TELEGIRO, INC. USER AGREEMENT

Updated as of February 2026

LICENSED MONEY TRANSMITTER NOTICE

Florida License #FT230000431 – Regulated by the Florida Office of Financial Regulation

New Jersey License #2305779 – Regulated by the New Jersey Department of Banking and Insurance

Services are currently available only to residents of Florida and New Jersey.

CONSUMER FRAUD ALERT

Be careful when a stranger asks you to send money. Notify us immediately if you believe your password has been lost or stolen or if someone may be using your account without your permission.

1. THIS IS YOUR CONTRACT WITH US

This User Agreement governs the terms and conditions under which you may access and use:

• TeleGiro’s website (www.telegiro.com) and mobile applications (the “Site”)
  
• TeleGiro digital wallet and payment services (the “Digital Wallet Services”)
  
• TeleGiro international money transfer services (the “Remittance Services”)
  

All services are collectively referred to as the “Services.”

This agreement is between TeleGiro, Inc. (“TeleGiro,” “we,” “us,” or “our”) and the user (“you” or “your”).

By accessing or using the Services, you agree to this User Agreement. If you do not agree, you must not use the Services.

2. DEFINITIONS

Account

Your TeleGiro account, including digital wallet and remittance capabilities.

FBO Account

A For-Benefit-Of account held at a partner financial institution for your benefit.

Digital Wallet Services

Digital wallet functionality, including account management, domestic payments, and related payment services provided through program partners.

Remittance Services

International money transfer services.

Recipient

A person who receives money through the Remittance Services.

Sender

A person who sends money through the Remittance Services.

Transaction

Any payment instruction processed through the Services.

Transfer Amount

The amount of money sent to a recipient, excluding fees.

Transfer Fee

The fee charged to process a transaction.

3. OVERVIEW OF SERVICES

a. Digital Wallet Services

We provide digital wallet functionality through program partners and regulated financial institutions. These services may allow you to:

• Maintain funds in an FBO account
  
• Send and receive domestic payments
  
• Link external bank accounts for funding and verification
  
• Manage transactions through our platform
  

Digital Wallet Services are provided in coordination with program partners and financial institutions.

b. Remittance Services

TeleGiro is a licensed money transmitter and registered Money Services Business (MSB). We provide international money transfer services under applicable licenses.

c. Our Role

TeleGiro provides money transmission and payment services in accordance with applicable licenses and registrations. We work with program partners, payment service providers, and financial institutions to facilitate transactions.

TeleGiro is not a bank.

d. Accessing the Services

You may access the Services:

• Through our website
  
• Through our mobile applications
  
• Through supported partner networks
  

Your wireless carrier may charge additional fees for data or SMS usage.

e. Personal Use Only

Services are intended for personal, non-commercial use unless explicitly authorized.

We may suspend or close accounts used for unauthorized commercial activity.

4. ELIGIBILITY AND REGISTRATION

a. Eligibility

You must:

• Be at least 18 years old
  
• Be a resident of Florida or New Jersey

• Present a valid and current passport from an unsanctioned country
  
• Have legal capacity to enter contracts
  

By opening an account, you represent that you meet these requirements.

b. Registration

To use the Services, you must create an account and provide accurate and complete information.

c. Information Required

You may be required to provide:

• Full legal name
  
• Address
  
• Email and phone number
  
• Government-issued ID
  
• Date of birth
  
• Social Security Number or other identifying information when required
  

We may request additional information to comply with legal or regulatory requirements.

d. Account Security

You are responsible for:

• Maintaining password confidentiality
  
• All activity under your account
  

Notify us immediately if your account is compromised.

5. DIGITAL WALLET SERVICES

a. Account Features

Your digital wallet may include:

• Funds held in an FBO account
  
• Domestic payment capabilities
  
• Transaction history
  
• Additional features through program partners
  

Features may vary by account and location.

b. Payment Authorization

By using the Services, you authorize TeleGiro and its partners to:

• Hold, receive, and transfer funds
  
• Process electronic payments
  
• Correct errors when necessary
  

This authorization remains in effect until revoked.

6. TRANSACTIONS

We may:

• Review transactions for compliance and fraud prevention
  
• Delay or decline transactions when required
  

We may impose transaction limits at our discretion.

TeleGiro accounts are intended primarily for payment and remittance transactions and are not designed for long-term storage of funds.

