Terms and Conditions

1. DEFINITIONS

In these Terms, the following expressions have the meanings below. A defined term includes the singular and plural where the context requires.

“Account” your profile in the App. The Account is not itself a bank account, payment account, e-money account or blockchain wallet.

“Applicable Provider” the exact legal entity identified in a Feature Schedule as contractually providing a service to you or to Pulsar for the relevant feature. A protocol, SDK, curator or infrastructure component is not automatically your service provider.

“App” the Pulsar Money mobile application and any related web interface provided by Pulsar.

“Available Balance” an amount that a Provider or the App displays as available for an instruction. It may differ from a ledger balance, on-chain balance or finally settled balance.

“Business Day” a day other than Saturday, Sunday or a public holiday in Romania, unless mandatory law or the applicable Provider Terms uses a different definition for the relevant service.

“Card” a virtual or physical payment card made available through the App and issued by the issuer identified in the applicable Card Terms for use on the identified card scheme.

“Card Terms” the separately presented contract governing the Card or payment service, including the responsible issuer or regulated provider, fees, limits, statutory rights and complaints information. A privacy notice is not made contractual merely by this definition.

“Component Provider” a protocol, wallet-infrastructure company, SDK, router, bridge, curator, oracle, chain, cloud provider or other technical dependency that may not contract directly with you.

“Cover Disclosure” the separate durable disclosure and terms, if any, for cover applicable to one exact position.

“Credentials” passwords, passkeys, one-time codes, device credentials, recovery methods, authentication tokens, wallet keys, authorization keys and any other method used to access an Account or authorize an action.

“Delegated Action” a blockchain action that you authorize Pulsar, an Applicable Provider or an approved signer to initiate or sign on your behalf within the limits described in a Feature Disclosure and Delegated Action Consent.

“Delegated Action Consent” your separate durable instruction specifying each signer, asset, contract, function, recipient, amount, cumulative limit, gas or fee tolerance, slippage, retry rule, duration, revocation method and other control applicable to a Delegated Action.

“Digital Asset” a crypto-asset, stablecoin, vault share, receipt token or other blockchain-based asset that the App supports for a specific feature.

“Earn” the App functionality through which you may instruct a Wallet to deposit supported Digital Assets into a disclosed Vault or other disclosed DeFi position.

“Earn Wallet” the Wallet identified in the applicable Wallet Control Schedule and Vault Schedule as holding assets or Vault shares used for Earn.

“Feature Disclosure” the transaction- or feature-specific information presented before activation or authorisation, including the information required by Appendix 2.

“Feature Schedule” the dated, versioned and separately accepted document identifying the exact legal and technical configuration of a Card, payment, Wallet, transfer, route, Vault or other feature. A Feature Schedule is operative only when completed and presented before first use.

“Feature Terms” additional contractual terms that govern a particular feature, transaction type, promotion, Card, Wallet, Vault or Provider service.

“Indicative Estimate” a non-binding display based on then-available market or provider data that is not capable of acceptance and may change before an Quote is presented.

“Instruction” a request, authorization, standing instruction or order submitted by you or pursuant to a Delegated Action Consent.

“Network” a blockchain, distributed ledger, payment network, card scheme, bank-transfer scheme or other settlement network used for a Transaction.

“Platform” the App, related websites, APIs and software interfaces provided by Pulsar.

“Provider Balance” a balance or entitlement administered by an Applicable Provider, including a fiat, e-money, card, settlement or provider-controlled smart-account balance.

“Provider Terms” the dated contract of an Applicable Provider that is presented to and accepted by you for its service. Provider fees, disclosures and privacy notices remain separate documents unless the contract expressly and lawfully incorporates them.

“Pulsar” Pulsar Money SRL, CUI 50067481, Trade Registry number: J2024000942322, with registered office at Cal. Cisnădiei Nr. 54A, 550376 Sibiu, Romania.

“Quote” an executable offer containing the rate, route, amounts, separately identified fees, minimum received value, expiry and other material conditions for a proposed Transaction.

“Regulated Provider” the exact entity identified in a Feature Schedule as providing a regulated payment, e-money, Card, crypto-asset or other regulated service.

“Smart Account” a blockchain account or smart-contract wallet used for a Provider Balance or Card functionality and subject to provider policies, permissions, debit rights and Provider Terms.

“Stablecoin” a Digital Asset intended to track a reference currency or asset. A Stablecoin is not necessarily fiat money, a bank deposit or protected by a deposit-guarantee scheme.

“Terms” these Terms and Conditions, together with documents expressly incorporated into them.

“Transaction” a card, payment, transfer, exchange, bridge, on/off-ramp, blockchain, Earn or other operation initiated through the App.

“User” an individual who creates an Account and accepts these Terms, also referred to as “you”.

“Vault” the identified smart contract or set of contracts into which assets are deposited for Earn, including its adapters, markets and receipt tokens.

“Vault Schedule” the Feature Schedule for a specific Vault, containing at least the information listed in Appendix 2 and the exact production addresses and roles.

“Wallet” a blockchain wallet or smart account accessible through the App. Wallets may have materially different control, signing, recovery, policy and custody arrangements.

“Wallet Control Schedule” the Feature Schedule identifying the beneficial owner, root authority, every signer and policy administrator, quorum, permitted mandate, privileged roles, export, recovery, insolvency and outside-App configuration for a Wallet.

2. AGREEMENT, ACCEPTANCE AND DOCUMENT HIERARCHY

2.1 Acceptance

By creating an Account or using the Platform after these Terms are presented to you, you agree to these Terms. If you do not agree, do not create an Account or use the Platform. We will record the version, time and method of acceptance and make a durable copy available to you.

A high-risk or regulated feature requires the separately presented Feature Schedule and, where applicable, Provider Terms, Feature Terms or a Delegated Action Consent. You are bound by Provider Terms only if the exact provider, document, version and link are presented before first use and your acceptance is recorded. Access to the rest of the App does not activate every feature.

2.2 Order of precedence

These Terms govern Pulsar’s provision of the Platform. Provider Terms govern the service supplied by the Applicable Provider. Feature Terms and a completed Feature Schedule govern the exact feature configuration. A Feature Schedule prevails only for provider identity, asset, route, fees, limits and technical configuration; it does not silently amend Pulsar’s liability, privacy duties, termination rights, governing law or mandatory consumer rights.

Pulsar cannot amend Provider Terms and an Applicable Provider cannot amend these Terms. If the App summarises Provider Terms, the summary is for convenience; the provider’s full terms govern its service. Pulsar remains responsible for the accuracy of its own summary and integration to the extent required by law.

2.3 Contract formation, immediate supply and withdrawal

Before you conclude a contract in the App, you will be able to review the required pre-contract information, correct input errors and obtain the accepted documents in a durable form. Where immediate performance requires a separate request or acknowledgement during a statutory withdrawal period, the relevant contracting party must obtain it before performance begins.

Withdrawing from an eligible ongoing framework contract, closing an Account, cancelling an unsubmitted Instruction and disputing a completed Transaction are different actions. Withdrawal from a framework contract does not reverse a card or blockchain Transaction already authorised and submitted. Blockchain finality does not remove statutory card-payment, execution-error, refund, chargeback or other mandatory rights.

