Last updated: February 2026

This Privacy Policy applies to all users of the Xolaxis Platform. Xolaxis Ltd does not serve US persons under its current Regulation S structure. If you are accessing from a restricted jurisdiction, please do not use the Platform.

1. Scope and Definitions

"Personal Data" is any information that identifies or can reasonably identify you, directly or indirectly - including name, email address, Telegram handle/ID, wallet addresses, IP address, device identifiers, transaction-related identifiers, and identity verification data such as passport or national ID details.

2. Data We Collect

Account data: email address, Telegram handle/ID, username, country/region, language settings. Verification data: legal name, nationality, government ID or passport details, proof of address, source-of-funds documentation, and enhanced due diligence materials as required by Licensed Custody Partner obligations. Deal and transaction data: deal terms and scope, amounts, wallet addresses, transaction hashes, timestamps, itemized receipts, evidence files, communication logs, dispute submissions. Device and usage data: device type, operating system, browser type, IP address, approximate location, session logs, security signals, and cookies (web Platform only).

3. How We Use Personal Data

We use Personal Data to operate and improve the Platform; coordinate deal custody release instructions to Licensed Custody Partners; authenticate users and prevent unauthorized access; detect and prevent fraud, abuse, and prohibited activity; conduct sanctions and AML screening; handle disputes and arbitration processes; maintain audit trails; provide user support; and comply with applicable legal and regulatory obligations. We may use aggregated or anonymized data for analytics and Platform improvement.

4. Legal Bases for Processing

Where applicable under local law, processing of Personal Data is based on one or more of: • Contract necessity: processing required to provide the Platform services; • Legitimate interests: security, fraud prevention, and Platform integrity; • Legal obligation: record-keeping and compliance requirements; • Consent: where required and separately obtained. The Platform does not serve US persons.

5. Sharing and Disclosures

We may share Personal Data with: • Licensed Custody Partners (to fulfill KYC/AML obligations for custody arrangements); • Independent arbitration panel members (case-specific, limited to relevant deal data); • Compliance and sanctions screening providers; • Hosting, infrastructure, and security service providers; • Professional advisors under confidentiality obligations; • Authorities where legally required by court order, law, or regulation. We do not sell, rent, or trade Personal Data to third parties for marketing purposes. In the event of a merger, acquisition, or asset sale, Personal Data may be transferred as part of the transaction, subject to equivalent privacy protections.

6. International Transfers

Xolaxis is incorporated in the British Virgin Islands. Personal Data may be processed by infrastructure providers or Licensed Custody Partners located in other jurisdictions. Where required, we apply appropriate safeguards including contractual data protection clauses and access controls.

7. Retention

We retain Personal Data for as long as necessary to: provide Platform services; resolve open or potential disputes; prevent fraud and abuse; and comply with legal and regulatory obligations. Minimum retention: five (5) years from the date of the last relevant transaction or account closure, or longer if required by law or ongoing legal proceedings. Blockchain transaction records (hashes, on-chain data) are immutable and cannot be deleted by Xolaxis or users.

8. Security

We implement reasonable technical and organizational safeguards including: encryption in transit and at rest; access controls and least-privilege permissions; multi-factor authentication for administrative systems; monitoring and anomaly detection; and regular security reviews. No method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your own account credentials and devices.

9. Your Rights

Depending on your jurisdiction, you may have rights to: access your Personal Data; correct inaccurate data; request deletion (subject to legal retention obligations); restrict or object to processing; and request data portability. We may require identity verification for privacy requests and may decline requests where processing is required for compliance, fraud prevention, active disputes, or legal obligations. To exercise your rights, contact: support@xolaxis.com

10. Cookies and Similar Technologies

The web Platform may use essential cookies for security, session management, and core functionality. Optional analytics tools may be used in aggregate form. You can control cookie preferences through your browser settings; disabling essential cookies may limit Platform functionality.

11. Marketing Communications

We may send service-related and transactional messages (deal updates, security alerts, policy changes) without separate marketing consent, as these are necessary to operate the service. Any optional marketing or promotional messages will include a clear opt-out mechanism.

