Terms of Service

TERMS OF SERVICE Effective date: 01/01/2026 Last updated: 01/02/2026 Please read these Terms of Service ("Terms") carefully before accessing, browsing, or using the website/application/software platform FinAlpha provided by Fintech AI Joint Stock Company ("FinAlpha", "We", "Us"). By accessing or using the Service (including creating an account, subscribing, using features, sending/receiving data, or contacting support), you confirm that you have read, understood, and agree to be bound by these Terms, and consent to the processing of personal data in accordance with our Security Policy (which is considered an integral part of these Terms). If you do not agree with any of these Terms, please stop using the Service. 1. General provisions & scope of service 1.1. Our Services may include (depending on the product): SaaS software, mobile applications, management tools, customer support services; KYC/KYB identity verification functions; and/or features related to trading/payment/digital assets (if provided under specific plans). 1.2. Risk warning: If the Service provides market analysis/recommendations/data display or trading-related features, you understand that markets can be volatile and there is a risk of loss. We are not a broker/agent/fiduciary investment advisor; all decisions you make are your own responsibility. 2. Terms of use & accounts 2.1. You must have full legal capacity as required by law. The platform is not intended for persons under 18 years of age. 2.2. When creating an account, you commit to providing complete, accurate, truthful information and updating it when changes occur. 2.3. We reserve the right to request and/or perform identity verification processes (KYC/KYB), enhanced due diligence as required by law and/or risk management policies, including document verification, biometric verification (selfie), photo/video verification, and screening for AML/CFT compliance (anti-money laundering/counter-terrorism financing), to the extent permitted by law. If you do not provide information or cooperate, We may refuse/suspend/terminate the Service. 3. User rights and responsibilities 3.1. You are permitted to access and use the Service for lawful purposes, in accordance with these Terms and Vietnamese law. 3.2. You are responsible for securing your account, password, OTP/2FA codes, and login devices; you bear responsibility for all activities arising from your account (except where determined to be caused by our system errors). 3.3. You agree not to engage in prohibited activities, including but not limited to: • Infiltrating, interfering with, or damaging the system; distributing malware; scanning for vulnerabilities; unauthorized data collection. • Impersonating identity, providing false information; assisting others in unauthorized use of accounts/data. • Buying or selling personal data in violation of regulations; unauthorized disclosure of personal data or trade secrets. • Fraud, money laundering, terrorism financing, or other illegal activities; circumventing system controls. • Copying/exploiting content, trademarks, source code, designs, etc. of ours for commercial purposes without written consent. 4. Service fees, payment & invoicing (if applicable) 4.1. Some features/service plans may require payment. Fee amounts, billing cycles, and payment methods are published in the relevant service plan/order/agreement. 4.2. You are responsible for paying in full and on time; We reserve the right to suspend service when overdue payments or signs of payment fraud arise. 4.3. Taxes, fees, and currency a) Fees displayed on the platform may or may not include VAT/taxes/fees as required (depending on the plan/order). Where not included, applicable taxes/fees will be added at checkout or shown on the invoice. b) Payment currency is VND (unless otherwise notified/agreed in writing). 4.5. Auto-renewal (if applicable) a) For recurring subscription plans, the Service may auto-renew at the end of each billing cycle (monthly/annually, etc.) unless you cancel renewal before the renewal date as instructed on the platform. b) In case of auto-renewal, the fee for the next cycle will be charged at the price at the time of renewal (unless otherwise committed in the contract/order). 4.6. Price and plan changes We may adjust fees/service plans from time to time and will publish/notify on the platform. Changes will take effect according to the notice and/or apply from the next billing cycle (as applicable and to the extent permitted by law). 4.7. Payment failure, collection, and service suspension a) If payment fails (e.g., insufficient balance, declined, technical error), We may (i) attempt to re-charge within a reasonable period; and/or (ii) request you to update your payment method. b) During the period of outstanding payment obligations, We reserve the right to suspend/restrict part or all of the Service, and/or terminate under these Terms. 4.8. Reconciliation, errors, and payment disputes a) If you suspect an unusual/incorrect transaction, you should notify us within a reasonable time from the transaction date for reconciliation support. b) We may request information/documentation for verification (e.g., transaction code, bank statement, order information). Resolution depends on reconciliation results with the system and/or payment intermediary. 4.9. Invoices and receipts (if applicable) a) We may provide electronic invoices/receipts as required and based on the information you provide. b) You are responsible for providing accurate and updated invoicing information; any risks arising from incorrect/incomplete information are your responsibility. 4.10. Disputed transactions/chargebacks and fraud a) If you initiate an unfounded transaction dispute/chargeback or there are signs of fraud, We may suspend your account and/or restrict the Service during investigation, while reserving the right to claim reimbursement for any costs incurred (if any) to the extent permitted by law. b) We may refuse to provide the Service to accounts with a history of unusual disputes/chargebacks. 