v1.1 Updated Oct 7, 2026 Part of the Terms by reference

ULTRAMINT — PROHIBITED JURISDICTIONS POLICY

Operator: Vivaach SRL, Costa Rica
Version: v1.1 [DRAFT]
Effective date: [insert on publication]

This Prohibited Jurisdictions Policy (this "Policy") is the "Prohibited Jurisdictions List" referred to in, and incorporated by reference into, the ULTRAMINT Terms of Service (§4.2(b), §7.2). It supplements and does not limit Section 4 of the Terms of Service; where this Policy and the Terms of Service address the same subject, both apply, and the Terms of Service control in the event of conflict. Capitalized terms used but not defined here have the meanings given in the Terms of Service. "Prohibited Jurisdiction" and "Prohibited Person" have the meanings given in Part 1. Vivaach SRL (the "Platform") may amend, expand, or update this Policy at any time, in its sole discretion, and the then-current version governs.

Structure of this Policy:

Part 1 — Scope of Prohibited Users, OFAC Sanctions, and the Global U.S. Person Rule (§§1–3)
Part 2 — Technical Geofencing, VPN & Proxy Circumvention Bans, and User Warranties (§§4–6)
Part 3 — Detection, Enforcement Actions, Market Voiding, and Fund Forfeiture Mechanics (§§7–10)

⚠️ WHO MAY NOT USE THIS PLATFORM

The Platform is offered only to non-U.S., non-sanctioned international users. U.S. Persons are strictly prohibited from trading or creating markets, wherever in the world they are located. Persons in OFAC-embargoed jurisdictions, persons on any sanctions list, and persons in any jurisdiction where use of the Platform is unlawful are also strictly prohibited. Eligibility is your responsibility, at all times.

NOTE ON THE PLATFORM'S ARCHITECTURE (applies throughout, and in particular to the enforcement provisions of Part 3). The Platform is non-custodial, and the Protocol Contracts are autonomous and immutable (no pause, upgrade, or administrative-proxy function). The enforcement rights in this Policy are therefore expressed accurately against that architecture: they operate at the level of the Interface, the Relay Service, accounts, allowlists, and the Platform's pre-settlement on-chain levers, together with the Platform's contractual and legal remedies (including debt, set-off, and legal action). The Platform does not custody user assets and does not represent that it can seize, freeze, reverse, or claw back on-chain assets already distributed to a user's Wallet (Terms of Service §2.6(d), §3.9(b), §4.6(a), §5.2).

PART 1 — SCOPE OF PROHIBITED USERS, OFAC SANCTIONS, AND THE GLOBAL U.S. PERSON RULE

1. Absolute Prohibition on U.S. Persons (Global Rule)

1.1 Definition of "U.S. Person"

1.1.1 For the purposes of this Policy and the Terms of Service, "U.S. Person" is to be construed broadly and inclusively, and incorporates, without limitation, the meanings given to that term (and to equivalent terms such as "United States person") under each of the following United States authorities, as each may be amended:

(a) SEC Regulation S under the U.S. Securities Act of 1933 (17 C.F.R. § 230.902(k));

(b) CFTC Rule 4.7 under the U.S. Commodity Exchange Act (17 C.F.R. § 4.7), and the CFTC's interpretations of "U.S. person"; and

1.1.2 Where these authorities differ in scope, the broadest applicable definition governs for the purpose of determining who is prohibited. A person who is a "U.S. Person" under any of the foregoing authorities is a U.S. Person for the purposes of this Policy.

1.2 Non-Exhaustive Enumeration of Prohibited U.S. Persons

1.2.1 Without limiting Section 1.1, and by way of illustration and not limitation, each of the following is a U.S. Person and is strictly prohibited from trading, taking any position, creating any market, or taking any other authenticated action on the Platform:

(a) any citizen of the United States, including a dual citizen who holds U.S. citizenship together with any other citizenship, regardless of any other nationality held and regardless of where the person resides or is located;

(b) any lawful permanent resident of the United States (a "green card" holder), and any natural person who is a resident of the United States or who otherwise meets the substantial-presence or residency tests of U.S. tax or immigration law;

(c) any corporation, limited liability company, partnership, limited partnership, or other entity created, incorporated, organized, or formed under the laws of the United States or of any State, territory, or possession thereof, or having its principal place of business in the United States;

(d) any estate of which an executor or administrator is a U.S. Person, or the income of which is subject to U.S. federal income taxation regardless of source, and any trust of which any trustee is a U.S. Person, that is subject to the primary supervision of a U.S. court, or over which one or more U.S. Persons have authority to control all substantial decisions;

(e) any account, wallet, or on-chain address held, owned, controlled, or operated by, on behalf of, or for the benefit of any U.S. Person, whether directly or indirectly, and whether or not the person holding legal title is itself a U.S. Person; and

(f) any person acting for the account, benefit, or at the direction of any of the foregoing, including any agent, nominee, custodian, or intermediary.

1.3 The Global Rule — Location Provides No Exemption

1.3.1 The prohibition on U.S. Persons is a global rule that follows the person, not the place. Physical presence, residence, domicile, or connection to a location outside the United States does NOT exempt, cure, or qualify a U.S. Person from this prohibition.

