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Terms of Use of the Viewing Platform

Published on 5 August 2026

IMPORTANT – NEW CONTRACTUAL FRAMEWORK

Regulatory compliance – Discontinuation of the former crypto-asset services (formerly digital assets)

Automata France SAS, which until now carried out certain crypto-asset activities under the commercial name “Vancelian”, is required to discontinue, as from 30 June 2026, the crypto-asset services operated by it and falling within the status of Crypto-Asset Service Provider within the meaning of Regulation (EU) 2023/1114 of 31 May 2023 on markets in crypto-assets (“MiCA”).

This mandatory discontinuation concerns the services formerly provided by Automata France SAS, in particular custody, deposit, withdrawal, purchase-sale or exchange services relating to crypto-assets (formerly digital assets) operated within the framework of the former Vancelian platform.

These terms and conditions of use (hereinafter the “Terms of Use”) constitute a substantial modification of (i) the characteristics of the services formerly provided by Automata France SAS and (ii) the former general terms and conditions applicable to those services, resulting from regulatory and technical developments. These Terms of Use require the express acceptance of Users and apply exclusively to access to the new software interface named “App Automata France” and to the read-only visualisation of the Historical Positions Pending Settlement, in particular the Vaults and Exclusive Offers.

These Terms of Use govern exclusively the conditions of access to and use of the Restricted Area (as defined below), as well as the arrangements for the read-only visualisation of the Vaults, Exclusive Offers and, more generally, the Historical Positions Pending Settlement.

New App Automata France interface

In accordance with the new regulatory requirements applicable to Automata Holding Ltd, App Automata France is a software interface enabling the user to view certain information and their historical positions.

Within this new framework, Automata Holding Ltd acts solely in the capacity of publisher of the interface. It carries out no crypto-asset transaction, provides no exchange or custody service, and does not act as counterparty to users’ transactions.

App Automata France offers no service in Fiat Currency. In particular, the interface does not permit the holding, issuance, deposit, withdrawal or exchange of euros. Any reference to a value in euros, where it appears in the interface, is purely indicative and denominated by reference to a stablecoin, in particular EURC or USDC.

Information relating to the former Vancelian services

Users still holding assets, balances or positions opened under the former services offered by Automata France SAS under the Vancelian name are invited to consult the FAQ dedicated to the plan for the discontinuation of crypto-asset services (formerly digital assets), available on the Website (in particular the section “Your exit or transfer options”).

The purpose of that FAQ is to set out, for information purposes, the practical arrangements enabling the users concerned to recover, withdraw, convert or transfer their assets within the framework of the plan for the discontinuation of the former services.

It is specified that such FAQ does not form part of these Terms of Use and does not modify their scope. These Terms of Use govern only the conditions of access to and use of the Restricted Area as well as the read-only visualisation of the Historical Positions Pending Settlement. They govern neither the former Vancelian services, nor the withdrawal, transfer or repayment arrangements applicable to positions previously opened in the former Vancelian application. Those elements remain governed, as the case may be, by the former applicable contractual documents, by the discontinuation plan, by any dedicated terms separately accepted by the user, or by the terms specific to the third-party companies concerned.

These Terms of Use, which may be updated periodically, set out the conditions under which Automata Holding Ltd (the “Company”) allows the eligible User to access, within the platform, the Restricted Area dedicated to the read-only visualisation of the Historical Positions Pending Settlement, in particular the Vaults and Exclusive Offers.

Reminder: these Terms of Use constitute a substantial modification of (i) the characteristics of the services formerly provided by Automata France SAS and (ii) the former general terms and conditions applicable to those services, resulting from regulatory and technical developments. These Terms of Use require the express acceptance of Users and apply exclusively to the use of the new software interface named “App Automata France”.

Please read these Terms of Use carefully before using the Services. These Terms of Use inform You of the conditions applicable to the Restricted Area, the Vaults, the Exclusive Offers or any other Historical Position Pending Settlement.

These Terms of Use are entered into between:

  • Automata Holding Ltd (the “Company”), a company incorporated under the laws of the United Arab Emirates (private company limited by shares) with its registered office at ResCo-Work79, Floor 1, Pixel Plaza – Tower 6, The Makers District, Abu Dhabi, Al Reem Island, United Arab Emirates, registered with the Abu Dhabi Global Market under number 33537,
  • and the User, a natural or legal person, acting in the capacity of professional or consumer, who (i) visits or uses the Company’s website accessible at the URL https://app.automatafrance.com/settlement-plan (hereinafter the “Website”) published by the Company and/or (ii) uses the Services offered within the Website/Application (as defined below), in particular those defined in the article entitled “Definitions” of these Terms of Use.

By using the Services and having expressly accepted these Terms of Use via the dedicated tab on the Website, you acknowledge and accept that you have read this document and consent to be legally bound by it.

The Company and the User are hereinafter individually referred to as a “Party” and jointly as the “Parties”.

PREAMBLE

Please consult the Website and the Application and read all of their sections Yourself. The Website and the Application provide a non-binding description of the Services that will be offered by the Company, more specifically on the following page: https://app.automatafrance.com/settlement-plan.

