Terms of Service

1.Introduction and scope

These Terms and Conditions (the “Terms”) constitute a legally binding agreement between Elendil Capital sp. z o.o. (“Elendil Capital”, “Offramp”, “Company”, “we”, “us”, or “our”) and any natural or legal person (“User”, “you”, or “your”) who accesses or uses the Offramp platform. The platform includes all associated websites, mobile and web applications, APIs, software, payment interfaces, and related services (collectively, the “Services”).

These Terms govern all access to and use of the Services and apply to all Transactions conducted through the platform. By accessing or using any part of the Services, you confirm that you have read, understood, and agreed to be bound by these Terms in full.

2.Definitions and interpretation

Unless otherwise defined herein, capitalized terms shall have the meanings assigned to them in these Terms. Words importing the singular include the plural and vice versa. References to statutes include all amendments, replacements, and subordinate legislation. Headings are included for convenience only and shall not affect interpretation. In the event of any inconsistency between these Terms and any supplemental terms applicable to specific Services, the supplemental terms shall prevail with respect to those Services.

3.Eligibility and personal use

Access to the Services is subject to eligibility requirements, including an age requirement whereby you confirm that you are at least eighteen (18) years old, as well as service availability based on your location. The Services are currently available only in supported countries, as listed in our Supported Countries for Offramp Services . This list may be updated from time to time at the Company’s sole discretion, without any obligation to provide reasons for restricting or modifying access. We may also refuse, suspend, or limit access to the Services as necessary to comply with applicable legal or regulatory obligations.

4.Account registration and verification

Access to the Services requires the creation of an account. You agree to provide accurate, complete, and up-to-date information at all times and to promptly update such information in the event of any changes. Account registration and continued access are subject to identity verification, due diligence checks, and ongoing monitoring.

Elendil Capital may request additional information or documentation at any time to comply with applicable legal, regulatory, or risk management requirements. You agree that we may, directly or through third parties, conduct any inquiries we deem necessary to verify the information you have provided. You further consent to the disclosure of certain personal information, including your name, residential address, date of birth, and other information as necessary, to such parties solely for the purpose of completing validation and verification processes.

Each user is permitted to maintain only one verified, active account. Any attempt to create or operate multiple accounts is prohibited and may result in review, risk assessment, and the denial, suspension, or termination of access to the Services.

5.Security of account and credentials

You are responsible for maintaining the confidentiality of your login credentials, security details, and authentication mechanisms. You must notify Elendil Capital immediately if you suspect unauthorized access or compromise of your Account. You remain responsible for all activities conducted through your Account unless such activities are directly attributable to a failure of Elendil Capital’s systems or security controls.

6.Prohibited and restricted use

You must not misuse the Services or platform. Prohibited conduct includes, but not limited to: introducing malware or malicious code; interfering with system integrity; bypassing security controls; using anonymization or obfuscation tools to conceal prohibited activity; transacting for or on behalf of any other person or entity; permitting any third party to access or use the Services or your Account on your behalf; providing false or misleading information; engaging in illegal, fraudulent, or unauthorized activity; violating sanctions or regulatory requirements; abusing disputes, chargebacks, promotions, or rewards; harassing or threatening any person; causing reputational or operational harm to the Company; or opening accounts under false or misleading identities.

7.Regulatory status and compliance

Elendil Capital sp. z o.o. is incorporated in the Republic of Poland and registered as a Virtual Asset Service Provider (VASP) under the Act of 1 March 2018 on Anti-Money Laundering and Counter-Terrorist Financing. The Company maintains comprehensive compliance frameworks, including AML and counter-terrorist financing controls, transaction monitoring, and reporting obligations. You agree to cooperate fully with all compliance requests.

7.1 Travel rule compliance

To comply with applicable legal and regulatory requirements, Elendil Capital may collect, verify, retain, and disclose information relating to the parties involved in virtual asset transfers. Certain transactions may be delayed, suspended, declined, or require additional review if the required information is missing, incomplete, inaccurate, or cannot be adequately verified by Elendil Capital or its service providers.

8.Description of services

The Services may include virtual asset exchange services, custody and administration of digital assets, fiat on-ramp and off-ramp services, issuance and management of payment cards, QR-based payments, and related

functionalities. Certain Services are provided through integrated third-party partners. Elendil Capital does not control such partners and is not responsible for their independent acts or omissions.

9.Fees and pricing

You agree to pay all applicable fees associated with your use of the Services. Fees may vary based on the type of Service, payment method, jurisdiction, or partner requirements. Current fees include card foreign exchange and withdrawal fees, bank transfer processing fees, currency conversion fees, and a physical card issuance fee, which is set at USD 100. Fees may be amended from time to time upon notice, where permitted by law.

