ULTRAMINT — MARKET CREATOR POLICY

Market Creator Obligations and Platform Discretionary Authority

Applicable to: All market creators ("Creator," "you") on the ULTRAMINT platform, with specific provisions applicable to creators of Closed Group Markets (the Members only markets of a Town) operating under Mode B (Authoritative / Creator-Resolved) resolution.

Operator: Vivaach SRL, Costa Rica

Capitalized terms used but not defined in this section have the meanings given in the ULTRAMINT Terms of Service.

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1. Creator Duty of Good Faith and Objectivity

1.1 Market Creation Standards

(a) By creating a market on the Platform, you agree and represent that you will draft objective, unambiguous, and verifiable resolution criteria at the time of market creation. The resolution criteria must be stated with sufficient specificity that a reasonable person could determine, on the basis of the stated criteria and the designated source or method of resolution, whether each possible outcome has or has not occurred.

(b) You shall not create a market with resolution criteria that are: (i) inherently subjective to a degree that makes objective resolution impossible; (ii) self-referential or circular, such that the outcome depends on the resolution itself; (iii) impossible to verify against any publicly available information or designated data source; or (iv) designed to guarantee a particular outcome regardless of real-world events.

(c) The Platform applies best-efforts content screening through its creation interface, including to authoritative Members only markets. Screening does not guarantee the clarity, enforceability, or resolvability of your criteria, is not an endorsement, and does not shift your responsibility for their quality or alter sole creator authority over Authoritative resolution (Acceptable Use / Prohibited Markets Policy §1.2).

1.2 Mode B Resolution Obligations

(a) Where you create a Closed Group Market (a Members only market of a Town) under Mode B (Authoritative / Creator-Resolved) and serve as the designated Resolver, you are contractually obligated to resolve the market:

    (i) with integrity — exercising honest, good-faith judgment consistent with the Platform's market-integrity standards and without subordinating the accuracy of the resolution to any personal interest, including any position you hold in the market;

    (ii) accurately — in accordance with the genuine, real-world outcome as it actually occurred, to the best of your knowledge and information;

    (iii) in strict accordance with the market's stated resolution criteria — resolving to the outcome that the criteria, properly applied, indicate; and

    (iv) within seven (7) days after the market's stated end date (the "Resolution Window"), as required by the Terms of Service (§3.4(c)).

(b) You shall not: (i) resolve a market other than in good faith and in accordance with the market's stated resolution criteria and the genuine, real-world outcome; (ii) knowingly resolve a market to a false or fabricated outcome, or otherwise dishonestly, in order to benefit a position held by you or any related person; or (iii) take any action to manipulate, procure, or distort the underlying real-world event or its reporting (Terms of Service §3.4(d)).

(c) Conduct in violation of this subsection is a market-integrity violation subject to investigation and enforcement under the Terms of Service (§3.9) and the sanctions provisions of Section 3 of this Policy.

1.3 Conflict of Interest Disclosure and Acknowledgment

(a) You acknowledge that, under the Terms of Service (§3.4(a)), a market creator who serves as the Resolver of a Mode B market is permitted to hold a position in that market. Holding a position does not, by itself, constitute a violation of this Policy or the Terms of Service.

(b) You acknowledge that every Mode B market must display, and you agree that it will display, the following mandatory disclosure on the market card before any participant takes a position (Terms of Service §3.4(b)):

"This market is resolved by its creator, who may hold a position."

(c) You acknowledge that this disclosure informs participants of the inherent conflict of interest in creator-resolved markets. The existence of this disclosure does not relieve you of your obligation to resolve with integrity, accurately, and in strict accordance with the market's stated resolution criteria. The disclosure addresses participants' informed consent to the conflict; it does not authorize you to resolve dishonestly, inaccurately, or in bad faith.

(d) Obligation owed to the Platform only. The obligations in this subsection are owed solely to Vivaach SRL as contractual obligations for the protection of the Platform's market-integrity standards. They do not create, and shall not be construed to create, any duty, obligation, warranty, or right of action running to any participant, buyer, or third party — whether as a third-party beneficiary, in tort, or on any other basis. The fact that compliance with these obligations may incidentally benefit participants does not convert them into participant-facing obligations or create participant standing to enforce them.

