Anwin Platform User Agreement

AquaRich International Investment Group Limited

Effective Date: 2026/5/1

Last Updated: 2026/5/1

Welcome to the services provided by the Anwin platform ("Anwin," "the Platform," or "we"). This Anwin Platform User Agreement (this "Agreement") is entered into between AquaRich International Investment Group Limited and you, and applies to your access to, registration for, login to, download, installation, or use of the Anwin app, official website, and related wallet services.

Before registering an account, clicking "Agree", or using any Platform service, please carefully read and fully understand this Agreement, especially the provisions relating to service scope, eligibility restrictions, fees, risk notices, account restrictions, limitations of liability, privacy handling, and dispute resolution. By clicking "Agree", completing registration, or continuing to use the Platform services, you acknowledge that you have read, understood, and agreed to be bound by this Agreement. If you do not agree to all or part of this Agreement, please do not use the Platform services.

Important Notice: The Platform provides digital asset wallet, deposit, withdrawal, address management, account security, compliance review, and related support services only to the extent permitted by applicable laws and regulations and within the actual business scope provided by the Platform. Unless expressly stated by the Platform in writing, nothing in this Agreement shall be construed as a representation or warranty that the Platform has obtained any license, registration, filing, or other business qualification in any particular jurisdiction.

■ Article 1 Scope of Agreement and Related Documents

1. This Agreement constitutes the basic legal document between you and the Platform regarding your use of the Platform services.

2. The following documents, to the extent relevant to your use of the Platform services, form an integral part of this Agreement and have the same legal effect as this Agreement:
• Anwin Privacy Policy;
• Anwin Risk Disclosure and Disclaimer;
• Anwin AML/KYC User Notice;
• Fee Schedule;
• supplemental agreements, announcements, notices, and page prompts relating to specific wallet services, assets, networks, requests, activities, or functions.

3. In case of inconsistency between this Agreement and the above documents, unless otherwise expressly stated, the more specific, more recent, or service-specific document shall prevail.

■ Article 2 Definitions

1. "User" means a natural person who registers for, accesses, or uses the Platform services; a legal person or other organization connected with the Platform's written consent shall be subject to the provisions appropriate to its nature.

2. "Digital Assets" means digital assets, tokens, or other on-chain value representations supported by the Platform from time to time. The specific supported scope is subject to the Platform's display at the relevant time.

3. "Account" means the user account registered on the Platform, including login identity, wallet functions, asset records, activity records, and related permission settings.

4. "Wallet Services" means digital asset custody, deposits, withdrawals, address management, internal ledger records, account security, and related support services provided by the Platform in accordance with Platform rules.

5. "Deposit" means the process by which a User places supported Digital Assets into the Platform account in accordance with the asset, network, and address displayed by the Platform.

6. "Withdrawal" means the process by which a User, in accordance with Platform rules, requests supported Digital Assets that are available for withdrawal in the Platform account to be sent to an external wallet address completed, verified, or reviewed as required by the Platform.

7. "Address Management" means the functions or processes for adding, viewing, modifying, deleting, or using deposit addresses, withdrawal addresses, address labels, notes, and other related address information.

8. "KYC" means Know Your Customer identification and verification procedures.

9. "KYB" means Know Your Business identification and verification procedures for enterprise customers.

10. "KYT" means the Platform's procedures for monitoring, screening, and reviewing wallet activity and on-chain activity.

11. "Applicable Laws and Regulations" means laws, regulations, regulatory rules, sanctions measures, judicial orders, and law enforcement requirements applicable to Users, the Platform, related assets, services, jurisdictions, or third parties.

12. "Restricted Regions/Restricted Persons" means countries, regions, individuals, entities, addresses, or other persons that are prohibited or restricted from using all or part of the Platform services due to law, sanctions, regulatory restrictions, Platform policy, or risk control reasons.

