Colombia

1. INTRODUCTION AND SCOPE

These Terms and Conditions for Colombia (the “Colombia Terms”) govern access to and use, by users residing in the Republic of Colombia, of the financial services offered through the BNKA technology platform (the “Platform”).

These Colombia Terms supplement and must be read together with the BNKA General Terms and Conditions (the “General Terms”). In the event of any inconsistency, these Colombia Terms shall prevail.

The Platform is owned by Neoxpat Limited, a company incorporated under the laws of Cyprus, which acts exclusively as the owner and operator of the technological infrastructure, without providing regulated financial services in Colombia.

2. SERVICE DELIVERY MODEL IN COLOMBIA

In the Republic of Colombia, the financial services accessible through the Platform are provided under a banking correspondent model, in accordance with applicable regulations and under the supervision of the Superintendence of Finance of Colombia (SFC).

3. PARTICIPATING ENTITIES

3.1 Banco Cooperativo Coopcentral

Banco Cooperativo Coopcentral is a financial institution incorporated under the laws of the Republic of Colombia and supervised by the Superintendence of Finance of Colombia.

The Bank is solely responsible for providing the financial products offered to users in Colombia, including, as applicable:

• accounts and deposits;

• low-value financial products;

• management and custody of funds;

• other products authorized under applicable regulations.

Funds deposited by users constitute financial products of the Bank and are governed by Colombian banking regulations. Depending on the nature of the product, such funds may be covered by the deposit insurance managed by the Financial Institutions Guarantee Fund (Fogafín).

3.2 BNKA as a digital correspondent

In Colombia, BNKA acts as the Bank’s digital correspondent, operating exclusively as a technological channel that allows users to:

• initiate requests to open and use the Bank’s financial products;

• check balances, transactions, and information;

• carry out transactions permitted under applicable regulations.

BNKA is not a financial institution, does not take deposits from the public, does not manage funds, does not set financial terms, and does not assume risks inherent to banking activity.

4. CONTRACTUAL RELATIONSHIP

By using the financial services available in Colombia:

• the user enters into a contract directly with Banco Cooperativo Coopcentral regarding the financial products;

• BNKA is not a contractual party to such financial products and acts solely as a digital correspondent and technology provider.

The specific terms and conditions of each financial product are determined by the Bank and communicated to the user in accordance with applicable regulations.

5. REGISTRATION, IDENTIFICATION, AND COMPLIANCE

Access to financial services is subject to compliance with identification, verification, and customer due diligence (KYC) processes, anti-money laundering and counter-terrorist financing (AML/CTF) requirements, and other controls required under Colombian regulations and the Bank’s policies.

The Bank and BNKA may request additional information, apply limits, suspend transactions, or restrict access when required for regulatory, security, or risk management reasons.

6. COSTS, FEES, AND ECONOMIC TERMS

Fees, commissions, and costs applicable to financial products are established by the Bank and communicated to the user prior to contracting or executing transactions.

BNKA does not determine or directly receive banking fees, except those related to the use of the Platform, when applicable and previously disclosed.

7. USER OBLIGATIONS

The user undertakes to:

• provide truthful, complete, and up-to-date information;

• use the services lawfully and in accordance with Colombian law;

• not use the services for unlawful, fraudulent, or prohibited activities;

• keep their credentials and devices confidential.

8. LIABILITY

Banco Cooperativo Coopcentral shall be exclusively responsible for the financial products it provides.

BNKA and Neoxpat Limited shall not be liable for:

• acts or omissions of the Bank;

• losses arising from financial products;

• changes in financial conditions;

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

Nothing in these Terms limits the consumer’s non-waivable rights under Colombian law.

9. SUSPENSION AND TERMINATION

Access to the services may be suspended or terminated in accordance with applicable regulations, the Bank’s policies, or requirements issued by a competent authority.

Termination of access to the Platform does not extinguish the user’s outstanding obligations toward the Bank.

10. AMENDMENTS

These Colombia Terms may be amended to reflect regulatory or operational changes. Amendments will be communicated in accordance with applicable regulations.

11. GOVERNING LAW AND JURISDICTION

These Colombia Terms are governed by the laws of the Republic of Colombia.

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