CiNKO Growth Terms and Conditions

These Growth Terms and Conditions were last updated on June 1, 2026.

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IMPORTANT NOTICE

These Growth Terms and Conditions govern your access to and use of CiNKO’s Growth Services. Please read them carefully before allocating any Digital Assets to a Growth Product. Growth Services are not bank deposits, savings products, or principal-protected investments. Returns are variable and not guaranteed. For certain Growth Products, you may receive less than what you originally allocated. If you do not understand or do not agree to these terms, you should not use the Growth Services.

PART 1 — INTRODUCTION AND SCOPE

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1.1 About These Growth Terms

These CiNKO Growth Terms and Conditions (the “Growth Terms”) govern your access to and use of the Growth Services available through the CiNKO Platform provided by Digital Finance (Bahamas) Ltd. (“we,” “us,” or “our”), which operates under the CiNKO brand.

These Growth Terms form part of CiNKO’s General Terms and Conditions (the “General Terms”) and should be read in conjunction with them. Capitalized terms used in these Growth Terms that are not defined herein have the meanings given to them in the General Terms. In the event of any inconsistency between these Growth Terms and the General Terms regarding the Growth Services, these Growth Terms shall prevail.

By accessing the Growth Services or assigning any Digital Asset to a Growth Product, you agree to be bound by these Growth Terms.

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1.2 Covered Services

These Growth Terms govern your access to and use of CiNKO’s Growth Services. The Growth Products currently available through the Growth Services are described in the Appendices to these Growth Terms, each of which forms part of these Growth Terms and sets forth the specific terms, mechanics, fees, and risk disclosures applicable to that product.

We may add, modify, or remove Growth Products at any time. New or modified Growth Products will be described in a new or updated Addendum to these Growth Terms, or in service-specific disclosures available through the CiNKO Platform. The addition of a new Addendum does not require an amendment to these Growth Terms.

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1.3 Nature of Growth Services

Growth Services are digital asset participation services that allow you to allocate compatible Digital Assets to Growth Products in order to participate in activities facilitated through regulated Growth Providers and third parties.

Growth Services are not and do not constitute:

a bank deposit, savings account, or deposit-taking service;
an investment with guaranteed capital or principal protection;
an investment fund, collective investment scheme, or managed investment product;
investment advice, financial advice, or any other form of professional advice; nor
a product with a guaranteed or fixed return of any kind.

The returns generated through Growth Services are variable, not guaranteed, and may be zero. For certain Growth Products, the amount returned to you upon withdrawal may be less than the amount you originally allocated. You should carefully read the product-specific risk disclosures in the applicable Appendix before allocating any Digital Assets. ‍

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1.4 Our Role

We act as a distributor and provider of Growth Services. We make Growth Products available to you through the CiNKO Platform and are responsible for the Growth Services we provide to you under these Growth Terms.

Growth Products are structured, operated, and managed by third-party Growth Providers that are regulated and independent of us. We are not responsible for the investment performance, operational conduct, or financial soundness of any Growth Provider, nor for the performance of the underlying assets or strategies associated with any Growth Product.

The identity of the Growth Provider and the legal and operational structure applicable to each Growth Product are set forth in the relevant Annex to these Growth Terms.

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1.5 Eligibility Requirements

You can only access the Growth Services if:

has a verified CiNKO account in good standing and has met all applicable identity verification and due diligence requirements;
has legal permission to access the Growth Services in accordance with the laws and regulations of your country or territory of residence;
the Growth Services are not restricted or prohibited in your jurisdiction;
has read and understood the risks associated with participating in the relevant Growth Product, including the risk of receiving less than their original Allocation and, for certain products, the risk of a realized loss; and
meets any additional eligibility requirements that we may specify at any time through the CiNKO Platform.

Growth Services are not available to residents or nationals of any jurisdiction where they constitute an unauthorized deposit-taking, investment, or securities activity, or where their availability is otherwise illegal. We may restrict or withdraw access to Growth Services in any jurisdiction at any time without prior notice if we determine that this is necessary to comply with applicable legal or regulatory requirements.

By accessing the Growth Services, you represent and warrant that you meet the eligibility requirements and that your participation is lawful in your jurisdiction.

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PART 2 — DEFINITIONS

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2.1 Definitions

In these Growth Terms, the following terms have the meanings set forth below, unless the context requires otherwise:

“Allocation” means the transfer of Digital Assets from your CiNKO Account to a Growth Product vault in accordance with your instructions and these Growth Terms.

“Business Day” means a day (other than a Saturday or Sunday) on which commercial banks are open for business in London, New York, and the Cayman Islands.

“CiNKO Platform” or “Platform” has the meaning set forth in the General Terms and Conditions.

“Growth Product” means each individual digital asset participation service available through the Growth Services at any given time, through which users can allocate eligible Digital Assets to participate in specific digital asset activities, as described in the applicable Schedule.

“Growth Provider” means any regulated third-party digital asset service provider through which a Growth Product is structured and operated, as identified in the applicable Schedule.

“Growth Services” has the meaning set forth in Section 1.2.

“General Terms” means CiNKO’s Terms and Conditions, as amended from time to time, available at https://cinko.io/en/terms-conditions.

