GENERAL TERMS OF USE

WEB INTERFACES

1 April 2026

1. BASICS

These General Terms of Use of Web Interfaces (“General Terms”) aim to present the basic rights and obligations between you as a visitor/user of the NAKA Web Interface (“User”, “you”, “your”) and the NAKA Entity managing and operating this Web Interface (“NAKA”, “us”, “our”). The NAKA Entity managing and operating this NAKA Web Interface is evident from the table below:

NAKA Web Interface

Operating NAKA Entity

Contact Email

www.naka.com

NAKA GLOBAL

support@naka.com 

www.ch.naka.com

NAKA CH

www.sv.naka.com

NAKA SLV

manager-ch.naka.com

NAKA CH

manager-sv.naka.com

NAKA SLV

pay.naka.com (Switzerland)

NAKA CH

pay.naka.com (El Salvador)

NAKA SLV

These General Terms refer solely to the use of the NAKA Web Interfaces. Provision of the NAKA Services (e.g., obtaining a NAKA card, participating in NAKA Card Payment Network as a Merchant, etc.) is governed by separate general terms of use for a specific NAKA Service, together with other legal documents, relating to that particular NAKA Service (in particular, the Personal Data Protection Notice: Web Interfaces). 

1.1 Your Agreement to these General Terms  

From the moment you start using the NAKA Web Interface independently, it is considered that you accept the content of these General Terms. These General Terms apply exclusively to the use of the NAKA Web Interface, to which the General Terms are linked, and do not regulate any other legal relations between you and us or between you and the NAKA Partners or third parties respectively.

These General Terms are binding for any visitor of the NAKA Web Interfaces. Getting acquainted with the General Terms is important for you in order not to use the NAKA Web Interface for any unlawful, illegal, unethical, or inconsistent purpose (whether intentionally or unintentionally).

If you do not fully understand a provision of these General Terms, we recommend you consult us before starting to use the NAKA Web Interfaces. We will be very happy to answer all your questions and clarify any possible ambiguities. We are available at the e-mail address stated above.

1.2 Changes to the General Terms

We will update these General Terms when necessary. For example, we might change it if applicable laws change, if a local authority in charge of monitoring web interfaces adopts a new decision, opinion, stance, or when other relevant circumstances change. In such cases, we reserve the right to change the provisions of these General Terms without prior notification. Each version of these General Terms will have the date of their effect stated at the top of the General Terms, so that you may track the currently applicable version of these General Terms by checking this date. We also recommend that you save a copy of the General Terms for future reference and comparison.

If you find the provisions of the changed General Terms unsuitable for you, we recommend that you cease to use the Web Interface from that point onwards. We recommend you check these General Terms and the Personal Data Protection Notice each time before using our Web Interfaces or review it periodically to stay informed of our current terms of use of the NAKA Web Interfaces. 

1.3 Applicable Terms and Definitions

Terms and capitalized words not defined in the main text have the following meanings:

Term

Definition / Meaning

Agent(s)

means shareholders, directors, officers, Associates, contractors, partners, insurers, and attorneys of the NAKA Entities.

Associate(s)

means any persons performing work for the NAKA Entities based on an independent contractor agreement.

ICT 

means information and communication technology.

NAKA Payment Network

means a Blockchain-based payment network compatible with EMV and PCI DSS standards, used to facilitate transactions and settlements between the Cardholders and the Merchants, who are associated with this Network, through the utilization of the Smart Contracts.

NAKA Entity(ies)

means any, several or all (as the context may require) of the following companies:

1. NAKA GLOBAL d.o.o. (NAKA GLOBAL Ltd.), incorporated under the laws of the Republic of Slovenia, with its corporate seat at Letališka c. 33F, 1000 Ljubljana, Republic of Slovenia, reg. no. 8106452000 (“NAKA GLOBAL”);

2. NAKA CH Sagl, incorporated under the laws of Switzerland, with its corporate seat at Crocicchio di Cortogna 6, 6900 Lugano, Switzerland, reg. no. CHE-327.549.674 (“NAKA CH”);

3. NAKA SLV, S.A. de C.V., incorporated under the laws of El Salvador, with its corporate seat at Calle Cuscatlan, Casa 4312, Colonia Escalon, the municipality of San Salvador, El Salvador, reg. no. 2023108736 (“NAKA SLV”);

4. NAKA EUROPE d.o.o. (NAKA EUROPE Ltd.), incorporated under the laws of the Republic of Slovenia, with its corporate seat at Letališka c. 33F, 1000 Ljubljana, Republic of Slovenia, reg. no. 9244557000 (“NAKA EUROPE”).

