity indicated in Annex F	Annex F

Each Contracting Entity is solely, exclusively and independently responsible for the operations and the legal, regulatory, contractual, tax and operational obligations pertaining to its jurisdiction. No other Group company, including the parent company, assumes joint, several, secondary or guarantee liability for the obligations of another Group entity, unless expressly stated otherwise in writing.

1.3 Nature of the Service

GLOBEN is a financial technology company and is not a bank or a depository institution. Depending on the jurisdiction and the applicable licenses, the Contracting Entity acts as a payment facilitator, payment aggregator, payment service provider, electronic money issuer or money transmitter, either directly within the scope of its authorizations or through duly authorized banks, acquirers, processors and money transmitters with which it maintains agreements (the "Regulated Partners"), as specified in each Jurisdictional Annex.

GLOBEN is not a party to the underlying commercial relationship between the Merchant User and its customers. GLOBEN does not sell, produce, deliver, warrant or verify the goods or services that are the subject of transactions processed through the Platform, and does not intervene in commercial disputes between them.

The foregoing is without prejudice to the functions GLOBEN performs as an intermediary in the chargeback, bank alert, unrecognized charge and preventive hold processes described in Section 11, within which GLOBEN retains the right to assess the relevance, completeness, legibility, timeliness and credibility of the documentary evidence submitted by the User, and to reject untimely, incomplete, illegible or manifestly irrelevant responses before transmitting them to the Card Network, the issuing bank, the acquirer or the payment processor.

1.4 Contract Structure and Order of Precedence

The following form an integral and inseparable part of these Terms, are incorporated by reference and are permanently accessible on the Website and in the App:

a) The GLOBEN Privacy Policy.

b) The Anti-Money Laundering, Counter-Terrorist Financing, Counter-Proliferation Financing and Sanctions Compliance Policy (BSA/AML and OFAC Program) (forthcoming).

c) The Policy for the Management of Chargebacks, Bank Alerts, Unrecognized Charges and Preventive Holds (forthcoming), which explains to the User how cases are notified and handled, how to submit responses and evidence, the reference timeframes for handling and resolution, the reconsideration process and the applicable operational fees.

d) The Acceptable Use and Restricted Activities Policy (forthcoming).

e) The Fraud Prevention Policy (forthcoming).

f) The current Fee Schedule, published on the Website and accessible from the User's dashboard.

g) The terms of the Regulated Partners applicable to the contracted service, when disclosed to the User.

h) The Specific Terms of each module activated by the User (Book Three).

i) The Jurisdictional Annexes (Book Two).

The published policies are the User-facing versions. The internal manuals, procedures and controls that GLOBEN uses to apply them are not part of these Terms, are confidential and are not publicly available.

In the event of a conflict, the order of precedence is as follows:

1. Mandatory and public-order laws of the User's jurisdiction.
2. Network Rules and Regulated Partner terms, to the extent binding on the User.
3. Any specific written agreement between the User and the Contracting Entity, solely to the extent of the conflict.
4. The applicable Jurisdictional Annex.
5. The Specific Terms of the activated module.
6. Book One (General Terms).
7. Supplementary policies and technical documentation.

1.5 Acceptance and Electronic Contracting

The User accepts these Terms by any of the following means, all of which have identical legal effect:

a) Checking the acceptance box or pressing the "I Accept" button during registration.

b) Registering for, accessing or using the Platform in any of its forms (App, web portal, payment button, payment links, API).

c) Activating a module, feature or additional service, in which case the User also accepts the Specific Terms of that module.

Layered acceptance. The User expressly acknowledges and agrees that GLOBEN's contracting model is modular and layered: the initial acceptance binds the User to the General Terms, and each subsequent activation of a module constitutes an autonomous, specific and unequivocal expression of consent with respect to the Specific Terms of that module. Such in-flow acceptance replaces, for all legal purposes, the execution of addenda, annexes or individual agreements on paper.

Evidentiary value. GLOBEN retains, for the applicable legal period, the electronic record of each acceptance, which includes at a minimum the User identifier, the date and time of acceptance and the exact version of the accepted document, as well as other session metadata (for example, channel, IP address or device identifier) when available in the system. The User acknowledges that such record constitutes evidence of the User's consent and has the effect of an electronic signature under the Electronic Signatures in Global and National Commerce Act (E-SIGN Act), the Uniform Electronic Transactions Act (UETA) as adopted in the applicable state, and the electronic signature laws of the User's jurisdiction, and agrees not to challenge its validity, authenticity or evidentiary weight solely because it is in electronic form.

1.6 User Representations upon Acceptance

The User represents that: (i) the User has read and understood these Terms; (ii) the User has full legal capacity or sufficient authority to be bound; (iii) the User acts on its own behalf and in its own interest, unless otherwise expressly declared and duly documented with GLOBEN; (iv) the information provided is true, complete and current; and (v) the funds the User channels have a lawful origin and destination.

1.7 Amendments to the Terms

GLOBEN may amend these Terms due to legal or regulatory changes, changes in the Network Rules or Regulated Partner requirements, security, risk structure, commercial conditions or the introduction of new features.

General notice: thirty (30) calendar days, by push notification, email to the registered address, prominent notice on the Platform and publication on the Website, without prejudice to any minimum notice periods required by law with respect to Consumers (Annex A).

Amendments effective immediately, notified as soon as reasonably practicable: (i) those imposed by a competent authority, law or regulation of immediate application; (ii) those arising from changes in the Network Rules or Regulated Partner requirements; (iii) those necessary to address a risk of fraud, security, system integrity or regulatory non-compliance; and (iv) those that expand the User's rights or benefits.

Effects. Continued use of the Platform after the effective date constitutes acceptance. A User who does not accept may terminate the relationship without penalty in accordance with Section 17 and withdraw the available balance, subject to outstanding obligations.

Version history. GLOBEN will maintain a historical repository of all versions of these Terms, its supplementary policies and the Specific Terms of each module, indicating their effective dates, and will keep in its systems the version accepted by each User in accordance with Section 1.5. Each transaction is governed by the version in effect on the date it was executed. The User may request, through the support channels, a copy of the version applicable to a given transaction.

Defined terms may be used in the singular or plural, capitalized or not, without altering their meaning.

Account Holder: the individual or legal entity in whose name the GLOBEN Account is opened.

Amount at Risk: the sum of (i) the value of the transactions disputed or under investigation; (ii) the associated fees, fines, penalties and costs that have been or may be passed on to GLOBEN by issuing banks, acquirers, payment processors, Regulated Partners or Card Networks; and (iii) the reasonably estimated exposure for transactions of the same nature that remain within the applicable dispute windows.

API: an application programming interface enabling the technical integration of the Platform with third-party systems.

App: the GLOBEN mobile application for the iOS and Android operating systems, and its updates.

Bank Alert: a notification issued by a bank, financial institution, acquirer, payment processor or Card Network reporting a transaction with risk indicators, possible fraud or any other circumstance requiring review. It may lead to an investigation and, depending on the outcome, may or may not result in a Chargeback.

Business Account: an account of an individual or legal entity that uses the Platform for economic, commercial or professional activity.

Business Day: with respect to Payphone Global Inc., any Monday through Friday, excluding United States federal holidays observed by the Federal Reserve System; with respect to the other Contracting Entities, the days on which they provide ordinary services at their domicile, excluding Saturdays, Sundays and public holidays.

Card Networks: Visa, Mastercard, American Express, Discover, the ACH network administered under the Nacha rules, and the other card brands, networks and payment schemes that GLOBEN has enabled in each jurisdiction from time to time, as disclosed on the Platform.

Card on File: a payment method tokenized and stored with the Cardholder's consent for subsequent transactions.

Cardholder: the holder or authorized user of a Payment Method.

Cash-In: the crediting of funds to the Digital Wallet as a result of a collection, top-up or deposit transaction, net of fees.

Cash-Out (Withdrawal): the transfer of funds from the Digital Wallet to a registered and verified bank account or another authorized disbursement method.

Chargeback: the process by which the Cardholder or its issuer disputes a transaction and requests its reversal.

Competent Authority: any federal, state or local public entity, regulator, supervisor, financial intelligence unit (including the Financial Crimes Enforcement Network, FinCEN), tax, sanctions, data protection, consumer protection or judicial authority with jurisdiction over GLOBEN or the User.

Consumer: an individual who uses the Platform primarily for personal, family or household purposes.

Digital Wallet: the electronic record of the User's balances within the Platform, arising from collection, top-up or transfer transactions, from which payments, transfers and withdrawals are executed. It is not a bank account or deposit, unless the Jurisdictional Annex expressly provides otherwise.

Funds Disbursement or Payouts: an optional module through which, when enabled by GLOBEN and permitted by the applicable license, the Merchant User instructs payments to beneficiaries other than the Account Holder, under specific terms and enhanced due diligence.

GLOBEN Account: the account opened by the User on the Platform, whether a Personal Account or a Business Account.

KYC / KYB: know-your-customer and know-your-business due diligence procedures, including the Customer Identification Program (CIP) and beneficial ownership identification.

Merchant or Merchant User: a User that uses the Platform to receive payments for the sale of goods or the provision of services through a Business Account.

Network Rules: the bylaws, rules, standards, guidelines and procedures of the Card Networks, including the Nacha Operating Rules, as in effect from time to time.

Payment Aggregator: an entity that, under an agreement with acquiring or issuing financial institutions, enables its customers to accept payments through authorized methods, settling funds in their favor.

Payment Facilitator: an entity that, sponsored by an acquiring bank and registered with the Card Networks, enables its Merchants to accept card payments as sub-merchants in accordance with the Network Rules.

Payment Methods: credit, debit or prepaid cards, ACH and other bank transfers, direct debits, cash payments at authorized locations, third-party digital wallets and any other method enabled by GLOBEN.

PCI DSS: the Payment Card Industry Data Security Standard.

Personal Account: an account of an individual who uses the Platform for personal, non-commercial purposes.

Preventive Hold: a temporary measure adopted by GLOBEN upon indications of risk, possible fraud, unusual activity, alerts from financial institutions or any circumstance requiring investigation, which may include temporary restriction of account access, suspension of withdrawals, holding of funds and requests for additional information.

Recurring Billing Mandate: the authorization granted by the Cardholder to a Merchant to periodically charge its payment method, under the terms of Annex G.

Regulated Partner: a bank, acquiring or sponsor bank, payment processor, money transmitter or other authorized entity with which the Contracting Entity maintains agreements for the provision of certain Platform services.

Rolling Reserve: a percentage of processed transactions that GLOBEN temporarily withholds as security for chargebacks, reversals and future obligations.

Second-Tier Receiving Merchant: a User or Merchant that receives payments made with funds traceable to a disputed transaction, even if it did not process that transaction.

Tax Identifier: the User's taxpayer identification number in its jurisdiction, including the Social Security Number (SSN), Individual Taxpayer Identification Number (ITIN) or Employer Identification Number (EIN) in the United States of America, and the RUC, NIT, NRC or equivalent in other jurisdictions.

Tokenization: the replacement of sensitive Payment Method data with a unique identifier that has no intrinsic value outside the authorized environment.

Transaction: any collection, payment, transfer, top-up, withdrawal, reversal, void or chargeback processed through the Platform.

Unrecognized Charge: a claim filed by the Cardholder stating that it does not recognize a transaction recorded on its account, because it claims not to have made it, not to have authorized it, or not to recognize the Merchant where it was made.

Website: the official GLOBEN website, globenpay.app, and its subdomains.

3.1 Legal Capacity

Individuals: be at least eighteen (18) years of age, or the age of majority in the User's state or country of residence if higher; have full legal capacity to contract under the laws of the User's jurisdiction; not be subject to any legal, judicial or administrative restriction limiting the capacity to contract; and hold a valid identity document.

Minors. GLOBEN does not currently offer accounts to minors and does not knowingly collect information from children under thirteen (13) years of age, in accordance with the Children's Online Privacy Protection Act (COPPA). In the future, and only in jurisdictions whose laws permit it, GLOBEN may offer a limited-access option for persons between fourteen (14) and seventeen (17) years of age, with the verifiable authorization of their parent or legal guardian. If enabled, such option will be governed by its own Specific Terms, which will define the available features, transaction limits, the mechanism for authorization and verification of the guardian, and the applicable liability regime. Until such Specific Terms are published and enabled on the Platform, the option will not be available and any account opened by a minor will be suspended upon detection.

Legal entities: be duly organized and existing (including corporations, limited liability companies and other entities), have the necessary corporate authorization, appoint a legal representative or attorney-in-fact with sufficient authority, and remain in good standing throughout the contractual relationship.

3.2 Registration and Verification (KYC / KYB)

Registration includes: (i) account and credential creation; (ii) identity verification, including document and biometric validation; (iii) verification of address, Tax Identifier and economic activity; (iv) declaration of source and use of funds; (v) for legal entities, verification of corporate structure, beneficial owners, legal representation and industry licenses; and (vi) screening against restrictive lists, sanctions lists (including those of the Office of Foreign Assets Control, OFAC) and politically exposed persons databases.

