REAL VIRTUAL ASSET VENTURE (PTY) LTD TERMS OF SERVICE Last updated: 30 April 2025

IMPORTANT NOTICE These Terms of Service constitute a legally binding agreement between: • REAL VIRTUAL ASSET VENTURE (PTY) LTD (registration number 2024/767369/07) (“RVAV”, “we”, “our”, “us”), a private company incorporated in the Republic of South Africa and a juristic representative of FINCOR SELECT (PTY) LTD, an authorised Category 1 Financial Services Provider (FSP No. 36046) licensed by the Financial Sector Conduct Authority (“FSCA”); and • the natural or juristic person who accesses or uses the Services (“you”, “your”, “User”).

By accessing or using any Service, you acknowledge that you have read, understood and agreed to be bound by these Terms, including all policies referenced herein (collectively, the “Agreement”). If you do not agree, do not use the Services.

Crypto assets are high‑risk, unregulated (in respect of certain activities) and may lose all value. You should obtain independent professional advice before dealing in crypto assets.

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1 DEFINITIONS “Account”               

A User account created with RVAV for access to the Services.
“Applicable Law”   Any law, regulation, directive, notice, guidance, rule or requirement issued by a competent authority and binding in the Republic of South Africa, including but not limited to the FAIS Act 37 of 2002, the Financial Intelligence Centre Act 38 of 2001 (“FICA”), the Protection of Personal Information Act 4 of 2013 (“POPIA”), the Electronic Communications and Transactions Act 25 of 2002 (“ECTA”), the Consumer Protection Act 68 of 2008, the Companies Act 71 of 2008, any FSCA Board Notices and Guidance, the Exchange Control Regulations, and the Financial Sector Regulation Act 9 of 2017.
“CASP”                  

A Crypto‑Asset Service Provider as defined in FAIS Board Notice 90 of 2022.
“Crypto Asset”    

A digital representation of value that is not issued by a central bank but is traded, transferred or stored electronically for payment, investment or other purposes.
“Exchange Order” An instruction submitted via the Platform to exchange one Crypto Asset for another or for fiat currency.
“Fees”                    

All charges published on the Platform or disclosed to you before you confirm an Exchange Order.
“Platform”              

The web application, mobile application, APIs and any other technology through which RVAV provides the Services.
“Prohibited Jurisdiction” Any jurisdiction listed in clause 10.3.
“Services”               

The Crypto‑Asset exchange, transfer, custody and related services offered by RVAV as described in clause 4.

Terms defined in the singular include the plural and vice versa.

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2 REGULATORY STATUS

2.1 RVAV renders crypto‑asset related financial services as a juristic representative of Fincor Select (Pty) Ltd in terms of section 13 of the FAIS Act. All such services fall under Fincor Select’s licence (FSP 36046).
2.2 RVAV is registered with the Financial Intelligence Centre as an accountable institution (FICA Schedule 1, Item 22).
2.3 RVAV is not a bank, deposit‑taking institution or collective investment scheme. Crypto Assets are not legal tender, not protected by the Deposit Insurance Fund and not guaranteed by any government.

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3 ELIGIBILITY

3.1 You must:
   (a) be at least 18 years old (or the age of majority in your jurisdiction);
   (b) have full legal capacity;
   (c) not be a resident, citizen or incorporated in a Prohibited Jurisdiction; and
   (d) not be subject to any sanctions administered by the UN, EU, OFAC or the South African government.
3.2 By opening an Account, you represent and warrant that the above requirements are met and that you act on your own behalf and not as agent, trustee or representative of another person, unless explicitly approved by RVAV in writing.

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4 DESCRIPTION OF SERVICES

4.1 RVAV provides the following Services to eligible Users:
   (i) facilitating peer‑to‑peer and order‑book exchanges of Crypto Assets;
   (ii) converting Crypto Assets to South African Rand (“ZAR”) or other supported fiat currencies and vice versa;
   (iii) providing hosted or non‑custodial wallets;
   (iv) transmitting Crypto Assets on behalf of Users; and
   (v) ancillary tools such as price data, reporting and staking (where permitted).
4.2 RVAV does not provide investment advice or portfolio management and nothing on the Platform constitutes a recommendation.

