GIB - Wallet & Remittance Services

Key Facts About Your U.S. Wallet

This summary provides key information about the LemFi U.S. Wallet & Remittance Services. Please read the entire Agreement for complete details.

What is it? The LemFi Wallet is an electronic money account for storing U.S. dollars and sending money domestically and internationally through the LemFi mobile app.

Who provides it? Pomelo Two US LLC ("LemFi US"), in partnership with FDIC-insured Partner Banks that hold the funds backing your Wallet.

Who can use it?

• U.S. residents (50 states + District of Columbia)
• 18 years of age or older
• Must complete identity verification (see Sections 10 and 24)

Is my Wallet FDIC-insured? No. Your Wallet contains electronic money, and is not a bank deposit account. Electronic money is not FDIC-insured.

How are my funds protected? Funds backing your Wallet are held in segregated safeguarding accounts at FDIC-insured Partner Banks. If LemFi fails, these safeguarded funds should be returned to you. See Section 6 for complete details.

Are there fees? No fees currently. We may charge fees in the future with 30 days' advance notice. Third-party fees may apply.

Does my Wallet earn interest? No. Wallet balances do not earn interest.

Are there limits? Yes. Limits apply and are shown in the LemFi App.

Can I overdraw my Wallet? No. Transactions will be declined if you have insufficient funds.

Can I cancel a transaction? Yes, within 30 minutes of initiating a remittance transfer for a full refund. After 30 minutes, most transactions cannot be cancelled.

What if there's an error or unauthorized transaction? Contact us immediately: +1 702 505 4976 or support@lemfi.com. Your liability depends on how quickly you report:

• Within 2 business days → Maximum $50 liability
• Within 60 days → Maximum $500 liability
• After 60 days → Could lose all unauthorized amounts

See Section 24 for complete error resolution procedures.

What activities are prohibited? Cryptocurrency, gambling, marijuana, adult content, weapons, and others. See Section 24 for the complete list. Only one Wallet per person.

1. Introduction

1.1 Who We Are: LemFi is a global financial services brand operating through various authorized legal entities in different jurisdictions. For U.S. customers, "LemFi," "we," or "us" means Pomelo Two US LLC ("LemFi US"). LemFi US provides the Wallet Services and related Remittance Services described in these Terms.

1.2 What the Service Is: The Wallet is an electronic money account that allows you to store U.S. dollars, send money domestically and internationally, and manage funds through the LemFi App.

Funds backing your Wallet are held in segregated safeguarding accounts at FDIC-insured Partner Banks. Your Wallet is not a bank deposit account and is not FDIC-insured. For complete information on how your funds are protected, see Section 6 (Safeguarding of Funds and FDIC Insurance).

1.3 How the Wallet Works: You can add money to your Wallet via eligible payment methods shown in the LemFi App (including debit card, Apple Pay, or Google Pay). You can hold funds in U.S. dollars and use the Wallet together with our Remittance Service to send funds to recipients in the United States and supported international corridors, as further described in Section 25 (Remittance Service).

1.4 Who May Use the Service: The Wallet Service is available only to natural persons who are residents of the United States, are at least 18 years old, and who successfully complete our identity-verification and onboarding requirements as described in Sections 10 and 24. By opening a Wallet, you represent that you meet these eligibility criteria.

1.5 Jurisdiction and Provider: The U.S. Wallet Service is provided by LemFi US and is governed by the laws of the United States and the State of Delaware, without regard to conflict-of-law principles.

1.6 Website and LemFi App: We operate the website at lemfi.com and the LemFi App through which you may access and manage your Wallet and Remittance Service.

1.7 How to Contact LemFi:

• Email: contact@lemfi.com or support@lemfi.com
• Messaging: You can send LemFi a message via the customer support function on the LemFi App
• Telephone: +1 702 505 4976

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 LemFi App at any time.

1.8 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 the 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.

2. Definitions

The following words have the following meaning:

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

"LemFi App" means the LemFi Finance mobile application, available on Google Play and the App Store.

"Applicable Law" means any federal or state law, regulation, rule, regulatory guidance, or court order that applies to LemFi US 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.

"Key Facts Summary" means the executive summary at the beginning of this Agreement.

"Business Day" means any day other than Saturday, Sunday, U.S. federal or New York state holiday on which the Partner Bank's offices are open for business.

"Electronic Payment" means a payment from your Wallet by electronic means.

