Terms and Conditions

Luso Digital Assets Terms of Service
August 2026

PLEASE READ THESE TERMS OF SERVICE CAREFULLY.

BY CLICKING THE "CREATE ACCOUNT" BUTTON OR ACCESSING OR USING THE SERVICES OF LUSO DIGITAL ASSETS, YOU AGREE AND ARE LEGALLY BOUND BY THESE TERMS AND CONDITIONS AND ALL TERMS INCORPORATED BY REFERENCE.

These Terms and Conditions are agreed between the customer and Luso Digital Assets (also referred to as 'Luso').

These Terms and any documents expressly incorporated herein by reference are apply to user's access and use of this Website, the Platform, and the services provided by Luso Digital Assets, as described in these Terms (collectively, the 'Services').

By accessing, downloading, using, or clicking 'I Agree' to accept any of Luso's Services, the Customer agree that they have read, understood, and accepted all these Terms, as well as Luso's Privacy Policy, available on the Site. The use of certain features of the Services may be subject to specific additional Terms and Conditions to the Customer and which, upon acceptance, will become part of the contractual relationship. If the Customer does not agree to these Terms, they must not access or use the Services.

1. Definitions

For the purposes of these Terms, and unless the context indicates otherwise, capitalized terms have the following meanings:

"Aggregator": a third-party provider of liquidity aggregation services that queries multiple liquidity sources on decentralized protocols and proposes execution routes for Digital Asset exchange transactions;

"Digital Assets" or "Cryptoassets": digital representations of value or rights that can be transferred and stored electronically using distributed ledger technology (DLT) or similar technology;

"Non-Custodial Digital Wallet" or "Wallet": the digital wallet for Digital Assets made available through the Platform, whose cryptographic credentials remain under the Client's exclusive control, pursuant to Section 7;

"Client": the natural or legal person who accepts these Terms and uses the Services;

"Consumer": a Client who is a natural person acting for purposes outside the scope of their commercial, industrial, artisanal, or professional activity;

"EMT" (Electronic Money Token): a cryptoasset classified as an electronic money token under Regulation (EU) 2023/1114 ("MiCA Regulation"), whose value is intended to remain stable by reference to a single official currency, namely EUR and USDC;

"Partners": third-party entities that are duly licensed, authorized, or qualified where legally required, and that provide services made available or accessible through the Platform, namely Monerium and the technology infrastructure providers for the Wallet;

"Platform": the technological infrastructure developed and made available by Luso, including the applications and interfaces through which the Customer accesses the Services;

"Services": the services described in Section 4, made available by Luso directly or through Partners;

"Website": the website www.lusodigitalassets.com and its respective subdomains.

2. Eligibility

To be eligible to use any of the Services, the user must be at least 18 (eighteen) years old, have full legal capacity and reside in a country where Luso's Services are accessible and available. In the case of corporate Customers, the person accepting these Terms represents and warrants that he or she has the authority to bind the respective entity. Please be aware that not all Services are offered in every country, especially in countries or jurisdictions subject to sanctions, embargoes, or other restrictive measures, as defined primarily by the United Nations and the European Union - for further details, please see the "Sanctions and Restricted Jurisdictions" section. Furthermore, access to certain Services may require the user to undergo an onboarding process and enhanced due diligence, which could lead to the denial of access to Luso's Services.

3. Operating Model and Regulatory Charter

Luso is a technology company (fintech) that develops solutions in the digital assets sector, providing its customers with a technology platform designed to facilitate access to the digital assets ecosystem in a simple, intuitive, transparent, and secure manner. Luso's operational model is based on providing its own technological infrastructure, through which customers can access various products and services related to digital assets, some of which are provided by partners that are duly licensed, authorized, or regulated to carry out their respective activities. Luso's operating model may include white-label solutions, integrations via application programming interfaces (APIs), and other forms of technological collaboration with specialized partners.

Luso is not a credit institution, payment institution, electronic money institution, investment firm, or a crypto-asset service provider (CASP) authorized under the MiCA Regulation. Luso does not provide digital asset custody services, does not accept deposits or other refundable funds from the public, does not issue electronic money, and does not provide investment, tax, or legal advice. Whenever the provision of a particular service depends on a Partner, the Customer may be required to enter into a separate contractual relationship with that entity, as well as to comply with its terms and conditions, privacy policy, and other applicable contractual documentation. In such cases, Luso acts as a technology facilitator for the relationship between the Customer and the Partner, without prejudice to Luso's own responsibilities regarding the services it actually provides. The fact that certain services are presented to the Customer through an experience integrated into the Platform does not mean that those services are provided by Luso; the Customer should consult the identification of the entity responsible for each service. Luso may, in the future, make additional services available in collaboration with crypto-asset service providers authorized under the MiCA Regulation. The availability of these services will be preceded by an update to these Terms and the Customer's acceptance of the terms and conditions of the respective provider. At the same time, Luso seeks to promote financial and technological literacy among its Customers by providing content and information that enables them to understand how digital assets work, the risks inherent in their use, and best security practices.

4. Services Provided

Through the Platform and, where applicable, through Partners, Luso provides its Customers with the following Services:

a) Access to a Non-Custodial Digital Wallet, supported by a technological infrastructure for distributed key management and authentication, intended for the storage, receipt, transfer, and management of Digital Assets (Section 7);

b) Access to services related to EMTs, such as the euro-denominated EURe issued by Monerium, including features for depositing and withdrawing funds in euros via the SEPA payment system (Section 6);

c) An interface providing access to swaps or yield-generating transactions involving Digital Assets, executed on decentralized protocols through Aggregators selected by Luso (Section 8);

d) Other products or services related to digital assets that may be made available through the Platform, either directly or through Partners, in accordance with Section 3.

Important note: The provision of certain Services depends on the involvement of duly authorized or regulated Partners. Luso does not directly provide all the services available on its Platform; in many cases, it acts as a technology facilitator between the Customer and these entities.

