CLIENT AGREEMENT｜NOVEMBER 2025

THIS DOCUMENT IS FOR EXTERNAL USE AND SHALL BE PUBLISHED ON

THE COMPANY’S PLATFORM

This Client Agreement (“Agreement”) is made by and between WUBU FZCO, incorporated under the laws of the Dubai Trade Centre (“DWTC”) in the United Arab Emirates (“UAE”), having registered Trade License Number(Wubu's license number and relevant dates will need to be added once the VARA license is issued), with registered address EO54- SRT Floor 25, Sheikh Rashid Tower, Dubai World Trade Centre (referred to as the “Company”) and you, our Client, with your details and address being as provided to us by you in the account opening form submitted to us by you. The Company and the Client are individually referred to as “Party”, and collectively, “Parties”.

Throughout this Client Agreement, the terms "we", "us", and "our" refer to the Company, together with its employees, consultants, directors, successors, subsidiaries, affiliates, payer correspondents and assignees. The terms "you" and "your" and “Client” refer to the Client to whom the below-mentioned services shall be rendered.

You agree that this Agreement shall govern our Services (as defined hereinbelow) through the platform located at www.wubu.com (“Platform”). Please read these terms and conditions carefully before accepting this Agreement and using the Platform.

The Company is licensed and regulated by the Virtual Assets Regulatory Authority (“VARA”) to undertake the ‘Broker-Dealer’ services in accordance with the scope of the Company’s license from VARA (collectively referred to in this Agreement as the (“Services”). The Services are rendered in compliance with the applicable law, legislation and rules of the VARA, including, inter alia, the Virtual Assets and Related Activities Regulations 2023, and the accompanying rulebooks along with their subsequent amendments issued by the VARA on May 2025 (the “VARA Regulations”).

THE COMPANY IS REQUIRED TO OBTAIN A VALID CONSENT FROM YOU TO GIVE EFFECT TO THIS AGREEMENT. BY CLICKING “I AGREE” BELOW, YOU AGREE THAT: (A) THIS WILL CONSTITUTE AS A VALID CONSENT PROVIDED BY YOU TO THE COMPANY IN ORDER TO GIVE EFFECT TO THIS AGREEMENT; (B) THIS AGREEMENT SHALL BE THE AGREEMENT BETWEEN THE PARTIES; (C) YOU SHALL BE BOUND BY THIS AGREEMENT AND BOUND TO COMPLY WITH THE LAWS, REGULATIONS AND RULES OF ANY APPLICABLE GOVERNMENTAL OR REGULATORY AUTHORITY.

BY CLICKING ON “I AGREE” BELOW, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS AGREEMENT, AS MAY BE AMENDED FROM TIME TO TIME. PLEASE READ THIS AGREEMENT CAREFULLY AND MAKE SURE YOU UNDERSTAND IT FULLY BEFORE USING THE PLATFORM AND OUR SERVICE.

BY CLICKING ON “I AGREE” BELOW, YOU ACKNOWLEDGE THAT YOU HAVE READ AND YOU UNDERSTAND AND ACKNOWLEDGE THE TERMS OF OUR PRIVACY POLICY.

BY CLICKING ON “I AGREE” BELOW, YOU ACKNOWLEDGE VIRTUAL ASSETS ARE PRONE TO CERTAIN RISKS. THE VALUE OF VIRTUAL ASSETS MAY INCREASE OR DECREASE, CAUSING SUBSTANTIAL RISK THAT YOU MAY LOSE MONEY BUYING, SELLING, HOLDING, OR INVESTING IN VIRTUAL ASSETS. YOU ACKNOWLEDGE THAT YOU HAVE READ OUR RISK DISCLOSURE STATEMENT BEFORE ENTERING INTO THIS AGREEMENT.

BY CLICKING ON “I AGREE” BELOW, YOU AGREE AND ACKNOWLEDGE THAT THIS AGREEMENT AND THE FOLLOWING DOCUMENTS (AS MAY BE AMENDED FROM TIME TO TIME AND PUBLISHED ON OUR PLATFORM), ARE INCORPORATED BY REFERENCE INTO THIS AGREEMENT AND AS AN INTEGRAL PART TO THIS AGREEMENT, FORM PART OF YOUR CONTRACTUAL RELATIONSHIP WITH US:

TERMS AND CONDITION FOR USE OF PLATFORM, IF ANY;
PRIVACY POLICY; (c) COOKIES POLICY;

(d) RISK DISCLOSURE STATEMENT; (e) PUBLIC DISCLOSURES.

BY REQUESTING FOR OUR SERVICES, YOU ARE CONSENTING TO THE TERMS AND CONDITIONS OF ALL THE ABOVEMENTIONED DOCUMENTS WHICH FORM PART OF THIS AGREEMENT.

THIS AGREEMENT SHALL BE EFFECTIVE FROM THE DATE ON WHICH THE COMPANY HAS COMPLETED ONBOARDING YOU AS A CLIENT AND YOUR ACCOUNT IS REGISTERED.

1. ABOUT THE COMPANY AND ITS SERVICES

Company and Services

1.1 The Company is licensed by the Dubai Virtual Assets Regulatory Authority (“VARA”) under license number the license will be added once given by VARA and is authorised to provide Broker-Dealer Services within the Emirate of Dubai. As a part of this license, the Company seeks to provide the following services in relation to virtual assets, namely USD Coin (“USDC”), and USD Tether (“USDT”). Any reference to the term virtual asset will be to the virtual assets identified hereinabove. The Company in particular will provide the following Services:

arranging orders for the purchase and sale of virtual assets between two entities or persons;
soliciting or accepting orders for virtual assets and accepting fiat currency, or other virtual assets, for such orders.

1.2 We reserve the right to add, modify, amend or otherwise change a Service, in whole or in part, and if we do so, we will provide you adequate notice of such change.

