Income Addicts | Terms and Privacy And Policy

Our Privacy Policy

IndexBlack Privacy Policy

Last updated: March, 2021

Before proceeding, please read the following information carefully. Please submit any questions you have about this Policy via our Support Portal at https://support.indexblack.com/customer/portal/emails/new.

From time to time, this Privacy Policy may be modified, and the date will be updated at the top of this page. In the event that we make any material changes, we will notify you by email (sent to the email address specified in your account), by posting a notice on our Services, or by other means, as required by law.

1. AGREEING TO THIS POLICY

Using our Services and accessing this Privacy Policy implies your acceptance of its terms. Where our processing of your personal information requires your consent, we will request that you consent to the collection, use, and disclosure of your personal information as described further below. Additional information regarding specific Services will be provided "just-in-time." Our privacy notices may include additional information or provide you with additional choices regarding our use of your data.

In the event you do not agree with any aspect of this Privacy Policy or you do not feel comfortable using our Services, please immediately cease using or accessing them.

2. HOW WE COLLECT YOUR PERSONAL INFORMATION

Individually identifiable information, such as a name, address, and e-mail address, is also known as personal information. In addition to the information you provide to us, we receive information from third parties and we collect information automatically. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

Information you provide to us: We will ask you for some information about yourself in order to establish an account and access our Services. We use this information either to comply with the law (such as verifying your identity), to provide the requested services (such as linking your bank account to a IndexBlack account) or for certain specific purposes, as described below. We may ask you for more information as we add new features and Services.

We may not be able to provide our Services to you effectively if you choose not to share certain information with us.

Information you share with us that is not required will always be voluntary.

We may collect the following types of information from you:

*Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.

*Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.

*Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.

*Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.

*Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.

*Employment Information: Office location, job title, and/or description of role.

*Correspondence: Survey responses, information provided to our support team or user research team.

*Audio, electronic, visual and similar information, such as call and video recordings.

Information we collect from you automatically: To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. By using this information, we can provide you with a streamlined and personalized experience, resolve customer support issues, enhance the performance of our Sites and Services, and protect your account from fraud by detecting unauthorized access. The automatic data we collect may include:

*Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.

*Usage Data: Authentication data, security questions, click-stream data, public social networking posts,and other data collected via cookies and similar technologies. Please read our Cookie Policy for more information.

For example, we may automatically receive and record the following information on our server logs:

*How you came to and use the Services;

*Device type and unique device identification numbers;

*Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);

*How your device interacts with our Sites and Services, including pages accessed and links clicked;

*Broad geographic location (e.g. country or city-level location); and

*Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.

Information we collect from our affiliates and third parties: From time to time, we may obtain information about you from our affiliates or third party sources as required or permitted by applicable law. These sources might include:

*Information from Public Databases, Credit Bureaus, & ID Verification Partners: By verifying your identity, we obtain information about you from public databases, credit bureaus, and ID verification partners. Identity verification partners like World-Check verify your identity based on government records and publicly available information. You may be required to provide us with certain information, including your name, address, job title, public employment profile, credit history, and status on any sanctions lists maintained by public authorities. Our legal obligations require that we obtain such information, such as anti-money laundering laws. It may be necessary to process additional data about you to assess risk and prevent fraudulent or illegal activities through our Services. We must process your personal information to continue to meet our contractual obligations to you and others. In its Privacy Policy, which is available at https://www.refinitiv.com/en/products/world-check kycscreening/privacystatement/, World-Check describes how it collects and uses personal information..

*We may analyze public blockchain data in order to ensure parties utilizing our Services are not engaging in illegal or prohibited activities under our Terms, as well as analyze transaction patterns in order to conduct research and development.

*In addition, joint marketing partners and resellers may share information about you with us to better understand what of our Services might be of interest to you, unless prohibited by applicable law.

*Advertisement providers and analytics providers: These companies provide us with non-identifiable information about how you found our Sites and how you use the Sites and Services. Information collected may be collected before creation of an account. We have a Cookie Policy that explains how you can manage the collection of this data.

3. ANONYMIZED AND AGGREGATED DATA

Using anonymization, personal information is modified in such a way that it can no longer be associated with a specific individual. No other provisions of this Privacy Policy apply to aggregated or anonymized customer data (for example, information about our customers that can no longer be linked to a single individual customer).

The purpose of IndexBlack’s use of anonymized or aggregated customer data can include (but is not limited to) understanding the needs and behaviors of our customers, improving our Services, conducting business intelligence and marketing, and detecting security threats. Depending on the data, we may perform our own analytics or allow third parties to perform analytics for us.

Our data may be anonymized in in various ways, such as transaction data, click-stream data, performance metrics, and fraud indicators.

4. WHAT WE DO WITH YOUR PERSONAL INFORMATION

Getting your personal information from you is our primary method of providing you with a seamless, smooth, efficient, and customized experience. The general purpose of using personal information is to create, develop, operate, deliver, and improve our Services, content and advertising, as well as to prevent loss and prevent fraud. Information that we collect may be used for the following purposes:

1) To maintain compliance with laws and regulations

The collection, use, and storage of your personal information is required by law for some of our core Services. For example, IndexBlack must identify and verify customers using our Services in order to comply with anti-money laundering laws across jurisdictions. Photo identification must be collected and stored as part of this process. In addition, we verify your identity using third parties by comparing the information you provide with databases and public records. In order to link a bank account to a IndexBlack Account, we may require additional information from you. This information may be used by us, our service providers, or the authorities to verify your identity or address, and/or manage risk as requested by law. You will be required to close your account if you fail to provide the required personal information.

2) To enforce our terms in our user agreement and other agreements

IndexBlack handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce our agreements with third parties, and/or prevent and detect violations of our posted user agreement or agreements for other Services. In addition, we may need to collect fees based on your use of our Services. We collect information about your account usage and closely monitor your interactions with our Services. We may use any of your personal information collected for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account.

3). Detecting and preventing fraud and/or money loss.

In order to identify, prevent, and mitigate fraud and abuse of our services, as well as to protect you against account compromise and fund loss, we process your personal information.

4). To provide our services such as IndexBlack.

The Services are provided to you via the processing of your personal information. In order to store funds on our platform, you will need to provide information such as your identification, contact information, and payment details. The services you request will not be available without these details. When providing identity verification and/or fraud prevention services, third parties such as identity verification services may also access and/or collect your personal information.

5) To provide Service communications

We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

6) To provide customer service

We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.

7) To ensure quality control

We process your personal information for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.

8) To ensure network and information security

We process your personal information in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your personal information, we may not be able to ensure the security of our Services.

9) For research and development purposes

We process your personal information to better understand the way you use and interact with IndexBlack Services. In addition, we use such information to customize, measure, and improve IndexBlack Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.

10) To enhance your experience

We process your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide us with access to certain personal information stored by third parties. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.

11) To facilitate corporate acquisitions, mergers, or transactions

We may process any information regarding your account and use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.

12) To engage in marketing activities

Based on your communication preferences, we may send you marketing communications (e.g. emails or mobile notifications) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.

13) To protect the health and safety of our employees and visitors, our facilities and our property and other rights. If you visit one of our locations, to maintain security at such locations you may be photographed or videotaped.

14) For any purpose that you provide your consent. We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under the applicable law, we may request your permission to allow us to share your personal information with third parties. In such instances, you may opt out of having your personal information shared with third parties, or allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your personal information, certain features or IndexBlack Services may not be available to you.

5. LEGAL BASES FOR PROCESSING YOUR INFORMATION

Depending on the personal information at issue, the context in which the information is collected, andthe purpose for which your personal information is used, our legal bases for processing your information under the EU General Data Protection Regulation ("GDPR") will vary for individuals who reside in the European Economic Area, United Kingdom, or Switzerland at the time their personal information is collected. Our general policy is to only process your data where we are legally required to do so, where it is necessary to perform any contract we have with you (or where it is necessary to take steps at your request if we want to enter into a contract with you), where it serves our legitimate business interests and is not contrary to your data protection rights or fundamental freedoms, or if you have given us your consent. It may be necessary in some rare instances for us to process your personal information in order to safeguard your vital interests or those of another person. As described above in Section 4, here's a list of the ways IndexBlack uses your personal information, along with its corresponding legal bases. In case you have questions or need more information about the legal basis for collecting and using your personal information, you can reach us by using the contact details under "How to contact us.".

Section & Purpose of Processing	Legal Bases for Processing
(2) To enforce our terms in our user agreement and other agreements (4) To provide IndexBlack Services (5) To provide Service communications (6) To provide customer service (7) To ensure quality control	We may take measures based on our contract with you or at your request prior to entering into a contract.
9) For research and development purposes (10) To enhance your experience (11) To facilitate corporate acquisitions, mergers, or transactions (12) To engage in direct marketing activities	On the basis of our legitimate interests. Any potential impact on your privacy and your rights under the data privacy laws is always taken into account and balanced when we process your personal data for our legitimate interests.
(1) To maintain legal and regulatory compliance (3) To detect and prevent fraud and/or funds loss (8) To ensure network and information security (13) To protect yours or our vital interests	Legally required, in the public interest, or in your best interests.
(10) To enhance your experience (12) To engage in third party marketing activities (14) For any purpose to which you consent	In accordance with your consent.

6. OUR PURPOSE IN SHARING PERSONAL INFORMATION

To ensure your privacy, we ensure that your personal information is accessed only by those who require it to carry out their responsibilities, and to share it only with third parties who have a legitimate need for it. Without your explicit consent, IndexBlack will never rent or sell your personal information. The following are the only times in which IndexBlack will divulge your personal information:

a.) In order to prevent fraud, IndexBlack may share your identity with third parties. Our system allows us to verify your identity by comparing the information you provide us with public records and third party databases. In order to provide you with identity verification and fraud prevention services, these service providers may create derivative data based on your personal information. For instance:

• *We may rely on Jumio UK, Limited or Jumio Corporation (collectively "Jumio") to verify your identity by comparing pictures in your government-issued ID with selfies you take. You may be asked to submit biometric data with your photo. The Jumio Privacy Policy, available at https://www.jumio.com/legal-information/privacy-policy/jumio-inc-privacy-policy-foronlineservices/, explains how Jumio collects and uses personal information.

• *Users in Germany may be asked to verify their identity through the use of SolarisBank AG ("Solarisbank"). We may collect biometric information from you. The Solarisbank Privacy Policy, available at https://www.solarisbank.com/en/privacy-policy/, describes how personal information is collected and used.

• *Our team uses Sift Science, Inc. ("Sift") to detect and prevent fraudulent activity on your account in real time. Sift treats the information it receives in accordance with its Privacy Policy, available at https://sift.com/service-privacy.

• *IndexBlack, Inc. ("Plaid") may be used by IndexBlack if you live in the US to connect your IndexBlack account with your bank account, verify your bank account, and confirm your bank account balance prior to approving transactions. Plaid treats the information that is shared with them in accordance with their Privacy Policy, available at https://plaid.com/legal/#enduserprivacy-policy.

b.) With financial institutions with which we partner to process payments you have authorized.

c.) With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with (other than those mentioned above) include:

• Network infrastructure

• Cloud storage

• Payment processing

• Transaction monitoring

• Security

• Document repository services

• Customer support

• Internet (e.g. ISPs)

• Data analytics

• Information Technology

• Marketing

d.) For third-party financial, technical, compliance, and legal audits of our operations, or to otherwise comply with our legal obligations, we work with our professional advisors who provide banking, legal, compliance, insurance, accounting and other consulting services.

e.) Whenever we have a legal obligation to do so, such as when we are required to do so by a subpoena, court order, or similar legal procedure, or where we reasonably believe that the disclosure of information is required in order to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement or any other applicable policies.

f.) Our Affiliates have access to your personal information as part of their regular business operations and as part of our offering Services to you. When it is deemed necessary for the protection of an individual's vital interests. If you establish an indirect IndexBlack Account on a third-party website or by using a third-party application, any information you provide on that website or application (and not directly on the IndexBlack website) will be shared with the owner of the third-party website or application. The owner of the third-party website or application will be responsible for protecting your information. The “Third-Party Sites and Services” section below contains more information.

7. PROTECTING AND STORING PERSONAL INFORMATION

Due to our respect for your privacy, IndexBlack maintains (and contractually requires third parties with whom it shares information to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us. The information we collect about you, including personal and transactional information, including payment information, such as encrypted bank account numbers and routing numbers, may be stored and processed in the United States and elsewhere in the world where our facilities or our service providers are located. We maintain physical, electronic, and procedural safeguards to protect your personal information in accordance with applicable laws and regulations. To protect your personal information, we, for instance, use firewalls, data encryption, and physical access controls to our buildings and files. All employees have access to personal information only if they need to do so to perform their duties. Payment vendors such as Worldpay, (UK) Limited, Worldpay Limited, or Worldpay AP Limited ("Worldpay") handle complete credit card information securely and off-site in accordance with Payment Card Industry Data Security Standards (PCI DSS). IndexBlack staff cannot access this information. Unfortunately, we are unable to guarantee that your personal information will not be lost, misused, unauthorized acquired, or altered. The protection of your own personal information is crucial to your own wellbeing. You should choose a password of sufficient length and complexity when registering, not disclose this password to anyone, and inform us immediately if your account has been accessed or used in an unauthorized manner. Further, we are unable to guarantee data security or confidentiality once it leaves our premises and is received by us via Internet or wireless connection, including emails, phone calls, or SMS, since we do not have any way to protect it once it is left and until it is received. Please contact us as soon as possible if you have reason to believe that your personal data is no longer secure using the contacts listed under the "How to contact us" section below.

8. SECURITY OF PERSONAL INFORMATION

While your IndexBlack account is active, we store your personal information securely. For legal, accounting, or reporting purposes, or to resolve disputes, we will retain your personal information only as long as necessary in light of the purposes for which it was collected. In addition to the fact that the duration of information retention varies by jurisdiction, we provide below information about typical retention periods for different aspects of your personal information.

• As per applicable laws, we may retain personal information collected in compliance with our legal obligations under financial or anti-money laundering laws for a period of time after the account is closed.

• The information you provide such as your name, email address, and telephone number for marketing purposes will be retained for as long as you remain a subscriber. Our suppression list will be updated as soon as your details have been received to make sure you are not inadvertently marketed to.

• Our website content such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for crime prevention and audit reasons (i.e. to prevent known fraudulent actors from registering for a new account).

• We may keep records of our telephone conversations with you for up to six years.

• Technical means of information collection, such as cookies, counters on webpages, and other advanced analytics tools, are stored until one year after the cookie expires.

9. THIRD-PARTY SITES AND SERVICES

The information you provide to IndexBlack may be shared with third parties if you authorize them to access your IndexBlack Services. IndexBlack will not authorize these third parties to use this information except to facilitate your transactions using IndexBlack Services unless you provide specific permission for it. An account connection is defined as a connection between your IndexBlack account and another account, payment instrument, or platform that is not IndexBlack affiliated. IndexBlack is not responsible for the activities or the use of data collected by third parties you interact with. Please be aware that third parties may have their own privacy policies. IndexBlack is not responsible for unauthorized thirdparty conduct, which may include contact details, financial information, or location data, collected by third parties. Make sure you are familiar with the privacy practices of such third parties.

Account connections include the following:

• Merchants: If you use your IndexBlack account to conduct a transaction with a third party merchant, the merchant may provide data about you and your transaction to us.

• Your Financial Services Providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction. Information that we share with a third party based on an account connection will be used and disclosed in accordance with the third party's privacy practices. Please review the privacy notice of any third party that will gain access to your personal information. IndexBlack is not responsible for such third party conduct.

10. PERSONAL INFORMATION ABOUT CHILDREN

Any person under the age of 18 is not knowingly requested to provide personal information to us. IndexBlack will not allow a user under the age of 18 to continue to use our Services if the user submits personal information to us and IndexBlack suspects the user is under the age of 18. The information will also be deleted as soon as possible. Our Services should not be used by children under the age of 18. Please notify us if you know anyone using our services under the age of 18.