"Electronic Money" means the electronic representation of U.S. dollar funds stored in your Wallet. When you add money to your Wallet, LemFi US issues an equivalent amount of Electronic Money and holds the underlying funds in safeguarded accounts at the Partner Banks.

"LemFi US" means the Pomelo Two US LLC, a Delaware limited liability company, which provides the U.S. Wallet Service and Remittance Services described in these Terms.

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

"LemFi 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 LemFi US for the purposes of these Terms and Services provided to U.S. customers.

"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.

"Partner Bank" means an FDIC-member insured depository institution that holds funds underlying your LemFi Wallet in segregated safeguarding accounts, as listed at https://banks.data.fdic.gov/bankfind-suite/bankfind/details/5175

"Payment" means the LemFi US 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.

"Payment Instrument" means a debit card, Apple Pay, Google Pay, or other approved method used to fund your Wallet.

"Remittance Service" means the service allowing You to send money from Your Wallet to non-Wallet accounts in supported countries, as further described in Section 25.

"Wallet Service" means the service allowing You to store, send, and receive Electronic Money in U.S. dollars through the LemFi App, as further described in Section 24.

"Service" means the U.S. Wallet Service and Remittance Service provided by LemFi US under these Terms.

"Terms" or "Agreement" means this document, including all provisions applicable to the U.S. Wallet Services.

"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 Wallet.

"us", "we" means LemFi US, as specified in Section 1.1 above.

"You", "your", "Customer" means you, being the individual that used the Wallet and agrees to these Terms.

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 Wallet and the related Remittance Services can provide to you. They describe your responsibilities to LemFi US and LemFi US's responsibilities to you, how and when these terms can be terminated and the extent of LemFi US'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 in the LemFi App, or by otherwise agreeing to these Terms on the LemFi App. By doing so, you agree to comply with them as amended from time to time.

When Do These Terms Come Into Force and When Do They End? These terms come into force when you have accepted them and LemFi US has successfully onboarded you as a customer. They remain in effect until terminated in accordance with this Section 3 or Section 13 (Wallet Closure).

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 1.7 (Contacting LemFi). LemFi may terminate these Terms, or suspend or close your access to the LemFi App and Wallet, at any time in accordance with Section 13 (Wallet Closure) or as otherwise permitted by Applicable Law. LemFi and its Partner Banks can also close or suspend your access to the Wallet to comply with legal or regulatory requirements.

What Happens When These Terms Are Terminated? When these Terms end, your Wallet will be closed, and you will no longer be able to access or use the Services. Accordingly, it is your sole responsibility to ensure that there is no money in any of your Wallet prior to terminating these Terms and closing your Wallet. For six years after these Terms are terminated, you will be able to contact LemFi by email to ask LemFi to transfer any remaining balance in your Wallet to a verified account in your name. During this period, LemFi may deduct any amounts you owe from such remaining balance.

4. Main Characteristics of the Service

4.1 Overview of the Wallet Service: The Wallet Service allows you to store, send, and receive Electronic Money in U.S. dollars through the LemFi App. Your Wallet is a custodial electronic-money account issued by LemFi US and backed by funds held in segregated safeguarding accounts with one or more Partner Banks. The Wallet is not a bank deposit account and does not earn interest. Funds underlying your Wallet are safeguarded as described in Section 24 (U.S. Wallet Service).

4.2 Funding Your Wallet: You can add money to your Wallet using a debit card, Apple Pay, Google Pay, or another Payment Instrument shown in the LemFi App and approved by LemFi US. Funds added in this way are converted to Electronic Money and credited to your Wallet once the payment is successfully processed. Funding by cash, check, or wire transfer is not permitted unless explicitly offered in the LemFi App. Specific processing times and limits are set out in Section 5.

4.3 Using Your Wallet: You may use your Wallet to hold U.S. dollar balances, send funds to other LemFi users, and initiate Remittance Transactions to Beneficiary Accounts in the United States or other supported countries.

4.4 Receiving Money: You may receive funds into your Wallet from other LemFi users or from permitted payment sources displayed in the LemFi App. When LemFi US receives the corresponding funds, it credits your Wallet with an equivalent amount of Electronic Money.

4.5 Limits and Restrictions: LemFi US may set or change limits on how much you can hold in your Wallet or add, send, or withdraw in a single Transaction or over a defined period. Applicable limits are shown in the LemFi App and may vary based on your verification status, usage history, and Applicable Law.

4.6 No Interest and No Deposit Insurance: Balances in your Wallet do not earn interest or any other return. Your Wallet is an electronic money account, not a bank account. Wallet balances are not FDIC-insured. Your funds are protected through safeguarding as described in Section 6.

