PUBLIC OFFER AGREEMENT

for Access to Cryptopayments Services by Individual Users

Last Updated: 26 May 2026

This Public Offer Agreement (“Public Offer”) is issued by LUNORA SOCIEDAD DE RESPONSABILIDAD LIMITADA, a company incorporated in the Republic of Costa Rica with legal entity identification number 3-102-919451, having its registered office at San José Sfera EBC Centro Corporativo, 8th floor, San José, Escazú, Costa Rica (“Company”, “Lunora”, “we”, “us” or “our”).

This Public Offer sets out the terms on which an individual user may enter into a legally binding agreement with the Company for access to and use of the Services made available under the Cryptopayments brand through the Website for personal, non-business purposes.

For the purposes of this Public Offer, “User” means an Individual User who accepts this Public Offer, registers an Account, accesses or uses the Services for personal, non-business purposes. Capitalised terms not defined herein shall have the meanings given to them in the Terms and Conditions published on the Website.

This Public Offer applies exclusively to Individual Users. This Public Offer does not apply to Business Users, Merchants, legal entities, organisations, sole proprietors or any person accessing or using the Services for business, professional, commercial, merchant, resale, third-party processing or similar purposes.

By registering an Account, submitting onboarding information, clicking “I agree”, “I accept”, “Start” or any similar acknowledgement, accessing or using the Services, the User confirms that the User has read, understood and agrees to be bound by this Public Offer, the Terms and Conditions, the Privacy Policy, the Fee Schedule, the Risk Disclosure and any other Supplementary Terms applicable to the relevant Services, each as made available on the Website at the time of acceptance.

The Terms and Conditions, Privacy Policy, Fee Schedule, Risk Disclosure and applicable Supplementary Terms form an integral part of this Public Offer and are incorporated herein by reference.

The User acknowledges and accepts that the Company is incorporated in the Republic of Costa Rica and that this Public Offer and the relationship between the User and the Company are governed by the laws of the Republic of Costa Rica, subject to any mandatory rights or protections available to the User under Applicable Law.

The User further acknowledges that the Services are not offered as regulated banking, deposit-taking, investment, securities, portfolio management, payment services, electronic money services or other regulated financial services. The User independently decides to access and use the Services provided by a Costa Rica-incorporated company and accepts the legal, regulatory, technical, operational and Digital Asset-related risks associated with such use.

The Company may provide or facilitate access to Wallet Services, Exchange Services, Fiat Payments, on-ramp, off-ramp, crypto-to-crypto swaps and other Services involving Supported Digital Assets, subject to successful onboarding, verification, KYC, KYT, sanctions screening, fraud prevention, Partner Requirements, technical availability and Applicable Law.

The User acknowledges that access to the Services is not guaranteed and may be refused, delayed, restricted, suspended, frozen or terminated in accordance with this Public Offer, the Terms and Conditions, Partner Requirements, internal policies and Applicable Law.

The User acknowledges and accepts that the Services, the Website, the Account Interface, any Wallet, Order, transaction, functionality, information, content, data, technical infrastructure and related materials made available by or on behalf of the Company are provided on an “as is” and “as available” basis, subject to Applicable Law, technical availability, blockchain network conditions, Partner Requirements, Supported Digital Asset availability and the Company’s compliance, security and risk-control requirements.

The User further acknowledges that the User independently determines whether the Services are suitable for the User’s intended personal use and accesses and uses the Services voluntarily and at the User’s own risk, including the risk of partial or total loss of Digital Assets or their value.

The User acknowledges that the Company does not guarantee uninterrupted access to the Services, successful execution of any Order, availability of any Supported Digital Asset, recoverability of Digital Assets sent to an incorrect address, or preservation of the market value of any Digital Asset.

The User further acknowledges that Digital Assets are not legal tender, fiat currency, electronic money, bank deposits, securities or protected investment products. The value of Digital Assets may fluctuate significantly, and the User may lose the entire value of the User’s Digital Assets.

The Company does not provide investment, financial, legal, tax, trading, portfolio management, brokerage, securities dealing, banking, payment services, electronic money services or other regulated financial services. The Services are provided on an execution-only, technical, operational or commercial basis in relation to Supported Digital Assets, as further described in the Terms and Conditions.

1. SERVICES PROVIDED

1.1. Under this Public Offer, the Company may provide or facilitate access to the Services made available under the Cryptopayments brand through the Website, Account Interface or any other approved access channel, for the purpose of enabling the User to access and use Wallet Services and related Digital Asset services for personal, non-business purposes.

1.2. The Services may include, subject to availability, successful completion of onboarding, KYC, KYT, sanctions screening, fraud prevention and other compliance checks, Partner Requirements, technical availability, Supported Digital Asset availability, blockchain network conditions and Applicable Law:

(a) creation and maintenance of an Account and Wallet;

(b) receipt of Supported Digital Assets;

(c) custody, safeguarding and storage of Supported Digital Assets through a Wallet, where such functionality is available;

(d) withdrawal, sending or transfer of Supported Digital Assets to wallet addresses specified by the User;

(e) exchange, conversion or swap of Supported Digital Assets, where such functionality is available;

(f) access to transaction history, Wallet records and account-related information through the Website or Account Interface; and

(g) any other Services or wallet-related functionality made available by the Company from time to time.

1.3. The Company is not obliged to make all Services available to the User. The Company may determine, restrict, suspend, modify or withdraw the Services available to the User based on the User’s jurisdiction, onboarding status, verification results, risk profile, transaction history, Partner Requirements, technical availability, internal policies or Applicable Law.

1.4. The User is solely responsible for the accuracy and completeness of all information, documents, confirmations and instructions provided to the Company or submitted through the Website, Account Interface or any other approved access channel, including wallet addresses, blockchain networks, transaction amounts, tags, memos, payment identifiers, source of funds information, source of Digital Assets information and any other details required for the execution or review of a transaction.

1.5. The User shall use the Services only for lawful personal, non-business purposes and in compliance with this Public Offer, the Terms and Conditions, applicable Supplementary Terms, Partner Requirements and Applicable Law. The User shall not use the Services for any unlawful, fraudulent, sanctioned, prohibited, abusive, commercial, merchant, third-party processing, resale or unauthorised activity, or in any manner that may cause the Company, its Partners, other Users or any third party to breach Applicable Law, sanctions restrictions, compliance obligations, Partner Requirements or risk-control requirements.

1.6. The User acknowledges that transactions involving Digital Assets may be irreversible once submitted to, broadcast to, confirmed on or otherwise processed through the relevant blockchain network, Partner, Wallet infrastructure or approved access channel. The Company does not guarantee that any transaction can be cancelled, amended, refunded, reversed or recovered after submission or confirmation.

