Startale App Terms of Service

Last revised: 2026/10/23

1. INTRODUCTION

Startale Labs (BVI) Ltd (the “Company”, “we,” “us,” or “our”) makes available to users the Startale App, which is a software application that enables users to interact with certain onchain applications and protocols. These Terms of Service (“Terms”) constitute a legally binding contract made between you (“you” or “your”) and the Company that governs your access or use, and/or attempted access or use, of the Startale App and the software services therein (together, the “Services”).

There are risks associated with the Services that the Company cannot anticipate, and these risks may adversely affect the business, operations, development, uses, features, of the Services. By accessing the Services, you expressly acknowledge, agree and assume such risks.

These Terms form an agreement and define the contractual relationship between you and the Company. Please read the Terms carefully. The Company reserves the right to amend the Terms at any time by posting the revised Terms on the Startale App. Unless otherwise stated in the Terms, the revised Terms shall be effective as indicated by the “Last revised” date indicated at the beginning of the Terms. Users are responsible for keeping themselves informed of the current Terms. Your continued use of the Services will be regarded as acceptance and acknowledgement of any amendments or modifications made to the Terms from time to time, whether or not reviewed by you. If you do not accept the revised Terms, you should not use the Services. Without limiting anything set forth elsewhere in the Terms, we shall not be liable to you or any third party for any losses suffered by any revisions to the Terms.

The “Terms” include the terms and conditions set out below and our different policies and guidelines found on the Startale App. Such policies and guidelines, which are incorporated in these terms and conditions by reference, include but are not limited to, the Privacy Policy. Your access or use, and/or attempted access or use, of certain Services, may be subject to additional terms (“Supplemental Terms”), and such Supplemental Terms will either be listed in these Terms of Service or will be presented to you for your acceptance when you access or use, and/or attempted access or use, the Service.

By accessing or using, and/or attempting to access or use the Services, you acknowledge that you have read, understood, and agreed to be bound by these Terms. If you do not accept these Terms, you are not permitted to and should not access or use, and/or attempt to access or use, any of the Services.

For the avoidance of doubt, the Company does not hold itself out as carrying on any regulated virtual asset service or investment business in or from within the British Virgin Islands or elsewhere and the Services do not constitute any form of regulated service.

PLEASE READ THESE TERMS CAREFULLY, AS THEY CONTAIN AN ARBITRATION AGREEMENT AND OTHER IMPORTANT INFORMATION REGARDING YOUR LEGAL RIGHTS, REMEDIES, AND OBLIGATIONS. THE ARBITRATION AGREEMENT REQUIRES THAT YOU SUBMIT ANY CLAIMS YOU HAVE AGAINST US TO BINDING AND FINAL ARBITRATION, AND FURTHER (1) YOU WILL ONLY BE PERMITTED TO PURSUE CLAIMS AGAINST THE COMPANY ON AN INDIVIDUAL BASIS, NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS OR REPRESENTATIVE ACTION OR PROCEEDING, (2) YOU WILL ONLY BE PERMITTED TO SEEK RELIEF (INCLUDING MONETARY, INJUNCTIVE, AND DECLARATORY RELIEF) ON AN INDIVIDUAL BASIS, AND (3) YOU MAY NOT BE ABLE TO HAVE ANY CLAIMS YOU HAVE AGAINST US RESOLVED BY A JURY OR IN A COURT OF LAW.

2. WALLETS

In order to access or use the Services, you may (1) create a self-custodial digital wallet (also known as “Startale Wallet” as described in Section 2.1 below) by creating an account using the compatible third-party social log-in credentials; or (2) connect a compatible cryptocurrency third-party wallet software.

In respect of the use of Startale Card (as defined in Section 3.6 below), you may also be required to sign smart contracts to create additional self-custodial digital wallet under the Startale App that is linked to the Startale Card (“Startale Card Linked Wallet”).

2.1 Startale Wallet

When you agree to log in or create an account on Startale App, you agree to generate one or more self-custodial digital wallets (“Startale Wallet”) which is enabled and provided by third-party service provider(s) (“Startale Wallet Providers”). You acknowledge that Startale shall have sole discretion to select, replace and/or remove any Startale Wallet Provider at any time from time to time without notification to you. By applying for an account on the Startale App and agreeing to generate the Startale Wallet, you acknowledge that you will access the Services utilising your designated third-party social log-in credentials. After initiating the creation of an account on Startale App using your designated third-party social log-in credentials, you will be redirected to third-party webpages (such as Google account) and/or the Startale Wallet Providers for authentication purposes. The Startale Wallet is linked to the third-party social log-in credentials that you use for creating an account on Startale App.

The Startale Wallet is governed by terms of service and privacy policies of the various third party service providers, including email providers and the Startale Wallet Providers. Information collected through any third party service provider (including Startale Wallet Providers) is subject to the privacy policy of such third party service provider. While we do not collect or store such information (such as your email information) provided to the third party service providers (including Startale Wallet Providers), we may obtain authenticated account information associated with your account such as email information from the Startale Wallet Providers. You should cease creating any Startale Wallet if you are not agreeable to the terms of the various third party service providers.

The Startale Wallet is a self-custodial cryptocurrency wallet that allows you to store your digital assets and undertake a variety of on-chain features available on Startale App, including to connect and use Third Party Content available on Startale App, Third Party Content supporting connection with Startale App, and send transactions across digital asset networks. Your Wallet is under your exclusive control. Neither the Company nor any Startale Wallet Provider stores, holds, or can recover your private keys, seed phrase, or password. Any linkage to third-party social login credentials is solely an authentication layer and does not confer custody or control of your Wallet or assets to the Company or Startale Wallet Providers

We do not develop, operate, control, own, maintain, or manage your Startale Wallet, and will not be responsible for any risks or activities associated with your Startale Wallet. You acknowledge that you may be unable to access your Startale Wallet, or the contents or assets in your Startale Wallet, if you lose the private keys, password or seed phrase associated with your Startale Wallet. Your access and use of your Startale Wallet is at your own risk and responsibility.