“Growth Balance” means the balance displayed on the CiNKO Platform that reflects the value of the Digital Assets allocated to Growth Products, including the accumulated and credited variable returns on such assets.

“Net Return” means the return generated on a Growth Product after deducting all applicable fees, credited to your Growth Balance.

“Segregated Portfolio” means a segregated portfolio of a Growth Provider that is organized as a segregated holding company, whose assets are allocated to a specific Growth Product and are separated from the assets of other segregated portfolios and from the general assets of the Growth Provider in accordance with applicable law.

“Vault Token” means a blockchain-based digital token issued by a Growth Provider that certifies an Allocation and enables the processing of a Withdrawal Request.

“Withdrawal Amount” means the amount of Digital Assets returned to you following a Withdrawal Request, which may be less than your original Allocation for certain Growth Products.

“Withdrawal Processing Period” means the period from the submission of a Withdrawal Request until the Withdrawal Amount is credited to your CiNKO Account, as specified for each Growth Product in the applicable Schedule.

“Withdrawal Request” means a request submitted by you through the CiNKO Platform to terminate an Assignment (in whole or in part) and receive the Withdrawal Amount.

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PART 3 — HOW GROWTH SERVICES WORK

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3.1 Make an Assignment

To allocate Digital Assets to a Growth Product, you must access the Growth section of the CiNKO Platform, select the relevant Growth Product, specify the amount you wish to allocate, and confirm the allocation. By confirming an Allocation, you authorize us to transfer the specified Digital Assets from your CiNKO Account to the vault of the corresponding Growth Product, in accordance with these Growth Terms and the applicable Addendum.

Before you confirm your Allocation, the CiNKO Platform will display the key terms applicable to that Growth Product, including the indicative rate of return, applicable fees, the minimum Allocation amount, and the Withdrawal Processing Period. You are responsible for reviewing this information carefully before confirming your Allocation.

The minimum Allocation amounts apply to each Growth Product and are set forth in the applicable Schedule. We may modify the minimum Allocation amounts at any time.

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3.2 Calculation and Verification of Performance

The return on each Growth Product is calculated daily at a variable rate determined by reference to the return on the underlying assets or strategy, less applicable fees. The methodology for calculating the return on each Growth Product is set forth in the applicable Schedule.

Net Returns are credited to your Growth Balance daily. Your Growth Balance reflects the current value of your Allocations, along with all Net Returns accrued and credited to date. The Growth Balance is indicative and is subject to the risks described in these Growth Terms and in the applicable Schedule.

The rates of return shown on the CiNKO Platform are for illustrative purposes only and are based on recent historical performance. Past performance is not indicative of future results. The illustrative rate of return may change daily. We do not guarantee any specific rate of return or that any return will be generated.

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3.3 Committees

The fees applicable to each Growth Product are deducted from the gross return generated on the underlying assets before the Net Return is credited to your Growth Balance. This means that your Growth Balance reflects only the Net Return. The fees applicable to each Growth Product are set forth in the applicable Schedule and are also disclosed on the CiNKO Platform prior to confirmation of the Allocation.

We do not charge a separate account fee for accessing the Growth Services. Fees are included in the calculation of the Net Return and are deducted at source by the Growth Provider before we credit the Net Return to your Growth Balance.

Fees may change at any time in accordance with the process set forth in Section 7.2 (Modifications). Updated fee rates will be reflected in the applicable Schedule and disclosed on the CiNKO Platform before they take effect. Information regarding current fees and transaction limits is also set forth in Annex 2 (Fee Schedule) of the General Terms, which must be read in conjunction with these Growth Terms.

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3.4 Withdrawal Requests

You may submit a Withdrawal Request at any time through the CiNKO Platform. Withdrawal Requests are subject to the Withdrawal Processing Period applicable to the corresponding Growth Product, as set forth in the applicable Schedule.

The Withdrawal Processing Period begins on the next Business Day following the submission of your Withdrawal Request if it is submitted before the applicable cutoff time, or on the next Business Day if it is submitted after the cutoff time or on a day that is not a Business Day. Cutoff times are specified in the applicable Schedule and displayed on the CiNKO Platform.

Once you submit a Withdrawal Request, it is irrevocable. You cannot cancel or modify a Withdrawal Request once it has been submitted.

We will take all reasonable steps to process Withdrawal Requests within the timeframes set forth in the applicable Annex. These timeframes are indicative and do not constitute a guarantee or a binding commitment. We are not liable for any delays arising from blockchain network conditions, Growth Provider operational processes, third-party infrastructure failures, regulatory requirements, or any other circumstances beyond our reasonable control. In the event that a significant delay is likely, we will notify you via the CiNKO Platform as soon as reasonably possible.

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3.5 Withdrawal Amount

The Withdrawal Amount credited to your CiNKO Account upon completion of a Withdrawal Request will be determined in accordance with the process described in the applicable Appendix. The Withdrawal Amount may be less than your original Allocation. There is no guarantee that you will receive the full amount you allocated. Please read the risk disclosures in the applicable Appendix carefully before making an Allocation.

