PART I – TERMS AND CONDITIONS

Preamble

These Terms and Conditions (the "Terms") govern the legally binding relationship between you and Pine Labs S.A. ("Pine", "we", "us", "our") when you access or use the website, web application, mobile application, APIs, and all related services collectively branded as "Pine" (the "Platform").

By accessing, registering on, or using the Platform in any capacity, you acknowledge that you have read, understood, and agree to be legally bound by these Terms and our Privacy Policy. If you do not agree, you must not use the Platform or any of its Services.

Definitions

For the purposes of these Terms (including the Privacy Policy and Cookie Policy forming part of this document), the following capitalised terms have the meanings set out below. Other terms defined elsewhere in this document have the meaning assigned to them at the point of definition.

1. Identification of the Operator

1.1. The Platform is operated by: Pine Labs S.A. – Registration Number: N° 155779597 – Registered Address: Calle Aquilino de la Guardia Calle 47, Ocean Busin, Panama, Panama, Panama, Republic of Panama ("Pine", "we", "us", "our").

1.2. Throughout these Terms, references to "you" or "User" mean any natural or legal person who accesses or uses the Platform in any capacity.

1.3. For any inquiries regarding these Terms, contact us at: contact@pinewallet.io.

2. Nature of the Platform and Role of Pine

2.1. Technology interface. Pine is a technology platform that provides Users with a unified self-custody digital asset interface. Through the Platform, Users can access:

• a non-custodial, self-custody multi-chain crypto wallet with smart-account capabilities (ERC-4337 account abstraction);
• portfolio tracking and transaction history across supported blockchain networks;
• access to card programmes (virtual and/or physical debit cards) operated by licensed third-party card issuers;
• access to fiat on-ramp and off-ramp services operated by regulated third-party payment and exchange partners;
• access to decentralised finance (DeFi) lending vaults and yield strategies operated by third-party DeFi protocols;
• token price information and market data provided by third-party data services;
• in-app notifications and communications infrastructure.

2.2. No financial services. Pine Labs S.A. is not:

• a bank or credit institution;
• an electronic money institution (EMI);
• a payment institution or payment service provider (PSP);
• a virtual asset service provider (VASP) in any regulated sense, unless expressly stated otherwise in the jurisdiction of the User;
• a securities firm, asset manager, or portfolio manager;
• a card issuer or card programme manager.

2.3. Pine does not:

• issue payment cards;
• hold, safeguard, or manage your fiat or crypto funds on your behalf (non-custodial model);
• receive customer deposits or take custody of digital assets;
• provide financial, tax, accounting, or legal advice;
• guarantee returns, yields, or profitability on any DeFi vault, savings product, or crypto-related activity.

2.4. Third-party contractual relationships. When you use any service accessible through Pine that is provided by a Third-Party Provider:

• you enter into a direct contractual relationship with the relevant Third-Party Provider (e.g., card issuer, on-ramp provider, DeFi protocol);
• the terms and conditions, policies, and regulatory obligations of such Third-Party Provider apply in addition to these Terms;
• Pine acts solely as a technology intermediary and access layer.

2.5. No guarantee or supervision of third parties. Pine does not guarantee, audit, supervise, or control:

• the licensing status of Third-Party Providers in your jurisdiction;
• the quality, safety, legality, or fitness for purpose of their products or services;
• the effective performance, continuity, or availability of those services.

You are solely responsible for assessing whether the use of any service is lawful and appropriate in your country of residence.

2.6. Regulatory status of Pine Labs S.A. in Panama. Pine Labs S.A. is a technology company incorporated and domiciled in the Republic of Panama. Pine Labs S.A. has taken the position that it does not conduct virtual asset service provider (VASP) activities as defined under Panamanian Law 129 of 2022 (Que regula los activos virtuales y los proveedores de servicios de activos virtuales), on the basis that:

• Pine does not hold, custody, or control user assets at any point (non-custodial model);
• fiat-to-crypto conversion and exchange activities are performed exclusively by VIRTUABROKER CORP. as the regulated or licensed party for those operations;
• DeFi vault interactions occur directly between Users and on-chain smart contracts without Pine's intermediation;
• card issuance and payment services are provided exclusively by licensed card issuers.