12. Minors

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect Personal Data from minors. If we learn that a minor has provided Personal Data, we will take steps to delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email, in-Platform notification, or Telegram. Continued use of the Platform after the effective date of changes constitutes acceptance of the updated Policy.

Last updated: February 2026

IMPORTANT NOTICE: Xolaxis Ltd (Xolaxis) is not a financial institution, money services business, escrow agent, custodian, broker, dealer, or payment processor. Xolaxis operates exclusively as a technology service platform that facilitates deal coordination between parties. All fund custody services are provided by independent, duly licensed custody partners.

1. Overview and Acceptance

These Terms of Use (the "Terms") govern your access to and use of the Xolaxis platform, including the Telegram bot, website, dashboards, APIs, and related services (the "Platform"). By creating an account, opening a deal, or otherwise using the Platform, you agree to be bound by these Terms and by the incorporated policies: Payments and Custody Partner Terms, Dispute and Arbitration Rules, Privacy Policy, and Risk Disclosure Policy. If you do not agree, do not use the Platform.

2. Definitions

"Orderer" (or "Buyer") is the user who creates a deal and initiates payment to the licensed custody partner. "Executor" (or "Provider") is the user performing the task or service. "Deal" means the transaction agreement between an Orderer and an Executor facilitated through the Platform. "Digital Assets" means supported blockchain assets (at launch: USDT on TRON, TRC-20). "Custody Arrangement" means the temporary holding of Digital Assets by a Licensed Custody Partner on behalf of the Orderer, pending satisfaction of Release Conditions. "Licensed Custody Partner" means a third-party entity, duly licensed and regulated in its jurisdiction, that provides custody services to Platform users as a separate contractual relationship. Xolaxis is not a party to that custody relationship. "Release Conditions" are defined in the Payments and Custody Partner Terms. "Dispute" means a formal claim raised within the Platform that pauses release pending resolution.

3. Platform Role

Xolaxis provides a deal coordination workflow, communication infrastructure, and dispute facilitation interface. Xolaxis does NOT provide custody, escrow, money transmission, payment processing, or any financial service. All custody of Digital Assets is handled exclusively by Licensed Custody Partners operating under their own regulatory licenses and separate terms of service. 4. Regulatory Positioning and Scope Limitations

Xolaxis Ltd is not registered as, and does not operate as, any of the following in any jurisdiction: • A financial institution or bank • A money services business or money transmitter • An escrow agent or escrow company • A broker, dealer, or investment adviser • A payment processor or e-money institution • A securities exchange or alternative trading system The Platform does not hold, transmit, receive, or custody user funds at any point. All custody is performed by the Licensed Custody Partner under its own licensing obligations. Digital Assets held by a Licensed Custody Partner are not deposits and are not protected by deposit insurance or governmental guarantees. Users interact with custody services under the Licensed Custody Partner's terms, not Xolaxis's. The Platform does not match trading orders, does not provide margin or leverage, and does not offer investment products.

5. Jurisdictions

You must be at least 18 years old and have full legal capacity to enter into binding agreements in your jurisdiction. You must not be located in, a resident of, or acting on behalf of a sanctioned or prohibited jurisdiction or person (including but not limited to OFAC SDN list designees). The Company applies geo-restrictions and may denylist jurisdictions at any time without notice. The Platform does not serve users in the United States of America or its territories. By using the Platform, you represent that you are not a U.S. person as defined under Regulation S of the U.S. Securities Act of 1933. You are solely responsible for ensuring your use of the Platform is lawful in your jurisdiction.

6. Accounts and Security

You must provide accurate and current account information and keep it updated. You are responsible for safeguarding your credentials, devices, and communications channels (including Telegram). You must notify us promptly of suspected unauthorized access. Notices may be delivered via email, in-Platform notifications, or Telegram messages associated with your account.

7. Risk-Based Verification (KYC/EDD)

The Platform applies a risk-based approach to identity verification and enhanced due diligence on behalf of its Licensed Custody Partners. Verification may be required based on deal size, cumulative volume, counterparty request, risk signals, sanctions screening, dispute patterns, or regulatory requirements of the applicable Licensed Custody Partner. Indicative thresholds: single-deal threshold USD 1,000; rolling 30-day threshold USD 5,000; high-risk category triggers per Licensed Custody Partner policy. Xolaxis reserves the right to amend these thresholds and related verification requirements at any time.