5. Use of Third-Party Service Providers

As part of its business operations, Luso uses various third-party service providers, duly licensed and registered, responsible for providing certain technology infrastructure services, issuing electronic money, managing cryptographic keys, aggregating liquidity, verifying identity, preventing money laundering, or other functions necessary for the Platform's operation. Luso ensures technological integration with these Partners and selects entities that, based on available information, comply with the legal and regulatory requirements applicable to their respective activities. Where applicable, the services provided through these Partners may be subject to their own terms and conditions, which will independently govern the relationship established between the Customer and the respective entity. Luso reserves the right to replace technology Partners, EMT issuers, or other service providers, provided that such replacement does not diminish the rights legally granted to Customers, and such replacement will be communicated whenever legally required.

6. Services Related to EMTs — Monerium

Luso provides its customers with certain services related to Electronic Money Tokens (EMTs) denominated in euros through technological integration with Monerium, an entity duly authorized to issue electronic money. The loading (deposit) of funds in euros and the corresponding redemption (withdrawal) are carried out via SEPA transfers processed by Monerium, with the corresponding EMTs issued directly to the Customer's Wallet and redeemed from it. The issuance, maintenance, redemption, par value convertibility, and management of these EMTs are the sole responsibility of Monerium, in accordance with applicable law and the relevant contractual documentation. The right to redeem EMTs at their face value is a right of the Customer vis-à-vis Monerium, and not vis-à-vis Luso. To enable the provision of these services, the identification and verification data collected by Luso during the onboarding process may be shared with Monerium, in accordance with Section 14 and the Privacy Policy. Luso acts exclusively as a technology platform; it does not act as an electronic money issuer, custodian, or counterparty to the transactions carried out, nor does it receive funds from Customers or execute transactions reserved for electronic money institutions. Luso does not guarantee the issuance, redemption, convertibility, availability, or continuity of the EMTs issued by Monerium, nor is it liable for decisions made by Monerium regarding the issuance, suspension, limitation, blocking, unavailability, or termination of the EMTs or the services it provides. EMTs constitute electronic money and are not bank deposits; they are not covered by the Deposit Guarantee Fund or by any equivalent deposit guarantee or investor compensation system.

7. Non-Custodial Digital Wallet

Luso provides its customers with access to a Non-Custodial Digital Wallet, designed to enable direct interaction with blockchain networks for the storage, receipt, transfer, and management of Digital Assets. The wallet is supported by a distributed cryptographic key management infrastructure (multi-party computation) provided by a specialized technology partner. In this model, the Customer's private key is generated and reconstructed in a distributed manner using the Customer's authentication credentials (namely login credentials and additional authentication factors), without Luso or the technology partner having, individually, the ability to reconstruct the private key or to move the Customer's Digital Assets.

The Platform offers the Customer the option to create a backup of their recovery key. The creation and secure storage of this backup are the sole responsibility of the Customer. The Customer acknowledges and agrees that the simultaneous loss of their authentication credentials and the backup copy of the recovery key may permanently and irreversibly prevent access to the Digital Assets registered in the Wallet, without Luso or the Technology Partner having any technical or legal means to recover them.

Luso does not hold possession, custody, or control of the Digital Assets registered in the Wallet and cannot authorize transactions, transfer assets, or unilaterally restore access to the Wallet. Luso will never ask the Customer to disclose their private key, recovery key, or any other element that allows access to or control of the Wallet.

All transactions carried out through the Wallet are authorized using the Customer's credentials and subsequently transmitted to the respective blockchain network; the Customer assumes full responsibility for the accuracy of the instructions transmitted, specifically regarding the destination address, the blockchain network used, amounts, and other elements necessary for executing the transaction. The transmission of incorrect, incomplete, or incompatible information may result in the permanent loss of the Digital Assets, and Luso will be unable to recover, reverse, or correct them.

Luso is limited to providing the technological infrastructure necessary for the operation of the Platform and the wallet interface, and may use its own or third-party infrastructure for the purposes of querying information contained on the blockchain, technically transmitting transactions previously authorized by the Customer, synchronizing the wallet, or providing complementary features. The use of such infrastructure does not grant Luso any power of disposal, control, or custody over the Customer's Digital Assets.

The Customer is solely responsible for the safekeeping, maintenance, and confidentiality of all security elements necessary for accessing and using the Wallet, including login credentials, PIN codes, passwords, biometric authentication mechanisms, additional authentication factors, and a backup copy of the recovery key, and fully assumes the risks arising from their loss, misuse, or disclosure to third parties.

8. Swap Transactions via Aggregators

The Platform provides an interface that allows the Customer to conduct swap transactions between Digital Assets, executed on decentralized protocols through third-party Aggregators selected by Luso. When requesting a quote, the Platform consults one or more Aggregators, which propose an execution route and an estimated price. The price presented to the Customer prior to transaction confirmation includes the spread charged by Luso, pursuant to Section 12, as well as, where applicable, the Aggregator's fees, with network fees (gas fees) presented or estimated separately.

The Customer acknowledges and agrees that:

(a) exchange transactions are executed directly from the Customer's Wallet, upon the Customer's cryptographic signature, through smart contracts of decentralized protocols that are not operated, controlled, audited, or guaranteed by Luso;

(b) the actual execution price may differ from the estimated price, depending on changes in market conditions between the quote and execution (slippage), the available liquidity depth, and the operation of the protocol used;

(c) Luso does not guarantee execution at the best available market price, the continuous availability of quotes, or the execution of any transaction;

(d) once confirmed on the blockchain network, the transaction is final and irreversible; and

(e) Luso is not a counterparty to exchange transactions, but merely provides the technological interface for accessing Aggregators.