4.7 Relationship to Partner Banks: LemFi US is not a bank. Funds supporting the Wallet are held for your benefit at Partner Banks that form part of the Network Banks. Your only contractual relationship under these Terms is with LemFi US, not with any Partner Bank. However, LemFi US and its Partner Banks work together to provide the Services and to comply with Applicable Law.

5. Wallet Use

5.1 Using and Accessing Wallet Services

To Use Your Wallet, 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 Wallet; (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; and (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.

You accept that you may only use the Wallet 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 Funds Are Processed When Added to Your Wallet: When you add money to your Wallet using an approved Payment Instrument (such as a linked debit card, Apple Pay, Google Pay, or another method shown in the LemFi App), LemFi US receives the corresponding amount and issues an equivalent value of Electronic Money, which is credited to your Wallet. We may delay crediting or place a temporary hold on funds until the underlying payment clears or is verified. LemFi US may also require you to confirm ownership of a Payment Instrument or complete other verification steps before funds are made available.

What Can You Use the Money In Your Wallet For? Once you have money in your Wallet, you will be able to: (a) send money to persons, other than you, which hold a Wallet with LemFi; and (b) 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).

How Do You Send Money to Non-LemFi Users (Remittance Services)? You can also send money from your Wallet 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).

A discussion of safeguarding is found in Section 6. Specific safeguarding arrangements and insurance coverage details are 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 LemFi 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 LemFi App? No, only LemFi is able to set spending limits.

How Do You Find Out the Balance of Money In Your Wallet and How Will You Know When Money Has Been Added to Your Wallet? You can check the balance of your Wallet 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 US is closed.

We will send a notification to your mobile device each time you receive money into your Wallet. 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 LemFi 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 Wallet? Account statements and transaction history for your Wallet are available through the LemFi App. You can access and download your statements at any time. Periodic statements will be generated and made available to you.

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 LemFi 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, LemFi US reserves the right to charge fees in the future for specific services (e.g., Remittance Services), subject to appropriate disclosure aligned to prevailing regulatory requirements. Any applicable fees will be clearly visible to you before you accept a transaction.

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 and FDIC Insurance

6.1 Overview: How Your Funds Are Protected: When you add money to your Wallet, LemFi US receives your funds and places them in custodial, segregated safeguarding accounts held at one or more FDIC-insured Partner Banks (together, the "Network Banks"). These accounts are:

• Maintained solely for the benefit of Wallet holders
• Completely separate from LemFi US's operational funds
• Held at FDIC-insured depository institutions

LemFi US then credits your Wallet with an equivalent amount of electronic money, which is what you see displayed in your LemFi App.

6.2 What Is Safeguarding? Safeguarding is a legal requirement for electronic money issuers that protects your funds if LemFi US experiences financial difficulties.

If LemFi US fails or becomes insolvent, the funds in the segregated Partner Bank accounts are protected from LemFi's creditors and should be returned to you in full.

This protection exists because the funds are:

• Held at separate institutions (Partner Banks, not LemFi)
• In accounts designated solely for Wallet holders' benefit
• Segregated from LemFi's own operational funds

6.3 Your Wallet is NOT FDIC-Insured (Important Distinction): IMPORTANT: Your Wallet is an electronic money account, not a bank deposit account. Your Wallet balance is not insured by the Federal Deposit Insurance Corporation (FDIC).

Here's the key distinction:

Your Wallet Balance represents Electronic Money displayed in the LemFi App. Underlying Funds at Partner Banks are actual U.S. dollars in segregated safeguarding accounts.

While the Partner Banks themselves are FDIC-insured institutions and they hold the actual funds backing your electronic money, your Wallet balance itself does not constitute a deposit at these institutions. Therefore, your Wallet balance is not covered by FDIC deposit insurance.

6.4 Safeguarding vs. FDIC Insurance: What's the Difference?

SAFEGUARDING (applies to your Wallet):

• Protects funds if LemFi US (the e-money issuer) fails
• Funds held separately at Partner Banks should be returned to you
• Required by law for electronic money issuers
• Applies to electronic money accounts

FDIC INSURANCE (does NOT apply to your Wallet):

• Protects deposits if a bank fails
• Covers up to $250,000 per depositor per insured bank
• Applies to traditional bank deposit accounts
• Does NOT cover electronic money accounts

6.5 Where Are Your Funds Held? LemFi US holds safeguarded funds with Partner Banks, which are FDIC-insured depository institutions. The current list of Partner Banks can be found at: https://banks.data.fdic.gov/bankfind-suite/bankfind/details/5175

LemFi US may change Partner Banks from time to time. Any such changes:

• Will be reflected in the updated list at the URL above
• Will not affect your Wallet balance
• Will not reduce the safeguarding protection

If you have questions about safeguarding or how your funds are protected, contact us using the information in Section 1.7.

