KYC/AML Addendum

Last updated: February 10, 2026

This KYC/AML Addendum ("KYC Addendum") applies only to the extent Customer enables, accesses, purchases, or uses any identity verification, KYC/AML, sanctions screening, PEP screening, document verification, or related services offered by H33 ("KYC Services"). Capitalized terms not defined here have the meanings in the Terms.

1. Scope; Third-Party Providers

1.1 KYC Services

KYC Services may include identity verification, document verification, sanctions screening, PEP screening, and credential issuance workflows.

1.2 Third-Party Providers

KYC Services may rely on third-party identity verification and screening providers ("KYC Providers"). KYC Providers are independent third parties; H33 does not control their datasets, methodologies, or decisions.

2. Roles; Compliance Responsibility

2.1 Customer is Responsible Party

Customer is solely responsible for determining whether it must comply with any KYC/AML, financial services, money transmission, MSB, broker-dealer, or similar regulatory obligations, and for implementing a compliance program appropriate to its business.

2.2 No Delegation of Legal Duty

Customer acknowledges KYC Services are a tool and do not transfer Customer's legal obligations to H33.

2.2(a) Regulated Activity Determination. Customer is solely responsible for determining whether its use case constitutes a regulated financial activity (including money transmission, MSB activity, or other regulated services). H33 does not operate Customer's financial workflows and does not assume Customer's compliance obligations.

2.3 No Legal/Regulatory Advice

H33 does not provide legal, compliance, financial, or regulatory advice.

3. Customer Obligations

Customer will:

• provide required end user notices and obtain required consents for collection and verification;
• submit only data Customer is authorized to process;
• ensure accuracy of information provided;
• maintain policies and procedures for handling false positives/negatives, escalations, and adverse action where applicable; and
• comply with sanctions, export controls, and all applicable laws.

4. Results; No Guarantee

4.1 Probabilistic/Database Limits

KYC Services may return results based on third-party data sources, heuristics, or matching. Results may be incomplete, outdated, or inaccurate.

4.2 No Guarantee

H33 does not guarantee that KYC Services will identify every risk, fraud attempt, sanctioned party, or high-risk user, or that results will satisfy any regulator, auditor, bank, or counterparty.

4.3 Customer Decisioning

Customer is solely responsible for its decisioning and actions taken based on KYC results.

5. Fees; Billing; No Refunds

5.1 Pricing

KYC Services are priced separately at the rates shown in Documentation, pricing pages, or the applicable Order Form.

5.2 Non-Refundable

KYC transaction fees are non-refundable, including where a verification is inconclusive, requires re-check, is rejected due to poor input quality, or returns an adverse result, except where required by law or due to a verified platform error (credit adjustment only).

6. Data Handling; Retention

6.1 Data Submitted

Customer is responsible for the data submitted for KYC Services. H33 may transmit necessary data to KYC Providers to perform the KYC Services.

6.2 Retention

Retention of KYC requests/results will follow the Terms, Documentation, and any applicable DPA/Privacy Policy, subject to legal holds and provider constraints.

7. Prohibited Uses

Customer may not use KYC Services:

• for unlawful discrimination, employment screening, housing decisions, or credit eligibility determinations unless expressly permitted and compliant with law;
• to violate privacy rights;
• to facilitate sanctions evasion or money laundering; or
• in any manner prohibited by the Terms or applicable law.

8. Indemnity (KYC-Specific)

Customer will defend and indemnify H33 from claims arising from:

• Customer's failure to provide required notices/consents;
• Customer's decisioning or adverse actions;
• Customer's noncompliance with AML/KYC laws; or
• Customer's misuse of KYC results.

9. Disclaimers

10. No Expansion of Liability

This KYC Addendum does not expand H33's liability or Customer remedies beyond the Terms, and the Terms' limitations of liability apply.