INFII Platform – Terms and Conditions Governing Products and Services

1.1. To open and maintain a Vault or access services/products, you must: a) Meet INFII's onboarding criteria, including submission of necessary personal and corporate documents; b) Consent to due diligence, verification checks, and KYC/KYB procedures; c) Provide any required information in the form and frequency requested by INFII; d) Acknowledge that failure to comply may result in rejection or closure of your Vault.

2.1. All instructions must be submitted through channels expressly approved or designated by INFII. 2.2. INFII may act on any instruction that reasonably appears to be issued by you or an authorized representative, without further verification. 2.3. The use of access credentials such as passcodes, PINs, digital signatures, or authentication tools will be deemed as valid authorisation from you. 2.4. INFII reserves the right to request additional identity verification and may delay the execution of any instruction until satisfactory confirmation is received. 2.5. Once submitted, all instructions are final and irrevocable unless INFII agrees otherwise in writing. 2.6. INFII may refuse, withhold, or delay execution of any instruction if it suspects fraud or unlawful activity, if the instruction is incomplete or unclear, if required by law or regulation, or due to technical or system issues. 2.7. INFII shall not be liable for any loss, damage, or delay arising from the execution or non-execution of any instruction, except where caused by its gross negligence, fraud, or willful misconduct.

3.1. INFII will provide Vault statements, transaction records, and other notifications through its digital channels, including the Platform, email, or in-app messaging. 3.2. You are responsible for promptly reviewing all statements and notifications and must report any errors, discrepancies, or unauthorized transactions without delay. 3.3. If no written dispute or objection is raised within fourteen (14) days from the date of issuance, the statement shall be deemed accurate, complete, and conclusive. 3.4. INFII reserves the right to amend or adjust any entries in your Vault to correct clerical errors, omissions, or mispostings, with or without prior notice.

4.1. INFII reserves the right to impose, revise, or update any service fees, charges, or applicable costs by providing at least twenty-one (21) days’ prior notice through email, Platform notification, or website publication. 4.2. INFII may debit your Vault or pursue other recovery methods. 4.3. All fees and charges paid to INFII are strictly non-refundable, unless expressly stated otherwise in writing. 4.4. You are solely responsible for the timely payment of all fees, charges, taxes, or other costs associated with your use of the Platform and related services. 4.5. INFII may, without further notice, debit any amounts due from your Vault balance or pursue alternative legal or administrative recovery methods if payment is not received. 4.6. The current fee schedule applicable to all services offered through the Platform is published at https://www.infii.com/pricing, which forms an integral part of these Terms. You acknowledge and agree that by continuing to use the Platform, you are deemed to have accepted and consented to the applicable fees as listed and updated from time to time.

5.1. You consent and authorize us to disclose or share your personal and transactional information with our service providers, affiliates, professional advisers, regulatory authorities, payment processors, law enforcement agencies, or any other third parties as may be required to a) provide the services to you, b) comply with applicable laws, regulations, court orders, or lawful requests, or c) enforce our rights and obligations under these Terms. 5.2. This clause remains effective post-termination.

6.1. INFII collects, uses, processes, and discloses your personal and corporate data in accordance with the Data Privacy and Protection (Clause 27). This includes: a) the collection of personal and corporate data you voluntarily provide; b) automatic collection through our digital interfaces (e.g., IP address, browser type); c) the use of cookies and similar technologies; d) purposes including but not limited to service provision, compliance, analytics, and security; e) lawful sharing with third parties such as service providers, regulators, and legal authorities; f) cross-border transfers of data where necessary; g) secure storage and data retention consistent with legal and regulatory obligations; h) your rights to access, correct, or withdraw consent where permitted by applicable laws. 6.2. Your consent under these Terms continues to remain valid and enforceable after closure of your Vault, termination of services, or in the event of your incapacity or death, to the extent permitted by law.

