Terms and Conditions

This Platform Agreement, along with any applicable Asset Card Terms, forms a binding contract between your company (“you,” “your,” or “Company”) and ACwallet Inc., d/b/a Asset Card (“Asset Card,” “we,” “us,” or “our”). This Agreement governs your use of the Asset Card platform and Services.

By submitting an application to open an Asset Card account or otherwise accessing or using the Services, you consent to this Agreement and agree to be bound by its terms.

This Agreement includes an arbitration clause requiring resolution of most disputes through individual arbitration. By accepting, you waive the right to a trial by jury or to participate in a class action. See Section 3.8 (Dispute Resolution and Arbitration) for more details.

You may only apply for, open, and maintain an Asset Card account and use the Services if you accept this Agreement.

1. The Asset Card Platform

1.1. Services

Subject to approval and this Agreement, Asset Card grants you access to our Services tailored for project-based businesses. These include expense management, card issuance, transaction tracking, and integrated reporting tools. Services may be delivered by us directly or via approved financial institution partners and third-party service providers. Some services may require agreement to additional Supplemental Terms.

1.2. Opening an Asset Card Account

To access our Services, you must submit an application providing Company Data, Personal Data, and connect at least one Linked Account. You may also need to provide verification documents such as company registration certificates, bank statements, or government-issued ID.

We share this information with our Financial Institution Partners to determine eligibility and compliance. We may also conduct credit checks or report to credit bureaus. If your application is incomplete, inaccurate, or outdated, we reserve the right to suspend or terminate your account.

If your account was created via a referral, we may share application status and limited spend data with the referring partner, as necessary to fulfill partner obligations.

Notice Regarding Account Opening:

To comply with U.S. law, we are required to collect and verify identifying information for each applicant, including names, addresses, and key control persons, which may include government-issued IDs.

1.3. Fees

Some Services may incur transaction, subscription, or other Fees. All Fees will be disclosed in advance, either in this Agreement, applicable Supplemental Terms, or through in-product notifications.

1.4. Managing Your Asset Card Account

You must designate at least one Administrator during application. Administrators can manage users, issue or cancel cards, set spend limits, connect financial accounts, access reporting, and consent to new terms.

You’re responsible for all actions taken by Administrators or Users using your Asset Card account, including compliance with any Third-Party Service terms.

1.5. Security

You are responsible for securing access credentials. Immediately revoke access for any compromised accounts and notify us of any suspected unauthorized access.

1.6. Authorized Users

You are responsible for ensuring all Users comply with this Agreement and your internal spend policies. You also assume responsibility for all payments and reimbursement requests made through the Services.

1.7. Eligibility and Prohibited Use

Only U.S.-based companies may apply. Consumers, sole proprietors, and foreign entities are not eligible. You may not use the Services for personal expenses, prohibited business types, or for any unlawful purposes as defined by our Prohibited Activities List and our Financial Institution Partners.

Violation of this section may result in immediate suspension or termination of your account and may subject you to fines and legal liability.

1.8. Public Identification

We may identify your company as a customer on our website or in promotional materials unless you request otherwise. No false endorsements will be implied.

1.9. Ownership & License

All platform IP—including but not limited to code, reports, models, and logos—remains the exclusive property of Asset Card. You are granted a non-transferable license to use the platform as described in this Agreement.

1.10. Data Privacy

We collect and process Personal and Company Data to provide Services and maintain compliance with our partners. Data may be shared with credit agencies, payment processors, and other partners under appropriate security measures.

See our Privacy Policy and Data Processing Addendum for more information.

1.11. Rewards (if applicable)

Any rewards are subject to the Asset Card Rewards Terms. All rewards are forfeited upon account termination or breach of this Agreement.

1.12. Beta Features

We may offer Beta Services that are experimental and may not perform reliably. Use with caution and do not rely on Beta features for mission-critical tasks.

1.13. Feedback

You grant us an irrevocable license to use any suggestions, ideas, or feedback you provide for any purpose without obligation or compensation.

1.14. Payment Services

Payment services may be offered through Financial Institution Partners or regulated subsidiaries. Separate addenda apply based on the jurisdiction and service provider involved.

1.15. International Payments

We may enable cross-border payments through authorized partners. Foreign exchange rates may include a margin. Your data may be shared with international partners as required for compliance.

This Payment Card Addendum (“Addendum”) supplements and is incorporated into the Asset Card Platform Agreement (the “Platform Agreement”) between you (“you” or “Company”) and ACwallet Inc., d/b/a Asset Card (“Asset Card,” “we,” “us,” or “our”). This Addendum governs your use of physical and virtual payment cards (“Cards”) issued through the Asset Card platform and related Services.

Capitalized terms not defined in this Addendum have the meanings assigned in the Platform Agreement.

1. Card Terms

Cards are issued by our authorized banking partners (each an “Issuer”). Your use of Cards is governed by this Addendum, the Platform Agreement, the Card Terms, and any applicable User Terms. Use of the Cards constitutes your agreement to these terms.

We or the Issuer may update the Card Terms by notice through your Asset Card account, and continued use of the Cards after such notice constitutes acceptance of those changes.

2. Spending Limits

(a) Users may not make Charges that exceed applicable spending limits as determined by Asset Card or set by you.

(b) Upon account approval, we and our Issuers will establish a Total Spending Limit—the maximum allowable aggregate Charges across all Cards. This limit may be adjusted at any time based on risk, compliance, or credit considerations.

(c) If you opt into a daily repayment structure for Cards, you may be required to open and maintain a dedicated Business Bank Account with one of our partners. In such cases:

• Your spending limit is tied to the current account balance.

• You authorize automatic daily debits from your Linked Account or Business Bank Account.

• If the account balance is zero, your Total Spending Limit becomes zero.

• If we are unable to collect funds from your default Linked Account, we may collect from any other Linked Account you have connected.

(d) Card Spending Limits and Daily Spending Limits may be set or modified by Administrators, Asset Card, or Issuers at any time.

(e) Your Available Spend at any time will be the lesser of (i) your current Total Spending Limit or (ii) the amount displayed within your account dashboard.

3. Requesting Cards

Administrators may request Cards for authorized Users. Cards may be denied, suspended, or canceled at our discretion or based on Issuer policies. Cards may be physical or virtual.

Administrators are responsible for ensuring Cards are only distributed to authorized individuals and for overseeing all Card activity.

4. Using Cards

Cards must only be used for legitimate business-related expenses that are associated with active projects or company operations. You are responsible for:

• Managing which team members are issued Cards.

• Implementing controls to ensure appropriate use.

• Charges made by any person issued a Card, even if unauthorized internally.

Asset Card, Issuers, or Card Networks may decline or reverse transactions at their discretion. We are not liable for any losses or damages resulting from declined or reversed transactions.

If you switch to daily repayments, we will issue a Final Monthly Card Statement. All cleared Charges will be debited from your designated Linked Account on that date.

5. Disputed Charges

For merchant disputes, first attempt to resolve directly with the merchant. If unsuccessful, you may request a chargeback via the Asset Card platform.