7. The LemFi App

What Is the LemFi App? The LemFi App is the application you use to access and manage your Wallet and related Remittance Service. Through the App, you can: (a) view the amount of U.S. dollars held in your Wallet; (b) add money to your Wallet using approved Payment Instruments; (c) send money from your Wallet to other LemFi users or to Beneficiary Accounts using the Remittance Service; (d) review your transaction history and download statements.

The App is the primary method for accessing and managing your Wallet.

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 Wallet via the LemFi App. It is your responsibility to keep all your Wallet details including your password safe and secure and ensure they cannot be accessed by others.

We will take all reasonable steps to ensure your Wallet can be viewed via the LemFi 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 may initiate a payment from your Wallet to another LemFi user or a Beneficiary Account by following the instructions in the App. You will be asked to provide 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.

Any instructions to change your details regarding your Wallet 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 you wish to send to the beneficiary account is not U.S. Dollars, 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 Wallet 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.

8. Electronic Communications and Disclosures (E-SIGN Act Consent)

8.1 Agreement to Electronic Delivery: The Wallet Service is an electronic commerce relationship. By accepting these Terms and using the Wallet, you agree to receive all communications, disclosures, and documentation electronically as described in this Section 8.

By subscribing to the Service, you acknowledge and expressly agree that all Service Communications (as defined below), this 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 in the same manner as if an original document or signature had been delivered.

8.2 What Communications Will Be Electronic: 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:

a) These Terms and any amendments, modifications, or supplements to them; b) Our Privacy Policy and any updates to it; c) Records of all your Transactions through the Wallet and Remittance Service; d) Periodic statements and account history; e) Transaction receipts and confirmations; f) Pre-transaction disclosures required for remittance transfers; g) All disclosures required by federal or state law, including those required under Regulation E, the Electronic Fund Transfer Act, the Remittance Rule, and other applicable laws; h) Notices regarding fees, limits, or changes to these Terms; i) Customer service communications, including communications regarding suspected fraud, errors, or disputes; j) Error resolution and claims procedures; k) Legal notices and other communications related to your Wallet or our relationship with you; and l) Any other communications related to the Wallet Service or Remittance Service.

8.3 How Electronic Communications Are Provided: Service Communications will be provided to you by one or more of the following methods:

a) Through the LemFi App; b) Via email to the email address you provide during registration or update in your profile; c) Via SMS/text message to your registered phone number; d) By posting on the LemFi website (lemfi.com); or e) By making information available for download or viewing through your Wallet account.

8.4 Hardware and Software Requirements: To receive and retain electronic Service Communications, you must have:

a) A hardware device (such as a smartphone, tablet, or computer) capable of accessing the internet; b) A current operating system (iOS, Android, Windows, Mac OS, or other supported system); c) Internet access via WiFi, mobile data, or other connection; d) The LemFi App installed on your mobile device (or access to the LemFi website); e) Sufficient storage space or cloud storage capability to retain electronic records; and f) A valid email address.

You are responsible for ensuring your device and software meet these requirements. You are also responsible for maintaining a valid email address on file with us and ensuring we can successfully deliver communications to you.

8.5 Your Responsibility to Maintain Current Contact Information: You must provide us with, and continue to maintain with us:

a) A valid email address at which you can receive emails; b) A valid mobile phone number (if you wish to receive SMS notifications); and c) Accurate contact information.

You must notify us promptly if your email address, phone number, or other contact information changes. You can update your contact information through the LemFi App or by contacting customer support using the methods in Section 1.7.

If we cannot reach you at your email address or other contact information on file, and we have made reasonable efforts to contact you, we may suspend or close your Wallet in accordance with Section 13.

8.6 How to Withdraw Your Consent? You have the right to withdraw your consent to receive Service Communications electronically at any time.

IMPORTANT: If you withdraw consent, you will not be able to use the Wallet Service, and we will close your Wallet in accordance with Section 13.

To withdraw your consent:

• Email us at support@lemfi.com with the subject line "Withdraw E-Sign Consent"
• Call us at +1 702 505 4976
• Use the customer support function in the LemFi App

Your withdrawal of consent will constitute notice of termination of these Terms and will result in closure of your Wallet. Before your Wallet is closed, we will return any remaining balance to you in accordance with Section 13.