7.1. You confirm that: a) You have the legal capacity, authority, and ability to enter into and comply with these Terms, and carry out transactions on the Platform. b) You have secured all required approvals, licenses, and consents to enter into and perform your obligations under these Terms. c) These Terms are legally binding and enforceable against you. d) All information and documents you provide are true, complete, up to date, and not misleading. You permit us to verify them as needed. e) You have read, understood, and accepted the Platform’s Data Privacy and Protection (Clause 27). f) You consent to the collection, use, processing, storage, and sharing of your personal and corporate data as stated in the Data Privacy and Protection (Clause 27). g) Your participation does not and will not breach any law, regulation, or agreement you are bound by. h) You have not and will not engage in unlawful activities such as tax evasion, money laundering, terrorism financing, bribery, or corruption, nor are you involved in sanctioned activities. i) You accept the Platform’s zero-tolerance on bribery and corruption. j) You are not a resident of, and will not access the Platform from, any location where our services are restricted. You will comply with all applicable laws. k) You act on your own behalf and not for anyone else, unless disclosed and approved by us in writing. l) You have not been declared bankrupt or insolvent. m) No existing or expected issue prevents you from fulfilling your obligations under these Terms.

8.1. You acknowledge and agree that INFII may offer similar or competing services to other clients, partners, or users, and this shall not constitute a conflict of interest. 8.2. INFII may also receive referral fees, commissions, or other forms of compensation from affiliates, service providers, or business partners for introducing or referring clients, including you, to such parties. 8.3. These arrangements will not affect our obligation to act in a fair and commercially reasonable manner in delivering services to you.

9.1. INFII may engage third-party service providers, contractors, or agents to perform any part of its services, including but not limited to technology support, payment processing, identity verification, data storage, or client onboarding. 9.2. You acknowledge and agree that such third parties may have access to your information to the extent necessary to carry out their duties, and INFII shall take reasonable steps to ensure they maintain confidentiality and comply with applicable data protection laws. 9.3. INFII shall not be liable for any act, omission, or default of such third parties beyond its reasonable control but will use reasonable efforts to ensure that they perform their services to an acceptable standard.

10.1. INFII reserves the right to approve or reject applications, suspend services, close Vaults, and take any lawful measures to ensure compliance or mitigate risk. 10.2. All communications, interactions, and transactions on the Platform may be recorded, stored, and used as evidence in any dispute or legal proceeding. 10.3. INFII’s internal records and system logs shall be deemed conclusive evidence of transactions and activities unless a clear and manifest error is proven. 10.4. INFII may take any actions required to comply with applicable laws, regulations, regulatory requests, or court orders, and shall not be held liable for doing so. 10.5. INFII reserves the right to freeze, restrict, or terminate any Vault or account in the event of non-compliance, suspected fraud, misconduct, or other risk-related concerns, without prior notice.

11.1. All payments due to INFII shall be made in full, free of any deductions, set-offs, counterclaims, or withholding taxes, except as required by applicable law. If any deduction or withholding is required by law, you shall increase the payment amount so that INFII receives the full amount originally invoiced. 11.2. Any overdue amounts may accrue interest at a rate reasonably determined by INFII, and INFII reserves the right to take necessary legal or administrative action to recover unpaid amounts, including suspension of services. 11.3. All fees, charges, and payments made to INFII are strictly non-refundable, unless otherwise expressly stated in writing.

12.1. INFII may, at its discretion, convert any funds, payments, or assets received in a foreign currency into its operating currency using the applicable exchange rate at the time of conversion. 12.2. You acknowledge and agree that such conversions may be subject to currency fluctuations and that INFII may apply reasonable fees or spreads for such conversion services. 12.3. INFII shall not be liable for any loss or shortfall arising from exchange rate differences or currency risks.

13.1. INFII reserves the right, without prior notice or consent, to apply, withhold, or set off any funds or assets held in your Vault against any fees, charges, liabilities, or other amounts owed to INFII under these Terms or in connection with any services provided. 13.2. INFII also retains a continuing lien over all funds and assets in your Vault as security for any outstanding obligations you owe to INFII.