The regulatory landscape for digital assets, fintech aggregators, and DeFi interfaces is evolving rapidly, both in Panama and globally. Pine Labs S.A. recommends that Users consult qualified legal counsel in their own jurisdiction to assess the legality of using any service accessible through the Platform. Pine likewise commits to monitoring applicable regulatory developments and updating its compliance posture accordingly.

3. Acceptance of the Terms

3.1. These Terms apply to all:

• visits, browsing, or use of the Platform;
• creation, access, and use of a Pine account;
• connection of a self-custody wallet via the Platform;
• use of any service, product, card, vault, on-ramp/off-ramp, or related functionality through Pine.

3.2. By:

• clicking "I agree", "Accept", or any similar action;
• registering an account;
• connecting a wallet through Privy or any other supported authentication method;
• using any part of the Platform,

you confirm that you have read, understand, and agree to be bound by these Terms.

3.3. If you use the Platform on behalf of a legal entity, you represent and warrant that you are duly authorised to bind that entity to these Terms.

3.4. Term. These Terms enter into force on the date on which you accept them (for example, by creating your Pine account or by first using any of the Services) and shall remain in force while you use the Platform or maintain an active account, or until they are superseded by a new version.

Pine will communicate any relevant changes to these Terms through the Platform or via your registered contact details, indicating the date from which the new version will be effective.

By continuing to use the Services after the entry into force of an updated version of the Terms, you are deemed to have accepted that version.

4. Eligibility

4.1. To use the Platform you must:

• be at least 18 years old, or the age of legal majority in your jurisdiction if higher;
• have full legal capacity to enter into binding contracts;
• not be a resident, citizen, or located in any jurisdiction subject to comprehensive international sanctions or listed as high-risk by Pine's internal compliance policies;
• not appear on international sanctions lists including, without limitation, OFAC SDN, EU Consolidated, UN Security Council, UK HMT, FATF High-Risk jurisdictions, or any other applicable watchlist;
• comply at all times with applicable laws and regulations in the country from which you access or use the Platform.

4.2. Pine may, at its sole discretion and without obligation to justify, refuse access or terminate any User's access where eligibility conditions are not met or where required for compliance or risk management reasons.

5. Account Registration and Profile Modes

5.1. Account creation. To access the Platform's features, you must register a Pine account. Registration is facilitated through Privy (privy.io), our authentication and embedded wallet provider. You may register using:

• an email address;
• social login (where supported by Privy);
• a Web3 wallet address.

5.2. Profile modes. Pine offers two profile modes that govern your access to features and the data you choose to share:

• LITE mode: Privacy-oriented profile with limited features. Designed for Users who prefer minimal data exposure.
• NORMAL mode: Full-feature profile providing access to all available services on the Platform, including card programmes, on-ramp/off-ramp, and DeFi vaults.

The specific features and limits associated with each profile mode are described in the Platform and may be updated from time to time.

5.3. Account accuracy. You agree to provide accurate, current, and complete information during registration and to keep it updated. You are responsible for all activity conducted under your account.

5.4. One account per User. Each User may only create and maintain one (1) Pine account, unless expressly authorised otherwise by Pine.

6. Self-Custody Wallet and Smart Accounts

6.1. Non-custodial model. Pine operates on a self-custody model. This means:

• you remain solely responsible for the management and security of your private keys, seed phrases, and wallet credentials;
• Pine does not have access to your private keys and cannot restore or recover them;
• Pine does not receive, hold, or control your crypto assets; all on-chain transactions occur directly from your wallet to the relevant smart contract, protocol, or third-party provider.

6.2. Smart accounts (ERC-4337). The Platform uses account abstraction (ERC-4337) via Pimlico as the bundler and paymaster infrastructure. Smart accounts enable:

• programmable spending limits and account controls;
• gasless transactions (sponsored by the Platform, subject to conditions);
• deterministic multi-account creation from a single authentication credential.

