Modveon Terms of Service

Verified participation in national, municipal, and user-generated communities; access to official government announcements and content; civic polls; the AI-powered complaint center; and related civic engagement tools.

We may introduce additional features and services over time. Material additions are subject to the change notification procedures in Section 19.

You must be at least 18 years of age to create an account or use the Services. By creating an account, you represent and warrant that you are at least 18 years old.

Account creation requires government-issued identity verification through the applicable national identity system — the Registro Nacional de las Personas Naturales ("RNPN") in El Salvador, or the equivalent system in your jurisdiction. Each government-issued identification document corresponds to a single user account. Duplicate or shared accounts are prohibited.

If you are accessing the App from the United States, you must be a citizen of El Salvador holding a valid Documento Único de Identidad ("DUI"). In addition to RNPN identity verification, you may be required to complete identity verification through Coinbase's Know Your Customer ("KYC") process to access on-ramp and off-ramp financial features.

The Services are not available to persons in jurisdictions where the Services are prohibited or restricted by applicable law. By using the Services, you represent and warrant that:

• (a) You are not located in, a national or resident of, or under the control of any jurisdiction subject to comprehensive sanctions administered by the U.S. Office of Foreign Assets Control ("OFAC"), the United Nations Security Council, or any applicable government sanctions authority;
• (b) You are not named on the OFAC Specially Designated Nationals and Blocked Persons List, the U.S. Commerce Department's Entity List, or any comparable restricted party list maintained by a relevant government authority; and
• (c) Your use of the Services does not violate any applicable export control or economic sanctions laws.

You must have the legal capacity to enter into a binding contract under the laws of your jurisdiction.

Account creation occurs exclusively through government identity verification as described in Section 4. By registering, you authorize us to verify your identity and retrieve your profile information from the applicable government identity database. Information retrieved from government databases is treated as authoritative for account creation and community assignment purposes.

If your identity cannot be verified against the applicable government database, access to the Services will be denied. Errors in your government identity record must be corrected directly through the applicable government authority (such as the RNPN in El Salvador). We have no ability to modify, override, or substitute government identity records.

By creating an account, you consent to receive disclosures, notices, and communications from us electronically, including by in-app notification, email, or WhatsApp message to the contact information you have provided. Electronic disclosures satisfy any legal requirement that such disclosures be provided in writing. You may withdraw this consent by closing your account, although doing so will prevent you from using the Services.

You are responsible for maintaining the security of your device and all credentials used to access the App, and are fully responsible for all activity that occurs under your account. You must not share your login credentials or allow unauthorized access to your account. Notify us immediately at support@modveon.com if you become aware of any unauthorized access to or use of your account. We are not liable for loss or damage arising from unauthorized access resulting from your failure to maintain adequate security.

Each government-issued identity document corresponds to one platform account. We reserve the right to suspend or terminate duplicate accounts without prior notice.

The Modveon platform separates money movement into two distinct steps:

Domestic peer-to-peer transfers between Modveon users in the same country are not subject to a Platform Access Fee.

Transactions processed on the Base blockchain network may incur network fees ("gas fees"). Gas fees are absorbed by Modveon and will not be charged to you as a separate line item.

We will provide at least 30 days' advance notice of any material change to the Platform Access Fee before it takes effect. Notice will be delivered through in-app notification and to your registered contact. Your continued use of the Services after the effective date of any fee change constitutes your acceptance of the revised fee. If you do not accept a material fee change, you may close your account before the change takes effect at no penalty.

• (g) Error Resolution. If you believe a transfer was executed in error or without your authorization, please contact us immediately at support@modveon.com. We will investigate and provide a written response within a reasonable timeframe. The remedies available are subject to the technical and operational limits of self-custodial blockchain transactions described in Section 7.

You may cash-off through our authorized agent network. In El Salvador, cash off-ramp services are available through authorized agent locations and Transfer365 bank withdrawal services. Applicable fees, transaction limits, and availability are displayed in the App prior to initiating a cash off-ramp transaction.

All transactions are subject to daily, weekly, and cumulative limits established by us, our partners, and applicable law. Current limits are available at modveon.com/fees and may be updated from time to time.

We reserve the right to refuse, delay, or reverse any transaction that we reasonably believe violates these Terms, applicable law, our AML/CFT policies, or that is identified by our compliance screening systems. We will not be liable for any loss arising from a refused or delayed transaction where such refusal or delay was required by law or our compliance obligations.

Your civic participation on the platform is tied to your verified identity. Upon account creation, you are automatically assigned to national and municipal communities based on the address in your verified government identity record. Community assignments reflect your government-verified information and cannot be manually overridden.

