Terms and Conditions

1. INTRODUCTION AND ACCEPTANCE

These terms and conditions (the "Terms") govern access to and use of the platform and services provided by Finturu LLC and its subsidiaries and affiliated entities (collectively, "Finturu", the "Company", "we", "us", or "our") (the "Services").

These Terms, together with the Privacy Policy, AML/CFT Policy, and any applicable service orders, mandate agreements, or product-specific terms, constitute a legally binding agreement between the Company and any individual or entity accessing or using the Services (each, a "User").

The Services may be used by (a) business Users, including merchants and other commercial entities engaging in payment collection, transfers, or commerce operations; and (b) individual Users accessing payout, transfer, or remittance-related functionalities. By registering for, accessing, or using the Services, each User acknowledges and agrees to be bound by these Terms and to comply with all applicable laws and regulatory requirements.

2. NATURE OF THE SERVICES

The Company operates a multi-layered technology platform designed to enable domestic and international commerce through the orchestration of payments, settlement, logistics, and multichannel operations.

The platform supports local-to-local transactions within a single jurisdiction, as well as local-toglobal and cross-border operations, allowing Users to manage financial flows, transfers, and commerce activities across multiple markets through a unified interface.

The Company provides infrastructure that allows Users to access financial and operational services through integrations with regulated financial institutions and third-party providers. The Company does not operate as a bank, licensed financial institution, or foreign exchange intermediary, and does not directly hold, custody, or safeguard customer funds. The Company does not act as a party to the underlying commercial transactions between buyers and sellers and assumes no responsibility for the delivery, quality, legality, or performance of goods or services exchanged between such parties.

3. FINANCIAL SERVICES INFRASTRUCTURE AND REGULATORY FRAMEWORK

The Company operates within a Banking-as-a-Service (BaaS) framework in coordination with regulated financial institutions, program sponsors, and infrastructure providers.

Certain financial services made available through the Services are provided by regulated third parties, including program sponsors such as Bridge and sponsor banks such as Lead Bank, as well as other regulated financial partners responsible for providing licensed financial services. Bridge, Lead Bank, and other financial partners are independent third parties and are not affiliates, agents, or joint venture partners of the Company.

When a User or business customer applies to access financial functionalities, including payment processing, settlement, account issuance, or payout capabilities, the Company collects onboarding information, including KYC/KYB data, which may be shared with program sponsors and sponsor banks. These entities may independently conduct due diligence, identity verification, and compliance assessments and may approve, deny, or restrict access to financial services in accordance with their regulatory obligations and risk appetite.

Business customers are required to provide accurate and complete beneficial ownership information, including the identification of any individual who directly or indirectly owns twenty-five percent (25%) or more of the equity or voting interests in the business, as necessary to comply with the Company's AML/CFT policies and the requirements of sponsor banks and other regulated financial institutions.

The Company does not independently make regulatory determinations or grant financial account approvals. Access to certain Services is conditional upon approval by the relevant financial institution.

4. USER ELIGIBILITY AND ACCOUNT REGISTRATION

Access to the Services is available to individuals and entities that meet applicable legal, regulatory, and compliance requirements. Users are required to provide accurate, complete, and up-to-date information during onboarding and throughout the duration of their relationship with Finturu.

Finturu reserves the right to verify any information provided and to request additional documentation where necessary to comply with regulatory obligations, risk management policies, or operational requirements. The Company may suspend, restrict, or terminate access to the Services where information is inaccurate, incomplete, or inconsistent with applicable standards.

Where financial services are involved, users acknowledge that identity verification and compliance procedures may be conducted not only by Finturu but also by program sponsors, sponsor banks, and other regulated third parties.

Individual users accessing transfer, payout, or remittance-related services may be subject to additional identity verification requirements, transaction limits, geographic restrictions, and ongoing monitoring obligations imposed by Finturu or its financial partners, in accordance with applicable regulatory standards.

Users are solely responsible for maintaining the confidentiality and security of their access credentials, including usernames, passwords, API keys, and authentication tokens, and for all activities conducted through their accounts. Finturu may require the use of specific security controls, including but not limited to Multi-Factor Authentication (MFA) and strong password standards, for accessing certain Services or administrative functionalities, consistent with Finturu's Access Control Policy and other internal security requirements.

5. COMPLIANCE AND PERMITTED USE

Use of the Services is subject to compliance with all applicable laws and regulations, including those relating to anti-money laundering, counter-terrorist financing, sanctions, fraud prevention, and financial crime.

Finturu maintains internal compliance procedures designed to support these obligations and operates in coordination with its financial partners to ensure adherence to regulatory standards. Users agree not to use the Services for unlawful purposes or in a manner that could expose Finturu or its partners to regulatory, financial, or reputational risk.

