Terms & Conditions

Platform Agreement
Stable Digital Trading Limited
Effective Date: 5 March 2026

Introduction

These Terms & Conditions ("Agreement") govern the Customer’s access to and use of the proprietary software platform ("Platform") provided by Stable Digital Trading Limited, a company incorporated in Hong Kong (Company No. 78181658), with its registered address at Room 3203, 32/F, Central Plaza, 18 Harbour Road, Wan Chai, Hong Kong ("Stable Digital", "we", "our", "us").

The "Customer" ("you", "your") means the individual or entity that has been onboarded and approved by a regulated service provider, licensed partner, or authorised entity that has entered into a separate agreement with Stable Digital to provide the Platform as part of its service delivery (each, a "Service Partner"). Service Partners may include, without limitation, trust companies, licensed money services businesses, virtual asset service providers, broker-dealers, or other regulated or authorised entities operating in any applicable jurisdiction.

1. Purpose & Scope

Stable Digital provides the Platform to its Service Partners under separate commercial agreements. Each Service Partner may, at its discretion, make the Platform available to its customers as part of its own service delivery. This Agreement sets out the terms on which the Customer is permitted to access and use the Platform as an authorised user of the applicable Service Partner.

The Platform is designed as a multi-service digital ecosystem intended to facilitate the Customer’s access to various financial, digital asset, and administrative services provided by the relevant Service Partner or its partners, including but not limited to trading, card services, financing, and other current or future service modules (collectively, the "Services"). This Agreement does not grant the Customer any licence or rights to the Platform beyond such authorised use.

Technology Provider Only: Stable Digital provides the Platform purely as a technology provider. Stable Digital does not act as custodian, trustee, execution counterparty, or regulated service provider for the Customer. All regulated activities — including trust, custody, onboarding, verification, approval, execution, settlement, and compliance functions — are conducted exclusively by the applicable Service Partner or its appointed agents.

Service-Specific Terms: The Customer acknowledges that access to and use of individual Services offered through the Platform may be subject to additional service-specific terms, conditions, policies, and/or disclosures (collectively, "Service Terms"). These Service Terms will be presented to the Customer within the Platform interface prior to initial access or use of the respective Service. By accessing or utilising any specific Service, the Customer agrees to be bound by its corresponding Service Terms, which shall form an integral part of this Agreement. In the event of any conflict between this Agreement and any Service Terms, the Service Terms shall prevail with respect to the specific Service to which they apply.

2. Relationship Between the Parties

By accessing the Platform, the Customer acknowledges and agrees that: (a) Stable Digital is not a financial institution, custodian, trustee, broker, liquidity provider, or issuer of any financial product or instrument. All regulated services are provided solely by the applicable Service Partner or its licensed partners. (b) The Customer’s regulated and fiduciary relationship (if any) is solely with the applicable Service Partner. (c) Stable Digital does not onboard the Customer, does not approve transactions, and has no role in know-your-customer (KYC), anti-money laundering (AML), sanctions screening, or any other regulatory compliance process. (d) Stable Digital acts only as a technology provider to the Service Partner. (e) The Customer is permitted to use the Platform only through the Service Partner’s authorisation, and such permission may be suspended or withdrawn upon the instruction of the Service Partner.

Nothing in this Agreement creates any agency, partnership, fiduciary relationship, trust arrangement, joint venture, employment, or broker-client relationship between Stable Digital and the Customer.

3. Access & Use

The Customer is permitted to access and use the Platform strictly through the authorisation granted by the applicable Service Partner, and solely for the purpose of viewing information, submitting instructions to the Service Partner, and monitoring transaction status in connection with the services provided by the Service Partner.

All intellectual property rights in and to the Platform, including all software, interfaces, APIs, data models, documentation, workflows and enhancements, are and shall remain the exclusive property of Stable Digital. No licence is granted by Stable Digital to the Customer other than the limited, revocable right of access described in this Agreement. Any access by the Customer is solely by virtue of, and subject to, the Service Partner’s authorisation. Stable Digital may suspend or terminate the Customer’s access immediately upon instruction from the Service Partner or where required by law or regulatory authority.

The Customer shall not assign, transfer, sublicense, rent, lease, or otherwise provide any access to the Platform to any third party. The Customer shall not attempt to copy, modify, interfere with, reverse-engineer, extract source code from, or otherwise misuse the Platform.