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3.6 Temporary Transfer of Digital Assets from Custody

When you make an Assignment, your Digital Assets are transferred from your CiNKO Account to the corresponding Growth Provider for the duration of the Assignment. During this period:

The assigned Digital Assets are not held in our custody under the General Terms or Annex 1 (Custody Annex) of the General Terms;
our custody of your Digital Assets resumes only once the Withdrawal Amount is credited to your CiNKO Account following the completion of a Withdrawal Request; and
The allocated Digital Assets are subject to the mechanics, risks, and legal structure of the corresponding Growth Product, as described in the applicable Schedule.

Nothing in these Growth Terms transfers ownership of your Digital Assets to us or to the Growth Provider, except to the extent strictly necessary to facilitate the operation of the Growth Product. Your beneficial interest in the underlying Digital Assets remains in effect throughout the Allocation Period, subject to the limited recourse provisions described in Section 4.3.

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3.7 Growth Balance — For informational purposes only

The Growth Balance displayed on the CiNKO Platform is for illustrative purposes only. It reflects the estimated current value of your Allocations and the cumulative Net Return based on the most recent data available, but may not reflect the exact Withdrawal Amount you would receive if you submitted a Withdrawal Request at any given time. The actual Withdrawal Amount will be determined at the time of processing in accordance with the applicable Schedule.

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PART 4 — GROWTH PROVIDER AND LEGAL STRUCTURE

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4.1 Growth Provider

The Growth Products offered through the Growth Services are structured and operated by Growth Providers, each of which is identified in the applicable Schedule. The identity, regulatory status, and legal structure of the Growth Provider for each Growth Product are set forth in the Schedule for that product. We will update the applicable Schedule to reflect any changes in the Growth Provider.

Growth Providers are independent of us. We do not control, manage, or have supervisory authority over any Growth Provider or any other party involved in the operation of the Growth Products.

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4.2 Legal Structure of the Growth Provider

The legal structure, protective measures, and asset segregation mechanisms applicable to each Growth Product are specific to the relevant Growth Provider and are described in the applicable Annex. You should carefully read the applicable Annex to understand the structural protections and limitations that apply to your Allocation.

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4.3 Limited resources

Your rights are enforceable against the assets of the relevant Growth Product, as described in the applicable Schedule, and not against us personally, except with respect to our own obligations under these Growth Terms. Neither we nor any member of our group guarantees the performance of any Growth Product or the obligations of any Growth Provider.

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4.4 Growth Provider’s Right to Modify

The Growth Provider, as the operator of the relevant Growth Product, has the right to modify the terms applicable to a Growth Product (including fee rates, performance methodologies, and operational parameters) by providing us with notice no less than the applicable Withdrawal Processing Period plus fourteen Business Days.

When we receive notification of a material change regarding a Growth Supplier:

We will notify you via the CiNKO Platform as soon as reasonably possible;
we will give you a reasonable opportunity to file a Request for Withdrawal before the change takes effect; and
We will update the applicable Annex to reflect the amended terms.

If a change is not material—for example, a minor change to cut-off times or operating procedures—we may update the applicable Schedule without individual notice.

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4.5 Group Structure and Cash Flow

The Growth Services are provided by Digital Finance (Bahamas) Ltd. (“DFB”), the regulated entity that operates the CiNKO Platform under a license from the Bahamas Securities Commission. DFB is a wholly owned subsidiary of Secure Transactions Inc. (“STI”), an exempt company incorporated in the Cayman Islands.

The institutional agreements with the Growth Provider under which Growth Products are operated are entered into by STI. When you make an Allocation, your Digital Assets are transferred from your CiNKO Account held with DFB to STI’s account with the relevant Growth Provider. Throughout this process, you retain beneficial ownership of the underlying Digital Assets, and STI has no beneficial interest in your assets.

STI does not hold a digital asset custody license and does not provide custody services. The transfer of assets through STI for the purpose of facilitating Growth Product allocations is a group operational arrangement and does not constitute a separate service. DFB remains fully responsible for the Growth Services provided to it under these Growth Terms.

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PART 5 — RISK DISCLOSURE

The risks set forth in this Part 5 apply to all Growth Products and should be read in conjunction with the general risk disclosures set forth in Section 9 of the General Terms, which also apply to your use of the Growth Services. Product-specific risk disclosures are set forth in the applicable Appendix. You should read all three carefully before making any Allocation.

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5.1 Variable return risk

All returns generated through the Growth Services are variable. Return rates fluctuate daily based on market conditions, the performance of underlying assets or strategies, and other factors. The indicative return rate displayed on the CiNKO Platform is based on recent historical performance and does not guarantee future returns.

The return may be zero or, for certain Growth Products, negative. A negative return means that your Growth Balance may decrease over time during the allocation period, regardless of capital movements in the underlying portfolio. If a negative return applies to a specific Growth Product, this is described in the applicable Annex.

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5.2 Capital risk

Growth Services do not guarantee the return of principal. The Withdrawal Amount you receive may be less than the amount you originally allocated, depending on the performance of the underlying assets or strategy associated with the relevant Growth Product. The degree of capital risk varies by product and is described in the applicable Annex. You should not allocate Digital Assets to any Growth Product unless you are prepared to accept the possibility of receiving less than your original Allocation.