DEFINITIONS

In addition to the terms defined elsewhere in these Terms of Use, terms beginning with a capital letter shall have the meaning set out below, whether used in the singular or the plural.

Application – means the software interface named “App Automata France”, accessible via the Website and published by the Company, which allows You to access the Restricted Area enabling the read-only visualisation of the positions pending Settlement (Vaults and Exclusive Offers), under the dedicated conditions applicable to that area.

Vaults and Exclusive Offers – mean the Historical Positions Pending Settlement, based on contracts entered into directly between the User and Third-Party Debtor Companies, the allocation of which is frozen as at 22 May 2026 and presented on a read-only basis within the Restricted Area. The conditions applicable to these positions are the subject of these Terms of Use and the substantive rights relating thereto remain governed by the contracts originally entered into with the Third-Party Debtor Companies.

Crypto-assets – means any digital representation of value which is not issued or guaranteed by a central bank or a public authority, which is not necessarily attached to a legal currency and which does not have the legal status of currency, but which is accepted by natural or legal persons as a means of exchange and which may be transferred, stored or exchanged electronically.

Restricted Area – means the part of the Application reserved solely for eligible Users whose e-mail address corresponds to an existing position, and accessible after acceptance of these Terms of Use. The Restricted Area is limited to the read-only visualisation of the Vaults and Exclusive Offers positions. No new outstanding amounts and no new clients are admitted therein. These Terms of Use do not modify the substantive rights and obligations applicable to these historical positions, in particular the payment, interest, reward or repayment obligations incumbent on the Third-Party Debtor Companies, which remain governed by the applicable underlying contracts.

Fees – has the meaning given to it in Article 4.

Fiat Currency – means the official currency of a country issued by a central bank or other monetary authority.

Services – means, for the purposes of these Terms of Use, the technical visualisation, aggregation and display services made available by the Company within the Restricted Area, enabling the eligible User to consult, on a read-only basis, certain information relating to their Historical Positions Pending Settlement, in particular the Vaults and Exclusive Offers, under the conditions described in the Article “Description of the Services”. The Services do not include any custody, administration, exchange, brokerage, order execution, reception and transmission of orders, transfer, advice, portfolio management or intermediation service relating to crypto-assets provided by the Company.

Website – means the website accessible at the following address: https://app.automatafrance.com.

Company – means Automata Holding Ltd, as well as “We”, “Our” or “Us” in these Terms of Use.

Third-Party Debtor Companies – mean the third-party companies that are parties to the contracts underlying the Vaults and Exclusive Offers, namely Solaria SAS and The Heights Bali SAS (Exclusive Offers, BTC loans) and Vancelian Ltd (Mining Programme), which alone bear the obligation to pay interest and rewards as well as to repay capital.

European Union – means the Member States of the European Union.

User – means You, as well as “You”, “Your” or “Yours”.

INTERPRETATION

Unless the context of these Terms of Use otherwise requires:

  • words denoting a gender include all other genders;
  • words in the singular or the plural also include, respectively, the plural or the singular;
  • the terms “hereof”, “herein”, “hereunder” and their derivatives or terms of similar meaning refer to this document taken as a whole;
  • the word “including” means “including, without limitation”.

ARTICLE 1 – PURPOSE

The Company publishes and makes available the App Automata France Application, access to which is reserved solely for eligible Users. That space, named the Restricted Area, is governed by these Terms of Use.

These Terms of Use are intended to define the conditions under which the eligible User accesses the Restricted Area and consults, on a read-only basis, certain information relating to their Historical Positions Pending Settlement, in particular the Vaults and Exclusive Offers.

The Restricted Area is strictly limited to a visualisation and information function. It does not permit any new outstanding amount, any new subscription, any new client, any transaction on the historical positions, any management, any arbitrage, or any intervention by the Company in the flows relating to the positions concerned.

The historical positions that may be consulted in the Restricted Area are based on contracts entered into directly between the User and the Third-Party Debtor Companies. These Terms of Use do not modify those contracts and do not substitute the Company for the Third-Party Debtor Companies in respect of their payment, interest, reward or repayment obligations.

These Terms of Use apply without prejudice to the underlying contracts applicable to the Vaults, Exclusive Offers or other Historical Positions Pending Settlement.

ARTICLE 2 – CONDITIONS OF ACCEPTANCE

Any User accessing the Website or the Application is required to take note of these Terms of Use, which are accessible and downloadable via the “Terms of Use” section appearing on all pages of the Website, and must comply with their terms.

The Terms of Use and the content of these sections may also be communicated by the Company by e-mail at the User’s request to the following address: support@vancelian.com.

These Terms of Use are formally accepted by the User upon registration, creation of their account, access to the Application, or more generally upon any positive action evidencing their consent to these Terms of Use, in particular by means of a checkbox, an acceptance button or an equivalent mechanism.

