Risk Disclosure & Financial Services Disclaimer

1. Important Information

DAT PAY is a financial technology and infrastructure platform operated by HACHTHER SARL.

DAT PAY may provide technology, software, interfaces and connectivity through which eligible users can access financial, payment and digital asset services.

Financial services may involve significant risks.

Before using any DAT PAY service, you should understand the nature of the relevant service, the applicable fees, the relevant risks and the identity of the institution responsible for providing the underlying regulated service.

Nothing on the DAT PAY website, client console or related communications constitutes investment, financial, legal, tax or accounting advice unless expressly stated otherwise and lawfully provided.

2. DAT PAY’s Regulatory Role

HACHTHER SARL does not represent itself as a bank, payment institution, electronic money issuer, money transfer institution, custodian, investment manager, broker, securities firm or virtual asset service provider unless and to the extent that it holds the applicable authorisation.

Where a regulated financial service is provided through an authorised third party, that institution is responsible for the regulated activity within the scope of its authorisation.

The availability of a financial service through DAT PAY does not mean that HACHTHER SARL itself is authorised to provide that service.

3. No Investment Advice

Information made available through DAT PAY does not constitute:

• investment advice;
• financial advice;
• trading advice;
• portfolio management advice;
• securities advice;
• digital asset investment advice;
• legal advice;
• tax advice;
• accounting advice.

You should obtain independent professional advice before making financial decisions where appropriate.

4. No Guarantee of Financial Outcomes

DAT PAY does not guarantee:

• profits;
• investment returns;
• capital appreciation;
• exchange rate outcomes;
• liquidity;
• transaction availability;
• transaction execution;
• asset value;
• future market conditions.

Past performance does not guarantee future results.

5. General Financial Risk

Financial services can expose you to:

• market risk;
• liquidity risk;
• counterparty risk;
• settlement risk;
• foreign exchange risk;
• operational risk;
• technology risk;
• cyber risk;
• regulatory risk;
• legal risk;
• fraud risk.

You should only use a financial service after considering whether the associated risks are appropriate for you.

6. Payment Risk

Payments may be affected by:

• incorrect beneficiary information;
• bank processing delays;
• payment network interruptions;
• compliance reviews;
• sanctions screening;
• fraud controls;
• liquidity constraints;
• intermediary institutions;
• public holidays;
• technical failures;
• regulatory restrictions.

A payment instruction may not settle immediately after submission.

A payment may be delayed, rejected or returned where required by law, regulation, compliance controls or the applicable Service Provider.

7. Cross-Border Payments

Cross-border transactions may involve multiple financial institutions, payment networks and jurisdictions.

As a result, a transaction may be subject to:

• intermediary processing;
• additional verification;
• sanctions screening;
• local regulatory requirements;
• foreign exchange conversion;
• correspondent banking requirements;
• transaction limits;
• additional fees.

The final amount received may differ from the amount initially instructed because of applicable fees, exchange rates or intermediary charges.

8. Foreign Exchange Risk

Currency conversion involves foreign exchange risk.

Exchange rates may change between:

• the time a transaction is initiated;
• the time a rate is displayed;
• the time a transaction is confirmed;
• the time a transaction is executed;
• the time funds are received.

Where a conversion is performed by a third-party provider, the applicable exchange rate and fees may be determined by that provider.

DAT PAY does not guarantee the availability of any particular exchange rate.

9. Currency Conversion

Where DAT PAY displays multiple currency balances or conversion functionality, the displayed balance or conversion rate may be based on information supplied by an underlying financial institution or service provider.

A displayed balance does not necessarily represent a bank deposit or account held by HACHTHER SARL.

The legal nature of the underlying funds depends on the applicable account and service structure.

10. Digital Asset Risk

Digital assets can involve substantial risk.

Depending on the asset and service, risks may include:

• extreme price volatility;
• liquidity limitations;
• permanent loss;
• fraud;
• theft;
• cyberattacks;
• regulatory restrictions;
• counterparty failure;
• blockchain failure;
• smart contract vulnerabilities;
• protocol changes;
• market manipulation;
• loss of private keys;
• transaction irreversibility.

Digital assets may lose some or all of their value.

You should not use funds that you cannot afford to lose when engaging in high-risk digital asset activities.