11.FOREIGN TRANSFERS

Depending on the nature of our global operations, IndexBlack may transfer, store, and process your personal information across our Affiliates, third-party partners, and service providers, including in Ireland, Germany, Singapore, Japan, the UK, the United States, the Philippines, and possibly elsewhere. Wherever your personal information is processed, we will protect it as outlined in this privacy policy and we will take appropriate steps to protect it as required under applicable laws. Your personal information is contractually obligated to be protected at least to the same level as required by applicable data protection laws. Whenever you communicate with IndexBlack electronically, you acknowledge and consent to this processing of your personal information. You can submit a complaint via our Support Portal if you have a concern about our privacy practices or how personal information is collected, used or disclosed.

12. YOUR PRIVACY RIGHTS AND CHOICES

Your personal information may be subject to certain rights based on the law where you reside. Unless any of the following rights are provided by law for your operating entity or jurisdiction, IndexBlack may provide you with those rights at their absolute discretion. You do not have absolute rights to personal information. The following circumstances might result in your rights under the applicable law being denied: (a) when denial of access is required or authorized by law; (b) if granting access would violate another's privacy; (c) to protect our rights and properties; (d) if the request is frivolous or vexatious.

• Accessibility and portability. The information we hold about you may be requested by you. Unless such provision adversely affects the rights and freedoms of others, this information will be provided without undue delay, subject to the possibility of a fee associated with acquiring the information (as permitted by law). There are cases where you can request that we provide your personal information to you in a structured, commonly used, and machine-readable format, or that we send it directly to another data controller.

• Information found to be incomplete or inaccurate may be corrected. If your personal information held by IndexBlack is inaccurate, you may request that it be corrected or updated. When logged in, click on the profile or my account tab if you wish to change your profile or account details.

• Erasure. Under certain circumstances, you may request that your personal information be erased. When you close your IndexBlack Account, the account will be marked as "Closed" in our database, but certain account information, including your request to delete, will be kept for a period of time. IndexBlack must comply with these requirements in order to deter fraud, so that anyone attempting to commit fraud cannot simply close their account and open a new one to avoid detection, while also complying with its legal obligations. Nonetheless, if you decide to close your account, your personal data will not be used by us for further purposes, nor shared with third parties, except as required to prevent fraud and assist law enforcement, according to law and this Privacy Policy.

• Retract consent. You may withdraw your consent at any time when the processing of your personal information is based on your consent. If you withdraw, IndexBlack will still be able to process your information based on consent before your withdrawal.

• Restrictions on processing. Depending on your jurisdiction, you may have certain rights regarding our processing or transferring your personal information. Occasionally, we may continue to process your personal information if it is necessary to defend legal claims or for any other exceptions permitted by relevant law.

• Individual decision-making using automated processes, including profiling. A customer account or a transaction can be flagged as illegal or fraudulent based on automated tools employed by IndexBlack. If you are subject to a decision solely based on automated processing of your personal information, including profiling, you may have the right to be exempt from such a decision, unless exceptions apply under relevant data protection laws.

• Promotional communications. IndexBlack offers opt-out options for marketing communications. Any communication with you that is solely directed towards advertising and promoting our products and services is direct marketing. Unless you have consented to be contacted electronically (by email or SMS), we will only contact you electronically based on our legitimate interests or as permitted by applicable law. Please go to your account settings to opt-out or submit a request via our Support Portal if you do not wish to receive marketing communications from us. o We will not send you information about our Services that are similar to those offered to you in a previous sale or deal that we negotiated with you. Users in the European Economic Area, the United Kingdom and Switzerland: To the extent we can rely on legitimate interest, we will only send you information about our Services that were subject to a previous sale or deal. For marketing purposes, we will only contact you electronically if you have consented to such communications. It is free and easy for you to object to such processing when the data is initially collected or when it is further processed for the purpose of direct marketing. Making a privacy request If you are unable to access the Privacy Rights Dashboard, you may contact us via our Support Portal. In addition to setting your communication preferences, you can also request individual rights in relation to your personal information via our Privacy Rights Dashboard. If you wish to request any individual rights, we recommend that you use the Privacy Rights Dashboard because it ensures that you have already been verified (based on the KYC information you provided to open your account and by providing the login credentials and multi-factor authentication necessary to access your account). Otherwise, in order to protect your privacy and security, we may take steps to verify your identity prior to complying with your request when we receive an individual rights request via other intake mechanisms. How to file a complaint Please contact us first via our Support Portal if you believe we are infringing on your rights so that we can attempt to resolve the issue or dispute informally.

13. CALIFORNIA PRIVACY RIGHTS

You may also request information from us if you are a California resident to determine whether we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. We may share the following information with you in this way:

• During the calendar year preceding this one, the types of information we disclosed to third parties for their direct marketing purposes; and

• You can use this information to provide the names and addresses of third parties who received this information, or, if you cannot figure out the nature of their business by the name, examples of the products or services they marketed. California residents are entitled to certain rights with respect to their personal information as a result of the California Consumer Privacy Act of 2018 ("CCPA"). However, there are limited exceptions to these rights. In this section, we use terms defined in the California Privacy Rights Act in the same way. A description of California residents' rights is included in the section below, as well as information about the categories of personal information IndexBlack has collected and disclosed. Categories of Personal Information Collected The following table describes the types of personal information IndexBlack has collected in the last 12 months, the sources and purposes of such collection, and the parties with whom the information has been shared.

Personal Information Category (corresponds to categories in CCPA §1798.140(o)(1))	Sources of Personal Information and Why We Collect this Information (see Section 4 above for more information)	Disclosure of Personal Information (see “Why We Share Personal Information with Other Parties” heading above for more information)
(A) Identification data, such as personal information	Information you provide us; Information collected from third parties; Why we collect this information: see Section 5, subsections 1, 2, 3, 4, 5, 6, 8, 9, 11, and 12	- Third party identity verification services - Financial institutions - Service providers - Professional advisors - our Affiliates
(B) Information about customers, such as signatures	Information you provide us; Information collected from third parties; Why we collect this information: see Section 5, subsections 1, 2, 5, 6, and 11	- Third party identity verification services - Financial institutions - Service providers
(C) Protected classifications under California and federal law, including gender, age and citizenship	Information you provide us; Information collected from third parties; Why we collect this information: see Section 5, subsection 1	- Third party identity verification services - Professional advisors
(D) Commercial information such as records of services purchased, obtained, or considered	Information you provide us; Information we collect from you automatically; Information collected from third parties; Why we collect this information: see Section 5, subsections 3, 4, 5, 6, 8, 9, 10, 11 and 12	- Third party identity verification services - Financial institutions - Service providers - Professional advisors - our Affiliates
(E) Biometric information	Information you provide us; Why we collect this information: see Section 5, subsection 1	- Third party identity verification services - Financial institutions
(F) Usage Data	Information we collect from you automatically; Why we collect this information: see Section 5, subsections 2, 3, 4, 6, 7, 8, 9, 10, and 12	- Third party identity verification services - Service providers - Professional advisors - our Affiliates
(G) Online Identifiers	Information we collect from you automatically; Why we collect this information: see Section 5, subsections 1, 3, 9 and 12	- Third party identity verification services - Service Providers
(H) Sensory data, such audio, electronic, visual information	Information you provide to us; Why we collect this information: see Section 5, subsections 3, 4, 5 and 7	Not applicable
(I) Professional or employment-related information	Information you provide us; Information collected from third parties; Why we collect this information: see Section 5, subsections 1, 12	- Third party identity verification services - Service providers - our Affiliates
(J) Inferences about preferences, characteristics, predispositions, etc.	Information you provide us; Information we collect from you automatically; Why we collect this information: see Section 5, subsections 9, 10, 12	- Service providers - Professional advisors - our Affiliates

Do Not Track

"Do Not Track" or "DNT" signals can be sent from certain Internet browsers, such as Internet Explorer, Firefox, and Safari. We currently do not respond to or process "DNT" signals since uniform standards have not been adopted.

Digital Balances

IndexBlack carries crime insurance that protects a portion of digital assets held across our storage systems against losses from theft, including cybersecurity breaches. However, our policy does not cover any losses resulting from unauthorized access to your personal IndexBlack account(s) due to a breach or loss of your credentials. It is your responsibility to use a strong password and maintain control of all login credentials you use to access IndexBlack. Digital currency is not legal tender and is not backed by the government. Digital currency, (including but not limited to tokens such as bitcoin, litecoin, and ethereum and stablecoins such as USDC), is not subject to Federal Deposit Insurance Corporation (“FDIC”) or Securities Investor Protection Corporation protections. In case of a covered security event, we will endeavor to make you whole; however, total losses may exceed insurance recoveries so funds may still be at risk.

Cash Balances

Cash balances, such as U.S. Dollars, British Pounds, Euros, customers store with IndexBlack are held as a balance in your IndexBlack account(s). For U.S. customers, IndexBlack combines your balance with the balances of other customers and holds those funds in custodial accounts at U.S. banks and/or invests those funds in liquid U.S. Treasuries or USD denominated money market funds in accordance with state money transmitter laws. Funds could be held in any one of these three manners so customers should not assume that funds are being held in one manner over the other. For non-U.S. customers, funds are held as cash in dedicated custodial accounts. All custodial pooled amounts are held separate from IndexBlack funds, and IndexBlack will neither use these funds for its operating expenses or any other corporate purposes.

To the extent U.S. customer funds are held as cash, they are maintained in pooled custodial accounts at one or more banks insured by the FDIC. Our custodial accounts have been established in a manner to make available pass-through FDIC insurance up to the per-depositor coverage limit then in place (currently $250,000 per individual). FDIC pass-through insurance protects funds held on behalf of a IndexBlack customer against the risk of loss should any FDIC-insured bank(s) where we maintain custodial accounts fail. FDIC insurance coverage is contingent upon IndexBlack maintaining accurate records and on determinations of the FDIC as receiver at the time of a receivership of a bank holding a custodial account.

IndexBlack Cookie Policy Effective Date: May, 2022

It explains how BlackRock, Inc. and its affiliate company (IndexBlack) use cookies and similar technologies on indexblack.com and any other website, page, feature, or content owned or operated by IndexBlack, and when you interact with IndexBlack advertisements or marketing emails. Here you can learn about these technologies, why we use them, and what control you have over our use of them.

Cookie and similar technologies can be used in some cases to collect personal information, or information that may become personal information if it is combined with other information. Additionally, to this Cookie Policy, the IndexBlack Privacy Policy will apply.

WHAT DO COOKIES DO?

Cookies are small files, typically of letters and numbers, downloaded onto your computer or mobile device when you visit certain websites. When you return to these websites, or visit other websites that use the same cookies, the websites recognize these cookies and your browsing device. A cookie cannot read data off your hard drive or read cookie files created by other websites.

Cookies set by the website operator are called "first party cookies". Cookies set by parties other than the website operator are called "third party cookies". The parties that set third party cookies can recognize your web browser both when it visits the IndexBlack website and when it visits certain other websites where the third party’s cookies are also present.

More information on cookies and their use can be found at www.aboutcookies.org or www.allaboutcookies.org.

WHY DO WE USE COOKIES?

When you access our Sites and Services, we or companies we work with may place cookies on your computer or other device. These technologies help us better understand user behavior, and inform us about which parts of our websites people have visited.

We use first party and third-party cookies to recognize you as a IndexBlack customer, customize IndexBlack Services, content, and advertising, to measure promotional effectiveness, and to collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.

We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from IndexBlack. We do not control the types of information collected and stored by these third-party cookies.

The following are some examples of information that we collect and how we may use it:

We may collect and store details of how you use our Sites and Services. Except in limited instances to ensure quality of our Services over the Internet, such information will not be associated with your IP address.

We may collect information such as your language, inferred zip code or area code, unique device identifier, referrer URL, location, and time zone so that we can better understand customer behavior and improve our Services.

We may collect information regarding customer activities on our websites and platforms, which is used to understand which parts of our Sites and Services are of most interest. This data is aggregated, and thus is considered non-personal information for the purposes of this Cookie Policy and our Global Privacy Policy.

WHAT TYPES OF COOKIES DO WE USE? We use the following types of cookies:

Strictly Necessary Cookies

These cookies are necessary for the Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. These also include cookies we may rely on for fraud prevention. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.

Performance/Analytics Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Sites. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functionality Cookies

These cookies allow us to remember the choices you make and to tailor our Services so we can provide relevant content to you. For example, a functionality cookie can remember your preferences (e.g., country or language selection), or your username.

Targeting/Advertising Cookies

IndexBlack uses third party service providers to display advertising on our Services and serve advertising on other third-party sites that may be relevant to you or your interests. These cookies are also used to help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information may be shared with other organizations, such as advertisers. This means that after you have been to our websites, you may see some advertisements about our Services elsewhere on the Internet. The information collected through this process by the third-party service providers does not enable us or them to identify your name, contact details or other personal information that directly identifies you unless you choose to provide these. Such advertising will only be delivered where permitted by applicable law. If you do not allow these cookies, you will experience less advertising tailored to your inferred interests on our Sites and will not receive targeted IndexBlack advertisements on third party websites.

WHAT IS THE LENGTH OF TIME THAT COOKIES REMAIN ON MY BROWSING DEVICE?

Whether a cookie is a "persistent" or a "session" cookie determines how long the cookie stays on your device. You will be able to delete session cookies when you close your browser. Unlike session cookies, persistent cookies stay on your computer or mobile device until they expire or are deleted.

DOES INDEXBLACK MAKE USE OF ANY OTHER SIMILAR TECHNOLOGIES?

As well as cookies, we may use similar technologies such as web beacons to track users across our Sites and Services. These tiny graphics resemble cookies in that they contain a unique identifier similar to that of a web beacon. This allows tracking of web users' movements online.

A clear gif, on the other hand, is embedded invisibly on web pages, and is about the size of the period at the end. Cookies are saved to a user's hard drive or device. Web beacons are used by us and our third-party service providers for the reasons outlined above (under "Cookies"), but their primary purpose is to assist us in better managing content on our Services based on the effectiveness of the content.

In addition, we may use what are known as Flash Cookies (also called "Local Shared Objects or LSOs") to collect information about how you use our services, to prevent fraud and for other website operations.

MANAGING COOKIES, SIMILAR TECHNOLOGIES, AND TARGETED MOBILE ADVERTISING ONLINE

A cookie can be accepted or rejected by you. Follow the steps outlined below to modify your preferences with regard to cookies placed on our Sites.

Cookies. By visiting our Cookie Consent Manager, you can enable or disable cookie categories. First-party cookies as well as third-party cookies can be enabled or disabled. Cookies can be enabled, disabled, or deleted in the browser with which you are viewing this website. To do this, follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings), or review the instructions provided by the browsers listed here: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile, and Android browser. Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Sites and Services. Also, you may not be able to use other parts of the Services if you disable cookies. Visit http://www.allaboutcookies.org to find out how to modify your browser's cookie settings.

By navigating to the appropriate settings in your mobile device and following the instructions, you can opt out of having your mobile advertising identifiers be used for certain types of advertising. By opting out, we will delete your personal data and not collect any more. Your ID will be removed from the system. We will not be able to utilize the prior ID if, at a later point, you decide to opt-in and for all practical purposes you will be a new user. For iOS devices, to limit interest-based ad tracking, go to Settings > Privacy > Advertising > Turn on “Limit Ad Tracking.” For Android devices, go to Settings > Google services > Ads > Turn on “opt out of Ads Personalization." For iOS and Android, you can also reset the advertising identifier that is currently assigned to you.

Download the DAA's AppChoices mobile application opt-out solution here: https://youradchoices.com/appchoices/ to opt out of data collection for interest-based advertising across mobile applications.

Do Not Track: Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our Sites do not currently process or respond to "DNT" signals.

Flash Cookies. Those who do not wish Flash Cookies to be stored on their computers can adjust the Flash player's settings to block the storage of Flash Cookies, found at the following URL: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. Flash Cookies can also be controlled via the global storage settings panel. Limiting or restricting Flash Cookie acceptance in the Flash Player could impair the functionality of some Flash applications, including, potentially, Flash applications used in conjunction with our services or online content.

HOW OFTEN WILL OUR COOKIE POLICY BE UPDATED?