At Xolaxis’ sole discretion, if we suspect fraud, misrepresentation, forged or unreliable documents, sanctions exposure, or other compliance or security risks, we may (i) require additional verification, (ii) place the deal and/or funds on hold, (iii) refuse to process or complete the transaction, (iv) suspend or terminate access, and/or (v) refer the deal and relevant information to our Licensed Custody Partner for review and handling in accordance with their policies and applicable law.

8. Prohibited Use

You must not use the Platform for unlawful activity, fraud, deception, money laundering, terrorist financing, sanctions evasion, or any activity requiring a regulatory license without holding such license. Prohibited categories include, without limitation: weapons, controlled substances, human trafficking, exploitation, stolen goods, counterfeit goods, and infringement of third-party rights. The Company may block deals, pause custody releases via the Licensed Custody Partner, suspend accounts, and report to authorities as required by law.

9. User Content

Users may upload content (including messages, files, receipts, photos, videos) as part of a deal or dispute. You represent you have rights to upload such content and that it is accurate and lawful. You grant the Company a limited license to host, process, store, and disclose such content for platform operation, security, compliance, dispute resolution, and legal obligations. Evidence standards and receipt requirements are defined in the Payments and Custody Partner Terms and Dispute Rules.

10. Modifications, Suspension, Termination

The Company may modify, suspend, or discontinue any part of the Platform at any time for security, compliance, legal, operational, or business reasons. The Company may suspend or terminate accounts and coordinate pause of custody releases with the Licensed Custody Partner where it reasonably believes there is a policy violation, fraud, sanctions exposure, legal risk, or security incident. Platform availability may be impacted by changes in applicable laws; you may incur losses due to suspension or termination.

11. Disclaimers

The Platform is provided on an "as is" and "as available" basis. We do not warrant uninterrupted service, error-free operation, or that any deal will complete successfully.

Blockchain transfers are irreversible and subject to network conditions outside our control. Xolaxis bears no responsibility for losses arising from network congestion, smart contract failures, or custody partner downtime.

12. Website Content Disclaimer

The team profiles shown on the Site are illustrative and for presentation purposes only and do not represent current employees, officers, or contractors unless expressly stated. Any references to “partners” or “partnered with” describe prospective relationships that may be under discussion or in contracting, and do not constitute an existing partnership, agency, endorsement, or binding commitment unless and until a written agreement is executed.

13. Limitation of Liability

To the maximum extent permitted by law, the Company is not liable for indirect, incidental, special, consequential, exemplary, or punitive damages, including lost profits, lost data, or reputational harm. Our total liability arising out of or relating to a specific deal will not exceed the platform service fees actually received by the Company for that deal. Licensed Custody Partner services are provided by an independent third party under their own terms and policies. Xolaxis does not operate custody and does not control the Licensed Custody Partner’s performance. Accordingly, we do not guarantee the Licensed Custody Partner’s services (including availability, processing times, or outcomes) and are not responsible for their acts or omissions, except to the extent required by applicable law. Users transact with Licensed Custody Partners at their own risk. Nothing in these Terms limits liability that cannot be excluded under applicable law.

14. Indemnification

You agree to defend, indemnify, and hold harmless the Company, its affiliates, directors, officers, employees, contractors, and agents from any claims, damages, losses, and expenses (including reasonable attorneys' fees) arising from: your use of the Platform, your deals, your content, your violation of applicable law, or your infringement of third-party rights.

15. Governing Law, Venue, Dispute Resolution

These Terms are governed by and construed in accordance with the laws of the British Virgin Islands. Any dispute arising out of or in connection with these Terms shall be referred to and finally resolved by arbitration under the rules of the British Virgin Islands International Arbitration Centre (BVI IAC), or such other arbitration body as mutually agreed.

Notwithstanding the above, the Company reserves the right to seek injunctive or other equitable relief in any court of competent jurisdiction.

16. Miscellaneous

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

The Company reserves the right to amend, modify, or supplement these Terms of Use at any time, without prior notice.