The Company reserves the right to adapt or amend these Terms of Use at any time, in particular in order to take into account developments in the Services, the Application, technical constraints, applicable regulation or its organisation. Any new version made available online shall prevail over any prior version, including any version printed or saved in digital or paper format by the User. The User is accordingly invited to consult and read these Terms of Use regularly. The applicable version of the Terms of Use is that accessible online at the time the User visits and uses the Website or the Application.

Your continued use of the Website or the Application after such modifications, with or without express acceptance of the new Terms of Use, shall constitute Your consent to those modifications, subject to cases in which express acceptance is required.

If You do not accept these modifications, You have no right to obtain information, to use the Services or to access the Website or the Application, and You must immediately cease any use thereof.

Users declare and acknowledge that they remain responsible for regularly checking these Terms of Use in the version in force at each relevant time, an up-to-date version being available for consultation at any time on the Website and the Application.

A User who does not wish to accept the new Terms of Use may repudiate them and cease using the Services, under the conditions set out below.

Acceptance of these Terms of Use entails acceptance of the conditions of access to and use of the Restricted Area. It does not entail acceptance of any new economic conditions relating to the historical positions, nor any amendment or novation of the underlying contracts applicable to the Vaults, Exclusive Offers or other Historical Positions Pending Settlement.

You understand and accept that We may, at any time and for any reason or for no reason, with or without notice and without having to refer to You, interrupt or restrict Your use of the Website and the Application, without there being any remedy.

We reserve the right to restrict Your access to the use of the Services. You acknowledge that we have the right to restrict Your access to the Services by any technically available means if we suspect, in our sole discretion, that (a) you have engaged in fraudulent activity; (b) you are the subject of any sanction administered or enforced by the Office of Foreign Assets Control of the U.S. Department of the Treasury (hereinafter “OFAC”), the United Nations Security Council, the European Union, HM Treasury, or any other legal or regulatory authority in any applicable jurisdiction; (c) either You, as a natural or legal person, or the address of Your personal wallet appears on the Specially Designated Nationals and Blocked Persons List (hereinafter the “SDN List”), the Consolidated Sanctions List (hereinafter the “Non-SDN Lists”), or any other sanctions list administered by OFAC; (d) you are located, organised or resident in a country or territory that is the subject of sanctions, or whose government is the subject of sanctions, including, without limitation, Cuba, Belarus, Iran, Iraq, Liberia, North Korea, Russia, Sudan and Syria; or (e) you have otherwise acted in breach of these Terms of Use. If we have a reasonable ground to suspect that you are using the Website or the Application for unlawful purposes, we reserve the right to take any measure that we deem appropriate.

These Terms of Use are entered into for an indefinite term.

The User acknowledges that they have full knowledge of the nature, purpose and characteristics of the Website, the Application and the Services, as well as of the prerequisites for their use. The User acknowledges that they have requested and obtained all necessary information, in particular concerning the quantitative and qualitative characteristics of the Services, enabling them to assess the suitability of the Services for their needs and to enter into these Terms of Use with full knowledge of the facts. The User is solely responsible for the choice to use the Website and the Services, such that the Company’s liability cannot, on any account, be sought on that ground.

ARTICLE 3 – DESCRIPTION OF THE SERVICES

3.1 Nature of the Application

The Services provided by the Company under these Terms of Use are limited to technical visualisation and display services within the Restricted Area, enabling the eligible User to consult, on a read-only basis, certain information relating to their Historical Positions Pending Settlement.

The Company itself provides NO custody, administration, exchange, brokerage, order execution, reception and transmission of orders, advice, portfolio management or intermediation service relating to crypto-assets.

The Application is made available in the form of a Web interface. It is not intended for “US persons” within the meaning of applicable US regulation, nor for persons located, organised or resident in a jurisdiction that is the subject of sanctions, who are not authorised to access it. Any attempt by a User to access the Application or to circumvent these restrictions is made at their sole risk and under their sole responsibility.

The Company makes no representation and provides no warranty as to the availability or compliance of the Application outside the territories where it is made available, and Users remain fully responsible for ensuring that their use of the Application complies with the laws applicable in their jurisdiction.

3.2 Access journey to the Restricted Area

Access to the Restricted Area is reserved solely for eligible Users whose e-mail address corresponds to an existing Historical Position Pending Settlement.

Where that condition is met, the User may be offered, within the Application, access to the Restricted Area, subject to prior acceptance of these Terms of Use.

The Restricted Area is limited to the read-only visualisation of the Historical Positions Pending Settlement, in particular the Vaults and Exclusive Offers. It does not permit any new subscription, any new outstanding amount, any transaction on the positions concerned, any management, any arbitrage, or any intervention by the Company in the flows relating to those positions.

3.3 Settlement of the Vaults and Exclusive Offers

The vault positions (“Vaults”) and exclusive offers (“Exclusive Offers”) are based on contracts entered into directly between the User and the third-party debtor companies (the “Third-Party Debtor Companies”), namely Solaria SAS and The Heights Bali SAS (in respect of Exclusive Offers, BTC loans) and Vancelian Ltd (in respect of the Mining Programme).