Cookie Policy may be updated periodically to reflect, for example, changes to the cookies we use or other operational, legal or regulatory reasons. During every 30-day period, we review all cookies to ensure this is an accurate reflection of all cookies. Our website will notify you when the changes are made the first time you visit it after the change. Feel free to revisit this page to stay informed if you wish.

Here is a comprehensive list of all the cookies used on IndexBlack:-

Name	Purpose	Expiry	Type	Category
<wallet>_is_wiz ard_completed	Identifies if wizard flow has been fully completed for current user.	10 Days	1st Party	Necessary
acid	Stores the Affiliate's Campaign ID.	Session	1st Party	Necessary
cc_cookie_acce pt	Stores the acceptance of cookies.	Session	1st Party	Necessary
cc_cookie_decli ne	Stores the decline of cookie bar.	Session	1st Party	Necessary
completing_part	Completed parts for Wizard in profile completion form.	10 Days	1st Party	Necessary
csrftoken	A CSRF token is a unique, secret, unpredictable value that is generated by the server-side application and transmitted to the user in such a way that it is included in a subsequent HTTP request made by the user. It is used for security purposes in order to prevent abuse of form submission.	1 year	1st Party	Necessary
dark_mode	Used by IndexBlack on redirections to IndexBlack area to switch to dark mode.	Session	1st Party	Necessary
Exit-popup-PSG- Sponsorship	Determines if the exit popup should be displayed.	10 days	1st Party	Necessary

Exit-popup- ROFM	Determines if the exit popup should be displayed.	10 days	1st Party	Necessary
forget_pass	Random number to ensure captcha answer is correct.	30 Days	1st Party	Necessary
forget_pass_x_	Stores captcha answer.	30 Days	1st Party	Necessary
investor	PAMM Investor Account of current user.	Session	1st Party	Necessary
investorHash	Encrypted value PAMM Investor Account of current user.	Session	1st Party	Necessary
lang	Stores user's selected language.	1 month	1st Party	Necessary
ltRefreshedBala nce	Last refreshed balance. If last refreshed balance is less than 15 Minutes it will retrieve the info from ltResponse.	Session	1st Party	Necessary
ltResponse	Balance of wallet.	Session	1st Party	Necessary
master_account	Wallet of current user.	Session	1st Party	Necessary
mc_data	Internal tracking cookie that stores the campaign ID of the first landing page the user visited and identifies the user in the future if they register an account.	1 month	1st Party	Necessary
mcid	Stores campaign ID of landing page visited.	Session	1st Party	Necessary
mobile_app	Used by IndexBlack App on redirections to IndexBlack area to switch to dark mode.	Session	1st Party	Necessary
mylogin	Wallet of current user. Cookie is shared among all subdomains. Used in main website to identify if current browser is logged in to client area.	Session	1st Party	Necessary
Path	Current path tracker.	current session	1st Party	Necessary
redesign_flag	Identifies if IndexBlack area is on redesign or not.	10 Days	1st Party	Necessary
refid	Affiliate ID used to register clients under specific Affiliates.	Session	1st Party	Necessary
regulator	Stores user's regulation.	Session	1st Party	Necessary
show_phone_ve rification	Identifies whether to show phone verification popup.	Session	1st Party	Necessary

show_phone_ve rification_delay

_<wallet>

Identifies whether to show phone verification popup after first occurrence of phone verification popup.

1 Day

1st Party

Necessary

show_profile_u pdate	Identifies whether to show force profile popup.	Session	1st Party	Necessary
user	Random User ID that identifies the user.	1 month	1st Party	Necessary
walletHash	Encrypted value of master_account	Session	1st Party	Necessary
Xrsc11_000	Balance of wallet.	Session	1st Party	Necessary
webinar	Tracks if the visitor is coming from a webinar registration.	Session	1st Party	Marketing
X-Access-Key	Keeps the website session alive.	Session	1st Party	Analytical
Secure- 1PSIDCC	Cookie required to use website options and services.	1 year	3rd Party	Necessary
Secure- 3PSIDCC	Cookie required to use website options and services.	1 year	3rd Party	Necessary
AKA_A2	Used by CDN Akamai for the Akamai cache function, used by the website to optimize the response time between the visitor and the website.	Session	3rd Party	Necessary
captcha_x_	SPAM protection service provided by Google that helps protect websites from spam and abuse.	Session	3rd Party	Necessary
com. IndexBlack.w ww. IndexBlack - smartbanner- closed	Used for the mobile app banner in order to hide the banner if users don’t want to download it.	Session	3rd Party	Necessary
com. IndexBlack.w ww. IndexBlack - smartbanner- installed	Used for the mobile app banner in order to determine whether it should be displayed or not.	Session	3rd Party	Necessary
Consent	Google cookie consent tracker.	17 years	3rd Party	Necessary
LOGIN_INFO	Used to play YouTube videos embedded on the website.	6 months	3rd Party	Necessary
LPSessionID	Cookie for chat history, stored until the browser is closed.	Session	3rd Party	Necessary
LPSID-Site ID	Visitor ID as identified in Conversational Cloud. Identifies a browser as long as the cookie is not deleted.	Session	3rd Party	Necessary

LPVID	Provides technical support to the chat function to make sure that the chat on the website works as intended, e.g. by identifying the browser which enables us to remember ongoing and previous chats as well as know where a user is visiting the website from.	1 year	3rd Party	Necessary
orejime	Store the user's consent about accepting/rejecting cookies	1 year	3rd Party	Necessary
SAME_SITE	Prevents the browser from sending this cookie along with cross-site requests.	Session	3rd Party	Necessary
VISITIR_INFO1_L IVE	Used to play YouTube videos embedded on the website.	6 months	3rd Party	Necessary
wordpress_test _cookie	WordPress sets a test cookie for every visitor to check if the browser accepts cookies.	current session	3rd Party	Necessary
xsrf	Used for security purposes in order to prevent abuse of form submission.	Session	3rd Party	Necessary
ar_v4	Owned by Doubleclick (Google). Uses Doubleclick to manage real-time bidding advertising exchange.	1 year	3rd Party	Marketing
adroll_fpc	Used to collect and use personalised data in order to deliver targeted and personalised advertising.	1 year	3rd Party	Marketing
_fbp	Used by Facebook to store and track visits across websites. The expiration is controlled by settings in the plugin.	3 months	3rd Party	Marketing
anid	Used to show Google ads on non- Google sites.	13 months	3rd Party	Marketing
Hm_lpvt	Used by Baidu Analytics to limit the frequency of requests. Baidu Analytics collects information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.	Session	3rd Party	Marketing
_clck	Microsoft clarity is using this cookie to store a unique user ID	1 year	3rd Party	Analytical

_clsk	Microsoft clarity is using this cookie to store and combine page views by a user into a single session.	1 day	3rd Party	Analytical
_uetsid	Microsoft Bing Ads is using this cookie to store and track visits across websites	1 day	3rd Party	Analytical
_uetvid	Microsoft Bing Ads is using this cookie to store and track visits across websites	16 days	3rd Party	Analytical
utmc	Stores time of visit on the website.	30 minutes	3rd Party	Analytical
utmz	Stores used keyword and search engine.	6 months	3rd Party	Analytical
_ga	Google Analytics uses the _ga and _gid cookies to distinguish unique users and pages that users have seen. The _ga cookie counts the number of visits to a page or post.	2 years	3rd Party	Analytical
_gac_gb_<conta iner-id>	Contains campaign related information. If Google Analytics and Google Ads accounts are linked, Google Ads website conversion tags will read this cookie unless the user opts out.	3 months	3rd Party	Analytical
_gat_gtag_UA_ 16960429_1	Used by Google Analytics to track conversions. Reads and filters requests from bots and then identifies users across browsing sessions.	1 min	3rd Party	Analytical
_gcl_au	Takes information in ad clicks and stores it in a first-party cookie so that conversions can be attributed outside the landing page.	Session	3rd Party	Analytical
_gid	Google Analytics uses the _ga and _gid cookies to distinguish unique users and pages that users have seen. The _gid cookie prevents repeats views of a page or post by a visitor.	1 day	3rd Party	Analytical

_hjAbsoluteSess ionInProgress	Detects the first pageview session of a user and sets a True/False flag.	30 Minutes	3rd Party	Analytical
_hjCachedUserA ttributes	Stores User Attributes which are sent through the Hotjar Identify API, whenever the user is not in the sample. Collected attributes will only be saved to Hotjar servers if the user interacts with a Hotjar Feedback tool, but the cookie will be used regardless of whether a Feedback tool is present.	Session	3rd Party	Analytical
_hjClosedSurvey Invites	Hotjar cookie that is set once a user interacts with an External Link Survey invitation modal, used to ensure that the same invite does not reappear if it has already been shown.	1 year	3rd Party	Analytical
_hjDonePolls	Hotjar cookie that is set once a user completes a survey using the On-site Survey widget, used to ensure that the same survey does not reappear if it has already been filled in.	1 year	3rd Party	Analytical
_hjFirstSeen	Set to identify a new user’s first session. It stores a true/false value, indicating whether this was the first time Hotjar saw this user. It is used by Recording filters to identify new user sessions.	Session	3rd Party	Analytical
_hjid	Hotjar cookie that is set when the customer first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID unique to that site on the browser and ensure that behavior in subsequent visits to the same site will be attributed to the same user ID.	365 days	3rd Party	Analytical
_hjIncludedInPa geviewSample	Set to let Hotjar know whether user is included in the data sampling defined by the site's pageview limit.	30 minutes	3rd Party	Analytical
_hjIncludedInSe ssionSample	Set to let Hotjar know whether user is included in the data sampling defined by the site's daily session limit.	30 minutes	3rd Party	Analytical

_hjLocalStorage Test	Checks if the Hotjar Tracking Script can use local storage. If it can, a value of 1 is set in this cookie. The data stored in_hjLocalStorageTest has no expiration time, but it is deleted almost immediately after it is created.	Under 100ms	3rd Party	Analytical
_hjMinimizedPo lls	Hotjar cookie that is set once a user minimizes an On-site Survey widget, used to ensure that the widget stays minimized when the user navigates through the site.	1 year	3rd Party	Analytical
_hjOptOut	This cookie is used to find whether the hotjar cookie is opted out of or not.	4 months	3rd Party	Analytical
_hjRecordingEn abled	Added when a Recording starts and read when the recording module is initialized to see if the user is already in a recording in a particular session.	Session	3rd Party	Analytical
_hjRecordingLas tActivity	Updated when a user recording starts and when data is sent through WebSocket (the user performs an action that Hotjar records).	Session	3rd Party	Analytical
_hjSessionRejec ted	If present, this cookie will be set to '1' for the duration of a user's session, if Hotjar rejected the session from connecting to our WebSocket due to server overload. This cookie is only applied in extremely rare situations to prevent severe performance issues.	Session	3rd Party	Analytical
_hjSessionResu med	Set when a session/recording is reconnected to the Hotjar servers after a break in connection.	Session	3rd Party	Analytical
_hjSessionTooLa rge	Causes Hotjar to stop collecting data if a session becomes too large. This is determined automatically by a signal from the WebSocket server if the session size exceeds the limit.	Session	3rd Party	Analytical
_hjShownFeedb ackMessage	Hotjar cookie that is set when a user minimizes or completes Incoming Feedback so that the Incoming Feedback will load as minimized immediately if the user navigates to another page where it is set to show.	365 days	3rd Party	Analytical

_hjTLDTest	When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed.	Session	3rd Party	Analytical
_hjUserAttribut esHash	User Attributes sent through the Hotjar Identify API are cached for the duration of the session in order to know when an attribute has changed and needs to be updated.	Session	3rd Party	Analytical
_hjViewportId	Stores information about the user viewport such as size and dimensions.	Session	3rd Party	Analytical
1P_JAR	Used by Google to collect website statistics and track conversion rates.	1 month	3rd Party	Analytical
APISID	HSID, SSID, APISID and SAPISID cookies enable Google to collect user information for videos hosted by YouTube.	2 years	3rd Party	Analytical
hjSiteLang	Set when a page that supports multiple languages on hotjar.com is visited so content is always loaded in the preferred language when available.	365 days	3rd Party	Analytical
Hm_lvt_	Baidu Analytics Tongji. Records a unique ID used to generate statistical data on how a visitor uses the website.	1 year	3rd Party	Analytical
OGPC	Enables the functionality of Google Maps.	Session	3rd Party	Analytical
OTZ	Used by Google Analytics to provide an aggregate analysis of Website visitors.	1 year	3rd Party	Analytical
pvc_visits[0]	Cookie created by post-views-counter third party which counts the number of visits to a post, and is used to prevent repeat views of a post by a visitor. The expiration is controlled by settings in the plugin.	Session	3rd Party	Analytical

RUL

Used by Google DoubleClick to determine whether the website advertisement has been properly displayed and collect data in order to

show relevant advertising to the visitor across the web.

1 year

3rd Party

Analytical

SAPISID

HSID, SSID, APISID and SAPISID cookies enable Google to collect user

information for videos hosted by YouTube.

2 years

3rd Party

Analytical

utma

The number of visits, including the time

of the first visit, the previous visit, and the current visit.

2 years

3rd Party

Analytical

This agreement (the “Agreement”) is for customers who reside outside the United States of America, United Kingdom, European Economic Area, Japan and Singapore.

IndexBlack is regulated by the UK Financial Conduct Authority.

This is a contract between you and each of:

IndexBlack a private limited company in affiliation with BlackRock Inc, incorporated in England and Wales with company number
09708629 and whose registered office address is 5 Fleet Place, London EC4M 7RD, United Kingdom;

References in this Agreement to "IndexBlack", "we", "our" or "us", are to IndexBlack depending on the services being discussed, and references to "you" or "your" are to the person with whom IndexBlack enters into this Agreement.

By signing up to use an account through IndexBlack.com or any of our associated websites, application programming interfaces (“APIs”), or mobile applications (collectively the "Site"), you agree that you have read, understood, and accept all of the terms and conditions contained in this Agreement, as well as our Privacy Policy and Cookie Policy.

We refer to the E-Money Services, Digital Currency Services and Additional Services (all defined below) collectively as the " IndexBlack Services", which can be accessed via the platform operated by IndexBlack (the “IndexBlack Platform”) (including the online platform which is accessible via the Site or at such location as may be prescribed by IndexBlack from time to time). Access to EMoney Services is not automatic is only provided where IndexBlack cedes in its discretion to provide them. Each of the IndexBlack Services is provided by IndexBlack as set out in clause 2 below.

*You should be aware that the risk of loss in trading or holding Digital Currencies can be substantial. As with any asset, the value of Digital Currencies can go up or down and there can be a substantial risk that you lose money buying, selling, holding, or investing in digital currencies. Digital Currency Services and Additional Services are not currently regulated by the Financial Conduct Authority or any other regulator in the UK. The Digital Currency Services and Additional Services are not within scope of the jurisdiction of the UK Financial Ombudsman Service, and your Digital Currencies and E-Money are not subject to protection under the UK Financial Services Compensation Scheme. Digital Currencies are not legal tender in the UK and as such no protection exists for you in the event that IndexBlack faces financial difficulties. You should carefully consider whether trading or holding Digital Currencies is suitable for you in light of your financial condition.*

1. ELIGIBILITY.

To be eligible to use any of the IndexBlack Services, you must be at least 18 years old and reside in a country in which the relevant IndexBlack Services are accessible. Please note that not all IndexBlack Services are available in every country. The list of IndexBlack Services accessible by country can be found at https://www.indexblack.com.

2. SERVICES.
2.1 E-Money Services.

Services provided by IndexBlack (the "E-Money Services") include:

(A) a digital wallet hosted by IndexBlack that allows you to store electronic money issued by IndexBlack that is denominated in fiat currency (aka "E-Money");

(B) the ability to send and receive E-Money through certain payment services (as detailed below).

UK financial regulator, Financial Conduct Authority ("FCA"), regulates the E-Money Services. With register number 900635, IndexBlack is an authorized electronic money institution registered with the FCA and regulated by it. There is no automatic access to IndexBlack E-Money Services; they are only available when IndexBlack chooses to offer them at its sole discretion.