1.3 You acknowledge and understand that the Services are provided through our technological platform (“Platform”) which is made available to you through a specific invitation or request and the details of which is included in Clause 1.10 hereinbelow.

1.4 Through the Platform we will facilitate transactions on virtual assets, which are listed in the https://www.wubu.com/info/va_standard If, due to any factors including a “fork”, or other changes, any previously supported virtual asset is no longer supported, we will assess the impact of such change as soon as possible and notify you of all measures adopted by us to reduce any losses.

Territorial Scope of Services

1.5 Services are not directed at or to be distributed to any persons domiciled in any jurisdiction where all or part of the Services may be illegal or otherwise prohibited or restricted by the laws, regulations, rules of a country or territory or by the order or decision of a governmental, regulatory or judicial authority (collectively referred to as “Applicable Laws and Regulations”).

1.6 The Client is responsible for compliance with Applicable Laws and Regulations within the Client’s jurisdiction and/or any jurisdiction from which the Client accesses the Platform and/or Services.

1.7 The Client shall not use or access or attempt to access the Platform and/or the Services if:

accessing the Platform and/or Services is illegal or is otherwise prohibited or restricted under the Applicable Laws and Regulations in the Client’s country (whether the Client is a citizen, a resident or a tax resident) and/or any jurisdiction from which the Client accesses the Platform and/or Services; or
investment into virtual assets would be considered as an investment into securities in the Client’s country (whether the Client is a citizen, a resident or a tax resident) and/or any jurisdiction from which the Client accesses the Platform and/or Services.

1.8 Failure to comply with Applicable Laws and Regulations may result termination of the Client’s account and loss of any assets contained within.

1.9 Any residents of any jurisdiction outside of the UAE entering into this Agreement confirm that they comply with the requirements above and enter into this Agreement on their own initiative and have not been solicited to do so.

Platform

1.10 The Client may access and use the Company’s Services through the Company’s access-controlled Platform – https://www.wubu.com .

1.11 The access to the Platform is controlled, and the Company shall provide access to the Platform only after a Client has been onboarded in the manner set out in this Agreement.

2. TYPES OF TRANSACTIONS

2.1 By availing the Services, the Client may undertake any of the following actions:

buy virtual asset in exchange for fiat currency (“Buy Order”); or
sell a virtual asset in exchange for fiat currency (“Sell Order”); or

A Buy Order, Sell Order are collectively referred to as ‘Orders’ and individually as ‘Order’.

The Services provided by the Company enables a client to make fiat-virtual asset, and virtual asset fiat transactions.

3. ONBOARDING AND ACCOUNT CREATION

On-Boarding and Know Your Customer

In order to avail the Services, you are required to create an account (“Client Account”) with us on our Platform. Prior to opening a Client Account on the Platform, you shall complete our onboarding process, that comprises of our due diligence and client verification processes. As part of the onboarding process, you will be required to set up the two-factor authentication (“2FA”), and once you have completed the 2FA, you will be required to complete the client profile set up in order for us to set up the Client Account.

As part of this process, the Client acknowledges and consents to the collection by us of identification documents and non-public personal information relating to the Client and, where applicable, any beneficial owners of the Client. The Client hereby confirms that all information provided, including personal identification documents and details regarding the source of funds, is true, accurate, and complete. The Client further represents and warrants that the personal identification documents submitted are true copies of the original documents, valid, and not expired. You agree to promptly notify us and provide updated information in the event of any change to the information or documents you have provided.

The Client acknowledges that the Company is entitled to share your collected personal data with any authority in the UAE, upon the request of the relevant authority.

You acknowledge that, under certain circumstances, we may require additional documentation or information from you. Such request may be made by us either during or, following the initial due diligence process. If, at any time, you refuse to provide such required information, we reserve the right to:

not grant you access to our Platform; or
close a Client Account; or
otherwise limit your access to the Client Account.

You acknowledge that the Company shall accept you as a client only after you satisfactorily clear all the verifications required by us, including any required under the anti-money laundering and combatting financing of terrorism (“AML/CFT”) laws.

In addition to the initial verifications undertaken by the Company, you may be subject to periodic due diligence and verification by the Company to ensure its ongoing compliance with any AML/CFT laws. Further, you agree and confirm that you shall immediately inform the Company if there are any changes in the information or documentation provided by you to the Company.

The Company may, at any time, refuse, restrict or limit the Service made available to the Client or decide to terminate this Agreement and close a Client Account, in the event the Client is found to have provided incorrect, incomplete, inaccurate, or false information to the Company.

You acknowledge that the initial due-diligence and ongoing due-diligence undertaken by the Company is a part of the Company’s Know Your Customer (“KYC”)/Know Your Business (“KYB”) obligations under AML/CFT laws. You are informed that we may also lawfully obtain information about you from other sources without your knowledge.

You further agree that the Company shall be entitled, at its sole discretion, to freeze, block, reject, or delay any transaction or asset transfer if it determines that such transaction or the Client is the subject to sanctions screening or otherwise raises suspicion under applicable laws. In such cases, the Client shall have no recourse against the Company, and the Company may, at its discretion, suspend or terminate access to the Services or the Platform.

Verification of Identity.

You agree to provide all requested personal information including, but not limited to, the following:

For an individual, your name, date and country of birth, nationality, residential status, residence address, mobile telephone number, email address, name and address of employer, acceptable government issued photo identification documentation and a passport sized photograph of you.
For a corporate entity, the entity’s name, type of entity, date of registration, registration numbers, license numbers, constitutional documents such as memorandum of association attested by competent authorities within the UAE country of registration, management information, principle place of business, information of ultimate beneficial owners, authorised representative and their identification documents and a passport sized photograph of the authorised representative or a photograph of the authorized representative with the face in focus and clearly visible taken using any electronic device including mobile and laptop at the time of registration.
A liveness check and biometric verification including a live video or recorded video of your biometrics features. You acknowledge and consent that we may employ the services of third-party service providers for this purpose, in accordance with Section 20 of this Agreement.