2.2 Other compatible wallets.

You may also connect a compatible third-party cryptocurrency wallet software (“Other Wallets”) to access or use the Services. When you connect any Other Wallet, you agree to the automatic generation of a Startale Wallet. Please refer to Section 2.1 above for further details on the Startale Wallet.

2.3 Startale Card Linked Wallet

When you agree to create a Startale Card, you agree to generate the Starale Card Linked Wallet accessible under Startale App. The self-custodial wallet is enabled and provided by Startale Wallet Providers. You acknowledge that Startale shall have sole discretion to select, replace and/or remove any Startale Wallet Provider for the Startale Card Linked Wallet at any time from time to time without notification to you. By applying for a Startale Card and agreeing to generate the Startale Card Linked Wallet, you acknowledge that the Startale Card Linked Wallet will be accessible by way of your Startale Wallet which in turn is accessible by way of your designated third-party social log-in credentials.

The Startale Card Linked Wallet is governed by terms of service and privacy policies of the various third party service providers. You acknowledge that the Startale Wallet Provider for the Startale Wallet and the Startale Card Linked Wallet may not be identical. Information collected through any third party service provider (including Startale Wallet Providers) is subject to the privacy policy of such third party service provider. While we do not collect or store such information (such as your email information) provided to the third party service providers (including Startale Wallet Providers), we may obtain authenticated account information associated with your account such as email information from the Startale Wallet Providers. You should cease creating or using a Startale Card if you are not agreeable to the terms of the various third party service providers.

The Startale Card Linked Wallet is a self-custodial cryptocurrency wallet that you designate for use with the Startale Card. The Startale Card Linked Wallet is not used for any other purposes other than the Startale Card. You will be required to designate a target asset balance under your Startale Card Linked Wallet. The Startale Card Linked Wallet is linked to your Startale Wallet, so that you can implement an automatic rebalance of your Startale Card Linked Wallet from assets in your Startale Wallet to satisfy your preset target balance. When signing the smart contract for creation of your Startale Card Linked Wallet, you also agree to implement automatic payment using assets in your Startale Card Linked Wallet for the costs, fees and expenses that you incur under the Startale Card.

Your Startale Card Linked Wallet is under your exclusive control. Neither the Company nor any Startale Wallet Provider stores, holds, or can recover your private keys, seed phrase, or password. Any linkage to third-party social login credentials or the Startale Card is solely an authentication layer and does not confer custody or control of your Wallet or assets to the Company or Startale Wallet Providers

We do not develop, operate, control, own, maintain, or manage your Startale Card Linked Wallet, and will not be responsible for any risks or activities associated with your Startale Card Linked Wallet. You acknowledge that you may be unable to access your Startale Card Linked Wallet, or the contents or assets in your Startale Card Linked Wallet, if you lose the private keys, password or seed phrase associated with your Startale Wallet. Your access and use of Startale Card and Startale Card Linked Wallet is at your own risk and responsibility.

2.4 Wallet Disclaimer

The Company does not have knowledge of or access to the private keys, seed phrase, or password associated with your Startale Wallets, Startale Card Linked Wallet or Other Wallets (together, the “Wallets”). We are not custodians of your Wallets or any assets therein. For the avoidance of doubt, the Company does not have control or custody over the assets in your Wallets at any time. Your relationship with any Wallet service provider is governed by the applicable terms with the provider of the Wallet, not these Terms. You are responsible for safeguarding the private key associated with your Wallets and any activity relating to your Wallet. We make no representations, warranty or undertaking on how the Services will function with your Wallet. You are responsible for all activities of any person who accesses your Wallet.

3. SERVICES

3.1 Startale App

The Startale App provides you with access to (1) certain services offered by the Company and/or its affiliates (“Startale Group”); and (2) certain applications, smart contracts, products or services offered, maintained or operated by third parties (“Third Party Content”), including:

1. Swap. User interface offered by Startale Group that enables the user to access and undertake swap transactions on third-party decentralized exchanges.

2. Earn. User interface offered by Startale Group that enables the user to access and undertake transactions offering yield-generating services.

3. Bridge. Service that enabling the user to bridge digital assets from one blockchain network to another compatible blockchain network each on the same digital wallet address.

4. STAR Points. Scoring system operated by the Company to award STAR Points to users based on their activity within the Startale App ecosystem.

5. Startale Card Programs. Service that enables the user to access a card program under which a card issuer issues a Startale Card (as defined in Section 3.6 below) that allows the user to make fiat payments funded by stablecoin balances held in the user’s Startale Card Linked Wallet (as defined in Section 3.6 below), which may be accessed through the Startale App.

Startale App is a software interface that enables the User to view information and interact with third-party protocols and applications using the User’s own self-custodial wallets. The Company does not provide, and does not hold itself out as providing, any “virtual assets service” as defined under the Virgin Islands Virtual Assets Service Providers Act, 2022, nor any exchange, transfer, safekeeping, or administration of virtual assets for or on behalf of another person. The Company does not conduct any activity that constitutes investment business under the Virgin Islands Securities and Investment Business Act, 2010, including dealing, arranging deals, managing investments, providing custodian services with respect to investments, or operating an investment exchange.

3.2 Swap

The Startale App provides a native interface that allows you to execute swap transactions via decentralized exchanges. When you submit a request for a swap transaction, the interface provided by Startale App searches for available swap quotes on various decentralized exchanges. You will be presented with the swap quotes retrieved by the Startale App, together with the applicable fees and charges. When you undertake a swap transaction via the native interface of Startale App, you are submitting a transaction request to the third-party decentralized exchanges. You acknowledge and agree that you are neither engaging in a transaction with the Company nor transferring any digital assets to Startale Group when you use the Startale App to undertake swap transactions. The Startale Group does not provide any services and is not acting as a counterparty, intermediary, or custodian with respect to any swap transaction undertaken via the Startale App. The Startale Group has no control over your swap transaction and does not settle any swap transactions. Although you are submitting the swap transaction via Startale App, the execution of the swaps is undertaken directly between you and the third party decentralized exchanges. By submitting a swap request via Startale App, you are interacting directly with the smart contracts of the relevant third-party decentralized exchange from your Wallet. The Company does not intermediate, match, broker, settle, or otherwise execute transactions, and does not come into custody, control, power, or possession of any money or virtual assets at any time.