Those Third-Party Debtor Companies alone bear the obligation to pay interest and rewards, as well as to repay capital, in respect of the positions concerned.

Since the discontinuation of the Company’s former Services, the allocation of the Vaults and Exclusive Offers positions has been frozen as at 22 May 2026 and is presented on a read-only basis within the Restricted Area. Interest and rewards, and then capital at maturity, are paid directly by the Third-Party Debtor Companies.

The Company does not intervene in any of these flows, whether originating from Solaria SAS, The Heights Bali SAS or Vancelian Ltd; the Application is limited to enabling their visualisation within the Restricted Area.

3.4 Limited role of the Company

The Company acts exclusively as publisher of a technical interface enabling the read-only visualisation of the Historical Positions Pending Settlement within the Restricted Area. The Company does not custody crypto-assets, does not hold Users’ private keys, does not initiate or sign any transaction on their behalf, does not receive, transmit, route or execute any order or flow, does not act as counterparty and exercises no control over the obligations incumbent on the Third-Party Debtor Companies.

3.5 Evolution of the Services

To the maximum extent permitted by law, the Company may, at any time and without notice, develop, improve or adapt the Website, the Application and the Services, and more generally the Services offered, in particular with a view to improving the functionalities offered on the Website and the Application or within the framework of the Services. This may include the deployment of update(s), new version(s), new services or other services, or the removal of existing Services. The Company may in particular evolve the Restricted Area in order to improve its visualisation, display or security functionalities, or in order to take into account technical, regulatory or organisational constraints.

In the event of the definitive discontinuation of an existing Service, the Company shall use reasonable efforts to inform Users of that modification with reasonable notice and to provide them with alternative solutions (e.g. transfers to a third-party service, etc.). In the event of the definitive discontinuation of all Services, the Company shall proceed with the termination of these Terms of Use.

In addition, the Company may, at any time and without notice, supplement or modify the Website, the Application, their content and the Services accessible thereon, according to technological developments. Where applicable, the User must ensure that the resources of their computer/telephone are adapted to the modifications of the Website, the Application and the Services.

ARTICLE 4 – FEES

Unless otherwise indicated and brought to the attention of the eligible User, access to the Restricted Area and the read-only visualisation of the Historical Positions Pending Settlement give rise to no specific fee charged by the Company under these Terms of Use.

These Terms of Use do not govern any fees that may be applicable under the underlying contracts applicable to the Vaults, Exclusive Offers or other Historical Positions Pending Settlement, which are described on the dedicated page of the Application available at the following URL: https://app.automatafrance.com/settlement-plan.

ARTICLE 5 – DATA PROTECTION

Personal data may be processed through the Website and the Application. The User may access the Company’s “privacy policy” on the Website: https://app.automatafrance.com/settlement-plan.

Cookies and other trackers or similar technologies (e.g. Google Analytics) may be installed and/or read in the User’s browser or terminal when visiting the Website and the Application. The User may access the Company’s “cookie policy” on the Website.

ARTICLE 6 – ACKNOWLEDGEMENT OF RISKS

6.1 Acknowledgements by the User

The User acknowledges that the Historical Positions Pending Settlement may be exposed to risks relating to crypto-assets, underlying assets, Third-Party Debtor Companies, blockchain networks, smart contracts, variations in value, payment delays or the absence of liquidity. The Restricted Area has an exclusively informative and visualisation function. Its use does not constitute an investment, trading, exchange, transfer, management or custody operation carried out by the Company.

6.2 Additional legal warnings

No statutory warranty of conformity applies to the Services or to these Terms of Use.

6.3 Risk factors

You declare that You have taken note of all of the risk factors annexed to these Terms of Use, that You have understood them and that You accept them.

ARTICLE 7 – REPRESENTATIONS, WARRANTIES AND UNDERTAKINGS

Hereby, You acknowledge that by using the Services, You represent and warrant that the following statements are accurate:

You are of sound mind and have the powers and authority required to understand and accept these Terms of Use, as well as to perform and fulfil the obligations set out herein, and You declare that You fully understand English as well as this English version of these Terms of Use.

You are of legal age under the law (i.e. at least 18 years of age) and have full legal capacity to enter into commitments under these Terms of Use.

In addition, You declare and acknowledge that:

  • You are a citizen or national of, or act on behalf of a company that has its domicile in, the European Union; and
  • You are not a citizen or national of, nor do You act on behalf of a company that is located in, or majority-owned by persons or entities from, a country subject to additional sanctions and/or presenting increased AML/CFT risks, such as: Afghanistan, Albania, Angola, Azerbaijan, Bosnia and Herzegovina, Bahamas, Barbados, Myanmar, Botswana, Burkina Faso, Burundi, Cayman Islands, Cambodia, Cameroon, Crimea, Luhansk or Donetsk (Ukraine), Chad, China, Congo, Congo (Democratic Republic), Cuba, Ethiopia, Eritrea, Fiji, Palau, Ghana, Guinea, Guinea-Bissau, Haiti, Iran, Iraq, Jamaica, Jordan, Lao People’s Democratic Republic, Liberia, Libya, Madagascar, Mali, Mozambique, Nicaragua, Uganda, North Korea, Pakistan, Panama, Puerto Rico, Russia, American Samoa, Senegal, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Tajikistan, Trinidad and Tobago, Turkmenistan, Uganda, Uzbekistan, Vanuatu, Venezuela, Yemen, Zimbabwe.

