March 18, 2026

TERMS OF USE

General Terms

This ROECNY Terms of Use Agreement ("Agreement") governs any access to, interaction with, or use of the websites, pages associated with each website, and all devices, mobile applications, and technology platforms (collectively, the "Sites") offered, operated, or made available by ROECNY GROUP LLC, its subsidiaries, and affiliates ("ROECNY," "we," or "us"), together with ROECNY's banking and other services (collectively, the "Services").

If the Services you use involve the collection, analysis, and processing of your data, including financial data, this Agreement governs your consent for ROECNY to collect and use that data. Other aspects of the Services may be covered by other terms, conditions, and agreements with ROECNY, including agreements with ROECNY's financial institution partners ("Bank"), such as deposit account agreements. By accepting electronically, installing, accessing, or using the Services, you agree to be bound by this Agreement and ROECNY's Privacy and Security Policy, as each may be amended from time to time. If you do not agree to this Agreement, you may not use the Services.

1. Accepting the Terms

By using the information, tools, features, software, functionality, content, updates, and new releases provided by ROECNY, you agree to be bound by this Agreement whether you are a "Visitor" browsing the ROECNY website, an "Applicant" who has started an application to open an Account, or a "Customer" with an open and active Account. "Account" means a demand deposit account held by a Bank and accessed through the Services.

The terms "you," "You," and "User" refer to all people and entities interacting with the Services, including Visitors, Applicants, and Customers. You may not use the ROECNY Services or accept this Agreement unless you are at least 18 years old and otherwise capable of forming a binding contract. If you accept this Agreement on behalf of a company or other entity, you represent that you have authority to bind that entity. You should print or save a local copy of this Agreement for your records.

2. Privacy and Your Personal Information

You can review the Privacy Policy on the Sites. You agree to the applicable Privacy Policy and any updates published by ROECNY. You agree that ROECNY may use and maintain your data according to the Privacy Policy as part of the Services, and you permit ROECNY to combine information you enter or upload with information from other users or other ROECNY services, including for non-identifiable aggregated analysis, service improvement, and promotions where permitted by law.

ROECNY may access or store personal information in multiple countries, including countries outside your own country, to the extent permitted by applicable law.

3. Electronic Communication

You agree to the applicable ROECNY E-Sign and Electronic Communications Agreement and any changes published by ROECNY.

4. Online Banking Services and Deposit Account

This section establishes the terms for Customers who register for an Account and whose Account is opened. Federal law requires the Bank to obtain sufficient information to verify the identity of an Applicant and, for legal entities, certain beneficial owners. Applicants may be asked questions and required to provide one or more forms of identification. ROECNY may use outside sources to confirm information and may provide application information to the Bank and third-party service providers for eligibility review, fraud prevention, and identity verification.

ROECNY may rely on the accuracy of the information supplied by Applicants and Customers and may deny applications, suspend Services, collect amounts due, or close an Account if information is incomplete, inaccurate, or outdated. Once approved, ROECNY may provide access to Account software, issue a debit card, and provide online banking services through the ROECNY website or mobile application.

Online banking services may include obtaining balances, transaction information and statements, transferring funds through ACH or wire transfers, and depositing checks by mobile check deposit. Accessing your Account with your username and password acts as your signature to authorize requested transactions through the online banking services. ROECNY may add, remove, or modify online banking features with prior notice.

Applicants must specify at least one Administrator to manage an Account. Administrators and any Secondary Admins designated by them may manage credentials, connected services, cards, transactions, reporting, and company information. The Customer is responsible for all actions taken through Administrator or Secondary Admin credentials and must keep usernames, passwords, PINs, and other security credentials confidential. Customers must notify ROECNY immediately of any breach of security or unauthorized use, and ROECNY may suspend access if an Account appears compromised.

Customers agree that the requested Services are for business or commercial purposes and not for personal, family, or household purposes. Customers agree to pay applicable charges, rates, balances, and fees, and authorize ROECNY to deduct accrued charges directly from the Account balance without prior notice where permitted.

ROECNY may impose and change transaction dollar or frequency limits for online banking services, including transfers, electronic payments, deposits, and other transactions. If a requested transaction exceeds applicable limits, ROECNY may process it but is not obligated to do so. ROECNY may also refuse, limit, or terminate services without prior notice if continued service would create unacceptable credit exposure or risk, or would cause ROECNY or the Bank to violate law, regulation, rule, or order.