1.3.2 A U.S. Person remains prohibited regardless of: (a) where the person is physically located when accessing the Platform; (b) the person's use of any non-U.S. residence, mailing address, telephone number, or banking or wallet infrastructure; (c) the person's holding of any additional non-U.S. citizenship or residency; or (d) any intention to relinquish U.S. status in the future. U.S. status is determined by the person's status, not by the person's location or stated intentions.

1.4 Nature of the Prohibition; Viewing Is Not Participation

1.4.1 The prohibition in this Section applies to use of and participation in the Platform — including registering or creating an account, signing in or authenticating (which provisions your non-custodial embedded Wallet via Magic.link), taking or exiting any position, creating or resolving any market, claiming any proceeds, and any other authenticated action. Every such action by a U.S. Person is prohibited and will be refused (Terms of Service §4.5(a)).

1.4.2 The Platform makes no offer, solicitation, inducement, or invitation to any U.S. Person in any medium (Terms of Service §4.3). The fact that certain public, unauthenticated informational pages may be viewable from a location does not constitute an offer or solicitation, does not constitute permission to use the Platform, and does not authorize registration, participation, or any authenticated action, all of which are refused (Terms of Service §4.5(b)). Viewing is not participation, and the ability to load a page is not permission to trade.

1.5 Definitions Used for Exclusion Only; No Submission to U.S. Jurisdiction

1.5.1 The United States legal definitions referenced in Section 1.1 are incorporated solely to identify, comprehensively and conservatively, the persons who are EXCLUDED from the Platform. Their use is a protective, over-inclusive eligibility screen adopted for the Platform's own risk management.

1.5.2 The incorporation of those definitions is not, and shall not be construed as: (a) an offer or provision of any service in or into the United States; (b) a submission by the Platform or Vivaach SRL to the jurisdiction of the United States, any U.S. State, or any U.S. regulator; (c) an admission or acknowledgment that the U.S. Securities Act, the U.S. Commodity Exchange Act, the rules of the SEC or the CFTC, the U.S. Internal Revenue Code, or any other U.S. law applies to the Platform, to any market, or to any transaction on the Platform; or (d) a representation that the Platform is registered with, licensed by, exempt under, or otherwise subject to oversight by any U.S. authority. The Platform does not offer its services in the United States and operates on an offshore, geoblocked basis for non-U.S. users only.

2. OFAC-Sanctioned Jurisdictions and List-Based Sanctions Prohibition

2.1 Comprehensively Embargoed Territories

2.1.1 Any person who is a citizen or resident of, incorporated or organized in, ordinarily resident in, or physically located or present in any of the following comprehensively sanctioned countries or regions is strictly prohibited from accessing or using the Platform, regardless of citizenship, residence, or physical location elsewhere:

(a) Cuba;

(b) the Islamic Republic of Iran;

(d) Syria; and

(e) the Crimea, Donetsk (DNR), Luhansk (LNR), Kherson, and Zaporizhzhia regions of Ukraine, and any other region of Ukraine that is the subject of comprehensive sanctions.

2.1.2 This Section automatically extends to any additional country, territory, or region that becomes subject to comprehensive economic or trade sanctions administered by OFAC (or by any other competent authority) after the effective date of this Policy, without the need for further amendment. The list in Section 2.1.1 is illustrative of the category and is not exhaustive.

2.2 Additional Jurisdictions Prohibited by Platform Policy

2.2.1 In addition to the comprehensively embargoed territories in Section 2.1, and as a matter of the Platform's own risk policy — which may be stricter than any applicable sanctions program requires — access to and use of the Platform is strictly prohibited from, and by any citizen or resident of, each of the following jurisdictions. Where a sovereign state is named, the prohibition extends to that state in its entirety and to every province, state, territory, possession, dependency, special administrative region, and overseas or associated territory of it, whether or not separately named:

(a) Europe, the United Kingdom, and associated states: all member states of the European Union; all member states of the European Economic Area; the United Kingdom; the Swiss Confederation; the Principality of Monaco; and Kosovo.

(b) Russia, Belarus, and Ukraine: the Russian Federation; the Republic of Belarus; and Ukraine in its entirety (and, for the avoidance of doubt, the regions identified in Section 2.1.1(e) remain separately and independently prohibited under Section 2.1).

(c) The Americas and the Caribbean: Argentina; Barbados; the Plurinational State of Bolivia; Brazil; Canada in its entirety (and, for the avoidance of doubt, including but not limited to the Province of Ontario); Haiti; Jamaica; Nicaragua; Panama; and the Bolivarian Republic of Venezuela.

(d) United States territories and possessions: American Samoa; and the United States Virgin Islands. The inclusion of any United States territory or possession in this Section is in addition to, and does not limit, narrow, or qualify, the absolute global prohibition on U.S. Persons in Part 1, Section 1.

(e) Asia and the Pacific: Afghanistan; Australia; Bangladesh; the People's Republic of China; India; Japan; the Lao People's Democratic Republic; Macao SAR (China); Malaysia; Mongolia; the Republic of the Union of Myanmar; New Zealand; Pakistan; Singapore; Taiwan; and Thailand.

(f) The Middle East and North Africa: Algeria; Iraq; Lebanon; Libya; Morocco; Palestine; the United Arab Emirates; Western Sahara; and the Republic of Yemen.

(g) Sub-Saharan Africa: Burkina Faso; Cameroon; the Central African Republic; the Republic of the Congo; the Democratic Republic of the Congo; Côte d'Ivoire; Ethiopia; Guinea; Guinea-Bissau; Kenya; Liberia; Madagascar; Mali; Mozambique; Namibia; the Republic of the Niger; Senegal; Somalia; South Sudan; the Republic of the Sudan; Uganda; and Zimbabwe.