Important information about procedures for opening a new account. To help the government fight the funding of terrorism and money laundering activities, United States federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account. When you open a GLOBEN Account, we will ask for your name, address, date of birth, Tax Identifier and other information that will allow us to identify you, and we may also ask to see your identity document or other documents. The same obligations apply, with the particulars of local law, in the other jurisdictions.

GLOBEN reserves the right to approve, condition, limit or reject any registration request, and to require additional documentation at any time based on the risk profile, without incurring any liability.

3.3 Duty to Update and to Keep Contact Information Current

The User must keep its information up to date and report any relevant change within five (5) Business Days, including changes of address, economic activity, legal representation, ownership structure, beneficial owners, tax status or enabling licenses.

Contact information. The User specifically undertakes to keep the email address, mobile phone number and other contact channels registered in its account permanently current, valid and under its exclusive control, and to update them immediately upon any change, loss of access or security compromise. The User acknowledges that such channels are the appropriate and sufficient means for receiving contractual, operational, security, chargeback, information request and amendment notices, and that notices sent to the registered contact details will be deemed validly delivered in accordance with Section 20, even if the User does not actually access them for reasons attributable to the User.

GLOBEN may require periodic revalidation of contact information and may condition the execution of transactions on completion of such revalidation.

Outdated information, including contact information, may result in limits on amounts, suspension of features, blocking of Cash-In or Cash-Out, or termination of the account.

3.4 Credential Security

The User is solely responsible for the custody and confidentiality of its credentials, for using multi-factor authentication when available and for the security of its devices. Transactions executed with the User's credentials are presumed to have been carried out by the User and constitute a valid expression of the User's will, unless the User demonstrates: (i) timely notice of the credential compromise; (ii) absence of negligence in their custody; and (iii) evidence of fraudulent access by third parties. The foregoing is without prejudice to the liability limits that the law grants to Consumers for unauthorized transfers (Annex A, Section A.6).

GLOBEN will never request full credentials, passwords, PINs or verification codes by email, phone call, messaging or any channel outside the Platform. Any such request must be presumed fraudulent and immediately reported to [email protected].

4.1 Service Catalog

a) Payment processing (Cash-In): acceptance of payments by card, ACH and other bank transfers, cash at authorized locations, payment links, QR codes, payment button and API integration.

b) Digital Wallet: balance inquiries, history, reporting, alerts and reconciliation.

c) User-to-User transfers: transfers of balances between GLOBEN Accounts, subject to limits and controls.

d) Withdrawal of funds (Cash-Out): in accordance with Section 6.

e) Tokenization and card on file: in accordance with Section 5.

f) Subscriptions and recurring billing: optional module, in accordance with Annex G.

g) Funds disbursement and mass payments (Payouts): optional module, available only in the jurisdictions and for the profiles that GLOBEN enables, subject to Specific Terms, enhanced due diligence on beneficiaries and the applicable license.

h) Ancillary services: reconciliation, report exports, accounting and ERP integrations, support and training.

GLOBEN may enable additional services, restrict them by jurisdiction, state, risk profile or available license, and discontinue them with fifteen (15) calendar days' notice for material changes and thirty (30) calendar days' notice for the discontinuation of essential services, unless a regulatory, Regulated Partner or security requirement imposes a shorter period.

4.2 Availability and Service Levels

GLOBEN will endeavor to achieve a target monthly availability of 99.5%, excluding scheduled maintenance, which will be notified forty-eight (48) hours in advance and will not exceed four (4) hours per event. Emergency maintenance may be performed without prior notice.

GLOBEN does not guarantee uninterrupted availability and is not liable for unavailability caused by third-party failures (connectivity and cloud providers, Card Networks, Regulated Partners, financial institutions), cyberattacks, infrastructure failures, force majeure events, or acts, omissions or device failures of the User.

5.1 Registration and Ownership of Payment Methods

When registering a Payment Method, the User represents and warrants that it is the legitimate holder or has the express and verifiable authorization of the holder. GLOBEN may apply reversible validation charges, verification codes, strong authentication (3-D Secure), bank account verification and any other anti-fraud control.

Fraudulent registration of payment methods may constitute a crime, will be reported to the Competent Authorities and will make the User liable for all resulting charges, damages, investigation costs and legal fees.

5.2 PCI DSS Compliance

GLOBEN and the processing providers involved in storing, processing or transmitting cardholder data maintain current PCI DSS compliance, in accordance with the version of the standard required from time to time.

API-integrating Users. A User that integrates the GLOBEN API must hold current PCI DSS compliance validation at the level corresponding to its volume and processing method, and must: (i) implement adequate security controls; (ii) transmit data exclusively through encrypted channels; (iii) never store full magnetic stripe data, CVV/CVC or PIN data under any circumstances; (iv) complete the applicable annual self-assessment questionnaire (SAQ); (v) maintain audit logs; and (vi) immediately report any breach.

Other Users. Users that exclusively use the methods provided by GLOBEN (App, web portal, payment button or payment links) do not store, process or transmit cardholder data and do not require their own PCI DSS validation, without prejudice to their obligation not to capture, record or retain card data by means outside the Platform.

The User's failure to comply with PCI DSS entitles GLOBEN to suspend the services immediately and makes the User liable for fines imposed by the Card Networks, forensic investigation costs and resulting damages.

6.1 Same-Owner Rule

Withdrawals may only be made to bank accounts or other disbursement destinations owned by the same Account Holder of the GLOBEN Account. The User may not register, and GLOBEN will not process withdrawals to, third-party accounts, including those of spouses, domestic partners, relatives, friends, employees, partners or any person other than the Account Holder.

Application by account type:

a) Personal Account: the destination bank account must be in the name of the individual who holds the GLOBEN Account.

b) Business Account of a legal entity: the destination bank account must be in the name of the account-holding entity. Withdrawal accounts registered before these Terms take effect that do not comply with this rule are subject to the regularization regime of Section 6.5, with a period of not less than thirty (30) calendar days.

c) Business Account of an individual (including a sole proprietor): the rule in subsection (a) applies, or the account in the duly evidenced registered trade name (DBA) of the same Account Holder.

Express exclusion. This rule does not apply to the Funds Disbursement or Payouts module described in Section 4.1(g), whose purpose is precisely to make payments to beneficiaries other than the Account Holder. That module is governed by its Specific Terms, which set out the due diligence on beneficiaries, limits, supporting documentation and the applicable AML/CFT and sanctions controls. Using the ordinary Cash-Out to replicate the purpose of the Payouts module constitutes a breach of these Terms.

6.2 Limited Exceptions

Only the following exceptions will be admitted, subject to documentary review and the express approval of GLOBEN's Compliance and Legal departments:

a) Joint accounts in which the Account Holder is a verified co-owner with the financial institution.

b) Legal representation, conservatorship, guardianship or special power of attorney duly evidenced by a current power of attorney or appointment, with express authority to receive funds.

c) Orders of a competent judicial or administrative authority, or duly evidenced probate or succession proceedings.

d) Accounts of enabled minors, only if GLOBEN enables the option provided in Section 3.1, in which case the destination may be the account of the parent or legal guardian previously identified and authorized in the account file.

e) At GLOBEN's discretion, provided it is verified that applicable AML/CFT and sanctions laws are not breached and that the need for and justification of enabling payment to third-party accounts or funds disbursement is duly documented in the User's file.

No other circumstance permits withdrawal to third-party accounts. GLOBEN may revoke an exception at any time if the conditions on which it was based change.

6.3 Ownership Verification

GLOBEN will validate ownership by cross-checking the identification data registered and verified on the Platform (Tax Identifier or identity document number, and name or legal name) against the data of the destination account holder declared and evidenced by the User. For this purpose, GLOBEN may use third-party bank account verification services (including instant verification through providers authorized by the User), validation micro-deposits, or require a bank certificate, account statement or equivalent document issued by the financial institution.

6.4 Rationale, Consent and Evasive Conduct

The User acknowledges that this rule responds to obligations to prevent money laundering, terrorist financing and sanctions violations, to prevent fraud and identity theft, to ensure traceability of the source and destination of funds, and to reduce chargebacks and unrecognized charges.

The User expressly agrees that registering or attempting to register third-party accounts, changing the withdrawal account in order to circumvent ownership validation, submitting altered or inaccurate ownership documentation, or using the Platform to channel funds to persons other than the Account Holder outside the cases of Section 6.2, constitute a material breach of these Terms and entitle GLOBEN, immediately and without prior notice, to block the account, hold the funds in accordance with Section 7 and evaluate termination of the relationship.

6.5 Transitional Regime

The same-owner rule applies fully to any registration or change of withdrawal account made as of the effective date of these Terms.

With respect to third-party withdrawal accounts registered and active on that date, including those arising from accounts migrated from other Group platforms, GLOBEN will carry out a progressive regularization process, individually notifying affected Users of the requirement to replace the destination account, with a period of not less than thirty (30) calendar days. If the period expires without regularization, GLOBEN may block Cash-Out to that account, without affecting ownership of the credited balance, which will remain available for withdrawal to an account that complies with the rule.

The foregoing does not prevent GLOBEN from immediately applying the measures of Section 6.4 upon detecting indications of fraud, deliberate evasion of controls, or AML/CFT or sanctions risk.

6.6 Processing and Crediting Timeframes

a) Processing by GLOBEN: up to one (1) Business Day from valid receipt of the instruction, provided the applicable operational, security and compliance validations have been passed.

b) Bank crediting: does not depend on GLOBEN and is determined by the Regulated Partner, the receiving bank and interbank clearing systems (including the ACH network). Under normal conditions it is estimated at one (1) to three (3) Business Days after processing. When GLOBEN enables real-time or instant transfers, their availability will depend on the receiving bank's participation in the relevant network and may be subject to the fee indicated in the Fee Schedule.

c) Variability: certain withdrawals may require additional review or be subject to special banking processes, so the crediting period may be extended up to a maximum of ten (10) Business Days, without constituting a breach by GLOBEN.

d) Delay factors: controls of the Regulated Partner or receiving bank, high or unusual amounts, regulatory, sanctions or anti-fraud compliance reviews, non-business days and holidays, and technical contingencies of financial institutions or third parties.

e) Liability: GLOBEN's obligation is limited to correctly processing the request within the stated timeframe. GLOBEN does not guarantee specific bank crediting times and is not liable for delays attributable to third parties, without prejudice to the rights granted by law to Consumers (Annex A).

6.7 Cross-Border Transactions

When enabled and permitted by the applicable license, GLOBEN may arrange transfers abroad through Regulated Partners, authorized foreign exchange intermediaries or Group companies enabled in the destination country. This provision applies to withdrawals to foreign accounts, transfers between Users in different jurisdictions (cross-border P2P) and the receipt and sending of remittances, in each case only to the extent and within the scope of the Contracting Entity's current authorizations and in accordance with the applicable Jurisdictional Annex. For Consumers in the United States of America, these transactions are subject, where applicable, to the Remittance Transfer Rule (Annex A).

The User bears the exchange rate risk, applicable taxes (including federal remittance transfer taxes, currency outflow taxes or financial transaction levies in the country of origin or destination) and bank and intermediary costs, which will be disclosed before execution when required by law. The estimated additional processing time is three (3) to seven (7) Business Days, and additional supporting documentation may be required.

7.1 General Right to Hold Funds

GLOBEN may temporarily hold funds, reserve balances, limit amounts, restrict features, block Cash-In or Cash-Out, or temporarily or permanently suspend the account in the following cases:

a) Notice of a Chargeback, Bank Alert or Unrecognized Charge, for the Amount at Risk, during the investigation.

b) Detection of suspicious patterns, risk signals, or high-risk transactions or transactions inconsistent with the declared profile, even if no chargeback, loss or formal claim has materialized, and for as long as the cause of the measure persists.

c) Failure to meet KYC, KYB, AML/CFT, sanctions or supporting documentation requirements.

d) Reversal of erroneous, duplicate or improperly processed transactions.

e) A request from a Competent Authority or a Regulated Partner, a court order, levy, garnishment, injunction or a match with restrictive or sanctions lists.

f) Negative balances, amounts owed, Card Network fines, or labor or third-party claims in accordance with Section 15.

g) Failure to comply with formal tax obligations, in accordance with Section 7.4.

h) Inactivity exceeding twelve (12) calendar months.

i) Registration, modification or use of third-party withdrawal accounts in breach of Section 6.

Traceability of funds. The measures in this Section may be applied not only to the originally disputed transaction but also to funds originating, directly or indirectly, from that transaction that can be traced within the GLOBEN ecosystem, regardless of whether they are held by a User other than the one who processed the disputed transaction, including the recipient of the funds, the Second-Tier Receiving Merchant and the accounts, cards and wallets linked to any of them by ownership, contact details, device, withdrawal bank account, address or any other reasonable linking element. Applying these measures does not imply attributing liability to the affected third party, but rather adopting precautionary measures while the origin and legitimacy of the funds are determined.