Where Romanian or other applicable law requires an online withdrawal function, the App or responsible Provider interface will make the function continuously available, prominent and no harder to use than entry into the contract, and will provide durable confirmation. This feature must be operational before the affected service is offered.

3. PULSAR’S ROLE AND RESPONSIBILITY

3.1 Platform provider

Pulsar designs, operates and supports the Platform, integrates third-party services, presents balances and disclosures, routes Instructions and provides customer-support coordination. Pulsar is responsible for its own software, statements, security measures, integration decisions and acts or omissions to the extent required by these Terms and applicable law.

A Feature Schedule identifies whether Pulsar or another entity performs each material function. Unless it expressly states that Pulsar provides a regulated service under an applicable authorisation, Pulsar provides only the Platform functions described in these Terms. This contractual description does not determine or override a regulatory classification based on the actual facts.

3.2 Applicable Providers

A regulated or third-party service is provided by the Applicable Provider identified in the completed Feature Schedule before first use. The schedule will state, where relevant, the legal entity, authorisation and regulator, service category, country scope, issuer, programme manager, card scheme, safeguarding or protection status, Provider Terms version, fees, limits, urgent contact, complaints path and data role.

Component Providers may supply infrastructure without contracting with you or owing you the duties of a regulated provider. A provider name in marketing, a partner announcement, a sandbox, an SDK integration or a meeting does not establish production availability, legal responsibility or a direct user contract.

3.3 No advice or fiduciary relationship

Information in the App, including asset descriptions, APY, prices, risk scores, route suggestions and educational material, is general information and is not personalised financial, investment, legal or tax advice unless a Feature Schedule expressly identifies an authorised advisory service. Any ranking or default route will disclose the material criteria and compensation that influence it. You should obtain independent advice where appropriate.

4. ELIGIBILITY, TERRITORIES AND VERIFICATION

4.1 Eligibility

You must be at least 18, have legal capacity, use the Platform for personal purposes unless business use is separately agreed, and be resident in a country that Pulsar and the relevant Providers support. You must not be subject to sanctions or otherwise prohibited from using a feature.

Availability varies by country, nationality, residence, device, Network, asset, Provider policy and verification status. A feature visible in the App may remain unavailable until all conditions are satisfied.

4.2 Information and verification

You must provide accurate, current and complete information. An Applicable Provider may conduct identity, address, liveness, source-of-funds, sanctions, fraud, tax-residency and other checks. Pulsar may conduct Account-security, fraud-prevention, sanctions or legal checks within its role. Do not assume all verification is performed exclusively by one provider.

Verification may be repeated and may result in delay, limits, refusal or suspension. A prior approval by Pulsar or another provider does not guarantee approval for a new Provider or feature. Provider decisions are subject to their terms and complaint routes; Pulsar will reasonably assist with routing a complaint but cannot override a provider decision it does not control.

5. ACCOUNT, DEVICES AND SECURITY

5.1 Account registration

You may create only one personal Account unless Pulsar agrees otherwise. You must keep your profile and contact details current. The Account is personal and may not be sold, transferred, shared or used for another person’s Transactions.

5.2 Credentials and devices

You must protect your Credentials and devices, use a strong device lock, enable multi-factor authentication where offered, verify requests and never share a recovery secret or private key. Pulsar and its Providers will not ask you to send a private key, recovery phrase or full password by email, chat or telephone.

An authenticated session is evidence that an Instruction came through your Account, but it does not conclusively prove valid authorization where the device, Credentials, Platform or Provider system was compromised. Mandatory unauthorized-transaction rights remain unaffected.

5.3 Suspected compromise

Notify [email protected] immediately if you suspect unauthorized access, a compromised device, phishing, a changed recovery method, an unexpected signature, an unknown allowance or an unauthorized Transaction. Where technically and legally possible, Pulsar may revoke sessions, disable new Instructions, suspend a Delegated Action, revoke a Pulsar-controlled signer or coordinate with a Provider. These measures may not stop an Instruction already accepted or a confirmed blockchain Transaction.

5.4 Records and notices

You must review confirmations, statements and activity regularly. Report discrepancies without undue delay. The deadline and remedy for a Card or regulated payment Transaction are determined by applicable law and Provider Terms and are not shortened by this clause.

6. BALANCES, ASSET LOCATION AND LEGAL CHARACTER

6.1 Aggregated display

The App may display Provider Balances, Smart Account balances, Wallet assets and Vault positions in a single interface and may label them using a reference currency such as EUR or USD. This is a user-interface presentation only. It does not merge balances, change their legal character, make Pulsar their holder or create a single claim against Pulsar.

6.2 Provider and Card balances

A live Feature Schedule must identify one exact legal and technical form for each Provider Balance; it may not leave the balance described merely as one of several possibilities. The schedule must state the person that owes or administers it, beneficial ownership, token and Network if applicable, redemption claim, safeguarding and insolvency treatment, and every material debit, reserve, freeze or conversion power.

A display of “USD”, “EUR” or another currency does not by itself mean you hold fiat currency, a bank deposit or a redeemable claim against Pulsar. Where accepted assets are converted or wrapped into provider-specific representations for Card spending, the conversion, issuer or controller, redemption path, fees and risks must be disclosed before use.

6.3 Wallet and Vault assets

Assets shown in a Wallet or Vault position are recorded on the relevant Network and controlled according to the Wallet and smart-contract configuration. A Vault share represents the rights encoded in the Vault and does not guarantee immediate redemption at the displayed value.

6.4 Data sources and valuation

Balances and valuations may come from Providers, blockchains, nodes, indexers, oracles or market-data services. They may be delayed, estimated, incomplete or wrong. A displayed fiat equivalent is not a Quote or promise of execution. If a discrepancy exists, the finally settled Provider ledger or relevant Network record controls, subject to correction rights under applicable law.

7. WALLETS, CONTROL AND DELEGATED SIGNING

7.1 No blanket custody label

Pulsar will describe each Wallet by its actual control configuration. A statement that a Wallet or protocol is “self-custodial” or “non-custodial” applies only to the disclosed configuration and does not mean that no signer, owner, provider, policy engine, recovery service or smart-contract role can affect transactions or access.

Before a Wallet is created or activated, the Wallet Control Schedule will identify: beneficial ownership and root authority; every signer, cosigner and key custodian; quorum and where each control is enforced; policies, value limits and allowed functions; who can change ownership, signers, policies or allowlists; revocation latency; recovery and export; outside-App access; insolvency consequences; and any power to pause, restrict, debit, sweep, migrate or upgrade the Wallet.

7.2 No unapproved or test configuration

The operative wallet configuration is only the one stated in the accepted Wallet Control Schedule. A development description, contemplated smart-contract wallet, sandbox, testnet or private-mainnet setup is not an operative user configuration. Test environments must use test assets unless a specifically approved production schedule states otherwise.

Pulsar will not migrate existing assets or materially change beneficial ownership, root authority, signer, quorum, policy administrator, outside-App access, recovery, export or withdrawal path by ordinary notice. The affected feature will require a clear impact notice, a reasonable exit opportunity where possible and new express consent before the new control model applies.

