UffPay Terms and Conditions for the App, the Digital Wallet and the Visa Prepaid Card

IMPORTANT NOTICE TO THE USER. These Terms and Conditions (the “Terms and Conditions”) are the contract for UffPay's digital financial services and form a legally binding adhesion contract between you and UFFPAY, SOCIEDAD ANÓNIMA. They govern customer registration, identity verification, the digital wallet, the Balance, funding, transfers between Users, remittances, payments, withdrawals, currency conversion, transaction limits, fees and the Visa Prepaid Card. These Terms and Conditions do not govern use of the www.uffpay.com website, which is governed by a separate document identified in Clause 1.2. Read them in full and carefully before registering, requesting the Visa Prepaid Card or carrying out any Transaction. By checking an unchecked box or pressing a button that clearly indicates acceptance, after the full text has been made available to you, you represent that you have read, understood and accepted these Terms and Conditions in their entirety, and that you have legal capacity to be bound. If you do not agree with any of their provisions, you must not register or use the Services. These Terms and Conditions contain significant provisions on the finality of Transactions, the allocation of losses arising from unauthorized transactions, suspension of the Account on compliance grounds, the scope of liability, indemnification and choice of forum; the most significant limitations, contained in Clauses 15, 17, 20, 26, 27 and 34.4, are highlighted in distinct characters in accordance with paragraph 2 of article 672 of the Commercial Code. Nothing in these Terms and Conditions excludes, limits or conditions the rights that the Consumer and User Protection Law grants to the User on a non-waivable, public-policy basis, nor the User's right to approach the Dirección de Atención y Asistencia al Consumidor (DIACO) and the competent courts at any time.

ADDITIONAL NOTICE FOR USERS SENDING FROM THE UNITED STATES OF AMERICA. If you request a remittance transfer from the United States of America, Annex A (United States Remittance Disclosures) forms part of these Terms and Conditions and prevails over any conflicting provision of the main body, including provisions on the finality of Transactions, claim deadlines and dispute resolution. Read Annex A before requesting a remittance transfer.

1. SCOPE OF THESE TERMS AND CONDITIONS AND RELATIONSHIP WITH THE OTHER DOCUMENTS

1.1 Matters governed by these Terms and Conditions

These Terms and Conditions govern, in full and exclusively, the contractual relationship between the Company and the User with respect to the digital financial services that the Company provides through the Application (collectively, the “Services”). In particular, these Terms and Conditions govern: (a) the User's eligibility and capacity to contract; (b) customer registration, identity verification and the Verification Levels; (c) the Account, the Balance and its legal nature; (d) the custody and safeguarding of User funds; (e) the funding of the Account and the permitted Funding Methods; (f) transfers between Users, cross-border remittances and transfers, payments, withdrawals and currency conversion; (g) the Applicable Exchange Rate; (h) transaction limits; (i) the Fee Schedule and the manner in which fees are disclosed and amended; (j) the execution, finality, reversal and monitoring of Transactions; (k) the issuance, use, blocking, replacement and termination of the Visa Prepaid Card; (l) unauthorized transactions and the allocation of the losses arising from them; (m) Transaction claims, disputes and Chargebacks; (n) Account inactivity; (o) the suspension, restriction and termination of the relationship and the return of the Balance; (p) prohibited uses and the measures arising under the Compliance Program; (q) the complaints procedure and the internal escalation ladder; and (r) the governing law and the resolution of disputes relating to the Services.

1.2 Matters not governed by these Terms and Conditions

These Terms and Conditions do not govern access to, browsing of, or use of the Company's institutional and commercial website located at www.uffpay.com, or of its subdomains, forms, informational sections, blogs, help centers and support portals (the “Site”), nor the Site Account, nor the editorial or advertising content published on the Site, nor the third-party links and resources accessible from it. All of those matters are governed by the UffPay Website Terms of Service (the “Site Terms”), a separate document that the User accepts separately and that is permanently and freely accessible on the Site. Acceptance of these Terms and Conditions does not constitute acceptance of the Site Terms, and the reverse is likewise true.

1.3 Related documents

The following documents are made available to the User together with these Terms and Conditions: (a) the UffPay Privacy Policy, which provides information on the processing of Personal Data; (b) the UffPay Cookie Policy, which provides information on the cookies and similar technologies used on the Site; (c) the Fee Schedule; (d) the table of transaction limits; and (e) the specific terms of the Visa Prepaid Card, when the User requests that product. The Privacy Policy and the Cookie Policy are stand-alone notices and are not deemed contractually accepted by the mere acceptance of these Terms and Conditions. The Fee Schedule, the limits table and the specific Card terms will be incorporated by reference only where they are readily accessible, are provided in full before acceptance or before the relevant Transaction, and clearly express the intent to make them binding, in accordance with article 6 of Decreto Número 47-2008 and article 48 of Decreto Número 06-2003. No document that has not been delivered or made accessible may be asserted against the User.

1.4 Independence of the documents

Each document identified in Clauses 1.2 and 1.3 retains its own subject matter and effective date. The Privacy Policy and the Cookie Policy are stand-alone notices, and any applicable specific Consents are collected separately. The Site Terms constitute a separate contract. Termination of any of those instruments does not automatically terminate the relationship arising under these Terms and Conditions and does not affect the User's Balance.

1.5 Order of precedence

In the event of a conflict between these Terms and Conditions and any of the documents identified in Clauses 1.2 and 1.3, the following will prevail, in this order: (a) mandatory consumer and user protection rules and any other public policy rules of the Republic of Guatemala; (b) these Terms and Conditions, as to all matters relating to the Services; (c) the specific terms of the Visa Prepaid Card, solely as to the operational particularities of the Visa Prepaid Card and provided that they do not reduce the rights these Terms and Conditions grant to the User; (d) the Fee Schedule, as to fees and charges; (e) the Privacy Policy, as to the processing of Personal Data; (f) the Cookie Policy, as to tracking technologies; and (g) the Site Terms, as to all matters relating to the Site. No order of precedence rule will be construed or applied in a manner that reduces the User's non-waivable rights, and in case of doubt the provision more favorable to the User will prevail.

1.6 Acceptance of these Terms and Conditions

The User expresses acceptance in the manner set out in Clause 5. The Company makes these Terms and Conditions available to the User in advance, in full, free of charge, and in an accessible, downloadable and retainable form, in Spanish, before collecting any expression of acceptance and before the User may carry out any Transaction.

2. DEFINITIONS AND INTERPRETATION

2.1 Definitions

For purposes of these Terms and Conditions, the capitalized defined terms have the meanings set out below, whether used in the singular or the plural:

• “Operating Partners” (Aliados Operativos): the processors, sponsors, plastic card manufacturers, acquirers, payment networks, banking institutions and other licensed third parties through which the Company provides, or enables the provision of, the Services, identified in Clause 3.7.
• “Application”: the mobile application named UffPay, in any of its versions for the supported operating systems, together with its updates, modules and the associated interfaces through which the Services are provided.
• “Clause”: each of the clauses of these Terms and Conditions.
• “Company”, “UffPay SA” or “we”: UFFPAY, SOCIEDAD ANÓNIMA, a Guatemalan sociedad anónima identified in Clause 3.
• “Board of Directors” (Consejo de Administración): the Company's management body, constituted in accordance with its articles of incorporation and with the Código de Comercio (Decreto 2-70).
• “User Content”: the information, texts, comments, ratings, images, files and any other materials that the User submits, uploads or transmits through the Application or through the support channels.
• “Chargeback” (Contracargo): the procedure by which a Transaction carried out with the Visa Prepaid Card is submitted to dispute before the Visa network in accordance with its rules, for the purpose of obtaining a refund of its amount.
• “Account”: the User's personal and unique record in the Application, through which the User accesses the Services and to which the User's Balance is linked.
• “Site Account”: the record that the User may create on the Site under the Site Terms, distinct and separate from the Account.
• “Personal Data”: any information concerning an identified or identifiable natural person, processed in accordance with the Privacy Policy and with applicable Guatemalan law.
• “Business Days”: Monday through Friday, excluding nationally observed holidays and public rest days in the Republic of Guatemala.
• “DIACO”: the Dirección de Atención y Asistencia al Consumidor of the Ministerio de Economía of the Republic of Guatemala (the Guatemalan consumer protection authority).
• “DPI”: the Documento Personal de Identificación (the Guatemalan national identity document) issued by RENAP.
• “Instruction”: any order, authorization or request that the User transmits to the Company through the Application for the execution of a Transaction.
• “IVE”: the Intendencia de Verificación Especial of the Superintendencia de Bancos of the Republic of Guatemala (the Guatemalan financial intelligence unit).
• “Funding Method” (Medio de Fondeo): each of the methods enabled to credit funds to the Balance in accordance with Clause 10.
• “Verification Level”: each of the Account levels resulting from the degree of identity verification completed by the User, in accordance with Clause 7.8.
• “Compliance Officer”: the person designated by the Company to perform the compliance functions required by the regulations in force, holding the applicable registration or approval.
• “Transaction” (Operación): any movement of funds carried out through the Application or the Visa Prepaid Card, including funding, transfers between Users, remittances, payments, withdrawals, currency conversions, refunds and reversals.
• “Cookie Policy”: the notice describing the cookies and similar technologies used on the Site. Device identifiers, software development kits and other technologies used in the Application are described in the Privacy Policy and in the applicable platform notices.
• “Privacy Policy”: the document governing the Company's processing of the User's Personal Data.
• “Compliance Program”: the Company's internal program for the prevention of the laundering of money or other assets and of terrorist financing, including its policies, manuals and procedures. The Compliance Program is an internal Company document and, by its nature and by operation of law, is not publicly available.
• “Intellectual Property”: all intellectual and industrial property rights in the Application, the underlying software, the databases, the trademarks, the trade names, the logos, the distinctive signs, the designs, the interfaces and the technological developments used by the Company.
• “RENAP”: the Registro Nacional de las Personas of the Republic of Guatemala (the Guatemalan national registry of persons).
• “Legal Representative” (Representante Legal): the person recorded with the Registro Mercantil General de la República as the Company's legal representative, identified in Clause 3.3.
• “Feedback” (Retroalimentación): the comments, ideas, suggestions, improvement proposals or error reports that the User voluntarily submits to the Company regarding the Application, the Visa Prepaid Card or the Services.
• “Balance” (Saldo): the available funds recorded in the User's favor in the User's Account, denominated in quetzales (GTQ) and in United States dollars (USD).
• “Services”: the digital financial services described in Clause 1.1 and further set out in Clause 11.
• “Site”: the website www.uffpay.com, its subdomains, pages, sections, forms and other web interfaces operated by the Company under that domain.
• “Fee Schedule” (Tarifario): the document setting out the commissions, fees and charges applicable to the Services, permanently available free of charge within the Application.
• “Visa Prepaid Card” or “Card”: the Visa-branded prepaid card, in physical or virtual form, linked to the User's Balance, the issuance and use of which are governed by Clause 16.
• “Site Terms”: the UffPay Website Terms of Service, which govern use of the Site.
• “Terms and Conditions”: this document.
• “Applicable Exchange Rate”: the exchange rate that the Company applies to a currency conversion at the time of the Transaction, determined and communicated in accordance with Clause 12.
• “UffPay”: collectively, UffPay Tech, Inc. and its subsidiary companies, including UffPay SA.
• “UffPay Tech”: UffPay Tech, Inc., the Company's parent company, incorporated under the laws of the State of Florida, United States of America.
• “User”, “you” or “your”: the natural person who registers in the Application and uses the Services in their own name and for their own account.

2.2 Rules of interpretation

Titles and headings are included solely for ease of reading and do not affect the interpretation of these Terms and Conditions. References to “including” or “includes” will always be read as “including, without limitation.” References to laws or decrees include their amendments, additions and implementing provisions in force. References to Clauses are to the clauses of these Terms and Conditions, unless expressly stated otherwise. Periods expressed in days mean calendar days, except where Business Days are expressly indicated. Periods expressed in months or years are computed in accordance with the Código Civil (Decreto Ley 106). Amounts are expressed in quetzales (GTQ) or in United States dollars (USD), as indicated in each case.

2.3 Interpretation in favor of the User

In accordance with article 1600 of the Código Civil (Decreto Ley 106) and paragraph 1o. of article 672 of the Código de Comercio (Decreto 2-70), and because this is a contract prepared in advance by the Company, any obscure, ambiguous, contradictory or doubtful clauses contained in these Terms and Conditions will be construed in the sense most favorable to the User. The same rule will apply in accordance with article 49 of Decreto Número 06-2003 (Ley de Protección al Consumidor y Usuario).

3. IDENTIFICATION OF THE PROVIDER AND NATURE OF THE SERVICE

In compliance with the provider's disclosure duties established in article 15 of Decreto Número 06-2003 (Ley de Protección al Consumidor y Usuario) and in article 52 of Decreto Número 47-2008 (Ley para el Reconocimiento de las Comunicaciones y Firmas Electrónicas), the Company identifies itself as follows.

3.1 General information about the Company

• Corporate name: UFFPAY, SOCIEDAD ANÓNIMA.
• Trade name: UFFPAY.
• Entity type: sociedad anónima (Guatemalan stock corporation).
• Nationality: Guatemalan.
• Domicile: Departamento de Guatemala, Republic of Guatemala.
• Registered address: Carretera a El Salvador 1-16, Apartamento 1, Fraijanes, Guatemala.
• Tax Identification Number (NIT): 120263173.
• Official website: www.uffpay.com.
• User support email address: support@uffpay.com.
• Email address for legal notices: legal@uffpay.com.

3.2 Incorporation and registry filings

The Company was incorporated by public deed number ninety-four (94), dated July 12, 2024, authorized in Guatemala City by notary Ana Estefanía Ortuño Herrera. It is registered with the Registro Mercantil General de la República as follows:

• Patente de Sociedad (corporate registration certificate): Registration 23101, Folio 96, Book 25 of Sociedades; file 82696-2024; registered on July 18, 2024.
• Patente de Empresa (business registration certificate): Registration 1108550, Folio 183, Book 1231 of Empresas Mercantiles; file 82698-2024.
• Authorized capital: four hundred ninety-nine thousand nine hundred ninety-nine quetzales (Q499,999.00), represented by 499,999 shares with a par value of one quetzal (Q1.00) each, Serie Primera, Clase Única.
• Subscribed and paid-in capital: five thousand quetzales (Q5,000.00).
• Corporate bodies: Asamblea General de Accionistas (general shareholders meeting); the management body, constituted as a Consejo de Administración (board of directors); and the Órgano de Fiscalización (supervisory body).