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5.3 Counterparty risk

Growth Products involve reliance on third parties, including Growth Providers, asset managers, validators, custodians, and other service providers and counterparties identified in the applicable Schedule. The insolvency, operational failure, or regulatory action affecting any of these parties could adversely affect your Allocation and the amount you receive upon withdrawal.

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5.4 Asset Protection Risk for Growth Products and Limited Recourse

Your claim is limited to the assets attributable to the relevant Growth Product, as described in the applicable Schedule. If those assets are insufficient, your claim may not be fully satisfied. The protection structure applicable to each Growth Product is described in the relevant Schedule, but no structure is entirely free from legal or operational risks. In the event of insolvency, there may be delays or costs associated with identifying and returning assets.

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5.5 Risk of withdrawal delays

Withdrawal Requests are subject to a Withdrawal Processing Period that varies by product and is set forth in the applicable Schedule. You cannot access your allocated Digital Assets during this period. Withdrawal Processing Periods are indicative and do not constitute a guarantee or a binding commitment regarding the time it will take to complete processing. Delays may occur due to circumstances beyond our reasonable control, including blockchain network conditions, unlocking cycles, Growth Provider operational processes, and third-party infrastructure failures. You should not allocate Digital Assets to a Growth Product if you may need access to those assets within the maximum Withdrawal Processing Period specified in the applicable Schedule.

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5.6 Regulatory risk

The legal and regulatory treatment of digital asset investment services may change over time. Changes in applicable laws, regulations, or regulatory interpretations may affect the availability of the Growth Services or specific Growth Products in one or more jurisdictions. We may be required to modify, suspend, or discontinue the Growth Services or a Growth Product to comply with applicable regulatory requirements, with or without prior notice depending on the circumstances.

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5.7 Technological and Network Risk

Growth Services and Growth Products rely on blockchain networks, smart contracts, and third-party infrastructure that may experience congestion, outages, protocol changes, or security vulnerabilities. These events may delay or prevent Allocations, Withdrawal Requests, or the crediting of Net Returns.

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5.8 Lack of government protection

Growth Services are not bank deposits and are not protected by any government deposit insurance program, insurance scheme, or investor compensation scheme. In the event of our insolvency or the insolvency of a Growth Provider, there is no government-backed protection for your allocated Digital Assets or your accumulated Net Return.

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5.9 Lack of guidance

We do not provide investment advice, financial advice, tax advice, or any other type of professional advice in connection with the Growth Services. Nothing in these Growth Terms, the CiNKO Platform, or any communication from us constitutes a recommendation, solicitation, or endorsement of any Growth Product. You are solely responsible for assessing whether the Growth Services and any specific Growth Product are suitable for you, taking into account your own financial situation, risk tolerance, and investment objectives. We recommend that you seek independent professional advice if you have any questions.

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PART 6 — SUSPENSION AND TERMINATION OF GROWTH SERVICES

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6.1 Suspension by us

We may suspend your access to the Growth Services or to a specific Growth Product, with or without prior notice, when:

as required by law or applicable regulatory requirements;
we reasonably believe that the suspension is necessary to protect the security or integrity of the CiNKO Platform or the Growth Services;
a Growth Provider suspends or terminates a Growth Product;
your CiNKO Account is suspended pursuant to the General Terms and Conditions; or
we are required to manage legal, regulatory, or risk exposure.

6.2 Termination of a Growth Product

We may discontinue a Growth Product at any time for operational, regulatory, or business reasons. When we discontinue a Growth Product:

We will notify you via the CiNKO Platform as soon as reasonably possible;
Any existing Allocation to that Growth Product will be subject to the applicable withdrawal process described in the relevant Schedule; and
We will take reasonable steps to facilitate the return of your allocated Digital Assets and the accrued Net Return in accordance with Growth Provider’s procedures and applicable law.

6.3 Consequences of Account Closure

If your CiNKO Account is terminated pursuant to the General Terms while you have active Allocations, your Allocations will be subject to the withdrawal process described in the applicable Schedule. We will take reasonable steps to facilitate the return of your allocated Digital Assets and the accrued Net Return, subject to applicable law, compliance requirements, the Growth Provider’s operational processes, and the deduction of any fees accrued but not yet applied prior to the termination date.

If you have active Allocations in any Growth Product at the time of termination, the withdrawal process may result in you receiving less than your original Allocation, including a realized loss, depending on the value of the underlying portfolio at the time of processing.

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6.4 Survival

The termination of your access to the Growth Services does not affect your accumulated Net Return, pending Withdrawal Requests, accrued but not yet applied fees, or any other rights or obligations that, by their nature, are intended to survive termination. ‍

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PART 7 — GENERAL PROVISIONS

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7.1 Liability

We will provide the Growth Services with reasonable care and skill, in accordance with applicable laws and regulatory requirements and generally accepted industry standards.

To the fullest extent permitted by applicable law, we are not liable for:

losses arising from the performance of any Growth Product, the performance of any Growth Provider, or the performance of the underlying assets or strategies;
losses arising from the insolvency, operational failure, or regulatory action affecting any Growth Provider or counterparty;
delays in the Withdrawal Processing Period caused by blockchain network conditions, Growth Provider’s operational processes, or other factors beyond our reasonable control;
the Withdrawal Amount is less than the original Allocation, when this results from the mechanics of the corresponding Growth Product, as described in the applicable Annex; or
any indirect, consequential, or economic losses arising from the Growth Services.