(e) Where you hold a position in a market you resolve, and you resolve in a manner that benefits that position, the Platform may — but is not obligated to — investigate whether your resolution was consistent with your obligations under this Section. The fact that participants were aware of the conflict does not preclude enforcement action under Section 3 of this Policy if the Platform determines, in its sole discretion, that you resolved in violation of Section 1.2.

1.4 Prohibition on Undisclosed Controlled-Wallet Positions

(a) Definition. A "Controlled Wallet" means any wallet, address, or account that you own, control, have signing authority over, or that is owned or controlled by any person acting at your direction, on your behalf, or in coordination with you, including without limitation a family member, household member, business partner, employee, agent, or any entity you control (collectively, "Related Persons").

(b) Prohibition. You shall not, directly or through any Related Person, take any position in a market you create through any Controlled Wallet unless that position, including its direction (outcome) and the wallet address through which it is held, is disclosed to the Platform before the market resolves. Holding undisclosed positions in your own market through Controlled Wallets — whether to amplify your exposure beyond what is visible to participants, to obscure the direction of your true economic interest, or for any other purpose — is a market-integrity violation subject to sanctions under Section 3 of this Policy and the Terms of Service (§3.9).

(c) Representation. By resolving a Mode B market, you represent and warrant that, at the time of resolution, all positions held in that market by you or any Related Person through any Controlled Wallet have been disclosed to the Platform, and that no undisclosed Controlled Wallet holds a position in the market. This representation is a material term of your agreement with the Platform, and a breach of it constitutes grounds for all sanctions described in Section 3, including fee forfeiture and clawback-as-debt.

(d) Presumption. Where on-chain analysis, behavioral patterns, or other evidence available to the Platform indicates that multiple wallets holding positions in a market you created are under common control, and that common control corresponds to you or a Related Person, the Platform may treat those wallets as Controlled Wallets for the purposes of this Section and impose sanctions accordingly. The Platform's determination under this subsection is administrative and contractual, subject to the Terms of Service (§3.9(d)).

(e) This prohibition is in addition to, and does not limit, the general anti-sybil provisions of the Terms of Service (§3.7) and the self-influenced outcomes prohibition in the Terms of Service (§3.8).

1.5 Prohibition on Self-Influenceable Markets

(a) You shall not create a market on any event, outcome, or question that you are able to directly influence, control, or determine through your own conduct, decision, or authority, where the purpose or effect is to profit from bringing about the outcome, unless the market's resolution criteria explicitly disclose and account for that influence.

(b) Without limitation, the following are prohibited:

    (i) creating a market on an action you will personally take (e.g., "Will I launch product X by date Y?") without disclosing your control over the outcome in the resolution criteria;

    (ii) creating a market on a decision within your professional authority (e.g., a hiring decision, a procurement choice, a policy determination) and taking a position whose profitability depends on your exercise of that authority; and

    (iii) creating a market on an event you have the practical ability to cause, prevent, or materially influence, and trading on your private knowledge of whether you will exercise that ability.

(c) Where a market's resolution criteria explicitly disclose and account for the creator's influence — for example, by framing the question as a commitment mechanism ("Will I complete X by Y? Creator has control over the outcome.") — the prohibition in subsection (a) does not apply, provided the disclosure is prominent, specific, and made before any participant takes a position.

(d) This prohibition operates at the level of conduct and is in addition to the Content Policy, under which self-referential and directly manipulable markets are prohibited from listing (Terms of Service §3.8).

1.6 Compliance with the Acceptable Use and Prohibited Markets Policy

(a) All markets you create must comply with the Platform's Acceptable Use and Prohibited Markets Policy (referred to in the Terms of Service as the "Content Policy" — Terms of Service §1(k)), which governs permitted and prohibited market subject matter, is incorporated by reference into this Policy and the Terms of Service, and is available at ultramint.xyz/legal/content-policy.

(b) A market created in violation of that Policy may be voided by the Platform at any time under Section 2.1, and you are subject to all sanctions described in Section 3 of this Policy, including fee forfeiture, account termination, and reporting to relevant authorities under Section 3.5.