7.3 Delegated Action Consent

A Delegated Action is disabled by default. Before enabling it, the App will ask you to accept a Delegated Action Consent in a durable form. For Earn, the permitted actions may include only the following, within the disclosed asset, address, value and duration limits:

• transferring a supported asset between your applicable Smart Account and Earn Wallet;
• creating or reducing a token allowance for the exact Vault or adapter shown in the Vault Schedule;
• depositing into, redeeming from, or claiming assets or rewards from that Vault;
• submitting necessary signatures, UserOperations and gas-sponsorship requests; and
• returning redeemed assets to the destination you selected.

The Consent does not authorize unrelated transfers, arbitrary contract calls, a different Vault or asset, borrowing, leverage, staking, trading or a change of beneficial owner unless you separately and expressly approve that function. Pulsar will not expand any approved signer, asset, contract, function, recipient, amount, fee tolerance, retry rule or duration without new express consent.

7.4 Signing controls and limitations

Only controls stated in the accepted Wallet Control Schedule may be relied on. These may include multiple authorization keys, a quorum, independent cosigners, immutable or change-controlled policies, allowlisted contracts and calldata validation. They reduce risk but do not eliminate compromise, implementation error, malicious policy changes, provider failure or collusion. A valid system signature does not by itself prove valid user authorisation or eliminate responsibility for acting outside the mandate.

Token allowances must be limited by amount or duration where the supported contract permits. If an unlimited allowance is technically required, the App will identify the exact spender and risk prominently and obtain separate express consent before creating it.

Pulsar will retain tamper-evident records of the Consent, policy decision, target, function, amount, route and resulting transaction identifier for the period required by law and its legitimate support and security needs.

7.5 Revocation, expiry and pending actions

You may revoke a Delegated Action using the method and expected effectiveness time stated in the Wallet Control Schedule. Revocation prevents new actions after it becomes effective but may not cancel an Instruction already signed, broadcast, accepted by a Provider or confirmed on a Network. The App will state whether revocation removes a signer, changes an on-chain policy, revokes an allowance or only disables the Pulsar interface.

7.6 Recovery, export and closure

Recovery and export depend on the actual Wallet configuration. Pulsar does not promise that every Wallet is independently accessible outside the App or that every Credential can be recovered. Before activation, the Wallet Control Schedule will state the verified recovery/export method and the consequences of Account closure, Provider outage, insolvency or Pulsar discontinuation. You should complete any available backup or export process promptly.

7.7 Action outside your mandate

If a Pulsar-controlled signer, policy engine, backend, transaction builder or person causes an action outside your accepted Delegated Action Consent, Pulsar will investigate promptly, preserve evidence, take reasonable containment and recovery steps, identify the responsible component and correct or compensate loss for which Pulsar is legally responsible. The action will not be treated as authorised solely because it carried a technically valid signature. Provider and mandatory-law remedies remain available for components controlled by others.

8. INSTRUCTIONS AND TRANSACTION LIFECYCLE

8.1 Review and authorization

Before authorisation, review whether a display is an Indicative Estimate or a Quote and, for a Quote, the asset, amount, source, destination, Network, provider, route, expiry, minimum received, slippage, separately identified fees, gas or fee cap, retry count, cancellation cut-off, approvals and warnings. You are responsible for information you enter, but Pulsar remains responsible for displaying information and constructing Instructions with reasonable care.

8.2 Transaction states

A Transaction may be requested, awaiting authorization, authorized, pending with a Provider, signed, broadcast, included in a block, confirmed, finalized, partially executed, failed, reverted, rejected, cancelled, reversed on a Provider ledger, refunded or subject to recovery. “Complete” in one component does not necessarily mean final settlement of every leg.

A multi-step Transaction may complete only in part. For example, an asset may leave the source Network while a bridge, conversion, deposit or return leg is delayed or fails. The App will use reasonable efforts to show the current state and available remediation, but timing is not guaranteed.

8.3 Finality, cancellation and gas

A confirmed blockchain Transaction is generally irreversible. Pulsar cannot alter a Network record it does not control. A Provider may cancel, reverse, correct or force-debit an entry only on a ledger or Smart Account it controls and only under Provider Terms and applicable law.

Network fees may be charged even if a Transaction fails or reverts. Gas sponsorship is subject to provider limits and may be unavailable, delayed or withdrawn. If sponsorship fails, the App may require a native Network asset or offer another route; it will not submit a route with a different provider, asset, destination, material timing, minimum received or greater user cost without renewed authorisation.

8.4 Errors and recovery

If Pulsar or a Provider makes a processing error, the responsible party may correct the error in accordance with law and Provider Terms. You must not knowingly retain or spend an obvious erroneous credit. Recovery attempts for a wrong address, wrong Network or irreversible Transaction are not guaranteed and may incur costs disclosed and accepted before the recovery attempt.

9. CARD, SMART-ACCOUNT AND PAYMENT FEATURES

9.1 Provider and issuer disclosure

The Card and related regulated services are available only after the exact Regulated Provider, issuer, programme manager and scheme approve the service for you and your country. The Card Feature Schedule will identify each legal entity, authorisation, regulator, country scope and Card Terms before you order or activate a Card. A group brand or programme name is not a substitute for the responsible entity.

9.2 Smart Account and spending authorization

The Card may be linked to a Smart Account containing supported Stablecoins or provider-specific wrapped assets. Under the Card Terms, the Applicable Provider may have permission to reserve, pull, debit, convert or transfer value from that Smart Account to authorize, clear and settle Card Transactions, fees, refunds, reversals and force debits. These powers are different from Pulsar’s permissions over an Earn Wallet and must be disclosed before activation.

9.3 Card Transactions

A Card Transaction may be authorized using a PIN, contactless device, wallet token, card credential, in-App confirmation or another method accepted by the issuer. Authorizations may create holds. Final amounts may differ due to tips, foreign exchange, incremental authorization, offline or delayed processing, merchant category, transport or hotel completion, and late presentment.

You must keep sufficient Available Balance for expected holds, final settlement and fees. A Provider may decline a Transaction because of balance, limits, compliance checks, fraud controls, country, merchant, Network or scheme rules. Pulsar cannot require an issuer or scheme to accept a Transaction.

9.4 Foreign exchange and conversion

A Card Transaction may require conversion between a Digital Asset, provider-specific token, reference currency and settlement currency. The confirmation or fee schedule will identify the rate source, markup and Pulsar, Provider and scheme fees to the extent known. A rate shown before authorization may be indicative where final settlement occurs later.

9.5 Unauthorized Transactions, refunds and chargebacks

Report a lost Card, compromised credential or unauthorised Card Transaction immediately using the 24/7 blocking channel identified in the Card Feature Schedule. You may also contact [email protected], but notice to Pulsar counts as notice to the Regulated Provider only if the schedule expressly says so. Applicable law, Card Terms and scheme rules determine liability, refund, chargeback, evidence and time limits. Nothing in these Terms treats every credentialed Transaction as authorised or waives a mandatory refund right.

