LEGAL DISCLAIMER FOR SPAYS

Effective Date: 13 July 2026

1. Introduction

Spays is a commercial brand operated by 3-102-966866 Sociedad de Responsabilidad Limitada, a company incorporated and registered under the laws of Costa Rica under corporate identification number 3-102-966866 (“Spays”, the “Company”, “we”, “us”, or “our”).

This Legal Disclaimer is intended to provide important information regarding the Company’s website, services, content, and the risks associated with crypto-assets and blockchain-based transactions.

By accessing or using the spays.io website or engaging with any services made available through Spays, you acknowledge that you have read, understood, and accepted this Disclaimer.

Where separate terms and conditions, risk disclosures, privacy notices, or third-party provider terms apply to a particular service, those documents shall apply in addition to this Disclaimer.

2. No Investment, Legal, or Tax Advice

The information made available by Spays through its website, platform, communications, services, or related materials is provided for general informational purposes only.

Nothing published or communicated by Spays constitutes:

  • investment advice;
  • financial advice;
  • legal advice;
  • tax advice;
  • accounting advice;
  • portfolio-management advice;
  • an investment recommendation;
  • an offer or invitation to acquire financial instruments; or
  • a guarantee regarding the value, suitability, profitability, or future performance of any crypto-asset.

Spays does not recommend, endorse, or guarantee the purchase, sale, exchange, holding, or use of any particular crypto-asset, token, protocol, blockchain network, product, or third-party service.

Information relating to supported crypto-assets, prices, rates, transaction estimates, market conditions, or technical characteristics should not be interpreted as a personal recommendation or assessment of suitability.

You should obtain independent advice from an appropriately qualified financial adviser, lawyer, accountant, or tax professional before making decisions involving crypto-assets or using services that may have financial, legal, regulatory, or tax consequences.

3. Risks of Crypto-Asset Transactions

Crypto-asset transactions involve significant risks. These risks may result in the partial or complete loss of the value of the crypto-assets or funds involved.

Such risks include, without limitation:

  • significant and sudden price volatility;
  • loss of liquidity;
  • market manipulation;
  • lack of an established or reliable market;
  • regulatory changes or restrictions;
  • cybersecurity incidents;
  • hacking, fraud, scams, phishing, or social engineering;
  • compromise of authentication or account credentials;
  • blockchain congestion or transaction delays;
  • forks, airdrops, protocol changes, or network failures;
  • smart-contract errors or vulnerabilities;
  • failures of wallet, custody, liquidity, payment, banking, or technology providers;
  • incorrect wallet addresses;
  • use of an incorrect or unsupported blockchain network;
  • transfer of unsupported crypto-assets;
  • irreversible transactions;
  • loss of private keys or access credentials;
  • suspension, blocking, or rejection of transactions for compliance reasons;
  • loss arising from stablecoin de-pegging or issuer failure; and
  • changes in the legal, tax, or regulatory treatment of crypto-assets.

The value of crypto-assets may increase or decrease significantly within a short period. Past performance is not an indication or guarantee of future performance.

Blockchain transactions are generally irreversible once confirmed. Spays may not be able to recover crypto-assets sent to an incorrect address, sent through an unsupported network, or transferred as an unsupported asset.

By using the services, you acknowledge and accept the risks associated with crypto-assets, blockchain technology, online services, and third-party infrastructure.

You are responsible for conducting your own assessment and determining whether a particular service or transaction is appropriate for your knowledge, experience, financial circumstances, and risk tolerance.

4. Regulatory Compliance and Status

Spays is committed to conducting its activities in accordance with the laws and requirements applicable to the Company and the relevant services.

The Company applies internal measures concerning:

  • customer identification and verification;
  • anti-money laundering;
  • counter-terrorist financing;
  • proliferation-financing risk;
  • sanctions screening;
  • transaction monitoring;
  • fraud prevention;
  • blockchain-transaction analysis;
  • data protection; and
  • information security.

The laws and regulatory frameworks applicable to crypto-assets differ between jurisdictions and continue to evolve.