You acknowledge that smart accounts involve additional smart contract risk. Pine does not guarantee the security or availability of any smart contract infrastructure operated by third parties.

6.3. Account security. You are solely responsible for:

• maintaining the confidentiality of your login credentials (email, private keys, seed phrases, API keys);
• securing your devices against malware, phishing, and unauthorised access;
• keeping your Privy-linked authentication methods secure.

6.4. You must notify Pine immediately at support@pinewallet.io if you become aware of any unauthorised use of your account or any security incident. Pine is not responsible for losses arising from your failure to protect your account or wallet.

6.5. No account or wallet recovery — user sole responsibility. The Platform operates on a self-custody, non-custodial architecture. This has the following irrevocable consequences which you must understand and accept before using the Platform:

6.5.1. Pine does not, and is technically incapable of:

• accessing, holding, or recovering your private keys, seed phrases, or wallet credentials at any time;
• resetting or restoring access to your Pine account or any associated wallet if you lose access to your authentication credentials (email address, social login, or any authentication factor linked to your Privy account);
• overriding or bypassing the authentication mechanisms of Privy or any other provider on your behalf;
• recovering crypto assets sent to incorrect addresses, locked in smart contracts, or rendered inaccessible due to loss of credentials or user error.

6.5.2. If you lose access to the email address, social login, or any authentication factor registered with your Privy account, access to your Pine account and all associated wallets may be permanently and irrecoverably lost. Any crypto assets held in those wallets may become permanently inaccessible with no possibility of recovery. Pine bears no liability whatsoever for any loss, damage, or harm arising from loss of access to authentication credentials.

6.5.3. You are solely and entirely responsible for:

• maintaining secure backups of your seed phrases, private keys, and all wallet recovery information;
• maintaining continuous access to the email address and all authentication methods linked to your Privy account;
• all transactions, transfers, deposits, withdrawals, vault interactions, card operations, and any other actions initiated from your wallet or account — whether or not such actions were authorised by you, whether resulting from user error, phishing, social engineering, device compromise, or any other cause.

6.5.4. Pine recommends that you:

• record and securely store your seed phrase(s) offline in a location known only to you;
• enable all security features available in your Privy account;
• never share your private keys, seed phrases, or authentication credentials with any person, including Pine support staff — Pine will never ask for these.

6.6. Supported blockchain networks. The Platform currently supports the following networks:

Pine may add, modify, or remove supported networks at any time with prior notice where practicable.

7. Services Accessible Through Pine

7.1. Portfolio and Transaction History

7.1.1. Pine provides portfolio tracking across supported blockchain networks using data sourced from Alchemy and Moralis (transaction history indexers) and CoinMarketCap (token pricing). These services are read-only and do not involve Pine holding or transacting your assets.

7.1.2. Portfolio data, transaction history, and token prices are sourced from third-party APIs and may not always be accurate, complete, or up to date. You should not rely exclusively on data displayed on the Platform for financial decision-making.

7.2. Card Programmes (Virtual and Physical Cards)

7.2.1. The Platform enables eligible Users to request access to debit card programmes (virtual and/or physical cards) issued and operated by regulated card issuers through an integrated card provider API (the "Card Provider" and "Card Issuers").

7.2.2. Pine is not a card issuer and does not participate in the processing, clearing, or settlement of card transactions. All card services are provided exclusively by the relevant Card Issuer under its own licence and regulatory framework.

7.2.3. Card access is subject to:

• successful completion of the Card Provider's onboarding and KYC/KYB process;
• your compliance with the Card Issuer's terms and conditions, which you must accept before activating or using any card;
• applicable limits, acceptance networks, supported currencies, and fee schedules as set by the Card Issuer.

7.2.4. Card-related functions available on the Platform include card onboarding, holder management, deposits/top-ups, transaction history, coupons, referrals, and tiered access. All these features are administered by the Card Provider and are subject to change without notice by the Card Provider.