3.3 Legal representation and limits on the powers of representation

The Company acts through its duly registered Legal Representative, Mr. Victor Eduardo Droz Gomez, who holds the positions of President of the Board of Directors and Legal Representative. His appointment is recorded with the Registro Mercantil General de la República under Registration 750657, Folio 792, Book 834 of Auxiliares de Comercio, effective as of July 18, 2024 and for a fixed term of three (3) years.

The Legal Representative's powers are not unlimited sole-signature powers. Under clause TERCERA of the Company's articles of incorporation: (a) the opening and closing of bank accounts require the Legal Representative to act jointly with another member of the Board of Directors, or the prior approval of the Board of Directors or of the General Shareholders Meeting (subsection i); and (b) credit or borrowing transactions in amounts exceeding five thousand United States dollars (US$5,000) require the prior approval of the Board of Directors or of the General Shareholders Meeting (subsection j). Any assertion, statement or document attributing unlimited sole-signature powers to the Legal Representative is incorrect and does not bind the Company as against third parties beyond the registered limits.

3.4 Corporate purpose

In accordance with its registered corporate purpose, the Company is engaged in providing technology services for the payment, collection, administration and operational management of businesses, through the use of software, digital platforms, web pages, applications and peripheral equipment.

3.5 Group structure and technology license

The Company is a subsidiary of UffPay Tech, the parent company of the UffPay group, incorporated in the State of Florida, United States of America. UffPay Tech owns the group's Intellectual Property and licenses to the Company the technology, software, platforms, trademarks and other intangible assets that the Company uses to operate the Application and provide the Services. UffPay Tech is a holding and technology development company; it does not itself provide payment processing services to the User and is not a party to the contractual relationship documented by these Terms and Conditions, without prejudice to the rights expressly stipulated in its favor in Clauses 24 and 27.

3.6 Regulatory position of the Company

UffPay SA is a financial technology company and is not a bank; it does not take bank deposits from the public and does not pay interest or yield on the Balance. The Services are provided by the Company with the support of the providers, processors, institutions and networks identified in the applicable disclosures. These Terms and Conditions do not attribute to the Company or to any third party any license, authorization, registration, supervision or regulatory status that is not expressly identified and verified. Nothing in this Clause excludes the registration, supervision, compliance or reporting obligations that applicable law imposes on the Company.

3.7 Operating Partners and sponsorship chain

The Services may involve payment processors, acquirers, a bank identification number (BIN) sponsor, a licensed issuer, a payment network, a card manufacturer, custodial institutions and fraud prevention and compliance providers. The identity and legal role of each third party that materially participates in a product will be disclosed to the User before the User contracts for that product and, where the third party receives Personal Data, will be described in the Privacy Policy. The Company will not attribute to a third party any license, sponsorship, custody or function that is not supported by the applicable agreement. The replacement of a third party in a manner that materially alters the Service will be notified in accordance with Clause 33. The involvement of third parties does not reduce the Company's obligations to the User.

3.8 Official channels

The Company's only official channels are the Application downloaded from the official application stores, the Site, and the email addresses support@uffpay.com and legal@uffpay.com. The Company does not operate through domains, applications, messaging accounts or profiles other than those published on the Site and in the Application. The User must always verify the source of the Application and the domain before entering any data or credentials.

4. LEGAL FRAMEWORK AND PROTECTIVE CHARACTER OF THE USER'S RIGHTS

4.1 Applicable legal framework

The Services and these Terms and Conditions are governed by the laws of the Republic of Guatemala, including the Constitución Política de la República de Guatemala; the Código Civil, Decreto Ley 106; the Código de Comercio, Decreto 2-70; Decreto Número 06-2003 and its implementing regulations; Decreto Número 47-2008; the constitutional, civil, criminal, consumer, electronic communications and sector-specific rules applicable to the processing of personal data; and applicable tax law. With respect to the prevention of the laundering of money or other assets and of terrorist financing, Decretos 67-2001 and 58-2005 and their implementing regulations will apply for so long as they remain in force and, as of the entry into force of Decreto 15-2026, that decree, its transitional provisions and the corresponding implementing or successor rules will apply.

4.2 Nature as an adhesion contract

These Terms and Conditions constitute an adhesion and form contract, the terms of which have been established in advance by the Company, within the meaning of article 1520 of the Código Civil (Decreto Ley 106), of Decreto Número 06-2003 and of article 672 of the Código de Comercio (Decreto 2-70). Commercial contracts are not subject to special formalities for their validity under article 671 of the Código de Comercio and are formed by the simple consent of the parties under article 1518 of the Código Civil, and must be performed in good faith under article 1519 of that same body of law.

4.3 Protective and non-waivable character of consumer and user rights

The provisions of Decreto Número 06-2003 are protective of the consumer and user and are of public policy. Accordingly, no provision of these Terms and Conditions may be construed or applied as a waiver, limitation, condition or advance settlement of the rights that such law grants to the User, and any stipulation that would produce that effect will be deemed not written. The User retains at all times, among others, the right to truthful, clear, timely and complete information; to the protection of the User's economic interests; to repair, indemnification, refund of the money or replacement of the service where performance is deficient for a cause attributable to the Company; to have the User's claims handled without any conditions; and to bring the matter before DIACO (the Guatemalan consumer protection authority) and before the competent courts.

4.4 Prohibition of abusive clauses

The Company has avoided the stipulations prohibited by article 47 of Decreto Número 06-2003 and any other terms that would create an abusive imbalance to the User's detriment. In particular, these Terms and Conditions do not contain, and do not admit any interpretation to the effect of: (a) empowering the Company to unilaterally modify the essential content of the contract without prior notice and without the User's right to terminate without penalty; (b) shifting to the User responsibility for deficiencies, omissions or errors not attributable to the User; (c) excluding or limiting repair, indemnification, refund of the money or replacement of the service for a breach attributable to the Company; (d) reversing the burden of proof to the User's detriment or attributing full or conclusive evidentiary value to the Company's records; (e) imposing on the User an advance waiver of non-waivable rights or of the User's home venue; (f) establishing automatic renewals without prior notice and without the possibility of cancellation; or (g) conditioning the filing or the admission of a claim on the completion of requirements, forms or prior formalities. Any stipulation of these Terms and Conditions that, notwithstanding the foregoing, proves to be abusive will be null and void as a matter of law and will be deemed not written, without affecting the validity of the remainder of the contract in accordance with Clause 35.2.

4.5 Registration of the adhesion contract with DIACO

In accordance with article 52 of Decreto Número 06-2003, the Company will comply with the approval and registration procedure applicable to this adhesion contract. The Company will not assert that these Terms and Conditions are registered until DIACO has issued the corresponding resolution. Once issued, the exact reference to the resolution will be incorporated into this Clause and a new version will be published before the contract is identified as registered. The status of the filing does not reduce the User's rights or the Company's obligations.

5. FORMATION OF THE CONTRACT BY ELECTRONIC MEANS

5.1 Expression of consent

The User expresses consent and acceptance through an affirmative and unequivocal action taken after the full text of these Terms and Conditions has been made available to the User in a form that is accessible, understandable, downloadable and capable of being retained: (a) checking an acceptance box that is not pre-checked; or (b) clicking a button that clearly indicates that the action constitutes acceptance of these Terms and Conditions. The Company will not enable funding, the movement of funds, or the application for the Visa Prepaid Card before obtaining and recording that acceptance. Merely downloading, accessing, remaining silent, or using the Application without that affirmative action does not constitute acceptance.

5.2 Validity and binding force of electronic acceptance

The User's electronic acceptance is fully valid and binding under articles 5, 8, 15 and 26 of Decreto Número 47-2008, which recognize the legal validity of electronic communications, of the electronic signature, and of contracts formed by electronic means, including through the interaction between an automated message system and a natural person. Neither these Terms and Conditions nor the User's Instructions will be denied validity, binding force, or evidentiary effect solely because they exist in electronic form.

5.3 Record of acceptance

The Company will retain, for the period required by law and in any event for a minimum of five (5) years, a record of the acceptance of these Terms and Conditions that will include, at a minimum: (a) the version and effective date of the text accepted; (b) the date and time of acceptance; (c) the Account identifier; (d) the acceptance mechanism used; and (e) the technical session data that permit the acceptance to be attributed, processed in accordance with the Privacy Policy. The User has the right to request and obtain, free of charge and within the ten (10) Business Days following the request, a copy of the text of the version the User accepted and evidence of that acceptance.

5.4 Attribution of Instructions

Instructions, authorizations, requests and communications that the User transmits through the Application using the User's credentials or authentication methods will be deemed issued by the User, in accordance with articles 17 and 18 of Decreto Número 47-2008. This attribution rule does not apply where the User establishes that the communication did not originate from the User or from a person authorized by the User, nor where the use of the credentials results from a security failure attributable to the Company or to an Operating Partner. Attribution likewise does not apply in the situations covered by Clause 17, which governs unauthorized transactions.

5.5 Evidentiary value of the records and User access

The electronic records retained by the Company relating to the Account, the Instructions, the Transactions and communications constitute admissible evidence under articles 11, 12 and 13 of Decreto Número 47-2008. Those records will be weighed under the rules of sana crítica (reasoned judicial assessment of the evidence) and are subject to rebuttal; they do not constitute statutorily fixed or conclusive proof, they do not bind the court, and they do not alter the statutory allocation of the burden of proof. In particular, this Clause does not relieve the Company of proving the facts it is required to prove under the law and under Clause 17.4, and it does not permit holding the User liable for deficiencies or errors that are not attributable to the User, in accordance with subsection c) of article 47 of Decreto Número 06-2003. The User has the right to request and obtain, free of charge, a copy of the records of the User's Transactions and of the supporting evidence concerning the User, in legible format, within the ten (10) Business Days following the request.

5.6 Correction of input errors

Before any Transaction is carried out, the Application provides the User with a review and confirmation step that allows the User to verify and correct the data entered. Where the Application does not provide such a means of detecting and correcting an input error before an Instruction is transmitted, the User has the right to withdraw the portion of the communication in which the error occurred, provided that the User gives notice as soon as possible and has obtained no material benefit from it, in accordance with article 28 of Decreto Número 47-2008.

5.7 Availability, retention and download of the text

The Company makes the complete and current version of these Terms and Conditions available to the User within the Application on a permanent, free of charge and accessible basis, so that it may be consulted, printed, downloaded and retained, in compliance with articles 48 and 50 of Decreto Número 06-2003 and article 7 of Decreto Número 47-2008. The Company will likewise keep the history of prior versions accessible, together with the respective effective date of each, in accordance with Clause 33.8.

5.8 Incorporation by reference

The Fee Schedule (Tarifario), the limits table and the specific terms of the Card are incorporated by reference only when the conditions of availability, accessibility, integrity and acceptance set out in Clause 1.3 are satisfied. The Privacy Policy and the Cookie Policy are separate notices and are not incorporated as part of a single contractual acceptance. No incorporated document may reduce the User's non waivable rights.

5.9 Authentication of Transactions

For the execution of certain Transactions, the Company may require strong authentication mechanisms, such as a password, a one time code, device biometric authentication, or confirmation through an independent channel. Those mechanisms may satisfy the electronic signature requirements with respect to a specific Instruction only where they make it possible to determine the User's identity and reliably indicate the User's intent with respect to the information presented, in accordance with article 8 of Decreto Número 47-2008. The requirement of strong authentication is a security measure of the Company and does not shift to the User the risk of failures of those mechanisms that are not attributable to the User.

6. ELIGIBILITY AND CAPACITY

6.1 Eligibility requirements

An individual may register and use the Services if that individual concurrently meets the following requirements: (a) has reached eighteen (18) years of age; (b) has full legal capacity to contract and to assume obligations under the Código Civil (Decreto Ley 106); (c) is Guatemalan, or is a foreign national with documented residence in the Republic of Guatemala or with a documented connection to the remittance corridor served by the Company; (d) holds a valid DPI (the Guatemalan national identity document) or, in the case of a foreign national, a valid passport and, where applicable, the immigration document evidencing his or her status; (e) holds a mobile telephone number and an email address in his or her own name; and (f) satisfactorily completes the identity verification process set out in Clause 7.

6.2 User representations and warranties

By accepting these Terms and Conditions, and with each Transaction, the User represents and warrants that: (a) the User meets the requirements of Clause 6.1; (b) the information and documentation the User has provided are truthful, accurate, complete and current, and the User undertakes to keep them updated; (c) the User acts in the User's own name, for the User's own account and for the User's own benefit, and not as a nominee, intermediary or undisclosed agent of a third party; (d) the funds the User deposits into the Account come from lawful activities and from sources the User can document; (e) the User will not use the Services for any of the prohibited uses set out in Clause 21; and (f) the User is not included on any national or international sanctions list and does not act on behalf of a person included on any such list.

6.3 Minors

The Services are not directed to and are not available to persons under eighteen (18) years of age. The Company does not open Accounts for minors and does not knowingly collect their Personal Data. If the Company detects that an Account was opened by a minor, it will suspend the Account, make the Balance available to the person exercising legal representation of the minor upon proof of that capacity, and close the Account, in accordance with Clause 20.6 and the Privacy Policy.

6.4 Acting for one's own account and prohibition on transferring the Account

The Account is personal, unique and non transferable. The User may not allow a third party to use the User's Account, credentials or Visa Prepaid Card, may not use a third party's Account, and may not operate for the account or benefit of an undisclosed third party. Use of the Account to channel third party funds constitutes a material breach and gives rise to the measures set out in Clause 21.4.