GLOBEN will notify the User of the hold, its cause, the affected amount, the estimated timeframe and the actions required for its regularization, except when the law prohibits such notice (for example, in connection with a suspicious activity report) or when a Competent Authority so orders.

7.2 Duration of Measures and Reasoned Decision

The hold will be limited to the Amount at Risk. GLOBEN will not hold amounts in excess of that amount, except by order of a Competent Authority or at the request of a Regulated Partner in accordance with the Network Rules.

GLOBEN's internal investigation will conclude with a reasoned decision within a maximum of thirty (30) Business Days from the adoption of the measure, extendable once for an equal period by a reasoned decision notified to the User.

This period applies to GLOBEN's internal decision and is independent of the chargeback, representment, pre-arbitration and arbitration cycles established by the Card Networks, issuing banks, acquirers and payment processors, which are governed by their own rules and timeframes, and of any timeframes imposed by a Competent Authority. When the final resolution depends on a third party, the measure may remain in place until the corresponding cycle concludes, and the User will be informed of the status of the case upon request.

Held funds do not earn interest, returns or any compensation in favor of the User during the holding period.

7.3 Rolling Reserve and Collateral

For Users with a high chargeback history, high-risk activity, no operating history or a sudden increase in volume, GLOBEN may establish a Rolling Reserve by withholding a percentage of each Transaction (typically between 5% and 10%) for a period of thirty (30) to one hundred eighty (180) calendar days, released gradually if no chargebacks materialize. The collateral conditions applicable to high-risk segments are set forth in Section 9.4.

GLOBEN will notify the User of the withholding percentage, the Rolling Reserve period, the reason justifying it and the conditions for its release, before applying it or, when the nature of the risk requires immediate application, at the time of doing so. GLOBEN may review the Rolling Reserve based on the account's performance and reduce or release it early when the causes that gave rise to it no longer exist.

7.4 Restrictions for Merchant Tax Non-Compliance (Business Accounts)

7.4.1 Ongoing requirement. Throughout the contractual relationship, the Merchant User must keep its tax registration or Tax Identifier active and in good standing under the laws of its jurisdiction, namely: (i) active tax registration, not suspended, cancelled or deregistered; (ii) not be classified by the tax authority as a non-existent or shell taxpayer or one with non-existent or simulated transactions, nor appear on equivalent tax risk lists; (iii) keep its registered economic activity consistent with the one declared on the Platform; and (iv) not be in a state of non-filing or non-compliance published by the tax authority in its official registries. In the United States of America, this requirement includes a match between the name and Tax Identifier and the records of the Internal Revenue Service (IRS), in accordance with Annex A.

7.4.2 Verification. GLOBEN may verify the Merchant's tax status periodically and automatically by consulting official sources, public registries, Tax Identifier matching programs and authorized validation services. The Merchant expressly and irrevocably authorizes such verification.

7.4.3 Graduated measures. Upon verifying an inconsistency, GLOBEN will apply the following measures in a staged and proportionate manner:

Stages, measures and notice

Stage	Situation	Measure	Notice
1	Inconsistency detected	Notice and request for regularization	Immediate
2	Not regularized by the deadline	Limit on the maximum Cash-In amount, at the limit GLOBEN indicates in the request according to its risk matrix	Fifteen (15) calendar days
3	Continued non-compliance	Blocking of Cash-In and holding of pending credits	Simultaneous notice
4	Registration cancelled, taxpayer classified as non-existent or shell, or order of an authority	Immediate blocking of Cash-In and Cash-Out, and evaluation of termination	No prior notice

7.4.4 Notice. Except in Stage 4 cases and those involving an order of a Competent Authority, risk of fraud or a regulatory requirement of immediate application, GLOBEN will give at least fifteen (15) calendar days' notice before applying Cash-In restrictions for tax reasons.

7.4.5 Regularization. To restore operations, the Merchant must: (i) cure its situation with the tax authority; (ii) send GLOBEN the certificate, record, form or public query evidencing the good standing of its registration; and (iii) update its account information. GLOBEN will verify the regularization and restore the services within three (3) Business Days after validation, releasing held funds not affected by other causes.

7.4.6 Effect on funds. The Cash-In restriction does not affect ownership of the previously credited balance, which will remain available unless another ground for holding under Section 7.1 applies or the law requires tax withholding.

7.4.7 Multi-jurisdictional application. This Section applies to the Tax Identifier corresponding to each jurisdiction (SSN, ITIN, EIN, RUC, NIT, NRC or other), in accordance with the applicable Jurisdictional Annex, and without prejudice to the reporting, information return and withholding obligations imposed by law on GLOBEN.

8.1 General Obligations

The User undertakes to: use the Platform exclusively for lawful purposes and within the declared and authorized line of business; comply with the federal, state and local laws applicable in its jurisdiction; provide true and current information; keep its contact information current in accordance with Section 3.3; protect its credentials; cooperate in fraud and compliance investigations; and retain supporting documentation for its transactions for at least five (5) years from the date of each transaction, or for any longer period required by law. Such documentation must make it possible to evidence the actual existence of the transaction, including, where applicable, inventory traceability and actual delivery of the goods or provision of the service.

Merchants must also: deliver the goods or services offered, maintain clear and published return, refund and warranty policies, address their customers' complaints in a timely manner, comply with the Network Rules applicable to them and comply with consumer protection laws.

8.2 Absolute Prohibitions

It is strictly prohibited to use the Platform for: money laundering, terrorist financing or proliferation financing; transactions with persons, entities or jurisdictions subject to sanctions of OFAC, the United Nations, the European Union, the United Kingdom or the User's jurisdiction; tax evasion or circumvention of foreign exchange controls; fraud, scams or any criminal activity; unlawful internet gambling in violation of the Unlawful Internet Gambling Enforcement Act (UIGEA) or applicable state or local law; the sale of illegal, counterfeit or pirated goods or services; infringement of intellectual property rights; identity theft or phishing; unauthorized sale, transfer or disclosure of customer data; storage of cardholder data without PCI DSS compliance; reverse engineering, scraping, crawling, use of unauthorized bots, cyberattacks or any interference with the Platform or other Users.

The following are also absolute prohibitions, and their verification entitles GLOBEN to immediately adopt the measures of Section 8.6:

a) Simulated transactions: processing transactions that do not correspond to an actual sale of goods or actual provision of services.

b) Self-dealing: processing transactions made with payment instruments owned by the Merchant itself, its managers, partners, employees or relatives, without real commercial substance.

c) Splitting: artificially dividing a transaction into several smaller ones to evade transaction limits, monitoring controls, authorization or reporting thresholds, or documentation requirements (including structuring prohibited by United States federal law).

d) Undeclared third-party transactions (factoring or transaction laundering): processing transactions on behalf of third parties not declared to GLOBEN, or assigning, leasing or sharing the point of sale, integration credentials or merchant codes.

e) Fraudulent chargebacks and intentional friendly fraud, including the Merchant's participation, collaboration or complicity in self-purchase schemes, use of stolen cards or simulated sales.

f) Card testing and any mass testing of credentials.

g) Irregular documentation: submitting documentation that is altered, prepared after the events it purports to support, or that does not correspond to the disputed transactions.

8.3 Restricted Activities

Unless expressly authorized in advance and in writing by GLOBEN and, where applicable, by the Regulated Partner, and subject to additional requirements, differentiated fees, limits and collateral, the following activities are restricted: firearms, ammunition, parts and explosives; controlled substances and narcotics, including cannabis and derivatives that are illegal under United States federal law even where permitted by state law; pornographic or sexually exploitative material and escort services; unregulated or unlicensed gambling, casinos and betting; illegal pyramid, Ponzi or multi-level schemes; unauthorized crypto-assets, exchanges and virtual asset services; money transmission, currency exchange, lending or other financial services without the required federal, state or local licenses; sale of organs or bodily fluids; unauthorized medical, pharmaceutical or telemedicine services; tobacco and vaping products without compliance with applicable age verification requirements; and unauthorized resale of tickets (scalping).

8.4 High-Risk Segments Subject to Special Conditions

The following are subject to enhanced requirements, including current licenses, periodic regulatory compliance verification, stricter transaction limits, intensive monitoring, differentiated fees and performance collateral: sports predictions and other games or betting, only in the states or countries where applicable law permits them and with a current license; payment aggregators and sub-merchant models; travel and tourism; supplements and health products; prepaid education; ticketing and events; and subscriptions and recurring billing.

Users that operate as aggregators with respect to sub-merchants are jointly and severally liable for their transactions, fraud, chargebacks and breaches, must perform full due diligence on each sub-merchant, monitor them continuously and report their transactions monthly, and may only operate as such with the prior authorization of GLOBEN and the Regulated Partner in accordance with the Network Rules.

8.5 Fraud Prevention Policy

The User undertakes to know and comply with GLOBEN's Fraud Prevention Policy, published on the Website, which forms an integral part of these Terms and includes anti-fraud controls, warning signs, the User's reporting obligations and the good practices required of Merchants.

8.6 Consequences of Breach

A breach entitles GLOBEN, without prejudice to other rights, to: suspend or terminate the account; block pending transactions; hold funds as security; reverse suspicious transactions; report to Competent Authorities; include the User on internal restrictive lists and share the information with the industry as permitted by law; bring civil and criminal actions; and claim damages, fines, investigation costs and legal fees.

Proven fraud. Once the User's participation or complicity in simulated transactions, self-dealing, friendly fraud, use of stolen payment instruments or any other fraudulent scheme is established, GLOBEN may also: (i) definitively apply the held funds to cover chargebacks, reversals, fines, penalties, investigation costs and operating losses actually incurred; (ii) demand reimbursement of the unpaid balance and set it off against any present or future balance; (iii) terminate the relationship immediately and permanently; (iv) report the User to the high-risk merchant registries and lists administered by the Card Networks, acquirers or payment processors (including MATCH and VMSS), in accordance with their rules; and (v) bring the corresponding criminal and civil actions.

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9.1 Structure

The applicable fees and charges are set forth in the current Fee Schedule, published on the Website and accessible from the User's dashboard, which forms an integral part of these Terms. Before activating its account, the User will receive clear information on the specific fees applicable to its profile and may consult them at any time on its dashboard.

9.2 Types of Charges

a) Cash-In fee: a percentage of the transaction amount, plus a fixed fee when applicable, automatically deducted before crediting. Formula: Credited balance = Transaction amount, less fee, less applicable taxes.

b) Cash-Out: GLOBEN does not charge a fee for ordinary withdrawals, without prejudice to costs applied by the receiving bank, which are borne by the User, and to the provisions of the Fee Schedule for specific products or channels (for example, instant withdrawals).

c) Chargeback, bank alert or unrecognized charge handling fee: applicable to each case handled, regardless of the outcome, and non-refundable.

d) Periodic service plans and fees: when GLOBEN offers account subscription plans or service packages with periodic charges, their terms, amount, frequency and benefits will be set forth in the Fee Schedule, and their contracting will be completed through the in-flow acceptance provided in Section 1.5.

e) Other: account reactivation after suspension for breach, premium services, additional certifications or validations, ACH returns attributable to the User and Card Network arbitration costs.

Unless the Fee Schedule establishes a periodic fee plan, no fees are charged for account opening, monthly maintenance, balance inquiries, reporting, standard technical support or software updates. GLOBEN does not charge inactivity fees, unless permitted by applicable law and disclosed in advance.

9.3 Fee Changes

GLOBEN will give thirty (30) calendar days' notice of any change. If the User does not accept, it may terminate the relationship without penalty by giving notice within the following fifteen (15) calendar days, withdrawing its funds within the regular timeframes. Continued use constitutes acceptance.

To the extent permitted by law, increases imposed by Card Networks, Regulated Partners, regulators or changes in tax rates, changes arising from laws of immediate application and adjustments to high-risk segments due to a proven increase in fraud may be applied without a notice period, and will be notified as soon as reasonably practicable.

9.4 Collateral for High-Risk Segments

a) Sports predictions and other games or betting, only in jurisdictions where applicable law permits them: a current license or authorization granted by the competent authority, monthly compliance verification, an insolvency insurance policy, annual financial audits and a performance guarantee equal to 10% of the average monthly volume of the last three (3) months, with a minimum of USD 5,000, held in a segregated account, adjustable quarterly and refundable upon termination of the relationship, net of pending chargebacks.

b) Payment aggregators: a guarantee equal to 5% of the aggregate average monthly volume, with a minimum of USD 10,000, in addition to the additional fee per active sub-merchant.

9.5 Tax Transparency

GLOBEN is not a withholding agent for the User's taxes except where expressly required by law, in which case it will make the corresponding withholdings and deliver the respective receipts. GLOBEN does not issue invoices for the User's sales. The User is solely responsible for reporting and paying its taxes (including state and local sales and use taxes) and for issuing the sales receipts required by law. GLOBEN will issue receipts for its own fees, file the information returns required by law (for example, Form 1099-K with the IRS) and make certificates and reports available for tax purposes.