1.7. The User agrees to pay all applicable fees, commissions, spreads, network fees, Partner fees, service fees, administrative fees and other charges applicable to the Services as disclosed in the Fee Schedule, the relevant transaction interface, the Account Interface, the Terms and Conditions or applicable Supplementary Terms.

1.8. This Section 1 is without prejudice to the more detailed provisions on the scope, availability, limitations, fees, refunds, Chargebacks, Order amendments, Wallet Services, KYT process and transaction finality set out in the Terms and Conditions.

2. TERM, ACCOUNT CLOSURE AND TERMINATION

2.1. This Public Offer becomes binding on the User when the User accepts it by registering an Account, submitting onboarding information, clicking “I agree”, “I accept”, “Start” or any similar acknowledgement, accessing or using the Services, or otherwise expressing acceptance through the Website, Account Interface or any other approved access channel.

2.2. The agreement between the User and the Company formed by acceptance of this Public Offer shall remain in force until terminated in accordance with this Public Offer, the Terms and Conditions, applicable Supplementary Terms, Partner Requirements or Applicable Law.

2.3. The User may stop using the Services at any time and may request closure of the User’s Account through the official support channels made available by the Company. Account closure shall be processed in accordance with the Terms and Conditions and may be subject to identity verification, ownership verification, security checks, outstanding obligations, pending Orders, pending transactions, unresolved Chargebacks, disputes, investigations, compliance reviews, sanctions restrictions, legal holds, Partner Requirements, outstanding fees or other legal, regulatory, operational or technical restrictions.

2.4. The Company may refuse, suspend, restrict, freeze, block or terminate the User’s access to any Account, Wallet, Balance, Order, transaction or Service, or terminate the relationship with the User, where the Company reasonably considers such action necessary or appropriate for legal, regulatory, compliance, AML/CTF, sanctions, fraud prevention, security, technical, operational, Partner Requirements or risk management reasons.

2.5. Without limitation, the Company may take any action under Clause 2.4 where:

(a) the User breaches this Public Offer, the Terms and Conditions, any Supplementary Terms, Partner Requirements or Applicable Law;

(b) the User provides false, inaccurate, incomplete, outdated, misleading, inconsistent or unverifiable information;

(c) the User fails to provide requested KYC, KYT, source of funds, source of Digital Assets, transaction, wallet ownership or other required information or documentation;

(d) the User, Account, Wallet, Balance, Order, transaction, payment method, Digital Asset, external wallet, counterparty, jurisdiction or activity raises sanctions, AML/CTF, fraud, security, Chargeback, scam, stolen funds, source of funds, source of Digital Assets or other compliance concerns;

(e) the Company is required or requested to do so by Applicable Law, competent authority, court, regulator, law enforcement body, Partner, payment provider, bank, blockchain analytics provider or other relevant third party;

(f) the Company reasonably considers such action necessary to protect the Company, its Partners, Users, Digital Assets, systems, reputation or third parties.

2.6. Termination, suspension, restriction, freezing or blocking shall not affect any rights, remedies, fees, charges, commissions, liabilities, indemnities, limitations of liability, compliance obligations, recordkeeping obligations or other obligations accrued before the effective date of such action.

2.7. Upon termination or Account closure, the User must settle all outstanding fees, charges, commissions, liabilities and other amounts owed to the Company. The Company may deduct, set off or withhold such amounts from the User’s Account, Wallet, Balance, transaction amount, settlement amount or any other amount payable by the Company to the User, to the extent permitted by Applicable Law and in accordance with the Terms and Conditions.

2.8. Any remaining Balance after termination or Account closure shall be handled in accordance with the Terms and Conditions. The Company may delay, restrict, freeze, block, reject or refuse withdrawal of any remaining Balance where required or permitted due to Applicable Law, sanctions restrictions, compliance review, Partner Requirements, technical limitations, security concerns, pending disputes, investigations, Chargebacks or other restrictions under the Terms and Conditions.

2.9. Any provisions of this Public Offer which by their nature are intended to survive termination shall remain in force after termination, including provisions relating to fees, compliance, AML/CTF, sanctions, data retention, confidentiality, intellectual property, liability, indemnity, dispute resolution, governing law and any other provisions necessary to give effect to accrued rights and obligations.

2.10. This Section 2 is without prejudice to the more detailed termination, suspension, administrative hold, remaining Balance and data retention provisions set out in the Terms and Conditions.

3. NOTICES AND COMMUNICATIONS

3.1. The User must maintain accurate, complete and up-to-date contact details in the User’s Account, including email address, phone number and any other contact information requested by the Company for the purposes of communication, onboarding, verification, security, compliance, transaction review and use of the Services.

3.2. The Company may send notices, requests, disclosures, updates, legal communications, service communications, compliance requests, security notifications and other communications to the User through any of the following methods:

(a) email address registered in the User’s Account;

(b) Account Interface;

(c) Website notification;

(d) in-platform or in-app notification;

(e) support ticket or official support channel;

(f) phone, messenger or other contact method provided by the User, where appropriate;

(g) any other reasonable communication method made available by the Company.

3.3. The User is responsible for regularly checking the User’s email, Account Interface, Website notifications and other communication channels used in connection with the Services.

3.4. Any notice or communication sent by the Company to the contact details registered in the User’s Account shall be deemed received by the User on the date of sending, publication or delivery, unless the Company receives an automatic delivery failure notification or has clear evidence that the communication was not delivered.

3.5. The User must promptly notify the Company of any change to the User’s contact details. The Company shall not be responsible for any loss, delay, restriction, missed notice, failed transaction, suspension, Account closure or other consequence arising from the User’s failure to keep contact details accurate and up to date.

3.6. Communications from the User to the Company must be submitted through the official support channels, contact details or other communication methods made available on the Website or through the Account Interface.

3.7. The Company may require the User to complete identity verification, security checks or other verification steps before acting on any instruction, request, notice or communication received from or purportedly sent by the User.

3.8. For contact details of the Company, the User should refer to the contact information made available on the Website.

4. REGISTRATION, VERIFICATION AND USE CONDITIONS

4.1. To access and use the Services, the User must complete the registration, onboarding, identification, verification and compliance checks required by the Company, including KYC, KYT, sanctions screening, fraud prevention, source of funds checks, source of Digital Assets checks and any other checks reasonably required by the Company.

4.2. The User shall provide all information, documents, confirmations and explanations reasonably requested by the Company for the purposes of onboarding, verification, compliance checks, transaction review, fraud prevention, sanctions screening, security, risk assessment and use of the Services.