Our liability to you in connection with the Growth Services is subject to the limitations set forth in Section 10.3 of the General Terms, which apply to these Growth Terms. Nothing in these Growth Terms excludes or limits liability for fraud, willful misconduct, or death or personal injury caused by our negligence.

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7.2 Amendments

We may modify these Growth Terms or any Addendum at any time to reflect changes to the Growth Services, applicable laws or regulations, the Growth Provider’s terms, or our business operations.

Each Addendum is part of these Growth Terms but is a separate version. This means that a modification to an Addendum applies only to users subscribed to the corresponding Growth Product and does not require reacceptance of these Growth Terms or any other Addendum. A modification to Parts 1 through 7 of these Growth Terms will require reacceptance by all users of the Growth Services.

Not all changes will require your active acceptance. A material change is one that alters the commission rate, the minimum allocation amount, the maximum withdrawal processing period, the capital risk profile, or the identity of a product’s Growth Provider. When a material modification is made, we will provide you with reasonable notice via the CiNKO Platform and ask you to re-accept the affected document before the modification takes effect. During this notice period, you may submit a Withdrawal Request regarding any affected Growth Product without any adverse consequences.

Non-substantive changes—such as minor operational updates to cut-off times or counterparty details—may be made by updating the relevant Annex and notifying the other party via the CiNKO Platform, without requiring a new acceptance.

Your continued use of the Growth Services after any changes take effect constitutes your acceptance of the updated terms. If you do not agree with any changes, you must stop using the Growth Services and submit Withdrawal Requests for all active Allocations.

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7.3 Language and Translation

These Growth Terms and all documents that form part of the agreement between you and us regarding the Growth Services are written in English, which is the governing language.

We may make translated versions of these Growth Terms and other documents or communications related to the Growth Services available to you through the CiNKO Platform for your convenience. When a translated version is made available:

In the event of any inconsistency, ambiguity, or conflict between the English version and any translated version, the English version shall prevail in all respects;
The translated versions are provided for informational purposes only and do not constitute a separate or independent agreement;
certain terms, words, or expressions used in the translated versions may have a different meaning, connotation, or legal interpretation in the relevant language or jurisdiction than their intended meaning in the English version; and
We do not guarantee that any translated version accurately reflects the meaning, effect, or legal interpretation of the English version.

If you have any questions about the meaning of any provision, please refer to the English version, which is available at all times on the CiNKO Platform.

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7.4 Governing Law and Jurisdiction

These Growth Terms and any dispute or claim arising out of or relating to them or the Growth Services shall be governed by and construed in accordance with the laws of the Commonwealth of the Bahamas.

The courts of the Commonwealth of the Bahamas shall have exclusive jurisdiction to resolve any dispute or claim arising out of or relating to these Growth Terms or the Growth Services, subject to any mandatory rights you may have under applicable law.

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7.5 Entire Agreement

These Growth Terms (comprising Parts 1 through 7), together with the General Terms and the Addendum or Addenda accepted by you with respect to each Growth Product in which you are enrolled, constitute the entire agreement between you and us regarding the Growth Services and supersede any prior agreement or understanding relating to the same subject matter.

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7.6 Relationship to the General Terms

All provisions of the General Terms apply to your use of the Growth Services and your CiNKO Account in connection with the Growth Services, unless these Growth Terms specifically provide otherwise. In particular, the provisions of the General Terms relating to account security, prohibited activities, compliance obligations, data protection, and claims management apply to the Growth Services. For clarity, Section 9 (Risk Disclosure) of the General Terms applies to the Growth Services in addition to, and not in lieu of, the risk disclosures set forth in Part 5 of these Growth Terms.

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APPENDIX 1 — USDC 24-Hour Strategy

USDC 24-Hour Strategy | Version 1.0 | Effective May 19, 2026

USD Money Market Fund Vault

USDC 24-HOUR STRATEGY — IMPORTANT INFORMATION

USDC 24-Hour Strategy is a digital asset investment service. It is not a bank deposit or a savings account. Returns are variable and are benchmarked against the 4-week U.S. Treasury Bill rate, less applicable fees. Your principal is intended to be preserved, but this is not guaranteed.

A1.1 Product Description

The USDC 24-Hour Strategy allows you to allocate USDC to the OpenTrade SPC USD Money Market Fund Vault (the “MMF Vault”), which is managed through the OpenTrade SPC Segregated Treasury Management Portfolio. The MMF Vault invests the allocated funds in a portfolio consisting exclusively of U.S. Treasury Bills and the Fidelity USD Money Market Fund—two of the most liquid and highest-rated instruments available in global financial markets.

The return you receive is variable and tracks the daily rate on 4-week U.S. Treasury bills, minus applicable fees. Interest accrues daily and is compounded daily, which means you earn interest on your interest.