Security of Credentials

The Customer shall maintain strict confidentiality of login credentials, passwords, authentication tokens, or access keys issued in relation to the Platform. The Customer shall: (a) Implement reasonable security controls to prevent unauthorised access. (b) Ensure that only authorised personnel access the Platform. (c) Immediately notify the Service Partner and Stable Digital of any suspected or actual unauthorised access, security breach, credential compromise, or misuse. (d) Remain responsible for all activities conducted through its accounts, whether authorised or unauthorised.

Prohibited Activities

The Customer shall not, and shall not permit any person to: (a) Copy, reproduce, modify, adapt, translate, or create derivative works of the Platform. (b) Reverse engineer, decompile, disassemble, extract source code from, or attempt to discover the underlying structure, algorithms, data models, or architecture of the Platform. (c) Access the Platform for the purpose of building, training, improving, or operating a competing product or service. (d) Access or use the Platform through automated scripts, bots, crawlers, scrapers, data-mining tools, or any mechanism intended to extract or harvest data. (e) Attempt to bypass or disable any security, authentication, usage monitoring, encryption, or access-control mechanisms implemented by Stable Digital. (f) Interfere with or disrupt the integrity, performance, or availability of the Platform or its underlying systems. (g) Use the Platform for any fraudulent, unlawful, abusive, manipulative, unauthorised, or otherwise prohibited purpose.

Stable Digital reserves the right to monitor usage of the Platform to ensure compliance with this Agreement and may suspend or restrict access where excessive, suspicious, abusive, or unauthorised activity is detected.

4. Fees

The Customer acknowledges that upon execution of each transaction, the applicable Service Partner will deduct all fees from the transaction proceeds prior to settlement, including: (i) the Service Partner's own fees for its services, and (ii) a platform fee payable to Stable Digital for the use of the Platform. The applicable platform fee will be displayed or made available within the Platform interface before the Customer confirms the transaction instruction.

The Customer acknowledges that: (a) By confirming a transaction instruction, the Customer authorises the Service Partner to deduct the platform fee on behalf of Stable Digital and to remit it to Stable Digital directly. (b) The platform fee is separate from and in addition to any fees charged by the Service Partner for its own services. (c) The Customer's obligation to pay the platform fee arises at the point of transaction confirmation, regardless of any subsequent dispute between the Customer and the Service Partner. (d) Failure to permit the deduction of applicable fees, or any arrangement that circumvents this fee mechanism, may result in suspension of Platform access. (e) Platform fees may be denominated in USD, USDT, or another currency or digital asset as disclosed within the Platform.

This fee arrangement does not modify or affect the Customer’s separate fee obligations to the applicable Service Partner.

Acceptance by Execution

The Customer acknowledges that the Platform hosts multiple Services, each of which may be subject to different fee structures. When the Customer accesses or initiates a specific Service via the Platform (e.g. trading, card transaction, or financing request), the applicable fee for that specific Service will be displayed or made available within the Platform interface. By proceeding with, executing, or otherwise confirming the instruction for that Service, the Customer is deemed to have accepted the displayed fee for that specific transaction or service period.

5. No Execution, Custody or Advisory Services

Stable Digital does not hold or control Customer assets, does not approve or process transactions, does not instruct liquidity providers, does not handle fiat or digital asset transfers, and does not provide any form of investment, financial, legal, tax, or regulatory advice.

All such responsibilities rest solely with the applicable Service Partner or the execution partners, custodians, or agents appointed by the Service Partner.

The Customer agrees that it shall not rely on Stable Digital for any fiduciary obligation, trust duty, suitability assessment, investment judgment, or regulatory compliance support, and understands that Stable Digital has no involvement in any Customer transaction other than providing the software interface through which the Customer may submit instructions to the Service Partner.

6. Deal Confirmations

Following each executed transaction, the Customer may have access to a consolidated confirmation (such as a Deal Confirmation Note) generated via the Platform. The note may summarise the transaction details, any service fees charged by the Service Partner, and any invoice issued by Stable Digital.

This document is provided for transparency only and does not create additional contractual obligations beyond this Agreement. All transaction execution, settlement, and related functions are performed solely by the applicable Service Partner or its contracted execution partners.

7. Customer Obligations

The Customer agrees to:

Ensure that any information provided to Stable Digital or the applicable Service Partner is accurate, complete, and not misleading.
Use any access or services provided by Stable Digital in a lawful and appropriate manner, in compliance with all applicable laws and regulations in the Customer’s jurisdiction.
Comply with any usage guidelines, requirements, or instructions communicated by Stable Digital or the applicable Service Partner from time to time.
Pay all applicable fees and charges issued by Stable Digital in connection with the services provided.

