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End-User Terms of Service

Operated by Parnasa Heritage Planning Holding Corp.

Effective: 15 June 2026

1. Introduction

These Terms of Service (the "Terms") govern your use of the Zanvil platform (the "Platform") operated by Parnasa Heritage Planning Holding Corp. ("Zanvil", "we", "our"), a company incorporated in Saint Kitts and Nevis (Company No. C 63753), with registered office at Unit #5, Long Stone House, P.O. Box 1200, Main Street Charlestown, Saint Kitts and Nevis.

By creating an account, accessing or using the Platform, you (the "End-User") agree to be bound by these Terms.

2. Relationship with BVNK and Lead Bank

The Platform delivers embedded financial services made available by Zanvil's partner System Pay Services (US), Inc. ("BVNK") and, where applicable, by Lead Bank (Kansas City, Missouri). Zanvil acts as a technology and operational service provider only; Zanvil is not a bank, money services business or financial institution.

To use the BVNK Services and Lead Bank services, you must separately accept:

Those agreements govern your contractual relationship with BVNK and Lead Bank. In the event of conflict between these Zanvil Terms and the BVNK or Lead Bank terms with respect to the BVNK or Lead Bank services, the BVNK or Lead Bank terms (as applicable) prevail.

3. Eligibility

3.5 Initiative (Reverse Enquiry)

3.6 Restriction on individual U.S. residents

The Platform is offered on a business-to-business basis. Eligibility is restricted to corporate clients (limited liability companies, corporations and other entities) and to natural persons resident outside the United States. Zanvil does not open accounts for individual residents of the United States. Entities formed under U.S. law are eligible subject to the standard onboarding; their ultimate beneficial owners may be of any nationality including U.S. persons.

4. The Services

Through the Platform, eligible End-Users may, subject to BVNK approval:

4.4 Availability of Services

The specific BVNK Services available to you depend on (i) your jurisdiction of residence and (ii) whether BVNK holds a money-transmitter license in your state. In U.S. states where BVNK does not hold a money-transmitter license, certain services may be routed through Lead Bank (Kansas City, Missouri) or Paxos Trust Company, LLC, in which case you will enter into a separate agreement with that provider. Available services are displayed in the Platform during onboarding.

5. Fees

Zanvil's fees are displayed in the in-product pricing screen and shown to you before each transaction. Conversion rates include a markup that constitutes part of Zanvil's compensation; the markup is part of the price and is not itemised separately in the rate quotation. The All-In Rate shown to you in the Platform before each conversion is the only rate applicable. By confirming the conversion you accept the All-In Rate then quoted. Network fees (blockchain fees, ACH, Fedwire, FedNow, RTP, SWIFT) are passed through at cost and shown to you before each transaction. BVNK and Lead Bank may apply their own fees as set out in their respective terms; those are not Zanvil fees. Zanvil may amend its fees and rates from time to time; the rate or fee applicable to any individual transaction is the rate or fee displayed and confirmed by you at the time of that transaction.

6. Administrator Authorization (Optional)

6.1 Optional

You are not required to authorize an Administrator. Many End-Users operate their account directly and never authorize one. This Section 6 applies only if and when you choose to authorize an Administrator.

6.2 How a Mandate is granted

An Administrator may send you a request through the Platform. By confirming that request, you grant the Administrator an Administrator Authorization Mandate (the “Mandate”) to operate your account on your behalf. The Mandate takes effect only upon your confirmation; you are never assigned an Administrator without your express acceptance. The Administrator is your agent, not Zanvil’s, and Zanvil does not employ, supervise or guarantee the Administrator.

6.3 Authority

The Mandate grants the Administrator general authority to operate your account on your behalf — including viewing balances, transaction history and statements; initiating payments to third-party beneficiaries; adding and managing beneficiaries; requesting currency conversions; and submitting documentation supporting specific transactions. The Administrator may not: (a) direct or route any payment to the Administrator, or to any account or wallet held in the Administrator’s name or controlled by the Administrator, directly or indirectly; (b) modify your security settings (email, telephone, MFA, devices); (c) close, transfer or assign your account; (d) designate sub-administrators or share credentials; or (e) amend or revoke the Mandate (only you may).

6.4 Revocation

You may revoke the Mandate at any time, with immediate effect, through the Platform. Until revocation, instructions submitted by the Administrator within the scope of the Mandate are binding on you as if you had submitted them yourself.

6.5 Your responsibility

You are responsible for every instruction issued under your account and your credentials, whether by you or by your Administrator, except in the case of unauthorized access reported to Zanvil promptly upon discovery. You are responsible for choosing and, where appropriate, revoking your Administrator.

6.6 Acceptance per transaction

Each instruction submitted through the Platform by you or by your Administrator, and each rate quotation confirmed, constitutes your acceptance of the relevant transaction terms and of any then-current network and conversion fees displayed to you or to your Administrator.

7. Acceptable Use

You shall not use the Platform:

8. Suspension and Termination

Zanvil may suspend or terminate your access to the Platform with immediate effect where required by law, regulator direction, BVNK direction, or where it reasonably believes you are in breach of these Terms or pose a financial-crime, security or operational risk. You may terminate by closing your account through the Platform, provided all funds have been withdrawn and outstanding fees are paid.