If an Account profile includes multiple businesses or tax identification numbers, the Customer acknowledges that Administrators may be able to grant access across those businesses, and that such access controls are managed by Administrators rather than the Bank. Customers release ROECNY and the Bank from liability for executing transfers or payments in accordance with Customer instructions and agree to indemnify them for claims arising from Administrator or Secondary Admin actions.

Customers also agree to the applicable Mobile Check Deposit Agreement, ROECNY ACH Sender Agreement, ROECNY WIRE Agreement, the E-Sign and Electronic Communications Agreement, applicable personal or business account agreements, the ROECNY fee schedule, the Privacy and Security Policy, and any other agreements relevant to the Account, each as updated from time to time.

5. Beta Version

ROECNY's current technology platform may operate in beta. Users understand they may be testing, evaluating, and providing feedback on beta functionality. During any beta period, users receive a personal, non-exclusive, non-transferable license solely for internal evaluation and must keep confidential their participation and the information provided during beta testing.

Users may not disclose, sublicense, sell, assign, lease, loan, or otherwise transfer beta data to third parties. Users agree to test the beta version as requested, promptly report defects or anomalies, and assign to ROECNY any feedback, ideas, suggestions, modifications, or improvements related to the beta version. The beta version may contain errors, bugs, and other problems and is provided strictly on an as-is basis without warranties.

6. User Information from Third-Party Sites

Users may direct ROECNY to retrieve information maintained online by third parties with which they have customer relationships, accounts, or financial transactions ("User Information"). ROECNY may work with online service providers to access that User Information. ROECNY does not review User Information for accuracy, legality, or non-infringement and is not responsible for third-party products or services.

ROECNY cannot always foresee technical or other difficulties that may result in failed or delayed retrieval, data loss, or service interruption, and cannot guarantee real-time transmission of data. Subject to the Privacy Policy, you grant ROECNY and its service providers a license to use User Information to operate, administer, develop, improve, and provide the Services, including use of aggregated non-identifying data derived from your use of the Services.

7. Reports, Information and Materials

ROECNY may provide reports, analyses, summaries, evaluations, informational communications, and other content in connection with the Services ("Content"). Content made available through ROECNY platforms is protected by intellectual property rights and belongs to ROECNY, its licensors, partners, and other content providers. You may not copy, distribute, display, modify, or otherwise use Content except as made available through the Services.

All Content is provided for convenience on an as-is and as-available basis, without warranty of any kind. ROECNY and its service providers do not warrant the accuracy or completeness of the Content. ROECNY may also use verification services for identity and fraud-prevention purposes, and by providing information through those services you license that content to ROECNY and the service providers for those purposes.

8. ROECNY Offers and Third-Party Links

ROECNY may present information about third-party products or services ("ROECNY Offers"), along with general tips, recommendations, or educational materials. The Services may contain links to third-party information, websites, or offers. ROECNY does not endorse, warrant, or guarantee the accuracy of third-party information, products, or services, and is not responsible for the policies or actions of third-party sites or advertisers.

If you elect to use third-party products or services, your use is governed by the third party's own terms and privacy policy.

9. Your Use of the Services

Your right to access and use the Sites and Services is personal, non-exclusive, non-transferable, non-sublicensable, and fully revocable. Use of Services that involve special registration, restricted access, or payment is also subject to any additional terms specified by ROECNY. You may access and use the Sites and Services only for lawful purposes.

You must provide true, accurate, current, and complete information requested in connection with the Services, including any "add account" setup forms, and must keep registration and user information up to date. You represent that you are a legal owner of, and authorized to provide, all information necessary to facilitate your use of the Services.

You may not use the Services in any manner that impairs, overburdens, damages, disables, or otherwise compromises the Services, another party's use of the Services, or any third-party services or devices through which you access ROECNY Sites. Your access may be interrupted from time to time for maintenance, repair, updates, or other actions taken by ROECNY. Your sole and exclusive remedy for any failure or nonperformance of the Services is for ROECNY to use commercially reasonable efforts to adjust or repair the applicable service.

10. Use With Your Mobile Device

Use of the Services through a mobile device may require a compatible device, internet or network access, software, updates, and applicable fees. You are solely responsible for these requirements and for your agreements with your mobile device and telecommunications providers.