■ Article 3 Registration Eligibility, Geographic Restrictions, and User Representations

1. You represent and warrant that:
1.1 you are at least 18 years old or have reached the legal age of majority required for using the Platform services in your jurisdiction, and have the civil capacity and authority necessary to enter into and perform this Agreement;
1.2 you are not a Restricted Person, are not located in a Restricted Region, and will not use the Platform services directly or indirectly on behalf of or for the benefit of any Restricted Person;
1.3 the identity information, contact details, residence, tax information, source of funds, source of wealth, beneficial ownership information, and other materials you provide to the Platform are true, accurate, complete, and kept up to date;
1.4 the funds, assets, addresses, and wallet activity involved in your use of the Platform services have lawful sources and lawful purposes;
1.5 unless expressly permitted by the Platform in writing, you use the Platform services only for yourself and for lawful purposes, and will not use the account, submit requests, or perform wallet operations on behalf of any undisclosed third party or anonymous person;
1.6 you will not circumvent geographic restrictions, sanctions restrictions, account restrictions, service limits, risk control measures, or other Platform rules.

2. The Platform may, based on Applicable Laws and Regulations, regulatory requirements, sanctions policies, risk control needs, or business arrangements, restrict or prohibit specific countries, regions, persons, addresses, devices, network environments, or wallet activity from using all or part of the services, and may implement such restrictions through geofencing, IP controls, device identification, address screening, and other methods.

3. If you no longer meet the registration eligibility requirements or if any of the above representations is no longer true, accurate, complete, or valid, you shall immediately stop using the Platform services and notify the Platform.

■ Article 4 Account Registration, Identity Verification, and Ongoing Due Diligence

1. You shall complete account registration in accordance with Platform requirements and set up a login password, two-factor authentication, or other security verification methods.

2. The Platform has the right, based on Applicable Laws and Regulations, Platform rules, and risk level, to require you to complete KYC, KYB, liveness checks, facial recognition, proof of address, source of funds explanation, tax information declaration, beneficial owner identification, or other supplemental review.

3. You understand and agree that:
3.1 the Platform may verify your identity, purpose of wallet use, source of funds, destination of assets, address information, and other information at the time of registration, before withdrawal, when risk is triggered, during periodic review, or when required by regulators;
3.2 if you fail to provide the required materials or explanations in a timely, complete, and truthful manner, the Platform has the right to suspend, refuse, restrict, or terminate the provision of all or part of the services to you;
3.3 the Platform may set different functional permissions, service scopes, and service limits for different Users based on risk level.

4. You shall promptly update your identity, contact details, residence, tax information, and other important information; you shall bear any losses, restrictions, reviews, or liabilities arising from your failure to update such information in a timely manner.

■ Article 5 Account Security and Use Rules

1. You shall properly safeguard your account, password, verification codes, two-factor authentication tools, login devices, email address, mobile number, and other authentication credentials, and shall be responsible for operations, instructions, and requests made through your account, except where it is proven that they were caused by the Platform's willful misconduct, fraud, or gross negligence.

2. In the context of custodial wallet services, the Platform does not deliver or disclose to you internal custodial private keys, signing materials, or security credentials controlled by the Platform. Unless otherwise expressly stated by the Platform, you have no right to require the Platform to provide relevant internal custodial key materials.

3. You shall not:
• lend, lease, share, or otherwise allow any third party to use your account;
• use another person's account, or allow another person to use your identity information, contact details, authentication tools, or payment methods;
• use automated scripts, crawlers, plug-ins, batch interfaces, cheating programs, or other technical means to interfere with the Platform systems;
• bypass, crack, probe, or attack the Platform's security measures, interface restrictions, or risk control mechanisms.

4. If you discover or suspect account compromise, abnormal login, abnormal withdrawal, identity misuse, suspicious links, fake customer service, or other security risks, you shall immediately notify the Platform through official channels. The Platform may take emergency restrictive measures within a reasonable scope.

■ Article 6 Scope of Services

1. Within the scope permitted by Applicable Laws and Regulations and the Platform's actual business scope, the Platform may provide eligible Users with services including but not limited to:
1.1 digital asset wallet and account management services;
1.2 on-chain digital asset deposit and withdrawal services;
1.3 deposit address, withdrawal address, and related address information management services;
1.4 balance display, activity records, notifications, and customer support services;
1.5 identity verification, compliance review, risk control, and security management services;
1.6 other wallet-related services launched by the Platform from time to time and explained by announcement.

2. Based on laws and regulations, business arrangements, technical conditions, risk control, network stability, availability of third-party services, or other reasonable reasons, the Platform has the right to add, adjust, restrict, suspend, or discontinue any asset, network, service, region, user group, address, payment method, or other function.

3. The Platform does not guarantee that any service, asset, network, or function will remain continuously available, nor does it guarantee that any withdrawal will be completed within a specific time, or that any particular asset will continue to be supported by the Platform.

