Finquest Exchange — https://exchange.finquestexchange.com · Version 1.0 · Effective Date: 1 April 2026

1. Introduction and acceptance

Welcome to Finquest Exchange, a digital asset trading platform operated by PowrAI Digital Exchange sp. z o.o. ("PowrAI", "we", "us", "our"), a company incorporated under Polish law (KRS: 0001141746, NIP: 5214096566), registered as a Virtual Asset Service Provider under licence RDWW-1725 issued by the Dyrektor Izby Administracji Skarbowej w Katowicach.

PowrAI Digital Exchange sp. z o.o. operates within the Finquest ecosystem as an independent legal entity, majority co-owned by Finquest Capital Group Ltd (CRO 726903, Ireland). The exchange constitutes one pillar of the broader Finquest ecosystem alongside tokenisation and wealth management services, each operated by separate legal entities.

By accessing or using Finquest Exchange (the "Platform") at https://exchange.finquestexchange.com, you ("User", "you") agree to be legally bound by these Terms of Service ("Terms"), our Privacy Policy, Cookie Policy, AML & KYC Policy, and Risk Disclosure Statement. If you do not agree, you must immediately cease using the Platform.

These Terms may be modified at any time. Continued use after modification constitutes acceptance. Material changes will be notified via email or prominent notice at least 7 days in advance.

2. Regulatory status and licensing

PowrAI Digital Exchange sp. z o.o. holds the following regulatory authorisations:

Regulatory authorisation does not guarantee profits or protection against losses, nor does it imply endorsement of any digital asset by any authority.

3. Eligibility and restricted persons

3.1 General eligibility

To use the Platform you must: be at least 18 years of age; have full legal capacity in your jurisdiction; not be a Restricted Person; successfully complete KYC/AML verification; and not act on behalf of a third party without prior written consent.

3.2 Restricted jurisdictions and persons

The following are strictly prohibited from accessing the Platform:

• Persons located in, resident in, or incorporated in the United States of America or its territories;
• Persons in jurisdictions subject to comprehensive EU, UN, OFAC or equivalent sanctions (including Iran, North Korea, Cuba, Syria, Russia/sanctioned entities, Belarus, Myanmar, Venezuela);
• Politically Exposed Persons (PEPs) or close associates, unless approved via Enhanced Due Diligence;
• Persons on any applicable sanctions list;
• Persons whose access to digital asset services is prohibited under their local law.

Use of VPNs or other circumvention tools is strictly prohibited and constitutes a material breach of these Terms, which may result in account termination and reporting to authorities. See also our Prohibited Countries & Restricted Users page.

4. Account registration and KYC verification

4.1 Account creation

You must register an account and provide accurate, complete, and current information. You are responsible for all activity under your account and the confidentiality of your credentials.

4.2 Identity verification (KYC)

All users must complete KYC via Sumsub (our third-party identity verification provider) before accessing trading features. Requirements include:

• Government-issued photo ID (passport, national identity card, or driver's licence);
• Proof of address dated within 3 months;
• Selfie and live liveness verification;
• Source of funds documentation above applicable thresholds;
• Enhanced Due Diligence (EDD) for PEPs, high-risk profiles, and large-volume users.

4.3 Account security

You are responsible for enabling Two-Factor Authentication (2FA). PowrAI will never request your password or 2FA codes. Report suspected unauthorised access to compliance@finquestexchange.com immediately.

5. Platform services

5.1 Spot trading

The Platform currently offers spot trading of digital assets. No leverage, margin, or derivative products are offered at this time.

5.2 Fiat on-ramp and off-ramp

Fiat deposit and withdrawal services are provided by Banxa Holdings Inc. ("Banxa"), an independent licensed payment service provider. By using fiat services you also agree to Banxa's terms. PowrAI is not responsible for Banxa delays, errors, or failures.

5.3 Wallet and custody

Digital assets are held in institutional-grade custody via Fireblocks. No digital asset storage is entirely risk-free. You are solely responsible for assets withdrawn to external wallets.

5.4 Service availability

The Platform operates 24/7 subject to maintenance. PowrAI does not guarantee uninterrupted availability.

6. Fees and charges

Fees are set out in the Fee Schedule in your account settings. These may include trading fees (maker/taker), withdrawal fees, Banxa fiat conversion fees, and inactivity fees. Fee changes will be communicated at least 7 days in advance.

7. Risk disclosure

IMPORTANT: Digital asset trading carries significant risk. You may lose all invested capital. Risks include market volatility, liquidity risk, technology failures, regulatory changes, cybersecurity threats, and tax obligations. Trading is not suitable for all users. Seek independent advice if in doubt. See our Risk Disclosure Statement.

8. AML and compliance

PowrAI operates an AML/CTF programme compliant with: the Polish AML Act; 5AMLD (Directive EU 2018/843); the Transfer of Funds Regulation (EU 2023/1113); and FATF VASP Recommendations. Suspicious accounts may be frozen and reported to competent authorities without prior notice.

9. Prohibited activities

You may not use the Platform for: money laundering or terrorist financing; market manipulation or wash trading; providing financial services to third parties; sanctions violations; accessing from a Restricted Jurisdiction via VPN; unauthorised system access; or any other illegal purpose.

10. Intellectual property

All Platform content is owned by PowrAI or its licensors. You may not reproduce or distribute any content without prior written consent.

11. Privacy and data protection

PowrAI processes personal data in accordance with its Privacy Policy and applicable GDPR obligations. Data is shared with Sumsub, Banxa, Fireblocks, and regulatory authorities as required.

12. Limitation of liability

PowrAI's total aggregate liability shall not exceed fees paid by you in the preceding 3 months. PowrAI is not liable for indirect losses, market movements, third-party failures, or force majeure events. Nothing excludes liability for fraud or wilful misconduct.

13. Account suspension and termination

PowrAI may suspend or terminate your account for: breach of these Terms; KYC/AML non-compliance; suspected prohibited activity; regulatory authority request; or extended inactivity. Withdrawal of remaining balances is subject to compliance holds.

14. Complaints and governing law

Complaints: complaints@finquestexchange.com. We acknowledge within 5 business days and respond within 30 business days.

These Terms are governed by Polish law. Disputes are subject to the exclusive jurisdiction of the competent courts of Poland, without prejudice to mandatory consumer protection rights under local law.

15. General provisions

• Entire Agreement: These Terms together with our Privacy Policy, Cookie Policy, AML & KYC Policy, and Risk Disclosure Statement constitute the entire agreement.
• Severability: Invalid provisions do not affect the remainder.
• Assignment: You may not assign rights without prior written consent. PowrAI may assign without restriction.
• Language: English version prevails over any translation.

16. Contact information