You further acknowledge and agree that the Company may require you to answer additional security questions to confirm your identity. You agree that all information and documentation you provide to the Company shall 100% be truthful, accurate and valid.

Source of Funds and Source of Wealth. You agree that the Company may on any specific transaction require that you disclose the source of funds and source of wealth you are using and the originating bank account of the funds. You understand and agree the Company is under no obligation to accept or execute an order placed by you.

Supervisory Authority Disclosures. We may provide information about you and your transactions to supervisory authorities and law enforcement institutions, as described in our Privacy Policy and in accordance with Applicable Laws and Regulations.

Client Classification

During the process of creation of a Client Account, in line with the VARA regulations, we have undertaken a ‘client classification assessment’ on you based on the particulars and information you supplied to us. We will notify you if you have been notified as a Retail Investor, Qualified Investor, or Institutional Investor, in accordance with VARA regulations and its subsequent updates dated 19th May 2025. Your classification status shall be displayed on your Platform homepage, for your information. You agree that you will promptly notify the Company of any changes that may affect your classification as a Retail Investor, Qualified Investor or Institutional Investor.

4. PLACING AN ORDER

Once the Client has been sufficiently onboarded by the Company, and a Client Account is registered, the Client shall be given access to the Platform. The Client can avail the Services and place Orders through the Platform. An Order may be placed by way of a ‘Market Order’.

For any Order, the Client shall contact the Company through the Platform or such other method previously agreed between the Parties and request for a quote from the Company for a Buy Order or Sell Order.

Market Order. A Market Order will be placed in accordance with the below:

If the request for a quote is placed through the Platform, the Client shall place this request by clicking on the buy/sell link on the Platform, visible on their profile which may be accessed after logging in to their Client Account. Clients may also request for Quote through our WhatsApp Customer Support available on the Platform. However, Clients cannot place Market Order outside the Platform.
The rate quoted by the Company will be valid only for a specific time period to be communicated to the Client within the quote itself (the “Window Period”).
Once the Company provides a quote to the Client, the Client may either reject or confirm the Order within the Window Period, as follows:
1. If the Order has been placed through the Platform, the Client shall accept the quote by clicking on the confirm link.
2. Upon completion of either of these steps, the Company may proceed with the execution of the Order.
The Client acknowledges and agrees that once the quotation is confirmed by the Client, the Order shall be deemed final, confirmed, and irrevocably executed. The Client shall have no right to cancel, amend, or withdraw from the Order thereafter.
The Client acknowledges that, unless otherwise expressly agreed by the Company, the Client shall only be allowed to place an Order only after the Client has deposited the relevant amount of virtual assets or Purchase Price into :

The wallet address allocated by the Company to the Client within Fireblocks Vault (“Designated Virtual Asset Address”); or
The Company’s designated Client bank account (“Designated Client Bank Account”), as applicable.

Such deposits shall constitute the Client’s available credit balance (“Credit Balance”) with the Company for trading purposes.
1. Throughout the provision of the Services, Client deposits of virtual assets shall be made to the Designated Virtual Asset Address , allocated to each Client by the Company through its Fireblocks vault infrastructure. This Designated Virtual Asset Address is cryptographically linked to Company’s Fireblocks vault environment which is uniquely linked to each Client and mapped to the Client’s internal balance on the ledger.

Designated Virtual Asset Address is a unique deposit address per Client and is not reused across Clients. The Company does not assume discretionary custody of virtual assets and shall only access the Designated Virtual Asset Address for execution, settlement, or emergency purposes.

The execution and settlement of an Order will be carried out in accordance with Clause 5 hereinbelow.

5. ORDER EXECUTION

5.1 Each accepted Order will form a part of this Client Agreement and will be subject to the terms listed herein.

5.2 The Parties will comply with the following:

Buy Order: When purchasing a virtual asset in exchange for fiat currency, the Client agrees to pre-fund the transaction by depositing the principal purchase amount (“Purchase Price”) into the Designated Client Bank Account. Upon receipt and confirmation of such funds, the Company shall execute the Buy Order by transferring the purchased virtual asset into the Designated Virtual Asset Address uniquely assigned to the Client. The Client’s Platform balance shall be updated accordingly.
Sell Order: When selling a virtual asset to the Company, the Client agrees to transfer the virtual asset into the Designated Virtual Asset Address. Upon receipt and confirmation of the virtual asset, the Company shall execute the Sell Order and transfer the fiat proceeds (net of applicable Charges)to the Client’s whitelisted bank account.

5.3 An Order will be deemed executed and completed by the Company:

Where the Client is purchasing a virtual asset, once the virtual asset has been transferred into the Client’s assigned Designated Virtual Asset Address and reflected in the Client’s balance on the Platform;
Where the Client is selling a virtual asset, once the Company has transferred the fiat currency to the Client’s whitelisted bank account;
(All client balances in virtual assets are maintained on an internal ledger corresponding 1:1 to assets held in Designated Client Virtual Asset Address uniquely mapped to each Client. These balances are segregated, auditable, and reconciled daily.

5.4 You are informed that the Designated Client Virtual Asset Address, or the Designated Client Bank Account do not benefit from any form of deposit protection. However, all Client virtual assets are held in segregated addresses and are not commingled with Company’s proprietary assets.

5.5 The Company shall use its best efforts to complete the settlement within twenty-four (24) hours from the time the Order is confirmed.