NAKA Group

means a group of legal entities, which are subsidiaries and/or the Affiliates of the parent company, NAKA GLOBAL, either directly or indirectly, including all NAKA Entities.

NAKA Mobile App(lication)(s)

means a software program developed, owned, and operated by one or more of the NAKA Entities, designed to be downloaded and installed by a User on a device (e.g., a smartphone or tablet) running a compatible operating system (e.g., iOS or Android). This includes all versions, updates, and integrated features of the published NAKA Mobile App.

NAKA Partner(s)

means any individual or a legal entity with whom the NAKA Entities concluded a service or other type of contract, such as ICT services and cloud service providers, AML/CTF checks service providers, CRM software providers, card processing service providers, etc.

NAKA Service(s)

means any of the products and services offered by any of the NAKA Entities, including the NAKA Mobile Apps and issuing of the Cards.

NAKA Web Interface(s)

refers to any browser-based graphical user interface, through which the Users access the NAKA Websites and/or interact with the NAKA Services and or the NAKA Entities (i.e., all content, functionalities, and digital tools hosted on the domains owned or operated by the NAKA Entities, public-facing pages, informational content, and digital touchpoints accessible via a web browser, including contact forms and other email correspondence for the purpose of direct marketing). 

NAKA Website(s)

means all websites, microsites and web pages owned, operated, or controlled by the NAKA Entities, regardless of the specific domain or subdomain name used to access them, including the NAKA Primary Websites.

Personal Data

means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more other factors.

User(s)

means any individual user of any of the Web Interface(s).

2. PROVISION OF SERVICES

Please note that the services described or presented on the NAKA Websites are not necessarily provided by the NAKA Entity, which operates that NAKA Website directly. Some of the services may be provided through the NAKA Group’s affiliated companies, a NAKA Partner, or other third parties. Specifically, payment services are provided by the NAKA Partners, while the Crypto-Asset related services are provided by the NAKA Entities, which are regulated under the laws of their incorporation, the NAKA Partners or other third parties.

Your use of the NAKA Services is governed by separate agreements between you and the specific service provider for each of the NAKA Services. For more information, please review the agreement, governing the provision of the particular NAKA Service you are using, or contact us at the email address stated in section 1. BASICS

3. COPYRIGHT AND OTHER INTELLECTUAL PROPERTY RIGHTS

The NAKA Web Interface is the intellectual property of NAKA (or a NAKA Partner from which NAKA obtained a license) and as such subject to copyright or other forms of intellectual property protection. In addition to the text and data on the NAKA Web Interface, the entire visual identity with all the visual elements is also considered legally protected property. NAKA (or the NAKA Partner, as applicable) is the copyright holder in connection with this NAKA Web Interface. As the User, you are granted a personal, temporary, non-exclusive, and non-transferable right to (i) a private or (ii) a commercial use of the NAKA Web Interface in accordance with these General Terms. 

Private use entails the use of the NAKA Web Interface for non-commercial purposes, e.g., getting informed on the services and offers provided by the NAKA Group and the NAKA Partners. Commercial use allows the use of the documents on the NAKA Web Interface (including copying, transcribing, reproduction, modification, or any kind of dissemination of the information), but only for internal use within your business, in which the documents must preserve all the notices regarding copyrights or other rights that are stated therein. Any attempt to tamper with, damage or cause permanent or temporary unavailability of the data on the NAKA Web Interface is punishable.

The trademarks and service marks published on the NAKA Web Interfaces are (i) our registered trademarks or (ii) we possess (exclusive) rights to their use, unless where explicitly indicated otherwise. In certain cases, trademarks and service marks on the NAKA Web Interface are shown for demonstrative purposes solely (to indicate type of services and similar).

You are strictly forbidden from using any of the NAKA’s brands (including trademarks and other brand names relating to the NAKA Services) for purposes other than allowed under these General Terms before obtaining a prior written authorization by NAKA. Even if you have obtained a prior written authorization by NAKA for any type of use, you are required to include a proprietary notice (e.g., copyright notice) and other referrals to NAKA or other rightful proprietor of the brand or a part thereof. In this case as well, you are granted a personal, temporary, non-exclusive, and non-transferable right to use. Any unauthorized or unreferred use shall be interpreted as a violation of intellectual property or other laws.

If you link any of the materials from the NAKA Web Interface or a part thereof onto your own web interface, you are required to include a notice that such link does not constitute an endorsement of your content by NAKA. In any case we reserve (i) the right to revoke any such license in cases we deem reasonable (for instance when the content of your web interface is not aligned with our values) under the conditions included in our notification on revoking the license and (ii) other rights granted under the applicable law.

