Lexxen Terms of Use

Title

Lexxen Terms of Use

Version

1.0

Issuing unit

Compliance

Scope

All users of the Lexxen platform

Effective date

August 31, 2026

Language

Courtesy translation. In case of conflict, the Portuguese version prevails.

1. Introduction

1.1. These Terms of Use ("Terms") govern access to and use of the Lexxen platform, made available by LEXXEN LTDA, enrolled with the CNPJ under No. 63.987.111/0001-53, with its registered office at Rua 15, nº 721, Quadra H12, Lote 12, Sala 1, Setor Marista, Goiânia/GO, CEP 74.150-020 ("Lexxen").

1.2. Lexxen develops and operates a technology platform that brings together, in a single interface, financial and virtual asset services provided by authorized partner institutions.

1.3. Please read these Terms carefully. They are supplemented by the Privacy Policy, the Crypto-Asset Risk Notice, the Partners Annex and the Fee Schedule, all available at www.lexxen.com and forming an integral part of this instrument for all purposes.

2. What Lexxen is and what Lexxen is not

This section is essential. It defines the limits of Lexxen's liability and must be read before any other.

2.1. Lexxen acts exclusively as a provider of a technology solution, integrating into its platform services provided by partner institutions duly authorized to operate by their respective regulators.

2.2. Lexxen IS NOT, and does not hold itself out as:

2.3. As a consequence of item 2.2, the User acknowledges that:

a) funds and virtual assets are not held by Lexxen. They remain under the ownership of the User with the responsible partner institution, in accordance with that institution's terms and contracts;

b) Lexxen does not carry out foreign exchange transactions, does not hold accounts in its own name abroad and does not intermediate the purchase and sale of foreign currency;

c) Lexxen does not issue cards and does not hold an issuing license with card networks or payment schemes;

d) the approval, maintenance and termination of the services provided by the partner institutions follow the policies of those institutions, over which Lexxen has no control.

2.4. The relationship between the User and each partner institution is direct, governed by the terms and contracts of the respective partner, which the User must read and accept where applicable. Lexxen will make available the links to or copies of those documents.

3. Definitions

3.1. For the purposes of these Terms:

• Virtual Asset: a digital representation of value that can be traded or transferred by electronic means and used for making payments or for investment purposes, under Article 3 of Law No. 14.478/2022. It does not include domestic or foreign currency, nor assets representing securities.
• Account: the User's registration on the Lexxen platform, which grants access to the contracted features.
• Payment Account: an individual, nominal account opened in the User's name with an authorized partner institution.
• Partner: an institution authorized by its regulator that actually provides the financial or virtual asset service made available through the platform. The list of current Partners is set out in the Partners Annex, at www.lexxen.com/privacy/partners.
• Platform: Lexxen's digital environment, including web interfaces, applications and APIs.
• VASP: a virtual asset service provider (Prestadora de Serviços de Ativos Virtuais, PSAV), under Law No. 14.478/2022 and the regulations of the Central Bank of Brazil.
• Stablecoin: a virtual asset whose value seeks to maintain parity with a fiat currency or another reference asset.
• User: a natural person or legal entity that registers on and uses the Platform.

4. Acceptance, capacity and term

4.1. Registration on and use of the Platform imply full acceptance of these Terms. If the User does not agree, the User must not use the Platform.

4.2. A User who is a natural person represents that he or she is over 18 years of age and has legal capacity. A User that is a legal entity represents that it is duly incorporated and that acceptance is given by a representative with the powers to do so.

4.3. These Terms are in force for an indefinite term, as from acceptance, for as long as the relationship between the parties lasts.

4.4. Electronic acceptance has full legal validity, equivalent to the written form, under Article 10, paragraph 2, of Provisional Measure No. 2.200-2/2001 (which established the Brazilian Public Key Infrastructure, ICP-Brasil) and Article 107 of the Brazilian Civil Code.

5. Registration, identity verification and updates

5.1. Access to the services depends on prior registration, with the provision of true, accurate and complete information, and on approval in the identity verification procedures (KYC, Know Your Customer, and KYB, Know Your Business).

5.2. Verification procedures may include: document validation, liveness check and facial biometrics, queries to public and private databases, screening against domestic and international restrictive lists, checks for Politically Exposed Persons (PEP) and adverse media analysis.