IMPORTANT: Withdrawing your consent to electronic communications will preclude any future use of the Wallet Service.

8.7 How Do You Update Your Contact Information? You can update your email address, phone number, and other contact information at any time by:

a) Logging into the LemFi App and updating your profile; or b) Contacting customer support using the methods in Section 1.7.

It is your sole responsibility to ensure that we have current and accurate contact information for you at all times. We are not responsible for any consequences (including missed communications, account restrictions, or account closure) that result from your failure to maintain current contact information.

8.8 Federal Law Compliance: This Section 8 satisfies the consent requirements of the Electronic Signatures in Global and National Commerce Act (E-SIGN Act), 15 U.S.C. § 7001 et seq. By accepting these Terms, you acknowledge and agree that:

a) You have read and understand this Section 8; b) You consent to receive all Service Communications electronically; c) You are able to access and retain electronic records; d) You meet the hardware and software requirements described in Section 8.4; e) You understand your right to receive paper copies and your right to withdraw consent; and f) You understand that withdrawal of consent will result in termination of the Wallet Service.

8.9 Confirming Your Ability to Access: Before you provide your consent to receive Service Communications electronically, we recommend that you:

a) Verify that you can access and read documents in the LemFi App; b) Verify that you can receive email at the address you have provided; c) Download and save a copy of these Terms for your records; and d) Test that you can view your transaction history in the App.

If you experience any difficulty accessing Service Communications, please contact customer support immediately using the methods in Section 1.7 (How to Contact LemFi).

8.10 Changes to Requirements: If we make material changes to the hardware or software requirements for accessing Service Communications, we will notify you and provide you with information about the new requirements. If the new requirements create a material risk that you will not be able to access or retain electronic communications, you will have the right to withdraw your consent without penalty before the effective date of the change.

8.11 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 App for the previous two years to the current date or the date of your last transaction undertaken through the LemFi App. Additionally, standard, widely available Internet browser software is required to access the disclosures from a personal mobile phone. You must be able to access the Internet to access our website.

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

You can also download your current transactions statement, and the transaction statements for the previous two years to the current date, from the Wallet Information section on the LemFi App.

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

9. Eligibility, Onboarding, and Ongoing Verification and Monitoring

Who can open a Wallet? You can open a Wallet if you are: a) at least 18 years old, and; b) a resident of the United States of America with a valid government-issued photo identification.

The Service is available only to natural persons using the Wallet for personal purposes. You may not use the Wallet or the Service as a business or professional money transfer service or as an intermediary on behalf of other persons or entities.

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 you a Wallet 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 US 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 Wallet 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.

When LemFi US May Request Re-Verification of Information: LemFi US (Pomelo Two US LLC) may ask you to confirm or update your details at any time, such as when you reach certain activity thresholds, use new features, change personal information, or during routine compliance reviews. These checks help us comply with U.S. Know Your Customer (KYC), Anti-Money-Laundering (AML), and sanctions-screening requirements.

What happens if you don't provide the requested information? If you fail to provide, verify, or update information when requested, LemFi US or the Partner Bank issuing your custodial account may suspend or restrict activity in your Wallet until verification is complete, or may close your Wallet as required by Applicable Law.

How does LemFi US monitor transactions? LemFi US, in collaboration with its Partner Banks, monitors Wallet activity to detect suspicious or prohibited transactions and ensure compliance with Applicable Law. Certain payments may be delayed, blocked, or reported to regulators if they appear to involve fraud, money-laundering, sanctions-related concerns, or other unlawful behavior.

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 Wallet or 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 your Wallet; b) provide LemFi with such information and materials as LemFi may reasonably require in order to provide you the Services and ensure that such information is true and accurate; c) regularly log on to your account to review your Wallet activity as well as any communication that may be added to your 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 Wallet; and f) apply all reasonable efforts to maintain security of your Wallet.

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 Services via 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 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 a Wallet for you to store money in; c) make LemFi's customer service team available to you; and d) allow you to use your account to send and receive legitimate and authorised payments.

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 our Partner Banks 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 our Partner Banks 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 the Partner Banks 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 Wallet via the 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) your instruction would cause your Wallet balance to become negative.

When LemFi May Refuse a Payment: We reserve the right to restrict the amount of money you may send or receive through your Wallet at our sole discretion. For example, we will stop you if you try to make a withdrawal exceeding the limit we may impose in relation to your account.