7. REMITTANCE SERVICES

a. Initiating Transfers

To send money internationally, you must provide:

• Transfer amount
  
• Destination country
  
• Recipient details
  
• Payment method
  

b. Exchange Rates

If currency conversion is required:

• A retail exchange rate will apply
  
• The rate is disclosed before you confirm the transaction
  
• The rate is locked once confirmed
  

c. Delivery Timing

Delivery times depend on:

• Destination country
  
• Delivery method
  
• Partner processing times
  
• Compliance reviews
  

Many transfers are completed the same day.

TeleGiro works with licensed payout partners and regulated financial institutions to deliver funds to recipients in destination countries.

d. Receipts

You will receive a receipt showing:

• Transfer amount
  
• Fees
  
• Exchange rate (if applicable)
  
• Recipient details
  
• Transaction date
  

Keep your receipt for your records.

8. FEES AND PRICING

All fees will be disclosed before you authorize a transaction.

You may cancel any transaction before authorization without charge.

Fees may vary based on:

• Transfer type
  
• Destination
  
• Payment method
  
• Delivery option
  

Additional third-party fees may apply.

9. PROHIBITED ACTIVITIES

You may not use the Services for:

• Illegal activities
  
• Fraud or money laundering
  
• Sanctioned transactions
  
• Unauthorized commercial use
  
• Prohibited goods or services
  

We may suspend or close accounts for violations.

10. ACCOUNT MANAGEMENT AND FUNDS

a. Protection of Funds

We maintain:

• Surety bonds
  
• Permissible investments
  
• Segregated customer funds
  

As required by state law.

b. Set-Off Rights

We may deduct amounts owed to us from your account, where permitted by law.

c. Dormant Accounts

If your account is inactive for an extended period, we may close it and handle funds in accordance with applicable unclaimed property laws.

11. CANCELLATION AND REFUNDS

You may cancel a transaction and receive a full refund if:

• Funds have not been delivered to the recipient
  

Contact customer support immediately to cancel.

Refunds are typically processed within ten business days.

12. PRIVACY AND SECURITY

Your information is handled according to our Privacy Policy.

We may share information with:

• Financial institutions
  
• Payment networks
  
• Compliance and fraud-prevention providers
  

We use industry-standard security measures to protect your data.

13. ERROR RESOLUTION AND COMPLAINTS

If you believe a transaction contains an error, contact us within 180 days.

TeleGiro follows the error resolution procedures required by the Electronic Fund Transfer Act (Regulation E).

You may also contact:

Consumer Financial Protection Bureau

Phone: 855-411-2372

Website: www.consumerfinance.gov

State regulator contact details are provided in the state-specific disclosures below.

14. LIMITATION OF LIABILITY

To the maximum extent permitted by law:

• We are not liable for indirect or consequential damages
  
• Our liability is limited to fees paid in the preceding 12 months
  

We are not responsible for failures caused by events outside our control.

15. DISCLAIMER OF WARRANTIES

Services are provided “as is” and “as available.”

We do not guarantee:

• Continuous availability
  
• Error-free operation
  
• Suitability for a particular purpose
  

16. TERMINATION

We may suspend or close your account if:

• You violate this agreement
  
• We detect fraud or risk
  
• Required by law
  

Upon termination:

• Pending transactions may be canceled
  
• Remaining funds will be returned according to applicable rules
  

17. ELECTRONIC COMMUNICATIONS

You agree to receive all disclosures electronically, including:

• Email
  
• Website postings
  
• In-app notifications
  

Electronic acceptance has the same legal effect as a written signature.

18. DISPUTE RESOLUTION

Disputes will be resolved by binding arbitration under the Federal Arbitration Act, unless otherwise required by law.

You waive the right to a jury trial.

19. GOVERNING LAW

This agreement is governed by the laws of:

• The United States
  
• The State of Delaware
  

20. MODIFICATIONS

We may modify this agreement from time to time.

Where required by law, we will provide advance notice of material changes.

Continued use of the Services after changes take effect constitutes acceptance.

21. CONTACT INFORMATION

TeleGiro, Inc.

5201 Waterford District Drive, 9th Floor

Miami, Florida 33126

Phone: (323) 546-9392

Email: info@telegiro.com

Hours: Monday–Friday, 9 a.m.–6 p.m. ET

Languages: English and Spanish

22. STATE-SPECIFIC DISCLOSURES

Florida Residents

TeleGiro is licensed by the Florida Office of Financial Regulation (License #FT230000431).

If you have a complaint, contact:

Florida Office of Financial Regulation

200 East Gaines Street

Tallahassee, FL 32399

Phone: (850) 487-9687

New Jersey Residents

TeleGiro is licensed by the New Jersey Department of Banking and Insurance (License #2305779).