A merchant refund or chargeback may take time and may be converted at a different rate. Card purchase chargeback rights do not automatically apply to a blockchain transfer, bridge, exchange, on/off-ramp or account-to-card transfer.

9.6 Safeguarding and protection

The Card Feature Schedule will state whether and how fiat or e-money is safeguarded, which entity owes the corresponding obligation, and what compensation, deposit-guarantee, regulator and ombudsman arrangements apply. Digital Assets and DeFi positions are not bank deposits and are not protected merely because they are accessible beside a Card balance.

10. TRANSFERS, FIAT ACCOUNTS AND ON/OFF-RAMPS

10.1 Conditional availability

The App may enable bank-transfer details, SEPA or other transfers, payment links, card funding, crypto deposits or withdrawals through Applicable Providers. Features, currencies and timelines vary. A roadmap discussion or partner onboarding does not make a feature available.

10.2 Provider relationship

Before use, the App will identify the provider that receives, transmits, converts, issues, redeems or pays out value; the legal nature of the balance; Provider Terms; fees; limits; supported countries; required payer/beneficiary information; and complaints route. A third party may require separate onboarding even if you completed verification elsewhere.

10.3 Transfer information and screening

You must provide complete and accurate beneficiary, account, address, Network, reference, source-of-funds and any legally required originator or beneficiary information. For crypto-asset transfers, the responsible provider may collect, verify, transmit and retain Travel Rule information and may require proof that you control an external wallet. Providers may screen, delay, reject, return, recall or freeze a transfer where required by law, scheme rules or reasonable fraud controls. Processing estimates are not guarantees and intermediary or recipient institutions may deduct disclosed or unavoidable fees.

10.4 Crypto deposits and withdrawals

Send only the supported asset on the exact Network and to the exact address shown. Unsupported tokens, bridged variants, memo/tag errors, address poisoning or sending to a contract that cannot receive the asset can cause permanent loss. Pulsar will use reasonable care in presenting supported routes but cannot recover assets from a Network or address it does not control.

11. EXCHANGE, SWAP AND BRIDGE ROUTING

11.1 Route providers

The App may obtain Indicative Estimates, Quotes and transaction data from one or more aggregators, decentralised exchanges, bridges, solvers, market makers or liquidity providers. The route may interact with multiple independent contracts and Networks. The exact Component Providers, Applicable Provider and route are shown before authorisation. Integration does not make a route component your custodian or contractual provider unless the Feature Schedule and its own terms expressly say so.

11.2 Quotes and execution

An Indicative Estimate cannot be accepted. A Quote is valid only until its stated expiry and specifies the route, slippage, price impact, minimum received, approvals, Pulsar fee, provider fee, bridge-message fee and estimated Network fee. Market movement, liquidity, fee changes, screening, congestion or provider failure may prevent execution. Pulsar does not describe a route as independent, cheapest or best unless the stated comparison method supports that claim and discloses material compensation or exclusions.

11.3 Route risks

Route risks include smart-contract bugs, malicious or compromised tokens, unlimited allowances, bridge or solver failure, liquidity shortfall, MEV and front-running, price impact, depeg, chain reorganization, a stuck message, partial completion, refund to an unexpected asset or Network, and a fee despite failure. The route provider’s status result may differ from final Network settlement.

11.4 Approvals and refunds

The App will identify each token approval and use a limited allowance where the supported contract permits. An unlimited allowance requires the separate warning and consent in Section 7.4. You may need to revoke an approval separately. Refund eligibility, asset, Network and timing depend on the provider and route; a refund is not guaranteed and may be lower after accepted costs or market movement.

12. STABLECOINS, WRAPPED ASSETS AND NETWORKS

12.1 Stablecoin issuer terms

USDC, EURC and other Stablecoins are issued and administered under the exact issuer terms identified in the Feature Schedule. In the EEA, an asset may be an e-money token and the issuer or consent requirements may differ from other regions. Holding a token does not automatically create a direct account with, or direct redemption access to, the issuer. The App will identify the issuer, supported token contract, Network and any material holder or redemption rights.

12.2 Stablecoin risks

A Stablecoin may trade above or below its reference value. The issuer or a public authority may freeze, blacklist, burn, reissue or restrict an address or redemption. Reserve, banking, issuer, regulatory, Network, bridge and liquidity events can cause loss or delay. A Vault may compound these risks.

12.3 Provider-specific wrapped assets

A Provider may convert supported assets into a provider-specific wrapped or settlement token used by its Smart Account or Card system. Such a token is not automatically fiat money, USDC or EURC. The Feature Schedule will identify the issuer or controller, backing or redemption mechanism, insolvency treatment, provider debit rights, supported Networks and material failure risks.

12.4 Network changes

Networks may be private, permissioned, in testing, capacity-limited, forked, paused, upgraded or discontinued. Pulsar may limit onboarding, transaction value or functionality to comply with Network and Provider rules. Pulsar is not required to support a fork, airdrop or new token unless it expressly confirms support.

13. EARN: FEATURE TERMS AND AUTHORIZATION

13.1 Separate acceptance

Earn is a high-risk optional feature. Before the first deposit into each materially different Vault, you must accept the completed Vault Schedule, Wallet Control Schedule, Delegated Action Consent and any applicable Provider Terms. Acceptance of these general Terms alone is not an Earn deposit instruction.

13.2 Exact production flow

The Vault Schedule and Wallet Control Schedule must describe every production step from the source balance to the Vault and back, including each intermediate Wallet, conversion, transfer, allowance, signer, contract call, share holder, gas arrangement and destination. No provider, chain, asset, vault, curator or route is incorporated into these Terms merely because it has been discussed, integrated in a sandbox, announced or used in a Base or private-mainnet test.

Because the flow may run in the background, your Deposit or Withdrawal instruction may authorize multiple Transactions and Delegated Actions. Pulsar will not treat a displayed strategy as an instruction. The instruction begins only after the required confirmation and may still fail or complete partially.

13.3 Vault Schedule

Before authorisation, the App will display or link in a durable form: the Network; asset and token contract; Vault and share-token addresses and version; legal and on-chain identity of the owner, curator, allocator, guardian, sentinel, fee recipient and other privileged roles; strategy and permitted markets/adapters; caps, gates, timelocks and withdrawal constraints; fees and compensation recipients; APY method and timestamp; delegated permissions; audits and their limitations; migration and emergency controls; and the risks required by Appendix 2.

13.4 Nature of Earn

Earn is an interaction with smart contracts and DeFi markets. It is not a bank deposit, e-money balance, fixed-interest savings account or guarantee. Its regulatory classification depends on the exact facts and applicable law and is not determined by a label in these Terms. Pulsar does not promise return of principal, a minimum APY, liquidity on demand or any particular tax treatment.

13.5 APY, fees and rewards

APY is variable, may be based on recent or projected performance and may exclude or include incentives as stated. It can fall to zero or become negative after loss, fees or depeg. The Vault Schedule will explain the data timestamp, calculation window, compounding assumption, protocol, curator, performance, management and Pulsar fees, gas and other costs. Rewards may change, expire, be unavailable or have no value.

