These Regulatory Disclosures provide important information about TERALEX PAY LIMITED, a company incorporated in Canada, registration number BC1536949, with office address at 5307 Victoria Drive #787, Vancouver, BC V5P 3V6, Canada.

They should be read together with the Terms and Conditions, Privacy Policy, Cookie Policy, fee information, product notices and any client-specific agreement or onboarding document issued or accepted by TERALEX PAY LIMITED. These disclosures are provided for transparency and do not replace the binding terms that govern access to or use of the services.

1. Company Information

TERALEX PAY LIMITED is a Canadian company incorporated under the laws of British Columbia. Its registration number is BC1536949 and its office address is 5307 Victoria Drive #787, Vancouver, BC V5P 3V6, Canada.

In these disclosures, TERALEX PAY LIMITED is referred to as "TERALEX", the "Company", "we", "us" or "our". References to "services" mean the website, client portal, fiat payment functionality, virtual currency functionality, exchange functionality, account access, support channels and related service infrastructure made available by the Company, subject to approval, availability and applicable law.

2. FINTRAC Money Services Business Registration

TERALEX is registered with the Financial Transactions and Reports Analysis Centre of Canada as a Money Services Business under Proceeds of Crime (Money Laundering) and Terrorist Financing Act.

FINTRAC MSB registration number: C10001718.

FINTRAC MSB registration covers money transferring, PSP, forex exchange and virtual currency-related services.

FINTRAC registration means that the Company is registered for the applicable anti-money laundering and anti-terrorist financing regime and is subject to the related compliance obligations. It should not be understood as a recommendation, endorsement, financial soundness approval, deposit guarantee or approval of any specific product, service, transaction or business model by FINTRAC.

3. Bank of Canada and Retail Payment Activities

Certain services may constitute retail payment activities under the Retail Payment Activities Act where the Company performs payment functions in relation to electronic funds transfers. Where Bank of Canada registration is required, the Company will not present itself as a registered payment service provider unless the relevant registration has been obtained or is otherwise permitted by applicable law.

If the Company is registered with the Bank of Canada as a payment service provider, the Company will disclose the applicable registration information, including any registration number or other information required to be made available. Bank of Canada registration, if applicable, should not be understood as meaning that the Company is a bank, deposit-taking institution, government-guaranteed provider, or that the Bank of Canada guarantees or endorses the Company or its services.

4. No Bank, Deposit or Government Guarantee

TERALEX is not a bank, trust company, credit union or deposit-taking institution. Unless expressly stated otherwise in writing, any account, balance, wallet view or service made available through the Company should not be treated as a bank account or insured deposit.

Client funds, balances or virtual currency may be held, processed, safeguarded, recorded or made available through third-party banks, payment institutions, virtual currency infrastructure providers, custodians, wallet infrastructure providers or other service providers involved in the relevant service. The availability, treatment, protection, segregation, return and any permitted deduction from such funds, balances or virtual currency are subject to the Terms and Conditions, applicable product terms, third-party arrangements, safeguarding or custody arrangements and applicable law.

5. Scope and Availability of Services

The Company may provide financial technology, payment-related, virtual currency-related, exchange, account access and related services, subject to applicable law, product availability, service partner availability, internal compliance review, client approval and completion of any required registrations, filings or approvals.

The use of the word "may" in these disclosures reflects that not every service, asset, payment rail, currency, jurisdiction or product feature is available to every client or available at all times. Availability may depend on law, regulation, sanctions requirements, internal risk assessment, partner requirements, technical capability, client location, client profile, verification status, transaction type, asset type and other compliance or operational factors.

The Company may refuse, delay, suspend, restrict or discontinue any service, account, transaction, wallet functionality, payment functionality or virtual currency functionality where required or appropriate for legal, regulatory, sanctions, fraud prevention, risk management, technical, partner-related or operational reasons.