6.5 Territorial and sanctions restrictions

The Company may restrict or deny access to the Services from jurisdictions in which providing them is not lawful, is subject to an authorization the Company does not hold, or is incompatible with the international sanctions regime applicable to the Company or to its Operating Partners. The Company will not carry out Transactions involving persons, entities or jurisdictions subject to sanctions, and may reject, hold or report them in accordance with Clause 21. The Company will inform the User of the existence of the restriction to the extent the law and its confidentiality obligations permit.

6.6 Politically exposed persons

Where the User is a politically exposed person, or has a family relationship or a relevant close association with one, the User must declare this at the time of registration and whenever the condition arises thereafter. This status does not by itself prevent access to the Services, but it results in the application of enhanced due diligence measures under the Compliance Program and the regulations referred to in Clause 4.1.

6.7 Personal use of the Account

The Account and the Services governed by these Terms and Conditions are intended for individuals. The Company may in the future make products available for legal entities or businesses; before doing so, it will make separate terms available to the business customer and obtain its express acceptance. Until those products are made available, the User may not use the User's personal Account to provide payment, currency exchange, remittance or processing services to third parties.

7. REGISTRATION, IDENTITY VERIFICATION AND VERIFICATION LEVELS

7.1 Registration application

To use the Services, the User must download the Application from an official app store and complete the registration application, providing, at a minimum: full first and last names as shown on the User's identification document; DPI or passport number; date of birth; nationality; residential address; mobile telephone number; email address; occupation or economic activity; and the declared source of funds. The Company requests only the data necessary to provide the Services and to comply with its legal obligations, in accordance with the proportionality principle set out in the Privacy Policy.

7.2 Accepted identification documents

The Company accepts as an identification document: (a) a valid DPI, in the case of Guatemalan nationals; and (b) a valid passport accompanied, where applicable, by the immigration document evidencing the foreign national's status in the country. The Company may require both sides of the document to be presented, in legible images, without cropping and without alterations.

7.3 Biometric verification and liveness check

As part of the process, the Company requires the capture of a photograph of the User's face (a selfie) and a liveness check, in order to compare the image with the one on the identification document and confirm that the application comes from the person to whom it relates. The capture and processing of the facial image constitute processing of sensitive data; the User gives express and informed consent to that processing at the time of capture, in accordance with the Privacy Policy, and may withdraw that consent at any time, on the understanding that withdrawal prevents provision of the Services and results in closure of the Account in accordance with Clause 20.

7.4 Validation against RENAP

The Company validates the User's identification data against the records of RENAP (the Guatemalan national registry of persons), in order to confirm the authenticity and validity of the DPI and the correspondence of the data declared. A discrepancy between the data declared and RENAP records does not by itself imply any allegation of wrongdoing by the User: the Company will notify the User of the discrepancy and allow the User to cure it in accordance with Clause 7.7.

7.5 Control lists and risk assessment

The Company screens the User's data against the lists and sources required by Guatemalan law and by the applicable resolutions of the United Nations Security Council. It may also use lists such as those of the Office of Foreign Assets Control (OFAC) where there is a nexus with the United States of America or where its Operating Partners so require. Automated tools support risk assessment but do not by themselves constitute a final decision; every adverse measure is subject to the human review provided for in Clause 7.7, except where a legal confidentiality restriction applies.

7.6 Outcome of the verification

Once verification is complete, the Company will notify the User, through the Application and at the registered email address, of one of the following outcomes: (a) approval, indicating the Verification Level assigned; (b) a request for additional information or documentation, precisely identifying what is required and the period for providing it, which will not be less than ten (10) Business Days; or (c) rejection. The Company will communicate a rejection within the five (5) Business Days following the decision and will indicate, to the extent the law and its confidentiality obligations permit, the general reason for the rejection and the means for requesting review of it.

7.7 Resubmission and right of review

A User whose registration has been rejected for curable reasons (such as an illegible image, an expired document, a data discrepancy or an input error) has the right to submit the application again, at no cost and with no reasonable limit on the number of attempts, once the cause has been cured. The User also has the right to request human review of any rejection, suspension or restriction resulting from an automated process, by submitting a request to support@uffpay.com. The Company will decide the review within the following ten (10) Business Days, by a reasoned written decision, and will inform the User of the right to escalate the matter in accordance with Clause 31. The Company will not charge the User any fee for the verification, for the resubmission of the application, or for the review.

7.8 Verification Levels

The Account operates by Verification Levels. The more verification completed, the greater the functionality enabled and the operating limits that apply. The Verification Levels are structured as follows:

Initial level

This corresponds to a registration that is in the process of verification. This level allows the User to complete registration, consult legal documents and submit the required information, but it does not allow the User to fund, receive, send, pay, convert or withdraw funds, or to apply for or use the Card, until the identity verification required for the relevant Service is complete. If, by error or because of a pending Transaction, funds are received before verification is complete, the Company will keep them safeguarded and will return them to the verified source or make them available to the User once the legally required verification has been satisfied.

Verified level

This corresponds to an Account whose User has satisfactorily completed the documentary, biometric and list screening verification set out in Clauses 7.2 through 7.5. It enables the ordinary set of Services, including the application for the Visa Prepaid Card, and the ordinary limits published in the Application.

Enhanced level

This corresponds to an Account whose User has additionally documented the source of the User's funds and the User's financial capacity through the supporting documentation the Company requests. It enables the higher limits published in the Application.

Movement from one Verification Level to another occurs at the User's request or on the Company's initiative, upon submission of the corresponding documentation. The Company discloses within the Application, clearly and accessibly, the requirements for each Verification Level and the limits associated with it, in accordance with Clause 13.3.

7.9 One Account per User

Each User may hold only one Account, associated with a single identification document and a single mobile telephone number. The Company may reject or consolidate duplicate registrations, upon prior notice to the User and without affecting the User's Balance.

7.10 Ongoing due diligence and updating of data

The User undertakes to keep the Account information updated and to notify the Company, as soon as it occurs, of any change in the User's identification data, contact data, economic activity, or status as a politically exposed person. The Company conducts ongoing due diligence and may periodically require the User to update information and documentation, as well as to document the source of funds, where the regulations referred to in Clause 4.1, the User's transactional profile, or the Compliance Program so warrant. The request will precisely identify what is being requested, its basis, and a reasonable period that will not be less than ten (10) Business Days. Unjustified failure to respond to the request entitles the Company to restrict the Account in accordance with Clause 20.2, on the understanding that such restriction does not affect the User's right to obtain the return of the User's Balance in accordance with Clause 20.6, absent a legal impediment.

7.11 Retention of documentation

The Company will retain identification documentation, verification records and Transaction records for the five (5) year period required by the regulations on the prevention of money laundering and other assets and of terrorist financing, and for such additional periods as are required by the Código Tributario and other applicable legislation, in accordance with the Privacy Policy.

7.12 Modification of sensitive registration data

Modification of the data that identify the User (first names, last names, date of birth, identification document number and mobile telephone number) requires the submission of supporting documentation and the approval of the Company's compliance function. The Company will decide the request within the ten (10) Business Days following its complete submission, by a reasoned decision. This requirement is a fraud and impersonation prevention measure and may not be used to obstruct the exercise of the User's rights or access to the User's Balance.

8. THE ACCOUNT AND THE BALANCE

8.1 Nature and purpose of the Account

The Account is the personal electronic record through which the User accesses the Services, holds the Balance, transmits Instructions and consults transaction history. The Account is not a bank account, is not a deposit account, is not a savings account, and is not subject to the regime of the Ley de Bancos y Grupos Financieros (Decreto 19-2002).

8.2 Legal nature of the Balance

The Balance represents funds owned by the User that the Company holds and administers on the User's behalf, for the sole purpose of carrying out the Instructions the User transmits. The Balance is not a bank deposit, does not constitute the taking of funds from the public, is not a financial intermediation transaction, and is not covered by the Fondo para la Protección del Ahorro or by any Guatemalan deposit insurance scheme.

8.3 No interest and no yield

The Balance does not generate interest, yield, dividends or any financial benefit for the User, and the Company does not offer any savings or investment product. Any yield that the safeguarded funds may generate while held by the custodian institution does not belong to the User and is not credited to the User.

8.4 Currencies

The Account supports a Balance in quetzales (GTQ) and in United States dollars (USD). The User may hold a Balance in both currencies and select the display currency. The Company may add or discontinue currencies, giving the User not less than thirty (30) calendar days' prior notice where the discontinuation affects a currency in which the User holds a Balance, and in that case allowing the User to convert or withdraw that Balance at no cost before the effective date.

8.5 Balance inquiry, transaction history and account statement

The User may consult the Balance and the complete history of the User's Transactions within the Application at any time and at no cost. The Company makes available to the User, at no cost, the account statement for any period within the last five (5) years, in a legible and downloadable format, within the ten (10) Business Days following the request.

8.6 User funds and the Company's own assets

The funds that make up the Balance belong economically to the Users, and the Company administers them solely to carry out their Instructions. The Company will not record them as its own revenue, will not use them to finance its operations, and will not pledge or encumber them. The existence and scope of any segregation of assets as against third parties depend on ownership, the legal structure of the accounts and the applicable custody agreements; the Company will not assert protection against creditors that is not supported by those agreements and by law. This clarification does not reduce the obligation to return the Balance in accordance with these Terms and Conditions.

8.7 Limited set off

The Company may charge against the User's Balance only in the situations and within the limits set out in Clause 15.9. Outside those situations, the Company may not dispose of the Balance for its own account.

9. CUSTODY AND SAFEGUARDING OF FUNDS

9.1 Custody arrangements

The funds corresponding to the Balance will be held at regulated financial institutions or with custody providers identified in the disclosures applicable to the product and the currency. Before enabling a Balance, the Company will inform the User of the identity and role of the relevant institution, the nature of the account, and the material safeguarding conditions. Any change that materially alters those conditions will be notified at least thirty (30) calendar days in advance, unless an urgent security measure or an order of an authority requires acting sooner, in which case notice will be given as soon as the law permits.

9.2 Segregation and reconciliation

The Company will hold User funds in accounts dedicated to that purpose and segregated from its operating accounts, with records that permit identification of the amount corresponding to each User. The Company will perform reconciliations no less frequently than each business day and will correct without delay any discrepancy identified.

9.3 Prohibition on the use of User funds

The Company will not use, lend, invest, pledge, or commit User funds to finance its own operations or those of third parties. Each disbursement will be made against funds actually available from the ordering User or against the Company's own operating resources, according to the applicable flow.

9.4 Positive operating balance policy

The Company will maintain a positive proprietary operating balance in the jurisdictions in which it must make disbursements and will not fund one User's payments with another User's funds in transit. This control will be verified through the applicable treasury, reconciliation, and continuity procedures.

9.5 Scope of any deposit insurance

Any protection of the Federal Deposit Insurance Corporation of the United States of America (FDIC) applies to eligible deposits held at the depository institution and is subject to applicable law, limits, account ownership, and recordkeeping requirements. These Terms and Conditions do not state that the User's Balance has direct or pass-through FDIC coverage unless such coverage has been expressly verified and disclosed in writing. Balances denominated in quetzales are not covered by the Fondo para la Protección del Ahorro (the Guatemalan savings protection fund).

9.6 Continuity of custody

In the event that a custodian institution is replaced, that the relationship with an Operating Partner is interrupted, or of any other circumstance affecting custody, the Company will adopt the measures necessary to preserve the integrity of User funds and their availability, and will inform the User of the status of the User's Balance and of the alternatives for accessing it within the five (5) Business Days following the event. The Company's obligation to make the Balance available to the User subsists in all cases and is not affected by its relationships with third parties.

10. FUNDING THE ACCOUNT

10.1 Funding Methods

The User may credit funds to the User's Balance through the Funding Methods that the Company enables and discloses within the Application, which may include, subject to availability: (a) a transfer from a bank account owned by the User; (b) a deposit or cash load at points of the correspondent network or at authorized agents; (c) a credit from a card owned by the User through the Operating Partners; (d) receipt of a transfer from another User; and (e) receipt of a remittance under Clause 11.3. For each Funding Method, and before the User confirms, the Application will disclose the amount, the applicable fee under the Fee Schedule, the estimated crediting time, and the net amount that will be credited to the Balance.

10.2 Ownership of the Funding Method

The User may fund the Account only with Funding Methods that the User owns. The Company may require proof of such ownership and may reject, hold, or return to source funds coming from a method that is not owned by the User or whose ownership cannot be established, informing the User to the extent the law permits.

10.3 Crediting and availability

Funds are credited to the Balance once the Company effectively and irrevocably receives them from the relevant institution or Operating Partner. The Application will display the status of each funding transaction and, where crediting is not immediate, the estimated time and the reason for the delay. The Company is not responsible for timeframes that depend exclusively on the ordering institution or on the payment network, but it is responsible for reporting them truthfully and for diligently managing the crediting.

10.4 Rejection and return of a funding transaction

The Company may reject a funding transaction when: (a) it comes from a method that is not enabled or that is not owned by the User; (b) it exceeds the limits applicable to the User's Verification Level under Clause 13; (c) its source cannot be established; or (d) there are reasonable indications of fraud or of a transaction subject to the measures in Clause 21. In the event of rejection, the Company will return the funds to their source at no cost to the User, absent a legal impediment or a requirement of a competent authority, and will inform the User to the extent the law permits.

10.5 Erroneous funding

Where the User credits a funding transaction in an amount or to an Account other than intended through the User's own error, the User must notify the Company promptly. The Company will provide diligent cooperation to seek the return of the funds, including by communicating with the receiving User, without this constituting a guarantee of the outcome where the return depends on the will of a third party. The Company will not charge any fee for this assistance.

11. THE SERVICES

11.1 Digital wallet

The Company makes available to the User a digital wallet that allows the User to hold and manage the User's Balance in the currencies set out in Clause 8.4, review the User's Transaction history, submit Instructions, and access the User's funds through the other Services.

11.2 Transfers between Users

The User may send funds to another User and request funds from another User, instantly or nearly instantly within the Application. Before confirmation, the Application will show the User the recipient's name or the identifying element that allows verification that the recipient is the intended person, the amount, the applicable fee, and the total amount. Once carried out, a transfer between Users is governed by Clause 15.3.