5.3. Lexxen uses specialized providers to carry out verification. The processing of data at this stage is subject to the Privacy Policy.

5.4. The User authorizes and acknowledges that, as a regulatory requirement, Lexxen must transmit to the Partners, including in real time, the identification and qualification data of the User and of the beneficiaries of transactions, as well as updates to registration data. This transmission is a condition for the operation of the services and arises from anti-money laundering and transaction traceability rules, including CMN Resolution No. 5.261/2025 (National Monetary Council) and BCB Resolution No. 518/2025 (Central Bank of Brazil).

5.5. The User undertakes to keep his or her data up to date and to respond, within the period indicated, to requests for documents or additional clarifications, including regarding the origin and destination of funds.

5.6. Lexxen and the Partners may refuse, suspend or terminate the registration in the event of: (i) false, incomplete or outdated information; (ii) failure to respond to a request for documents; (iii) identification on restrictive lists; (iv) incompatibility with the risk policy; (v) an order from a competent authority.

5.7. The registration is personal and non-transferable. Ownership may only be changed by means of a formally documented corporate change approved in advance.

6. Access security

6.1. Access credentials are personal and confidential. Sharing of login, password, tokens or authentication devices is prohibited.

6.2. Two-factor authentication (MFA) is mandatory and must be enabled immediately after the Account is created.

6.3. Transactions carried out with valid credentials are presumed legitimate, unless technically proven otherwise. The User must immediately report, through the official channels, any suspicion of unauthorized access, loss or compromise of credentials.

6.4. The User is responsible for the security of the devices he or she uses, keeping systems up to date and adopting reasonable protective measures.

6.5. In legal entity accounts, the designated administrator is responsible for creating, delegating and revoking the access of its representatives, and the legal entity is liable for the acts performed by them.

7. Available services

Not all of the services below may be available to all Users. Availability depends on the profile, registration approval and the policies of the Partners.

7.1. Payment account

7.1.1. Through the Platform, the User may request the opening of an individual, nominal payment account in his or her own name, with a Partner authorized by the Central Bank of Brazil.

7.1.2. The account is owned by the User vis-à-vis the Partner. Lexxen is not the holder, joint holder, depositary or custodian of the funds.

7.1.3. Opening, maintenance, limits and closure follow the Partner's rules. Approval is not guaranteed.

7.1.4. Balances in a payment account do not constitute a bank deposit, do not bear interest, do not generate yield or monetary adjustment and are not covered by the Credit Guarantee Fund (FGC).

7.1.5. Features may include receiving and sending funds via PIX, TED, boleto and QR Code, as made available by the Partner.

7.2. Virtual cards

7.2.1. The Platform allows the User to request the issuance of virtual cards issued by Partners, in the modalities made available, among them a card with a credit function and a card backed by a virtual asset (stablecoin).

7.2.2. Lexxen is not an issuer. Issuance, credit analysis, setting of limits, approval, blocking and cancellation are decisions of the issuing Partner and of the card network, over which Lexxen has no control.

7.2.3. Use of the cards is subject to the rules of the card network, the payment scheme and the issuer, which the User represents that he or she knows and accepts.

7.2.4. With respect to the card backed by a virtual asset, the User acknowledges that:

a) the settlement of each transaction involves the conversion of the virtual asset into fiat currency, at the rate and under the conditions applied by the Partner at the time of the transaction;

b) the price variation of the virtual asset between authorization and settlement may change the amount actually debited;

c) a conversion spread and other costs, disclosed in the Fee Schedule, may apply;

d) the warnings in the Crypto-Asset Risk Notice apply in full.

7.2.5. International transactions may be subject to IOF (the Brazilian tax on financial transactions) and conversion fees, according to the issuer's fee table.

7.2.6. Disputes, reversals and chargebacks follow the deadlines and procedures of the card network and the issuer. Lexxen acts solely as a forwarding channel, with no decision-making power over the merits.

7.2.7. In the event of suspected fraud, loss or misuse, the User must immediately notify Lexxen through the official channels so that the card can be blocked.

7.3. Virtual assets: purchase, sale, conversion and transfer

7.3.1. The Platform allows the User to contract transactions with virtual assets, including acquisition, disposal, conversion between assets and conversion between virtual assets and fiat currency (on-ramp and off-ramp), executed by an authorized Partner VASP.

