1. Introduction

1.1 About LemFi

LemFi is a global financial services brand operating through various authorized legal entities in different jurisdictions.

Global Account:

A Customer may open a Global Account through the LemFi app. The Global Account serves as a single access point through which the Customer may select and activate specific and available Digital Wallet Services offered by LemFi entities in different jurisdictions (each, a “Wallet Service”). The Global Account is not itself a custodial account. It is a consolidated electronic interface through which you may view and manage one or more Wallets.

When you open a Global Account, you enter into a contract with the individual Digital Wallet Service providers which are the Affiliates of the Pomelo Technology US Inc, a company organized under the laws of Delaware, United States. Pomelo Technology US Inc provides the Global Account interface, which allows you to access and manage one or more Digital Wallet Services. LemFi operates the website at https://www.lemfi.com/.

If you are a resident of the United States, United Kingdom, Canada, or any European Union member state, you are NOT ELIGIBLE to open or use the Global Account services described in these Terms, regardless of your citizenship or nationality. Separate terms and conditions apply to services provided to residents of these jurisdictions.

Wallet Services:

When you select a specific Digital Wallet Service, you enter into a separate contract with the LemFi entity that provides that Wallet Service, as described in Section 24 below.

Each Digital Wallet Service corresponds to a custodial wallet held with a regulated partner bank under the supervision of the applicable LemFi entity. For USD Digital Wallet Services, this custodial wallet is opened and maintained by Global Innovations Bank (“GIB”) on your behalf. Each wallet is a custodial electronic money account issued by the relevant LemFi entity and backed by funds held in segregated safeguarding accounts with the partner bank.

• USD Wallet Service: Provided by Pomelo Two US LLC, a Delaware corporation. Banking services are provided by Global Innovations Bank (“GIB”), an FDIC-insured depository institution.

• GBP Wallet Service: Provided by RightCard Payment Services Limited, authorized in the UK by the Financial Conduct Authority under the Electronic Money Regulations 2011 (Register Reference 900424).

• CAD Wallet Service: Provided by Pomelo Technology Canada Ltd, registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a Money Service Business (registration number M20383642).

• EUR Wallet Service: Provided by Pomelo Remits Europe Ltd (utilizing Modulr Finance B.V., which is authorized and regulated by the Dutch Central Bank (DNB) as an Electronic Money Institution (Firm Reference Number R182870) or the RightCard Payment Services Ltd., whichever is applicable.

• NGN Wallet Service: Your Global Account may connect to your existing Pagatech account or wallet. The NGN Wallet is subject to Pagatech’s terms and conditions.

1.2 Governing Law

Global Account Service:

The Global Account Service provided by the Pomelo Technology US Inc is governed by the laws of United States and the State of Delaware, without regard to conflict-of-law principles.

Wallet Services:

Each Wallet Service is governed by the laws applicable to the LemFi entity providing that service, as specified below and further described in Section 24:

• GBP Wallet Service (Section 24.2): Governed by the laws of England and Wales.

• USD Wallet Service (Section 24.3): Governed by the laws of the United States and the State of New York, without regard to conflict-of-law principles.

• CAD Wallet Service (Section 24.4): Governed by the laws of the Province of Ontario and the federal laws of Canada applicable therein.

• EUR Wallet Service (Section 24.5): Governed by the laws of Ireland.

• NGN Wallet Service (Section 4.1(a)): Governed by the laws of the Federal Republic of Nigeria.

1.3 How to Contact LemFi

 * Email: [contact@lemfi.com](mailto:contact@lemfi.com) or [support@lemfi.com](mailto:support@lemfi.com)

 * Messaging: You can send LemFi a message via the customer support function on the app

 * Telephone:

 * **For Nigerian Customers:** \+23 49129337161

For U.S. Customers: +1 702 505 4976

For UK Customers: +44 2045795921

For Canadian Customers: +1 437 500 1260

For European Customers: +33 6 44 65 68 12

You can call us at any time seven days a week. You can contact us via email or via the customer support function on the app at any time.

2. Definitions

The following words have the following meaning:

"Affiliate" means any entity that controls, is controlled by, or is under common control with your LemFi entity.

"app" or "LemFi Mobile App" means the "LemFi Finance" mobile application, which is available on Google Play and the App Store.

"Applicable Law" means any law, regulation, rule, regulatory guidance, or court order that applies to your LemFi entity or the Services.

"beneficiary" means the person who will receive money, if you execute a payment using the app.

"beneficiary account" is the mobile money wallet, payment account, bank account belonging to the beneficiary.

"Business Day" means Monday through Friday, excluding public holidays. For USD Wallet Services, this specifically means any day other than Saturday, Sunday, federal or New York state holidays on which the Bank's offices are open for business. For the purposes of GBP Wallet Services, CAD Wallet Services, and EUR Wallet Services business days means Monday through to Friday, excluding public holidays and weekends (Saturday and Sunday).

“Digital Wallet Services” means the use of the LemFi Digital Wallet, the Global Account or the Wallet.

"Electronic Payment" means a payment from your Global Account by electronic means.

"electronic money" means an electronic alternative to money. By way of explanation, when you send your LemFi entity money, your LemFi entity will credit your wallet. The balance of your wallet(s) will be backed by an equivalent amount of money which your LemFi entity holds in its safeguarded accounts. The value in your wallet(s) is technically referred to as "electronic money".

"Global Account" means your LemFi Global Account including all wallets held with your LemFi entity.

“LemFi” means the Pomelo Technology US Inc, its Affiliates, Digital Wallet Services, the app, the Global Account.

"LemFi Digital Wallet" or "wallet" means an electronic money account with your LemFi entity, which represents the stored value of your funds, currencies, and its use.

"LemFi Digital Wallet Balance" is the aggregate amount comprising all the funds that you have received into your wallet, which may include funds from deposits, currency conversions, or other receipts.

“LemFi entity” means the Affiliates of the Pomelo Technology US Inc or the Wallet Services providers.

"money" when 'money' is referred to in these terms, this refers to money (as you would normally understand it) and electronic money stored in your wallet.

“Nominated Account” means a payment account in your own name that you designate for transferring funds to and from linked to your LemFi Digital Wallet representing your Global Account. The Nominated Account must be in your name and originate from a country where you are resident and where LemFi Global Account services are offered. For Nigerian users, this may be your Paga Account or Wallet.

“NGN Wallet” means the wallet, or the Nominated Account provided by Pagatech

"payment" means the LemFi entity sending money from your wallet to another wallet or to a non-wallet payment account.

"payment account" means any type of account that can hold money, including a bank account and an electronic money account.

“Service” means any service provided to you by a LemFi entity, including the Global Account Service or any Digital Wallet Service.

"Terms" or "Agreement" means this document, including all provisions that apply to your region.

"Transaction" means the specific instruction to send money through the Services, including remittances to beneficiaries.

"Transaction Amount" means the amount you wish to send or convert to any other permitted currency from your LemFi Digital Wallet Balance.

"us", "we" means the LemFi entity that provides services to you, as specified in Section 1.1 above.

"You", "your", "Customer" means you, being the individual that wishes to use LemFi's Global Account Services ("Global Account") and agrees to comply with LemFi's onboarding requirements and any amendments to these terms and conditions as amended from time to time.

Additional definitions specific to your jurisdiction:

For Customers using US Services:

• "GIB" means Global Innovations Bank, the FDIC-insured depository institution that provides banking services for your USD wallet and remittance transactions.

• "Network Banks" means GIB and other FDIC member and insured depository institutions that hold funds underlying your LemFi Digital Wallet, as listed at https://banks.data.fdic.gov/bankfind-suite/bankfind/details/5175

• "Payment Instrument" means your credit card, debit card or bank account used to fund your LemFi Digital Wallet or any other method of funding made available.

All other capitalized terms have the meanings given in these Terms or in the LemFi Privacy Notice.

3. Acceptance and Duration of Terms Why should you read these terms?

These terms explain what your Global Account can provide to you. They explain your responsibilities to LemFi and LemFi's responsibilities to you, how and when these terms can be terminated and the extent of LemFi's liability to you.

How do you accept these terms?

You can accept these terms by ticking or clicking on the relevant terms and conditions icon box when you register with LemFi, or by otherwise agreeing to these terms on the app.

When do these terms come into force and when do they end?

These terms come into force when you have accepted them and we have onboarded you as our client, or as otherwise advised, and shall remain in force until terminated.

How can these terms be terminated?

You can terminate these terms immediately at any time by contacting LemFi's support team using one of the methods set out in Section 1.2 above. We can terminate these terms at any time . LemFi and GIB can also close or suspend your access to the app in accordance with section 13.

What happens when these terms are terminated?

Among other things, you will no longer be a client of LemFi and will therefore be unable to use the app. Accordingly, it is your sole responsibility to ensure that there is no money in any of your wallets prior to terminating these terms and closing your account. For six years after these terms are terminated, you will be able to contact LemFi by email to ask LemFi to send money in your wallets to a payment account belonging to you. During this period, LemFi may deduct money from your wallet to pay money you owe to LemFi.

4. Main Characteristics of the Service

4.1 Description of LemFi's Digital Wallet Services

LemFi's Services allow you to:

(a) add money into your wallet accounts from your own Nominated Accounts; (b) receive money from your family, friends, employer, or income as a freelance contractor, customer (as available); (c) exchange money in other currencies (as available); (d) send money, in various currencies, to wallets belonging to other persons (for example your friends and family, suppliers, contractors); (e) send money, in various currencies, to accounts which are not wallets (for example payment accounts belonging to your friends, family, suppliers, contractors, which live overseas); (f) view the balance of your wallets on the LemFi app;
(g) see foreign exchange transactions that you have entered into with LemFi via the app; (h) see payments that you have executed from your wallet(s) via the app.

Additional services specific to your wallet currency and region are described in Sections 24 and 25 below.

(b) You can also open and access, via the app, a wallet in Nigerian Naira (NGN) which is provided by Pagatech (a company based in Nigeria). The use of the NGN wallet is subject to Pagatech’s terms and conditions, which can be found via the following weblink
https://www.mypaga.com/paga-web/pc/terms.paga. By opening an NGN wallet, you will be deemed to have agreed to Pagatech’s terms and understand that the use of the NGN wallet is subject to Pagatech’s terms and that Pagatech is responsible for the operation of and payments from the NGN wallet. LemFi’s services allow you to interact with Pagatech in relation to your NGN wallet.

4.2 # Supported Currencies and Wallets

The specific wallet currencies available to you and any partner relationships for those wallets vary by region, as set out in Section 24 below.

5. Account Information and Use

What are Global Accounts and wallets?

Your Global Account is the consolidated electronic interface provided by LemFi, through which you can view and manage one or more wallets. The wallets are provided by us through banking and payment partners which are subject to our mutual Terms and Conditions, as amended from time to time. Specific partner details vary by region as set out in Sections 24 below.

5.1 Opening and Accessing Wallets

To use your Global Account, you represent and warrant that:

(a) you are solely responsible for activities on your account, security over the use of your device to access the LemFi Global Account; (b) you shall continue to meet our eligibility criteria on an ongoing basis and as amended from time to time; (c) you have the requisite power, authority and capacity to enter into and comply with these Terms; (d) the information you provide us in order to enable us to satisfy our client verification and on-boarding checks in respect of you is complete, accurate and not misleading and furthermore that you will notify us of any changes to the information provided; (e) If the Global Account is used for business purposes it will be operated in a way that is compliant with all relevant legislation, regulations, codes of conduct or regulatory guidance or directions.