13.6 Withdrawal

A withdrawal request is an instruction to redeem or transfer the position. It is not a refund. Withdrawal may be delayed, partially filled, executed in kind, subject to a gate, capped, paused or impossible at the expected value because of liquidity, loss, Provider or Network conditions. The App will not promise immediate access unless the exact Vault supports it at the time.

14. EARN RISKS, INCIDENTS AND RECOVERY

14.1 Total loss risk

Earn may result in partial or total loss. You should not deposit assets you cannot afford to lose. Audits, formal verification, monitoring, timelocks, caps, multisignatures, policies, sentinels, curators and cover can reduce particular risks but do not eliminate them.

14.2 Material risk categories

Risks include, without limitation:

• a bug, exploit, unintended interaction, upgrade, migration, malicious token or failure in the Vault, adapter, market, wallet, bridge, oracle, Network or other composed protocol;
• oracle delay, manipulation or failure; liquidation failure; bad debt; insufficient collateral; interest-rate-model or market-design failure;
• Stablecoin or collateral depeg, issuer or authority freeze/blacklist, reserve or redemption failure, concentrated exposure or market illiquidity;
• insufficient idle liquidity, withdrawal queue, run, gate, cap, penalty, in-kind exit, delayed deallocation or inability to obtain the expected asset;
• error, compromise, misconduct or change by an owner, curator, allocator, sentinel, guardian, fee recipient, governance body, adapter registry, multisig or other privileged role;
• timelock, cap, fee, gate, market or allocation changes that alter risk or return after deposit;
• Delegated Action, signer, cosigner, policy, key, device, authentication, backend, cloud, node or relayer compromise or outage;
• MEV, front-running, congestion, reorganization, finality failure, fork, bridge failure, gas spike or incorrect transaction construction;
• inaccurate data, delayed indexer, wrong address/version, misleading APY or material integration error; and
• legal, sanctions, tax or regulatory change that restricts access, transfer, redemption, recovery or availability.

14.3 Emergency measures

If Pulsar reasonably suspects a security, legal, protocol or market-integrity incident, it may proportionately disable new deposits, remove a strategy from general discovery, revoke a Pulsar-controlled signer, reduce a policy, delay an unsubmitted Instruction, show warnings or coordinate with Providers. Disabling new deposits or discovery will not intentionally hide an existing position or its available exit information. Pulsar will preserve position records and the verified withdrawal, export or Provider-contact path where legally and technically possible, and will explain any dependency that prevents access. Pulsar will give notice where practicable and lawful. These actions may not pause the Vault, recover assets or stop a Transaction already signed or confirmed.

14.4 Exploit and recovery allocation

Pulsar does not promise to reimburse a protocol loss. Before Pulsar administers assets, compensation, settlements, recoveries or rewards for affected users, it will publish or provide a recovery policy explaining eligibility, evidence, allocation method, custody or segregation, deductions, sanctions checks, distribution timing, treatment of disputed and unclaimed amounts, and the responsible legal entity. Pulsar will not retain a user-specific recovery as its own revenue without a lawful and prominently disclosed basis. Timing and amount are not guaranteed. Pulsar remains responsible for loss caused by its own breach or negligence to the extent required by law.

15. COVER OR PROTECTION ARRANGEMENTS

15.1 No cover by default

No Wallet, Smart Account, Vault, principal, yield or Transaction is covered or insured merely because the App mentions security, protection, a provider discussion or a possible partner. Unless a separate Cover Disclosure is active and accepted for the exact position, you bear the full loss risk described in these Terms.

15.2 Required Cover Disclosure

If Pulsar offers access to a cover or protection arrangement, the App must disclose before activation: the legal provider and product; whether it is insurance, discretionary mutual cover or another arrangement; the exact covered Vault, address, Network and asset; covered events; exclusions; deductible or first-loss amount; cover amount and capacity; period and renewal; premium and how it is deducted; claimant/member and beneficiary; proof-of-loss requirements; filing delay and deadline; assessment and appeal process; payout asset; and what happens if capacity, terms or the Vault changes.

The words “covered”, “protected” and “insured” will be used only as supported by the operative cover wording. A public capacity figure or price for another Vault is not a quote for you. Cover may exclude depeg, phishing, key compromise, frontend attacks, market loss and events outside the designated protocol, and claims may be subject to member or committee assessment.

15.3 No guarantee of claim

Pulsar does not guarantee that a claim will be accepted or paid. Pulsar will not make itself the claimant or beneficiary for users unless the legal structure, authority, allocation method and user rights are expressly documented. Pulsar will provide reasonable evidence and cooperation within its control where it has undertaken to administer a claim.

16. REWARDS, REFERRALS AND PROMOTIONS

Rewards, cashback, points, referral bonuses, yield grants and promotions are governed by separate dated terms shown before participation. Those terms identify the promoter, eligibility, start and end dates, qualifying action, calculation, cap, funding source, vesting or expiry, tax treatment, abuse rules and complaint route. They may be funded by Pulsar or a partner, conditional, non-transferable or unavailable in some countries. Points have no cash value, ownership, governance, equity, revenue-share or redemption right unless the applicable promotion terms expressly create one. A sponsored reward is not user-owned principal and does not increase the guaranteed value of a Vault position.

17. FEES, RATES AND LIMITS

17.1 Fee disclosure

Before a paid Transaction, the App will display the fees and amounts known to Pulsar, including any Pulsar fee, Provider fee, exchange markup or spread, Vault fee, Network fee and estimated third-party deduction. Variable or unknowable fees will be identified as estimates and the basis explained. You authorize only the fee and route presented, subject to immaterial Network variation disclosed in the confirmation.

17.2 No hard-coded launch fee

Fees and FX markups may change and are not fixed by a percentage stated in these Terms. The current fee schedule and transaction confirmation govern. Provider fees may change under Provider Terms. Where law requires advance notice or consent, that requirement applies.

17.3 Limits

Pulsar or a Provider may apply transaction, balance, velocity, country, asset, Network, Card, Vault or risk limits. The App will display applicable limits where practicable. Limits are not a promise of available liquidity or execution and may be reduced for security, compliance, Network or Provider reasons.

17.4 Compensation and conflicts

Pulsar may receive a disclosed fee, spread or markup, interchange share, referral payment, routing rebate, vault-related compensation, sponsored-reward funding or other benefit from a Provider. Before the relevant paid feature is used, the Fee and Conflict Schedule will identify the type of benefit, who pays it, how it is calculated where known, whether it changes the amount you pay or receive, and whether it may influence a displayed default, ranking or recommendation. Pulsar will not describe a route as the cheapest, best or optimal unless the disclosed method and current data support that claim. A hidden settlement conversion or provider charge will not be presented as a zero-fee route.

17.5 Tax and legal reporting

Transactions, rewards, conversions, Card use, transfers and Vault positions may have tax consequences. Pulsar does not provide individual tax, accounting or legal advice. You are responsible for obtaining advice and filing or paying amounts applicable to you. Pulsar or a Provider may collect tax-residency or reporting information and may report, withhold, restrict or disclose information where law requires, including under applicable crypto-asset reporting rules. Any statement or export is tax-supporting information, not a guarantee of a tax result or a completed filing.