■ Article 7 Restrictions on Use of Wallet Services

1. The service scope of the Platform is subject to this Agreement and the wallet-related functions displayed on Platform pages. You shall use deposit, withdrawal, address management, account security, and customer support functions in accordance with Platform rules.

2. The Platform may set or adjust supported assets, networks, number of addresses, withdrawal limits, withdrawal frequency, review processes, and other service conditions based on laws and regulations, compliance review, risk control, technical conditions, or Platform policies.

3. You shall not use the Platform services to circumvent regulatory requirements, sanctions restrictions, risk control rules, identity verification requirements, address screening requirements, or other Platform restrictions.

4. If your use of the Platform services involves third-party wallets, third-party payment tools, third-party networks, third-party websites, or other services not controlled by the Platform, you shall review and comply with the relevant third-party rules and bear the risks arising therefrom.

■ Article 8 Deposits, Withdrawals, and Request Handling

1. You shall initiate deposits only to the assets, networks, addresses, or receiving methods expressly displayed and supported by the Platform. You shall bear the risks of loss, delay, or inability to recover assets resulting from selecting the wrong asset, wrong network, wrong address, wrong tag/memo, or using a network not supported by the Platform.

2. Deposit crediting may be affected by block confirmations, on-chain congestion, node abnormalities, system delays, risk review, or other factors. The Platform has the right to credit assets after completing necessary confirmations and reviews.

3. After a withdrawal request is submitted, the Platform may conduct identity verification, address screening, limit checks, manual review, abnormality detection, KYT review, or other compliance checks. The Platform does not guarantee that withdrawals will be completed within a specific time.

4. For deposits, withdrawals, address management, or related requests, the Platform may delay, review, refuse, cancel, restrict, or otherwise handle the relevant request as necessary for risk control, compliance, system security, or dispute handling.

5. Once a digital asset withdrawal request has been broadcast on the relevant blockchain network and confirmed by the network, it is generally irreversible. You shall bear losses caused by wrong addresses, wrong networks, wrong amounts, contract risks, or compatibility issues with third-party wallets, except where otherwise provided by law or caused by the Platform's willful misconduct, fraud, or gross negligence.

■ Article 9 Fees, Taxes, and Authorization to Deduct

1. Fees that may arise from your use of the Platform services include but are not limited to:
• service fees related to deposits and withdrawals;
• on-chain withdrawal miner fees/Gas fees/network fees;
• third-party service fees;
• taxes, levies, withholding, or other amounts required by laws and regulations.

2. Specific rates, charging methods, calculation basis, waiver conditions, and adjustment arrangements shall be subject to the Fee Schedule, request page, confirmation page, or other announcements published by the Platform at the relevant time.

3. You authorize the Platform, to the extent permitted by law, to directly deduct the above fees, taxes, and amounts that must be withheld or paid according to law from your account balance or other payable amounts.

4. Unless expressly required by law, fees collected by the Platform are generally non-refundable.

5. You shall independently assess and bear any tax filing and payment obligations arising from holding, depositing, withdrawing, or using digital asset wallet services. The Platform does not provide tax advice and does not guarantee any specific tax outcome for any wallet operation.

■ Article 10 User Conduct Rules and Prohibited Matters

1. You undertake not to use the Platform to engage in, participate in, assist, facilitate, or make easier any of the following conduct:
• money laundering, terrorist financing, proliferation financing, tax evasion, smuggling, corruption, bribery, human trafficking, weapons-related offenses, drug-related offenses, fraud, extortion, hacker laundering, handling of stolen assets, or other illegal or criminal activities;
• using false identity, misappropriated identity, forged materials, account impersonation, bulk registration, or other deceptive means to pass verification or use Platform services;
• using Platform vulnerabilities, system delays, incorrect data, incorrect displays, or other abnormal circumstances to obtain improper benefits;
• initiating or receiving asset flows involving sanctioned persons, restricted persons, or high-risk addresses;
• using split requests, related-account cycling, abnormal path arrangements, or other methods to circumvent service limits, risk control rules, or regulatory requirements;
• interfering with, damaging, testing, bypassing, or attacking Platform systems, interfaces, networks, wallets, databases, security controls, or other users' accounts;
• infringing the lawful rights and interests of the Platform, other Users, or third parties.