2.2 Several Liability. It is understood that IndexBlack’s liability is separate and not joint, and that each transaction shall be responsible only for its own obligations under this Agreement, excluding any breach of those obligations by another transaction. Therefore, they are liable to you only for their own breach of this Agreement, and not for each other's.

2.3 Charges. By using this service, you agree to pay all charges. On the ‘Pricing and Fees Disclosures’ and ‘Trading Fees’ pages on the Site, which shall form part of this Agreement, you will find a list of the fees associated with IndexBlack Services, as amended from time to time.

3. ACCOUNT SETUP.

3.1 Registering an account on IndexBlack. By creating a IndexBlack account and accepting the terms of this Agreement, you can access the IndexBlack Services. Using a IndexBlack Account constitutes your agreement to use the IndexBlack Services only for yourself and not on behalf of another entity, unless IndexBlack has already given you prior approval in accordance with Section 3.2 and 4.10 of this Agreement. Customers are limited to

registering one IndexBlack account each. All activities associated with that account are your responsibility. If we determine that we no longer want to open a IndexBlack Account for you, or if we no longer want to handle any IndexBlack Accounts (including duplicate accounts) or if we no longer wish to handle the trading of specific Digital Currencies in your account, we may refuse to open the account.

3.2 Third party Access. You acknowledge that the express permission you give to a Regulated Third

Party to access or connect to your IndexBlack Account(s), either through the Regulated Third
Party's product or service or through the Site, will not relieve you of any of your obligations under this Agreement. Regulated Third Parties who have access to your IndexBlack Account(s) are fully responsible for any act or omission, and any action they take is considered an act you have authorized. Further, you agree not to hold IndexBlack liable for any act or omission of any Regulated Third Party with access to your IndexBlack Account(s) and will indemnify IndexBlack from any and all such liability.

With respect to your IndexBlack Account(s), you may change or remove permissions granted by you at any time through the tabs on the 'Settings' page of the Site.

3.3 Identity Verification. If we ask for any information (which we may ask at any time deemed appropriate) for the purposes of identifying you and detecting money laundering, terrorist financing, fraud, or any other form of financial crime, including as outlined in Appendix 2 (Verification Procedures and Limits), you agree to provide it to us and allow us to keep a record of it. Before you are allowed to start using the IndexBlack Services and to access specific IndexBlack Services, including certain transfers of E-Money and Digital Currency, you will have to complete certain verification procedures, and the limits applicable to your use of the IndexBlack Services may be altered in light of the information we collect on an ongoing basis.

If we request information from you, it may include (but is not limited to) personal information such as your name, residential address, telephone number, email address, date of birth, taxpayer identification number, government identification number, information regarding your bank account (such as the bank name, IndexBlack collects and maintains customer information that refers to the type of account, routing number, account number, the customer role, billing type, international subscriber identifiers, international mobile equipment identifiers, and other subscriber status information, as well as any other information that it is required to collect from time to time under applicable law..

You may also be required to undergo “Enhanced Due Diligence”, where IndexBlack may request that you submit additional information about yourself or your business, provide relevant records, and arrange for meetings with IndexBlack staff so that IndexBlack may, among other things, establish the source of your wealth and source of funds for any transactions carried out in the course of your use of IndexBlack Services.

By providing us with this or any other information that we require, you affirm that the information is true, accurate, and complete, and that no information has been withheld that could influence

IndexBlack evaluation of you for purposes of your registration for a IndexBlack Account or the provision of IndexBlack Services to you. In addition, you agree to promptly notify IndexBlack in writing as soon as there are any changes in circumstances that may cause any such information provided to become false, inaccurate, or incomplete. Additionally, you agree to provide IndexBlack with any other additional documents, records, and information that may be required by IndexBlack and/or applicable law. Such information may be retained by IndexBlack.

It is your consent to us making inquiries directly or through third parties that we consider necessary to verify your identity or to protect you and/or us from fraud and/or other financial crimes, as well as to take action we reasonably deem necessary based on the results of such inquiries. If you provide us with your personal information, you agree that your personal information may be disclosed to credit reference agencies, fraud prevention agencies, and financial crime investigators. These entities have the right to respond to our inquiries fully. Your credit rating will not be adversely affected by this identification check. You may be required to wait some period of time after completing a transaction before using further IndexBlack Services and/or before engaging in transactions that exceed certain volume limits.

By providing us with this or any other information that we require, you affirm that the information is true, accurate, and complete, and that no information has been withheld that could influence IndexBlack evaluation of you for purposes of your registration for a IndexBlack Account or the provision of IndexBlack Services to you. In addition, you agree to promptly notify

IndexBlack in writing as soon as there are any changes in circumstances that may cause any such information provided to become false, inaccurate, or incomplete. Additionally, you agree to provide IndexBlack with any other additional documents, records, and information that may be required by IndexBlack and/or applicable law. Such information may be retained by IndexBlack.

4. E-MONEY SERVICES

4.1 Loading. You can load funds into your E-Money Wallet using bank transfer (or other payment methods available on the Site for your location), and your E-Money Wallet will show loaded funds once

we have received them. Loading of funds may be done manually, or as part of a recurring transaction that you set up on your IndexBlack Account (see Section 5.12 below for more details). You may only load your own funds, from your own account, and not from any joint, pooled or third party account. When funds are loaded into the E-Money Wallet you will be issued with E-Money by IndexBlack Payments that represents the funds you have loaded. The E-Money Wallet is not a deposit or investment account which means that your E-Money will not be protected by the Financial Services Compensation Scheme. IndexBlack Payments will only hold funds received from users in a designated safekeeping account with a regulated financial institution. E-Money held in an E-Money Wallet will not earn any interest. Your E- Money Wallet may hold E-Money denominated in different currencies and we will show the E-Money balance for each currency that you hold.

4.2 Purchase or Sale of Digital Currency. You may purchase supported Digital Currency by using EMoney credited to your E-Money Wallet. To carry out a Digital Currency Transaction using E-Money, you must follow the relevant instructions on the Site. A Digital Currency Transaction using E-Money should normally be settled no later than one business day after we receive your instructions. You authorise us to debit E-Money from your E-Money Wallet. Although we will attempt to deliver Digital Currency to you as promptly as possible, E-Money may be debited from your E-Money Wallet before Digital Currency is delivered to your Digital Currency Wallet.

You may sell Digital Currency in exchange for E-Money. You authorise us to debit your Digital Currency Wallet and credit your E-Money Wallet with the relevant amount of E-Money.

4.3 Receipt of Instructions. If we receive instructions from you to purchase Digital Currency using EMoney on a non-business day or after 4:30 pm (London time) on a business day, we may treat those instructions as if they were received by us on the following business day.

4.4 Revocation. When you give us instructions to carry out a Digital Currency Transaction using EMoney, you cannot withdraw your consent to that Digital Currency Transaction unless the Digital
Currency Transaction is not due to occur until an agreed date in the future e.g. if you have set up Future Transactions (see Section 5.12 below for more details). In the case of a Future Transaction, you may withdraw your consent up until the end of the business day before the date that the Future Transaction is due to take place. To withdraw your consent to a Future Transaction, follow the instructions on the Site.

4.5 Unsuccessful Payments. If a payment to load funds into your E-Money Wallet is not successful, you authorise IndexBlack, in its sole discretion, either to cancel any related Digital Currency Transactions or to debit your other payment methods, including IndexBlack balances or other linked accounts, in any amount necessary to complete the Digital Currency Transactions in question. You are responsible for

maintaining an adequate balance and/or sufficient credit limits in order to avoid overdraft, or similar fees charged by your payment provider.

4.6 Account Information. You will be able to see your E-Money Wallet balance and your transaction history using the Site, including (i) the amount (and currency) of each Digital Currency Purchase, (ii) a reference to identify the payer and / or payee (as appropriate), (iii) any fees charged (including a breakdown of the fees), (iv) where there has been a currency exchange, the rate of exchange, and the amount (in the new currency) after exchange (where you are the payer) or the amount (in the original currency) before the exchange (where you are the payee), and (v) the debit or credit date of each Digital Currency Purchase (as appropriate).

4.7 Redeeming E-Money. You may redeem all or part of any E-Money held in your E-Money Wallet at any time by selecting the relevant option in the Site and following the instructions. Unless agreed otherwise, funds will be transferred to the bank account you have registered with us. If this Agreement is terminated, we will redeem any E-Money remaining in your E-Money Wallet and attempt to transfer funds to the bank account you have registered with us. Prior to redeeming E-Money from your E-Money Wallet, we may conduct checks for the purposes of preventing fraud, money laundering, terrorist financing and other financial crimes, and as required by applicable law. This may mean you are prevented or delayed from withdrawing E-Money until those checks are completed to our reasonable satisfaction in order to comply with our regulatory requirements.

4.8 Unauthorised and Incorrect Transactions. Where a purchase of Digital Currency and / or redemption of E-Money is initiated from your E-Money Wallet using your credentials, we will assume that you authorised such transaction, unless you notify us otherwise.

If you believe that a transaction using your E-Money Wallet has been carried out that you did not authorize (an “Unauthorized Transaction”), or if you have reason to believe that a transaction using your E-Money Wallet has been incorrectly carried out or is not complete (an “Incorrect Transaction”), you must contact us as soon as possible, and in any case no later than 13 months after the Unauthorised Transaction or Incorrect Transaction occurred.

It is important that you regularly check your E-Money Wallet balance and your transaction history to ensure any Unauthorised Transactions or Incorrect Transactions are identified and notified to us at the earliest possible opportunity.

4.9 Refund Rights.

(A) Unauthorised Transactions - E-Money Wallet.

If an Unauthorised Transaction occurs in your E-Money Wallet as a result of our failure, we will refund you the amount of that transaction by no later than the end of the next business day after becoming aware of the Unauthorised Transaction and restore your E-Money Wallet to the state it would have been in had the Unauthorised Transaction not taken place. Generally, you will not be liable for losses incurred after you have notified us of the Unauthorised Transaction or if we have failed at any time to provide you with the means for notifying us.

Where there is a dispute between us and you regarding whether or not a transaction is an Unauthorised Transaction, we may (but are not obliged to) temporarily credit your E-Money Wallet whilst we settle the dispute. Where we determine that the transaction was authorised, we may reverse that credit and correct errors made in any statement of E-Money Wallet without prior notice to you, although please note that during this period your E-Money Wallet may be temporarily locked to avoid further Unauthorised Transactions. You will also be liable to us (as a debt) for any E-Money you have transferred which was temporarily credited to your E-Money Wallet.

(B) Incorrect Transactions - E-Money Wallet.

Where an Incorrect Transaction is made in your E-Money Wallet as a result of our action or error we shall refund to you the amount of that transaction without undue delay and restore your E-Money Wallet to the state in which it would have been had the Incorrect Transaction not taken place. We will also endeavor to provide you with reasonable notice where possible. We will also pay any charges for which we are responsible, and for any interest which you can show that you have had to pay as a consequence of any Incorrect Transaction. Irrespective of our liability, on your request, we shall try to trace any Incorrect Transaction initiated by you free of charge. However, we cannot guarantee that we will be able to trace such transactions.

4.10 Appointment of Regulated Third Parties. You may, as set out in Section 3.2, appoint appropriately regulated third parties to access your E-Money Wallet (“Regulated Third Parties”). If you do so, you should be aware that by virtue of such access, that Regulated Third Party may access your transactional and other data, and / or may initiate transfers from your E-Money Wallet. You will be liable for any actions that any Regulated Third Parties take on your IndexBlack Account, as further set out in Section 3.2 above. We reserve the right to refuse access to any Regulated Third Parties, as set out in Section 4.11 below.

4.11 Refusing to deal with Regulated Third Parties. We may refuse access to Regulated Third Parties for objectively justified and duly evidenced reasons relating to unauthorised or fraudulent access to your EMoney Wallet, money laundering, terrorist financing, fraud, or any other financial crime, and as required by applicable law. In such cases, unless we are prohibited

by applicable law, we will inform you that that Regulated Third Party's access has been denied and the reasons why. We will permit access again once we are satisfied that the reasons for refusing access no longer exist.

4.12 Consent. By opening a IndexBlack Account with us you provide your explicit consent to us providing payment services (i.e. the E-Money Services) to you. You can withdraw this consent at any time by closing your IndexBlack Account.

For the avoidance of doubt, this consent does not relate to our processing of your personal information or your rights under and in accordance with data protection law and regulations. Please see Section 11 (Data Protection) below and our Privacy Policy for information about how we process your personal data, and the rights you have in respect of this.

4.13 Financial Ombudsman Service. If you have a complaint relating to the E-Money Services provided to you by IndexBlack Payments, and that complaint cannot be resolved through the dispute process set out in Section 10.2, you may then be able to take unresolved complaints to the Financial Ombudsman Service ("FOS"). You agree that you will not raise a complaint with the FOS until the dispute process set out in Section 10.2 has been completed.

5. DIGITAL CURRENCY SERVICES.

5.1 In General. Digital Currency can be sent and received from Third Party Wallets outside IndexBlack Platforms, or can be redeemed, received, and stored by third parties outside the Platform (these transactions are considered to be "Digital Currency Transactions").

For the purchase of Digital Currency on IndexBlack, the following options are available:

(A) IndexBlack Payments will receive E-Money from your E-Money Wallet;

(B) Central bank issued currency (such as GBP or EUR) supported by IndexBlack; and/or

Conversely, when you sell Digital Currency on the IndexBlack Platform, you may elect to receive: (D) E- Money into your E-Money Wallet held with IndexBlack Payments;

(E) Central bank issued currency (such as GBP or EUR) supported by IndexBlack; and/or

(F) Other types of Digital Currency in your Digital Currency Wallet.

IndexBlack facilitates and enables the purchase and sale of Digital Currency between its customers on the IndexBlack Platform.

5.2 Fiat Currency Transactions (not using your E-Money Wallet). Your Digital Currency Wallet can be used to purchase supported Digital Currencies by linking a valid payment method. To complete your purchase, you authorize us to deduct funds from your selected payment method(s).

The Digital Currency will be delivered to your Digital Currency Wallet as soon as possible, but funds may be debited from your selected payment method before your Digital Currency Transaction is complete, and before the Digital Currency has been delivered to your Digital Currency Wallet. With
IndexBlack, you can sell Digital Currency for fiat currencies (such as GBP or EUR). If you authorize us to debit your Digital Currency Wallet and/or credit your selected payment method(s) in settlement of sell transactions, we will debit your Digital Currency Wallet and credit your selected payment method(s). As soon as possible, we will send these instructions. Once we send such instructions, your selected payment method(s) should be credited by the end of the business day.

5.3 Fulfillment of the Order. It is our goal to fulfill every purchase of Digital Currency, but in some cases we may not be able to. Upon receiving such notification, we will contact you and ask for your approval to re-attempt the purchase at the current Exchange Rate (as defined below).

5.4 Availability of Payment Methods. Payment methods are available based on a number of variables, including, for example, where you are located, the identification information that you provide to us, and limitations imposed by third parties.

5.5 Conversion Fees. Whenever Digital Currency is bought or sold, there is a fee (the "Conversion Fee"). The Conversion Fee applicable to each transaction will be displayed on the Site before the transaction is completed as well as on each receipt. Our Conversion Fees are subject to change at any time without notice. We will not process a transaction if you will be charged more than the value of your transaction, together with the Conversion Fee and any other associated fees.

5.6 Exchange Rates. A Digital Currency sale or purchase is also dependent on the exchange rate at the time of the transaction. As defined on the Website, an "Exchange Rate" represents the price of a supported Digital Currency in fiat currency. Depending on your preference, the Exchange Rate is stated as either a "Buy Price" or a "Sell Price," which corresponds to the price at which you may buy or sell Digital Currency.

There is a possibility that the Buy Price Exchange Rate may differ from the Sell Price Exchange Rate at any given time, and that we may add a margin, or a spread, to the quoted Exchange Rate. In order to authorize a transaction, you must accept the Exchange Rate. A specific Exchange Rate cannot be guaranteed. Digital Currency can be bought and / or sold on the open market at any particular price and at any given time is not guaranteed.