5.6 You are solely responsible for withdrawing settled virtual assets from your Designated Client Virtual Asset Address to your external wallet within twenty-four (24) hours of receipt. If such virtual assets remain unwithdrawn for more than seventy-two (72) hours from the time of settlement, the Company reserves the right to suspend your ability to place new orders. Company shall also issue reminders, flag the account for compliance observation, and, if inactivity continues for seven (7) days, initiate a compliance review.

5.7 The Company may, at its sole discretion, refuse to execute or cancel any Order from you. We may refuse any Orders previously given by you, that has not yet been acted upon, for any reason whatsoever including, without limitation, due to manifest error, suspicious activity, or market abuse.

5.8 All Transactions are final, non-refundable, and non-reversible. Once executed in part or in full, neither Party shall be entitled to reversal of any transfer, payment, or delivery.

5.9 You acknowledge and agree that the Company shall not be responsible to issue refunds of any kind or amount or be held liable for any loss arising from Client side errors, including but not limited to providing an incorrect wallet address, loss of private keys, or failure to follow instructions.

5.10 The Platform shall provide Clients with a summary of all executed, rejected, or cancelled trades on the Platform dashboard, and an email confirmation will be sent upon completion of each transaction.

5.11 All proceeds related to the Client’s virtual assets, including airdrops, staking gains, or similar distributions, shall accrue to the Client’s benefit.

5.12 For the purpose of provision of Services, the Company will use a third-party virtual assets wallet infrastructure provider Fireblocks. Further, the Company will avail the services of third-party service provider ‘Elliptic’, the global leader in virtual assets risk management solutions, through its integration with ’Firelocks’, to screen the virtual assets transactions. The Company shall remain liable for the Client’s virtual assets in the course of providing Services to the Clients. After the final settlement of a virtual asset Buy or Sell order, the Company shall remain liable for the virtual assets only for as long as those virtual assets are stored in a wallet infrastructure in the control of the Company. Upon the withdrawal of virtual assets by the Client from the Company’s virtual asset wallet infrastructure to the Client’s whitelisted wallet outside of the Client’s ecosystem, the Company shall no longer remain responsible for the same.

Throughout the provision of the Services, Client deposits of virtual assets shall be made to the Designated Virtual Asset Address allocated to each Client by the Company through its Fireblocks vault infrastructure. The Client virtual assets will leave the control of the Company only during the following scenarios:

When the relevant virtual assets will be transferred back to the Client’s virtual asset address in the event of Buy Order.
When the relevant virtual assets will be transferred to the execution partner for the completion of the Services in the event of a Sell Order.

5.13 The Company may combine (or ‘aggregate’) an order for the Clients with orders of other clients. The Company will use its best efforts, to ensure that the aggregation will not work overall to the Client’s disadvantage. However, the effect of aggregation may work on some occasions to the Client’s disadvantage in relation to a particular order. The Company will ensure that aggregation only occurs when necessary and will ensure fair treatment by applying uniform execution prices for aggregated order, maintaining audit trails of order timestamps, and reviewing execution quality daily to confirm Clients are not systematically disadvantaged.

6. CANCELLATION AND REFUNDS

6.1 The Company reserves the right, at any time and at its sole discretion, to refuse the processing of a transaction or suspend, restrict, or terminate the Client’s account or use of the Services, for any reason including, but not limited to:

a breach of a provision of this Agreement;
failure to make deposit of the virtual asset or Purchase Price into the designated accounts of the Company;
any attempt to gain unauthorised access to the Company’ servers or any other client’s account; (d) any violation of Applicable Laws and Regulations; or (e) due to operational or technical difficulties.

6.2 Subject to Applicable Laws and Regulations, and VARA regulations, at any time the Company may:

terminate or suspend your use of the Service,
modify or suspend the type or dollar amount of transactions in connection with the Service; or
change the Client verification process for registering for the Service.

7. CHARGES

7.1 When accessing the Services, you agree to pay all applicable fees associated with any Order or transaction. Our charges will either be a commission or a mark-up/mark-down (“Charges”) on the quotes received by us from the execution venues like a crypto-exchange, market maker or brokerdealer. In case of over-the-counter desk transaction, the Charge shall be embedded in the quote received by the Client in terms of Clause 4.3 herein.

7.2 The Parties agree that the Company is entitled to collect its Charges in either fiat currency or virtual assets. Prior to transferring any fiat amounts or virtual assets into the Client’s bank account or virtual asset wallet, the Company shall be authorised to deduct its Charges.

7.3 In addition to the foregoing, the Company may charge you for any other miscellaneous expenses it reasonably incurs in connection with executing and completing a transaction which shall include but not limited to third party licensed bank charges. The Company shall disclose any such applicable miscellaneous expenses to the Client in advance of the transaction via the Platform or pre-trade notification in compliance with applicable client notification obligations under VARA regulations. Such Charges shall also include any fees associated with the transfer of assets from the Designated Client Bank Account or Designated Client Virtual Asset Address to the Client’s external bank account or virtual asset wallet, as applicable.

7.4 You agree that this Agreement governs all submissions of requests for price quotes by you to buy and/or sell Virtual Assets on Company’s Platform. You acknowledge and agree that Company shall determine the prices in its sole discretion. Company’s quoted prices are inclusive of the source price and internal margin determined solely by Company. Company may further communicate to you other applicable fees using any of its available communication channels. You acknowledge that the prices Company provides you are solely for your internal use.

7.4 Your Responsibility for Taxes. You acknowledge and agree that a virtual asset transaction may be subject to taxation by state, or local authorities. For example, any profits you make by selling virtual assets may be considered income and may be subject to taxation. You understand and agree it is your sole responsibility to determine whether and to what extent taxes may or may not apply to your transactions, and to pay all such tax liabilities in accordance with Applicable Laws and Regulations.

REPRESENTATIONS AND WARRANTIES.