2.2.2 For the avoidance of doubt, the Platform prohibits the jurisdictions in Section 2.2.1 whether or not they are subject to comprehensive embargo or to any specific regulatory prohibition, and the Platform may add further jurisdictions to this Section at any time in its sole discretion.

2.2.3 The enumeration in Section 2.2.1 is a floor and not a ceiling. It does not limit, and shall not be read to limit, Sections 2.1, 3.1, or 3.2, each of which may prohibit a jurisdiction that is not named in Section 2.2.1. The absence of a jurisdiction from Section 2.2.1 is not a representation that access from that jurisdiction is permitted (Section 3.3.2).

2.3 Prohibition of Sanctioned and Listed Persons (Regardless of Location)

2.3.1 The following persons are strictly prohibited from accessing or using the Platform, and from holding, controlling, or benefiting from any account or wallet address that interacts with the Platform, regardless of citizenship, residence, or physical location:

(a) any person, entity, vessel, or wallet or on-chain address named on, or included in:

(i) the OFAC Specially Designated Nationals and Blocked Persons (SDN) List;

(ii) the OFAC Sectoral Sanctions Identifications (SSI) List;

(iii) the OFAC Consolidated Sanctions List or any other list maintained or administered by OFAC (including any list of sanctioned digital-currency addresses); or

(iv) any sanctions list or program administered by the United Nations Security Council, the European Union or any EU member state, or the United Kingdom (including HM Treasury's Office of Financial Sanctions Implementation), or any other applicable sanctions authority;

(b) any person that is owned, 50% or more in the aggregate, or otherwise controlled, directly or indirectly, by, or that is acting for or on behalf of, any person described in subsection (a) (consistent with OFAC's "50 Percent Rule"); and

2.3.2 The prohibitions in this Section 2 are absolute and non-waivable. The Platform will not, and cannot, grant any exception, license, or authorization to a prohibited person; any relief from a sanctions prohibition can come only from the competent sanctions authority, not from the Platform.

2.4 Screening of the True Participant

2.4.1 Where the Platform applies any sanctions screening, blocklist, allowlist, or restriction, it applies it to the true participant — the person whose cryptographic signature authorizes a transaction — and not to the Relay Service or any other intermediary that submits a transaction (Terms of Service §4.8(d)). A prohibited person cannot cure their status by transacting through a relay, a nominee, or any other intermediary.

3. Other Restricted and High-Risk Jurisdictions

3.1 Jurisdictions Where the Activity Is Prohibited or Regulated

3.1.1 Access to and use of the Platform is strictly prohibited from, and by any citizen or resident of, any jurisdiction in which the offering, operation, or use of prediction markets, event contracts, online real-money purchases of outcome positions, event-based derivatives, or the trading of crypto-assets or digital-asset positions is prohibited, restricted, or unlawful, or would require a license, registration, authorization, or approval that the Platform does not hold.

3.1.2 Without limiting Section 3.1.1, this Section applies to (by way of example and not limitation):

(a) any jurisdiction already prohibited under Section 2.2, each of which is prohibited both under this catch-all and as a matter of Platform policy; and

(b) any jurisdiction that prohibits, bans, or criminalizes online gambling, real-money purchases of outcome positions, gaming, or prediction-market activity, or that treats such activity as unlawful absent a local license.

3.2 Catch-All Prohibition

3.2.1 In addition to every prohibition set out above, and notwithstanding the absence of any specific jurisdiction from this Policy, access to and use of the Platform is strictly prohibited from, and by any person in, any jurisdiction in which the offering of, access to, or participation in the Platform is unlawful, prohibited, or restricted under any applicable law, or in which such offering, access, or participation would subject the Platform or Vivaach SRL to any licensing, registration, authorization, filing, or other regulatory requirement that the Platform does not then satisfy.

3.2.2 Under no circumstances may any person access or use the Platform in a manner that is unlawful in the jurisdiction from which, or in respect of which, they access it.

3.3 Living List; Non-Exhaustiveness; User Responsibility

3.3.1 This Policy is a living document. The Platform may amend, expand, narrow, or update the jurisdictions and categories in this Policy at any time, in its sole discretion, without prior notice and without amending the Terms of Service, and the then-current version governs each transaction or action as of the time it is taken (Terms of Service §4.2(b), §7.2(d)).

3.3.2 The lists and categories in this Policy are not exhaustive. The absence of a jurisdiction, person, region, or address from this Policy does NOT constitute permission, authorization, or a representation of eligibility, and does not exempt any person who is otherwise prohibited under this Policy, Section 4 of the Terms of Service, or applicable law.

3.3.3 You are solely responsible for determining, and for ensuring on an ongoing basis, that your access to and use of the Platform is lawful for you and that you are not a Prohibited Person under this Policy. Ignorance of your status or of applicable law is not a defense. Any breach of this Policy is a breach of the Terms of Service and entitles the Platform to exercise every remedy in the Terms of Service (§4.4, §4.6, §4.7), including refusal of access, restriction or termination of your account, blocking of associated wallet addresses, voiding or unwinding of positions, forfeiture of tainted funds, and reporting to and cooperation with competent authorities.