We may refuse to carry out any Wallet transaction if: a) we reasonably believe that you or someone else is using the Wallet 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 funds in the Wallet; 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; k) there are insufficient cleared funds in your Wallet to cover the amount of the payment; m) there are technical issues which prevent us from executing a Transaction; 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 LemFi US and our Partner Banks reserve the right to decline receipt of any payments coming into your Wallet where required by Applicable Law or to protect the integrity of the Service.

Will LemFi tell you why a payment was refused? We will tell you if we do not accept or complete a payment for you and the reason why unless we are prohibited for legal, regulatory or security reasons.

12. Payments and Withdrawals

What types of payments can you receive into your Wallet? 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 Wallet.

When will money appear in your Wallet? When we have received an electronic payment the money will be credited to your Wallet 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 Wallet? All withdrawals must be authorised by you. You can make a withdrawal by initiating a transfer to your linked U.S. bank account or other designated accounts.

We may restrict the amount you may withdraw at any given time and the frequency of your withdrawals at our discretion, as permitted by Applicable Law. You may also 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.

Further discussion of the withdrawal methods are detailed in Section 24 below.

Is there a minimum withdrawal amount? Withdrawal values must not be less than the equivalent of $1 unless you wish to close your Wallet.

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

13. Wallet Closure

How do you close your Wallet? If you wish to close your 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 1.7 above.

When can LemFi US close your Wallet? In addition to your cancellation rights, LemFi US and our Partner Banks shall be entitled to close your Wallet immediately for the following reasons: a) you breach these Terms; b) we reasonably suspect fraud, money-laundering, sanctions violations, or other illegal activity; c) if you have not given us any documents, we need to meet our regulatory or legal responsibilities, such as satisfactory evidence or documentation for us to complete our anti money laundering verification process; d) if we believe, acting reasonably that any information or declaration you have given to us when opening a Wallet 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; e) if you have behaved abusively, offensively or violently towards our staff. Or you use abusive or offensive language in instructions you give us; 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 Wallet is closed? Upon closure, LemFi US will return any remaining funds to your linked U.S. bank account (or other account you designate, if permitted) unless prevented by law.

You remain responsible for any outstanding obligations or liabilities under these Terms at the time of closure. We may retain the money in your Wallet 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 Wallet.

LemFi US may retain information and records relating to your Wallet for as long as required under Applicable Law.

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.

LemFi US (Pomelo Two US LLC) 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.

For details on consumer liability for unauthorized transactions and error resolution procedures, please refer to Section 24.

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 Wallet.

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 Account.

14.2 Force Majeure (Events Beyond Our Control): LemFi US 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 are detailed in Sections 24 and 26 below.

How do you make a complaint? If you wish to make a complaint in relation to your Wallet, please contact us using the methods set out in Section 1.7 above.

Specific complaint escalation procedures are detailed in Section 26 below.

16. Tax and Reporting

16.1 Tax Reporting Obligations: To follow the law, we may need to share information about you and your Wallet 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 are detailed in Section 24 below.

16.2 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

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

17.2 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 Wallet 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 US 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 Wallet. 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 US is entitled to rely on the last email address you have provided, and an email sent to that email address by LemFi US 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.

19.2 Your Responsibility to Maintain Contact Information: We will provide you with information about your Wallet within your LemFi App and this information will be updated each time you make a transaction.

As your Wallet 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 Account until measures have been taken to verify your identity.

21. Complaints

If you wish to make a complaint in relation to your Account, please contact us using the methods set out in Section 1.7 above.

Specific complaint procedures are detailed in Section 26 below.

22. Data Protection and Privacy

22.1 Data Processing and Privacy Notices: We will obtain, process, store and use your personal data in accordance with and subject to Applicable Law.

Privacy Notice(s): Please read the Privacy Notice applicable to your region to understand how we process your personal data and your rights.

https://lemfi.com/en-gb/privacy#additional-information-for-united-states-of-america-residents

https://gibank.com/privacypolicy/

22.2 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.

22.3 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 Account to relevant regulatory authorities, government bodies, law enforcement, and other authorized parties as required by Applicable Law.

Further specific disclosures are detailed in Section 24 below.

23. Miscellaneous

23.1 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.

23.2 Entire Agreement: This Agreement constitutes the entire agreement between you and us regarding your Wallet. 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.