By registering a Client Account to use the Service, you represent and warrant to us that:

you are legally authorised to enter into this Agreement and avail the Services;
you have provided us with your necessary identification information including name, address and other unique identification numbers;
the information that you have provided to us in registering for the Service is true, accurate and complete at the time provided and you shall immediately notify us in case of any change in relation thereto;
you will only use the Services in accordance with the rights granted to it under the Agreement;
you shall not act as an agent and resell the Services for the benefit of a third party without the prior written permission of the Company;
Fiat currency or virtual assets you use for the purposes of completing transactions are legally and beneficially yours and have not been obtained from illegal activities;
you are not, and shall not become, a sanctioned individual or entity, and shall not use the Services to engage in any activity involving sanctioned persons or jurisdictions.
any virtual asset provided to the Company has not been derived from any unlicensed platforms; and
you have all necessary capacity, authority, powers, consents, licences and authorisations and has taken all necessary action to enable you lawfully to enter into and perform this Agreement;
you have noted the client classification assigned to you and you will inform the Company if there are any changes that may impact this classification;
you have read these terms and conditions and all disclosures (including all risk disclosures) and you are aware of and understand the risks inherent in making investments into virtual assets;
you have satisfied yourself as to the observance of any applicable law, including obtaining any requisite government or other consents;
this Agreement, each transaction and the obligations created under them both are binding upon you and you do not and will not violate the terms of any regulation, order, charge or agreement by which you are bound;
no event of default or any event which may become (with the passage of time, the giving of notice, the making of any determination or any combination of the above) an event of default has occurred and is continuing with respect to the you;
any information which you provide or have provided to us in respect of your financial position or other matters is accurate and not misleading in any material respect;
you are willing and financially able to sustain loss of funds resulting from transactions;
neither you, and in case the Client is a corporate entity, any of your shareholders, ultimate beneficial owners, directors or key management personnel have been convicted of any crimes (in any jurisdiction) and there are no criminal lawsuits or other litigation, actions, administrative or other proceedings or governmental investigations of a criminal nature pending or threatened against or relating to you or your properties or business.
you have disclosed the details of its ultimate beneficial owners.
you have received this Agreement and agree to be bound by its terms and conditions.

The Company represents and warrants that it will perform the Services with reasonable care and skill in a timely and competent manner in accordance with VARA regulations, best industry standards and practices applicable to the Services. While performing the Services, we will act honestly, fairly and in the best interests of our clients and the integrity of the virtual asset market in the UAE.

9. MODIFICATIONS TO THIS AGREEMENT

The Company may change or modify this Agreement, including fees and charges under this Agreement, by providing you via the Platform a prior notice of at least 30 calendar days. We will explain the reason for the change when we provide you with a notice of the change. We will ensure the most recent version of the Agreement is always available on the Platform. We may change the terms of this Agreement for any reason including but not limited to the following:

To make the Agreement easier to understand or fairer to you;
To correct any error we have identified in the Agreement;
To cover any improvement or change to our Services;
To reasonably respond to changes or anticipated changes in the general banking market, to industry guidance or codes of practice;
As a result of changes in technology, the systems we use to run our banking business and/or market practice;
To ensure that we comply with legal or regulatory requirements and guidance such as a direction from the local Financial Intelligence Unit.
As a result of a change or forthcoming change in law, or a decision or recommendation by the courts;
As a reasonable response to actual or expected increases in our costs in providing the Services.

If you do not want to continue this Agreement because of a change we are making you have the right to terminate this Agreement immediately and without charge by giving us written notice before the change comes into effect. However, in the event that you do not cancel during the notice period specified in Clause 9.1 hereinabove and you continue to access and use the Services then you will be deemed to have accepted the changes, which will then apply to you.

10. SECURITY

10.1 Security Measures. When you create the Client Account, you agree to: (i) create a strong password that you do not use for any other website or online service; (ii) maintain the security of your Client Account by protecting your password and restricting access to your Client Account; (iii) promptly notify us if you discover or otherwise suspect any security breaches related to your Client Account; and (iv) take responsibility for all activities that occur under your Client Account and accept all risks of any authorized or unauthorized access to your account, to the maximum extent permitted by law.

10.2 You agree that you will not grant any person access to your Client Account, except as described herein, as granting access may violate Applicable Laws and Regulations.

10.3 You must, at all times, observe the security measures required that may be needed to prevent unauthorized use or fraud. You must comply with all instructions that we may give you from time to time in relation to the operation of the Platform, your Client Account and adopt security arrangements in connection with the same. You agree that you shall not exploit the Platform in any unauthorized way whatsoever, including but not limited to trespass, or materially burden the network capacity of the Company. The Client shall not use: (i) the Platform for any illegal or immoral purpose; (ii) interfere with another user’s access to or use of any the Services; or (iii) do anything that may directly or indirectly result in violation of any Applicable Laws and Regulations, such as laws governing intellectual property and other proprietary rights, data protection and privacy, anti-money laundering and currency control.

10.4 You agree to co-operate fully with us, the supervisory authorities and any relevant law enforcement agency in relation to any investigation into any actual or suspected misuse of your security details, including your security measures. You will provide any and all relevant information to assist in any such investigation if requested to do so by us or by law enforcement bodies.

10.5 You acknowledge that use of the internet may be subject to a virus attack and/or communication failure. The Company shall not bear any liability, whatsoever, for any damage or interruptions caused by computer viruses, spyware, Trojan horses, worms or other malware that may affect your systems, computer or other equipment, or any phishing, spoofing or other virus attacks. Further, you may

face technical difficulties including failures, delays, or malfunction, which may cause Orders not to be transmitted, received or executed as a result of such disruption, failure or malfunction, software erosion or hardware damage, which could be the result of hardware, software or communication link inadequacies or other causes. The Company shall not be liable for any losses arising from any such Orders not being transmitted, received or executed.