Luso selects and integrates the Aggregators available on the Platform based on criteria of technical reliability and market reputation, and may add, replace, or remove Aggregators at any time. This selection does not constitute a guarantee, recommendation, or endorsement regarding the Aggregators, the underlying protocols, or the tradable Digital Assets.

9. Interaction with Decentralized Finance (DeFi) Protocols

Certain features of the Platform allow the Customer to interact with decentralized finance (DeFi) protocols and other smart contracts deployed on public blockchain networks. The Customer acknowledges and agrees that:

a) Decentralized protocols are developed, operated, and governed by third parties or decentralized communities, and are not operated, controlled, audited, guaranteed, or recommended by Luso;

b) Smart contracts may contain errors, vulnerabilities, or design flaws and may be subject to cyberattacks, exploits, governance changes, or updates that result in the total or partial loss of the Digital Assets involved;

c) Granting token transfer authorizations (token approvals/allowances) to smart contracts involves risks, particularly when granted for unlimited amounts; it is the Client's responsibility to manage and revoke such authorizations;

d) Digital Assets tradable through decentralized protocols may have limited or no liquidity, may lose all their value, and may, in certain cases, constitute fraudulent or deceptive instruments created by third parties;

e) Transactions on public networks are exposed to adverse market practices by third parties, including front-running and other forms of value extraction (MEV);

f) The presentation of a protocol, aggregator, or digital asset on the Platform's interface does not constitute a recommendation, invitation, or incentive to use or acquire it, nor does it constitute an endorsement of its quality, security, liquidity, or legal compliance.

10. Blockchain Transactions

The Services may involve conducting transactions on public or private blockchain networks, depending on the nature of the Digital Asset or the service used by the Customer. After the Client authorizes the transaction using the appropriate authentication credentials and cryptographic signature, the transaction is transmitted to the applicable blockchain network, and its validation, processing, and confirmation depend exclusively on the operation of that network and its consensus mechanisms. Once validated and confirmed by the blockchain network, the transaction becomes final and irreversible and cannot be canceled, modified, annulled, or reversed by Luso, by any third party, or, as a general rule, by the Customer themselves. Any errors in specifying the destination address, the blockchain network, the amount, or other technical details shall be the sole responsibility of the Customer.

For the purposes of these Terms, a transaction will only be considered complete after the minimum number of confirmations required by the respective network has been obtained; this number may vary depending on the protocol, the type of Digital Asset, or the security criteria adopted. Luso does not guarantee minimum or maximum transaction confirmation times.

Transactions conducted on the blockchain may be subject to network fees (network fees, gas fees, validator fees, miner fees) or other charges inherent to the operation of the respective network. These fees are determined by the protocols or decentralized networks used; they do not constitute compensation for Luso and may vary depending on market conditions and network congestion, and may be deducted from the transaction amount or charged separately.

Luso has no control over the operation of blockchain networks, nor does it guarantee their availability, performance, stability, or operational continuity, and cannot be held liable for delays, failures, interruptions, or losses arising from the operation of these networks or their respective protocols, including congestion, unavailability of validators, consensus failures, cyberattacks, protocol vulnerabilities, forks (or hard forks), changes to network rules, or performance degradation.

11. Forks and Airdrops

Luso assumes no obligation to support, on the Platform or in the Wallet interface, assets resulting from blockchain network forks, free token distributions (airdrops), or similar events, nor to provide features that allow users to view, claim, or transfer such assets, without prejudice to these assets remaining associated with the Customer's cryptographic keys on the respective network.

Any decision to provide support for these assets is at Luso's sole discretion and does not confer upon the Customer any right or expectation regarding support for future events of the same nature.

12. Commissions and Fees

For the use of the Digital Asset exchange feature described in Section 8, Luso charges a spread, which is included in the price displayed to the Customer prior to the confirmation of each transaction. Currently, Luso does not charge any other commissions for the Services. Network fees (Section 10) and any commissions charged by Partners—namely by Monerium, in accordance with the relevant contractual documentation—do not constitute remuneration for Luso and are added, where applicable, to the transaction amounts. Luso may change its commissions and fees, or introduce new ones, by providing prior notice to the Customer in accordance with the Section on Changes to the Terms. Such changes do not apply to transactions that have already been confirmed.

13. Account Creation

To use certain Services, the Customer must create a Luso account and provide all requested information. Luso may, at its sole discretion, limit the number of accounts that each Customer may hold, maintain, or acquire. By creating an account, the Customer agrees to:

a) Provide accurate, truthful, and complete information;

b) Maintain and promptly update account information;

c) Maintain account security by protecting their authentication credentials and access to them;

d) Immediately notify Luso if you discover or suspect any security breach related to your account; and

e) Assume responsibility for all activities that occur on your account, accepting, to the fullest extent permitted by law, the risks of any authorized or unauthorized access to it.

14. Know Your Customer (KYC) and Anti-Money Laundering

The process of identifying and verifying Customers' identities is conducted by Luso, which adopts internal procedures designed to prevent money laundering, terrorist financing, and other illicit practices, and may engage specialized third-party entities to carry out identification, verification, transaction monitoring, and risk assessment procedures. By using the Services, the Customer agrees to provide Luso with any information it may request at any time for the purposes of identity verification and the detection of money laundering, terrorist financing, or other financial crimes, and authorizes Luso to maintain a record of such information. The Customer must complete certain verification procedures before using the Services or accessing the account; the limits applicable to the use of the Services may be modified as a result of the information collected on an ongoing basis.

The requested information may include, among other things: name, residential address, phone number, email address, date of birth, tax identification number, civil identification number, copy of identification document, proof of address, bank account information, nature of professional or business activity, device identifiers, and any other information that Luso is required to collect under applicable law.

To enable the provision of the services described in Section 6, and pursuant to the agreements entered into between Luso and Monerium, the Customer's identification and verification data may be shared with Monerium, which requires such data to comply with its own legal and regulatory obligations as an issuer of electronic money. The data may also be shared with other Partners and with competent authorities, in accordance with the law and the Privacy Policy.