(c) Creation-interface content screening applies to both resolution modes and is not warranted to detect every prohibited market. Screening, acceptance, listing, or absence of rejection does not constitute endorsement or relieve you of compliance obligations. It gives the Platform no on-chain override of an Authoritative market. You remain solely responsible for compliance with both policies and applicable law.

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2. Platform Discretionary Override and Intervention

2.1 Reservation of Discretionary Authority

(a) Vivaach SRL reserves the absolute, unreviewable right — but expressly not the obligation — to take any one or more of the following actions in connection with any market you create, at any time and in its sole discretion, without prior notice or liability:

    (i) stop further position-taking in the market, which is a one-way, irreversible on-chain action that prevents any new positions from being acquired but does not affect existing positions or prevent resolution (Terms of Service §2.6(e)(i));

    (ii) void the market with refunds to each participant at par and with no settlement fee deducted, in accordance with the Terms of Service (§2.4), which constitutes a final resolution to the "void" outcome (Terms of Service §2.6(e)(ii));

    (iii) withhold, reduce, or forfeit any unpaid creator fees associated with the market;

    (iv) decline to relay any transaction through the Relay Service in connection with the market;

    (v) suspend, restrict, or terminate your account and access to the Platform; and

    (vi) take any off-chain measure described in the Terms of Service (§2.6(f)), including suspending, restricting, or modifying the Interface in respect of the market.

(b) The actions described in subsection (a)(i) and (a)(ii) are the only on-chain levers available to the Platform. The Protocol Contracts contain no pause function, no upgrade mechanism, and no administrative proxy (Terms of Service §2.6(e)). Where a market has already settled — including through a Creator's resolution — the resulting allocation of funds is permanent and cannot be altered, reversed, voided, or overridden by the Platform or any person (Terms of Service §2.6(d)). The Platform's authority under this Section is exercisable only in respect of markets that have not yet reached a terminal state (settlement or void).

(c) The Platform may exercise the authority described in this Section in any case involving, without limitation:

    (i) evident Creator bad faith — including resolution to a false or fabricated outcome, dishonest resolution to benefit the Creator's own position, or manipulation of the underlying event;

    (ii) collusion between the Creator and one or more participants, or between the Creator and any third party, to manipulate the market's outcome, pricing, or participation;

    (iii) market rules that are materially ambiguous, contradictory, or unresolvable — such that the stated resolution criteria cannot yield a determinate outcome;

    (iv) regulatory command — including any court order, subpoena, injunction, regulatory directive, or law-enforcement request (Terms of Service §6.2);

    (v) platform-integrity risk — including any conduct that threatens the security, stability, reputation, or orderly operation of the Platform, the Protocol Contracts, or the Blockchain; or

    (vi) any other ground that Vivaach SRL, in its sole discretion, determines warrants intervention.

2.2 No Obligation to Monitor, Detect, or Intervene

(a) The authority described in Section 2.1 is a right and not a duty (Terms of Service §2.6(k)). Vivaach SRL:

    (i) has no contractual obligation to monitor your markets, your resolution decisions, your compliance with the resolution criteria, or your conduct generally;

    (ii) does not guarantee that it will detect, prevent, or successfully remediate any violation, bad-faith resolution, collusion, or platform-integrity risk;

    (iii) is not liable for any failure or delay in exercising the authority described in this Section, regardless of the circumstances; and

    (iv) owes no duty of care, fiduciary obligation, or other legal duty to any participant in your markets to exercise, or to refrain from exercising, any power described in this Section.

(b) The exercise or non-exercise of this authority in any instance is at Vivaach SRL's sole and unreviewable discretion, creates no enforceable expectation of future exercise, and does not constitute a general duty to monitor or police Creator conduct.

(c) The Platform's decision not to intervene — including a decision not to void a market, not to investigate a resolution, or not to sanction a Creator — is equally discretionary and creates no rights, obligations, precedent, custom, practice, or course of dealing obligating the Platform to take or refrain from any action in any other market or circumstance.

2.3 Resolution Window and Void upon Creator Failure to Resolve

(a) Where a Creator fails to resolve a Mode B market within the seven (7) day Resolution Window (Terms of Service §3.4(c)), the Platform may, in its sole discretion, stop further position-taking in the market and void the market with refunds to each participant at par and with no settlement fee deducted, in accordance with the Terms of Service (§2.4).