You agree not to use the Website or the Services for unlawful purposes, including, without limitation, for the sending or storage of any unlawful content or for fraudulent purposes. The Company reserves the right to terminate Your use thereof if You use or attempt to use the Website or the Services for unlawful purposes, including, without limitation, for the sending or storage of any unlawful content or for fraudulent purposes.

You shall use the Website exclusively for Your personal and own use and You shall not resell it to a third party.

You shall not authorise third parties to use Your User Account.

You shall not assign or otherwise transfer Your access rights to a User Account to any other natural or legal person; You shall not use a User Account that is encumbered with rights for the benefit of a person other than You without appropriate authorisation.

You shall not use the Website in a manner that causes disturbance, nuisance, inconvenience or annoyance.

You shall not harm the proper functioning of the Company’s business.

You shall not in any manner attempt to harm the Company’s business.

You shall keep the credentials of Your User Account secure and strictly confidential.

You undertake not intentionally to exploit, or attempt to exploit, any error, bug, vulnerability or defect affecting the code, smart contracts or any other aspect of the Application or of the Company for the purposes of personal enrichment or with a view to obtaining an advantage other than those expressly provided for by the expected functionality of the Application. You further agree to report without delay any anomaly of that nature to the Company and to refrain from sharing or disseminating any information relating to such anomalies to third parties, except where required by law.

ARTICLE 8 – LIMITATION OF LIABILITY

To the fullest extent permitted by law and by any regulatory provision to which We are subject, You acknowledge and accept that the entirety of the risk arising from Your use of the Services is borne exclusively by You and remains at all times at Your charge, before, during and after the possible occurrence of such risk.

The User shall be liable for the obligations incumbent upon them under these Terms of Use, in accordance with the applicable general rules.

The Company’s liability for defective performance or non-performance of its obligations in accordance with these Terms of Use may be engaged only in the event of proven fault on the part of the Company.

Furthermore, the Company’s liability may be engaged only in respect of direct damage alone (to the exclusion of any indirect damage) suffered by the User by reason of a breach by the Company of its obligations as they result from these Terms of Use. By contrast, the Company shall under no circumstances be held liable for indirect damage caused to the User. In addition, except in the event of gross negligence or wilful misconduct, the Company may be held liable towards the User only for foreseeable damage alone.

The Company shall not incur liability in the event of a breach or delay in the performance of its obligations under these Terms of Use if such delay or breach results from the fault of a third party or from a force majeure event; for the purposes of these Terms of Use, force majeure is defined as any act, omission, cause or circumstance beyond the Company’s reasonable control, including, without limitation: natural disasters, war, a state of national emergency, protest or rebellion movements, civil unrest, riots or strikes and any form of industrial dispute (whether or not involving the staff of either party), earthquakes, floods, droughts, epidemics, fires, explosions, acts of terrorism or any other act ordered by a government, council or constituted body.

The Company cannot be held liable in the event of abnormal use, which includes use that is not in accordance with these Terms of Use, or fraudulent or unlawful use of the Website or the Services by the User and, more generally, for any breach by the User of these Terms of Use.

The User must at all times ensure the security of their User Account.

Clause applicable solely to professional Users. This clause applies only to professional Users. In that regard, our aggregate liability for any generating fact or event arising out of or in connection with these Terms of Use shall be capped at the total amount of the Fees paid by a User for the use of the Services offered by the Company during the preceding twelve (12) months, and may under no circumstances exceed that amount. The limitations of liability set out in this clause constitute an essential element of the basis of the agreement entered into between Us and You.

Neither We nor any other party involved in the design, production or provision of the Services may be held liable, in any manner whatsoever, for incidental, special, exemplary, legal (reasonable costs) or consequential losses or damages, including, without limitation, loss of profits, loss of data (excluding personal data, the specific rules for which are set out in our privacy policy), loss of goodwill, service interruption, computer damage or system failure or the cost of replacement products or services, nor for any damage whatsoever of a personal nature, including harm to physical integrity or moral suffering resulting from or in connection with these Services, whether or not based on a warranty, contract, tort, including negligence, product liability or any other cause, whether or not We have been informed of such elements and of the possibility of such or similar damage, and even if a limited remedy provided for and contained in these Terms of Use has failed or might fail of its essential purpose.

ARTICLE 9 – INDEMNIFICATION

Clause applicable solely to professional Users. This clause applies exclusively to professional Users. You agree to hold harmless, indemnify and keep Us and Our contractors, subcontractors, affiliates and subsidiaries, as well as Our agents and their officers, directors, employees and agents, indemnified against any claim, liability, damage, loss and expense, including, without limitation, reasonable attorneys’ and accountants’ fees, arising out of, or in any way connected with, Your breach of any of these Terms of Use.