5.7 Authorizations; Reversals; Cancellations. You agree to pay any associated conversion fees, exchange fees, and any other fees by clicking on the Buy or Sell button on the Site.

Any transaction marked as complete or pending cannot be canceled, reversed, or changed. We reserve the right to, in our sole discretion, cancel the transaction if you do not complete the payment or if your payment method does not have sufficient funds to complete your transaction. You authorize us, in our sole discretion, to use your other payment methods, including the balances in your E-Money Wallet and/or Digital Currency Wallet, in order to complete the transaction. Your payment provider may charge you fees for overdrafts, insufficient funds, or similar items if you do not maintain an adequate balance and/or credit limit. Until such insufficient payment is addressed, IndexBlack reserves the right to suspend access to all IndexBlack Services.

5.8 Digital Currency Transactions. We will process Digital Currency Transactions in accordance with the instructions we receive from you. You should verify all transaction information prior to submitting instructions to us. We do not guarantee the identity of any user, receiver, requestee or other third party and we will have no liability or responsibility for ensuring that the information you provide is accurate and complete.

Digital Currency Transactions cannot be reversed once they have been broadcast to the relevant Digital Currency network. If you initiate a Digital Currency Transaction by entering the recipient's email address or mobile phone number and the recipient does not have an existing IndexBlack Account, we will invite the recipient to open a IndexBlack Account. If the recipient does not open a

IndexBlack Account within 30 days, we will return the relevant Digital Currency to your Digital Currency Wallet.

We may charge network fees (“miner fees”) to process a Digital Currency Transaction on your behalf. We will calculate the miner fees at our discretion, although we will always notify you of the miner fees

at (or before) the time you authorize the Digital Currency Transaction. A full list of IndexBlack miner fees can be found on our ‘Pricing and Fees Disclosures’ page on the Site. Miner fees for each individual transaction will be disclosed to you at the time of purchase on the checkout page. When you or a third party sends Digital Currency to a IndexBlack Digital Currency Wallet from an external wallet not hosted on IndexBlack, the person initiating the transaction is solely responsible for executing the transaction properly, which may include, among other things, payment of miner fees in order for the transaction to be completed successfully. Non-payment of miner fees may cause your transaction to remain in a pending state outside of IndexBlack control and we are not responsible for delays or loss incurred as a result of an error in the initiation of the transaction and have no obligation to assist in the remediation of such transactions.

Once submitted to a Digital Currency network, a Digital Currency Transaction will be unconfirmed for a period of time pending sufficient confirmation of the transaction by the Digital Currency network. A Digital Currency Transaction is not complete while it is in a pending state. Digital Currency associated with Digital Currency Transactions that are in a pending state will be designated accordingly and will not be included in your Digital Currency Wallet balance or be available to conduct Digital Currency Transactions until confirmed by the network.

We may also refuse to process or cancel any pending Digital Currency Transaction as required by law, regulation or any court or other authority to which IndexBlack is subject in any jurisdiction, for instance, if there is suspicion of money laundering, terrorist financing, fraud, or any other financial crime.

5.9 Supported Digital Currencies. Our Digital Currency Services are available only in connection with those digital currencies that IndexBlack supports (“Supported Digital Currencies”), and this may change from time to time.

Under no circumstances should you attempt to use your Digital Currency Wallet to store, send, request, or receive digital currencies in any form that we do not support. We assume no responsibility or liability in connection with any attempt to use your Digital Currency Wallet for digital currencies that we do not support. You acknowledge and agree that IndexBlack bears no responsibility and is not liable for any unsupported asset that is sent to a wallet associated with your IndexBlack Account.

5.10 Ending support of a Digital Currency. IndexBlack may in its sole discretion terminate support for any Digital Currency. IndexBlack will provide you no less than 10 days’ notice (unless a shorter period is required by applicable law or a regulatory authority) via email to the email address associated with your IndexBlack account to announce the end of such support. If you do not sell or send such Digital Currency off platform during this time, IndexBlack reserves the right to withdraw such Digital Currencies from

your account and credit your IndexBlack account with the market value of a supported Digital Currency or a fiat currency (which denomination will be selected in our reasonable discretion).

5.11 USDC Wallets. Where available, you may also elect to buy USD Coin through IndexBlack, a
Digital Currency fully collateralized by the US Dollar, which is issued by Circle Internet Financial (“Circle”) and supported by IndexBlack (“USDC”). You are the owner of the balance of your “USDC Wallet” (i.e. the Digital Currency Wallet provided to you by IndexBlack to hold USDC and through which Digital Currency Transactions in USDC can be carried out). IndexBlack is not the issuer of USDC, does not hold U.S. Dollars (“USD”) on reserve for USDC holders, and has no obligation to repurchase your USDC for USD. You can redeem your USDC with Circle, and IndexBlack may also elect to repurchase your USDC in exchange for USD. You agree to be bound by the terms of the Circle USDC Agreement (located at https://support.usdc.circle.com/hc/en-us/articles/360001233386-Circle-USDCUser-Agreement), which provides additional obligations, undertakings, and limitations with respect to USDC.

5.12 Recurring Digital Currency Transactions. If you set up a recurring purchase of Digital Currency (a "Future Transaction"), you authorise us to initiate recurring electronic payments in accordance with your selected Digital Currency Transaction and any corresponding payment accounts, such as direct debits from, or credits to, your linked bank account. Your Future Transactions will occur in identical, periodic instalments, based on your period selection (e.g., daily, weekly, monthly), until either you or IndexBlack cancels the Future Transaction.

If you select a bank account as your payment method for a Future Transaction, and such transaction falls on a weekend or public holiday in the location in which the relevant bank is located, or after the relevant bank’s business hours, the credit or debit will be executed on the next business day, although the Digital Currency fees at the time of the regularly-scheduled transaction will apply. If your bank is unable to process any payment to IndexBlack, we will notify you of cancellation of the transaction and may avail ourselves of remedies set forth in this Agreement to recover any amount owed to

IndexBlack. This authorisation will remain in full force and effect until you change your Future Transaction settings or until you provide us with written notice via https://help.indexblack.com. You agree to notify IndexBlack in writing of any changes in your linked bank account information prior to a Future Transaction.

IndexBlack may, at any time, terminate Future Transactions by providing notice to you.

5.13 Supplemental Protocols Excluded. Unless specifically announced on the Site or via an official public statement of IndexBlack, Supported Digital Currencies excludes all other protocols and/or functionality which supplement or interact with the Supported Digital Currency. This exclusion includes but is not limited to: metacoins, colored coins, side chains, or other derivative, enhanced, or forked protocols, tokens, or coins or other functionality, such as staking, protocol governance, and/or any smart contract

functionality, which may supplement or interact with a Supported Digital Currency (collectively, “Supplemental Protocols”). Do not use your IndexBlack Account to attempt to receive, request, send, store, or engage in any other type of transaction or functionality involving any such Supplemental Protocols, as the IndexBlack Platform is not configured to detect, secure, or process these transactions and functionalities. Any attempted transactions in such items will result in loss of the item.

You acknowledge and agree that Supplemental Protocols are excluded from Supported Digital Currency and that IndexBlack has no liability for any losses related to Supplemental Protocols.

5.14 Operation of Digital Currency Protocols. We do not own or control the underlying software protocols which govern the operation of Digital Currencies supported on our platform. Generally, the underlying protocols are ‘open source’ and anyone can use, copy, modify, and distribute them.

We assume no responsibility for the operation of the underlying protocols and we are not able to guarantee the functionality or security of network operations. You acknowledge and accept the risk that underlying software protocols relating to any Digital Currency you store in your Digital Currency Wallet may change.

In particular, the underlying protocols are likely to be subject to sudden changes in operating rules (including “forks”). Any such material operating changes may materially affect the availability, value, functionality, and/or the name of the Digital Currency you store in your Digital Currency Wallet. IndexBlack does not control the timing and features of these material operating changes. It is your responsibility to make yourself aware of upcoming operating changes and you must carefully consider publicly available information and information that may be provided by IndexBlack in determining whether to continue to transact in the affected Digital Currency using your IndexBlack Account. In the event of any such operational change, IndexBlack reserves the right to takes such steps as may be necessary to protect the security and safety of assets held on the IndexBlack Platform, including temporarily suspending operations for the involved digital currency(ies), and other necessary steps; IndexBlack will use its best efforts to provide you notice of its response to any material operating change; however, such changes are outside of IndexBlack control and may occur without notice to IndexBlack. IndexBlack response to any material operating change is subject to its sole discretion and includes deciding not to support any new digital currency, fork, or other actions.

You acknowledge and accept the risks of operating changes to Digital Currency protocols and agree that IndexBlack is not responsible for such operating changes and not liable for any loss of value you may experience as a result of such changes in operating rules. You acknowledge and accept that IndexBlack has sole discretion to determine its response to any operating change and that we have no responsibility to assist you with unsupported currencies or protocols.

5.15 Digital Currency Storage & Transmission Delays. The IndexBlack Group securely stores Digital Currency private keys, in a combination of online and offline storage. Our security protocols may delay the initiation or crediting of a Digital Currency Transaction.

5.16 Third party Payments. We have no control over, or liability for, the delivery, quality, safety, legality or any other aspect of any goods or services that you may purchase or receive from, or sell or transfer to, any third party (including other users of the Digital Currency Services). We are not responsible for ensuring that a third party buyer or a seller you transact with will complete the transaction or is authorised to do so. If you experience a problem with any goods or services purchased from, or sold to, any third party using Digital Currency transferred using the Digital Currency Services, or if you have a dispute with such third party, you should resolve the dispute directly with that third party.

5.17 IndexBlack Vaults. IndexBlack does not support the use of multisig vaults. You may elect to use other services, such as the IndexBlack Vault, which allow you to set withdrawal timedelays and create other conditions around the custody and transfer of your Digital Currency. Additional rules associated with such product(s) and service(s) may apply.

5.18 Digital Currency Title. All Digital Currencies held in your Digital Currency Wallet are assets held by the IndexBlack Group for your benefit on a custodial basis. Among other things, this means:

(A) Title to Digital Currency shall at all times remain with you and shall not transfer to any company in the IndexBlack Group. As the owner of Digital Currency in your Digital Currency Wallet, you shall bear all risk of loss of such Digital Currency. No company within the IndexBlack Group shall have any liability for fluctuations in the fiat currency value of Digital Currency held in your Digital Currency Wallet.

(B) None of the Digital Currencies in your Digital Currency Wallet are the property of, or shall or may be loaned to, IndexBlack; IndexBlack does not represent or treat assets in a user’s Digital Currency Wallets as belonging to IndexBlack. IndexBlack not grant a security interest in the Digital Currency held in your Digital Currency Wallet. Except as required by a facially valid court order, or except as provided herein, IndexBlack will not sell, transfer, loan, hypothecate, or otherwise alienate Digital Currency in your Digital Currency Wallet unless instructed by you or compelled by a court of competent jurisdiction to do so.

(C) You control the Digital Currencies held in your Digital Currency Wallet. At any time, subject to outages, downtime, and other applicable policies, you may withdraw your Digital Currency by sending it to a different blockchain address controlled by you or a third party.

(D) In order to more securely hold customer Digital Currency, the IndexBlack Group may use shared blockchain addresses, controlled by a member of the IndexBlack Group, to hold Digital Currencies held on behalf of customers and/or held on behalf of IndexBlack. Customers’ Digital Currency is segregated from the IndexBlack Group’s own Digital Currency or funds by way of separate ledger accounting entries for customer and IndexBlack Group accounts. Notwithstanding the foregoing, the IndexBlack Group shall not have any obligation to use different blockchain addresses to store Digital Currencies owned by you and Digital Currencies owned by other customers or by the IndexBlack Group.

IndexBlack is under no obligation to issue any replacement Digital Currency in the event that any Digital Currency, password or private key is lost, stolen, malfunctioning, destroyed or otherwise inaccessible.

5.19 Advanced Trading. IndexBlack offers and you may access an order book for various Digital Currency and Fiat Currency trading pairs (each an “Order Book”) on the IndexBlack Site
(“Advanced Trading”). See your IndexBlack Account to see what Order Books are available within Advanced Trading. IndexBlack does not offer Advanced Trading to customers in all jurisdictions. By accessing Advanced Trading or the IndexBlack API for Advanced Trading, you accept and agree to be bound by the Trading Rules

6. TRANSACTIONS LIMITS AND ENHANCED DUE DILIGENCE

6.1 Transactions Limits. The use of all IndexBlack Services is subject to a limit on the volume, stated in GBP, EUR or other fiat currency or Digital Currency, you may transact or transfer in a given period (e.g. daily). Please see Appendix 2 (Verification Procedures and Limits) for further details. To view your limits, login to your IndexBlack Account. Your transaction limits may vary depending on your payment method, verification steps you have completed, and other factors. We reserve the right to change applicable limits as we deem necessary.

6.2 Enhanced Due Diligence. We may require you to submit additional information about yourself or your business, provide records, and arrange for meetings with IndexBlack staff if you wish to raise your limits ("Enhanced Due Diligence"). We reserve the right to charge you costs and fees associated with such Enhanced Due Diligence although if we intend to do so, we will notify you in advance so that you can decide whether you wish to proceed with the request. In our discretion, we may refuse to raise your limits, or we may lower your limits at a subsequent time even if you have completed Enhanced Due Diligence.

7. SUSPENSION, TERMINATION, AND CANCELLATION.

7.1 Suspension, Termination and Cancellation. As outlined below, the following may occur: (a) We may refuse to complete, or place on hold, block, cancel, or reverse a transaction you have authorized (even after funds have been deducted from your IndexBlack Account), (b) we may suspend, restrict, or terminate your access to any or all of the IndexBlack Services, and/or (c) we may deactivate or cancel your IndexBlack Account with immediate effect for any reason, including but not limited to:

(A) we reasonably believe that we need to do so in order to protect our reputation;
(B) we are, in our reasonable opinion, required to do so by applicable law, regulation or any court or other authority to which we are subject in any jurisdiction;
(C) we reasonably suspect you of acting in breach of this Agreement;
(D) we reasonably suspect you to have breached our ‘Behaviour Policy’ or our ‘Policy on Prohibited Use,

Prohibited Businesses and Conditional Use’ (as set out in Appendix 1);

(E) we have concerns that a transaction is erroneous or about the security of your IndexBlack Account or we suspect that the IndexBlack Services are being used in a fraudulent or unauthorised manner;
(F) we suspect money laundering, terrorist financing, fraud, or any other financial crime;
(G) use of your IndexBlack Account is subject to any pending litigation, investigation, or government proceeding and / or we perceive a heightened risk of legal or regulatory non-compliance associated with your IndexBlack Account activity; and / or
(H) you take any action that may circumvent our controls such as opening multiple IndexBlack Accounts or abusing promotions which we may offer from time to time.

If you have authorized a transaction, we may refuse to complete or block, cancel or reverse it if insufficient funds are available to cover the transaction and associated fees within your E-Money Wallet or Digital Currency Wallet at the time that we receive notification of the transaction or if your credit or debit card or other valid payment method linked to your IndexBlack Account or Digital Currency Wallet is declined.

7.2 We will notify you (unless it would be unlawful for us to do so) if we refuse to complete a transaction, suspend, restrict or close your IndexBlack Account, and / or terminate your use of IndexBlack Services, and where applicable, with the procedure for correcting any factual errors that lead to the refusal, suspension or closure of your IndexBlack Account. The suspension will be lifted or the transaction will be completed as soon as reasonably practicable once the reasons for refusal or suspension have been removed. The reinstatement of a transaction, however, is not guaranteed to be at the same price or under the same terms as the suspended, reversed, or cancelled transaction

In the event that your IndexBlack Account is deactivated or cancelled, we will give you a twomonth notice before suspending or terminating your account. It may be necessary for our risk management and security protocols to take certain actions, including limiting access to, suspending, or closing your IndexBlack Account, based on confidential criteria. As a result, IndexBlack is under no obligation to give you any details regarding its risk management and security procedures.