PART 2 — TECHNICAL GEOFENCING, VPN & PROXY CIRCUMVENTION BANS, AND USER WARRANTIES

4. Technical Geofencing and Compliance Controls

4.1 Geolocation and Eligibility Enforcement

4.1.1 The Platform deploys automated geolocation and eligibility controls to identify and refuse access originating from, or associated with, a Prohibited Jurisdiction. Specifically, the Platform:

(a) determines the country associated with your network connection at its content-delivery edge, and enforces eligibility on that basis at its backend;

(b) checks every authenticated action — including registration, signing in or authenticating, taking or exiting a position, creating or resolving a market, claiming, and withdrawing — and refuses that action where the determined country is a Prohibited Jurisdiction, or where anonymizing infrastructure is detected; and

(c) applies automated risk and abuse controls, including per-address rate limits and spending limits at the Relay Service (Terms of Service §4.5(a)).

4.1.2 You consent to the collection and processing of your IP address, the country derived from it, and related device, network, and risk signals for the purposes described in this Section, as further described in the Privacy Policy (Terms of Service §4.5(c)).

4.2 No Present Identity or Sanctions Screening; Reserved Right

4.2.1 You should understand, and this Policy does not obscure, that the Platform does not presently conduct identity verification ("Know Your Customer" / KYC), sanctions or watchlist screening, blockchain-analytics or wallet-provenance screening, or source-of-funds checks on users. Present eligibility enforcement consists of the geolocation and anti-circumvention controls described in this Part and your own continuing representations and warranties under Section 6 (Terms of Service §4.8(a)).

4.2.2 The absence of such screening is not a representation by the Platform that any user is eligible, that any wallet is unconnected to illicit activity, or that any user has been screened or cleared. Eligibility and sanctions compliance are enforced primarily through your binding warranties in Section 6, on which the Platform relies.

4.2.3 The Platform reserves the right, at any time and in its sole discretion, to introduce and apply identity verification, sanctions and watchlist screening, blockchain-analytics and wallet-provenance tools, and source-of-funds checks — and to condition, delay, suspend, or refuse access or any transaction pending their completion — as a condition of continued access (Terms of Service §4.8(b), (c)). Where any such control is applied to a transaction, it is applied to the true participant (the person whose cryptographic signature authorizes the transaction), not to the Relay Service or any other intermediary (Terms of Service §4.8(d)).

4.3 No Control Is Perfect; No Waiver

4.3.1 You acknowledge that no geolocation, anonymizer-detection, or risk-screening technology intercepts every impermissible access, and the Platform's controls are not warranted to do so. The controls are provided on a commercially reasonable, best-efforts basis and may produce false positives or false negatives.

4.3.2 Any failure of a control to detect, refuse, or prevent a particular access, transaction, or circumvention does not: (a) constitute permission to use the Platform; (b) constitute a waiver of any provision of this Policy or the Terms of Service; (c) constitute consent by the Platform to your use; or (d) make your access authorized. You remain fully responsible for your own eligibility and compliance at all times, and the Platform's failure to detect a breach does not cure it (Terms of Service §4.5(d)).

5. Strict Ban on VPNs, Proxies, and Circumvention Technologies

5.1 Absolute Prohibition

5.1.1 You shall not, under any circumstances, use, deploy, enable, or rely on any technology, tool, service, technique, or methodology — whether now existing or later developed — that is designed or used to disguise, alter, relocate, mask, obfuscate, reroute, or misrepresent your true IP address, device location, or physical location, for the purpose or with the effect of accessing the Platform from, or concealing that you are accessing it from, a Prohibited Jurisdiction, or of otherwise bypassing, defeating, or interfering with the Platform's geographic, eligibility, or compliance controls (Terms of Service §4.4(a)).

5.1.2 Without limiting Section 5.1.1, the prohibited technologies include, by way of example and not limitation:

(a) Virtual Private Networks (VPNs) of any kind;

(b) the Tor browser or any other onion-routing or anonymizing network;

(d) Apple Private Relay and any comparable private-relay, oblivious-routing, or IP-masking service offered by any operating system, browser, or device;

(e) Smart DNS services and DNS-based location-masking tools;

(f) GPS-, geolocation-, or device-location-spoofing software or hardware;

(g) virtual machines, remote desktops, or remote or cloud-hosted browsers used to originate a connection from a non-Prohibited Jurisdiction; and

(h) any other IP-spoofing, IP-masking, or location-spoofing tool, or any combination of the foregoing.

5.1.3 There is no permitted use of the technologies described in this Section to access the Platform. This prohibition applies regardless of your actual citizenship, residence, eligibility, or stated reason, including where you use such a tool for general privacy or security and are not in fact located in a Prohibited Jurisdiction (Terms of Service §4.4(b)).

5.2 Circumvention Is a Material Breach and an Act of Fraud

5.2.1 Any use or attempted use of any technology described in Section 5.1, and any other attempt to conceal, alter, spoof, or misrepresent your IP address or physical location, or to bypass, disable, or evade the Platform's geographic or eligibility controls, constitutes:

(a) a material breach of this Policy and of the Terms of Service; and

(b) fraudulent and unauthorized access to the Platform — a standalone violation, independent of whether you would otherwise have been eligible, and independent of any actual loss to the Platform (Terms of Service §4.4(c)).