7.2.5. Pine is not responsible for:

• the availability or timing of card balances;
• any holds, freezes, or compliance reviews imposed by the Card Provider or Card Issuer;
• declined transactions, disputes, or chargebacks.

Deposit and top-up funds transferred to fund a card account are held exclusively by the Card Issuer or its processor. Pine does not hold these funds.

7.3. Fiat On-Ramp and Off-Ramp (Bank/Exchange Services)

7.3.1. The Platform integrates fiat-to-crypto and crypto-to-fiat exchange services provided by VIRTUABROKER CORP. (trading as "VirtuaBroker", the "Exchange Partner"), a technology and infrastructure company that enables access to digital asset services, enabling Users to:

• deposit fiat currency to acquire crypto assets (on-ramp);
• exchange or convert crypto assets to fiat (off-ramp);
• execute open-banking deposits and withdrawals;
• view exchange rates and liquidity pairs.

Where required, certain elements of VirtuaBroker's services (including fiat processing, KYC/AML, custody, or liquidity) may be provided by regulated third-party service providers integrated into VirtuaBroker's platform. VirtuaBroker is not regulated by the UK Financial Conduct Authority (FCA) and does not provide regulated financial services directly; financial services compensation schemes do not apply to VirtuaBroker's services.

7.3.2. VirtuaBroker Service Acknowledgment (Mandatory). By accessing fiat on-ramp, off-ramp, or exchange services through Pine:

"The End User acknowledges that the Services are provided by VIRTUABROKER CORP., acting as the service provider, and confirms that it has reviewed, understands, and agrees to be bound by VIRTUABROKER CORP. Terms and Conditions, as made available at https://virtuabroker.com/terms-conditions/. Such Terms and Conditions set forth, inter alia, the scope of the Services, the responsibilities of VIRTUABROKER CORP., and the applicable conditions governing the provision of the Services."

7.3.3. Mandate Authorisation (Collection Agent). By initiating any exchange transaction through Pine, you expressly and irrevocably authorise VIRTUABROKER CORP. to act as your collection agent and authorised representative for the sole purpose of executing exchange transactions with the relevant financial institutions or payment service providers duly authorised to operate in the exchange market. This mandate grants VIRTUABROKER CORP. the right to manage and represent you in accordance with VIRTUABROKER CORP.'s Terms and Conditions, which you hereby accept. VIRTUABROKER CORP. will act on your behalf exclusively for the purposes of executing the required exchange transactions. Pine Labs S.A. shall, upon request by VIRTUABROKER CORP., present evidence of your consent to these Terms and Conditions as required under our service agreement with VIRTUABROKER CORP.

7.3.4. You also authorise Pine Labs S.A. to transmit necessary information (including personal data, wallet addresses, and transaction details) to VIRTUABROKER CORP. for compliance and processing purposes.

7.3.5. Exchange rates, fees, and transaction limits are determined by VIRTUABROKER CORP. and its underlying partners, and are subject to change. Pine displays rates provided by VIRTUABROKER CORP. and does not guarantee their accuracy at the time of settlement.

7.3.6. Chargeback Procedure. In the event that you dispute a transaction directly with VIRTUABROKER CORP. or through a financial institution, payment service provider, card scheme, or similar intermediary (a "chargeback"), Pine Labs S.A. will be notified and required to provide a decision with supporting documentation within twenty-four (24) hours of such notification. If Pine Labs S.A. does not provide sufficient documentation to establish the inapplicability of the chargeback, VIRTUABROKER CORP. may decide whether to authorise the chargeback; if authorised, the value of the transaction will be deductible from the applicable balance. Notwithstanding the foregoing, VIRTUABROKER CORP. shall not be liable for any chargeback requested by any End User.

7.3.7. ECB Instant Payment Scheme. You are advised that the instant payment scheme managed by the European Central Bank allows users to flag transactions as fraud. If a transaction processed through VIRTUABROKER CORP.'s infrastructure is flagged as fraudulent under this scheme, VIRTUABROKER CORP. will conduct the chargeback and the applicable transaction fees charged will not be returned.