18. PROHIBITED USE

You must not use the Platform for an activity listed in Appendix 1 or prohibited by law or Provider Terms. You must not attempt to evade verification, sanctions, limits, Card controls, a policy, Network restriction or a Provider decision. Pulsar may investigate suspected misuse and share information with Providers or authorities where lawful.

19. THIRD-PARTY DEPENDENCIES AND SERVICE AVAILABILITY

19.1 Dependencies

The Platform depends on Providers, app stores, Networks, nodes, relayers, cloud services, data services, smart contracts, banks, card schemes and telecommunications. Availability, performance and terms can change. Pulsar will use reasonable care in selecting, integrating and monitoring material Providers where such a duty applies, but cannot guarantee a third party’s performance.

19.2 Maintenance and incidents

Pulsar may perform maintenance or suspend a feature for security, legal, Provider or technical reasons. Where practicable, Pulsar will provide advance notice of planned material downtime and timely incident information. It will distinguish what Pulsar has paused from what remains active on a Network.

19.3 Provider changes

Pulsar may replace or add a Provider only after making the required disclosure and obtaining any acceptance required by law or the new Provider. A change that materially changes asset control, legal counterparty, fees, risk or withdrawal rights will not be treated as a cosmetic update.

19.4 Insolvency and loss of access

A Provider, issuer, bank, bridge operator, protocol contributor, curator, wallet-infrastructure provider or other dependency may become insolvent, cease operating, lose authorisation or deny access. Asset ownership, segregation, safeguarding, redemption and creditor status can differ by feature and may be disputed. The applicable Feature Schedule will state the available information and verified exit or claim route; Pulsar does not promise that a label such as ‘non-custodial’, ‘safeguarded’ or ‘on-chain’ removes insolvency or access risk.

19.5 Test and preview environments

A sandbox, testnet, private-mainnet test, preview, waitlist, pilot, marketing announcement, signed commercial agreement or technical integration does not by itself mean a feature is approved or live for users. Test environments use test assets only unless a separately approved production disclosure expressly states otherwise. Pulsar will label preview features and will not invite a production-value transfer until the applicable release gates are complete.

20. SUSPENSION, RESTRICTIONS AND SECURITY ACTIONS

20.1 When action may be taken

Pulsar may proportionately suspend an Account, session, signer, Instruction or feature where it reasonably believes this is necessary to prevent fraud or harm, protect security, investigate a breach, comply with law, enforce these Terms or respond to a Provider or Network restriction. A Provider may take separate action under Provider Terms.

20.2 Limits of a suspension

Suspending the App does not necessarily freeze a Wallet or Network asset. Conversely, a Provider may restrict a Provider Balance even if the App remains accessible. A suspension will not transfer, confiscate or forfeit your asset merely because access is restricted. Pulsar will describe the scope, preserve records and position visibility, and provide the verified withdrawal, export, urgent Card-blocking or Provider-contact steps where lawful and technically possible. A restriction on new activity will not silently disable an available exit from an existing position.

20.3 Notice and review

Pulsar will notify you of a material restriction and give reasons unless prohibited by law or doing so would undermine security or an investigation. You may request review through support. Pulsar will restore access when the grounds no longer apply, subject to Provider control and law.

21. CLOSING THE ACCOUNT AND EXIT

21.1 Your request

You may request Account closure through the App or support. Before closure, you should complete or cancel pending Transactions, withdraw or transfer assets, redeem Earn positions where possible, download statements and complete any Wallet export or recovery process disclosed to you.

21.2 Pending and restricted assets

Closure may be delayed while a Transaction, dispute, chargeback, compliance review, security incident, legal hold or Vault withdrawal remains pending, but only to the extent lawful and necessary. Closing the Account does not cancel an enforceable debt or remove your rights in assets that remain in a Wallet or with a Provider.

21.3 Orderly discontinuation

Before Pulsar materially discontinues a Wallet or Earn integration, it will provide reasonable notice where practicable and lawful, explain the verified exit path, and allow a reasonable transition period. Emergency or Provider events may shorten the period. Pulsar does not promise independent access after shutdown unless the Wallet Control Schedule confirms and Pulsar has tested that path.

21.4 Provider closure

Closing the Pulsar Account does not automatically close a Provider account, Card or Wallet. Provider Terms determine their closure. Pulsar will provide reasonable routing information and cooperation for components it integrated.

21.5 Termination by Pulsar

Pulsar may terminate these Terms or discontinue a feature for a material breach, illegality, fraud or security risk, loss of a necessary Provider or authorisation, or a genuine product discontinuation. Unless urgent action or law prevents it, Pulsar will give reasonable durable notice, the reason, effective date and available review or complaint route. Termination will not remove accrued rights, mandatory remedies, records or an available orderly withdrawal, Wallet export or Provider claim path.

21.6 Death, incapacity and dormant Accounts

An authorised representative or estate may contact support if a user dies or lacks legal capacity. Pulsar may require official and identity evidence, court or succession documents and sanctions checks before disclosing information or assisting with a Provider process; it cannot bypass a Wallet key or Provider rule. Pulsar may apply proportionate security restrictions to a long-dormant Account after notice where practicable, but dormancy alone does not transfer or forfeit assets. Any dormancy fee must be separately disclosed and lawful.

22. PERSONAL DATA AND BLOCKCHAIN DATA

22.1 Privacy notice

Pulsar processes personal data as described in the Pulsar Privacy Notice presented before registration. The notice identifies purposes, legal bases, recipients, international transfers, retention and your rights. Provider privacy notices apply to data each Provider processes within its role.

22.2 Controller roles

Pulsar and an Applicable Provider may each act as an independent controller for different purposes, as joint controllers for a defined operation, or one may process data for the other under a contract. The Feature Disclosure or privacy notice will explain the material allocation and contact point. A general statement that every provider is only a processor is not made.

22.3 Data categories

Depending on the feature, data may include identity and contact details, verification and liveness results, device and security data, Card and payment data, wallet addresses, on-chain activity, balances, transaction routes, support communications, Delegated Action consents and policy logs, fraud signals and tax-related information.

22.4 Public blockchain

Blockchain transactions and wallet addresses are public or shared with Network participants and may be permanent. Pulsar cannot erase a Network record. Deleting the Account does not delete public blockchain data, though Pulsar will apply legal retention and rights to the off-chain personal data it controls.

22.5 Consent, verification and transfers

Acceptance of these Terms or a privacy notice is not consent to every data use. Where consent is the legal basis, it will be specific, informed and separately withdrawable without affecting earlier lawful processing. Identity verification may involve document, facial-image and liveness data and sharing with the identified verification or regulated Provider; the privacy notice will state whether biometric data is created or retained. International transfers will use an applicable lawful mechanism and disclosed safeguards. Optional marketing and optional automation will not be bundled with access unless legally necessary for the requested service.

23. INTELLECTUAL PROPERTY, SOFTWARE AND APP STORES

23.1 Licence

Pulsar grants you a personal, limited, revocable, non-exclusive and non-transferable licence to use the App for its intended purpose while your Account is active and you comply with these Terms. No intellectual property right is transferred to you.