10.6 You understand that access to the Platform is provided on “as-is” basis. The Company make no warranties, express or implied representations or guarantees as to the merchantability and/or fitness for any particular purpose or otherwise with respect to the Platform, its content, and documentation.

11. TERMINATION

Termination by Client. You may terminate this Agreement for any reason by giving us at least 30 calendar days’ notice. Notice must be given to us by email to help@wubu.com and must include details of your account or other withdrawal destination to which (subject to Know Your Customer procedures) we may return any funds or virtual assets remaining within your account following deduction of any charges, dues or other sums properly due to the Company.

Termination by Company for Cause. This Agreement may be immediately terminated, in whole or in part, by notice given to the Client by the Company in case of any of the following circumstances:

if you are in breach of the terms of this Agreement or any other instruction or communication provided to you by the Company
if you fail to pay the Charges or any other fees, costs, expenses or other monies due to Company at the time at which such monies become due and payable;
if Company receives written confirmation of your dissolution or winding up or you become bankrupt, insolvent or are subject to any analogous insolvency procedure in any relevant jurisdiction;
if you unable to pay your debts as they become due, or make a general assignment or composition with or for the benefit of creditors, or become the subject of insolvency, bankruptcy or similar proceedings, or a petition is presented for your winding- up or liquidation or an administrator or liquidator is appointed over all or substantially all of your assets;
if Company receives an order from a court or other regulatory authority to terminate this Agreement;
if you are dissolved, or, if your capacity or existence is dependent upon a record in a formal register, such registration is removed or ends, or any procedure is commenced seeking or proposing your dissolution, removal from such a register or ending of such registration;
if the Company believes that funds used by you to make payment to the Company or to make an investment have been obtained through unlawful means or that such funds are being used to effect suspicious transactions or if the Company believes that you are otherwise in violation of any AML/CFT laws;
if you do not, upon request by Company, provide the Company with any information or documents relating to you and/or your Client Account;
if the Company deems that the continuing to provide Services to the Client poses a reputational, regulatory, operational, or any other risk to Company;
if the Company believes that you may be in breach of any applicable law;
if you have been found to have provided incorrect, incomplete, inaccurate or false information to the Company;
you have seriously or persistently breached this Agreement or we have a reason to believe that you have used, or intend to use the Platform or the Client Account for fraudulent or other unlawful purposes;
if, despite reasonable attempts by the Company to communicate with you using your address or any other contact details on record, the Company has been unsuccessful.

Termination by Company for Cause. The Company may terminate this Agreement, in whole or in part, for any reason by giving you at least 30 calendar days’ notice. We will serve to notice to your most recently updated email address.

Consequences of Termination.

Following termination of this Agreement, Company shall determine whether to complete any outstanding transactions or obligations. For the avoidance of doubt, you agree that you shall be responsible for the payment of any costs, fees, charges, expenses, levies, taxes and duties incurred by Company, in relation to any such outstanding transactions at the time of termination. Any outstanding fees, costs and expenses incurred by the Company at the time of termination or resulting from such termination shall become due and payable by the Client immediately upon termination.
Any pending Orders at the time of the termination of this Agreement shall be cancelled automatically without the need for any further notice to you. After deductions of any amounts or charges owed to us, the Company shall transfer any fiat currency or virtual assets of the Client in the Company’s control to the Client designated bank account and virtual asset wallet respectively.
You understand and agree that the date of refund to you by the Company (if applicable) may be different from the date your Client Account is closed.
Clauses 12, 13, 14, 17.1, 17.4, 20, 21.3 and 21.4 shall survive termination of this Agreement. Post termination, Clauses 18.3 and 18.4 shall survive for the period specified therein.

12. LIABILITY

General exclusion. Neither the Company or their directors, officers, employees, or agents shall be liable for any losses, damages, costs or expenses, whether arising out of negligence, breach of contract, misrepresentation or otherwise, incurred or suffered by the Client under this Agreement (including any transaction or where the Company has declined to enter into a proposed transaction) unless such loss is a reasonably foreseeable consequence or arises directly from the Company or our personnel’s respective gross negligence, wilful default or fraud. In no circumstance shall the Company’s liability include losses suffered by the Client or any third party for any special damage, or loss of profits or loss of goodwill or loss of business opportunity arising under or in connection with this Agreement, whether arising out of negligence, breach of contract, misrepresentation or otherwise.

Changes in the market. Without limitation, the Company does not accept any liability by reason of any delay or change in market conditions before any particular transaction is executed. The Company shall not be liable to the Client:

for the act or omission of any third party utilised by the Company to assist with the due diligence process, provided that the Company has used reasonable care and skill in selecting and instructing such third party.
If the Client divulges or give any security information and/or your security measures to an unauthorized third party;
Any third party sees information concerning Client’s account displayed on your screen;
Any third party observes the Client when entering your security measures;
Any third party overhears any telephone call that the Client make to us in connection with your account or any aspect of the Platform.

The Company provides the Services on an execution -only basis. The Company does not provide individual or tailored advice in relation to Virtual Asset markets and trading, including advice on the investment of the Client’s money. The Company shall not be liable for any of the Client’s investment decisions.

The Company shall not accept any liability for loss or corruption of any data, database or software or theft as a result of a security breach of the Client.

Nothing in this Clause 12 excludes or limits our liability for:

death or personal injury caused by our negligence;
(ii) fraud or fraudulent misrepresentation; or
(iii) any other liability which cannot be limited or excluded under applicable law.