7.3.8. Disputes related to fiat payments, bank transfers, order status, or exchange execution must be addressed primarily with VIRTUABROKER CORP. in accordance with VIRTUABROKER CORP.'s Terms and Conditions (https://virtuabroker.com/terms-conditions/).

7.4. DeFi Lending Vaults (Pine Plus)

7.4.1. The Platform provides access to DeFi lending vaults based on the ERC-4626 tokenised vault standard, powered by the Morpho protocol (app.morpho.org). Currently supported vaults are deployed on:

• Ethereum Mainnet (Chain ID 1)
• Base (Chain ID 8453)
• Arbitrum One (Chain ID 42161)

7.4.2. By depositing into a vault, you:

• interact directly with Morpho's smart contracts on the relevant blockchain;
• acknowledge that Pine does not control, operate, or manage these smart contracts;
• understand that funds deposited are subject to Morpho's own terms of service and applicable protocol risks.

7.4.3. Pine does not:

• guarantee any specific yield, return, or interest rate on vault deposits;
• insure or guarantee the security of smart contracts;
• operate or control the vault strategies.

7.4.4. Deposits into DeFi vaults involve significant risks, including but not limited to:

• Smart contract risk: bugs, vulnerabilities, or exploits in the Morpho protocol or underlying contracts;
• Liquidity risk: inability to withdraw funds immediately under certain market conditions;
• Market risk: fluctuations in the value of deposited or received assets;
• Oracle risk: manipulation or failure of price oracles used by the protocols;
• Regulatory risk: regulatory changes that may affect the use or legality of DeFi protocols.

Past performance or historical yield data displayed on the Platform is not indicative of future results. You may lose part or all of your deposited assets.

7.5. Token Pricing and Market Data

7.5.1. The Platform displays token prices sourced from CoinMarketCap (pro-api.coinmarketcap.com) for informational purposes only. Prices are cached and may not reflect real-time market conditions.

7.5.2. Token price data is provided for informational purposes only and does not constitute financial advice or a solicitation to buy or sell any asset.

7.6. Token Swaps and Cross-Chain Bridge (Relay)

7.6.1. The Platform integrates token swap and cross-chain bridge functionality powered by Relay (relay.link), enabling Users to:

• swap tokens within a supported blockchain network;
• bridge assets across supported blockchain networks.

7.6.2. Relay is an independent third-party protocol. By using swap or bridge functionality:

• you interact directly with Relay's smart contracts and liquidity infrastructure;
• Relay charges its own service fee per transaction, disclosed to you before confirming any swap or bridge transaction;
• Pine does not control, operate, or guarantee the execution, pricing, availability, or settlement of any swap or bridge transaction.

7.6.3. Cross-chain bridge transactions carry additional risks beyond standard on-chain transfers, including but not limited to:

• Bridge smart contract risk: vulnerabilities or exploits in Relay's or underlying bridge contracts;
• Liquidity risk: insufficient liquidity for a given asset or route at the time of transaction;
• Delivery risk: delays or failures in asset delivery across chains.

Pine bears no liability for losses arising from the use of Relay's swap or bridge services.

7.7. Saved Payment Methods and Beneficiary Information

The Platform may allow Users to optionally store payment methods, beneficiary information, payout destinations, bank account details, phone numbers, or related identifiers for convenience and streamlined transaction flows.

Users acknowledge and agree that:

(a) the functionality is optional;

(b) Users remain solely responsible for verifying the accuracy, ownership, and legality of any saved payment information before initiating a transaction;

(c) Pine does not guarantee the validity, ownership, availability, or correctness of any payment destination or beneficiary information stored by the User;

(d) Users may update or remove saved payment methods through the Platform where supported.

Pine shall not be liable for failed, delayed, irreversible, or misdirected transactions resulting from inaccurate, outdated, incomplete, fraudulent, or incorrectly entered beneficiary or payment method information supplied or stored by the User.