4.3. Such information may include, without limitation, information relating to the User’s identity, date of birth, citizenship, residential address, contact details, identification document, selfie or liveness check, payment account details, wallet addresses, source of funds, source of Digital Assets, purpose of using the Services, expected transaction activity, origin and destination of transactions, transaction participants and any other information required by the Company or its Partners.

4.4. The User shall ensure that all information, documents, confirmations and instructions provided to the Company are true, accurate, complete, up to date and not misleading.

4.5. The User must promptly update any information previously provided to the Company if such information becomes inaccurate, outdated, incomplete or misleading.

4.6. The Company may rely on the information, documents, confirmations and transaction instructions provided by the User and shall not be responsible for any delay, rejection, restriction, suspension, loss, failed transaction, incorrect transfer or other consequence resulting from inaccurate, incomplete, outdated, misleading or unverifiable information provided by the User.

4.7. The Company shall provide or facilitate access to the Services in accordance with this Public Offer, the Terms and Conditions, applicable Supplementary Terms, Website functionality, Account Interface functionality, technical availability, blockchain network conditions, Partner Requirements, Applicable Law and the Company’s compliance, security and risk-control requirements.

4.8. Completion of registration, onboarding or verification does not guarantee continued access to the Services. The Company may conduct ongoing due diligence, transaction monitoring, KYT checks, sanctions screening, fraud checks and other compliance reviews at any time in accordance with the Terms and Conditions.

4.9. The Company may refuse onboarding, reject registration, delay activation, restrict access, request additional information or decline to provide any Service where the Company reasonably considers that the User, Account, Wallet, transaction, payment method, Digital Asset, external wallet, counterparty, jurisdiction, source of funds, source of Digital Assets or intended use of the Services raises legal, compliance, sanctions, AML/CTF, fraud, security, technical, Partner Requirements or risk-control concerns.

5. COMPLIANCE, AML/CTF AND SANCTIONS CONTROLS

5.1. The Company may refuse, delay, withhold, suspend, restrict, freeze, block, cancel or terminate any Account, Wallet, Balance, Order, transaction, Wallet functionality or access to any Service if the Company reasonably believes or suspects that:

(a) the User, any transaction participant, recipient, sender, wallet address, payment method, protocol, Digital Asset, service or other relevant party appears on, or is connected with, any sanctions, watchlist, adverse media, high-risk, restricted or prohibited list;

(b) the transaction involves any country, region, sector, person, entity, wallet address, protocol, Digital Asset, service or activity subject to sanctions, restrictions, elevated risk controls or Partner Requirements;

(c) the transaction may constitute, facilitate or be connected with money laundering, terrorist financing, proliferation financing, fraud, sanctions evasion, unlawful activity, scam activity, stolen funds or suspicious activity;

(d) the User fails to provide requested information, documents, confirmations or explanations in a timely, accurate and complete manner;

(e) the transaction appears to violate Applicable Law, sanctions restrictions, AML/CTF requirements, Partner Requirements, the Terms and Conditions, this Public Offer, any Supplementary Terms or the Company’s internal compliance or risk-control policies;

(f) the transaction materially deviates from the User’s declared profile, expected use of the Services, risk profile or previous transaction activity;

(g) the User commits or is suspected of committing a breach of this Public Offer, the Terms and Conditions, any Supplementary Terms, Partner Requirements or Applicable Law;

(h) execution of the transaction or provision of the Services is prohibited, restricted, not supported or not acceptable under Applicable Law, competent authority instructions, Partner Requirements, technical limitations or internal risk assessment;

(i) execution is prevented or materially affected by technical, operational, blockchain network, liquidity, Wallet infrastructure, cybersecurity or other issues, or by Partner Requirements;

(j) the User provides false, misleading, incomplete, outdated, inconsistent, unverifiable or fabricated information or documents;

(k) there is any suspected loss, theft, compromise, account takeover, unauthorised access or unauthorised use of the User’s Account, Wallet, credentials, wallet details, payment details, devices or other access methods; or

(l) the Company considers such action necessary to protect the Company, its Partners, Users, Digital Assets, systems, reputation, third parties or the integrity and security of the Services.

5.2. The Company may request additional information, documents, confirmations or explanations from the User at any time where required or considered appropriate for compliance, AML/CTF, sanctions screening, fraud prevention, transaction review, security, source of funds, source of Digital Assets, wallet ownership, risk-control or other legitimate purposes connected with the Services.

5.3. Where legally and practically permitted, the Company may notify the User of any refusal, delay, withholding, suspension, restriction, freezing, blocking, cancellation or termination under this Section 5.

5.4. The Company shall not be required to provide any notice, reason, explanation or disclosure where doing so may breach Applicable Law, sanctions restrictions, AML/CTF requirements, security requirements, Partner Requirements, instructions of a competent authority, law enforcement request, court order or the Company’s internal compliance, security or risk-control procedures.

5.5. The Company shall not be liable for any loss, delay, damage, rejection, suspension, restriction, freezing, blocking, non-execution, failed transaction, missed opportunity, market movement, loss of value or other consequence arising from any action taken in good faith under this Section 5, except to the extent such liability cannot be excluded under Applicable Law or arises from the Company’s fraud, wilful misconduct or gross negligence.

5.6. Where the reasons for refusal, suspension, freezing, withholding, blocking or restriction cease to exist, the Company may, at its discretion and subject to Applicable Law, technical availability, Website functionality, Account Interface functionality, blockchain network conditions, Partner Requirements, compliance checks and internal risk assessment, reinstate access to the Services or process the relevant transaction.

5.7. If a transaction or Service is not executed and the User has already paid a specific amount for such unexecuted transaction or Service, the Company may refund such amount to the User in accordance with the Terms and Conditions, the Fee Schedule and applicable Supplementary Terms, unless prohibited or restricted by Applicable Law, sanctions restrictions, AML/CTF requirements, competent authority instructions, Partner Requirements, technical restrictions, security concerns or risk-control requirements.

5.8. Any refund under Clause 5.7 may be subject to deduction of applicable fees, network fees, Partner fees, third-party charges, exchange differences, costs already incurred and any amounts owed by the User to the Company, in accordance with the Terms and Conditions and the Fee Schedule.

5.9. This Section 5 is without prejudice to the more detailed provisions on KYC, KYT, transaction monitoring, sanctions controls, restricted jurisdictions, prohibited activities, Wallet restrictions, refunds, Chargebacks, Order amendments, suspension, termination, administrative holds and remaining Balance set out in the Terms and Conditions.

6. NO ADVICE

6.1. The User acknowledges that the Company does not provide investment, financial, legal, tax, trading, portfolio management, brokerage, securities dealing, banking, payment services, electronic money services or other regulated financial or advisory services.