8. Data Protection

Stable Digital shall take reasonable measures to maintain the security and integrity of data processed through the Platform.

Customer data, including data generated or provided through the use of specific Services, may be shared with the applicable Service Partner, liquidity providers, infrastructure vendors, payment processors, or regulators when required, and may be processed internally by Stable Digital to facilitate the provision, improvement, and analysis of all Services offered through the Platform.

The Customer consents to such processing solely for the purpose of operating the Platform and facilitating the Services, and in accordance with Stable Digital’s Privacy Policy, which is available on Stable Digital’s website.

Where the Customer is located in a jurisdiction with specific data protection requirements (such as GDPR, PDPO, CCPA, or equivalent legislation), Stable Digital will handle personal data in accordance with applicable law and any supplementary data processing terms made available to the Customer.

9. Disclaimer, Liability & Indemnity

The Customer acknowledges that all pricing displayed on the Platform is provided by the applicable Service Partner or its appointed liquidity providers. Stable Digital does not validate, verify, or guarantee the accuracy, fairness, or competitiveness of any indicative or executable prices. The Customer further acknowledges that Stable Digital does not execute, match, fill, clear, or settle any orders. Any transaction submitted through the Platform is processed solely by the applicable Service Partner.

Stable Digital shall not be liable for indirect, consequential, or market-related losses, nor for delays caused by Service Partner processes, banking systems, blockchain networks, liquidity providers, payment processors, or other external factors.

Liability Cap: Stable Digital’s total aggregate liability under this Agreement shall not exceed the amount of fees paid by the Customer to Stable Digital in the preceding twelve (12) months.

The Customer shall indemnify and hold harmless Stable Digital, its officers, directors, employees, and agents from and against any losses, claims, damages, liabilities, costs, or expenses arising from the Customer’s misuse of the Platform, breach of this Agreement, or submission of fraudulent, inaccurate, or unlawful instructions.

10. Term & Termination

This Agreement remains in effect for so long as the Customer has access to the Platform. Stable Digital may amend or update this Agreement from time to time. The updated Agreement will take effect upon posting on Stable Digital’s website or notification to the Customer (including via the Platform). If the Customer does not agree to the updated terms, the Customer must immediately cease all use of the Platform. Continued access or use shall constitute the Customer’s acceptance of any updated version.

Stable Digital may suspend or terminate the Customer’s access to the Platform immediately, without prior notice, where: (a) Required by the applicable Service Partner or any regulatory or governmental authority. (b) The Customer fails to pay any applicable fees. (c) Suspicious, fraudulent, unauthorised, abusive, or unlawful activity is detected. (d) The Customer breaches this Agreement or attempts to use the Platform for any prohibited purpose. (e) Stable Digital determines, in its sole discretion, that continued access may pose operational, security, compliance, or regulatory risk.

Upon termination, the Customer must immediately stop using the Platform, and all rights granted under this Agreement will automatically cease. Termination shall not affect Stable Digital’s right to recover any outstanding fees, charges, or other accrued obligations owed by the Customer.

Any breach of this clause shall constitute a material breach of this Agreement and may result in immediate suspension or termination of access without notice. Stable Digital shall not be liable to the Customer for any suspension or termination in accordance with this clause.

11. Governing Law & Dispute Resolution

This Agreement is governed by and construed in accordance with the laws of Hong Kong SAR, without regard to its conflicts of law provisions.

Any dispute, controversy, or claim arising out of or in connection with this Agreement shall be subject to the exclusive jurisdiction of the courts of Hong Kong, unless otherwise required by the mandatory laws of the Customer’s jurisdiction.

12. Entire Agreement

This Agreement, together with any applicable Service Terms and Stable Digital’s Privacy Policy, constitutes the entire understanding between Stable Digital and the Customer regarding Platform access and supersedes all prior discussions, representations, and agreements relating to the subject matter herein.

13. Severability

If any provision of this Agreement is held to be invalid, illegal, or unenforceable under the laws of any jurisdiction, such invalidity shall not affect the remaining provisions, which shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving the original intent.

Acceptance
By accessing or using the Platform, the Customer acknowledges that they have read, understood, and agree to be bound by these Terms & Conditions. The Customer’s continued use of the Platform constitutes full and ongoing acceptance of this Agreement and any updated versions thereof.

Stable Digital Trading Limited is not required to countersign this Agreement.