Effective Date: April 1, 2025

1. Nature of Digital Assets

Cryptocurrencies and digital assets are highly speculative, carry a high degree of risk, and are not suitable for all investors. Unlike traditional fiat currencies, digital assets are not backed by a central bank or government. Their value is determined entirely by market supply and demand.

2. Market Volatility and Potential for Total Loss

The price of digital assets can change rapidly and unpredictably. You acknowledge that:

• The value of assets in your Zelencio wallet may drop to zero in a short period.

• "Flash crashes" and extreme liquidity shortages can occur without warning.

• Zelencio is not liable for any financial losses resulting from market movements, including those triggered by our SOMD (Auto-Swap) automation.

3. No Guarantee of Price Accuracy

While Zelencio uses global WebSockets (including data from providers like Gate.io), there may be technical delays or discrepancies. The price you see on your screen may not be the exact price at the moment of execution due to "Slippage" or "Network Latency."

4. Regulatory and Legal Risks

The regulatory environment for cryptocurrency in Africa and globally is still evolving.

• Changes in government laws (e.g., Central Bank of Nigeria mandates) may suddenly restrict your ability to withdraw or trade assets.

• Zelencio may be forced to suspend services in your specific region to comply with new laws.

• Digital assets are generally not covered by "Deposit Insurance" or "Investor Protection" schemes.

5. Security and Personal Responsibility

The security of your assets is a shared responsibility. Zelencio is not responsible for losses if:

• You lose your mobile device and do not have a backup of your 2FA.

• You are a victim of a "Phishing" or "Social Engineering" attack.

• You share your Zelencio Code (Voucher) with a stranger who redeems it before you.

6. P2P and Third-Party Risks

By using the C2C/P2P Marketplace or Escrow Hub, you acknowledge that:

• You are trading directly with another human being.

• Zelencio acts as an escrow custodian but does not control the actual bank transfer (fiat) between parties.

• You carry the risk of "Bank Account Freezes" if your trading partner uses suspicious funds.

7. "Automation" and Technical Risk

Using the SOMD (Swap on Market Drop) feature involves technical risks. Zelencio does not warrant that the automation will execute 100% of the time, especially during periods of extreme network congestion or server maintenance.

Effective Date: April 1, 2025
Last Updated: March 1, 2026

SECTION 1: STATEMENT OF PURPOSE AND COMPLIANCE

1.1. Zero Tolerance Policy: Zelencio (“the Platform”) maintains a zero-tolerance policy regarding money laundering, terrorist financing, and the facilitation of financial crimes. We are committed to the highest standards of compliance as set forth by the Financial Action Task Force (FATF) and the relevant financial intelligence units in the jurisdictions where we operate (including the SEC and EFCC in Nigeria).

1.2. Scope of Policy: This policy applies to all users, employees, and third-party partners of Zelencio. Our objective is to ensure that the platform is not used to hide the proceeds of crime, facilitate the movement of illegal funds, or support sanctioned entities.

SECTION 2: THE COMPLIANCE FRAMEWORK

2.1. Money Laundering Reporting Officer (MLRO): Zelencio appoints a dedicated Compliance Officer/MLRO responsible for overseeing the AML/CTF framework. The MLRO has the authority to block transactions, freeze accounts, and report activity to government authorities without user consent.

2.2. Risk-Based Approach (RBA): Zelencio utilizes a Risk-Based Approach to monitor users. Each account is assigned a risk profile (Low, Medium, High) based on:

• Geographic location (IP address and residency).

• Transaction frequency and volume.

• The use of "High-Risk" features such as Zelencio Codes or P2P Trading.

SECTION 3: CUSTOMER DUE DILIGENCE (KYC/CDD)

3.1. Verification Requirements: No user is permitted to execute financial transactions on the Zelencio Internal Ledger without completing the mandatory tiered KYC process.

• Identification: Verification of government-issued ID via AI-driven authenticity checks.

• Liveness: Visual biometric verification to prevent the use of static photos or deepfakes.

• Sanctions Screening: Every user is screened against global sanctions lists (e.g., OFAC, UN, EU, and local watchlists).

3.2. Ongoing Due Diligence: Zelencio does not just verify users once. We perform "Ongoing Monitoring" to ensure that user behavior remains consistent with their declared profile. If a "Basic KYC" user suddenly attempts a $50,000 transaction, the account will be flagged for Enhanced Due Diligence (EDD).

SECTION 4: TRANSACTION MONITORING AND DETECTION

4.1. Real-Time Surveillance: Zelencio utilizes proprietary AI monitoring to scan the Internal Ledger 24/7 for "Red Flag" behaviors:

• Structuring (Smurfing): Multiple small transactions designed to avoid hitting a KYC threshold.

• Rapid Movement: Assets deposited and immediately withdrawn to an external address with no trading activity.

• Voucher Abuse: High-frequency generation and redemption of Zelencio Codes between unrelated UIDs.

• P2P Anomalies: Frequent trade cancellations or disputes in the C2C Marketplace.

4.2. Internal Ledger Traceability: Unlike decentralized wallets, Zelencio maintains a centralized record of every movement. Every "Zelencio Code" and "Internal Transfer" is permanently linked to the creator’s and redeemer’s Verified UID.

SECTION 5: SUSPICIOUS ACTIVITY REPORTING (SAR)

5.1. Mandatory Reporting: Where Zelencio has reasonable grounds to suspect that funds are the proceeds of criminal activity, we are legally bound to file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the relevant financial authorities.

5.2. "Tipping Off" Prohibition: In accordance with international law, Zelencio is strictly prohibited from notifying a user that their account is under investigation or that a SAR has been filed.

SECTION 6: SANCTIONS AND PROHIBITED COUNTRIES

6.1. Geofencing: Zelencio employs IP-blocking and KYC-blocking to prevent access from "High-Risk Jurisdictions" as defined by the FATF.
6.2. Asset Freezing: If a user is added to an international sanctions list after they have joined the platform, Zelencio will immediately freeze their assets and notify the relevant regulatory body.