Furthermore, your use of any third-party decentralized exchanges through the Startale App is subject to the terms and conditions of the decentralized exchanges. You are solely responsible for reviewing, understanding, and complying with any such terms, and the Company shall have no liability or responsibility in connection therewith.

3.3 Earn

The Startale App provides a native interface that allows you access to yield-generating services (“Earn Feature”) for digital assets provided by affiliates of the Company or third-party service providers. The Startale App solely facilitates access to the Earn Feature by providing a user interface. The Company does not itself offer, endorse, warrant, guarantee, or otherwise make any representation as to the suitability, reliability, legality, or performance of the Earn Feature.

You expressly acknowledge and agree that, by engaging with such functionality via the Startale App, you are authorising and undertaking a transfer of your digital assets from the connected Wallet to the service provider of the relevant Earn Feature, which may include Third Party Content.

Your access and/or use of any Third Party Content shall be subject to the applicable terms, conditions, and functionalities of the relevant Third Party Content and any associated smart contracts or protocols. You acknowledge that depending on the applicable terms, your digital assets may be locked, staked, or otherwise committed to the Third Party Content, and any redemption or withdrawal thereof may be subject to specific conditions, delays, or limitations. You understand and agree that in the event of any failure, vulnerability, exploit, security breach, hack, or other adverse incident affecting any Third Party Content, smart contract, or protocol, your digital assets may be compromised or rendered permanently inaccessible, resulting in partial or total loss.

The Company provides only a software interface to Third Party Content offering yield-related functionality. The Company does not arrange deals, provide investment advice, manage investments, provide custodian services with respect to investments, solicit, endorse, or market any particular yield product. Any yields, APYs, rewards, or terms are determined and provided solely by the relevant third-party or affiliate service provider, and your participation is governed exclusively by their terms and applicable smart contracts. You acknowledge that the Company has no discretion or control over the selection, deployment, locking, staking, redemption, or withdrawal of your assets and does not hold, safeguard, or administer your assets. Where an affiliate of the Company offers a product accessible via the Earn Feature, the Company’s role remains limited to providing access through the user interface. The Company does not act as agent or intermediary for any affiliate product and does not arrange or advise on such product. You must review and accept the affiliate’s terms separately.

3.4 Bridge

The Startale App provides a service that allows a user to bridge digital assets from one blockchain network to a different blockchain network by using a third-party bridge provider. The sending wallet address and the receiving wallet address in respect of the bridge are identical, albeit on different blockchain networks. The bridge feature is provided by a third-party service provider and the Company does not control or hold any administrative keys to the bridging contracts. The bridge feature is available for bridging of digital assets between Startale Wallets only.

3.5 STAR Points

The Company utilises a scoring system that awards STAR Points based on the user’s activity within the Startale App ecosystem. The scoring system may be used to determine a user’s eligibility and/or priority for campaigns undertaken within the Startale App ecosystem. The Company has the sole discretion to modify or impose additional restrictions on eligibility for these campaigns. In addition, the Company may also modify the award eligibility and calculation of STAR Points, at its sole discretion and from time to time. In the absence of manifest error, all calculations of the STAR Points by the Company in accordance with the stated methodology will be final and binding on the user.

STAR Points are in-app points that are non-transferable and cannot be returned or redeemed with the Startale Group in exchange for money. The STAR Points cannot be used outside Startale App. For the avoidance of doubt, STAR Points are not, and are not intended to constitute, capital markets products, securities or securities-based derivatives contracts of any form, units in a business trust, units in a collective investment scheme or any other form of investment in any jurisdiction.

3.6 Startale Card Programs

The Startale App provides access to a card program (“Startale Card Program”) under which one or more third-party issuers (“Third Party Card Issuer”) issue Startale-branded debit cards (“Startale Card”) on supported payment networks that allow you to make fiat payments funded by stablecoin balances held in your Startale Card Linked Wallet and accessible through the Startale App.

Although your Startale Card may enable you to use stablecoin balances held in your Startale Card Linked Wallet and accessible through the Startale App to fund your purchases, the Company is not the issuer of the Startale Card nor the manager of the Startale Card Program. The Startale Card Program and the Startale Card are provided, operated, and administered by the applicable Third Party Card Issuer and its service providers.

The Company is not responsible for any decisions by the Third Party Card Issuer to approve, decline, suspend or close your Startale Card account. The Company may, at the request of the Third Party Card Issuer, the payment network or a regulatory authority, suspend or restrict your access to Startale App or certain features, to protect against fraud, comply with applicable laws or manage risk of the Startale Card Program. The Company is not responsible for merchant acceptance of your Startale Card or for resolving disputes about goods or services purchased with the Startale Card. In the event a transaction is refunded, cancelled or reversed, any refunded amount (less any associated fees, charges and deductions) will be credited to your Startale Card Linked Wallet after the Company is notified that backend processing of the refund by the Third Party Card Issuer and other relevant parties have been completed. For the avoidance of doubt, the Company does not act as a custodian to any person in respect of the refund amount.

Your access to Startale Card is subject to certain Know-Your-Customer and Anti-Money Laundering verification procedures (“KYC / AML Procedures”) which will be notified to you during your registration and application for Startale Card. For the avoidance of doubt, any information collected from you during the KYC / AML Procedures is for and on behalf of the Third Party Card Issuer and its service providers, and you consent for us to transmit the information to them.

We reserve the right to introduce, amend, or modify, any additional fees separate from the fees payable by the Third Party Card Issuer. We will notify you of such additional fees, if any, before the additional fees become effective.

