# Welcome to Delos Legal Hub Welcome to the **Delos Legal Hub**, your centralized gateway to all of Delos Financial Group’s legal policies, disclosures, and governance frameworks. Whether you’re a new client seeking clarity on our terms of use, a partner reviewing our contractual standards, or a regulator auditing our governance framework, the Legal Hub provides transparent, easy-to-navigate documentation. All resources are available for download in PDF format, and each policy carries its last-updated date to help you track amendments over time. **Please review all information in this Hub carefully before entering into any contractual relationship with Delos.** If you have questions about any document or need further clarification, contact our Legal & Compliance team at and We’re committed to keeping you informed and protected at every step of your Delos experience. # Licensing Delos Financial Group maintains an array of licensing across the globe to support its activities. **Delos Financial LTD** is registered with FinCEN (Financial Crimes Enforcement Network) in the United States with MSB Registration Number: 31000282338107 MSB Activities: Dealer in foreign exchange, Issuer of money orders, Money transmitter, Other, Seller of money orders States of MSB Activities:\ Alabama, Alaska, American Samoa, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District Of Columbia, Federated States Of Micronesia, Florida, Georgia, Guam, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Marshall Islands, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Northern Mariana Islands, Ohio, Oklahoma, Oregon, Palau, Pennsylvania, Puerto Rico, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Virgin Islands, US, Washington, West Virginia, Wisconsin, Wyoming **Delos Financial LTD**, (formerly Hadoli Pay) a British Columbia corporation has been registered under RPAA with the Bank of Canada with ref. case number REG-3140 and duly registered as a Money Service Business with FINTRAC in Canada with MSB registration number M23425816 to perform the following activities: Foreign Exchange Dealing, Money Transferring, Dealing in Virtual Currencies, Payment Service Provision. **Delos Financial Limited** operates as a financial technology company, registered in the UK under company number 15208885 with its registered address at Formal House, 60 St. Georges Place, Cheltenham, Gloucestershire, England, GL50 3PN. It is important to note that Delos UK is a financial technology company providing financial technology platform services, and not a licensed money transmitter nor a bank.​ **Delos Financial ΜΟΝΟΠΡΟΣΩΠΗ Α.Ε.** (Delos Greece) is an independent entity and is not actively trading pending the issuance of its Electronic Money Institution license. # Legal Disclaimer Delos Financial Limited and its subsidiaries (collectively, “Delos”) are independent legal entities, each duly incorporated in its respective jurisdiction. The principal operating addresses for these entities are: * **Canada:** Delos Financial LTD, 255 5 Ave SW, Calgary, AB T2P 3G6 * **United Kingdom:** Delos Financial Limited, Formal House, 60 St. Georges Place, Cheltenham, Gloucestershire, England, GL50 3PN * **Greece:** Delos Financial ΜΟΝΟΠΡΟΣΩΠΗ A.Ε., Leof. El. Venizelou 238, Kallithea 176 75, Athens, Attica Delos provides financial technology platform services exclusively through contractual relationships with partner banks, custodians, and other financial institutions. Customer funds and assets are held directly by these partners, and Delos does not accept custody of, nor is it responsible for, such assets unless stated otherwise. Delos is under no obligation to proactively inform customers of this arrangement, though customers are free to inquire about the status or holding of their assets at any time. Delos makes no representations or warranties, express or implied, regarding the security, performance, or solvency of any partner institution. Under no circumstances shall Delos, its officers, directors, employees, or affiliates be liable for any direct, indirect, incidental, consequential, or punitive damages arising from the use of its services or from any actions or omissions of its partners. By accessing or using any Delos services, you acknowledge that you have read, understood, and agree to this disclaimer in its entirety. If you do not agree with the terms set forth above, please do not use Delos’s services. # Prohibited Activities Any corporates or individuals directly or indirectly involved in the below: #### 1. Illegal Drugs & Drug Paraphernalia * Illegal drugs * Substances designed to mimic illegal drugs * Equipment designed for making or using drugs #### 2. Fraudulent Identification * Fake references or ID-providing services #### 3. Telecommunications Abuse * Jamming devices * Other equipment designed to manipulate or disrupt telecommunications #### 4. Unlawful Violence Any business or organization that: * Engages in, encourages, promotes, or celebrates unlawful violence or physical harm to persons or property * Targets violence toward any group based on race, religion, disability, gender, sexual orientation, national origin, or other immutable characteristic #### 5. Unlawful Products & Services * Any product or service that violates applicable laws in the jurisdictions where it is offered or targeted #### 6. Intellectual Property Infringement * Unauthorized sale or distribution of music, movies, software, or other licensed materials * Counterfeit goods; illegally imported or exported products * Unauthorized sale of brand-name or designer items * Any other service or product that infringes trademarks, patents, copyrights, trade secrets, or privacy rights #### 7. Unfair, Predatory, or Deceptive Practices * Pyramid schemes * “Get rich quick” schemes, including: * Promises of high rewards with little effort or upfront work * Outrageous claims, deceptive or fake testimonials * High-pressure upselling or inducements without follow-through * No-value-added services (resale of services without added benefit; unauthorized resale of government offerings) * Predatory sales of online traffic or engagement * Negative-response marketing and telemarketing * Predatory mortgage consulting, lending, credit repair, and counseling * Predatory investment opportunities with no or low money down * Remote technical support scams; mugshot publication/pay-to-remove sites; essay mills; chain letters; door-to-door sales * Any other business Delos deems unfair, deceptive, or predatory #### 8. Adult Content & Services * Pornography or mature content (literature, imagery, media) depicting explicit acts * Prostitution, escorts, pay-per-view sexual services, sexual massages, adult live chats * Adult video stores; gentlemen’s clubs, topless bars, strip clubs * Online dating services #### 9. Certain Legal Services * Law firms collecting fees for non-legal service purposes (high AML risk) * Bankruptcy attorneys * Bail bond services #### 10. Firearms, Explosives & Dangerous Materials * Dual-use goods * Firearms, ammunition, gunpowder, weapons, fireworks, other explosives * Peptides, research chemicals, toxic, flammable, or radioactive materials * Direct sales of precious metals (evaluated case-by-case) #### 11. Unlicensed Gambling & Cash-Intensive Businesses * Unlicensed or unauthorized games of chance (including online gambling, sweepstakes, contests, fantasy sports for prize) * Sports forecasting or odds-making for prize * Lotteries (national lotteries evaluated case-by-case) * Bidding-fee auctions * Other cash-intensive operations #### 12. Cannabis & Marijuana * Cannabis products (including dispensaries and related businesses) #### 13. Sanctions & Licensing Violations * Unlicensed or unregistered financial institutions, crypto asset service providers, "buy now pay later" remittance or payment service providers * Entities or individuals subject to U.S. or other applicable sanctions * Customers or beneficial owners who are sanctioned * Shell banks or shell companies; companies formed by bearer shares (unless publicly traded on a recognized exchange) # Prohibited Jurisdictions > **Disclaimer:** Businesses and individuals from these jurisdictions are **prohibited** from using Delos banking services. *** #### Prohibited / Banned Jurisdictions * Abkhazia * Afghanistan * Barbados * Bolivia * Belarus * Botswana * Burkina Faso * Burundi * Cambodia * Central African Republic * Crimea * Cuba * Democratic Republic of the Congo * Donetsk People’s Republic (DNR) * Ghana * Guinea * Guinea-Bissau * Haiti * Iran * Iraq * Jordan * Kherson occupied areas * Kosovo * Kuwait * Liberia * Libya * Luhansk People’s Republic (LNR) * Mali * Morocco * Mozambique * Myanmar / Burma * Nagorno-Karabakh * Nepal * Nicaragua * North Korea / DPRK * Pakistan * Palestine * Papua New Guinea * Russia * Senegal * Somalia * South Ossetia * South Sudan * Sudan * Syria / Syrian Arab Republic * Tanzania * Transnistria * Trinidad & Tobago * Tunisia * Uganda * Ukraine * Vanuatu * Venezuela * Yemen * Zaporizhzhia occupied areas * Zimbabwe * Any other unrecognised / occupied territory *** # Business Risk Rating ### Eligibility Disclaimer > Eligibility criteria may vary on a case-by-case basis and are non-exhaustive. *** ### Low-Risk **Must be** a corporate in a “low-risk” country **AND** **not** involved in any of: * Cryptocurrency or cryptocurrency-adjacent businesses, or regular digital-currency transactions * I-Gaming * Forex/CFDs * MSBs / financial institutions processing downstream payments * High-risk countries or activities (see “Countries by Risk”) **Must not trigger** any of these red flags: * Newly established companies (≤ 12 months) without a solid business plan * Limited online presence * Operating in prohibited, medium- or higher-risk industries * Payments to high-risk jurisdictions * Other red flags identified via compliance controls or proof of address **May be considered** under the low-risk model (fees may vary): * Marketplaces * Crowdfunding / crowdlending platforms * Affiliate-marketing schemes * Embassies, consulates, diplomatic missions * Economic-citizenship / citizenship-by-investment programs * Scholarship programs (beneficiary ≠ educational institution) * Charities and non-profits * EU- or UK-regulated iGaming (and associated group companies) * EU-regulated CFD/Forex (and associated group companies) * Financial institutions and/or MiCA- or Tier-1-jurisdiction VASPs (operational payments only) * Financial institutions for B2C payouts and 1st-party wholesale FX > **Note:** Businesses outside the above jurisdictions may be assessed on a case-by-case basis—please inquire individually. *** ### Medium-Risk **Affiliated with medium-risk jurisdictions** and/or **involved in**: * Crypto exchanges or any VASP * Financial institutions (e.g., VC or investment funds; some exceptions apply) * Money service businesses / money transmitters * Offshore incorporations * Opaque ownership structures (nominee directors/shareholders) * Sweepstakes operators * Securities dealers * Higher-risk corporate service providers * Web3 companies with regular virtual-currency transactions * Market makers or liquidity providers * Newly established companies not qualifying as low risk * Limited online presence * Payments to high-risk countries * EU-/UK-regulated iGaming or CFD/Forex group companies * Charities, non-profits, scholarship programs (beneficiary ≠ educational institution) *** ### Higher-Risk **Affiliated with higher-risk countries** and/or **involved in**: * Offshore-regulated iGaming (and associated group companies) * Opaque ownership (nominee directors/shareholders) * Offshore-regulated CFD/Forex (and associated group companies) * Paying-agent companies * High-risk merchant processors * Adult-adjacent businesses (ultra-limited, board & correspondent-bank approval required) * Interactions with high-risk jurisdictions * Offshore banks or regulated money transmitters (alternative pricing may apply) * ICOs / IDOs * Nutraceuticals and supplements (excluding MLM) * Precious-metals trading * Economic-citizenship or citizenship-by-investment programs # High-Risk Jurisdictions > **Note:** This list will vary depending on the underlying correspondent bank and each individual use-case. > > \ > Certain fees and services are not guaranteed simply because a client falls into one category or the other; service availability is always subject to individual discussion. > > \ > “Restricted” means certain services may not be available to corporates/institutions in these jurisdictions. Please inquire individually. *** ### High-Risk Jurisdictions * Albania * Algeria * Angola * Armenia * Azerbaijan * Bulgaria * Cameroon * China * Côte d'Ivoire * Guatemala * Jamaica * Kazakhstan * Kenya * Kyrgyzstan * Laos * Lebanon * Moldova * Monaco * Namibia * Panama * Saudi Arabia * Serbia * Sri Lanka * Vietnam * Virgin Islands (UK) *** # Insurance Information Delos Financial Ltd is insured by Relm Insurance Ltd. under the SIGMAWEB3 Package Policy, policy number RILPCRMDOGLTEOCY144712026, with a total Policy Limit of Insurance of USD 2,000,000. | Cover | Insurance Amount | | ------------------------------------------------------------------ | -------------------------------------------------- | | Commercial General Liability | USD 1,000,000 | | Crime (incl. Employee Theft, Computer Fraud, Funds Transfer Fraud) | USD 1,000,000 per event / USD 2,000,000 aggregate | | Social Engineering Fraud | USD 100,000 | | Cyber and Technology Errors & Omissions | USD 1,000,000 | | Cyber Business Interruption | included in wider Cyber & Technology E\&O coverage | | Directors and Officers Liability | USD 1,000,000 | Policy period: June 24, 2026 to June 24, 2027. Territorial scope: Worldwide. If you would like to request details of any specific policy, please email us at: [**help@delos.financial**](mailto:help@delos.financial) # Transactional Account Agreement ### 1. Introduction Welcome to **Delos Financial LTD** (“Delos” or “the Company”). Delos is a British Columbia corporation registered as a Money Services Business (MSB) with FINTRAC (no. M23425816) since June 8, 2023 and is authorized to perform: * **Foreign Exchange Dealing** * **Money Transferring** * **Dealing in Virtual Currencies** * **Payment Service Provision** These Terms govern your use of our technology platform for banking, FX, and virtual-currency exchange services (“Services”). By accessing or using the Services, you agree to be bound by these Terms. *** ### 2. Company Overview 1. **Regulation:** Delos is regulated by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as an MSB. 2. **Intermediary Role:** Delos is *not* a bank. We operate as an intermediary between you and third-party banks, custodians, and financial institutions. We do not accept deposits, issue loans, or provide traditional banking services unless otherwise stated within specific terms of service. *** ### 3. Services and Terms #### 3.1 Scope of Services Delos (directly or via affiliates/third-party providers) will deliver the Services outlined in these Terms. #### 3.2 Platform & Account Services * We host, maintain, and support the platform. * You gain access to facilitate Payment Technology Services and Account Services under general and any applicable specific pricing terms. #### 3.3 Specific Payment-Technology Terms * Services governed by specific pricing terms inherit those terms. * Anything not covered by specific terms defaults to the general Terms herein. #### 3.4 Priority of Terms When general Terms conflict with a service’s specific pricing terms, the specific pricing terms prevail—except where expressly stated. #### 3.5 Acceptance & Updates * Using any service means you accept its terms. * We may update these Terms (and any specific pricing terms) via the platform; you must accept any update before continuing. #### 3.6 Service Modifications We may add/remove/modify Services or impose new conditions at any time. We’ll notify you of critical changes requiring your action; otherwise, we’re not liable for modifications made without notice. #### 3.7 Subcontracting Delos may subcontract its obligations to third-party service providers. #### 3.8 Jurisdictional Roll-Outs Features or updates may launch at different times by jurisdiction; we’re not liable for timing or availability variations. #### 3.9 Beta Releases * **Beta Releases** may contain incomplete or buggy features. * Use in production at your own risk; participation requires feedback and grants Delos full rights to any improvements. #### 3.10 Support General support is available via platform documentation or by emailing ****. #### 3.11 “As-Is” Disclaimer Services are provided “AS IS” and “AS AVAILABLE.” Aside from any express warranty, Delos disclaims all implied warranties (fitness for purpose, merchantability, non-infringement). #### 3.12 Limitation of Liability Delos (and affiliates) are not liable for losses arising from: * Your improper use * Unauthorized access or hacking * Service interruptions * Malware or bugs transmitted via Services * Data errors or omissions * Third-party content or conduct *** ### 4. Eligibility 1. **Business Entities:** Must be validly subsisting (corporations, partnerships, non-profits, etc.) *and* **not** conducting business or based in prohibited jurisdictions: . 2. **Natural Persons:** Must be of legal age, have contractual capacity, *and* **not** a resident of prohibited jurisdictions: 3. **Principal Status:** You represent you act in your own name, not on behalf of another, unless Delos agrees in writing. *** ### 5. Restrictions #### 5.1 Prohibited Actions You may not: * Bypass technical limits or access non-public systems * Act as a pass-through “service bureau” without adding value * Reverse-engineer the platform * Engage in illegal/fraudulent/deceptive acts * Disrupt Service operations or impair other users * Copy, republish, resell, or distribute the platform (unless expressly permitted) #### 5.2 Ongoing Compliance By using the platform, you acknowledge and warrant ongoing compliance with these restrictions. *** ### 6. Customer Responsibilities #### 6.1 General You alone are responsible for legal compliance in using the Services. #### 6.2 Specific Duties 1. **Due Diligence & Operating Procedures:** * Provide all information for onboarding, AML/KYC/KYB, sanctions screening, etc. * Vet recipients and intended use of funds. * Respond promptly to our information requests. 2. **Security & Fraud Policy:** * Adhere to Delos’s security/fraud policies and any updates (within 90 days of notice). 3. **Credentials:** * Protect your login credentials. You’re liable for all activity under your ID. Notify us immediately if compromised. 4. **Record-Keeping:** * We may retain transaction records and supporting KYC/KYB documentation. #### 6.3 Regulated Entities If you’re a regulated financial institution, you alone must file any SARs or similar regulatory reports. *** ### 7. Fees 1. **Payable Fees:** As specified in this agreement or, if not expressly agreed, our standard fee schedule applies. 2. **Payment Obligation:** You must pay all fees due, regardless of other provisions. 3. **Fee Changes:** We may revise fees at any time with 30 days’ notice for any service in use. 4. **Your Costs:** You cover all implementation/integration costs for Payment Technology Services. 5. **Non-Refundable:** All paid fees are non-refundable, except where a transaction is canceled before processing starts. 6. **Unpaid Accounts:** We may liquidate your assets to cover unpaid fees. *** ### 8. Term * **Initial Term:** One year from the Effective Date. * **Renewal:** Automatically renews for additional one-year terms unless properly terminated (see § 9). *** ### 9. Termination & Suspension #### 9.1 Service Changes We may modify, suspend, or discontinue any Service for regulatory, technical, or third-party reasons. #### 9.2 Voluntary Termination Either party may terminate for any reason with ≥ 20 business days’ written notice. #### 9.3 Post-Termination Obligations * We’ll finish all authorized transactions. * You’ll pay fees for completed transactions. * We’ll return remaining funds (less fees) within 10 business days, once you provide valid receiving instructions. #### 9.4 Suspension Rights We may immediately suspend Services if: * You violate law or these Terms * Provision of Services risks non-compliance or legal breach * We’re directed by regulators or third parties * You fail to update needed software * We suspect fraud, credit risk, DDoS/activity threats, or other unlawful activity #### 9.5 Reinstatement We may, at our discretion, reinstate Services once issues are resolved to our satisfaction. #### 9.6 Survival Clauses naturally surviving termination (confidentiality, indemnification, limitation of liability, governing law) remain in effect. *** ### 10. Dispute Resolution 1. **Negotiation:** Parties will attempt good-faith negotiation for 30 days. 2. **Arbitration:** If unresolved, disputes are finally settled by binding arbitration in Vancouver, under ICDR Canada rules, by a single English-speaking arbitrator. 3. **Governing Law:** British Columbia law (no conflict-of-laws principles). *** ### 11. Confidentiality 1. **Obligation:** Both parties will keep each other’s Confidential Information secret. 2. **Exceptions:** Excludes information that (a) is public through no breach; (b) received lawfully from third parties; (c) already known; or (d) independently developed. *** ### 12. Intellectual Property 1. **Ownership:** Delos (or its licensors) retains all IP in the platform, Services, software, and documentation. 2. **License:** You receive a non-exclusive, non-transferable, revocable right to use the platform solely for business purposes under these Terms. 3. **Feedback:** We may use any feedback you provide without obligation. *** ### 13. Data Protection 1. **Collection & Use:** We collect/use your data per our Privacy Policy; you consent and must comply with data-protection laws. 2. **Security:** We implement reasonable safeguards but cannot guarantee absolute security. 3. **Breach Notification:** We’ll promptly notify you of any data breach affecting your information. *** ### 14. Use of Digital Assets 1. **Blockchain Independence:** We do not control blockchains or markets; we disclaim liability for trading losses or incorrect-wallet transfers. 2. **Segregation:** Your digital assets are held separately by custodians and not on Delos’s balance sheet. 3. **Regulatory Scope:** We are not subject to MiCAR or UK FCA consumer-duty rules. *** ### 15. Account Management 1. **Restrictions:** We may decline, freeze, or reverse transactions or access to protect you, Delos, or comply with law (e.g., inactivity, suspected fraud). 2. **Replacement Accounts:** We may move your account to another institution for security. 3. **Third-Party Services:** Direct account services are provided by the designated institution; Delos is not liable for them. 4. **Intermediaries:** Funds may be held in custodial or direct accounts at approved institutions. 