5. Refunds, service cancellation, and processing of paid amounts 5.1. General principle a) Unless otherwise stated in the service plan/order/contract, service fees paid are non-refundable for the period during which the Service has been provided/access has been activated (including digital/SaaS services). b) This refund policy does not exclude any mandatory refund/cancellation rights required by law (if any). 5.2. Cases eligible for refund consideration We may consider refunds (full or partial) in the following cases, after verification: a) Duplicate payment for the same order/service plan. b) Incorrectly charged amount due to technical errors from our system (not including errors from the bank/payment gateway/your device). c) Service cannot be provided for a significant period due to our fault and We cannot resolve within a reasonable timeframe (in this case, service time extension/credit may be prioritized over cash refund, at our discretion and/or as agreed with you). d) Other cases as agreed in writing between you and us. 5.3. Non-refundable cases (following SaaS standards) a) You change your usage needs, no longer need the service, or do not use it during the purchased period. b) You violate the Terms resulting in service suspension/termination under Section 10. c) Fees charged by (i) bank/payment gateway; (ii) exchange rate differences; (iii) transfer fees; (iv) other deductions beyond our reasonable control. 5.4. Renewal cancellation and plan expiration a) You may cancel subscription renewal as instructed on the platform. Cancellation takes effect from the next billing cycle; you may continue using the Service until the end of the paid period (unless suspended/terminated under Section 10). b) Unless otherwise stated in the plan/contract, cancellation of renewal does not entail a refund for the remaining time of the current active cycle. 5.5. Refund request process a) Submit your request through the contact channels in Section 13, with at minimum: (i) account email/ID; (ii) order/transaction code; (iii) payment date; (iv) amount; (v) reason description and supporting documents (if any). b) We will respond and process within a reasonable timeframe upon receiving complete information (processing time may depend on bank/payment gateway reconciliation procedures). 5.6. Refund method and timeline (if approved) a) Refunds (if any) are generally processed to the original payment method or another method as agreed and in accordance with regulations. b) The time for funds to reach your account depends on the bank/payment gateway and may take several business days. 5.7. Promotions, discount codes, credits/trials (if applicable) Discount/promotional credits/trials (if any) may have separate terms of use and are not convertible to cash/non-refundable, unless otherwise required by law. 6. Privacy, personal data & cookies 6.1. We process personal data in accordance with the Privacy Policy and current Vietnamese law (including personal data protection regulations and KYC/AML-related regulations). 6.2. Data may be collected from: (i) information you provide; (ii) automatically collected data (IP, cookies, device, system logs, usage behavior); (iii) third parties through integration/login/verification partners. 6.3. Cookies: You have the right to manage cookies (except essential cookies). Disabling cookies may affect your experience or certain features. 6.4. Data retention: We retain data according to processing purposes and legal retention requirements; certain KYC/KYB records and transaction histories may need to be kept for minimum periods as required by anti-money laundering regulations. 7. Information security & incident response 7.1. We apply reasonable organizational, technical, and physical measures (encryption, access control, firewalls, monitoring, backups, etc.) to protect data. 7.2. In the event of a security incident/data breach, We will handle it according to internal procedures and notify users/authorities as required by law (especially for sensitive data such as biometrics/location, per notification commitments stated in the policy). 8. Intellectual property 8.1. All content, software, source code, interfaces, designs, trademarks, logos, materials, etc. belong to us or our licensors and are protected under intellectual property law. 8.2. You may only use them to the extent necessary to access the Service; any copying, modification, distribution, or commercial exploitation without written consent is strictly prohibited. 9. Third-party services/links The Service may contain links/APIs/integrations from third parties. Your use constitutes a direct relationship between you and the third party; We are not responsible for third-party content/policies/operations, unless otherwise required by law. 10. Disclaimer & limitation of liability 10.1. The Service is provided "as is" and "as available." We do not guarantee that the Service will always be uninterrupted or completely error-free. 10.2. To the extent permitted by law, We are not liable for indirect damages, lost profits, or data loss caused by: device errors, internet issues, malware, third-party actions, or your failure to secure your account. 10.3. Nothing in the Service shall be construed as a guarantee of specific results, profits, or investment performance. 11. Service suspension and termination We reserve the right to suspend/terminate the Service or restrict accounts when: (i) you violate the Terms; (ii) required by law/government authority; (iii) suspected fraud/AML concerns; (iv) security risks; (v) you fail to cooperate in providing required information. 12. Amendment of terms We may update these Terms from time to time. Changes take effect when published/notified on the platform. Your continued use after updates constitutes acceptance of the amended terms. 13. Governing law & dispute resolution These Terms are governed by Vietnamese law. Disputes arising shall be resolved primarily through negotiation/mediation; if unsuccessful, the parties may bring the matter to the competent authority as prescribed (or arbitration if agreed/applicable under specific product terms). 14. Contact information If you have questions or wish to exercise your personal data rights, please contact: • Email: legal@finalpha.ai • Hotline: 0967915569