You agree to bear all fees and charges that you incur in respect of the Startale Card. Under the Startale Card Program, you will be required to create the Startale Card Linked Wallet and a smart contract as part of the payment backend process (“Hold Contract”). Details of the Startale Card Linked Wallet are set out in Section 2.3 above. The Hold Contract is a smart contract that implements and/or lifts temporary holds on assets in your Startale Card Linked Wallet as and when you incur expenses on the Startale Card pending settlement confirmation. The Hold Contract is intended to facilitate your adherence to the preset spending balance under the Startale Card Linked Wallet. The Company does not control and is not responsible for the operation, security, or performance of the smart contracts in respect of the Startale Card Linked Wallet, the Hold Contract or any other smart contracts used in the Startale Card Program.

You agree to defend, indemnify and hold harmless the Company, the Startale Group and their respective officers, employees, directors, service providers, licensors and agents from and against any and all claims, disputes, losses, damages, demands, costs and expenses, including any reasonable legal and professional fees, rights, claims, actions of any kind and injuries (including death), arising out of or in connection with the fees and charges that you incur in respect of the Startale Card.

You agree that we have the right to determine and set the spending limit for your Startale Card at our sole discretion. We reserve the right to modify your spending limit at any time, with or without prior notice, including by temporarily increasing or decreasing the limit or reducing the spending limit to US$0.

Your use of the Startale Card will be subject to additional terms and conditions, including but not limited to, terms and conditions of the Third Party Card Issuer, as well as any additional terms governing the Startale Card Program that may be made available to you from time to time.

3.7 Modification to Services

We reserve the right in our sole discretion to modify, upgrade, suspend, or discontinue, whether temporarily or permanently, any part of the Services (or any features or elements thereof) at any time and without liability. You agree that the Company will not be liable to you or to any third party for any modification, suspension or discontinuance of any part of the Services.

4. ELIGIBILITY

In accessing and/or using the Services, you represent and warrant that:

• you are at least 18 years of age and are of sound mind;

• you possess the legal authority to create a binding legal obligation

• you will use the Services in accordance with these Terms and all applicable laws and regulations;

• you will only use the Services for lawful purposes;

• you will not carry out fraudulent activity using our Services;

• you will only use the Services to make legitimate transactions for yourself

• you will not impair the Services and the network and software on which it runs in any way;

• you accept the Terms wholly and unconditionally;

• if and when applicable, you will satisfy all your obligations, tax, withholding or otherwise as required by your country of residence; and

• you will be responsible for any use of your account whether by you or anyone other than you.

You further agree not to use the Services or its contents or information for any commercial or non-personal purpose (direct or indirect) or for any purpose that is illegal, unlawful or prohibited by the Terms. You agree not to modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer, sell or re-sell any information, software, or the Services.

We reserve the right at our sole discretion to deny anyone access to the Services offered at any time without notice, and for any reason, including but not limited to, violation of these Terms. You acknowledge and agree that the Company shall not be liable for any damage or loss resulting from such actions (including but not limited to the failure or delay or effectiveness of the actions). You further agree not to take or attempt to take any measures to circumvent any such actions by us. Any successful access or use of the Service shall not be construed to be a waiver of any rights of the Company under these Terms nor be implied to be the user’s compliance with these Terms.

5. FEES

5.1 Startale Fees

The Company may charge you certain fees when you use any Service. Fees charged by the Company are technology/platform fees for the use of the Startale App’s interface and routing features. They are not commissions, spreads, or remuneration for the exchange, transfer, safekeeping, custody, administration, or settlement of virtual assets, regardless of the manner the technology/platform fees are determined. The Company will disclose to you fees that it charges to you before the fees are incurred by you. For example, platform fees are payable to the Company when you use the native interface in Startale App that searches for quotes and enables you to send instructions to undertake swap transactions on decentralized exchanges. The applicable platform fees will be disclosed to you before you confirm the swap transaction. You acknowledge that fees charged by the Company for any Service is subject to change from to time in the Company’s sole and absolute discretion.

5.2 Network Fees

When you undertake a blockchain transaction, you are required to pay network fees (often called gas fees) unless otherwise notified to you on the Startale App. You are responsible for paying these fees whenever you make a transaction on Startale App. These network fees are in addition to any fees charged by the Company, if any.

Before sending a transaction, you should ensure your Wallet has enough balance to cover the network fees and the compatible type of digital assets for payment of the network fees. The Company is not responsible or liable for any blockchain transaction that fails due to insufficient funds or lack of compatible type of digital assets in your Wallet.

5.3 Third Party Fees

You may incur charges from third parties for use of Third Party Content that you access via Startale App or your Startale Wallet, such as when you use the native interface on Startale App to send instructions to execute transactions on decentralized exchanges.

6. THIRD PARTY CONTENT

You may use the Services to access and engage with Third Party Content, such as decentralized exchanges, yield-generating services and other on-chain products and services. We do not own, control, verify, warrant or endorse any Third Party Content, including but not limited to the content, products, services or information available or accessible from those Third Party Content.

The inclusion of, or reference to, any Third Party Content is not, and shall not be implied or deemed, to be any approval, validation, recommendation or endorsement by us. We make no representation, warranties undertakings, covenants, guarantees, assurances with respect to any aspect of the Third Party Content, including but not limited to the safety, security, availability, accuracy, reliability, legality, suitability, performance, quality, design, code, continuity, or applicable terms. We do not assume any responsibility or liability for the Third Party Content whatsoever, including any damage or loss caused by your use or access or reliance of any Third Party Content. You acknowledge that we may be unable to provide the Services if there is any disruption, suspension, error or failure of any Third Party Content.

Your access and use of the Third Party Content may be subject to additional terms and conditions, privacy policies or other agreements with such third parties. You should conduct your own independent due diligence and investigations on the Third Party Content. You acknowledge that you use or access the Third Party Content at your sole risk notwithstanding that you are using or accessing the Third Party Content via the Services. You are solely liable for any fees, costs, expenses, losses and damages in respect of the use or access of the Third Party Content. In no event will the Company or the Startale Group be responsible or liable to you or any other person or entity under any circumstances for any fees, costs, expenses, losses or damages arising out of or in connection with any Third Party Content regardless of you using or accessing such Third Party Content via the Services.