(b) This void power is discretionary, not automatic. You should understand the following:

    (i) The Platform has no contractual duty to monitor whether you have resolved within the Resolution Window, to detect your failure to resolve, or to exercise the void power within any particular timeframe after the window expires.

    (ii) The Platform does not guarantee that it will exercise this power in any particular case, within any particular time, or at all.

    (iii) Voiding is the Platform's only remedy for an absent Creator-Resolver. Because the Resolver is fixed in the market's smart contract at creation, the Platform cannot substitute itself, any other party, or any automated system as Resolver. If you do not resolve, the only on-chain alternative is a void. There is no fallback resolution mechanism.

    (iv) Where a market's collateral has been deployed to a third-party yield venue, the Protocol Contracts require the collateral to be recovered from that venue before the market can be voided. If the yield venue is frozen, illiquid, exploited, or otherwise unable to return the collateral, the void and all refunds are blocked until recovery succeeds, and the Platform has no power to override this (Terms of Service §2.6(g)). Funds may remain committed for an indefinite period.

(c) The exercise of the void power under this subsection is an administrative and platform-integrity measure taken at Vivaach SRL's sole discretion. It does not constitute:

    (i) an act of adjudication, arbitration, or dispute resolution;

    (ii) a determination by the Platform that any participant's claim, grievance, or position is valid;

    (iii) an acknowledgment that you breached your obligations under this Policy; or

    (iv) a waiver of the Platform's right to pursue further sanctions against you under Section 3 of this Policy.

(d) Your failure to resolve within the Resolution Window may independently constitute a market-integrity violation subject to investigation and sanctions under the Terms of Service (§3.9) and Section 3 of this Policy, regardless of whether the Platform exercises or declines to exercise the void power.

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3. Creator Sanctions and Fee Forfeiture

3.1 Sanctions Authority

(a) Vivaach SRL reserves the right, at its sole discretion and without limitation, to impose any one or more of the following sanctions where it determines that Creator misconduct has occurred, including without limitation any violation of Section 1 of this Policy, any violation of the Terms of Service (§3.4 or §3.9), or any conduct that Vivaach SRL determines, in its sole discretion, threatens platform integrity:

    (i) withhold any unpaid creator fees associated with the affected market or any other market you have created;

    (ii) set off against future distributions — apply any amounts owed by you to the Platform against creator fees, balances, distributions, or rewards you hold or may later acquire on the Platform (Terms of Service §3.9(f));

    (iii) suspend or permanently revoke your market creation privileges on the Platform;

    (iv) suspend, restrict, or permanently terminate your account and access to the Platform;

    (v) void the affected market and return stakes to participants at par with no fee deducted, in accordance with the Terms of Service (§2.4), subject to the yield-venue caveat in Section 2.3(b)(iv) of this Policy; and

    (vi) take any other enforcement action described in the Terms of Service (§3.9).

(b) On-chain clawback limitations. You acknowledge that creator fees distributed on-chain to your Wallet are recorded on the public Blockchain and that the Protocol Contracts contain no administrative function by which the Platform can seize, reverse, or redirect funds already distributed to your Wallet. Where the Platform determines that clawback of previously distributed creator fees is warranted, the following applies:

    (i) Any creator fees obtained through, derived from, or attributable to a violation of this Policy or the Terms of Service constitute a debt immediately due and payable by you to the Platform (Terms of Service §3.9(f)).

    (ii) The Platform may recover that debt by set-off against any balance, position, distribution, fee, or reward you now hold or later acquire on the Platform, by withholding future distributions, and by legal or arbitral action, together with interest and the reasonable costs of recovery.

    (iii) This obligation survives termination of your account.

3.2 Procedure and Notice

(a) Fee forfeiture, access revocation, and any other sanction under this Section may be applied independently or in combination, in any order, and may be imposed without prior notice where Vivaach SRL determines that immediate action is necessary to protect platform integrity, participants, or the Platform's legal position.

(b) Where Vivaach SRL determines that immediate action is not required, it may, but is not obligated to, provide you with notice of the conduct under investigation and an opportunity to respond before imposing sanctions. The provision of such notice in any instance does not establish a right to notice in any future instance.

