Risk Disclosure

Last updated: February 2026

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.

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