5.2.2 Any person who accesses the Platform by such means is deemed to have knowingly made false representations under Part 1 of this Policy and Section 4.1 of the Terms of Service, and to have obtained access and any resulting positions, balances, winnings, or rewards through fraud (Terms of Service §4.4(d)).

5.2.3 Upon detecting or reasonably suspecting any breach of this Section, the Platform may exercise any and all remedies in the Terms of Service (§4.6), including, without limitation: blocking or banning the IP address, device, network, or wallet address; suspending, restricting, freezing, or permanently terminating your account and access; canceling, rejecting, voiding, or unwinding pending or open orders and positions; withholding, reversing, or forfeiting funds, balances, winnings, proceeds, and rewards to the extent attributable to or tainted by the breach; and reporting the conduct to, and cooperating with, competent authorities. These remedies are cumulative, and amounts forfeited are not recoverable by you. You further agree to the circumvention indemnity in the Terms of Service (§4.7).

6. Continuous Representations and Warranties

6.1 Warranties Repeated at Every Interaction

6.1.1 Each and every time you sign in, authenticate, interact with the Interface, sign an instruction, or take any action on the Platform, you are deemed to automatically make, and to repeat and reaffirm, each of the representations and warranties in this Section, as of the moment of that action. Each such action is a fresh, independent representation, and the Platform relies on each of them in permitting your access and processing your instruction.

6.1.2 You represent, warrant, and covenant that, at the time of and immediately following each such action:

(a) you are NOT a U.S. Person (as defined in Part 1, §1), and you are not a person named on, owned or controlled by, or acting on behalf of any person named on, the OFAC SDN List, the OFAC SSI List, or any other OFAC, United Nations, European Union, or United Kingdom (HM Treasury / OFSI) sanctions list, and you are not otherwise the target of any applicable sanctions (Part 1, §§1-2);

(b) you are NOT physically located, resident, or present in any Prohibited Jurisdiction, and you are not accessing the Platform from, or on behalf of any person in, any Prohibited Jurisdiction (Part 1, §§1-3);

(c) you are NOT using, and are not accessing the Platform through, any VPN, Tor, proxy, residential proxy, private relay, Smart DNS, virtual or remote machine, or any IP-masking, IP-spoofing, or location-spoofing tool described in Section 5, and you are not otherwise disguising or misrepresenting your location or identity; and

(d) the wallet address and any funds you use are not derived from, connected to, or associated with any sanctioned person, sanctioned property, or unlawful activity, and have not been transacted through or commingled with any sanctioned or illicit mixer, tumbler, or obfuscation service (including, by way of example and not limitation, Tornado Cash or any comparable service), any stolen-funds, ransomware, fraud, or darknet address, or any wallet or address associated with a sanctioned person or with a person otherwise prohibited under this Policy.

6.2 Reliance, Ongoing Duty, and Consequences of Breach

6.2.1 You acknowledge that, because the Platform does not presently perform KYC or sanctions screening (Section 4.2), the Platform relies entirely on the truth and accuracy of the warranties in this Section in permitting your access and each of your transactions. Each warranty is a material term of your agreement with the Platform.

6.2.2 These representations and warranties are continuing in nature. If any of them becomes untrue or inaccurate at any time, you must immediately cease all use of the Platform, must not take any further action, and must notify the Platform, and you remain responsible for any action taken while any warranty was untrue (Terms of Service §4.1, §4.5(d)).

6.2.3 Any breach or inaccuracy of any warranty in this Section is a material breach of this Policy and the Terms of Service and, where it concerns your location, identity, or use of circumvention technology, is deemed fraudulent access under Section 5.2. Such a breach entitles the Platform to exercise every remedy described in Section 5.2.3 and the Terms of Service (§§4.4, 4.6, 4.7), including forfeiture of tainted funds and reporting to competent authorities.

6.3 Sole Responsibility

6.3.1 You are solely responsible for determining, and for ensuring on an ongoing basis, that each warranty in this Section is true as to you. Ignorance of your status, of your wallet's transaction history, or of applicable law is not a defense. The Platform's controls, and the absence of a particular check, do not shift this responsibility to the Platform (Part 1, §3.3; Terms of Service §4.5(d)).

PART 3 — DETECTION, ENFORCEMENT ACTIONS, MARKET VOIDING, AND FUND FORFEITURE MECHANICS

7. Detection and Investigative Rights

7.1 Right to Monitor, Review, and Investigate

7.1.1 The Platform reserves the absolute right, in its sole discretion and at any time, to monitor, review, analyze, and investigate any account, wallet address, transaction, connection, or pattern of activity that it suspects may involve a breach of this Policy — including breaches concerning U.S.-Person status, presence in a Prohibited Jurisdiction, use of circumvention technology, or a match to a sanctions list (Terms of Service §3.9(a)).

7.1.2 For that purpose, the Platform may review the information available to it, including without limitation:

(a) public on-chain data associated with a wallet address, including its transaction history, counterparties, and connections to sanctioned, mixer/tumbler (e.g., Tornado Cash), stolen-funds, or other illicit addresses;

(b) IP addresses, the country derived from them at the content-delivery edge, and connection metadata, including indicators of VPN, proxy, Tor, private-relay, or other anonymizing infrastructure; and

(c) device, network, and connection metadata and risk signals available to the Platform, and the results of any rate-limiting or abuse controls at the Relay Service.

7.1.3 You consent to the collection and processing of this data for the purposes described in this Section and Part 2 (§4.1.2), as further described in the Privacy Policy.