5. **Custodial vs. Direct Accounts:** * **Custodial:** Held by a licensed custodian in a notional account. * **Direct:** You enter into agreements with the institution and authorize Delos as agent. *** ### 16. Foreign Currency Transactions 1. **FX Payments:** We calculate required local-currency funds (including conversion rates and fees) and may route through intermediaries for best execution. 2. **Refunds:** If a payment fails, you may (a) request fund recovery, or (b) redirect to another recipient—fees apply. 3. **Currency-Conversion Refunds:** Refunds reverse FX at the prevailing rate; conversion fees apply. *** ### 17. Tax Reporting Obligations 1. **Compliance:** You provide documentation to help us fulfill any reporting requirements. 2. **Withholding:** We may withhold and remit taxes as required. 3. **Your Liability:** You are responsible for determining and reporting your own tax liabilities. 4. **Notification:** You must inform us of changes to your tax status. 5. **No Interest:** No interest is paid on held funds. *** ### 18. Reversals & Account Numbers 1. **Reversals:** You may request reversal of erroneous/duplicate transactions; we’ll make reasonable efforts under law. 2. **Wire-Transfer Details:** We provide the account details but funds become available only after receipt. 3. **Chargebacks:** If a wire transfer is reversed, we may debit your account; refunded funds return to the originator’s bank. *** ### 19. Access & Support 1. **Portals:** Access via [app.delos.financial](https://app.delos.financial) or [delos-baas.com](https://delos-baas.com). 2. **Response Times:** * Critical issues: 1 hr (24/7) * Medium issues: 8 hrs (business hours) * Low issues: 24 hrs (business hours) 3. **Exclusions:** Downtime for maintenance, third-party outages, or customer-requested interruptions do not count. 4. **Outage Measurement:** We use our own procedures; third-party tests aren’t recognized. 5. **Maintenance:** Scheduled ≤ 24 hrs/month; emergency maintenance with 24 hrs’ notice when possible. *** ### 20. Payment of Fees 1. **Included Fees:** Our quotes include all Delos-imposed fees; you cover any additional third-party or intermediary fees. 2. **Confiscation:** We’re not liable if intermediaries or authorities legally confiscate funds. *** ### 21. Miscellaneous 1. **Entire Agreement:** These Terms (and referenced documents) are the complete agreement, superseding prior agreements. 2. **Amendments:** We may modify at any time; your continued use = acceptance. 3. **Assignment:** You may not transfer your rights/obligations without our consent; we may assign freely provided your rights aren’t diminished. 4. **Waiver:** No waiver of any provision constitutes a further or continuing waiver. 5. **Severability:** If any clause is unenforceable, the remainder stays in effect; the invalid clause is revised minimally to be enforceable. 6. **Force Majeure:** No liability for delays/failures due to events beyond our control (acts of God, war, strikes, government action, etc.). 7. **Notices:** Must be in writing via personal delivery, certified mail, or email to addresses on file. 8. **Regulatory Info:** See [delos-banking.com/legal](https://www.delos-banking.com/legal). 9. **API Changes:** We’ll notify you of public API changes within 30 days. 10. **Contact Info:** You’re responsible for keeping your contact details up to date. *** ### 22. Additional Disclaimers **22.1 Partner Institutions**\ Delos makes no representations or warranties, express or implied, regarding the security, performance, solvency, regulatory compliance, or operational integrity of any partner institution, bank, custodian, or third-party service provider engaged in connection with the Services. **22.2 No Warranties**\ Under no circumstances shall Delos, its officers, directors, employees, agents, or affiliates be liable for any direct, indirect, incidental, special, consequential, punitive, or exemplary damages (including, but not limited to, loss of profits, goodwill, use, data, or other intangible losses) arising out of or in connection with: 1. Your use of or inability to use the Services; 2. Any actions or omissions of any partner institution or third-party provider; 3. Any interruption, suspension, or termination of access to the Services; 4. Any errors, omissions, or inaccuracies in any data or content provided through the Services; 5. Any unauthorized access, hacking, data breach, or other security event. *** ### 23. Indemnification **23.1 Your Indemnity Obligation**\ You shall defend, indemnify and hold harmless Delos, its parent and affiliate companies, and their respective officers, directors, employees, agents and representatives (each, an “Indemnitee”) from and against any and all losses, liabilities, damages, fines, penalties, settlement amounts, costs and expenses (including reasonable attorneys’ fees and court costs) (collectively, “Losses”) incurred by any Indemnitee arising out of or relating to: * Your breach of these Terms; * Your negligent or willful acts or omissions; * Your violation of any applicable law, regulation or third-party right; * Any claim by a third party (including any partner institution) related to your use of the Services or your actions or omissions in connection therewith. **23.2 Digital Assets Indemnity**\ Without limiting the foregoing, you specifically agree to indemnify and hold harmless Delos and the other Indemnitees against any Losses arising from or relating to: * Any loss, theft, mis-transfer, or unauthorized use of digital assets that you instruct Delos (or its custodians) to custody, transfer or trade; * Inaccurate wallet addresses, blockchain network congestion, “gas” or transaction-fee fluctuations, or any blockchain-specific risks; * Any claim that your instructions or transactions with digital assets infringe or misappropriate a third party’s intellectual property or rights. **23.3 Procedure**\ Delos will: (a) promptly notify you in writing of any claim for which it seeks indemnity; (b) give you sole control of the defense and any settlement negotiations; and (c) reasonably cooperate at your expense. You may not settle any claim that imposes any obligation or admission by Delos without its prior written consent. *** ### 24. Insurance **24.1 Coverage Requirement**\ You shall maintain, at your own expense, commercially reasonable insurance coverage (including, as applicable, cyber-liability, errors & omissions, and directors & officers insurance) with insurers rated A– or better by A.M. Best, in amounts sufficient to cover your liabilities under these Terms. Upon request, you will provide Delos with certificates of insurance. *** ### 25. Group Entities These Terms and all of the provisions contained herein apply equally to and may be enforced by any member of the Delos Financial Group, including but not limited to: * **Canada:** Delos Financial LTD, 255 5 Ave SW, Calgary, AB T2P 3G6 * **United Kingdom:** Delos Financial Limited, Formal House, 60 St. Georges Place, Cheltenham, Gloucestershire, England, GL50 3PN * **Greece:** Delos Financial ΜΟΝΟΠΡΟΣΩΠΗ A.Ε., Leof. El. Venizelou 238, Kallithea 176 75, Athens, Attica *** ### 26. Acknowledgment By signing up for or using the Services, you confirm you have read, understood, and agree to these Terms and Conditions. *** **Delos Financial LTD**\ 205 5 Ave SW, Calgary, AB T2P 3L6, Canada\ Email: | # Platform Agreement (BaaS) ### 1. Background and Purpose 1.1 **Overview.** Delos operates a licensed technology Platform enabling the creation and management of fiat and digital-asset accounts, payment initiation and receipt, currency exchange and integration with independent custodians (the “Platform Services”). 1.2 **Objective.** Platform Partner desires to embed and offer these Platform Services to its own customers (“End Users”). This Agreement sets the complete terms under which Delos will provide, and Platform Partner will access and resell, the Platform Services. 1.3 **Relationship of the Parties.** Delos and Platform Partner agree that Platform Partner acts as an independent reseller; nothing herein creates a partnership, joint venture, fiduciary, employment, or agency relationship. *** ### 2. Definitions * **“Account”**\ A ledger entry representing fiat or digital-asset holdings maintained by Delos or its custodians for Platform Partner or an End User. * **“API Integration”**\ Programmatic access via Delos’s API, as described in the Documentation. * **“White Label Integration”**\ A dedicated, non-transferable instance of Delos’s user interface and backend, re-branded for Platform Partner but fully managed and hosted by Delos. * **“Authorized Users”**\ Platform Partner’s employees, contractors or agents permitted to access the Platform Services. * **“Chargeback”**\ Any reversal, refund, reclamation or other debit initiated by an End User’s financial institution, payment network or similar entity. * **“Commission Account”**\ The same pool as the Reserve Account, which also collects all commissions, fees and revenue due to Platform Partner under Section 7. * **“Confidential Information”**\ Non-public technical, business or financial information disclosed by one Party to the other under this Agreement. * **“End User”**\ Any individual or entity that opens or uses an Account or otherwise interacts with the Platform Services through Platform Partner’s front-end. * **“Fees”**\ All amounts owed by Platform Partner to Delos, including subscription, transaction, conversion, professional-services, commission splits, and other charges. * **“Foreign Exchange Conversion”**\ The process by which Delos converts one fiat currency into another using rates set by Delos, including any margins. * **“KYC/AML”**\ The collection, verification, screening, and retention of End User identity data for anti-money-laundering and sanctions compliance. * **“Platform Services”**\ Collectively, the Platform infrastructure, APIs, White Label instances, support, Professional Services, account and payment functions, currency conversion, custody integrations, reporting tools and any enhancements provided by Delos. * **“Professional Services”**\ Advisory, integration, customization, testing, training, data-migration or other technical services provided by Delos at Platform Partner’s request. * **“Reserve Account”**\ A cash deposit held by Delos on behalf of Platform Partner to secure potential Chargebacks, overdrafts, indemnity claims, penalties or other obligations. * **“Service Levels”**\ The availability and support performance targets set forth in Section 6. * **“Third-Party Custodians”**\ Licensed custodial institutions engaged by Delos to hold, safeguard and settle digital-asset holdings. *** ### 3. Grant of License & Access Rights 3.1 **License.** Delos grants Platform Partner a limited, revocable, non-exclusive, non-transferable right to access and use the Platform Services solely to offer them to End Users in compliance with this Agreement. 3.2 **Integration Options.** Platform Partner may choose, for each deployment, either: * **API Integration:** Direct programmatic access via API keys and webhooks; or * **White Label Integration:** A self-contained, non-transferable portal instance bearing Platform Partner’s branding, hosted and fully managed by Delos. 3.3 **White Label Terms.** White Label instances remain Delos’s property, receive the same upgrades and patches as the core Platform, and may not be sub-licensed, copied, or re-sold. Delos retains complete operational control, including user-management and security configuration. 3.4 **Access Credentials.** Delos will issue API keys, login credentials and certificates. Platform Partner is responsible for safeguarding credentials and all actions under them. 3.5 **Restrictions.** Platform Partner shall not: * Reverse-engineer, decompile or disassemble any Delos software; * Bypass security controls or usage limits; * Use the Platform to offer hosting or consulting to third parties outside this Agreement; * Frame or mirror any portion of Delos’s interfaces; * Permit unauthorized third-party access. 3.6 **Reservation of Rights.** All rights not expressly granted are reserved by Delos. Delos may modify, suspend or discontinue any portion of the Platform Services at any time without liability. *** ### 4. Delivery of Platform Services 4.1 **Account Lifecycle.** Delos will provide APIs or White Label UIs to open, close and manage Accounts; load, transfer and withdraw funds; and report balances and transaction histories. 4.2 **Payments.** Platform Partner may initiate domestic and cross-border payments via supported rails. Delos executes through banking and custodian networks and provides real-time status updates. 4.3 **Foreign Exchange.** Delos performs currency conversions at its system-published rates, inclusive of margins retained by Delos. 4.4 **Digital-Asset Custody.** Delos forwards custody instructions to Third-Party Custodians unless otherwise specified. Delos disclaims any warranty regarding custodians’ solvency, security or performance. 4.5 **Notifications & Reporting.** Delos issues webhooks for transaction events and dashboards, CSV exports, ledger queries, Reserve/Commission-balance alerts and risk-monitoring feeds. 4.6 **Professional Services.** At Partner’s request, Delos will perform integration, customization, training or other work, billed per Delos’s then-current fee schedule. *** ### 5. Platform Partner Responsibilities 5.1 **User Interface & Branding.** Platform Partner’s offering must clearly credit Delos as the service provider, conform to Delos’s brand guidelines, and display all disclaimers and limitation-of-liability notices mandated by Delos. 5.2 **End User Terms.** Partner shall ensure every End User consents to terms that: * Name Delos as third-party beneficiary; * Authorize Delos to process End User data under its Privacy Policy; * Include Delos’s disclaimer, limitation of liability and indemnity clauses. **5.3 Onboarding & KYC/AML.**\ Platform Partner shall collect all identity and verification documentation for each End User, including government-issued IDs, proof of address, and any other data required for anti-money-laundering, counter-terrorist financing, and sanctions-screening purposes. Platform Partner will perform preliminary risk scoring and sanctions checks, then deliver the complete KYC/AML/“Know-Your-Business” (KYC/B) dossier to Delos within 24 hours of collection. **Delos does not rely on Partner’s KYC;** Delos will itself execute final identity verification, risk assessment, and End User onboarding for every End User—no reliance or “nested” KYC (i.e., Partner A relying on Partner B’s KYC) is permitted. 5.4 **Security & Incident Response.** Platform Partner shall: * Use TLS 1.2+ and AES-256 encryption; * Implement multi-factor authentication for all Authorized Users; * Keep audit logs of access and configuration changes; * Notify Delos of any breach or unauthorized access within 48 hours; * Cooperate fully in any incident investigation. 5.5 **Reserve & Commission Account.** Platform Partner will fund and maintain a combined Reserve/Commission Account, ensuring a minimum balance as set by Delos. This account holds: * Funds to cover Chargebacks, overdrafts, indemnity obligations, and fees; * All transaction commissions, revenue shares and Platform Partner commissions.\ Delos may, at its sole discretion, liquidate any assets in this account—or in any End User account—to settle overdue Fees or indemnity claims. 5.6 **Regulatory Cooperation.** Platform Partner will support any audits, examinations or investigations by regulators or Delos, providing records, systems access and personnel as reasonably requested. 5.7 **Compliance with Laws.** Platform Partner shall comply with all applicable laws, including data-privacy, payments-systems, anti-money-laundering, sanctions, tax and consumer protection regulations. *** ### 6. Service Levels & Support 6.1 **Availability Commitment.** Delos will use commercially reasonable efforts to maintain 99.5% monthly uptime, excluding scheduled maintenance, force-majeure events, and Platform Partner-caused issues. 6.2 **Support Response Times.** * **Critical:** 1-hour response, 4-hour resolution or workaround. * **High:** 4-hour response, 24-hour resolution. * **Medium:** 1 business-day response, 3-business-day resolution. * **Low:** 2 business-day response, 5-business-day resolution. 6.3 **No Service Credits.** Service levels are targets only; Delos is not liable for missed targets and will not issue credits. 6.4 **Maintenance Windows.** Routine maintenance occurs 11 pm–4 am Calgary time with 48 hours’ notice; emergency maintenance may occur without notice. *** ### 7. Fees, Invoicing & Payment 7.1 **Fee Components.** Platform Partner shall pay: * Subscription Fees for Platform access; * Transaction Fees per payment or currency conversion; * Professional Services Fees for any custom work; * Commission splits held in Commission Account; * Reserve Account contributions and any necessary top-ups. 7.2 **Invoicing & Due Date.** Delos will invoice monthly in arrears. All amounts are due within seven (7) days of invoice date. 7.3 **Late Payment & Liquidation.** Overdue amounts accrue interest at 1.5% per month (or highest lawful rate). Delos may suspend Services and/or liquidate assets in the Reserve/Commission Account or any End User account to satisfy unpaid Fees. 7.4 **Taxes.** All Fees exclude VAT/GST, sales tax and withholding taxes. Platform Partner is responsible for remitting all such taxes and grossing up payments to ensure Delos receives full invoiced amounts. 7.5 **Set-Off.** Delos may offset any amounts owed by Platform Partner against amounts in the Reserve/Commission Account or any credits otherwise due. *** ### 8. Confidentiality 8.1 **Non-Disclosure.** Each Party will keep the other’s Confidential Information in strict confidence, use it solely under this Agreement, and disclose it only to Authorized Users bound by confidentiality obligations. 8.2 **Permitted Disclosure.** A Party may disclose Confidential Information if compelled by law, provided it gives prompt notice to the disclosing Party and cooperates in seeking protective measures. 8.3 **Return or Destruction.** Upon termination, each Party will return or destroy all Confidential Information of the other and certify in writing that it has done so. *** ### 9. Data Privacy & Security 9.1 **Roles.** Platform Partner is the data controller of End User personal data; Delos is the processor under applicable privacy laws. 9.2 **Processor Obligations.** Delos will: * Process data only on documented instructions; * Maintain appropriate technical and organizational safeguards; * Notify Platform Partner of personal-data breaches without undue delay; * Assist with data-subject access, erasure and portability requests. 9.3 **Cross-Border Transfers.** Any personal data transferred outside Canada will comply with lawful transfer mechanisms. 9.4 **Retention & Deletion.** Delos retains personal data only as needed to provide the Platform Services or to comply with legal obligations, then securely deletes or anonymizes it. *** ### 10. Intellectual Property 10.1 **Delos IP.** Delos retains all rights in the Platform Services, APIs, software, Documentation, trademarks, and any enhancements or derivative works. 10.2 **Partner IP.** Platform Partner retains rights in its trademarks, front-end code, branding and materials. 10.3 **Feedback License.** Platform Partner grants Delos a perpetual, irrevocable, royalty-free license to use any feedback to improve the Platform Services. *** ### 11. Indemnification 11.1 **Partner Indemnity.** Platform Partner will indemnify, defend and hold harmless Delos and its officers, directors, employees, agents and affiliates (“Delos Indemnitees”) from all claims, liabilities, losses, damages, costs and expenses (including reasonable attorneys’ fees) arising out of: * Platform Partner’s or End Users’ breach of this Agreement or negligence, fraud or willful misconduct; * Platform Partner’s violation of applicable laws; * Claims that Platform Partner’s materials or End User data infringe third-party rights; * Chargebacks, refunds or reversals caused by Platform Partner’s operations. 11.2 **Digital-Asset Indemnity.** Without limiting 11.1, Platform Partner also indemnifies for losses arising from incorrect wallet addresses, blockchain-network events, gas-fee fluctuations, unauthorized transfers or any custody-related risks. 11.3 **Procedure.** Delos will notify Platform Partner promptly of any indemnified claim, tender the defense, and cooperate at Platform Partner’s expense. No settlement imposing obligations on Delos shall be made without Delos’s written consent. *** ### 12. Disclaimers & Limitation of Liability 12.1 **Warranty Disclaimer.** THE PLATFORM SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE,” WITHOUT ANY WARRANTY, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE OR NON-INFRINGEMENT. 12.2 **No Liability.** UNDER NO CIRCUMSTANCES SHALL DELOS OR ANY DELOS INDEMNITEE BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE OR CONSEQUENTIAL DAMAGES, INCLUDING LOST PROFITS OR DATA, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. 12.3 **Aggregate Cap.** EXCEPT FOR PLATFORM PARTNER’S INDEMNITY OBLIGATIONS, PAYMENT OBLIGATIONS OR BREACH OF CONFIDENTIALITY OR DATA-PROTECTION OBLIGATIONS, AND GROSS NEGLIGENCE OR WILLFUL MISCONDUCT, DELOS’S AGGREGATE LIABILITY SHALL NOT EXCEED THE TOTAL FEES PAID BY PLATFORM PARTNER IN THE 3 MONTHS PRECEDING THE CLAIM. 12.4 **Absolute Indemnity.** PLATFORM PARTNER EXPRESSLY AGREES TO INDEMNIFY AND HOLD HARMLESS DELOS FOR ANY AND ALL LOSSES FOR ANY REASON WHATSOEVER. *** ### 13. Term & Termination 13.1 **Term.** Two-year Initial Term, auto-renewing for one-year periods unless ninety (90) days’ prior written notice is given. 13.2 **Termination for Cause.** Immediate termination if a material breach is uncured within thirty (30) days of notice, insolvency, bankruptcy proceedings or fraud. 13.3 **Suspension.** Delos may suspend Services instantly if illegal, fraudulent or abusive activity is detected or if Platform Partner breaches security obligations. 13.4 **Effect of Termination.** Upon termination: * Platform Partner pays all accrued Fees and expenses; * Delos may liquidate the Reserve/Commission Account to settle obligations; * Return or destroy all Confidential Information; * Sections 1, 2, 8, 9, 10, 11, 12, 13.4, 14, 15, 16, 17, 18 and 19 survive. *** ### 14. Audit Rights Delos may audit Platform Partner’s compliance once per year with thirty (30) days’ notice during business hours; Partner shall remedy any deficiencies within fifteen (15) days. *** ### 15. Group Entities This Agreement may be enforced by Delos Financial LTD or any Delos affiliate, including: * Delos Financial LTD (Canada) * Delos Financial Limited (UK) * Delos Financial ΜΟΝΟΠΡΟΣΩΠΗ A.