7.3.2. Lexxen does not hold virtual assets in custody, does not operate its own wallet and does not execute orders in its own name. Custody and execution are the responsibility of the Partner.

7.3.3. The quotes displayed are indicative and may vary until the transaction is completed. The applicable rate is the one in effect at the time of execution by the Partner.

7.3.4. Transactions with virtual assets are, by their nature, irreversible. Once the transaction has been confirmed and settled, there is no reversal, cancellation or unwinding.

7.3.5. In transfers to external wallets, the User is fully responsible for the address provided, the network (blockchain) selected and the compatibility of the asset. Sending to an incorrect address or network results in the definitive and irrecoverable loss of the assets.

7.3.6. Network fees (gas fees) may apply, set by the network and not by Lexxen.

7.3.7. Transfers may be subject to traceability rules applicable to VASPs, including the sharing of originator and beneficiary information (Travel Rule).

7.3.8. The User declares awareness that virtual assets are not guaranteed by the FGC, are neither issued nor guaranteed by the Central Bank of Brazil and do not constitute legal tender.

7.3.9. The warnings in the Crypto-Asset Risk Notice apply in full, and the User represents that he or she has read it before the first transaction.

7.4. International accounts (virtual accounts)

7.4.1. The Platform may provide access to international accounts opened by a Partner authorized abroad, in the User's name, for receiving and sending funds in foreign currency.

7.4.2. Lexxen does not carry out foreign exchange transactions, does not intermediate the purchase and sale of foreign currency and does not hold accounts in its own name abroad. Any currency conversion is executed by an authorized institution, under Law No. 14.286/2021 and the regulations of the Central Bank of Brazil.

7.4.3. The User is solely responsible for compliance with the tax, foreign exchange and reporting obligations arising from holding funds abroad, including, where applicable, the Declaration of Brazilian Capital Abroad (CBE) to the Central Bank and the obligations before the Brazilian Federal Revenue Service.

7.4.4. The service is subject to the laws and regulations of the jurisdiction in which the account is held, as well as to the policies of the Partner, which may impose usage restrictions, limits and additional documentation requirements.

7.4.5. Lexxen does not provide tax, fiscal, foreign exchange, accounting, legal or investment advice.

7.5. Management tools and reports

7.5.1. The Platform may provide statements, reports, metrics and financial organization tools, for strictly managerial and informational purposes.

7.5.2. Such information does not replace the User's accounting records, tax documents or ancillary obligations, and does not constitute accounting, tax, legal or investment advice.

7.5.3. Data originating from third-party systems may present discrepancies or synchronization delays, which do not constitute a failure in the provision of the services.

8. Fees, charges and taxes

8.1. The applicable fees are set out in the Fee Schedule, made available on the platform or in the applicable contractual document, which forms an integral part of these Terms. They may include per-transaction fees, percentages on amounts transacted, virtual asset conversion spread, card issuance and maintenance fees, transfer fees and inactive account maintenance fees.

8.2. The User authorizes the debit of the fees due from the available balance or from the linked account.

8.3. Changes to fees will be communicated with at least 30 (thirty) days' notice through the official channels. If the User disagrees, the User may terminate the relationship, without penalty, before the changes take effect.

Period aligned with Article 6, VIII, and Article 46 of the CDC (the Brazilian Consumer Protection Code), and more protective than the 5 days in the previous document, which would hardly withstand judicial review.

8.4. The User is solely responsible for the taxes levied on his or her transactions, including IOF and Income Tax on capital gains from virtual assets and ancillary obligations, among them the reporting of crypto-asset transactions to the Brazilian Federal Revenue Service (RFB Normative Instruction No. 1.888/2019 and subsequent rules).