9.6 Reconciliation

Any discrepancy in fees must be reported within thirty (30) calendar days after the transaction. Once the error is verified, GLOBEN will credit or debit the difference and explain the adjustment. The foregoing is without prejudice to the error-reporting periods granted by law to Consumers (Annex A).

The Digital Wallet reflects available balances, transaction history, funds pending settlement and held balances. Its characteristics are:

a) It is not a bank account or demand deposit, except as provided in the applicable Jurisdictional Annex.

b) It does not earn interest or returns in favor of the User.

c) Users' funds are held segregated from the Contracting Entity's own assets, in custodial or dedicated accounts (including accounts opened with Regulated Partners in the name of the Contracting Entity for the benefit of its Users, known as FBO accounts), in accordance with the regulations of each jurisdiction.

d) Credited funds are available for withdrawal according to the applicable schedule and validations.

e) Unless the Jurisdictional Annex expressly provides otherwise, balances are not insured by the Federal Deposit Insurance Corporation (FDIC) or any other deposit insurance scheme.

The User represents that all funds channeled have a lawful origin, that it complies with its tax obligations with respect to them and that it has documentation supporting their origin. If an unlawful origin is determined, GLOBEN will hold the funds, report to the Competent Authority, permanently terminate the account and cooperate with investigations, without any liability for funds seized, levied or frozen by an authority.

11.1 GLOBEN's Role and Applicable Policy

GLOBEN acts as an intermediary in the chargeback process. GLOBEN does not decide the outcome, which rests with the issuing bank or the Card Network, does not guarantee a favorable outcome and assumes no liability for chargebacks arising from legitimate disputes or User errors. GLOBEN will notify the User, facilitate its defense, transmit the admissible evidence and manage the financial settlement of the case.

This Section is supplemented by the Policy for the Management of Chargebacks, Bank Alerts, Unrecognized Charges and Preventive Holds, published on the Website (forthcoming), which forms an integral part of these Terms and explains to the User how cases are notified and handled, the required documentation, the reference timeframes for handling and resolution, the response and reconsideration process and the measures applicable to traceable funds. Each case is governed by the version of that Policy in effect on the date of the transaction giving rise to it.

This Section governs the Merchant User's position with respect to its customers' disputes and does not limit the rights granted by law to Consumers regarding errors and unauthorized transfers in their own GLOBEN Account (Annex A, Section A.6).

11.2 Notice and Response Deadlines

Upon receiving notice of a Chargeback, Bank Alert or Unrecognized Charge, GLOBEN will inform the User by email, push notification and dashboard alert, indicating the date of the original transaction, the disputed amount, the reason code when available, the response deadline and the required documentation, and will automatically reserve funds for the Amount at Risk.

The User must submit its evidence within the deadline stated in the notice, which as a general rule will be two (2) Business Days from its sending. That deadline may be shorter when the issuing bank, acquirer, payment processor or Card Network imposes a shorter representment window, in which case the latter will govern, and may be longer when the applicable window allows it and the notice expressly so indicates.

Failure to respond within the deadline constitutes automatic acceptance of the case, debit of the disputed amount, charge of the handling fee and loss of the right to dispute it later.

11.3 Evidence

Evidence must be clear, legible, relevant, authentic, complete and sufficient, submitted in English or Spanish (with translation when required by the Card Network) and include, depending on the type of dispute: proof of delivery with confirmation and signature, matching delivery address, communications with the customer, access or download logs for digital products, usage or attendance records for services, express authorization of the amount, terms accepted by the customer, the tax receipt for the transaction and refund receipts where applicable.

The technical data of the transaction held by GLOBEN (3-D Secure authentication, AVS result, CVV2 validation, transaction IP address, device identifier and electronic receipt) will be incorporated by GLOBEN into the defense file without the need to request it from the User.

Evaluation of evidence. GLOBEN will evaluate the evidence submitted before transmitting it and may reject, return for correction or decline to forward responses that are untimely, incomplete, illegible, manifestly irrelevant or unrelated to the disputed transaction, informing the User of the reason. Rejection on these grounds does not interrupt or suspend the Card Network deadlines and creates no liability for GLOBEN.

11.4 Holding of Funds and Traceability

Holds associated with these cases are subject to Sections 7.1 and 7.2, are limited to the Amount at Risk and may extend to traceable funds held by linked third parties under the terms set forth therein.

11.5 Thresholds, Fines and Costs

If the User's chargeback, fraud or dispute ratio exceeds the thresholds of the Card Network monitoring programs in effect from time to time, or the internal thresholds that GLOBEN or the Regulated Partner establish and communicate to the User, GLOBEN may require a remediation plan, increase collateral, adjust fees or suspend the account. Fines, penalties and review fees imposed by the Card Networks or Regulated Partners will be passed through in full to the responsible User.

Card Network arbitration requires the User's express prior authorization, and the User bears its cost if it loses. Absent such authorization, GLOBEN will accept the issuer's decision.

11.6 User Liability

The Merchant User is solely and fully liable for all chargebacks arising from its transactions, for the associated economic losses and handling fees, for Card Network fines and for any reputational damage caused. It undertakes to maintain a sufficient balance to cover potential chargebacks and to reimburse GLOBEN for any amount debited in excess of the available balance, hereby authorizing set-off against present or future balances and debits to the registered bank account under the ACH authorization in Annex A.

11.7 Responses, Reasoned Decision and Reconsideration

Once a restriction, suspension or hold is adopted, GLOBEN will notify the User, through the registered contact channels, of: (i) the measure adopted and its scope; (ii) the amount held, where applicable; (iii) the provision of these Terms or of the Policy on which it is based; (iv) the required documentation and the deadline for submitting it; and (v) the channel available for submitting responses.

GLOBEN will analyze the responses and communicate a reasoned decision. GLOBEN will not be required to disclose information subject to legal confidentiality, the disclosure of which would compromise the effectiveness of an ongoing investigation or would contravene the Network Rules, the instructions of Regulated Partners or of a Competent Authority, or the legal prohibition on disclosing the existence of a suspicious activity report.

The User may request reconsideration of the decision once, within ten (10) Business Days after notice, providing information or documentation not previously submitted.

The Contracting Entity maintains a comprehensive AML/CFT/CPF and sanctions compliance program, with a designated compliance officer, policies approved by its governing bodies, ongoing training, independent testing and audits, automated transaction monitoring and reporting of unusual or suspicious transactions to the corresponding Competent Authority. In the United States of America, that program conforms to the Bank Secrecy Act, the USA PATRIOT Act, the Anti-Money Laundering Act of 2020 and their implementing regulations, including the filing of Suspicious Activity Reports with FinCEN; in other jurisdictions, it conforms to the local laws indicated in the Jurisdictional Annex. Details are set forth in the AML/CFT/CPF and Sanctions Policy, published on the Website (forthcoming).

GLOBEN automatically and periodically screens against sanctions and restrictive lists, including those of OFAC (the Specially Designated Nationals and Blocked Persons List and sectoral lists), the consolidated lists of the United Nations, the European Union, the United Kingdom, INTERPOL and applicable national lists, as well as politically exposed persons databases.

The User acknowledges and agrees that: (i) GLOBEN may request additional information at any time and suspend the account if it is not provided on time; (ii) GLOBEN may reject or terminate the relationship without giving a detailed reason when it detects suspicious activity; (iii) suspicious activity reports are confidential and mandatory and will not be disclosed to the User, and such non-disclosure may not be construed as a lack of reasons for the measures adopted; (iv) GLOBEN assumes no liability for reporting in good faith, in accordance with the safe harbor protections provided by law; and (v) funds may remain blocked or frozen while under investigation by a Competent Authority or when sanctions laws require them to be blocked.

Matches with restrictive or sanctions lists will result in immediate blocking of the account, holding or blocking of funds, mandatory reporting and, once the match is confirmed, permanent termination of the relationship.

13.1 Applicable Framework

GLOBEN processes personal data in accordance with applicable privacy and data protection laws. In the United States of America, this includes, as applicable, the Gramm-Leach-Bliley Act and its Regulation P, Section 5 of the Federal Trade Commission Act, the FTC Safeguards Rule, the Fair Credit Reporting Act, the Children's Online Privacy Protection Act and state privacy, biometric data and breach notification laws (including the California Consumer Privacy Act, as amended by the California Privacy Rights Act). In other jurisdictions, the laws indicated in each Jurisdictional Annex apply. Details are set forth in the GLOBEN Privacy Policy, published on the Website, and GLOBEN applies as a minimum cross-cutting standard the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality and accountability.

13.2 Data Processed

Identification data (name, identity document, Tax Identifier, date of birth, nationality, image and biometric data for identity verification), contact data, financial and transaction data, tokenized payment method information (never full card data), browsing and device data (IP, geolocation, cookies) and the Merchant's business data.

13.3 Purposes and Bases for Processing

a) Performance of the contract: provision of the service, transaction processing, Digital Wallet management, support and collections.

b) Compliance with legal obligations: KYC, AML/CFT, sanctions, tax obligations, regulatory reporting and responding to requests from authorities.

c) Legitimate interest and operational purposes: fraud prevention and detection, management of chargebacks and preventive holds, information security, service improvement and development, and aggregated or de-identified analytics.

d) Consent: marketing communications, processing of biometric data where the law requires prior consent, and secondary purposes, revocable at any time without affecting the core service.

Transactional and security notifications are inherent to the service and cannot be disabled while the account is active.

13.4 Disclosures and Processors

GLOBEN may disclose data to Regulated Partners, payment processors, acquiring and receiving banks, Card Networks, identity verification providers, anti-fraud services, cloud infrastructure providers, external auditors, insurers, legal advisors bound by confidentiality, Competent Authorities and Group companies (including ECUAPAYPHONE C.A. and the other subsidiaries of Payphone Global Inc.) for administrative and operational purposes. All third parties are contractually bound to protect the data, use it solely for authorized purposes and submit to audits.

Data may be processed in the United States of America and in the countries where the Group companies and their providers operate. International transfers are carried out through appropriate safeguards (standard contractual clauses, adequacy decisions, informed consent or the mechanism required by applicable law), with additional security measures.

13.5 Retention

Transaction data and KYC files: ten (10) years from termination of the relationship, a period that covers the five (5)-year minimum required by the Bank Secrecy Act, or any longer period required by applicable regulations. Support communications and records: five (5) years. Records of contractual acceptance and recurring billing consent: for the entire term and ten (10) additional years. Biometric data: destroyed once the verification purpose for which it was collected has been satisfied and, in any event, no later than three (3) years after the User's last interaction with GLOBEN, in accordance with the Privacy Policy. Other data is deleted within ninety (90) calendar days after termination, unless there is a legal obligation to retain it.

13.6 Data Subject Rights

To the extent granted by applicable law, the User may exercise its rights to access or know, rectify or correct, update, delete or erase, object, data portability, restriction of processing, withdrawal of consent, opt out of the sale or sharing of data for advertising, limit the use of sensitive data and not be subject to automated decisions with significant effects, by writing to [email protected] or using the form available on the Website. GLOBEN will acknowledge receipt within ten (10) Business Days and respond within forty-five (45) calendar days of receipt, extendable for an equal period when reasonably necessary, or within any shorter period set by applicable law. Exercising these rights is free of charge and GLOBEN will not discriminate against the User for exercising them.

These rights may be limited when processing is necessary to comply with legal obligations, to establish or defend legal claims, to prevent fraud, for reasons of public interest, when the information is subject to the Gramm-Leach-Bliley Act or another legal exemption, or when it would affect the rights of third parties.

13.7 Automated Decisions

GLOBEN uses automated scoring and fraud and compliance risk detection systems. The User has the right to request human review, express its point of view and challenge the decision, except when disclosing the logic of the system would compromise the effectiveness of fraud prevention, AML/CFT or sanctions controls, or when the law prohibits such disclosure.

13.8 Security Breaches

GLOBEN will notify affected Users and the competent authorities within the timeframes and under the conditions set by applicable breach notification laws (including United States state laws and, where applicable, notification to the Federal Trade Commission under the FTC Safeguards Rule) and, in any event, without undue delay when the breach poses a material risk to their rights, reporting the nature of the incident, the data affected, the likely consequences, the measures adopted and protective recommendations.

14.1 Ownership

All elements of the Platform (software, source and object code, APIs, algorithms, databases, design, interfaces, content, trademarks, including the GLOBEN mark, trade names, logos, patents and trade secrets) are the exclusive property of Payphone Global Inc., the Group companies or their licensors.

14.2 License to Use

GLOBEN grants the User a limited, non-exclusive, revocable, non-transferable and non-sublicensable license to access and use the Platform in accordance with these Terms, download the App, use the API in accordance with the technical documentation and integrate the payment button in compliance with the brand guidelines.

The User may not copy, modify, adapt, translate, create derivative works of, reverse engineer, decompile, sublicense, resell, lease or distribute the Platform, remove proprietary notices, use the GLOBEN marks without written authorization, perform scraping or mass data extraction, use unauthorized bots, access the Platform to develop a competing product, or replicate, frame or duplicate any part of the Platform.