8. KYC / AML Compliance

8.1. Compliance Commitment. Pine and its Third-Party Providers are strictly committed to complying with applicable laws and regulations on anti-money laundering (AML), counter-terrorism financing (CTF), and international sanctions regimes.

8.2. KYC / KYB verification. Depending on the services you use and your profile mode, you may be required to complete a Know Your Customer (KYC) or Know Your Business (KYB) verification process. KYC/KYB is conducted by VIRTUABROKER CORP. and/or the Card Provider as part of their own regulated onboarding procedures, using Sumsub (sumsub.com) as their identity verification and compliance sub-processor. You may be required to provide:

• government-issued identification documents;
• proof of address;
• biometric data and/or a liveness check (processed by Sumsub on behalf of the relevant provider);
• source of funds documentation;
• any other information required by law or by the relevant provider.

KYC token sharing. Where technically feasible and subject to your explicit consent, the KYC verification completed through Sumsub in the context of VIRTUABROKER CORP.'s onboarding may be reused by the Card Provider through a secure Sumsub identity verification token. This mechanism enables you to avoid repeating the full identity verification process when accessing the card programme on the Platform. By accepting these Terms and using the relevant services, you authorise Pine Labs S.A. to facilitate the transmission of such verification token between VIRTUABROKER CORP. and the Card Provider solely for identity verification purposes.

8.3. Transaction monitoring. Pine and/or its authorised third-party providers shall carry out continuous monitoring of blockchain wallet addresses and transactions conducted through the Platform. Such activity shall be checked against international sanctions watchlists and automated AML risk-scoring tools. Detection of high-risk, unusual, or suspicious activity may result in suspension, immediate restriction, or definitive termination of access to the Platform.

8.4. Sanctions screening. Pine reserves the right to:

• block, suspend, or restrict access for Users in or associated with sanctioned or restricted jurisdictions;
• freeze or refuse transactions involving wallet addresses associated with sanctioned entities or illicit activity;
• report suspicious activity to competent authorities as required by law.

8.5. Refusal to provide required KYC documentation may result in denial of access to specific services.

9. Prohibited Uses

9.1. You agree that you will not use the Platform or any service accessible through it:

• for any unlawful, fraudulent, or abusive purpose;
• to violate any applicable international, federal, national, or local law or regulation;
• in connection with money laundering, terrorism financing, sanctions evasion, or handling criminal proceeds;
• to engage in fraud, chargeback abuse, or unauthorised card or payment use;
• to harass, threaten, defame, or abuse any person or entity;
• to infringe intellectual property rights, trade secrets, or proprietary information;
• to upload, transmit, or distribute malware, viruses, or any malicious code;
• to attempt unauthorised access to any system, account, API, smart contract, network, or data;
• to perform automated scraping, excessive API calls, denial-of-service attacks, or any behaviour that may disrupt the Platform;
• to use VPNs, proxies, or similar tools to bypass geo-restrictions, sanctions, or compliance controls.

9.2. You must not:

• create multiple accounts for abusive or deceptive purposes;
• sell, lease, or otherwise transfer your Pine account without our prior written consent;
• impersonate Pine, its employees, partners, or any other person or entity;
• upload or store beneficiary information belonging to third parties without proper authority or a lawful basis.

9.3. Pine reserves the right to investigate and take appropriate action in case of suspected prohibited use, including account suspension or termination, blocking access, and notification to relevant authorities.

10. Fees, Pricing, and Taxes

10.1. Pine Platform Fees.

10.1.1. External withdrawal fee. Pine charges a flat fee of USD 0.10, deducted in the token being transferred, for each transfer of crypto assets to a wallet address outside the Platform. This fee is added to the transfer amount. For example, withdrawing 5 USDC to an external address will result in a total balance deduction of 5.10 USDC. The applicable fee is always displayed on the Platform before you confirm the transaction. Pine reserves the right to update this fee with reasonable prior notice.