You must report disputed Charges or errors within 60 days of the transaction posting. We may issue provisional credits while we investigate. If the dispute is valid, your account will be credited accordingly.

By submitting a chargeback, you assign all rights related to that transaction to the Issuer.

6. Lost or Stolen Cards

If a Card is lost, stolen, or compromised, you must:

• Immediately lock the Card via your dashboard.

• Notify us through the platform.

• Take appropriate action to prevent further misuse.

You may request a replacement Card through your Administrator portal. You are responsible for updating any recurring payments or vendor records with new Card details.

Asset Card may suspend accounts if fraud or misuse is suspected. You are responsible for any losses unless otherwise limited by Card Network rules.

7. Foreign Exchange

All Cards settle in U.S. Dollars (USD). If a transaction is conducted in a foreign currency:

• It will be converted to USD at the applicable Card Network rate.

• We may add a foreign exchange margin of up to 3%.

• You will see both the original and converted amounts on your statement.

Exchange rates are variable and depend on factors such as timing, currency, transaction type, and your account relationship.

This Payments Addendum (this “Addendum”) is incorporated into and made a part of the Asset Card Platform Agreement (the “Platform Agreement”) between you (“you” or “Company”) and ACwallet Inc., d/b/a Asset Card (“Asset Card,” “we,” “us,” or “our”). This Addendum governs the use of Payment Services provided through your Asset Card Account.

Capitalized terms not defined herein have the meanings set forth in the Platform Agreement.

1. Definitions

1.1. Bank – A financial institution selected by Asset Card to act as custodian for the Custodial Account.

1.2. Bill Payment – A payment made through the Payment Services to a Payee on your behalf for an Invoice or other amount owed.

1.3. Custodial Account(s) – One or more accounts maintained by a Bank for the benefit of Payors using the Payment Services.

1.4. Invoice – A request for payment submitted by a Payee.

1.5. Nacha Rules – The NACHA Operating Rules and Guidelines.

1.6. Payee – A business seeking payment for goods or services provided to Company or on Company’s behalf.

1.7. Payments – Has the meaning described in Section 4.1.

1.8. Payors – You and other entities utilizing the Payment Services.

1.9. Reimbursement – A payment made to a User to cover a valid business expense, per diem, or allowance.

1.10. User Repayment – A repayment from a User to Company through the Payment Services for unauthorized or personal charges.

2. Bill Payments

2.1. Payments may be funded by ACH from your Linked Account, or through financing from Asset Card affiliates or banking partners. Payments are held in a Custodial Account before being disbursed via ACH, wire, or paper check.

2.2. To initiate a Bill Payment:

• Upload/import an Invoice or manually input payment details.

• Review and approve the Payment Form generated by the platform.

• Select a Payment Method and Settlement Method.

• Approvals must be completed prior to the cutoff time to avoid delays.

2.3. Wire Payments:

• You may authorize payments via wire transfer.

• Wire payments are typically irreversible.

• You are responsible for all wire fees and must confirm payment details are accurate.

2.3.1. You cannot cancel or amend a wire once processed. We may assist in recovery efforts but are not liable for inability to cancel.

2.3.2. Wire payments may not be available for all Payees or transactions.

2.4. Asset Card is not affiliated with your Payees and assumes no responsibility for delivery, product quality, or disputes. You confirm services were received to your satisfaction at time of submission.

2.5. We may require Payees to enroll in our system, including acceptance of any privacy or legal policies.

2.6. For check payments, we will mail a physical check via regular mail. Delivery timelines depend on postal services. Contact support to cancel a check that has not yet been deposited.

2.7. Same Day ACH may be available for certain Bill Payments, subject to a disclosed Fee. Payment must be approved before cutoff. Asset Card is not responsible for delays at the receiving bank.

3. Reimbursements and User Repayments

3.1. If enabled, you may:

• Submit reimbursements to Users.

• Accept repayments from Users for unauthorized or personal charges.

Users must provide valid bank account details. You are responsible for ensuring this information is correct.

3.2. A designated Reviewer (e.g. an Administrator or manager) will approve or deny Reimbursements. Approved amounts will be credited to the User’s account, subject to availability of funds and compliance requirements.

4. Company Authorization

4.1. You authorize our financial partners to debit your Linked Account for the total amount of each Payment and associated Fees. This is an extension of the ACH authorization in Section 2.3 of the Platform Agreement.

4.2. You are solely responsible for safeguarding login credentials. Any Payment submitted via your Asset Card Account will be considered authorized, even if submitted in error, provided we acted in good faith.

4.3. We reserve the right to delay or reject any Payment based on compliance or risk policies.

4.4. If a User reverses a repayment after funds have been received, you authorize us to debit your Linked Account for the amount of the reversal and any associated Fees.

4.5. You may request to cancel a Payment before it is executed. We will cooperate when possible, but are not obligated to reverse an authorized transaction.

4.6. Neither Asset Card nor its partners are liable for errors in submitted Payment data. NACHA rules govern all ACH transactions.

4.7. We may update our transaction procedures to comply with law, banking partner rules, or operational needs.

(continued in next message – Sections 5–14...)

Continuing with the Payments Addendum for Asset Card, here are Sections 5 through 14:

5. Texas-Resident Customers

For customers residing in Texas, First Internet Bank of Indiana (“FIB”) is the legal entity responsible for handling, safeguarding, and transmitting funds used in connection with Payment Services. FIB has appointed Asset Card as its authorized agent for facilitating these services under this Addendum.

6. International Payments

International Payments are processed by authorized International Payments Partners under separate agreements between you and such partners. You may be required to sign additional authorization forms and agreements in accordance with international payment network rules.

7. Your Relationship with the Bank

The Bank holds all funds deposited in Custodial Accounts in trust for the benefit of all participating Payors. Your funds may be pooled with those of other Payors and will be held under the Bank’s name as custodian.

You acknowledge and agree that:

• These funds are not held in a segregated account solely for you.

• Funds will be disbursed based on Payment instructions you submit through Asset Card.

8. Your Relationship with Asset Card

You appoint Asset Card as your designated agent to:

• Facilitate all Payment Services described in this Addendum.

• Maintain records of Payment activity and balances.

• Instruct the Bank on disbursement and receipt of funds.

• Share Payment details with Payees as needed.

• Take any other steps required to enable the functionality and security of the Payment Services.

You agree that the Bank may rely entirely on instructions from Asset Card without seeking additional authorization from you.

9. Relationship between FIB and Asset Card

Asset Card is authorized to collect information from you and facilitate Payments as an agent for First Internet Bank of Indiana. You expressly agree to Asset Card acting in this dual capacity and waive any conflict of interest resulting from this arrangement.

10. The Custodial Accounts

All funds in the Custodial Accounts are held for the collective benefit of all Payors. Funds will remain in these accounts until disbursed in accordance with your Payment instructions. By submitting Payment instructions, you authorize Asset Card and the Bank to make the transfers described.

11. No Interest

You will not earn interest or other earnings on funds held in the Custodial Accounts.

12. Restricted Activities

You may not use the Payment Services to:

• Violate any law or regulation.

• Engage in fraud or misrepresentation.

• Submit false or misleading information.