The Company may assign these Terms as part of a merger, acquisition, restructuring, or asset sale without your consent. These Terms and all incorporated policies constitute the entire agreement between you and the Company regarding the Platform and supersede all prior agreements on the same subject.

Last updated: February 2026

Risks associated with Digital Assets, P2P deals, and the Platform

READ CAREFULLY: Using the Xolaxis Platform involves significant risks including total loss of Digital Assets. Xolaxis Ltd is not a financial institution, escrow agent, or custodian - all fund custody is performed by Licensed Custody Partners. This Policy does not constitute financial, legal, or investment advice.

1. Purpose and User Acknowledgement

This document describes the material risks associated with Digital Assets and the Xolaxis Platform and summarizes the controls applied to reduce operational, fraud, and compliance risk. By using the Platform, you acknowledge that you have read, understood, and accepted all risks described herein. You accept that you may lose part or all of the Digital Assets involved in a deal.

2. Regulatory and Legislative Risk

Laws and regulations governing Digital Assets, blockchain technology, and P2P platforms vary by jurisdiction and are subject to rapid change. Legislative or regulatory developments may: • Restrict or prohibit the use, transfer, or custody of Digital Assets; • Require the Platform to suspend services in certain jurisdictions; • Result in account restrictions, fund freezes, or mandatory reporting; • Affect the value or exchangeability of Digital Assets. You are responsible for ensuring your use of the Platform complies with all applicable laws in your jurisdiction.

3. No Government Oversight; No Deposit Insurance

Xolaxis Ltd is not registered as a broker, dealer, exchange, capital markets provider, money services business, escrow agent, or custodian in any jurisdiction. Digital Assets held by a Licensed Custody Partner are not bank deposits and are not protected by any deposit insurance scheme, governmental guarantee, or investor protection fund. In the event of the insolvency or failure of a Licensed Custody Partner, your Digital Assets may be at risk. Xolaxis bears no liability for Licensed Custody Partner insolvency.

4. Platform Availability Risk

The Platform may become unavailable due to: changes in applicable law; regulatory enforcement actions; third-party infrastructure failures; cybersecurity incidents; scheduled or emergency maintenance; or operational decisions by the Company. Platform unavailability may prevent you from accessing deal information, submitting evidence, or completing transactions. You may suffer losses as a result.

5. Technology and Internet Risk

Software bugs, hardware failures, security vulnerabilities, or internet instability may cause transaction delays, processing errors, or inability to execute instructions. Internet transmission is not fully reliable or secure. Service delays or data interception may occur despite reasonable safeguards.

Cybersecurity incidents, including hacking, malware, credential theft, and denial-of-service attacks, may disrupt Platform services, compromise accounts, or impair dispute handling despite reasonable safeguards.

6. Blockchain-Specific Risks

Blockchain networks carry inherent risks including: network congestion causing settlement delays; hard forks or protocol changes affecting asset compatibility; validator or node failures; smart contract bugs; and permanent loss of funds sent to incorrect addresses. Blockchain transactions are irreversible once confirmed. There is no mechanism to reverse an on-chain transfer, regardless of the circumstances.

7. Counterparty Risk in P2P Deals

All deals are agreements between users. Xolaxis is not a party to any deal. Risks include: • An Executor failing to perform as agreed; • An Orderer refusing to approve completed work in bad faith; • Either party providing false information, evidence, or representations; • Deal terms being ambiguous or incomplete. The Licensed Custody Partner arrangement and in-Platform dispute process mitigate but do not eliminate counterparty risk. You may suffer losses even after a dispute resolution process.

8. Dispute and Evidence Risk

Dispute outcomes depend on the quality and completeness of submitted evidence and the interpretation of deal terms. Risks include: evidence being incomplete, ambiguous, or disputed; arbitration decisions not matching your expectations; and enforcement limitations where funds have already been released on-chain. In-Platform arbitration outcomes may differ from outcomes in external legal proceedings.

9. Tax Risk

Proceeds, income, gains, and other amounts arising from Platform use may be subject to taxes, levies, duties, withholding, or other charges under applicable law. Tax treatment of Digital Assets is unclear and evolving in many jurisdictions and may change with retrospective effect. You are solely responsible for your own tax compliance. Xolaxis does not provide tax advice.