Risk of Loss and Failure of Service. The Company acknowledges that certain failures of service including but not limited to system outages, operational disruptions, or custody incidents may result in a risk of loss to the Client. While the Company maintains adequate operational resilience, key management, and custody safeguards, the Client acknowledges and accepts that residual risks of loss may still occur due to factors beyond the Company’s reasonable control. The Company shall not exclude or limit its liability where such loss arises directly from the Company’s gross negligence, wilful misconduct, fraud, or material failure of service, or where otherwise prohibited. The Company shall promptly notify the Client and VARA of any material incident, system failure, or operational breach which could reasonably result in a loss or impact Client Assets and shall take all reasonable measures to mitigate such risk in line with its obligations.

13. INDEMNITY

13.1 The Client shall indemnify, defend and hold harmless the Company, its affiliates and any of its respective officers, employees and agents from and against any and all losses, claims, damages, liabilities or expenses arising out of, or relating to:

Any information provided to the Company to facilitate the provision of Services;
Anything done or omitted to be done for the purpose of carrying out any transaction for your Client Account or providing any Service to you or otherwise acting on your instructions under this Agreement;
Any breach of its representation and warranties;
Any failure to comply with applicable law;
Any breach of the Client’s obligations under the Agreement
Any gross negligence or wilful misconduct by you

13.2 The Client’s indemnity obligation under this Clause 13 shall be limited to the extent that the loss is caused by our gross negligence, wilful misconduct, fraud or other criminal action.

14. SET OFF

14.1 The Company may, at any time and without prior notice to the Client, set off any liability or debt the Company owes to the Client against any liability the Client owes to the Company, irrespective of the currency or its denomination. If the liabilities to be set off are expressed in different currencies, the Company may convert either liability at an exchange rate which the Company deems reasonable for the purpose of such set off.

14.2 Any exercise by the Company of its rights under this clause shall be without prejudice to any other rights or remedies available to the Company hereunder or at law.

14.3 You agree that this Agreement is intended to be and constitute a “Netting Agreement” and each transaction executed by the Company, in furtherance to an Order is intended to be and constitutes a “Qualified Financial Contract”, as each term is defined in UAE Federal Decree-Law No. 10/2018 On Netting (the “Netting Law”). You agree that you shall not take any steps or bring any proceedings in any forum to dispute or contest or otherwise seek to challenge the validity or enforceability of this Agreement or any trading transaction on the basis that this Agreement or any such transaction(s) do not constitute or are not part of a Netting Agreement or collectively or individually are not in compliance with or within the scope of the Netting Law.

15. ERROR RESOLUTION AND CUSTOMER SERVICE

15.1 Error Resolution and Customer Service Contact. We are committed in delivering “best in class” services. If you experience an error or problems using our Platform or the Services, or to report a complaint to us, please contact us as follows:

Email our customer management team at service@wubu.com.

Please contact us as soon as possible if you become aware of a transaction error or any other problems related to the Service.

15.2 Complaints Handling. Complaints about our Services or the Platform will be dealt with in accordance with our Complaints Handling Policy available https://www.wubu.com/info/complaints_handling_policy You can obtain further detailed information on your rights by contacting the Company via contact details above. The Company will acknowledge a complaint within 1 (one) week of such complaint being made, and resolve complaints within 4 (four) weeks of the complaint being made, except in extraordinary circumstances in which case the Company will provide you an update on the status of the complaint, and explain the extraordinary circumstances delaying its resolution, within 4 (four) weeks of the complaint being made and resolve the complaint no later than 8 (eight) weeks from when the complaint was made.

16. BANKRUPTCY PROTECTION

16.1 The Company agrees to maintain all client assets in a segregated wallet or wallets that are distinct from the Company’s own operating funds and assets. Client assets including Client virtual assets and Client money funds shall not be subject to claims by the Company's creditors in the event of insolvency or bankruptcy.

16.2 Bankruptcy Remoteness: In the event of the Company's bankruptcy or insolvency, the client assets described above shall remain protected and unaffected by the Company's financial difficulties. The Company shall ensure that such assets are structured in a manner that isolates them from the Company's estate, thus ensuring that they are not subject to liquidation or claims by the Company's creditors.

16.3 The Company shall, when establishing any client money account with the bank, enter into a legally binding agreement specifying that the account is a Designated Client Bank Account. The Company shall notify the bank that the account is held for benefit of Clients and that the funds therein shall not be used to offset any obligations of the Company, nor shall they be subject to liens, set-offs, or claims by the bank or any other party.

16.4 The Company agrees to notify clients promptly in the event of any bankruptcy or insolvency proceedings and provide clear instructions on how clients can retrieve or transfer their assets.

16.5 The Company will comply with all applicable laws and regulations related to the protection of client assets and insolvency procedures.

17. NO OBLIGATION AND RELATIONSHIP

17.1 While this Agreement governs any transactions or other contracts which the Company enters into with the Client, it does not impose any obligation on the Company to accept any orders submitted by the Client or to proceed with any transaction.

17.2 Each Party to the Agreement is acting in its capacity as an independent contractor. Neither Party is an agent of the other Party and has no authority to represent the other Party as to any matters.

Neither Party’s employees shall be considered employees or agents of the other Party, nor shall they be entitled to privileges given or extended to the other Party’s employees.

18. COMMUNICATION

18.1 Notices. You agree to accept all communications from us via email. If we send an email to the email address on record for your account, you agree and understand that this constitutes notice from us to you. If you email us, this constitutes notice from you to us. For all notices made by email, the date of receipt is considered to be the date of transmission.

18.2 Language. This Agreement and all documents and information in connection with the Agreement and the Platform will be provided in English. We will communicate with you in connection with the Agreement in English, and we will only accept instructions and notices form you given in English.

19. INFORMATION WE COLLECT AND HOW WE USE IT

19.1 Information We Collect. In the course of provision of the Services the Company will collect the following information: (a) information such as name, date of birth/personal code, nationality, residence address, tax identification number, and email address that you provide when you register your Client Account; and (b) information about Orders placed and transactions executed such as date, amount, rate etc, bank account details and a virtual asset wallet information.