7.2 Right to Require Verification

7.2.1 Where the Platform identifies suspicious geographic, identity, or wallet-provenance activity, or otherwise in its sole discretion, the Platform reserves the right to require you, as a condition of continued access or of any particular transaction, to provide satisfactory:

(a) proof of your physical location (for example, verified geolocation or other location evidence);

(b) proof of your identity, citizenship, and residence; and/or

7.2.2 The Platform may decline, delay, suspend, or condition access or any transaction pending satisfactory completion of any verification it requires. If you fail or refuse to provide requested information, or if verification indicates that you are or have become a Prohibited Person, the Platform may exercise any enforcement action in Section 8 and any remedy in Section 9.

7.3 No Present Screening; No Duty to Monitor; Reliance on Your Warranties

7.3.1 The rights in this Section are rights, not duties. Consistent with Part 2 (§4.2) and the Terms of Service (§4.8(a)), the Platform does not presently conduct identity verification, sanctions or watchlist screening, or blockchain-analytics/wallet-provenance screening, and is under no obligation to monitor, investigate, detect, or prevent any breach. The Platform relies on your continuing representations and warranties (Part 2, §6), and the absence of any check does not shift responsibility to the Platform or make prohibited access authorized (Terms of Service §4.5(d)).

7.4 Cooperation

7.4.1 You agree to cooperate promptly and in good faith with any investigation under this Section and to provide any information, documentation, or explanation the Platform reasonably requests. Failure to cooperate is itself grounds for enforcement action under Section 8.

8. Immediate Enforcement Actions and Wallet Blacklisting

8.1 Immediate Action Without Notice

8.1.1 Upon detecting, or upon reasonably suspecting, that any person is a Prohibited Person or has breached any provision of this Policy, the Platform may, immediately, in its sole discretion, and without prior notice or liability, take any one or more of the following actions.

8.2 Interface and Account Measures

8.2.1 The Platform may:

(a) blacklist and block the violating wallet address from accessing and interacting with the Platform's Interface / dApp;

(b) terminate all active sessions and revoke wallet-connection and dApp authorizations at the Platform and Interface level, and require re-authentication that will itself be refused. For the avoidance of doubt, this operates at the level of the Platform's own sessions and Interface connection; it does not, and in a non-custodial architecture cannot, revoke or alter any on-chain token approval or allowance you have granted, which remains within your sole control through your Wallet; and

(c) suspend, restrict, freeze, or permanently terminate the user's account, access, and any balances or entitlements that are administered by or claimable through the Platform and within the Platform's control (Terms of Service §3.9(b), §4.6(a)).

8.3 Relay and Allowlist Measures

8.3.1 The Platform may decline to relay any transaction from the violating wallet through the Relay Service, and may exclude the violating wallet address from any allowlist, thereby preventing participation in any allowlisted market. Any allowlist or restriction is enforced against the true signing address, not against the Relay Service or any intermediary (Terms of Service §4.8(d)).

8.3.2 Architecture caveat. You acknowledge that the Protocol Contracts are autonomous and permissionless. Accordingly, the measures in this Section prevent access through the Platform's Interface and Relay Service and to allowlisted markets, but the Platform cannot guarantee that it can prevent a determined person from interacting directly, by other means, with an autonomous, immutable smart contract that does not enforce a per-market allowlist. Any such direct interaction remains a breach of this Policy and is undertaken entirely at the user's own risk and liability (Terms of Service §5.3(c)).

8.4 Pre-Settlement On-Chain Levers

8.4.1 With respect to any market in which a Prohibited Person holds a position that has not yet settled, the Platform may exercise its two on-chain levers: stop further position-taking (a one-way action) and/or void the market with refunds under Section 9.3 (Terms of Service §2.6(e)). The Platform cannot alter, reverse, or re-settle a market that has already settled (Terms of Service §2.6(d)); its remedies as to a settled market are the contractual and legal remedies in Section 9.

8.5 Cumulative; No Notice Required

8.5.1 The actions in this Section may be taken independently or in combination, in any order, without prior notice, and are cumulative with, and in addition to, all other rights and remedies available to the Platform under this Policy, the Terms of Service, at law, or in equity (Terms of Service §4.6(b)).

9. Void Ab Initio, Forfeiture, and Clawback of Funds

9.1 Prohibited Access Is Void Ab Initio (Contractual)

9.1.1 Any access, position, trade, entitlement, or purported right obtained by a Prohibited Person — including any U.S. Person, any OFAC- or other-sanctioned person, and any person who accessed the Platform through a VPN, proxy, or other circumvention technology in breach of Part 2 — is, as between that person and the Platform, VOID AB INITIO (void from the beginning) and confers no right, title, interest, or entitlement of any kind, including no right to any winnings, payout, distribution, creator fee, reward, or profit.

9.1.2 You acknowledge and agree that the technical irreversibility of on-chain settlement (Terms of Service §2.6(d)) is a property of the Protocol Contracts and does NOT validate, ratify, or confer legitimacy on any entitlement that is void ab initio under this Section. The fact that a settlement has executed on-chain, or that funds have been distributed on-chain, does not make a Prohibited Person's gain lawful or non-recoverable; it merely changes the mechanism by which the Platform pursues its remedy (Section 9.2), from an on-chain reversal (which does not exist) to the contractual and legal remedies described below.

