Terms and Conditions - Captiros AI

Terms and Conditions of Service

Captiros Global Holdings Ltd.

Trading as Captiros AI

Effective Date: July 21, 2021
Last Revised: February 6, 2026

IMPORTANT NOTICE

By accessing, registering for, or using the Captiros platform and associated services (collectively, the "Platform"), you ("User," "you," or "your") acknowledge that you have read, understood, and agree to be legally bound by these Terms and Conditions of Service (the "Terms"), together with all policies, guidelines, and amendments incorporated herein by reference. If you do not agree to these Terms in their entirety, you must immediately cease all use of the Platform and refrain from creating or maintaining an account.

1

DEFINITIONS AND INTERPRETATION

1.1 Definitions

In these Terms, unless the context otherwise requires, the following terms shall have the meanings set forth below:

"Captiros," "we," "us," or "our" refers to Captiros Global Holdings Ltd., a company duly registered and incorporated under the laws of the United Kingdom, with its registered office located at Cannon Bridge House, 25 Dowgate Hill, London EC4R 2YA, United Kingdom, operating under the trading name Captiros AI.

"Platform" means the web-based interface, mobile applications, application programming interfaces (APIs), and all associated technological infrastructure, software, and systems provided, operated, and maintained by Captiros for the purposes of investment management, portfolio tracking, market analysis, and related financial services.

"Services" means all functionality, tools, features, data analytics, content, educational resources, and services made available to Users through the Platform.

"User," "you," or "your" means any individual or entity that accesses, registers for, or uses the Platform and Services.

"Account" or "User Account" means the registered account created by a User to access and utilize the Platform and Services.

"Third-Party Charges" means any and all fees, costs, charges, commissions, or expenses imposed, assessed, or levied by external financial institutions, payment service providers, intermediary banks, correspondent banks, regulatory authorities, tax authorities, or other third-party service providers in connection with the processing, settlement, transfer, conversion, or receipt of funds.

"Settlement" means the final transfer, crediting, and availability of funds to a User's designated bank account, cryptocurrency wallet, or other payment method following a withdrawal request, investment liquidation, or fund transfer transaction.

"Settlement Agent" means Captiros and/or its designated banking partners, payment processors, or financial institutions authorized to process settlements and fund transfers on behalf of Users.

"Blockchain Transaction" means any deposit, withdrawal, transfer, or other transaction conducted via distributed ledger technology, including but not limited to cryptocurrency networks such as Bitcoin, Ethereum, or other digital asset protocols.

"Fiat Currency" means government-issued legal tender, including but not limited to United States Dollars (USD), British Pounds Sterling (GBP), Euros (EUR), or other traditional currencies.

"Cryptocurrency" or "Digital Asset" means any digital or virtual currency utilizing cryptography for security and operating on decentralized blockchain networks, including but not limited to Bitcoin (BTC), Ethereum (ETH), and other cryptocurrencies.

"Intermediary Institution" means any third-party financial institution, correspondent bank, intermediary bank, or payment service provider that acts solely as a conduit or facilitator for the transfer of funds between parties, without being the originating or ultimate receiving party.

1.2 Interpretation

  • Headings and section titles are included for convenience and reference purposes only and shall not affect the interpretation or construction of these Terms.
  • References to any statute, regulation, or legislative provision shall be construed as including references to any statutory modification, consolidation, re-enactment, or extension thereof.
  • Words importing the singular shall include the plural and vice versa, and words importing a gender shall include all genders.
2

ELIGIBILITY AND CAPACITY TO CONTRACT

2.1 Age and Legal Capacity Requirements

To access, register for, or use the Platform and Services, you must satisfy all of the following eligibility criteria:

  • You must be at least eighteen (18) years of age, or such higher age of majority as may be prescribed by the laws of your jurisdiction of residence;
  • You must possess full legal capacity and competence to enter into and be bound by legally binding contracts under the laws applicable to you;
  • You must not be subject to any legal disability, incapacity, or restriction that would prevent you from entering into or performing obligations under these Terms;
  • You must not be a resident, citizen, national, or domiciliary of any jurisdiction where the access to or use of the Platform or Services would violate applicable local, national, or international laws, regulations, or sanctions;
  • You must not be included on, or associated with any person or entity included on, any sanctions list maintained by the United Nations, European Union, United Kingdom, United States Office of Foreign Assets Control (OFAC), or any other competent governmental or regulatory authority.