11. Stablecoin Risk

Stablecoins are digital assets designed to maintain a reference value against a currency, commodity or other asset.

A stablecoin may nevertheless:

• lose its intended peg;
• experience liquidity constraints;
• experience redemption restrictions;
• become subject to regulatory restrictions;
• depend on reserves or counterparties;
• experience issuer-related risks;
• experience blockchain or smart contract risks.

A stablecoin should not automatically be treated as equivalent to fiat currency or as a guaranteed bank deposit.

The risks associated with a particular stablecoin depend on its issuer, reserve structure, legal framework, blockchain, redemption mechanism and market conditions.

12. Blockchain Network Risk

Blockchain networks operate independently of DAT PAY.

Networks may experience:

• congestion;
• delays;
• outages;
• reorganisation;
• forks;
• protocol upgrades;
• validator failures;
• unexpected technical events;
• increased transaction fees.

DAT PAY cannot guarantee the availability or performance of any blockchain network.

13. Blockchain Transaction Finality

Some blockchain transactions may become practically or technically irreversible once confirmed.

You are responsible for verifying:

• wallet address;
• blockchain network;
• asset;
• amount;
• transaction details.

Sending an asset to an incorrect address or unsupported network may result in permanent loss.

DAT PAY may not be able to recover assets sent incorrectly.

14. Digital Asset Wallet Risk

Wallets may be hosted by a service provider or controlled directly by the user.

Where you control your own wallet credentials, you are responsible for protecting:

• private keys;
• recovery phrases;
• authentication credentials;
• wallet access information.

Loss or compromise of these credentials may result in permanent loss of access to digital assets.

DAT PAY cannot guarantee recovery of assets controlled through self-custody arrangements.

15. Self-Custody Risk

Self-custody means that the user may have direct responsibility for controlling access to digital assets.

Depending on the architecture, DAT PAY may not have the ability to:

• recover private keys;
• reverse blockchain transactions;
• restore access to a lost wallet;
• cancel a confirmed transaction;
• recover assets sent to an incorrect address.

Users should maintain appropriate security and recovery procedures for credentials under their control.

16. Custody Risk

Where digital assets or funds are held by a third-party custodian or financial institution, the relevant institution may be responsible for safeguarding those assets.

Custody arrangements may be subject to:

• insolvency risk;
• operational risk;
• cyber risk;
• regulatory risk;
• counterparty risk;
• withdrawal restrictions.

Users should review the terms governing the relevant custody arrangement.

17. Counterparty Risk

Financial services may involve third-party counterparties.

A counterparty may experience:

• financial difficulties;
• insolvency;
• operational failure;
• regulatory restrictions;
• cyber incidents;
• liquidity problems.

DAT PAY does not guarantee the financial condition or continued operation of every third-party institution involved in a transaction.

18. Third-Party Service Providers

DAT PAY may rely on third-party financial institutions, payment providers, technology providers, compliance providers and infrastructure providers.

The failure or interruption of a third-party service may affect DAT PAY services.

Third-party providers may apply their own:

• onboarding requirements;
• compliance requirements;
• transaction limits;
• fees;
• restrictions;
• terms;
• risk controls.

19. Compliance and Transaction Reviews

Transactions may be delayed or restricted because of:

• KYC or KYB requirements;
• sanctions screening;
• AML/CFT monitoring;
• fraud prevention;
• source of funds checks;
• source of wealth checks;
• regulatory requirements;
• transaction monitoring;
• third-party compliance requirements.

A transaction being delayed or reviewed does not necessarily mean that wrongdoing has occurred.

20. Account Restrictions

DAT PAY or an applicable Service Provider may restrict or suspend access where necessary to:

• comply with law;
• comply with sanctions;
• prevent fraud;
• investigate financial crime;
• protect customers;
• protect the platform;
• satisfy regulatory requirements;
• verify information;
• respond to lawful requests.

Where legally permitted, additional information may be provided concerning the reason for a restriction.

Certain compliance investigations may remain confidential by law.

21. Transaction Limits

Transactions may be subject to limits.

Limits may depend on:

• customer type;
• jurisdiction;
• verification status;
• transaction history;
• risk classification;
• currency;
• asset;
• payment method;
• Service Provider requirements;
• regulatory requirements.