23.2 Restrictions

Except where law permits, you must not copy, sell, reverse engineer, interfere with, scrape, bypass security, introduce malware or automate abusive access to the Platform. This restriction does not prevent lawful interoperability, portability, security research protected by law or use of an independent service outside the Platform. Open-source components remain subject to their licences.

23.3 App stores

Apple, Google and other app stores are not parties to these Terms and are not responsible for the Platform, support or claims, except as their own mandatory terms provide. You must comply with the applicable store terms. Store providers may be third-party beneficiaries of the licence provisions where their rules require.

24. WARRANTIES, RISK ALLOCATION AND STANDARD OF CARE

24.1 Digital-service conformity

Pulsar will provide the Platform with the functionality, compatibility, security, updates and support required by these Terms, pre-contract information and mandatory digital-service law for the legally required period. If Pulsar fails to supply or the digital service is not in conformity, you retain the correction, price reduction, termination, refund, damages and other remedies that applicable law makes available. Nothing in an ‘as available’ description removes a mandatory conformity, update or security duty.

24.2 Matters outside reasonable control

Pulsar does not warrant that markets, Networks, Providers, routes, Vaults or third-party data will be uninterrupted, error-free or profitable. Pulsar is not responsible for loss caused exclusively by a Provider, Network, protocol, market movement or your act outside Pulsar’s reasonable control. This does not exclude responsibility where Pulsar’s selection, description, integration, Instruction construction, promised control or security failure materially caused or increased the loss.

24.3 Force majeure

A party is not liable for delay caused by an event beyond its reasonable control to the extent the party could not reasonably prevent or mitigate it. Cyber incidents are not automatically force majeure if reasonable security measures were not maintained. Payment obligations, accrued rights and mandatory consumer remedies are not extinguished by this clause.

25. LIABILITY

25.1 Causation and foreseeability

To the extent permitted by law, Pulsar is responsible for direct loss that was reasonably foreseeable when you accepted the relevant terms and was caused by Pulsar’s breach of these Terms or an applicable duty. Pulsar is not responsible for loss to the extent caused by your fraud, wilful misconduct, failure to take a reasonable security step after a clear warning, or a third party or event outside Pulsar’s reasonable control.

25.2 Excluded categories

If you use the Platform as a consumer, Pulsar does not exclude loss that law requires it to compensate. To the extent law permits, Pulsar is not liable for business loss, loss of profit, opportunity or goodwill arising from personal consumer use, or remote and unforeseeable indirect loss.

25.3 Non-excludable liability

Nothing in these Terms excludes or limits liability for fraud, wilful misconduct, gross negligence, death or personal injury caused by negligence, unlawful processing of personal data, an unauthorised action caused by Pulsar acting outside an accepted Delegated Action Consent, mandatory unauthorised-payment or execution-error rights, mandatory digital-service remedies, or any other liability that cannot lawfully be excluded or limited. No separate monetary cap applies to a consumer claim unless a later, prominently disclosed term is validly agreed and lawful for that claim.

25.4 Third-party claims and your misconduct

You are responsible for loss and reasonable enforcement costs caused by your fraud, wilful misconduct, knowing unlawful use or material breach. You do not give Pulsar a broad indemnity for ordinary consumer use, a Provider’s failure or a claim caused by Pulsar’s own act.

26. CHANGES TO TERMS, FEATURES AND PROVIDERS

26.1 Changes to these Terms

Pulsar may change these Terms for a valid reason, including a legal, regulatory, security, Provider, technical or product change. Pulsar will explain the material change and effective date in a durable medium. Unless a shorter period is necessary for law or urgent security, material adverse changes will receive reasonable advance notice. A two-month period applies only where required for the relevant payment-service framework, not automatically to every software term.

26.2 Consent and right to stop

Where law or the nature of the change requires express consent, Pulsar will request it. Continued use will not be the only acceptance mechanism where that would be unlawful or unfair. You may stop using the affected feature and close the Account before an adverse change takes effect, subject to pending Transactions and Provider Terms.

26.3 Urgent and favourable changes

Pulsar may make an immediate change required by law, a competent authority or an urgent security threat, or a change unambiguously in your favour. Pulsar will notify you as soon as reasonably practicable and will not use this clause to impose an unrelated adverse commercial change without notice.

26.4 Changes requiring a new decision

Pulsar will not silently migrate an existing asset or expand control over it. A material change to the legal counterparty, asset form, Network, Wallet owner or root of trust, signer or quorum, policy administrator, Delegated Action scope, Vault address or privileged roles, fee method, withdrawal path, insolvency treatment or cover requires a clear impact notice and an exit opportunity where feasible. A new express acceptance is required before the changed control or mandate applies where law, Provider Terms or the nature of the change requires it. Refusal will not authorise Pulsar to move an existing asset except where separately authorised or required by law.

27. COMMUNICATIONS, SUPPORT AND COMPLAINTS

27.1 Electronic communications

Pulsar may provide agreements, notices, confirmations and statements electronically through the App or the email registered to your Account. Keep your contact details current and retain copies. Where law requires a durable medium, the communication will be downloadable or otherwise storable and unchanged.

27.2 Support and complaints

Contact [email protected] for support or a complaint. Include your Account email, Transaction identifier, date, amount and a clear description, but never send private keys or recovery phrases. Pulsar will issue a case identifier, acknowledge a complaint about its own service within five Business Days and provide a reasoned final response within thirty calendar days, or sooner where mandatory law requires. If exceptional complexity prevents a final response, Pulsar will explain the reason and revised lawful deadline. The applicable Feature Schedule identifies the responsible Provider, its direct complaint route and statutory response period. Notice to Pulsar counts as notice to a Provider only where that schedule expressly says so; otherwise Pulsar will promptly route or tell you how to submit the Provider complaint.

27.3 External routes

If you are dissatisfied, you may contact the competent consumer-protection authority, including the Romanian National Authority for Consumer Protection (ANPC) and its alternative-dispute-resolution service (SAL) where applicable, or the financial ombudsman, regulator or alternative-dispute body identified in the Provider Terms. Current ANPC information is available at anpc.ro/sal. Pulsar will not direct users to the discontinued EU Online Dispute Resolution platform. Nothing in these Terms requires completion of Pulsar’s process before you use a right available by law.

28. GOVERNING LAW AND COURTS

These Terms are governed by Romanian law. If you are a consumer resident in another country, this choice does not deprive you of mandatory protection available under the law that would apply without this choice. You may bring proceedings in the courts available under mandatory consumer-jurisdiction rules, including, where applicable, the courts of your habitual residence. These Terms do not require exclusive venue in Sibiu.

29. GENERAL

29.1 Assignment

You may not transfer your Account or these Terms without Pulsar’s consent. Pulsar may transfer these Terms as part of a reorganisation, financing or sale only where the transfer does not reduce your rights and you receive notice as required by law. Provider contracts may have separate assignment rules.

29.2 No waiver and severability

A delay in enforcing a right is not a waiver. If a term is invalid or unfair, it will not bind the consumer to that extent; the remainder continues where it can operate fairly and lawfully. A court may not rewrite an unfair consumer term merely to preserve an excessive protection for Pulsar.

