Last updated: June 2025

These Terms and Conditions (the “Terms”) govern the procedure for accessing and using the software services via the website https://fintap.app, the Fintap mobile application and the related products (“Fintap”, the “Services”, the “Service” or the “Platform”) provided by FREEFLOW FINANCE S.A. de C.V., registered in the Republic of El Salvador (“we”, “us”, “our”).

By obtaining access, registering or using any Fintap Service you confirm that you have read, understood and agreed to comply with these Terms in full. We therefore recommend that you read this document carefully and refrain from using the Services if you do not agree with these Terms.

Any actions performed by you on the Platform are undertaken in full awareness of all associated risks and exclusively on the basis of your own knowledge and at your own discretion.

We do not offer financial or investment advice. We provide technological services and do not give any recommendations regarding transactions or operations with digital assets.

1. Eligibility

In order to have the right to use and interact with our Services, you must warrant that:

• a) you have reached the age of majority in your country of residence and therefore possess the legal capacity to enter into and comply with agreements;
• b) you have never been suspended or otherwise restricted from using our Services;
• c) the conclusion of a legally binding agreement with us does not contradict and does not violate any other contractual obligations by which you are legally bound;
• d) you are not located in, resident of, or otherwise subject to any restricted territory or jurisdiction subject to sanctions imposed by the EU, El Salvador or the United Nations;
• e) you are not identified as an individual officially classified as a Specially Designated National (“SDN”) or affiliated with companies, groups or organisations classified as SDN;
• f) you are not subject to any international sanctions, including sanctions of the EU, El Salvador and the United Nations, nor are you an affiliate of companies, groups or organisations subject to international sanctions.

By creating an account (“Account”) you represent that you have the legal capacity to enter into agreements and agree to be legally bound by these Terms in full.

We reserve the right at any time to assess your entitlement to access and use our Services by checking your compliance with the eligibility criteria listed above. If the eligibility criteria are amended, modified or expanded we may review your entitlement accordingly. Fintap may require you to provide evidence of compliance. Any decision, including initial and ongoing assessments and reviews of your entitlement, is final and made at our sole discretion.

You undertake to refrain from using our Services to finance, support or participate in any unlawful activity, including, without limitation, prohibited trade, illegal gambling, fraud, money‑laundering or terrorist activity.

2. Nature of the Services

Fintap functions as non‑custodial digital‑wallet software intended for digital assets such as cryptocurrencies. This means that you, and only you, have full control and responsibility for your Digital Assets and private keys, thereby authorising transactions from your wallet address autonomously. Because Fintap operates as non‑custodial wallet software, all related actions and any potential losses remain entirely under your control at all times.

Fintap enables you to:

• a) generate wallet addresses and related private keys that allow you to send and receive various digital assets;
• b) buy, sell and swap digital assets;
• c) obtain access to digital‑asset price information provided by independent third‑party service‑providers.

Fintap does not store or control users’ private keys and cannot gain access to your funds. You are fully responsible for safeguarding your private keys, seed phrases and wallet credentials.

We do not offer financial, investment, legal or tax advice, nor do we provide any custody, exchange or brokerage services. Nothing on the Platform shall be construed as an offer or recommendation to invest or trade.

Remember that using the features and services of Fintap implies your acceptance of the risks associated with managing digital assets and transactional activity, including network volatility, cybersecurity threats and market volatility.

By using our Site and Services you unconditionally assume full responsibility for your actions under the tax laws applicable at your place of residence with respect to any transactions carried out on the Site, including, without limitation, income or gains tax.

3. Third‑Party Providers

The Platform may comprise integrations with third‑party providers (payment systems, exchange APIs, etc.), for example:

• crypto‑assets such as Ethereum and Bitcoin;
• cryptocurrency exchanges;
• information providers (for price data, market data and other relevant information).

Our Platform connects you to various services provided by our partners, including, without limitation, crypto‑to‑crypto swaps, the purchase and sale of cryptocurrencies, services for displaying fiat balances and cryptocurrency exchange rates. Please note that we do not control these third‑party services (“Third‑Party Services”).

Your interaction with such Third‑Party Services and the associated informational content, products or services (“Third‑Party Content”) is strictly voluntary, and any use of such content is at your own risk. Although this Agreement governs your interaction with our Service, your interaction with Third‑Party Content and Services is likely to be governed by additional terms established by the relevant third‑party providers. Such additional terms may include separate fees, disclaimers, risk warnings and privacy policies that differ from ours. You are responsible for understanding and acknowledging those terms, including how such providers process your personal information.

