Argentina

1. ACCEPTANCE AND SCOPE

These Terms and Conditions (the “Argentina Terms”) govern access to and use of the BNKA.com technology platform (the “Platform”) by natural persons residing in the Republic of Argentina. Access to, registration on, or use of the Platform implies that the user declares that they have read, understood, and fully accepted these Argentina Terms. If the user does not agree with them, they must refrain from using the Platform.

These Argentina Terms supplement the BNKA General Terms and Conditions. In the event of any conflict or inconsistency, these Argentina Terms shall prevail with respect to services and users located in the Republic of Argentina.

2. DEFINITIONS

For the purposes of these Argentina Terms, the following definitions shall apply:

“Platform”: the technological interface accessible through BNKA.com and/or associated applications.

“User”: a natural person residing in the Republic of Argentina who accesses and uses the Platform.

“PSP”: Payment Service Provider as defined under the regulations of the Central Bank of the Republic of Argentina (BCRA).

“PSAV”: Virtual Asset Service Provider as defined under the regulations of the National Securities Commission (CNV).

“CVU”: Uniform Virtual Key associated with a payment account.

“PSP Services”: payment account (CVU), transfers, and payments in Argentine pesos.

“PSAV Services”: services related to virtual assets (purchase, sale, exchange, execution of orders and/or custody, as applicable).

3. NATURE OF BNKA.COM AND NEOXPAT LIMITED

The Platform is operated technologically by Neoxpat Limited, which acts exclusively as a provider of technological infrastructure and a digital interface. For regulatory purposes in the Republic of Argentina, it is expressly stated that:

BNKA.com and Neoxpat Limited:

• are not a bank;

• are not a Payment Service Provider (PSP);

• are not a Virtual Asset Service Provider (PSAV);

• do not provide regulated financial services;

• do not safeguard or hold user funds;

• do not process payments;

• do not issue electronic money;

• do not grant credit;

• do not execute transactions involving crypto-assets.

The Platform does not execute financial transactions itself, but enables users to access and initiate instructions regarding services provided by duly authorized independent third parties.

4. SERVICE PROVIDERS IN ARGENTINA (STRICT SEGREGATION OF ROLES)

In the Republic of Argentina, the services accessible through the Platform are provided by independent entities, each within the scope of its respective authorization and under its sole responsibility.

4.1 Block Digital Services S.A. – Payment Service Provider (PSP)

Block Digital Services S.A. is a company incorporated under the laws of the Republic of Argentina and registered as a Payment Service Provider with the BCRA.

Block Digital Services S.A. is the only entity responsible for providing the PSP Services, including:

• opening and administration of payment accounts with CVU;

• deposit, withdrawal and administration of funds in Argentine pesos;

• domestic transfers;

• payments and other payment services permitted under BCRA regulations.

Block Digital Services S.A. provides services exclusively in fiat currency (Argentine pesos) and does not provide services involving virtual assets, does not act as a PSAV, and does not purchase, sell, intermediate or safeguard crypto-assets.

4.2 Digital Trading S.A. – Virtual Asset Service Provider (PSAV)

Digital Trading S.A. is a company incorporated under the laws of the Republic of Argentina and registered as a Virtual Asset Service Provider with the CNV. Digital Trading S.A. is the only entity responsible for providing the PSAV Services, including:

• purchase, sale and exchange of virtual assets;

• execution of crypto-asset orders;

• custody of virtual assets, where applicable.

PSAV Services are not provided by Block Digital Services S.A., nor by BNKA.com, nor by Neoxpat Limited.

5. SEGREGATION OF SERVICES, FUNDS AND RESPONSIBILITIES

PSP Services and PSAV Services are strictly segregated in terms of:

• contractual arrangements;

• operations;

• regulatory framework; and

• liability.

In particular:

• Funds credited to CVU accounts: do not constitute bank deposits; are not covered by the deposit guarantee scheme; are used exclusively for PSP Services; and are not allocated to or linked to transactions involving crypto-assets.

• Any transaction involving virtual assets: is executed exclusively by Digital Trading S.A., under its own regulatory framework, and under its sole responsibility towards the user.

6. PLATFORM FEATURES

The Platform enables users, among other functionalities, to:

• view information, balances and transaction history;

• initiate requests and instructions to service providers;

• access notifications and support.

The Platform does not execute financial transactions by itself.

Execution is carried out exclusively by the competent service provider:

• Block Digital Services S.A. for PSP Services;

• Digital Trading S.A. for PSAV Services.

7. CONTRACTUAL RELATIONSHIP

The user acknowledges and agrees that:

• with respect to PSP Services, they enter into a direct and independent contract with Block Digital Services S.A.;

• with respect to PSAV Services, they enter into a direct and independent contract with Digital Trading S.A.;

• BNKA.com and Neoxpat Limited are not parties to regulated financial services contracts.

Each entity is solely responsible for the services it provides.

8. REGISTRATION, KYC, AML/CFT AND COMPLIANCE POWERS

Access to the services is subject to compliance with the following processes:

• identification and identity verification (KYC);

• anti-money laundering and counter-terrorism financing (AML/CFT);

• other applicable regulatory controls.

Service providers may, in accordance with applicable regulations:

• request additional information;

• apply operational limits;

• delay, reject or block transactions;

• suspend or cancel services.

9. SECURITY, ERRORS AND UNAUTHORIZED TRANSACTIONS

The user is responsible for maintaining the confidentiality of their credentials and devices.

Any unauthorized transaction, error or claim must be reported immediately through official channels.

Claims will be handled by the entity responsible for the relevant service.

10. FEES, COSTS AND TAXES

Applicable fees and charges will be disclosed by the service provider prior to the execution of each transaction. Any applicable taxes and/or withholdings shall be applied in accordance with current regulations. The user is responsible for their personal tax obligations.

11. LIMITATION OF LIABILITY

BNKA.com and Neoxpat Limited shall not be liable for:

• acts or omissions of Block Digital Services S.A. or Digital Trading S.A.;

• losses arising from PSP or PSAV Services;

• fluctuations in the value of virtual assets;

• interruptions attributable to third parties or to causes beyond their reasonable control.

Nothing herein limits non-waivable consumer rights under Argentine law.

12. SUSPENSION AND TERMINATION

BNKA.com may suspend or restrict access to the Platform in the event of:

• legal or regulatory requirements;

• security incidents;

• indications of fraud;

• operational or compliance risks.

Service providers may suspend or terminate the contractual relationship in accordance with their own terms and applicable regulations.

13. GOVERNING LAW AND JURISDICTION

These Argentina Terms shall be governed by the laws of the Republic of Argentina.

Any dispute shall be submitted to the jurisdiction of the competent courts of the Republic of Argentina, without prejudice to consumer rights.