You may participate in national and municipal communities and, where eligible, create or join user-generated communities ("UGCs") at the municipal or district level. Each community may have rules established by its creator, subject to these Terms and applicable law. We may intervene in or delete any community that violates applicable law, these Terms, or government directives.

You may participate in civic polls within communities for which you are eligible. Poll results are withheld from all participants until the poll closes. You will receive an in-app notification when poll results become available. We maintain records of poll participation as required by applicable law and our platform governance obligations.

The in-app complaint center allows you to submit complaints or civic reports to relevant community authorities or government officials. Complaint routing is performed using automated AI-powered systems, subject to audit trails and human oversight. We do not guarantee any particular outcome or government response to complaints submitted through the platform.

Certain platform features — including complaint routing, content management assistance, and community governance tools — use artificial intelligence and automated systems. Where automated systems materially affect your access to platform features, you may contact us at support@modveon.com to request information about the basis of any automated decision.

Authorized government officials may post in their official capacity within designated communities. Such content represents the views of the relevant official or government body and not those of Modveon. We do not verify the accuracy or completeness of government-sourced content and accept no liability for it.

Government officials using the platform in an official capacity ("Official Users") are designated through an official credentialing process. Official User status grants elevated platform permissions as described in this Section.

Official Users may:

• (a) Post content in their official capacity within designated communities and, where authorized, at the national level;
• (b) Access platform management and community oversight tools within their designated scope of authority; and
• (c) Access platform dashboards and complaint routing information relevant to their official functions, subject to applicable data protection requirements.

Official Users are responsible for ensuring their use of the platform complies with all applicable laws, government ethics rules, and official conduct requirements. Official Users must not use elevated permissions for personal purposes or beyond their designated scope of authority.

Official Users are solely liable for content posted in their official capacity. We do not assume liability for content posted by Official Users in the performance of their government functions.

We reserve the right to revoke Official User status at any time, with notice to the relevant government authority, where an Official User has violated these Terms or applicable law, or where revocation is required by regulatory or governmental directive.

You retain ownership of posts, comments, images, and other materials you submit through the App ("User Content"). By submitting User Content, you grant us a perpetual, worldwide, non-exclusive, royalty-free license to host, display, distribute, reproduce, and use that content for the operation, improvement, and compliance purposes of the Services.

User Content must comply with all applicable laws and these Terms. Prohibited content includes but is not limited to: false or misleading information; hate speech or content promoting discrimination; harassment, threats, or defamatory material; incitement to violence; obscene or indecent content; content infringing third-party intellectual property rights; and content impersonating government officials, other users, or any other person.

Content shared in communities is visible to eligible members of those communities. Do not post private, confidential, financially sensitive, or personally identifiable information of others in community posts or public channels.

We and designated community managers may review, restrict, remove, or take other action with respect to User Content that violates these Terms or applicable law. Government Super Managers designated by applicable government authorities may exercise manager authority within their designated scope. Material management actions are logged.

Any user may report content believed to violate these Terms using the in-app reporting function. Reports are reviewed in good faith and may result in content removal, account restriction, temporary suspension, permanent termination, or referral to relevant authorities.

We operate an anti-money laundering and counter-terrorism financing compliance program in accordance with applicable law. All transactions conducted through the platform are subject to monitoring by our compliance systems, including transaction monitoring and sanctions screening performed by third-party analytics tools. By using the Services, you consent to this monitoring.

We screen users and transactions against the OFAC Specially Designated Nationals and Blocked Persons List, the United Nations Security Council sanctions list, and other applicable government sanctions lists using automated screening tools. Transactions identified as potentially involving sanctioned persons, entities, or jurisdictions may be delayed, blocked, reported to relevant authorities, or reversed without prior notice to you.

We are required by applicable law to report certain transactions and suspicious activity to government authorities. This includes reports to the Financial Intelligence Unit ("UIF") in El Salvador and to the Financial Crimes Enforcement Network ("FinCEN") in the United States. By using the Services, you acknowledge these reporting obligations and consent to the submission of required reports.

We may disclose your information and transaction records to government authorities or law enforcement agencies in response to a valid court order, subpoena, warrant, or other lawful legal process, or where we reasonably believe disclosure is necessary to prevent imminent harm, fraud, or illegal activity. We maintain distinct processes for responding to legal process affecting our application-layer controls and for matters involving our infrastructure partners.

We may request additional information or documentation from you at any time to verify your identity, the source of your funds, or the purpose of any transaction. Failure to provide requested information within a reasonable timeframe may result in restriction or termination of your access to the Services.