Although USDC Strategy 24h is designed to generate a positive return under normal market conditions, a negative rate of return is theoretically possible in the event of a widespread market disruption or extraordinary market conditions. In such circumstances, interest would accrue at the negative rate and reduce your Growth Balance during the allocation period.

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A1.2 Key Product Details

Product Name

USDC 24-Hour Strategy

Growth Provider

OpenTrade SPC — Segregated Treasury Management Portfolio

Underlying assets

U.S. Treasury Bills and Fidelity's USD Money Market Fund

Performance Basis

Variable — based on the 4-week U.S. Treasury Bill Daily Rate, minus fees

Accumulation of interest

Daily, capitalized

Minimum allocation

USD 100

Minimum withdrawal

None

Compatible networks

Avalanche, Ethereum, Plume

Lock-up period

None

Retirement

At any time—typically on the same business day if before the cut-off time; maximum T+2 business days

Cutoff time

As shown on the CiNKO Platform

Capital protection

Expected but not guaranteed

FCA-regulated broker

Five Sigma Finance Limited

A1.3 Growth Supplier Details

The Provider for the USDC 24-Hour Strategy is OpenTrade SPC, an exempt segregated holding company incorporated under the laws of the Cayman Islands. OpenTrade SPC operates this product through its Segregated Treasury Management Portfolio, whose assets are segregated from the assets of other segregated portfolios and from the general assets of OpenTrade SPC in accordance with the laws of the Cayman Islands. The portfolio’s assets are held within a bankruptcy-free special purpose vehicle (SPV) structure and are subject to a Security Trust Deed under which an independent security trustee holds a security interest in the portfolio’s assets for the benefit of the lenders, including us acting on behalf of our users. The portfolio is managed by Five Sigma Finance Limited, an investment manager regulated by the UK Financial Conduct Authority (FCA). OpenTrade SPC and Five Sigma Finance Limited are independent of Digital Finance (Bahamas) Ltd. and are not subject to our direction or control.

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A1.4 Portfolio Structure

The assets allocated to USDC Strategy 24h are held within OpenTrade SPC’s Segregated Treasury Management Portfolio. Under the laws of the Cayman Islands, the assets in this Segregated Portfolio are separate from the assets of other segregated portfolios and from the general assets of OpenTrade SPC. The portfolio’s assets are held within a bankruptcy-free SPV structure and are subject to a Security Trust Deed under which an independent security trustee holds a security interest in the portfolio’s assets for the benefit of the lenders, including us acting on behalf of our users. This structure is designed to protect your allocated assets from claims by creditors of OpenTrade SPC or other segregated portfolios. However, no structure is completely risk-free, and the return of assets in an insolvency scenario depends on the accuracy of our records and the application of applicable insolvency laws.

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A1.5 Commissions

The rate of return displayed on the CiNKO Platform for the USDC 24-Hour Strategy is the net rate—fees have already been deducted before the rate is displayed. You will not be charged any separate fees. Current rates of return are displayed on the CiNKO Platform before you confirm any Allocation. For more information on the fees applicable to Growth Services, please refer to the CiNKO Platform, our FAQ at https://help.cinko.io/en/articles/8519789-fees-and-limits, or contact our customer service team.

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A1.6 Withdrawals

You can submit a withdrawal request for USDC Strategy 24h at any time through the CiNKO Platform.

Requests submitted before the daily cutoff time on a Business Day are typically processed on the same Business Day.
Applications submitted after the cutoff time or on a day that is not a Business Day are treated as having been submitted at the start of the next Business Day.
Withdrawal processing for the USDC 24-Hour Strategy is typically completed within 2 business days of the applicable processing start date.
In exceptional circumstances (including technical issues or market disruptions), we may notify you that processing will take longer.

Once completed, the withdrawal amount will be credited to your CiNKO USDC wallet.

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A1.7 Withdrawal Amount

The Withdrawal Amount for USDC Strategy 24h will reflect your original Allocation plus all accumulated Net Returns credited to your Growth Balance as of the processing date, minus any required deductions. USDC Strategy 24h is designed to preserve capital, which means that under normal circumstances, the Withdrawal Amount should be at least equal to your original Allocation. However, this is not guaranteed, and in exceptional circumstances (such as a significant decline in the value of the underlying assets), the Withdrawal Amount may be less than your original Allocation.

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A1.8 Disclosure of product-specific risks

In addition to the general risk disclosures in Part 5, the following risks are specific to USDC Strategy 24h:

Interest rate risk: The yield is benchmarked against the 4-week U.S. Treasury bill rate. If U.S. short-term interest rates fall, the yield on USDC Strategy 24h will fall accordingly and may approach zero. ‍
Money Market Fund Risk: A portion of the portfolio is invested in the Fidelity USD Money Market Fund, which is itself a managed product subject to its own risks, including credit risk, interest rate risk, and liquidity risk. ‍
Risk of Negative Returns: Although considered a highly exceptional scenario, a negative return is theoretically possible for this product in the context of a widespread market disruption or extraordinary market conditions. In such circumstances, the negative return would accrue daily and reduce your Growth Balance during the allocation period. ‍
Limited Liability: Your liability is limited to the assets in the OpenTrade SPC Segregated Treasury Management Portfolio. If those assets are insufficient, your claim may not be fully satisfied. ‍
Risk of processing delays: Although withdrawals are typically processed the same day or the next day, delays may occur, and the maximum processing time is 2 business days.