11.3 Remittances and cross border transfers

The Company facilitates the receipt of remittances sent from the United States of America to the Republic of Guatemala for crediting to the receiving User's Balance. The process comprises verification of the transaction under the know your customer and anti money laundering rules applicable in the country of origin and in Guatemala, the transfer of the funds, and their crediting to the Balance. The service in the country of origin may be subject to additional terms applicable to the sender and to the entity that operates it; those terms do not reduce the rights that these Terms and Conditions grant to the receiving User in the Republic of Guatemala. The Application will inform the receiving User of the amount received, the Applicable Exchange Rate where the remittance involves conversion, the applicable fee, and the net amount credited.

11.4 Payments

The User may pay for goods and services at the merchants and providers enabled within the Application, as well as by means of the Visa Prepaid Card under Clause 16. The Company acts solely as a means of payment and is not a party to the sale or service relationship between the User and the merchant, nor is it responsible for the existence, quality, suitability, delivery, or warranty of the goods or services purchased, without prejudice to its obligations regarding Chargebacks under Clause 18 and to those imposed on it by law as a payment service provider.

11.5 Withdrawals

The User may withdraw the User's Balance through the means that the Company enables and discloses within the Application, including a transfer to a bank account owned by the User and cash withdrawal by means of the Visa Prepaid Card at network ATMs, where those channels are in fact enabled. The User's right to access the User's Balance is essential; the Company may restrict it only in the circumstances expressly provided in Clauses 15.5, 20, and 21, for the time strictly necessary and after notice to the User to the extent the law permits.

11.6 Currency conversion

The User may convert the User's Balance between the available currencies, in accordance with Clause 12.

11.7 Addition, modification, and discontinuation of Services

The Company may add new Services or features, modify them, or discontinue them. The addition of a new Service may be subject to additional terms, which will be made available to the User and will require the User's express acceptance before use. The discontinuation of a Service that the User has been using will be notified at least thirty (30) calendar days in advance and may not affect the Balance or Transactions already ordered. No modification of the Services may deprive the User of access to the User's Balance.

11.8 Availability of the Services

The Company seeks to keep the Services continuously available. Where a Service must be interrupted for scheduled maintenance, the Company will announce it with reasonable advance notice within the Application and will seek to perform it at times of lower impact. In the event of an unscheduled interruption, the Company will report its existence and its estimated duration, and will make available, where technically possible, an alternate channel for urgent transactions and for the handling of complaints.

11.9 Actual availability

The description of a feature in these Terms and Conditions does not by itself constitute a statement that the feature is enabled for all Users or on all dates. A Service, currency, Funding Method, withdrawal channel, or card product will be available only when it appears enabled in the Application for the relevant User and its material conditions have been presented before use. The Company will not charge for, or obtain acceptance of, a product that is not yet operational.

12. EXCHANGE RATE AND CURRENCY CONVERSION

12.1 Applicable Exchange Rate

Where a Transaction involves conversion between quetzales and United States dollars, the Applicable Exchange Rate will apply, meaning the exchange rate that the Company applies at the time of the Transaction, which is disclosed to the User within the Application before the User confirms the Transaction. The Applicable Exchange Rate is determined from market references and from the conditions that the Company obtains from its banking institution and from its Operating Partners, plus any spread that applies under Clause 12.2.

12.2 Prior disclosure and itemization

Before the User confirms a Transaction involving currency conversion, the Application will display, clearly, legibly, and on the same screen: (a) the Applicable Exchange Rate expressed numerically; (b) the exchange spread or margin and the applicable fee under the Fee Schedule, identified separately; (c) the amount in the source currency; and (d) the resulting amount in the destination currency. The User may cancel the Transaction at no cost before confirming it. The Company will not apply to the Transaction an exchange rate other than the one disclosed to and accepted by the User.

12.3 No fixed exchange rate

The Company does not guarantee or set any determined, permanent, or reference exchange rate. No commercial communication, promotional material, or prior version of these Terms and Conditions establishes a binding exchange rate. The Applicable Exchange Rate is the rate disclosed to the User at the time of each Transaction under Clause 12.2, and only that rate.

12.4 Validity period of the quote

Where the Company displays a quote to the User, it will state the period during which the quote remains valid. If the Transaction is confirmed within that period, the Company will carry it out at the Applicable Exchange Rate disclosed, even if the market reference has varied in the meantime. If the period expires without confirmation, the Application will display a new quote before carrying out the Transaction.

12.5 Exchange rate risk

The User acknowledges that exchange rates fluctuate and that the value of the User's Balance expressed in a different currency may vary. The Company is not responsible for movements in the foreign exchange market, without prejudice to its duty to provide truthful, clear, complete, and timely information under Clause 12.2 and to carry out the Transaction on the terms disclosed.

12.6 Card Transactions in a different currency

Where the User carries out a Transaction with the Visa Prepaid Card in a currency other than that of the Balance charged, the conversion will be performed in accordance with the rules of the Visa network and the Applicable Exchange Rate, and the foreign currency transaction fee, if any, will be itemized in the Fee Schedule. The amount ultimately charged may differ from the amount shown at the time of authorization where network settlement occurs on a later date; the Application will inform the User of this circumstance before the Transaction and will reflect the final amount in the Transaction details.

13. OPERATING LIMITS

13.1 Existence and purpose of the limits

The Company establishes operating limits by amount, by frequency, by period, and by type of Transaction. Such limits are based on security, fraud risk management, and compliance with the regulations on prevention of laundering of money or other assets and of terrorism financing, as well as on the rules of the Visa network and of the Operating Partners, and do not constitute a discretionary power of the Company to restrict the User's access to the User's funds.

13.2 Publication of the limits

The Company publishes within the Application, on a permanent, free, accessible, and understandable basis, the current table of operating limits, expressed in quetzales and, where applicable, in United States dollars, indicating the Verification Level to which each limit corresponds. Before the User confirms a Transaction that approaches or exceeds a limit, the Application will inform the User of the applicable limit and of the available margin.

13.3 Limits by Verification Level

Operating limits vary according to the Account's Verification Level under Clause 7.8: the initial Level operates with reduced limits; the verified Level, with the ordinary limits; and the expanded Level, with the higher limits. The User may ascertain, at any time and within the Application, the Verification Level assigned to the User, the limits that apply to the User, and the specific requirements for moving up to the next level.

13.4 Modification of the limits

The Company may modify the operating limits. Any reduction of a limit applicable to the User will be notified no less than thirty (30) calendar days in advance, except where the reduction results from a requirement of a competent authority, from a legal obligation of immediate compliance, or from a reasoned fraud prevention measure, in which case it will take effect immediately and will be communicated to the User within the following two (2) Business Days, stating the reason to the extent permitted by law. An increase of a limit does not require prior notice.

13.5 Request for an increase

The User may request at any time the review or increase of the User's limits through the Application or at support@uffpay.com. The Company will decide the request within ten (10) Business Days following its complete submission, by means of a reasoned decision, and, in the event of denial, will state the requirements the User would have to satisfy and the User's right to escalate under Clause 31. The request and its processing are free of charge.

13.6 Transactions that exceed the limits

Transactions that exceed the applicable limits will be rejected or subjected to additional review. The rejection will be communicated to the User at that time, indicating the limit exceeded and the means for requesting an increase. Rejection of a Transaction for exceeding a limit does not affect the User's Balance and does not give rise to any charge.

14. FEES, COMMISSIONS, AND CHARGES

14.1 The Fee Schedule

The commissions, fees, and charges applicable to the Services are set out in the Fee Schedule, which the Company maintains within the Application on a permanent, free, accessible, and downloadable basis. The Fee Schedule states each item in quetzales and, where applicable, in United States dollars, indicating whether the amount is fixed or a percentage, the base on which it is calculated, and the applicable taxes.

14.2 Transparency before the Transaction

Before the User confirms any Transaction that gives rise to a charge, the Application will display, on the same screen and in legible form: the amount of the Transaction; the itemization of each commission, charge, and exchange rate spread; the total amount that will be debited from the Balance; and the net amount the recipient will receive. The Company will not apply to the User any charge that was not disclosed to and accepted by the User on that screen, and will not charge for services not rendered, in accordance with Decreto Número 06-2003.

14.3 Services at no cost

The Company does not charge an Account opening fee, a monthly maintenance fee, an inactivity charge, a charge for checking the Balance or transaction history, a charge for issuing the account statement, a charge for identity verification, or a charge for filing or processing a claim. Transfers between Users within the Application are free of charge. The foregoing is without prejudice to the commissions applicable to the other Services under the Fee Schedule.

14.4 Collection of commissions

Commissions accepted by the User will be deducted from the Balance or added to the amount of the Transaction, as disclosed to the User. If the Balance is insufficient to cover the amount of the Transaction and its commission, the Transaction will not be carried out and no charge will be generated; the Application will inform the User of the reason for the rejection. The Company will not carry out Transactions that would produce a negative Balance, except in the technical circumstances set out in Clause 15.9.

14.5 Modification of the Fee Schedule

Any increase of a commission, addition of a new fee item, or unfavorable modification will be notified no less than thirty (30) calendar days in advance. Its entry into force as against the User will require the User's express acceptance under Clause 33.3 and may not be inferred from silence or from mere continued use of the Services. A User who does not accept may close the User's Account without penalty and obtain the full return of the User's Balance under Clause 20.6. Reductions of commissions may be applied immediately, with notice of the reduction given in the Application.

14.6 Prohibition of undisclosed charges and of higher prices

The Company will not charge a price higher than the price disclosed, displayed, or published, and will not charge for a service it has not actually rendered. Any charge applied in breach of this Clause will be refunded under Clause 14.7.

14.7 Refund of improper charges

Once an improper charge, a duplicate charge, or a technical error attributable to the Company or to an Operating Partner has been verified, the Company will credit the corresponding amount back to the User's Balance within five (5) Business Days following verification, without any need for the User to request it where the Company detects the matter on its own, and will inform the User accordingly. Where the credit depends on a refund by a third party, the Company will nonetheless make the credit within the stated period and will pursue recovery from the third party on its own account.

14.8 Taxes

The User is responsible for the taxes, duties, and contributions that, under applicable law, arise from the User's own transactions. The Company will make the withholdings and file the reports required of it by law, and will provide the User with the corresponding tax receipts for the services it renders to the User.

15. EXECUTION OF TRANSACTIONS

15.1 Instruction and confirmation

Every Transaction is carried out on the basis of the User's Instruction transmitted through the Application. Before execution, the Application presents the User with a review screen showing the complete details of the Transaction and allowing the User to correct them or to cancel the Transaction at no cost. The Transaction is carried out only after the User confirms it and, where applicable, passes the authentication required by Clause 5.9.

15.2 The User's duty to verify

The User must carefully verify the details of each Transaction (in particular the identity of the recipient, the amount, and the currency) before confirming it. This duty does not relieve the Company of its obligation to present the information clearly and sufficiently, and does not entitle the Company to shift to the User the consequences of errors or deficiencies not attributable to the User.

15.3 Final nature of Transactions

Once carried out and confirmed, a Transaction is deemed final and, by its nature, cannot be revoked, cancelled, or modified unilaterally by the User. The foregoing does not impair the User's non waivable rights as a consumer, nor the reversal, correction, reimbursement, or Chargeback situations provided for in Clauses 15.4, 17, and 18, nor the User's right to claim such redress as may be appropriate under the law.

15.4 Grounds for reversal and correction

The Company will reverse, correct, or reimburse a Transaction where any of the following circumstances applies: (a) a verifiable technical error attributable to the Company or to an Operating Partner; (b) duplication of the Transaction; (c) a credit or debit made in error; (d) an unauthorized Transaction under Clause 17; (e) a favorable outcome of a claim or of a Chargeback under Clause 18; or (f) an order of a competent authority or a legal provision. The reversal or correction will be carried out at no cost to the User and will be communicated to the User, stating the reason, the amount, and the date.

15.5 Hold, rejection, or reversal for compliance reasons

The Company may reject, temporarily hold, or reverse a Transaction where there are reasonable indications that it is related to fraud, to laundering of money or other assets, to terrorism financing, to an unlawful activity, or to a breach of Clause 21, or where a competent authority or applicable regulation so requires. The hold will be maintained only for the time strictly necessary to complete the verification or to respond to the authority's request. The Company will inform the User of the existence of the measure and of its lifting as soon as the law permits; where anti money laundering regulations impose confidentiality on the Company, the Company will refrain from disclosing the reason, provided that such confidentiality may not be used to prolong the measure beyond what is necessary or to evade the duty to decide the matter. Once the verification is completed with no finding that justifies the measure, the Company will lift it immediately and make the funds available to the User.

15.6 Transaction monitoring

The Company monitors Transactions through automated systems for detecting unusual or suspicious transactions, in accordance with the Compliance Program. As a result of such monitoring, the Company may request additional information from the User, apply a measure under Clause 15.5, or file the reports required of it by law. The User has the right to request human review of any measure adopted on the basis of an automated process, in accordance with Clause 7.7.

15.7 Notification of Transactions

The Company will notify the User, through the Application and through the other channels the User configures, of each Transaction carried out on the User's Account and with the User's Visa Prepaid Card, as soon as technically possible. The User must review such notifications and report any discrepancy in accordance with Clauses 17.1 and 18.2. The Company will not charge for these notifications and may not deactivate them without the User's request.

15.8 Receipts and records

For each Transaction, the Application generates a receipt that can be viewed and downloaded and that identifies the date, the time, the type of Transaction, the amount, the commissions, the Applicable Exchange Rate where relevant, the recipient, and the reference number. The Company will retain such receipts and make them available to the User in accordance with Clauses 5.5 and 8.5.

15.9 Set off, negative balances, and recovery of funds

The Company may deduct from the User's Balance, informing the User in advance where possible and in any event within the following two (2) Business Days, stating the reason and the details of the calculation: (a) the commissions accepted by the User under Clause 14; (b) amounts credited in error, by duplication, or as a result of a technical failure; (c) amounts corresponding to a Chargeback resolved against the User under Clause 18; and (d) amounts the User owes the Company under a liquidated, due, and previously communicated obligation. The deduction will be strictly limited to those amounts.