We may suspend or terminate your account, with or without prior notice, if we reasonably determine that:

• (a) You have violated these Terms or any applicable law;
• (b) Your activity poses a material security, compliance, legal, or reputational risk to the Services or to us;
• (c) We are required to do so by a valid court order, regulatory requirement, or government directive; or
• (d) Continued operation of your account would expose us, our partners, or our users to unacceptable legal or regulatory risk.

Suspected fraudulent, abusive, or illegal activity may be referred to law enforcement authorities. If your account is terminated for any reason, you (i) remain bound by these Terms, (ii) must immediately cease using the Services, and (iii) acknowledge that licenses granted to you under these Terms are terminated.

For Modveon-initiated closures that are not required by legal or regulatory obligation, we will provide at least 30 days' advance written notice before your account is closed, delivered through in-app notification and to your registered contact.

Upon account closure, whether initiated by you or by us:

We may suspend or terminate all or part of the Services immediately and without penalty if required or directed to do so by a government or regulatory authority. In such cases, our sole obligation is to provide as much advance notice as practicable under the circumstances and to assist you in accessing your private key and exporting your stablecoin through available means.

Sections 6, 7.2, 11.1, 13, 15, 16, 17, 18, 19, and 21 survive any termination or expiration of these Terms.

Certain Services are provided through or in connection with third-party partners, including:

• (b) Bill pay network in El Salvador;
• (c) Cash on-ramp and cash off-ramp agent in El Salvador;
• (d) Bank withdrawal services in El Salvador;
• (e) Payment processing services;
• (f) AML/CFT compliance monitoring and sanctions screening; and
• (g) Virtual card services, where available.

Your use of third-party services may be subject to additional terms and conditions imposed by those parties. Please review any applicable third-party terms before using those services. We are not responsible for the acts or omissions of third-party partners beyond what is expressly required by these Terms or applicable law.

We do not guarantee the continuous availability of any third-party service. Interruptions or changes to third-party services may temporarily or permanently affect certain platform features. We will endeavor to provide notice of material third-party service changes where practicable.

All rights, title, and interest in and to the Modveon platform — including its source code, architecture, databases, interfaces, design, logos, trademarks, the Sivar brand, and content — belong exclusively to Modveon Inc. and its licensors and are protected by applicable intellectual property laws. These Terms do not transfer any ownership interest in the platform or any of its components to you.

We grant you a personal, limited, non-exclusive, non-transferable, revocable license to access and use the App solely for lawful purposes in accordance with these Terms.

You must not: copy, modify, distribute, sell, or create derivative works from the App or its content; reverse-engineer, decompile, or attempt to extract source code; remove or alter any copyright, trademark, or proprietary notice; or use Modveon or Sivar trademarks or branding without our prior written consent.

If you provide feedback, suggestions, or ideas regarding the Services, you grant us a perpetual, irrevocable, worldwide, royalty-free license to use that feedback for any purpose without compensation or obligation to you.

The Services are provided on an "as is" and "as available" basis without warranties of any kind. We do not warrant that the Services will be uninterrupted, error-free, secure, or available at any particular time or location.

To the maximum extent permitted by applicable law, we disclaim all warranties, express, implied, or statutory, including implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement.

To the fullest extent permitted by applicable law, our total aggregate liability to you for any claim arising from or related to these Terms or the Services — regardless of the theory of liability — is limited to the greater of:

• (a) the total Platform Access Fees paid by you in the twelve (12) months immediately preceding the event giving rise to the claim; or
• (b) USD $50.

We are not liable under any circumstances for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, data, goodwill, or business opportunity, even if we have been advised of the possibility of such damages.

Nothing in this Section limits our liability for: (i) fraud or fraudulent misrepresentation; (ii) gross negligence or willful misconduct; (iii) death or personal injury caused by our negligence; or (iv) any other liability that cannot be excluded or limited under applicable law. In El Salvador, consumer protection laws may provide additional rights that cannot be waived; the El Salvador Country Addendum governs to the extent of any conflict.

You acknowledge that the limitations of liability in this Section reflect a reasonable and negotiated allocation of risk between the parties and are an essential element of the basis of the bargain between you and us. The Platform Access Fee would be higher without these limitations.

These Terms, together with the applicable Country Addendum, the Privacy Policy, and any applicable product-specific disclosures, constitute the entire agreement between you and us regarding the Services and supersede all prior agreements, representations, and understandings.

If any provision of these Terms is held to be invalid, illegal, or unenforceable under applicable law, that provision will be modified to the minimum extent necessary to make it enforceable, or if modification is not possible, severed from these Terms, without affecting the validity or enforceability of the remaining provisions.