14.1. INFII does not provide any form of financial, investment, legal, accounting, or tax advice in connection with the use of its Platform or services. 14.2. All information provided by INFII is for general informational purposes only and should not be relied upon as professional advice. 14.3. You are solely responsible for obtaining independent advice from qualified professionals before making any decisions based on the services or information provided by INFII.

15.1. To the fullest extent permitted by law, INFII shall not be liable for any loss, damage, cost, or expense incurred by you in connection with the use of the Platform or services, except where such loss is directly caused by INFII’s gross negligence, wilful misconduct, or fraud. 15.2. INFII shall not, under any circumstances, be liable for any indirect, incidental, special, punitive, or consequential damages, including but not limited to loss of profits, revenue, business, or data, even if advised of the possibility of such losses.

16.1. You agree to fully indemnify, defend, and hold harmless INFII, its officers, directors, employees, and agents from and against any and all claims, liabilities, losses, damages, costs, and expenses (including legal fees) arising from or related to your use of the Platform or services, breach of these Terms, or violation of any applicable law or regulation—except to the extent such losses result directly from INFII’s gross negligence or wilful misconduct.

17.1. INFII shall not be held liable for any delay, failure, or interruption in the performance of its obligations under these Terms caused by events beyond its reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, civil unrest, government restrictions or actions, labour disputes, power or utility failures, internet or telecommunications outages, or system breakdowns. 17.2. During such events, INFII’s obligations shall be suspended for the duration of the force majeure event, and it shall not be considered in breach of these Terms as a result of such non-performance.

18.1. You may terminate your use of the Platform and request closure of your Vault at any time by providing a formal board resolution to support@infii.io to INFII, subject to the settlement of all outstanding obligations. 18.2. INFII reserves the right to suspend or terminate your access to the Platform and close your Vault immediately, with or without notice, if: a) You breach these Terms; b) You fail to comply with applicable laws or regulatory requirements; c) You become insolvent or bankrupt; d) Suspicious, fraudulent, or unlawful activity is detected; e) Termination is required by law, regulation, or order of a competent authority; or f) Your Vault balance is insufficient to cover applicable fees or charges, and despite system-generated reminders, no corrective action is taken. In such cases, your account may be suspended. Reactivation is subject to full settlement of all outstanding dues and payment of a reactivation fee. 18.3 Termination shall not affect any rights, obligations, or liabilities accrued prior to the effective date of termination, and any provisions intended to survive termination shall remain in full force and effect.

19.1. All notices, updates, and communications from INFII may be delivered via email, in-app notifications, messages through the Platform, or by publication on our official website. Such communications shall be deemed received upon transmission or publication. 19.2. You are responsible for ensuring that your contact details, including email address and other communication channels, are accurate and kept up to date. INFII shall not be liable for any loss arising from your failure to do so. 19.3. You acknowledge that access to your Account or the Platform may be restricted or unavailable in certain countries due to local laws, regulatory constraints, or platform limitations. In particular, the INFII mobile application is currently only available on the Apple App Store for the Malaysia region. As such, you may encounter issues downloading or updating the application when located outside Malaysia. If you are unable to access or manage your Account due to such limitations, please contact us at support@infii.io for assistance.

20.1. INFII reserves the right to amend, modify, or update these Terms at its sole discretion by providing at least twenty-one (21) days’ prior notice to you. Such notice may be given through email, the Platform, or our official website. 20.2. Your continued access or use of the Platform or its services after the effective date of any amendments shall constitute your acceptance of the revised Terms. If you do not agree to the changes, you must discontinue use of the Platform before the changes take effect.

21.1. INFII may assign or transfer any of its rights and obligations under these Terms to any affiliate, successor, or third party without prior notice. 21.2. You may not assign, transfer, or delegate any of your rights or obligations under these Terms without INFII’s prior written consent. Any unauthorized assignment shall be deemed null and void.