Pursuant to Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets, transfers of Digital Assets may require the collection and transmission of information regarding the payer and the payee, as well as measures to verify ownership of self-hosted wallets.

The Customer authorizes Luso to conduct any inquiries, either directly or through third parties, that Luso deems necessary to verify the Customer's identity or to protect the Customer and/or Luso against financial crimes, and to take any measures reasonably necessary based on the results of such inquiries. The Customer acknowledges that their personal information may be disclosed to credit reference agencies and agencies dedicated to preventing fraud and financial crimes, and that these agencies may respond in full to the inquiries made. This procedure is intended solely for identity verification and should not have any adverse effects on the Customer's credit rating.

Luso may also require the Customer to wait a certain period of time after the completion of a transaction before making new Services available and/or before allowing transactions above certain limits.

15. Enhanced Due Diligence Measures

The Customer may also be required to undergo enhanced due diligence measures, during which Luso may ask to provide additional documents and/or information about the client or its business activities. Among other measures, Luso may establish the source of assets and/or funds involved in any transactions conducted while using the Services. By providing Luso with this or any other requested information, the Customer confirms that it is true, accurate, and complete, and that the Client has not withheld or omitted any information that may influence Luso's assessment, the Client agrees to promptly notify Luso in writing of any changes in circumstances that may render the information provided false, inaccurate, or incomplete, and to provide any additional documents or information that may be required by Luso and/or applicable law.

16. Ownership of Assets

The ownership of the Digital Assets belongs exclusively to the Client. Luso does not assume custody of Clients' Digital Assets, does not hold direct possession or control over them, and does not include them in its assets; consequently, it may not use them for its own account, encumber them, or dispose of them. EMTs and the funds underlying their deposits and redemptions are managed by Monerium, in accordance with Section 6 and Monerium's contractual documentation.

17. Suspension and Limitation of Access

Luso may, at any time and without prejudice to other legally permissible measures, suspend, restrict, or terminate, temporarily or permanently, the Customer's access to the Platform, as well as limit the use of certain Services, whenever such action is necessary to protect the security of the Platform, comply with legal obligations, or safeguard the legitimate interests of Luso, its Partners, or third parties, specifically when:

a) The Customer breaches these Terms, applicable policies, or any obligations assumed toward Luso or its Partners;

b) There is reasonable evidence of fraudulent, abusive, unlawful, or unauthorized use of the Platform or the Services;

c) It is necessary to comply with legal or regulatory obligations, court decisions, orders from competent authorities, or legitimate requests from regulatory bodies;

d) Such action is determined or requested by a Partner responsible for providing a specific service;

e) It is necessary to perform technical interventions, maintenance, updates, vulnerability mitigation, or respond to security incidents;

f) Luso reasonably believes that taking these measures is necessary to protect the integrity, security, reputation, or operation of the Platform and the Services;

g) There are reasonable grounds to suspect money laundering, terrorist financing, fraud, financing the proliferation of weapons of mass destruction, evasion of international sanctions, or any other illegal activity;

h) The Customer's account or transactions are the subject of a dispute, administrative, criminal, or regulatory investigation, or there is an increased risk of legal or regulatory noncompliance;

i) There is an attempt to circumvent security or control mechanisms implemented by Luso or its Partners, including the creation of multiple accounts, the misuse of promotional campaigns, or the manipulation of the Platform's features; or

j) Luso detects transactions that are manifestly anomalous, erroneous, or likely to compromise the security of the Customer's account, the Platform's systems, or the services provided by Partners.

Whenever legally permitted and operationally feasible, Luso will endeavor to inform the Customer of the suspension or restriction imposed, indicating, where appropriate, the grounds for such action. The suspension or restriction of access to the Platform does not affect the legal relationships that the Customer maintains directly with Partners, which will remain subject to their respective terms and conditions. The Customer acknowledges, however, that the suspension of access to the Platform may, in practice, limit the use of the Wallet interface provided by Luso, without prejudice to the fact that the Digital Assets remain associated with the Customer's cryptographic keys on the respective blockchain network, which may be stored by the Customer and linked to or transferred to another wallet.

18. Term and Cancellation by the Customer

The contract between the Customer and Luso is in effect for an indefinite term, beginning upon acceptance of these Terms. The Customer may, at any time and at no cost, close their Luso account using the features available on the Platform or by submitting a request to customer support. Closing the account does not affect transactions that have already been confirmed or obligations that arose prior to closure, including legal data retention obligations. Before closing the account, the Customer must ensure that they have a backup copy of their Wallet's recovery key and/or that they have transferred their Digital Assets to another address under their control, as well as that they have redeemed or transferred any held EMTs, in accordance with Monerium's contractual documentation. After the account is closed, Luso may cease to provide access to the Wallet interface; however, the Digital Assets associated with the Customer's cryptographic keys will remain on the respective blockchain network.

19. Right of Withdrawal

If the Customer is a Consumer and the contract was entered into remotely, the Customer has a period of 14 (fourteen) days from the date the contract was entered into to exercise the right of withdrawal, without having to provide any reason, pursuant to Decree-Law No. 24/2014, of February 14. To this end, the Customer may communicate their decision through an unequivocal statement addressed to customer support (support@lusodigitalassets.com), using the withdrawal form available on the Website. The Customer acknowledges and accepts, however, that the right of free termination does not apply to transactions involving Digital Assets that have already been executed, namely swaps, blockchain transfers, and EMT deposits or redemptions, insofar as these involve services whose price depends on market fluctuations that Luso cannot control and/or services provided in full with the Customer's prior and express consent. Transactions confirmed on the blockchain are, in any case, technically irreversible. Exercising the right of free termination results in the closure of the account; with regard to the Customer's Digital Assets and EMTs, the provisions of Section 18 apply.