29.3 Entire agreement

These Terms, applicable Feature Terms and documents expressly incorporated into them form the agreement between you and Pulsar about the Platform. They do not replace Provider Terms. Public claims, in-App statements and pre-contract information remain relevant where applicable law gives them contractual effect.

29.4 Language

The Platform may provide these Terms in English and other languages. The version presented and accepted in the language required by applicable law governs to the extent mandatory. Pulsar will not rely on an English-priority clause to remove a consumer right created by a required translation.

29.5 Survival

Provisions concerning completed Transactions, accrued fees, security records, privacy, intellectual property, liability, complaints, recovery and disputes survive closure to the extent necessary for their purpose and permitted by law.

APPENDIX 1: PROHIBITED ACTIVITIES

You must not use, or attempt to use, the Platform or an Applicable Provider for:

• fraud, theft, deception, money laundering, terrorist financing, sanctions evasion, bribery, corruption, tax evasion or other unlawful conduct;
• transactions involving a sanctioned, blocked or restricted person, address, country, territory, asset, merchant or activity;
• illegal gambling, controlled substances, weapons, exploitation, trafficking, counterfeit goods, ransomware, stolen data, malware or unlawful adult content;
• market manipulation, wash trading, spoofing, front-running, abusive arbitrage, exploiting a pricing or technical error, or manipulating a reward or referral programme;
• circumventing KYC, source-of-funds, country, Card, Network, policy, balance, velocity or other limits;
• using another person’s identity, Account, Card, Wallet, bank account or funds without lawful authority, or operating as an undisclosed nominee, money mule or payment intermediary;
• unlicensed money transmission, payment processing, custody, exchange, brokerage, securities, investment, lending or other regulated activity;
• interfering with, probing, overloading, reverse engineering or compromising the Platform, a Provider, signer, policy engine, smart contract, Network, API or data source;
• automated access, bots or scripts that exceed published limits, evade controls or harm users or systems;
• sending spam, phishing, malicious approvals, deceptive tokens, address-poisoning transactions or content that infringes rights; or
• any activity prohibited by Provider Terms, Card scheme rules or applicable law.

APPENDIX 2: MINIMUM FEATURE DISCLOSURE

Before a feature or materially different Transaction is activated, Pulsar will present the applicable information below in the App or another durable medium. Information that is not applicable may be omitted, but a material fact may not be hidden merely because a third party supplies the feature.

Provider and legal role

• legal entity, registered address and country;
• whether it is the issuer, programme manager, payment/e-money provider, wallet infrastructure provider, route provider, protocol, curator, cover provider or another role;
• regulatory status, licence or authorisation identifier, authorised service categories, passport territory and competent authority where relevant;
• direct Provider Terms, version, link, privacy notice, acceptance method, complaints route and country eligibility;
• whether Pulsar is a referrer, technical integrator, agent, distributor, outsourced provider or another role, and whether notice to Pulsar counts as notice to the Provider.

Asset and balance

• legal and technical form of the balance; token name, contract and Network;
• beneficial owner or holder and the legal claim, if any, against an issuer, Provider or safeguarding institution;
• party administering, issuing, redeeming or able to debit, freeze, blacklist or restrict it;
• safeguarding, segregation, compensation or deposit-guarantee status, insolvency treatment and creditor position, or a clear statement that a protection does not apply;
• conversion and wrapping chain, hidden settlement assets, redemption, migration and exit path.

Wallet control

• owner/root of trust; additional signers, key quorum and privileged roles;
• legal entity controlling each signer or key share and the technical system enforcing each control;
• allowed functions, recipients, contracts, assets, per-action and cumulative value limits, fee/gas and slippage caps, retry count, duration, expiry and revocation latency;
• who can change owner, policies, allowlists, quorum or signers, and which controls a signer cannot change;
• pending-action treatment after revocation; export, recovery, outside-App access, closure, outage and insolvency consequences.

Transaction and pricing

• whether the display is an Indicative Estimate or Quote; source, destination, route, Network, Quote expiry, minimum received and material dependencies;
• Pulsar, Provider, spread/markup, Vault, Network and estimated third-party fees;
• route-provider identity and data shared, including originating wallet address where applicable;
• limits, expected timing, finality, cancellation cutoff, retry and batch rules, refund and partial-execution rules;
• Travel Rule or originator/beneficiary information that may be collected or transmitted.

Card and regulated service

• licensed provider, issuer, programme manager, card scheme, regulator and country-specific availability;
• Card Terms, fees, FX, holds, force debits, unauthorized-transaction and chargeback process;
• precise balance debited and every conversion or settlement step;
• safeguarding and insolvency treatment, 24/7 loss/blocking route, complaints and ombudsman or ADR information.

Vault and Earn

• Vault/share-token address and version, Network, asset, curator, owner, allocator, sentinel, gates and other material roles;
• underlying markets/adapters, caps, timelocks, fees, liquidity and withdrawal mechanics;
• APY methodology, audits and limitations, Delegated Action permissions and incident controls;
• smart-contract, oracle, bad-debt, liquidity, governance, depeg, blacklist, Network, bridge, signer and composability risks.

Compensation and conflicts

• each Pulsar fee, spread, markup, interchange share, referral payment, rebate, vault-related payment, sponsored-reward funding or other Provider benefit;
• payer, recipient and calculation or reasonable basis where known;
• whether the benefit affects the amount paid or received or may influence a default, ranking, routing or recommendation;
• selection and ranking criteria and any material limitation on a cheapest, best or optimal-route claim.

Data, tax and records

• controller, joint-controller and processor roles; identity, liveness or biometric handling; Provider and international-transfer recipients;
• public and persistent on-chain data and any originating-address sharing;
• tax-residency, withholding or reporting obligations and the entity responsible;
• record access, statement export, retention and treatment after suspension, closure or provider failure.

Cover, if any

• provider/product and legal nature; exact covered position and period;
• covered events, exclusions, deductible, capacity, premium and termination;
• claimant/member, beneficiary, evidence, filing window, assessment, appeal and payout;
• clear statement that claim acceptance and payment are not guaranteed.

APPENDIX 3: EARN HIGH-RISK ACKNOWLEDGEMENT

Before the first Earn deposit into each materially different Vault, the App will require an affirmative acknowledgement substantially covering the following points:

• I understand this is a DeFi Vault position, not a bank deposit or guaranteed savings product, and I may lose all deposited assets.
• I reviewed the exact asset, Network, Vault address/version, curator and material roles, fees, APY method and withdrawal constraints.
• I understand the disclosed Delegated Action and that approved server-side signers may submit policy-permitted transactions without a new signature from me for every step.
• I understand audits and security controls do not eliminate smart-contract, oracle, bad-debt, liquidity, Stablecoin, governance, bridge, signer and Network risks.
• I understand APY is variable, withdrawals may be delayed or incomplete, and a failed Transaction may still consume Network fees.
• I understand no cover or insurance applies unless a separate Cover Disclosure for this exact position is active and accepted.

This acknowledgement records that the risks were presented and understood. It does not waive any claim for misdescription, an action outside an accepted mandate, fraud, negligence, breach of data-protection or security duties, mandatory digital-service remedies or another right that cannot lawfully be waived.

~ END OF TERMS ~