2. If the Platform has reasonable grounds to suspect that you have violated the preceding paragraph or are involved in a high-risk situation, the Platform has the right to take measures such as risk warnings, supplemental review, service restrictions, delayed handling, asset freezing, service suspension, account termination, evidence preservation, and reporting to regulatory or law enforcement authorities.

3. Where required by laws and regulations, judicial orders, regulatory requirements, sanctions policies, or investigations, the Platform may restrict, freeze, retain, preserve, disclose, or hand over relevant information, records, assets, or service permissions without prior notice to you.

■ Article 11 Custody Arrangements, Asset Segregation, and Security Measures

1. The Platform will implement reasonable custody and security management measures for Users' Digital Assets based on its internal controls, technical architecture, and risk policies, including but not limited to separation of cold and hot wallets, multi-level approvals, permission controls, log audits, address screening, abnormality alerts, disaster recovery mechanisms, and internal reconciliation.

2. The Platform may distinguish and manage User assets and the Platform's own assets in internal accounting, and take necessary measures to reduce risks of unauthorized access, theft, misappropriation, mistaken withdrawals, or abnormal asset flows.

3. Although the Platform will take reasonable security measures, you understand and agree that Digital Assets and related technologies still involve risks that cannot be completely eliminated, including but not limited to on-chain congestion, cyberattacks, address contamination, protocol vulnerabilities, smart contract defects, infrastructure interruptions, third-party supplier failures, force majeure, and other risks not fully controllable by the Platform.

4. Unless otherwise mandatorily required by law, the Platform makes no warranty regarding the security, stability, value, or suitability of any Digital Asset, network, protocol, third-party wallet, third-party payment tool, or third-party project.

■ Article 12 Risk Notice and No Investment Advice

1. Digital Assets involve high volatility, high risk, technical complexity, regulatory uncertainty, and the possibility of total loss, and are not suitable for all Users. You shall independently decide whether to use the Platform services based on your financial condition, risk tolerance, tax status, and legal compliance requirements.

2. For risks involving technology, custody, compliance, cybersecurity, third parties, taxes, and force majeure related to the use of the Platform services, please also carefully read the Anwin Risk Disclosure and Disclaimer.

3. Any information, risk notices, operational announcements, customer support communications, or other content provided by the Platform is for general information only and does not constitute investment advice, legal advice, tax advice, accounting advice, fiduciary management advice, or any commitment regarding returns.

■ Article 13 Privacy Protection and Use of Information

1. The Platform will collect, use, process, share, store, and protect your personal information, activity information, device information, on-chain address information, risk control information, and compliance information in accordance with the Anwin Privacy Policy.

2. You understand and agree that the Platform may use relevant information for lawful purposes such as account registration, identity verification, processing of deposit and withdrawal requests, service management, risk control, customer support, dispute handling, anti-money laundering compliance, regulatory cooperation, audit archiving, and security management.

3. For details on information categories, processing purposes, legal bases, cross-border processing, sharing recipients, retention periods, and your related rights, please refer to the Anwin Privacy Policy.

■ Article 14 Service Interruption, System Maintenance, and Limitations of Liability

1. The Platform may suspend, restrict, delay, or terminate all or part of the services due to system maintenance, version upgrades, security testing, risk control measures, regulatory requirements, asset abnormalities, third-party service interruptions, or other reasonable reasons.

2. To the maximum extent permitted by law, the Platform shall not be liable, or shall be liable only to the minimum extent required by law, for losses, delays, restrictions, interruptions, data inconsistencies, request failures, or other impacts caused by:
• blockchain network abnormalities, forks, rollbacks, congestion, or protocol changes;
• failures of third-party service providers, banks, payment institutions, telecommunications operators, cloud service providers, node service providers, or analytics service providers;
• force majeure or events beyond the Platform's reasonable control;
• losses caused by the User's own operational errors, wrong addresses, wrong networks, phishing, compromised devices, or other User-related reasons;
• restrictions or measures taken to comply with laws and regulations, judicial orders, regulatory requirements, or sanctions policies.

3. The foregoing limitations of liability shall not apply if the loss is directly caused by the Platform's willful misconduct, fraud, or gross negligence.

4. To the extent permitted by law, the Platform shall not be liable for any indirect, incidental, special, consequential loss, loss of profits, loss of expected returns, loss of opportunity, loss of goodwill, or loss of data value.