22.1. No failure or delay by INFII in exercising any right, power, or remedy under these Terms shall operate as a waiver of such right or limit its enforcement. Any waiver must be made in writing to be effective

23.1. If any provision of these Terms is found to be invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect to the maximum extent permitted by law.

24.1. These Terms constitute the entire agreement between you and INFII with respect to the services provided and supersede all prior or contemporaneous agreements, understandings, representations, or communications, whether written or oral.

25.1. These Terms shall be governed by and construed in accordance with the laws of Malaysia, without regard to conflict of law principles. 25.2. Any dispute, controversy, or claim arising out of or in connection with these Terms shall first be addressed through INFII’s internal complaints and dispute resolution procedures. Parties agree to use reasonable efforts to resolve disputes amicably before pursuing any external legal remedies.

26.1. Legal notices, summons, or other court documents may be served on you by mail, email, or any other method permitted under applicable law. Such service shall be deemed effective upon delivery or transmission, as applicable.

27.1. In the event that you die or are otherwise incapacitated, we will cooperate with your Representatives (means authorised heir(s), executor(s), administrator(s), successor(s) in title and/or assign(s) of a Customer) in accordance with applicable laws and regulations. 27.2. Upon notice of your death or incapacitation, we may suspend activity in your Vault, pending verification or resolution of such notice. 27.3. Notwithstanding the foregoing, prior to agreeing to transfer funds from your Vault to your Representative(s), we reserves the right to require your representative(s) to do the following: a) To provide evidence reasonably satisfactory to us that demonstrates your death or incapacitation and the subsequent entitlement of your representative(s) to such a transfer; b) To comply with and submit to identity verification requirements which are at least equivalent to those you were submitted to when opening your Vault as set out in this Agreement; c) To indemnify and hold us harmless to the extent and in the form required by us, including, but not limited to, claims of negligence; and d) To provide any other information, evidence, documentation, confirmation or any other details or verification that we may reasonably require in order to allow us to process such a request. 27.4. If your account remains inactive for seven (7) consecutive years, we will classify the funds as unclaimed and proceed in accordance with the Unclaimed Moneys Act 1965, including the transfer of such funds to the appropriate authority as prescribed by law.

28.1. We are committed to treating our users fairly and resolving any concerns promptly and transparently. If you are dissatisfied with any part of our service or platform, you have the right to submit a complaint through your account portal. 28.2. All complaints must be submitted through the designated complaint feature available within your INFII account. We do not accept complaints via external communication channels unless otherwise specified. 28.3. Upon receiving your complaint, we will acknowledge it within 5 business days and aim to resolve the matter within 21 business days. If more time is required, we will keep you informed of the delay and the expected timeline for resolution. 28.4. If you are not satisfied with the outcome, you may contact our Customer Service team to request that your complaint be referred to a member of the management team for further review and handling. 28.5. We maintain a secure record of all complaints and their outcomes in accordance with regulatory and legal requirements.

29.1. INFII is committed to protecting the privacy and confidentiality of your personal and corporate data. This clause sets out how your data will be collected, used, processed, stored, and disclosed in connection with your use of the Platform and related services. 29.2. By using the Platform, you expressly consent to the collection, use, storage, processing, and disclosure of yours and your counterparties’ personal and corporate information, including but not limited to name, contact details, identification documents, business records, account activities, and transaction history, for the following purposes: a) verifying your identity and conducting due diligence (e.g., KYC/KYB); b) managing your Vault and providing you with services; c) fulfilling legal, regulatory, or compliance obligations; d) detecting and preventing fraud, misconduct, or other unlawful activities; e) managing risk and operational processes (e.g., audits, reporting, data backups); f) communicating with you regarding your account, service updates, or legal notices; or g) sharing with third-party service providers, affiliates, professional advisers, or regulatory authorities where necessary to perform services or comply with applicable laws. 29.3. INFII will take reasonable technical and organizational measures to safeguard your data from unauthorized access, loss, misuse, or alteration. 29.4. You acknowledge that certain data may be transferred or stored in jurisdictions outside of Labuan or Malaysia, where data protection standards may differ. INFII will take reasonable steps to ensure that such transfers comply with applicable data protection laws. 29.5. You have the right to access, update, or correct your personal data held by INFII, subject to reasonable administrative procedures. Requests must be submitted in writing to the designated contact. 29.6. INFII will retain your data for as long as necessary to fulfill the purposes outlined above or as required by law, including after the closure of your Vault.

