KYC / KYB Policy

SOAX LTD — Know Your Customer / Know Your Business Policy.

This KYC / KYB Policy (the "Policy") forms part of, and is incorporated by reference into, the SOAX Terms of Use. Capitalised terms used but not defined here have the meanings given to them in the ToU.

1. Purpose and Scope

1. This Know Your Customer / Know Your Business Policy (the "Policy") explains how SOAX LTD ("SOAX", "we", "us" or "our") verifies those who register for and use the Platform, and the standards SOAX applies to maintain a secure, lawful and trusted service. SOAX operates a web access infrastructure platform and, while it is not a regulated financial institution, it applies identity-verification and risk-management measures as a matter of good governance and consistent with market best practice.

2. Capitalised terms used but not defined in this Policy have the meaning given to them in the Terms of Use. This Policy forms part of, and should be read together with, the Terms of Use, the Acceptable Use Policy and the Privacy Policy.

2. When Verification Applies

1. Identity verification is a condition of access to the paid Platform. Before an Organization is able to complete a purchase or activate a paid Service, the Owner (and, where applicable, the underlying Business Entity and its authorised representatives) must successfully complete the verification steps presented through the Dashboard.

2. The verification steps presented to a given Organization, and the information required to complete them, may vary depending on the Entity Type, the Service, the intended use, the jurisdiction, the payment method and SOAX's internal risk assessment. SOAX may update these requirements from time to time.

3. SOAX may decline to open an Account, or to enable a purchase or any particular Service, where verification has not been satisfactorily completed.

4. The verification and ongoing monitoring described in this Policy are not limited to customers. SOAX also applies proportionate identity, business and risk verification to its Business Partners (the clients, customers, suppliers, partners, agents, intermediaries and other third parties with whom SOAX has, or proposes to have, a business or contractual relationship), to the extent appropriate to the nature of the relationship and the risk it presents.

5. Each Business Partner must provide the information and documentation that SOAX reasonably requires for verification and ongoing monitoring, and must ensure that its own directors, officers, employees, agents and representatives comply with this Policy in connection with any dealings with SOAX. The remaining provisions of this Policy apply to Business Partners with any necessary modifications.

3. Information We May Require

1. Depending on the applicable verification level, SOAX (directly or through its verification providers) may require information and supporting documentation such as the identity and contact details of the Owner and authorised representatives, business registration and entity details, tax identification information, ownership and beneficial ownership information and, where relevant, copies of identification documents or other supporting evidence.

2. You must ensure that all information and documentation provided is accurate, complete, current and not misleading, and must promptly notify SOAX of any material change.

4. Ongoing Monitoring and Re-Verification

1. SOAX may carry out identity verification and risk review at any time, not only at onboarding, and reserves the right, on the basis of its internal monitoring and risk assessment, to: (a) request additional or updated information, explanations or supporting documentation, including further copies of identification or business documents; (b) re-verify the Organization, the Owner, Business Partner, any authorised representative, the underlying Business Entity, any beneficial owner or controller, or any payment source; and (c) review activity on the Account for compliance, fraud-prevention, sanctions and security purposes.

2. Circumstances that may trigger further verification include, among others, a change in ownership, control, representatives, business activity or jurisdiction; unusual, high-risk or suspicious activity; a change in payment method; or any other factor SOAX reasonably considers relevant to risk.

3. You must provide any information or documentation requested under this Section promptly. SOAX may suspend or restrict access pending completion of such review.

5. Verification Providers

1. SOAX may use reputable third-party identity-verification and screening providers to perform or support verification and ongoing monitoring. Such providers process personal data in accordance with the Privacy Policy and, where applicable, as independent controllers under their own privacy terms.

6. Consequences of Non-Completion

1. Where verification is not satisfactorily completed, or where SOAX identifies a compliance, fraud, sanctions or other material risk, SOAX may refuse, restrict, suspend or terminate access to the Platform or any Service, in whole or in part, in accordance with the Terms of Use. Any such measure shall not constitute a breach of the Agreement and shall not give rise to any refund, compensation or other remedy, except to the extent required by mandatory applicable law.

7. Data Protection and Confidentiality

1. SOAX treats information collected for verification purposes as confidential and processes it only for identity verification, eligibility assessment, risk management, fraud prevention and compliance with applicable law. The categories of data collected, the legal bases for processing and the applicable retention periods are described in the Privacy Policy.

8. Changes to this Policy

1. SOAX may amend this Policy from time to time. The version published on the Site is the current version and supersedes any earlier version.

9. Contact

9.1. Questions about this Policy may be directed to support@soax.com.

Effective Date: 1 June 2026