Finturu reserves the right to monitor usage, investigate potential violations, and take appropriate action, including the immediate suspension or termination of access, where necessary. This includes, without limitation, violations of applicable laws or regulations, as well as breaches of Finturu's internal security policies and procedures, including its Acceptable Use Policy (AUP) and information security standards. Certain compliance-related determinations, including account approval, transaction restrictions, reporting obligations, or transaction limits, may be performed by sponsor banks or regulated entities and are outside the direct control of Finturu.

6. THIRD-PARTY SERVICES AND INTEGRATIONS

The Services rely on integrations with third-party providers, including regulated financial institutions, program sponsors, logistics providers, e-commerce platforms, and communication channels, which enable Finturu to deliver a unified infrastructure across domestic and international operations.

Finturu integrates with financial infrastructure partners such as Bridge and sponsor banks such as Lead Bank, as well as with payment processors, compliance providers, and identity verification services required to support regulated financial activities.

The platform also connects with leading e-commerce platforms and marketplaces, including Shopify, WooCommerce, Tiendanube, and Amazon, enabling business customers to manage multichannel commerce operations. In addition, Finturu integrates with logistics and fulfillment providers such as FedEx, DHL, and other regional or international carriers to support shipping, delivery, and order management.

Finturu may further support integrations with digital communication and social commerce channels, including WhatsApp, Instagram, and Facebook, which may be used to facilitate customer engagement, payment link distribution, and transaction workflows.

Additional third-party providers may be integrated into the platform from time to time and will be clearly identified within the platform interface.

Finturu does not own, control, or operate any third-party services. Each provider is solely responsible for its services, performance, regulatory compliance, and contractual obligations. The inclusion of any third-party provider does not imply endorsement, affiliation, or joint venture.

7. DATA PROCESSING AND INFORMATION SHARING

Finturu processes personal and business data as necessary to provide the Services, comply with regulatory obligations, and support operational functionality. This includes the collection, use, and sharing of data with financial institutions, program sponsors, compliance providers, infrastructure partners, and other service providers involved in the delivery of the Services.

Users acknowledge that such data sharing is necessary to enable regulated financial services, including identity verification, fraud prevention, transaction monitoring, and compliance with applicable laws. Failure to provide required information may result in denial, restriction, or suspension of access to certain Services.

All data processing activities are conducted in accordance with the Company's Privacy Policy and applicable data protection regulations. Customer account data is generally retained for the duration of the customer relationship and is scheduled for deletion within sixty (60) days following termination of the applicable contract, in line with the Company's Data Management Policy, except where a longer retention period is required or permitted to comply with anti-money laundering and counter-terrorist financing (AML/CFT) obligations, tax or accounting requirements, ongoing dispute resolution, or other applicable legal or regulatory requirements.

8. FUNDS FLOW AND SETTLEMENT

Finturu does not hold, receive, or custody customer funds. All funds processed through the platform are received, held, and settled by regulated financial institutions, sponsor banks, or authorized payment partners.

Depending on the service used, funds may be processed by sponsor banks such as Lead Bank or other regulated financial partners and subsequently settled to users in fiat currency or other supported formats, in accordance with the applicable financial infrastructure.

Settlement timelines, currency conversions, foreign exchange spreads, and availability of funds may vary depending on the payment method, jurisdiction, regulatory requirements, and financial partner involved.

9. REGULATED AND NON-REGULATED SERVICES

Finturu provides a technology and orchestration platform and does not itself provide regulated financial services. Certain functionalities available through the platform may constitute regulated financial services and are provided by licensed financial institutions or partners.

Users acknowledge that such services are subject to the terms, conditions, and regulatory oversight of the relevant financial institution, including sponsor banks and financial service providers.

10. RISK DISCLOSURE

Use of the Services involves inherent operational, financial, and regulatory risks. Users acknowledge and accept that Finturu operates solely as a technology and orchestration platform and does not assume custody, control, or safeguarding responsibilities over customer funds.

All funds processed through the platform are handled by regulated financial institutions, including sponsor banks, payment processors, and settlement partners. As a result, funds may be subject to delays, restrictions, reversals, holds, or compliance reviews imposed by such institutions in accordance with applicable regulatory frameworks.

Finturu does not provide deposit insurance, guarantee the availability of funds, or assume responsibility for the performance, solvency, or regulatory standing of any financial partner. The availability and timing of funds may depend on multiple external factors, including payment method, jurisdiction, regulatory requirements, and operational conditions of third-party providers.

Users further acknowledge that transaction execution, settlement timing, and currency conversion may be impacted by third-party infrastructure, including foreign exchange fluctuations, applicable spreads, and processing conditions imposed by financial partners. By using the Services, users expressly accept these risks and agree that Finturu shall not be held liable for any outcomes arising from such dependencies.

11. SERVICE AVAILABILITY AND DEPENDENCY

Finturu provides access to a distributed and interoperable infrastructure composed of multiple thirdparty systems, including financial institutions, payment networks, logistics providers, and ecommerce platforms. The availability and performance of the Services are therefore inherently dependent on such external systems.