SECTION 7: RECORD KEEPING AND DATA RETENTION

7.1. The 5-Year Mandate: To assist in historical criminal investigations, Zelencio retains the following records for a minimum of five (5) years after the termination of the user relationship:

• Copies of all KYC documents and liveness recordings.

• Full transaction history (including IP addresses and device IDs).

• All communication logs from the P2P Chat and Support Hub.

SECTION 8: TRAINING AND INTERNAL AUDIT

8.1. Staff Training: All Zelencio employees handling financial data undergo annual AML/CTF training to identify modern money laundering techniques, including "Triangular Scams" and "Voucher Layering."
8.2. Independent Audit: Zelencio subjects its internal ledger and compliance protocols to periodic independent audits to ensure the platform meets global CEX (Centralized Exchange) standards.

Effective Date: April 1, 2025

1.1. Introduction

Zelencio (“we,” “us,” or “our”) uses cookies and similar tracking technologies (pixels, beacons, and local storage) to enhance your experience on our website and within the secure WebViews used for financial transactions in our mobile application. This policy explains what these technologies are and your rights to control our use of them.

1.2. What are Cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. They are widely used by website owners to make their websites work more efficiently and to provide reporting information.

1.3. Types of Cookies We Use

• Essential/Strictly Necessary Cookies: These are vital for the operation of Zelencio. They enable you to log into secure areas of our platform, use a shopping cart for "One-Click Buy," and utilize our internal ledger services. Without these, the platform cannot function.

• Performance and Analytics Cookies: These help us understand how users interact with our Help Center and WebViews. We use this data to improve app speed and fix technical glitches. All data is aggregated and anonymized.

• Functionality Cookies: These recognize you when you return to our platform. This allows us to personalize content for you (e.g., your choice of language or currency display).

• Third-Party Cookies (Payment Gateways): When you enter the checkout flow via Paystack, Flutterwave, or Stripe, these licensed providers may set their own cookies to ensure the security of the payment session and to prevent credit card fraud.

1.4. Managing Your Cookie Preferences

Most mobile browsers and apps allow you to control cookies through their settings. however, please note that if you limit the ability of websites to set cookies, you may worsen your overall user experience and, in the case of Zelencio, you may be unable to complete fiat-to-crypto purchases because our payment partners require essential cookies for security.

2. ZELENCIO WEBSITE & CONTENT DISCLAIMER

Effective Date: April 1, 2025

2.1. General Information Only

The information provided on the Zelencio website (zelencio.com), the Help Center, and within the Zelencio mobile application is for general informational purposes only. While we strive to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, or reliability of the market data, charts, or articles provided.

2.2. No Financial Advice (Non-Reliance)

Zelencio is a technology platform and a Virtual Asset Service Provider. We do not provide financial, investment, legal, or tax advice.

• Any data or "Trading Guides" provided are for educational purposes.

• The use of advanced features like SOMD (Auto-Swap) or Smart Limit Orders should be based on your own research.

• You should consult with a qualified financial professional before engaging in cryptocurrency trading.

2.3. External Links and Third-Party Gateways

Zelencio utilizes secure WebViews to connect you with third-party payment processors.

• No Control: We have no control over the nature, content, and availability of those external sites.

• No Endorsement: The inclusion of any links (e.g., to Flutterwave or Stripe) does not necessarily imply a recommendation or endorse the views expressed within them.

• User Risk: Once you leave the Zelencio native interface and enter a third-party WebView, you are subject to the terms and privacy policies of that specific provider.

2.4. Technical Reliability

Every effort is made to keep the website and matching engine up and running smoothly. However, Zelencio takes no responsibility for, and will not be liable for, the platform being temporarily unavailable due to technical issues beyond our control, nor for any trading losses incurred during such downtime.

2.5. Accuracy of Global Market Data

Zelencio aggregates market prices from various global liquidity sources. Due to the decentralized nature of cryptocurrency markets, prices may vary between exchanges. Zelencio does not warrant that the prices shown in our "Market View" will match the prices on other platforms or the "On-Chain" global average at any specific millisecond.

Effective Date: April 1, 2025

Last Updated: March 1, 2026

Section 1: General Provisions

1.1. Purpose and Scope

This Refund and Transaction Finality Policy governs all refund requests, fee disputes, and transaction reversal inquiries submitted by users of the Zelencio platform. This policy applies to all features, services, and transaction types available within the Zelencio ecosystem, including but not limited to on-chain operations, internal transfers, P2P trading, automated tools, and code-based asset distribution.

1.2. User Acknowledgement

By executing any transaction on the Zelencio platform, you confirm that you have read, understood, and irrevocably agreed to the terms of this policy as presented to you at the point of execution. All applicable fees and finality conditions are disclosed on-screen prior to confirmation. Your act of confirming a transaction constitutes full and binding acceptance of all associated fees and finality terms.

1.3. Definition of Service Fees

Zelencio charges a unified Service Fee on applicable transactions. This Service Fee is a consolidated charge that may include:

- Network Fee (Gas Fee): A fee paid to the underlying blockchain network to process and validate on-chain transactions. This fee is determined by network conditions and is not controlled by Zelencio.

- Platform Fee: A fee charged by Zelencio for the provision of its technological infrastructure, execution environment, and associated services.

Where a Service Fee applies, it is displayed to the user before transaction confirmation. The breakdown of Network Fee and Platform Fee components is available within the transaction details screen.

1.4. Classification of Transactions

For the purpose of this policy, all Zelencio transactions are classified into three categories based on their refundability:

- Category A — Fully Refundable: Transactions eligible for a complete reversal under qualifying conditions.

- Category B — Partially Refundable: Transactions where the principal amount may be recoverable, but Service Fees are final and non-refundable.

- Category C — Non-Refundable: Transactions that are final and irreversible upon execution, with no refund applicable under any circumstance.

Section 2: On-Chain Transactions

 2.1. On-Chain Deposits

On-chain deposits are blockchain-initiated transactions executed externally by the sender and received by Zelencio wallet addresses. These transactions are Category C — Non-Refundable and are governed by the following:

- No Service Fee is charged by Zelencio for receiving on-chain deposits.