You accept that you may only use the Global Account as a freelancer, self-employed person or without any underlying business activity solely for your own transactions without any third party or beneficiary's interest.

How do you add money to a Global Account wallet?

You can add money to a Global Account wallet:

(a) by sending money from your Nominated Account (which must be in your own name) to your custodial wallet using the account details linked to your wallet; (b) receiving money from your friends, family, employer, or customer or any other method permitted by LemFi from time to time.

Specific methods and account details for adding money vary by region and wallet currency, as described in Section 24 below.

What can you use the money in your wallet for?

Once you have money in one of your wallets, you will be able to:

(a) exchange money from one currency to another by transferring money from a wallet you hold in one currency to a wallet you hold in a different currency; (b) send money to persons, other than you, which hold a wallet with LemFi; (c) send money in various currencies to bank and mobile money accounts located in countries which LemFi permits and supports, the details of which are specified on the app (subject to change from time to time).

Specific supported countries and payment methods are detailed in Section 25 below.

How does currency conversion work between your wallets work?

When you convert funds between your custodial wallets in different currencies, LemFi facilitates the exchange. Exchange rates and any applicable fees are displayed in the app before you authorize the conversion. Once authorized, conversions cannot be cancelled. Your funds remain safeguarded throughout the conversion process.

How do you send money to Non-LemFi users (Remittances)?

You can also send money from your custodial wallets to accounts that are not LemFi wallets. These remittance transactions may involve currency conversion and are subject to processing times and regulatory requirements. See Section 25 for complete details about remittance services.

How does your wallet differ from a bank account?

Your wallet differs from a bank account in that money in your wallet:

(a) will not be invested or lent to third parties; (b) will not accrue interest; and (c) will be safeguarded or insured in accordance with the requirements for your region (which protects your money if LemFi faces financial difficulties).

Specific safeguarding arrangements and insurance coverage details vary by region, as provided in Section 24 below.

Are there limits on how much money you can send and exchange using the app?

Yes, these limits are set out in the app. If you have any queries on these limits or would like to ask to change them, please contact the LemFi customer support.

Are you able to set spending limits on the app?

No, only LemFi is able to set spending limits.

How do you find out the balance of money in your wallets and how will you know when money has been added to your wallets?

You can check the balance of your wallets by viewing the balance and transaction history of your wallet on the app. You can view such information from the app at any time until your account with LemFi is closed.

We will send a notification to your mobile device each time you receive money into one of your wallets. You can turn off these notifications through your device's settings at any time. If you turn off notifications, you should regularly check your payments on the app. It's important that you know what payments go into and out of your account, so LemFi recommends that you do not turn off notifications.

Will you receive an automatic statement relating to your wallets?

Account statements and transaction history for your custodial wallets are available through the LemFi app. You can access and download your statements at any time. Depending on the region of the wallet service and applicable regulations, periodic statements will be generated and made available to you where required.

Please note that once you are no longer a LemFi customer or your relationship with us has been suspended you will no longer have access to the app to obtain your online statement history. Accordingly, you may wish to print or download any of your account information before requesting the closure of your account to ensure your records are complete. Alternatively, you may request your account statements from customer support. After verification of your identity, LemFi shall email the statements to you.

Will LemFi charge fees?

No. However, we reserve the right to charge fees in the future subject to appropriate disclosure aligned to prevailing regulatory requirements.

Can you ever have a negative balance in your wallet?

LemFi will check that you have enough money in your wallet before deducting money from it. However, you may fall into negative balance if you are charged fees in excess of your balance. If this ever happens, you must immediately top up your wallet.

What if money is paid into your wallet by mistake?

If LemFi reasonably believes that money has been paid into your wallet by mistake, LemFi:

(a) shall contact you and let you know; (b) shall be entitled to share your personal information with the paying bank so that you can be contacted directly; (c) shall be entitled to freeze an amount of money up to the amount received by you; and/or (d) shall be entitled to deduct the appropriate amount of money from your wallet and send it to the payment service provider of the payer where LemFi deems that you have been paid by mistake.

You must let LemFi know if you think that a payment made to you was not a mistake. If you think a payment made to you from a payment service provider was not a mistake, LemFi may share your personal information with the payment service provider of the payer so that you can be contacted directly. This is because LemFi is required to cooperate with other payment service providers and share all relevant information in order to assist with tracing money sent to the wrong person.

Can someone other than you add money to your wallet?

A person other than you can add money to your wallet only by:

(a) sending money from their own wallet with LemFi; or (b) by sending money from another account they hold and entering the details of your account as the beneficiary details.

6. Safeguarding of Funds

What is safeguarding?
Safeguarding is a regulatory requirement whereby your LemFi entity holds customer funds separately from its own funds in designated bank accounts. This protects your money.

What is the point of safeguarding?

Safeguarding your money means that in the unlikely event that LemFi gets into financial difficulties, the money which LemFi safeguards on your behalf will be protected from the claims of LemFi's creditors and should be returned to you in full.

Specific safeguarding arrangements, including when safeguarding applies and which banking partners hold safeguarded funds, vary by region as set out in Section 24 below.

7. The LemFi Mobile App

What is the LemFi app?
The app is LemFi's mobile application where you can, among other things, view and manage the value held in your wallet, which represents the custodial account value maintained by LemFi on your behalf:

(a) view the amount and currency of money held in your wallet with LemFi; (b) exchange money in your wallet from one currency to the currency of another wallet you hold; (c) send money in one of your wallets to other wallets and to any payment accounts which are not wallets; (d) exchange money in one of your wallets to another currency prior to it being sent to the beneficiary account you provide LemFi with the details of; (e) view the details of money you have exchanged and payments you have executed;
(f) download your statements.

How do you access the LemFi app?

You can access the app by downloading it onto your phone from your usual app provider. To use LemFi's mobile app, you need at least the following operating systems:

(a) iOS - version 12 minimum; (b) Android - version 5.0 minimum; (c) or the applicable latest version of iOS or Android as applicable from time to time.

As a Customer you will be given access to view your Account via LemFi App. It is your responsibility to keep all your Global Account details including your password safe and secure and ensure they cannot be accessed by others.

We will take all reasonable steps to ensure your Global Account can be viewed via the LemFi mobile app at any time. There will be times when we need to interrupt our online service to perform maintenance.

How do you make a payment using the LemFi app?

You can make a request for money in one of your wallets or account to be sent to another wallet or a payment account which is not a wallet via the app by following the instructions on the app, which will include inserting the following details:

(a) the amount of money in the currency of your wallet you wish to make the payment from; (b) the currency of the money you wish to send to the beneficiary account; (c) the name of the person, company or institution you want to send the money to; and (d) if the payment is to a non-wallet payment account, the payment account details as requested by the app for your region.

For GBP Wallets, you can also make a request for money to be sent to a payment account by using a payment initiation service provider authorised under UK regulations.

Any instructions to change details on your Global Account may be made by you subject to available features and functionality of our LemFi app and your device. It is important that you maintain the email address we have for you to ensure that any important communications or alerts are received. You should also make sure that your email settings are set up to receive emails from us.

If the currency of the money you wish to send to the beneficiary account is different to the currency of the wallet you are making the payment from then LemFi will carry out a foreign exchange transaction for you at the foreign exchange rate set out in the app prior to sending money in the exchanged currency to the beneficiary account.

How long will it take for the money to be added to your wallet?

This depends on the payment method used and may vary by region. The timing may be affected by factors including the sending bank’s processing time, intermediary banks, verification requirements, and applicable regulations.

What if you add money to your wallet in a currency other than the currency of your wallet?

When you add money to your wallet, it is added in the currency of the wallet you are topping up and not the currency of the money you send. If you send LemFi money by bank transfer in a currency other than the currency of your wallet, this money will be converted into the currency of your wallet. Where possible, the exchange rate, and any applicable fees, will be displayed to you before the conversion. The exchange rate applied and the converted amount will be shown on your statement.

Can you set up a payment to be made at a date in the future?

No, you can only ask LemFi to make payments for immediate execution.

How long will it take for the money to reach the desired account?

Payment execution timelines vary by region and payment method, as set out in Sections 24 and 25 below.

Can you cancel a payment once you have asked LemFi to execute it?

No, however, if you suspect that you have been a victim of fraud or made the transaction in error you must notify us immediately.

Payments out of your Global Account are typically instant and we cannot stop a payment you've asked us to make once they have been processed.

You must tell us immediately if you do not recognise any transaction within your Global Account.

8. Electronic Communications and Disclosures

8.1. Consent to Electronic Communications

These Terms and other documents referred to in these Terms constitute a legal contract between you and us and set out both your and our rights and obligations under the Agreement and important information regarding the Global Account that we will provide to you. For your own protection you should read them carefully before accepting them. If you do not understand anything, contact us to ask for further information.

Consent for Electronic Disclosures. The Service is an electronic commerce relationship. Therefore, by subscribing to the Service, you acknowledge and expressly agree that transmission of the Service Communications (as defined below), the Customer Agreement, and any document delivered to you in connection with the Service shall be executed using electronic signatures, as applicable, and delivered in electronic format. Such electronic documents shall suffice to bind the parties thereunder in the same manner as if an original document or signature had been delivered.

8.2 Types of Electronic Communications Provided

Unless otherwise required by applicable law, the following categories of information ("Service Communications") will only be provided by electronic means and not in paper format or through other non-electronic means:

(i) this Agreement and the applicable Privacy Policy and any amendments, modifications or supplements to them; (ii) your records of Transactions through the Digital Wallet Service; (iii) any initial, periodic or other disclosures or notices provided in connection with the Digital WalletService, including without limitation those required by federal or state law; (iv) any customer service communications, including without limitation communications with respect to claims of error or unauthorized use of the Digital Wallet Service; and (v) any other communication related to us or the Service.

8.3 Accessing and Requesting Paper Copies

Access to electronic disclosures will be provided by way of the Internet. Your history of use of the Service is available for viewing online from your account on the Service via the LemFi Mobile App. In order to view these disclosures, you will need a hardware device that can access the Internet via modem or other form of connection. Your hardware device must run on an appropriate operating system. You must be able to access the Internet to access our website. Additionally, standard, widely available Internet browser software is required to access the disclosures from a personal mobile phone.

If you require a printed copy of your Transaction history, you can request this by emailing support@lemfi.com.

You can download your transactions statement from the Account Information Section on the LemFi Mobile App. Specific retention periods for transaction history vary by region as described in Section 24 below.

You can also request a copy of this Agreement accepted by you via email by contacting support@lemfi.com.

8.4 Withdrawing Consent

If you consent to electronic access to documents, we are not required to provide you with paper copies. You may obtain your Transaction Statement or copy of this Agreement in paper form by printing them yourself. If you decide to withdraw your consent for Digital Wallet Service Communications and documentation electronically you must notify LemFi by email via support@lemfi.com. Such notice will constitute notice of termination of your registration with us and preclude future use of the Service.

9. Eligibility and Onboarding

Who can subscribe for a Global Account?