7.3 Consequences of Termination or Suspension. You are permitted to access your IndexBlack Account upon termination of this Agreement for any reason, unless prohibited by applicable law or by any court or other order to which IndexBlack in any jurisdiction is subject:

(A) Upon transferring Digital Currency out of a Digital Currency Wallet (s) or the IndexBlack Platform within ninety (90) days of this notice; and/or

(B) at any time during the six-year period commencing with the termination date of this Agreement, in order to transfer E-Money out of your IndexBlack Wallet as well as out of IndexBlack.

IndexBlack Services and IndexBlack Accounts are not permitted to be used for any other purposes during these periods, and we may, at our discretion, limit the functionality of the IndexBlack Platform or access to the Site accordingly.

Upon a suspension or closure of IndexBlack Accounts or termination of your use of IndexBlack
Services, we reserve the right to require you to re-complete the processes outlined at Section 3.3 (Identity Verification) before allowing you to move or withdraw Digital Currency or E-Money. Depending on your IndexBlack Account type, you may cancel the account at any time by withdrawing all funds in your E-Money and Digital Currency Wallets. In the event you cancel your IndexBlack Account, there will be no charge, but you will need to pay any outstanding amounts. Upon cancellation of your order, we are authorised to cancel or suspend any pending transaction.

8. LIABILITY

8.1 Release of IndexBlack. If you have a dispute with one or more users of the IndexBlack Services (other than IndexBlack), you agree that neither we nor our affiliates or service providers, nor any of our respective officers, directors, agents, joint venturers, employees and representatives, will be liable for any claims, demands and damages (actual and consequential, direct or indirect) of any kind or nature arising out of or in any way connected with such disputes.

8.2 Indemnification. You agree to indemnify us, our affiliates and service providers, and each of our, or their, respective officers, directors, agents, employees and representatives, in respect of any costs (including attorneys' fees and any fines, fees or penalties imposed by any regulatory authority) that have been reasonably incurred in connection with any claims, demands or damages arising out of or related to your breach and / or our enforcement of this Agreement (including without limitation your breach of our ‘Behaviour Policy’ or our ‘Policy on Prohibited Use, Prohibited Businesses and Conditional Use’ (as set out in Appendix 1)) or your violation of any law, rule or regulation, or the rights of any third party.

8.3 Limitations of Liability. IndexBlack total aggregate liability to you for any individual claim or series of connected claims for losses, costs, liabilities or expenses which you may suffer arising out of, or in connection with, any breach by IndexBlack of this Agreement shall be limited to a maximum aggregate value of the combined value of the Digital Currency and E-Money on deposit in your E-Money Wallet and your Digital Currency Wallet at the time of the relevant breach by IndexBlack. Where we are considering a specific claim relating to a specific transaction this sum shall be further limited to the purchase / sale amount (as relevant) of the transaction in dispute.

8.4 Limitation of loss. In addition to the liability cap at Section 8.3 (Limitations of Liability) above, in no event shall we, our affiliates or service providers, or any of our or their respective officers, directors, agents, employees or representatives, be liable for any of the following types of loss or damage arising under or in connection with this Agreement or otherwise:

(A) any loss of profits or loss of expected revenue or gains, including any loss of anticipated trading profits and / or any actual or hypothetical trading losses, whether direct or indirect, even if we are advised of or knew or should have known of the possibility of the same. This means, by way of example only (and without limiting the scope of the preceding sentence), that if you claim that we failed to process a Digital Currency Transaction properly, your damages are limited to no more than the combined value of the supported Digital Currency and E-Money at issue in the transaction, and that you may not recover for any "loss" of anticipated trading profits or for any actual trading losses made as a result of the failure to buy or sell the Digital Currency;

(B) any loss of, or damage to, reputation or goodwill; any loss of business or opportunity, customers or contracts; any loss or waste of overheads, management or other staff time; or any other loss of revenue or actual or anticipated savings, whether direct or indirect, even if we are advised of or knew or should have known of the possibility of the same;

(C) any loss of use of hardware, software or data and / or any corruption of data; including but not limited to any losses or damages arising out of or relating to any inaccuracy, defect or omission of digital currency price data; any error or delay in the transmission of such data; and / or any interruption in any such data; and

(D) any loss or damage whatsoever which does not arise directly as a result of our breach of this Agreement (whether or not you are able to prove such loss or damage).

8.5 Applicable law. The limitation of liability in this Section 8 (Liability) is subject to any obligations that

we have under applicable law and regulation, including our obligation to exercise reasonable care and skill in our provision of the IndexBlack Services. Nothing in this Agreement shall limit our liability resulting from our fraud or fraudulent misrepresentation, gross negligence, deliberate misconduct, for death or personal injury resulting from either our or our subcontractors’ negligence.

8.6 No Warranties. The IndexBlack Services are provided on an "as is" and "as available" basis, with no further promises made by us around availability of the IndexBlack Services. Specifically, we do not give any implied warranties of title, merchantability, fitness for a particular purpose and/or non-infringement. We do not make any promises that access to the Site, any of the IndexBlack Services, or any of the materials contained therein, will be continuous, uninterrupted, timely, or errorfree.

We make no representations about the accuracy, order, timeliness or completeness of historical Digital Currency price data available on the Site. Any materials, information, view, opinion, projection or estimate presented via the Site is made available by IndexBlack for informational purposes only, and is subject to change without notice. You must make your own assessment of the relevance, timeliness, accuracy, adequacy, commercial value, completeness and reliability of the materials, information, view opinion, projection or estimate provided on the Site and/or the Site. Accordingly, no warranty whatsoever is given by IndexBlack and no liability whatsoever is accepted by IndexBlack for any loss arising whether directly or indirectly as a result of you acting on any materials, information, view, opinion, projection or estimate provided in or made available through the Site and/or the Site.

The IndexBlack Services, IndexBlack Platform and Site are not intended to provide specific investment, tax or legal advice or to make any recommendations about the suitability of any investments or products for any particular investor. You should seek your own independent financial, legal, regulatory, tax or other advice before making an investment in the investments or products. In the event that you choose not to seek advice from a relevant adviser, you should consider whether the investment or product is suitable for you.

We will make reasonable efforts to ensure that Digital Currency Transactions, requests for debits and credits involving Digital Currency Wallets, E-Money Wallets, bank accounts, credit and debit cards are processed in a timely manner but IndexBlack makes no representations or warranties regarding the amount of time needed to complete processing which is dependent upon many factors outside of our control. We will make reasonable efforts to ensure that requests for electronic debits and credits involving bank accounts, credit cards, and cheque issuances are processed in a timely manner, but we make no representations or warranties regarding the amount of time needed to complete processing which is dependent upon many factors outside of our control.

Except for the express statements set forth in this Agreement, you hereby acknowledge and agree that you have not relied upon any other statement or understanding, whether written or oral, with respect to your use and access of the IndexBlack Services and Site.

8.7 No Liability for Breach. We are not liable for any breach of the Agreement, including delays, failure in performance or interruption of service, where they arise directly or indirectly from abnormal and unforeseeable circumstances beyond our control, the consequences of which would have been unavoidable despite all effects to the contrary, nor are we liable where the breach is due to the application of mandatory legal rules.

9. AUTHENTICITY AND AVAILABILITY OF THE SITE

9.1 Access & Availability. It may be difficult or impossible to access IndexBlack Services during times of significant volatility or volume. Your IndexBlack Account or IndexBlack Services may be limited as a result, including the inability to initiate or complete transactions, and support response times may also be delayed.

(A) While we strive to provide excellent service to you, we cannot guarantee that the Site or other IndexBlack Services will be available without interruptions, that orders will be executed, accepted, recorded, or that your IndexBlack Account will remain open; and

(B) During times of substantial volatility or volume, our customer support response times may be delayed, especially for non-trust and safety issues.

No responsibility or liability will be assumed by IndexBlack in the event of service interruptions, delays in processing transactions, or inadequate customer support.

9.2 Accuracy of the Website. Despite our intention to provide accurate and timely information on the Site, we cannot guarantee that it is always completely accurate, complete, or up-to-date, or that technical errors or typographical errors will not be present.

To the extent permitted by applicable law, we may without notice change or update information in order to provide you with as complete and accurate information as possible, including information about our policies, products, and services. In this respect, you should verify all information before taking any action based on it. We are not liable for the decisions you make based on the information contained on the Site.

Please note that we are not responsible for the content of third-party links (including, without limitation, any website). In the event that you access or link to these third-party materials, please note that we are not responsible for the information, content, or services that they provide.

10. CUSTOMER FEEDBACK, QUERIES, COMPLAINTS, AND DISPUTE RESOLUTION

To help us identify you, your IndexBlack Account, and the transaction on which you have feedback, questions, or complaints, please provide us with your name, email address, and any other information you may need.

10.2 Complaints. You agree to contact IndexBlack support in the first instance if you have a dispute with us. If we cannot resolve the dispute through our support team, you and we agree to use the complaints process set out in this Section 10.2. You agree to use this process before commencing any action as set out in Section 10.4. If you do not follow the procedures set out in this Section 10.2 before pursuing action under Section 10.4, we shall have the right to ask the relevant court/authority to dismiss your action/application unless and until you complete the following steps:

Please use our complaint form if your complaint has not been resolved through your contact with IndexBlack Support. Be sure to state the cause of your complaint, how you would like it resolved, and any other information you believe to be relevant. Customer support is available through IndexBlack support page, help.indexblack.com, or you can request the complaint form directly from IndexBlack. After you submit your complaint form, we will acknowledge its receipt. Your complaint will be reviewed by a customer complaints officer. Based on the information you have provided, and any information provided by IndexBlack, the Officer will examine your complaint without prejudice.

In less than 15 business days after a complaint has been received, a resolution notice will be sent to you with the following information: (i) the Officer will offer to resolve your complaint in the way that you requested; (ii) the Officer will reject your complaint and set forth the reasons for the rejection; or (iii) the Officer will offer to resolve your complaint in an alternative way. The officer may (unless prohibited by applicable law) send you a holding reply if he or she cannot respond to your complaint within 15 business days. The holding reply will include the reasons for the delay in replying to your complaint and specify the deadline by which the officer will respond to your complaint (which will not be later than 35 business days from our receipt of the complaint).

Your acceptance of any resolution proposal will make it binding on us. We will not, by offering a resolution, admit any liability or wrongdoing regarding the subject matter of the complaint.

10.3 If your complaint cannot be resolved through the complaint process described in Section 10.2 above, you may escalate it through the dispute processes described in Sections 10.4(A) to 10.4(B) below, as necessary.

10.4 As agreed between you and us, we will not begin any of the dispute processes listed at Sections 10.4(A) to 10.4(B) below in relation to the whole or part of your complaint until the complaint procedure set out in Section 10.2 has been completed. However, neither this Section 10.4 nor Section 10.2 prevents any party from seeking conservatory or similar interim relief in any court of competent jurisdiction.

(A) E-Money Services. In the case of complaints regarding E-Money Services, you may have the right to file that complaint with the FOS, as detailed in Section 4.13.

(B) For complaints or disputes arising out of or in connection with this Agreement or the provision of IndexBlack Services, the IndexBlack Platform or the Site, that cannot be resolved via the complaint process set out in Section 10.2 above, you submit to the non-exclusive jurisdiction of the courts of England and Wales without prejudice to any mandatory rights available to consumers (being individuals not engaged in conduct related to their trade, business or profession, “Consumers”) to commence proceedings against IndexBlack before the courts of the jurisdiction in which they are domiciled.

11. DATA PROTECTION.

11.1 Personal Data. In connection with this Agreement, or the IndexBlack Services, you acknowledge that we may process personal data about you (if you are an individual), as well as personal data you have provided (or may provide in the future) to us about your employees, associates, or any other individual. During the course of this agreement, we will process the personal data in accordance with the Privacy Policy. Therefore, you agree to:

(A) Any personal data that you have disclosed to us about any individuals other than yourself has been or will be disclosed in compliance with all applicable laws protecting personal information, and those data are accurate, up-to-date, and relevant when they are disclosed;

(B) By providing us with any such personal data, you acknowledge that you have read and understood our Privacy Statement, a copy of which is available here: Privacy Statement, and, in the case of personal data relating to an individual other than yourself, you have (or will at the time of disclosure) provided the individual with a copy of, or directed the individual towards, this Privacy Statement (as amended from time to time); and

(C) If we will from time to time provide you with an updated Privacy Policy, you will read it promptly and send updated copies to, or direct anyone whose personal data you have shared with us, to the updated Privacy Policy.

12. SECURITY

12.1 Password Security. To access IndexBlack Services, you will need a username and password which you will need to create or be given. It is your responsibility to maintain adequate security on the electronic device through which you access IndexBlack Services and to maintain control over any and all personal information that you use to access IndexBlack Services. In addition to ensuring the encryption and password protection of the electronic device, all reasonable measures should be taken to prevent the loss, theft or misuse of such a device.

In the event of the loss or compromise of your electronic device or your security details, unauthorized third parties may gain access to your IndexBlack Account and any associated accounts. This includes your linked bank accounts and credit cards. Be sure to safeguard these details at all times. You should not, for example, copy them down or otherwise make them public.

If you are logged into your IndexBlack Account, you shouldn't allow remote access or share your screen with anyone. You will never be asked for your IDs, passwords, or 2-factor authentication codes by IndexBlack, or for a screen share, or otherwise requested to give access to your computer or account. Unless specifically authorized in accordance with Sections 3.2 and 4.10, you should not provide your account details to third parties to remotely access your account. If you have any doubt regarding the authenticity of any communication or notice, log into your IndexBlack Account through the Site to review any transactions or required actions.

We assume no responsibility for any loss that you may sustain due to compromise of account login credentials due to no fault of IndexBlack and/or failure to follow the requirements set out in this Section 12.1, or follow or act on any notices or alerts that we may send to you.

12.2 Verification and Authentication. IndexBlack Services require users to create a password and provide an email address. With IndexBlack, a user can create a two-factor authentication by utilizing a mobile device (Short Message Service ("SMS") or Time-based One Time Password application. For two- factor authentication via SMS, a verified phone number is required. Users are responsible for maintaining adequate security and control of any and all security details used to access IndexBlack Services and for keeping electronic devices through which IndexBlack Services are accessed safe. Making sure said electronic devices are password-protected will help prevent the loss, theft, or misuse of said electronic devices. If your electronic device is lost or compromised, third parties may be able to access your IndexBlack Account without your permission, and you may also lose or have your funds stolen, along with any linked bank accounts and credit/debit cards.

12.3 Security Breach. The following steps should be taken if you suspect that a IndexBlack
Account or any of your security details have been compromised, or if you become aware of a security breach (such as a cyber-security attack) that affects you and / or IndexBlack (together a "Security Breach").

(A) notify IndexBlackSupport as soon as possible
(B) continue to provide accurate and up to date information throughout the duration of the Security Breach; and
(C) you must take any steps that we reasonably require to reduce, manage or report any Security Breach.

Failure to provide prompt notification of any Security Breach may be taken into account in our determination of the appropriate resolution of the matter.

12.4 Safety and Security of Your Computer and Devices. If you are affected by computer viruses or other malicious software, or if you are attacked by phishing, spoofing, or any other malicious software, IndexBlack will not be responsible for the damage or interruptions caused. Virus prevention software that is readily available and reputable should be regularly used. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from us.

13. GENERAL

13.1 Your Compliance with Applicable Law. You must comply with all applicable laws, regulations, licensing requirements and third party rights (including, without limitation, data privacy laws and antimoney laundering and countering the financing of terrorism laws) in your use of the IndexBlack Services, the IndexBlack Platform and the Site.

13.2 Limited Licence. We grant you a limited, non-exclusive, non-transferable licence, subject to the terms of this Agreement, to access and use the Site, and related content, materials, information (collectively, the "Content") solely for approved purposes as permitted by us from time to time. Any other use of the Site or Content is expressly prohibited and all other right, title, and interest in the Site or Content is exclusively the property of IndexBlack and its licensors. You agree not to copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Content, in whole or in part.