6. Third-Party Providers

The Company may use third-party providers to deliver, support or enable parts of its services. These providers may include banks, payment partners, virtual currency infrastructure providers, custody infrastructure providers, know your client and know your business providers, sanctions and screening providers, transaction monitoring providers, blockchain analytics providers, cloud providers, IT providers, customer support providers, professional advisers and other operational partners.

Certain technical, infrastructure, processing, verification, screening, hosting, execution, settlement or recordkeeping functions may be performed by third parties. The Company remains responsible for managing its own regulatory and compliance obligations, and the use of a third-party provider does not remove the Company's responsibility for its own legal, AML, sanctions, privacy, safeguarding, recordkeeping and customer relationship controls. The Company may depend on third-party systems, payment networks, blockchain networks, intermediaries, wallet infrastructure providers or external wallets involved in a transaction, but it seeks to maintain access to the records, reports, logs and supporting evidence required for its own review, audit and regulatory compliance.

Information on the processing of personal information by the Company and its service providers is set out in the Privacy Policy.

7. Compliance Reviews and Information Requests

The Company may conduct identity verification, business verification, beneficial ownership checks, authorised person checks, sanctions screening, politically exposed person screening, head of international organisation screening, adverse media checks, fraud checks, source of funds checks, source of wealth checks, transaction monitoring, Travel Rule checks, blockchain analytics and other compliance reviews.

The Company may request additional information or documents before opening an account, providing a service, increasing limits, processing a transaction, releasing funds, executing a payment, processing a virtual currency transaction or continuing a business relationship.

Where required or appropriate, the Company may delay, reject, suspend, block, cancel, reverse where possible, return where permitted, or refuse to process a transaction or service. In some cases, the Company may be legally or operationally restricted from providing a full explanation for a delay, rejection, hold, restriction, account closure or other compliance action.

8. Travel Rule and Transfer Information

For certain electronic funds transfers and virtual currency transfers, the Company may be required to collect, verify, store, transmit or obtain information about the sender, recipient and transaction. This may include name, address, account number, wallet address, transaction reference, transaction hash, counterparty information or other information required under applicable anti-money laundering rules.

The Company may request additional information, delay processing, reject a transfer, suspend a transfer or take other follow-up measures if required information is missing, incomplete, inconsistent or cannot be verified.

9. Virtual Currency Risks

Virtual currency services involve material risks. These may include price volatility, market illiquidity, blockchain delays, network congestion, network fees, irreversible transactions, incorrect wallet addresses, loss of access, external wallet risk, protocol risk, fork risk, cyber risk, fraud risk, sanctions risk, regulatory change, technical failure and third-party provider risk.

Where the Company provides Virtual Currency exchange services, the Company acts as principal: it purchases Virtual Currency from institutional liquidity providers and sells it to Clients. The Client's counterparty is the Company, not the underlying market or liquidity source. Client Virtual Currency is held in an omnibus wallet managed by the Company, segregated by token type, so that each supported Virtual Currency is maintained in a separate pool. The Client holds a proportional interest against the relevant pool. In the event of loss, theft, technical failure, security breach or insolvency affecting an omnibus wallet or token pool, losses may be shared proportionally across all Clients with a claim against that pool. Clients should carefully review the risk disclosures set out in the Terms and Conditions before using Virtual Currency services.

A virtual currency transfer may be final and irreversible once submitted to the relevant network or provider. The Company may not be able to cancel, reverse, recover or modify a virtual currency transaction after it has been executed or broadcast. Clients are responsible for checking wallet addresses, networks, transaction details, asset types and instructions before confirming a virtual currency transaction. Where supported virtual currency is held, recorded or made available for a Client through the Company or a third-party provider, the Client may have a beneficial interest, entitlement or contractual claim in accordance with the Terms and Conditions, product terms and applicable custody arrangements. Unless separately disclosed, agreed and permitted by applicable law and product terms, the Company will not lend, pledge, rehypothecate, stake, use for margin, transfer for its own account or otherwise use Client virtual currency for its own purposes.