10.Transaction limits and controls

Transaction limits may apply based on your verification level, jurisdiction, risk profile, or partner requirements. Limits may be increased or reduced at Elendil Capital’s discretion. Requests for higher limits may be considered subject to additional due diligence and documentation. Limits may also be applied or adjusted in real time to manage operational, legal, or financial risk.

11.Suspension, termination, and refusal of service

Elendil Capital may suspend, restrict, or terminate your account or access to the services at any time if required by law, if these terms are violated, if your account poses a security, legal, or compliance risk, or if your use of the services may harm the Company, its employees, or its partners. We may also act in response to legal orders or requests and may refuse to provide Services in the future.

12.Actions and enforcement

Where grounds for enforcement exist, Elendil Capital may take one or more actions, including placing holds on funds, limiting withdrawals, closing accounts without prior notice where lawful, terminating all related agreements, reporting fraudulent or unlawful activity to competent authorities, and pursuing legal remedies to recover losses or damages. You may be notified as soon as reasonably possible, unless doing so would be unlawful, compromise security, cause adverse consequences, or interfere with an ongoing investigation.

13.Transactions, reversals, and finality

Transactions involving digital assets may be irreversible once confirmed on the relevant network. Fiat Transactions are subject to banking partner processing times and controls. Elendil Capital does not guarantee the completion time of any Transaction and shall not be responsible for delays caused by third parties or external systems.

14.Registration and know your business (KYB) — business accounts only

Where the User is a legal person or other business entity (“Business Customer”), the additional requirements in this Section apply together with all other applicable provisions of these Terms. Business Customers must complete a separate business account registration and Know Your Business (“KYB”) process. As part of this process, Elendil Capital may require information and documents including, but not limited to: (a) a valid certificate of incorporation or equivalent constitutional document; (b) the entity’s registered name, registration number, and registered address; (c) documentary evidence of the entity’s principal place of business; (d) a description of the entity’s business activities and the purpose for which the Services are to be used; (e) identification and verification documents for all directors, officers, and persons with significant control; and (f) a complete and accurate register of beneficial owners, identifying all natural persons who ultimately own or control, directly or indirectly, more than twenty-five percent (25%) of the entity’s shares or voting rights, or who otherwise exercise control by other means.

The Business Customer shall promptly notify Elendil Capital, and in any event within five (5) days, of any change to its ownership, control structure, beneficial ownership, management, or authorized representatives.

Elendil Capital reserves the right to conduct enhanced due diligence in relation to any Business Customer, including requesting additional documentation, performing third-party screening, and conducting ongoing periodic reviews. Submission of the foregoing documentation does not guarantee approval of a business account. Elendil Capital may decline, suspend, or terminate any business account at its sole discretion, including for reasons arising from its risk appetite, regulatory obligations, or internal compliance policies, without being required to provide reasons for such decision.

15.Authorized users and user management — business accounts only

The Business Customer may appoint one or more individuals to access and use the business account on its behalf (each, an "Authorized User"), subject to approval by Elendil Capital. At least one Authorized User must be designated as the primary account administrator (the "Account Administrator"), who is responsible for managing user access, keeping Authorized User information up to date, and ensuring compliance with these Terms.

Before access is granted, each Authorized User must complete any applicable identity verification and due diligence requirements. The Business Customer remains fully responsible for all activities conducted through the account by its Authorized Users, including any instructions, transactions, or actions taken using their credentials.

The Business Customer must promptly notify Elendil Capital of any changes affecting an Authorized User's authority or access rights, including where an individual ceases to be employed by, engaged by, or otherwise authorized to act on behalf of the Business Customer. Elendil Capital will not be liable for any loss, liability, or damage resulting from the Business Customer's failure to promptly update or revoke Authorized User access.

16.Business representations and warranties — business accounts only

By applying for, maintaining, or using a business account, the Business Customer confirms on an ongoing basis that: (a) it is duly incorporated, validly existing, and in good standing under the laws of its jurisdiction of incorporation; (b) it has full legal authority to enter into and comply with these Terms; (c) its use of the Services is lawful and consistent with all applicable laws and regulations; (d) neither the Business Customer nor its directors, beneficial owners, Authorized Users, or relevant connected persons are subject to sanctions, asset freezes, or restrictive measures imposed by the EU, UN, OFAC, UK, Poland, or any other applicable authority; (e) none of its directors, beneficial owners, or Authorized Users is a Politically Exposed Person

(PEP) or a family member or close associate of a PEP, unless expressly disclosed to and accepted by Elendil Capital in writing; (f) it maintains appropriate internal controls, including AML, KYC, sanctions, fraud prevention, and data protection measures where relevant to its business; and (g) all information and documents provided are accurate, complete, current, and not misleading.

The Business Customer must notify Elendil Capital without undue delay, and where possible within five (5) business days, of any material change affecting its account, including changes to beneficial ownership, control, directors, authorized representatives, business activity, regulatory status, sanctions exposure, or source of funds.