13.3 Prohibited and Conditional Use. In connection with your use of the IndexBlack Services, and your interactions with other users and third parties, you agree to comply with the ‘Policy on Prohibited Use, Prohibited Businesses and Conditional Use’ (as set out in Appendix 1). Nothing contained herein should be construed as granting, by implication, estoppel or otherwise, any licence or right for the EMoney or Digital Currency to be used for illegal, unlawful, fraudulent, unethical, or unauthorised purposes or to promote or facilitate any illegal, unlawful, fraudulent, unethical or unauthorised activities. We reserve the right at all times to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, regulation, sanctions programs, legal process or governmental request.

13.4 Export Controls & Sanctions. Your use of the IndexBlack Services and the Site is subject to international export controls and economic sanctions requirements. By sending, receiving, buying,

selling, trading or storing Digital Currency through the Site or IndexBlack Services, you agree that you will comply with those requirements. You are not permitted to acquire Digital Currency or use any of the IndexBlack Services through the Site if:

(A) you are in, under the control of, or a national or resident of Cuba, Iran, North Korea, Sudan, or Syria or any other country subject to United States embargo, UN sanctions, the European Union or HM Treasury's financial sanctions regimes (each a "Sanctioned Country"), or if you are a person on the economic sanctions lists as published from time to time by applicable authorities (including, but not limited to the Office of Financial Sanctions Implementation (part of HM Treasury), the U.S. Commerce Department's Denied Persons List, Unverified List, or Entity List, or the EU financial sanctions regime) (a "Sanctioned Person"); or

13.5 Amendments. We will notify you of any change to the Agreement relating to E-Money Services by email at least two months in advance. In such circumstances, you will be deemed to have accepted the change if you do not notify us otherwise prior to the date the change takes effect and continue to use the IndexBlack Services. If you do not accept the change you should let us know, and the Agreement will terminate at the end of the two-month notice. You may also end the Agreement immediately and free of charge with effect at any time before the expiry of the two-month notice.

We may make all other amendments to the Agreement (including in relation to any other IndexBlack Services) by posting the revised Agreement on the Site or by emailing it to you, indicating when the revised Agreement becomes effective. Although we will endeavour to provide you with advance notice where possible, where lawful we may indicate that the revised Agreement shall be effective immediately and if you do not agree with any such modification, you should close your IndexBlack Account and cease using the IndexBlack Services. You agree that any notification of amendments in the manner as aforesaid shall be sufficient notice to you, and your continued access and/or use of IndexBlack Services and/or the Site shall constitute an affirmative

acknowledgement by you of the amendments and shall be deemed to be your acceptance of the revised Agreement.

Copies of the most up-to-date version of the Agreement will be made available in the Site at all times.

13.6 Relationship of the Parties. Nothing in this Agreement shall be deemed or is intended to be deemed, nor shall it cause, either you or IndexBlack to be treated as partners or joint ventures, or either you or IndexBlack to be treated as the agent of the other.

13.7 Privacy of Others. If you receive information about another user through the IndexBlack Services, you must keep the information confidential and only use it in connection with the
IndexBlack Services. You may not disclose or distribute a user’s information to a third party or use the information except as reasonably necessary to carry out a transaction and other functions reasonably incidental thereto such as support, reconciliation and accounting unless you receive the user’s express consent to do so. You may not send unsolicited communications to another user through the IndexBlack Services.

13.8 Contact Information. You are responsible for keeping your contact details (including your email address and telephone number) up to date in your IndexBlack Account profile in order to receive any notices or alerts that we may send to you (including notices or alerts of actual or suspected Security Breaches). Please see Appendix 3 for more detail in relation to how we will communicate with you.

13.9 Taxes. It is your sole responsibility to determine whether, and to what extent, any taxes apply to any transactions you conduct through the IndexBlack Services, and to withhold, collect, report and remit the correct amount of tax to the appropriate tax authorities. Your transaction history is available through your IndexBlack Account.

13.10 Unclaimed Property. If we hold E-Money or Digital Currency on your behalf, and we are unable to contact you and have no record of your use of the IndexBlack Services for several years, applicable law may require us to report the E-Money or Digital Currency as unclaimed property to the authorities in certain jurisdictions. We will try to locate you at the address shown in our records, but if we are unable to, we may be required to deliver any such E-Money or Digital Currency to the authorities in certain jurisdictions as unclaimed property. We reserve the right to deduct a dormancy fee or other administrative charges from such unclaimed funds, as permitted by applicable law.

13.11 Death of Account Holder. For security reasons, if we receive legal documentation confirming your death or other information leading us to believe you have died, we will freeze your IndexBlack Account and during this time, no transactions may be completed until: (i) your designated executor / trustee has opened a new IndexBlack Account or informed IndexBlack about another, existing, IndexBlack Account in their name, as further described below, and the entirety of your IndexBlack Account has been transferred to such new account, or (ii) we have received proof in a form satisfactory to us that you have not died. If we have reason to believe you may have died but we do not have proof of your death in a form satisfactory to us, you authorize us to make inquiries, whether directly or through third parties, that we consider necessary to ascertain whether you have died. Upon receipt by us of proof satisfactory to us that you have died, the executor / trustee you have designated in a valid Will or similar testamentary document will be required to open a new IndexBlack Account or inform IndexBlack of another, existing IndexBlack Account in their name to which the entirety of the funds in your IndexBlack Account shall be transferred. If you have not designated an executor / trustee, then we reserve the right to (i) treat as your executor / trustee any person entitled to inherit your IndexBlack Account, as

determined by us upon receipt and review of the documentation we, in our sole and absolute discretion, deem necessary or appropriate, including (but not limited to) a Will or similar document, or (ii) require an order designating an executor / trustee from a court having competent jurisdiction over your estate. In the event we determine, in our sole and absolute discretion, that there is uncertainty regarding the validity of the executor / trustee designation, we reserve the right to require an order resolving such issue from a court of competent jurisdiction before taking any action relating to your IndexBlack Account. Pursuant to the above, unless your designated executor / trustee already holds a IndexBlack Account (in which case they may still be required to undergo additional identity verification procedures), the opening of a new IndexBlack

Account by a designated executor / trustee is mandatory following the death of a
IndexBlack Account owner, and you hereby agree that your executor / trustee will be required to open a new IndexBlack Account and provide the information required under Section 3 of this Agreement in order to gain access to the contents of your IndexBlack Account.

13.12 Entire Agreement. This Agreement (including documents incorporated by reference herein) comprise the entire understanding and agreement between you and IndexBlack as to the subject matter hereof, and it supersedes any and all prior discussions, agreements and understandings of any kind (including without limitation any prior versions of this Agreement), and every nature between and among you and IndexBlack.

13.13 Interpretation. Section headings in this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement.

13.14 Transfer and Assignment. This Agreement is personal to you and you cannot transfer or assign your rights, licenses, interests and/or obligations to anyone else. We may transfer or assign our rights licenses, interests and / or our obligations at any time, including as part of a merger, acquisition or other corporate reorganization involving IndexBlack, provided that this transfer or assignment does not materially impact the quality of the IndexBlack Services you receive. Subject to the foregoing, this Agreement will bind and inure to the benefit of the parties, their successors and permitted assigns. You reserve the right to terminate the agreement with immediate effect in the event we transfer and/or assign the Agreement.

13.15 Security Interests. You must not create security over your E-Money or Digital Currency unless you have obtained our prior approval in writing.

13.16 Invalidity. If any provision of this Agreement is determined to be invalid or unenforceable under any applicable law, this will not affect the validity of any other provision. If any provision is found unenforceable, the unenforceable provision will be severed, and the remaining provisions will be enforced.

13.17 Enforcement of Our Rights. We may not always strictly enforce our rights under this Agreement. If we do choose not to enforce our rights at any time, this is a temporary measure and we may enforce our rights strictly again at any time.

13.18 Language. This Agreement and any information or notifications that you or we are to provide should be in English. Any translation of this Agreement or other documents is provided for your convenience only and may not accurately represent the information in the original English. In the event of any inconsistency, the English language version of this Agreement or other documents shall prevail.

13.19 Change of Control. In the event that IndexBlack is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you and our relationship with you (including this Agreement) as part of such merger, acquisition, sale, or other change of control.

13.20 Survival. All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement, including, without limitation, the Sections relating to suspension or termination, IndexBlack Account cancellation, debts owed to IndexBlack, general use of the IndexBlack Platform or Site, disputes with IndexBlack, and general provisions will continue to be binding and operate after the termination or expiration of this Agreement.

13.21 Governing Law. This Agreement and the relationship between us shall be governed by the laws of England and Wales, subject to any local mandatory law, or rights available to Consumers.

APPENDICES

Appendix 1 : PROHIBITED USE, PROHIBITED BUSINESSES AND CONDITIONAL USE

1. Prohibited Use. You may not use your IndexBlack Account to engage in the following categories of activity ("Prohibited Uses"). The specific types of use listed below are representative, but not exhaustive. If you are uncertain as to whether or not your use of IndexBlack Services or the IndexBlack Platform involves a Prohibited Use or have questions about how these requirements apply to you, please submit a support request at: https://help.indexblack.com.

By opening a IndexBlack Account, you represent and warrant that you will not use your
IndexBlack Account, any IndexBlack Services and/or the IndexBlack Platform to do any of the following:

(A) Unlawful Activity: Activity which would violate, or assist in violation of, any law, statute, ordinance, or regulation or sanctions programs administered in the countries where IndexBlack conducts business, including but not limited to regulatory regimes administered by the U.S. Department of Treasury's Office of Foreign Assets Control ("OFAC"), or which would involve proceeds of any unlawful activity; publish, distribute or disseminate any unlawful material or information.
(B) Abusive Activity: Actions which impose an unreasonable or disproportionately large load on our infrastructure, or detrimentally interfere with, intercept, or expropriate any system, data, or information; transmit or upload any material to the Site that contains viruses, trojan horses, worms, or any other harmful or deleterious programs; attempt to gain unauthorised access to the Site, other IndexBlack Accounts, computer systems or networks connected to the Site, through password mining or any other means; use IndexBlack Account information of another party to access or use the Site, except in the case of specific merchants and / or applications which are specifically authorised by a user to access such user's IndexBlack Account and information; or transfer your account access or rights to your account to a third party, unless by operation of law or with the express permission of IndexBlack.
(C) Abuse Other Users: Interfere with another individual's or entity's access to or use of any

IndexBlack Services; defame, abuse, extort, harass, stalk, threaten or otherwise violate or infringe the legal rights (such as, but not limited to, rights of privacy, publicity and intellectual property) of others; harvest or otherwise collect information from the Site about others, including without limitation email addresses, without proper consent.

(D) Fraud: Activity which operates to defraud IndexBlack, IndexBlack users, or any other person; provide any false, inaccurate, or misleading information to IndexBlack.
(E) Gambling: Lotteries; bidding fee auctions; sports forecasting or odds making; fantasy sports leagues with cash prizes; internet gaming; contests; sweepstakes; games of chance.
(F) Intellectual Property Infringement: Engage in transactions involving items that infringe or violate any copyright, trademark, right of publicity or privacy or any other proprietary right under the law, including but not limited to sales, distribution, or access to counterfeit music, movies, software, or other licensed materials without the appropriate authorisation from the rights holder; use of IndexBlack intellectual property, name, or logo, including use of IndexBlack trade or service marks, without express consent from IndexBlack or in a manner that otherwise harms IndexBlack or the IndexBlack brand; any action that implies an untrue endorsement by or affiliation with IndexBlack.

2. Prohibited Businesses. In addition to the Prohibited Uses described above, the following categories of businesses, business practices, and sale items are barred from being carried out using IndexBlack Services or the IndexBlack Platform ("Prohibited Businesses"). Most Prohibited Businesses categories are imposed by card network rules or the requirements of our banking providers or processors. The specific types of use listed below are representative, but not exhaustive. If you are uncertain as to whether or not your use of IndexBlack Services or the IndexBlack Platform involves a Prohibited Business, or have questions about how these requirements apply to you, please contact us at: https://help.indexblack.com.

By opening a IndexBlack Account, you represent and warrant that you will not use IndexBlack Services or the IndexBlack Platform in connection with any of the following businesses, activities, practices, or items:

(A) Investment and Credit Services: securities brokers; mortgage consulting or debt reduction services; credit counselling or repair; real estate opportunities; investment schemes;
(B) Restricted Financial Services: check cashing, bail bonds; collections agencies;
(C) Intellectual Property or Proprietary Rights Infringement: sales, distribution, or access to counterfeit music, movies, software, or other licensed materials without the appropriate authorisation from the rights holder;
(D) Counterfeit or Unauthorised Goods: unauthorised sale or resale of brand name or designer products or services; sale of goods or services that are illegally imported or exported or which are stolen;
(E) Regulated Products and Services: marijuana dispensaries and related businesses; sale of tobacco, ecigarettes, and e-liquid; online prescription or pharmaceutical services; age restricted goods or services; weapons and munitions; gunpowder and other explosives; fireworks and related goods; toxic, flammable, and radioactive materials;
(F) Drugs and Drug Paraphernalia: sale of narcotics, controlled substances, and any equipment designed for making or using drugs, such as bongs, vaporizers, and hookahs;
(G) Pseudo-Pharmaceuticals: pharmaceuticals and other products that make health claims that have not been approved or verified by the applicable local and/or national regulatory body;

(H) Substances designed to mimic illegal drugs: sale of a legal substance that provides the same effect as an illegal drug (e.g. salvia, kratom);
(I) Adult Content and Services: pornography and other obscene materials (including literature, imagery and other media); sites offering any sexually-related services such as prostitution, escorts, pay-per view, adult live chat features;
(J) Multi-level Marketing: pyramid schemes, network marketing, and referral marketing programs;
(K) Unfair, predatory or deceptive practices: investment opportunities or other services that promise high rewards; sale or resale of a service without added benefit to the buyer; resale of government offerings without authorisation or added value; sites that we determine in our sole discretion to be unfair, deceptive, or predatory towards consumers; and
(L) High-risk businesses: any businesses that we believe poses elevated financial risk, legal liability, or violates card network or bank policies.

3. Conditional Use. Express written consent and approval from IndexBlack must be obtained prior to using IndexBlack Services for the following categories of business and/or use ("Conditional Uses"). Consent may be requested by contacting us at: https://help.indexblack.com.

IndexBlack may also require you to agree to additional conditions, make supplemental representations and warranties, complete enhanced on-boarding procedures, and operate subject to restrictions if you use IndexBlack Services in connection with any of the following businesses, activities, or practices:

(A) Money Services: Money transmitters, Digital Currency transmitters; currency or Digital Currency exchanges or dealers; gift cards; prepaid cards; sale of in-game currency unless the merchant is the operator of the virtual world; act as a payment intermediary or aggregator or otherwise resell any of the IndexBlack Services;
(B) Charities: Acceptance of donations for non-profit enterprise;

(C) Games of Skill: Games which are not defined as gambling under this Agreement or by law, but which require an entry fee and award a prize; and

(D) Religious/Spiritual Organisations: Operation of a for-profit religious or spiritual organisation.

Appendix 2 : VERIFICATION PROCEDURES AND LIMITS

To prevent IndexBlack and the community from fraudulent users, and to keep appropriate records of its customers, IndexBlack uses a variety of systems and procedures to collect and verify information about you. IndexBlack Services or the IndexBlack Platform that are available to you, limits imposed on your use of IndexBlack Services (including, but not limited to, daily or weekly conversion limits, withdrawal limits, instant buy limits, Digital Currency Wallet transfer limits, etc., and any changes to such limitations from time to time, may be determined based on the identifying information and/or proof of identity you provide.

We may require additional information from you, or to wait a certain amount of time after a transaction is completed, before allowing you to use any IndexBlack Services and/or before allowing you to engage in transactions over certain volume limits. Your level of identity verification will help determine which volume limits apply to your account.

You can request larger limits by going to https://help.indexblack.com. IndexBlack requires you to submit to Enhanced Due Diligence. Additional fees may apply, and IndexBlack cannot guarantee that we will increase your limits.