Ε. (Greece) *** ### 16. Governing Law & Dispute Resolution 16.1 **Governing Law.** British Columbia law governs, without conflict-of-law rules. 16.2 **Good-Faith Negotiation.** Parties will attempt to resolve disputes by senior-management discussions for thirty (30) days. 16.3 **Arbitration.** Unresolved disputes go to binding arbitration in Vancouver under Canadian Arbitration Association rules, English language, single arbitrator. *** ### 17. Force Majeure Neither Party is liable for delays due to events beyond its control (acts of God, war, strikes, pandemics, government orders, third-party outages). Affected Party shall notify the other and mitigate impacts promptly. *** ### 18. Assignment Platform Partner may not assign without Delos’s consent; Delos may assign to any affiliate or in connection with a sale or merger. *** ### 19. Notices All notices must be in writing, sent by certified mail, courier or email with receipt confirmation, to the addresses above or as updated in writing. *** ### 20. Miscellaneous 20.1 **Amendments.** Written and signed by both Parties.\ 20.2 **Waiver.** No delay or failure to enforce any right constitutes a waiver.\ 20.3 **Severability.** Invalid provisions are reformed; remainder stays in effect.\ 20.4 **Entire Agreement.** This document is the complete agreement, superseding all prior understandings. 20.5 **Transactional Account Agreement Applicability**\ Notwithstanding any other provision of this Agreement, the following accounts maintained with Delos are governed by, and subject to all terms and conditions of, Delos’s standard Main Account Terms and Conditions (the “Transactional Account Agreement”): 1. Platform Partner’s Commission/Reserve Account; 2. Platform Partner’s own Transactional Account(s) with Delos; and 3. All End User Accounts opened or maintained under this Agreement. Each such account shall at all times adhere to the rights, obligations, fees, limits, indemnities and liabilities set forth in the Transactional Account Agreement. # Privacy Policy **Covers the following entities** * **Canada:** Delos Financial LTD, 255 5 Ave SW, Calgary, AB T2P 3G6 * **United Kingdom:** Delos Financial Limited, Formal House, 60 St. Georges Place, Cheltenham, Gloucestershire, England, GL50 3PN * **Greece:** Delos Financial ΜΟΝΟΠΡΟΣΩΠΗ A.Ε., Leof. El. Venizelou 238, Kallithea 176 75, Athens, Attica **Last Updated:** 10 Oct 2025\ **Last Reviewed:** 25 Jun 2025\ **Next Review:** 25 Jun 2026 Delos Financial Group (“Delos”, “we”, “us”, “our”) is committed to protecting the privacy of individuals whose personal data we process. This Policy explains what personal data we collect, why we process it, how we protect it, your rights, and how to contact us. *** ### Global Privacy Notice (short summary) This Global Privacy Notice summarises the key privacy information you need when interacting with Delos Financial Group: * **Controller:** Delos Financial Group acts as the data controller for the personal data described in this policy. * **What we collect:** identity, contact, financial, authentication and device/usage data necessary to provide, secure and improve our services. * **Why we process:** to perform contracts, meet legal and regulatory obligations (including AML/KYC), prevent fraud, maintain security, and for legitimate business interests such as improving services — or with consent where required. * **Sharing:** we share data with trusted service providers, regulators where required, and in corporate transactions. We do not sell personal data for marketing. * **Transfers:** personal data may be transferred internationally; we apply appropriate safeguards (contractual safeguards, SCCs or equivalent). * **Your rights:** access, correction, deletion, restriction, objection, portability, withdraw consent and complaint to a supervisory authority where applicable. * **Security & retention:** we apply encryption, access controls and retention limits aligned to legal requirements. * **Contact:** — use this address to exercise rights, ask questions or raise concerns. For more detail on each item below, see the full policy sections that follow. *** ### 1. Data controller & contact Delos Financial Group (each entity above) is the data controller for personal data processed in connection with the services provided by the Group entities.\ **Data Protection Officer (DPO) / privacy contact:** *** ### 2. Information we collect We collect categories of personal data necessary to provide and improve our services, including (examples): * **Identifying information:** name, date of birth, national ID. * **Contact information:** postal address, email, phone. * **Financial information:** bank account details, transaction history. * **Authentication data:** passwords, 2FA credentials (stored securely). * **Usage & device data:** IP address, device fingerprints, logs, cookies. * **Customer support and case notes.** We collect this information from you, from your interactions with our services, and from third parties (e.g., identity verification providers, payment processors, partners) where permitted. *** ### 3. Lawful bases for processing We rely on lawful bases that apply depending on context, such as: performance of a contract; compliance with legal obligations (e.g., AML/KYC requirements); your consent where required; and our legitimate interests (e.g., fraud prevention, improving services), balanced against your rights. *** ### 4. How we use your information We use personal data to: deliver account and payment services; verify identity and comply with AML/KYC and sanctions rules; operate and secure our products; provide customer support; detect and prevent fraud; perform analytics and improve our services; and meet legal or regulatory obligations. *** ### 5. Sharing & processors We do not sell personal data for third-party marketing. We share data with: service providers and processors (e.g., identity verification, payment, cloud hosting), regulators and law enforcement when required by law, and in corporate transactions (with safeguards). All processors are contractually bound to protect personal data and only process it per our instructions. *** ### 6. International transfers & safeguards Personal data may be processed or stored in countries outside the EEA/UK/Canada (including the US). When data is transferred internationally we apply appropriate safeguards (e.g., EU Standard Contractual Clauses, contractual commitments, binding safeguards) or other lawful transfer mechanisms, and we document transfer risk assessments. *** ### 7. Data retention We retain personal data only as long as necessary to fulfil the purpose for which it was collected, to comply with legal obligations (for example AML/record-keeping laws) and to resolve disputes. Retention periods are documented and aligned with our Document Retention Policy. *** ### 8. Data security We use technical and organisational measures to protect personal data including encryption in transit and at rest, access controls, keys managed via cloud KMS, monitoring and logging, regular security assessments, and incident response processes. *** ### 9. Cookies & tracking We use cookies and similar technologies to operate our services, remember preferences, secure accounts and for analytics. Where required by law we will obtain consent. You can manage cookie preferences via your browser or the preferences tools we provide. *** ### 10. Children Our services are not directed at children. We do not knowingly collect personal data from children under applicable age thresholds. If we become aware that we have collected such data we will delete it in accordance with applicable law. *** ### 11. Your rights — quick summary Subject to applicable law, you may have the right to: * Access the personal data we hold about you. * Request correction or completion of inaccurate personal data. * Request deletion/erasure where permitted. * Request restriction of processing. * Object to processing (including profiling) where grounds exist. * Request data portability (receive a copy in machine-readable format). * Withdraw consent where processing is based on consent. * Lodge a complaint with a supervisory authority (see jurisdictional notices below). To exercise rights: contact . We will verify requests and respond within applicable legal timescales. *** ### 12. Privacy notices by jurisdiction #### GDPR Notice (EU / EEA / UK) If you are an EU/EEA or UK data subject, the GDPR (or UK GDPR) may apply to processing by Delos. You have all rights described in Section 11. Where we rely on legitimate interests we will document and balance those interests; where we rely on consent you may withdraw consent at any time without affecting processing lawfully carried out before withdrawal. You have the right to lodge a complaint with your local supervisory authority (for example the Information Commissioner’s Office (ICO) in the UK or the relevant national authority in the EU). #### PIPEDA Notice (Canada) If your personal data is processed under Canadian jurisdiction, PIPEDA and applicable provincial privacy laws govern processing. We rely on consent, contract performance or legal obligations as the basis for processing. You can withhold or withdraw consent (subject to legal or contractual restrictions) and request access or correction of your personal information. If you have a privacy complaint that we cannot resolve, you may contact the Office of the Privacy Commissioner of Canada (OPC). #### United States notice (overview / state law) There is no single U.S. federal privacy law covering all personal data; certain state laws (e.g., California CCPA/CPRA) may afford additional rights to residents (such as rights to know, delete, and limit sale/sharing). Where applicable state law provides specific rights, we will honour those rights. We do not “sell” personal data for purposes of consumer protection laws. To exercise state-specific rights, or for more information, contact . *** ### 13. Automated decision-making & profiling We may use automated tools for identity verification, fraud detection and risk scoring. Where automated decision-making has a legal or similarly significant effect, we provide information about the logic involved, the meaning, and the possible consequences, and offer a way to request human review where required by law. *** ### 14. Breach notification In the event of a personal data breach that creates a risk to your rights and freedoms, we will follow our incident response procedures and notify affected individuals and regulators as required by applicable law without undue delay. *** ### 15. How to exercise your rights or complain * **Contact (DPO):** * **Postal:** use the relevant entity address at top of this policy. * If you are not satisfied with our response you may lodge a complaint with the relevant supervisory authority in your jurisdiction (e.g., ICO in the UK, OPC in Canada, or the relevant EU Member State authority). *** ### 16. Changes to this policy We may update this Policy from time to time. We will publish the updated policy with a revised “Last Updated” date and, where required by law, notify you of material changes. # Complaints Policy **Delos Financial Group**\ *Covers the following entities:* * **Canada:** Delos Financial LTD, 255 5 Ave SW, Calgary, AB T2P 3G6 * **United Kingdom:** Delos Financial Limited, Formal House, 60 St. Georges Place, Cheltenham, Gloucestershire, England, GL50 3PN * **Greece:** Delos Financial ΜΟΝΟΠΡΟΣΩΠΗ A.Ε., Leof. El. Venizelou 238, Kallithea 176 75, Athens, Attica **Last Updated:** 25th June 2025\ **Effective Date:** 25th June 2025\ **Next Review:** 25th June 2026 *** ### 1. Purpose To ensure that all complaints from customers or other stakeholders are handled promptly, fairly, and consistently across all Delos Financial Group entities, and that insights gained drive continuous improvement. *** ### 2. Scope Applies to any expression of dissatisfaction—verbal or written—regarding products, services, policies, or staff conduct at any Delos Financial Group entity. *** ### 3. Definitions * **Complaint:** An expression of dissatisfaction about any aspect of Delos Financial Group’s operations. * **Complainant:** The individual or organization making the complaint. * **Complaint Handler:** The person or team assigned to address and resolve the complaint. *** ### 4. Principles 1. **Accessibility:** Complaints may be submitted via email, online form, phone, or postal mail. 2. **Fairness:** All complaints are assessed objectively and without bias. 3. **Transparency:** We communicate clearly about process steps and timeframes. 4. **Confidentiality:** Personal data and case details are protected and shared only on a need-to-know basis. 5. **Accountability:** We acknowledge mistakes, take corrective action, and apply lessons learned. *** ### 5. How to Submit a Complaint * **Email:** * **Online Form:** delos-banking.com/complaints * **Phone:** +30 698 927 4199 (Mon–Fri, 10:00–18:00 GMT+3) * **Postal Mail:**\ Delos Financial LTD\ 255 5 Ave SW\ Calgary, AB T2P 3G6\ Canada **Please include:** * Your full name and contact details * Entity or service concerned * Date and description of the issue * Account or reference number (if available) * Desired resolution *** ### 6. Complaint Handling Process 1. **Acknowledgement:** We will acknowledge receipt within **2 business days**, identifying the Complaint Handler and expected resolution timeframe. 2. **Investigation:** The Complaint Handler gathers facts—reviewing records, interviewing staff, and consulting with you as needed. 3. **Response:** A written decision is issued within **15 business days** of acknowledgment, detailing findings and any corrective measures. 4. **Escalation:** If unresolved after 15 business days, we will explain the delay, set a revised deadline (no more than an additional 15 business days), and offer a senior-level review. 5. **Closure:** Once resolved, we confirm closure in writing and invite your feedback on the process. *** ### 7. Appeals & External Referral If you remain dissatisfied after our final response, you may: * Request an internal review by a senior manager. * Escalate to an appropriate external body (e.g., financial ombudsman, data protection authority) depending on your jurisdiction and the nature of the complaint. *** ### 8. Record-Keeping & Reporting * All complaints and related documentation are logged centrally. * Senior management reviews quarterly reports on complaint volumes, categories, and outcomes. * Trend analysis informs policy, procedural, and product enhancements. *** ### 9. Data Protection All personal data processed during complaint handling are subject to our Privacy Policy and applicable data-protection laws. Records are retained securely for at least **5 years** before being reviewed for archiving or destruction. *** ### 10. Training & Review * All staff receive annual training on complaint-handling procedures and customer-service standards. * This policy is reviewed at least annually—or sooner if legal, regulatory, or operational changes demand—to ensure continued effectiveness. # Website Terms of Use **Last Updated:** 25 June 2025\ **Effective Date:** 25 June 2025 Welcome to delos-banking.com (“Website”), owned and operated by the Delos Financial Group (“Delos,” “we,” “us” or “our”). These Terms of Use (“Terms”) govern your access to and use of the Website and any content, functionality, and services offered on or through the Website. By accessing or using the Website, you agree to be bound by these Terms. If you do not agree with any part of these Terms, you must not use the Website. *** #### 1. Eligibility * You must be at least 18 years old and have the legal capacity to enter into binding contracts under applicable law. * Use of certain services may be restricted by jurisdiction; please review our Eligible & Prohibited Jurisdictions for details. #### 2. Account Registration * Some areas of the Website require you to register for an account. When registering, you agree to: * Provide accurate, current, and complete information. * Maintain and promptly update your account information. * Keep your login credentials secure and notify us immediately of any unauthorized use. #### 3. Website Content * All text, graphics, images, logos, button icons, software, and other materials on the Website (“Content”) are owned or licensed by Delos and protected by intellectual property laws. * You may view and download Content solely for your personal, non-commercial use, provided you retain all copyright and other proprietary notices. * Any other use—including reproduction, modification, distribution, or republication—without Delos’s express written permission is strictly prohibited. #### 4. Permitted & Prohibited Conduct * **Permitted:** * Browsing informational pages. * Submitting inquiries or support requests. * Using interactive features for which you are authorized. * **Prohibited:** * Attempting to gain unauthorized access to our systems or data. * Interfering with Website functionality or security. * Transmitting harmful code, spam, or fraudulent communications. * Using the Website for illegal or deceptive activities. #### 5. Third-Party Links & Services * The Website may contain links to third-party websites or offer integrations with third-party services. * Delos has no control over, and assumes no responsibility for, the content, privacy practices, or performance of third-party sites or services. * Your interactions with any third parties are solely between you and the third party. #### 6. Privacy * Your use of the Website is also governed by our Privacy Policy. By using the Website, you consent to the collection, use, and disclosure of your information as described therein. #### 7. Disclaimers * The Website and Content are provided “as is” and “as available,” without warranty of any kind, express or implied, including merchantability, fitness for a particular purpose, or non-infringement. * Delos does not warrant that the Website will be uninterrupted, error-free, secure, or free of viruses or other harmful components. #### 8. Limitation of Liability * To the fullest extent permitted by law, Delos and its affiliates, officers, directors, employees, and agents will not be liable for any indirect, incidental, special, consequential, or punitive damages arising out of or related to your use of the Website, even if Delos has been advised of the possibility of such damages. * Our total liability for direct damages shall not exceed the amount you have paid, if any, to access or use the Website. #### 9. Indemnification You agree to defend, indemnify, and hold harmless Delos and its officers, directors, employees, agents, and affiliates from and against any claims, liabilities, damages, losses, or expenses (including reasonable attorneys’ fees) arising out of or in any way connected with: * Your access to or use of the Website; * Your violation of these Terms; * Your violation of any law or the rights of any third party. #### 10. Governing Law & Dispute Resolution * These Terms and any dispute arising out of or relating to them shall be governed by the laws of England and Wales (without regard to conflict-of-law principles). * Any dispute shall be resolved exclusively in the courts of England and Wales, and you consent to personal jurisdiction there. #### 11. Changes to These Terms * We may modify these Terms at any time by posting the revised version on the Website with a new “Last Updated” date. * Your continued use of the Website after changes are posted constitutes your acceptance of the revised Terms. #### 12. Severability * If any provision of these Terms is held invalid or unenforceable, the remaining provisions will remain in full force and effect. #### 13. Entire Agreement These Terms, together with any documents expressly incorporated by reference, constitute the entire agreement between you and Delos regarding the Website. *** **Contact Us** If you have questions or comments about these Terms, please contact us at:\ **Email:** \ **Mail:**\ Delos Financial LTD\ 255 5 Ave SW\ Calgary, AB T2P 3G6\ Canada # Cookie Policy **Last Updated:** 25 June 2025\ **Effective Date:** 25 June 2025 This Cookie Policy explains how Delos Financial Group (“Delos,” “we,” “us,” or “our”) uses cookies and similar tracking technologies on delos-banking.com (the “Website”). By continuing to use or access the Website, you agree to the use of cookies as described below. *** ### 1. What Are Cookies? Cookies are small text files placed on your device (computer, tablet, or mobile) when you visit a website. They help a site recognize your device and remember information about your visit, which can improve your experience. *** ### 2. Types of Cookies We Use 1. **Strictly Necessary Cookies** * **Purpose:** Enable core site functionality (e.g., secure login, form submissions, navigation). * **Duration:** Session only (deleted when you close your browser). * **Examples:** * Session ID cookies * Anti-fraud security tokens 2. **Performance & Analytics Cookies** * **Purpose:** Collect anonymous information about site usage (e.g., page views, load times) to help us understand and improve performance. * **Duration:** Typically 1–24 months. * **Examples:** * Google Analytics `_ga`, `_gid` 3. **Functionality Cookies** * **Purpose:** Remember your preferences (e.g., language, location) and provide enhanced, personalized features. * **Duration:** Up to 12 months. * **Examples:** * Language selector cookie * “Remember me” login preference 4. **Targeting & Advertising Cookies** * **Purpose:** Deliver relevant advertising, limit ad frequency, and measure campaign effectiveness. * **Duration:** Up to 24 months. * **Examples:** * Third-party ad network identifiers * Retargeting cookies *** ### 3. Third-Party Cookies Some cookies on our Website are set by third parties (e.g., analytics providers, advertising networks). We do not control these cookies. For details on a third party’s use of cookies, please refer to their privacy or cookie policy. *** ### 4. Your Cookie Choices * **Browser Settings:** You can usually set your browser to block or delete cookies. Consult your browser’s “Help” section for instructions. * **Opt-Out Links:** * Google Analytics: * Network Advertising Initiative: * Digital Advertising Alliance: > **Note:** Disabling strictly necessary cookies may impair your ability to use key features of the Website. *** ### 5. How We Secure Your Information We treat all cookie-related data in accordance with our \[Privacy Policy]. We implement technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. *** ### 6. Changes to This Cookie Po # Card Terms - U.S. Consumer | INTEREST RATE AND INTEREST CHARGES | | | ------------------------------------------------------------------------------------------------------------------ | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Annual Percentage Rate (APR) for Purchases |