Our failure or delay in exercising any right or remedy under these Terms does not constitute a waiver of that right or remedy. A waiver of any breach does not constitute a waiver of any subsequent breach.

We may assign or transfer our rights and obligations under these Terms to an affiliate, successor, or acquirer without your consent, provided that the assignee assumes all obligations under these Terms. You may not assign or transfer your rights or obligations under these Terms without our prior written consent.

We are not liable for any failure or delay in performance caused by circumstances beyond our reasonable control, including natural disasters, pandemics, acts of war or terrorism, governmental or regulatory actions, power or telecommunications failures, blockchain network failures, or actions or failures of third-party service providers.

These Terms do not create a partnership, joint venture, agency, franchise, or employment relationship between you and us.

These Terms are made in the English language. In the event of any conflict between the English version and any translation, the English version prevails, except where applicable law in a specific jurisdiction requires otherwise.

For support, legal notices, or privacy inquiries:

• Modveon (operated by Modveon Payments LLC in the US and Modveon El Salvador, S.A.S. de C.V. in El Salvador)
• Email: support@modveon.com
• Website: modveon.com
• El Salvador: sivarapp.sv

You have rights as a consumer under the Ley de Protección al Consumidor (LPC) that exist independently of and cannot be limited by any contract. Nothing in these Terms, the Master Terms, or any agreement with Modveon El Salvador limits or excludes rights granted to you by the LPC or any other applicable Salvadoran consumer protection law.

You have the right to receive clear, complete, truthful, and timely information about the Services, all applicable fees, and your rights before committing to any transaction. We will never charge you a fee that was not disclosed to you before the relevant transaction was confirmed.

If we make any material change to fees, the scope of Services, or these Terms, you have the right to close your account and export your private key at no penalty at any time before the change takes effect. See Section ES-7 for notice requirements.

These Terms and all user-facing disclosures are provided in Spanish. Any ambiguity in these Terms shall be interpreted in the manner most favorable to you as the consumer, in accordance with the LPC.

Mandatory pre-dispute arbitration clauses are not enforceable against consumers under Salvadoran law. Notwithstanding anything to the contrary in the Master Terms, you are not required to submit any dispute with Modveon El Salvador to arbitration. You retain the right to bring claims before the Defensoría del Consumidor or the competent Salvadoran courts at any time.

You have the unrestricted right to submit complaints about our Services to the Defensoría del Consumidor at any time, without prior exhaustion of any internal complaint process. The Defensoría del Consumidor may be reached at:

• Website: defensoria.gob.sv
• National Hotline: 910

We encourage you to first contact us through the in-app complaint center or at support@modveon.com to resolve disputes directly. We will acknowledge all complaints promptly and provide a substantive written response within a reasonable timeframe. Use of our internal complaint process does not waive or delay your right to contact the Defensoría del Consumidor at any time.

Disputes that cannot be resolved through informal negotiation or the Defensoría del Consumidor process shall be submitted to the competent courts of the Republic of El Salvador. We consent to the jurisdiction of the competent Salvadoran courts for all disputes arising from your use of the Services in El Salvador.

Modveon El Salvador operates an anti-money laundering and counter-terrorism financing ("AML/CFT") compliance program in accordance with applicable Salvadoran law. All transactions on the Modveon platform in El Salvador are subject to AML/CFT monitoring. By using the Services, you consent to this monitoring.

We are legally required to submit the following reports to the Financial Investigation Unit of El Salvador ("UIF"):

• (a) Reporte de Operaciones en Efectivo (ROE): (i) cash transactions conducted in a single day, or aggregated over the course of one month, that amount to USD 10,000 or more must be reported to the UIF within five business days following the date of the transaction or, in the case of monthly aggregated transactions, within five business days following the end of the corresponding month; (ii) transactions conducted through means other than cash, including checks and credit or debit cards, carried out in a single day or aggregated over the course of one month, that amount to USD 25,000 or more must be reported to the UIF within five business days following the date of the transaction or, in the case of monthly aggregated transactions, within five business days following the end of the corresponding month; and (iii) digital asset transactions equal to or exceeding USD 1,000, or its equivalent in legal tender, must be reported to the UIF within five business days following the date of the transaction.
• (b) Reporte de Operaciones Sospechosas (ROS): we must report transactions or patterns of activity we reasonably suspect involve money laundering, terrorism financing, or other financial crimes, regardless of transaction amount.

You acknowledge that submission of these reports is a legal obligation imposed on us by Salvadoran law. Filing a report does not constitute an accusation or finding of wrongdoing against you.