If, as a result of a technical failure, a network reversal, or a subsequent settlement, the Balance becomes negative, the User must cure it and the Company may apply subsequent funding to that purpose. The Company will not charge interest, late charges, penalties, or overdraft fees on a negative Balance, and may not claim from the User a negative Balance that arose from a cause not attributable to the User. The Company will inform the User of the origin of the negative Balance and will allow the User to file a claim under Clause 31.

16. VISA PREPAID CARD

16.1 Nature of the Card

The Visa Prepaid Card is a prepaid payment instrument linked to the User's Balance. It is not a credit card, it is not a bank debit card, it does not grant a line of credit, it does not permit overdraft, and it does not bear interest or any yield. Every Transaction made with the Card is debited from the User's available Balance and is subject to the existence of sufficient funds and to the limits set out in Clause 13.

16.2 Issuance and sponsorship chain

The Card will be offered under a program sponsored and operated by entities authorized under the rules of the Visa network. Before the User may apply for it, the Application and the Card's specific terms will clearly identify the licensed issuer, the sponsor of the bank identification number (BIN), the network, the Company, and their respective roles. The Card may not be applied for until that information and the specific terms have been made available to the User. UffPay SA does not hold itself out as a licensed issuer unless a current and verified authorization establishes otherwise.

16.3 Forms and maximum number of Cards

The Card is offered in virtual form and in physical form. The User may keep a maximum of two (2) Visa Prepaid Cards active at the same time, counting both forms together. Applying for an additional Card above that maximum requires the prior cancellation of one of the active Cards.

16.4 Application, delivery, and activation

The Card is applied for within the Application and requires the Account to be, at a minimum, at the verified Level under Clause 7.8. The physical Card will be sent to the address indicated by the User within the enabled territory. Before confirming the application, the Application will display the total cost, the estimated delivery time, and the maximum delivery time, and will retain that information in the application receipt. If the Card is not received within the maximum period communicated, the User may choose between replacement at no cost or a refund of the issuance and shipping charges. Activation will take place within the Application before first use. The virtual Card will be enabled only when the program is operational and after its specific conditions have been presented and accepted.

16.5 Term and renewal

The Card's expiration date will be the one shown on the Card itself or in the Application. The Company will notify the User of the approaching expiration no less than thirty (30) calendar days in advance and will display the renewal procedure and cost before obtaining the User's acceptance. No renewal charge will be applied without express acceptance, and expiration will not affect the Balance.

16.6 Use of the Card

The Card allows purchases at merchants affiliated with the Visa network, both in person and online, cash withdrawals at ATMs on the network, and contactless transactions, according to the functionalities enabled and disclosed within the Application. The User may enable and disable at any time, from the Application and at no cost, the online purchase, foreign transaction, cash withdrawal, and contactless transaction functionalities.

16.7 Authorizations and temporary holds

Certain merchants (such as lodging establishments, vehicle rental companies, and service stations) request a prior authorization for an estimated amount, which is temporarily held against the Balance and may differ from the amount ultimately charged. The Application will identify such holds separately from final charges, will disclose their amount, and will release the unused amount as soon as the merchant or the network confirms it and, in any event, within the timeframes of the Visa network. If thirty (30) calendar days have elapsed since the authorization and the hold has neither settled nor been released, the Company will release it on its own initiative and will notify the User.

16.8 Card credentials

The User is responsible for safeguarding the physical Card, its number, its expiration date, its verification code, and its personal identification number. The Company will not request from the User, by any means, the User's personal identification number, verification code, or access credentials. The User must not share them with any person, including persons who claim to act on behalf of the Company.

16.9 Loss, theft, cloning, and blocking by the User

The User may block and unblock the Card immediately, free of charge, and without stating a reason, from the Application, where that function is available. In the event of loss, theft, cloning, or suspicion of unauthorized use, the User must block the Card immediately and give notice through the Application or at support@uffpay.com. The Company will make it possible to receive such notices at all times, every day of the year. The Company will record the date and time of the notice and will provide the User with the corresponding reference number. Blocking the Card does not block the Account and does not prevent the User from accessing the User's Balance through the other enabled means.

16.10 Blocking by the Company

The Company may block the Card as a preventive measure where it detects a usage pattern consistent with fraud, where the Visa network or an Operating Partner so notifies it, where there are indications that the Card credentials have been compromised, or where a circumstance under Clause 20.2 applies. The block will be communicated to the User immediately through the Application and to the registered email address, stating the reason to the extent permitted by law and the means for having it lifted. The Company will lift the block as soon as the cause ceases and, in any event, will decide on lifting it within five (5) Business Days following the User's request. Blocking the Card does not deprive the User of access to the User's Balance through the other means, unless a circumstance under Clause 20.2 also applies with respect to the Account.

16.11 Replacement

The User may request replacement of the Card within the Application. The replacement cost is set out in the Fee Schedule. No replacement cost will be charged where the replacement is due to a manufacturing defect, to a failure not attributable to the User, to an unauthorized transaction recognized under Clause 17, to non receipt of the Card under Clause 16.4, or to a blocking decision by the Company adopted without cause attributable to the User.

16.12 Merchant refunds

Where a merchant issues a refund in respect of a purchase made with the Card, the amount will be credited to the User's Balance once the network and the Operating Partners transmit it. The Company will inform the User of the status of the refund and, where the refund is not credited within the network's ordinary timeframes, will pursue the matter with the merchant and the network on the User's behalf and at no cost to the User, in accordance with Clause 18.

16.13 Termination of the Card

The User may cancel the Card at any time, at no cost and without penalty, from the Application. Cancellation of the Card does not entail closure of the Account and does not affect the Balance. The Company may cancel the Card in the circumstances set out in Clause 20.2 and where the Visa network or the BIN sponsor withdraws the product, in which case it will notify the User no less than thirty (30) calendar days in advance, except in cases of urgency due to fraud, and will offer the User alternative means of accessing the User's Balance.

16.14 Visa network rules

Use of the Card is also subject to the rules of the Visa network and to those of the Operating Partners. Such rules do not apply against the User to the extent that they reduce the rights granted to the User by these Terms and Conditions or by Guatemalan law; in the event of conflict, the provision more favorable to the User will prevail, in accordance with Clause 1.5.

17. UNAUTHORIZED TRANSACTIONS AND ALLOCATION OF LOSSES

17.1 User's duty to give notice

The User must notify the Company, as soon as the User becomes aware of it, of the loss or theft of the User's device or Card, of the disclosure or compromise of the User's credentials, and of any Transaction the User did not authorize. Notice may be given through the Application or at support@uffpay.com, at all times and at no cost. The Company will record the date and time of the notice and will provide the User with a reference number.

17.2 Immediate action by the Company

Upon receipt of the notice, the Company will immediately block the Card and the compromised means of access and will take the measures available to it to prevent further Transactions. The Company will confirm to the User that the block has been carried out, using the same channel through which the notice was given.

17.3 Allocation of losses

From the time of the notice provided for in Clause 17.1, the User bears no loss arising from unauthorized Transactions carried out after that notice. Those losses are for the Company's account.

With respect to unauthorized Transactions carried out before the notice, the loss is for the Company's account, unless the Company proves that the Transaction occurred through the User's wilful misconduct or through the User's gross negligence in safeguarding the User's credentials, device, or Card. Gross negligence includes, among other cases, voluntarily giving the credentials or the personal identification number to a third party, writing those credentials on the Card itself or keeping them together with it, and failing to give notice for a manifestly unreasonable period of time after becoming aware of the event. It does not constitute gross negligence by the User to have been the victim of impersonation of the Company, of a fraudulent message, or of a deception technique, nor does use of the Card without its physical presence where the User has not disclosed the Card data.

In no event does the User bear the loss where the unauthorized Transaction occurred through a failure of the systems, procedures, or controls of the Company or of an Operating Partner, where the Company did not make an effective means of giving notice available to the User, or where the Company did not apply the authentication mechanisms under Clause 5.9 that were required for the type of Transaction involved.

17.4 Burden of proof

It is for the Company to prove that the Transaction was correctly authenticated, recorded, and posted and that it was not affected by a technical failure or by any other deficiency in the service. The Company's record of the use of the User's credentials is not, by itself, sufficient to prove that the User authorized the Transaction, that the User acted fraudulently, or that the User engaged in wilful misconduct or gross negligence. This rule is established in accordance with subparagraph c) of article 47 of Decreto Número 06-2003, which prohibits shifting to the consumer responsibility for acts not attributable to the consumer, and it may not be modified to the User's detriment.

17.5 Refund

Upon receipt of notice of an unauthorized Transaction, the Company will credit the amount claimed back to the User's Balance within the following ten (10) Business Days, unless within that period it has reasonable and documented grounds to suspect wilful misconduct by the User, in which case it will notify the User in writing, stating those grounds, and will continue the investigation in accordance with Clause 18. A refund made under this Clause is provisional until the investigation concludes and may be reversed only in the case provided for in Clause 18.8.

17.6 User's cooperation

The User will cooperate reasonably with the investigation by providing the information available to the User and, where the Company requests it with justified cause, proof of the report filed with the competent authority. The Company may not condition the receipt, admission, or processing of the claim on the prior filing of a report, on any form, or on any other step.

17.7 Prohibition on shifting risks

No provision of these Terms and Conditions shifts to the User the risk of security failures in the systems of the Company or of the Operating Partners, the risk of cloning or compromise of the Card by means unrelated to the User's conduct, or the risk arising from the absence of adequate authentication mechanisms.

18. TRANSACTION CLAIMS, DISPUTES, AND CHARGEBACKS

18.1 Scope of this Clause

This Clause governs the User's claim in respect of a specific Transaction, whether because the User does not recognize it, because its amount or terms differ from those accepted, because the goods or services paid for were not delivered or performed, because it was the subject of a refund that was not credited, or because the Transaction was defectively carried out or was not carried out.

18.2 Time period for making a claim

The User must submit a claim as soon as the User becomes aware of the event and, in any case, within ninety (90) calendar days following the date of the Transaction. This period is established in order to allow the Company to exercise the network's remedies against third parties in a timely manner. Expiration of this period does not extinguish the User's right: the Company will likewise admit and process a claim submitted thereafter, and may not assert the expiration of the contractual period or of the network period as grounds for rejection, deciding the claim in that case in accordance with Clause 17 and with the law. This period does not shorten any statutory limitation period or the User's right to go to DIACO (the Guatemalan consumer protection authority) or to the courts.

18.3 Submission of the claim

The claim is submitted through any of the channels listed in Clause 31.1, stating, to the extent possible for the User, the date and amount of the Transaction, the merchant or recipient, the reason for the claim, and any supporting documentation the User may have. The absence of any of these items will not be grounds for rejection: the Company will admit the claim and, where it needs to, will request the missing information from the User. The User will not be required to complete any form or format, or to take any prior step, as a condition for making a claim.

18.4 Acknowledgment of receipt and time periods for decision

The Company will acknowledge receipt of the claim within two (2) Business Days following its submission, assigning it a reference number. The Company will decide the claim by written and reasoned decision within fifteen (15) Business Days following the acknowledgment of receipt. Where the decision depends on the outcome of a Chargeback before the network or on a third party's response, the Company may extend that period for the time strictly necessary, informing the User within the original period and stating the reason, the status of the matter, and the new estimated date, and keeping the User informed of progress at intervals of no more than fifteen (15) Business Days.

18.5 Handling of the Chargeback before the network

Where the claim relates to a Transaction made with the Visa Prepaid Card and is eligible for a Chargeback, the Company will initiate the Chargeback with the Visa network on the User's behalf, at no cost to the User, and will inform the User, at the time the claim is received, of the time period established by the network rules for the type of dispute involved. The User is not required to pursue the Chargeback personally or to contact the merchant, without prejudice to the User's ability to do so. The Company may not require the User, as a condition for initiating the Chargeback, to show that the User first attempted to resolve the matter with the merchant.

18.6 Provisional refund during the investigation

Where the claim relates to a Transaction that the User does not recognize, the refund provided for in Clause 17.5 will apply. In all other cases, the Company will assess, having regard to the plausibility of the claim and to the amount involved, whether a provisional refund during the investigation is appropriate, and will state the reasons for its decision. The Company will not withhold the User's undisputed Balance on account of a pending claim.

18.7 Decision and statement of reasons

The decision on the claim will be communicated to the User in writing, will state the facts verified and the basis for the decision, and will expressly inform the User of the right to escalate the matter in accordance with Clause 31.4 and to go to DIACO or to the competent courts. Where the claim is decided in the User's favor, the Company will credit the corresponding amount to the User's Balance within the following five (5) Business Days.

18.8 Reversal of the provisional refund

The provisional refund may be reversed only where the investigation concludes, by written and reasoned decision, that the Transaction was authorized by the User or that a case of wilful misconduct or gross negligence under Clause 17.3 exists, and provided that such conclusion is proved in accordance with Clause 17.4. The Company will notify the User of the reversal at least five (5) Business Days in advance, will state the grounds for it, will make available to the User the materials on which it relies, and will inform the User of the right to escalate and to go to DIACO or to the courts. The reversal may not be carried out while the claim is escalated internally under Clause 31.4 or is pending before DIACO or a court.

18.9 Claims regarding goods and services purchased

Where the claim concerns the existence, quality, delivery, or warranty of goods or services purchased from a merchant, the corresponding consumer relationship is between the User and that merchant. Nevertheless, the Company will process the Chargeback in accordance with Clause 18.5 where the network rules so permit, and will provide the User with reasonable assistance in exercising the User's rights, including delivery of the records of the Transaction.

18.10 Prohibition on conditions and on retaliation

The Company will handle every claim without imposing any condition, in accordance with Decreto Número 06-2003, and will not take any measure to the User's detriment on account of the User having made a claim, escalated a claim, or gone to DIACO or to the courts.

19. ACCOUNT INACTIVITY

19.1 Inactive Account

An Account is deemed inactive where no Transaction and no access by the User has been recorded for twelve (12) consecutive months.

19.2 Prior notice

Before classifying an Account as inactive, the Company will notify the User, at the registered email address and through the Application, at least thirty (30) calendar days in advance, of the approaching classification, its effects, and how to avoid it.