• Harm the integrity or functionality of the Payment Services.

• Enable or facilitate money laundering, terrorist financing, or sanctions evasion.

• Interfere with investigations or provide incomplete/inaccurate information.

• Attempt to recover funds for the same transaction from Asset Card, the Bank, and a Payee.

Violations may result in suspension or termination of your access, withholding of funds, and notifications to financial institutions or law enforcement.

13. Limitation on Duties of Asset Card

Asset Card’s role is limited to:

• Providing platform software and technical services.

• Acting as your agent in facilitating transactions.

• Instructing the Bank according to your submitted Payment instructions.

Asset Card does not provide banking services or hold any funds directly. Nothing in this Addendum should be interpreted as making Asset Card a money transmitter or financial institution under applicable laws.

14. Additional Responsibilities and Limitations

14.1. Your Internal Responsibilities

You are solely responsible for:

• Informing Users of your reimbursement policies.

• Reviewing and verifying Payment and Reimbursement requests.

• Managing tax compliance related to expenses and reimbursements.

• Confirming account details for both Users and Payees.

14.2. Verification and Identity Checks

You authorize Asset Card and its partners to:

• Request additional identification or tax details.

• Verify your Linked Account(s).

• Run credit or background checks if needed for risk, compliance, or underwriting.

Failure to comply with verification requirements may result in account suspension.

14.3. "As Is" Service

The Payment Services are provided as is without warranty of any kind. Asset Card and its partners disclaim all warranties, including merchantability, fitness for a particular purpose, and non-infringement. No guarantee is made that the Services will be error-free, timely, or continuously available.

14.4. Limitation of Liability

In addition to the Platform Agreement’s limitations:

• Asset Card and its partners are not liable for indirect, incidental, or consequential damages.

• Total liability is limited to direct damages up to the amount of Fees paid in connection with the relevant Payment.

14.5. Indemnification

You agree to indemnify and hold harmless Asset Card, its financial partners, and service providers from any claims, losses, or damages related to:

• Errors in Payment instructions.

• Misuse of Payment Services by your company or Users.

• Failure to maintain adequate funds.

• Violation of this Addendum or applicable law.

This Productivity Integration Addendum (this “Addendum”) is incorporated into and made a part of the Asset Card Platform Agreement (the “Platform Agreement”) between you (“you” or “Company”) and ACwallet Inc., d/b/a Asset Card (“Asset Card,” “we,” “us,” or “our”). Capitalized terms not defined herein have the meaning given in the Platform Agreement.

This Addendum governs your activation and use of Productivity Integrations, defined as integrations developed by Asset Card to connect the Services with Gmail, Google Calendar, Microsoft Outlook, and other productivity applications (collectively, “Productivity Applications”).

These integrations enable Asset Card to access, collect, and process Company Data, documentation, and communication from Productivity Applications on a continuous basis.

1. Representations and Warranties

By enabling Productivity Integrations, you represent and warrant the following:

(a) You have authority over the Productivity Applications you connect and will only enable integrations for accounts you own and control within your company domain.

(b) Where required by law, you will:

• (i) Obtain informed consent from Users; and

• (ii) Provide notice and enforce appropriate technology and privacy policies.

(c) You consent to Asset Card processing Company Data and Personal Data from Productivity Applications, including:

• Email headers and messages

• Calendar events and lists

• Attachments or files associated with communications

(d) You will not use Productivity Integrations in any jurisdiction unless their operation is lawful in that location.

(e) Your use of these integrations will not cause you or Asset Card to violate any applicable laws, regulations, or third-party rights.

2. Personal Data

Personal Data accessed through Productivity Integrations will be processed in accordance with Asset Card’s Privacy Policy, as updated from time to time.

3. Limitation of Liability

You acknowledge that Productivity Applications are Third-Party Services, and Asset Card:

• Does not control their performance or functionality

• Provides no support for them

• Disclaims all liability for failures, errors, or data loss arising from or related to these services

You agree to indemnify Asset Card under Section 3.6 of the Platform Agreement for any losses or damages resulting from your breach of this Addendum or your use of the Productivity Integrations.

This Payments Addendum (this “Addendum”) is incorporated into and forms part of the Platform Agreement between you (“you” or “Company”) and ACwallet LLC, doing business as Asset Card (“Asset Card”), and its affiliates, including any designated payment processing entity. This Addendum governs your use of the Asset Card platform for payment-related services (the “Payment Services”), including services provided by ACwallet LLC through its licensed partners, such as Stripe and Celtic Bank.

Capitalized terms used in this Addendum but not otherwise defined shall have the meanings assigned in the Platform Agreement.

1. Definitions

1.1. Bill Payment: A payment made via the Payment Services to a third-party vendor (“Payee”) on your behalf.

1.2. Invoice: A billing document submitted by a Payee to the Company.

1.3. Nacha Rules: The NACHA Operating Rules and Guidelines applicable to ACH transactions.

1.4. Payee: Any business entity that submits an invoice or receives funds through the Payment Services.

1.5. Payments: Defined in Section 4.1 as debits for Bill Payments and Reimbursements.

1.6. Payors: Refers to you and any other entities utilizing the Payment Services to make payments.

1.7. Pooled Account(s): One or more custodial accounts maintained by Asset Card or its financial partners to facilitate transactions.

1.8. Reimbursement: A payment made by you to a User for approved business expenses, including per diems.

1.9. Payment Services: Includes money transmission activities and related tools for Bill Payments, Reimbursements, and User Repayments.

1.10. User Repayment: A repayment made by a User to the Company, typically in response to unauthorized or non-business expenses.

2. Bill Payments

2.1. Bill Payments made using Asset Card’s Payment Services may be funded via ACH transfer from your Linked Account or by other methods approved by Asset Card. Payments are settled via ACH, wire, or check, depending on the method selected at the time of scheduling.

2.2. You authorize ACwallet LLC to debit your Linked Account for the amount of each scheduled Bill Payment. You are responsible for ensuring that sufficient funds are available in the Linked Account at the time of the transaction.

2.3. Asset Card may delay or cancel a Bill Payment if it detects suspicious activity, insufficient funds, or any compliance concern. Asset Card is not liable for any late fees or penalties incurred as a result.

2.4. If a Payee does not accept electronic payments, Asset Card may issue a paper check on your behalf. You are responsible for ensuring correct Payee details and mailing address.

2.5. You agree that once a Bill Payment is submitted, it may not be canceled or reversed unless explicitly allowed by Asset Card and not yet processed.

2.6. All Bill Payments must comply with applicable law, the Platform Agreement, and this Addendum. You agree not to use Payment Services for any illegal or unauthorized transaction.

2.7. ACwallet LLC retains the right to change the accepted funding methods or impose limits on Bill Payment amounts or frequency, at its discretion.

3. Reimbursements and User Repayments

Reimbursements processed through Asset Card’s Payment Services must comply with your internal expense policies. Asset Card facilitates reimbursement payments but is not responsible for validating the legitimacy of submitted expenses.

User Repayments must be initiated through the platform when Users need to return funds (e.g., for personal or non-approved expenses). Asset Card may support these repayments via ACH debit or other approved methods.