0.00%


| | APR for Balance Transfers |

N/A


| | APR for Cash Advances |

N/A


| | Paying Interest | You will not be charged interest on purchases. Your due date for payment of amounts owed on your Card is 21 days after the close of each billing cycle. | | Minimum Interest Charge | There is no interest chargeable to this Credit Card. | | For Credit Card Tips from the Consumer Financial Protection Bureau |

To learn more about factors to consider when applying for or using a credit card, visit the website of the Consumer Financial Protection Bureau at:

| | FEES | | | Annual Fees | Custom, depends on the product | |

Transaction Fees

  • Balance Transfer
  • Cash Advance
  • International Transaction
|


N/A

None

1% of each transaction in U.S. dollars.

| |

Penalty Fees


  • Late Payment
  • Over the Credit Line
  • Returned Payment
|



2% of the current outstanding card balance

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| How We Will Calculate Your Balance: We use a method called "average daily balance". See your Cardholder Agreement for more details. Billing Rights: Information on your rights to dispute transactions and how to exercise those rights is provided in your Card Regulations. \ Military Lending Act Disclosure: The following disclosure applies to persons covered by the Military Lending Act – other governmental programs and laws may also govern or apply to this transaction but are not described in the following disclosure. The following disclosure is required by the Military Lending Act. Federal law provides important protections to members of the Armed Forces and their dependents relating to extensions of consumer credit. In general, the cost of consumer credit to a member of the Armed Forces and his or her dependent may not exceed an annual percentage rate of 36 percent. This rate must include, as applicable to the credit transaction or account: the costs associated with credit insurance premiums; fees for ancillary products sold in connection with the credit transaction; any application fee charged (other than certain application fees for specified credit transactions or accounts); and any participation fee charged (other than certain participation fees for a credit card account). To learn if you are covered by the Military Lending Act or about the applicable rate, call us at +30 698 927 4199.The Arbitration and Class Waiver sections of your Agreement will not apply to you if you are covered by the Military Lending Act nor do any provisions of the Agreement that waive any right to legal recourse under any state or federal law to the extent required by the Military Lending Act. ### DELOS CARDHOLDER AGREEMENT – SET LINE OF CREDIT Last Updated: July 7, 2026 Arbitration Clause; Notices: PLEASE REVIEW THE ARBITRATION CLAUSE AND NOTICES SET FORTH BELOW IN THE SECTION TITLED DISPUTE RESOLUTION AND ARBITRATION. BY USING THE DELOS CARD, YOU ARE AGREEING TO THE ARBITRATION CLAUSE AND NOTICES SET FORTH IN THAT SECTION. THE ARBITRATION CLAUSE WILL HAVE A SUBSTANTIAL EFFECT ON YOUR RIGHTS IN THE EVENT OF A DISPUTE, INCLUDING YOUR RIGHT TO BRING OR PARTICIPATE IN A CLASS PROCEEDING. This Delos Cardholder Agreement (“Agreement”) is a binding agreement between you (“you” or “your”) and the Issuer (“we”, “us,” or “our”) that governs your use of the card account (“Account”) and Delos card (“Delos Card” or “Card”). The Delos Card is provided to you on behalf of Delos in connection with your status as Delos customer and pursuant to your separate User Agreement between you and Delos (the “User Terms”). We are not a party to the User Terms and disclaim any liability for the performance of services covered therein. In the event of any conflict between this Agreement and the User Terms, this Agreement shall be controlling. #### Additional Definitions The term “Card” means any card we issue associated with your Account, including renewal and substitute cards. The term “Card” also means any other access device that allows you to obtain Account credit from us, including your Account number. Other capitalized terms that are not defined here are generally defined the first time we use those terms. The term “Issuer” refers to Third National, including its affiliates, successors, and assigns. The term “Supported Blockchain” means the Ethereum Blockchain, Polygon Blockchain, Optimism Blockchain, Arbitrum Blockchain and other blockchain networks. We may update this list of Supported Blockchains at any time and at our sole discretion. The terms "you" and "your" mean each and all of the persons who are granted, accept or use the Account and any person who has guaranteed payment of the Account. #### Overview of Account Agreement We reserve the right to amend this Agreement or impose additional obligations or restrictions on you at any time with or without notice to you, except where required by applicable law. By continuing to use the Cards, you agree to be bound by such amendments or additional obligations or restrictions. We will notify you of any amendment to this Agreement by email and in-app notification. If any amendment to this Agreement allows you to reject such amendment, and if you reject the amendment in the manner described in such amendment, we may terminate your Account. If an amendment to this Agreement increases the applicable Interest Charges applicable to your Account, any existing unpaid balances may be subject to such increase to the Interest Charges. You agree that this Agreement becomes effective the first time you use any Card or the Account. You agree that you were not solicited for this product. You also agree that we may keep and use an image or copy of the Agreement to enforce its terms against you. When the Agreement states we “may” take an action, it means we are authorized to take that action in our sole discretion, subject only to any limitations or requirements established by law and the express terms of the Agreement. Please read this Agreement carefully and keep them for future reference. We may make new offers to you in the future or forward offers from others that may interest you. If these offers have new or different terms, those terms will be provided with the offer. If you accept the offer, the previously disclosed terms in the Agreement will still apply, except as modified by the offer. Delos provides technology services in connection with the Delos Card, and is not a bank or credit union and does not itself extend credit, set interest rates, determine repayment terms or hold Collateral. Nothing in this Agreement shall be construed as creating a lender-borrower relationship between you and Delos. You acknowledge and agree that Delos: 1. is an express third-party beneficiary of this Agreement, with the limited right to enforce obligations that directly relate to its role; 2. is not responsible for any decisions by the Issuer to approve, decline, suspend or close your Card account. Delos may, at the request of the Issuer, the payment network or a regulatory authority, suspend or restrict your access to the Delos platform or certain features, to protect against fraud, comply with applicable laws or manage program risk; 3. does not control and is not responsible for the operation, security, or performance of the smart contracts used to hold your Collateral; and 4. is not responsible for merchant acceptance of your Delos Card or for resolving disputes about goods or services purchased with the Delos Card. #### Account Information We Need We need and will request complete, current and valid information about you to manage your Account. Such information may include but is not limited to: your legal name; your address(es); your telephone number(s); your date(s) of birth; your employment and income information; and your Social Security number(s); or other government identification number(s). You must tell us when this information changes, and, if we agree to issue additional Cards, you must notify us of any changes to this information for each additional cardholder. You may update your address as described on your most recent Statement, through the website we maintain for your Account, or by calling us at the telephone number shown on your most recent Statement or the back of your Card. We may require that you provide additional documents that are acceptable to us so that we can verify this information and any changes. We may restrict or close your Account if we are unable to verify your information or if you do not provide the additional information we request, at our sole discretion. TO HELP THE GOVERNMENT FIGHT THE FUNDING OF TERRORISM AND MONEY LAUNDERING ACTIVITIES, FEDERAL LAW REQUIRES US TO OBTAIN, VERIFY, AND RECORD INFORMATION THAT IDENTIFIES EACH PERSON WHO OPENS AN ACCOUNT. WHAT THESE MEANS FOR YOU: WHEN YOU OPEN AN ACCOUNT, WE WILL ASK FOR THE NAME, ADDRESS, EMPLOYER IDENTIFICATION NUMBER AND ORGANIZATIONAL DOCUMENTS OF THE ACCOUNT OWNER AND THE NAMES, ADDRESSES, DATES OF BIRTH, AND OTHER INFORMATION CONCERNING EACH PRINCIPAL OWNER THAT WILL ALLOW US TO IDENTIFY THE ACCOUNT OWNER AND ITS PRINCIPAL OWNERS. WE MAY ALSO ASK TO SEE A COPY OF EACH PRINCIPAL OWNERS' DRIVER'S LICENSES OR OTHER IDENTIFICATION DOCUMENTS. #### Balance Categories of Your Account “Balance Categories” are the different Account segments we may establish with unique pricing, grace periods or other terms. The Balance Categories of your Account may include Purchases, Cash Advances, and Special Offers. We reserve the right to decide which Balance Category applies for each Account transaction and our decision will be final. A “Purchase” means the property, rights, goods and services we allow you to purchase, rent, or otherwise obtain directly from merchants and vendors by using your Card. A “Special Offer” means transactions and balances that post to your Account, subject to unique pricing, grace periods, or other terms we disclose from time to time for promotional and other reasons. Our Special Offer disclosures, if any, will explain when any unpaid Special Offer balances may be transferred to and combined with a different Balance Category after any temporary rate period ends. #### Your Promises To Us You promise to do everything the Agreement requires of you, as long as your Account has a balance or remains open. Each of you and all of you promise, individually and together, to pay us all amounts due on your Account, now and in the future. This includes amounts where you did not sign a purchase slip or other documents for the transaction. If you use your Card number without presenting your actual Card (such as for mail, telephone or Internet purchases), these transactions will be treated as if you used the Card in person. The amounts due on your Account include all transactions in each Balance Category made by any of you, plus all Fees and all Interest Charges, as described in this Agreement. Your “Interest Charges” are the charges we add to your Account based on the Annual Percentage Rates we apply to your Account balances. Your “Fees” are the charges we add to your Account that are not based on the Annual Percentage Rates, if any. If you allow someone else to use your Card, you are responsible for all transactions made by that person and all associated Fees and Interest Charges. If you die, your promise to pay us will apply to your estate, as permitted by law. #### Using Your Account and Card You may use your Card and the Account for making Purchases and for obtaining any Special Offers that we may provide, as permitted by this Agreement and applicable law. You agree to sign the Card immediately after you receive it. The Card is valid during the dates shown on the front. The Card is our property and you agree to return it to us or destroy it, if we ask. You agree to take reasonable steps to prevent the unauthorized use of your Card and Account. We are not responsible to you if someone refuses to accept your Card for any reason. We may reject any transaction for any reason. We may limit the combined dollar amount or the total number of certain Account transactions allowed during a single day or other time periods. We may restrict or delay the availability of Account credit, to protect you and us against potential fraud, unauthorized transactions, Account misconduct or misuse, or for other risk management reasons. We will not be liable to you if this happens. Except as otherwise required by applicable law or regulation, we will not be responsible for merchandise or services purchased or leased through the use of any Card or the Account. You agree not to use, try to use, or permit use of the Card or Account for any Internet gambling transactions or any other transactions that are illegal or not permitted by us. Even if you do, you must still pay us for these transactions, and they remain subject to all other terms of our Agreement. You must reimburse us for all damages and expenses associated with these transactions. You acknowledge and agree that you have read and understood the [Prohibitions List](https://legal.raincards.xyz/legal/prohibitions) and that you will not engage in any such activities when using the Services or the Delos Card. From time to time, Account services may be unavailable to you, due to circumstances beyond our control, such as system failures, fires, floods, natural disasters or other unpredictable events. When this happens, you may be unable to use your Card or obtain Account information. We will not be responsible or liable to you if this happens. #### Using a PIN We may give you a personal identification number (“PIN”). For security reasons, you may have to provide the PIN before you are able to complete some transactions using the Card. With a PIN, you may, if enabled by us, use your Card to obtain cash from certain automated teller machines (“ATM”) or make Purchases at certain merchant point-of-sale devices (“POS”). Where enabled, you may do these things if the ATM or POS requires entry of a PIN and displays the logo of the Payment Card Network on your Card. We will treat any allowed ATM transactions as Cash Advances and all POS transactions as Purchases. Keep your PIN secure and do not write it down, give it to anyone, or keep it with your Card. If you lose your Card or believe someone has gained unauthorized access to your PIN, you must contact us immediately. #### Statements and Billing Cycles The documents or information we provide after each Billing Cycle through your Statement will disclose important information about your Account, including your Account transactions, payments, Fees, Interest Charges, unpaid balances in each Balance Category, and payment requirements. The intervals of time between your regular Statements (each, a “Billing Cycle”) are generally equal (approximately 30 days), but may vary slightly in length. Your first Billing Cycle may be more or less than 30 days. You must pay any Minimum Interest Charge and any Fees due after your first Billing Cycle, even if it is for a period less than 30 days. Your Statements disclose the specific length of each Billing Cycle. Your Account will continue to have Billing Cycles, even if a Statement is not required after any Billing Cycle. We will send a single Statement to you for all Cards on your Account, except when we are not required or permitted by law to send a Statement. We will send a Statement at the end of each Billing Cycle when your Account has a debit or credit balance of more than $0.01, if we have charged any Interest Charges to your Account, or as otherwise required by law. #### Disputed Transactions You must promptly inspect each Statement you receive and tell us about any errors or questions you have, as described in the “Billing Rights” section of your Statement and this Agreement. If you do not notify us as provided in these disclosures, we may assume that all information in the Statement is correct. If you dispute a transaction made by you or someone else on your Account, and we later credit your Account for all or part of the disputed amount, you agree to: * Give us all of your rights against that other person; * Give us any merchandise or other purchases you received in connection with the disputed amount, if we ask; * Not pursue any claim or reimbursement from the merchant and other person; and * Help us pursue and obtain reimbursement from the merchant and that other person, by promptly returning documents with any signatures we may request and otherwise providing us with reasonable cooperation. #### No Warranties TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW AND EXCEPT AS OTHERWISE PROVIDED IN THE “BILLING RIGHTS” SECTION OF YOUR STATEMENTS AND THIS AGREEMENT, WE EXPRESSLY DISCLAIM ALL WARRANTIES, INCLUDING BUT NOT LMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, RELIABILITY, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE. #### Lost or Stolen Cards; Unauthorized Use; Replacement Cards For Consumers: You must take reasonable steps to prevent the unauthorized use of your Card and Account. If you notice the loss or theft of your Card, or a possible unauthorized use of your Card, you should write to us immediately at the address provided on your Statement or call us at the telephone number provided on your Statement. You will not be liable for any unauthorized use that occurs after you notify us. You may, however, be liable for unauthorized use that occurs before your notice to us. In any case, your liability will not exceed $50 (or any lesser amount required by law or as provided under the express terms of a benefit provided by a Payment Card Network). If we reimburse your Account for unauthorized charges made using your Card, you agree to help us investigate, pursue and obtain reimbursement from the wrongdoer. Your help includes giving us documents that we ask for and that are acceptable to us. Unless canceled, a Card will be valid through the expiration date which is printed on the Card. We may replace a Card at any time and we may continue to issue renewal or replacement Cards until you notify us to cancel the Account. You are responsible for canceling any lost, misused or stolen Cards or the Account that you suspect may have been the subject of fraud, unauthorized use or misuse, whether as a result of termination of employment or otherwise. You are responsible for retrieving the canceled Card and destroying it to prevent further use. You may also cancel a Card by calling our customer service center. All telephone communications by you to us must be made by calling our customer service center at +30 698 927 4199 as soon as the need arises. You understand that we will require a reasonable amount of time to act on any request made by telephone. You will not be liable for any unauthorized use of your Card after you notify us orally or in writing of the loss, theft, or possible unauthorized use and you meet the following conditions: (1) you have exercised reasonable care with the Card; (2) you have not reported two or more incidents of unauthorized Card use within the previous 12 months; and (3) you have maintained your Account(s) in good standing. The foregoing liability limitation does not apply to ATM cash advance transactions. In any case, your maximum liability for unauthorized use of a Card will not exceed $50 and you will not be liable for any unauthorized use that occurs after you notify us (or our designee) at the address or telephone number above. #### Credit Limits The credit limit will be determined, in part, by the amount of available Collateral (as defined below). We may assign different credit limits for the different Balance Categories of your Account. For example, your credit limit for any Cash Advances or Special Offers may be lower than your credit limit for Purchases or the overall credit limit of your Account. We may raise, lower, restrict, or cancel your credit limit on any Balance Category or the Account at any time and for any reason, subject to any notices that are required by law. This will not affect your obligation to pay us. You are responsible for keeping track of your Account balances and available credit. You agree not to allow your Account to go over any credit limit. We may honor transactions above your credit limits, but, if we do, this will not increase your credit limit and you must pay us the full amount of these transactions. Provided you maintain sufficient collateral to cover a Purchase, Delos reserves the right to set a daily or monthly spending limit at their sole discretion. The limit could be temporary or permanent. We will tell you if we do this, but we won’t always notify you in advance. Any limits set will also apply to Authorized Users. We may set and vary limits and restrictions on certain uses of the Card or certain transactions. For example, contactless purchases may have their own limits. #### Interest Charges We may charge Interest Charges to your Account as shown in the Agreement, including your Account Opening Disclosures and Statements. If we charge Interest Charges to your Account, we calculate the Interest Charges by applying a Daily Periodic Rate to an “Average Daily Balance” of each Balance Category in your Account. To get the “Average Daily Balance,” we take the beginning balance of your Account each day (including any previously billed and unpaid transactions, Interest Charges and Fees), add any new Fees and Account transactions (including Purchases, Special Offers, or debit adjustments), and then subtract any unbilled Interest Charges and any payments or credits. This gives us the “Daily Balance” in each Balance Category. Then, we add up all the Daily Balances in each Balance Category for the Billing Cycle and divide the total by the number of days in the Billing Cycle. This gives us the “Average Daily Balance.” Your Statements disclose the “Average Daily Balance” of each Balance Category as the “Balance Subject To Interest Rate.” Interest Charges begin to accrue from the earlier of the date of the transaction, the date the transaction is processed and first posts to your Account, or the first day of the Billing Cycle, except as prohibited by law or as otherwise described in the Agreement. Interest Charges accrue on each unpaid amount until it is paid in full. Billed and unpaid Interest Charges are added to the proper Balance Category of your Account. We will not assess Interest Charges during a Billing Cycle for any new Purchases made during that Billing Cycle, if you pay the previous month’s New Balance in full by its payment due date or if your previous month’s New Balance was zero or a credit amount. If you have been paying your Account in full with no Interest Charges applied to Purchases, and you do not pay the next New Balance of your Account in full, we will assess prorated Interest Charges on the unpaid balance of your Purchases, as permitted or required by law. There is no grace period on any new Purchase transaction when there is an unpaid balance from a previous Statement. A Special Offer transaction is not subject to a grace period, unless the terms we provided with the Special Offer expressly state that these transactions are subject to a grace period. To determine the “Daily Periodic Rate” that applies to each Balance Category, we divide the corresponding Annual Percentage Rates by the number of days in a year. The resulting Daily Periodic Rate is carried three places past the decimal point and the last digit is rounded. We calculate your total Interest Charges by multiplying the Average Daily Balance of each Balance Category by its Daily Periodic Rate and then multiplying the result by the number of days in the Billing Cycle. This calculation may vary slightly from the Interest Charges we actually charge after a Billing Cycle, due to the effects of rounding or as a result of any Minimum Interest Charge that applies. Your Account Opening Disclosures disclose the Daily Periodic Rates and the corresponding Annual Percentage Rates that apply to each Balance Category. Your Account Opening Disclosures disclose the Minimum Interest Charges that will be due if any Balance Category of your Account is subject to Interest Charges after a Billing Cycle. Your Account Opening Disclosures also disclose which Annual Percentage Rates and Daily Periodic Rates may vary from Billing Cycle to Billing Cycle, based on changes to a published index rate. These Account Opening Disclosures identify the index rate we use, and the different margins we add to the index rate to determine the variable Annual Percentage Rates. #### Fees You must pay the following Fees we charge to your Account, in the amounts shown on your Account Opening Disclosures, shown in this Agreement, or disclosed to you at the time you ask us to provide particular services to you or on your behalf. Annual Fee: We may charge you this Fee for making the Account available and issuing Cards to you. We will post and treat this Fee as a Purchase transaction. Late Payment Fee: We may charge you this Fee if we do not receive your payment in time to credit it by the due date shown on your Statement. We will post and treat this Fee as a Purchase transaction. Returned Payment Fee: We may charge you this Fee each time any payment you make to us is not paid by your financial institution for any reason, even if that institution later pays it. We will post and treat this Fee as a Purchase transaction. Copying Fee: We may charge you a Fee of $10.00 for each paper copy of a transaction document or a Statement you request, unless they are required to resolve a billing dispute. We will post and treat this Fee as a Purchase transaction. Fees for Faster Payment Services: We may make services available that allow you to make faster payments through a customer service representative using a telephone, the Internet or other payment system. We will describe the terms for using these services before you use them. You do not have to use these other payment services, and we may charge you a Fee for using them. If we do, we will tell you the amount of the Fee at the time you request the service. We are not responsible if a payment made using our payment services is rejected or not paid. Even if it is, we may still keep the Fee. We will post and treat these Fees as a Purchase transaction. Foreign Transaction Fee: We may charge you this Fee each time you make a transaction in a currency other than US Dollars or make a transaction in a country outside the United States. This Fee will post to the same Balance Category as the transaction (for example, as a Purchase), and be treated as other transactions that post to this Balance Category. #### Transactions Made in Foreign Currencies If you make a transaction in a foreign currency, the Payment Card Network will convert it into a U.S. dollar amount. The Payment Card Network will use its currency conversion procedures in effect when it processes the transaction. The conversion rate in effect on the processing date might differ from the rate in effect on the transaction or posting date. We do not currently adjust the currency exchange rate. #### Making Payments You are responsible for payment in full of all transactions and fees identified on your Statement at the end of each Billing Cycle. You make a payment to Delos through any means permitted by Delos as disclosed when you log into your Account. You agree to follow the payment requirements we disclose on Statements from time to time. You may pay all or any part of your outstanding Account balance early, without penalty. If your due date occurs on a day on which we do not receive payments, any payment received the next day that conforms to the above requirements will not be treated as late. Please allow at least five (5) days for postal delivery. Unless we or our agents specifically instruct you to remit payment in a different manner, payments received at any other location or in any other form may not be credited for up to five (5) days. This may cause you to be charged Late Payment Fees and additional Interest Charges. If you give your Account number or other Account information to someone else to make a payment for you, we may provide Account information to them and process their payment as if you made it. We may refuse to accept any payment made by someone else for your Account. If we accept a payment made by someone else for your Account, you will be responsible for the payment made, even if that payment is rejected or not paid. #### Collateral and Security Agreement This Account is a secured Account. Either your primary linked wallet or any additional wallets may provide the collateral that will secure the charges made by you on any Card (the “Collateral”). The Collateral must be in a wallet on a Supported Blockchain. By entering into this Agreement, you are furnishing and granting us a security interest in the Collateral, as well as any additions to, substitutions or renewals of the Collateral. No portion of the Collateral may be used by you to secure other loans. In addition to the Collateral serving as collateral for your obligations to us, you also authorize Delos to liquidate Collateral pursuant to this section in the event of a “Liquidation Event.” A “Liquidation Event” will occur at a period set by Delos, a) in accordance with the terms of any “smart-contract” or other electronic code pursuant to which one or more transactions will be triggered with respect to some or all of the Collateral; b) if you fail to make a payment of the full amount owed to Delos within 21 calendar days of the due date on your Statement provided to you; or c) the Market Value of your Collateral drops below the value of the existing charges on your Delos card(s) and you do not add additional collateral or reduce the value of the existing charges to less than the Market Value of your Collateral by making a payment. “Market Value” of the Collateral will be determined by Delos using the net redemption value provided by a centralized stablecoin issuer and/or the real time price posted on a reputable and recognized exchange or price aggregator, or by reference to a price oracle, subject to Delos ’s sole discretion. You agree to pay all transaction costs or “gas” fees relating to any Liquidation transaction and that all such costs or fees will be paid from your Collateral and will not be credited to your Account. You agree that the market value of your collateral is determined solely by Delos through the above methods. You further agree that the Market Value is determined at the time of a Liquidation Event and any change in or fluctuation in value of the collateral before or after a Liquidation Event will have no bearing on obligations owed to Delos. You, through one or more of your linked wallet or additional wallets, must ensure that the Collateral has Market Value in United States Dollars (“USD”) that is greater than or equal to the value of all unpaid charges to all of your Cards. For example, if you provide Collateral with a Market Value equal to $100 of value in USD, and that Market Value does not change, your spending limit will be equal to $100 USD. Once $100 USD has been charged to your Card, you will be required to either make a payment or to provide additional Collateral in order to be able to make any additional Charges. If, at any time, the Market Value of the Collateral is less than the value of all unpaid charges, we may require you to add to the Collateral or you may be subject to a Liquidation Event, at our sole discretion. If the Market Value of your collateral is subject to a liquidation event when the Market Value is below your existing charges, you still owe us any difference between the USD value of the charges, and the USD value of the collateral at the time of Liquidation. The Collateral will be owned by you at all times and held in your custody. You authorize Delos and its designees to liquidate the Collateral upon a Liquidation Event and use the amounts to satisfy your payment obligations owed to Delos. You agree that Delos will not be required to notify you prior to such liquidation and you acknowledge and agree that, because of the nature of the blockchain technology and smart contract infrastructure, Delos may not be in a position to stop a liquidation from occurring. To withdraw your Collateral, you must provide Delos at least (3) business days prior notice. You agree that any Collateral that has been provided to us within the (3) business days of your notice to us may be subject to liquidation notwithstanding your notice to us of your withdrawal of the prior Collateral. Your withdrawal of any Collateral will not terminate any outstanding payment obligations you may have on your Card.