10.1.2. Gas fee sponsorship (EVM networks). For standard on-Platform transactions on supported EVM-compatible networks, Pine sponsors blockchain network transaction fees ("gas fees") through Privy and Pimlico (ERC-4337 paymaster infrastructure), at no additional cost to you. Gas fee sponsorship is subject to conditions and may be modified, limited, or discontinued at Pine's discretion, with notice where practicable.

10.1.3. Internal transfer fee. Pine charges a fee of USD 0.10 equivalent, deducted in the token being transferred, per transfer of crypto assets in either of the following cases: (i) transfers between wallet accounts associated with the same Pine User profile; or (ii) transfers to a wallet account associated with a different Pine User's profile on the Platform. This fee applies exclusively to transfers that involve a wallet account that is the fourth (4th) or later account created under a User profile. The first three (3) wallet accounts created under a User profile are permanently exempt from this fee, regardless of the total number of accounts held. For the purposes of this clause, an "active wallet account" means any Pine smart wallet account that has been created under a User profile and has not been deactivated, regardless of its current balance. The applicable fee is displayed on the Platform before you confirm the transaction. Pine reserves the right to modify this fee or the applicable threshold with prior notice to Users.

10.2. Third-Party Provider fees are set independently by those providers, are not controlled by Pine, and are disclosed to you on the Platform before transaction confirmation:

• VirtuaBroker on-ramp, off-ramp, and exchange fees;
• Card Provider card programme fees;
• Relay swap and cross-chain bridge fees;
• Morpho vault protocol fees;
• Pimlico paymaster fees (where applicable outside sponsored operations).

10.3. Blockchain network transaction fees (gas fees) not covered under Pine's gas sponsorship programme are:

• determined by the relevant blockchain network and are outside Pine's control;
• non-refundable once incurred.

10.4. You are solely responsible for:

• determining whether any transaction executed through the Platform has tax implications in your jurisdiction;
• reporting and paying all applicable taxes including income tax, capital gains tax, VAT, GST, or equivalent.

Pine does not provide tax advice.

11. Irreversibility of Blockchain Transactions

11.1. Blockchain transactions are irreversible. Once executed and confirmed on the network, they cannot be cancelled or reversed by Pine. You must carefully verify addresses, amounts, and network selection before confirming any transaction.

11.2. If you send assets to an unsupported address or via an unsupported network, your funds may be permanently lost. Pine and its Third-Party Providers will not be liable for such losses. Recovery attempts, if any, will be made on a best-effort and discretionary basis and may be subject to fees.

11.3. Smart account operations (ERC-4337) are submitted as UserOperations to the Pimlico bundler and are subject to the same irreversibility principles once confirmed on-chain.

12. Intellectual Property

12.1. The Platform, including its design, text, graphics, logos, icons, code, interfaces, and all content ("Pine Content"), is owned by or licensed to Pine and is protected by applicable intellectual property laws.

12.2. You are granted a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform for personal, non-commercial purposes only.

12.3. You must not, without prior written consent:

• reproduce, distribute, modify, or create derivative works of any Pine Content;
• reverse engineer, decompile, or attempt to extract source code from the Platform;
• use any trademarks, logos, or trade names of Pine or its partners except as permitted by law.

13. No Financial or Tax Advice

13.1. All information provided on or through the Platform is for general information purposes only. It does not constitute:

• financial advice or a recommendation to buy, sell, or hold any asset;
• financial, tax, accounting, or legal advice;
• a solicitation or offer to buy, sell, or transact in any asset.

13.2. Decisions to interact with DeFi protocols, cards, on-ramp/off-ramp services, or any crypto-related product involve a high degree of risk and should be made only after consulting qualified professional advisors and carefully assessing your financial situation.

14. Disclaimer of Warranties

14.1. The Platform and all services accessible through it are provided on an "as is" and "as available" basis without any warranties of any kind, whether express, implied, or statutory, including but not limited to implied warranties of merchantability, fitness for a particular purpose, non-infringement, availability, reliability, or error-free operation.