4. Company Authorization

You authorize ACwallet LLC to initiate ACH debits and credits from your Linked Account in accordance with the NACHA Rules and Section 2.3 of the Platform Agreement.

This authorization remains effective until revoked in writing and all outstanding transactions have cleared. You must ensure that the Linked Account remains active and adequately funded to support Payment Services activity.

5. International Payments

Asset Card does not currently support international payments directly. If you use third-party services (e.g., Wise US Inc.), those services are governed by separate agreements. Asset Card does not control, endorse, or assume liability for any third-party payment providers or international transactions.

6. Pooled Accounts

ACwallet LLC and its financial partners may maintain pooled custodial accounts to facilitate the delivery of Payment Services. You acknowledge and agree:

• Funds in pooled accounts remain the property of ACwallet LLC or its designated partner until disbursed.

• You do not earn interest on funds held in pooled accounts.

• These accounts may be commingled with funds from other customers, but proper accounting and separation of funds are maintained.

7. Restricted Activities

You agree not to use the Payment Services for any prohibited or restricted activities, including:

• Fraudulent or deceptive practices

• Money laundering or financing of terrorism

• Transactions involving illegal goods or services

• Use in connection with sanctioned countries or individuals (as defined by OFAC or similar authorities)

Asset Card reserves the right to suspend or terminate access to the Payment Services in the event of suspected or confirmed violation of these terms.

8. Limitation on Duties of Asset Card

Asset Card provides access to payment infrastructure and financial services through third-party partners such as Stripe and Celtic Bank. Asset Card itself does not receive, hold, or transmit customer funds.

Your use of these services is subject to applicable agreements, rules, and compliance programs of those partners. Asset Card is not liable for any interruption, delay, or error caused by those third-party systems.

9. Additional Responsibilities and Limitations

You agree to:

• Notify and train Users on your internal expense policies

• Maintain responsibility for verifying the identity and eligibility of Users

• Comply with all applicable AML, KYC, and data protection regulations

• Report any misuse, unauthorized access, or suspicious activity immediately

Asset Card may request additional information from you to meet its compliance or operational requirements at any time.

10. ACwallet LLC Money Transmission Licenses

ACwallet LLC is a registered money services business (MSB) and operates through licensed financial partners, including Stripe and Celtic Bank.

For a list of state licenses, regulatory disclosures, and any additional compliance information, please visit: [Insert URL for compliance or legal page]

This Early Access Program Addendum ("Addendum") is incorporated into and made a part of the Asset Card Platform Agreement between you ("you" or "Company") and ACwallet LLC, doing business as Asset Card ("Asset Card", "we", or "us"), governing use of your Asset Card Account. Capitalized terms not defined herein shall have the meanings assigned in the Platform Agreement. The Platform Agreement, as supplemented by this Addendum (collectively, the "Agreement"), governs your participation in the Asset Card Early Access Program, as defined below.

1. Definitions

1.1. "Early Access Program" means Asset Card’s program that grants customers early access to new or experimental Asset Card Services.

1.2. "Pre-Release Information" means any non-public information about Early Access Services made available through the Early Access Program, including but not limited to business plans, product roadmaps, pricing, systems, source code, marketing strategies, trade secrets, financial data, or any other confidential materials. Pre-Release Information may be designated as “confidential” or would reasonably be understood to be confidential based on its nature.

2. Overview and Participation

2.1. Through the Early Access Program, Company may gain access to unreleased features or services provided by Asset Card (“Early Access Services”). These may be labeled “Early Access,” “Alpha,” “Beta,” “Preview,” “Test,” “Asset Card Labs,” or similar. By opting in, you agree to:

• (a) receive any such Early Access Services made available by us as part of the Program; and

• (b) provide feedback on your experience using those services.

Asset Card is not obligated to provide notice when provisioning new Early Access Services to your account.

2.2. You acknowledge and agree that the form, availability, and content of Early Access Services are subject to change at our discretion and without prior notice. We may suspend or terminate the Early Access Program or your access to it at any time.

2.3. Pre-Release Information remains the sole property of Asset Card. You agree to treat all such information as confidential and to use it only as needed to test and evaluate Early Access Services. You may share this information with your Users only to the extent necessary and are responsible for their compliance with confidentiality obligations. Exceptions to confidentiality apply only if:

• (a) the information is or becomes public without your breach,

• (b) you lawfully receive it from a third party with no duty of confidentiality,

• (c) you independently develop it without use of Pre-Release Information, or

• (d) Asset Card provides written authorization to disclose it.

2.4. Voluntary Participation. Participation in the Early Access Program is voluntary and at your own discretion. By opting in, you agree not to assert any claim, action, or proceeding against Asset Card based on the performance, availability, or reliability of Early Access Services.

3. Additional Terms

3.1. Without limiting other disclaimers in the Agreement, you understand and agree that:

• (a) Early Access Services are pre-release, incomplete, and not fully tested;

• (b) they may contain bugs, flaws, or errors that affect your systems or data;

• (c) they may not be fully compliant with regulatory or legal requirements;

• (d) they may cause unexpected failures, data loss, or operational impacts; and

• (e) they are provided entirely “as is” and as available, without any warranties

3.2. Limitation of Liability. In no event will Asset Card be liable for any damages arising from or related to this Addendum or the Early Access Program, whether under contract, tort (including negligence), or any other legal theory. This includes direct, indirect, incidental, special, or consequential damages—even if we were advised of the possibility. If this limitation is unenforceable under applicable law, Asset Card’s total liability shall not exceed $1,000.00.

3.3. Indemnification. For clarity, all indemnification obligations in the Platform Agreement that apply to the general Services also apply to the Early Access Services.

3.4. Feedback License. Any feedback, suggestions, or recommendations you provide in connection with the Early Access Services may be used by Asset Card for any purpose without restriction, attribution, or compensation.

3.5. Survival. The confidentiality, limitation of liability, indemnification, and feedback provisions of this Addendum shall survive the termination of your participation in the Early Access Program.

This Subscription Purchase Addendum (“Addendum”) is incorporated into and made a part of the Platform Agreement between you (“you” or “Company”) and ACwallet LLC, doing business as Asset Card (“Asset Card,” “we,” or “us”) governing use of your Asset Card Account. Capitalized terms not defined herein shall have the meanings set forth in the Platform Agreement.

1. Subscription Services

Access to certain advanced features of the Asset Card platform may require the purchase of a subscription service (“Subscription Services”). If you opt in to Subscription Services through your Account or by executing an order form, you agree to pay all applicable subscription fees (“Subscription Fees”) on a recurring basis, based on your selected billing period (“Subscription Term”). Unless otherwise specified, Subscription Terms are billed monthly. Implementation services billed on a one-time or limited basis are also considered Subscription Services under this Addendum.

2. Fees

You agree to pay all Subscription Fees when due, along with any applicable taxes.

2.1 Subscription Fees are charged in advance at the beginning of each Subscription Term. Billing details are available in your Asset Card Account.

2.2 We will debit your designated Linked Account for Subscription Fees. If no default is specified, you authorize us to debit any Linked Account associated with your Account. You are responsible for ensuring sufficient funds are available at the time of debit.