In order to be a Global Account subscriber, you must:

• A. be over the age of 18 years;

• B. provide valid identification and successfully complete LemFi's onboarding and verification process as required for your country of residence;

• C. NOT be a resident of the United States, Canada, United Kingdom, or any European Union member state.

• D. accept these Terms;

Specific eligibility requirements for your region are set out in Section 24 below.

What information will LemFi need from you?

We have certain responsibilities under Applicable Law to verify the identity of, and run anti-money laundering checks on, our Customers prior to providing access to a Global Account and periodically thereafter. In order to fulfil these responsibilities, we will use third-party identification checking services to confirm your identity based on documentation and procedures applicable to your country of residence when you first use our services, and we will carry out regular monitoring checks while you remain a customer. As such, you give LemFi permission to obtain, verify, and record information that identifies and authenticates you, ultimate beneficial owners and partners (as applicable) and your funding sources. If the information reasonably requested is not granted, or such a change is not approved by us, we will consider this a serious breach of the Terms and may suspend or terminate the Services accordingly.

We may verify the information you provide us or we obtain ourselves on you in a manner deemed appropriate and suitable to us. We reserve the right to close, suspend, or limit access to your Global Account in the event we are unable to obtain or verify such information.

We will not be liable for any losses, damages or costs arising from our conduct of the checks detailed in this section.

Can LemFi change these Terms?

We may amend these Terms where we have a valid reason for doing so. If any amendments materially affect how we manage and provide the Services, or change fees, limits, or your rights, we will provide you with at least thirty (30) days' advance notice via LemFi App or through email before they are due to take effect.

Where changes are required by law, regulation, court order, or are necessary for security or fraud prevention reasons, such changes may take effect immediately or on such shorter notice period as we reasonably determine. We will notify you of such changes as soon as reasonably practicable.

If, as a result of the amendments we make to the Terms, you wish to close your Account with us, you may do so free of charge before the effective date of the change, in accordance with section 13.

10. Your Obligations

10.1 Lawful Use and Authority

You will be legally bound by the Terms so it is important on entering it, and on a continuing basis, you agree that you have and will maintain full legal capacity and all necessary authority, permissions and powers, and have taken all necessary action to enable you:

a. to enter into these Terms lawfully and freely; b. to give us orders and instructions based solely on your own instructions and your own use; c. to enter into any transactions at your own risk; and d. use the account or Digital Wallet Services for lawful and permitted purposes.

In accepting these terms, you confirm there is no action, suit or civil or criminal proceeding, or pending or threatened action against you, before any court, tribunal, governmental body, agency or official, or any arbitrator that purports to affect or is likely to affect, the legality, validity or enforceability of these Terms or ability to perform your obligations under these Terms.

10.2 Information Accuracy and Updates

You shall:

a. co-operate with LemFi in all matters relating to the Global Account; b. provide LemFi with such information and materials as LemFi may reasonably require in order to operate the Global Account and ensure that such information is true and accurate; c. regularly log on to your online Global Account to review your account activities as well as any communication that may be added to your Global Account from time to time and to inform us as soon as possible of any disputed transaction; d. notify us promptly of any changes to your circumstances or information you provided e.g. your income, residency or changes to your contact details, including any associated accounts; e. notify us immediately if you have lost access, control, or use of your account; and f. apply all reasonable efforts to maintain security of your account.

You are wholly responsible for the accuracy of any information that you provide to us and we shall not be liable to you nor anyone else (in any way whatsoever) should we act upon any incorrect information received from you which may result in financial loss or damage (including any costs, expenses or liabilities) of any kind. You will notify us immediately if you discover that any information we hold for you is obsolete, incorrect, misleading, inconsistent or fraudulent.

10.3 Security Responsibilities

Your access to the LemFi app will be protected via the username and password you created as part of the registration process.

Your username and password are personal to you and you must not share your username or password with anyone else. We shall not be liable to you for any losses, damages or costs suffered as a result of you sharing your username or password with a third party.

You must notify us immediately if you learn or suspect that the security of your username or password may have been breached. If we receive such a notification from you or determine ourselves that the security of your username or password may have been breached, you will not be able to access your Global Account until measures have been taken to verify your identity.

10.4. Indemnification

You will indemnify us against any liability, cost, expense, loss or any damage incurred by us (including but not limited to professional advisors' fees) arising from your breach of these Terms, negligence, wilful default or fraud or fraudulent misrepresentation.

11. LemFi's Rights and Obligations

11.1 Service Provision

We shall:
(a) provide you with access to the LemFi app; (b) provide you with wallet accounts for you to store money in; (c) make LemFi's customer service team available to you; and (d) allow you to use the Global Account to send and receive legitimate and authorised payments.

Specific wallet currencies and banking partners vary by region, as detailed in Section 24 below.

11.2 Verification and Monitoring

You acknowledge that any transaction dealt by us on your instructions will be based on our risk assessment including any statutory and other requirements relating to money laundering and combating terrorist financing.

We are legally obliged to keep your information confidential. However, LemFi or GIB may be required by Applicable Law to make a disclosure to relevant authorities where we know or suspect that a transaction may involve money laundering or terrorist financing. If we make a disclosure in relation to this matter, we may not be able to tell you that a disclosure has been made. LemFi or GIB may have to stop providing Services to you for a period of time and may not be able to tell you why. Neither LemFi nor GIB shall be

liable in any way whatsoever for any loss or damage (including any costs, expenses or liabilities) of any kind incurred by you as a result of having to make such a disclosure or having to stop providing Services to you for such a period of time.

If LemFi's performance of any of its obligations under the Agreement is prevented or delayed by any act or omission by you or failure to perform any relevant obligation under these Terms ("Customer Default"), LemFi shall without limiting its other rights or remedies have the right to suspend performance of the Services until you remedy the Customer Default. You grant us your consent for us to rely on the Customer Default to relieve us from the performance of any of our obligations, including to the extent the Customer Default prevents or delays LemFi's performance of any of its obligations.

In the event of a Customer Default, LemFi shall not be liable for any costs or losses sustained or incurred by you arising directly or indirectly from LemFi's failure or delay to perform any of its obligations as set out in these Terms.

11.3 Following Your Instructions and Payment Restrictions

You can give us instructions related to your Global Account via LemFi app or where so accepted by us via email.

We will always follow your instructions unless:

a) we reasonably believe that you didn't authorise the instruction; b) we reasonably suspect the instruction is fraudulent; c) it's necessary to reject your instruction to protect you or us from a crime; d) your instructions are unclear or incomplete; e) following your instruction would mean that we breach a law or regulation that we must comply with; or f) following your instruction would mean a Wallet balance goes below a nil balance.

When might LemFi refuse a payment?

We reserve the right to restrict the amount of money you may send or receive at our sole discretion. We will stop you if you try to make a withdrawal exceeding the limit we may impose in relation to your Global Account.

We can refuse to carry out any transaction on the Global Account in the following circumstances:

a) we reasonably believe that you or someone else is using the Global Account illegally or fraudulently; b) we are required to do so by law or we reasonably believe that carrying out the transaction would cause us to breach any law or regulation that applies to us; c) you are subject to a bankruptcy, insolvency, winding up or other similar event or where we reasonably believe that any of these are likely to happen; d) the relationship between you and us has irretrievably broken down (for example you have been threatening or abusive to our colleagues); e) there is a dispute (which we reasonably believe to be genuine) about the ownership or entitlement to the money in the Global Account; f) you are in breach of these Terms; g) we need to contact you to verify the validity of or clarify any instructions; h) we need to ask you for further information to complete the payment and you do not provide it to us; i) we need you to provide identification documents, or any other information, to prove your identity, or the authenticity of such information, to ensure we are meeting our legal and regulatory obligations; j) we need to verify the identity or authority of any person attempting to carry out a transaction on the Global Account or who informs us that they are acting for you; k) there are insufficient cleared funds in the Global Account to cover the amount of the payment; l) the terms of the Nominated Account prevent completion of an Electronic Payment; m) there are technical issues which prevent us from executing an Electronic Payment; n) circumstances beyond our reasonable control prevent us from offering a normal service (such as a computer failure or industrial action); o) We believe that you are using the account for business purposes not permitted by us; and/or p) Lemfi and GIB reserve the right to decline receipt of any payments coming into your account at our sole discretion.

Will LemFi tell you why a payment was refused?

We will tell you if we do not accept or make a payment for you and the reason why unless we cannot for legal, regulatory or security reasons.

12. Payments and Withdrawals

What types of payments can you receive into your Global Account?

We will only allow payments from you, friends, family, or your customers provided your incoming and outgoing payments are legitimate, untainted with fraud, free from theft or any criminal activity whatsoever, and subject to our approval.

Can you deposit cash or cheques?

We cannot accept any cash or cheque payments into your Global Account.

When will money appear in your account?

When we have received an electronic payment the money will be credited to your account on the same day subject to any delays beyond our control and our acceptance of the transaction in compliance with our legal and regulatory obligations, including but not limited to additional and satisfactory information being provided by you related to your transactions.

How do you withdraw money from your Global Account?

All withdrawals must be authorised by you.

You may be asked to produce confirmation of your identity before any withdrawal is carried out and a withdrawal is not authorised by us until this confirmation has been provided to us.

Withdrawals from your Global Account will be made to your Nominated Account. Upon processing, we will debit your Global Account with the amount you have instructed us to pay. Your Nominated Account must be in your own name, and we will verify name matching before processing any withdrawal. However, name-matching is not required for transfers between the custodial wallets under the same Global Account, e.g. your USD Wallet or GBP Wallet.

Payments out of your Global Account are instant and we cannot stop a payment you've asked us to make once they have been processed.

Specific withdrawal methods for your region are detailed in Section 24 below.

Is there a minimum withdrawal amount?

Withdrawal values must not be less than the equivalent of £1 (or currency equivalent) unless you wish to close your Global Account.

You will not be able to submit a withdrawal request if you do not have enough money in the Global Account to make the payment.

13. Account Closure

How do you close your Global Account?

If you wish to close your Global Account or LemFi Digital Wallet you just need to tell us. You can do this at any time through email sent to our Customer Support using the contact details in Section 1.2 above.

When can LemFi close your account?

In addition to your cancellation rights, LemFi and GIB shall be entitled to close your Global Account immediately for the following reasons:

a. if you have not given us any documents, we need to meet our regulatory or legal responsibilities; b. if you have failed to provide us with satisfactory evidence or documentation for us to complete our anti money laundering verification process; c. if we believe, acting reasonably that any information or declaration you have given to us when opening a Global Account or subsequently, is untrue, misleading, or incomplete in any material way, or if you fail to inform us of any information you later become aware of which makes any previous information untrue, misleading or incomplete; d. if you have behaved abusively, offensively or violently towards our staff. Or you use abusive or offensive language in instructions you give us; e. misuse or suspected misuse of the Global Account, including looking after someone else's money or as part of an economic crime such as money laundering, fraud, bribery, corruption, terrorism finance, or to avoid sanctions, or if you've acted fraudulently or illegally; f. if under the terms of a court order; or g. if you have done or failed to do something which means we are unable to comply with our legal and/or regulatory obligations.

What happens to your money when your account is closed?

Unless prevented due to legal reasons, upon the closure of your Global Account we will send any money held with us to your Nominated Account.

