RIV Technologies FZE (also “RIV Technologies”, or “the Company”) is a Virtual Assets Service Provider (VASP),
authorized by Dubai’s Virtual Assets Regulatory Authority (VARA). The company is incorporated in Dubai World
Trade Centre, with license number L-2616, is headquartered in Dubai at the following address:
The Offices 3 – One Central, Dubai World Trade Centre, Dubai.

For VARA regulatory purposes, the Company’s responsible individuals are Roberto Rivera and Alvise Di Stefano.

Keep in mind that Virtual Assets (VAs) may fluctuate in value and carry inherent risks, including:

Risk Disclosure Statement on Virtual Assets

Virtual Assets (“VAs”) involve a high degree of risk and are not suitable for all investors. Before engaging in any
Virtual Asset-related activity, clients should carefully consider the following material risks, in accordance with
the Market Conduct Rulebook issued by the Dubai Virtual Assets Regulatory Authority (VARA):

– Loss of Value and Volatility

Virtual Assets may lose their value in part or in full. Prices of Virtual Assets can be extremely volatile and may
fluctuate rapidly over short periods of time due to market sentiment, technological developments, regulatory changes,
liquidity conditions, or other external factors. Past performance is not indicative of future results, and there is no
guarantee that any Virtual Asset will retain its value.

– Transferability and Irreversibility

Virtual Assets may not always be transferable. Certain transactions may be delayed, restricted, suspended, or rendered
impossible due to network congestion, protocol limitations, compliance controls, or technical failures. Once initiated,
Virtual Asset transactions are generally irreversible, and erroneous or fraudulent transfers may not be recoverable.

– Liquidity Risk

Virtual Assets may not be liquid. There may be limited demand or market depth for certain Virtual Assets at any given time, which could make it difficult or impossible to buy, sell, or convert such assets at a desired price or within a reasonable timeframe.
Illiquidity may result in significant losses or forced liquidation at unfavorable prices.

– Transparency and Privacy Limitations

Some Virtual Asset transactions are not private and may be recorded permanently on public distributed ledger technologies (“DLTs”).
Transaction data, including wallet addresses, transaction amounts, and timestamps, may be publicly visible and traceable.
While identities may not be directly disclosed on-chain, blockchain analytics may allow transactions to be linked to individuals or entities.

– Fraud, Cybersecurity, and Legal Risks

Virtual Assets may be subject to fraud, market manipulation, theft, cybersecurity attacks, including hacks, phishing,
smart-contract exploits, and other targeted schemes. Clients may not benefit from the same legal or regulatory protections available in traditional financial markets, including investor compensation schemes, deposit protection, or guaranteed recovery mechanisms.
Legal and regulatory treatment of Virtual Assets may change, potentially affecting their value, transferability, or legality.

Clients acknowledge and accept these risks when engaging in Virtual Asset-related activities.

On Data Privacy

As a Virtual Asset Service Provider (VASP), we adhere to stringent data protection regulations set by the Dubai Virtual Assets Regulatory Authority (VARA) and follow best practices to ensure the confidentiality, integrity, and availability of personal data.

We collect only essential data for service provision, using robust encryption for data in transit and at rest to ensure security.
Access to data is controlled through role-based access controls (RBAC) and multi-factor authentication (MFA), limiting access to authorized personnel.

Data is stored securely with regular backups and retained only as long as necessary. Clients have rights to access, correct, port, and request deletion of their data. In the event of a data breach, we have an incident response plan to contain and mitigate impacts, with prompt notification to affected clients and regulatory authorities.

We conduct regular audits and assessments to ensure compliance with data protection laws and continuous monitoring to identify and address vulnerabilities.
Employees receive regular training on data privacy and security best practices. For any data privacy concerns, clients can contact our Data Protection Officer at dpo@riv-technologies.com.

These measures ensure the confidentiality, integrity, and availability of client data, maintaining trust and compliance with regulatory standards.

On Conflicts of Interests

RIV Technologies is committed to managing conflicts of interest with integrity and transparency. Our Conflicts of Interest Policy outlines our approach to identifying, documenting, escalating, and managing conflicts of interest.

We enforce organizational separation measures, such as Chinese walls, to ensure the autonomy of individual business units and minimize potential conflicts.
Employees and management are required to declare their holdings in virtual assets, disclose personal relationships with clients or third-party service providers, and adhere to strict guidelines regarding gifts and remuneration from third-party blockchain companies.

In cases where conflicts of interest cannot be adequately managed through internal measures, full disclosure will be made to affected parties to enable them to make informed decisions.

RIV Technologies maintains a strict zero-tolerance policy towards bribery and corruption. We are committed to conducting our business with integrity, transparency, and accountability.

On Whistleblowing

RIV Technologies is committed to maintaining a transparent and ethical environment, as outlined in our Whistleblowing Policy. This policy provides a safe, secure, and reliable avenue for whistleblowers to report suspicious activities without fear of repercussion.

The Whistleblowing Policy applies to all employees, officers, senior management, directors, and third parties associated with RIV Technologies. The policy covers cases such as money laundering, fraud, and bribery, and guarantees whistleblower protections including confidentiality, protection from litigation, and protection from retaliatory acts.

Whistleblowers can report their concerns via email, phone, or post, and are encouraged to provide supporting evidence to facilitate the investigation process.
Our commitment to fairness and justice is reflected in our detailed investigation process, which ensures that all reports are thoroughly and promptly investigated.

On Handling of Client Complaints

At RIV Technologies, we are committed to providing the highest quality of service and ensuring the satisfaction of our clients. However, we recognize that there may be occasions when our clients may have concerns or complaints. This section outlines our policy for handling client complaints, ensuring they are addressed promptly, fairly, and transparently, in accordance with the regulations set by the Dubai Virtual Assets Regulatory Authority (VARA).

RIV Technologies is dedicated to addressing any concerns or complaints in a timely and fair manner. Our complaints handling procedure is designed to ensure that all complaints are investigated promptly and resolved as soon as practicable. For more information on how to submit a complaint and our process for handling complaints,
please check our Complaints Policy at this address (https://riv-technologies.com/complaints).

Terms and Conditions

RIV Technologies’ terms and conditions can be accessed here [link will be included once live].

Referral and Introduction Arrangements (Rule I.B.1.c)

RIV Technologies does not, as a general practice, refer or introduce clients to other Entities, including other VASPs, for the purposes of providing Virtual Asset services.

Should such a referral or introduction arrangement arise, RIV Technologies will disclose to the client, prior to any referral, the full terms of such arrangement. This includes:

At present, RIV Technologies confirms that no monetary or non-monetary benefits are received from third-party referrals or introductions.

Further Disclosures

RIV Technologies will publish on its website or by other means available to the public details of any past convictions or prosecutions of any member(s) of their Senior Management or Board, whether before the courts of the UAE or the courts of another jurisdiction.