- Once a transaction is broadcast to the blockchain network, it is final and cannot be reversed, recalled, or modified by Zelencio under any circumstance.

- Zelencio has no authority or technical ability to intercept, reverse, or retrieve funds sent to a blockchain address.

- In the event that a user sends funds to an incorrect wallet address or incompatible network, those funds are permanently lost. Zelencio Support, legal escalation, or court orders cannot compel the recovery of such funds, as they exist entirely outside the platform's control.

2.2. On-Chain Withdrawals

On-chain withdrawals are transactions initiated by the user to send digital assets from their Zelencio wallet to an external blockchain address. These transactions are **Category C — Non-Refundable** and are governed by the following:

- A Service Fee comprising a Network Fee and Platform Fee is charged at the time of withdrawal. This fee is displayed and confirmed by the user prior to execution. Once confirmed, the Service Fee is final and non-refundable under all circumstances.

- Once a withdrawal is broadcast to the blockchain network, it cannot be reversed, recalled, or redirected by Zelencio.

- Users who submit an incorrect destination address or select an incompatible network accept full and sole responsibility for the permanent loss of those funds.

- No legal instrument, including court orders or regulatory demands, can compel Zelencio to recover funds that have been broadcast to a public blockchain network, as such funds are beyond the technical reach of the platform.

---

## Section 3: Internal Transactions

### 3.1. Internal Transfers

Internal transfers are off-chain asset movements conducted between verified Zelencio users within the platform's internal ledger system. These transactions are **Category A — Fully Refundable** under qualifying conditions and are governed by the following:

- No Service Fee is currently charged for internal transfers between verified users.

- All internal transfer records are fully tracked, logged, and auditable within the Zelencio system.

- In the event of a confirmed fraudulent transaction, an unauthorized transfer, or a court-ordered recovery, Zelencio reserves the right to initiate a reversal from the recipient's balance back to the sender, provided that the recipient's balance is sufficient to cover the refund amount at the time of processing.

- Refund requests for internal transfers require a formal investigation. No refund will be processed without sufficient evidence, internal confirmation of the reported irregularity, and where applicable, a valid legal instrument or court order supporting the claim.

- Zelencio does not process refund requests based on user regret, change of mind, or unverified claims.

---

## Section 4: Code-Based and Gift Transactions

### 4.1. Zelencio Codes (Encrypted Vouchers)

Zelencio Codes are encrypted internal vouchers created by users to transfer digital assets via a unique code string. These transactions are **Category B — Partially Refundable** and are governed by the following:

- A Platform Service Fee is charged at the time of code creation. This fee is final and non-refundable upon creation, as it represents a completed service regardless of whether the code is redeemed.

- Users retain the right to cancel or block an unredeemed Zelencio Code at any time prior to redemption. Upon cancellation, the principal asset amount (excluding the Service Fee) will be returned to the creator's wallet.

- Once a Zelencio Code has been redeemed by a recipient, the transaction is considered complete. Post-redemption refund requests will be assessed on a case-by-case basis. Where a verified recipient is identified and their balance is sufficient, Zelencio may process a full or partial refund. Where the recipient's balance is insufficient, a partial refund may be offered, with the user's written agreement that any irrecoverable remainder is permanently forfeited.

### 4.2. Crypto Gifts

Crypto Gifts are platform-facilitated asset distributions sent to other verified Zelencio users. These transactions are **Category B — Partially Refundable** and are subject to the same provisions as Section 4.1, including:

- The Platform Service Fee charged at the time of gift creation is final and non-refundable.

- The principal gift amount may be recalled prior to redemption by the intended recipient.

- Post-redemption recovery is subject to recipient balance sufficiency and user agreement on partial recovery terms where applicable.

---

## Section 5: Buy and Sell Transactions

### 5.1. Express Buy and Sell

Express Buy and Sell transactions are executed via Zelencio's internal engine and may involve third-party liquidity providers or partner services to ensure successful execution. These transactions are **Category B — Partially Refundable** and are governed by the following:

- All Service Fees charged on Express Buy and Sell transactions are final and non-refundable upon execution, as they compensate for services rendered by both Zelencio and any applicable third-party provider.

- In circumstances where a transaction error is attributable to Zelencio's platform and a refund is determined to be appropriate, Zelencio will make reasonable efforts to process a full refund of the principal transaction amount.

- Where a third-party provider is involved, Zelencio's ability to process a refund is contingent on the third party's own refund policies and cooperation. If the third-party provider declines to support the reversal, Zelencio may be unable to process a full refund of the principal amount, and the user will be notified accordingly with a documented explanation.

---

## Section 6: P2P and User-to-User Transactions

### 6.1. U2U / P2P Marketplace Transactions

User-to-User (U2U) and Peer-to-Peer (P2P) transactions are direct trades between verified users on the Zelencio marketplace, monitored and governed by the platform's internal dispute and escrow systems. These transactions are **Category A — Fully Refundable** under qualifying conditions and are governed by the following:

- Zelencio monitors all internal fund movements within U2U/P2P trades. Funds are held in a locked state during the active trade window to protect both parties.

- Zelencio is unable to monitor, verify, or reverse payments made through external channels, including local bank transfers, mobile money, or third-party payment applications. Users who conduct off-platform payments do so at their own risk.

- In the event of a confirmed fraudulent trade or verified scam, the offending account will be permanently banned without the right of appeal. A full refund of the affected principal amount will be processed to the aggrieved party where the locked funds are sufficient to cover the claim.

- All P2P dispute refunds are subject to formal investigation by the Zelencio Trust & Safety team prior to processing.

---

## Section 7: Trading and Automation Transactions

### 7.1. Swap Transactions

Asset swap transactions are executed algorithmically on blockchain networks or through Zelencio's internal matching engine. These transactions are **Category C — Non-Refundable** and are governed by the following:

- All swap transactions, once confirmed and executed, are final and irreversible.

- Zelencio does not control the outcome, timing, or execution price of blockchain-based swap transactions.

- No refund will be issued for swap transactions on grounds of price slippage, market movement, user error, or dissatisfaction with the executed rate.