Subject to the above, we may retain the money in your Global Account if you do not address any concerns we have about the origin of the money or another person claims that the money belongs to them. If this occurs, you will not be able to access the money and we will continue to hold the money until the issue is resolved.

We will not be legally responsible for any remuneration, costs, charges, fees, expenses, taxes, or other amounts which become payable by closing your Global Account.

14. Liability and Limitations

14.1 LemFi's Liability**

No provision of the Terms will be deemed to restrict, qualify or exclude any duty owed to you under Applicable Law. Except and to the extent of any duties that we owe you in accordance with any statutory rights that we cannot lawfully exclude or restrict any liability therefor, we do not owe you any further duties except as expressly set out in this Agreement.

We will not be liable to you for any loss, damages or costs suffered or incurred by you except and only to the extent that such loss arises directly from our gross negligence, wilful default, or fraud. We will not be liable to you for any losses, damages or costs suffered or incurred by you:

a. which could not have been reasonably anticipated by us when you gave us an instruction; b. in relation to any loss of business, loss of goodwill, loss of opportunity or loss of profit; or c. which are indirect or consequential.

In exceptional circumstances, you might be entitled to recover some or all of your losses (subject to legal limits) if you have been a victim of fraud and have informed us immediately of such an event, or where you have made an unauthorised transaction. Specific fraud protection frameworks for your region are detailed in Section 24 below.

Nothing in these Terms require you to compensate us to any extent prohibited by Applicable Law. We will not be liable for any loss or damage of any kind that is attributable to:

• our failure to take any action which, in our opinion, might breach Applicable Law, or any action taken in order to comply with Applicable Law or the requirements of any market;

• any loss (including, without limitation, those which may occur due to delays during the process of verifying your identity in compliance with money laundering regulations);

• any reasonable refusal or failure to accept and / or execute any instruction received by you; or

• our reasonable reliance on any information, instructions, notices or communications that we believe to be from you and/or a person authorised by you to give the same, including any person authorised to give instructions in respect of your Global Account.

We will take reasonable care in the assessment and appointment of bankers, counterparties, agents and other third parties. Subject to the performance of that duty we will not be liable for any losses, damages or costs suffered or incurred by you that is attributable to the performance of any third party involved in the provision of the Global Account.

14.2 Force Majeure (Events Beyond Our Control)

LemFi will not be responsible for any liabilities arising because of any circumstance outside of its reasonable control. Such circumstances may include, but are not limited to, changes in Applicable Law, governmental, regulatory or judicial changes, currency restrictions, acts of God, civil unrest, war, terrorism, strikes, lock-outs, industrial disputes, breakdown in market systems or infrastructure (including of trading, clearing house, market participant or counterparty), failure, breakdown or disruption of electronic communications or other communications or computer service.

We shall not be in breach of these Terms if there is, and shall not be liable or have responsibility of any kind for any loss or damage incurred by you as a result of, any total or partial failure, interruption or delay in performance of our duties and obligations occasioned by any act of God, fire, act of government, state, governmental or supranational body or regulatory authority or war, civil commotion, terrorism, failure of any computer dealing system, interruptions of power supplies, labour disputes of whatever nature or any other reason (whether or not similar in kind to any of the above) beyond our reasonable control.

15. Fraud and Dispute Resolution

What should you do if you think you've been scammed?

You must notify us immediately if you are a victim of fraud and provide all relevant information, including but not limited to why you believe you are a victim of fraud, the nature of fraud, what payments you authorised and why, and actions you took following the fraud.

You must co-operate with our internal enquiries promptly and in a transparent manner.

How does LemFi investigate fraud claims?

We will investigate your claim for fraud and provide you with our response subject to our legal and regulatory obligations. You accept that we may not be able to provide a written response to your claim for fraud if it contravenes our other legal or regulatory obligations as applicable to us.

Following receipt of a fraud claim, we shall investigate such claim and respond to you accordingly.

Specific fraud protection frameworks, reimbursement procedures, and dispute resolution mechanisms for your region are detailed in Sections 24 and 26 below.

How do you make a complaint?

If you wish to make a complaint in relation to the Global Account, please contact us using the methods set out in Section 1.2 above.

Specific complaint escalation procedures and ombudsman services for your region are detailed in Section 26 below.

16. Tax and Reporting

Tax Reporting Obligations

To follow the law, we may need to share information about you and your Global Account with relevant tax authorities. They may pass this on to other tax authorities in other countries. You agree that we can give documents or information to tax authorities for this purpose.

We won't be responsible for any loss you may have if we disclose information about you in this way.

Specific tax authority names and reporting requirements for your region are detailed in Section 24 below.

Information Requests

If we ask you to give us personal information or documents so that we can decide if we need to share information with tax authorities, you agree to do this within 30 days of our request.

You'll need to let us know if any of this information changes after you give it to us.

17. Assignment and Transfer

Your Rights

These Terms are personal to you and you may not transfer or assign any rights or obligations to any third party.

LemFi's Rights

We may assign or transfer our rights and obligations under the Terms to any Affiliate or to any successor business. If this occurs, you will be notified by email.

If we assign or transfer any rights or obligations, you authorise us to transfer any of your money held by us or on our behalf to such Affiliate or successor business, or someone nominated by that person.

We will only transfer your money to another person who we believe will hold them under applicable regulatory standards or in respect of whom we have exercised all required due skill, care and diligence in assessing whether that person will apply adequate measures to protect it.

We will give you at least ten (10) Business Days written notice prior to any actions under this section.

If you object to such an assignment, you may terminate this Agreement and close your Global Account with us in accordance with these Terms.

18. Third Parties

A person who is not a party to the Agreement will not have any benefits under the Contracts (Rights of Third Parties) Act 1999 and will not have any rights to enforce its terms. This Agreement is for the sole benefit of the parties hereto and their respective permitted successors and assigns. Nothing herein, express or implied, is intended to or shall confer upon any other person or entity any legal or equitable right, benefit, or remedy of any nature whatsoever under or by reason of this Agreement

19. Notices and Communications

19.1 How LemFi Will Communicate With You

We will send all notices, information and other correspondence to you via the LemFi app or to the email address you have provided us with when you set up your Global Account. You agree as an ongoing obligation to provide us with an up to date email address and to inform us as soon as reasonably practicable if this should change. LemFi is entitled to rely on the last email address you have provided, and an email sent to that email address by LemFi shall be good service under these Terms.

We cannot guarantee that general emails will be successfully delivered, or that they will be secure and virus free. We will not be liable for any loss, damage, expense, harm or inconvenience caused as a result of an email being lost, delayed, intercepted, corrupted or otherwise altered, or for failing to be delivered for any reason beyond our reasonable control.

If we choose to correspond by post, communications will be sent to the address you provided when you set up your Account. Alternatively, we may communicate with you when appropriate by telephone.

Specific contact methods for your LemFi entity are provided in Section 1.2 above.

19.2 Your Responsibility to Maintain Contact Information

We will provide you with information about your Global Account within your LemFi app and this information will be updated each time you make a transaction.

As your Global Account is managed via the LemFi app you will only receive electronic transaction statements.

20. Security

Your access to the LemFi app will be protected via the username and password you created as part of the registration process.

Your username and password are personal to you and you must not share your username or password with anyone else. We shall not be liable to you for any losses, damages or costs suffered as a result of you sharing your username or password with a third party.

You must notify us immediately if you learn or suspect that the security of your username or password may have been breached. If we receive such a notification from you or determine ourselves that the security of your username or password may have been breached, you will not be able to access your LemFi Global Account until measures have been taken to verify your identity.

21. Complaints

If you wish to make a complaint in relation to the Global Account, please contact us using the methods set out in Section 1.2 above.

Specific complaint procedures and ombudsman services for your region are detailed in Section 26 below.

22. Data Protection and Privacy

Data Processing and Privacy Notices

We will obtain, process, store and use your personal data in accordance with and subject to Data Protection Legislation.

Privacy Notice(s): Please read the Privacy Notice applicable to your region to understand how we process your personal data and your rights. Links to applicable privacy notices are provided in Section 24 below.

Record Retention

We will keep records of any information obtained to verify your identity for as long as we are prescribed to do so by applicable anti-money laundering and counter-terrorism financing regulations, as amended, supplemented or replaced from time to time.

Disclosure of Information

You consent to and grant us the authority to disclose any information (when required by law or otherwise) in relation to your Global Account to relevant regulatory authorities, government bodies, law enforcement, and other authorized parties as required by Applicable Law.

Specific disclosure requirements for your region are detailed in Section 24 below.

23. Miscellaneous

Severability

If it is found that any section within these Terms is invalid, that invalid section will have no effect on the validity of the remaining sections in these Terms. The remaining Terms will continue to remain in place.

Entire Agreement

This Agreement constitutes the entire agreement between you and us regarding your Global Account. You acknowledge that you have not relied on any statement, promise, representation, assurance or warranty made or given by or on behalf of us which is not set out in these Terms.

Amendments to Terms

Changes to these Terms are governed by section 9.

English Language

These Terms may be provided to you in English or any other language that we support. For the avoidance of doubt, any non-English version of the Agreement is provided for translation purposes only. In the event that any conflict arises between the English and non-English versions of the Terms, the English version shall prevail.

24. Wallet Services

General Digital Wallet Services (applies to all regions)

Your Global Account includes Wallet Services that allow you to store electronic money, fund your account through your Nominated Account or any other method permitted by LemFi, make payments, and exchange currencies. Wallets are not bank accounts, do not earn interest, and funds are safeguarded or insured as set out below for your region.

Prohibited Uses of Wallet Services (applies globally):

(i) unlawful activity, including money laundering or terrorist financing; (ii) sanctions violations; (iii) fraudulent or deceptive activity; (iv) activity otherwise prohibited by applicable law; (v) use by any person not meeting eligibility requirements for their region.

UK Wallet Services

UK Wallet Services are regulated under the Electronic Money Regulations 2011 and supervised by the Financial Conduct Authority (FCA). Funds are safeguarded with designated partner banks. If LemFi ceases operations, safeguarded funds will be protected from creditors and should be returned to you in full. Complaints may be escalated to the UK Financial Ombudsman Service (FOS).

USD Wallet Services Overview

USD Wallet Services allow you to store funds in US Dollars in your LemFi Digital Wallet. Your LemFi Digital Wallet is an e-money account provided in partnership with Global Innovations Bank ("GIB").

Banking Partnership

Global Innovations Bank (GIB) acts as a banking partner to LemFi for your USD wallet. GIB is regulated in the United States and is a member of the Federal Deposit Insurance Corporation (FDIC).

The funds you deposit into your LemFi USD Wallet are held by GIB in your custodial wallet, which forms part of GIB’s segregated safeguarding accounts structure, separate from LemFi’s operational funds.

Safeguarding of USD Wallet Funds

IMPORTANT: Your USD wallet is an e-money account, not a bank deposit account. Your wallet balance represents electronic money and is NOT insured by the Federal Deposit Insurance Corporation (FDIC).

When you add money to your LemFi Digital Wallet, LemFi receives your funds and places them in segregated safeguarding accounts at GIB or Network Banks, separate from LemFi's own funds. LemFi then credits your wallet with an equivalent amount of electronic money.