App stores (including the Apple App Store and Google Play) are not parties to these Terms and are not responsible for the App, and the User also agrees to comply with the terms of use of the store from which it downloads the App.

14.3 User Content

The User retains ownership of its content, trademarks and customer data, and grants GLOBEN a worldwide, royalty-free, non-exclusive and sublicensable license, limited to what is necessary to store, process and transmit such content in order to provide the service, make backups and analyze aggregated and de-identified data. This license does not entitle GLOBEN to commercialize the User's content or claim ownership of it.

Ideas, suggestions or recommendations that the User provides about the Platform may be freely used by GLOBEN without any obligation of compensation and do not constitute confidential information.

14.4 Prior Approval of Publications and Communications

Any publication, launch, update or public communication by the User that uses the trademarks, logos, trade name or visual identity of GLOBEN, describes the integration with the Platform, announces the availability of payments through GLOBEN, or attributes to GLOBEN features, coverage, licenses, insurance (including FDIC insurance), warranties, timeframes or results, requires GLOBEN's prior, express and written approval, requested from [email protected] and [email protected].

This obligation includes, by way of example: listings and publications in app stores (App Store, Google Play and equivalents); new versions or updates of mobile or web applications that integrate the Platform; websites, landing pages and advertising campaigns; press releases, announcements and social media posts; and marketing materials directed at end customers.

GLOBEN will respond to the request within five (5) Business Days. Silence does not constitute approval. GLOBEN may require the immediate correction or withdrawal of any publication made without approval, that is misleading as to the nature of the service, that attributes to GLOBEN obligations or coverage it does not assume, or that violates the brand guidelines, advertising laws or consumer protection laws. Breach of this clause permits suspension of the account and makes the User liable for the resulting damages, penalties and claims.

This Section is without prejudice to the Merchant User's right to display the GLOBEN logo in accordance with Section 19.

15.1 Services Provided "As Is"

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE PLATFORM IS PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT EXPRESS OR IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, UNINTERRUPTED AVAILABILITY, ERROR-FREE OPERATION OR COMPATIBILITY WITH ALL DEVICES AND SYSTEMS.

15.2 Exclusions

GLOBEN is not liable for: the quality, legality, delivery, suitability or conformity of the goods and services sold by Users; breaches between the Merchant and its customers; rejections, blocks or delays by issuing or receiving banks; failures of connectivity, cloud, Card Network, Regulated Partner or infrastructure providers; errors, omissions or negligence of the User; the sharing of credentials with third parties; phishing or social engineering attacks directed at the User; and force majeure or acts of God.

15.3 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, GLOBEN WILL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE OR EXEMPLARY DAMAGES, INCLUDING LOST PROFITS, LOSS OF REVENUE OR SALES, LOSS OF DATA, LOSS OF BUSINESS OPPORTUNITIES, BUSINESS INTERRUPTION OR REPUTATIONAL HARM, EVEN IF ADVISED OF THEIR POSSIBILITY.

THE TOTAL AGGREGATE LIABILITY OF GLOBEN, THE GROUP COMPANIES AND THE REGULATED PARTNERS TO THE USER, FOR ANY CAUSE AND UNDER ANY LEGAL THEORY, WILL NOT EXCEED THE GREATER OF: (I) THE TOTAL FEES ACTUALLY PAID BY THE USER TO GLOBEN DURING THE THREE (3) CALENDAR MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM; OR (II) USD 100.00.

15.4 Exceptions to the Limitation

The foregoing limitations do not apply in cases of proven willful misconduct or gross negligence of GLOBEN, death or personal injury caused by its negligence, proven fraud, or with respect to rights that cannot be limited or excluded by law, including Consumers' rights under the Electronic Fund Transfer Act and its Regulation E. In jurisdictions or states where the law prohibits these limitations in whole or in part, they will apply to the maximum extent permitted.

15.5 Indemnification

The User will defend, indemnify and hold harmless GLOBEN, Payphone Global Inc., the other Group companies, the Regulated Partners and their respective directors, officers, employees, agents, contractors and suppliers from and against any claim, demand, action, loss, liability, cost or expense (including reasonable attorneys' fees and litigation costs) arising from: breach of these Terms; violation of laws or third-party rights; its content, products or services; its transactions with its customers; its fraud, negligence or willful misconduct; excessive chargebacks resulting from its improper practices; Card Network fines attributable to its conduct; publications or communications made in breach of Section 14.4; and unauthorized use of the Platform. This obligation does not apply to Consumers to the extent prohibited by applicable law.

Upon receipt of an indemnifiable claim, GLOBEN will give the User reasonable notice, and the User may assume the defense at its own cost. GLOBEN may participate with its own counsel and assume sole control of the defense if the User fails to do so in a timely manner. The User may not settle a claim that imposes obligations on GLOBEN without GLOBEN's written consent. This obligation survives termination.

15.6 Independent Parties

GLOBEN and the User are independent parties. There is no employment, subordination, partnership, joint venture, agency, mandate or franchise relationship. Personnel assigned by the User are under the User's exclusive employment, and the User assumes all corresponding labor, social security, payroll and occupational health and safety obligations.

If a labor, administrative or judicial claim is brought seeking to establish an employment relationship between the User's personnel and GLOBEN or any Group company, the User will assume the entire defense at its own cost, reimburse the expenses incurred by GLOBEN and pay any judgment, award, fine or penalty imposed by judgment, settlement, conciliation or any other mechanism. GLOBEN may hold funds in the Digital Wallet to secure performance of this obligation, suspend the account until the claim is resolved and terminate the agreement. This obligation survives termination.

15.7 Force Majeure

Neither party will be liable for failures or delays arising from natural disasters, pandemics, wars, armed conflicts, terrorism, civil unrest, acts of government, third-party strikes, widespread infrastructure failures, massive cyberattacks, embargoes or economic sanctions, or any other unforeseeable, unavoidable and insurmountable event beyond its control. During the event, deadlines are suspended for its duration plus a reasonable recovery period, and no penalties or default interest accrue.

GLOBEN, on its own initiative or at the request of a Regulated Partner or Card Network, may audit the Merchant User to verify compliance with these Terms, applicable law, the Network Rules and PCI DSS standards, through documentary, on-site or technical audits.

Ordinary audits will be performed based on GLOBEN's risk assessment of the User or when the case requires, without a fixed frequency, and will be notified at least forty-eight (48) hours in advance. Extraordinary audits may be performed without prior notice in the event of suspected fraud or breach, sudden and unexplained increases in chargebacks, indications of security breaches or a request from an authority.

The User must provide access to facilities, systems and information, designate a responsible contact, deliver the requested documentation, allow interviews and refrain from obstructing the audit. The costs of ordinary audits are borne by GLOBEN; those of extraordinary audits prompted by a User breach are borne by the User.

Minor findings give rise to remediation plans of fifteen (15) to thirty (30) calendar days; significant findings, to suspension of features until cured and possible adjustment of fees or collateral; and critical findings, to immediate suspension, holding of funds, reporting to authorities, termination and legal action.

17.1 Term

These Terms take effect upon the User's electronic acceptance and remain in effect indefinitely until terminated in accordance with this Section.

17.2 Termination by the User

The User may terminate at any time, without cause, by requesting it on the Platform or writing to [email protected]. The User must withdraw its available funds within ten (10) Business Days thereafter and settle all outstanding obligations. Termination is not available while chargebacks, bank alerts, unrecognized charges or preventive holds are under investigation (unless the amount is secured), or while there are negative balances or amounts owed.

17.3 Suspension and Termination by GLOBEN

GLOBEN may immediately suspend, in whole or in part, and terminate the relationship without liability in the following cases: breach of these Terms or the supplementary policies; operating in prohibited or restricted activities without authorization; providing false or fraudulent information; indications of money laundering, terrorist financing or sanctions violations; inclusion on restrictive or sanctions lists; a chargeback ratio above the critical level without corrective measures; refusal to cooperate with audits or information requests; breach of indemnification obligations; uncured tax non-compliance under Section 7.4; a request from a Regulated Partner, Card Network or Competent Authority; and the existence of significant risk to GLOBEN, other Users or the integrity of the financial system.

For inactivity: if the account has no transactions for one hundred eighty (180) consecutive days, GLOBEN will give thirty (30) calendar days' notice and, absent a response, may close it, transferring the remaining funds to the Account Holder's registered bank account that complies with Section 6 or, failing that, keeping them available to the Account Holder in accordance with Section 17.4.

For regulatory changes or termination of the agreement with a Regulated Partner: with fifteen (15) calendar days' notice where possible, facilitating the transition and withdrawal of balances.

For business reasons: with thirty (30) calendar days' notice, facilitating migration and processing of balances.

17.4 Effects

Upon termination, access to the Platform and the processing of new transactions are suspended, with read-only access to the history maintained for thirty (30) calendar days. The User must withdraw its available funds within ten (10) Business Days after notice, pay any amounts owed, cease using the GLOBEN marks and destroy its confidential material. GLOBEN will process the Cash-Out of balances not held or disputed, deliver transaction certificates if requested within thirty (30) calendar days and retain the information in accordance with regulatory timeframes.

Funds associated with pending chargebacks, bank alerts, unrecognized charges or preventive holds will remain held until resolved. If the User does not claim its funds within one hundred eighty (180) calendar days after termination, GLOBEN will send a final notice to the registered contact details. Unclaimed funds will remain available to the User, who may request their withdrawal through the support channels, subject to validation of its identity and the destination account in accordance with Section 6, without prejudice to the unclaimed property laws applicable in the jurisdiction of the Contracting Entity or the User, under which the Contracting Entity may be required to remit such funds to the competent authority, from which the User may then claim them.

17.5 Survival

The following survive termination: the definitions, intellectual property and Section 14.4, the limitation of liability and indemnification, labor liability, the authorizations to obtain and report credit information, confidentiality, data retention and processing obligations, the document retention obligations of Section 8.1, outstanding payment obligations, the governing law and dispute resolution mechanism (including the arbitration agreement in Annex A), and any obligation that by its nature should survive.

The User expressly authorizes GLOBEN, for the duration of the contractual relationship and until the obligations arising from it are extinguished, to obtain credit and consumer reports and to consult and report information to consumer reporting agencies, credit bureaus, risk databases, commercial databases and trade references, to the extent permitted by the laws of the User's jurisdiction. For Business Accounts, the authorization extends to the owners, representatives and personal guarantors of the Merchant, who grant it in their own name upon accepting these Terms. In the United States of America, these inquiries are made for a permissible purpose under the Fair Credit Reporting Act.

The information will be used for initial risk assessment, ongoing monitoring, adjustment of limits, fees and conditions, any credit decisions and protecting the industry against high-risk users.

GLOBEN undertakes to report only accurate and verifiable information, to update it when the User regularizes its situation and to comply with applicable data protection and credit reporting laws. The User may dispute and request the correction of inaccurate information by providing the corresponding evidence.

The Merchant User authorizes GLOBEN to publicly identify it as a customer and to include its trade name, legal name, trademark and logo on the Website, marketing materials, sales presentations and customer lists, respecting its brand guidelines when available.

Success stories and testimonials require the User's prior and specific authorization; the User may review and approve the content before publication and withdraw its authorization at any time. GLOBEN will comply with the Federal Trade Commission guides on endorsements and testimonials.

The User may revoke the authorization to use its identity by notifying [email protected]. GLOBEN will remove the references within thirty (30) calendar days thereafter. Revocation does not affect uses already made or GLOBEN's right to refer, in strictly factual contexts, to the present or past existence of the commercial relationship.

The Merchant User may display the GLOBEN logo to indicate that it accepts payments through the Platform, subject to the brand usage guidelines and Section 14.4, without altering it or using it in a way that implies unauthorized endorsement or association, and must discontinue its use immediately upon GLOBEN's request.

GLOBEN will notify the User by email to the registered address, push notification, dashboard message or, in the case of general changes, notice on the Website. Notices are deemed delivered at the time of sending or publication, without prejudice to the consent to electronic communications set forth in Annex A.

The User is solely responsible for maintaining a valid, active and accessible email address and mobile phone number under its control, in accordance with Section 3.3, and for configuring its filters, allowed sender lists and notification permissions so that GLOBEN's communications can actually be received. Non-delivery, bounced email, disabled notifications or failure to read for reasons attributable to the User do not affect the validity or effectiveness of the notice delivered.

The User must send its formal notices (termination, disputes, claims, exercise of rights) to the email and physical address of the Contracting Entity indicated in the applicable Jurisdictional Annex, to the attention of the Legal Department. They will be deemed delivered upon confirmed receipt.

21.1 Severability

If any provision is held invalid, illegal or unenforceable, it will be modified or removed to the minimum extent necessary to make it valid and enforceable, the remaining provisions will remain in full force, and the parties agree to replace it with a valid provision that approximates the original economic purpose, except as provided in Section A.14 with respect to the class action waiver.