23.3 Amendments to Terms: Changes to these Terms are governed by Section 1.8.

23.4 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

24.1 General Wallet Services: Your Wallet includes Wallet Services that allow you to store electronic money, fund your account through approved Payment Instruments, make payments, and use remittance services. Your Wallet is not a bank account, does not earn interest, and funds are safeguarded as set out below.

For prohibited uses of the Wallet, see Section 24.4 below.

24.2 U.S. Wallet Service

Overview: The Service allows you to store funds in U.S. dollars in your Wallet. Your Wallet is an electronic money account provided by LemFi US in partnership with one or more FDIC-insured Partner Banks.

Banking Partnership: LemFi US partners with Partner Banks, which are FDIC-insured depository institutions, to hold the funds that back your Wallet. The current list of Partner Banks can be found here.

The funds you add to your LemFi Wallet are held by Partner Banks in segregated safeguarding accounts, separate from LemFi's operational funds.

For complete details on how your funds are protected through safeguarding and information about FDIC insurance, see Section 6 (Safeguarding of Funds and FDIC Insurance).

Federal Identity Verification and Know-Your-Customer Requirements: For comprehensive details regarding eligibility and our Know-Your-Customer (KYC) requirements, please refer to Section 9.

IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A WALLET

TO HELP THE GOVERNMENT FIGHT THE FUNDING OF TERRORISM AND MONEY LAUNDERING ACTIVITIES, FEDERAL LAW REQUIRES ALL FINANCIAL INSTITUTIONS TO OBTAIN, VERIFY, AND RECORD INFORMATION THAT IDENTIFIES EACH PERSON WHO OPENS AN ACCOUNT.

WHAT THIS MEANS FOR YOU: WHEN YOU OPEN A WALLET, WE WILL ASK FOR YOUR NAME, ADDRESS, DATE OF BIRTH, AND OTHER INFORMATION THAT WILL ALLOW US TO IDENTIFY YOU. WE MAY ALSO ASK TO SEE A COPY OF YOUR DRIVER'S LICENSE OR OTHER IDENTIFYING DOCUMENTS.

Identity Verification Process: To comply with U.S. federal law (including the USA PATRIOT Act and Bank Secrecy Act) and help fight the funding of terrorism and money laundering, we must obtain, verify, and record information that identifies each person who opens a U.S. Wallet.

Required Verification Information: When you apply to open a U.S. Wallet, we will collect the following information ("KYC Information"):

a) Your full legal name; b) Your physical residential address in the United States (P.O. boxes not accepted for identity verification purposes); c) An unexpired U.S. government-issued photo identification document (such as a U.S. passport, state driver's license, or state-issued ID card); d) Your U.S. Taxpayer Identification Number (Social Security Number, Individual Taxpayer Identification Number, or Employer Identification Number); e) Your date of birth; f) Your telephone number; g) Your email address; and h) Any other information we reasonably require to verify your identity and comply with applicable U.S. law.

Will LemFi or our Partner Banks Perform Ongoing Verification? We or our Partner Banks may periodically contact you to re-verify your KYC Information or request additional documentation or information. You agree to respond promptly to any such requests. Failure to provide requested information may result in limitations on your Wallet or closure of your Wallet.

Your Responsibility Regarding Data Accuracy and Updates: You represent and warrant that all KYC Information you provide is complete, accurate, and not misleading. You agree to promptly notify us of any changes to your KYC Information by updating your profile in the LemFi App or contacting customer support at the contact information provided in Section 1.7. Failure to maintain accurate information may result in restrictions or closure of your Wallet.

Identity Verification Decisions: We and our Partner Banks reserve the right to accept or reject any Wallet application in our sole discretion based on the results of our identity verification process. If we cannot verify your identity to our satisfaction or our Partner Banks' satisfaction, we may decline to open a Wallet for you or may close an existing Wallet.

Retention of Information: We will retain your KYC Information and identity verification documentation for as long as required by the USA PATRIOT Act, Bank Secrecy Act, and other applicable U.S. anti-money laundering and counter-terrorism financing regulations.

Adding Money to Your Wallet: You can add money to your Wallet: (a) by linking a debit card; (b) by sending money from your personal bank account via ACH transfer using the routing and account number linked to your Wallet; (c) by sending money from your personal bank account using the account details provided in the app (as applicable); (d) receiving money from your friends or family for personal purposes.

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

Payment Execution Timelines for Wallets

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

Payments out of your Wallet 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 LemFi US, or our Partner Banks, 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: You are specifically prohibited from using your 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 our the Partner Bank holding the account backing your Wallet 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: You are prohibited from holding multiple Wallets. You may register only once for a Wallet. If we detect you hold multiple Wallets, we reserve the right to merge or terminate the Wallets without notification to you.