10. Restricted Jurisdictions, Persons and Activities

The Company may restrict or refuse services to certain countries, regions, industries, business types, persons, entities, wallet addresses, counterparties, transaction types, assets or use cases based on applicable law, sanctions, partner requirements, internal risk assessment, reputational risk or operational limitations.

The services must not be used for unlawful activity, fraud, sanctions evasion, money laundering, terrorist financing, tax evasion, corruption, human trafficking, illegal gambling, darknet activity, scams, ransomware, unlicensed financial services, prohibited goods or services, misleading information, nominee arrangements intended to conceal identity or control, or any other activity prohibited by the Terms and Conditions or applicable law.

11. Safeguarding and Treatment of Client Funds

Where the Company holds or is treated as holding end-user funds, the Company will apply the safeguarding arrangements required by applicable law and by the relevant product terms. Safeguarding arrangements may include the use of third-party banks, payment institutions, trust accounts, segregated accounts, custodians, insurers, guarantors or other service providers, depending on the product, jurisdiction and applicable legal requirements. Where safeguarding applies, the arrangements are intended to support appropriate separation of safeguarded funds from the Company's operating funds, appropriate recordkeeping, reconciliation and return processes, subject to applicable law and the relevant product terms.

The Company safeguards end-user funds in accordance with section 20(1)(c) of the Retail Payment Activities Act through insurance arrangements that cover those funds. End-user funds are maintained in a dedicated account with a qualifying financial institution, segregated from the Company's own operating funds at all times. A Safeguarding Disclosure Notice setting out further details is provided to clients before entering into a payment service agreement.

Safeguarding arrangements, where applicable, do not make the Company a bank, trust company, credit union or deposit-taking institution and do not create deposit insurance unless expressly stated in writing. Where funds or assets are subject to safeguarding or custody arrangements, any fee deduction, charge, return, hold, restriction or set-off will apply only to the extent permitted by applicable law, the Terms and Conditions and the relevant product terms, and should not be read as a general right to use safeguarded funds or protected Client assets to satisfy unrelated obligations of the Company. Additional information may be provided in the Terms and Conditions, product terms, client agreement, safeguarding notice or other applicable disclosure.

12. Complaints, Errors and Contact

Clients may contact the Company regarding service, compliance, regulatory, complaint or error-related questions using the contact details published by the Company. Unless a more specific process applies, complaints and error-related requests should be sent to support@teralex.com and should include the client identifier, transaction reference if applicable, date, amount, currency or virtual currency, description of the issue and supporting documents.

The Company will review complaints and error-related requests in accordance with the Terms and Conditions, applicable law and any complaints handling process made available by the Company. The Company aims to provide a response within 30 business days after receiving the information required to review the matter, unless applicable law requires a different timeframe. Complex matters, third-party provider reviews, payment network issues, blockchain events, sanctions concerns, fraud reviews, regulatory requests or incomplete information may require additional time. Where practicable and permitted by law, the Company will inform the client if additional time is required.

Nothing in these disclosures limits any right a client may have to contact a competent regulator, law enforcement authority, court, consumer protection authority, privacy authority or other competent authority where permitted by applicable law, including any mandatory right that cannot be limited by contract.

13. Regulators and Third-Party Statements

No regulator, government authority, bank, payment partner, virtual currency provider, screening provider or other service provider should be understood as recommending, endorsing, guaranteeing or assuming responsibility for the Company or its services unless that authority or provider expressly states this in writing.

14. Updates to These Disclosures

The Company may update these Regulatory Disclosures from time to time to reflect changes in law, regulation, services, registration status, service providers, internal policies, operational arrangements or risk management requirements. The current version will be made available through the Company website, legal hub, client portal or other official communication channel. Where a material change requires notice under the Terms and Conditions or applicable law, the Company will provide notice in the manner and within the timeframe required.

15. Contact Details

• Company: TERALEX PAY LIMITED
• Registration number: BC1536949
• FINTRAC MSB number: C10001718
• Office address: 5307 Victoria Drive #787, Vancouver, BC V5P 3V6, Canada
• Website: https://teralex.com/
• Contact email: support@teralex.com

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