21.2 Entire Agreement

These Terms, together with the policies and annexes incorporated by reference, constitute the entire and exclusive agreement between the User and the Contracting Entity regarding their subject matter, and supersede any prior agreement, understanding, negotiation, proposal or version, written or oral.

21.3 Relationship with Other Agreements

If the User has entered into specific agreements with the Contracting Entity or another Group company, these Terms apply on a supplementary basis; in the event of a conflict, the specific agreement prevails solely to the extent of the conflict.

21.4 No Waiver

Failure to exercise or delay in exercising any right does not constitute a waiver. GLOBEN's rights are cumulative and not exclusive of those provided by law.

21.5 Assignment

The User may not assign, transfer, delegate or sublicense these Terms or any right or obligation arising from them. GLOBEN may assign them to any Group company, to a Regulated Partner, in connection with a merger, acquisition, sale of assets or corporate reorganization, or to any successor in the business, notifying the User when the assignment materially affects its rights.

21.6 Set-Off

GLOBEN may set off any amount owed by the User against present or future balances in its Digital Wallet, without prior demand, to the extent permitted by applicable law.

21.7 Language

These Terms are executed in English and Spanish. For Users subject to Annex A, the English version will prevail in the event of a conflict; for Users subject to Annexes B through F, the Spanish version will prevail.

21.8 Headings and Interpretation

Headings are for reference only and do not affect interpretation. "Including" means "including without limitation". References to days are to calendar days unless "Business Days" is indicated, as defined in Section 2. References to amounts in dollars are to United States dollars. The singular includes the plural and vice versa.

21.9 Binding Effect

These Terms bind the parties, their legal successors, permitted assigns and representatives.

21.10 Transitional Provisions

a) Third-party withdrawal accounts. The regime of Section 6.5 applies.

b) Active modules. Merchants that, on the effective date, have the Subscriptions and Recurring Billing module active under an addendum executed with any Group company are subject, from that date, to Annex G, which replaces that addendum to the extent of any inconsistency, without the need for a new signature.

c) Pending cases. Chargebacks, bank alerts, unrecognized charges and preventive holds initiated before the effective date will continue to be governed by the version in effect on the date of the transaction that gave rise to them.

d) Effectiveness of Annex G. Because it is an optional module that is only activated upon the Merchant's express acceptance, the Specific Terms of Annex G apply from their publication to Merchants that accept them in the activation flow, even before the general effective date of these Terms. For those Merchants, the provisions of Book One referred to in Annex G will apply from the same date, solely with respect to the module.

21.11 Contact

• General support: [email protected]
• Help Center: available on the Website and in the App
• Legal matters and formal notices: [email protected]
• Privacy and data protection: [email protected]
• Compliance: [email protected]
• Security (incident reporting): [email protected]
• Marketing and brand use: [email protected]
• Mailing address: Payphone Global Inc., 3561 FAU Blvd., Suite 400, Boca Raton, FL 33431, United States of America. Attn: Legal Department.

GLOBEN will issue an initial response to general inquiries within one (1) Business Day and to legal or compliance matters within three (3) Business Days. The initial response does not imply resolution of the case, the timeframe for which will depend on its nature and, where applicable, on the timeframes set forth in these Terms, applicable law and the supplementary policies. Security incident reports, such as unauthorized access, compromised credentials, vulnerabilities or brand impersonation, will be handled as a priority according to their criticality.

This Annex applies to Users domiciled, resident or organized in the United States of America and to transactions executed in that territory. In the event of a conflict between the English and Spanish versions of these Terms, the English version will prevail for such Users.

A.1 Contracting Entity. Payphone Global Inc., a corporation organized under the laws of the State of Wyoming, with its registered office at [registered agent address], Wyoming, and its principal office at 3561 FAU Blvd., Suite 400, Boca Raton, FL 33431, which operates the Platform under the GLOBEN brand.

A.2 Nature of the Service, Regulated Partners and Licenses.

GLOBEN IS A FINANCIAL TECHNOLOGY COMPANY AND IS NOT A BANK.

Payphone Global Inc. offers services only in the states and with respect to the activities for which it holds the applicable licenses, registrations or exemptions, or through duly authorized Regulated Partners. Banking, custody of funds, card issuing or money transmission services requiring a license are provided by the Regulated Partner identified on the Platform (for example, [Partner Bank Name], Member FDIC), subject to its own terms.

Payment facilitation. Card acceptance services for Merchants are provided in the capacity of a Payment Facilitator sponsored by an acquiring bank that is a member of the Card Networks (the "Acquiring Bank"). The Network Rules require the Merchant to be bound by certain terms of the Acquiring Bank, which are incorporated into these Terms and prevail to the extent mandatory. The Acquiring Bank may directly enforce against the Merchant the rights arising from those terms. When the Merchant's transaction volume exceeds the thresholds set forth in the Network Rules, the Merchant must enter into a direct agreement with the Acquiring Bank as a condition to continue processing.

Registration and licenses. Where applicable, Payphone Global Inc. registers as a Money Services Business with FinCEN and obtains the state money transmitter licenses required. Information on current state licenses and contact details for state regulators is published on the Website.

A.3 Custody of Funds and FDIC Insurance. Users' funds are held in custodial accounts opened with one or more Regulated Partners in the name of Payphone Global Inc. for the benefit of Users (FBO accounts), separate from Payphone Global Inc.'s operating funds. Unless expressly disclosed otherwise for a specific product offered through an insured partner bank, Digital Wallet balances are not deposits and are not insured by the FDIC. Where pass-through deposit insurance coverage is disclosed, it will apply only if the conditions of FDIC regulations are met and within the applicable limits, and it only protects against the failure of the insured bank; it does not protect against the insolvency, bankruptcy or default of Payphone Global Inc. or any other non-bank entity. GLOBEN does not pay interest on balances.

A.4 BSA/AML and Sanctions (OFAC) Compliance. Payphone Global Inc. maintains a compliance program in accordance with the Bank Secrecy Act, the USA PATRIOT Act, the Anti-Money Laundering Act of 2020 and their implementing regulations, including a Customer Identification Program, Customer Due Diligence, beneficial ownership identification, monitoring, the filing of Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) where applicable, and recordkeeping. GLOBEN will block, reject or report transactions in accordance with the sanctions programs administered by OFAC, without liability to the User.

A.5 Consumer Protection. For Users who are Consumers, the following apply to the extent enforceable: the Electronic Fund Transfer Act and its Regulation E (including, where applicable, the prepaid account and error resolution rules), the Remittance Transfer Rule (Regulation E, Subpart B) for international transfers, the Gramm-Leach-Bliley Act and its Regulation P on financial privacy, the Fair Credit Reporting Act with respect to credit inquiries and reporting, the prohibition of unfair, deceptive or abusive acts or practices (UDAAP) enforced by the Consumer Financial Protection Bureau (CFPB) and the Federal Trade Commission, and state consumer protection laws. In the event of a conflict, the provisions of this Annex and of those laws prevail over Book One with respect to Consumers.

A.6 Errors and Unauthorized Transfers (Consumers).

a) Contact. If you believe your credentials or device have been lost or stolen, or that a transfer has been or may be made from your GLOBEN Account without your permission, or if you think your statement or Digital Wallet history contains an error, contact us immediately through the App, at [email protected], by phone at [customer service phone number] or in writing at the address indicated in Section A.15.

b) Liability for unauthorized transfers. Telling us at once is the best way to keep your possible losses down. If you tell us within two (2) Business Days after you learn of the loss or theft of your credentials or device, you can lose no more than USD 50 for unauthorized transfers. If you do not tell us within that period, and we can prove we could have stopped the transfer if you had told us in time, you could lose as much as USD 500. Also, if your statement or history shows transfers that you did not make or authorize, tell us at once; if you do not tell us within sixty (60) days after the first statement or electronic record showing the error was sent or made available to you, you may not get back any money you lost after that period if we can prove that we could have stopped it if you had told us in time. If a good reason (such as a long trip or a hospital stay) kept you from telling us, we will extend these time periods.

c) Error resolution. When you contact us, tell us your name and account number, describe the error or the transfer you are unsure about and explain as clearly as you can why you believe it is an error, and tell us the dollar amount. If you tell us orally, we may require that you send us your complaint in writing within ten (10) Business Days. We will determine whether an error occurred within ten (10) Business Days after we hear from you (twenty (20) Business Days if the account has been open for less than thirty (30) days) and will correct any error promptly. If we need more time, we may take up to forty-five (45) days (ninety (90) days for new accounts, point-of-sale transactions or transfers initiated outside the United States of America) to investigate, in which case we will provisionally credit your Digital Wallet within the stated timeframes for the amount you think is in error, so that you will have use of the money while we complete our investigation. If we ask you to put your complaint in writing and we do not receive it within ten (10) Business Days, we may not provisionally credit your account. If we decide there was no error, we will send you a written explanation within three (3) Business Days after we finish our investigation, and you may ask for copies of the documents we used in our investigation. This Section will be interpreted in accordance with 12 C.F.R. §§ 1005.6 and 1005.11.

d) Precedence. This Section prevails over Sections 3.4, 6.6, 9.6 and 11 of Book One to the extent inconsistent with respect to Consumers.

A.7 Consent to Electronic Communications and Signatures (E-SIGN). In accordance with the E-SIGN Act, the User consents to receive electronically all notices, disclosures, agreements, statements, receipts and other communications relating to its GLOBEN Account, through the App, the Website or the registered email address. To access and retain them, the User needs a device with internet access, a currently supported browser or operating system, software capable of reading PDF files, a valid email address and the ability to store or print. The User may request, free of charge, a paper copy of any communication by writing to [email protected], and may withdraw its consent at any time by the same means, in which case GLOBEN may terminate the relationship because the Platform is provided exclusively in electronic form. Withdrawal of consent does not affect the validity of communications previously delivered. The User must keep its email address up to date in accordance with Section 3.3.

A.8 Calls and Text Messages (TCPA). By providing a phone number, the User expressly consents to receive calls and text messages, including those made using an automatic telephone dialing system or prerecorded messages, relating to its GLOBEN Account, identity verification, security, fraud prevention, transactions and the collection of amounts owed. Marketing calls or text messages will be sent only with the User's prior express written consent, which is not a condition of contracting. The User may opt out of text messages by replying "STOP" or contacting support. Message and data rates from the User's carrier may apply.

A.9 ACH Transfers and Nacha Rules. ACH transfers are additionally governed by the Nacha Operating Rules. The User authorizes GLOBEN and its Regulated Partners to initiate the ACH credits and debits to the registered bank account necessary to provide the service, including withdrawals instructed by the User, the reversal of erroneous credits and, for Merchant Users, the recovery of negative balances, chargebacks, fees and amounts owed. This authorization remains in effect until the User revokes it, giving a reasonable opportunity to act on the revocation, and all outstanding amounts have been paid. ACH returns for reasons attributable to the User may incur the fee set forth in the Fee Schedule.

A.10 Tax and Information Reporting Obligations. The Merchant User must provide a valid Form W-9 (or the applicable Form W-8), with a name and Tax Identifier matching IRS records. GLOBEN or the Regulated Partner will issue Form 1099-K or other forms required in accordance with the thresholds established by law from time to time. Failure to provide a valid Tax Identifier, or discrepancies notified by the IRS (B-Notice), will entitle GLOBEN to apply backup withholding under section 3406 of the Internal Revenue Code and to restrict Cash-In until regularization, under the terms of Section 7.4. The User is responsible for the state and local sales and use taxes applicable to its transactions.

A.11 Privacy. Payphone Global Inc. processes Users' personal information in accordance with the GLOBEN Privacy Policy, the Gramm-Leach-Bliley Act and, with respect to residents of California and other states with comprehensive privacy laws, the California Consumer Privacy Act (as amended by the California Privacy Rights Act) and analogous state laws, including the rights to know, access, correct, delete, port, limit the use of sensitive information and opt out of the sale or sharing of personal information for advertising. GLOBEN does not sell its Users' personal information for monetary consideration. Requests are handled at [email protected] and through the mechanisms described in the Privacy Policy.

A.12 Unclaimed Funds. If the GLOBEN Account remains inactive for the period established by the applicable state unclaimed property law, Payphone Global Inc. may be required to remit the balance to the competent state authority. Before doing so, GLOBEN will attempt to notify the User as required by that law. Once remitted, the User may claim the funds from the corresponding state authority.

A.13 Complaints and Regulatory Information. Complaints may be submitted to GLOBEN at [email protected] or [email protected]. Consumers may also submit complaints to the Consumer Financial Protection Bureau (www.consumerfinance.gov) and to the financial regulator of their state of residence, whose contact details are published on the Website together with the applicable state licensing information.

A.14 Governing Law, Informal Resolution, Arbitration and Class Action Waiver.