10. Risk Management Controls

The Company applies the following controls to mitigate risk: • Wallet address screening and OFAC/sanctions checks; • Risk scoring per deal and per user based on behavioral signals; • Tiered transaction limits and KYC triggers; • Geo-restrictions for prohibited jurisdictions; • Evidence standards and receipt verification for purchase-included deals; • Deal-level fund segregation by the Licensed Custody Partner; • Audit logging and anomaly detection; • Incident response and business continuity procedures. Controls may be adjusted at any time based on emerging risk signals or regulatory requirements.

11. Risk Triggers, Holds, Paused Releases

If risk triggers arise, the Company may instruct the Licensed Custody Partner to pause, delay, refuse, or return funds (where feasible) without prior notice and without giving you the opportunity to choose the timing, sequencing, or order of actions. Triggers may include: suspected fraud; sanctions exposure; account takeover; regulatory orders; system compromise; or unresolved KYC/EDD requests. Neither the Company nor the Licensed Custody Partner is liable for losses arising from lawful compliance holds or pauses.

12. Incident Response and Business Continuity

In a security incident, the Company may: suspend affected Platform features; coordinate with the Licensed Custody Partner to secure held assets; rotate access credentials; engage forensic and legal advisors; and notify affected users as required by law. Business continuity measures may include data backups, infrastructure redundancy, staged service restoration, and rollback procedures.

13. User Responsibilities

You are responsible for: • Using correct wallet addresses and blockchain networks for all transfers; • Maintaining the security of your account, devices, and communication channels; • Providing truthful, accurate, and complete information and evidence; • Keeping independent records of all deal terms, evidence, and communications; • Ensuring your use of the Platform is lawful in your jurisdiction; • Understanding and accepting all risks described in this Policy before using the Platform.

You must protect your devices and accounts against phishing, malware, SIM swap, and social engineering; never share private keys, seed phrases, or 2FA codes; and immediately report suspected compromise to support.

14. Cybersecurity and Security Incident Risk

The Platform and related services (including the Telegram bot, website, APIs, cloud infrastructure, and third-party tools) may be targeted by cyberattacks, including hacking, malware, ransomware, phishing, credential stuffing, SIM swap, social engineering, denial-of-service, insider threats, and exploitation of software vulnerabilities.

Even with reasonable safeguards, security incidents may result in unauthorized access, theft, loss of data, delays, suspension of services, inability to submit evidence, and/or inability to complete or enforce deals. Losses may be permanent and unrecoverable.

Xolaxis does not guarantee that the Platform will be free from cybersecurity incidents or that any incident can be prevented, detected, resolved, or remediated without delay.

15. Custody Partner and Third-Party Infrastructure Risk

All fund custody is performed by Licensed Custody Partners. Xolaxis does not control private keys, wallets, or custody operations, and does not guarantee the availability, performance, security, solvency, or outcomes of any Licensed Custody Partner.

Third parties (including hosting providers, messaging providers, screening vendors, and analytics providers) may be involved in Platform operations and may suffer outages or security incidents. Such third-party failures may affect Platform availability, processing times, or dispute handling.

In a security incident or risk event, Xolaxis may request that a Licensed Custody Partner place funds on hold, pause releases, return funds where feasible, or take other compliance actions in accordance with the Custody Partner’s policies and applicable law. Execution remains subject to the Custody Partner’s controls, compliance checks, and lawful restrictions.

16. Data Breach, Communications, and Confidentiality Risk

Electronic communications are not fully secure or reliable. Messages may be delayed, intercepted, misdelivered, or spoofed. You should treat any unexpected message requesting credentials, seed phrases, private keys, or 2FA codes as fraudulent.

A data breach may expose information submitted to the Platform (including deal terms, evidence files, chat logs, and identifiers). Xolaxis may be required to notify users and/or authorities depending on applicable law, but does not guarantee a specific notification timeline in all jurisdictions.

Users remain responsible for maintaining independent records of deal terms, receipts, and evidence outside the Platform for their own protection.

17. Incident Response Actions, Suspension, Cooperation

In the event of a suspected or confirmed security incident, Xolaxis may, without prior notice where permitted, suspend or restrict access to the Platform or specific features, disable accounts or sessions, rotate credentials, and require additional verification or evidence re-submission.