19.2 How We Use Your Information. We use your information to process transactions you have requested. We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. We may use or disclose your information to third parties: (i) where it is necessary for completing transactions that you have requested; (ii) in order to comply with a governmental institution, court order, subpoena or other legal disclosure requirements; (iii) with your permission; or (iv) to our trusted employees, auditors, affiliates, service providers, or attorneys as needed and in accordance with Applicable Laws and Regulations.

19.3 Retention Periods. We will retain information on transactions for not less than 8 years from the date of termination of this Agreement and your right to access and use of the Services. Without prejudice to our obligation to maintain records sufficient to meet the requirements of Applicable Laws and Regulations, voice, and electronic communications relevant to any of the matters referred to in this clause may be kept for a minimum of 8 years from the date of termination of this Agreement and your right to access and use the Services.

19.4 Confidentiality. You agree that you will maintain all the quotes provided by us and the details of the transactions strictly confidential. This obligation shall survive for a period of five (5) years after the termination of this Agreement.

20. THIRD PARTY SERVICE PROVIDERS AND OUTSOURCING DISLCOSURE

20.1 In accordance with the VARA regulations, the Company shall disclose its use of third-party service providers and affiliated entities involved in the provision of its Services. The Company engages external service providers to support specific operational, technical, and compliance-related functions. These arrangements are subject to thorough due diligence, legally binding outsourcing agreements, data protection safeguards, and ongoing oversight to ensure business continuity, operational integrity, and compliance with VARA regulations. A detailed list of such service providers is provided in Appendix A: Outsourced Service Providers. This list is reviewed and updated periodically. The Company confirms that appropriate due diligence and contractual safeguards are in place to ensure compliance with regulatory and confidentiality requirements.

21. SIGNATURES

21.1 Acceptable Signatures. You agree that the Company may elect to rely on a signature that is transmitted, recorded or stored by any electronic, optical or similar means (including telecopy, imaging, photocopying, electronic mail, electronic data interchange, telegram or telex) as if it were executed physically with wet signatures. Such signatures may create legally binding contract under the UAE laws.

22. APPLICABLE LAW AND JURISDICTION

22.1 Applicable Law. This Agreement shall be governed by the laws applicable to the Emirate of Dubai United Arab Emirates.

22.2 Jurisdiction. In case of any disputes in relation to this Agreement or any Orders (including the execution and settlement thereof), you agree to submit to the exclusive jurisdiction of the Dubai Courts (excluding the DIFC courts).

23. MISCELLANEOUS

23.1 Assignment. This Agreement, or your rights and obligations hereunder, may not be transferred by you, but may be assigned by us without restriction. Any attempted transfer or assignment by you in violation hereof shall be null and void. This Agreement shall be binding and inure to the benefit of the parties hereto, our successors, and permitted assigns.

23.2 Third parties. A person who is not a party to this Agreement shall not have any rights to enforce any term of this Agreement.

23.3 Waiver. Failure by any Party to exercise or enforce any rights available to that Party or the giving of any forbearance, delay or indulgence by any Party shall not be construed as a waiver of that Party’s rights under this Agreement. No provision of this Agreement shall be waived unless such waiver is made in writing and signed by an authorised representative of the Party against which enforcement of the waiver is sought. A waiver shall not constitute a consent to, or waiver of any subsequent breach of any provision of the same or different nature.

23.4 Severability. If any provision of this Agreement is deemed unenforceable or illegal, the remaining provisions will continue in full force and effect.

23.5 Intellectual Property: Client agrees and acknowledges that the Company is the owner and/or authorised user of all trademarks, service marks, design marks, patents, copyrights, database rights and all other intellectual property appearing on or contained within the Platform, unless otherwise indicated. All information, text, material, graphics, software and advertisements on the Platform are the copyright of the Company, its suppliers and licensors, unless expressly indicated otherwise by the Company. Except as provided in this Agreement, the use of the Platform does not grant to the Client, any right, title, interest, or license to any such intellectual property accessed by the Client hereof. The Client unconditionally agrees that Client is not authorised to use any of the trademarks belonging to the Company without Company’s prior express written consent.

23.6 Entire Agreement. This Agreement (together with any documents referred to therein) constitutes the entire agreement between the parties and supersedes and extinguishes all previous agreements, promises, assurances, warranties, representations and understandings between them, whether written

or oral, relating to its subject matter. Upon You and the Company entering into this Agreement, the Company will share a digital copy of this Agreement with you at the email address provided by to you to the Company. You understand that apart from the digital copy of this Agreement which will be shared with you at the email address provided by to you to the Company, the Company will not provide you with an additional paper (non-electronic) copy of this Agreement unless you specifically request it by contacting us at the Customer Service number or email address below.

23.7 Force Majeure. We shall not be in breach of this Agreement nor liable for any loss you may suffer if we are prevented from providing Services, by reason of strikes, industrial action, failure of power supplies, failure of banking payment transmission or clearing systems (save insofar as we are legally liable), failure of telecommunications or other equipment, industrial dispute or other causes beyond our reasonable control.

Appendix A: Outsourced Service Providers

Pursuant to Section 20 of this Agreement and in accordance with applicable VARA requirements, the Company discloses below the third-party service providers engaged in the facilitation of Company’s Services.

Service Provider	Service Description	Entity Type
Fireblocks Ltd.	Non-custodial wallet infrastructure; generation and monitoring of Designated Client Virtual Asset Address	External third-party
Elliptic(under the service of Fireblocks Ltd.)	Blockchain analytics and AML transaction monitoring	External third-party
Notabene(under the service of Fireblocks Ltd.)	Compliance with travel rules and perform identity verification.	External third-party