2.2 Representations and Warranties

By registering for an Account or using the Platform, you represent, warrant, and covenant that:

  • You meet all eligibility requirements set forth in Section 2.1 above;
  • All information provided by you during registration and at all times thereafter is true, accurate, current, and complete;
  • You will promptly update any information provided to Captiros to maintain its accuracy and completeness;
  • You have the authority to bind yourself (and, if applicable, any entity on whose behalf you are acting) to these Terms.
3

ACCOUNT REGISTRATION AND SECURITY

3.1 Account Creation and Information Accuracy

To access certain features of the Platform, you must create a User Account by completing the registration process and providing all required information, including but not limited to your full legal name, email address, telephone number, date of birth, residential address, and such other information as may be requested by Captiros from time to time.

You agree to provide accurate, current, and complete information during the registration process and to promptly update such information as necessary to maintain its accuracy and completeness at all times.

3.2 Account Security and Confidentiality

You are solely and exclusively responsible for:

  • Maintaining the confidentiality and security of your Account login credentials, including your username, password, two-factor authentication codes, security questions and answers, and any other authentication methods;
  • All activities, transactions, and actions conducted through or under your Account, whether or not authorized by you;
  • Any consequences arising from unauthorized access to or use of your Account resulting from your failure to maintain adequate security measures.

3.3 Notification of Unauthorized Access

You agree to notify Captiros immediately upon becoming aware of, or reasonably suspecting, any unauthorized access to, use of, or breach of security affecting your Account. Such notification shall be sent to: legal@captirosai.com

Notwithstanding any such notification, you acknowledge and agree that you shall remain liable for all activities conducted through your Account until such time as Captiros has had a reasonable opportunity to act upon your notification and take appropriate security measures.

3.4 Identity Verification and Compliance

Captiros reserves the right, at any time and in its sole discretion, to request additional documentation or information from you for the purposes of:

  • Verifying your identity, age, residential address, or other eligibility criteria;
  • Complying with applicable anti-money laundering (AML), know-your-customer (KYC), counter-terrorist financing (CTF), or other regulatory obligations;
  • Assessing creditworthiness, financial standing, or risk profile;
  • Investigating suspected fraudulent, suspicious, or prohibited activities.

Failure to provide requested documentation or information within a reasonable timeframe may result in temporary or permanent suspension of your Account and access to Services.

4

NATURE AND SCOPE OF SERVICES

4.1 Services Provided

Captiros provides a technology-driven online platform offering the following services:

  • Portfolio management tools and investment tracking functionality;
  • AI-generated trading signals, market analysis, and investment recommendations;
  • Real-time and historical market data, charts, and analytics;
  • Educational content, research materials, and investment resources;
  • Account management features, including deposits, withdrawals, and transaction history.

4.2 Non-Advisory Capacity and Disclaimer

IMPORTANT: Captiros is NOT a licensed broker-dealer, investment adviser, registered investment adviser, financial institution, fiduciary, or regulated financial services provider under the laws of the United Kingdom, United States, or any other jurisdiction.

The Services, content, information, and materials provided through the Platform do NOT constitute:

  • Financial, investment, legal, tax, or accounting advice;
  • A recommendation, endorsement, or solicitation to buy, sell, or hold any security, asset, or investment;
  • An offer to sell or a solicitation of an offer to buy securities or investments;
  • Professional advisory services requiring regulatory authorization or licensure;
  • A guarantee, warranty, or assurance of any particular investment outcome or return.

4.3 User Responsibility for Investment Decisions

All investment decisions, transactions, and actions taken by you through the Platform are made solely at your own discretion, judgment, and risk. You are solely responsible for evaluating the merits, risks, and suitability of any investment strategy, security, or asset.

You acknowledge that Captiros has not assessed your financial situation, investment objectives, risk tolerance, or personal circumstances, and that any investment signals, recommendations, or content provided through the Platform are generic in nature and not tailored to your individual needs.