Limits may change without prior notice where required by law, risk controls or operational requirements.

22. Fees and Charges

Transactions may involve fees charged by:

• DAT PAY;
• financial institutions;
• payment providers;
• blockchain networks;
• intermediaries;
• foreign exchange providers;
• other Service Providers.

Network fees may change depending on blockchain conditions.

You are responsible for reviewing applicable charges before confirming a transaction.

23. Tax Risk

Your use of DAT PAY may create tax obligations depending on your jurisdiction and activity.

Potential tax considerations may include:

• income tax;
• capital gains;
• withholding tax;
• value-added tax;
• reporting obligations;
• digital asset taxation;
• foreign exchange taxation.

DAT PAY does not provide tax advice.

You are responsible for determining and complying with your tax obligations.

24. Regulatory Risk

Financial and digital asset regulation can change.

Changes in law or regulation may result in:

• new verification requirements;
• additional reporting;
• transaction restrictions;
• service suspension;
• product changes;
• geographic restrictions;
• changes to available assets;
• changes to fees;
• changes to service providers.

A service that is available today may not remain available in every jurisdiction.

25. Jurisdictional Risk

A financial product may be lawful in one jurisdiction and restricted or prohibited in another.

You are responsible for ensuring that your use of DAT PAY complies with the laws applicable to you.

DAT PAY may restrict access based on:

• residence;
• nationality;
• location;
• transaction origin;
• transaction destination;
• applicable sanctions;
• regulatory requirements;
• financial crime risk.

26. Fraud and Cybersecurity Risk

Financial technology platforms may be targeted by:

• phishing;
• malware;
• account takeover;
• social engineering;
• identity theft;
• payment fraud;
• credential theft;
• SIM-related attacks;
• malicious applications;
• other cyber threats.

You should:

• protect your authentication credentials;
• enable available security features;
• verify transaction information;
• avoid sharing passwords or recovery credentials;
• verify communications claiming to originate from DAT PAY;
• report suspected account compromise immediately.

DAT PAY will never ask you to disclose private keys or passwords through an unsolicited communication.

27. Technology Risk

Technology may fail because of:

• software defects;
• infrastructure failures;
• network failures;
• cloud service interruptions;
• cybersecurity incidents;
• database failures;
• telecommunications failures;
• maintenance;
• third-party outages.

DAT PAY aims to maintain appropriate operational controls but cannot guarantee uninterrupted service.

28. API and Integration Risk

Where DAT PAY provides API functionality, third-party applications may interact with the platform.

You are responsible for ensuring that any application authorised to access your account is legitimate and appropriately secured.

API credentials must be treated as confidential.

Unauthorised disclosure of API credentials may result in unauthorised activity.

29. Market Data

Where DAT PAY displays prices, exchange rates, asset values or other financial information, such information may be obtained from third-party sources.

Market data may:

• be delayed;
• contain errors;
• change rapidly;
• differ between providers;
• become temporarily unavailable.

Market information should not be treated as a guarantee of execution price.

30. No Reliance on Indicative Prices

Prices displayed before execution may be indicative unless expressly identified as executable.

The final execution price may differ because of:

• market movement;
• liquidity;
• spreads;
• fees;
• execution timing;
• network conditions;
• Service Provider conditions.

31. No Guarantee of Liquidity

DAT PAY does not guarantee that a particular currency, asset or financial instrument will always have sufficient liquidity.

Liquidity may change because of:

• market conditions;
• regulatory changes;
• counterparty availability;
• network conditions;
• transaction size;
• market volatility.

32. No Guarantee of Asset Availability

The availability of an asset, currency or payment method may change.

DAT PAY may remove, restrict or suspend support for an asset or service because of:

• regulatory requirements;
• security concerns;
• liquidity;
• provider restrictions;
• technical issues;
• market conditions;
• compliance considerations.

33. Operational and Settlement Risk

Transactions may involve several parties.

A transaction may therefore remain pending while different systems complete:

• verification;
• compliance screening;
• payment processing;
• settlement;
• blockchain confirmation;
• reconciliation.

A displayed “pending” status does not necessarily mean that funds have been lost.