References to Spays as a crypto-asset service provider or as providing crypto-asset-related services describe the commercial nature of the relevant activities. Such references do not constitute a representation that Spays holds a licence, registration, or authorisation in every jurisdiction from which the website may be accessed.

Unless expressly stated in the relevant contractual documentation, Spays does not represent that it is:

  • a bank;
  • a payment institution;
  • an electronic money institution;
  • an investment firm;
  • an investment adviser;
  • a securities broker;
  • a fund manager;
  • a deposit-taking institution; or
  • a licensed financial institution in the user’s jurisdiction.

Certain payment, banking, card, wallet, custody, liquidity, identity-verification, or other regulated or technical services may be provided by independent third-party providers.

Where a third party provides a service, that service may be governed by the third party’s own terms and conditions, policies, fees, regulatory status, and applicable law.

You are responsible for understanding and complying with the laws, regulations, tax obligations, restrictions, and reporting requirements applicable to you in your country of residence, citizenship, establishment, or operation.

Spays does not guarantee that its website or services comply with the legal or regulatory requirements of every country or territory.

5. Availability of Services

The availability of the website does not mean that all Spays services are offered or lawfully available in every jurisdiction.

Services may be unavailable, restricted, suspended, or limited depending on:

  • the user’s country of residence or establishment;
  • citizenship or nationality;
  • applicable sanctions;
  • regulatory requirements;
  • the user’s risk profile;
  • the requested crypto-asset or blockchain network;
  • the availability of third-party providers;
  • payment-method restrictions;
  • transaction limits;
  • technical capabilities; or
  • Spays’ internal risk policies.

Spays may refuse, suspend, restrict, or discontinue access to any service where this is necessary for legal, compliance, security, technical, operational, or risk-management reasons.

No information on the website constitutes an offer to provide a service in a jurisdiction where the provision or use of that service would be unlawful.

6. User-Initiated Access and Cross-Border Use

Where a user accesses Spays from a jurisdiction in which the Company does not actively advertise, market, or promote particular services, the user confirms that the access and request for information or services are made on the user’s own initiative.

User-initiated access does not automatically mean that the user is eligible to receive the requested service and does not override any applicable legal, regulatory, sanctions, licensing, registration, or internal compliance restrictions.

Spays reserves the right to assess:

  • the user’s identity;
  • residence and nationality;
  • jurisdiction;
  • eligibility;
  • source of funds;
  • source of wealth;
  • intended use of the service;
  • transaction activity;
  • sanctions exposure; and
  • any other relevant compliance or risk factor.

Spays may refuse to provide services even where the user initially contacted the Company independently.

You remain responsible for determining whether accessing or using the services is permitted under the laws applicable to you.

7. No Guarantee of Transaction Completion

Spays does not guarantee that any transaction will be accepted, completed, executed, settled, or completed within a particular period.

Transactions may be delayed, refused, suspended, cancelled, or blocked as a result of:

  • identity-verification requirements;
  • anti-money laundering or sanctions checks;
  • blockchain-transaction analysis;
  • Travel Rule or counterparty-information requirements;
  • fraud concerns;
  • security incidents;
  • technical failures;
  • network congestion;
  • insufficient blockchain confirmations;
  • incorrect or incomplete transaction information;
  • third-party provider restrictions;
  • banking or payment delays;
  • unsupported assets or networks;
  • legal or regulatory restrictions; or
  • requests from competent authorities.

Any displayed transaction time, exchange rate, fee, or settlement estimate is indicative unless expressly confirmed as final.

8. Third-Party Services, Links, and Content

The Spays website or services may contain links to, integrations with, or information concerning third-party websites, applications, providers, platforms, products, or services.

These may include:

  • banks;
  • payment service providers;
  • card processors;
  • crypto-asset exchanges;
  • liquidity providers;
  • wallet or custody infrastructure providers;
  • identity-verification providers;
  • blockchain-analysis providers;
  • social-media platforms;
  • analytics providers; and
  • other technology or business partners.

Spays does not control and is not responsible for the availability, accuracy, security, legality, content, privacy practices, performance, or conduct of independent third parties.