APPENDIX 2 — USDC Strategy 7d

USDC Strategy 7d | Version 1.0 | Effective June 1, 2026

Stablecoin Staking Yield Vault

USDC 7-DAY STRATEGY — IMPORTANT INFORMATION

USDC Strategy 7d is a high-risk digital asset investment service. Your capital is at risk. The amount you receive upon withdrawal may be less than your original investment. Withdrawals are subject to Solana’s unlocking period and may take up to 10 business days. Do not invest funds that you may need access to quickly.

A2.1 Product Description

The USDC 7-Day Strategy allows you to allocate USDC to the OpenTrade SPC Stablecoin Staking Yield Vault (the “Staking Vault”), which is operated through the OpenTrade SPC Stablecoin Staking Yield Segregated Portfolio. The Staking Vault implements a delta-neutral Solana carry trade strategy designed to generate returns from Solana (SOL) staking rewards without exposure to SOL price movements.

The strategy works as follows: your USDC is used to purchase SOL, which is staked with the Figment validator to earn staking rewards from the Solana network. Simultaneously, an equivalent short position is maintained in SOL perpetual futures, which hedges the price risk of SOL. The result is that returns are generated from staking rewards and perpetual futures funding rates without significant exposure to SOL’s price rising or falling. This type of strategy is known as a “delta-neutral” strategy.

The strategy is managed programmatically by an experienced quantitative hedge fund using institutional-grade infrastructure. Throughout the process, top-tier financial counterparties are used, including Circle, Crypto.com, and OKX. All investments are made through a bankruptcy-free SPV structure operated by Five Sigma Finance Limited, an FCA-regulated asset manager, and overseen by an independent trustee and a board of directors.

The yield rate applicable to USDC Strategy 7d is variable and is determined daily based on SOL staking rewards and perpetual futures funding rates, net of applicable fees. Under certain market conditions—specifically when the funding rate for short positions in SOL perpetual futures becomes negative, i.e., when short position holders must pay long position holders instead of receiving payment—the overall yield rate may be negative. When the yield rate is negative, interest accrues daily at that negative rate and is applied to your pending allocation, reducing your Growth Balance during the allocation period. There is no lower limit on the negative rate.

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A2.2 Key Product Details

Product Name

USDC 7-Day Strategy

Growth Provider

OpenTrade SPC — Segregated Stablecoin Staking Yield Portfolio

Strategy

Delta-neutral SOL carry trade: SOL staking + short SOL perpetual futures hedging

Performance Basis

Variable — derived from SOL staking rewards and perpetual futures funding rates, minus fees. It may be negative under certain market conditions.

Basis for the indicative rate

Annualized return over the past 30 days (past performance is not indicative of future results)

Accumulation of interest

Daily

Minimum allocation

None

Minimum withdrawal

None

Compatible networks

Ethereum

Lock-up period

None — but the withdrawal is subject to SOL's unlock delay

Retirement

At any time—typically 3 to 5 business days; maximum 10 business days

Cutoff time

6:00 p.m. GMT on a business day

Capital protection

None — The withdrawal amount may be less than the allocation

Key counterparties

Figment (Solana validator), Circle, Crypto.com, OKX

FCA-regulated broker

Five Sigma Finance Limited

Trustee

Independent Trustee under the Guarantee Trust Deed

A2.3 Growth Supplier Details

The Growth Provider for the USDC 7-Day Strategy is OpenTrade SPC, an exempt segregated holding company organized under the laws of the Cayman Islands. OpenTrade SPC operates this product through its Stablecoin Staking Yield Segregated Portfolio, whose assets are segregated from the assets of other segregated portfolios and from the general assets of OpenTrade SPC in accordance with the laws of the Cayman Islands. The portfolio’s assets are held within a bankruptcy-free SPV structure and are subject to a Security Trust Deed under which an independent security trustee holds a security interest in the portfolio’s assets for the benefit of the lenders, including us acting on behalf of our users. The portfolio is managed by Five Sigma Finance Limited, an investment manager regulated by the UK Financial Conduct Authority (FCA). OpenTrade SPC and Five Sigma Finance Limited are independent of Digital Finance (Bahamas) Ltd. and are not subject to our direction or control.

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A2.4 Portfolio Structure

The assets allocated to USDC Strategy 7d are held within OpenTrade SPC’s Stablecoin Staking Yield Segregated Portfolio. Under the laws of the Cayman Islands, the assets in this Segregated Portfolio are separate from the assets in other segregated portfolios and from the general assets of OpenTrade SPC. The portfolio’s assets are held within a bankruptcy-free SPV structure and are subject to a Security Trust Deed under which an independent security trustee holds a security interest in the portfolio’s assets for the benefit of the lenders, including us acting on behalf of our users. This structure is designed to protect your allocated assets from claims by creditors of OpenTrade SPC or other segregated portfolios. However, no structure is completely risk-free, and the return of assets in an insolvency scenario depends on the accuracy of our records and the application of applicable insolvency laws.