■ Article 15 Account Restrictions, Suspension, Termination, and Asset Handling

1. The Platform has the right to restrict, suspend, freeze, delay handling, terminate, or take other measures against your account or related services in any of the following circumstances:
• you violate this Agreement, Platform rules, or Applicable Laws and Regulations;
• you no longer meet registration eligibility or service access conditions;
• you fail to complete KYC/KYB/KYT, supplemental verification, or ongoing due diligence;
• the Platform reasonably suspects that your account, assets, requests, addresses, or wallet activity involve illegal activities, sanctions risks, fraud risks, dispute risks, security risks, or abnormal patterns;
• judicial authorities, regulatory authorities, law enforcement authorities, or other competent authorities require it;
• your account has been inactive for a long period and meets the Platform's inactive account handling policy;
• the Platform decides to stop providing services to you due to business termination, service discontinuation, technical adjustments, regulatory changes, or risk control.

2. Where permitted by law and practically feasible, the Platform may send you a notice explaining the relevant measures; however, if notice may impede an investigation, violate legal requirements, or increase security risks, the Platform may proceed without prior notice.

3. After account termination, your access and service permissions may be immediately closed, but this shall not affect fees, taxes, indemnities, dispute handling, investigation cooperation, or provisions of this Agreement that by their nature should survive termination.

4. Subject to compliance with laws and regulations, regulatory requirements, judicial orders, or investigation obligations, you may apply to withdraw any remaining assets available for withdrawal in accordance with Platform procedures. The Platform has the right to complete necessary identity verification, compliance review, risk review, and fee settlement before processing.

■ Article 16 Intellectual Property

1. Intellectual property rights in the Platform and its related software, interfaces, brand identifiers, logos, names, domains, graphics, copy, databases, code, technology, design, page layout, and other content belong to the Platform or relevant rights holders.

2. Without the Platform's prior written consent, you shall not copy, modify, reverse engineer, decompile, scrape, disseminate, lease, publicly display, authorize others to use, or otherwise use the foregoing content.

■ Article 17 Notices and Delivery

1. The Platform may send notices to you through app push notifications, in-platform messages, email, SMS, announcements, webpage pop-ups, or other reasonable methods.

2. You shall ensure that your registered email address, mobile number, address, and other contact methods remain true, valid, and capable of receiving notices; you shall bear the consequences caused by your failure to update or properly check them in a timely manner.

3. Unless otherwise required by law, a notice sent by the Platform to your last retained contact method shall be deemed delivered.

■ Article 18 Dispute Resolution and Governing Law

1. The formation, validity, interpretation, performance, dispute resolution, and other matters of this Agreement shall be governed by the laws of El Salvador, without applying its conflict of laws rules.

2. If you have any objection regarding Platform services, request handling, account restrictions, dispute handling, or other matters, you shall first submit an appeal through the Platform's official customer support or complaint channels. The Platform will handle and respond within a reasonable period.

3. If the parties cannot resolve a dispute through negotiation, either party may file a complaint with a competent regulatory authority in accordance with applicable law, or submit the dispute to a competent court in El Salvador.

■ Article 19 Amendments and Version Effect

1. The Platform has the right to amend this Agreement and related rules based on laws and regulations, regulatory requirements, business adjustments, risk control needs, product changes, or other reasonable reasons.

2. For material changes, the Platform will notify you in advance through announcements, email, app push notifications, or other reasonable methods. Changes shall take effect on the effective date stated in the notice.

3. If you continue to access or use the Platform services after the changes take effect, you shall be deemed to have accepted the amended Agreement; if you do not agree to the changes, you shall stop using the relevant services before the effective date and handle your account and assets in accordance with Platform procedures.

4. If this Agreement exists in different language versions, unless otherwise expressly stated by the Platform, the English version shall prevail.

■ Article 20 Contact and Complaint Channels

If you need to contact the Platform, submit a complaint, appeal, report, or learn more information, please contact us through the following official channels:
• Support: [email protected]
• Compliance: [email protected]
• Complaints: [email protected]
• Official Website: anwin.tech
• Company Name: AquaRich International Investment Group Limited
• Registered Address: FLAT A516, 5/F, EFFICIENCY HOUSE, 35 TAI YAU STREET, SAN PO KONG HONG KONG