### 7.2. SOMD (Swap on Market Drop) — Automated Transactions

SOMD is an automated trading feature that executes pre-configured swap instructions on behalf of the user based on real-time market conditions. These transactions are **Category C — Non-Refundable** and are governed by the following:

- By activating SOMD, the user grants Zelencio irrevocable, pre-authorized permission to execute swap transactions on their behalf when configured trigger conditions are met.

- All SOMD-executed transactions are final upon execution and cannot be reversed or refunded.

- Zelencio bears no liability for the financial outcome of SOMD executions, including losses resulting from market volatility, slippage, or unfavorable execution prices.

### 7.3. Trade Transactions

Trade transactions executed through Zelencio's trading interface are broadcast to blockchain networks or settled through the internal matching engine. These transactions are **Category C — Non-Refundable** and carry the same finality provisions as Sections 7.1 and 7.2. No reversal, recall, or refund will be processed once a trade order is executed, regardless of the circumstances.

---

 Section 8: Referral and Reward Transactions

 8.1. Referral Rewards and Bonus Transfers

Referral rewards, bonus credits, and associated fund transfers generated through Zelencio's Referral and Rewards Ecosystem are Category A — Fully Refundable where a fee has been charged, under the following conditions:

- Where any Service Fee is applied to a referral reward disbursement or bonus transfer, and the transaction is subsequently found to be erroneous, fraudulent, or system-generated in error, Zelencio will process a full refund of both the principal amount and any associated fee.

- Referral rewards issued correctly and in accordance with the Referral Program terms are not subject to recall or reversal at the user's request.

Section 9: Refund Request Process

9.1. How to Submit a Refund Request

All refund requests must be submitted through the official Zelencio support channel:

- Support Email: help@zelencio.com

- Help Center: zelencio.com/help

9.2. Required Information

To initiate a refund investigation, users must provide:

- Full name and registered Zelencio Identity Number (ZIN)

- Transaction ID and date of the disputed transaction

- A clear description of the issue and the refund basis being claimed

- Supporting evidence, including screenshots, transaction records, or third-party documentation where applicable

- Where legally required, a valid court order or official legal instrument

 9.3. Investigation Timeline

Zelencio will acknowledge all refund requests within **3 business days** of receipt. A full investigation decision will be communicated to the user within **14 business days**, subject to complexity and the availability of required documentation. Zelencio reserves the right to extend this timeline for cases requiring legal review or third-party involvement.

9.4. Final Decisions

All refund decisions made by Zelencio following a completed investigation are final. Users who disagree with a refund outcome may escalate the matter through the dispute resolution process outlined in Section 10 of the Zelencio Terms of Service and User Agreement.

Section 10: Limitation of Liability

10.1. Blockchain Irreversibility

Zelencio explicitly disclaims all liability for the irreversibility of blockchain transactions. The decentralized and immutable nature of public blockchain networks means that no entity, including Zelencio, its parent company DMG Dynasty, its officers, or its technical team, can reverse a confirmed on-chain transaction under any circumstances, including legal compulsion.

 10.2. User Responsibility

Users bear sole and complete responsibility for verifying all transaction details — including destination addresses, network compatibility, amounts, and fee disclosures — prior to confirming any transaction on the Zelencio platform. Zelencio shall not be held liable for losses arising from user error.

10.3. Third-Party Limitations

Where Zelencio's services rely on third-party providers for execution, Zelencio's refund obligations are limited to what is recoverable within the platform's control. Zelencio will make reasonable efforts to advocate on behalf of the user with third-party providers but cannot guarantee outcomes beyond its operational reach.

Effective Date: April 1, 2025

Last Updated: March 14, 2026

Section 1: Purpose and Overview

1.1. Introduction

This Restricted Jurisdictions and Geo-Restriction Declaration (hereinafter referred to as "this Declaration") is a legally binding document that forms part of the Zelencio Terms of Service and User Agreement, Privacy Policy, and AML/CTF Compliance Policy. This Declaration governs the geographic availability of the Zelencio platform, its mobile application, and all associated digital asset services operated by DMG Dynasty.

The purpose of this Declaration is to clearly communicate to users, app store reviewers, regulatory bodies, and the general public which countries and jurisdictions are restricted from accessing or using the Zelencio platform, the legal basis for each restriction, and the obligations placed on users in connection with jurisdictional compliance.

1.2. Scope of Application

This Declaration applies to all versions of the Zelencio platform, including the Zelencio mobile application distributed through the Google Play Store, any web-based interface accessible via zelencio.com or associated domains, and any future distribution channel through which Zelencio services are made available. It applies to all users, whether registered or unregistered, who attempt to access the platform from any location worldwide.

1.3. User Acknowledgement of Jurisdictional Responsibility

By downloading, installing, accessing, or using the Zelencio platform in any capacity, you represent, warrant, and confirm that you are not located in, a citizen of, a tax resident of, or otherwise subject to the laws of any jurisdiction listed in this Declaration as restricted or prohibited. You further confirm that your use of the Zelencio platform does not violate any applicable law, regulation, or directive in your place of residence or domicile. Zelencio relies on this representation in good faith. Any user who provides false or misleading information regarding their jurisdiction of residence assumes full legal and financial responsibility for any consequences arising from such misrepresentation.

Section 2: Fully Restricted Jurisdictions

2.1. Definition of a Fully Restricted Jurisdiction

A Fully Restricted Jurisdiction is any country or territory in which Zelencio does not currently hold the required financial services license, virtual asset service provider registration, or cryptocurrency exchange authorization mandated by that jurisdiction's applicable laws and regulatory framework. Access to and use of the Zelencio platform, including account registration, asset deposits, trading, withdrawals, and all other features, is entirely prohibited for residents and citizens of Fully Restricted Jurisdictions.

2.2. List of Fully Restricted Jurisdictions

The following countries are designated as Fully Restricted Jurisdictions. Residents and citizens of these countries are prohibited from using the Zelencio platform in any capacity:

United States of America (USA) — Restricted under the requirements of the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Financial Crimes Enforcement Network (FinCEN), and applicable state-level money transmission licensing laws including the New York BitLicense framework.