This safeguarding structure means that if LemFi experiences financial difficulties, the funds backing your e-money are protected from LemFi's creditors and should be returned to you in full.

You should understand that:

• Your USD wallet balance is electronic money, not a deposit

• Electronic money is not covered by FDIC deposit insurance

• The backing funds are held in safeguarded accounts at GIB and Network Banks

• Safeguarding protects your money if LemFi fails, but operates differently than FDIC insurance

• While GIB and Network Banks are FDIC-insured institutions, your e-money wallet balance itself does not constitute a deposit at these institutions

Eligibility for USD Wallet Services

To use the USD Wallet Services, you must:

• be over the age of 18 years;

  • be a Nigerian citizen or a citizen of another country where USD Wallet Services are offered by LemFi (as applicable), excluding resident of the United States, Canada, United Kingdom, and European Union member states;

  • provide your full name;

  • provide your date of birth;

  • provide your complete current address (which might be verified);

  • provide your email address;

  • provide your mobile phone number;

  • provide valid government issued identification

  • successfully complete our client verification and on-boarding checks (“liveness check”);

  • accept these Terms applicable to LemFi Global Accounts;

  • provide purpose of your use of the Global Accounts;

  • provide details of expected monthly activity;

  • provide details of your current occupation;

  • provide information on your annual income;

  • provide any other additional information as required from time to time to continue to comply with the applicable Global Account conditions.

Additional verification requirements may apply based on regulatory obligations applicable to Pomelo Two US LLC or GIB. LemFI will inform you of any additional documentation or information required during the onboarding process.

How USD Wallets Differ from Bank Accounts

Your US Digital Wallet differs from a bank account in that: (a) funds in your wallet will not be invested or lent to third parties; (b) funds will not accrue interest; and (c) funds are protected through safeguarding (as described above) rather than FDIC deposit insurance.

Adding Money to Your USD Wallet

You can add money to your USD wallet:

(a) by sending money from any permitted account via ACH transfer to your wallet using the routing and account number linked to your wallet; (b) by sending money from your bank account using the account details provided in the app (as applicable); (c) receiving money from your friends, family, employer, or customer.

Withdrawals from USD Wallet

All withdrawals must be authorized by you. You may be asked to produce confirmation of your identity before any withdrawal is carried out.

Payments out of your USD wallet are typically processed immediately and we cannot stop a payment you've asked us to make once it has been processed.

Payment Execution Timelines for USD Wallets

For US domestic transfers (ACH): Payments are typically processed within 1-3 Business Days.

Payments out of your Global Account are typically processed immediately and we cannot stop a payment you've asked us to make once it has been processed.

Compliance with OFAC and Other Sanctions

All U.S. persons, including U.S. banks, bank holding companies, and non-bank subsidiaries, must comply with OFAC's regulations. This means that we, or GIB, may institute a hold on your account or your funds, if you are a Specially Designated National, fall into the scope of a country-based sanction program or within other applicable sanctions programs (including non-US sanctions programs).

Prohibited Activities for USD Wallets

In addition to the globally prohibited uses listed in Section 24.1, you are specifically prohibited from using your US Digital Wallet in connection with:

a. Adult Content, including, but not limited to, pornographic services and goods, adult entertainment related activities, or escort services; b. Alcoholic beverages, including the facilitation, sale, or distribution of alcoholic beverages; c. Bearer share corporations; d. Chemicals, including the facilitation, sale, or distribution of chemicals; e. Crypto-currencies or digital assets, including companies that facilitate the creation, sale, distribution, custody or exchange of crypto-currencies or digital assets; f. Dietary supplements, including the facilitation, sale or distribution of dietary supplements; g. Embassies and Foreign Consulates; h. Financial institutions, where GIB does not maintain a direct relationship with the financial institution or bank and a nested relationship is established; i. Foreign Bulk Shipment of Currency; j. Foreign Casinos/Gambling Establishments/Internet Gambling or other betting related services; k. Foreign Governments; l. Foreign offshore shell companies; m. Foreign Shell Banks; n. Jewels, precious metals, or stones, including the facilitation, sale, distribution, or exchange of jewels, precious

metals or stones; o. Medical devices and medications, including the facilitation, sale or distribution of drugs, prescription medications, or medical devices; p. Marijuana activities, including the creation, facilitation, sale or distribution of marijuana or marijuana paraphernalia, regardless of whether or not such sale is lawful in the jurisdiction in which the customer operates; q. Numbered or Designated Name Accounts; r. OFAC Listed countries, businesses, organizations, entities, or individuals; s. Parallel Banking Relationships; t. Online dating or marriage services; u. Online payday lenders; v. Payable Through Accounts; w. Pouch Activities; x. Stocks and other security interests, including the sale of stocks and other security interests; y. Telemarketing activities; z. Tobacco goods, including the facilitation, sale or distribution of tobacco goods; aa. Unlawful or Illegal Activities, including, without limitation: (i) the creation, facilitation, sale or distribution of any prohibited or illegal good or service or an activity that requires a governmental license where the customer lacks such a license; (ii) the creation, facilitation, sale or distribution of goods or services that violate the intellectual property rights of a third party; or
(iii) any Ponzi-scheme or pyramid selling; bb. Violence related activities, including the creation, facilitation, sale, or distribution of any material that promotes violence or hatred; or cc. Weapons, including the facilitation, sale or distribution of firearms or other weapons, military or semi-military goods, military software, or technologies.

Multiple Registrations Prohibited

Multiple registrations are prohibited. You may register only once, and each user must maintain a separate registration. If we detect multiple active registrations for a single user, we reserve the right to merge or terminate the registrations and refuse you all continued use of your Global Account without notification to you.

No Overdrafts Permitted

You are not permitted to overdraw your Digital Wallet. If the available balance in your Digital Wallet is insufficient to cover any payment or withdrawal you have authorized, the payment or withdrawal you have requested will be declined.

If your Digital Wallet balance becomes negative for any reason, you must load funds immediately to cover the negative balance. Any load we receive to your Digital Wallet will first be applied to any negative balance in your Digital Wallet.

We may also use any funds in any other account you have with GIB to offset a negative balance in your Digital Wallet.

How do I See My Transaction History and When Will LemFi Provide Periodic Statements?

You can access the details of all your Transactions and other information relating to your use of the USD Wallet by logging into the LemFi App and selecting the transfers or transaction history section.

You can download your transactions statement from the Account Information Section on the LemFi Mobile App for the previous two years to the current date or the date of your last transaction undertaken through the LemFi Mobile App.

Statements and transaction history for you USD Wallet are made available to you through the LemFi. We will provide periodic statements at least monthly for any month in which an electronic fund transfer has occurred I your wallet, or at least quarterly for any quarter in which no electronic fund transfers occurred

but your wallet remains accessible for electronic fund transfers. You can access and download your account information at any time. We will not mail paper statements unless required by law or requested by you.

Consumer Liability for Unauthorized Transfers (USD Wallets) IMPORTANT - READ CAREFULLY

Tell us AT ONCE if your phone, password, or other means of accessing your LemFi Digital Wallet has been lost or stolen, or if you believe someone has transferred or may transfer money from your wallet without your permission**.** Telephoning or emailing is the best way of keeping your possible losses down. You could lose all the money in your LemFi Digital Wallet.

Access Device for Your LemFi Digital Wallet

Your “access device” for purposes of these protections includes your mobile phone with the LemFi app installed, your username and password, biometric authentication, and any other means we provide to access your LemFi Digital Wallet and authorize electronic fund transfers.

Contact us immediately if:

• Your access device (phone, login credentials, or other means of access) has been lost or stolen, OR

• You believe someone has made or may make unauthorized electronic fund transfers from your LemFi Digital Wallet

How to contact us:

• Telephone: US +1 702 505 4976

• Email: contact@lemfi.com or support@lemfi.com

• Our business days are Monday through Friday, excluding US federal holidays

To help us identify you, please provide:

• Your name

• Your LemFi Digital Wallet customer identification number

• Your registered email address or phone number

Contacting us promptly is the best way to keep your possible losses down.

Your Maximum Liability Depends on When You Notify Us:

• 1. If You Know Your Access Device Was Lost or Stolen

  • If you learn that your access device has been lost or stolen:

  • If you notify us within 2 business days after you learn of the loss or theft, your liability is limited to $50 for unauthorized transfers made with your access device before you notified us.

  • If you do NOT notify us within 2 business days after you learn of the loss or theft, your liability may be up to $500 for unauthorized transfers that occur after the close of 2 business days and before you notify us, if we can prove that those additional unauthorized transfers would not have occurred had you notified us within 2 business days.

2: If You Discover Unauthorized Transfers on Your Periodic Statement

• If you did not know your access device was lost or stolen, but you discover unauthorized electronic fund transfers when you review your periodic statement:

• If you notify us within 60 calendar days after we transmit the periodic statement on which an unauthorized transfer first appears, your maximum liability is $500, if we can prove we could have prevented the unauthorized transfers had you notified us sooner.

• If you do NOT notify us within 60 calendar days after we transmit the periodic statement showing unauthorized transfers, your liability for unauthorized transfers that occur after the close of the 60 calendar days and before you notify us is unlimited, if we can prove we could have stopped those transfers had you notified us within the 60-day period. This means you could lose all money taken from your wallet after the 60-day period ends.

Extensions: If a good reason (such as extended travel or hospitalization) prevented you from notifying us within the time periods specified above, we will extend the time periods to a reasonable duration.

LemFi's Liability for Failed Transfers (USD Wallets)

If we do not complete a transfer to or from your LemFi Digital Wallet on time or in the correct amount according to our agreement with you, we will be liable for your losses or damages. However, there are some exceptions. We will not be liable, for instance:

(i) If, through no fault of ours, you do not have enough money in your LemFi Digital Wallet to make the funds transfer. (ii) If, through no fault of ours, our payment partner or the receiving bank cannot process a payment for any reason whatsoever. (iii) If, our systems and internal controls will not allow a payment to be processed. (iv) If, for some legal or regulatory reason, we cannot complete the transaction. (v) If circumstances beyond our control (such as fire or flood) prevent the transfer, despite reasonable precautions that we have taken. (vi) There may be other exceptions stated in our agreement with you.

Error Resolution Procedures for USD Wallet

In Case of Errors or Questions About Your Electronic Transfers

Telephone us at US +1 702 505 4976, or write to us at contact@lemfi.com as soon as you can if you think your account history, periodic statement, or balances or receipt is wrong or if you need more information about a transfer listed on the transaction history. We must hear from you no later than 60 days after you we made available to you the periodic statement on which the problem or error appeared.

In the event you notice an error, please make contact with us and provide the following information:

(i) Tell us your name and LemFi Digital Wallet unique customer identification number. (ii) Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information. (iii) Tell us the dollar amount of the suspected error.

If you tell us orally, we may require that you send us your complaint or question in writing within 10 business days.

We will determine whether an error occurred within 10 business days after we hear from you and will correct any error promptly. If we need more time, however, we may take up to 45 days to investigate your complaint or question. If we decide to do this, we will credit your account within 10 business days for the amount you think is in error, so that you will have the use of the money during the time it takes us to complete our investigation. If we ask you to put your complaint or question in writing and we do not receive it within 10 business days, we may not credit your account.