7. YOUR RESPONSIBILITIES

Between you and us, you will be solely responsible for your use of the Service and Third Party Content.

The Company may display, publish, or otherwise make available certain information, data, metrics, estimates, analytics, yields, annual percentage yields (APYs), rewards, rates, historical performance data, protocol information, token information, risk disclaimers, transaction history, or other materials relating to the Service and/or any Third Party Content (collectively, “Platform Information”), including but not limited to the Earn Feature and Startale Card. Such Platform Information may be obtained from, provided by, or derived from providers of the Third Party Content, third-party service providers, blockchain networks, smart contracts, publicly available sources, or other third parties. The Company does not independently verify, audit, monitor, or validate any Platform Information and makes no representation, warranty, undertaking, guarantee, or assurance, whether express or implied, as to the accuracy, completeness, reliability, availability, timeliness, currency, suitability, or fitness for any purpose of any Platform Information. The Company has no obligation to update, correct, supplement, or continue to provide any Platform Information and any Platform Information may become inaccurate, incomplete, outdated, or unavailable at any time without notice.

Any Platform Information is provided solely for your convenience and reference and does not constitute, and shall not be construed as, financial, investment, legal, tax, accounting, or other professional advice, recommendation, endorsement, solicitation, or representation. You should refrain from taking any action based on such information. You acknowledge and agree that you shall not rely upon any Platform Information in making any decision to access, use, or participate in any Third Party Content. You are solely responsible for conducting your own independent research, due diligence, and assessment of any Third Party Content.

Your decision to access or use the Service or Third Party Content shall be made entirely based on your own knowledge and judgment. Before you make any financial, legal, tax or other decisions involving the Service or Third Party Content, you should seek independent professional advice as appropriate.

You are responsible for maintaining the confidentiality of your credentials and are fully responsible for all activities that occur under your credentials.

8. PROHIBITED ACTIVITIES

When using the Services or any Third Party Content, you undertake not to perform or attempt to perform any of the following actions, either on your own or in cooperation with a third party (collectively, the “Prohibited Activities”):

1. Infringe the Startale Group’s or a third party’s rights, including intellectual property rights, trade secrets, publicity rights)

2. Violate any applicable laws and regulations;

3. Violate any applicable anti-money laundering laws, anti-terrorism laws, export control laws, end user restrictions, or economic sanctions laws/regulations, including but not limited to those administered or promulgated by the United Nations Security Council, the British Virgin Islands, Singapore, Japan, the United Kingdom, the United States (including U.S. Department of Treasury’s Office of Foreign Assets Control);

4. Conceal your location through IP proxying or other methods;

5. Engage in any act that hinders, damages, disables, overburdens, impairs, or otherwise interferes with the use of the Services (including sending false information or spam, and obstructing the communications of other users);

6. Use the Services for purposes that diverge from the intended usage of the Services;

7. Impersonate another person or entity or falsely state or otherwise misrepresent your affiliation with a person or entity, or adopt a false identity if the purpose of doing so is to mislead, deceive, or defraud another;

8. Attempt to gain unauthorised access to the Services, other accounts, computer systems, or networks connected to the Services, through hacking, password mining or any other means;

9. "frame", "mirror" or otherwise incorporate any part of the Services into any other applications without our prior written consent

10. Re-sell, use, copy, monitor, display, download or reproduce any content or information, software, products or services available on Startale App for any commercial or competitive activity or purpose;

11. Download, distribute, make available for public transmission, alter, operate, reverse engineer, decompile, disassemble, delete or perform similar actions to all or part of the Services beyond a scope expressly authorised by the Company (including actions that invalidate or circumvent functions such as content protection and access control, as well as intentional exploitation of any defects within the Services);

12. Use the Services in a way that is dangerous, harmful, fraudulent, misleading, deceptive, threatening, harassing, defamatory, obscene, or otherwise objectionable;

13. Violate, compromise, or interfere with the security, integrity, or availability of any computer, network, or technology associated with the Service, including using the Service in a manner that constitutes excessive or abusive usage, attempts to disrupt, attack, or interfere with other users, or otherwise impacts the stability of the Service;

14. Violate any other provisions of these Terms; and

15. Aid, facilitate or abet any of the above.

The Company reserves the right to block your access to or use of, and/or attempted access to or use of, the Services and transactions using the Services, and take any other necessary measures, if the Company determines in its sole discretion that you have breached or may be in breach of your obligations under these Terms. The Company may also implement geo-blocking or access restrictions where necessary to comply with applicable sanctions, export controls, and other legal or regulatory requirements. You agree that the Company may deny or terminate access without liability where such restrictions apply.

9. INTELLECTUAL PROPERTY RIGHTS

9.1 Services

The Company grants you permission to use and access the Services and the Startale App subject always to the Terms. You acknowledge and agree that the Company retains ownership of all rights, title and interest, as well as any updates or modifications to the Services and the Startale App. This includes but is not limited to, the content, material, information, data, software, images, text, logos, illustrations, scripts, service marks, trademarks, logo, audio, video, music and the overall design and look. Notwithstanding the foregoing, the Company does not claim ownership rights over any Third Party Content.

9.2 Name and Logos

The name and logos, “Startale” and “Startale App”, and certain other logos and trademarks are trademarks and service marks of the Startale Group (collectively, the “Startale Group Trademarks”). Other company, product, and service names and logos used and displayed via the Services may be trademarks or service marks of their respective owners who may or may not endorse or be affiliated with or connected to Startale Group. You agree not to use any Startale Group Trademarks without our express prior written approval which we may withhold at our discretion for any reason. All goodwill generated from the use of the Startale Group Trademarks will inure to our exclusive benefit.