United Kingdom (UK) — Restricted under the requirements of the Financial Conduct Authority (FCA), which mandates registration and authorization for all firms providing cryptoasset services to UK residents.

Canada — Restricted under the requirements of the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) and provincial securities regulators including the Ontario Securities Commission (OSC), which require registration as a Money Services Business and compliance with securities law for crypto trading platforms.

European Union Member States — Restricted under the requirements of the Markets in Crypto-Assets Regulation (MiCA) framework, Anti-Money Laundering Directives (AMLD), and applicable national financial authority requirements across all EU member states, including but not limited to Germany, France, the Netherlands, Italy, Spain, Sweden, Poland, and others.

United Arab Emirates (UAE) — Restricted under the requirements of the Virtual Assets Regulatory Authority (VARA) in Dubai and the Financial Services Regulatory Authority (FSRA) in the Abu Dhabi Global Market (ADGM), which require a Virtual Asset Service Provider license for operation.

Israel — Restricted under the requirements of the Israel Securities Authority (ISA) and applicable financial regulation governing digital asset platforms and trading services.

India — Restricted under the requirements of the Reserve Bank of India (RBI), the Securities and Exchange Board of India (SEBI), and evolving regulatory guidance governing virtual digital assets and crypto exchange services.

Australia — Restricted under the requirements of the Australian Securities and Investments Commission (ASIC) and the Australian Transaction Reports and Analysis Centre (AUSTRAC), which require an Australian Financial Services License and registration for digital currency exchange providers.

Singapore — Restricted under the requirements of the Monetary Authority of Singapore (MAS) and the Payment Services Act, which require a Digital Payment Token Service license for the provision of cryptocurrency exchange services.

Japan — Restricted under the requirements of the Financial Services Agency (FSA) of Japan, which requires registration as a Crypto Asset Exchange Service Provider.

South Korea — Restricted under the requirements of the Financial Intelligence Unit (FIU) of South Korea and the Act on Reporting and Using Specified Financial Transaction Information, which mandate Virtual Asset Service Provider registration.

Switzerland — Restricted under the requirements of the Swiss Financial Market Supervisory Authority (FINMA), which requires authorization for firms providing digital asset trading and custody services.

Hong Kong — Restricted under the requirements of the Securities and Futures Commission (SFC) of Hong Kong, which mandates licensing for virtual asset trading platforms under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).

New Zealand — Restricted under the requirements of the Financial Markets Authority (FMA) of New Zealand and the Financial Intelligence Unit, which require registration for firms providing digital asset services.

Saudi Arabia — Restricted under the requirements of the Saudi Central Bank (SAMA) and the Capital Market Authority (CMA), which prohibit or impose strict licensing requirements on virtual asset service providers.

Any country or territory designated as a High-Risk Jurisdiction by the Financial Action Task Force (FATF), including countries currently on the FATF Grey List or Black List, is subject to enhanced access restrictions and may be blocked from accessing specific features of the Zelencio platform without prior notice.

2.3. Updates to the Restricted Jurisdictions List

The regulatory landscape governing virtual assets and cryptocurrency exchanges is continuously evolving. Zelencio reserves the right to add, remove, or reclassify jurisdictions on this list at any time, without prior individual notice, in response to changes in applicable laws, regulatory guidance, or licensing requirements in any jurisdiction. The most current version of this Declaration will always be accessible on the Zelencio Policy Center. Users are responsible for reviewing this Declaration periodically for updates.

Section 3: Partially Restricted Jurisdictions

3.1. Definition of a Partially Restricted Jurisdiction

A Partially Restricted Jurisdiction is any country or territory where Zelencio's services are accessible but where specific features of the platform are unavailable, limited, or subject to enhanced compliance requirements due to local regulatory conditions. Users in Partially Restricted Jurisdictions may access the Zelencio platform for permitted activities but must acknowledge that certain features may be disabled or subject to additional verification requirements.

3.2. Current Partially Restricted Jurisdictions and Applicable Limitations

The following jurisdictions are designated as Partially Restricted. Users in these regions may register and access the platform but are subject to the specified feature limitations:

China (People's Republic of China) — Fiat-to-crypto conversion features, P2P trading involving Chinese Yuan (CNY), and marketing activities directed at Chinese residents are restricted. General platform access for non-CNY digital asset management may be available subject to continued monitoring of regulatory developments.

Iran — Access to Zelencio services is permitted subject to strict compliance with applicable international sanctions frameworks. Users in Iran are prohibited from conducting transactions that involve sanctioned entities, sanctioned assets, or that violate United Nations, United States OFAC, European Union, or United Kingdom sanctions programs, regardless of the user's location.

Russia — Access to Zelencio services is subject to ongoing monitoring in connection with international sanctions imposed following geopolitical developments. Transactions involving sanctioned Russian individuals, entities, or assets are strictly prohibited. Zelencio reserves the right to reclassify Russia as a Fully Restricted Jurisdiction at any time.

North Korea (Democratic People's Republic of Korea) — Access to Zelencio is currently fully prohibited due to international sanctions. North Korea is included in this section for reference but is treated in practice as a Fully Restricted Jurisdiction.

Cuba and Syria — Access is subject to OFAC sanctions compliance monitoring. Users must not be affiliated with sanctioned entities or use Zelencio to conduct transactions that would constitute a sanctions violation.

Section 4: Platform Enforcement and Technical Controls

4.1. Geo-Restriction Mechanisms

Zelencio employs a combination of technical and procedural controls to enforce jurisdictional restrictions. These controls include, but are not limited to, Internet Protocol (IP) address detection and geo-filtering at the point of access, device-level and network-level signals assessed during application launch and account registration, mandatory disclosure of jurisdiction of residence during the KYC identity verification process, and ongoing monitoring of user activity patterns for signals of jurisdictional misrepresentation.