By interacting with Third‑Party Services you confirm that you have read, understood and agreed to the provider’s terms. While we endeavour to partner with reputable organisations, we neither endorse nor guarantee their offerings and disclaim all liability arising from your use of those services.

4. Fees, Charges and Commissions

Fees connected with the Services or any part thereof are primarily established by our third‑party partners and are available on fintap.app and/or in the Fintap mobile application. Such fees may include, inter alia, account‑maintenance fees, transaction fees, withdrawal fees, gas fees (network processing power) or fees for specific services offered by our partners. These fees are controlled by third‑party organisations, and we neither influence nor regulate the creation or alteration of such fees.

We emphasise that these fees are levied by third‑party organisations that we do not control and do not influence in terms of creating or adjusting fees. Those partners reserve the right to revise their fee structures at their own discretion.

In certain cases Fintap may receive a share of the revenue from such fees charged by third parties. However, receipt of such revenue does not grant us any authority to control or make decisions regarding those fees.

Fee information may change without prior notice. Any update or adjustment to the fee structure will be reflected promptly on our website and/or in the mobile application. Your continued use of our Services after such updates signifies your acceptance of those changes. We recommend that users regularly check our website and mobile application to remain aware of the current fee schedule.

Once published online, any new fee information takes effect immediately unless stated otherwise. You are responsible for remaining informed of the current fee structure.

It is also important to understand that third‑party services, including blockchain networks, may charge additional fees for processing transactions. These additional fees are outside our jurisdiction and influence. Accordingly, we disclaim all liability for fees charged by third‑party services.

Your virtual‑currency transactions may entail transactional fees such as mining fees that are prescribed by the virtual‑currency system or the blockchain network you choose to use. Before initiating a transaction you are responsible for ensuring that your wallet has a sufficient balance and/or gas to complete the transaction in full.

We do not control or influence such fees or the mechanisms for setting fees in third‑party systems. Consequently, we are not liable for any transaction failures or financial losses you may incur due to incorrectly entered transactional fees (for example, fees set too low or too high). This also applies to any issues arising from insufficient funds or gas associated with your wallet address.

5. Prohibited Conduct

When using the Platform you undertake to:

• a) comply with and respect these Terms;
• b) be responsible for all actions you perform using Fintap;
• c) provide us with any documents and information requested by us for compliance procedures;
• d) refrain from encouraging or inducing third parties to engage in any of the activities prohibited by this section;
• e) not impersonate another person and not allow or attempt to authorise another user’s wallet without permission, and, in addition, refrain from any use of our Services that could interfere with, disrupt, negatively affect or prevent other users from fully using our Services;
• f) not distribute viruses or other malicious computer code through Fintap;
• g) not perform any actions that may create an unreasonable or disproportionately large load on our infrastructure or the infrastructure of any of our third‑party providers;
• h) not engage in reverse‑engineering, not circumvent and not attempt to circumvent any measures we may use to prevent or limit access to the Services, including, without limitation, other accounts, computer systems or networks connected to the Services;
• i) respect, do not violate, do not misappropriate and do not infringe the rights of Fintap, our users or other persons, including the right to privacy, publicity rights, intellectual‑property rights or any other proprietary rights.

We reserve the right to discontinue or modify some or all of our Services and to cease publication of our Website at any time at our sole discretion without explanation; and, except as expressly provided in these Terms, you will not be entitled to any compensation or other payment in the event of discontinuation or modification of any Services or if we cease publishing the Website.

Breach of these Terms

Without prejudice to our other rights under these Terms, if you breach these Terms in any way, or if we have reasonable grounds to suspect that you have breached these Terms in any way, we may:

• (a) send you one or more formal warnings;
• (b) temporarily suspend your access to our Platform;
• (c) permanently prohibit you from accessing our Platform;
• (d) block access to our Platform from devices using your IP address;
• (e) suspend or delete your Account on our Platform.

If we suspend, prohibit or block your access to our Platform, you must not take any action to circumvent such suspension, prohibition or blocking.

Fintap reserves the right to report suspicious activity to law‑enforcement and regulatory authorities.

6. Copyright Notice

Subject to the express provisions of these Terms:

• (a) we, together with our licensors, own and control all the copyright and other intellectual‑property rights and material on our Platform; and
• (b) all the copyright and other intellectual‑property rights and material on our Platform are reserved.

You are not entitled to copy, reproduce or distribute any part of the Platform without our prior written consent.