2.3 Fees are non-refundable and non-cancelable once the Subscription Term has begun. To avoid renewal charges, you must cancel before the start of the next billing cycle. Late payments may incur interest at 1.5% per month or the maximum amount allowed by law.

2.4 If additional paid users (“seats”) are added during a billing period, you will be billed a prorated amount on your next invoice. These seats remain active and billable through the rest of your Subscription Term unless modified.

3. Purchases via Reseller

3.1 If you purchase Subscription Services through an authorized third-party reseller (“Reseller”), your access remains subject to both this Addendum and the terms of your agreement with the Reseller (“Reseller Agreement”).

3.2 Any refund, cancellation, or credit will be issued to the Reseller, not directly to you. Termination rights are also governed by your Reseller Agreement.

3.3 If your Reseller loses authorization or fails to pay us on your behalf, we may suspend your Subscription Services unless you contract directly with us and pay any outstanding amounts. Resellers cannot bind Asset Card to terms not included in this Addendum or the Platform Agreement.

3.4 You must notify Asset Card in writing within five (5) business days of terminating your relationship with a Reseller.

3.5 Upon Reseller Termination, you are responsible for any unpaid Subscription Fees that your Reseller did not remit. You authorize us to collect such fees from your Linked Account without additional notice.

4. Promotional Trials

We may offer trial periods or promotional pricing (“Offers”) from time to time. Eligibility is at our discretion and may be withdrawn at any time. Offer details will be shared during sign-up or through in-app messaging.

5. Automatic Renewal

Your Subscription Services will renew automatically unless canceled before the end of the current billing cycle.

• If self-served: cancel anytime via your Asset Card Account.

• If sales-led: notify your representative at least thirty (30) days before renewal.

Cancellation requests received after a billing cycle has started will take effect in the following cycle. You remain responsible for full payment through the end of your current Subscription Term.

6. Warranties

We represent and warrant that:

• ACwallet LLC is a legally formed entity in good standing under the laws of its jurisdiction of formation;

• Our Subscription Services will perform materially as described in our documentation;

• We will comply with applicable laws when providing Subscription Services;

• We have the authority to enter into this Addendum.

All other warranties, express or implied (including fitness for a particular purpose, merchantability, and non-infringement), are disclaimed.

7. Restrictions and Acceptable Use

You agree not to:

• Use the Subscription Services outside of your internal business purposes;

• Reverse engineer, copy, or modify the Subscription Services;

• Make Subscription Services available to unauthorized users;

• Overload, misuse, or compromise the integrity or security of the system;

• Violate any applicable laws or circumvent usage limits.

8. Indemnification

8.1 Asset Card will defend and indemnify you from claims by third parties that the Subscription Services infringe their U.S. patent or copyright, except when caused by:

• Your modifications;

• Your combination with non-Asset Card software;

• Use outside the permitted scope.

8.2 You must promptly notify us of any such claim. We retain the right to control the defense. You may participate at your own expense. We will not settle a claim that imposes obligations on you without your consent.

8.3 This section represents our entire liability and your sole remedy for third-party IP infringement claims.

9. Limitation of Liability

9.1 Except in cases of gross negligence, willful misconduct, or indemnification obligations, neither party is liable for indirect, special, punitive, or consequential damages.

Our total liability is capped at the total Subscription Fees paid by you in the twelve (12) months preceding the event giving rise to the claim.

9.2 These limits do not apply to your obligations to pay owed fees or charges under the Platform Agreement.

10. Plans

Different plans may include varying levels of access and features. We reserve the right to update plan offerings and pricing with prior notice. If you do not agree to changes, you must cancel before your renewal date. Continued use signifies acceptance of any updated terms.

11. Taxes

All fees are exclusive of applicable taxes. You are responsible for all sales, VAT, or other taxes (excluding taxes on our net income). If withholding taxes apply, you must cover the difference so we receive the full payment amount.

This Business Account Addendum ("Addendum") is incorporated into and made a part of the Asset Card Platform Agreement (the "Platform Agreement") between you ("you" or "Company") and ACwallet LLC, doing business as Asset Card ("Asset Card"). Capitalized terms used herein but not otherwise defined shall have the meaning provided in the Platform Agreement.

This Addendum governs your use of the Business Account feature of your Asset Card Account, which provides access to financial tools, including deposit account services and card-issuing features, made available through our banking and service partners: Stripe, Inc. (as platform) and Celtic Bank (as our issuing bank) (together, “Partners”).

1. Overview

If approved, your Company may open and manage a Business Account through Asset Card. Your associated deposit and card accounts are provisioned via our Partners, including Celtic Bank, Member FDIC. By using these services, you agree to be bound by the Partner Agreements, including the terms of service of Stripe and Celtic Bank.

The deposit account and related financial features are managed through the Stripe Treasury platform and issued by Celtic Bank. Asset Card is not a bank and does not hold your funds.

2. Representations & Warranties

You represent and warrant that:

• You are authorized to open and manage a Business Account on behalf of the Company;

• All information submitted is accurate and complete;

• You have sufficient funds to initiate payments or transfers;

• You will provide all required identity verification or compliance documentation as requested by Asset Card or our Partners.

3. Business Information

To comply with legal and regulatory requirements, you agree to provide business and personal identity information, including (but not limited to): legal business name, address, tax identification number (TIN), and beneficial ownership information. Additional documentation may be required at any time. See our Privacy Policy for more on how we handle your information.

4. General Terms

a. Your Relationship with Asset Card

You authorize Asset Card to act as your agent for purposes of facilitating the Business Account services. This includes:

• Managing and accessing balances through our platform;

• Executing payments or transfers from your deposit account;

• Communicating with Stripe and Celtic Bank on your behalf;

• Sharing transaction and compliance data as necessary.

You are responsible for maintaining security over your login credentials. Notify us immediately of any unauthorized access or use.

b. Asset Card’s Role with Partners

Asset Card facilitates services on your behalf but does not provide financial services directly. Banking features are made available through Stripe and Celtic Bank. You acknowledge their separate role as regulated financial institutions.

c. Disclosures

Asset Card is not a bank, and your deposits are not held by Asset Card. Deposit and card services are provided by Celtic Bank, Member FDIC. Funds held at Celtic Bank may be eligible for FDIC insurance, subject to standard limits and eligibility criteria.

d. Rewards

From time to time, Asset Card may offer cash-back or other rewards on qualifying deposits or card usage. Reward terms and eligibility are set solely by Asset Card and may change or be discontinued at any time. These are not interest payments.

e. Fees

Some services may include fees. Fees charged by Asset Card are governed by the Platform Agreement. Partner-specific fees are governed by their separate terms.

f. Legal and Compliance Obligations

We and our Partners reserve the right to freeze funds, refuse transactions, or suspend your Business Account if we believe there has been a violation of applicable law, regulation, or policy. We may be required to act without prior notice in response to legal or regulatory requests.

5. Information Sharing

You authorize Asset Card to share your business and account information with Stripe, Celtic Bank, and other service providers as necessary to operate your Business Account. Asset Card is not responsible for how these Partners use or protect your data once shared. Refer to each Partner’s privacy policies for more information.