4.2. Use of Virtual Private Networks (VPNs) and Circumvention Tools

The use of Virtual Private Networks (VPNs), proxy servers, Tor networks, or any other tool or technology designed to mask, alter, or falsify a user's actual geographic location for the purpose of bypassing Zelencio's jurisdictional restrictions is strictly prohibited. Any user found to have used circumvention tools to access the platform from a Restricted Jurisdiction will be subject to immediate account suspension, permanent termination without appeal, forfeiture of any pending transactions in accordance with applicable law, and reporting to relevant regulatory authorities where legally required.

4.3. Account Registration Declarations

During the account registration process, all users are required to declare their country of residence. This declaration is made under conditions that constitute a legal representation. Providing a false country of residence for the purpose of circumventing jurisdictional restrictions constitutes a material breach of the Zelencio Terms of Service and may constitute a criminal offence under the laws of the user's actual jurisdiction of residence.

Section 5: Regulatory Basis and Compliance Framework

5.1. Zelencio's Regulatory Position

Zelencio is a product of DMG Dynasty, a registered technology company. Zelencio operates as a Virtual Asset Service Provider (VASP) under a technology-first framework, providing software infrastructure for digital asset management. Zelencio does not currently hold financial services licenses in the Fully Restricted Jurisdictions listed in Section 2 of this Declaration. The platform's services are made available exclusively in jurisdictions where such services are either not subject to licensing requirements, are expressly permitted without a license for technology service providers, or where Zelencio has assessed that its services fall within an applicable regulatory exemption.

5.2. Target Markets

Zelencio's primary target markets are jurisdictions in sub-Saharan Africa and other emerging markets where the platform's services are accessible without a specific financial services license requirement for virtual asset service providers at the technology layer. These markets include, but are not limited to, Nigeria, Ghana, Kenya, Tanzania, Uganda, Rwanda, Zambia, Zimbabwe, Cameroon, Senegal, Ivory Coast, Ethiopia, and other jurisdictions across the African continent where digital asset services are accessible at the technology provider level.

Zelencio monitors regulatory developments in all of its target markets on an ongoing basis and will update its compliance posture, feature availability, and this Declaration as the regulatory environment in these markets evolves.

5.3. FATF Compliance Posture

Zelencio's AML and CTF compliance framework is designed in alignment with the Financial Action Task Force (FATF) Recommendations for Virtual Asset Service Providers, as detailed in the Zelencio AML and CTF Compliance Policy. Zelencio applies a risk-based approach to user verification, transaction monitoring, and jurisdictional access controls as part of this framework.

Section 6: Consequences of Unauthorized Access

6.1. Account Action for Restricted Jurisdiction Users

If Zelencio determines, at any time and through any means, that a user is accessing the platform from a Fully Restricted Jurisdiction, the following actions may be taken without prior notice: immediate suspension of the user's account and all associated transactions, initiation of an enhanced due diligence review, request for additional documentation to verify the user's true jurisdiction of residence, permanent termination of the account where the restriction is confirmed, and where legally required, reporting of the account to relevant regulatory authorities.

6.2. Fund Handling Upon Account Termination for Restricted Jurisdiction Violations

In the event that an account is terminated due to confirmed unauthorized access from a Restricted Jurisdiction, any digital assets held within the account will be subject to a mandatory review period. Following the completion of the review and subject to applicable laws, sanctions screening, and the absence of any legal hold or court order, Zelencio will make reasonable efforts to return verifiable assets to the user through a compliant withdrawal channel. Zelencio shall not be liable for any losses, delays, or costs incurred as a result of fund recovery processes arising from unauthorized jurisdictional access.

6.3. Legal Liability of the User

Users who access the Zelencio platform from a Restricted Jurisdiction assume full, sole, and complete legal and financial liability for any consequences arising from such unauthorized access, including but not limited to regulatory penalties, fines, legal proceedings, and asset forfeiture imposed by their local regulatory authorities. Zelencio expressly disclaims all liability in connection with a user's unauthorized access from a Restricted Jurisdiction.

Section 7: Contact and Compliance Inquiries

7.1. Jurisdictional Inquiries

Users or prospective users who have questions regarding the availability of Zelencio services in a specific jurisdiction, or who wish to seek clarification on the application of this Declaration to their circumstances, may direct their inquiry to the following official contact channels:

Support Email: help@zelencio.com

Official Help Center: help.zelencio.com

Legal and Compliance Portal: zelencio.com/help

Zelencio will make reasonable efforts to respond to jurisdictional inquiries within 5 business days. However, Zelencio's response to such an inquiry does not constitute legal advice, and users are strongly encouraged to seek independent legal counsel in their jurisdiction before accessing the platform.

7.2. Reporting of Suspected Violations

If you have reason to believe that another user is accessing the Zelencio platform from a Restricted Jurisdiction or is using circumvention tools to bypass jurisdictional controls, you may report this to Zelencio's compliance team at help@zelencio.com. All reports will be treated with confidentiality and reviewed by the Zelencio Trust and Safety team.

Effective Date: April 1, 2025

Last Updated: March 14, 2026

Section 1: Purpose and Scope 

1.1. Introduction

This Custodial Wallet and Financial Services Disclosure (hereinafter referred to as "this Disclosure") is a legally binding document that forms part of the Zelencio Terms of Service and User Agreement and must be read in conjunction with the Zelencio Privacy Policy, AML and CTF Compliance Policy, Risk Disclosure Statement, and Restricted Jurisdictions Declaration. This Disclosure is published in fulfilment of Zelencio's commitment to full transparency regarding the nature of its custody model, the classification of its services, and the rights and responsibilities of users in connection with digital assets held on the platform.

The purpose of this Disclosure is to ensure that every user of the Zelencio platform fully understands the nature of the custodial relationship between themselves and Zelencio, what it means for their digital assets, what protections exist, and what limitations apply.

1.2. Scope of Application

This Disclosure applies to all users of the Zelencio platform, including all registered account holders across all account tiers and verification levels. It applies to all digital assets deposited into, held within, transferred through, or withdrawn from the Zelencio platform, regardless of the method of deposit or the feature through which the asset is accessed or managed.

Section 2: Nature of Zelencio's Custody Model

2.1. Definition of a Custodial Wallet

A custodial wallet is a digital asset wallet in which the private keys that control access to the on-chain blockchain address are held and managed by the platform operator, not by the individual user. In a custodial model, the platform operator acts as a trusted intermediary responsible for the safekeeping, management, and execution of transactions on behalf of the user.