6.2. Nothing in this Public Offer, the Terms and Conditions, the Website, the Account Interface, any Risk Disclosure, support communication or other communication from or on behalf of the Company shall be treated as advice, recommendation, solicitation, guarantee or assurance in relation to any Digital Asset, Wallet, Order, transaction, transfer, exchange, conversion, swap or use of the Services.

6.3. The User is solely responsible for making independent decisions regarding the use of the Services and any receipt, holding, storage, withdrawal, sending, transfer, exchange, conversion or other interaction with Digital Assets.

6.4. The Company may provide technical, operational, compliance-related, transaction-related or general informational materials through the Website, Account Interface, support channels or other communication methods. Such information is provided for informational purposes only and shall not constitute advice, a recommendation or a representation that any Digital Asset or transaction is suitable for the User.

6.5. This Section 6 is without prejudice to the more detailed provisions on no financial, investment, legal or tax advice set out in the Terms and Conditions.

7. SECURITY

7.1. The User shall access and use the Services only through authentication methods made available or required by the Company, including username, password, two-factor authentication, device verification, transaction confirmation, withdrawal confirmation or any other security procedure required by the Company from time to time.

7.2. The User is solely responsible for maintaining the confidentiality and security of the User’s Account credentials, passwords, authentication codes, devices, email account, phone number, two-factor authentication credentials, backup codes, API keys, payment details, wallet details and any other access or authentication information connected with the Services.

7.3. The User shall not disclose, share, transfer, sell, lend or otherwise make available the User’s Account, credentials, Wallet access rights, authentication tools, API keys or access details to any third party, unless expressly approved by the Company in writing.

7.4. The User shall immediately notify the Company through official support channels if the User becomes aware of, or suspects, any loss, theft, compromise, unauthorised access, unauthorised use, phishing attempt, security breach, account takeover or other security incident relating to the User’s Account, credentials, devices, Wallet, payment details or use of the Services.

7.5. The User shall use secure communication channels and shall not transmit passwords, authentication codes, backup codes, private keys, seed phrases, wallet access details or other sensitive access information through unsecured channels, including email, messaging applications or other unprotected means.

7.6. The Company may suspend, restrict, freeze, block or terminate access to the Account, Wallet, Balance, Order, transaction or Services if the Company reasonably suspects unauthorised access, security breach, account takeover, compromise of credentials, misuse of the Account, phishing, fraud, malware, cyberattack or other security risk.

7.7. The Company shall not be liable for any loss, damage, delay, unauthorised transaction, failed transaction, restriction, suspension, loss of access or other consequence arising from the User’s failure to comply with this Section 7 or from any use of the User’s credentials, devices, authentication tools or access details by third parties, except to the extent such liability cannot be excluded under Applicable Law or arises from the Company’s fraud, wilful misconduct or gross negligence.

7.8. This Section 7 is without prejudice to the more detailed provisions on Account security, Wallet security, unauthorised access, transaction monitoring, suspension and liability set out in the Terms and Conditions.

8. LIMITATION OF LIABILITY

8.1. To the fullest extent permitted by Applicable Law, the Company, its Affiliates, directors, officers, employees, contractors, representatives, Partners and service providers shall not be liable for any indirect, incidental, special, punitive, exemplary, consequential or similar losses or damages, including loss of profit, loss of opportunity, loss of data, loss of goodwill, loss of expected savings, loss in value of Digital Assets, market movement, business interruption or any similar loss.

8.2. The Company shall not be liable for any loss, damage, delay, failed transaction, unauthorised transaction, restriction, suspension, freezing, blocking, interruption, rejection, non-execution or other consequence arising from:

(a) the User’s incorrect, incomplete, outdated, misleading, inconsistent or unverifiable information, documents, confirmations or instructions;

(b) incorrect wallet addresses, incorrect blockchain networks, unsupported Digital Assets, missing or incorrect tags, memos, payment identifiers or other transaction details provided by the User;

(c) actions or omissions of third parties using the User’s credentials, devices, Account access details, Wallet access rights, email account, phone number, authentication tools or other access methods;

(d) unauthorised access, cyberattacks, phishing, malware, technical failures, blockchain network failures, forks, congestion, protocol changes, validator or miner delays or other events outside the Company’s reasonable control;

(e) actions, omissions, restrictions, delays, failures, fees or requirements of blockchain networks, wallet providers, payment providers, liquidity providers, banking providers, technology providers, custody infrastructure providers, blockchain analytics providers, compliance providers, Partners, counterparties or other third-party service providers;

(f) compliance, AML/CTF, sanctions, fraud prevention, security, transaction monitoring, KYT, Partner Requirements or risk-control actions taken by the Company in good faith;

(g) regulatory, legislative, tax, market, liquidity, Digital Asset value, blockchain network or technical changes;

(h) force majeure events or other circumstances beyond the Company’s reasonable control.

8.3. The Company does not guarantee uninterrupted, error-free, continuous or real-time operation of the Services, the Website, the Account Interface, any Wallet, any Order, any transaction, any blockchain network or any Partner service, or that they will be free from cyber risks, vulnerabilities, interruptions or technical limitations.

8.4. To the fullest extent permitted by Applicable Law, the Company’s total aggregate liability to the User under or in connection with this Public Offer, the Terms and Conditions, the Services, any Account, Wallet, Order, transaction, Digital Asset, Fiat Payments or any related functionality shall not exceed the total amount of fees paid by the User to the Company in the twelve (12) months immediately preceding the event giving rise to the claim.

8.5. For any transaction that is rejected, delayed, blocked, frozen, cancelled or declined due to compliance, sanctions, AML/CTF, fraud prevention, security, risk management, Partner Requirements or Applicable Law, the Company’s liability shall be limited to the refund of any fees charged by the Company for that rejected transaction, if any, unless such limitation is prohibited by Applicable Law.

8.6. Nothing in this Public Offer shall exclude or limit liability for fraud, fraudulent misrepresentation, wilful misconduct, gross negligence, intentional violation of law or any other liability that cannot be excluded or limited under Applicable Law.

8.7. If the User acts as a consumer under Applicable Law, nothing in this Public Offer limits any mandatory statutory rights that cannot be excluded or limited under Applicable Law.

8.8. This Section 8 is without prejudice to the more detailed disclaimer of warranties, exclusion of damages, limitation of liability, indemnity and no double recovery provisions set out in the Terms and Conditions.

9. FEES

9.1. The User agrees to pay all applicable fees, commissions, spreads, network fees, Partner fees, service fees, administrative fees and other charges applicable to the Services as disclosed in the Fee Schedule, the Account Interface, the relevant transaction interface, the Terms and Conditions or applicable Supplementary Terms.