If you have a complaint, contact:

New Jersey Department of Banking and Insurance

20 West State Street

Trenton, NJ 08625

Phone: (609) 292-7272

23. REGULATORY COMPLIANCE NOTICES

a. AML / BSA Compliance Notice

TeleGiro, Inc. is registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business (FinCEN Registration No. 31000298380846) and is licensed as a Money Transmitter in Florida (License No. FT230000431) and New Jersey (License No. 2305779). We are subject to the Bank Secrecy Act (BSA), 31 U.S.C. Section 5311 et seq., and its implementing regulations. By opening an account and using our Services, you acknowledge and consent to the following:

• Transaction Monitoring. We monitor all transactions for compliance with applicable anti-money laundering (AML) and countering the financing of terrorism (CFT) laws. Automated and manual procedures are applied on an ongoing basis.
• Suspicious Activity Reporting. We are required by federal law to file Suspicious Activity Reports (SARs) with FinCEN when we detect activity we reasonably suspect involves money laundering, fraud, or financial crime. We are prohibited by law from disclosing to you that a SAR has been or may be filed.
• Currency Transaction Reporting. We are required to file Currency Transaction Reports (CTRs) with FinCEN for any cash transaction or series of related transactions exceeding $10,000 in a single business day.
• Record Retention. We retain transaction records and customer identification information for a minimum of five (5) years from the date of the transaction or account closure, as required by 31 C.F.R. Section 1022.410.
• Cooperation with Law Enforcement. We may be required to provide information about your account and transactions to law enforcement pursuant to lawful process. We may be legally prohibited from notifying you of such disclosure.

b. OFAC Screening Notice

TeleGiro complies with regulations administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), including the Specially Designated Nationals and Blocked Persons List (SDN List) and all applicable sanctions programs.

• Screening at Onboarding. Prior to establishing any customer relationship, we screen your name, date of birth, and address against the OFAC SDN List and other applicable sanctions lists.
• Ongoing Screening. Your account and transactions are subject to continuous and automated sanctions screening throughout our relationship.
• Blocking and Rejection. If you or any party associated with a transaction appears on the SDN List or any blocked-party list, we are legally required to block the transaction, freeze associated funds, and report the matter to OFAC. We may not provide the specific reason for such action where disclosure is prohibited by law.
• Prohibited Jurisdictions. You represent and warrant that you are not located in, or acting on behalf of any person in, a country or territory subject to comprehensive OFAC sanctions (currently including Cuba, Iran, North Korea, Syria, and certain regions of Ukraine). Services may not be available for transactions to or from these jurisdictions.
• Record Retention. We retain records of all OFAC-related actions for a minimum of ten (10) years, as required by OFAC regulations.

c. Identity Verification / KYC Consent

Federal law, including the USA PATRIOT Act (31 U.S.C. Section 5318(l)) and FinCEN’s Customer Identification Program rules (31 C.F.R. Section 1022.210), requires us to establish and maintain a Customer Identification Program (CIP). By creating an account, you expressly consent to the following:

• Information Collection. We will collect, at minimum: your full legal name, date of birth, current residential address, and a government-issued identification number (e.g., passport, driver’s license, consular ID, or Social Security/ITIN where required).
• Document Verification. We may require you to submit a government-issued photo ID. You consent to our retention of such documents for a minimum of five (5) years after account closure, as required by law.
• Biometric Verification. For mobile app users, our identity verification may include capture of a facial image (selfie) for liveness detection and document matching. Biometric data used solely for verification is not retained following completion of the verification session. You consent to this limited collection as a condition of account use.
• Third-Party Verification Services. We use IDM Global (via White Wings Technologies, Inc.) as our identity verification and KYC service provider. Your identity information will be transmitted to IDM Global for verification. You consent to this transmission.
• Verification Tiers. Our KYC program applies a tiered approach: basic verification at registration; enhanced document verification triggered when transaction activity exceeds applicable thresholds. Higher tiers unlock increased transaction limits.
• Consequences of Failure to Verify. If we cannot verify your identity, we may decline to open your account, suspend or limit your access, or refuse to process transactions.

IMPORTANT NOTICE: Federal law requires us to obtain, verify, and record information that identifies each person who opens an account. When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents. (31 C.F.R. Section 1022.210(a)(5)(i))

REGULATORY DISCLOSURE

TeleGiro, Inc. is a licensed money transmitter and not a bank.

Customer funds are held in For-Benefit-Of accounts at regulated partner financial institutions.

Florida License #FT230000431

New Jersey License #2305779

FinCEN MSB Registration