Zelencio operates a custodial wallet model. This means that when you deposit digital assets into your Zelencio wallet, those assets are held under the custody of Zelencio on your behalf. Zelencio manages the underlying private keys associated with the blockchain addresses assigned to your account. You do not have direct access to the private keys of your Zelencio wallet addresses.

2.2. What Custodial Control Means for Your Assets

Because Zelencio holds the private keys to your wallet addresses, the following conditions apply to your digital assets while they are held on the platform. You access and manage your assets exclusively through the Zelencio platform interface and application. All on-chain transactions, including deposits received and withdrawals executed, are processed by Zelencio's infrastructure on your behalf. Your assets are credited and debited within Zelencio's internal ledger system, which reflects your real-time balance and transaction history. You are not able to independently interact with the blockchain using your Zelencio wallet address outside of the Zelencio platform. Internal transfers, swaps, P2P trades, and code-based transactions are settled within Zelencio's internal ledger and do not necessarily result in an immediate on-chain transaction for every individual movement.

2.3. Distinction Between Custodial and Non-Custodial Wallets

It is important that users understand the distinction between Zelencio's custodial model and a non-custodial wallet, such as MetaMask, Trust Wallet, or a hardware wallet. In a non-custodial wallet, the user holds their own private keys and is solely responsible for the security and management of their assets. In a custodial wallet such as Zelencio, the platform holds the private keys and provides a managed, secured environment for asset storage, trading, and transfer. Custodial wallets offer greater convenience, user experience, and access to integrated platform features such as P2P trading, escrow, automation, and internal transfers. However, they also mean that the user is relying on Zelencio's security infrastructure, operational integrity, and continued availability to access their assets. Users who prefer to maintain sole control over their private keys are advised to use a non-custodial wallet for long-term storage of large asset holdings.

2.4. User's Beneficial Ownership of Assets

Notwithstanding Zelencio's custodial control of the private keys, users retain full beneficial ownership of all digital assets credited to their Zelencio account. Zelencio does not claim ownership of user assets. User assets are not Zelencio's assets, are not available for use by Zelencio for its own operational purposes, and are not subject to claims by Zelencio's creditors in the ordinary course of business, except where a legal hold, court order, regulatory freeze, or confirmed fraudulent transaction investigation requires otherwise. Zelencio maintains detailed internal records of all user asset balances and transaction histories to support the accurate attribution of beneficial ownership at all times.

Section 3: Classification of Zelencio's Services

3.1. Zelencio as a Virtual Asset Service Provider

Zelencio is classified as a Virtual Asset Service Provider (VASP) under the framework established by the Financial Action Task Force (FATF) Recommendations for Virtual Asset Service Providers. As a VASP, Zelencio provides services that include the exchange of virtual assets for fiat currencies or other virtual assets, the transfer of virtual assets on behalf of users, the safekeeping and administration of virtual assets and related instruments, and the participation in and provision of financial services related to an issuer's offer or sale of virtual assets.

3.2. Technology-First Operational Framework

Zelencio operates under a technology-first framework, meaning that the platform's primary function is to provide a secure and efficient technological infrastructure for digital asset management. Zelencio is not a licensed bank, a licensed securities dealer, a licensed investment advisor, or a licensed money services business in any jurisdiction where such a license is required and has not been obtained. Zelencio does not offer fiat banking services, interest-bearing deposit accounts, or investment products. Zelencio does not provide financial advice, investment recommendations, or portfolio management services. Users are responsible for making their own independent financial and investment decisions.

3.3. Services Provided by Zelencio

The following services are provided by Zelencio within its custodial and VASP framework. Custodial digital asset storage, providing users with secured wallet addresses for the receipt and holding of supported cryptocurrencies. On-chain deposit processing, facilitating the receipt of digital assets sent to user wallet addresses from external blockchain sources. On-chain withdrawal execution, processing user-initiated transfers of digital assets from Zelencio wallets to external blockchain addresses. Internal asset transfers, enabling off-chain movements of digital assets between verified Zelencio users via the internal ledger. Asset swap and conversion services, providing algorithmic and market-based exchange of one supported digital asset for another. P2P and U2U marketplace services, operating a monitored peer-to-peer trading environment with integrated fund locking and escrow support. Zelencio Code and Crypto Gift distribution, enabling encrypted internal voucher creation and asset gifting between users. Referral and rewards management, tracking and distributing referral bonuses and platform rewards in accordance with the Referral and Rewards Ecosystem policy. Automated trading tools, including the Swap on Market Drop (SOMD) feature, executing pre-authorized user instructions based on configured market conditions. Escrow Hub services, providing a human-moderated escrow environment for the trade of digital products between users.

3.4. Services Not Provided by Zelencio

Zelencio does not provide the following services, and users should not interpret any platform feature as constituting any of the following. Zelencio does not provide fiat currency deposit accounts or fiat banking services. Zelencio does not provide interest on user balances or yield-bearing products of any kind. Zelencio does not provide investment advice, financial planning, or portfolio management. Zelencio does not provide insurance or deposit protection schemes for user assets. Zelencio does not guarantee profits, returns, or the preservation of asset value. Zelencio does not provide legal, tax, or accounting services or advice.

Section 4: Asset Security and Segregation

4.1. Security Infrastructure

Zelencio employs institutional-grade security infrastructure to protect user assets held under its custody. This infrastructure includes AES-256 military-grade encryption for all sensitive identity and financial data stored within the platform. Multi-factor authentication requirements, including sequential PIN and Google Authenticator two-factor authentication, for all outbound asset movements. AI-driven fraud detection systems that monitor platform activity continuously for suspicious behavior, unauthorized access attempts, and transaction anomalies. Cold and warm wallet architecture for the management of on-chain asset holdings, designed to limit exposure of the majority of user assets to online attack vectors. A tiered KYC and AML verification framework that ensures all users are verified in accordance with FATF standards before accessing higher-value transaction features.