While Finturu makes commercially reasonable efforts to ensure service continuity, it does not guarantee uninterrupted access. Service interruptions, delays, or degradation may occur due to maintenance, system updates, failures in banking infrastructure, downtime in payment networks, regulatory actions, or disruptions affecting integrated platforms such as Shopify, Amazon, FedEx, DHL, WhatsApp, Instagram, or Facebook, among others that may be incorporated into the platform over time.

Users acknowledge that certain functionalities may be temporarily unavailable or limited due to factors beyond Finturu's control, and that such conditions are inherent to the nature of interconnected financial and operational systems.

12. FEES, PRICING AND ECONOMIC CONDITIONS

Use of the Services is subject to applicable fees, which may include transaction fees, processing fees, foreign exchange spreads, settlement costs, and other service-related charges. Such fees are disclosed through the platform, applicable agreements, or pricing schedules.

Fees may vary depending on transaction type, geography, currency, risk profile, and the financial partner involved in the transaction flow. Certain economic conditions, including foreign exchange rates and banking-related charges, may be determined by third-party financial institutions and are outside the direct control of Finturu.

Finturu reserves the right to update its pricing structure from time to time to reflect changes in market conditions, regulatory requirements, or operational costs. Continued use of the Services following such updates constitutes acceptance of the revised pricing.

13. TRANSACTION LIMITS, CONTROLS AND RESTRICTIONS

Finturu, together with its financial partners, may impose transaction limits, velocity controls, and usage restrictions as part of its compliance and risk management framework. Such controls may be applied dynamically and may reflect regulatory requirements, risk assessments, or operational considerations.

These limitations may affect transaction volumes, frequency, geographic scope, or access to specific functionalities. Users acknowledge that such restrictions may be implemented, modified, or enforced without prior notice where necessary to ensure compliance with applicable laws or to mitigate financial or operational risk.

Finturu shall not be liable for any losses, delays, or limitations resulting from the application of such controls, particularly where they originate from regulatory obligations or third-party financial institutions.

14. CONFIDENTIALITY AND DATA SECURITY

Each party agrees to maintain the confidentiality of non-public, proprietary, or sensitive information disclosed in connection with the Services. Such information shall be used solely for the purposes of fulfilling obligations under these Terms or as otherwise required by law.

Finturu implements commercially reasonable administrative, technical, and organizational safeguards designed to protect user data and ensure the integrity of its systems. These safeguards are aligned with recognized industry standards, including control frameworks commonly associated with SOC 2 compliance.

Compliance monitoring, audit traceability, and control enforcement are supported through internal systems and third-party compliance infrastructure, including platforms such as Vanta, which support continuous oversight, documentation management, and audit readiness.

Information may be disclosed to regulatory authorities, financial partners, or service providers where necessary to comply with legal obligations or to support the provision of the Services.

15. INTELLECTUAL PROPERTY

All intellectual property rights associated with the platform, including software, APIs, data models, system architecture, branding, and proprietary methodologies, remain the exclusive property of Finturu or its licensors.

Users are granted a limited, non-exclusive, non-transferable, and revocable right to access and use the Services strictly in accordance with these Terms. No ownership rights are transferred as a result of such use.

16. LIMITATION OF LIABILITY

To the maximum extent permitted by applicable law, Finturu shall not be liable for indirect, incidental, consequential, special, or punitive damages, including but not limited to loss of profits, revenues, business opportunities, or data, arising out of or in connection with the use of the Services.

Finturu's total liability, under any circumstance, shall be limited to the amount of fees paid by the user to Finturu in connection with the Services during the relevant period.

Finturu shall not be liable for actions or omissions of financial institutions, sponsor banks, payment processors, logistics providers, or any third-party service providers integrated into the platform, including but not limited to delays in settlement, fund availability, transaction execution, or service interruptions.

17. INDEMNIFICATION

Users agree to indemnify, defend, and hold harmless Finturu, its affiliates, officers, directors, employees, and partners from and against any claims, liabilities, damages, losses, or expenses arising from or related to their use of the Services, including any violation of these Terms or applicable laws and regulations.

This obligation includes, but is not limited to, disputes arising between users and third parties, misuse of the platform, or unauthorized activities conducted through the user's account.

18. GOVERNING LAW AND DISPUTE RESOLUTION

These Terms shall be governed by and construed in accordance with the laws of the State of Florida, United States, without regard to conflict of law principles.

Any dispute arising out of or in connection with these Terms shall be submitted to the competent courts of such jurisdiction, unless otherwise agreed between the parties.

19. MODIFICATIONS AND CONTINUOUS IMPROVEMENT

Finturu reserves the right to modify, update, or enhance these Terms at any time to reflect changes in its services, regulatory environment, or operational structure.

Updated Terms will be made available through the platform or other appropriate communication channels. Continued use of the Services following such updates constitutes acceptance of the revised Terms.