20. Liability

Luso provides a technology platform designed to facilitate Clients' access to products and services related to digital assets—whether its own or those provided by Partners—and undertakes to use reasonable efforts to ensure the availability, security, and proper functioning of its Platform, subject to the limitations inherent in computer systems, electronic communications networks, and third-party infrastructure. Whenever a particular service is provided by a Partner, liability for the provision of that service rests exclusively with the respective entity, in accordance with applicable law and the contractual documentation entered into between that entity and the Customer. Luso shall not be liable for delays, interruptions, performance failures, service unavailability, loss of connectivity, unavailability of application programming interfaces (APIs), operational or cybersecurity incidents, or any other occurrences attributable to Partners, blockchain networks, decentralized protocols, Aggregators, or any other external systems not managed by Luso. Luso's liability is limited to the services it directly provides and to the availability of its Platform, and it shall be liable for damages resulting from willful misconduct or gross negligence directly attributable to it, in accordance with applicable law.

21. Limitation of Liability and Losses

Without prejudice to the provisions of Section 20, Luso's total aggregate liability to the Customer for any individual claim or series of related claims arising out of or in connection with Luso's breach of these Terms shall be limited to the amounts directly paid by the Customer to Luso as commissions or fees during the 12 (twelve) months preceding the event giving rise to the liability. In the case of a claim relating to a specific transaction, this amount shall also be limited to the value of the transaction in question.

In addition to the above limit, and to the fullest extent permitted by law, Luso, its service providers, and their respective directors, officers, agents, employees, and representatives shall not be liable for:

a) Loss of profits, revenue, or expected gains, including anticipated business profits and direct or indirect business losses, even if Luso was advised of or should have been aware of the possibility of such occurrence;

b) Loss or damage to reputation or good name, loss of business, opportunities, customers, or contracts, or loss of actual or anticipated savings;

c) Loss of use of hardware, software, or data, and/or data corruption, including losses arising from inaccuracies, defects, omissions, errors, delays, or interruptions in the transmission of Digital Asset price data; and

d) Any indirect damages that do not result directly and immediately from Luso's breach of these Terms.

LDA shall not be liable for delays or failures resulting from events of force majeure, including the unavailability of blockchain networks, network congestion, hard forks, cyberattacks, the unavailability of technology providers or third-party service providers, or any other events reasonably beyond its control. The limitations set forth in this Section apply only to the extent permitted by applicable law, without prejudice to Consumers' mandatory rights or liability arising from fraud, willful misconduct, gross negligence, or death or personal injury resulting from the negligence of Luso or its subcontractors.

22. Indemnification

To the extent permitted by law and, in the case of Consumers, only in cases of negligent breach, the Customer agrees to indemnify Luso, its subsidiaries, and service providers, as well as their respective executives, directors, officers, agents, employees, and representatives against any costs (including legal's fees, fines, or penalties imposed by any regulatory authority) that have been reasonably incurred in connection with any claims, demands, or damages arising out of or related to the Customer's breach of these Terms, or a violation of any law, rule, or regulation, or the infringement of third-party rights.

23. Without Guarantees

The Luso Services, Platform, and Site are provided "as it is," without any other capabilities assured by Luso regarding the availability of these Services. To the extent permitted by law, Luso's do not offer any implied warranties of title, merchantability, fitness for a particular purpose, and/or non-infringement, nor does it promise that access to the Site, any of Luso's Services, or any of the materials contained therein will be continuous, uninterrupted, timely, or error-free.

Luso makes no representations about the accuracy, order, timeliness, or completeness of the historical data of Digital Assets prices available on the Site. Any materials, information, opinions, projections, or estimates presented through the Site are provided by Luso solely for informational purposes and are subject to change without notice; the Client should conduct it's own assessment of their relevance, timeliness, accuracy, suitability, and reliability.

Unless LDA expressly provides consulting services regarding cryptoassets under a specific contract entered into with the Client, the information made available through the Platform or the Website is for informational purposes only and is not intended to provide tax or legal advice, nor to make recommendations regarding the suitability of any products for any particular person. Whenever LDA is not contractually bound to provide advisory services regarding cryptoassets, the Client must seek financial, legal, tax, or other advice that they deem appropriate before conducting transactions involving cryptoassets.

The account with Luso is not a bank account, and Digital Assets do not constitute deposits or other guaranteed financial products. Except as otherwise permitted by Luso, no interest will be paid on any funds or Digital Assets. Except for the express statements set forth in these Terms, the Customer acknowledges and agrees that they have not relied on any other statement or understanding, whether written or spoken, regarding the use and access to Luso's Services and Site. The Customer acknowledges that cryptoassets are highly volatile assets that may experience significant fluctuations in value and result in partial or total loss of the investment made.

24. Force Majeure

Luso is not liable for any breach of these Terms, including delays, failure to perform, or interruptions of the Services, or interruptions in the Services, when such breaches result, directly or indirectly from abnormal and unforeseeable circumstances beyond Luso's control, the consequences of which would have been unavoidable despite all contrary efforts - including, but not limited to, natural disasters, widespread power or telecommunications outages, large-scale cyberattacks, armed conflicts, and acts of public authorities — nor when such non-compliance is due to the application of mandatory legal provisions.