5

FINANCIAL RISK DISCLOSURE AND WARNINGS

5.1 General Investment Risks

You expressly acknowledge, understand, and accept that:

  • All investments, whether in traditional securities, cryptocurrencies, derivatives, commodities, or other financial instruments, carry inherent risk of partial or total loss of invested capital;
  • Past performance, historical returns, backtested results, or simulated performance data are not indicative, predictive, or guarantees of future performance or results;
  • Market conditions, economic factors, political events, regulatory changes, and other circumstances beyond your or Captiros's control may adversely affect the value, liquidity, or performance of investments;
  • Captiros does not guarantee, warrant, represent, or promise that you will achieve any specific investment return, profit, or financial outcome through use of the Platform or Services.

5.2 Cryptocurrency and Digital Asset Risks

Investments in cryptocurrencies and digital assets involve heightened and unique risks, including but not limited to:

  • Extreme price volatility, with potential for rapid and substantial depreciation in value;
  • Regulatory uncertainty, with governments worldwide implementing or considering restrictions, prohibitions, or adverse tax treatment of digital assets;
  • Cybersecurity threats, including hacking, theft, loss of private keys, and vulnerabilities in smart contracts or blockchain protocols;
  • Lack of regulatory oversight, investor protection schemes, or deposit insurance comparable to traditional financial institutions;
  • Limited liquidity, market manipulation, and potential difficulty in executing transactions at desired prices;
  • Risk of total and permanent loss of invested capital without recourse or recovery.

5.3 Recommendation to Seek Professional Advice

You are strongly encouraged and advised to seek independent financial, legal, tax, and accounting advice from qualified professionals before making any investment decision or conducting any transaction through the Platform.

Captiros shall not be held liable for any losses, damages, or adverse consequences arising from your failure to obtain such professional advice prior to investing.

6

DEPOSITS AND ACCOUNT FUNDING

6.1 Approved Payment Methods

Users may fund their Accounts through such payment methods as Captiros may approve, designate, and make available from time to time, which may include but are not limited to:

  • Bank wire transfers (domestic and international);
  • Automated Clearing House (ACH) transfers or Single Euro Payments Area (SEPA) transfers;
  • Credit card or debit card payments;
  • Cryptocurrency transfers to designated wallet addresses;
  • Third-party payment processors or digital wallet services.

6.2 Processing Times and Availability

Deposit processing times vary depending upon the payment method selected, network congestion (in the case of Blockchain Transactions), banking hours and holidays, verification or compliance checks, and other factors beyond Captiros's control.

Captiros does not guarantee immediate availability or crediting of deposited funds. Funds will be credited to your Account only upon receipt, verification, and clearing by Captiros or its payment service providers.

6.3 Third-Party Payment Processors

Where deposits are processed through third-party payment service providers, you acknowledge and agree that such providers operate under their own terms and conditions, privacy policies, and fee schedules, which you must separately review, understand, and accept.

Captiros is not responsible for the acts, omissions, errors, delays, or failures of third-party payment processors.

7

WITHDRAWALS AND FUND TRANSFERS

7.1 Withdrawal Requests

You may request withdrawal of available funds from your Account at any time, subject to:

  • Completion of all applicable identity verification and compliance checks;
  • Satisfaction of any minimum withdrawal threshold amounts;
  • Compliance with any applicable holding periods or lock-up restrictions;
  • Settlement of any outstanding obligations, fees, or charges owed to Captiros or third parties.

7.2 Verification and Compliance Holds

Captiros reserves the right to delay, suspend, or refuse withdrawal requests pending:

  • Completion of enhanced due diligence, identity verification, or source of funds inquiries;
  • Resolution of suspected fraudulent, suspicious, or prohibited activities;
  • Compliance with applicable anti-money laundering (AML), know-your-customer (KYC), counter-terrorist financing (CTF), or sanctions screening obligations;
  • Receipt of lawful requests or orders from governmental, regulatory, or law enforcement authorities.

7.3 Processing Times

Withdrawal processing times vary based on the payment method selected, involvement of banking intermediaries, currency conversion requirements, compliance protocols, and other factors.

Captiros endeavors to process withdrawals in a timely manner but does not guarantee any specific processing timeframe. Users acknowledge that international wire transfers may take several business days to complete.