6. Deposit Account Terms

Your deposit account is provided through Celtic Bank, not Asset Card. You agree to Celtic Bank’s account terms and Stripe Treasury’s platform terms. FDIC insurance applies only to funds held at Celtic Bank and is subject to federal deposit insurance rules and limits.

7. Set Off and Collections

If you fail to meet your payment obligations or default under the Platform Agreement, you authorize Asset Card and its Partners to debit or liquidate funds in your deposit account to satisfy outstanding amounts. You are responsible for all legal, collection, and recovery costs incurred.

8. Limitation of Liability

The Business Account and associated deposit services are provided “as is” and as available. Asset Card, Stripe, and Celtic Bank disclaim all warranties, express or implied. We are not liable for any losses related to delays, disruptions, unauthorized use, or force majeure events. To the maximum extent permitted by law, our liability is limited to amounts paid by you in the six (6) months preceding the event giving rise to the claim.

9. Indemnity

You agree to indemnify and hold harmless Asset Card, Stripe, and Celtic Bank from any claims, losses, or damages arising from your use of the Business Account, violation of applicable law, or breach of this Addendum or the Platform Agreement.

10. Limitation on Duties of Asset Card

Asset Card’s responsibilities are limited to:

• Providing platform access and account interfaces;

• Acting as your authorized agent;

• Facilitating integration with Stripe and Celtic Bank.

Asset Card does not offer direct money transmission, deposit-taking, or investment services.

11. Termination

You may request to close your Business Account at any time, subject to full payment of any outstanding obligations and clearance of all balances. Account closure will also terminate any associated access to banking services via Stripe and Celtic Bank. Asset Card may also suspend or terminate your Business Account for cause or upon notice.

12. Electronic Records & Signatures

You agree to receive account communications, records, disclosures, and agreements electronically. Digital signatures and electronic acknowledgments are legally binding for all Business Account activity and documentation.

Deposit accounts are issued by Celtic Bank, Member FDIC. ACwallet LLC is not a bank. Banking services are enabled through Stripe, Inc. and subject to the Partner Terms of Service.

THIS ACH DEBIT AUTHORIZATION GOVERNS THE AUTOMATED DEBITING OF ANY BUSINESS BANK ACCOUNT YOU LINK TO YOUR ASSET CARD ACCOUNT (EACH, A “LINKED ACCOUNT”). PLEASE REVIEW CAREFULLY.

By accepting this Agreement, you authorize ACwallet LLC, doing business as Asset Card (“Asset Card”), our financial institution partners (“Financial Institution Partners”), and each of their respective affiliates and assigns, to electronically debit your Linked Account(s) via the Automated Clearing House (“ACH”) network for the purpose of processing payments and collecting any amounts due under the Asset Card Platform Agreement (“Agreement”).

You may designate a specific Linked Account within the Services to serve as your default account for debits associated with your use of the Asset Card platform. If a default account is not designated, or if a debit attempt fails, Asset Card may debit any Linked Account connected to your Account. This authorization applies to your business, its affiliates, and any legal assignees or receivers.

All ACH transactions authorized under this Agreement will be processed in accordance with applicable law and the operating rules of the National Automated Clearing House Association (NACHA). You also authorize Asset Card or its partners to initiate micro-deposits or similar verification transfers, and to make correcting debits or credits in the event of processing errors.

You represent and warrant that you are authorized to act on behalf of the business associated with the Linked Account(s), and that you have full authority to execute this ACH Debit Authorization.

Debits may include both one-time and recurring amounts owed to Asset Card for services provided, including expense management, card issuance, and any associated fees. These payments may reflect the full amount shown on periodic statements or billing summaries issued by Asset Card.

To revoke this authorization, you must notify us in writing at least thirty (30) days prior to the effective date of cancellation. Revocation of this ACH authorization does not relieve you of your obligations under the Platform Agreement, including timely payment of any outstanding amounts owed.

1. Introduction

ACwallet Inc. d/b/a Asset Card ("Asset Card," "we," "our," or "us") is committed to helping businesses streamline and manage expenses across projects, teams, and assets. This Privacy Policy explains how we collect, use, disclose, and protect data that can identify or reasonably be linked to a particular individual, household, or device ("Personal Information") when users interact with our platform and services.

Asset Card provides project-based expense management tools, including digital and physical payment cards, real-time transaction tracking, budget controls, and integrations with third-party services. Our products are built for commercial use and are not intended for personal, family, or household purposes. However, in the course of delivering our services to business customers, we may process Personal Information in a commercial context.

We want you to understand how we handle your information and the rights and choices you have in relation to your Personal Information. This Privacy Policy applies to all interactions with Asset Card through our website (assetcard.io), our platform (including mobile and web apps), and other related services (collectively, the "Platform").

If you have any questions about this Privacy Policy or our data practices, you may contact us at:

Email: support@assetcard.io

Mail: ACwallet Inc., Attn: Privacy Counsel, [Insert Mailing Address Here]

2. Applicability of this Privacy Policy & Asset Card’s Business

This Privacy Policy applies to Personal Information we collect and process in our capacity as a data controller when you:

• Access or use our project-based expense management tools, delegated card issuance features, project wallets, integrations (e.g., with Stripe Treasury, Plaid), and other services (collectively, the "Services");

• Visit our website (assetcard.io);

• Engage with us through our communications, marketing, social media, or events (collectively with the Services and Website, the "Platform").

This Privacy Policy does not apply to information processed by Asset Card on behalf of a customer (a "Company") under a service agreement (the "Agreement"). In those cases, we act as a processor or service provider and process Personal Information only on behalf of and at the direction of the Company. If you are an end user or authorized employee of a Company, please contact your Company directly to exercise any data rights or questions regarding your Personal Information.

This Privacy Policy also does not apply to third-party applications, services, or integrations ("Third-Party Services") that may be connected to the Platform, such as external accounting systems, rideshare platforms, or HR software. These services are governed by their own privacy policies and terms of use.

3. Personal Information Asset Card Processes

We collect and process Personal Information in order to provide and improve our Services and operate our Platform. The types of Personal Information we collect fall into the following categories:

A. Personal Information You Provide to Us

• Contact Information: Name, email, phone number, business name, role/title, and mailing address.

• Identity and Verification Information: Information for identity verification and risk checks (e.g., date of birth, government-issued ID, social security number, photo, citizenship).

• Business Financial Information: Company tax details, bank accounts, and any documentation submitted to verify financial eligibility or compliance.

• Communications and Content: Messages sent to our team (support, sales, feedback) and content shared on or through our Platform.

• Third-Party Contacts: Information about other users you refer, invite, or interact with on our Platform (e.g., name, email, phone number).

• Audio/Video Recordings: With your consent, we may record calls or meetings for training, support, or compliance purposes.

B. Personal Information Generated Automatically

• Usage Data: Pages viewed, features used, workflows initiated, time spent, and clicks/taps within the app.

• Device Information: Device type, browser, IP address, operating system, settings, crash logs, and session metadata.

• Location Information: Derived from IP address or specific location if required for services like mileage reimbursement.