25. Risk Disclosures

Luso is committed to transparently disclosing the risks associated with Digital Assets. Before using the Services, the Customer must carefully read, understand, and accept the following risks, carefully considering their risk tolerance and financial situation:

a) Market risk and volatility: the value of Digital Assets is highly volatile, and the Customer may lose a significant portion or all of the capital invested. Luso is not liable for losses resulting from market fluctuations;

b) Lack of public guarantees: Digital Assets and accounts with Luso are not covered by the Deposit Guarantee Fund, the Investor Compensation System, or any equivalent protection mechanism;

c) Technological risk: The Services rely on computer systems, blockchain networks, and smart contracts that are susceptible to failures, vulnerabilities, cyberattacks, and outages;

d) Irreversibility: Transactions confirmed on the blockchain are final and cannot be reversed, even in the event of an error or fraud;

e) Self-custody risk: The loss of authentication credentials and the backup copy of the recovery key results in the permanent loss of access to Digital Assets;

f) Specific DeFi risks: Decentralized protocols carry increased risks of smart contract vulnerabilities, loss of liquidity, fraud, and manipulation, as set forth in Section 9;

g) Liquidity risk: Certain Digital Assets may have limited or no liquidity, making it difficult or impossible to sell them;

h) Regulatory risk: The legal and regulatory framework governing Digital Assets is evolving, and legislative or regulatory changes may affect the value of the assets or the availability of the Services;

i) Risk specific to EMTs: EMTs constitute electronic money issued by Monerium, and their redemption depends on Monerium's solvency and compliance with its legal and contractual obligations; and

j) Tax risk: the holding and trading of Digital Assets may give rise to tax obligations, the determination and fulfillment of which are the Client's responsibility.

26. Security

Luso assumes no responsibility for any loss the Customer may incur due to the compromise of account login credentials that is not attributable to Luso and/or due to failure to comply with the requirements of these Terms or with notices or alerts sent by Luso.

If the customers suspect that their Luso's account or any security data has been compromised, or if they become aware of any fraud, attempted fraud or any other security incident (including a cybersecurity attack) affecting them and/or Luso, the Customer must: (a) notify Luso's Customer Support as soon as possible via email at support@lusodigitalassets.com; (b) continue to provide accurate and up-to-date information during the security breach; and (c) take all reasonable steps that Luso reasonably requests to mitigate, manage, or report the incident. Failure to provide immediate notification of any security breach may be taken into account when determining the appropriate resolution of the matter.

Luso shall not be held liable for any damages or disruptions caused by computer viruses or other malicious code that may affect the client's computer or other equipment, or for any phishing, spoofing, or similar attacks. Luso advises the regular use of reliable virus prevention and detection software and warns that SMS and email services are susceptible to spoofing attacks and must exercise caution when opening messages that purport to originate from Luso.

27. Data Protection

The Client acknowledges that we may process the personal data provided and/or to be provided in the future, and/or in relation to their employees and other associates, in connection with these Terms or the Services of Luso. Such data is processed in accordance with Luso's Privacy Policy, available on the Website, which forms an integral part of these Terms, and includes, when necessary for the provision of the Services, the sharing of data with Partners, specifically Monerium, pursuant to Sections 6 and 14.

The client declares and warrants that:

a) the disclosure to Luso of any personal data relating to individuals other than the Client has been or will be made in compliance with all applicable data protection laws, and that such data is accurate, up-to-date, and relevant at the time of disclosure;

b) before providing any personal data to Luso, the Customer acknowledges having read and understood the Privacy Policy, and in the case of personal data relating to third parties, has provided the respective data subject with a copy of the Privacy Policy or has informed them where it can be accessed.

28. Customer Support Feedback, Inquiries, Complaints, and Dispute Resolution

If the Customer has any comments, questions, or complaints, they should contact Luso via the customer support via email at support@lusodigitalassets.com, please providing their name, email address, and any other information necessary to identify the Customer, their account, and the transaction in question.

If have a dispute with Luso, the Customer agrees to contact the customer support team first to attempt to resolve the issue. If the dispute cannot be resolved in this matter, both parties agree to utilize the complaints process established in this Section before initiating any legal action, without prejudice to the Customer's mandatory rights—particularly as a Consumer—and the possibility for either party to request provisional or precautionary measures from a competent court.

The complaint must state the reason for the complaint, how the Customer would like it resolved, and any other information deemed relevant. Luso will acknowledge receipt of the complaint request upon submission via email, and it will be reviewed by the Chief Compliance Officer, hereinafter referred to as "CCO", based on the information provided by the Customer and by Luso. Within 15 (fifteen) business days of receiving the complaint, the CCO will address all points raised in it by sending an email ("Resolution Notice") in which they will: (i) offer to resolve the complaint in the manner requested; (ii) decide to reject the complaint and explain the reasons for the rejection; or (iii) propose an alternative resolution to the complaint. Under certain circumstances, if the CCO cannot respond to the complaint within 15 (fifteen) business days, will send a feedback response indicating the reasons for the delay in responding to the complaint and specifying the timeframe within which it will respond, which will not exceed 35 (thirty-five) business days from the date of receipt of the complaint. Any resolution offer made to the customer will only become binding on Luso if accepted by the Customer and does not constitute any admission by Luso of any irregularity or liability in relation to the matter of the complaint.

Luso provides an optional complaint form on the Website, designed to facilitate the submission and handling of complaints. Its use is not mandatory, and the Customer may submit complaints through any channel made available by Luso, provided that the Customer supplies the minimum information necessary for a proper analysis of the situation.

The Customer may also file a complaint through the Complaints Book, in either physical or electronic format, the latter of which is available at www.livroreclamacoes.pt.

Pursuant to Law No. 144/2015, of September 8, in the event of a consumer dispute, the Consumer may turn to the competent alternative consumer dispute resolution entities, namely the CNIACC — National Center for Information and Arbitration of Consumer Disputes (www.cniacc.pt) or to the territorially competent consumer dispute arbitration center, an updated list of which is available on the Consumer Portal at www.consumidor.gov.pt. Recourse to these entities is optional and does not preclude the right to access the courts.

For complaints or disputes arising out of or related to these Terms or the provision of the Services that cannot be resolved through the procedures described above, the parties submit to the non-exclusive jurisdiction of the Portuguese courts, without prejudice to any mandatory rights of Consumers, including the right to bring actions before the courts of their respective domicile.