9.2. The Fee Schedule forms an integral part of this Public Offer and the Terms and Conditions. By accepting this Public Offer or using the Services, the User confirms that the User has read, understood and agreed to the Fee Schedule applicable at the time of acceptance or use of the relevant Service.

9.3. Applicable fees may be calculated as a percentage of the relevant transaction amount, as a fixed amount, as a spread, as a network fee, as a Partner fee, as an administrative fee or in any other manner disclosed in the Fee Schedule, the relevant transaction interface, the Account Interface or applicable Supplementary Terms.

9.4. The User authorises the Company to deduct, withhold, set off or charge applicable fees, commissions, spreads, network fees, Partner fees, administrative fees and other amounts automatically at the time of the relevant transaction, from the transaction amount, from the User’s Account, Wallet, Balance or from any other amount payable to or by the User, where technically possible and permitted by Applicable Law.

9.5. The User is responsible for any applicable taxes, duties, levies, blockchain network fees, miner fees, gas fees, Partner fees, payment provider fees, banking charges, exchange differences, third-party provider charges or other costs arising from or in connection with the User’s use of the Services, unless expressly stated otherwise in the Fee Schedule or applicable Supplementary Terms.

9.6. The Company may update the Fee Schedule from time to time in accordance with the Terms and Conditions. Where a fee update materially affects the User’s rights or obligations, the Company will provide notice in accordance with the Terms and Conditions, unless the update is required to take effect earlier due to blockchain network fees, Partner fees, technical costs, security reasons, Applicable Law, regulatory requirements, sanctions restrictions, AML/CTF, fraud prevention, operational reasons or other urgent circumstances.

9.7. If the User fails to pay any fees, commissions, charges, costs or other amounts due to the Company, the Company may suspend, restrict, freeze, block or terminate access to any Account, Wallet, Balance, Order, transaction or Service until such amounts are paid in full.

9.8. To the extent technically possible and permitted by Applicable Law, the Company may deduct, set off or withhold any due and payable amounts owed by the User to the Company from any available Balance, transaction amount, settlement amount, refund amount or other amount connected with the User’s Account or Wallet.

9.9. The User remains liable for any unpaid amounts and for any actual direct documented losses, costs, expenses, Chargebacks, penalties, Partner costs, investigation costs or legal costs incurred by the Company as a result of the User’s failure to pay amounts due under this Public Offer, the Terms and Conditions, the Fee Schedule or applicable Supplementary Terms.

9.10. This Section 9 is without prejudice to the more detailed provisions on fees, refunds, Chargebacks, Order amendments, minimum transaction amounts and deductions set out in the Terms and Conditions.

10. ACCESS TO AND USE OF THE SERVICES

10.1. The Company shall have no obligation to provide access to the Services unless and until the User has completed the onboarding, verification, KYC, KYT, sanctions screening, fraud prevention, security and other compliance checks required by the Company.

10.2. Access to and use of the Services is subject to this Public Offer, the Terms and Conditions, applicable Supplementary Terms, Website functionality, Account Interface functionality, technical availability, Supported Digital Asset availability, blockchain network conditions, transaction limits, Partner Requirements, Applicable Law and the Company’s compliance, security and risk-control requirements.

10.3. The Company may request additional information, documents, confirmations or explanations from the User at any time where reasonably required for the provision of the Services, onboarding, verification, compliance checks, transaction review, fraud prevention, sanctions screening, security, source of funds checks, source of Digital Assets checks, wallet ownership verification or risk-control purposes.

10.4. The Company may refuse, reject, cancel, delay, suspend, restrict, freeze, block or decline to process any Order, transaction, instruction, deposit, withdrawal, exchange, conversion or other request where permitted under this Public Offer, the Terms and Conditions or applicable Supplementary Terms, or where reasonably required due to technical, operational, compliance, sanctions, AML/CTF, fraud prevention, security, Partner Requirements or risk-control reasons.

10.5. The Company may suspend, restrict, freeze, block, modify or terminate access to the Services in whole or in part where the Website, Account Interface, Wallet infrastructure, blockchain network, liquidity provider, payment provider, technology provider, custody infrastructure provider, blockchain analytics provider, compliance provider, Partner or any other relevant third-party service provider is unavailable, restricted, interrupted, malfunctioning or otherwise unable to support the relevant Services.

10.6. The User shall not attempt to bypass, disable, manipulate, interfere with or circumvent any security, authentication, verification, compliance, KYC, KYT, sanctions screening, fraud prevention, transaction monitoring, transaction limit, Wallet control, withdrawal control or risk-control mechanism applied by the Company or its Partners.

10.7. The User must use the Services only through the Website, Account Interface or other access channels approved by the Company and must not use any unauthorised scripts, bots, crawlers, automation tools, scraping tools, reverse engineering methods or other technical means to access, monitor, interfere with or manipulate the Services.

10.8. This Section 10 is without prejudice to the more detailed provisions on access, onboarding, eligibility, verification, prohibited use, Wallet Services, transaction monitoring, suspension, termination and service limitations set out in the Terms and Conditions.

11. TRANSACTION LIMITS

11.1. The Company may impose limits on the amount, frequency, type, volume, value, source, destination, method or timing of any Order, deposit, withdrawal, exchange, conversion, transfer or other transaction in order to ensure security, prevent fraud, comply with Applicable Law, apply Partner Requirements, manage operational risk, manage liquidity risk or apply the Company’s compliance and risk-control requirements.

11.2. Transaction limits may vary depending on the User’s verification level, jurisdiction, risk profile, transaction history, Account status, Wallet status, type of Digital Asset, blockchain network, payment method, source of funds, source of Digital Assets, destination wallet, counterparty, Partner Requirements, technical availability and other relevant legal, compliance, security, operational or risk factors.

11.3. The Company may amend, reduce, increase, suspend, remove or apply transaction limits at any time, with or without prior notice, where the Company considers this necessary or appropriate for legal, regulatory, compliance, sanctions, AML/CTF, fraud prevention, security, technical, operational, Partner Requirements or risk management reasons.

11.4. Where reasonably practicable and permitted by Applicable Law, Partner Requirements and the Company’s internal policies, the Company may notify the User of material changes to transaction limits through the Website, Account Interface, email, in-platform notification, support channels or any other reasonable communication method.

11.5. The Company shall not be liable for any loss, delay, failed transaction, rejected transaction, missed opportunity, market movement, loss of value or other consequence arising from the application, amendment, reduction, suspension or removal of transaction limits, except to the extent such liability cannot be excluded under Applicable Law or arises from the Company’s fraud, wilful misconduct or gross negligence.

11.6. This Section 11 is without prejudice to the more detailed provisions on transaction limits, Order execution, refunds, Chargebacks, Wallet restrictions, compliance controls and transaction monitoring set out in the Terms and Conditions.