8

FINANCIAL OPERATIONS, SETTLEMENT TERMS, AND THIRD-PARTY CHARGES

IMPORTANT: This section governs your authorization for settlement processing and your financial responsibility for Third-Party Charges. Please read carefully.

8.1 Authorization for Settlement Processing

By creating an Account and accepting these Terms, you hereby grant to Captiros and its designated Settlement Agents irrevocable, unconditional authorization to:

  • Process withdrawals, settlements, and fund transfers on your behalf in accordance with your instructions;
  • Engage, utilize, and contract with third-party financial institutions, intermediary banks, correspondent banks, payment processors, currency exchange providers, and other service providers as necessary or appropriate to complete settlement transactions;
  • Advance payment of Third-Party Charges on your behalf to facilitate expedited settlement and avoid delays, with such advanced amounts to be reimbursed by you in accordance with Section 8.3 below.

8.2 Third-Party Charges: Nature, Scope, and Disclosure

(a) Definition and Categories of Third-Party Charges

For the purposes of these Terms, "Third-Party Charges" include, without limitation, any and all of the following fees, costs, and expenses imposed by external entities:

• Intermediary bank fees, correspondent banking charges, and beneficiary bank fees

• SWIFT network fees, SEPA transfer fees, or other international payment system charges

• Currency conversion fees, foreign exchange margin charges, and cross-currency settlement costs

• Anti-money laundering (AML) and know-your-customer (KYC) screening fees

• Regulatory compliance costs, government filing fees, and reporting charges

• Wire transfer fees, payment processing fees, and transaction handling charges

• Cross-border transaction fees, international settlement charges

• Withholding taxes, remittance taxes, or other statutory deductions

(b) Advance Disclosure and Estimates

Captiros and its Settlement Agents will use commercially reasonable efforts to provide advance notice of estimated Third-Party Charges where practicable. However, you acknowledge and agree that:

  • Final Third-Party Charges may vary from estimates due to real-time market conditions, currency exchange rate fluctuations, changes in third-party fee schedules, or actions by external service providers;
  • Certain charges may not be ascertainable or calculable until after transaction completion;
  • Captiros does not control and is not responsible for Third-Party Charges imposed by external entities.

(c) No Markup or Profit by Captiros

Third-Party Charges are imposed by external entities, NOT by Captiros. Captiros does NOT mark up, add profit margins to, or derive revenue from Third-Party Charges. Captiros serves solely as a conduit, facilitator, or agent for settlement transactions and passes through actual Third-Party Charges at cost.

8.3 User Responsibility for Third-Party Charges

(a) Direct and Sole Liability

YOU EXPRESSLY ACKNOWLEDGE, UNDERSTAND, AND AGREE THAT YOU ARE DIRECTLY, PERSONALLY, AND SOLELY LIABLE FOR ALL THIRD-PARTY CHARGES INCURRED IN CONNECTION WITH THE SETTLEMENT, PROCESSING, OR TRANSFER OF YOUR FUNDS.

This liability exists regardless of whether such charges were disclosed in advance, estimated accurately, or specifically itemized prior to transaction completion.

(b) Advance Payment and Reimbursement Obligation

Where Settlement Agents advance payment of Third-Party Charges on your behalf to avoid settlement delays or facilitate expedited processing:

  • You hereby authorize Settlement Agents to deduct, set off, or recoup the advanced amount from your available Account balance, settlement proceeds, or future deposits;
  • In the event that deduction from available funds is not possible, commercially impracticable, or results in insufficient funds, you covenant and agree to reimburse Settlement Agents directly within fifteen (15) calendar days of receiving an itemized invoice, statement, or reimbursement request;
  • Failure to reimburse Third-Party Charges within the specified timeframe may result in immediate account suspension, termination of Services, initiation of legal proceedings for debt recovery, and/or referral to third-party debt collection agencies, with you being liable for all associated collection costs, legal fees, and expenses.

(c) Documentation and Verification Rights

Upon your written request, Captiros or Settlement Agents shall provide itemized documentation evidencing:

  • The nature, amount, and purpose of each Third-Party Charge;
  • The identity and contact information of the third-party provider imposing the charge;
  • Proof of payment to the third-party provider, such as wire confirmation receipts, invoice acknowledgments, or banking statements.