Xolaxis may place deals under review, pause dispute processing, extend response timelines, and coordinate with Licensed Custody Partners, vendors, forensic specialists, and legal advisors.

Xolaxis may preserve logs and records and share information with authorities where required or permitted by law. These actions may affect timing of releases and dispute resolution.

18. No Liability for Cyber Incidents Beyond Legal Minimum

To the maximum extent permitted by applicable law, Xolaxis is not responsible for losses arising from cybersecurity incidents, third-party outages, blockchain attacks, or compromise of user devices, accounts, or communication channels, including losses caused by phishing, social engineering, SIM swap, malware, or unauthorized access.

Nothing in this Policy limits liability that cannot be excluded under applicable law.

Last updated: February 2026

IMPORTANT: Xolaxis Ltd is not an arbitration institution. In-Platform dispute resolution is a facilitation service. Enforcement of panel decisions operates by instructing the Licensed Custody Partner to release or return held funds. Xolaxis is not a party to disputes between Orderers and Executors and does not guarantee any particular outcome.

1. Scope and Relationship to Terms

These Dispute and Arbitration Rules govern in-Platform disputes between Orderers and Executors and are incorporated into the Terms of Use and Payments and Custody Partner Terms. These Rules govern only in-Platform outcomes (release/return decisions as instructed to the Licensed Custody Partner). They do not prevent a party from seeking external legal remedies unless a binding arbitration clause is separately adopted.

2. Opening a Dispute

An Orderer or Executor may open a dispute within 48 hours after the Executor's submission event or any release-triggering event. Opening a dispute pauses all pending release instructions to the Licensed Custody Partner. If funds have already been released on-chain, in-Platform enforcement may be limited to an evidentiary record only. Only one active dispute may be open per deal at a time.

3. Evidence Standards

Parties must submit evidence relevant to the deal terms, which may include: itemized receipts, photos and videos, timestamps, delivery confirmations, communication logs, and agreed acceptance criteria. All evidence must be submitted through the Platform. Any evidence obtained, shared, or discussed outside the Platform (including private messages, external chats, emails, or other channels) is not considered valid evidence and will not be reviewed. If a party relies primarily on off-Platform evidence, the dispute may be closed in favor of the other party at Xolaxis’ sole discretion.

Submitting falsified, manipulated, or misleading evidence is strictly prohibited and may result in immediate account termination, permanent restrictions, and reporting to relevant authorities where required or permitted by law. Where funds have already been released, no refund will be issued.

4. Support Triage

Support will attempt to resolve disputes through clarification, additional evidence requests, and proposed settlement options. Support triage response within 7 business days of dispute opening. Support may impose evidence submission deadlines (minimum 24-hour notice) and may close a dispute if a party fails to respond within the stated deadline.

5. Independent Arbitration Panel

If not resolved by support triage, disputes may be escalated to an independent arbitration panel of 2-3 external qualified reviewers (not Company employees or affiliates). The panel’s decision may be reviewed at most once, solely at the Company’s discretion and only if there is clear evidence of a material error or newly discovered evidence that could not reasonably have been provided earlier.

Panel members review deal terms and submitted evidence and issue a written decision for in-Platform enforcement. Panel composition is determined by the Company based on deal type, value, and complexity. Parties may object to a panel member for demonstrated conflict of interest within 24 hours of notification.

6. Decision Standards

Decisions are based on: (a) written deal terms and defined scope; (b) quality and consistency of submitted evidence; (c) reasonableness of performance against deal criteria; (d) receipt verification for purchase-included deals. The panel may award: full release to the Executor; full return to the Orderer; or a partial split where supported by evidence and deal terms. Panel decisions are final within the Platform.

7. Timelines

Target timelines: • Support triage decision: within 7 business days of dispute opening • Panel escalation decision: within 21 calendar days after complete evidence is received Timelines may be extended for complex cases, pending KYC/EDD verification, compliance holds, or legal requests. The Company will notify affected parties of material extensions.