8.5. Lexxen does not withhold taxes at source on behalf of the User, except where required by law.

9. Permitted use and prohibited conduct

9.1. The User undertakes to use the Platform in a lawful and ethical manner, consistent with its purpose, and not to use it for:

a) money laundering, concealment of assets, financing of terrorism or of the proliferation of weapons of mass destruction;

b) fraud, swindling, misappropriation or any criminal offense;

c) transactions intended to conceal the origin, ownership or destination of funds or assets, or to prevent the identification of the parties;

d) transactions on behalf of unidentified third parties, or making the Account available to third parties ("pass-through account");

e) sham transactions, self-transfers without economic substance or artificial circulation of funds;

f) gambling, lotteries or betting not authorized in Brazil;

g) financial pyramids, Ponzi schemes, irregular raising of public savings or irregular offering of securities;

h) trade in illicit goods or services, including narcotics, weapons, child sexual abuse material and counterfeit products;

i) violation of intellectual property rights or of third parties' personal data;

j) attacks on the Platform, reverse engineering, use of bots or scrapers, or attempts to circumvent security controls;

k) any conduct prohibited by the policies of the Partners or by applicable regulations.

9.2. The User declares, under penalty of law, that the funds and assets used on the Platform have a lawful origin and are consistent with his or her declared economic and financial capacity.

9.3. The User is prohibited from acting as an unauthorized intermediary, providing to third parties, through his or her Account, payment, foreign exchange or virtual asset services that require regulatory authorization.

10. Monitoring, prevention of unlawful acts and precautionary measures

10.1. Lexxen and the Partners maintain continuous monitoring of transactions, in compliance with Law No. 9.613/1998 (the Brazilian Anti-Money Laundering Law), Law No. 14.478/2022 and the regulations of the Central Bank of Brazil and of COAF (the Brazilian Financial Intelligence Unit).

10.2. Where an atypical or suspicious transaction, or one inconsistent with the User's profile, is identified, Lexxen may, individually or cumulatively:

a) request documents, clarifications and evidence of the origin and destination of funds;

b) preventively suspend the transaction, the feature or the Account;

c) refuse to execute the transaction;

d) terminate the relationship, under clause 14.

10.3. Under Article 11 of Law No. 9.613/1998, the reporting of suspicious transactions to the competent authorities, including COAF, is mandatory and will be made without the User's knowledge.

10.4. Blocks or holds ordered by a judicial or administrative authority or by a regulated Partner will be complied with by Lexxen, which has no power to reverse them. Challenges must be directed to the originating authority or institution.

10.5. Lexxen will inform the User of the measures adopted whenever legally permitted.

10.6. The measures in this clause are precautionary and not punitive in nature, and will be applied in a manner proportional to the risk identified, for the time necessary for the investigation.

11. Personal data protection

11.1. The processing of personal data is subject to Law No. 13.709/2018 (LGPD, the Brazilian General Data Protection Law) and is detailed in the Privacy Policy, available at www.lexxen.com/privacy.

11.2. Lexxen acts as controller of the Users' personal data. The Partners act as independent controllers for their own regulatory purposes. Service providers engaged by Lexxen act as processors.

11.3. The sharing of data with Partners and authorities, where arising from a legal or regulatory obligation or necessary for the performance of this contract, does not depend on consent, under Article 7, II and V, of the LGPD.

11.4. The list of Partners and processors is set out in the Partners Annex, at www.lexxen.com/privacy/partners.

11.5. Data Protection Officer (DPO) contact: Siffermann Sociedade Individual de Advocacia, Thiago de Oliveira Rocha Siffermann (OAB/GO 40.724), compliance@lexxen.com.

12. Intellectual property

12.1. The Platform, its source code, architecture, interfaces, trademarks, logos, databases and other elements are the exclusive property of Lexxen or its licensors.

12.2. The User is granted a non-exclusive, non-transferable, revocable and limited license to use the contracted services, with assignment, sublicensing or commercial exploitation prohibited.

12.3. Copying, modifying, decompiling, reverse engineering, extracting data by automated means or creating derivative works without express authorization is prohibited.

12.4. The User grants Lexxen a limited license to use the User's trademark exclusively to identify the User as a client in institutional materials, which may be revoked at any time by request to support@lexxen.com.

13. Liability

13.1. Lexxen is liable for the services it actually provides: the operation of the Platform and the correct forwarding of the User's instructions to the Partners.

13.2. Lexxen is not liable for:

a) acts, omissions, decisions, failures or insolvency of the Partners, of card networks or of institutions participating in payment schemes;

b) price variation of virtual assets, losses arising from market fluctuations or from the User's investment decisions;

c) loss of assets due to User error in the destination address, in the network chosen or in the safekeeping of credentials;

d) unavailability of blockchain networks, congestion, forks or failures of third-party protocols;

e) unavailability of essential third-party services: internet, payment networks, banking systems, cloud providers;

f) the User's failure to comply with tax, foreign exchange or regulatory obligations;

g) misuse of the Account by third parties, where resulting from the User's failure to safeguard credentials.