12. TRANSACTION FINALITY AND NO CANCELLATIONS

12.1. The User is solely responsible for reviewing and confirming all Order, transaction, Wallet, payment, blockchain network, wallet address, tag, memo, reference, payment identifier, amount, Digital Asset and other transaction details before submitting any instruction through the Website, Account Interface or any other approved access channel.

12.2. Once an Order or transaction has been submitted, confirmed by the User, processed by the Company or a Partner, submitted to a blockchain network, broadcast to a blockchain network, confirmed on a blockchain network, settled, executed or otherwise rendered irreversible, it may not be capable of being cancelled, amended, refunded, reversed, recalled or recovered.

12.3. The Company does not guarantee that any Order or transaction can be cancelled, amended, refunded, reversed, recalled or recovered after submission or confirmation.

12.4. The Company shall not be responsible for recovering Digital Assets or fiat amounts sent, transferred, exchanged, converted or processed in accordance with incorrect, incomplete, outdated, unsupported or mistaken instructions provided by the User, including where Digital Assets are sent to an incorrect wallet address, through an incorrect or unsupported blockchain network, without a required memo, tag, reference or payment identifier, to an incompatible wallet, to a restricted wallet, to a scam wallet, to a third-party wallet or to any destination outside the Company’s control.

12.5. The User is solely responsible for monitoring the status of the User’s Orders and transactions through the Website, Account Interface and, where applicable, the relevant blockchain network or external service.

12.6. Delays, failures, rejections, reversals or non-execution may occur due to blockchain network congestion, forks, protocol changes, validator or miner delays, Partner processing, payment provider processing, liquidity limitations, technical issues, compliance checks, sanctions screening, fraud prevention checks, security reviews, Partner Requirements or Applicable Law.

12.7. The Company shall not be liable for any loss, delay, failed transaction, missed opportunity, market movement, loss of value, incorrect transfer, unsupported transfer or other consequence arising from the User’s failure to review and confirm transaction details or from the irreversible nature of blockchain transactions, except to the extent such liability cannot be excluded under Applicable Law or arises from the Company’s fraud, wilful misconduct or gross negligence.

12.8. This Section 12 is without prejudice to the more detailed provisions on Order execution, Order amendments, refunds, Chargebacks, Wallet Services, unsupported transactions and transaction finality set out in the Terms and Conditions.

13. USER INDEMNITY

13.1. To the fullest extent permitted by Applicable Law, the User shall indemnify and hold harmless the Company, its Affiliates, directors, officers, employees, contractors, representatives, Partners and service providers from and against any actual direct documented losses, liabilities, costs, expenses, claims, penalties, Chargebacks, Partner costs, investigation costs or damages incurred by the Company arising out of or in connection with:

(a) the User’s breach of this Public Offer, the Terms and Conditions, any Supplementary Terms, Partner Requirements or Applicable Law;

(b) the User’s unlawful, fraudulent, prohibited, abusive, negligent or unauthorised use of the Services;

(c) any false, misleading, incomplete, outdated, inconsistent, unverifiable or fabricated information, documents, confirmations or instructions provided by the User;

(d) any incorrect, incomplete, unsupported or mistaken Order, transaction instruction, wallet address, blockchain network, tag, memo, reference, payment identifier or other transaction detail provided by the User;

(e) any breach by the User of sanctions restrictions, AML/CTF requirements, fraud prevention requirements, security requirements, tax obligations or third-party rights;

(f) any use of the Services by a third party through the User’s Account, Wallet, credentials, devices, authentication tools, payment details, wallet details or other access methods, except to the extent caused by the Company’s fraud, wilful misconduct or gross negligence;

(g) any Chargeback, payment dispute, recall, reversal, complaint, claim or investigation arising from the User’s breach of this Public Offer, the Terms and Conditions, Applicable Law or the User’s incorrect or unauthorised use of the Services.

13.2. The indemnity under this Section 13 shall not apply to the extent that the relevant losses, liabilities, costs, expenses, claims or damages are caused by the Company’s fraud, wilful misconduct or gross negligence.

13.3. If the User acts as a consumer under Applicable Law, this Section 13 shall apply only to the extent permitted by Applicable Law and shall not limit any mandatory consumer rights that cannot be excluded, restricted or waived.

13.4. This Section 13 shall survive termination of the relationship between the User and the Company.

13.5. This Section 13 is without prejudice to the more detailed indemnification, limitation of liability and no double recovery provisions set out in the Terms and Conditions.

14. CONFIDENTIALITY AND DATA DISCLOSURE

14.1. For the purposes of this Public Offer, “Confidential Information” means any non-public information disclosed or made available by the User to the Company or by the Company to the User in connection with this Public Offer, the Terms and Conditions, the Services, the Account, Wallet, Orders, transactions, onboarding, verification or use of the Services.

14.2. Confidential Information may include, without limitation:

(a) information relating to the User’s identity, contact details, onboarding, verification, Account, Wallet, transactions, wallet addresses, payment details, source of funds, source of Digital Assets and use of the Services;

(b) information relating to the Company, the Brand, the Website, the Account Interface, Services, technical infrastructure, security procedures, compliance checks, risk-control procedures, fees, business operations, software, systems, documentation, proprietary materials and internal procedures;

(c) any other information which, by its nature or the circumstances of disclosure, should reasonably be treated as confidential.

14.3. The User shall keep confidential any non-public information relating to the Company, the Services, technical infrastructure, security procedures, compliance checks, risk-control procedures, software, systems, documentation, proprietary materials or internal procedures disclosed or made available to the User in connection with the Services.

14.4. The Company shall process, protect and disclose information relating to the User in accordance with the Privacy Policy, this Public Offer, the Terms and Conditions, applicable Supplementary Terms and Applicable Law.

14.5. The Company may disclose information relating to the User where reasonably necessary for the provision of the Services, onboarding, verification, transaction processing, Wallet operations, compliance checks, AML/CTF controls, sanctions screening, fraud prevention, security, risk control, audits, legal advice, dispute handling, enforcement of rights, cooperation with competent authorities or compliance with Applicable Law.

14.6. The Company may disclose information to its Affiliates, directors, officers, employees, contractors, professional advisers, auditors, Partners, payment providers, liquidity providers, custody infrastructure providers, blockchain analytics providers, technology providers, compliance providers, fraud prevention providers, banks and other third-party service providers, where such disclosure is reasonably necessary in connection with the Services or permitted under the Privacy Policy, the Terms and Conditions or Applicable Law.