ARTICLE 10 – INTELLECTUAL PROPERTY

These Terms of Use do not entail any transfer, grant or licence of intellectual property rights or of the sui generis right of a database producer for the benefit of the User.

The Website and the Application, taken as a whole, as well as each of the elements of which they are composed taken individually, in particular the programmes and developments, their structure, and the content including data, texts, still or moving images, logos, sounds, graphics, photographs and files, are the exclusive property of the Company or of third parties that have provided them or have granted the Company the right to exploit them.

Any representation or reproduction, in whole or in part, of the Website or the Application or of any of their elements, without the express authorisation of the Company, is prohibited and would constitute an infringement and/or an act of unfair competition or free-riding. In any event, on any representation or reproduction authorised by the Company of all or part of the Website and the Application or of the elements of which they are composed, the mention “Copyright [2026] – all rights reserved” must appear.

The databases present on the Website and the Application are protected under intellectual property, and any extraction or reuse of a qualitatively or quantitatively substantial part of the content of those databases is prohibited and liable to sanctions.

The trademarks and logos appearing on the Website and the Application are trademarks registered by the Company or by third parties. Any reproduction, imitation or use, in whole or in part, of those distinctive signs without the express authorisation of the Company or in breach of its intellectual property rights engages the liability of their author.

The other distinctive signs, in particular corporate names, trade names, shop signs and domain names reproduced on the Website and the Application, are the property of the Company or of third parties, and any reproduction thereof without express authorisation is liable to constitute identity theft engaging the liability of its author.

ARTICLE 11 – EXCLUSIONS OF LIABILITY

If you choose to use the Services, you do so entirely at your own risk and, to the fullest extent permitted by applicable law, subject to the conditions set out in this clause.

You acknowledge and accept that we have, under no circumstances and on any account whatsoever, any obligation to carry out verifications not required by applicable law, including, without limitation, background checks, in respect of any User.

We shall carry out only those verifications that are required by law or that we reasonably consider necessary to offer the Services.

Hereby, you acknowledge and accept that the Services, as well as the Website and the Application, are made available to you “as is” and “as available”, without any warranty of any kind, and that, without prejudice to the generality of the foregoing, we give no warranty and assume no liability as to their accuracy, availability, reliability, security, fitness for a particular purpose or performance.

We give no warranty that the Services, including, without limitation, any information provided via any means of communication whatsoever, will meet Your requirements or will be available or made available on an uninterrupted, secure or error-free basis.

We give no warranty as to the quality of any content, nor as to the truthfulness, completeness or reliability of any content obtained through the Website and the Application.

No advice or information, whether oral or written, obtained from Us or through Our Website or Our Application, shall create any warranty, express or otherwise, under these Terms of Use.

We disclaim all liability in the event of interruption, delay or errors of use and cannot be held liable for any loss whatsoever, whether direct, indirect or consequential.

The Company does not warrant, ensure or represent that any item downloaded from the Internet onto this Website or the Application is free from viruses. You are expressly responsible for implementing appropriate procedures, antivirus protection and software intended to protect Yourself and Your data. In that regard, the Company cannot be held liable for any damage caused to Your equipment by reason of the use of the Website or the Application or by reason of any content published on a website or to which a link refers. You must also be aware that SMS and e-mail services are vulnerable to spoofing and phishing attacks and must exercise vigilance when examining messages purporting to originate from us. Your use is entirely at Your own risk.

The Company assumes no responsibility as to the success or lack of success of the Services. You hereby acknowledge that the Services are in a development phase and that, accordingly, the Company can provide no warranty of any kind whatsoever concerning the success or lack of success of said Services. You may lose the entirety of the amounts invested.

The Website and the Application may contain links to websites, advertisers, services, special offers or other events or activities of third parties that do not belong to us and are not under our control. We neither approve nor acknowledge any responsibility whatsoever in respect of such third-party sites, information, items, products or services. If You access a third-party website from the Website or the Application, You do so at Your sole risk, and You understand that these Terms of Use do not apply to Your use of those sites. You expressly release Us from any liability of any kind whatsoever resulting from Your use of any third-party website, service or content. In addition, Your dealings with advertisers found on the Website or the Application, or Your participation in their promotional operations, including payment and delivery of goods, as well as any other terms (such as warranties), engage only You and said advertisers. You accept that We shall not be liable for any loss or damage of any kind whatsoever in connection with Your dealings with those advertisers.

The regulatory status of crypto-assets remains uncertain or unsettled in many jurisdictions. Indeed, certain jurisdictions may adopt legislative provisions affecting the Services, the Company assuming no liability in respect of any regulatory action that may be brought or that may be liable to affect the Company in the future. In addition, the Company may cease carrying on its activities in any jurisdiction that would bring regulatory action, amend its law unfavourably or render commercially inoperative or undesirable any exchange in said jurisdiction.