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5 ACCOUNT OPENING & KYC

5.1 You must complete all on‑boarding steps, including identity verification, proof of address, source‑of‑funds and ongoing monitoring, as required by FICA and RVAV’s internal risk‑based policies.
5.2 RVAV may request additional information at any time. Failure to comply may result in suspension or termination.
5.3 You authorise RVAV to make any enquiries, directly or through third parties, to verify your identity.

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6 EXCHANGE ORDERS & EXECUTION

6.1 An Exchange Order constitutes a binding offer. Once you confirm, it cannot be cancelled except where allowed under clause 6.4.
6.2 Rates are displayed inclusive of Fees and are valid for 15 minutes unless otherwise stated.
6.3 If we receive a payment that is less or more than the confirmed amount, RVAV may (a) adjust the Exchange Order to the amount actually received at the prevailing Rate, or (b) return the excess or deficit (if technically feasible), less network fees.
6.4 RVAV reserves the right to refuse, reverse or cancel any Exchange Order where:
   (a) we suspect the transaction is linked to money laundering, terrorism financing, fraud or other illicit activity;
   (b) the Rate displayed was an obvious error; or
   (c) required by Applicable Law, a court order or a regulatory authority.

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7 FEES & PAYMENTS

7.1 Current Fees are published on the Platform and/or disclosed prior to transaction confirmation.
7.2 Fees are automatically deducted from the amount exchanged or debited separately.
7.3 All blockchain network fees are borne by you unless expressly waived.

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8 RESTRICTED JURISDICTIONS & ACTIVITIES

8.1 The Services are intended solely for Users located in South Africa and other jurisdictions that do not prohibit crypto‑asset activities.
8.2 You may not use the Services for gambling, darknet markets, tumblers/mixers, ransomware, purchase of prohibited goods or any activity contrary to Applicable Law.
8.3 The following jurisdictions are Prohibited Jurisdictions: Afghanistan, Belarus, Central African Republic, Crimea, Cuba, Democratic Republic of the Congo, Iran, Iraq, Lebanon, Libya, Myanmar, North Korea, Russia, Sudan, Syria, United States of America (including its territories), Venezuela and any jurisdiction subject to comprehensive sanctions. RVAV may update this list at any time.

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9 RISK DISCLOSURE

9.1 Crypto Assets are volatile and may lose all value. Past performance is not indicative of future results.
9.2 Transactions are irreversible once recorded on a blockchain. Incorrect addresses or tags may result in permanent loss.
9.3 Regulatory changes may adversely affect the value or legality of Crypto Assets.
9.4 You acknowledge that you have been warned of the risks and accept full responsibility.

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10 TAXES

You are solely responsible for determining and paying any taxes arising from your activities. RVAV does not provide tax advice. Transaction histories are available for download to assist with tax reporting.

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11 DATA PROTECTION

11.1 RVAV processes personal information in accordance with POPIA and its Privacy Notice (available on the Platform).
11.2 By using the Services, you consent to such processing, international data transfers and disclosure to third‑party service providers for identity verification, fraud detection and similar purposes.

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12 INTELLECTUAL PROPERTY

All logos, trademarks, software and content displayed on the Platform are owned by or licensed to RVAV. You may not copy, modify, distribute or create derivative works without our prior written consent.

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13 SUSPENSION & TERMINATION

13.1 RVAV may suspend, restrict or terminate your access immediately if we believe you have breached this Agreement, Applicable Law, or if required by a competent authority.
13.2 You may close your Account at any time provided that (a) no outstanding disputes exist and (b) all balances are withdrawn. Certain provisions will survive termination (e.g. liability, dispute resolution).