No Overdrafts Permitted: You are not permitted to overdraw your Wallet. If the available balance in your Wallet is insufficient to cover any payment or withdrawal you have authorized, the payment or withdrawal you have requested will be declined.

If your Wallet balance becomes negative for any reason, including but not limited to fees charged to your Wallet, you must load funds immediately to cover the negative balance. Any load we receive to your Wallet will first be applied to any negative balance in your 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 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 App for the previous two years to the current date or the date of your last transaction undertaken through the LemFi App.

Statements and transaction history for your Wallet are made available to you through the LemFi App. We will provide periodic statements at least monthly for any month in which an electronic fund transfer has occurred in 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 statement information at any time, for a period of up to two years from the current date or your last transaction. We will not mail paper statements unless required by law or requested by you.

Consumer Liability for Unauthorized Transfers

IMPORTANT - READ CAREFULLY

Tell us AT ONCE if your phone, password, or other means of accessing your 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 Wallet.

Access Device for Your 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 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 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 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: If we do not complete a transfer to or from your 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 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 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 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:

a) Tell us your name and Wallet unique customer identification number. 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. c) 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 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 Wallets, we may take up to 20 business days to credit your 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 WALLET MUST BE DIRECTED TO US (LEMFI/POMELO TWO US LLC), AND NOT TO ANY OF OUR PARTNER BANKS OR ANY OTHER FINANCIAL INSTITUTION WHERE YOU HAVE YOUR ACCOUNT.

We are responsible for the Wallet service and for resolving any errors in transactions made with your Wallet.

Confidentiality and Disclosure: We will disclose information to third parties about your account or the fund transfers you make: a) Where it is necessary for completing transfers, or b) In order to verify the existence and condition of your Wallet for a third party, such as payment partner or merchant, or c) In order to comply with government agency or court orders, or d) If you give us your written permission.

United States IRS Tax Reporting: To comply with US tax laws, we may need to share information about you and your 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 Account Subscribers Using U.S. Services: Please read the following privacy policies:

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

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 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; and 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 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 Account or any Services.

Intellectual Property: You acknowledge that the Service, including but not limited to the content of the LemFi 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 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 our Partner Banks are authorized at any time to set-off the funds deposited with us against your debts or liabilities owed to us. LemFi and our Partner Banks may exercise this right of set-off without notice to you unless required by applicable law.

No Commercial Use: Your Account may not be used for commercial purposes. You agree that any commercial use of your Account is in violation of this Agreement and is undertaken at your own risk. If LemFi discovers you are using your Account for such impermissible purposes, LemFi and our Partner Banks 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 Wallet is only for yourself, and 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

25.1 Overview: Remittance Services allow you to send money from your 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. All activities prohibited in connection with your Wallet, including Remittance Services, are detailed in Section 24.

25.2 How The Remittance Services Work: Our Partner Banks provides banking services for your remittance transactions. The funds underlying your remittance transactions are held by FDIC member and insured depository institutions in segregated safeguarding accounts. The list of Partner Banks is subject to change from time to time and can be found upon request.

Safeguarding of Remittance Funds: IMPORTANT: Funds in your Wallet are electronic money and are NOT insured by the Federal Deposit Insurance Corporation (FDIC). For full details on safeguarding and FDIC insurance, please refer to Section 6 (Safeguarding of Wallet Funds).

The funds underlying your remittance transactions are held by one of our Partner 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 our Partner 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 Wallet to select countries. The current list of supported countries is available in the LemFi App and on our website at https://lemfi.com/en-us.

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

How to Use Remittance Services: You may access your Wallet by logging into your LemFi 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 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 Wallet and transferred to the beneficiary account you provide.

Currency Conversion for Remittances: When you send money to a beneficiary whose account is in a different 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 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 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 submit it via the Wallet. You may cancel a transaction as described below, but after the cancellation window expires, the payment order may not be withdrawn or revoked.

Right to Cancel: (i) 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. (ii) 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 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 our Partner Banks may, in its sole discretion, 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 and 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 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 Wallets, we may take up to 90 days to investigate your complaint or question. For new 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: 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

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 US's direction and subject to LemFi US's 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 1.7. 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 Wallet except as provided by the applicable laws.

Upon termination, LemFi US will retain records of your transaction history in accordance with regulatory requirements and LemFi US 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 1.7 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 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 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 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 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 LemFi 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:

(A) 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

(B) 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.