9.1.3 No valid trade ever came into existence; no right to any "winning" payout. Because a Prohibited Person — including, in particular, any U.S. Person — was never eligible to access the Platform or to take any position, any position or trade such a person purported to take never validly came into existence as between that person and the Platform. Being void ab initio, it is treated as if it had never been entered. Such a person therefore has zero legal right, claim, or entitlement to any winning payout, profit, proceeds, or return of any kind, and any amount that would otherwise have been payable on a "winning" position is forfeited in full under Section 9.2. This is so regardless of how the underlying market resolved and regardless of whether the position would, but for the prohibition, have been a winning one.

9.2 Forfeiture and Clawback of Winnings, Payouts, and Creator Fees

9.2.1 All winnings, payouts, proceeds, protocol rewards, and creator-fee entitlements obtained through, derived from, or attributable to prohibited access are forfeited and are not recoverable by the Prohibited Person (Terms of Service §4.6(b)). To the extent any such amount is within the Platform's control (for example, an account-level balance or an entitlement not yet distributed on-chain), the Platform may withhold, cancel, or forfeit it directly.

9.2.2 To the extent any such amount has already been distributed on-chain to the Prohibited Person's Wallet, the Platform does not represent that it can seize or reverse it (Terms of Service §3.9(b), §4.6(a)). Instead, any such amount constitutes a debt immediately due and payable by the Prohibited Person to the Platform, which the Platform may recover by:

(a) set-off against any balance, position, distribution, fee, or reward the person holds or later acquires on the Platform;

(b) withholding future distributions; and

(c) legal or arbitral action, together with interest and the reasonable costs of recovery (Terms of Service §3.9(f)).

9.2.3 Forfeiture and clawback of creator-fee entitlements are additionally governed by, and consistent with, the Market Creator Agreement (§6) and the Market Creator Policy (§3).

9.3 Handling of Deposited Funds and Collateral

You acknowledge that the handling of an unsettled position held by a Prohibited Person depends on why the person is prohibited, and that the two paths below are fundamentally different.

9.3.1 Standard path — geoblock and eligibility violations (return of principal). Where a Prohibited Person is subject to an eligibility, geoblock, U.S.-Person, or circumvention violation but is not a sanctioned person and is not subject to a sanctions-based prohibition or blocking order, the standard handling of an unsettled position is a pre-settlement void with return of principal. Where the Platform voids the market under Section 8.4, the void is effected through the Protocol Contracts' standard refund mechanism, and each participant's staked collateral is returned at par, with no Platform fee deducted, plus any pro-rata net yield (Terms of Service §2.4(b)). Return of a non-sanctioned person's lawfully-held principal on a void is the standard practice: the Platform's remedy for an eligibility breach is to unwind the prohibited participation, not to expropriate principal.

(a) The Platform does not deduct any "processing fee" from a void refund. The refund returns the staked amount at par and does not include, and the Platform does not reimburse, your own gas or network fees, interest, opportunity cost, or any consequential loss (Terms of Service §2.4(b)(iii)).

(b) Where a market's collateral was deployed to a third-party yield venue, refunds are subject to the yield-venue caveat: return may be delayed, or reduced pro rata, until recovery from that venue succeeds, and the Platform has no power to override this (Terms of Service §2.4(b)(ii), §2.6(g)).

(c) For the avoidance of doubt, the return of principal under this standard path does not entitle the Prohibited Person to any winnings, profit, or "winning" payout, all of which remain void ab initio and forfeited under Sections 9.1 and 9.2.

9.3.2 Sanctions override — NO return of funds to sanctioned persons; right to withhold, block, and freeze. The return-of-principal handling in Section 9.3.1 does NOT apply, and is expressly overridden, where the Prohibited Person is a person named on or subject to any OFAC, United Nations, European Union, or United Kingdom (HM Treasury / OFSI) sanctions list or program, is owned or controlled by or acting on behalf of any such person, or is otherwise subject to a sanctions-based prohibition or a binding legal order requiring that funds be blocked or withheld.

(a) Return is prohibited by law. You acknowledge that applicable sanctions law prohibits the Platform from returning, refunding, releasing, transferring, or otherwise making funds available to such a person or to a blocked address. In this circumstance, returning the person's principal is not permitted and the standard path in Section 9.3.1 does not apply.

(b) Platform's right to withhold, block, and freeze. In such a circumstance the Platform has the right, and where required by applicable law the obligation, to: (i) withhold and not return or refund any principal, collateral, winnings, or other funds to the sanctioned person; (ii) retain, block, or freeze such funds to the fullest extent within its control; (iii) decline to trigger or effect a void-refund that would result in value being sent to the sanctioned person or a blocked address; and (iv) block the sanctioned address from claiming, withdrawing, or otherwise receiving funds through the Interface, the Relay Service, and any allowlist — in each case pending and in accordance with direction from the competent sanctions authority, and without prior notice to or liability toward the person.

(c) Non-custody caveat (consistent with §9.4.2). The Platform does not custody user assets and cannot itself freeze or seize on-chain assets already held in a user's Wallet. Where funds are within the Platform's control, it will block, retain, or freeze them as sanctions law requires; where they are not, its compliance is effected by refusing to return or facilitate, blocking access, retaining any controllable funds, and reporting to and cooperating with the competent authority, which is responsible for any actual on-chain blocking or seizure. The Platform will not take any step to release blocked funds except as authorized or directed by the competent authority (for example, pursuant to an OFAC licence or comparable authorization).