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14 LIMITATION OF LIABILITY

14.1 To the fullest extent permitted by law, RVAV, its directors, officers, employees and representatives shall not be liable for any indirect, consequential, punitive or special loss, including loss of profits, data, goodwill or opportunity.
14.2 RVAV’s aggregate liability in any 12‑month period shall not exceed the total Fees paid by you to RVAV in that period.
14.3 Nothing in this Agreement limits liability for fraud, gross negligence or any liability that cannot be excluded under South African law.

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15 FORCE MAJEURE

RVAV shall not be responsible for any delay or failure to perform resulting from events beyond its reasonable control, including but not limited to acts of God, power failure, war, civil unrest, cyber‑attacks, labour disputes, changes in law or blockchain network congestion.

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16 COMPLAINTS & DISPUTE RESOLUTION

16.1 Internal complaints procedure. If you are dissatisfied with the Services, please contact our Compliance Officer at compliance@rvavcrypto.com or via the in‑app chat. Provide your name, Account email, transaction reference (if applicable) and a brief description of the complaint. We will acknowledge receipt within 5 Business Days and endeavour to resolve the complaint within 15 Business Days.

16.2 Escalation to Fincor Select. As RVAV acts under Fincor Select’s licence, you may refer an unresolved complaint to Fincor Select (Pty) Ltd – Complaints Department, complaints@fincor.co.za.

16.3 FAIS Ombud. If your complaint relates to a financial service and remains unresolved after 6 weeks, or if you are dissatisfied with the outcome, you may lodge a complaint with the Office of the FAIS Ombud (contact details at www.faisombud.co.za) within 6 months.

16.4 Arbitration. Any dispute that cannot be resolved through the above process shall be referred to confidential arbitration under the Arbitration Foundation of Southern Africa (“AFSA”) rules. The tribunal shall consist of one arbitrator with expertise in crypto‑asset law. The seat of arbitration shall be Johannesburg, South Africa. The language shall be English. The arbitrator’s award shall be final and binding and may be made an order of any competent court.

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17 ANTI‑MONEY LAUNDERING & COUNTER‑TERRORIST FINANCING

17.1 You undertake to comply with all AML/CFT obligations in terms of FICA, including, but not limited to, providing true and complete KYC information, co‑operating with enhanced due‑diligence requests and refraining from structuring transactions to avoid reporting thresholds.

17.2 RVAV reserves the right to freeze or block any funds and to file suspicious‐transaction reports with the Financial Intelligence Centre without notice.

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18 MODIFICATIONS TO THE TERMS

18.1 RVAV may amend these Terms by posting the revised version (with a new “Last updated” date) on the Platform. Changes will take effect 14 days after posting unless a shorter period is required by law. Continued use of the Services after the effective date constitutes acceptance.

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19 GOVERNING LAW & JURISDICTION

This Agreement is governed by the laws of the Republic of South Africa. Subject to clause 16, you consent to the non‑exclusive jurisdiction of the High Court of South Africa.

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20 NOTICES

20.1 Notices to RVAV must be sent by email to legal@rvavcrypto.com and will be deemed received on the next Business Day. RVAV may give notices by email to your registered email address or by posting on the Platform.

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21 SEVERABILITY

If any part of this Agreement is found unenforceable, the remainder will remain in full force and effect.

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22 ASSIGNMENT

You may not assign or transfer any rights or obligations under this Agreement without RVAV’s prior written consent. RVAV may assign its rights and obligations to an affiliate or successor in connection with a merger, acquisition or sale of assets.

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23 ENTIRE AGREEMENT

These Terms, together with the Privacy Notice and any additional policies or agreements referenced herein, constitute the entire agreement between you and RVAV and supersede all prior understandings.

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24 CONTACT INFORMATION

REAL VIRTUAL ASSET VENTURE (PTY) LTD
Registration No. 2024/767369/07
Email: team@rvavcrypto.com
Website: https://rvavcrypto.com
Registered office: 18th Floor, The Pinnacle, 1 Rivonia Road, Sandton, 2196, South Africa (correspondence only).