29. Taxes and Reporting of Tax Information

It is the sole responsibility of the Client to determine whether and to what extent, any taxes apply to the transactions it conducts through Luso's Services, as well as to withhold, collect, report, and remit the correct amount of tax to the competent tax authorities. The transaction history is available through the Luso account. The Customer acknowledges that, pursuant to applicable legislation regarding administrative cooperation and the exchange of tax information, specifically Directive (EU) 2023/2226 (DAC8) and its transposition into national law, Luso and/or its Partners may be required to collect and report to the competent tax authorities, including the Tax and Customs Authority, information about the Customer and their cryptoasset transactions, which may be subject to automatic exchange with tax authorities in other jurisdictions.

30. Death of the Account Holder

If Luso receives legal documentation confirming the death of the Client or other information leading to believe they have passed away, it will suspend access to the Luso account—during which time no transactions may be completed through the Platform—and will notify the relevant Partners, when applicable.

If Luso have reason to believe that the Client may have passed away but do not have satisfactory proof of death, it may take the steps, the client authorizes us to conduct investigations, directly or through third parties, that it deems necessary to verify whether they are deceased.

Access to the deceased Customer's digital assets will be granted, to the extent that it is technically and legally possible, to the eligible heirs or the head of the household, in accordance with Portuguese law, upon presentation of sufficient documentary evidence of their status (namely, proof of heir status); Luso may require additional documentation or a court order in the event of doubt or a dispute among interested parties, as well as the completion of the applicable identity verification procedures. The Customer acknowledges that, as this is a Non-Custodial Digital Wallet, Luso does not have access to the Customer's private keys nor the ability to move or transfer the Digital Assets registered in the Wallet. Heirs' access to these assets will depend on the availability of the Customer's authentication credentials and/or a backup copy of the recovery key, the safekeeping and transfer of which upon the Customer's death are the Customer's sole responsibility. Luso recommends that the Customer take appropriate estate planning measures regarding their Digital Assets. With regard to EMTs and funds managed by Monerium, the succession procedures set forth in that entity's contractual documentation shall apply.

31. Inactive Accounts

If the Customer's account remains inactive for an extended period and Luso is unable to contact the Customer using the information on file, Luso may, upon prior notice sent to the registered contact information, close the account, in accordance with the provisions of Section 18. In any case, the Digital Assets will remain associated with the Customer's cryptographic keys on the respective blockchain network, and the EMTs will remain subject to Monerium's contractual documentation and applicable electronic money legislation.

32. General Provisions

Customers are required to comply with all applicable laws, regulations, and third-party rights (including, without limitation, data protection laws and laws regarding the prevention of money laundering and terrorist financing) when using the Services, the Platform, and the Website. It is the responsibility of Customers to ensure that they comply with the legal requirements of their country of residence regarding the use of the Services. Luso reserves the right to suspend or terminate the accounts of Customers who violate any laws or regulations or engage in fraudulent or suspicious activities, and will cooperate with the relevant authorities to maintain the integrity of the Platform.

Luso grants the Customer a limited, non-exclusive, and non-transferable license, subject to these Terms, to access and use the Website, the Platform, and the related content, materials, and information, solely for the purposes approved by Luso. Any other use is expressly prohibited, and all other rights, titles, and interests remain the exclusive property of Luso and its licensors. The Customer agrees not to copy, transmit, distribute, sell, license, reverse engineer, modify, publish, create derivative works, or exploit, in whole or in part, any content from the Site or the Platform. The logos and trademarks related to the Services or displayed on the Website are trademarks or registered trademarks and may not be copied, imitated, or used without Luso's prior written consent.

The Customer agrees not to use the Services for any illegal, unlawful, fraudulent, or unauthorized purposes, nor to promote or facilitate such activities. The Customer also agrees not to use any robot, spider, crawler, scraper, or other automated means or interface not provided by Luso to access the Services or extract data. Luso reserves the right, at any time, to monitor, review, retain, and/or disclose any information necessary to comply with any law, regulation, sanction, legal proceeding, or request from a competent authority.

Luso will refuse to establish a client relationship or provide any Services to anyone who engages in any of the following activities—or whose business and/or activities are in any way connected to them—as they fall outside the company's risk appetite:

a) Money laundering or the use of proceeds from criminal activities;

b) Terrorist financing;

c) Trade (or any connection with the trade, manufacture, transport, financing, advising, assisting, or use) in weapons, ammunition, equipment, goods, or military or defense technology;

d) Industries involving child labor or forced labor;

e) The sex industry/pornography;

f) Activities resulting in the destruction of virgin forest;

g) Trade in diamonds not certified under the Kimberley Process;

h) Animal testing or activities that promote animal cruelty (e.g., trophy hunting, trade in animal parts, whaling);

i) The manufacture, sale, or distribution of unlicensed chemical or pharmaceutical products;

j) Unregulated gambling or gambling oriented toward the black market;

k) Unregulated financial activities;

l) Unregulated charitable organizations;

m) Shell banks.

This restriction applies whenever funds originate from, or are intended to finance, any of these prohibited activities. By accepting these Terms, the Customer agrees not to engage in or finance any of the activities described above.

Use of the Services is subject to compliance with applicable sanctions and restrictive measures regimes, including those adopted by the United Nations and the European Union, as well as other regimes that Luso voluntarily decides to apply. By sending, receiving, buying, selling, exchanging, or storing Digital Assets through the Site or the Services, the Customer agrees to comply with these requirements. You may not use the Services of regulated partners if you:

a) Are a resident of, or are under the control of a person established in, a country or territory subject to comprehensive sanctions or restrictive measures—including, as of the date of these Terms, Iran, North Korea, Syria, Cuba, Russia, Belarus, and the territories of Crimea and Sevastopol, as well as the regions of Donetsk, Luhansk, Zaporizhzhia, and Kherson not controlled by the Ukrainian government—or is listed on sanctions lists published by the competent authorities, as updated from time to time;

b) Intend to supply Digital Assets acquired or stored to a sanctioned country, a national or resident of a sanctioned country, or a sanctioned person;

c) Be a national or resident of any country restricted by the Partner.