9.3 Feedback

If you provide us with any feedback or suggestions regarding the Services or Startale App (“Feedback”), you hereby unconditionally and irrevocably assign to the Company all rights to such Feedback and agree that the Company shall have the right to use and fully exploit such Feedback and related information in any manner it deems appropriate. The Company will treat any Feedback you provide us with as non-confidential and non-proprietary. You agree that you will not submit to us any Feedback or other information or ideas that you consider to be confidential or proprietary and that you do not have the required permission and consent to submit.

9.4 Usage Data

You hereby authorise the Company and its third-party service providers to derive statistical and usage data relating to your use of the Service (“Usage Data”). We may use the Usage Data for any purpose in accordance with applicable laws and our Privacy Policy.

10. INDEMNITY

You agree to defend, indemnify and hold harmless the Company, the Startale Group and their respective officers, employees, directors, service providers, licensors and agents from and against any and all claims, disputes, losses, damages, demands, costs and expenses, including any reasonable legal and professional fees, rights, claims, actions of any kind and injuries (including death), arising out of or in connection with (a) your access or use of the Services; (b) any Third Party Content; (c) your violation of these Terms; or (d) your breach of any laws or regulations.

11. DISCLAIMER

YOUR ACCESS OR USE OF THE SERVICES IS AT YOUR SOLE RISK. THE SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. THE COMPANY AND THE STARTALE GROUP EXPRESSLY DISCLAIM ALL REPRESENTATIONS AND WARRANTIES OF ANY KIND WITH RESPECT TO THE SERVICES AND THE PLATFORM INFORMATION, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

THE COMPANY AND THE STARTALE GROUP MAKES NO REPRESENTATION, WARRANTY, UNDERTAKING, GUARANTEE OR ASSURANCE (WHETHER EXPRESS OR IMPLIED) WITH RESPECT TO THE SERVICES AND THE PLATFORM INFORMATION, INCLUDING BUT NOT LIMITED THAT (A) THE SERVICES OR ANY THIRD PARTY CONTENT WILL MEET YOUR REQUIREMENTS; (B) THE SERVICES OR ANY THIRD PARTY CONTENT WILL BE UNINTERRUPTED, TIMELY, SECURE, ERROR-FREE, OR FREE OF VULNERABILITIES OR VIRUSES OR BUGS; (C) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SERVICES OR ANY THIRD PARTY CONTENT WILL BE ACCURATE OR RELIABLE; OR (D) THE SECURITY MEASURES OF THE SERVICES OR ANY THIRD PARTY CONTENT. THE SERVICES OR ANY THIRD PARTY CONTENT MAY CEASE TO OPERATE OR EXPERIENCE SYSTEM FAILURES OR UNPLANNED INTERRUPTIONS, WHETHER DUE TO DEFECTS, REGULATORY ACTIONS, ACTS OR OMISSIONS OF THIRD PARTY CONTENT, OR OTHERWISE.

BY ACCESSING AND USING THE SERVICES, YOU REPRESENT AND WARRANT THAT YOU UNDERSTAND THE INHERENT RISKS ASSOCIATED WITH USING CRYPTOGRAPHIC AND BLOCKCHAIN-BASED SYSTEMS, AND THAT YOU HAVE A WORKING KNOWLEDGE OF THE USAGE AND INTRICACIES OF DIGITAL ASSETS. YOU ACKNOWLEDGE AND ACCEPT THAT THE COST AND SPEED OF TRANSACTING WITH CRYPTOGRAPHIC AND BLOCKCHAIN-BASED SYSTEMS ARE VARIABLE AND MAY INCREASE DRAMATICALLY AT ANY TIME. YOU FURTHER ACKNOWLEDGE AND ACCEPT THE RISK THAT IT MAY TAKE TIME FOR THE SERVICES, THIRD PARTY CONTENT OR BLOCKCHAIN NETWORK (AS APPLICABLE) TO PROCESS YOUR INSTRUCTIONS OR TRANSACTION AND YOUR DIGITAL ASSETS MAY LOSE SOME OR ALL OF THEIR VALUE DUE TO THE FLUCTUATION OF PRICES OF DIGITAL ASSETS WHILE THEY ARE BEING PROCESSED BY THE SERVICES, THIRD PARTY CONTENT OR BLOCKCHAIN NETWORK. YOU FURTHER ACKNOWLEDGE THAT THE COMPANY AND STARTALE GROUP IS NOT RESPONSIBLE FOR ANY OF THESE VARIABLES OR RISKS AND CANNOT BE HELD LIABLE FOR ANY RESULTING LOSSES THAT YOU EXPERIENCE WHILE ACCESSING OR USING THE SERVICES OR ANY THIRD PARTY CONTENT. ACCORDINGLY, YOU UNDERSTAND AND AGREE TO ASSUME FULL RESPONSIBILITY FOR ALL OF THE RISKS OF ACCESSING AND USING THE SERVICE AND ANY THIRD PARTY CONTENT.

WE HAVE NO CONTROL OVER ANY UPGRADES TO ANY THIRD PARTY CONTENT. YOU ACKNOWLEDGE THAT UPGRADES MAY CAUSE OR INTRODUCE BUGS, VIRUSES, VULNERABILITIES, RISKS, INTERRUPTION TO THE OPERATION OF THE SERVICES AND/OR THE THIRD PARTY CONTENT, OR CAUSE YOU LOSS OR DAMAGE. YOU SHOULD CONDUCT YOUR OWN INDEPENDENT DUE DILIGENCE BEFORE USING THE SERVICES OR ANY THIRD PARTY CONTENT AT ALL TIMES. YOU ARE RESPONSIBLE FOR YOUR USE OF THE SERVICES OR ANY THIRD PARTY CONTENT REGARDLESS OF ANY UPGRADES.