(c) The Platform's determinations under this Section are administrative and contractual. They do not require proof to any criminal or civil evidentiary standard and are final as between you and the Platform, subject to the dispute-resolution provisions of the Terms of Service (§6) (Terms of Service §3.9(d)).

3.3 Acknowledgment of Enforcement Limitations

(a) You acknowledge that no staking collateral or bond mechanism exists on the Platform at this time. Sanctions available to the Platform in connection with Creator misconduct are therefore limited to the fee forfeiture, set-off, clawback-as-debt, account-level, and platform-access measures described in this Section.

(b) This acknowledgment does not limit Vivaach SRL's right to: (i) pursue any additional remedy available under applicable law, including civil action for damages, equitable relief, or recovery of the Platform's costs; (ii) report your conduct to relevant authorities under Section 3.5 of this Policy; or (iii) implement staking, bonding, or on-chain collateral mechanisms in the future, which, if implemented, will apply to markets created after the implementation date and will be described in an amendment to these Terms.

3.4 Non-Waiver and Cumulative Remedies

(a) The Platform's failure or delay in exercising any sanction or enforcement right under this Section is not a waiver of its right to exercise that or any other right later. The rights and remedies in this Section are cumulative and in addition to all other rights and remedies available to the Platform at law, in equity, or under the Terms of Service (Terms of Service §3.11).

(b) The imposition of sanctions under this Section does not affect the finality of any Resolution Outcome or the irreversibility of on-chain settlement (Terms of Service §2.6(d)). Where a market has settled before sanctions are imposed, the settlement stands and cannot be reversed.

3.5 Reporting to Authorities

(a) Vivaach SRL reserves the right to report Creator conduct to relevant regulatory, law-enforcement, and governmental authorities where:

    (i) reporting is required by applicable law or regulation;

    (ii) the Platform has received a lawful request, order, subpoena, or directive from a competent authority; or

    (iii) Vivaach SRL determines, in its sole discretion, that reporting is appropriate in light of the nature and severity of the conduct, the risk to participants or the public, or the Platform's legal or regulatory obligations.

(b) The Platform may make such reports without prior notice to you and without liability to you for doing so (Terms of Service §3.10).

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4. Creator Indemnification of the Platform

4.1 Scope of Indemnification

(a) You agree to fully indemnify, defend, and hold harmless Vivaach SRL, its affiliates, and their respective officers, directors, employees, contractors, agents, successors, and assigns (collectively, the "Indemnified Parties") from and against any and all claims, demands, disputes, losses, liabilities, damages, judgments, settlements, costs, and expenses — including reasonable attorneys' fees, expert fees, and costs of investigation and litigation — arising out of or relating to:

    (i) the market rules, resolution criteria, or structure of any market you create, including any allegation that the criteria are ambiguous, unfair, misleading, deceptive, or unresolvable;

    (ii) your resolution decision in any Mode B market, including any allegation that you resolved erroneously, in bad faith, with bias, dishonestly, or in violation of the stated resolution criteria;

    (iii) your failure to resolve within the Resolution Window, and any consequences arising therefrom, including consequences to participants whose funds remain committed pending resolution or void;

    (iv) any misrepresentation made by you in connection with a market, including misrepresentations regarding the underlying event, the resolution criteria, your qualifications, your relationship to the event, or your interest in the outcome;

    (v) any allegation by a participant that you resolved in bad faith, with bias, in violation of stated criteria, or in a manner that benefited your own position, regardless of whether the allegation is substantiated;

    (vi) any regulatory inquiry, investigation, enforcement action, fine, penalty, or sanction arising from a market you created or resolved, or from conduct by you in connection with any market;

    (vii) your violation of any provision of this Policy, the Terms of Service, or applicable law in connection with your creation or resolution of any market; and

    (viii) any third-party claim arising from the underlying event or outcome of a market you created, including claims by persons or entities who are not participants on the Platform.

4.2 Survival

(a) This indemnification obligation survives the suspension or termination of your account, the closure of your relationship with the Platform, the expiration or termination of the Terms of Service, and the voiding or settlement of any affected market.