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A2.5 Commissions

The rate of return displayed on the CiNKO Platform for USDC Strategy 7d is the net rate—fees have already been applied before the rate is displayed. You will not be charged any separate fees. Current rates of return are displayed on the CiNKO Platform before you confirm any Allocation. For more information on the fees applicable to Growth Services, please refer to the CiNKO Platform, our FAQ at https://help.cinko.io/en/articles/8519789-fees-and-limits, or contact our customer service team.

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A2.6 Withdrawals

You can submit a withdrawal request for USDC Strategy 7d at any time via the CiNKO Platform. However, withdrawals require that SOL be unlocked from the Solana network, which is subject to Solana network block times and cannot be expedited. You should take this delay into account when deciding whether to allocate funds to USDC Strategy 7d.

The withdrawal processing period for USDC Strategy 7d works as follows:

The cut-off time is 6:00 p.m. GMT on a Business Day. Requests submitted before 6:00 p.m. GMT on a Business Day will be treated as having been submitted on that Business Day. Requests submitted after 6:00 p.m. GMT or on a day that is not a Business Day will be treated as having been submitted at the start of the next Business Day.
Unlocking SOL requires at least one Solana network epoch, which is approximately 2 to 3 days. Actual unlocking times may vary depending on network conditions.
Typical total withdrawal processing time: 3 to 5 business days from the applicable processing start date.
Maximum withdrawal processing time: 10 business days from the applicable processing start date.
In exceptional circumstances—including disruptions to the Solana network, high market volatility, or operational issues with the Growth Provider—we may notify you that processing will take longer than 10 Business Days. We will provide you with a notice via the CiNKO Platform as soon as reasonably possible if this occurs.

Once completed, the withdrawal amount will be credited to your CiNKO USDC wallet.

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A2.7 Withdrawal Amount — Capital at Risk

Your capital is at risk. The Withdrawal Amount for USDC Strategy 7d is determined based on the net realized value of the Staking Vault portfolio at the time of processing. This means that the Withdrawal Amount may be less than the amount you originally allocated. You may lose some or all of your allocation. Past performance is not indicative of future results.

The Withdrawal Amount is calculated based on the net income of the underlying portfolio at the time of processing, after deducting all applicable fees and amounts due in accordance with the order of priority of payments set forth in the Trust Deed. The indicative rate of return and the Growth Balance displayed on the CiNKO Platform are not guarantees of the Withdrawal Amount you will receive.

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A2.8 Disclosure of product-specific risks

In addition to the general risk disclosures in Part 5, the following risks are specific to USDC Strategy 7d:

Capital risk: This product does not offer principal protection. The withdrawal amount may be less than your original investment. You may lose some or all of your investment.
SOL Staking Risk: Stakingrewards on the Solana network are variable and may decrease due to changes in the network, protocol updates, or other factors beyond the control of Growth Provider or the validator .
Perpetual Futures Financing Rate Risk: The financing rate for short positions in SOL perpetual futures may be negative under certain market conditions, reducing overall returns. In extreme conditions, this could result in a loss. ‍
Negative yield risk: Under certain market conditions, the yield rate applicable to USDC Strategy 7d may be negative. This occurs when the funding rate for short positions in SOL perpetual futures is sufficiently negative to exceed the SOL staking rewards component of the yield. When a negative rate is applied, it accrues daily and reduces your Growth Balance during the allocation period. This reduction is independent of and in addition to any capital loss that may be realized upon withdrawal. There is no contractual lower limit on the negative rate. ‍
Solana Network Risk: The Solana blockchain may experience network outages, congestion, protocol changes, or forks that delay unlocking, affect the value of staked SOL, or otherwise disrupt Staking Vault operations. ‍
Validator Risk: The Staking Vault relies on a third-party Solana validator. Operational failure, misconduct, or insolvency on the part of the validator could negatively impact staking rewards or the return of staked assets. ‍
Counterparty risk: The Staking Vault uses third-party counterparties identified in the product key details table above. Operational failure, insolvency, or regulatory action affecting any of these parties could adversely affect the Staking Vault and your Withdrawal Amount. ‍
Risk of Withdrawal Delays: Withdrawals require the unlocking of SOL, which cannot be expedited. You may not be able to access your allocated Digital Assets for up to 10 Business Days after submitting a Withdrawal Request. Do not allocate funds to USDC Strategy 7d if you may need access to those funds within 10 Business Days. ‍
Increased complexity: This product involves a more complex underlying strategy than USDC Strategy 24h. The delta-neutral structure is designed to eliminate exposure to the price of SOL, but this hedging may not be perfect under all market conditions. You should ensure that you understand how this product works before investing. ‍
Limited Liability: Your liability is limited to the assets of the relevant Segregated Portfolio. If those assets are insufficient, your claim may not be fully satisfied.

ACCEPTANCE

By accepting these Growth Terms, you confirm that you have read, understood, and accepted Parts 1 through 7 of these Growth Terms and the applicable Addendum for each Growth Product you have selected. Your acceptance of an Addendum is recorded separately for each Growth Product at the time of enrollment. A modification to an Addendum will require only your new acceptance of that Addendum. A modification to Parts 1 through 7 will require your new acceptance of these Growth Terms.