DIGITAL ASSETS, BLOCKCHAIN TECHNOLOGY, AND ANY RELATED SOFTWARE AND SERVICES ARE ALSO SUBJECT TO LEGAL AND REGULATORY UNCERTAINTY IN ANY JURISDICTIONS. THERE MAY BE NO REGULATORY RECOURSE FOR ANY LOSS RESULTING FROM YOUR USE OF THE SERVICES. YOU ALSO UNDERSTAND THAT LEGISLATIVE AND REGULATORY CHANGES OR ACTIONS MAY ADVERSELY AFFECT THE USAGE, TRANSFERABILITY, TRANSACTABILITY AND ACCESSIBILITY OF DIGITAL ASSETS, THE SERVICES OR ANY THIRD PARTY CONTENT.

12. LIMITATION OF LIABILITY

THE COMPANY AND THE STARTALE GROUP WILL NOT BE LIABLE FOR ANY DAMAGES OF ANY TYPE ARISING OUT OF OR IN CONNECTION WITH YOUR ACCESS OR USE (OR INABILITY TO ACCESS OR USE) THE SERVICES OR ANY THIRD PARTY CONTENT, INCLUDING BUT NOT LIMITED TO (A) UNAUTHORIZED ACCESS TO YOUR WALLET; (B) STATEMENTS OR CONDUCT OF ANY THIRD PARTY CONTENT; (C) INTERRUPTION OR CESSATION OF FUNCTION RELATED TO THE SERVICES OR ANY THIRD PARTY CONTENT; (D) BUGS, VIRUSES, TROJAN HORSES, DEFECTS OF THE SERVICES OR ANY THIRD PARTY CONTENT OR THAT MAY BE TRANSMITTED TO OR THROUGH THE SERVICE OR ANY THIRD PARTY CONTENT; (E) ERRORS OR OMISSIONS IN, OR LOSS OR DAMAGE INCURRED AS A RESULT OF THE USE OF, ANY CONTENT MADE AVAILABLE THROUGH THE SERVICES OR ANY THIRD PARTY CONTENT; (F) DAMAGES ARISING FROM THE COMPROMISE OR LOSS OF YOUR LOGIN CREDENTIALS; (G) LOSS OF FUNDS IN YOUR WALLET; (H) FAILURE OR INABILITY TO ACCESS YOUR WALLET; (I) MISTAKES, OMISSIONS, INTERRUPTIONS, DELAYS, DEFECTS AND/OR ERRORS IN THE TRANSMISSION OF TRANSACTIONS OR MESSAGES TO ANY BLOCKCHAIN NETWORK; (J) FAILURE OF ANY DATA OR INFORMATION TO BE SENT OR BE RECEIVED BY THE INTENDED RECIPIENT IN THE INTENDED FORM; (K) LOSS OF VALUE OF ANY DIGITAL TOKEN; OR (L) ANY OTHER MATTER RELATING TO THE SERVICES OR ANY THIRD PARTY CONTENT.

FURTHER, THE COMPANY AND STARTALE GROUP SHALL NOT BE LIABLE UNDER ANY CIRCUMSTANCES FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY DAMAGES, OR DAMAGES FOR LOSS OF PROFITS, INCLUDING DAMAGES FOR LOSS OF GOODWILL, USE, OR DATA OR OTHER INTANGIBLE LOSSES ARISING OUT OF OR IN CONNECTION WITH ANY ACCESS OR USE (OR INABILITY TO ACCESS OR USE) THE SERVICES OR ANY THIRD PARTY CONTENT, EVEN IF THE COMPANY OR STARTALE GROUP HAVE BEEN ADVISED OF OR KNEW OR SHOULD HAVE KNOWN THE POSSIBILITY OF SUCH DAMAGES.

IN NO EVENT WILL THE COMPANY AND STARTALE GROUP’S TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES, OR CAUSES OF ACTION EXCEED THE FEES YOU HAVE PAID THE COMPANY FOR USE OF THE SERVICES FOR THE LAST SIX (6) MONTHS, OR ONE HUNDRED UNITED STATES DOLLARS (100 USD), WHICHEVER IS THE GREATER. THE COMPANY SHALL NOT BE LIABLE IN RESPECT OF ANY CLAIM MADE BY YOU AGAINST IT UNLESS YOU PROVIDE A NOTICE WITHIN 30 CALENDAR DAYS FROM THE DATE SUCH CLAIM ARISES, SUCH NOTICE STATING THE FOLLOWING INFORMATION: (1) YOUR FULL NAME, POSTAL ADDRESS, EMAIL ADDRESS AND TELEPHONE NUMBER; (2) A BRIEF DESCRIPTION OF THE NATURE OR BASIS OF THE CLAIM; AND (3) THE SPECIFIC RELIEF YOU ARE SEEKING.

SOME JURISDICTIONS DO NOT ALLOW THE DISCLAIMER OR EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE LIMITATIONS SET FORTH ABOVE MAY NOT APPLY TO YOU OR BE ENFORCEABLE WITH RESPECT TO YOU. IF YOU ARE DISSATISFIED WITH ANY PORTION OF THE SERVICE OR WITH THESE TERMS, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USE OF THE SERVICE.

13. PRIVACY POLICY

13.1 Privacy & data protection

You acknowledge and agree that when you access or use any third-party service through the Services, any data or information you provide to such third parties (including, but not limited to, personal data) may also be shared with or made available to the Company in accordance with the applicable terms and privacy policies of those third parties. The Company will process any such data received from third parties in accordance with its own Privacy Policy and applicable data protection laws. It is your responsibility to review and understand the terms and privacy policies of any third party with whom you interact via the Services, including how your data may be shared with the Company.

You represent and warrant that all information, including personal information provided to the Company (either directly by you or via any third party), has been lawfully collected and provided in accordance with applicable data protection and privacy legislation and all required consents have been obtained.

The Company processes personal data in accordance with applicable data protection laws, including the British Virgin Islands Data Protection Act, 2021. Our Privacy Policy, which also governs your use of the Services and is incorporated by reference into these Terms, can be found at Privacy Policy. By using the Services, you acknowledge and agree to such processing.