The inclusion of a third-party link, integration, name, logo, or service does not necessarily constitute an endorsement, recommendation, guarantee, or partnership beyond the specific arrangement expressly stated.

Your use of third-party services is subject to the relevant third party’s own terms, privacy policy, fees, procedures, and risk disclosures.

You should review the applicable third-party documentation before using such services.

9. Information Accuracy

Spays takes reasonable steps to provide accurate and current information. However, information concerning crypto-assets, blockchain networks, regulation, fees, third-party services, transaction times, and market conditions may change rapidly.

Spays does not warrant that all website content is:

  • complete;
  • accurate;
  • current;
  • free from error;
  • available at all times; or
  • suitable for a particular purpose.

Spays may update, correct, remove, or amend website content without prior notice.

You should independently verify material information before relying on it or making a decision.

10. Website and Technology Risks

The website and services are provided on an “as is” and “as available” basis, subject to applicable law.

Spays does not guarantee that:

  • the website or services will always be available;
  • access will be uninterrupted;
  • the website will be free from errors or delays;
  • all defects will be corrected immediately;
  • the website will be free from malware or harmful components;
  • the services will be compatible with every device or system; or
  • third-party infrastructure will operate without interruption.

You are responsible for maintaining appropriate security measures for your devices, accounts, passwords, authentication methods, wallets, and internet connections.

You must never disclose a wallet private key, seed phrase, password, or authentication code to another person.

Spays will not request your wallet seed phrase or private key in order to provide customer support or investigate a complaint.

11. Limitation of Liability

To the maximum extent permitted by applicable law, Spays and its shareholders, managers, directors, employees, contractors, affiliates, and representatives shall not be liable for losses arising from:

  • market movements or crypto-asset volatility;
  • decisions made in reliance on website information;
  • use of an incorrect wallet address or blockchain network;
  • unsupported assets;
  • irreversible blockchain transactions;
  • loss of private keys, passwords, or access credentials;
  • unauthorised access caused by the user’s failure to secure an account;
  • failures or acts of third-party providers;
  • blockchain congestion, forks, protocol changes, or network failures;
  • legal or regulatory changes;
  • sanctions or compliance restrictions;
  • suspension, refusal, or delay of a transaction;
  • force majeure events;
  • interruption or unavailability of the website; or
  • circumstances outside the reasonable control of Spays.

Nothing in this Disclaimer excludes or limits liability that cannot lawfully be excluded or limited under applicable law.

12. No Fiduciary Relationship

Your access to the website or use of the services does not create a fiduciary, advisory, trustee, agency, partnership, or joint-venture relationship between you and Spays, except where a specific relationship is expressly established in a written agreement.

Spays does not assume a duty to monitor the value or suitability of any crypto-asset for you or to advise you when to acquire, hold, exchange, transfer, or dispose of a crypto-asset.

13. Tax Responsibility

Crypto-asset transactions may have tax consequences.

You are solely responsible for:

  • determining the tax treatment of your transactions;
  • maintaining appropriate records;
  • calculating taxes;
  • submitting tax returns;
  • making required disclosures; and
  • paying any applicable taxes, duties, or charges.

Spays does not provide tax advice and does not guarantee that transaction reports or other information provided through the services will satisfy your tax-reporting obligations.

14. Changes to This Disclaimer

Spays may amend this Disclaimer from time to time to reflect changes in:

  • applicable law;
  • regulatory requirements;
  • the Company’s services;
  • its business model;
  • technology;
  • third-party arrangements; or
  • relevant risks.

The updated version will be published on the website and will become effective from the date stated in the updated Disclaimer.

You should review this Disclaimer periodically.

15. Contact Information

Questions regarding this Disclaimer may be submitted through the contact details hello@spays.io or contact form available on the Spays website.

Conclusion

By accessing the Spays website or using its services, you confirm that you have read and understood this Legal Disclaimer and acknowledge the risks and limitations described above.

Where you do not agree with this Disclaimer, you should not access or use the website or services.

Date of last update: 13 July 2026