9.4 Legally Mandated Handling; OFAC and Law-Enforcement Orders

9.4.1 Where the Platform is subject to a binding legal or regulatory obligation or order (including under applicable sanctions law) concerning a Prohibited Person or a wallet address, the Platform will comply to the extent compliance is technically within its control, which may include: ceasing to deal with and refusing to facilitate the person or address; blocking the address from the Interface, the Relay Service, and all allowlists; voiding any pre-settlement market where technically possible; retaining, segregating, or handling any funds that are actually within the Platform's control as the applicable law or order requires; and reporting to, and cooperating with, the relevant authorities, without prior notice to the person and without liability to that person (Terms of Service §3.9, §3.10, §4.6). You acknowledge that, because the Platform is non-custodial, the set of funds "within the Platform's control" may be limited or nil, and nothing in this Section confers on the Platform any custody, retention, or segregation capability over on-chain assets that it does not otherwise possess.

9.4.2 No representation of seizure or freezing capability. Because the Platform is non-custodial and the Protocol Contracts are immutable and contain no seizure, freeze, sweep, or reversal function, the Platform does not custody user assets and does not represent that it is able to freeze, seize, block, or reverse on-chain assets held in, or already distributed to, a user's Wallet (Terms of Service §2.6(d), §5.2). The Platform's sanctions and legal compliance in respect of such assets is effected through refusal to deal, access denial, voiding where technically possible, the clawback-as-debt and set-off remedies in Section 9.2, and reporting to authorities — not through custody-based seizure. Any actual blocking or seizure of on-chain assets is a matter for the competent authority, which the Platform will not obstruct.

9.5 Clawback as Debt; Survival

9.5.1 Every clawback, forfeiture, set-off, and recovery right in this Section is a reserved contractual and legal right of the Platform, exercisable at its discretion, and survives the termination of the person's account and access and the closure of the relationship (Terms of Service §3.9(f)). Amounts forfeited are not recoverable by the Prohibited Person, and the exercise of one remedy does not waive any other.

10. Immunity of the Platform; No Liability for Enforcement

10.1 Waiver and Release

10.1.1 To the maximum extent permitted by applicable law, you irrevocably and unconditionally waive, release, and agree not to assert any claim, demand, cause of action, proceeding, or right to damages or other relief against Vivaach SRL, its affiliates, and their respective officers, directors, employees, contractors, and agents, and the Platform's service providers (including any Relay Service, RPC or node provider, wallet provider, hosting or content-delivery provider) (collectively, the "Released Parties") arising out of or relating to any exercise, attempted exercise, non-exercise, or timing of any right or action under this Policy, including without limitation:

(a) any detection, monitoring, investigation, or verification measure under Section 7;

(b) any blacklisting or blocking of a wallet address, termination of sessions, revocation of dApp authorizations, or suspension, restriction, freezing, or termination of an account under Section 8;

(c) any refusal to relay, exclusion from an allowlist, or exercise of a pre-settlement on-chain lever (stop position-taking or void) under Section 8;

(d) any void ab initio determination, forfeiture, clawback, set-off, or debt recovery under Section 9; and

(e) any retention, non-return, or reporting of funds or information under a legal, regulatory, or sanctions obligation under Section 9.4.

10.2 Scope of the Waiver

10.2.1 This waiver applies whether or not the Platform provided prior notice, whether or not the relevant person was in fact a Prohibited Person, and whether or not any control succeeded or failed (a failure to detect or prevent a breach is not a waiver of any provision of this Policy and confers no right on any person). It extends to any claim for lost winnings, lost payouts, lost or forfeited creator fees, lost revenue, lost profit or "expected" value, reputational harm, and any indirect, incidental, special, consequential, exemplary, or punitive damages, on any theory whether in contract, tort, strict liability, or otherwise.

10.3 Relationship to Other Protections

10.3.1 This waiver is in addition to, and does not limit, the limitation of liability and damages cap (Terms of Service §6.8), the release of claims (§6.11), the assumption of risk (§2.7), and the user indemnities (§4.7) in the Terms of Service, each of which applies in full to the matters addressed in this Policy.

10.3.2 Nothing in this Section excludes or limits any liability that cannot lawfully be excluded or limited under applicable law; where any waiver or limitation is held unenforceable, it applies to the maximum extent permitted, and the remainder of this Section remains in full force.

Cross-references: Terms of Service §§2.4(b), 2.6(d)-(g), 3.9, 3.10, 4.1, 4.2, 4.3, 4.4, 4.5, 4.6, 4.7, 4.8, 5.2, 5.3, 6.8, 6.11, 7.2, 7.3. Market Creator Agreement §6; Market Creator Policy §3. External authorities referenced for exclusion only: 17 C.F.R. § 230.902(k) (SEC Reg S); 17 C.F.R. § 4.7 (CFTC); 26 U.S.C. § 7701(a)(30) (IRC); OFAC SDN / SSI / Consolidated lists and the OFAC 50 Percent Rule; UN, EU, and UK (HM Treasury / OFSI) sanctions programs. Privacy Policy (IP/geolocation processing). Enforcement rights are expressed against a non-custodial, immutable architecture; the Platform does not represent that it can seize, freeze, or reverse on-chain assets already distributed to a user's Wallet (§2.6(d), §3.9(b), §4.6(a), §5.2).

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