The Company, acts as data controller in respect of personal data it processes in connection with the Services. You may exercise your rights under the British Virgin Islands Data Protection Act, 2021 (including rights of access, correction and, where applicable, deletion) by contacting [email protected]. Where personal data is transferred to our affiliates or processors outside the BVI, we will implement appropriate safeguards consistent with applicable law and our Privacy Policy.

You acknowledge and agree that the Company may share your data, including personal data, with its affiliates, including Startale Group Pte. Ltd., for purposes connected with the provision, maintenance, improvement, and administration of the Services, as well as for compliance with applicable laws and regulations. Any such sharing of data will be carried out in accordance with the Company’s Privacy Policy and applicable data protection laws. Startale Group Pte. Ltd. will process any personal data received from the Company in accordance with its own privacy policy and the requirements of applicable data protection legislation.

13.2 Analytics Tools

The Company may use third-party analytics tools and services to help us understand how users interact with the Services and to improve the functionality and user experience of the Startale App. These analytics tools may collect and process certain technical information about your use of the Services, such as device information, usage statistics, and wallet addresses.

Except for wallet addresses, the Company will not store or permit the storage of any personal information or user data by such third-party analytics providers. Wallet addresses may be collected and processed for the purpose of analytics, but will not be used to identify you as an individual or combined with other personal data in the possession of the Company or its analytics providers.

14. GENERAL

14.1 Governing Law

The Terms and the relationship between the Company and you in respect of our Services (including Startale App) shall be governed by, and construed in accordance with, the laws of the British Virgin Islands.

14.2 Dispute Resolution

Any dispute, controversy or claim arising out of, relating to or in connection with or under the Terms, or the breach, termination or invalidity thereof (including non-contractual disputes or claims) (the “Dispute”) shall be referred to and finally resolved by arbitration administered by the British Virgin Islands International Arbitration Centre (“BVI IAC”) in accordance with the Arbitration Rules of the BVI IAC ("Arbitration Rules") for the time being in force, which rules are deemed to be incorporated by reference to this paragraph. In any arbitration commenced pursuant to this paragraph, the tribunal shall consist of one (1) arbitrator to be appointed by the President of the Court of Arbitration of the BVI IAC. The language of the arbitration shall be English, and the seat of the arbitration shall be British Virgin Islands. Except as otherwise provided in the Arbitration Rules, any decision of the arbitrator in any matter within this paragraph 14.2 will be final, binding and incontestable and may be used as a basis for enforcement thereon in the British Virgin Islands or elsewhere. The arbitrator will be entitled to include in its decision a determination as to the payment of the costs and expenses of the arbitrator, the administrative costs of the arbitrator, the legal fees incurred by the Parties, the costs and expenses of witnesses and all other costs and expenses necessarily incurred in the opinion of the arbitrator in order to properly settle the Dispute. The language to be used in the arbitral proceedings shall be English.

Any Dispute shall be brought solely in your individual capacity and not as a plaintiff or class member in any purported class, collective, or representative action, including private attorney-general actions or requests for public injunctions. No collective or representative proceedings or requests for relief of any kind shall be permitted.

14.3 Entire agreement

These Terms (together with the terms incorporated by reference thereto in this Terms) constitute the entire agreement between you and the Company with respect to the Services and Startale App. The latest version of the Terms will supersede all previous versions as well as any other agreements or understandings (oral or written) between you and the Company.

14.4 Severance

If any provision of the Terms or part thereof is rendered void, illegal or unenforceable by any legislation to which it is subject, the parties agree to modify the provision to reflect the parties’ intentions to the maximum extent permitted by law, and the other provisions of these Terms remain in full force and effect.

14.5 Assignment and Third Party Rights

You may not assign, convey, transfer or delegate your rights, duties or obligations hereunder without the prior written consent of the Company. The Company reserves the right to assign or transfer any of its rights, duties or obligations under these Terms, in whole or in part, without restriction. Other than you, the Company and the Startale Group, no other person has any rights to enforce any provision of these Terms.

14.6 Force Majeure

The Company will not be in default hereunder by reason of any failure or delay in the performance of its obligations where such failure or delay is due to civil disturbances, riot, epidemic, acts or omissions or conduct of Third Party Content, hostilities, war, terrorist attack, embargo, natural disaster, acts of God, flood, fire, sabotage, fluctuations or unavailability of electrical power, interruption in telecommunications or network access or equipment, interruption in blockchain networks, or any other circumstances or causes beyond the reasonable control of the Company.

14.7 Non-Waiver of Rights

The failure of the Company or the Startale Group to exercise or enforce any right or provision of these Terms will not constitute a waiver of such right or provision.

14.8 Notice

Any notices or other communications provided by us under these Terms, including without limitation, regarding amendments or modifications to these Terms, may be delivered by posting such notice or communication on our website, within the Startale App, and/or through other electronic communication. You hereby agree to receive electronically all communications, agreements, documents, notices and disclosures that we provide in connection with your use of the Services.

14.9 No other duties

These Terms are not intended to and do not, create or impose any fiduciary duties on us. None of the Company, Startale Group, its respective directors, shareholders, employees or sub-contractors shall be deemed to be your agent or partner whatsoever. To the maximum extent permitted by applicable laws, you acknowledge and agree that none of the Company or Startale Group (including its respective directors, shareholders, employees or sub-contractors) owe any fiduciary duties or liabilities to you or any other party. You hereby irrevocably and unconditionally waive any duties or liabilities of the Company and Startale Group that may exist under applicable laws. We do not owe you any duties or obligations except for those expressly stated in these Terms.

14.10 Support

You may contact us for any technical and customer support in respect of the Services or if you wish to submit a complaint regarding the Services.

In the event of fraud, unauthorised use or any suspicious or unusual activity, whether actual or suspected, associated with your account by third parties, you should immediately contact us by [email protected]. We reserve the right to suspend or terminate all Services to you if we reasonably believe your account or activity is linked to fraud, illegal activity or breach of these Terms.