13.3. The Platform is provided on an "as is" basis, and uninterrupted or error-free operation is not guaranteed. Lexxen will use reasonable technical efforts to maintain availability and will communicate scheduled interruptions whenever possible.

13.4. Limitation of liability. Except in cases of willful misconduct or gross negligence, and in situations where such limitation is prohibited by law, notably in consumer relationships, Lexxen's liability for losses and damages is limited to the amount of the fees actually paid by the User to Lexxen in the 12 (twelve) months preceding the event.

13.5. The User undertakes to indemnify Lexxen for losses arising from a breach of these Terms, from false information provided, from non-compliance with applicable law or from unlawful use of the Platform.

13.6. Consumer relationships. Where the User is the end recipient of the services, the Consumer Protection Code (Law No. 8.078/1990) applies, and no provision of these Terms shall be construed as a restriction of any right legally guaranteed to the consumer.

A material difference from the previous document, which declared the CDC inapplicable and required a waiver by the user. A clause of that kind is void where a consumer is involved (CDC, Article 51, I) and weakens the entire document in court.

14. Suspension and termination

14.1. The User may close his or her Account at any time through the official channels, subject to the settlement of outstanding obligations, the absence of transactions in progress and the withdrawal of balances and assets.

14.2. Lexxen may suspend or terminate the Account, with prior notice whenever possible, in the event of: (i) breach of these Terms; (ii) false or outdated information; (iii) a requirement of a Partner, regulator or authority; (iv) material risk of fraud, unlawful act or regulatory non-compliance; (v) prolonged inactivity; (vi) discontinuation of the service.

14.3. Where there is an imminent risk of an unlawful act, fraud or non-compliance with a legal order, suspension may be immediate and without prior notice, with subsequent communication where permitted.

14.4. Once the relationship has ended, the User will have 30 (thirty) days to transfer balances and assets and to obtain statements and receipts. If the transfer is not possible for a cause attributable to the User, the amounts will remain available for the periods required by law.

14.5. Termination does not extinguish obligations previously incurred, nor the duty to retain records for the periods required by law.

15. Support and customer service

15.1. Support is provided through support@lexxen.com and the channels indicated at www.lexxen.com.

15.2. Response times:

15.3. If the matter is not resolved by support, the User may resort to the Ombudsman/Compliance channel: compliance@lexxen.com.

15.4. Requests relating to services provided by Partners may need to be handled directly through the channels of the responsible institution, in which case Lexxen will provide guidance on how to proceed.

15.5. Lexxen may record and monitor customer service interactions for quality, security and audit purposes, subject to the Privacy Policy.

16. Changes to these Terms

16.1. These Terms may be changed at any time for legal, regulatory, technological or operational adjustment.

16.2. Material changes (those that restrict rights, create obligations or change fees) will be communicated with at least 30 (thirty) days' notice through the official channels.

16.3. Continued use after the effective date implies agreement. If the User disagrees, the User may terminate the relationship without penalty before the changes take effect.

16.4. Previous versions will remain available for consultation at www.lexxen.com.

17. Final provisions

17.1. Tolerance of the breach of any clause does not constitute novation or waiver.

17.2. The invalidity of any clause does not affect the others.

17.3. These Terms may be supplemented by product-specific terms, which prevail in respect of their specific matters, with these Terms applying on a subsidiary basis.

17.4. Communications will be made using the registered contact details, and it is the User's responsibility to keep them up to date.

17.5. The User may not assign his or her contractual position without Lexxen's consent. Lexxen may assign this contract in the event of a corporate reorganization, upon notice.

17.6. These Terms are governed by the laws of the Federative Republic of Brazil.

17.7. Jurisdiction. The courts of the Judicial District of Goiânia, State of Goiás, are elected to settle any disputes. Where the User is a consumer, the courts of the User's domicile are guaranteed, under Article 101, I, of the CDC.

Documents forming an integral part of these Terms

LEXXEN LTDA, CNPJ 63.987.111/0001-53 Goiânia/GO, August 31, 2026, version 1.0