8.4 Cryptocurrency Transactions: Taxation and Fee Treatment

(a) Blockchain Network Fees Only

For deposits, withdrawals, or transfers conducted via Blockchain Transactions, including but not limited to Bitcoin, Ethereum, Litecoin, or other cryptocurrency networks:

  • Users are responsible ONLY for network transaction fees (commonly referred to as "gas fees," "miner fees," or "network fees") as determined and calculated algorithmically by the applicable blockchain protocol itself;
  • NO ADDITIONAL TAXES, SURCHARGES, PROCESSING FEES, OR OTHER CHARGES SHALL BE IMPOSED, ASSESSED, OR LEVIED BY CAPTIROS on pure Blockchain Transactions, unless such charges are expressly disclosed in advance in writing and separately consented to by the User;
  • The amount of blockchain network fees is determined by factors including network congestion, transaction complexity, and blockchain protocol parameters, and is not controlled by Captiros.

(b) Non-Applicability of Third-Party Charges to Pure Cryptocurrency Transactions

The Third-Party Charges described in Section 8.2 apply ONLY to settlements and fund transfers processed through traditional Fiat Currency banking channels and intermediary financial institutions.

Third-Party Charges DO NOT apply to pure Blockchain Transactions conducted entirely on cryptocurrency networks without involvement of banks or fiat currency conversion.

8.5 Fiat Currency Bank Settlement: User Election and Charge Allocation

(a) Elective Use of Traditional Banking Channels

Where you elect, choose, or request to receive funds via traditional Fiat Currency banking channels, including but not limited to bank wire transfers, ACH transfers, SEPA payments, or checks, rather than directly via cryptocurrency or Blockchain Transactions:

  • You acknowledge and understand that such election necessarily involves and requires the participation, engagement, and services of one or more third-party financial institutions, intermediary banks, correspondent banks, payment processors, and currency exchange providers acting as intermediaries in the transfer chain;
  • All Third-Party Charges arising from, relating to, or incurred in connection with such Fiat Currency banking settlement, including without limitation all charges specified in Section 8.2(a) above, are and shall be CHARGED DIRECTLY TO YOU, the User and investor;
  • Such Third-Party Charges are NOT borne, absorbed, subsidized, or paid by Captiros, and Captiros has no obligation or liability to cover, reduce, or reimburse such charges.

(b) Cryptocurrency Alternative and Cost Comparison

Users are hereby informed and advised that cryptocurrency withdrawal options, where available, typically incur substantially lower transaction costs consisting only of blockchain network fees (generally ranging from $1 to $50 depending on network congestion), as opposed to traditional banking transfers which may incur Third-Party Charges ranging from 5% to 40% or more of the transfer amount depending on transaction characteristics, currency pairs, and intermediary involvement.

By electing to use traditional banking channels notwithstanding the availability of cryptocurrency alternatives, you acknowledge that you have made an informed choice accepting responsibility for the higher Third-Party Charges associated with fiat currency transfers.

(c) No Markup, Commission, or Profit by Captiros

Captiros does NOT impose, add, or apply any markup, commission, surcharge, or profit margin on Third-Party Charges. All Third-Party Charges represent actual costs incurred and paid by Settlement Agents to external service providers, passed through to you at cost without any additional fee or benefit to Captiros.

8.6 Confidentiality of In-Transit Funds and Prohibition on Unauthorized Intermediary Charges

(a) Confidential Status of Funds During Transit

All funds transferred from the Captiros Platform to a User's designated receiving bank account or payment method are hereby designated and classified as CONFIDENTIAL IN-TRANSIT FUNDS from the time of initial transfer until final crediting and availability in the User's designated account.

(b) Prohibition on Unauthorized Deductions by Intermediary Institutions

Third-party financial institutions, intermediary banks, correspondent banks, payment service providers, or other entities acting solely as conduits, facilitators, or intermediaries for the transfer of funds between Captiros (or Settlement Agents) and Users ("Intermediary Institutions") are expressly and strictly PROHIBITED from:

  • Imposing, assessing, levying, or deducting any additional taxes, levies, surcharges, fees, or charges on in-transit funds beyond the standard, disclosed, and agreed-upon processing fees enumerated in Section 8.2(a);
  • Deducting, withholding, or diverting any amounts from in-transit funds for purposes unrelated to the lawful, authorized completion of the settlement transaction;
  • Withholding or delaying transfer of funds on grounds other than: (i) legitimate, documented anti-money laundering (AML) or know-your-customer (KYC) compliance holds; (ii) valid court orders, judicial attachments, or garnishment orders issued by courts of competent jurisdiction; or (iii) binding directives from competent governmental or regulatory authorities.