Failure to provide accurate information or to comply with this Section may result in additional review, account restriction, suspension, termination, reporting to competent authorities, or any other action required by law or internal policy.

17.Business transaction limits, enhanced services, and tax — business accounts only

Business Customers may be eligible for higher transaction limits, increased thresholds, or additional business services, subject to successful completion of KYB, risk assessment, and any additional due diligence required by Elendil Capital or its partners.

Applicable limits may be communicated at or after account approval and may be updated from time to time based on risk profile, transaction activity, regulatory requirements, partner requirements, or internal policy.

Where API access, batch processing, or technical integration features are made available, these may be subject to separate technical, operational, commercial, and security requirements. The Business Customer is responsible for ensuring that any integration is lawful, secure, properly authorized, and used only for legitimate business purposes.

Elendil Capital may restrict, suspend, or revoke access to enhanced services or technical integrations where misuse, security risk, regulatory concern, or non-compliance is suspected.

Business Customers are solely responsible for their own tax reporting, filings, and payments, including VAT, corporate income tax, withholding tax, and any other applicable taxes. Elendil Capital does not provide legal, tax, accounting, or investment advice. Reports or statements made available through the platform are provided for recordkeeping purposes only and do not constitute official tax advice or tax documentation.

18.Data processing and confidentiality — business accounts only

Each party must comply with applicable data protection laws, including Regulation (EU) 2016/679 (“GDPR”), the Polish Data Protection Act, and any other applicable privacy or data protection legislation.

Where Elendil Capital processes personal data on behalf of a Business Customer as a processor within the meaning of Article 28 GDPR, the parties shall enter into a Data Processing Agreement (“DPA”) before such processing begins. The DPA will form part of these Terms.

Where Elendil Capital processes personal data for its own legal, regulatory, AML/CTF, sanctions, fraud prevention, security, or compliance purposes, it may act as an independent controller. Such processing will be carried out in accordance with applicable law, Elendil Capital’s privacy notice, and relevant legal obligations.

The Business Customer must ensure that it has a lawful basis to provide personal data to Elendil Capital, including personal data relating to directors, beneficial owners, Authorized Users, employees, representatives, and other connected persons. The Business Customer is responsible for providing any required privacy notices to those individuals, unless otherwise agreed or required by law.

Personal data must not be submitted to the platform unless it is necessary, accurate, lawful, and relevant to the Services or compliance requirements. Elendil Capital may retain information where required for AML/CTF, sanctions, tax, legal, audit, dispute resolution, or regulatory purposes.

Each party must keep confidential all non-public information received from the other party in connection with these Terms or the Services (“Confidential Information”). Confidential Information may only be disclosed:

• (a)to its employees, officers, advisors, or subcontractors who have a need to know such information for the performance of their duties and are bound by equivalent confidentiality obligations; or (b) as required by applicable law, regulation, or a binding order of a competent court or regulatory authority, provided that, where permitted by law, the receiving party shall notify the disclosing party promptly upon becoming aware of any such requirement and shall cooperate reasonably to limit the scope of any required disclosure.

19.Disclaimers

The Services are provided on an “as is” and “as available” basis. Elendil Capital makes no representations or warranties of any kind, express or implied, including warranties of merchantability, fitness for a particular purpose, or uninterrupted availability.

20.Limitation of liability

To the maximum extent permitted by law, Elendil Capital shall not be liable for indirect, incidental, consequential, special, or punitive damages. Our aggregate liability arising out of or in connection with the Services shall be limited to direct damages only and capped at the total fees paid by you to Elendil Capital during the twelve (12) months preceding the event giving rise to the claim, except where mandatory consumer protection laws apply.

21.Consumer rights

Nothing in these Terms excludes or limits rights that cannot be waived under applicable consumer protection laws of the European Union or the Republic of Poland.

22.Force majeure

Elendil Capital shall not be liable for any failure or delay in performance resulting from events beyond its reasonable control, including natural disasters, governmental actions, network failures, or system outages.

23.Governing law and jurisdiction

These Terms shall be governed by and construed in accordance with the laws of the Republic of Poland. The courts of Poland shall have exclusive jurisdiction over any disputes.

24.Contact information

Elendil Capital sp. z o.o.

Bartycka 22B / 21A

00-716 Warszawa

Republic of Poland

25.Partner terms

Certain Services are subject to separate terms and conditions of third-party partners. Links to partner terms will be made available as applicable:

Dinari: https://dinari.com/terms

Rain: https://www.rain.xyz/legal

Manteca: https://manteca.dev/es/tyc/crypto

Bridge: https://www.bridge.xyz/legal/overview

Due: https://www.opendue.com/legal/t-n-c-due-network-sl

Superbank: https://www.superbank.co/