14.7. Confidentiality obligations shall not apply to information which:

(a) is or becomes publicly available without breach of this Public Offer;

(b) was lawfully known to the receiving party before disclosure;

(c) is lawfully received from a third party without breach of any confidentiality obligation;

(d) is independently developed without use of the other party’s Confidential Information;

(e) is required or permitted to be disclosed under Applicable Law, court order, competent authority request, regulator request, law enforcement request, sanctions authority request, AML/CTF authority request, Partner Requirements or other legal, regulatory, compliance or security requirement.

14.8. The Company shall not be required to disclose to the User any information where such disclosure may breach Applicable Law, sanctions restrictions, AML/CTF requirements, security requirements, Partner Requirements, instructions of a competent authority, law enforcement request, court order or the Company’s internal compliance, security or risk-control procedures.

14.9. The confidentiality obligations under this Section 14 shall remain in force for three (3) years after termination of the relationship between the User and the Company, except for information which constitutes trade secrets, personal data, security-sensitive information or information subject to legal, regulatory, AML/CTF, sanctions, professional confidentiality or recordkeeping obligations, which shall remain protected for as long as required or permitted under Applicable Law.

14.10. This Section 14 is without prejudice to the Privacy Policy and the more detailed provisions on personal data, data retention, disclosure, compliance reporting and cooperation with authorities set out in the Terms and Conditions.

15. RELATIONSHIP OF THE PARTIES

15.1. In providing or facilitating access to the Services, the Company acts as an independent service provider.

15.2. Nothing in this Public Offer, the Terms and Conditions, any Supplementary Terms or the User’s use of the Services shall create any partnership, joint venture, employment, agency, fiduciary relationship, trust, financial advisory relationship, investment advisory relationship or other similar relationship between the User and the Company.

15.3. The User has no authority to bind, represent, act for or create obligations on behalf of the Company.

15.4. The Company has no fiduciary duty to the User and does not act as the User’s broker, financial adviser, investment adviser, portfolio manager, tax adviser, legal adviser, trustee, agent or representative.

15.5. Any amendments or updates to this Public Offer, the Terms and Conditions, the Fee Schedule, the Privacy Policy, the Risk Disclosure or applicable Supplementary Terms may be made in accordance with the change and notification procedures set out in the Terms and Conditions.

15.6. This Section 15 is without prejudice to the more detailed provisions on no advice, limitation of liability, changes to terms and use of the Services set out in the Terms and Conditions.

16. ASSIGNMENT

16.1. The User may not assign, transfer, novate, delegate, sublicense or otherwise dispose of any rights or obligations under this Public Offer, the Terms and Conditions or any applicable Supplementary Terms without the Company’s prior written consent.

16.2. Any attempted assignment, transfer, novation, delegation, sublicensing or disposal by the User without the Company’s prior written consent shall be null and void.

16.3. The Company may assign, transfer, novate, delegate or otherwise dispose of this Public Offer, the Terms and Conditions, any applicable Supplementary Terms or any rights or obligations arising in connection with the Services, in whole or in part, to any Affiliate, successor, purchaser, transferee, assignee or other entity involved in the continuation, restructuring, transfer, sale, merger, reorganisation or operation of the Services.

16.4. Where reasonably practicable and required under Applicable Law, the Company may notify the User of any assignment, transfer, novation or delegation under Clause 16.3 through the Website, Account Interface, email, in-platform notification or any other reasonable communication method.

16.5. Any assignment, transfer, novation or delegation by the Company shall not affect any mandatory rights of the User that cannot be excluded or limited under Applicable Law.

16.6. This Public Offer shall be binding upon and shall benefit the Company, the User and their respective permitted successors and assigns.

16.7. This Section 16 is without prejudice to any assignment, transfer, restructuring, change of service provider, Partner arrangement or business continuity provisions set out in the Terms and Conditions.

17. SEVERABILITY

17.1. If any provision of this Public Offer is held to be invalid, illegal or unenforceable under Applicable Law or by any competent court, authority or tribunal, such provision shall be severed, limited or interpreted to the minimum extent necessary to make it valid, legal and enforceable.

17.2. The remaining provisions of this Public Offer shall continue in full force and effect.

17.3. Any invalid, illegal or unenforceable provision shall be replaced, to the extent permitted by Applicable Law, by a valid, legal and enforceable provision that most closely reflects the original commercial and legal intent of the Company and the User.

17.4. The invalidity, illegality or unenforceability of any provision of this Public Offer shall not affect the validity, legality or enforceability of any provision of the Terms and Conditions, the Fee Schedule, the Privacy Policy, the Risk Disclosure or any applicable Supplementary Terms, unless expressly required under Applicable Law.

17.5. This Section 17 is without prejudice to the severability provisions set out in the Terms and Conditions.

18. FORCE MAJEURE

18.1. Neither the Company nor the User shall be liable for any delay, failure or partial failure to perform obligations under this Public Offer, the Terms and Conditions or any applicable Supplementary Terms to the extent that such delay or failure is caused by an event beyond the affected party’s reasonable control (“Force Majeure”).

18.2. Force Majeure may include, without limitation, fire, explosion, flood, earthquake, storm, epidemic, pandemic, war, civil unrest, acts of terrorism, labour disputes, strikes, lockouts, embargoes, sanctions, changes in law, acts or restrictions of governmental or regulatory authorities, court orders, cyberattacks, hacks of exchanges or third-party platforms, unauthorised access to digital platforms, blockchain network malfunctions, forks, congestion or disruptions, validator or miner failures, power outages, communication network failures, internet failures, failures or restrictions of Partners, payment providers, banking providers, liquidity providers, custody infrastructure providers, technology providers, blockchain analytics providers, compliance providers or other third-party service providers, and any other event beyond the affected party’s reasonable control.

18.3. The party affected by Force Majeure shall notify the other party as soon as reasonably practicable after becoming aware of the Force Majeure event, where such notice is reasonably possible and legally permitted.

18.4. The affected party’s obligations shall be suspended only to the extent and for the period directly affected by the Force Majeure event.

18.5. Force Majeure shall not release the User from any payment obligation, fee, commission, charge, cost, liability or other amount accrued or due before the Force Majeure event.

18.6. If a Force Majeure event continues for more than thirty (30) calendar days and materially prevents the provision of the Services, the Company may suspend, restrict, modify or terminate the affected Services or terminate the relationship with the User in accordance with this Public Offer and the Terms and Conditions.

18.7. This Section 18 is without prejudice to any service limitation, suspension, termination, liability limitation or operational disruption provisions set out in the Terms and Conditions.

19. DISPUTE RESOLUTION

19.1. The User must first attempt to resolve any dispute, controversy, complaint or claim arising out of or in connection with this Public Offer, the Terms and Conditions, the Services, any Account, Wallet, Order, transaction, Digital Asset, Fiat Payments or relationship between the User and the Company through the Company’s official support channels, unless such prior attempt is prohibited by Applicable Law or urgent injunctive, interim or protective relief is required.