• Cookies and Similar Technologies: Cookies, tags, web beacons, SDKs, and similar tools used for analytics, personalization, and advertising. You can manage these in our [Cookie Policy].

C. Information from Third Parties

• Connected Integrations: Data from third-party services you or your Company link to Asset Card (e.g., Plaid, Stripe, QuickBooks). This may include transaction records, account data, or HRIS details.

• Financial Institution Partners: We may receive data from our banking and card-issuing partners to provide our card and treasury services.

• Marketing and Analytics Partners: We may receive contact or profile data to identify and understand business prospects or enhance our marketing.

• Vendors and Referrals: Data shared with or about vendors or referred businesses, including contact and tax details.

4. How We Use Personal Information

We use Personal Information to:

• Provide, maintain, and improve our Services and Platform

• Issue and manage payment cards and project budgets

• Verify identity and manage risk

• Enable reimbursements, transfers, and integrations

• Communicate with you (support, alerts, account updates)

• Send marketing materials (as permitted by law)

• Comply with legal and regulatory obligations

• Detect and prevent fraud or security threats

• Analyze usage and improve the Platform

• Create anonymized or aggregated data for business purposes

5. How We Share Personal Information

We may share your Personal Information with:

• Your Company: As an Authorized User, your Company’s administrators may access your data and usage.

• Service Providers: Vendors supporting operations, such as hosting, KYC/AML, analytics, or communications.

• Financial Partners: Banks, card networks, or payment processors enabling card issuance or fund transfers.

• Third-Party Integrations: Apps or platforms you or your Company connect (e.g., QuickBooks, Slack).

• Marketing and Analytics Providers: To help deliver ads and understand usage, as permitted by law.

• Legal/Regulatory Authorities: To comply with laws, enforce terms, or respond to lawful requests.

• In Corporate Transactions: If we merge, sell, or restructure, your data may be part of that process.

We do not sell Personal Information for monetary value. Certain disclosures (e.g., for targeted advertising) may qualify as “sales” or “sharing” under applicable law. You may opt out of such practices as outlined in Section 6.

6. Your Rights and Choices

You may have the right to:

• Access, correct, or delete your Personal Information

• Object to or restrict certain processing

• Withdraw consent for marketing

• Manage cookie or tracking preferences

To exercise your rights, please contact your Company administrator (if applicable) or reach out to us at support@assetcard.io. For residents of California, the E.U., U.K., or other jurisdictions with specific rights, additional details and opt-out mechanisms can be found on our [Your Privacy Choices] page.

7. International Transfers

Asset Card is based in the U.S., and data may be transferred to or processed in other countries. When applicable, we use appropriate safeguards (e.g., Standard Contractual Clauses, adequacy decisions, encryption) to ensure compliance with international data protection laws.

8. Lawful Bases for Processing

Where required by law (e.g., under GDPR), we rely on lawful bases for processing Personal Information, including:

• Contract performance (e.g., providing services)

• Legal obligations

• Legitimate interests (e.g., improving our services, preventing fraud)

• Consent (when required and provided by you)

9. Security

We implement technical and organizational safeguards to protect your Personal Information. However, no method is entirely secure. We recommend enabling MFA and using strong passwords. Report concerns to security@assetcard.io.

10. Use by Minors

Asset Card is not intended for use by individuals under the age of 18, and we do not knowingly collect data from children.

11. Data Retention

We retain Personal Information as long as necessary to fulfill the purposes outlined in this policy, meet legal requirements, resolve disputes, or enforce agreements. When no longer needed, we securely delete or anonymize the data.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on our website with the “Last Updated” date revised accordingly. Where required, we will provide advance notice of significant changes.

13. Contact Us

Questions, concerns, or requests regarding this Privacy Policy can be sent to:

Email: support@assetcard.io

Mail: ACwallet Inc., Attn: Privacy Counsel, [Insert Mailing Address Here]

14. California Privacy Rights (CCPA)

California residents have the right to:

• Know what Personal Information we collect and why

• Access, correct, or delete their Personal Information

• Opt out of the sale or sharing of Personal Information

• Not be discriminated against for exercising their rights

For full details, including the categories of Personal Information collected and disclosed, see Sections 3–6. You may opt out of certain practices using the “Do Not Sell or Share My Info” link in the footer of our website or by enabling the Global Privacy Control (GPC) signal in your browser.

SMS/Text Messaging Consent and Data Use

When you provide your mobile phone number and opt in to receive SMS messages from Asset Card (AC Wallet LLC), we will use that number solely to send you messages related to the service you requested (e.g., demo confirmations, appointment reminders, and related follow-ups).

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All categories in this Privacy Policy regarding information sharing exclude SMS consent data and mobile phone numbers collected for SMS purposes; this information will not be shared with any third parties for their own marketing purposes.

Message frequency varies. Message and data rates may apply. You can opt out at any time by replying STOP to any message. For assistance, reply HELP or contact support@assetcard.io.

Cookie Policy

This Cookie Policy explains how ACwallet Inc. d/b/a Asset Card ("Asset Card," "we," "our," or "us") uses cookies and similar technologies to collect and process data through our website (assetcard.io), applications, and services (the "Platform"). Capitalized terms not defined here have the meanings set forth in our [Privacy Policy].

What are cookies?

Cookies are small data files placed on your device by a website. They can store preferences, session details, and browsing behavior. Cookies may be:

• Session cookies, which expire when you close your browser.

• Persistent cookies, which remain stored until deleted or expire.

• First-party cookies, set by Asset Card.

• Third-party cookies, set by service providers like analytics or advertising platforms.

We also use other tracking technologies such as pixels, web beacons, SDKs, and device fingerprinting to help deliver secure, efficient, and personalized experiences.

Does Asset Card use cookies?

Yes. Asset Card uses both first-party and third-party cookies. These technologies help us:

• Maintain secure user sessions and logins

• Measure usage and improve performance

• Customize content and settings

• Deliver limited remarketing and promotional campaigns (where permitted)

• Prevent fraud and ensure platform security

Examples of third-party cookies include those from Google Analytics and advertising tools such as LinkedIn or Google Ads.

What types of cookies does Asset Card use?

We use the following types of cookies:

• Necessary Cookies: Enable core functionality like authentication, session continuity, and fraud prevention.

• Analytics Cookies: Help us understand how users interact with the Platform so we can improve functionality and performance.

• Advertising Cookies: If used, these cookies may support promotional campaigns or retargeting (e.g., for our own marketing or remarketing via platforms like LinkedIn or Google Ads). Asset Card does not sell Personal Information or allow third parties to profile users for unrelated advertising.

To learn more about cookies, visit https://www.allaboutcookies.org.

How can I manage or opt out of cookies?

Most browsers allow you to manage cookies, including:

• Blocking all or some cookies

• Deleting existing cookies

• Setting preferences per website

You can also use tools such as:

• Google Analytics Opt-out: https://tools.google.com/dlpage/gaoptout

• Digital Advertising Alliance: https://www.aboutads.info/choices

• Network Advertising Initiative: https://www.networkadvertising.org/choices

Disabling some cookies may limit functionality or degrade performance of certain features.