The User acknowledges and accepts that use of the Services confers on the User no right in the form of an equity interest or a claim against the Company and/or its affiliates. Use of the Services confers no direct or indirect right over the capital or revenues of the Company. It constitutes neither evidence of an ownership right nor a right of control. Use of the Services confers on the User no asset or share in the Company, nor in the Website nor in the Application. The User’s rights are strictly limited to those provided for in these Terms of Use.

The User acknowledges and accepts that, to the fullest extent permitted by applicable law, no provision of these Terms of Use constitutes or entails any warranty or undertaking as to any form of performance of the Services or of any crypto-asset linked to the Services by means of the information provided to you. Such information is strictly intended for the use described in these Terms of Use.

The User acknowledges and accepts that the User may access the Website and the Application only by using authorised means. The Company incurs no liability if you do not have a device, computer, operating system, browser or any other software or hardware compatible with the technology. The Company reserves the right to terminate your use thereof if you use or attempt to use an incompatible or unauthorised device.

The limitation of liability clauses are of general application and may be supplemented by additional policies, procedures, limitation of liability clauses, guidelines, rules, modalities or specific conditions of application communicated by the Company, in particular through a registration or subscription process, or by any other means. In the event of a conflict between the Terms of Use and any additional policy, procedure, limitation of liability clause, guideline, rule, modality or specific condition of application, said additional policies, procedures, limitation of liability clauses, guidelines, rules, modalities or specific conditions of application shall prevail.

ARTICLE 12 – GENERAL PROVISIONS

Any reference to a law, legislative or regulatory text, decree, order, regulation or any other similar instrument appearing in these Terms of Use shall be construed as a reference to that text or instrument as in force at a given time, taking into account any amendment, extension, extension of scope, codification or consolidation, and includes all then-current subordinate legislative or regulatory texts.

If one or more of these Terms of Use, or any part thereof, is or becomes invalid, unlawful or unenforceable in any respect, it shall, to the extent of such invalidity, unlawfulness or unenforceability, be deemed severed and deleted, and all other provisions shall remain in force and continue to produce all their effects.

Unless You indicate otherwise to us, or unless the law provides otherwise, You agree to receive all communications from us by the posting of notices on Your User Account within the Application. You acknowledge that You are able to print such communications for Your records. You agree that all communications that we address to You by electronic means satisfy any legal requirement requiring that a communication be made in writing.

To the extent that we may address messages to You directly via Your User Account on the Application, it is incumbent upon You to monitor those messages and to respond to them appropriately. You represent and warrant that any information that You enter is accurate and that it relates exclusively to You.

All communications and all data that we collect are governed by our Privacy Policy.

The Company draws the User’s attention to the risks inherent in any economic operation relating to crypto-assets. The User’s use of the Services entails acceptance of those risks. In that regard, any financial loss suffered by the User and resulting from the use of the Services shall not constitute a situation of unforeseeability (imprévision) and shall not give rise to the benefit of any legal or regulatory provision that may apply to such a situation, which the User expressly acknowledges and accepts. The same applies, more generally, in the event that the contractual balance were to be upset by circumstances that were not foreseeable at the time of conclusion of the Terms of Use, even if their performance were to prove excessively onerous, the User accepting to bear the entirety of the economic and financial consequences thereof and, in that case, to waive reliance on any legal or regulatory provision that would apply to such a situation of unforeseeability.

Any waiver of any breach of these Terms of Use by the Company, or of any default, under any of the stipulations of these Terms of Use by the User, shall be valid only if agreed in writing. Any subsequent breach or default by the User, whether similar or not, shall in no way affect these Terms of Use. Likewise, any failure or delay by either Party to these Terms of Use to require the strict performance of any of the stipulations of these Terms of Use shall not be construed as entailing a waiver of any of its rights under these Terms of Use.

These Terms of Use contain the entirety of the stipulations agreed between the Parties concerning exclusively access to and use of the Restricted Area. They neither repeal nor replace the former contractual documents applicable to the former Vancelian services, nor the underlying contracts entered into with the Third-Party Debtor Companies in respect of the Vaults, Exclusive Offers or other Historical Positions Pending Settlement.

Unless otherwise provided, the time limits and periods indicated in these Terms of Use are understood in calendar days.

ARTICLE 13 – ASSIGNMENT

The Company reserves the right to assign, at any time and without notice to You, its rights and obligations under these Terms of Use to any person, without seeking Your consent to such assignment. The Company may make a notification, for purely informational purposes, via Your User Account on the Application.

ARTICLE 14 – PRE-CONTRACTUAL INFORMATION – CLIENT ACCEPTANCE

The User acknowledges that they have been informed in a comprehensible manner, by means of the making available of these Terms of Use, prior to acceptance thereof:

  • of the essential characteristics of the Services, having regard to the means of communication used;
  • of the price of the Services;
  • of the arrangements for payment, supply and performance of these Terms of Use;
  • of the identity of the Company, its postal and electronic contact details, as well as of its activities, if those do not emerge from the context;
  • of the legal and contractual warranties and the arrangements for their implementation;
  • of the possibility of having recourse to conventional mediation in the event of a dispute;
  • of the absence of a right of withdrawal and the other important contractual conditions.