30.1. In these Terms, unless the context otherwise requires, the following expressions shall have the meanings set out below: "Applicable Law" means all applicable laws, statutes, regulations, rules, directives, codes, guidelines, or industry standards, whether or not having the force of law, in any jurisdiction relevant to the services provided or the customers served, and includes any amendments, modifications, variations, or re-enactments thereof from time to time. "Authorities" means any local or foreign governmental, regulatory, enforcement, or supervisory body or authority, including but not limited to financial services regulators, anti-corruption agencies, the police, tax authorities, and any other competent authorities. "Business Day" means any day on which the Platform is open and operational for carrying out transactions and business of the nature contemplated under these Terms, excluding weekends and public holidays (unless otherwise stated). "Customer Information" means any information relating to you that the Platform collects, receives, stores, or processes in connection with the provision of its services or products, including your Personal and Corporate Data, Vault details, transaction records, and other associated data. "Event of Default" means any event, occurrence, or circumstance that entitles the Platform to terminate these Terms or suspend, restrict, or discontinue any service or product under Clause 18 (Termination and Vault Closure). "Loss" means any and all losses, damages, costs (including legal fees on a full indemnity basis), expenses, liabilities, penalties, taxes, charges, suits, claims, demands, actions, proceedings, or other liabilities of any nature whatsoever—whether direct, indirect, consequential, economic, or special, and whether foreseeable or not—arising under contract, tort, statute, or otherwise, including any loss of profits, revenue, goodwill, data, or opportunity. "Personal and Corporate Data" means any data, whether true or not, relating to an individual or a legal entity who can be identified from that data or from that data in combination with other information. "PIN" means any personal identification number, passcode, or security code issued or created for use with any Platform service or product. "Platform" means the digital infrastructure, systems, interfaces, and services operated by by "INFII," through which clients may access and utilize various financial products and services, including but not limited to Vaults, fund transfers, identity verification, data reporting, and transaction monitoring. The Platform includes all related websites, mobile applications, backend systems, APIs, and third-party integrations as may be designated by INFII from time to time. "Related Entities" means all related corporations and associate corporations of: (i) the Platform; (ii) the Platform’s holding company or companies; and (iii) the Platform’s ultimate holding company or companies. The term "Related Entity" shall be construed accordingly. "Vault" means a consolidated facility assigned to the client, comprising one or more digital wallets or accounts used to collect, hold, and transact in funds or other supported assets. Vaults are managed via the INFII Platform and maintained in partnership with licensed digital custody, banking, or card issuance service providers. Each Vault may include sub-accounts or wallets with distinct functionalities, subject to applicable regulatory, operational, or platform-specific requirements. 30.2. Unless the context otherwise requires: (a) Headings are inserted for convenience only and shall not affect the interpretation of these Terms. (b) References to a “Clause” are references to clauses of these Terms. (c) References to “you” include the individual or entity who has registered or maintains a Vault with the Platform, uses any of the Platform’s services or products, or is otherwise bound by these Terms, and (where applicable) that individual’s legal representative(s). (d) The term “person” includes individuals, corporations, partnerships, trusts, unincorporated associations, and other legal or business entities. (e) The terms “includes” or “including” shall be interpreted to mean “includes without limitation” or “including without limitation.” (f) References to actions include omissions and failures to act. (g) References to any law, regulation, guideline, code, or rule include any amendment, supplement, variation, or re-enactment thereof. 30.3. In the event of any inconsistency or conflict between the English version of these Terms and any translation, including but not limited to the Bahasa Malaysia version, the English version shall prevail and govern.