14.2. Pine does not warrant that:

• the Platform will meet your requirements;
• any service will be available in all countries or at all times;
• any transaction will be executed, confirmed, or settled within a particular timeframe;
• the Platform will be free from interruptions, errors, security breaches, or vulnerabilities;
• data from Third-Party Providers (portfolio balances, transaction history, token prices, vault yields) will be accurate or current.

15. Limitation of Liability

15.1. To the maximum extent permitted by applicable law, Pine, its directors, employees, partners, agents, and affiliates shall not be liable for:

• any indirect, incidental, special, punitive, or consequential damages;
• loss of profits, revenue, data, goodwill, or opportunities;
• business interruption;
• any loss resulting from:
  • your use or inability to use the Platform;
  • any action or omission of Third-Party Providers (VirtuaBroker, Card Provider, Relay, Morpho, Pimlico, Alchemy, Moralis, Privy, Novu, CoinMarketCap, or any other provider);
  • blockchain failures, protocol exploits, forks, attacks, or network congestion;
  • smart contract bugs or vulnerabilities in ERC-4337 or ERC-4626 infrastructure;
  • unauthorised access to or compromise of your wallet, private keys, or credentials;
  • regulatory changes or government actions affecting services or assets.

15.2. Where Pine is found liable notwithstanding the above, Pine's aggregate liability to you in respect of any claim shall be limited to the total amount of fees paid by you directly to Pine in the twelve (12) months preceding the event giving rise to the claim.

15.3. Nothing in these Terms excludes or limits any liability that cannot legally be excluded or limited under applicable consumer protection law.

16. Indemnity

16.1. You agree to indemnify, defend, and hold harmless Pine, its officers, directors, employees, agents, and affiliates from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or related to:

• your breach of these Terms;
• your violation of any applicable law or the rights of any third party;
• your use of the Platform in a negligent, unlawful, or prohibited manner;
• any dispute between you and a Third-Party Provider.

17. Suspension and Termination

17.1. Pine reserves the right to suspend or terminate your account and/or access to the Platform, with or without notice, where:

• you breach these Terms or applicable law;
• Pine suspects fraud, money laundering, sanctions violations, or other illicit activity;
• required by a competent authority or applicable law;
• continued access poses a compliance or security risk.

17.2. Upon termination, your right to use the Platform ceases immediately. You remain responsible for any obligations incurred prior to termination.

18. Changes to the Platform and to These Terms

18.1. Pine may, at any time and at its sole discretion, modify, suspend, or discontinue any part of the Platform or any service.

18.2. Pine may amend these Terms from time to time. Updated Terms will be published on the Platform with an updated "Last Updated" date.

18.3. Where changes are material, Pine will use reasonable efforts to notify you (for example, via in-app notification or email). Your continued use of the Platform after the effective date constitutes acceptance of the updated Terms.

19. Governing Law and Dispute Resolution

19.1. These Terms, and any dispute or claim arising out of or in connection with them, shall be governed by and construed in accordance with the laws of the Republic of Panama, without regard to conflict-of-laws principles.

19.2. The parties agree to first seek good-faith resolution of any dispute through direct negotiation for a period of thirty (30) days from the date of written notice of the dispute.

19.3. If no amicable resolution is reached, disputes shall be submitted to the exclusive jurisdiction of the courts of the Republic of Panama, except where mandatory law of the User's country of residence grants the right to bring actions in local courts.

20. Miscellaneous

20.1. Entire agreement. These Terms, together with the Privacy Policy and any other documents incorporated by reference, constitute the entire agreement between you and Pine relating to the Platform.

20.2. Severability. If any provision is held invalid or unenforceable, the remaining provisions continue in full force and effect.

20.3. No waiver. Failure by Pine to enforce any right or provision shall not constitute a waiver of that right or provision.

20.4. Assignment. You may not assign your rights or obligations under these Terms without Pine's prior written consent. Pine may assign these Terms to any affiliate or successor entity.

20.5. Language. These Terms may be made available in multiple languages. In case of any discrepancy, the English version shall prevail.

20.6. Contact. Legal enquiries: contact@pinewallet.io | Support: support@pinewallet.io