8. Binding In-Platform Enforcement

Panel decisions are binding within the Platform. Following a final decision, the Company will promptly submit the decision and a corresponding release/return request to the Licensed Custody Partner. The actual execution of any release or return is performed by the Licensed Custody Partner under its own terms, policies, and applicable law, and may be subject to compliance checks, holds, or lawful restrictions. The Company does not control custody and does not guarantee execution outcomes, except to the extent required by applicable law. If funds have already been released on-chain prior to the decision, the panel decision serves as an evidentiary record. Recovery of already-released funds is not guaranteed and Xolaxis bears no liability for on-chain transactions already executed.

9. Dispute Administration Fees

A dispute administration fee may apply to deter abuse. The fee, if applicable, will be displayed before a dispute is formally opened. The fee is refundable to the substantially prevailing party at the Company's discretion. High-value disputes may require an advance arbitration deposit to cover panel costs. The deposit amount will be specified at the time of escalation.

10. Abuse; Bad Faith; Repeat Offenders

Repeated abusive disputes, bad-faith claims, fabricated evidence, manipulation, coercion, harassment, threats, extortion, off-Platform coordination, attempts to bypass Platform rules, chargeback-like behavior, and any other conduct undermining the integrity of the dispute process may result in one or more of the following actions, at the Company’s sole discretion and without prior notice where permitted by law: deal cancellation, deal closure in favor of the other party, refusal to process future transactions, immediate holds on funds, delayed releases pending review, mandatory enhanced verification (KYC/EDD), reduced limits, temporary or permanent feature restrictions, account suspension, permanent termination, forfeiture of any dispute-related fees (if applicable), and reporting to relevant authorities or the Licensed Custody Partner where required or permitted by law. The Platform may maintain internal risk scores based on dispute history, evidence quality, and behavioral signals.

11. External Remedies; Governing Law

These Rules operate under the governing law of the British Virgin Islands as defined in the Terms of Use. Nothing in these Rules limits rights that cannot be contractually waived under applicable law. Users retain the right to pursue external legal remedies, subject to any binding arbitration clause adopted in the Terms of Use.

Last updated: February 2026

IMPORTANT: Xolaxis Ltd does not hold, custody, transmit, or control user funds at any time. All custody of Digital Assets is performed exclusively by Licensed Custody Partners - independently licensed and regulated third-party entities. Xolaxis coordinates deal workflows and communicates release instructions to the Licensed Custody Partners; it does not act as escrow agent, custodian, money transmitter, or financial institution.

1. Scope

These Payments and Custody Partner Terms govern deal funding, custody arrangements, release conditions, refunds, platform fees, evidence standards, and settlement mechanics for deals on the Xolaxis Platform. They are incorporated by reference into the Xolaxis Terms of Use. Fund custody is performed by the applicable Licensed Custody Partner under its own regulatory license and separate user agreement. By initiating a deal, users consent to the routing of funds through the Licensed Custody Partner and agree to its terms of service.

2. Supported Assets and Networks

Supported Digital Assets and networks are listed in the Platform. Launch configuration: USDT on TRON (TRC-20). Users are solely responsible for using correct wallet addresses and selecting the correct network. Transactions on public blockchains are irreversible. Xolaxis and its Licensed Custody Partners bear no responsibility for funds sent to incorrect addresses or networks. Users bear all applicable network fees and any third-party costs associated with on-chain transfers.

3. Deal Types

Service-only deal: The Orderer initiates a Custody Arrangement equal to the agreed service amount plus Platform fees. Funds are released to the Executor upon satisfaction of the applicable Release Condition. Purchase-included deal: The Executor purchases goods or services on behalf of the Orderer. The Custody Arrangement may include a receipt-backed Purchase Budget plus the service fee. Purchase amounts are subject to itemized receipt verification. 4. Funding and Custody Arrangement

The Orderer initiates a Custody Arrangement by sending Digital Assets to the address provided by the Licensed Custody Partner for the specific deal. Funds are held by the Licensed Custody Partner in segregated deal accounts under its own custody controls and regulatory obligations. Xolaxis does not have control over, access to, or custody of any user funds at any point. The Licensed Custody Partner is solely responsible for the safekeeping and operational security of held Digital Assets under its applicable license. The Licensed Custody Partner may delay crediting funds until sufficient blockchain confirmation thresholds are met (minimum confirmations are defined per asset/network).