19.2. The Company will use reasonable efforts to review and address the matter internally as soon as reasonably practicable, taking into account the nature and complexity of the dispute, the information provided by the User, the involvement of Partners, technical investigation, compliance review, legal restrictions and any other relevant circumstances.

19.3. If the dispute is not resolved through internal review, the dispute shall be handled in accordance with the dispute resolution, governing law and jurisdiction provisions set out in the Terms and Conditions.

19.4. Subject to any mandatory rights available to the User under Applicable Law, any dispute arising out of or in connection with this Public Offer, the Terms and Conditions, the Services or the relationship between the User and the Company shall be submitted to the exclusive jurisdiction of the competent courts of the Republic of Costa Rica.

19.5. Nothing in this Section 19 shall prevent the Company from refusing, delaying, suspending, restricting, freezing, blocking, terminating or otherwise controlling access to any Account, Wallet, Balance, Order, transaction or Service in accordance with this Public Offer and the Terms and Conditions where required or reasonably considered necessary for compliance, sanctions, AML/CTF, fraud prevention, security, technical, operational, Partner Requirements or risk-control reasons.

19.6. Nothing in this Section 19 shall prevent the Company or the User from seeking urgent injunctive, interim, protective or equitable relief before any competent court.

19.7. This Section 19 is without prejudice to the more detailed notice of claim, internal dispute resolution, governing law, jurisdiction, class action waiver and severability provisions set out in the Terms and Conditions.

20. GOVERNING LAW

20.1. This Public Offer, including any non-contractual obligations arising out of or in connection with it, shall be governed by and construed in accordance with the laws of the Republic of Costa Rica, without regard to conflict-of-law rules.

20.2. This Section 20 is without prejudice to any mandatory rights or protections available to the User under Applicable Law, including any mandatory consumer protection rules that cannot be excluded or limited by agreement.

20.3. This Section 20 is without prejudice to the governing law and jurisdiction provisions set out in the Terms and Conditions.

21. WAIVER

21.1. No failure or delay by the Company in exercising any right, power, discretion or remedy under this Public Offer, the Terms and Conditions, the Fee Schedule, the Privacy Policy, the Risk Disclosure, any applicable Supplementary Terms or Applicable Law shall operate as a waiver of that right, power, discretion or remedy.

21.2. Any waiver by the Company shall be valid only if made in writing and shall apply only to the specific circumstances for which it is given.

21.3. A waiver of any breach, default or non-compliance shall not be deemed to be a waiver of any subsequent or continuing breach, default or non-compliance.

21.4. The Company’s rights, powers, discretions and remedies under this Public Offer are cumulative and do not exclude any rights, powers, discretions or remedies available under the Terms and Conditions, Applicable Law or otherwise.

22. ELECTRONIC ACCEPTANCE AND RECORDS

22.1. This Public Offer does not require handwritten signature or exchange of signed counterparts in order to become binding on the User.

22.2. The User accepts this Public Offer by registering an Account, submitting onboarding information, clicking “I agree”, “I accept”, “Start” or any similar acknowledgement, accessing or using the Services, or otherwise expressing acceptance through the Website, Account Interface or any other approved access channel.

22.3. The Company may record and retain evidence of the User’s acceptance of this Public Offer, the Terms and Conditions, the Privacy Policy, the Fee Schedule, the Risk Disclosure and any applicable Supplementary Terms, including the date and time of acceptance, User ID, email address, IP address, device information, version of accepted documents and other relevant technical or account information.

22.4. Such electronic records may be used by the Company as evidence of the User’s acceptance of this Public Offer and the documents incorporated by reference.

22.5. The User agrees that electronic acceptance, electronic records, electronic notices and electronic communications may have legal effect to the extent permitted by Applicable Law.

22.6. The Company may provide the User with access to the current version of this Public Offer, the Terms and Conditions, the Privacy Policy, the Fee Schedule, the Risk Disclosure and applicable Supplementary Terms through the Website, Account Interface or other approved communication channels.

FEE SCHEDULE

for Cryptopayments Services by Individual Users

Last Updated: 26 May 2026

This Fee Schedule forms an integral part of the Public Offer Agreement, the Terms and Conditions and any applicable Supplementary Terms made available by LUNORA SOCIEDAD DE RESPONSABILIDAD LIMITADA (“Company”, “Lunora”, “we”, “us” or “our”).

Capitalised terms not defined in this Fee Schedule shall have the meanings given to them in the Terms and Conditions.

The fees and commissions below apply to the Services made available to Individual Users under the Cryptopayments brand, unless otherwise displayed in the Account Interface, transaction interface, Website, Terms and Conditions, applicable Supplementary Terms or otherwise communicated by the Company.

1. Fees and Commissions

2. Charging of Fees

The applicable fee, commission, spread, network fee, Partner fee, administrative fee or other charge may be charged by the Company at the time of the relevant transaction, deducted from the relevant transaction amount, deducted from the User’s Account, Wallet or Balance, or otherwise charged in accordance with the Public Offer Agreement, the Terms and Conditions and Applicable Law.

By accepting the Public Offer Agreement, using the Services or submitting an Order or transaction, the User authorises the Company to charge, deduct, withhold or set off applicable fees and commissions in accordance with this Fee Schedule, the Terms and Conditions and the relevant transaction interface.

3. Third-Party Fees and Costs

Unless expressly stated otherwise in this Fee Schedule, the User remains responsible for any applicable taxes, duties, blockchain network fees, miner fees, gas fees, Partner fees, payment provider fees, banking charges, third-party provider charges, exchange differences, currency conversion costs or other costs arising from or in connection with the User’s use of the Services.

Third-party fees and blockchain network fees may change without prior notice and may depend on blockchain network conditions, payment provider rules, Partner Requirements, market conditions, liquidity availability, technical limitations or other external factors outside the Company’s control.

4. Updates

The Company may update this Fee Schedule from time to time in accordance with the Terms and Conditions.

Where a fee update materially affects the User’s rights or obligations, the Company will provide notice in accordance with the Terms and Conditions, unless the update is required to take effect earlier due to blockchain network fees, Partner fees, technical costs, security reasons, Applicable Law, sanctions restrictions, AML/CTF, fraud prevention, operational reasons or other urgent circumstances.

5. No Waiver

If any fee is not charged, deducted or collected by the Company at any particular time, this shall not constitute a waiver of the Company’s right to charge, deduct or collect such fee or any other applicable fee in the future, unless expressly confirmed by the Company in writing.