1.1. To open and maintain a Vault with INFII, you must meet all of the following criteria: a) Be at least eighteen (18) years of age (for individuals) or a duly incorporated and validly existing legal entity; b) Successfully complete Know-Your-Customer (KYC) or Know-Your-Business (KYB) verification, as required by INFII and its appointed verification partners; c) Not be engaged in, or associated with, any unlawful activities, including but not limited to money laundering, terrorism financing, human trafficking, or evasion of international sanctions; d) Maintain only one (1) Corporate Vault per legal entity or individual, unless prior written approval is granted by INFI.

2.1. Each Vault may contain multiple wallets, with each wallet holding and managing funds independently. 2.2. Wallet functionality (e.g., transferability, limits, returns) will be defined by the Platform based on product specifications.

3.1. You authorize INFII to deduct all applicable fees, taxes, and charges directly from your Vault as they become due. 3.2. A minimum initial deposit may be required to activate and maintain your Vault, as determined by the Platform. 3.3. Failure to meet or maintain the required minimum balance may result in restrictions, suspension, or deactivation of the Vault. 3.4. A maximum balance threshold may apply to your Vault. Any amounts exceeding this limit may be subject to overage fees, as specified in the applicable fee schedule or product terms.

4.1. You may transfer funds between your wallets or to third parties, subject to applicable laws, regulatory requirements, and Platform rules and limitations. 4.2. INFII shall not be liable for any losses arising from incorrect transfer instructions, recipient errors, or third-party actions beyond its control. 4.3. You are required to promptly notify INFII of any unexpected or erroneous incoming funds. INFII reserves the right to reverse or reclaim such funds without prior notice if determined to have been credited in error.

5.1. INFII may facilitate payments or fund transfers through third-party payment operators, gateways, or networks. Such transactions are subject to the rules, terms, and conditions of the respective payment systems. 5.2. In the event of a dispute, chargeback, or regulatory requirement, INFII may withhold, suspend, or reverse a transfer in accordance with the applicable rules of the involved payment service providers.

6.1. Your Vault may be suspended or deactivated without prior notice if there is an insufficient balance, failure to pay applicable service fees, or prolonged inactivity as determined by the Platform. 6.2. Reactivation of the Vault is subject to full settlement of all outstanding fees, charges, and compliance with the current minimum balance and operational requirements. 6.3. If your account remains inactive for a period of three (3) years, we reserve the right to suspend the account.

7.1. You may request to close your Vault at any time, provided all funds are fully transferred out and no outstanding obligations remain. 7.2. INFII reserves the right to terminate your Vault immediately without prior notice in cases of breach of these Terms, failure to comply with regulatory or verification requirements, suspected fraud or misconduct, or extended periods of inactivity. 7.3. Upon closure, any remaining balance (after applicable deductions, fees, or obligations) will be returned to you following internal review and verification procedures.

8.1. INFII Vaults do not accept or support cash deposits, cheque-based payments, or any other physical forms of fund transfer. All transactions must be conducted through approved digital or electronic channels.

9.1. Monthly Vault statements will be provided to you electronically via the Platform or your registered communication channel. 9.2. You are responsible for promptly reviewing all statements and must report any discrepancies or unauthorized transactions to INFII within fourteen (14) days from the statement date. If no such report is received, the statement shall be deemed accurate and accepted.

10.1. INFII will maintain records of your Vault, transactions, and related information for a minimum of seven (7) years, or as required by applicable laws, regulations, and guidelines issued by Labuan FSA and under the Anti-Money Laundering Act (AMLA). 10.2. In the event of the death of a Vault holder or authorized signatory, INFII will require satisfactory proof of authority—such as a death certificate, grant of probate, or court order—before releasing or transferring any remaining funds to a claimant or beneficiary.