7. No Warranties

The Platform and Services are provided on an “as is” and “as available” basis. To the maximum extent permitted by law, we make no express or implied representations or warranties regarding:

• the accuracy, reliability, availability, timeliness or completeness of any information, content or services provided or owned by us or any third party or contained in any third‑party materials or on any third‑party websites available or linked to our Platform or Services, including, without limitation, warranties of merchantability, fitness for a particular purpose, title, non‑infringement, absence of computer viruses, or that the results of using the Services will meet your requirements, and any implied warranties;
• the availability, functionality, continuity, error‑free nature, timeliness or uptime of the Services;
• the security or integrity of blockchain networks or third‑party integrations.

8. Limitation of Liability

To the maximum extent permitted by law, we and our affiliates, suppliers and contractors shall not be liable for any direct, indirect, incidental, punitive or special losses, including loss of data or loss of digital assets, arising from the use of or inability to use the Platform regardless of cause.

• interruptions of access to the Services and/or delays or losses in data transmission caused by hardware failures, software failures or communications systems failures beyond our control (for example, power outages, telephone‑line failures or connection problems caused by the user’s internet‑service provider or special software installed on the user’s device);
• potential failures, interruptions, errors or delays in processing operations during your use of the Services;
• any unauthorised access and/or fraudulent use of the Platform using the user’s personal access codes arising as a result of the user’s negligence (for example, insufficient protection of the secrecy of access codes from theft or the transfer of computer viruses);
• the possibility of unauthorised third‑party access to your wallet information, including, without limitation, your wallet address, private key and seed phrase;
• the risk of introduction or detection of malicious software in Fintap, bugs or other malfunctions in the Fintap software;
• the risk of unknown vulnerabilities or unforeseen changes in relevant blockchain networks;
• the inability to gain full access to Fintap Services;
• any other issues concerning the Platform or any other aspect of the Services;
• the occurrence of any force‑majeure event.

You acknowledge and accept that Fintap cannot control and is not obliged to act in any of the cases listed above.

Fintap is not responsible for any losses or for fluctuations in the exchange rates and values of the virtual currencies credited to your Account.

You hereby release us from any damages, harm, costs, losses, claims, liabilities and expenses (including, without limitation, legal expenses and any amounts paid by us to a third party in settlement of a claim or dispute) incurred or suffered by us directly or indirectly as a result of your use of the Platform or any breach by you of any provision of these Terms.

We shall in no case be liable, beyond the amount of USD 150, for any direct or indirect damages caused, regardless of whether such damages were caused by the negligence of our employees or by any other reason. We shall not be liable for any indirect, special, incidental or consequential damages. Notwithstanding the foregoing, we do not exclude liability for any condition or warranty that cannot be excluded under the law of El Salvador.

We may suspend or terminate your access to the Platform without prior notice:

• if you do not comply, or we have reasonable grounds to believe that you do not comply, with any of your obligations under these Terms and/or you breach any provision of these Terms;
• if this is required under applicable law or by a regulatory body;
• if you use Fintap for unlawful or criminal purposes;
• if you engage in other unlawful activity or behaviour violating the Terms, or create circumstances under which we find it necessary to suspend the performance of certain functions.

You may discontinue use at any time by ceasing access to the Platform.

9. Amendments

We are entitled to amend, modify or adapt our Services or any part of our Services in accordance with these Terms. Any changes take effect from the moment of publication on the Platform. Continued use after such changes signifies agreement.

You hereby agree that we may assign, transfer, subcontract or otherwise deal with our rights and/or obligations under these Terms.

You may not, without our prior written consent, assign, transfer or otherwise deal with any of your rights and/or obligations under these Terms.

10. Severability

If any provision of these Terms is held by a court or other competent authority to be unlawful and/or unenforceable, the other provisions shall remain in force.

These Terms remain in force even if one or more provisions are invalid, unlawful or unenforceable. The validity of the remaining provisions is not affected.

11. Governing Law and Dispute Resolution

These Terms are governed by the laws of the Republic of El Salvador. Disputes arising in connection with these Terms shall be resolved in accordance with the laws of the Republic of El Salvador. In the event of any conflict between the laws of the Republic of El Salvador and these Terms, the laws of the Republic of El Salvador shall prevail.

12. Contact Information

If you need to contact us, or if you detect errors or encounter problems in our Services, or if you have a complaint, please contact us by sending an e‑mail to [email protected]. A representative will acknowledge receipt of your message and address your concerns fairly and promptly.

********

In the event of any discrepancies between the English text of these Terms and its translation into any other language, the English text of the Terms shall prevail, as shall the English version of any other documentation/information published on the Platform.

********

These Terms are effective from 30 June 2025 until replaced by a later version.

© 2025 FREEFLOW FINANCE S.A. de C.V. All rights reserved.