For errors involving new LemFi Digital Wallets (wallets opened 30 days or less before the transaction in question)or foreign-initiated transactions, we may take up to 90 days to investigate your complaint or question. For new LemFi Digital Wallets, we may take up to 20 business days to credit your LemFi Digital Wallet for the amount you think is in error.

We will tell you the results within three business days after completing our investigation. If we decide that there was no error, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation.

ALL QUESTIONS ABOUT TRANSACTIONS MADE WITH YOUR LEMFI DIGITAL WALLET MUST BE DIRECTED TO US (LEMFI/POMELO TWO US LLC), AND NOT TO GIB OR ANY OTHER FINANCIAL INSTITUTION WHERE YOU HAVE YOUR ACCOUNT.

We are responsible for the LEMFI DIGITAL WALLET service and for resolving any errors in transactions made with your LemFi Digital Wallet.

Confidentiality and Disclosure (USD Wallets)

We will disclose information to third parties about your account or the fund transfers you make:

(i) Where it is necessary for completing transfers, or (ii) In order to verify the existence and condition of your LemFi Digital Wallet for a third party, such as payment partner or merchant, or (iii) In order to comply with government agency or court orders, or (iv) If you give us your written permission.

US Tax Reporting

IRS Tax Reporting: To comply with US tax laws, we may need to share information about you and your Global Account with the Internal Revenue Service (IRS). You agree that we can provide documents or information to the IRS for this purpose.

We may be required to issue Form 1099 or other tax reporting documents to you and the IRS based on your account activity.

Tax Information Requests: If we ask you to provide your Social Security Number, Individual Taxpayer Identification Number, or other tax-related information, you agree to provide this within 30 days of our request.

You must notify us promptly if any of this information changes.

US Privacy and Data Protection for Global Account Subscribers Using U.S. Services

Please read the following privacy policies:

• LemFi Privacy Notice: https://lemfi.com/en-us/privacy

• GIB Privacy Policy: https://gibank.com/privacypolicy/

Record Retention: We will keep records of any information obtained to verify your identity for as long as required by the USA PATRIOT Act, Bank Secrecy Act, and other applicable anti-money laundering and counter-terrorism financing regulations.

Disclosure of Information for US Services: You consent to and grant us the authority to disclose any information (when required by law or otherwise) in relation to your Global Account to the following bodies: a. Internal Revenue Service (IRS); b. Financial Crimes Enforcement Network (FinCEN); c. Office of Foreign Assets Control (OFAC); d. State banking or financial services regulators; e. Federal banking regulators; f. Law enforcement agencies; g. Any other government body as required by law.

Service Interruptions

We try to always maintain the Service available to you, however access to your Global Account or use of the Wallet Services may occasionally be interrupted for example if we need to carry out maintenance on our system. Please contact us through our Customer Service to notify you of any problems you may be experiencing while using your Global Account or any Services.

Intellectual Property

You acknowledge that the Service, including but not limited to the content of the LemFi Mobile App, text, graphics, links, buttons, logos, and images, as well as all other copyrights, trademarks, service marks, logos, and product and service names are owned exclusively by or licensed to LemFi or a LemFi affiliate (the "LemFi Intellectual Property"). You agree to lawful use of any software used to provide the LemFi Mobile App. You may not copy, modify, or reverse engineer any part of the LemFi Intellectual Property.

Right of Set-Off

You agree that Lemfi and GIB are authorized at any time to set-off the funds deposited with us against your debts or liabilities owed to us. LemFi and GIB may exercise this right of set-off without notice to you unless required by applicable law.

No Commercial Use

Your Global Account may not be used for commercial purposes. You agree that any commercial use of your Global Account is in violation of this Agreement and is undertaken at your own risk. If LemFi discovers you are using your Global Account for such impermissible purposes, LemFi and GIB reserve the right to reject your Transaction(s) and terminate your right to use the Service at any time without notice or liability.

Eligible Payment Instruments

Only specific Payment Instruments are eligible for use with the Service. LemFi reserves the right, at its sole discretion, at any time to refuse or reject payment by certain types of Payment Instruments.

Transactions must be settled with a Payment Instrument issued by a U.S. financial institution.

No Third-Party Transactions

No Transactions on behalf of third parties are permitted. The use of the LemFi Digital Wallet is only for yourself. You may not use the Service to transfer funds on behalf of any other natural person or entity.

Transaction Accuracy

No changes will be permitted to your Transaction after its submission for processing. It is your responsibility to ensure accuracy in the Transaction details before submitting the Transaction.

25. Remittance Services

General Remittance Services (applies to all regions)

Remittance Services allow you to send money from your Digital Wallet to non-Wallet accounts (bank or mobile money) in supported countries. Transfers may involve foreign exchange conversion at displayed rates. Once authorized, remittances may be irrevocable, subject to cancellation rights under applicable law for your region.

Prohibited Uses of Remittance Services (applies globally):

(i) unlawful activity, including money laundering or terrorist financing; (ii) sanctions violations; (iii) fraudulent or deceptive activity; (iv) activity otherwise prohibited by applicable law; (v) use by any person not meeting eligibility requirements for their region.

UK Remittance Services

UK Remittance Services are regulated by the UK Payment Services Regulations. Execution times, safeguarding, and supported corridors are set out in the UK sections above. Complaints may be escalated to the FOS.

US Remittance Services Overview

US Remittance Services allow you to send money from your LemFi Digital Wallet to beneficiaries in the United States and other supported countries around the world. US Remittance Services are provided in partnership with Global Innovations Bank ("GIB").

Banking Partnership for Remittances

Global Innovations Bank (GIB) provides banking services for your remittance transactions. The funds underlying your remittance transactions are held by GIB or other FDIC member and insured depository institutions ("Network Banks") in segregated safeguarding accounts. The list of Network Banks is subject

to change from time to time and can be found at: https://banks.data.fdic.gov/bankfind-suite/bankfind/details/5175

Safeguarding of Remittance Funds

IMPORTANT: Funds in your LemFi Digital Wallet used for remittance transactions are electronic money and are NOT insured by the Federal Deposit Insurance Corporation (FDIC).

The funds underlying your remittance transactions are held by GIB or Network Banks in segregated safeguarding accounts separate from LemFi's own funds. This means that if LemFi experiences financial difficulties, these safeguarded funds are protected from LemFi's creditors and should be returned to you.

While GIB and Network Banks are FDIC-insured institutions, your e-money balance is not a deposit at these institutions and therefore is not FDIC-insured. Your funds are protected through safeguarding requirements that apply to e-money issuers.

Supported Countries

LemFi supports international payments from your USD wallet to select countries. The current list of supported countries is available in the app and on our website at https://lemfi.com/en-gb/international-money-transfer.

This list is subject to change based on regulatory requirements and our banking partners' capabilities.

How to Use Remittance Services

You may access your LemFi Digital Wallet by logging into your LemFi Mobile App. From here you will be able to access the details of your Transactions, including dates, currencies, charges, or exchange rates applied. This information is stored and will be available to you at any time.

You can only remit up to the amount that is available in your LemFi Digital Wallet. If you do not have enough funds you will not be able to make the Transaction. Once you have inserted all the details necessary to make the Transaction, the amount will be deducted from your LemFi Digital Wallet and transferred to the account inserted by you.

Currency Conversion for Remittances

When you send money to a beneficiary whose account is in a difference currency than your wallet, LemFi facilitates the currency conversion as part of the remittance transaction. You do not need to separately convert funds between your wallets before sending.

The exchange rate is displayed and locked in when you authorize the transaction. Any fees associated with currency conversion are disclosed before you complete the remittance. Your funds remain safeguarded in accordance with applicable regulations throughout the conversion and remittance process.

Providing Beneficiary Information

You must provide valid and complete beneficiary information for all remittance transactions, including:

• Beneficiary name

• Beneficiary account details (bank account number, mobile money number, etc.)

• Beneficiary address (where required)

• Any other information required by the destination country or payment method

We reserve the right to refuse any transaction if beneficiary information is incomplete, incorrect, or suspicious.

Exchange Rates

Locked-In Exchange Rates: We specify the exchange rate applicable to your transaction before you initiate or submit your requested Transaction. We display the value of the exchange rate available to you, and once you submit the transaction for completion the rate displayed on the LemFi App is locked in unless the submitted transaction fails for any reason whatsoever. If the submitted transaction fails your funds would be returned to your LemFi Digital Wallet in its original currency.

The exchange rate is guaranteed at the time you authorize the transaction and will not change even if market rates fluctuate before the transaction is completed.

Transaction Fees

We may charge a fee on money transfers to certain countries. All applicable Fees relating to any Transactions are fully visible to you on the LemFi App before you accept the Transaction. Any applicable fees associated with a Transaction are deducted when you submit a transaction for completion.

Transaction Fees we may charge do not include any fees that the Recipient's bank may charge. Those fees may be deducted from your LemFi Digital Wallet (in the case of your bank) or the delivered amount (in the case of the Recipient's bank).

Authorization and Cancellation of Remittances

A Transaction will be deemed received by us at the time you it via the LemFi Digital Wallet. You may cancel a transaction as described below, but after the cancellation window expires, the payment order may not be withdrawn or revoke.

Right to Cancel:

a) You may cancel a Transaction after sending the instructions by contacting LemFi Customer Service within thirty (30) minutes of the Transaction being authorized by you. After this, we cannot ensure the Transaction will be cancelled.

b) If you instruct us to submit a Transaction to a designated Beneficiary and later request that we stop the payment of such Transaction within the time frames set from time to time by us (but in no event will the time limit we set be less than thirty (30) minutes from the time on the receipt of the Transaction), we will need to check first if the Transaction has been paid to the Beneficiary. If we can confirm that payment has not been made, the Transaction will be cancelled and we will refund or credit back to you in your LemFi Digital Wallet in equal amounts in the US Dollar.

You have the right to cancel a remittance transfer and obtain a refund of all funds paid to LemFi, including any fees, if you contact LemFi Support within 30 minutes of the payment initiation.

When you contact LemFi Support, you must provide us with information to help identify the transfer you wish to cancel, including the amount and location where the funds were sent. We will refund your money within three (3) business days of your request to cancel a transfer as long as the funds have not already been picked up or deposited into a recipient's account.

Refused Transactions

Either Lemfi or GIB may, in its sole discretion to refuse any Transaction. Reasons for refusal may include but are not limited to an inability to match your registration information with your bank account details, incorrect Recipient details, an insufficient deposit amount or where processing the Transaction may cause either of us or any of our affiliates to breach applicable laws.

We generally will attempt to notify you of any refusal, using the contact information provided as part of your registration, stating (where possible) the reasons for the refusal and whether the problem can be corrected. We will not notify you of a refusal where to do so would be unlawful.

Error Resolution for International Remittances (US)

For funds transmitted to Recipients located in other countries:

If you think there has been an error or problem with your money transfer, you must contact LemFi Customer Support no later than 180 days of the date we promised to you that the funds would be made available to the Beneficiary.

When you do, you must disclose to LemFi the following information: (1) Your name and address; (2) The error or problem with the transfer, and why you believe it is an error or problem; (3) The name of the person receiving the funds, and if you know it, his or her telephone number or address; (4) The USD amount of the transfer; and (5) The confirmation code or number of the Transaction.