ROECNY makes no representations or warranties regarding the availability of telecommunications services, uninterrupted access to the Services, security intrusions involving telecommunications services, or any disclosure or transmission failure involving data, communications, or settings connected with the Services.

11. Online and Mobile Alerts

ROECNY may provide automatic alerts and voluntary account-related alerts. Voluntary alerts may be enabled by default, customized, deactivated, or reactivated by you. ROECNY may add or discontinue alerts at any time in its sole discretion.

Alerts may be delayed or prevented by a variety of factors. ROECNY will use commercially reasonable efforts to deliver alerts in a timely manner, but cannot guarantee delivery, timeliness, or accuracy. ROECNY is not liable for delayed delivery, failed delivery, misdirected delivery, content errors, or actions taken in reliance on an alert. Alerts may include information such as your login ID or account balances, and anyone with access to your email may be able to view that content.

12. Rights You Grant to Us

By submitting information, usernames, passwords, PINs, materials, and other content through the Services, you license that content to ROECNY for the purpose of providing the Services. You represent that you are entitled to submit that content without causing ROECNY to owe fees or become subject to additional restrictions or limitations.

When you use features that connect to third-party sites or accounts, you expressly authorize ROECNY to access your information maintained by those third parties on your behalf as your agent. You grant ROECNY a limited power of attorney and appoint ROECNY as your attorney-in-fact and agent, solely to access third-party sites, retrieve information, and use that information to provide the Services. You acknowledge that when ROECNY retrieves information from third-party sites, it acts as your agent and not as the agent of the third party that operates the site.

13. Telephone Calls: Monitoring and Recording

By providing a telephone number to ROECNY, you authorize ROECNY, the Bank, and service providers to contact you using automatic dialing systems, prerecorded voice, voicemail, messaging services, and text messages. Carrier charges may still apply.

You also consent to ROECNY monitoring and recording telephone conversations and other electronic communications for reasonable business purposes, including security and quality assurance, except where additional notice is required by law.

14. ROECNY's Intellectual Property Rights

The contents of the Services, including text, graphics, images, logos, icons, software, and other materials, are protected by copyright, trademark, and other laws, and belong to or are licensed to ROECNY or its suppliers. ROECNY grants you a limited right to view and use the Services subject to this Agreement. You may download or print a copy of service information only for your personal, internal, and non-commercial use.

Any distribution, reproduction, or electronic republication of Service content for another purpose is prohibited without prior written consent. You agree not to use the Sites, Services, or content in a way that violates any applicable law, regulation, or this Agreement.

15. Access and Interference

You agree that you will not use robots, spiders, scrapers, deep-link tools, or similar automated means to access, acquire, copy, or monitor the Services without ROECNY's express written consent.

You also agree not to use unapproved engines, software, tools, agents, or mechanisms to search or navigate the Services, not to post or transmit files containing viruses or destructive features, and not to decipher, decompile, disassemble, or reverse engineer software that forms part of the Services.

16. Rules for Posting

ROECNY may allow you to post content on bulletin boards, blogs, or other publicly available locations on the Sites ("User Content"). You are responsible for all User Content you submit, upload, post, or store through the Services. You grant ROECNY a worldwide, royalty-free, non-exclusive license to host and use that User Content in connection with the Services.

You must archive your User Content frequently, provide appropriate disclosures, and ensure that you have the rights necessary to submit the content. By submitting content, feedback, suggestions, or ideas, you grant ROECNY a broad license to use, reproduce, modify, distribute, display, and perform that content in connection with the Services and ROECNY's business.

You agree not to use the Services to post unlawful, defamatory, obscene, threatening, abusive, hateful, infringing, deceptive, promotional, or otherwise inappropriate material; to interfere with other users; or to misuse other users' personal or business contact information. ROECNY is not responsible for community or forum content posted by users or third parties.

17. Social Media Sites

ROECNY may provide experiences on social media platforms such as Facebook, Twitter, and LinkedIn that enable online sharing and collaboration. Content you post on those platforms is subject to the terms of use and privacy policies of those platforms, and you should review those third-party terms directly.