19.3 Effects of inactivity

Inactivity does not give rise to any charge, fee, or penalty of any kind, does not reduce the User's Balance, and does not extinguish the User's right to it. The Company may, for security reasons, restrict the carrying out of Transactions on an inactive Account until the User re-authenticates, and may deactivate the associated Visa Prepaid Card.

19.4 Reactivation

The User may reactivate the Account at any time, at no cost, by re-authenticating and, where compliance regulations so require because of the time elapsed, by updating the User's information in accordance with Clause 7.10. The Company will decide the reactivation request within the following five (5) Business Days.

19.5 Balance in inactive Accounts

The Balance of an inactive Account remains fully available to its holder. The Company does not confiscate it, does not apply it to any other purpose, and does not subject it to any charge by reason of the inactivity. The User may request its return at any time in accordance with Clause 20.6.

19.6 Closure for prolonged inactivity

After twenty-four (24) consecutive months of inactivity, the Company may close the Account upon prior notice to the User of at least thirty (30) calendar days, and will make the Balance available to the User in accordance with Clause 20.6. If it is not possible to make the Balance available for reasons beyond the Company's control, the Company will keep it identified and available for the User or the User's successors in interest, free of any charge, for the period established by law, and will make reasonable and documented efforts to locate the User.

20. SUSPENSION, RESTRICTION, AND TERMINATION

20.1 Termination by the User

The User may terminate this relationship and request the closing of the Account at any time, without stating a cause, without penalty, and at no cost, through the Application or at support@uffpay.com. The Company will confirm receipt of the request within the following two (2) Business Days and will proceed in accordance with Clause 20.6.

20.2 Suspension, restriction, or termination by the Company

The Company may suspend, restrict, or terminate the Account, or any of the Services, where reasonable and proportionate cause exists, including: (a) breach of these Terms and Conditions, in particular of Clauses 6, 7, and 21; (b) reasonable indications of fraud, impersonation, or unauthorized access; (c) the existence of a requirement from a competent authority or of a legal obligation; (d) the application of a measure arising from the Compliance Program; (e) the provision of false, inaccurate, or misleading information; (f) unjustified failure to respond to an update request under Clause 7.10; (g) use of the Account for the account of, or for the benefit of, an undisclosed third party; or (h) justified reasons of security or maintenance, for the time strictly necessary.

20.3 Proportionality, notice, and right to be heard

The measure adopted by the Company will be the least burdensome measure suitable to address the cause giving rise to it and will remain in place for the time strictly necessary. The Company will inform the User of the measure, its scope, its estimated duration, and its reason, except where a legal confidentiality obligation prevents it from doing so, and will inform the User of the means for submitting arguments and the documentation supporting them. The Company will decide on those submissions within the ten (10) Business Days following their submission, by written and reasoned decision, and will inform the User of the right to escalate in accordance with Clause 31 and to go to DIACO or to the courts. Except in cases of proven urgency, risk of fraud, or legal mandate, termination by the Company will be notified at least thirty (30) calendar days in advance.

20.4 Measures arising from the Compliance Program

Where the measure is based on the regulations on the prevention of laundering of money or other assets or of terrorist financing, the Company will refrain from disclosing to the User those matters that the law requires it to keep confidential, including the possible filing of a report with IVE (the Guatemalan financial intelligence unit). That confidentiality does not relieve the Company from: (a) informing the User of the existence of the measure and of its scope; (b) reviewing it periodically and lifting it as soon as its cause ceases; (c) deciding the User's claim within the time periods set out in Clause 31.3; or (d) making the Balance available to the User where there is no legal impediment to doing so.

20.5 Effects of termination

Upon termination of the relationship: (a) the User's access to the Services ceases and the User's Visa Prepaid Cards are cancelled; (b) obligations that arose previously survive; (c) the Company retains the records for the periods set out in Clause 7.11; and (d) the Clauses identified in Clause 35.10 survive.

20.6 Return of the Balance

Upon termination of the relationship for any cause, the Company will make the entirety of the User's Balance available to the User, without any deduction other than those expressly authorized by Clause 15.9, without penalty and at no cost, within the ten (10) Business Days following the closing request or the notice of termination. Where an investigation is pending, a hold has been ordered by a competent authority, or a legal impediment exists, the period will run from the conclusion of the investigation or the lifting of the impediment and will not exceed thirty (30) Business Days from that time; the Company will inform the User, at intervals of no more than fifteen (15) Business Days, of the status of the matter and of the portion of the Balance not affected by the measure, which it will make available to the User immediately. The obligation to return the Balance is essential, is not subject to any quantitative limit, and may not be waived, made conditional, or set off outside the cases provided for in Clause 15.9.

20.7 Death of the User

Once the User's death has been established, the Company will suspend the Account and will make the Balance available to the person who proves entitlement to it under Guatemalan law, free of any charge and within the ten (10) Business Days following such proof.

21. PROHIBITED USES AND REGULATORY COMPLIANCE

21.1 General obligation of lawful use

The User agrees to use the Application, the Account, the Balance, and the Visa Prepaid Card in good faith and in accordance with these Terms and Conditions, with the law, and with public policy.

21.2 Prohibited conduct

The User may not:

• (a) use the Services for the laundering of money or other assets, for terrorist financing, for the evasion of sanctions, or for any unlawful activity;
• (b) provide false, inaccurate, or misleading information, or impersonate another person;
• (c) use a third party's Account or Card, allow a third party to use the User's own, or act on behalf of an undisclosed third party;
• (d) structure Transactions for the purpose of evading the Company's limits, reporting thresholds, or controls;
• (e) use the Services to pay for goods or services whose sale is prohibited or restricted by Guatemalan law or by the rules of the Visa network;
• (f) use the Account to provide payment, currency exchange, remittance, or processing services to third parties;
• (g) access the Application by unauthorized automated means, interfere with its operation, introduce malicious software, defeat its security measures, or reverse engineer, decompile, or disassemble its code;
• (h) obtain or attempt to obtain an improper benefit through the abuse of promotions, reversals, Chargebacks, or system failures; or
• (i) infringe intellectual property rights or other rights of the Company, of UffPay Tech, or of third parties.

21.3 Restricted activities

The Company may restrict use of the Services with respect to sectors and activities that, under the law, under the rules of the Visa network, or under the policies of its Operating Partners, are prohibited or subject to restriction. The Company will publish and keep current within the Application the list of such restricted activities, and will notify the User when a Transaction is declined on that basis.

21.4 Consequences of noncompliance

A breach of this Clause entitles the Company to take the measures set out in Clauses 15.5 and 20.2, in accordance with the principle of proportionality and with due regard for the User's right of defense, without prejudice to any legal actions that may apply and to the reporting obligations that the law imposes on the Company.

21.5 Compliance Program and reports to the authority

The Company will comply with the regime for the prevention of the laundering of money or other assets and of terrorist financing in force from time to time. To that end it will apply know your customer measures, risk based assessment, monitoring, and recordkeeping. The entity or participant that is legally responsible will file with the IVE (the Guatemalan financial intelligence unit) the reports required in the applicable cases, through the applicable channels, and within the applicable time periods, including Cash Transaction Reports and Suspicious Transaction Reports where they apply. UffPay SA will file them directly only where its classification, obligation, channel, and deadline are formally confirmed; in all other cases it will cooperate with the sponsoring institution or the authorized participant that bears responsibility. The filing of a mandatory report does not, in and of itself, constitute a complaint or an accusation against the User. This provision does not exclude liability for willful misconduct, gross negligence, breach of the law, or improper disclosure of confidential information.

21.6 Statutory confidentiality

The Company is not permitted to inform the User or any third party of the existence, the content, or the processing of a report filed with the IVE. The User acknowledges that this confidentiality is a legal obligation of the Company. This confidentiality does not relieve the Company of its duty to resolve the User's claims within the time periods set out in Clause 31.3, or to make the Balance available to the User where there is no legal impediment.

21.7 Cooperation with authorities

The Company will respond to requests from the competent authorities made in accordance with the law, providing the information and carrying out the measures lawfully ordered, and will inform the User of the same where the law permits, in accordance with the Privacy Policy.

22. SECURITY OF THE ACCOUNT AND THE DEVICE AND FRAUD PREVENTION

22.1 The Company's measures

The Company applies technical and organizational measures that are reasonable and proportionate to the risk in order to protect the Account, the Balance, and the User's information. Depending on the system, the data, the flow, and the architecture actually implemented, these measures may include encryption in transit or at rest, strong authentication, access controls, monitoring, and the security standards applicable to the Operating Partners that actually process Card data. No system is infallible; this warning does not shift to the User any risks that are allocated to the Company under Clause 17.

22.2 The User's obligations

The User agrees to:

• (a) safeguard the User's credentials and not disclose them to any person;
• (b) keep the User's device locked and updated;
• (c) download the Application only from the official app stores;
• (d) enable strong authentication where available;
• (e) not use the Application on devices that are compromised or modified in order to circumvent their security controls; and
• (f) give the notices required by Clause 17.1 as promptly as possible.

22.3 Legitimate communications from the Company and fraud prevention

The Company does not ask the User, by email, text message, instant messaging, telephone call, or any other means, for the User's passwords, one time codes, personal identification number, or the verification code of the User's Card. The Company also does not ask the User to transfer funds to an account other than the User's own "to protect them", or to install remote access applications. Any communication making any of those requests is fraudulent and does not come from us. The User must not act on it and must report it in accordance with Clause 22.4.

22.4 Reporting channel

The User may report any attempted fraud, impersonation, or unauthorized access through the Application or by writing to support@uffpay.com. The Company will acknowledge receipt within the following two (2) Business Days and will take the appropriate measures.

22.5 Security incidents

In the event of a security incident affecting the Account, the Balance, or the User's Personal Data, the Company will without delay adopt containment and remediation measures, will inform the affected User as soon as it has sufficient and reliable information, describing the nature of the incident, the data or transactions affected, and the recommended measures, and will give the corresponding notice to the competent authority where the law so requires, all in accordance with the Privacy Policy.

23. PROTECTION OF PERSONAL DATA

23.1 Reference to the Privacy Policy

The processing of Personal Data in connection with the Application, the Account, and the Services is described in the Privacy Policy, which is available before registration and on a permanent basis within the Application. With respect to the Application and to the authenticated relationship with the User, UffPay SA acts in the role described in that Policy; UffPay Tech acts with respect to the public Site, or jointly, only where the Policy identifies processing that covers both environments. Acceptance of these Terms and Conditions does not replace the specific consent that may be required for biometric data, commercial communications, or other particular processing.

23.2 Reference to the Cookie Policy

The use of cookies and similar technologies on the Site is described in the Cookie Policy. Device identifiers, software development kits, operating system permissions, and the other technologies used in the Application are described in the Privacy Policy. Acceptance of these Terms and Conditions does not, in and of itself, constitute consent to technologies that require separate authorization.

23.3 Applicable legal framework

As of the effective date of these Terms and Conditions, the Republic of Guatemala does not have a general, comprehensive personal data protection law applicable to the private sector. Decreto Número 57-2008 is the Ley de Acceso a la Información Pública, and the data protection regime in its articles 30 to 32 is directed to the obligated parties defined in that law; the Company does not invoke it as a source of general obligations for a private controller. Processing related to the Application is governed by the commitments assumed in the Privacy Policy and by the constitutional, civil, criminal, consumer protection, electronic communications, anti money laundering, and sector specific rules that apply.

24. INTELLECTUAL PROPERTY

24.1 Ownership

The Application and all of its components constitute Intellectual Property of UffPay Tech, of the Company, or of their licensors, and are protected by applicable law. The Application software is licensed to the Company by UffPay Tech in accordance with Clause 3.5.

24.2 Limited license granted to the User

The Company grants the User a personal, limited, non-exclusive, non-transferable, non-sublicensable, and revocable license to install and use the Application on the User's devices, for the sole purpose of accessing the Services as an end consumer. This license terminates upon termination of the relationship, and its termination does not affect the User's right to the return of the User's Balance in accordance with Clause 20.6.

24.3 Restrictions

The User may not copy, modify, translate, sublicense, sell, assign, lease, distribute, publicly communicate, or commercially exploit the Application or the Intellectual Property, nor reverse engineer or decompile them, except to the extent that the law mandatorily permits.

24.4 User Content

User Content remains owned by the User. The User grants the Company a worldwide, non-exclusive, royalty free, and limited license to store, reproduce, and use the User Content and to disclose it to the Company's Operating Partners, solely to the extent necessary to provide the Services, handle the User's claims, and comply with the Company's legal obligations. The User represents that it holds the necessary rights in the User Content that it submits.

24.5 Feedback

Feedback that the User voluntarily submits may be used by the Company and by UffPay Tech with no obligation of confidentiality, attribution, or compensation. The Company will not claim rights in the User's creations that are unrelated to Feedback concerning the Services.

Personal Data contained in the Feedback will be processed in accordance with the Privacy Policy.

24.6 Third party marks

Third party marks that actually appear in the Application, on the Site, or in an enabled product belong to their respective owners and are used for identification purposes only. Reference to a mark does not attribute to its owner any contractual or regulatory role other than the one disclosed and verified for the corresponding product.

25. WARRANTIES AND SCOPE OF PERFORMANCE

25.1 Warranties given by the Company

The Company warrants to the User that: (a) it will provide the Services with the professional diligence expected of a digital financial services provider; (b) it will carry out Instructions in accordance with the terms communicated and accepted; (c) it will keep the User's Balance intact, separately identified, and available in accordance with Clauses 8 and 9; (d) it will disclose the terms, the fees, the limits, and the Applicable Exchange Rate truthfully, clearly, completely, and on a timely basis; and (e) it will handle the User's claims without imposing any condition and within the time periods set out in Clauses 18 and 31.

25.2 Scope of the disclaimer

The Company seeks to provide continuous availability and uninterrupted operation of the Application, but does not warrant that the Services will be free of every interruption or error, nor that they will be compatible with all existing devices, operating systems, data networks, or software versions. This disclaimer relates exclusively to technical availability and does not extend to the warranties in Clause 25.1, to the obligation to return the Balance, or to the User's mandatory rights.