The list of restricted countries and territories may be changed at any time depending on changes to applicable sanctions regimes.

Luso may apply enhanced control measures to Customers who are nationals or residents of countries considered high-risk. Regardless of this circumstance, the Customer agrees to comply with any additional requests that Luso may make to mitigate the risk arising from such nationality or residence. This internal list is not made available to the public, but includes countries with high levels of corruption, geopolitical instability, low financial inclusion, or high levels of bank secrecy, among other factors.

The Customer agrees that Luso's pre-contractual and contractual communications, notifications, notices, and information shall be provided in a durable medium, specifically via email to the address registered in the account or through notifications on the Platform, and shall be deemed received at the time they are made available. It is the Customer's responsibility to keep their contact information (including email address and phone number) up to date in their account profile in order to receive any notices or alerts, including notices of actual or suspected security breaches, and the Customer further agrees to keep Luso informed of any changes to the information provided during the account creation process.

Luso's marketing communications are clearly identified as such and are prepared in a clear, accurate, and non-misleading manner, in accordance with applicable law. Luso does not direct promotions or advertisements to residents of the United Kingdom or the United States of America. The information provided by Luso does not constitute investment advice or a recommendation to purchase any Digital Asset.

If, for any reason not prohibited by law, the Customer receives information about another user through the Services, the Customer must keep such information confidential and use it only in connection with the Services. The Customer may not disclose or distribute another user's information to third parties, nor use it except to the extent reasonably necessary to carry out a transaction and incidental functions (such as support, reconciliation, and accounting), unless the user in question has given express consent. The Customer may not send unsolicited communications to another user through the Services.

Nothing in these Terms shall be construed as establishing the Customer and Luso as partners, associates, or joint venture partners, nor as agents or financial advisors to one another.

The Customer may not create liens, security interests, or any other encumbrances or charges on the Digital Assets accessed through the Platform that involve Luso or the Platform without Luso's prior written approval.

These Terms are personal and the Client may not be transferred or assigned its rights, licenses, interests, and/or obligations to third parties. Luso may transfer or assign its rights, licenses, interests, and/or obligations at any time, including in connection with a merger, acquisition, or other corporate reorganization, provided that such transfer or assignment does not materially affect the quality of the Services provided to the Customer. Subject to the foregoing, these Terms shall bind and inure to the benefit of the parties, their permitted successors, and assigns. The Client reserves the right to terminate the agreement with immediate effect and at no cost, in the event of a transfer and/or assignment of Luso's contractual position.

Luso may amend these Terms, including to reflect changes in laws or regulations, changes to the Services, Partners, or commissions, or to improve clarity. Changes will be communicated to the Customer in a durable medium (by email and/or through the Platform) at least 30 (thirty) days prior to their effective date, except when they result from legal or regulatory requirements or security reasons that require immediate implementation. If the Customer does not accept the changes, they may terminate the contract, at no cost, up until the date the changes take effect, in accordance with Section 18. Continued use of the Services after the changes take effect constitutes acceptance of those changes. The current version of the Terms is permanently available on the Website, with the respective date indicated.

These Terms (including the documents incorporated herein by reference) constitute the entire agreement between the Customer and Luso regarding the matters set forth herein, superseding any and all prior discussions, agreements, and understandings of any kind or nature between the Customer and Luso, including any prior versions of these Terms.

If any provision of these Terms is deemed invalid or unenforceable under any applicable law, it shall not affect the validity of the remaining provisions, which shall remain in full force and effect.

Luso's failure to exercise any right provided for in these Terms does not constitute a waiver of such right, and Luso may exercise it at any time.

The section titles of these Terms are for reference purposes only and do not affect interpretation of any provision of these Terms.

These Terms agreement and any information or notifications provided by the client or Luso must be in Portuguese or English. The Portuguese-language version of these Terms constitutes the authentic and prevailing version, and any translations are provided solely for the Customer's convenience.

In the event that Luso is acquired or merged with a third entity, Luso reserves the right, in any of these circumstances, to transfer or assign the information we collected from the Client and the business relationship (including these Terms) as part of such merger, acquisition, sale, or other change of control, in accordance with Section 32.12 and the Privacy Policy.

All provisions of these Terms that, by their nature, extend beyond their termination—including, without limitation, the sections regarding suspension, cancellation, liability, indemnification, dispute resolution, and general provisions—shall remain binding and in effect after the termination of these Terms.

33. Governing Law and Jurisdiction

These Terms and the relationship between Luso and its Clients shall be governed by the laws of Portugal. Unless otherwise required by mandatory law, the parties submit to the non-exclusive jurisdiction of the Portuguese courts, without prejudice to the mandatory rights granted to Consumers, including any rules of jurisdiction that are more favorable to them.

34. Client's Declaration

The Customer declares that the conclusion of this contract was preceded by a careful and complete reading of the respective Terms, having been duly informed and clarified by Luso as to its content and scope, accepting them freely, voluntarily, and with full knowledge. The Customer further declares that they understand and accept that cryptoasset transfer operations are technically irreversible, assuming full responsibility for the correct indication of the destination address, and acknowledges that the value of Digital Assets may vary during the transaction processing period, accepting the risks inherent in their volatility.

The Customer also accept that Luso may suspend, refuse, or report the transactions to the competent authorities, or transmit information to the Partners responsible for executing the service, when necessary to comply with legal or contractual obligations, whenever signs of high risk are detected or there is a legal obligation to do so, declaring that the origin of the funds is legitimate and that the purpose of the transaction is lawful. For legal and regulatory compliance purposes, records and consents associated with transfers may be retained for the legally required period, namely 5 (five) years, extendable in accordance with the law.