\ \ We will not, in any circumstance, be holding custody of your Collateral. Delos is not a custodian or owner of your Collateral. If a Liquidation Event occurs, only the amount required to repay your outstanding financial obligations to Delos will be liquidated from your Collateral. Any unencumbered Collateral balances shall remain freely accessible. You authorize and consent to Delos liquidating the Collateral upon a Liquidation Event through a third party or by other means in order to satisfy payment obligations owed by you to Delos, the Issuer or other third party, as applicable. You acknowledge and agree that the Supported Blockchains that we accept as Collateral, including any Supported Blockchains that consist of or include tokenized assets, are issued and managed by third parties, and are subject to their own terms, conditions, and risks. We and Delos make no representations or warranties regarding any Supported Blockchain, or any underlying collateral related to such Supported Blockchain, including but not limited to their value, liquidity, stability, yield, rewards, or any other attributes. We and Delos expressly disclaim all responsibility and liability for any losses, fluctuations, or other outcomes arising from the ownership, use, performance, or characteristics of any Supported Blockchain and/or Collateral. You are responsible for evaluating and accepting the risks associated with any Supported Blockchain you choose to use as Collateral. You waive any right to require us to: (a) proceed against any Cardholder or any other person; (b) proceed against or exhaust any security held under this Agreement; or (c) pursue any other remedy available to us under applicable law. Issuer or Delos, without prior notice, and from time to time, may: (a) renew, compromise, extend, accelerate or otherwise change the terms relating to the Account; (b) take and hold security (other than the Collateral) for payment of the Account and enforce, exchange and release the security in any manner that we determine is proper; (c) release or substitute any Cardholder, guarantor, or endorser of the Account; and (d) increase or lower the Credit Limit on your Account, and no such action shall change the fact that the Collateral shall at all times serve as security for the Account. #### Payment Processing We may accept and process payments without losing any of our rights. Even if we credit your payment to your Account, we may delay the availability of Account credit until we confirm that your payment has cleared. We may resubmit and electronically collect returned payments. We may also adjust your Account as necessary to correct errors, to process returned and reversed payments, and to handle similar issues. An “Item” means a check, draft, money order or other negotiable instrument you use to pay your Account. This includes any image of these instruments. When you provide an Item as payment, you authorize us either to use information from your Item to make a one time electronic fund transfer from your deposit account or to process the payment as a check transaction. When we use information from your Item to make an electronic funds transfer, funds may be withdrawn from your deposit account as soon as the same day your payment is received and you will not receive your Item back from your financial institution. You may contact us and ask that we not process your future Items in this way. If we process the payment as a check transaction, you understand and agree that we may convert your Item into an electronic image that can be collected from your depository institution as a substitute check. We will not be responsible if an Item you provide has physical features that, when imaged, result in it not being processed as you intended. #### Items with Restrictive Words, Conditions or Instructions All Items that have restrictive words, conditions, limitations or special instructions added (including Items marked with the words “Paid in Full” or similar language), and all accompanying communications, must be mailed to and received at: Card Services, Delos, Partner Mailing Address]. If you make your payment or send any accompanying communications to any other address, we may accept and process the payment, without losing any of our rights. #### Credit Balances We may reject and return to you any portion of a payment that creates a credit balance on your Account. Any credit balance we allow will not be available to you until we confirm that the payment creating the credit balance has cleared. We may reduce the amount of any credit balance by any new amounts billed to your Account. You may contact us as provided on your Statement and request a refund of any available credit balance. If you contact us in writing, we will refund your credit balance within seven (7) business days from our receipt of your written request. A business day means any day in which our offices are open for the processing of Account payments and credits. #### Account Default We may consider you in default of your Agreement with us if: * close or suspend your Account; * lower your credit limits; * demand that you immediately pay the entire balance owing on your Account; * continue to charge you Interest Charges and Fees as long as your balances remain outstanding; and/or * pursue any other action against you that the law allows, which includes the filing of a lawsuit against you. * You agree to pay us all of our collection expenses, attorneys’ fees, and court costs, unless the law does not allow us to collect these amounts. Paying the Interest Charges and Fees charged in connection with a default will not, by itself, cure the default. If you are in default, we may take the following actions without notifying you, after providing you with any notices that may be required by applicable law: * you do not make any payment when it is due; * any payment you make is rejected, not paid or cannot be processed; * you exceed a credit limit; * a bankruptcy or other insolvency proceeding is filed by or against you; * you die or are legally declared incompetent or incapacitated; * we determine that you made a false, incomplete or misleading statement on any of your Account documentation, or you otherwise tried to defraud us; * you do not comply with any term of this Agreement or any other agreement with us; or * you permanently reside outside the United States. #### Communications By accepting these Card Terms or using your Card, you acknowledge that you have received, reviewed, and agree to be bound by the Issuer’s [E-Sign & Electronic Communications Notice](https://legal.raincards.xyz/legal/electronic-communications-notice) (the “E-Sign Notice”), which is incorporated herein by reference. You consent to receive all disclosures, notices, agreements, and other communications from Issuer and its service providers in electronic form, in accordance with the E-Sign Notice. You agree that such electronic communications satisfy any legal requirement that such communications be in writing. The E-Sign Notice may be amended by Issuer from time to time, and your continued use of the Card after any such amendment constitutes your acceptance of the amended E-Sign Notice. We may contact you from time to time about your Account. We may contact you in any manner we choose, unless the law says that we cannot. For example, we may: * contact you by mail, telephone, email, fax, recorded message, text message or personal visit; * contact you using an automated dialing or similar device (“Autodialer”); * contact you at your home and at your place of employment; * contact you on your mobile telephone; * contact you at any time, including weekends and holidays; * contact you with any frequency; * leave recorded and other messages on your answering machine/service and with others; and * identify ourselves, your relationship with us, and our purpose for contacting you, even if others might hear or read it. Our contacts with you about your Account are not unsolicited and may result from information we obtain from you or others. We may monitor or record any conversation or other communication with you. Unless the law prohibits us from doing so, we may modify or suppress caller identification and similar services and identify ourselves on these services in any manner we choose. When you give us or we obtain your mobile telephone number, we may contact you at this number using an Autodialer and can also leave recorded and other messages. We may do these things, whether we contact you or you contact us. If you ask us to discuss your Account with someone else, you must provide us with documents and authorization that we ask for and that are acceptable to us. #### Credit Reports We may provide information about you and the Account to consumer credit reporting agencies. We may also provide information about you and the Account to others as described in our Privacy Notices. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report. We may obtain and use credit and income information about you from consumer credit reporting agencies and others as the law allows. If you believe we have reported inaccurate information about you to a credit reporting agency, notify us in writing at: Card Services, Delos, . In doing so, identify yourself, your Account, the information you believe is inaccurate, and tell us why you believe the information is incorrect. If you have supporting documents or information, such as a copy of a credit report that includes information you believe is inaccurate, send us the supporting documents and information, too. #### Closing or Suspending Your Account You may ask us to close your Account by calling or writing us as described on your Statement. If you do, we may provide you with additional details about this process and request certain information from you, including payment information. If you use your Card or charges post to your Account after you ask us to close it, we may keep your Account open or reopen it. We may close or suspend your Account and your right to obtain credit from us. We may do this at any time and for any reason, as permitted by law, even if you are not in default. A suspension of your Account might be permanent or temporary. If your Account is closed or suspended for any reason, you must stop using your Card. You must also cancel all recurring charges or similar billing arrangements connected with the Account. We will not do this for you. If we close or permanently suspend your Account, you must also destroy all Cards. You must still pay us all amounts you owe on the Account, even if these amounts are charged after your Account is closed or suspended. #### Additional Services We may, from time to time, make additional services available to you directly or through affiliated or non-affiliated third parties. Without limitation, such services may include providing you with virtual accounts in order to enable you to use your Account or otherwise engage in various financial transactions that we do not directly provide. Each such service is subject to its own terms and conditions, and we shall not be responsible to you for any aspect of those services. We may permit you to charge any applicable fees for such services to your Account. You acknowledge and agree that we may receive compensation or otherwise benefit as a result of making such services available to you. #### The Law that Applies to Your Agreement This Agreement will be interpreted using Puerto Rican law. Federal law shall govern the Arbitration provisions of this Agreement, and as otherwise applicable. You waive any applicable statute of limitations, as the law allows. Otherwise, the applicable statute of limitations period for all provisions and purposes under this Agreement (including the right to collect debt) will be the longer of the time period provided by Puerto Rico law or the law of the jurisdiction where you live. If any part of this Agreement is found to be unenforceable, the remaining parts will remain in effect. #### Waiver We will not lose any of our rights if we delay taking any action for any reason or if we do not notify you. For example, we may waive your Interest Charges or Fees without notifying you and without losing our right to charge them in the future. We may always enforce our rights later and may take other actions not listed in this Agreement if the law allows them. You do not have to receive notice from us of any waiver, delay, demand or dishonor. We may proceed against you before proceeding against someone else. #### Assignment This Agreement will be binding on, and benefit, any of your and our successors and assigns. You may not transfer your Account or your Agreement to someone else without our written permission. We may transfer your Account, this Agreement, or any of our rights or obligations therein, to another company or person at any time, without your permission and without prior notice to you. If we do, they will take our place under this Agreement. You must pay them and perform all of your obligations to them and not us. If you pay us after you are informed or learn that we have transferred your Account or this Agreement, we can handle your payment in any way we think is reasonable. This includes returning the payment to you or forwarding the payment to the other company or person. #### Dispute Resolution and Arbitration PLEASE READ THIS "DISPUTE RESOLUTION AND ARBITRATION" PROVISION VERY CAREFULLY. IT LIMITS YOUR RIGHTS IN THE EVENT OF A DISPUTE BETWEEN YOU AND ISSUER. DELOS IS THE TECHNOLOGY PROVIDER FOR THE CARD BUT IS NOT THE ISSUER, CREDITOR OR LENDER. DELOS IS NOT A PARTY TO THIS AGREEMENT AND HAS NO LIABILITY FOR THE ISSUER’S OBLIGATIONS UNDER IT. HOWEVER, DELOS IS AN EXPRESS THIRD-PARTY BENEFICIARY OF THIS AGREEMENT WITH RESPECT TO ANY PROVISIONS THAT ALLOCATE RISK, DISCLAIM LIABILITY, LIMIT REMEDIES OR REQUIRE DISPUTES TO BE RESOLVED THROUGH ARBITRATION. ACCORDINGLY, TO THE EXTENT A DISPUTE INVOLVES DELOS, DELOS SHALL BE ENTITLED TO INVOKE AND BENEFIT FROM THE SAME PROTECTIONS, LIMITATIONS AND DISPUTE RESOLUTION PROCEDURES AS THE ISSUER. TO THE EXTENT YOU HAVE ANY DISPUTE YOU MAY HAVE WITH DELOS RELATING SOLELY TO SERVICES PROVIDED TO YOU UNDER YOUR SEPARATE USER TERMS WITH DELOS, SUCH DISPUTES WILL BE GOVERNED EXCLUSIVELY IN ACCORDANCE WITH THE DELOS USER TERMS. #### Binding Arbitration (a) You and Issuer agree that any and all past, present and future Disputes (defined below) shall be determined by arbitration, unless your Dispute is subject to an exception to this agreement to arbitrate set forth below. You and Issuer further agree that any arbitration pursuant to this section shall not proceed as a class, group or representative action. The award of the arbitrator may be entered in any court having jurisdiction. “Dispute” means any dispute, claim, or controversy between you and Issuer that arises out of or relates to (i) this Agreement (including, without limitation, the Issuer Card, your Account, any addenda hereto or other terms incorporated herein by reference), (ii) the breach, termination, enforcement, interpretation or validity hereof, including the determination of the scope or applicability of the agreement to arbitrate hereunder, or (iii) any additional services we may provide to you in connection with this Agreement. (b) This agreement to arbitrate shall be construed under and be subject to the Federal Arbitration Act, notwithstanding any other choice of law set out in this Agreement. (c) The Binding Arbitration and Class Waiver sections of this Agreement does not apply to you if you are covered by the Military Lending Act nor do any provisions of the Agreement that waive any right to legal recourse under any state or federal law to the extent required by the Military Lending Act. #### Arbitration Procedure (a) Before filing a claim against Issuer, you agree to try to resolve the Dispute informally by providing written notice to Issuer of the actual or potential Dispute. Similarly, Issuer will provide written notice to you of any actual or potential Dispute to endeavor to resolve any claim we may possess informally before taking any formal action. The party that provides the notice of the actual or potential Dispute (the "Notifying Party") will include in that notice (a "Notice of Dispute") the name of Company, the Notifying Party's contact information for any communications relating to such Dispute, and sufficient details regarding such Dispute to enable the other party (the "Notified Party") to understand the basis of and evaluate the concerns raised. If the Notified Party responds within ten (10) business days after receiving the Notice of Dispute that it is ready and willing to engage in good faith discussions in an effort to resolve the Dispute informally, then each party shall promptly participate in such discussions in good faith. (b) If, notwithstanding the Notifying Party's compliance with all of its obligations under the preceding paragraph, a Dispute is not resolved within thirty (30) days after the Notice of Dispute is sent (or if the Notified Party fails to respond to the Notice of Dispute within ten (10) business days), the Notifying Party may initiate an arbitration proceeding as described below. If either party purports to initiate arbitration without first providing a Notice of Dispute and otherwise complying with all of its obligations under the preceding paragraph, then, notwithstanding any other provision of this Card Agreement, the arbitrator(s) will promptly dismiss the claim with prejudice and will award the other party all of its costs and expenses (including, without limitation, reasonable attorneys' fees) incurred in connection with such Dispute. (c) You and Issuer each agree to resolve any Disputes that are not resolved informally as described above through final and binding arbitration as discussed herein, except as set forth under Section 12.3 below. You and Issuer agree that the American Arbitration Association ("AAA") will administer the arbitration under its Consumer Arbitration Rules (the "Rules"). The Rules are available at [www.adr.org](http://www.adr.org/) or by calling the AAA at 1-800-778-7879. A party who desires to initiate arbitration must provide the other party with a written Demand for Arbitration as specified in the AAA Rules. (The AAA provides a general Demand for Arbitration.) Arbitration will proceed on an individual basis and will be handled by a sole arbitrator. The single arbitrator will be either a retired judge or an attorney licensed to practice law and will be selected by the parties from the AAA's roster of arbitrators. If the parties are unable to agree upon an arbitrator within fourteen (14) days of delivery of the Demand for Arbitration, then the AAA will appoint the arbitrator in accordance with the AAA Rules. The arbitrator(s) shall be authorized to award any remedies, including injunctive relief, that would be available to you in an individual lawsuit, subject to any effective and enforceable limitations of liability or exclusions of remedies set forth herein. Notwithstanding any language to the contrary in this paragraph, if a party seeks injunctive relief that would significantly impact other Issuer users as reasonably determined by either party, the parties agree that such arbitration will proceed on an individual basis but will be handled by a panel of three (3) arbitrators. Each party shall select one arbitrator, and the two party-selected arbitrators shall select the third, who shall serve as chair of the arbitral panel. That chairperson shall be a retired judge or an attorney licensed to practice law and with experience arbitrating or mediating disputes. In the event of disagreement as to whether the threshold for a three-arbitrator panel has been met, the sole arbitrator appointed in accordance with this Section shall make that determination. If the arbitrator determines a three-person panel is appropriate, the arbitrator may -- if selected by either party or as the chair by the two party-selected arbitrators -- participate in the arbitral panel. Except as and to the extent otherwise may be required by law, the arbitration proceeding and any award shall be confidential. \ \ (d) You and Issuer further agree that the arbitration will be held in the English language in New York, New York, or, if you so elect, all proceedings can be conducted via videoconference, telephonically or via other remote electronic means. (e) Filing costs and administrative fees shall be paid in accordance with the AAA Rules; provided that the prevailing party will be entitled to recover its reasonable attorneys' fees, expert witness fees, and out-of-pocket costs incurred in connection with the arbitration proceeding, in addition to any other relief it may be awarded. (f) You and Issuer agree that, notwithstanding anything to the contrary in the Rules, the arbitration of any Dispute shall proceed on an individual basis, and neither you nor Issuer may bring a claim as a part of a class, group, collective, coordinated, consolidated or mass arbitration (each, a "Collective Arbitration"). Without limiting the generality of the foregoing, a claim to resolve any Dispute against Issuer will be deemed a Collective Arbitration if (i) two (2) or more similar claims for arbitration are filed concurrently by or on behalf of one or more claimants; and (ii) counsel for the claimants are the same, share fees or coordinate across the arbitrations. "Concurrently" for purposes of this provision means that both arbitrations are pending (filed but not yet resolved) at the same time. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU NOR ISSUER SHALL BE ENTITLED TO CONSOLIDATE, JOIN OR COORDINATE DISPUTES BY OR AGAINST OTHER INDIVIDUALS OR ENTITIES, OR ARBITRATE OR LITIGATE ANY DISPUTE IN A REPRESENTATIVE CAPACITY, INCLUDING AS A REPRESENTATIVE MEMBER OF A CLASS OR IN A PRIVATE ATTORNEY GENERAL CAPACITY. IN CONNECTION WITH ANY DISPUTE, ANY AND ALL SUCH RIGHTS ARE HEREBY EXPRESSLY AND UNCONDITIONALLY WAIVED. Without limiting the foregoing, any challenge to the validity of this paragraph shall be determined exclusively by the arbitrator. #### Small Claims Notwithstanding your and Issuer’s agreement to arbitrate Disputes, You and Issuer retain the right to bring an individual action in small claims court. #### Class Waiver To the extent applicable law permits, any dispute arising out of or relating to this Card Agreement, whether in arbitration or in court, will be conducted only on an individual basis and not in a class, consolidated or representative action. Notwithstanding any other provision of this Agreement or the AAA Rules, disputes regarding the interpretation, applicability, or enforceability of this class waiver may be resolved only by a court and not by an arbitrator. If this waiver of class or consolidated actions is deemed invalid or unenforceable, neither party is entitled to arbitration. #### No Jury Trial If for any reason a claim or dispute proceeds in court rather than through arbitration, each party knowingly and irrevocably waives any right to trial by jury in any action, proceeding or counterclaim arising out of or relating to this Card Agreement. #### Venue and Jurisdiction for Judicial Proceedings Except as otherwise required by applicable law or provided in this Card Agreement, in the event that the agreement to arbitrate is found not to apply to you or your Dispute, you and Issuer agree that any judicial proceeding may only be brought in a court of competent jurisdiction in Puerto Rico. Both you and Issuer irrevocably consent to venue and personal jurisdiction there; provided that either party may bring any action to confirm an arbitral award in any court having jurisdiction. #### Confidentiality The existence of and all information regarding any Dispute will be held in strict confidence by the parties and will not be disclosed by either party except as reasonably necessary in connection with the conduct of the arbitration or the confirmation or enforcement of any arbitral award. Any such permitted disclosure will, to the maximum extent reasonably practicable, be made subject to obligations of confidentiality at least as stringent as the provisions of this paragraph. If any disclosure of information regarding any Dispute is required under applicable law, the parties shall reasonably cooperate with one another to obtain protective orders or otherwise to preserve the confidentiality of such information. #### Survival The following provisions of this Agreement shall survive any termination or expiration of this Agreement and shall remain in full force and effect until all of your obligations to us have been fully and finally satisfied: (a) all of your payment obligations and our right to collect all amounts owed by you; (b) all security interest, collateral, and setoff provisions, including our rights in any Collateral; (c) any indemnification obligations; (d) the limitation of liability provisions; (e) the disclaimer of warranties provisions; (f) the dispute resolution and arbitration provisions, including the class waiver; (g) our communications and contact rights; (h) our credit reporting rights and your consent thereto; (i) the governing law and jurisdiction provisions; (j) our assignment rights; (k) any waiver provisions; (l) all representations and warranties made by you; (m) any accrued rights, remedies, or causes of action in favor of either party; and (n) any other provision that by its nature or express terms is intended to survive. #### Severability If any provision of this Agreement is found to be invalid, illegal, or unenforceable by a court or arbitrator of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving its intent, or if such modification is not possible, such provision shall be severed from this Agreement. The remaining provisions shall remain in full force and effect. Notwithstanding the foregoing paragraph, in the event that a court finds the prohibition of Collective Arbitration under the Dispute Resolution and Arbitration Section to be invalid or unenforceable, then all provisions related to arbitration in that section shall be deemed void, except for any portion of any provision in that section related to the resolution of Disputes through litigation in court. #### Entire Agreement This Agreement constitutes the entire agreement between you and Issuer regarding the subject matter hereof and supersede all prior or contemporaneous agreements, understandings, representations, and communications whether written or oral, regarding such subject matter. #### Limitation of Liability TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL ISSUER, ITS AFFILIATES, OR ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, OR LICENSORS BE LIABLE TO YOU FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, PUNITIVE, OR OTHER SIMILAR DAMAGES, INCLUDING BUT NOT LIMITED TO LOST PROFITS, LOST REVENUE, LOST DATA, LOSS OF GOODWILL, BUSINESS INTERRUPTION, OR LOSS OF BUSINESS OPPORTUNITY, WHETHER ARISING IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, EVEN IF ISSUER HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN NO EVENT SHALL ISSUER’S TOTAL LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THIS AGREEMENT OR YOUR ACCOUNT EXCEED THE LESSER OF (A) YOUR ACTUAL DIRECT DAMAGES PROVEN OR (B) THE TOTAL AMOUNTS PAID BY YOU IN CONNECTION WITH THIS AGREEMENT IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM. #### Indemnity You will indemnify and defend Issuer, its affiliates, and its partners, directors, officers, employees, agents, trustees, administrators, managers, advisors, and representatives (each an “Indemnitee”) against, and hold each Indemnitee harmless from, any and all claims, litigation, investigations, proceedings, losses, damages, fines, penalties, liabilities, settlements, costs, fees, and expenses incurred by any Indemnitee or asserted against any Indemnitee by any person arising out of, in connection with, related to, or as a result of your (i) breach of any of the representations, warranties, or covenants contained in this Agreement; or (ii) gross negligence, fraud, or violation of any applicable law or rights of any third-party. Issuer may defend any claim subject to indemnification hereunder, using counsel of its choice, and you will pay or promptly reimburse Issuer for the reasonable fees of such counsel and all related costs and reasonable expenses. If you are a user from a jurisdiction that does not allow certain indemnification obligations, you agree that this indemnity is intended to be as broad as permitted under the laws of such jurisdiction. #### Your Billing Rights: Keep This Document For Future Use This notice is for Consumers using the Card Account and tells you about your rights and our responsibilities under the Fair Credit Billing Act. #### What To Do If You Find A Mistake On Your Statement If you think there is an error on your statement, write to us at: Card Services \[Partner Name Partner Mailing Address] In your letter, give us the following information: * Account information: Your name and account number. * Dollar amount: The dollar amount of the suspected error. * Description of problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us: * Within 60 days after the error appeared on your statement. * At least 3 business days before an automated payment is scheduled, if you want to stop payment on the amount you think is wrong. You must notify us of any potential errors in writing. You may call us or notify us electronically, but if you do we are not required to investigate any potential errors and you may have to pay the amount in question. #### What Will Happen After We Receive Your Letter When we receive your letter, we must do two things: * Within 30 days of receiving your letter, we must tell you that we received your letter. We will also tell you if we have already corrected the error. * Within 90 days of receiving your letter, we must either correct the error or explain to you why we believe the bill is correct. While we investigate whether or not there has been an error: If we do not follow all of the rules above, you do not have to pay the first $50 of the amount you question even if your bill is correct. If you receive our explanation but still believe your bill is wrong, you must write to us within 10 days telling us that you still refuse to pay. If you do so, we cannot report you as delinquent without also reporting that you are questioning your bill. We must tell you the name of anyone to whom we reported you as delinquent, and we must let those organizations know when the matter has been settled between us. * If we made a mistake: You will not have to pay the amount in question or any interest or other fees related to that amount. * If we do not believe there was a mistake: You will have to pay the amount in question, along with applicable interest and fees. We will send you a statement of the amount you owe and the date payment is due. We may then report you as delinquent if you do not pay the amount we think you owe. After we finish our investigation, one of two things will happen: * We cannot try to collect the amount in question, or report you as delinquent on that amount. * The charge in question may remain on your statement, and we may continue to charge you interest on that amount. * While you do not have to pay the amount in question, you are responsible for the remainder of your balance. * We can apply any unpaid amount against your credit limit (where applicable). #### Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To use this right, all of the following must be true: * The purchase must have been made in your home state or within 100 miles of your current mailing address, and the purchase price must have been more than $50. (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed to you, or if we own the company that sold you the goods or services.) * You must have used your credit card for the purchase. Purchases made with cash advances from an ATM do not qualify. * You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at: Card Services Delos While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay, we may report you as delinquent. ### Additional Disclosures for Residents of Certain States Maryland Residents: * This Agreement is governed by the Credit Grantor Revolving Credit Provisions in Subtitle 9 of Title 12 (Credit Regulations) of the Maryland Commercial Law, Md. Commercial Law Code Ann. § 12-901, et. seq. * Upon your default pursuant to the terms of this Agreement, we may recover from you our attorneys’ fees and all court or other collection costs actually incurred by us in connection with your default. * You acknowledge that you received a copy of this Agreement. South Dakota Residents: Any improprieties regarding this loan or our lending practices may be referred to the South Dakota Division of Banking at: Division of Banking, South Dakota Department of Labor and Regulation, 1714 Lincoln Ave., Suite 2, Pierre, SD 57501. Phone: 605.773.3421. Wisconsin Residents: * Notwithstanding anything to the contrary in this Agreement, we will not be entitled to recover our attorneys’ fees from you upon default. * Notwithstanding anything to the contrary in this Agreement, this Agreement shall be governed by Wisconsin law and any legal action that we bring against you, if any, will be in Wisconsin. * By accepting this Agreement, you are certifying that this Account is being incurred by you in the interest of your marriage or family. * No provision of any marital property agreement (including any premarital agreement), unilateral statement under §766.59 of the Wisconsin Statutes, or court decree under §766.70 of the Wisconsin Statutes adversely affects our interest unless we, prior to the time that the loan is approved, are furnished with a copy of the marital property agreement, a statement, or a decree or have actual knowledge of the adverse provision. * You must notify us if you have a spouse and provide us with their name and address so that we can provide a copy of this Agreement or otherwise notify your spouse of this Account. * Your spouse may terminate the Account by requesting termination in writing, in which case we may require you to pay the entire amount due to us immediately. Termination of the Account by your spouse does not reduce or remove any of your liability to us in connection with the Account. \ \ \ \ \ \ \ \ \ \ \ \ \ \ \
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# Card Terms - International Consumer These Delos Spend Card Terms (the “Card Terms”) are a binding agreement between you (“you” or “your”) and the Issuer (“we”, “us”, or “our”) that governs your use of the Delos Spend Cards, including the process for obtaining and managing Delos Spend Cards, access to which is provided to you by Delos Financial Limited (“Delos”). ## Important Disclosures PLEASE REVIEW THE ARBITRATION CLAUSE AND NOTICES SET FORTH BELOW IN SECTION 16. BY USING THE CARD, YOU ARE AGREEING TO THE ARBITRATION CLAUSE AND NOTICES SET FORTH IN THAT SECTION. THE ARBITRATION CLAUSE WILL HAVE A SUBSTANTIAL EFFECT ON YOUR RIGHTS IN THE EVENT OF A DISPUTE, INCLUDING YOUR RIGHT TO BRING OR PARTICIPATE IN A CLASS PROCEEDING. Rates, fees, and other important information about your Delos Spend Card (“Delos Card” or “Card”) are set forth in these Important Disclosures. Effective as of July 7, 2026 **Interest Rates and Interest Charges - 0%** **Annual Percentage Rate (APR) for Purchases - 0%** **Your Delos Spend Card is currently Zero - 0 % interest on all purchases.** Issuer and Delos reserve the right to implement interest in the future, for new purchases. Delos will disclose any changes to this agreement prior to the introduction of interest and other charges associated with your Delos Card. #### **Fees** **Transaction Fee** ***Foreign Purchases:*** \- Foreign Exchange Fee (non USD): up to 3% \- Cross Border Fee: up to 3% ***Penalty Fees*** \- Late payment: Up to $40 \- Returned payment: Up to $29 WHEN YOU APPLY FOR A CARD ACCOUNT, ACTIVATE A CARD, OR OTHERWISE PARTICIPATE IN THE PROGRAM IN ANY WAY, YOU REPRESENT THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO THESE CARD TERMS. \ Terms ----- **Background:** The Delos Card is provided to you on behalf of Delos in connection with your status as Delos customer and pursuant to your separate Transaction Account Agreement between you and Delos (the “User Agreement”). The Issuer is not a party to the User Agreement and disclaims any liability for the performance of services covered therein. Delos has opened a Delos Account for purposes of facilitating transactions you make using a Card based on a limit established by Delos pursuant to the User Agreement. You understand that you have access to the Services and Delos Card only to the extent authorized by the Delos. You acknowledge and agree that Delos will satisfy obligations created through your use of the Delos Card and you will repay Delos based on the terms of your User Agreement, subject to the terms below. In the event of a conflict between these Card Terms and your User Agreement, these Card Terms will control. Details on Delos’s collection, use, and handling of your personal data are described in Delos Privacy Policy (). Please review it carefully and contact Delos if you have any questions. By opening, using, or maintaining a Card, you consent to and direct Issuer to share information relating to transactions, including receipt information or other personal data, in order to deliver the Services. **Issuer:** The card program is issued by the Issuer under license from Visa. The information about the cost of the Card described in the above table is accurate as of July 7, 2026. This information may change after that date. To find out what may have changed, call or write the servicer, at and +30 698 927 4199. Issuer reserves the right to amend these Card Terms or impose additional obligations or restrictions on you at any time with or without notice to you. By continuing to use the Services, you agree to be bound by such amendments or additional obligations or restrictions. The date on the top of this page shows when the Card Terms were last updated. Capitalized terms that are not defined here have the definitions provided in the User Agreement. Delos provides technology services in connection with the Delos Card, and is not a bank or credit union and does not itself extend credit, set interest rates, determine repayment terms or hold Collateral. Nothing in these Card Terms shall be construed as creating a lender-borrower relationship between you and Delos. **You acknowledge and agree that Delos:** 1. is an express third-party beneficiary of these Card Terms, with the limited right to enforce obligations that directly relate to its role; 2. is not responsible for any decisions by the Issuer to approve, decline, suspend or close your Card account. Delos may, at the request of the Issuer, the payment network or a regulatory authority, suspend or restrict your access to the Delos platform or certain features, to protect against fraud, comply with applicable laws or manage program risk; 3. does not control and is not responsible for the operation, security, or performance of the smart contracts used to hold your Collateral; and 4. is not responsible for merchant acceptance of your Delos Card or for resolving disputes about goods or services purchased with the Delos Card. **Defined Terms:** “Card Networks” means the payment card networks including Visa or Mastercard. “Charge” means a payment for goods or services made to a merchant that accepts payments on the applicable Card Network. “Chargeback” means a dispute that you initiate against a merchant for an unresolved dispute with the merchant or where a Charge is unauthorized. “Fee” means charges we impose on you for use of Services or your use of a Delos Card. “Issuer” refers to Third National, including its affiliates, successors, and assigns. “Periodic Statement” means the periodic statements that reflect activity for all Cards issued to you identifying charges, fees, refunds, or other amounts owed or credited to your Delos Account during the time covered by that statement. “Supported Blockchains” means the Ethereum Blockchain, Polygon Blockchain, Optimism Blockchain, Arbitrium Blockchain and other blockchain networks which may be added at the sole discretion of Issuer. We may update this list of Supported Blockchains at any time and at our sole discretion. ## Agreement: 1\. Accepting this Agreement & Eligibility These Card Terms become effective and legally binding when you activate or create your Card by following the instructions on the Delos platform. You and we agree to comply with, and be bound by, this entire agreement. You should retain and carefully review these Card Terms. By creating a Card, you agree to the Arbitration Clause below as it pertains to these Card Terms, even if you do not use the Account or the Card. By using a Card you represent and warrant in your individual capacity that: * You are not a person who is blocked or sanctioned by the United States Government, including those identified by the United States Office of Foreign Asset Controls (OFAC). * You will use the Services exclusively for purposes permitted by these Card Terms. * All information you provide to us, either directly or through Delos, is and will be true, correct, and complete. * You will use the Delos Card for personal, family, or household use. * You will only use the Delos Card in compliance with applicable law * You attest that you reside outside the United States and are signing up for a card that is intended for those residing outside of the United States. * You attest that you were not solicited for this Card. 2\. Issuer Terms The Issuer is identified on the back of the Delos Card issued to you and is responsible for funding your payments for goods and services you purchase at a merchant through your Delos Card and based on information provided by Partner. Please note that the Issuer may require you to accept additional terms in addition to the agreements you have with Delos, and your use of the Delos Cards will then also be subject to such additional terms. 3\. Collateral This Account is a secured Account. Either your primary Linked Wallet or any Additional Wallets may provide the collateral that will secure the Charges made by you on any Card (the “Collateral”). The Collateral must be held in a wallet on a Supported Blockchain. By entering into these Card Terms, you are furnishing and granting us a security interest in the Collateral, as well as any additions to, substitutions or renewals of the Collateral. No portion of the Collateral may be used by you to secure other loans. A “Liquidation Event” will occur a) if you have an outstanding payment obligation to Delos or the Issuer, as applicable, and such payment obligation has not been paid in full by you within one (1) calendar day; OR b) the Market Value of your Collateral drops below the value of the existing charges on your Delos Card(s) and you do not add additional collateral or reduce the value of the existing charges to less than the Market Value of the Collateral by making a payment. Delos and Issuer may allow for an additional grace period at their discretion. “Market Value” of the Collateral will be determined by Delos and/or Issuer using the net redemption value provided by a centralized stablecoin issuer and/or the real time price posted on a reputable and recognized exchange or price aggregator, or by reference to a price oracle, subject to Delos or Issuers discretion. You agree to pay all transaction costs or “gas” fees relating to the any Liquidation transaction and that all such costs or fees will be paid from your Collateral and will not be credited to your Account. You agree that the market value of your collateral is determined solely by Issuer through the above methods. You further agree that the Market Value is determined at the time of a Liquidation Event and any change in or fluctuation in value of the Collateral before or after a Liquidation Event will have no bearing on obligations owed to Delos and/or Issuer. You, through one or more of your Linked Wallet or Additional Wallets, must ensure that the Collateral has a Market Value in United States Dollars (“USD”) that is greater than or equal to the value of all unpaid Charges to all of your Delos Cards. For example, if you provide Digital Assets with a Market Value equal to $100 of value in USD, and that Market Value does not change, your spending limit will be equal to $100 USD across all your Delos Cards. Once $100 USD has been charged to your Delos Cards, you will be required to either make a payment or to provide additional Collateral in order to make any additional Charges. If, at any time, the Market Value of your Collateral becomes less than the value of all unpaid Charges, we may require you to add to the Collateral or you may be subject to a Liquidation Event, at our discretion. If the Market Value of your Collateral is subject to a Liquidation Event when the Market Value is below your existing charges, you still owe Delos and Issuer any difference between the USD value of the charges, and the USD value of the collateral at the time of the Liquidation Event. Your withdrawal of any Collateral will not terminate any outstanding payment obligations you may have on your Delos Cards. Delos and Issuer will not, in any circumstance, be holding custody of your Collateral. Third National is not a custodian or owner of your Collateral. You authorize and consent to Delos or Issuer liquidating the Collateral upon a Liquidation Event through a third party or by other means in order to satisfy payment obligations owed by you to Delos, the Issuer or other third party, as applicable. You acknowledge and agree that the Supported Blockchains, including any Supported Blockchains that consist of or include tokenized assets, are issued and managed by third parties, and are subject to their own terms, conditions, and risks. We and Delos make no representations or warranties regarding any Supported Blockchain, or any underlying Collateral related to such Supported Blockchain, including but not limited to their value, liquidity, stability, yield, rewards, or any other attributes. We and Delos expressly disclaim all responsibility and liability for any losses, fluctuations, or other outcomes arising from the ownership, use, performance, or characteristics of any Supported Blockchain and/or Collateral. You are responsible for evaluating and accepting the risks associated with any Supported Blockchain you use to provide Collateral. You waive any right to require us to: (a) proceed against any other person; (b) proceed against or exhaust any security held under these Card Terms; or (c) pursue any other remedy available to us under applicable law. We may, without prior notice, and from time to time: (a) renew, compromise, extend, accelerate or otherwise change the terms relating to the Account; (b) take and hold security (other than the Collateral) for payment of the Account and enforce, exchange and release the security in any manner that we determine is proper; (c) release or substitute any person, guarantor, or endorser of the Account; and (d) increase or lower the Credit Limit on your Account, and no such action shall change the fact that the Collateral shall at all times serve as security for the Account. 4\. Spending Limits Your spending limit is generally set by Delos pursuant to the terms of the Delos Terms and the amount of Collateral. Issuer may additionally set spending limits on each Delos Card or an aggregate spending limit across all Delos Cards, at its sole discretion. Delos Account Spending limits are dynamic and may be modified at any time with or without notice to you, including temporary increases or decreases or reducing spending limits to $0. Any authorized Charge or fee on a Delos Card may reduce your spending limit by a corresponding amount. When you use your Delos Card to initiate a transaction at certain merchants where the amount of the final transaction is unknown at the time of authorization, Issuer may assess a value to such a Charge for an amount higher or lower than the final Charges. This initial “hold” Charge will reduce your spending limit until the final Charge is determined. 5\. Purchases & Restrictions Delos and Issuer reserve the right to block and terminate transactions and suspend access to your Account, unless prohibited by applicable law, at any time and for any reason, including if we believe that you are using the Card or your Account for non-consumer purposes. You may use your Account to purchase or lease goods or services (each, a “Purchase”) by presenting your Card or providing to participating merchants and establishments that honor the Card your Card number and additional information by any other means (for example, over the phone, online or through a mobile app). We will not be liable to you (or anyone else) if any merchant or other person cannot or will not process a purchase permitted under these Card Terms. Unless prohibited by applicable law, we may from time to time limit the type, number and dollar amount of any purchase, including any cash-like transaction, even if you have sufficient available credit to complete the purchase. Cash-like transactions include, but are not limited to, the following transactions to the extent they are accepted: • purchasing travelers checks, foreign currency, money orders, wire transfers, cryptocurrency, other similar digital or virtual currency and other similar transactions; • purchasing lottery tickets, casino gaming chips, race track wagers, and similar offline and online betting transactions; • person-to-person money transfers and account-funding transactions that transfer currency; and • making a payment using a third-party service including bill payment transactions not made directly with the merchant or their service provider. We reserve the right to deny any purchase for any reason, such as account default, suspected fraudulent or unlawful activity, internet gambling, or any indication of increased risk related to the purchase. We may terminate or suspend your use of the Card or the Account, with or without notice to you before or at the time we take such action. Cash advances and balance transfers are not available under these Card Terms. You acknowledge and agree that you have read and understood the [Prohibitions List](https://legal.raincards.xyz/legal/prohibitions) and that you will not engage in any such activities when using the Services or the Delos Card. You acknowledge and agree that you will not use the Delos Card (1) for any expense which is not an expense incurred by you; (2) for any purpose prohibited by these Card Terms; or (3) for, with, or for the benefit of any individual or entity who is blocked or sanctioned by the United States, including those identified by the United States Department of Treasury’s Office of Foreign Assets Control (OFAC). You will use all reasonable means to protect your Delos Cards and log-in credentials to the Delos Account from unauthorized use. You will not allow any other person or third party to use the Services or the Delos Card on your behalf. You will immediately notify us where you know or suspect that access to your Delos Account has been compromised or your Delos Card has been lost, stolen, or compromised in any way. 6\. Payments 6.1 Promise to Pay While you will generally repay Delos for amounts transacted with your Card, you also promise to pay Issuer or its assignees for all amounts charged to the Account not repaid to Issuer by Partner, including all purchases, interest, and charges charged to your Account. Except as prohibited by applicable law, you are obligated to repay Delos or its assignees, for all transactions made using your Card by people you have authorized to use the Card even if their use of the Card exceeds the authorization which you gave them, 6.2 Periodic Statements You are responsible for payment in full of all Charges and Fees. Your Delos Account may furnish to you Periodic Statements identifying Charges, Fees, refunds, the amount of your Collateral, any other Card transactions, or other amounts owed or credited to your Delos Account. Periodic Statements may be made accessible to you on your Delos Account daily, monthly, or as otherwise prescribed by Issuer. You must notify us promptly if you believe that there are any errors on your Periodic Statement, and submit any disputes or Chargebacks in accordance with these Card Terms. We are not obligated to send you a monthly statement if we deem your Account to be uncollectible or applicable law does not require us to send you a monthly statement for other reasons. Your failure to get a statement will have no bearing on your obligations and Delos and Issuer may still liquidate your collateral per Section 3 of this agreement. 6.3 Repayment Where applicable, you may make a repayment for a balance on one or more of your Delos Cards by any means that are permitted by Delos and as provided in your Delos Account. Any failure to pay the full amount owed to Delos or the Issuer, as applicable, when required is a breach of these Card Terms. You are responsible for all costs or expenses that we may incur in collecting amounts owed but not timely paid, including legal or collections fees and any interest at the maximum rate permitted under law. 6.4 Prepayment At any time and where applicable, you may pay all or any part of your outstanding Account balance, without penalty. Payment of more than the payment due in one billing cycle will not relieve you of the obligation to pay the entire payment due in subsequent billing cycles. 7\. Fees. 1. The Fees applicable to your Account are described above. You are responsible for Fees in addition to Charges. 