Appendix 3 : COMMUNICATIONS

1. Electronic Delivery of Communications. In connection with your IndexBlack Account and your use of IndexBlack Services, you agree and consent to receive electronic communications, agreements, documents, notices, and disclosures (collectively, "Communications"). Communication types include:

(A) terms of use and policies you agree to (e.g. the Agreement and Privacy Policy), including updates to these agreements or policies;

(B) account details, history, transaction receipts, confirmations, and any other account or transaction information;

(D) responses to claims or customer support inquiries filed in connection with your IndexBlack Account.

We may communicate with you through the Site, emailing them to you at your primary email address in your IndexBlack Account, chatting with you via instant message, or other electronic means such as text message or mobile push notification, unless otherwise stated in this Agreement, and you acknowledge that the posting of such Communications on the Site, or the sending of emails to you at the primary email address in your IndexBlack Account, constitutes sufficient notice of the subject matter therein.

2. How to Withdraw Your Consent. You may withdraw your consent to receive Communications electronically by contacting us at: https://help.indexblacks.com. If you fail to provide or if you withdraw your consent to receive Communications in the specified manner , IndexBlack reserves the right to immediately close your IndexBlack Account or charge you additional fees for paper copies of the Communications.

3. Updating your Information. It is your responsibility to provide us with a true, accurate and complete email address and your contact information, and to keep such information up to date. You understand and agree that if IndexBlack sends you an electronic Communication but you do not receive it because your primary email address you have provided is incorrect, out-of-date, blocked by your service provider, or you are otherwise unable to receive electronic Communications, IndexBlack will be deemed to have provided the Communication to you.

You may update your information by logging into your IndexBlack Account and visiting settings or by contacting our support team at: https://help.indexblack.com.

Appendix 4 : DEVELOPER’S TOOLS LICENSE

Developer’s Tools. An eligible user may create a IndexBlack account to access the platform's application programming interface and any associated documentation, source code, and executable applications (the IndexBlackAPI), the IndexBlack Sandbox at
https://public.sandbox.pro.oinbase.com/, and any other resources or services found at https://developers.indexblack.com/ (collectively, the Developer's Tools).

To the extent permitted by law, the IndexBlack Developer Agreement, which is available at https://developers.indexblack.com/docs/wallet/terms/2 (and may be updated from time to time), shall apply to your use of the Developer's Tools in addition to this Agreement, including without limitation the released, indemnifies, disclaimers, limitations of liability, prohibited use, dispute resolution, and cancellation policies above. In all jurisdictions, IndexBlack does not provide its Developer's Tools to customers.

Licenses for IndexBlack exist in the following jurisdictions in the United States:

Alabama
Sale of Checks License, SC 509

Alabama Securities Commission 401 Adams Avenue, Suite 280 Montgomery, AL 36104

Alaska
Money Transmitter License, #AK-MT-10088 (View Disclosure)

Department of Commerce, Community and Economic Development Division of Banking & Securities
550 West 7th, Suite 1850
Anchorage, Alaska 99501

Arizona
Money Transmitter, MT-0928767

Arizona Department of Financial Institutions 2910 N. 44th Street, Suite 310
Phoenix, AZ 85018

Arkansas
Money Transmission License, 43387

Arkansas Securities Department Heritage West Building, Suite 300 201 East Markham Street
Little Rock, AR 72201-1692

Colorado
Money Transmitter License, 500252 (View Disclosure)

Colorado Division of Banking 1560 Broadway, Suite 975 Denver, CO 80202

Connecticut
Connecticut Money Transmitter License, MT-1163082

Agency: Connecticut Department of Banking 260 Constitution Plaza
Hartford, CT 06103-1800

Delaware
Sale of Checks and Transmission of Money, 019214

Office of the State Bank Commissioner 555 E. Loockerman Street, Suite 210 Dover, DE 19901

District of Columbia
District of Columbia Money Transmitter License, MTR1163082

Department of Insurance, Securities, and Banking 810 First Street, NE, Suite 701
Washington, District of Columbia 20002

Florida
Money Transmitters Part II, FT230000152 View Disclosure

Florida Office of Financial Regulation 101 E. Gaines Street
Tallahassee, FL 32399

Georgia
Seller of Payment Instruments License, 42796

Georgia Department of Banking and Finance Money Services Businesses
2990 Brandywine Road, Suite 200
Atlanta, GA 30341-5565

Idaho
Money Transmitter License, MTL-169

Idaho Department of Finance, Securities Bureau 800 Park Boulevard, Suite 200
Boise, ID 83720-0031

Illinois
Transmitter or Money, MT.0000350 View Disclosure

Illinois Department of Financial and Professional Regulation 320 West Washington Street
Springfield, IL 62786

Iowa
Money Services License, 2014-0087

State of Iowa Division of Banking 200 E. Grand Avenue, Suite 300 Des Moines, IA 50309

Kansas
Kansas Money Transmitter License, MT.0000078

Kansas Office of the State Bank Commissioner 700 SW Jackson Street, Suite 300
Topeka, KS 66603

Kentucky
Money Transmitter License, SC298809

Kentucky Department of Financial Institutions 1025 Capital Center Drive, Suite 200 Frankfort, KY 40601

Louisiana
Money Transmitter License, 1163082-907647 View Disclosure

Louisiana Office of Financial Institutions Post Office Box 94095
Baton Rouge, LA 70804-9095

Maine
Money Transmitter License, MD1505

Department of Professional & Financial Regulation Bureau of Consumer Credit Protection
76 Northern Avenue
Gardiner, ME 04345

Maryland
Money Transmitter License, 12-1163082 View Disclosure

Maryland Commissioner of Financial Regulation 500 North Calvert Street, Suite 402
Baltimore, Maryland 21202

Michigan
Money Transmitter License, MT0021833

Michigan Department of Insurance and Financial Institutions

PO Box 30220
Lansing MI 48909-7720

Minnesota
Money Transmitter License, MN-MT-1163082

Minnesota Department of Commerce and Financial Institutions Division 85 7th Place East Suite 500
St. Paul, MN 55101

Mississippi
Money Transmitter License, MT/002612/2014

Mississippi Department of Banking and Consumer Finance Post Office Box 12129
Jackson, MS 39236

Nebraska
Nebraska Money Transmitter License, 1163082

Nebraska Department of Banking & Finance 1526 K Street, Suite 300
Lincoln, NE 68508-2732

Nevada
Money Transmitter, MT11045 View Disclosure

Nevada Financial Institutions Division

1830 College Parkway, Ste. 100 Carson City, NV 89706

New Hampshire
Money Transmitter License, 19523-MT

New Hampshire Banking Department 53 Regional Drive, Suite 200 Concord, NH 03301

New Jersey
Money Transmitter License, L067513

New Jersey Department of Banking and Insurance 20 West State Street, PO Box 325
Trenton, NJ 08625

New Mexico
Money Transmitter License, 1163082

New Mexico Financial Institutions Department Mortgage Unit 2550 Cerrillos Road, 3rd Floor
PO Box 25101 (87504)
Sante Fe, NM 87505

New York
Money Transmitter License, MT 103755 Virtual Currency License, 0000003

New York Department of Financial Services One State Street
New York, NY 10004-1511

North Carolina
Money Transmitter License, 161420

North Carolina Commissioner of Banks 316 W. Edenton Street
Raleigh, NC 27603

North Dakota
North Dakota Money Transmitter License, MT102790

North Dakota Department of Financial Institutions 2000 Schafer Street, Suite G Bismark, ND 58501

Ohio
Money Transmitter License, OHMT 104

Ohio Division of Financial Institutions 77 South High Street, 21st Floor Columbus, OH 43215

Oklahoma
Oklahoma - DOB Money Transmission License, OKDOB001

Oklahoma Department of Banking 2900 North Lincoln Boulevard

Oklahoma City, OK 73105

Oregon
Money Transmitter License, #MTX-30192

Oregon Department of Consumer and Business Services Division of Finance and Corporate Securities
PO Box 14480, 350 Winter St., NE, Suite 410
Salem, Oregon 97309-0405

Pennsylvania
Pennsylvania Money Transmitter License, 51015

Pennsylvania Department of Banking and Securities 17 North Second Street, Suite 1300
Harrisburg, Pennsylvania 17101

Puerto Rico
Money Transmitter License, TM-053

Office of the Commissioner of Financial Institutions 1492 Ponce de León Avenue, Suite 600
Centro Europa Building
San Juan, PR 00907

Rhode Island
Electronic Money Transfers, 20153173MT

Department of Business Regulation

1511 Pontiac Ave Cranston, RI 02920

Rhode Island
Sales of Checks, 20163238SC

Department of Business Regulation 1511 Pontiac Ave
Cranston, RI 02920

South Carolina
Money Transmitter License, 1163082

Office of the Attorney General Money Services Division 10000 Assembly Street Columbia, SC 29201

South Dakota
Money Transmitter License, MT.2100

South Dakota Department of Labor and Regulation Division of Banking
1601 N. Harrison Avenue, Suite 1
Pierre, South Dakota 57501

Tennessee
Money Transmitter License, 1163082 View Disclosure

Tennessee Department of Financial Institutions
312 Rosa L. Parks Avenue, 26th Floor Nashville, TN 37243

Texas
License Number 3121 View Disclosure

Texas Department of Banking 2601 North Lamar Blvd Austin, TX 78075

Vermont
Money Transmitter, 100-076

Vermont Department of Financial Regulation 89 Main Street
Montpelier, VT 05620

Virginia
Money Transmitter License, MO-306 View Disclosure

Bureau of Financial Institutions State Corporation Commission 1300 East Main Street, Suite 800 P.O. Box 640

Richmond, Virginia 23218-0640

Washington
Money Transmitter License, 550-MT-90174 View Disclosure

State of Washington - Department of Financial Institutions Division of Consumer Services
150 Israel Road, S.W.
Tumwater, WA 98501

West Virginia
Money Transmitter License, WVMT-1163082

West Virginia Division of Financial Institutions 900 Pennsylvania Avenue, Suite 306 Charleston, WV 25302

DISCLOSURES

Alaska
Please note that this license does not cover the transmission of virtual currency.

For Alaska Residents Only:

If your issue is unresolved by IndexBlock, Inc. & 1-888-908-7930, please submit formal complaints with the State of Alaska, Division of Banking & Securities.

Formal complaints must be in writing, please download the form here:

https://www.commerce.alaska.gov/web/portals/3/pub/DBSGeneralComplaintFormupdated.pdf Formal complaint forms may be submitted via:

1. Fax: 907-465-1230

2. Email: msb_licensing@alaska.gov
3. Mail: Division of Banking & Securities PO Box 110807 Juneau, AK 99811-0807

If you have questions regarding formal complaints, please call 907-465-2521

Colorado
Colorado State Banking Commissioner

CUSTOMER NOTICE

Entities other than FDIC insured financial institutions that conduct money transmission activities in Colorado, including the sale of money orders, transfer of funds, and other instruments for the payment of money or credit, are required to be licensed by the Colorado Division of Banking pursuant to the Money Transmitters Act, Title 11, Article 110, Colorado Revised Statutes.
If you have a Question about or Problem with YOUR TRANSACTION - THE MONEY YOU SENT You must contact the Money Transmitter who processed your transaction for assistance. The Division of Banking does not have access to this information.
If you are a Colorado Resident and have a Complaint about THE MONEY TRANSMITTER – THE COMPANY THAT SENT YOUR MONEY ALL complaints must be submitted in writing. Please fill out the Complaint Form provided on the Colorado Division of Banking’s website and return it and any documentation supporting the complaint via mail or email to the Division of Banking at:

Colorado Division of Banking
1560 Broadway, Suite 975 Denver, CO 80202 email: DORA_BankingWebsite@state.co.us website: www.dora.colorado.gov/dob

Section 11-110-120, C.R.S. requires that money transmitters and money order companies post this notice in a conspicuous, well-lighted location visible to customers.

Colorado Customer Notice (MO7)

Florida

If you have a question or complaint, please contact the consumer assistance division of IndexBlock at https://support.indexblack.com or 1-888-908-7930.

Florida residents may contact the Florida Office of Financial Regulation with any unresolved questions or complaints about IndexBlock, Inc. at 200 E. Gaines Street, Tallahassee, FL 32399-0376, telephone number: (850) 487-9687 (toll free).

Illinois

Illinois residents may contact the Illinois Department of Financial Institutions, Consumer Credit Section with any unresolved questions or complaints about IndexBlock, Inc. at (888) 473-4858 (toll-free).

Louisiana

Please note the license issued to IndexBlock by the Louisiana Office of Financial Institutions does not cover the exchange or transmission of virtual currency.

Maryland

The Commissioner of Financial Regulation for the State of Maryland will accept all questions or complaints from Maryland residents regarding IndexBlock, Inc. (License No. 12-1163082 and NMLS ID: 1163082) by contacting the Commissioner's office at: 500 North Calvert Street, Suite 402, Baltimore, Maryland 21202, or (888) 784-0136. Additional information about IndexBlock, Inc. may be obtained at www.nmlsconsumeraccess.org.

Nevada

IndexBlock, Inc. is licensed by the Nevada Department of Business and Industry as a money transmitter. At this time, the Nevada Department of Business and Industry does not license or regulate services related to virtual currency, including but not limited to virtual currency transmission or exchange which may be conducted by IndexBlock.

New York
Please note the following disclosures associated with virtual currency:

Virtual currency is not legal tender, is not backed by the government, and accounts and value balances are not subject to Federal Deposit Insurance Corporation or Securities Investor Protection Corporation protections.
Legislative and regulatory changes or actions at the state, federal, or international level may adversely affect the use, transfer, exchange, and value of virtual currency.
Transactions in virtual currency may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable.
Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction.
The value of virtual currency may be derived from the continued willingness of market participants to exchange fiat currency for virtual currency, which may result in the potential for permanent and total loss of value of a particular virtual currency should the market for that virtual currency disappear.
There is no assurance that a person who accepts a virtual currency as payment today will continue to do so in the future.
The volatility and unpredictability of the price of virtual currency relative to fiat currency may result in significant loss over a short period of time.
The nature of virtual currency may lead to an increased risk of fraud or cyber-attack.
The nature of virtual currency means that any technological difficulties experienced by

IndexBlock may prevent the access or use of a' customer’s virtual currency.
Any bond or trust account maintained by IndexBlock for the benefit of its customers may not be

sufficient to cover all losses incurred by customers.

IndexBlock, Inc. is regulated and licensed as a money transmitter by the New York State
Department of Financial Services. If you have a question or complaint, please first contact the consumer assistance division of IndexBlock at https://support.indexblack.com, [_1-888- 9087930_|tel:18889087930], or at its mailing address: 82 Nassau St #61234, New York, NY 10038.

For unresolved/written complaints, you may mail a complaint to New York State Department of Financial Services, Consumer Services Division, One State Street, New York, NY 10004-1417, [_800-342- 3736_|tel:8003423736], email: consumers@dfs.ny.gov, website: www.dfs.ny.gov/complaint

Tennessee

Please note that this license and the required surety bond do not cover the transmission of virtual currency. IndexBlock is licensed by the Tennessee Department of Financial Institutions as a money transmitter. The Tennessee Department of Financial Institutions does not regulate virtual currency.

Texas

If you have a complaint, first contact the consumer assistance division of IndexBlock at https://support.indexblack.com or (888) 908-7930. If you still have an unresolved complaint regarding the company's money transmission or currency exchange activity, please direct your complaint to: Texas Department of Banking, 2601 North Lamar Boulevard, Austin, Texas 78705, 1-877276-5554 (toll free), www.dob.texas.gov.

Virginia

IndexBlock, Inc. is licensed by the Virginia State Corporation Commission as a money transmitter, but such license does not cover the transmission of virtual currency (Bitcoin).

Washington

If you have a complaint, first contact the consumer assistance division of https://support.indexblack.com or 1-888-908-7930, and if you still have an unresolved complaint regarding the company’s money transmission activity, please contact the Washington State Department of Financial Institutions, Division of Consumer Services using one of the following methods:

Our Privacy Policy

Licenses for IndexBlack exist in the following jurisdictions in the United States:

DISCLOSURES

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