25.3 Mandatory rights not affected

Nothing in this Clause excludes, limits, or conditions the rights that Decreto Número 06-2003 grants to the User on a mandatory basis, in particular the User's right to redress, to compensation, to a refund of the money, or to replacement of the service where performance proves deficient for a cause attributable to the Company.

26. LIABILITY

26.1 Liability of the Company

The Company is liable to the User for breach of the obligations that these Terms and Conditions and the law impose on it, in accordance with the general contractual liability regime of the Código Civil (Decreto Ley 106) and with Decreto Número 06-2003.

26.2 Recoverable damages and excluded damages

To the maximum extent permitted by law, the Company's liability covers actual loss (daño emergente) and lost profits (lucro cesante) that are the immediate and direct consequence of a breach attributable to it, in accordance with article 1434 of the Código Civil, and does not cover indirect, remote, incidental, special, or consequential damages, nor loss of opportunity, of data, or of reputation that does not meet that standard.

26.3 Matters that cannot be limited

The limitations in this Clause do not apply, and nothing in these Terms and Conditions excludes or limits the Company's liability: (a) for wilful misconduct or gross negligence; (b) for harm to the life, bodily integrity, or health of persons; (c) in cases in which the law does not permit the exclusion or limitation of liability; (d) with respect to the rights that Decreto Número 06-2003 grants to the User on a mandatory basis, in particular those in subsections c), d), and f) of its article 47; or (e) with respect to the obligation to make the User's Balance available to the User in accordance with Clause 20.6.

26.4 No monetary cap

These Terms and Conditions do not establish any monetary cap on the Company's liability. Any compensation owed will be determined in accordance with the law and with Clause 26.2. Under no circumstances may the Company's obligation to return to the User the Balance that legitimately belongs to the User be limited or made conditional; that Balance consists of the User's own funds and is always returnable in full.

26.5 Acts of third parties and of the User

The Company is not liable for damages that are the exclusive consequence of: (a) an act of God or force majeure under Clause 28; (b) the User's own act, including breach of Clauses 21 and 22.2 and the cases of wilful misconduct or gross negligence under Clause 17.3; or (c) the act of a third party for which the Company is not answerable under Clause 26.7. Where the conduct of the User and that of the Company both contribute to causing the damage, compensation will be apportioned according to each party's causal contribution.

26.6 Duty to mitigate

Both parties undertake to adopt the reasonable measures available to them to mitigate the damages arising from any breach, as soon as they become aware of it.

26.7 Liability for the Aliados Operativos (Operating Partners)

The Company is liable to the User for the acts and omissions of the Aliados Operativos (Operating Partners) that it uses to perform the Services, as if they were its own, in everything that relates to the contracted performance. The Company is not liable for the consumer relationship between the User and a merchant under Clause 11.4, nor for the services of application stores, telecommunications carriers, or device manufacturers, without prejudice to its obligation to process Chargebacks in accordance with Clause 18.

27. INDEMNIFICATION BY THE USER

27.1 Scope

The User will be liable to the Company and to UffPay Tech only for third party claims arising directly from wilful, fraudulent, or unlawful conduct by the User, from a material and culpable infringement of third party rights, or from a deliberate material misstatement in the User's representations. This obligation does not cover ordinary errors, unauthorized Transactions, deficiencies in the Services, acts of third parties, or conduct that is not attributable to the User.

27.2 Procedure

The Company will notify the User, without undue delay, of any claim subject to indemnification, and may assume the defense of the matter at its own cost, in which case the User will cooperate reasonably. Neither party will settle a claim that imposes obligations or admissions on the other party without that party's prior consent, which will not be withheld without reasonable cause.

27.3 Limits on the indemnification obligation

This Clause will be construed narrowly, does not impose strict liability on the User, does not limit the User's rights as a consumer, and does not apply to the extent that the claim is attributable to the Company, to UffPay Tech, or to an Aliado Operativo (Operating Partner). No defense costs will be payable without reasonable supporting documentation and without the User having had an opportunity to participate in the defense.

28. FORCE MAJEURE AND ACT OF GOD

Neither party will be liable for a breach caused directly by an unforeseeable and unavoidable event beyond its reasonable control that meets the requirements for caso fortuito (act of God) or fuerza mayor (force majeure) under article 1426 of the Código Civil. A failure of an Aliado Operativo (Operating Partner) will qualify as such only where the event giving rise to it meets those requirements and does not result from a lack of reasonable diligence, selection, supervision, redundancy, or continuity on the part of the Company. The Company will report the event and its estimated duration, will apply its continuity measures, and will restore the Services as soon as possible. Force majeure does not affect the integrity of the Balance, does not prevent claims from being handled through available channels, does not excuse obligations that are not affected, and does not protect the Company if it was already in default (mora).

29. SERVICE RISKS AND WARNINGS TO THE USER

29.1 Risk warning

The User acknowledges that the use of digital financial services involves risks, including: errors in entering the data for a Transaction; unauthorized access resulting from the loss, theft, or compromise of the device or of the credentials; exchange rate fluctuations; interruptions and technical failures; regulatory changes; and attempts at fraud, impersonation, and deception by third parties.

29.2 Allocation of risks

This warning is informational and preventive in purpose and does not alter the allocation of liability set out in Clauses 17 and 26, nor does it shift to the User any risk that under those Clauses is borne by the Company. The User assumes only the consequences of the User's own wilful misconduct or gross negligence, on the terms of Clause 17.3.

29.3 Financial education and control tools

The Company makes available to the User, within the Application and at no cost, information and tools to manage the User's risk, including the blocking and unblocking of the Card, the activation and deactivation of features under Clause 16.6, Transaction notifications, and fraud prevention materials.

30. COMMUNICATIONS AND NOTICES

30.1 Consent to electronic means

The User agrees that the relationship with the Company be conducted by electronic means and that communications, notices, account statements, receipts, and decisions be sent to the User through the Application and to the registered email address. Such communications take effect in accordance with article 24 of Decreto Número 47-2008. The User may request at any time, at no cost, that a specific communication also be delivered in physical form or in downloadable format.

30.2 When communications take effect

Communications from the Company will be deemed received when they enter the information system designated by the User or become available to the User in the Application. Where the communication is to produce an adverse effect for the User, the corresponding period will be counted from the time the communication is effectively made available and accessible to the User.

30.3 Updating contact information

The User undertakes to keep the User's email address and telephone number up to date. The Company may not invoke the non-receipt of a communication where it sent that communication to contact information that it knew to be out of date, or where it received a delivery error notice and did not use an alternative means.

30.4 Commercial communications

Sending commercial communications requires the User's prior consent, is revocable at any time, at no cost and by a simple means that will be included in each communication, and its revocation does not affect the provision of the Services. Operational, security, and compliance communications and those relating to contractual amendments are not commercial communications and cannot be turned off while the relationship remains in effect.

30.5 Notices addressed to the Company

Legal or formal notices addressed to the Company must be sent to the email address legal@uffpay.com or, in writing, to the registered address stated in Clause 3.1, to the attention of the Legal Department. Ordinary inquiries, complaints, and claims are submitted through the channels in Clause 31.1. The Company will acknowledge receipt of every legal notice within the following two (2) Business Days.

30.6 Recording of communications

Communications between the User and the Company may be recorded and retained for quality, security, evidentiary, and compliance purposes, in accordance with the Privacy Policy. The Company will inform the User of this at the start of the communication where voice channels are involved.

30.7 Language of communications

Communications between the parties will be conducted in the Spanish language.

31. USER SUPPORT, COMPLAINTS, AND INTERNAL ESCALATION

31.1 Support channels

The User may contact the Company through: (a) the chat or ticketing system enabled within the Application; (b) support@uffpay.com; and (c) legal@uffpay.com for formal notices and escalated claims. The Company will maintain the Libro de Quejas (complaints book) or the corresponding electronic means required under applicable regulations and will identify it visibly and accessibly within the Application and the Site. The internal channels do not limit the User's right to turn to DIACO (the Guatemalan consumer protection authority) or to the courts of competent jurisdiction.

31.2 Filing a complaint or claim

The User may file a complaint or claim through any of the channels in Clause 31.1, stating, to the extent possible, the User's name and contact information, a description of the matter complained of and its date, the specific relief sought, and any supporting documentation the User may have. The absence of any of these elements will not be grounds for rejecting the claim: the Company will accept it and, where necessary, will request the missing information from the User. No form, format, or prior step will be required of the User as a condition for making a claim. Claims relating to a specific Transaction are further governed by Clause 18.

31.3 Acknowledgment of receipt and general deadlines

The Company will acknowledge receipt of every claim within the two (2) Business Days following its filing, assigning it a reference number that allows it to be tracked. The Company will communicate its reasoned decision within the fifteen (15) Business Days following the acknowledgment of receipt. Where the complexity of the matter or the need to obtain information from a third party so warrants, the Company may extend that period on one occasion only and by up to fifteen (15) additional Business Days, notifying the User within the original period, stating the reason and the new estimated response date.

31.4 Internal escalation ladder

Where the User is not satisfied with the response received, or where the applicable period expires without a response, the matter will be escalated through the following levels, in this order.

31.4.1 Level 1: User Support

The User support team receives, logs, and resolves the claim within the deadlines in Clause 31.3. Every response will be reasoned and will expressly state the User's right to escalate to Level 2 and how to do so.

31.4.2 Level 2: Coordinación de Atención al Consumidor (Consumer Affairs Coordination Office)

At the User's request, or on the Company's own initiative where the claim concerns a possible infringement of the User's rights as a consumer, the matter will pass to the Company's Coordinación de Atención al Consumidor (Consumer Affairs Coordination Office), which will review it independently of whoever decided the matter at Level 1 and will issue its reasoned decision within the following ten (10) Business Days.

31.4.3 Level 3: Legal and Compliance Department

If the User is still not satisfied, or if the matter concerns the interpretation of these Terms and Conditions, an unauthorized transaction, a Chargeback, personal data, a suspension, restriction, or termination measure, or a compliance matter, the matter will pass to the Company's Legal and Compliance Department, which may be contacted at legal@uffpay.com, and which will issue its reasoned decision within the following ten (10) Business Days.

31.4.4 Level 4: Final internal decision

Once the preceding levels have been exhausted, the final internal decision will rest with the Legal Representative or with the person the Company designates in accordance with its structure then in effect, who will decide within the following ten (10) Business Days by a written and reasoned response. If that person has a personal interest in the matter, the claim will be decided by a body free of conflict. This internal stage is not a precondition and does not suspend the User's right to turn to DIACO or to the courts.

31.5 Reserved compliance matters

Where a claim relates to a compliance measure, the internal review will verify the correct application of the procedure, the proportionality of the restrictions, and the availability of the portion of the Balance not subject to a legal impediment. The claim will not suspend or reverse a report or measure required by a competent authority or by law, and the Company will inform the User only to the extent permitted by the applicable statutory confidentiality (reserva legal). No internal review will extend the response deadlines or maintain a restriction after its cause has ceased.

31.6 Internal disagreement and escalation within the group

No disagreement among areas, bodies, or companies of the group will suspend the response deadlines, alter the User's rights, or delay the return of the portion of the Balance not subject to a legal impediment. Once the applicable period has expired without a decision, the User may treat the internal process as exhausted and immediately exercise the mechanisms in Clause 31.8.

31.7 Documentation, traceability, and recordkeeping

Every claim, its handling, and its resolution will be documented in writing and logged by the Company, stating the date, the level that decided the matter, and the grounds for the decision. The Company will retain that record for the applicable legal period and in any event for a minimum of five (5) years, and will make available to the User copies of the records concerning the User within the ten (10) Business Days following the User's request.

31.8 Non-exclusive nature of the internal process

The procedure described in this Clause is an internal support mechanism and does not constitute a procedural prerequisite, a precondition, or a waiver of any kind. The User may turn to DIACO or to the courts of competent jurisdiction at any time and without exhausting the internal process. Use of the internal process does not suspend, interrupt, or shorten the limitation periods or the statutory periods for the exercise of the User's rights, nor may the Company invoke it as grounds for the inadmissibility of an action brought by the User.

31.9 Rights before the consumer protection authority

Without prejudice to the foregoing, the User has the right to turn to DIACO and to use the dispute resolution mechanisms provided in article 78 of Decreto Número 06-2003, namely: direct conciliatory settlement, consumer arbitration, and the administrative procedure.

32. RIGHT OF WITHDRAWAL

32.1 Recognition of the right

The Company grants the User, as a contractual matter and consistent with the right of withdrawal that Decreto Número 06-2003 provides for adhesion contracts, the right to withdraw from the contracting of the Services within the five (5) Business Days following its acceptance, without stating a reason, without penalty, and at no cost whatsoever. If a statutory period is more favorable to the User, that period will prevail.

32.2 Exercise and effects

Withdrawal is exercised through any of the channels in Clause 31.1. Once withdrawal has been exercised, the Company will close the Account and make available to the User the entirety of the User's Balance in accordance with Clause 20.6, without any deduction other than the fees corresponding to Transactions that the User actually ordered and that were carried out before the withdrawal.

32.3 Scope

The right of withdrawal applies to the contractual relationship and not to individual Transactions already carried out on the User's Instruction, which are governed by Clause 15.3, without prejudice to the reversal, refund, and Chargeback rights in Clauses 15.4, 17, and 18.

33. AMENDMENTS TO THESE TERMS AND CONDITIONS

33.1 Amendment right and its limits

The Company may amend these Terms and Conditions to reflect legal, regulatory, technical, or operational changes, or changes affecting the Operating Partners or the Services. This right shall not be exercised in an arbitrary or unexpected manner, or to the detriment of the User's rights, and it does not authorize the Company to unilaterally alter the essential content of the relationship or to avoid its obligations, in compliance with subparagraph a) of article 47 of Decreto Número 06-2003. Every amendment shall state its effective date and its version number.

33.2 Prior notice

Every material amendment shall be notified to the User no less than thirty (30) calendar days before it takes effect, by means of a prominent notice in the Application and by email to the registered address. The notice shall clearly identify the amended Clauses, describe the scope of the change, state the effective date, and make available to the User the full amended text together with a comparison (redline) version.