(c) User Notification Obligations and Captiros Response

If you become aware that an Intermediary Institution has imposed unauthorized charges, deductions, or withholdings in contravention of Section 8.6(b) above, you must notify Captiros immediately in writing by email to: legal@captirosai.com

Upon receipt of such notification, Captiros will:

  • Conduct a commercially reasonable investigation into the reported unauthorized charge;
  • Where appropriate and practicable, communicate with the Intermediary Institution to seek clarification, correction, reversal, or reimbursement;
  • Provide you with assistance in documenting and pursuing recovery of unauthorized deductions;
  • Consider alternative routing or banking partners to avoid future occurrences.

(d) Limitation on Captiros Liability for Intermediary Actions

Notwithstanding the foregoing, Captiros shall NOT be held liable, responsible, or accountable for unauthorized deductions, delays, or diversions caused by Intermediary Institutions acting outside the scope of their authorized mandate or in violation of applicable banking regulations, provided that Captiros has exercised reasonable care, due diligence, and good judgment in selecting, engaging, and instructing such Intermediary Institutions.

Additional Financial Operations Provisions

8.7 Fee Schedule, Rate Disclosure, and Transparency

Captiros shall maintain and make available on the Platform a publicly accessible fee schedule detailing: (a) standard Captiros platform service fees, if any; (b) estimated ranges for common categories of Third-Party Charges based on historical data; (c) applicable currency conversion rates and foreign exchange spreads. Users are responsible for reviewing the fee schedule prior to initiating transactions.

8.8 Changes to Third-Party Charges

Third-Party Charges are determined by external service providers and are subject to change at any time at the sole discretion of such providers, without advance notice to Captiros or Users. Captiros will use reasonable efforts to update fee estimates and disclosures promptly upon becoming aware of changes, but does NOT warrant or guarantee the accuracy of estimates provided prior to transaction completion. Actual charges may differ from estimates.

8.9 Holding Periods, Withdrawal Restrictions, and Charge Settlement

Captiros reserves the right to impose, maintain, or extend holding periods or withdrawal restrictions where: (a) required or mandated by applicable law, regulation, or regulatory directive; (b) necessary to comply with anti-money laundering (AML), know-your-customer (KYC), or counter-terrorist financing (CTF) protocols; (c) reasonably required to mitigate fraud, security risks, or suspicious activity; (d) outstanding Third-Party Charges advanced on your behalf remain unreimbursed beyond the timeframe specified in Section 8.3(b)(ii).

8.10 Settlement Agent Discretion and Operational Authority

Settlement Agents retain sole and absolute discretion to: (a) select, engage, and contract with intermediary banks, payment processors, currency exchange providers, and other service providers; (b) determine the optimal, most efficient, or most cost-effective routing for fund transfers; (c) implement risk management protocols, fraud prevention measures, or compliance holds as deemed necessary or prudent in their professional judgment; (d) decline to process transactions that pose unacceptable legal, regulatory, reputational, or financial risks.

CONTACT INFORMATION

For questions, concerns, inquiries, or disputes regarding these Terms, the Platform, or Services, please contact:

Legal Department

Captiros Global Holdings Ltd.

Cannon Bridge House, 25 Dowgate Hill

London EC4R 2YA, United Kingdom

ACKNOWLEDGMENT OF ACCEPTANCE

BY CLICKING "I ACCEPT," "I AGREE," OR ANY SIMILAR BUTTON, BY REGISTERING FOR AN ACCOUNT, OR BY ACCESSING OR USING THE PLATFORM IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS AND CONDITIONS IN THEIR ENTIRETY. IF YOU DO NOT AGREE TO THESE TERMS, YOU MUST NOT ACCESS, REGISTER FOR, OR USE THE PLATFORM OR SERVICES.

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