Investigation Timeline:

The law generally requires an investigation and determination as to whether an error occurred within 90 days after you contact LemFi Support. LemFi will inform you of its determination within three business days after completing its investigation. When LemFi decides that there was no error it will send you a written explanation. You may ask for copies of any documents used in the investigation.

Error Resolution for Domestic US Transfers

For electronic funds transfers transmitted to Recipients located within the U.S.:

Write to us at contact@lemfi.com or support@lemfi.com as soon as you can, if you think your statement or receipt is wrong or if you need more information about a transfer listed on the statement or receipt.

If your periodic statement shows transactions that you did not initiate, please contact LemFi Support at once to let us know. LemFi Support must hear from you no later than 60 days after we made available to you the periodic statement on which the error appears.

If you do not tell LemFi Support, you may not get back any of the money you lost after the 60 days, if we can prove that we could have stopped someone from taking the money had you told us in time.

When you do, you must disclose to LemFi Support the following information: (a) Tell us your name and account number (if any); (b) Describe the error or the transfer you are unsure about, and explain as clearly as you can why you believe it is an error or why you need more information; and (c) Tell us the dollar amount of the suspected error.

If you tell us orally, we may require you to send us your complaint or question in writing within 10 business days.

Investigation Timeline:

LemFi will determine whether an error occurred within 10 business days after we hear from you and will correct any error promptly. If we need more time, however, LemFi may take up to 45 days to investigate your complaint or question. If we decide to do this, LemFi will credit your account within 10 business days for the amount you think is in error, so that you will have the use of the money during the time it takes us to complete our investigation. If LemFi Support requests you to put your complaint in writing and you fail to do so, LemFi may not credit your LemFi Digital Wallet. Furthermore, LemFi reserves the right not to make available any refunds to you as permitted by law or due to your own negligence.

For errors involving new LemFi Digital Wallets, we may take up to 90 days to investigate your complaint or question. For new LemFi Digital Wallets, we may take up to 20 business days to credit your account for the amount you think is in error based on our discretion.

We will inform you of our determination within three business days after completing our investigation. If we decide that there was no error, we will send you a written explanation. You may ask for copies of any documents we used in our investigation.

Limitations of Liability for Remittances (US)

Neither we nor any of our agents, affiliates, holding companies, subsidiaries, employees, officers, directors, service providers, or subcontractors will be liable for any acts or omissions, unless permitted by applicable law, including but not limited to:

a) For losses or damages alleged to result from our failure to properly complete a transaction (other than as noted in the error resolution sections above); b) For losses or damages alleged to result from our delay in completing a transaction; c) If, through no fault of ours, you do not have enough money in Your Bank Account or have not timely deposited sufficient funds with us to make the transaction; d) If your system or device was not working properly during your use of the US Remittance Services and you knew about the breakdown when you started the transaction; e) For errors made by you or a beneficiary, such as making a transfer to an unintended person or transferring an unintended amount; f) For errors by your bank, such as the provision of incorrect bank account information for your Bank Account; g) For losses or damage arising from your misuse or inability to use our Services, whether due to reasons within our control or not; h) For losses or damage to you from our inability to complete a transaction because we are prohibited by law or for losses or damage caused as a result of actions taken due to our obligations under applicable law or order; i) Due to circumstances beyond our control (such as failure or interruption of telecommunications or data transmission systems) that prevent or affect the Transaction, despite reasonable precautions that we have taken; j) Due to your own negligence or failures.

Disclaimer for Remittances (US)

IN PROVIDING THE US REMITTANCE SERVICES TO YOU, NEITHER WE NOR ANY OF OUR AFFILIATES, HOLDING COMPANIES, SUBSIDIARIES, EMPLOYEES, OFFICERS, DIRECTORS, AGENTS, SERVICE PROVIDERS OR SUBCONTRACTORS, MAKES ANY EXPRESS WARRANTIES OR REPRESENTATIONS TO YOU WITH RESPECT TO THE SERVICE EXCEPT AS SET OUT IN THIS AGREEMENT, AND ALL IMPLIED AND STATUTORY WARRANTIES AND REPRESENTATIONS, INCLUDING WITHOUT LIMITATION ANY WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE, MERCHANTABILITY OR NON-INFRINGEMENT ARE HEREBY EXPRESSLY DISCLAIMED TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW.

IN NO EVENT SHALL WE OR ANY OF OUR AFFILIATES, HOLDING COMPANIES, SUBSIDIARIES, EMPLOYEES, OFFICERS, DIRECTORS, AGENTS, SERVICE PROVIDERS OR SUBCONTRACTORS BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, SPECIAL, CONSEQUENTIAL, PUNITIVE, EXEMPLARY OR INCIDENTAL DAMAGES, WHETHER BASED ON NEGLIGENCE, WILFUL MISCONDUCT, TORT, CONTRACT OR ANY OTHER THEORY OF LAW, OR FOR ANY DAMAGES FOR LOSS OF DATA, LOSS OF INCOME, FAILURE TO REALIZE EXPECTED REVENUES OR SAVINGS, LOSS OF PROFITS OR ANY ECONOMIC OR PECUNIARY LOSS.

WE FURTHER DISCLAIM ANY AND ALL LIABILITY FOR ANY GOODS OR SERVICES BOUGHT OR SOLD BY YOU THAT ARE SETTLED THROUGH YOUR PARTICIPATION IN THE SERVICE.

Service Providers

We use agents and other service providers to help us deliver the US Remittance Services to you. For example, a third party service provider may manage services on our behalf. Among other functions, third party service providers facilitate the delivery or settlement of your funds to recipients abroad. All third party services provided to you or us are performed at LemFi's direction and subject to our supervision and control.

Payment Instruments and Authorization

For us to collect payments from you and process transactions, you authorize us to access, charge, or debit funds from any of the payment instruments you provide us in connection with your use of the US Remittance Service, including, for example, your credit card, debit card or bank account (each a ”Payment Instrument“). If your payment fails or is insufficient, you authorize us to re-try one or more times using the same or a different Payment Instrument. We are not responsible for any fees or charges that may be imposed by the financial institution that issued your Payment Instrument.

Your authorization will remain in effect until you revoke it. You may revoke your authorization at any time by contacting us using the contact information in Section 1.2. If you revoke your authorization, we will not process further debits or charges using the revoked Payment Instrument, though we may require reasonable notice to process your revocation and may complete transactions already in process.
Revocation does not affect your obligation to pay for transactions you have already authorized.

Termination of Remittance Services

In the event you terminate this Agreement, we shall have no obligation to store, retain, report, or otherwise provide you with copies of, or access to, the Transaction data or any records, documentation, or other information in connection with any Transaction or the LemFi Digital Wallet except as provided by the applicable laws.

Upon termination, LemFi will retain records of your transaction history in accordance with regulatory requirements and LemFi retention policies and regulatory obligations.

26. Dispute Resolution and Arbitration

26.1 General Dispute Resolution (applies to all regions)

If you have a complaint, please contact LemFi customer support using the contact information in Section 1.2 above. We will investigate and attempt to resolve your complaint promptly. If we cannot resolve your issue, you may escalate in accordance with the procedures for your region set out below.

26.2 UK Dispute Resolution: What happens when you are still not happy once LemFi has responded to your complaint?

If you are still not happy once LemFi has responded to your complaint, there are options open to you. If you are an eligible complainant (i.e. you are acting for purposes which are wholly or mainly outside your trade, business, craft, or profession) and your complaint falls within the Financial Ombudsman Service’s jurisdiction, you may be able to take your complaint to the Financial Ombudsman Service. Further information on eligibility criteria and the procedures involved in referring your complaint to the Financial Ombudsman Service are available on the following weblink (http://www.financial-ombudsman.org.uk).

If you are not an eligible complainant (i.e. you are acting for purposes which are wholly or mainly related to your trade, business, craft, or profession) or your complaint does not fall within the Financial Ombudsman Service’s jurisdiction or you do not wish to refer your complaint to the Financial Ombudsman Service, you may refer your complaint to the courts in accordance with section 10.12, should you not be satisfied with LemFi's final response to your complaint.

26.3 US Dispute Resolution and Arbitration: What is the process for raising a complaint or dispute?

PLEASE READ THIS ARBITRATION CLAUSE CAREFULLY AS IT INCLUDES A CLASS ACTION WAIVER AND WAIVER OF A TRIAL BY JURY. PLEASE KEEP A COPY OF THIS ARBITRATION CLAUSE FOR YOUR RECORDS.

IF YOU DO NOT AGREE TO THE TERMS OF THIS ARBITRATION CLAUSE, DO NOT USE THE LEMFI APP OR LEMFI DIGITAL WALLET

Informal Dispute Resolution

Before formally pursuing a dispute in arbitration or small claims court, you agree to first send a detailed notice ("Notice") to:

For disputes with LemFi/Pomelo Two US LLC: Pomelo Two US LLC Attn: Compliance Email: complaints@lemfi.com

If we have a dispute with you, we agree to first send a Notice to you at your most recent email address on file with us, or if no email address is on file, other contact information associated with your LemFi Digital Wallet.

Your Notice must contain all of the following information: (1) your full name; (2) information that enables us to identify your Account, your address, mobile phone number, email address, and date of birth you used to register your LemFi Digital Wallet if any; and (3) a detailed description of your dispute, including the nature and factual basis of your claim(s) and the relief you are seeking with a corresponding calculation of your alleged damages (if any).

You must personally sign this Notice for it to be effective. You and we agree to then negotiate in a good faith effort to resolve the dispute. As part of these good faith negotiations, if we request a telephone conference with you to discuss your dispute, you agree to personally participate, with your attorney if you are represented by counsel. Likewise, if you request a telephone conference to discuss our dispute with you, then we agree to have one representative participate.

This informal process should lead to a resolution of the dispute. However, if the dispute is not resolved within 60 days after receipt of a fully completed Notice and the Parties have not otherwise mutually agreed to an extension of this informal dispute resolution time-period, you or we may initiate an arbitration (subject to a Party's right to elect small claims court as provided below).

Completion of this informal dispute resolution is a condition precedent to filing any demand for arbitration or small claims court action. Failure to do so is a breach of this Agreement. The statute of limitations and any filing fee deadlines will be tolled while you and we engage in this informal dispute resolution process.

Unless prohibited by applicable law, the arbitration provider shall not accept or administer any demand for arbitration and shall administratively close any arbitration unless the Party bringing such demand for arbitration can certify in writing that the terms and conditions of this informal dispute resolution process were fully satisfied. A court of competent jurisdiction shall have authority to enforce this provision and to enjoin any arbitration proceeding or small claims court action.

Scope of Arbitration

All disputes, claims, or controversies between you and us arising out of or related to this Agreement or any aspect of the relationship between you and us, whether based in contract, tort, statute, fraud, misrepresentation, consumer rights, constitution, regulation, ordinance or any other legal theory, will be resolved through final and binding arbitration before a neutral arbitrator instead of in a court by a judge or jury.

Claims subject to arbitration include initial claims, counterclaims, cross-claims, and third-party claims. Such claims also include data breach or privacy claims arising from or relating directly or indirectly to our disclosure (or disclosure by a third party acting on our behalf) of any non-public personal information about you, and disputes arising from communications involving telephones, automatic dialling systems, artificial or prerecorded voice messages, SMS text messages or facsimile machines. Claims subject to arbitration also include disputes arising from facts, actions or omissions that occurred prior to the date of this Agreement.