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR RIGHTS AND HOW DISPUTES BETWEEN YOU AND GLOBEN ARE RESOLVED.

a) Governing law. This Annex, these Terms and the relationship between the User and Payphone Global Inc. are governed by the laws of the State of Wyoming and applicable United States federal law, without giving effect to conflict of laws rules. The Federal Arbitration Act governs the interpretation and enforcement of this Section.

b) Prior informal resolution. Before initiating arbitration, the claiming party must send the other a written notice of dispute describing the nature and basis of the claim and the relief sought (the "Notice of Dispute"). A Notice of Dispute addressed to GLOBEN must be sent to [email protected] and to the address indicated in Section A.15. The parties will negotiate in good faith for sixty (60) days from its receipt. Statutes of limitations and filing deadlines are tolled during that period.

c) Binding arbitration. Any dispute, claim or controversy arising out of or relating to these Terms, the Platform or the relationship between the parties, including their existence, validity, interpretation, performance or termination, that is not resolved under subsection (b) will be resolved by individual binding arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules when the User is a Consumer, and under its Commercial Arbitration Rules in all other cases. The arbitration will be conducted by a single arbitrator, in English. Seat: Cheyenne, Wyoming, unless a Consumer User requests that the hearing be held in the county of the User's residence. For claims under USD 25,000, the arbitration may be conducted solely on the basis of documents or by videoconference, unless the arbitrator orders an in-person hearing. Judgment on the award may be entered in any court of competent jurisdiction.

d) Costs. For Consumers, payment of administrative fees and arbitrator compensation is governed by the AAA Consumer Fee Schedule, and GLOBEN will pay the fees allocated to it under that schedule. In all other cases, each party bears its own legal expenses and the costs of the arbitration are shared equally, unless the arbitrator decides otherwise.

e) Mass arbitration. If twenty-five (25) or more similar arbitration demands are filed against GLOBEN by the same counsel or in a coordinated manner, the AAA Mass Arbitration Supplementary Rules will apply and the demands may be administered in batches, without prejudice to each claimant's right to an individual award.

f) Class action and jury trial waiver.

THE USER AND GLOBEN AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, CONSOLIDATED OR REPRESENTATIVE ACTION. THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON'S CLAIMS OR AWARD RELIEF IN FAVOR OF ANYONE OTHER THAN THE CLAIMING PARTY. THE USER AND GLOBEN WAIVE THE RIGHT TO A JURY TRIAL.

g) Right to opt out. The User may opt out of this arbitration agreement and the class action waiver by giving written notice to [email protected] within thirty (30) calendar days after its first acceptance of these Terms, stating its name, address, registered email and its decision to opt out. Exercising this right does not affect any other provision or the rest of the contractual relationship.

h) Exceptions. Either party may bring individual claims in a competent small claims court, for as long as the matter remains in that court. GLOBEN retains the right to seek injunctive relief from a competent court to protect its intellectual property or the security of the Platform.

i) Severability. If the class action waiver in subsection (f) is found invalid or unenforceable with respect to a claim, that claim will be decided by a court and not in arbitration, and the remainder of this Section will continue to apply to the other claims.

j) Judicial forum. Matters not subject to arbitration will be submitted to the exclusive jurisdiction of the state and federal courts located in Laramie County, Wyoming, and the parties consent to such jurisdiction.

k) Time to bring claims. Unless the law provides a longer non-waivable period, any claim must be brought within one (1) year after the event giving rise to it.

A.15 Notices. [email protected] | Payphone Global Inc., 3561 FAU Blvd., Suite 400, Boca Raton, FL 33431, United States of America. Attn: Legal Department.

This Annex applies to Users resident or domiciled in the Republic of Ecuador. For such Users, the Spanish version of these Terms prevails.

B.1 Contracting Entity. ECUAPAYPHONE C.A., a corporation (sociedad anónima) and subsidiary of Payphone Global Inc., organized under the laws of the Republic of Ecuador, with RUC 0190402452001, domiciled in Cuenca, Ecuador, which provides in Ecuador the services of the Platform identified by the GLOBEN brand.

B.2 Regulatory authorization. ECUAPAYPHONE C.A. is authorized and supervised by:

a) The Central Bank of Ecuador (Banco Central del Ecuador), as a Specialized Electronic Deposit and Payment Company (Sociedad Especializada en Depósitos y Pagos Electrónicos, SEDPE), under the Organic Law for the Development, Regulation and Control of Technological Financial Services and its Regulations.

b) The Superintendency of Banks of Ecuador (Superintendencia de Bancos), as a payment aggregator, under the Organic Monetary and Financial Code and the applicable resolutions.

B.3 Territorial scope and non-resident customers. The services provided by ECUAPAYPHONE C.A. are directed to Users resident or domiciled in Ecuador and to transactions executed in Ecuadorian territory. The onboarding of non-residents and the provision of cross-border services, including sending and receiving remittances from abroad and transfers between Users in different jurisdictions, are subject to the specific authorizations granted by the competent authority and to the applicable reporting requirements, and will only be available to the extent and within the scope of such authorizations in effect. When the transaction pertains to another jurisdiction, it will be provided by the Group entity enabled there, in accordance with the corresponding Annex.

B.4 Digital Wallet. Balances reflected in the Digital Wallet correspond to electronic money or customer funds according to the regulatory classification in effect, are fully backed and segregated from the assets of ECUAPAYPHONE C.A. in the dedicated accounts required by regulation, are not bank deposits, do not earn interest and are not covered by Ecuador's Deposit Insurance.

B.5 Data protection. The Organic Law on Personal Data Protection (Ley Orgánica de Protección de Datos Personales) and its Regulations apply. The supervisory authority is the Superintendency of Personal Data Protection, before which the User may file complaints. ECUAPAYPHONE C.A. has a designated and registered Data Protection Officer, who may be contacted at [email protected].

B.6 Consumer protection. When the User is a final consumer, the Organic Consumer Protection Law (Ley Orgánica de Defensa del Consumidor) and its Regulations apply. Clauses of these Terms that are contrary to the consumer's non-waivable rights will be deemed not written solely with respect to that User. The User retains the right to resort to the Ombudsman's Office (Defensoría del Pueblo) and consumer protection authorities.

B.7 Anti-money laundering. The Organic Law for the Prevention, Detection and Eradication of the Crime of Money Laundering and Financing of Crimes and its regulations apply. ECUAPAYPHONE C.A. reports to the Financial and Economic Analysis Unit (UAFE) unusual and unjustified transactions and transactions equal to or above the legal reporting thresholds, and complies with the registration, structuring and information submission obligations imposed by regulation.

B.8 Tax obligations. For purposes of Section 7.4, the Tax Identifier is the Single Taxpayer Registry number (RUC), which must remain active. ECUAPAYPHONE C.A. may restrict Cash-In when the RUC is suspended, cancelled or deregistered, when the Merchant appears on the lists of taxpayers with non-existent transactions or shell companies published by the Internal Revenue Service (Servicio de Rentas Internas), or when the registered economic activity is inconsistent with the one declared on the Platform. ECUAPAYPHONE C.A. will make the withholdings at source required by law as a withholding agent and will issue the corresponding receipts.

B.9 Electronic signature. The electronic acceptance described in Section 1.5 has full effect under the Law on Electronic Commerce, Electronic Signatures and Data Messages, and data messages and their records have the same legal value and evidentiary weight as written documents.

B.10 Governing law and dispute resolution. The relationship between the User and ECUAPAYPHONE C.A. is governed by the laws of the Republic of Ecuador.

Any dispute arising from these Terms, their existence, validity, interpretation, scope, performance, breach, enforcement or termination will be resolved by arbitration at law administered by the Arbitration and Mediation Center of the Quito Chamber of Commerce, under the Arbitration and Mediation Law and the Rules of said Center. Seat: Quito, Ecuador. Language: Spanish. Sole arbitrator, appointed by mutual agreement or, failing that, by the Center. Each party bears its own legal expenses and the costs of the arbitration are shared equally, unless the arbitrator decides otherwise.

ECUAPAYPHONE C.A. retains the right to resort to the ordinary courts to seek urgent interim measures, enforce awards, collect clear, liquid and enforceable obligations through executive or coercive proceedings, and protect its intellectual property.

For Users who are final consumers, arbitration will only be mandatory if the User expressly accepts it when the dispute arises, without prejudice to the User's right to resort to the administrative or judicial channels available under the law.

B.11 Notices. [email protected] | ECUAPAYPHONE C.A., calle Pedro Calderón de la Barca y Gustavo Adolfo Bécquer, parroquia Yanuncay, Cuenca, Ecuador. Attn: Legal Department.

This Annex applies to Users resident or domiciled in the Republic of El Salvador. For such Users, the Spanish version of these Terms prevails.

C.1 Contracting Entity. Payphone El Salvador S.A. de C.V., a subsidiary of Payphone Global Inc., organized under the laws of the Republic of El Salvador.

C.2 Regulatory framework. The entity provides payment processing and aggregation services in accordance with Salvadoran law. When the activity requires authorization or registration with the Central Reserve Bank of El Salvador or the Superintendency of the Financial System, the services will be provided only within the scope of such authorization or, failing that, through authorized financial institutions with which the entity maintains agreements in effect. The entity does not take deposits from the public or engage in financial intermediation.

C.3 Anti-money laundering. The Law Against Money and Asset Laundering, its Regulations and the Instructions of the Financial Investigation Unit (UIF) of the Attorney General's Office apply. The entity maintains an accredited compliance officer, performs ordinary and enhanced due diligence, and files suspicious transaction reports and regulated transaction reports in accordance with the legal thresholds.

C.4 Consumer protection. The Consumer Protection Law applies. The consumer User may file complaints with the Consumer Protection Agency (Defensoría del Consumidor). Clauses that the law classifies as abusive will be deemed not written with respect to such User.

C.5 Data protection and credit. The Salvadoran data protection regulations in effect and the Law Regulating Personal Credit History Information Services apply to inquiries and reports to credit information agencies, for which the User's express authorization is required and obtained.

C.6 Electronic signature. Electronic acceptance has full effect under the Electronic Signature Law and the regulations on data messages.

C.7 Tax obligations. For purposes of Section 7.4, the Tax Identifier is the NIT / Taxpayer Registration Number (NRC), which must be active and in good standing with the Ministry of Finance. The entity will make the VAT and income tax withholdings and collections required by law as a withholding or collection agent.

C.8 Governing law and disputes. Governed by the laws of the Republic of El Salvador. Any dispute will be resolved by arbitration at law before the Mediation and Arbitration Center of the Chamber of Commerce and Industry of El Salvador, under the Law on Mediation, Conciliation and Arbitration, seated in San Salvador, in Spanish and with a sole arbitrator. The exceptions and reservations set forth in Section B.10, including the one relating to consumers, apply as relevant.

C.9 Notices. [email protected] | [full address], El Salvador. Attn: Legal Department.

This Annex applies to Users resident or domiciled in the Republic of Guatemala. For such Users, the Spanish version of these Terms prevails.

D.1 Contracting Entity. Payphone Guatemala S.A., a subsidiary of Payphone Global Inc., organized under the laws of the Republic of Guatemala.

D.2 Regulatory framework. The entity provides technological payment processing and aggregation services, without engaging in financial intermediation or taking funds from the public, activities reserved to entities authorized by the Monetary Board and supervised by the Superintendency of Banks. Services requiring the participation of financial system entities are provided through authorized institutions with which the entity maintains agreements in effect.

D.3 Anti-money laundering. The Law Against Money or Other Asset Laundering (Decree 67-2001), the Law to Prevent and Suppress the Financing of Terrorism (Decree 58-2005) and their regulations apply. Reports are filed with the Special Verification Intendancy (IVE) of the Superintendency of Banks, including suspicious transaction reports and reports of transactions exceeding the legal thresholds.

D.4 Consumer protection. The Consumer and User Protection Law (Decree 006-2003) applies. The consumer User may resort to the Consumer Assistance Directorate (DIACO).

D.5 Data protection. In the absence of a general personal data protection law, the entity applies as a minimum standard the principles and rights set forth in Section 13 of Book One, as well as the constitutional guarantees of privacy and the right of access to information, without prejudice to sector regulations and the banking secrecy applicable to information channeled through financial institutions.

D.6 Electronic signature. Electronic acceptance has full effect under the Law for the Recognition of Electronic Communications and Signatures (Decree 47-2008).

D.7 Tax obligations. For purposes of Section 7.4, the Tax Identifier is the NIT, which must be active with the Superintendency of Tax Administration (SAT), not suspended or cancelled, and the Merchant must not appear on the official lists of taxpayers with inconsistencies. The entity will make the VAT and income tax withholdings required by law.

D.8 Governing law and disputes. Governed by the laws of the Republic of Guatemala. Any dispute will be resolved by arbitration at law administered by the Dispute Resolution Commission of the Chamber of Industry of Guatemala (CRECIG), under the Arbitration Law (Decree 67-95), seated in Guatemala City, in Spanish and with a sole arbitrator. The exceptions and reservations set forth in Section B.10, including the one relating to consumers, apply as relevant.