The fact that Users use the Website or the Application entails full and complete acceptance of these Terms of Use, which the User expressly acknowledges, waiving reliance on any contradictory document, which would be unenforceable against the Company.

ARTICLE 15 – MEDIATION AND DISPUTE RESOLUTION

Any User having the status of consumer within the meaning of applicable law may, free of charge, refer the matter to a consumer mediator with a view to the amicable resolution of a dispute opposing them to the Company.

The body designated for that purpose by the Company is the Centre de la Médiation de la Consommation de Conciliateur de Justice (“CM2C”).

In order to contact that body, the User may go to its website https://www.cm2c.net/declarer-un-litige.php and file a claim there.

A dispute may be examined by the consumer mediator only if:

  • the User evidences that they have previously attempted to resolve their dispute directly with the Company by means of a written claim expressly identified as such, setting out in detail the grounds of their claim as well as all information useful to the Company to understand, examine and assess the causes, consequences and effects of that claim, and sent by e-mail to: support@vancelian.com;
  • the claim is not manifestly unfounded or abusive;
  • the dispute has not already been examined, nor is it being examined, by another mediator or by a court;
  • the User refers the matter to the mediator within a maximum period of one year from the date of their written claim addressed to the Company;
  • the dispute falls within the mediator’s competence.

The User is informed by the mediator of the outcome reserved for their request for mediation.

In addition, the User is informed that, pursuant to Article 14 of Regulation (EU) No 524/2013, the European Commission has set up an online dispute resolution platform, facilitating the independent out-of-court settlement of online disputes between consumers and professionals within the European Union. That platform is accessible at the following link: https://webgate.ec.europa.eu/odr/.

ARTICLE 16 – GOVERNING LAW AND COMPETENT JURISDICTION

These Terms of Use are governed by French law and construed in accordance therewith.

IN THE EVENT OF A DISPUTE RELATING TO THE INTERPRETATION OR PERFORMANCE OF THESE TERMS OF USE, THE PARTIES SHALL ENDEAVOUR TO FIND AN AMICABLE SOLUTION.

Failing amicable settlement, You acknowledge and accept that in the event of a claim or dispute, such claim or dispute shall be submitted to the exclusive jurisdiction of the courts of Paris (France).

THESE PROVISIONS RELATING TO THE APPLICABLE LAW AND COMPETENT COURTS APPLY SUBJECT TO THE MANDATORY PROVISIONS THAT MUST BE APPLIED TO THE USER IN THEIR CAPACITY AS A CONSUMER.

These Terms of Use may be translated by the Company or by third parties into other languages. The French version shall prevail in the event of any discrepancy arising from the translation.

ARTICLE 17 – CONTACT US

If You have any questions, please do not hesitate to contact us at the following e-mail address: support@vancelian.com.

ANNEX – RISK FACTORS

Legal risk and risk of unfavourable regulatory intervention in one or more jurisdictions

The operation of the Services may be affected by the adoption of restrictive laws, the publication of restrictive or unfavourable opinions, the issuance of injunctions by national regulatory authorities, the bringing of proceedings or investigations of a regulatory nature, including, without limitation, the introduction of restrictions on the use or holding of crypto-assets, liable to prevent or limit the development of the Services.

Having regard to the absence of an established legal qualification of crypto-assets in most States, each User is strongly recommended to carry out a legal and tax analysis relating to the use of the Services, in light of the laws applicable to their nationality and place of residence.

Risk of theft and hacking

Computer hackers or other malicious or criminal groups or organisations may attempt to harm the Website and the Application or to compromise the availability of the Services in various ways, including, without limitation, by denial-of-service attacks, Sybil attacks, spoofing operations, malicious surfing, malware attacks or attacks based on consensus mechanisms.

Risk of security flaws in the core infrastructure software of the Website and the Application

There is a risk of weaknesses or bugs within the core infrastructure elements of the Website and the Application, liable to hinder the use of the Services.

Risk of flaw or exploitable vulnerability in the field of cryptography

Advances in cryptography, or technical progress such as the development of quantum computers, may pose risks to crypto-assets as well as to the Website and the Application.

Risk of dissolution of the project

Notwithstanding the fact that Users permanently have access to their funds, for several reasons including, without limitation, an unfavourable fluctuation in the market value of crypto-assets, the breakdown of business relationships or competing intellectual property claims, the project may cease to constitute a viable activity and be dissolved.

Risk of malfunction of the Website, the Application and the Services

The Website, the Application and the Services may be affected by an unfavourable malfunction including, without limitation, a malfunction resulting in the loss of market information.

Unforeseen risks

Crypto-assets constitute a new and unproven technology. In addition to the risks set out above, there are other risks that the Company’s team is unable to foresee. Risks may also arise and/or materialise in the form of unforeseen combinations or modifications of the risks set out herein.

In the event of doubt as to the measures that You must take and the consequences that will result therefrom, You are invited to consult, where applicable, Your professional adviser, in particular legal, financial, tax or other, in order to obtain the necessary opinions.

Last updated: 5 August 2026