(b) This indemnification obligation applies regardless of whether Vivaach SRL exercised or declined to exercise its discretionary intervention rights under Section 2 of this Policy in connection with the relevant market. The Platform's decision not to intervene in a market does not relieve you of your indemnification obligation, does not constitute an approval of your conduct, and does not estop the Indemnified Parties from seeking indemnification.

4.3 Control of Defense

(a) Vivaach SRL reserves the right, at your expense, to assume the exclusive control of the defense and settlement of any matter subject to indemnification under this Section, including selection of counsel, litigation strategy, and all decisions relating to settlement or appeal. You agree to cooperate fully with the Indemnified Parties in the defense of any such matter, including by providing documents, information, and testimony as reasonably requested.

(b) You may not settle any claim that is subject to indemnification under this Section — and in particular may not consent to the entry of any judgment, order, or decree, or agree to any relief — that imposes any obligation, restriction, injunction, or liability on any Indemnified Party, or that contains any admission or finding adverse to any Indemnified Party, without Vivaach SRL's prior written consent.

(c) This Section does not limit Vivaach SRL's right to participate in, or assume control of, the defense of any matter at any time, even if the Creator has previously been conducting the defense.

4.4 Identity Representations and Consent to Jurisdiction

(a) Identity representation. By creating any market on the Platform, you represent and warrant that: (i) all identity information, contact information, and account information you have provided to the Platform — including your email address and any additional information provided during onboarding or in response to a Platform request — is accurate, current, and complete; and (ii) you will promptly update any such information if it becomes inaccurate or incomplete.

(b) Consent to service of process. You irrevocably consent to service of process in connection with any legal or arbitral proceeding arising under this Policy, the Terms of Service, or applicable law, at the email address registered to your Platform account. Service effected by email to that address, with a copy sent by international courier to any physical address you have provided to the Platform, shall constitute valid and effective service for all purposes, including personal jurisdiction.

(c) Consent to jurisdiction. You irrevocably submit to the personal jurisdiction of the arbitral tribunal and courts specified in the Terms of Service (§6) for any proceeding arising under this Policy or the Terms of Service, and you waive any objection to jurisdiction, venue, or forum non conveniens.

(d) Waiver of pseudonymity defense. You acknowledge that your acceptance of these Terms and this Policy constitutes a binding agreement notwithstanding the pseudonymous nature of blockchain transactions. You waive any defense based on the pseudonymity, anonymity, or unverifiability of your on-chain identity, wallet address, or blockchain activity, in any proceeding to enforce these Terms, this Policy, or any obligation arising under them.

(e) Material breach. Any material inaccuracy in the representations under subsection (a) constitutes an independent breach of this Policy, entitling the Platform to all sanctions described in Section 3 and all other remedies available at law or in equity, including the right to void any market you have created and to seek damages arising from the misrepresentation.

4.5 Relationship to Other Obligations

(a) The indemnification obligation in this Section is in addition to, and does not limit or supersede, any other indemnification, contribution, or defense obligation you may owe under the Terms of Service, under applicable law, or under any other agreement between you and Vivaach SRL.

(b) Nothing in this Section limits the Platform's right to seek direct recovery from you under the Terms of Service (§3.9), including recovery of the Platform's costs of investigation, enforcement, and any losses caused to the Platform.

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5. General Provisions

(a) Entire creator obligation. This Section, together with the Terms of Service (§§3.4, 3.8, 3.9, 3.10), constitutes the entire statement of your obligations as a market creator on the Platform. In the event of conflict between this Section and the body of the Terms of Service, the Terms of Service control.

(b) Survival. This Section, including all indemnification, fee-forfeiture, clawback, sanctions, and reporting provisions, survives the suspension or termination of your account and the closure of your relationship with the Platform.

(c) Severability. If any provision of this Section is held unenforceable, it shall be enforced to the maximum extent permissible, and the remaining provisions remain in full force and effect.

(d) Maximum extent of law. All limitations, exclusions, reservations of discretion, and waivers in this Section apply to the maximum extent permitted by applicable law. Nothing in this Section excludes or limits any liability that cannot lawfully be excluded or limited under applicable law.

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Cross-references: Terms of Service §§2.2(d), 2.4, 2.6(d)-(g), 2.6(k), 3.4, 3.7, 3.8, 3.9, 3.10, 3.11, 6.2.