2. Returned Payment fees become payable by you each time a payment on your Account is returned or reversed for any reason or we must return any check, instrument, or transaction you send us because it is incomplete or faulty, we will charge you a returned payment fee of $29.00. However, we will not charge a returned payment fee if we are charging a late fee with respect to the same minimum payment due and will never charge a returned payment fee exceeding the minimum payment due that was due immediately prior to the date on which the payment was returned to us. 3. Foreign Currency Transactions. If you make a transaction using your Account in a foreign currency (including, for example, online purchases from a merchant located outside of the U.S.), the credit card association will convert any transaction in foreign currency into U.S. dollars using an exchange rate for the applicable central processing date that is (1) selected by the association from the range of rates available in wholesale currency markets, which rate may vary from the rate the association receives, or (2) the government mandated rate. The conversion rate you get may differ from the rate on the transaction date or the posting date, and from the rate that the credit card association gets. A merchant or other third party may convert a transaction into U.S. dollars or another currency, using a rate they select, before sending it to the credit card association. 4. Additional Services. We may, from time to time, make additional services available to you directly or through affiliated or non-affiliated third parties. Without limitation, such services may include providing you with virtual accounts in order to enable you to use your Account or otherwise engage in various financial transactions that we do not directly provide. Each such service is subject to its own terms and conditions, and we shall not be responsible to you for any aspect of those services. We may permit you to charge any applicable fees for such services to your Account. You acknowledge and agree that we may receive compensation or otherwise benefit as a result of making such services available to you. 8\. Managing Your Delos Cards 8.1 Requesting and Replacing Cards We or Delos may decide not to grant requests for Delos Cards or limit the number of physical or virtual Delos Cards provided to you. You are responsible for securing Delos Cards, account numbers, and Delos Card security features. You will promptly notify us and take appropriate measures to prevent unauthorized transactions when a Delos Card is lost, stolen, breached, or needs to be replaced. In such cases, you may request the issuance of replacement Delos Cards through your Delos Account. Replacement Cards may have new account numbers that could require you to update the Delos Card on file for any scheduled or recurring payments. You are solely responsible for updating Delos Card information stored with merchants where account numbers have been changed. 8.2 Permitted and Unauthorized Use You agree to establish and maintain controls designed to ensure that the Delos Cards are only used by you and your permitted authorized users for bona fide purposes and in compliance with these Card Terms, any Issuer terms, and applicable law. You are responsible for Charges and transactions made by any person given access to Delos Cards even if they are not the person associated with or named on the Delos Card. Delos, Issuer, Card Networks, or other intermediary third-party service providers (including merchant acquirers) may deny or reverse Charges for any reason. Issuer is not responsible for any losses, damages, or harm caused by any Charges that are denied or reversed. 8.3 Lost or Stolen Cards. If your Card is lost or stolen or if you think someone may be using your Card or Account without your permission, you must notify us promptly by emailing us at or calling us at +30 698 927 4199. You will not be liable for any unauthorized use that occurs after you notify us. You may, however, be liable for unauthorized use that occurs before receipt of your notice by us. You have an obligation to assist us in our investigation if your Delos Card is lost or stolen or you believe someone is using your Delos Card or your Delos Account without your permission. 9\. Chargebacks You are responsible for reviewing your Periodic Statements promptly and identifying any Charges that you believe are unauthorized or that you dispute. If you and a merchant have a dispute regarding a Charge identified on your Periodic Statement, such as delivery of incorrect goods or services or being charged the wrong amount, you should first attempt to resolve the dispute with the merchant. If the dispute is not resolved to your satisfaction or if you believe the Charge is unauthorized, you may initiate a Chargeback through your Delos Account. You must report any disputed Charge or error no more than 60 days after the disputed Charge is posted on your Periodic Statement. We may require additional details on the transaction and our review of your disputed Charge will be conditioned on you providing all of the information we may require to review the disputed Charge. You understand that the Delos Card is subject to Card Network rules regarding chargebacks. The Card Networks have additional established procedures for resolving chargebacks that may require you to provide further details of the disputed Charge or associated documentation. Charges relating to disputed Charges and Chargebacks that are pending resolution may still be due and owing as of the date that payment is due as provided in the applicable Periodic Statement. Chargebacks resolved in your favor will be credited to your Delos Account on either the current or a future Periodic Statement. We may impose Fees, reduce your spending limits, or suspend access to your Delos Account or the Services if you fail to pay Charges relating to Chargebacks that are pending resolution on the payment date. 10\. Termination Subject to applicable law, we may suspend, revoke or cancel your Account privileges, your right to use the Card or deny any transaction, in our sole discretion at any time, with or without cause and with or without giving you notice. Any termination of credit privileges, whether initiated by us or by you, will not affect any of our rights or your obligations under these Card Terms, including your obligation to repay any amounts you owe us according to the terms of these Card Terms. On our demand or upon termination of credit privileges, you agree to surrender to us or destroy the Card. If you attempt to use the Card after the termination of credit privileges (whether or not we have provided notice of such termination), the Card may be retained by a merchant, ATM or financial institution where you attempt to use the Card. 11\. Change of Terms Subject to applicable law, we may at any time change, add to or delete terms and conditions of these Card Terms, including interest rates and this Change of Terms provision. Such changes may be based on our anti-fraud policies and procedures, your level of compliance with these Card Terms, prevailing economic conditions and/or any other factors. We will give you notice of any change, addition or deletion as required by applicable law. As of the effective date, the changed terms, at our option, will apply to new purchases and the outstanding balances of your Account, to the extent permitted by applicable law. 12\. Default and Remedies We may consider you in default of these Card Terms if: * You do not make any payment when it is due; * Any payment you make is rejected, not paid or cannot be processed; * You exceed a credit limit; * A bankruptcy or other insolvency proceeding is filed by or against you; * We determine that you made a false, incomplete or misleading statement on any of your Account documentation, or you otherwise tried to defraud us; * We reasonably believe that you are or may become unable to pay all of your financial obligations; or * You do not comply with any term of these Card Terms or any other agreement with us. In the event of your default under these Card Terms, we may, subject to applicable law (including any applicable notice requirement): (a) declare all or any portion of your outstanding Account balance to be immediately due and payable; (b) instead allow you to repay your Account balance by paying the minimum payment due each billing cycle, without waiving any rights under subsection (a); and/or (c) commence a collection action against you and charge you for any court costs and/or any reasonable attorneys’ fees and costs we are charged in connection with such action by any attorney who is not our salaried employee. After a default, interest charges will continue to accrue until your total Account balance, including accrued interest charges, is paid in full, subject to applicable law. 13\. ‍ Delay in Enforcement We may at any time and in our sole discretion delay or waive enforcing any of our rights or remedies under these Card Terms or under applicable law without losing any of those or any other rights or remedies. Even if we do not enforce our rights or remedies at any one time, we may enforce them at a later date. For example, we may accept late payments without losing any of our rights under these Card Terms. 14\. Communications and Call Recording. You authorize Delos, Issuer and their partners (each of Issuer’s affiliates, agents, assigns, and service providers (collectively, the “Messaging Parties”) to use automatic telephone dialing systems, artificial or prerecorded voice message systems, text messaging systems and automated email systems, or any system capable of storing and dialing telephone numbers to deliver messages relating to these Card Terms, your Account, or your relationship with the Messaging Parties more generally (including but not limited to: messages about upcoming payment due dates, missed payments and returned payments) to any telephone number(s) you provide to the Messaging Parties. You also agree that these messages may deliver prerecorded and/or artificial voice messages. You understand that telephone messages may be played by a machine automatically when the telephone is answered, whether answered by you or someone else, and that these messages may also be recorded by your answering machine. You also authorize the Messaging Parties to deliver messages to you via mail or email at any addresses you supply to them or that they obtain through any legal means. By accepting these Card Terms or using your Card, you acknowledge that you have received, reviewed, and agree to be bound by the Issuer’s [E-Sign & Electronic Communications Notice](https://legal.raincards.xyz/legal/electronic-communications-notice) (the “E-Sign Notice”), which is incorporated herein by reference. You consent to receive all disclosures, notices, agreements, and other communications from Issuer and the Messaging Parties in electronic form, in accordance with the E-Sign Notice. You agree that such electronic communications satisfy any legal requirement that such communications be in writing. The E-Sign Notice may be amended by Issuer from time to time, and your continued use of the Card after any such amendment constitutes your acceptance of the amended E-Sign Notice. You understand that anyone with access to your mail, telephone or email account may listen to or read the messages the Messaging Parties leave or send you, and you agree that the Messaging Parties will have no liability for anyone accessing such messages. You further understand that, when you receive a telephone call, text message or email, you may incur a charge from the company that provides you with telecommunications, wireless and/or internet services, and you agree that the Messaging Parties will have no liability for such charges except to the extent required by applicable law. You expressly authorize the Messaging Parties to monitor and record your calls with the Messaging Parties. If any telephone number you have provided to the Messaging Parties changes, or if you cease to be the owner, subscriber, or primary user of any such telephone number, you agree to immediately give notice to the Messaging Party who delivered the messages of such facts so that the Messaging Party can update its records. This authorization is part of our bargain concerning these Card Terms, and we do not intend it to be revocable. However, to the extent you have the right to revoke your consent to communications by autodialed calls and text messages to your mobile number under applicable law, you may exercise this right by contacting the applicable Messaging Party directly or by sending a request by email to with the subject line “END COMMUNICATIONS.” You may opt-out of receiving most of these messages at any time by sending us a request to or by responding “STOP” to any text message. To stop emails only, you can follow the opt-out instructions included at the bottom of the Messaging Parties’ emails. 15\. Governing Law These Card Terms will be interpreted in accordance with the laws of Puerto Rico without regard to conflict-of-law provisions. Judicial proceedings (other than small claims actions) that are excluded from the Arbitration section below must be brought in state or federal court in Puerto Rico, unless we both agree in writing to some other location, and you hereby consent to the venue and personal jurisdiction of such court. 16\. Dispute Resolution & Arbitration PLEASE READ THIS "DISPUTE RESOLUTION AND ARBITRATION" PROVISION VERY CAREFULLY. IT LIMITS YOUR RIGHTS IN THE EVENT OF A DISPUTE BETWEEN YOU AND ISSUER. DELOS IS THE TECHNOLOGY PROVIDER FOR THE CARD BUT IS NOT THE ISSUER, CREDITOR OR LENDER. DELOS IS NOT A PARTY TO THESE CARD TERMS AND HAS NO LIABILITY FOR THE ISSUER’S OBLIGATIONS UNDER IT. HOWEVER, DELOS IS AN EXPRESS THIRD-PARTY BENEFICIARY OF THESE CARD TERMS WITH RESPECT TO ANY PROVISIONS THAT ALLOCATE RISK, DISCLAIM LIABILITY, LIMIT REMEDIES OR REQUIRE DISPUTES TO BE RESOLVED THROUGH ARBITRATION. ACCORDINGLY, TO THE EXTENT A DISPUTE INVOLVES DELOS, DELOS SHALL BE ENTITLED TO INVOKE AND BENEFIT FROM THE SAME PROTECTIONS, LIMITATIONS AND DISPUTE RESOLUTION PROCEDURES AS THE ISSUER. TO THE EXTENT YOU HAVE ANY DISPUTE YOU MAY HAVE WITH DELOS RELATING SOLELY TO SERVICES PROVIDED TO YOU UNDER YOUR SEPARATE USER TERMS WITH DELOS, SUCH DISPUTES WILL BE GOVERNED EXCLUSIVELY IN ACCORDANCE WITH THE DELOS USER TERMS. Binding Arbitration: (a) You and Issuer agree that any and all past, present and future Disputes (defined below) shall be determined by arbitration, unless your Dispute is subject to an exception to this agreement to arbitrate set forth below. You and Issuer further agree that any arbitration pursuant to this section shall not proceed as a class, group or representative action. The award of the arbitrator may be entered in any court having jurisdiction. “Dispute” means any dispute, claim, or controversy between you and Issuer that arises out of or relates to (i) these Card Terms (including any addenda hereto or other terms incorporated herein by reference), (ii) the breach, termination, enforcement, interpretation or validity hereof, including the determination of the scope or applicability of the agreement to arbitrate hereunder, or (iii) any Services (including, without limitation, the Delos Card). (b) This agreement to arbitrate shall be construed under and be subject to the Federal Arbitration Act, notwithstanding any other choice of law set out in these Card Terms. Arbitration Procedure: (a) Before filing a claim against Issuer, you agree to try to resolve the Dispute informally by providing written notice to Issuer of the actual or potential Dispute. Similarly, Issuer will provide written notice to you of any actual or potential Dispute to endeavor to resolve any claim we may possess informally before taking any formal action. The party that provides the notice of the actual or potential Dispute (the "Notifying Party") will include in that notice (a "Notice of Dispute") your name, the Notifying Party's contact information for any communications relating to such Dispute, and sufficient details regarding such Dispute to enable the other party (the "Notified Party") to understand the basis of and evaluate the concerns raised. If the Notified Party responds within ten (10) business days after receiving the Notice of Dispute that it is ready and willing to engage in good faith discussions in an effort to resolve the Dispute informally, then each party shall promptly participate in such discussions in good faith. (b) If, notwithstanding the Notifying Party's compliance with all of its obligations under the preceding paragraph, a Dispute is not resolved within thirty (30) days after the Notice of Dispute is sent (or if the Notified Party fails to respond to the Notice of Dispute within ten (10) business days), the Notifying Party may initiate an arbitration proceeding as described below. If either party purports to initiate arbitration without first providing a Notice of Dispute and otherwise complying with all of its obligations under the preceding paragraph, then, notwithstanding any other provision of these Card Terms, the arbitrator(s) will promptly dismiss the claim with prejudice and will award the other party all of its costs and expenses (including, without limitation, reasonable attorneys' fees) incurred in connection with such Dispute. (c) You and Issuer each agree to resolve any Disputes that are not resolved informally as described above through final and binding arbitration as discussed herein, except as set forth under Section 12.3 below. You and Issuer agree that the American Arbitration Association ("AAA") will administer the arbitration under its Consumer Arbitration Rules (the "Rules"). The Rules are available at [www.adr.org](http://www.adr.org) or by calling the AAA at 1-800-778-7879. A party who desires to initiate arbitration must provide the other party with a written Demand for Arbitration as specified in the AAA Rules. (The AAA provides a general Demand for Arbitration.) Arbitration will proceed on an individual basis and will be handled by a sole arbitrator. The single arbitrator will be either a retired judge or an attorney licensed to practice law and will be selected by the parties from the AAA's roster of arbitrators. If the parties are unable to agree upon an arbitrator within fourteen (14) days of delivery of the Demand for Arbitration, then the AAA will appoint the arbitrator in accordance with the AAA Rules. The arbitrator(s) shall be authorized to award any remedies, including injunctive relief, that would be available to you in an individual lawsuit, subject to any effective and enforceable limitations of liability or exclusions of remedies set forth herein. Notwithstanding any language to the contrary in this paragraph, if a party seeks injunctive relief that would significantly impact other Issuer users as reasonably determined by either party, the parties agree that such arbitration will proceed on an individual basis but will be handled by a panel of three (3) arbitrators. Each party shall select one arbitrator, and the two party-selected arbitrators shall select the third, who shall serve as chair of the arbitral panel. That chairperson shall be a retired judge or an attorney licensed to practice law and with experience arbitrating or mediating disputes. In the event of disagreement as to whether the threshold for a three-arbitrator panel has been met, the sole arbitrator appointed in accordance with this Section shall make that determination. If the arbitrator determines a three-person panel is appropriate, the arbitrator may -- if selected by either party or as the chair by the two party-selected arbitrators -- participate in the arbitral panel. Except as and to the extent otherwise may be required by law, the arbitration proceeding and any award shall be confidential. (d) You and Issuer further agree that the arbitration will be held in the English language in New York, New York, or, if you so elect, all proceedings can be conducted via videoconference, telephonically or via other remote electronic means. (e) Filing costs and administrative fees shall be paid in accordance with the AAA Rules; provided that the prevailing party will be entitled to recover its reasonable attorneys' fees, expert witness fees, and out-of-pocket costs incurred in connection with the arbitration proceeding, in addition to any other relief it may be awarded. (f) You and Issuer agree that, notwithstanding anything to the contrary in the Rules, the arbitration of any Dispute shall proceed on an individual basis, and neither you nor Issuer may bring a claim as a part of a class, group, collective, coordinated, consolidated or mass arbitration (each, a "Collective Arbitration"). Without limiting the generality of the foregoing, a claim to resolve any Dispute against Issuer will be deemed a Collective Arbitration if (i) two (2) or more similar claims for arbitration are filed concurrently by or on behalf of one or more claimants; and (ii) counsel for the claimants are the same, share fees or coordinate across the arbitrations. "Concurrently" for purposes of this provision means that both arbitrations are pending (filed but not yet resolved) at the same time. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, NEITHER YOU NOR ISSUER SHALL BE ENTITLED TO CONSOLIDATE, JOIN OR COORDINATE DISPUTES BY OR AGAINST OTHER INDIVIDUALS OR ENTITIES, OR ARBITRATE OR LITIGATE ANY DISPUTE IN A REPRESENTATIVE CAPACITY, INCLUDING AS A REPRESENTATIVE MEMBER OF A CLASS OR IN A PRIVATE ATTORNEY GENERAL CAPACITY. IN CONNECTION WITH ANY DISPUTE, ANY AND ALL SUCH RIGHTS ARE HEREBY EXPRESSLY AND UNCONDITIONALLY WAIVED. Without limiting the foregoing, any challenge to the validity of this paragraph shall be determined exclusively by the arbitrator. Small Claims: Notwithstanding your and Issuer’s agreement to arbitrate Disputes, You and Issuer retain the right to bring an individual action in small claims court. Class Waiver: To the extent applicable law permits, any dispute arising out of or relating to these Card Terms, whether in arbitration or in court, will be conducted only on an individual basis and not in a class, consolidated or representative action. Notwithstanding any other provision of these Card Terms or the AAA Rules, disputes regarding the interpretation, applicability, or enforceability of this class waiver may be resolved only by a court and not by an arbitrator. If this waiver of class or consolidated actions is deemed invalid or unenforceable, neither party is entitled to arbitration. No Jury Trial: If for any reason a claim or dispute proceeds in court rather than through arbitration, each party knowingly and irrevocably waives any right to trial by jury in any action, proceeding or counterclaim arising out of or relating to these Card Terms. Venue and Jurisdiction for Judicial Proceedings: Except as otherwise required by applicable law or provided in these Card Terms, in the event that the agreement to arbitrate is found not to apply to you or your Dispute, you and Issuer agree that any judicial proceeding may only be brought in a court of competent jurisdiction in Puerto Rico. Both you and Issuer irrevocably consent to venue and personal jurisdiction in Puerto Rico; provided that either party may bring any action to confirm an arbitral award in any court having jurisdiction. Confidentiality: The existence of all information regarding any Dispute will be held in strict confidence by the parties and will not be disclosed by either party except as reasonably necessary in connection with the conduct of the arbitration or the confirmation or enforcement of any arbitral award. Any such permitted disclosure will, to the maximum extent reasonably practicable, be made subject to obligations of confidentiality at least as stringent as the provisions of this paragraph. If any disclosure of information regarding any Dispute is required under applicable law, the parties shall reasonably cooperate with one another to obtain protective orders or otherwise to preserve the confidentiality of such information. 17\. Survival The following provisions of these Card Terms shall survive any termination or expiration of these Card Terms and shall remain in full force and effect until all of your obligations to us have been fully and finally satisfied: (a) all of your payment obligations and our right to collect all amounts owed by you; (b) all security interest, collateral, and setoff provisions, including our rights in any Collateral; (c) any indemnification obligations; (d) the limitation of liability provisions; (e) the disclaimer of warranties provisions; (f) the dispute resolution and arbitration provisions, including the class waiver; (g) our communications and contact rights; (h) our assignment rights; (k) any waiver provisions; (l) all representations and warranties made by you; (m) any accrued rights, remedies, or causes of action in favor of either party; and (n) any other provision that by its nature or express terms is intended to survive. 18\. Severability If any provision of these Card Terms is found to be invalid, illegal, or unenforceable by a court or arbitrator of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving its intent, or if such modification is not possible, such provision shall be severed from these Card Terms. The remaining provisions shall remain in full force and effect. Notwithstanding the foregoing paragraph, in the event that a court finds the prohibition of Collective Arbitration in Section 16 to be invalid or unenforceable, then all provisions in Section 16 shall be deemed void, except for any portion of any provision in Section 16 related to the resolution of Disputes through litigation in court. 19\. Assignment These Card Terms will be binding on, and benefit, any of your and our successors and assigns. You may not transfer your Account or your Agreement to someone else without our written permission. We may transfer your Account, these Card Terms, or any of our rights or obligations therein, to another company or person at any time, without your permission and without prior notice to you. If we do, they will take our place under these Card Terms. You must pay them and perform all of your obligations to them and not us. If you pay us after you are informed or learn that we have transferred your Account or this Agreement, we can handle your payment in any way we think is reasonable. This includes returning the payment to you or forwarding the payment to the other company or person. 20\. Entire Agreement These Card Terms constitute the entire agreement between you and Issuer regarding the subject matter hereof and supersede all prior or contemporaneous agreements, understandings, representations, and communications whether written or oral, regarding such subject matter. 21\. Force Majeure We shall not be liable for any delay or failure to perform any obligation under these Card Terms to the extent that such delay or failure is caused by circumstances beyond our reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, civil unrest, labor disputes, government actions, epidemics or pandemics, internet or telecommunications failures, or failures of third-party service providers. 22\. Disclaimer of Warranties TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE EXPRESSLY DISCLAIM ALL WARRANTIES, INCLUDING BUT NOT LMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, RELIABILITY, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE. 23\. Limitation of Liability TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL ISSUER, ITS AFFILIATES, OR ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, OR LICENSORS BE LIABLE TO YOU FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, PUNITIVE, OR OTHER SIMILAR DAMAGES, INCLUDING BUT NOT LIMITED TO LOST PROFITS, LOST REVENUE, LOST DATA, LOSS OF GOODWILL, BUSINESS INTERRUPTION, OR LOSS OF BUSINESS OPPORTUNITY, WHETHER ARISING IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE. IN NO EVENT SHALL ISSUER’S TOTAL LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THIS AGREEMENT OR YOUR ACCOUNT EXCEED THE LESSER OF (A) YOUR ACTUAL DIRECT DAMAGES PROVEN OR (B) THE TOTAL AMOUNTS PAID BY YOU IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM. 24\. Indemnity You will indemnify and defend Issuer, its affiliates, and its partners, directors, officers, employees, agents, trustees, administrators, managers, advisors, and representatives (each an “Indemnitee”) against, and hold each Indemnitee harmless from, any and all claims, litigation, investigations, proceedings, losses, damages, fines, penalties, liabilities, settlements, costs, fees, and expenses incurred by any Indemnitee or asserted against any Indemnitee by any person arising out of, in connection with, related to, or as a result of your (i) breach of any of the representations, warranties, or covenants contained in these Card Terms; or (ii) gross negligence, fraud, or violation of any applicable law or rights of any third-party. Issuer may defend any claim subject to indemnification hereunder, using counsel of its choice, and you will pay or promptly reimburse Issuer for the reasonable fees of such counsel and all related costs and reasonable expenses. If you are a user from a jurisdiction that does not allow certain indemnification obligations, you agree that this indemnity is intended to be as broad as permitted under the laws of such jurisdiction.\ \ \ \
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# Account Opening Privacy Notice | FACTS |