THIRD-PARTY MATERIALS: The NAKA Web Interfaces may contain links to third-party websites or other types of intellectual property rights (e.g., trademarks, logos, brand names, designs), including advertisement links (“Materials”). All such Materials are provided solely for your convenience or easier reference and do not represent an endorsement by NAKA of the content contained in or provided at such third-party websites. All Materials are the property of their respective owners and NAKA, as a rule, does not exercise any kind of control over such third-party Materials. Therefore, you are accessing the third-party Materials at your own risk and liability. It is recommended to read and understand terms and conditions provided by the respective third parties.

All third-party Materials on the NAKA Web Interfaces are shown for indicative and/or demonstrative purposes only. The third-party Materials are used to indicate the type of companies, products or services, as applicable. All third-party Materials (including without limitation all trademarks, logos and brand names) are the property of their respective owners. In no way does the display of the third-party Materials constitute reference to actual companies, products or services or endorsement of any kind by such third parties, unless otherwise explicitly indicated otherwise. 

4. USE OF TECHNOLOGY AND SECURITY OF SERVICES

The technologies used to deliver the NAKA Services, including but not limited to payment infrastructure and digital platforms, are licensed from other NAKA Group companies, including the parent company, NAKA GLOBAL, or third-party providers. All of such technology partners retain ownership of the underlying systems and are responsible for maintaining the security, reliability, and compliance of their solutions.

NAKA is committed to providing secure, dependable, and uninterrupted services through a robust and reliable framework. We place a strong emphasis on the security of all information technology solutions used to deliver the NAKA Services. Therefore, NAKA requires all its contractual partners—whether they are outsourcing parties or direct service providers to NAKA's customers—to adhere to the highest security standards applicable in their respective industries, including the FinTech industry.

For example, NAKA GLOBAL implements extensive information security controls and measures. These comply with international standards: ISO 9001:2015 (Quality Management Systems), ISO 27001:2022 (Information Security Management Systems), and ISO 22301:2019 (Business Continuity Management Systems), for which NAKA GLOBAL holds official certifications from the respective issuing authorities.

5. LIMITATION OF LIABILITY

Our fundamental principle is to try to the best of our ability and with due diligence to make the information on any NAKA Web Interface as accurate and current as possible. Nevertheless, please note that all the texts and information are for presentation purposes only.

The NAKA Web Interfaces are accessible continuously (24 hours a day, 365 days a year), except in case of events beyond our control or for technical reasons (e.g., website maintenance), when short periods of disrupted access or functioning of the NAKA Web Interfaces can occur. Notifications on planned longer interruptions will be published on the NAKA Web Interfaces or through other communication channels ahead of time.

Please note that you use the NAKA Web Interfaces at your own risk. Neither we nor any other legal or natural person who has participated in the creation of the NAKA Web Interface is responsible for the damages and/or loss of profit that could be incurred:

(a) Due to using inaccurate or incomplete information;

(b) Because of an event beyond our control or an event that cannot be avoided, stopped or averted;

(c) Due to occasional non-functioning of the NAKA Web Interface;

(d) Due to the data acquired through online links that are published on the NAKA Web Interfaces, but are not our property.

We recommend you ensure suitable software protection measures for uninterrupted and safe data access (e.g., protection against hacking, viruses and other malware). 

6. VIOLATION OF GENERAL TERMS

It is in our interest to provide you with as pleasant user experience as possible, as well as with ample useful information on any of the NAKA Web Interfaces, which can, among other things, be achieved by using the NAKA Web Interface in accordance with these General Terms. However, in the event of a violation of these General Terms and/or unauthorized use of the NAKA Web Interface, we reserve the right to act in a manner considered appropriate, e.g., by reporting the suspected illegal actions to the competent law enforcement authorities, control authorities or other authorized entities. If so required by the applicable legislation, we will disclose to the aforementioned authorities all the necessary information, including your Personal Data, e.g., names, e-mail addresses, IP addresses, search history, etc., in accordance with the Personal Data Protection Notice: WEB INTERFACES.

7. APPLICABLE LEGISLATION

For any questions regarding the implementation and interpretation of these General Terms, the law of the jurisdiction in which the NAKA Entity, managing and operating the NAKA Web Interface in question, is incorporated (as regulated in these General Terms), applies to the highest extent allowed under the mandatory conflict of laws rules. 

Any disputes arising from the violation of these General Terms will be settled by NAKA in an amicable manner. If that is not possible, the competent court is the court with subject matter jurisdiction, unless specifically required otherwise under the mandatory rules.

8. CONTACT

If you have any questions or comments in connection with these General Terms, we are available at support@naka.com.

NAKA Team