34. Irreversible Transactions

Some transactions cannot be reversed after submission.

You are responsible for reviewing transaction information before confirmation.

DAT PAY cannot guarantee recovery of funds resulting from:

• incorrect beneficiary details;
• incorrect wallet address;
• incorrect network;
• incorrect amount;
• fraudulent instructions initiated through compromised credentials.

35. Force Majeure

Services may be affected by events beyond reasonable control, including:

• war;
• terrorism;
• civil unrest;
• natural disasters;
• government action;
• regulatory intervention;
• sanctions;
• telecommunications failure;
• internet outages;
• cyberattacks;
• banking system failures;
• blockchain failures;
• third-party infrastructure failures.

DAT PAY cannot guarantee uninterrupted service during such events.

36. Information Security

DAT PAY maintains technical and organisational controls designed to protect systems and information.

However, no digital system can be guaranteed to be completely secure.

You remain responsible for maintaining appropriate security over credentials and devices under your control.

37. No Deposit Guarantee

Unless expressly provided by an authorised institution under its applicable legal framework, funds displayed through DAT PAY should not be treated as deposits with HACHTHER SARL.

HACHTHER SARL does not represent that balances displayed through its technology constitute insured deposits, guaranteed funds or protected customer assets.

Any applicable deposit protection, safeguarding or compensation arrangement depends on the legal status of the institution actually holding the relevant funds and the applicable jurisdiction.

38. No Government Guarantee

Unless expressly stated by the relevant authorised institution, DAT PAY does not represent that funds or digital assets accessed through the platform are guaranteed by:

• a government;
• a central bank;
• a deposit insurance scheme;
• an investor compensation scheme;
• HACHTHER SARL.

The existence and scope of any protection must be determined under the legal framework applicable to the relevant financial institution and service.

39. Professional Advice

You should obtain independent advice where necessary before:

• making significant financial transactions;
• purchasing digital assets;
• converting currencies;
• entering into investment arrangements;
• using leverage;
• establishing a business account;
• engaging in cross-border transactions.

DAT PAY does not assess whether a particular transaction is suitable for your individual circumstances unless a specific regulated service expressly provides such an assessment.

40. Customer Responsibility

You are responsible for:

• understanding the service you use;
• verifying transaction details;
• maintaining account security;
• complying with applicable laws;
• providing accurate information;
• paying applicable taxes;
• maintaining adequate records;
• evaluating financial and digital asset risks.

41. Acceptance of Risk

By using a DAT PAY service, you acknowledge that financial, payment and digital asset services may involve risks and that you are responsible for considering whether those risks are appropriate for your circumstances.

Where a separate product agreement contains additional risk disclosures, those disclosures also apply.

42. Regulatory Perimeter

DAT PAY is operated by HACHTHER SARL as a financial technology and infrastructure platform.

HACHTHER SARL does not represent itself as a bank, payment institution, electronic money issuer, money transfer institution, custodian, investment manager, broker or virtual asset service provider unless and to the extent that it holds the applicable authorisation.

Where regulated activities are performed by an authorised institution, that institution remains responsible for those activities within the scope of its authorisation.

43. No Circumvention of Regulation

DAT PAY does not intend to facilitate the circumvention of financial regulation.

The platform may restrict or discontinue services where necessary to comply with:

• applicable law;
• regulatory requirements;
• sanctions;
• AML/CFT requirements;
• licensing requirements;
• contractual restrictions;
• financial crime risk controls.

44. Changes to This Disclosure

DAT PAY may update this Risk Disclosure and Financial Services Disclaimer when:

• products change;
• services change;
• applicable regulations change;
• financial markets change;
• digital asset risks evolve;
• technology changes;
• third-party service structures change.

The latest version will be published on the DAT PAY website.

45. Contact

Questions concerning this Risk Disclosure and Financial Services Disclaimer may be submitted through the official contact channels published on the DAT PAY website.

HACHTHER SARL DAT PAY Republic of Cameroon

46. Legal Entity

DAT PAY is a financial technology and infrastructure platform operated by HACHTHER SARL, a company incorporated and registered in the Republic of Cameroon under RCCM No. RC/DLA/2019/B/1809, with Unique Identification Number (UIN) M041914224584L.