4.2. Asset Segregation

Zelencio maintains a strict operational policy of segregating user assets from the company's own operational funds. User digital assets credited to Zelencio accounts are tracked, recorded, and managed separately from Zelencio's corporate treasury. Zelencio does not commingle user assets with its own operational funds for the purpose of business expenses, corporate investments, or any other internal use. This segregation is maintained at the internal ledger level and is reflected in Zelencio's asset management records.

4.3. Limitations of Security Guarantees

While Zelencio employs industry-leading security practices, users must understand that no digital security system is entirely immune to risk. Zelencio does not guarantee the absolute security of digital assets held on the platform. In the event of an unforeseen security incident, Zelencio will take all reasonably practicable steps to contain the incident, notify affected users, and work to recover or restore affected balances where technically and legally possible. Users are encouraged to review the Zelencio Risk Disclosure Statement for a full account of the risks associated with using a custodial digital asset platform.

Section 5: User Rights in Relation to Custodied Assets

5.1. Right to Withdraw Assets

All verified Zelencio users have the right to withdraw their digital assets from the platform to an external wallet address of their choosing at any time, subject to the completion of applicable identity verification requirements, the absence of any account restriction, suspension, legal hold, or active investigation, the availability of sufficient balance to cover applicable withdrawal Service Fees, and network availability and processing conditions on the relevant blockchain.

5.2. Right to Transaction History and Balance Information

All users have the right to access a complete record of their transaction history and current asset balances within the Zelencio platform at any time through the account dashboard and transaction history interface. Zelencio maintains accurate and up-to-date records of all user account activity and makes these records available to users on demand through the platform interface.

5.3. Right to Account Closure

Users have the right to close their Zelencio account at any time. To close an account, the user must first withdraw all remaining digital asset balances to an external wallet address. Account closure requests must be submitted through official support channels at help@zelencio.com. Accounts with pending transactions, open escrow positions, active P2P trades, or outstanding disputes may not be immediately closeable and will remain active until all pending matters are resolved. Accounts subject to investigation, legal hold, or regulatory freeze may not be closed until the relevant matter is concluded.

5.4. Right to Data Access and Deletion

In connection with Zelencio's custodial operations, users retain the rights to their personal data as described in the Zelencio Privacy Policy, including the right to request access to their personal data, the right to request correction of inaccurate data, and the right to request deletion of their data, subject to applicable legal and regulatory data retention requirements which may require Zelencio to retain certain records for a mandatory period notwithstanding a deletion request.

Section 6: Platform Risk and Operational Continuity

6.1. Counterparty Risk

By using a custodial platform, users are exposed to counterparty risk, meaning the risk that Zelencio as an entity could face operational difficulties, technical failures, or regulatory action that affects the accessibility of user assets. Users should be aware that digital assets held on a custodial platform are subject to the operational health and regulatory standing of the platform operator. Users with significant long-term holdings are encouraged to consider maintaining a portion of their assets in a non-custodial wallet as a risk management measure.

6.2. Platform Availability

Zelencio will make all commercially reasonable efforts to maintain continuous availability of the platform and its services. However, scheduled maintenance, unscheduled technical incidents, network outages, blockchain congestion, and third-party service disruptions may result in temporary unavailability of certain features. Zelencio will communicate planned downtime through the platform and its official communication channels wherever possible. Zelencio shall not be liable for losses arising from temporary platform unavailability except in cases of gross negligence or willful misconduct by Zelencio.

6.3. Regulatory Risk

The regulatory environment governing virtual asset service providers, custodial wallets, and cryptocurrency exchanges is subject to rapid and material change in many jurisdictions. Changes in applicable laws, regulatory guidance, or licensing requirements may require Zelencio to restrict, modify, or discontinue certain services in specific jurisdictions without prior notice. Zelencio will make reasonable efforts to communicate material regulatory-driven changes to affected users in advance wherever legally permissible.

Section 7: Financial Services Declaration for App Distribution

7.1. Statement for App Store and Regulatory Review

This section constitutes Zelencio's formal financial services declaration for the purpose of app store submission, regulatory review, and public transparency. Zelencio is a custodial digital asset management platform and virtual asset service provider developed and operated by DMG Dynasty. The Zelencio platform provides cryptocurrency wallet, exchange, transfer, and related digital asset management services. Zelencio does not hold a banking license, securities dealer license, or regulated financial services license in any jurisdiction. Zelencio's services are made available in jurisdictions where the provision of virtual asset services at the technology layer does not require a specific regulatory license at this stage of the platform's development. Zelencio restricts access to its platform from jurisdictions where a financial services or virtual asset service provider license is required and not currently held, as detailed in the Zelencio Restricted Jurisdictions and Geo-Restriction Declaration. Zelencio's primary target markets are in sub-Saharan Africa and other emerging markets where digital asset services are accessible without a platform-level financial services license requirement. Zelencio complies with applicable AML, CTF, and KYC requirements in its operating markets in accordance with FATF Recommendations for Virtual Asset Service Providers.

7.2. Confirmation of Non-Banking Status

Zelencio is not a bank. Zelencio is not a deposit-taking institution. User balances held on the Zelencio platform are digital asset balances, not fiat currency bank deposits. These balances are not covered by any government-backed deposit insurance scheme, including but not limited to the Nigerian Deposit Insurance Corporation (NDIC), the Federal Deposit Insurance Corporation (FDIC), the Financial Services Compensation Scheme (FSCS), or any equivalent scheme in any other jurisdiction. Users are advised to consider this when determining the amount of digital assets they choose to hold on the platform.

Section 8: Contact and Disclosure Inquiries

8.1. Official Contact for Custodial and Financial Services Inquiries

For all inquiries relating to the nature of Zelencio's custody model, asset security, financial services classification, or the contents of this Disclosure, users may contact Zelencio through the following official channels.

Support Email: help@zelencio.com

Official Help Center: help.zelencio.com

Legal and Compliance Portal: zelencio.com/help

Zelencio will make reasonable efforts to respond to all inquiries relating to this Disclosure within 5 business days. Nothing communicated by Zelencio in response to such inquiries constitutes legal, financial, or investment advice.