5. Platform Fees

Platform service fees are displayed to the Orderer before initiating the Custody Arrangement and are deducted from the Custody Arrangement amount upon release. Progressive service fee schedule: • $0 – $500: 20% of amount in bracket • $500 – $2,500: 10% of amount in bracket • $2,500 – $5,000: 7.5% of amount in bracket • $5,000 – $10,000: 5.0% of amount in bracket • Above $10,000: Custom rate (negotiated, contact support) Purchase-included deals: an additional 5% is charged on the Purchase Budget amount on top of the service fee. Fees are non-refundable once a Release Condition has been satisfied and release has been executed by the Licensed Custody Partner. Fees are generally borne by the Orderer unless the deal specifies otherwise.

6. Executor Submission; Evidence Standards

To request release, the Executor must mark the work as completed within the Platform and submit the agreed evidence, which may include: photos or video proof, itemized receipts, delivery confirmations, timestamps, and chat/communication logs. For purchase-included deals, receipts must be itemized, match the Purchase Budget scope, and be submitted in legible format. The Platform may require additional proof. Submission of a release request constitutes the Executor's declaration that the work is complete and that all evidence is accurate and unaltered.

7. Release Conditions

Xolaxis send the request to the Licensed Custody Partner to release held funds only upon a valid Release Condition: (a) Orderer approval: The Orderer confirms deal completion within the Platform; (b) Milestone approval: Orderer approves a specific milestone; (c) Mutual written instruction: Both parties submit signed release instructions; (d) Deemed acceptance: Orderer inactivity following submission, subject to support review (see Section 8); (e) Dispute or arbitration decision: A resolution is issued per the Dispute Rules; (f) Lawful order: A competent legal authority orders release or return. Xolaxis or the Licensed Custody Partner may place a compliance hold or risk hold that pauses release pending investigation.

8. Orderer Inactivity and Deemed Acceptance

If the Orderer does not respond following the Executor's submission, the Platform may instruct the Licensed Custody Partner to release funds after a support-reviewed process in the Platform's reasonable discretion based on evidence standards. Default timeline: • T+14 days after submission: Platform sends reminder notifications to Orderer; • T+21 days after submission: Eligibility for support-reviewed release, provided: - No dispute is open; - Evidence meets the applicable standard; - No compliance or risk hold applies. Support may extend these timelines where evidence is unclear, delivery is disputed, additional KYC/EDD is pending, or the Licensed Custody Partner requires further verification.

9. Refunds; Adjustments; Overages

Refunds may be instructed by Xolaxis to the Licensed Custody Partner only before release and only if a refund Release Condition is met (e.g., cancellation per agreed deal terms, arbitration decision, or mutual instruction). If the purchase amount, receipts, and any additional costs are agreed upfront in the deal terms before acceptance, the funded amount will be treated as a single fixed sum. The funded amount will be either (i) fully used and released in accordance with the agreed terms, or (ii) fully returned (if a return condition applies). Partial refunds, split releases, or pro-rata adjustments are not supported unless expressly agreed in the deal terms before funding.

10. Finality

Once the Licensed Custody Partner executes a release on-chain pursuant to a valid Release Condition and Xolaxis's instruction, the transfer is final and irreversible on the blockchain. Users acknowledge and accept blockchain irreversibility. Recovery of released funds is generally not possible, and Xolaxis bears no liability for released amounts.

11. Holds; Freezes; Paused Releases

Xolaxis may request the Licensed Custody Partner to pause, delay, or refuse a release in response to: fraud indicators, sanctions exposure, AML/KYC requirements, security incidents, legal requests, regulatory orders, or suspected prohibited activity. Such instructions may be issued without prior notice to the affected user. Xolaxis and the Licensed Custody Partner are not liable for losses arising from lawful holds or pauses required for compliance purposes.

12. Records and Statements

The Platform provides deal timelines, blockchain transaction hashes, fee summaries, and evidence audit trails. Users should independently maintain records of deal terms, communications, and evidence submitted. Platform records are maintained for a minimum period as required by the applicable Licensed Custody Partner's regulatory obligations and by BVI law.