D.9 Notices. [email protected] | [full address], Guatemala. Attn: Legal Department.

This Annex applies to Users resident or domiciled in the Republic of Nicaragua. For such Users, the Spanish version of these Terms prevails.

E.1 Contracting Entity. Payphone Nicaragua S.A. de C.V., a subsidiary of Payphone Global Inc., organized under the laws of the Republic of Nicaragua.

E.2 Regulatory framework. The entity provides technological payment processing and aggregation services. It does not take deposits or engage in financial intermediation, activities reserved to entities authorized and supervised by the Superintendency of Banks and Other Financial Institutions (SIBOIF). Transactions requiring the participation of financial system entities are executed through authorized institutions.

E.3 Anti-money laundering. Law 977, the Law Against Money Laundering, Terrorist Financing and the Financing of the Proliferation of Weapons of Mass Destruction, and its regulations apply. The entity registers with the competent authority where applicable, maintains a compliance officer and files suspicious transaction reports with the Financial Analysis Unit (UAF).

E.4 Consumer protection. Law 842, the Law for the Protection of the Rights of Consumers and Users, applies. The consumer User may resort to the Consumer Protection Directorate of MIFIC.

E.5 Data protection. Law 787, the Personal Data Protection Law, and its regulations apply, including the duties of information, consent, security, confidentiality and registration of data files with the competent authority where applicable.

E.6 Electronic signature. Electronic acceptance has full effect under Law 729, the Electronic Signature Law, and Law 787 as relevant.

E.7 Tax obligations. For purposes of Section 7.4, the Tax Identifier is the RUC, which must be active with the General Directorate of Revenue (DGI). The entity will make the withholdings required by law as a withholding agent.

E.8 Governing law and disputes. Governed by the laws of the Republic of Nicaragua. Any dispute will be resolved by arbitration at law under Law 540, the Mediation and Arbitration Law, administered by the Mediation and Arbitration Center of the Chamber of Commerce and Services of Nicaragua, seated in Managua, in Spanish and with a sole arbitrator. The exceptions and reservations set forth in Section B.10, including the one relating to consumers, apply as relevant.

E.9 Notices. [email protected] | [full address], Nicaragua. Attn: Legal Department.

F.1 Scope. This Annex applies to Users domiciled in countries other than those governed by Annexes A through E, when GLOBEN expressly enables the service for that jurisdiction. For such Users, the Spanish version of these Terms prevails.

F.2 Contracting Entity and local conditions. Unless it is disclosed during registration or by means of a jurisdictional addendum published on the Website that the service will be provided by another Group company, the Contracting Entity will be Payphone Global Inc. The applicable local conditions will be disclosed to the User during the registration process and through such addendum, which will be automatically incorporated into these Terms.

F.3 Services subject to licensing. In each jurisdiction, GLOBEN will only provide the services for which it holds the license, registration, authorization or exemption required by local law, or that it provides through authorized third parties. GLOBEN may restrict, limit, suspend or discontinue services in any country for regulatory, international sanctions, risk or operational viability reasons, giving such reasonable advance notice as circumstances permit.

F.4 Restricted territories. GLOBEN does not provide services to persons domiciled or located in jurisdictions subject to comprehensive economic sanctions of OFAC, the United Nations, the European Union or the United Kingdom, or to persons included on sanctions lists. The User represents that none of these circumstances applies to it and undertakes to report any change immediately.

F.5 User's local compliance. The User is solely responsible for complying with the tax, foreign exchange, consumer protection, data protection, labor, sector-specific and licensing laws applicable in its jurisdiction. GLOBEN does not advise on or guarantee the User's regulatory compliance and recommends that the User consult its own legal and accounting advisors.

F.6 Default governing law. In the absence of a specific jurisdictional addendum, the relationship will be governed by the laws of the State of Wyoming and applicable United States federal law, and disputes will be resolved by international arbitration administered by the International Centre for Dispute Resolution (ICDR) of the American Arbitration Association, under its International Arbitration Rules, seated in Miami, Florida, in Spanish or English and before a sole arbitrator. The class action waiver and the other provisions of Section A.14 apply to the extent permitted by the law of the User's jurisdiction. The foregoing is without prejudice to the mandatory laws of the User's jurisdiction and to the User's right, when acting as a consumer, to resort to the forums recognized by local law.

(Applicable exclusively to Business Accounts that activate the module. Its acceptance in the activation flow replaces the execution of individual addenda.)

G.1 Purpose and Activation

The Subscriptions Module allows the Merchant to configure periodic billing plans and execute recurring charges on its customers' tokenized Payment Methods, with their prior consent.

Activation. The module is not activated automatically. Its enablement is subject to the following procedure:

a) Request. The Merchant requests activation through the channel GLOBEN enables for that purpose (request form, assigned account executive or the mechanism published in the Business Account dashboard).

b) Evaluation. GLOBEN verifies compliance with the checklist defined by the Compliance and Fraud Prevention departments, which includes verification of the line of business, evidence of industry licenses where applicable, the definition of amount and frequency limits and, where applicable, the establishment of collateral or a Rolling Reserve in accordance with Sections 7.3 and 9.4 of Book One. When the Merchant does not meet all requirements, activation will require the express and documented approval of Compliance.

c) Acceptance of these Terms. Once the request is approved, the Merchant expresses its express acceptance of these Specific Terms through the electronic mechanism GLOBEN provides (request form, Business Account dashboard or equivalent channel), in accordance with the in-flow acceptance mechanism described in Section 1.5 of Book One.

d) Enablement. GLOBEN enables the module in its systems once the foregoing subsections have been met.

GLOBEN will retain the electronic record of acceptance, identifying the Merchant and the representative who granted it, the date, time, version of the accepted document and the other metadata available in the system.

G.2 Specific Definitions

Subscription: the contractual relationship between the Merchant and its customer that gives rise to periodic charges.

Plan: the configuration of amount, currency, frequency, duration, trial period and renewal terms.

Recurring Billing Mandate: the express, specific and informed authorization granted by the Cardholder to the Merchant to charge its Payment Method periodically.

Billing Cycle: the period to which each charge corresponds.

Merchant-Initiated Transaction (MIT): a charge executed without the Cardholder's intervention, based on a valid Mandate.

G.3 Cardholder Consent

Before the first charge, the Merchant must obtain and retain the Recurring Billing Mandate, which must meet the following minimum requirements:

a) Be granted through an affirmative and unequivocal action, separate from the acceptance of other terms.

b) Clearly, prominently and in advance disclose: the Merchant's identity, the description of the good or service, the exact amount or calculation method, currency, frequency, date of the first and subsequent charges, duration and automatic renewal terms, and the cancellation procedure and channel.

c) Where there is a free or promotional trial period, expressly disclose the date on which it ends, the amount that will be charged thereafter and how to cancel before that date.

d) Deliver to the Cardholder confirmation of the Mandate through a durable medium (email or equivalent) immediately after it is granted.

Retention of evidence. The Merchant must retain evidence of the Mandate and its confirmation for the entire term of the Subscription and for five (5) additional years, or any longer period required by regulation or the Network Rules, and deliver it to GLOBEN within twenty-four (24) hours of request, especially for chargeback defense.

Regulatory compliance. The Merchant is responsible for ensuring that its Plans and its enrollment and cancellation flows comply with the laws applicable to automatic renewals and subscriptions, including the Restore Online Shoppers' Confidence Act (ROSCA), state automatic renewal laws and, for recurring ACH debits, the Electronic Fund Transfer Act and the Nacha Rules.

G.4 Execution of Charges

a) The first charge will be processed as a Cardholder-initiated transaction, with strong authentication when required by the issuer, and will generate the card on file and the initial transaction identifier that will link subsequent charges.

b) Subsequent charges will be processed as MITs, with the recurring indicators required by the Card Networks.

c) The descriptor appearing on the Cardholder's statement must recognizably identify the Merchant and include a contact channel.

d) Advance notice. The Merchant must send a reminder to the Cardholder at least forty-eight (48) hours before each charge when the frequency is semi-annual or annual, when a trial period ends, when the amount changes, and whenever applicable law or the Network Rules require longer notice.

e) Retries. Upon a decline, the Merchant may retry the charge according to the cadence and maximum number of retries configured by GLOBEN, in compliance with the Network Rules. It is prohibited to split the amount, alter the amount to force authorization or retry on payment methods not authorized by the Cardholder.

f) Receipt. The Merchant must send a receipt for each charge executed.

G.5 Changes to Terms

Any change in the amount, frequency, scope of service or renewal terms must be notified to the Cardholder at least thirty (30) calendar days in advance, informing it of its right to cancel without penalty before the change takes effect. When required by applicable law or the Network Rules, the Merchant must obtain a new express Mandate.

G.6 Cancellation

a) The Merchant must offer a cancellation mechanism at least as simple, accessible and direct as the one used to enroll, available online and without requiring phone calls, forced retention or unnecessary additional steps.

b) Cancellation takes effect immediately with respect to future charges. Unless the law or a more favorable Merchant policy provides otherwise, it does not entitle the Cardholder to a pro rata refund of the current Billing Cycle, and the Merchant must clearly disclose this at the time of enrollment.

c) The Merchant must confirm the cancellation to the Cardholder through a durable medium within twenty-four (24) hours.

d) The Subscription is automatically cancelled when the token is revoked, the card expires or is cancelled, the Merchant's account is suspended or terminated, or the Cardholder revokes the Mandate with GLOBEN or its issuer.

e) GLOBEN's right. GLOBEN may cancel or suspend Mandates and recurring charges, immediately and without liability, when there are indications of a lack of valid consent, repeated Cardholder complaints, abnormal chargeback or cancellation rates, a request from a Card Network, the issuer, a Regulated Partner or a Competent Authority, or a breach of this Annex.

G.7 Reversals, Chargebacks and Liability

a) The Merchant is solely responsible to the Cardholder for providing the subscribed service, for the accuracy of the charges and for handling its complaints.

b) Any chargeback, reversal, refund, fine or penalty arising from a recurring charge is borne exclusively by the Merchant, including the handling fee, regardless of the outcome of the dispute.

c) GLOBEN may debit those amounts from the Digital Wallet, set them off against present or future balances and, if insufficient, demand immediate reimbursement.

d) Chargebacks on recurring charges for which the Mandate cannot be evidenced will be presumed, as between the parties, attributable to the Merchant.

e) GLOBEN may apply to this module chargeback and cancellation thresholds stricter than the general ones, as well as a specific Rolling Reserve.

f) GLOBEN is not a party to the Subscription, does not guarantee its performance and assumes no liability to the Merchant's customers.

G.8 Additional Merchant Obligations

Keep the terms and cancellation policy published to its customers up to date; not assign or transfer Mandates to third parties without the Cardholder's consent and GLOBEN's authorization; not use cards on file for purposes other than those authorized; address complaints within forty-eight (48) hours; and cooperate with GLOBEN in any investigation related to the module.

G.9 Suspension of the Module

GLOBEN may suspend or deactivate the module, while keeping the other services active, when the Merchant breaches this Annex, when required by a Card Network, a Regulated Partner or a Competent Authority, or when the performance of the subscription portfolio represents a material risk. Deactivation does not release the Merchant from its obligations to Cardholders or from outstanding financial obligations.

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BY CLICKING "I ACCEPT", REGISTERING, ACTIVATING A MODULE OR USING THE GLOBEN PLATFORM IN ANY OF ITS FORMS (APP, WEB PORTAL, PAYMENT BUTTON, PAYMENT LINKS, API), THE USER EXPRESSLY DECLARES THAT IT:

• Has read these Terms, their supplementary policies and the Jurisdictional Annex applicable to it in their entirety.
• Has understood the provisions, rights and obligations set forth.
• Agrees to be fully and unconditionally bound by them.
• Has the legal capacity or sufficient authority to enter into this agreement.
• Has had the opportunity to consult legal advisors if it deemed it necessary.
• Has provided information that is true, complete and accurate.
• Undertakes to comply with the laws and regulations applicable in its jurisdiction.
• Acknowledges that GLOBEN is a financial technology company and not a bank, that it acts as a technology intermediary and that it does not guarantee commercial transactions between Users.
• Understands and accepts the limitations of liability and indemnification obligations set forth.
• Accepts the dispute resolution mechanism set forth in its Jurisdictional Annex, including, for Users in the United States of America, individual arbitration and the waiver of class actions and jury trial, unless it exercises its right to opt out under Section A.14.
• Acknowledges that the in-flow electronic acceptance of each module's terms replaces the execution of individual addenda and has full legal effect.
• Consents to receive electronic communications, undertakes to keep the registered contact details current and under its control, and accepts that notices sent to those details are deemed validly delivered.

IF YOU DO NOT AGREE WITH ANY PROVISION, OR IF YOU DO NOT HAVE THE LEGAL CAPACITY TO ENTER INTO THIS AGREEMENT, YOU MUST REFRAIN FROM USING THE GLOBEN PLATFORM.

Payphone Global Inc. | GLOBEN

globenpay.app | [email protected]