You agree that we and you are each waiving the right to trial by a jury.

The only exceptions to mandatory arbitration are the following: (1) invocation of small claims under the procedures set forth under this Arbitration Clause; or (2) any claim for injunctive other equitable relief in

a court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation, or violation of either party's copyrights, trademarks, trade secrets, patents, or other intellectual property rights.

Arbitration Rules

The arbitration will be administered by National Arbitration and Mediation ("NAM"). NAM shall not accept or administer any demand for arbitration and shall administratively close any arbitration unless the Party bringing such demand for arbitration can certify in writing that the terms and conditions of the informal mediation process provided above is fully satisfied.

Any arbitration between the Parties shall be administered by NAM in accordance with NAM's operative Comprehensive Dispute Resolution Rules and Procedures (the "NAM Rules") in effect at the time any demand for arbitration is filed with NAM, as modified by this Agreement.

For a copy of the NAM Rules, please visit https://www.namadr.com/resources/rules-fees-forms or contact NAM at:

• NAM's National Processing Center

• 990 Stewart Avenue, 1st Floor

• Garden City, NY 11530

• Email: commercial@namadr.com

• Phone: (800) 358-2550

If NAM is unable or unwilling to perform its duties under this Agreement, the Parties shall mutually agree on an alternative administrator that will replace NAM and assume NAM's role consistent with this Agreement. If the Parties are unable to agree, they will petition a court of competent jurisdiction to appoint an administrator that will assume NAM's duties under this Agreement.

Payment of all filing, administration and arbitrator fees will be governed by the NAM Rules or rules of the other organization.

Federal Arbitration Act: Notwithstanding any choice of law or other provision in this Agreement, the Parties agree and acknowledge that this Arbitration section evidences a transaction involving interstate commerce and that the Federal Arbitration Act, 9 U.S.C. § 1 et seq. ("FAA"), will govern its interpretation and enforcement and proceedings pursuant thereto. It is the intent of the parties that the FAA and NAM Rules pre-empt all state laws to the fullest extent permitted by law. If the FAA and NAM Rules are found to not apply to any issue that arises under this Arbitration Clause or the enforcement thereof, then that issue shall be resolved under the laws of the State of New York.

Arbitration Procedure

A Party who desires to initiate arbitration must provide the other party with a written demand for arbitration as specified in the NAM Rules. The Parties agree that each individual claim for arbitration must set out the identity of the plaintiff and the plaintiff's counsel, a detailed description of the legal claims being asserted and the requested relief, including a good-faith calculation of the specific amount in dispute.

The arbitrator, and not any federal, state, or local court or agency, has exclusive authority to resolve any disputes relating to the interpretation, applicability, enforceability or formation of this Arbitration Clause, including any claim that all or any part of this Arbitration Clause is void or voidable. The arbitrator is responsible for determining all threshold arbitrability issues, including issues relating to whether this Agreement is unconscionable or illusory and any defence to arbitration, including waiver, delay, laches, or estoppel.

The arbitrator will conduct hearings, if any, by teleconference or videoconference, rather than by personal appearances, unless the arbitrator determines upon request by you or by us that an in-person hearing is required. Any in-person appearances will be held at a location which is reasonably convenient to the Parties with due consideration of their ability to travel and other pertinent circumstances. If the Parties are unable to agree on a location, such determination should be made by the NAM or by the arbitrator.

The arbitrator's decision will follow the terms of this Terms and will be final and binding, subject to any appeal rights under the FAA. The arbitrator must apply substantive governing law consistent with the FAA and applicable statutes of limitation and privileges. The arbitrator may award any damages or other relief or remedies that would apply under applicable law to an individual action brought in court. The arbitrator will have authority to award temporary, interim, or permanent injunctive relief or relief providing for specific performance of this Agreement, but only to the extent necessary to provide relief warranted by the individual claim before the arbitrator. The award rendered by the arbitrator may be confirmed and enforced in any court having jurisdiction thereof.

Notwithstanding any of the foregoing, nothing in this Agreement will preclude you from bringing issues to the attention of federal, state, or local agencies and, if the law allows, they can seek relief against us for you.

Mass Filing Procedures

If, at any time, 25 or more similar demands for arbitration are asserted against us or related parties by the same or coordinated counsel or entities ("Mass Filing"), consistent with the definition and criteria of Mass Filings set forth in the NAM's Mass Filing Supplemental Dispute Resolution Rules and Procedures ("NAM's Mass Filing Rules", available at https://www.namadr.com/resources/rules-fees-forms/"), the additional protocols set forth below shall apply.

If you or your counsel file a demand for arbitration (a "Demand") that fits within the definition of Mass Filing referred to above, then you agree that your Demand for arbitration shall be subject to the additional protocols set forth in this Mass Filing subsection. You also acknowledge that the adjudication of your dispute might be delayed and that any applicable statute of limitations shall be tolled from the time at which you initiate informal dispute resolution until your Demand is decided, withdrawn, or settled.

NAM's Mass Filing Rules shall apply if your Demand is deemed by NAM, in its sole discretion pursuant to NAM's Mass Filing Rules and this dispute resolution section, to be part of a Mass Filing. Such election for NAM's Mass Filing Rules and related fee schedule must be made by either you or us in writing and submitted to NAM and all Parties.

Bellwether Proceedings

Bellwether proceedings are encouraged by courts and arbitration administrators when there are multiple disputes involving similar claims against the same or related parties. Counsel for the Mass Filings claimants (including you) and counsel for us shall each select 15 Demands (30 total), and no more than 30 arbitrations shall be filed, processed, adjudicated, or pending at the same time, with each of the 30 individual arbitrations presided over by a different arbitrator, in a first set of bellwether proceedings.

During this time, no other Demands that are part of the Mass Filings may be filed, processed, adjudicated, or pending. If the Parties are unable to resolve the remaining Demands after the first set of bellwether proceedings are arbitrated or otherwise resolved, then counsel for the claimants and counsel for us shall each select an additional 15 Demands (30 total) to be filed, processed, and adjudicated as individual arbitrations, with each of the 30 arbitrations presided over by a different arbitrator, in a second set of bellwether proceedings.

During this time, no other Demands for arbitration that are part of the Mass Filings may be filed, processed, or adjudicated. This staged process of bellwether proceedings, with each set including 30 Demands adjudicated on an individual basis, shall continue until each Demand included in the Mass Filings (including your Demand) is adjudicated or otherwise resolved.

Fees associated with a Demand included in the Mass Filings, including fees owed by us and the claimants (including you), shall only be due after your Demand is chosen as part of a set of bellwether proceedings and therefore properly designated for filing, processing, and adjudication.

Any applicable statute of limitations shall be tolled beginning when you initiate the informal dispute resolution process set forth above, and if the first Mass Filings' Demands are chosen for the initial set of bellwether proceedings have been filed, your claims will remain tolled until your Demand is decided, withdrawn, or settled. A court of competent jurisdiction located in New York, New York, U.S.A. shall have the power to enforce this subsection.

The bellwether proceedings set forth above are preferred by the Parties. However, if said proceedings are determined to not be feasible under the circumstances, the Parties agree to cooperate with each other and the arbitration provider or arbitrator to establish alternative processes or procedures that the arbitration provider or arbitrator believe will provide for an efficient, cost-effective resolution of claims. Any disagreement between the parties as to whether bellwether proceedings should apply shall be resolved by a procedural arbitrator appointed by NAM.

The Parties each agree that we each value the integrity and efficiency of the arbitration and small claims court process and wish to employ the process for the fair resolution of genuine and sincere disputes between us. The Parties acknowledge and agree to act in good faith to ensure the fair resolution of genuine and sincere disputes. The Parties further agree that application of these Mass Filings procedures have been reasonably designed to result in an efficient and fair adjudication of such cases.

Class Action Waiver

You agree that any arbitration under this Agreement will take place on an individual basis, and not as a class, collective, private attorney general, or representative action or proceeding and such class, collective, private attorney general, or representative arbitrations are not permitted, and (unless all

parties otherwise agree in writing) you are agreeing to give up the ability to participate in or join claims of multiple individuals against us in a single proceeding (the "Class Action Waiver").

If a claim does not proceed in arbitration for any reason, the Class Action Waiver will remain in effect, and you shall not join or file any action or proceeding in court on a class, representative or joint basis against us.

Jury Waiver

Each Party waives the right to a trial by jury in any court in any suit, action, or proceeding on any matter arising in connection with or in any way related to the transactions of which this Agreement is a part or its enforcement, except where such waiver is prohibited by law or deemed by a court of law to be against public policy. The Parties each acknowledge that each Party makes this waiver knowingly, willingly and voluntarily and without duress, and only after extensive consideration of the ramifications of this waiver with their respective attorneys.

Small Claims Exception

Notwithstanding the foregoing, either you or we may elect to have an individual claim heard in small claims court. If the request to proceed in small claims court is made after an arbitration has been initiated but before an arbitrator has been appointed, such arbitration shall be administratively closed. Any controversy over the small claims court's jurisdiction shall be determined solely by the small claims court.

All other issues (except as otherwise provided herein) are exclusively for the arbitrator to decide, as well as any request to proceed in small claims court that is made after an arbitrator has been appointed. If you or we challenge the small claims court election in your dispute, and the small claims court determines that it does not have jurisdiction, then the claim shall be heard in arbitration.

Venue and Forum Selection

Except where prohibited by law and except for claims that are heard in a small claims court as set forth in this Agreement, any claims arising out of or relating to this Agreement, our services, or to your relationship with us that for whatever reason are not required to be arbitrated or filed in small claims court, will be litigated exclusively in the federal or state courts located in New York, New York, U.S.A. You consent to the exercise of personal jurisdiction of courts in the State of New York and waive any claim that such courts constitute an inconvenient forum.

Severability; Survival; Conflicts

If any part of this Arbitration Clause is found by a court or arbitrator to be unenforceable, the remainder is enforceable, except that:

1. if the Class Action Waiver is limited, voided or found unenforceable in a proceeding between you and us, and that determination becomes final after all appeals have been exhausted, then this Arbitration Clause (except for this sentence) shall be null and void with respect to such proceeding; and

2. if a claim is brought seeking public injunctive relief and a court determines that the restrictions in the Class Action Waiver or elsewhere in this Arbitration Clause prohibiting the arbitrator from awarding relief on behalf of third parties are unenforceable with respect to such claim, and that determination becomes

final after all appeals have been exhausted, the claim for public injunctive relief will be determined in court and any individual claims seeking monetary relief will be arbitrated. In such a case the parties will request that the court stay the claim for public injunctive relief until the arbitration award pertaining to individual relief has been entered in court.

This Arbitration Clause will survive the termination of the Agreement, regardless of reason for termination, the sale or assignment of your obligation by us to a third party, the repayment of some or all amounts owed under the Agreement and any bankruptcy by you, to the extent consistent with applicable bankruptcy law.

In the event of a conflict or inconsistency between this Arbitration Clause, on the one hand, and the applicable arbitration rules or the other provisions of the Agreement, on the other hand, this Arbitration Clause shall govern.