Where required by applicable AML/CFT law or a competent government authority, we may freeze or block transactions, suspend account access, or take other remedial measures without prior notice to you. We will notify you as promptly as legally permissible following any such action.

Under the Ley de Protección de Datos Personales of El Salvador, you have the following rights with respect to your personal data processed by Modveon El Salvador:

• (a) Right of Access (Derecho de Acceso). You may request information about what personal data we hold about you, how it is used, and with whom it is shared.
• (b) Right of Rectification (Derecho de Rectificación). You may request correction of any inaccurate or incomplete personal data we hold about you.
• (c) Right of Erasure (Derecho de Cancelación / Supresión). You may request deletion of your personal data, subject to our legal obligations to retain certain records. AML/CFT laws require us to retain transaction records and identity data for a minimum period; those records cannot be erased on request.
• (d) Right to Portability (Derecho de Portabilidad). You may request your personal data in a structured, commonly used, and machine-readable format.
• (e) Right to Object (Derecho de Oposición). You may object to certain processing of your personal data where that processing is not required by law or is not necessary for the performance of our agreement with you.
• (f) Right to Limitation (Derecho de Limitación). You have the right to request the restriction of the processing of your personal data, in accordance with the provisions set forth under the LPDP.

To exercise any of these rights, submit a request to support@modveon.com. We will respond within twenty (20) business days, which may be extended for justified reasons by up to an additional twenty (20) business days.

Consistent with the LPDP's opt-in model, we process your personal data only on the basis of:

• (a) your explicit, informed, free, and unambiguous consent, obtained at account creation and at relevant points in the Services;
• (b) the performance of our contractual obligations to you under these Terms; or
• (c) our legal obligations under applicable Salvadoran law, including AML/CFT and CNAD requirements.

You may withdraw consent at any time by contacting us at support@modveon.com. Withdrawal of consent may limit or prevent your ability to use the Services.

Your personal data is processed and stored on servers located in the United States. By using the Services and creating a Sivar account, you explicitly consent to the transfer of your personal data to the United States for processing in accordance with this Addendum and the Modveon Privacy Policy. We maintain contractual and technical safeguards designed to protect your data in transit and at rest.

Questions, concerns, or requests regarding the processing of your personal data may be directed to support@modveon.com.

We retain your personal data only as long as necessary to provide the Services, comply with applicable legal obligations, and resolve disputes. AML/CFT records are retained for a minimum of fifteen (15) years from the date of the relevant transaction. For a full description of our data retention practices, see the Modveon Privacy Policy at modveon.com/privacy.

We share your personal data with the following categories of authorized sub-processors that assist in delivering the Services: cloud infrastructure providers (GCP); compliance and transaction monitoring providers (Hawk.ai / Scorechain); communication service providers (SendGrid, WhatsApp); and analytics providers (PostHog). A current list of sub-processors is maintained at modveon.com/sub-processors.

A valid Documento Único de Identidad ("DUI") is required to create a Sivar account in El Salvador. Your DUI is used to verify your identity, assign you to your national and municipal communities, and fulfill our AML/CFT obligations.

We verify your DUI information against the Registro Nacional de las Personas Naturales ("RNPN"). Information retrieved from the RNPN — including your full name, profile photograph, municipality, and district of residence — is authoritative for account creation and community assignment purposes.

If your DUI cannot be verified against the RNPN, access to the Services will be denied. Errors in RNPN records must be corrected directly through the RNPN. Modveon El Salvador has no authority to modify government identity records.

Your community assignment is based on the address in your DUI record. If your DUI address is outdated, your access will be limited to the national community until your address is updated through the RNPN and re-verified through the App.

The primary channel for submitting service complaints in El Salvador is the in-app complaint center, accessible through the Sivar application. All complaints are logged, timestamped, and tracked through our AI-powered complaint management system. You will receive a unique complaint reference number upon submission.

Complaints may also be submitted by email to support@modveon.com.

We will:

• (a) acknowledge receipt of your complaint promptly;
• (b) provide a substantive written response within a reasonable timeframe; and
• (c) for unresolved complaints, provide written notice of escalation options, including the Defensoría del Consumidor.

You may escalate any unresolved complaint to the Defensoría del Consumidor (Section ES-3.2) at any time. Our response times and internal procedures do not limit or delay your right to escalate.

Before any transaction is confirmed, the Modveon application will display all applicable fees and the total cost of the transaction. You will always see the complete cost of a transaction before you confirm it. We do not charge undisclosed fees.

All fees are stated in U.S. dollars.