8.1 BVNK-directed suspension or termination

Where BVNK has suspended or terminated your access to the BVNK Services for any reason permitted under the BVNK U.S. Terms of Service — Embedded Wallets or applicable BVNK policy, Zanvil shall mirror the suspension or termination on the Zanvil Platform as required by Service Schedule 3, Annex 1 (Technology Services — Access). Zanvil shall give you notice consistent with BVNK's notice obligations to you and shall not be liable for losses arising from such mirrored action, except in cases of Zanvil's own fraud, gross negligence or wilful misconduct.

8.2 Account closure mechanics

Closure of a Fiat Virtual Account or Digital Asset Wallet is permanent and cannot be reversed. Before closure, all funds must be withdrawn: fiat balances via the available payment rails (ACH, Fedwire, FedNow, RTP, SEPA, SWIFT) to a nominated external bank account; digital assets to an external on-chain address you control. In exceptional circumstances (regulatory or compliance obligation), Zanvil and BVNK may close an account that still holds funds; in such case, fiat funds are returned to the originating source or to a nominated external bank account, and digital assets are returned to a designated wallet address (subject to the permanence of blockchain addresses and applicable law). No closure fee or dormancy fee is charged by Zanvil.

9. Liability

To the maximum extent permitted by law, Zanvil's total aggregate liability to you arising out of or in connection with these Terms shall not exceed the greater of (i) USD 1,000 or (ii) the total fees you paid to Zanvil in the one (1) month preceding the event giving rise to the claim. Zanvil shall not be liable for indirect, incidental, consequential, special, exemplary or punitive damages, or for lost profits or lost data. The foregoing cap shall not apply to Zanvil's fraud, gross negligence or wilful misconduct, or to any liability that cannot lawfully be excluded under the laws applicable to your residence.

9.1 Specific risk disclaimers

Without limiting the generality of the foregoing, Zanvil shall not be liable for any losses arising from: (i) acts, omissions or failures of BVNK, Lead Bank, Paxos or any other BVNK Service Partner; (ii) volatility, depreciation or loss of value of any digital asset (including stablecoins); (iii) sanctions, anti-money-laundering or fraud-prevention blocks or holds carried out in good faith and consistent with applicable law; (iv) decisions made by BVNK regarding the onboarding, suspension, refusal, restriction or termination of an End-User; or (v) blockchain failures, network congestion, forks, protocol changes or third-party hacks affecting any on-chain transaction.

10. Privacy

Zanvil processes personal data in accordance with the Zanvil Privacy Notice, incorporated into these Terms by reference and available at zanvil.app/privacy. Personal data is also processed by BVNK under the BVNK Privacy Policy (available at help.bvnk.com), the BVNK Data Protection Addendum, and by Lead Bank under the Lead Bank Privacy Policy and the GLBA Privacy Notice.

11. Communications and electronic delivery

You consent to electronic delivery of all notices, agreements and disclosures from Zanvil and from BVNK / Lead Bank as their respective terms provide. Zanvil shall communicate with you exclusively through the Platform and through the email address and phone number you register at onboarding (the "authenticated channel"). High-risk requests (security setting changes, mandate revocation, account closure) are processed only through the authenticated channel with step-up authentication.

12. Changes to the Terms

Zanvil may amend these Terms by posting a revised version and giving you at least thirty (30) days' notice (or shorter notice where required by law or to address a security risk). Continued use after the effective date constitutes acceptance.

13. Governing Law and Dispute Resolution

13.1 Governing law

If you are an entity formed under U.S. law (e.g., a U.S. limited liability company or corporation), these Terms are governed by the laws of the State of Delaware, without regard to conflict-of-laws principles. For all other End-Users, these Terms are governed by the laws of Saint Kitts and Nevis.

13.2 Arbitration

If you are an entity formed under U.S. law, any dispute arising out of or in connection with these Terms shall be resolved by binding arbitration administered by Judicial Dispute Resolution LLC under the AAA Rules, conducted in San Francisco, California, on an individual basis only. For all other End-Users, any dispute shall be resolved by binding arbitration administered by an arbitral institution to be agreed by the parties, in the English language, on an individual basis.

13.3 Class action waiver

You waive any right to participate in any class action or representative proceeding, irrespective of forum.

13.4 No effect on third-party agreements

This Section does not affect the separate dispute-resolution provisions in the BVNK U.S. Terms of Service or the Lead Bank Terms and Conditions.

14. Miscellaneous

15. Complaints

The primary channel for any complaint relating to the Platform or to Zanvil-provided services is complaints@zanvil.app. Failure to use the Zanvil complaint channel as primary may delay resolution, as Zanvil holds the operational records of your account. Complaints relating specifically to services provided by BVNK or Lead Bank may also be raised directly with those providers; in such case BVNK and Lead Bank may, at their discretion, re-route the complaint to Zanvil for handling.

By creating an account, you confirm that you have read, understood and agreed to these Terms.

ZANVIL is a technology and integration layer; payment, custody and account services are provided through regulated partner institutions. Digital asset values can fluctuate. © 2026 Zanvil. All rights reserved.