33.3 Amendments that reduce the User's rights

In the case of amendments that reduce the User's rights, increase the User's obligations, increase fees, or reduce transaction limits, they shall take effect as against the User only upon the User's express acceptance. Absent acceptance within the notice period, the User may continue under the version in force as of the User's most recent acceptance until the Account is closed, and mere continued use of the Services shall not be construed as acceptance of terms unfavorable to the User. Where the Company cannot operationally maintain the prior version, it shall allow the User to terminate the relationship pursuant to Clause 33.4, and this shall not relieve the Company of its obligation to return the Balance in full.

33.4 Right to terminate without penalty

A User who does not accept an amendment may terminate the relationship and close the Account, at any time and without penalty, with the right to the full return of the Balance pursuant to Clause 20.6.

33.5 Non-material amendments

In the case of corrections of clerical errors, clarifications that do not alter the meaning of an obligation, or changes that are favorable to the User, the amendment may take effect upon its publication in the Application, as so stated in the version notice.

33.6 No retroactive effect

Amendments shall have no retroactive effect to the User's detriment and shall not affect Transactions already carried out, claims in process, or rights already acquired under the prior version.

33.7 No automatic renewals

The Services do not give rise to subscriptions, memberships, recurring charges, or automatic renewals. If the Company offers in the future a service subject to automatic renewal, it shall disclose in advance, clearly and prominently, its price, its frequency, and its duration, shall obtain the User's express consent, shall give notice of each renewal no less than thirty (30) calendar days in advance, and shall permit cancellation at any time, without penalty, and by the same means through which the service was contracted. Renewal of the Visa Prepaid Card is governed by Clause 16.5.

33.8 Version history

The Company shall keep accessible within the Application the version history of these Terms and Conditions, together with the corresponding effective date, and shall retain the record of the version accepted by each User pursuant to Clause 5.3.

34. GOVERNING LAW AND DISPUTE RESOLUTION

34.1 Governing law

These Terms and Conditions are governed by and construed in accordance with the laws of the Republic of Guatemala. The obligations arising from them are commercial in nature and are governed by the Código de Comercio (the Guatemalan Commercial Code, Decreto 2-70) and, failing that, by the Código Civil (the Guatemalan Civil Code, Decreto Ley 106), pursuant to articles 1 and 694 of the Código de Comercio, and shall be construed in good faith, under the principle of la verdad sabida y la buena fe guardada set out in article 669 of the Código de Comercio and in accordance with article 1519 of the Código Civil, without prejudice to the protective character of consumer and user protection law.

34.2 Prior good faith negotiation

In the event of any dispute, the parties shall seek to resolve it in good faith through direct negotiation and through the channels described in Clause 31, within thirty (30) calendar days counted from written notice of the dispute. This prior negotiation is not a condition precedent to bringing an action and does not prevent the User from turning at any time to DIACO (the Guatemalan consumer protection authority) or to the competent courts pursuant to Clause 31.8.

34.3 Mechanisms before the consumer protection authority

The User fully retains the right to turn to DIACO and to exercise the mechanisms provided in article 78 of Decreto Número 06-2003, pursuant to Clause 31.9.

34.4 Venue and jurisdiction

For any dispute not resolved pursuant to the preceding Clauses, the parties submit to the jurisdiction of the competent courts of the Republic of Guatemala. It is expressly recorded that this submission does not deprive the consumer User of the right to sue before the competent judge of the User's own domicile, or of the right to turn to DIACO, rights that the User fully retains and does not waive by virtue of these Terms and Conditions. For the Company, this submission entails a waiver of any other venue that might correspond to it by reason of its domicile. This provision is highlighted in distinct characters in compliance with numeral 2o. of article 672 of the Código de Comercio.

34.5 Voluntary arbitration

The parties may, by express agreement adopted after the dispute has arisen, submit it to administered arbitration under the applicable Guatemalan legislation, seated in Ciudad de Guatemala and conducted in Spanish. Acceptance of these Terms and Conditions neither constitutes nor contains an arbitration agreement: arbitration requires in every case the subsequent and voluntary agreement of the User and does not deprive the User of the right to turn to DIACO or to the courts, or of any of the User's non-waivable rights under Decreto Número 06-2003.

34.6 Interim relief

Either party may request from the competent judicial authority such precautionary or urgent measures as may be necessary to protect its rights, without first having to exhaust the mechanisms of Clauses 31 and 34.2.

34.7 Limitation periods

Without prejudice to any special periods established by law, personal actions arising from these Terms and Conditions are subject to the general limitation period of five (5) years under article 1508 of the Código Civil, applicable in commercial matters by reference from article 694 of the Código de Comercio. Violations of consumer protection law are subject to a limitation period of three (3) years under article 104 of Decreto Número 06-2003. These Terms and Conditions do not shorten any statutory limitation period to the User's detriment.

34.8 Language of proceedings

The language of these Terms and Conditions and of any proceeding arising from them shall be Spanish.

35. GENERAL PROVISIONS

35.1 Entire agreement

These Terms and Conditions, together with the Fee Schedule, the limits table, and the specific terms of the Card incorporated pursuant to Clauses 1.3 and 5.8, constitute the entire agreement between the User and the Company with respect to the Services and supersede any prior contractual agreement or communication on that same subject matter. The Privacy Policy and the Cookie Policy are separate notices; the Site Terms constitute a separate agreement. No provision of this Clause reduces the User's non-waivable rights or excludes the binding effect of the Company's information or advertising.

35.2 Severability

If any provision of these Terms and Conditions is declared void, ineffective, or unenforceable, that shall not affect the validity of the remaining provisions, which shall remain in full force provided they are severable, pursuant to article 1308 of the Código Civil. The affected provision shall be replaced or construed in the manner that most closely approximates the parties' intent within the framework of the law and without prejudice to the User.

35.3 Assignment

The Company may assign its contractual position and the rights and obligations arising from these Terms and Conditions to companies of the UffPay group or to a universal or particular successor to its business, upon notice to the User no less than thirty (30) calendar days in advance and provided that the assignment does not diminish the User's rights or guarantees; a User who does not accept the assignment may terminate the relationship pursuant to Clause 33.4. The User may not assign the Account or the User's rights arising from these Terms and Conditions without the Company's prior written consent.

35.4 No waiver

Forbearance by either party, or the failure of either party to exercise a right or power, shall not constitute a waiver of that right or power, nor shall it prevent its later exercise.

35.5 Independence of the parties

These Terms and Conditions do not create any partnership, association, mandate, agency, franchise, or employment relationship between the User and the Company or UffPay.

35.6 No third party rights

Except as expressly provided in favor of UffPay Tech in Clauses 24 and 27, these Terms and Conditions confer no rights on third parties who are not party to them.

35.7 Governing language

The official and governing language of these Terms and Conditions is Spanish, pursuant to article 671 of the Código de Comercio. Any translation into another language is provided solely as a courtesy; in the event of any discrepancy between versions, the Spanish language version shall prevail.

35.8 Construction in favor of the User

In case of doubt, these Terms and Conditions shall be construed in the sense most favorable to the User, pursuant to article 49 of Decreto Número 06-2003, article 1600 of the Código Civil, and numeral 1o. of article 672 of the Código de Comercio, as provided in Clause 2.3.

35.9 Headings and exhibits

Headings are included solely for ease of reading. These Terms and Conditions contain no exhibits; the documents referred to in Clause 1.3 are incorporated by reference pursuant to Clause 5.8.

35.10 Survival

The following shall survive termination of the relationship, for such time as corresponds to their nature and to the law: Clauses 5.3, 5.5, 7.11, 8.6, 15.9, 17, 18, 20.5, 20.6, 21.5, 21.6, 23, 24, 26, 27, 31, 34, and this Clause 35.

35.11 Delivery of a copy

The Company makes available to the User, within the Application, a complete, legible, downloadable, and retainable copy of these Terms and Conditions, pursuant to article 50 of Decreto Número 06-2003.

35.12 Effective date and version

These Terms and Conditions are in force as of August 12, 2026 and correspond to Version 2026.4. They supersede Version 2026.3 and every prior version with respect to the Application and the Services, without affecting Transactions already carried out, claims in process, or rights acquired under a prior version, pursuant to Clause 33.6.

36. ACCEPTANCE

By checking a box that is not pre-checked, or by clicking an acceptance button after the full text has been presented, the User declares that the User has read, understood, and accepted these Terms and Conditions and has the legal capacity to be bound. The Fee Schedule, the limits table, and the specific terms of the Card shall be incorporated only where they have been made available to the User in full, accessibly, and in advance, and where the corresponding acceptance has been obtained. The Privacy Policy and the Cookie Policy are provided as separate notices; their receipt or review does not amount to a joint contractual acceptance and does not replace the specific Consents that may apply. The Company shall retain a record of the version, date, time, and affirmative action taken pursuant to Clause 5.3. To use the Site, the User must separately accept the Site Terms.

UFFPAY, SOCIEDAD ANÓNIMA · Carretera a El Salvador 1-16, Apartamento 1, Fraijanes, Guatemala · NIT 120263173 · www.uffpay.com · support@uffpay.com · legal@uffpay.com · Version 2026.4 · In force since August 12, 2026

ANNEX A. UNITED STATES REMITTANCE DISCLOSURES

This Annex A applies to any remittance transfer that you request from a State of the United States of America, the District of Columbia or a United States territory, primarily for personal, family or household purposes. It states rights that United States federal law gives you, specifically the Electronic Fund Transfer Act and Regulation E, subpart B (12 C.F.R. sections 1005.30 to 1005.36). Those rights apply whether or not they are repeated here, and they prevail over any conflicting provision of these Terms and Conditions.

A.1 Which rules apply to your transfer

The federal remittance rules apply when the transfer is requested by a consumer in the United States, is sent to a recipient in another country and is made primarily for personal, family or household purposes. They do not apply to transfers of fifteen United States dollars (US$15.00) or less, or to transfers requested for business or commercial purposes. Where the remittance transfer provider for your transfer is a third party rather than UffPay, that provider is identified on the disclosure you receive before you pay, and that provider is responsible for the obligations described in this Annex A.

A.2 The disclosures you receive

Before you pay for a remittance transfer you receive a disclosure that states the transfer amount, the fees and taxes we charge, the total you pay, the exchange rate, any covered fees charged by other parties and the total amount the recipient will receive. When you pay, you receive a receipt with the same figures, plus the date the funds will be available to the recipient, the recipient's details as you supplied them, and how to contact us and the authorities. If you ask for it, we will promptly give you a longer written notice that describes your error resolution and cancellation rights in full.

A.3 Your right to cancel and obtain a refund

• You may cancel a remittance transfer for a full refund if you ask us to cancel within thirty (30) minutes after you make or authorize payment, and the funds have not already been picked up by the recipient or deposited into the recipient's account.
• If you scheduled the transfer at least three (3) business days before the date on which it is to be sent, you may instead cancel it by telling us at least three (3) business days before that date.
• Your request may be oral or written. It must give us enough information to identify you and the transfer, such as your name and your address or telephone number, and the confirmation number of the transfer.
• When you cancel, we refund the total amount you paid, including all fees and, to the extent not prohibited by law, taxes, at no additional cost to you, within three (3) business days of receiving your request.

A.4 Your right to dispute an error

Tell us within one hundred eighty (180) days after the date we disclosed that the funds would be available to the recipient. If your notice is based on documentation, information or clarification that you asked us for, you have until the later of that date or sixty (60) days after we send you what you requested. You may tell us orally or in writing, through the Application, by telephone or at support@uffpay.com.

• Give us your name and your telephone number or address, the recipient's name and, if you know them, the recipient's telephone number or address, and enough detail to identify the transfer.
• Tell us why you believe there is an error and, so far as you can, the type, date and amount of the error.
• An error includes an incorrect amount paid by you, a computational or bookkeeping mistake, the recipient receiving less than the amount we disclosed, our failure to make the funds available by the date we disclosed, and our failure to give you documentation or information you requested.
• We will investigate and determine whether an error occurred within ninety (90) days of receiving your notice, and we will tell you the result within three (3) business days after we finish. If we find no error, we will send you a written explanation, and you may ask for copies of the documents we relied on.
• We do not charge you anything for any part of the error resolution process.

A.5 How we correct an error

• Where you paid an incorrect amount, we made a computational or bookkeeping mistake, or the recipient received less than we disclosed, you choose whether we refund you the amount needed to resolve the error or make that amount available to the recipient at no additional cost to you or to the recipient.
• Where the funds were not available by the date we disclosed, you choose between a refund and resending the amount at no additional cost, and in either case we also refund the fees you paid and, to the extent not prohibited by law, the taxes collected on the transfer.
• Where the funds were not available on time because you gave us incorrect or insufficient information, we refund the amount within three (3) business days of giving you our report, and we may deduct fees and taxes actually charged by others on the failed attempt, but never our own fee.
• If you give us an incorrect account number or an incorrect identifier for the recipient's institution, you could lose the amount of the transfer. We will use reasonable efforts to recover it, and the conditions set by federal law determine whether the loss falls on you.

A.6 These rights cannot be waived

United States federal law prohibits any agreement that waives a right or a cause of action it creates. Nothing in these Terms and Conditions, including the provisions on the finality of Transactions, claim deadlines, governing law, forum, arbitration and limitation of liability, reduces, shortens or conditions the periods and rights stated in this Annex A for a remittance transfer requested from the United States. Where a provision of the main body conflicts with this Annex A, this Annex A governs. Where the law of a State of the United States gives you greater protection than federal law, that State law also continues to apply.

A.7 Language

We provide these disclosures in English and in Spanish. Where you conduct the transaction with us in Spanish, or assert an error with us in Spanish, you receive them in Spanish as well as in English. The English and Spanish versions of this Annex A carry the same content. If they differ in the description of a right conferred by United States federal law, the version that gives you the greater protection applies.

A.8 Questions and complaints

For questions or complaints about a remittance transfer, contact UffPay through the Application or at support@uffpay.com. You may also contact the State agency that licenses or charters the remittance transfer provider for your transfer; that agency is identified, with its telephone number and website, on the receipt you receive when you pay. You may contact the Consumer Financial Protection Bureau at any time.

• Consumer Financial Protection Bureau
• 855-411-2372
• 855-729-2372 (TTY/TDD)
• www.consumerfinance.gov