18. Disclaimer of Representations and Warranties

The Sites, Services, information, data, features, content, and all associated services and products are provided on an "as is" and "as available" basis. ROECNY, its affiliates, and its third-party providers, licensors, distributors, and suppliers disclaim all express and implied warranties to the fullest extent permitted by law, including warranties concerning accuracy, reliability, completeness, non-infringement, merchantability, and fitness for a particular purpose.

ROECNY does not warrant that content available through the Services will be free from viruses or other harmful code. Where certain limitations or exclusions are not permitted by law, they apply only to the extent allowed by the relevant jurisdiction.

19. Not a Financial Planner, Broker or Tax Advisor

Neither ROECNY nor the Services are intended to provide legal, tax, or financial advice. ROECNY is not a financial planner, broker, or tax advisor. The Services are intended to help with financial organization and decision-making in a general way, but your circumstances are unique, and you should obtain advice from qualified advisers before making final decisions or implementing a financial strategy.

20. Limitations on ROECNY's Liability

ROECNY will not be responsible or liable to you or any third party, whether in contract, warranty, tort, including negligence, or otherwise, for indirect, special, incidental, consequential, exemplary, liquidated, or punitive damages, including loss of profit, revenue, or business, arising in whole or in part from your access to the Sites, your use of the Services, the Sites, or this Agreement, even if ROECNY has been advised of the possibility of those damages.

Notwithstanding anything to the contrary in this Agreement, ROECNY's liability to you for any cause and regardless of the form of the action will at all times be limited to a maximum of USD 500.00.

21. Your Indemnification of ROECNY

You shall defend, indemnify, and hold harmless ROECNY and its officers, directors, shareholders, and employees from and against all claims, suits, proceedings, losses, liabilities, and expenses, including attorneys' fees, arising out of or attributable to any breach of this Agreement or any activity by you in relation to the Sites or your use of the Services.

22. Ending Your Relationship with ROECNY

This Agreement continues until terminated by you or ROECNY. If you want to terminate your legal agreement with ROECNY, you may close your account for the ROECNY Service by emailing cs@roecny.com.

ROECNY may terminate its legal agreement with you and your access to the Services if you breach this Agreement, if ROECNY believes termination is required by law, for any reason at any time with or without notice, or immediately upon notice to the email address associated with your account. You acknowledge that ROECNY may deactivate or delete your account and related information and prohibit further access to the Services, and that ROECNY is not liable to you or any third party for such termination.

23. Modifications

ROECNY may modify or discontinue the Sites or Services temporarily or permanently, with or without notice. If you are a user of the ROECNY Services, you will be notified of changes where applicable. If you do not agree to a change after receiving notice, you may stop using the Services. Your continued use of the Services after notice of a change constitutes your agreement to that change.

ROECNY may also modify this Agreement from time to time and may provide changes electronically, including by email or by posting the updated Agreement on the Sites. The Agreement will indicate when it was last revised, and you are deemed to accept and agree to any change when you continue using the Services after the updated Agreement is posted.

24. Governing Law and Forum for Disputes

Delaware law governs this Agreement without regard to conflict-of-laws principles. Any dispute or claim relating in any way to the Services or these Terms of Use will be resolved by binding arbitration rather than in court, except that qualifying claims may be brought in small claims court. The Federal Arbitration Act governs the interpretation and enforcement of the arbitration provision.

Any party may seek injunctions or other equitable relief from a court of competent jurisdiction. Each party agrees that disputes must be brought only in an individual capacity and not as a plaintiff or class member in any purported class or representative proceeding. By entering into this Agreement and agreeing to arbitration, you and ROECNY waive the right to file a lawsuit, the right to a jury trial, and the right to participate in a class action or class-wide proceeding.

25. Assignment

ROECNY may transfer, subcontract, or otherwise deal with its rights and obligations under these terms and conditions without notifying you or obtaining your consent. You may not transfer, subcontract, or otherwise deal with your rights or obligations under these terms and conditions.

26. Severability

If any provision of these terms and conditions is determined by a court or other competent authority to be unlawful or unenforceable, the remaining provisions will continue in effect. If part of an unlawful or unenforceable provision could be deleted so that the remainder would be lawful or enforceable, that part will be deemed deleted and the rest of the provision will continue in effect.

Contact

ROECNY PTE. LTD.

77 High Street, High Street Plaza, Singapore 179433

ROECNY GROUP LLC.

99 Wall Street #2099, New York NY 10005

Email: cs@roecny.com