WHAT DOES THIRD NATIONAL (“ISSUER”) DO
WITH YOUR PERSONAL INFORMATION?

| | | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | --------------------------- | |


|


| | | Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. | | |


|


| | | What? |

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number and date of birth
  • Account balances and payment history
  • Credit history and credit scores

When you are no longer our customer, we continue to share your information as described in this notice.

| | |


|


| | | How? | All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Issuer chooses to share; and whether you can limit this sharing. | | |


|


| | | Reasons we can share your personal information | Does Issuer share? | Can you limit this sharing? | |

For our everyday business purposes—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

| YES | NO | |

For our marketing purposes—
to offer our products and services to you

| YES | NO | | For joint marketing with other financial companies | YES | NO | |

For our affiliates’ everyday business purposes—
information about your transactions and experiences

| YES | NO | |

For our affiliates’ everyday business purposes—
information about your creditworthiness

| NO | WE DON’T SHARE | | For our affiliates to market to you | NO | WE DON’T SHARE | | For nonaffiliates to market to you | NO | WE DON’T SHARE | |


|


| | |


|


| | | Questions? | Call +30 698 927 4199 or go to [legal.delos-banking.com](https://legal.delos-banking.com) | | | Who we are | | | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Who is providing this notice? | Issuer | |


|


| | What we do | | | How does Issuer protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. | | How does Issuer collect my personal information? |

We collect your personal information, for example, when you

  • open an account or perform transactions
  • pay your bills or reload funds
  • use your card

We may also collect your personal information from others, such as credit bureaus, affiliates, and other companies.

| | Why can’t I limit all sharing? |

Federal law gives you the right to limit only

  • sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

| |


|


| | Definitions | | | Affiliates |

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Issuer does share with our affiliates.
| | Nonaffiliates |

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Issuer does not share with nonaffiliates so they can market to you.
| | Joint marketing |

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Issuer may partner with certain non-affiliated financial companies to offer financial products and services to you.
| |


|


| | Other important information | | |

California and Vermont: In accordance with state law, we will not share your personal information with nonaffiliates except as permitted by law, including for example, for our own marketing purposes, for everyday business purposes,

such as servicing your account, or with your consent.

| | # Trust & Safety **Fraud & Security Centre** Protecting you is our priority. If you believe your account has been compromised or you’ve encountered suspicious activity, act immediately using the contacts below. **Report Suspicious Activity**\ Delos Financial Ltd.\ Email: \ Phone: +30 698 927 4199\ Available 24/7 for urgent security concerns To report suspected fraud, email us with:\ • Your name and client ID\ • A description of the suspicious activity\ • The date and amount involved (if applicable)\ • Any relevant screenshots or transaction IDs **Escalate to Regulators** Canada — FINTRAC\ 1-866-346-8722\ fintrac-canafe.gc.ca/reporting Canada — Canadian Anti-Fraud Centre (CAFC)\ 1-888-495-8501\ antifraudcentre-centreantifraude.ca United States — FinCEN\ fincen.gov/resources/reporting\ 1-800-767-2825 United States — CFPB\ 1-855-411-2372\ consumerfinance.gov/sending-money **How to Stay Safe** We will never:\ • Call or email you asking for your password, PIN, or one-time passcode\ • Ask you to send money to “verify” your account or reverse a transaction\ • Pressure you to act immediately without time to verify Watch out for:\ • Phishing emails — fake emails impersonating Delos Financial asking you to click a link or confirm account details. Always check the sender’s email domain ends in @delos.financial\ • Impersonation scams — someone posing as a Delos agent, government official, or law enforcement asking you to transfer funds urgently\ • Romance or investment scams — being asked by someone you’ve met online to send money through Delos Financial on their behalf\ • Unauthorized transactions — any transaction on your account you don’t recognise **If You Think You’ve Been Scammed** Act quickly — time matters with financial fraud: 1. Stop all transfers — do not send any further funds 2. Contact us immediately at or +30 698 927 4199 3. Change your password and 2FA code through the Delos app or website 4. Report to the Canadian Anti-Fraud Centre at 1-888-495-8501 or antifraudcentre-centreantifraude.ca 5. Report to local police and obtain a case reference number 6. Contact your bank if your bank account or card was used **Verify You’re Talking to Delos Financial** If you receive an unexpected call or message claiming to be from Delos Financial and are unsure it is genuine, hang up or do not reply, then contact us directly using the details at the top of this page. Our only official contact channels are:\ • Emails with the @delos.financial domain\ • Phone: +30 698 921 4199\ • [www.delos-banking.com](http://www.delos-banking.com) and # Whitepaper ## Delos Security Whitepaper ## Security at Delos ### Building Trust Through Security At Delos, security is not treated as a standalone function or\ compliance exercise. It is a fundamental business capability that\ supports the trust placed in us by our customers, partners, and\ stakeholders. We recognize that safeguarding information, maintaining\ operational resilience, and protecting the integrity of our services\ are essential responsibilities. Security considerations are embedded\ throughout our governance, operational processes, technology\ lifecycle, and decision-making practices. Our objective is to maintain a security program that is\ proportionate to the risks we manage, aligned with recognized\ international standards, and continuously evolving to address\ emerging threats and changing business requirements. ### Security Governance Delos maintains a structured information security program\ supported by executive leadership and integrated into organizational\ governance processes. The program is designed to provide oversight of information\ security risks, support informed decision-making, promote\ accountability, and ensure that security objectives remain aligned\ with business priorities. Security responsibilities are formally assigned, and governance\ activities include risk management, policy oversight, control\ effectiveness reviews, incident management, third-party risk\ management, and continuous improvement initiatives. ### Risk-Based Security Approach Delos applies a risk-based methodology to the design,\ implementation, and operation of security controls. Security, operational, technology, vendor, and business risks are\ regularly identified, assessed, evaluated, and managed through\ established governance processes. Risk management activities support\ the prioritization of security initiatives and the ongoing\ improvement of the control environment. This approach enables Delos to maintain a balanced and sustainable\ security posture while supporting business growth and innovation. ### Security Program The Delos security program incorporates administrative, technical,\ and organizational measures intended to protect the confidentiality,\ integrity, and availability of information and services. The program includes areas such as: * Information security governance * Identity and access management * Vulnerability management * Security monitoring and response * Secure development practices * Third-party risk management * Business continuity and resilience * Security awareness and training * Data protection and privacy controls * Continuous assessment and improvement Security activities are periodically reviewed to ensure continued\ effectiveness and alignment with evolving risks and business needs. ### Secure Operations Delos maintains operational processes designed to support the\ secure and reliable delivery of services. Security considerations are incorporated into the management of\ systems, applications, changes, vendors, and operational activities.\ Processes are established to support the identification, evaluation,\ escalation, and remediation of security-related issues when\ appropriate. Operational resilience and service reliability remain important\ considerations across all stages of service delivery. ### Product and Development Security Security is considered throughout the lifecycle of products and\ technology services. Development, deployment, and change management activities are\ supported by security practices intended to reduce risk, promote\ consistency, and strengthen the overall security posture of the\ organization. Security requirements are incorporated into relevant stages of\ planning, implementation, testing, and operational management. ### Security Monitoring and Incident Management Delos maintains capabilities intended to support the\ identification, assessment, investigation, and management of security\ events and incidents. Established processes guide incident handling activities,\ including assessment, escalation, containment, recovery,\ communication, and post-incident review where applicable. Lessons learned from operational events are used to strengthen\ processes, controls, and organizational resilience. ### Business Continuity and Operational Resilience Maintaining the continuity of critical business operations is an\ important element of the Delos security program. Business continuity and recovery capabilities are designed to\ support operational resilience and help ensure that services can\ continue to be delivered or restored following disruptive events. These capabilities are reviewed periodically as part of the\ organization's ongoing risk management and resilience efforts. ### Third-Party Risk Management Delos recognizes the importance of managing risks associated with\ external service providers and business partners. Third-party relationships are evaluated using a risk-based\ approach that considers factors such as security, operational\ resilience, regulatory obligations, and business impact. Appropriate oversight activities are performed throughout the\ lifecycle of applicable vendor relationships. ### Security Awareness and Culture Security is a shared responsibility across the organization. Personnel are expected to understand and fulfill their security\ responsibilities through adherence to established policies,\ procedures, and standards. Security awareness initiatives support a\ culture of accountability, risk awareness, and responsible handling\ of information and technology resources. ### Continuous Improvement Delos views security as an ongoing process rather than a fixed\ state. Our security program is regularly reviewed and enhanced through\ governance activities, risk assessments, operational experience,\ industry developments, and evolving business requirements. This commitment to continuous improvement helps ensure that\ security remains effective, relevant, and aligned with organizational\ objectives. ### Alignment with Recognized Standards The Delos security program is informed by recognized international\ security frameworks, standards, and industry best practices. These include principles and control domains commonly associated\ with: * ISO/IEC 27001:2022 * SOC 2 Trust Services Criteria * NIST Cybersecurity Framework * OWASP Security Practices Delos continues to invest in the maturity and effectiveness of its\ security and compliance capabilities as part of its long-term\ operational strategy. ### Contact For security, compliance, privacy, or third-party risk management\ inquiries, please contact: [**security@delos.financial**](mailto:security@delos.financial) # Brand Guidelines, Fonts & Logo Official Delos brand assets for internal use and approved partners. The pack contains the wordmark and mark in SVG and PNG (positive and reversed), the colour palette with CSS and JSON tokens, typography sources and licensing notes, the production favicon set, and a 7-page brand guidelines PDF covering logo usage, clearspace, minimum sizes, colour, typography, and components. Do not recolour, outline, skew, or apply effects to the logo. Place the positive logo only on solid light surfaces and the reversed logo only on dark surfaces. For anything not covered by the guidelines, contact the brand team before publishing. {% file src="/files/24xZJ15NbBAyDGSLYU8K" %}