Do Not Track & Global Privacy Control (GPC)

Some browsers support "Do Not Track" (DNT) and Global Privacy Control (GPC) signals. Asset Card honors GPC settings in jurisdictions where required, such as California under the CPRA. However, DNT signals are not currently recognized due to lack of industry-wide standards.

Changes to this Cookie Policy

We may update this Cookie Policy to reflect changes in law, our data practices, or use of cookies. When we do, we will update the “Last Updated” date. Continued use of the Platform after such changes means you accept the revised Cookie Policy.

This Data Processing Addendum (“DPA”) is incorporated into and forms part of the Asset Card Platform Agreement (“Agreement”) between you (“Company”) and ACwallet Inc. d/b/a Asset Card (“Asset Card,” “we,” “us,” or “our”). This DPA is effective upon the date of your acceptance or the date otherwise agreed by the parties (“DPA Effective Date”).

By agreeing to this DPA on behalf of your Company, you represent that you have the legal authority to bind the Company and that you understand and agree to its terms.

1. Definitions

Terms like “Controller,” “Processor,” “Data Subject,” “Personal Data,” “Restricted Transfer,” “Security Incident,” and “Subprocessor” have the meanings set out under applicable data protection laws or as used in the Agreement. “Standard Contractual Clauses” (SCCs) refers to the European Commission-approved clauses for cross-border data transfers.

2. Roles and Applicability

• Company is Controller.

• Asset Card as Processor: When processing data on Company’s behalf to provide Services.

• Asset Card as Controller: When determining purposes and means for regulatory compliance, fraud prevention, risk management, and business operations.

3. Asset Card’s Obligations as Processor

• Instructions: Asset Card processes Personal Data only per Company instructions or as required by law.

• CCPA Compliance: Asset Card certifies it will not sell, share, or use Personal Data outside of direct business relationship except as permitted.

• Security: Asset Card maintains safeguards to prevent unauthorized access, as detailed in Annex 2.

• Security Incidents: Company will be notified without undue delay of any confirmed Security Incident.

• Subprocessors: Company provides general authorization. Changes will be posted at https://trust.assetcard.io.

• Data Subject Requests: Asset Card will support Company in fulfilling verified requests from Data Subjects.

• Assistance: Reasonable support for data protection impact assessments or regulatory inquiries.

• Data Retention: Personal Data will be deleted upon written request after termination, except for necessary legal retention.

• Audits: Records of compliance are available upon request; formal audits subject to written request and reasonable scheduling.

4. Asset Card’s Obligations as Controller

When acting as Controller, Asset Card will process data in accordance with its Privacy Policy and all applicable data protection laws.

5. Company’s Obligations

Company must:

• Ensure lawful data collection and provide required notices/consents.

• Not submit sensitive data unless explicitly allowed in the Agreement.

• Provide accurate, lawful instructions.

6. Cross-Border Transfers

SCCs and the UK Addendum are incorporated by reference for any Restricted Transfers. See Annex 1 and 2 for additional details.

7. Liability and Miscellaneous

Each party’s liability is subject to the limitations set forth in the Agreement. This DPA is governed by the terms and jurisdiction specified in the Agreement.

Annex 1: Details of Processing Activities

A. List of Parties

• Exporter: Company

• Importer: ACwallet Inc. d/b/a Asset Card, 4444 N Flagler Dr, West Palm Beach, FL 33407, USA

• Roles: Company as Controller; Asset Card as Processor and/or Controller

B. Description of Transfer

• Data Subjects: Company personnel, users, and transaction participants

• Categories of Data: Contact info, transaction and receipt data, and other relevant user or business data

• Sensitive Data: May include biometric, financial, or identity verification data (if explicitly permitted)

• Frequency & Purpose: Continuous processing to deliver and improve Services

C. Supervisory Authority

• EU: Irish Data Protection Commission

• UK: Information Commissioner’s Office

Annex 2: Technical and Organizational Measures

Asset Card employs industry-standard technical and organizational measures to protect Personal Data:

• Access Controls: Role-based access, MFA, encryption, and session lockouts

• Data Segregation: Data is logically separated and access is role-restricted

• Monitoring & Audits: System access logs are recorded and reviewed

• Incident Response: Documented plan to detect, report, and mitigate data breaches

• Data Destruction: Deletion via secure overwrite or physical destruction of storage media

• Transmission Security: TLS encryption in transit and secure cloud storage in use

• Vendor Assessments: Subprocessors are vetted and contractually bound to similar obligations

These controls are monitored, reviewed, and updated regularly as part of our comprehensive information security program.

1. Introduction

Asset Card hosts in-person and virtual events—including webinars, conferences, and meetups—to engage with current and prospective customers, partners, and community stakeholders. This Events Privacy Notice explains how we collect, use, and share your Personal Information in connection with these events, and the rights you may have under applicable laws.

2. Categories of Personal Information We Collect and Why

When you register for or attend an Asset Card event, we may collect the following categories of Personal Information:

• Identifiers: Name, email, phone number

• Employment Information: Company name, job title

• Location Data: IP address, city, state

• Health Data: Dietary restrictions, allergies (if voluntarily provided)

• Media: Photos, video, or recordings of the event

• Technical Data: Browser/device information used during virtual events

We use this information to:

• Register and communicate with you before, during, and after the event

• Manage event logistics and provide personalized experiences

• Send event-related updates or future marketing communications

• Maintain security and comply with legal obligations

We rely on a lawful basis such as your consent, our legitimate business interests, or contractual necessity, depending on the context.

Asset Card events are not intended for individuals under the age of 18. We do not knowingly collect or process data from minors.

3. Disclosures of Personal Information

We may share your Personal Information:

• With trusted service providers (e.g., registration platforms, IT vendors, caterers)

• With co-hosts or sponsors, when applicable (you’ll be informed at registration)

• To comply with legal obligations or protect our rights and security

• With government or regulatory bodies if required by law

All third-party service providers are required to protect your Personal Information through appropriate contractual safeguards.

4. Photography & Media Use

By attending an Asset Card event, you acknowledge that you may be photographed or recorded. We may use this media content for promotional or marketing purposes, such as event recaps or social media posts. If you do not wish to be included in such materials, please notify an event organizer onsite or contact us in advance.

5. How to Exercise Your Privacy Rights

Depending on your location, you may have the right to:

• Access or request deletion of your Personal Information

• Object to or restrict certain uses of your data

• Withdraw consent for future marketing

To exercise these rights, please refer to Section 6 (“Your Rights and Choices”) in our Privacy Policy.

6. California Residents – Do Not Sell or Share My Personal Information

California law may classify certain data-sharing practices—such as targeted advertising—as a “sale” or “share” of Personal Information. This may include identifiers, employment details, location, or device data.

You can opt out of these practices by visiting our Your Privacy Choices page or enabling Global Privacy Control (GPC) settings in your browser.

7. International Data Transfers

Your Personal Information may be processed in the United States or other jurisdictions. We implement safeguards such as Standard Contractual Clauses to ensure appropriate protection for any cross-border data transfers. For more information, see Section 7 of our Privacy Policy.

8. Security

We apply administrative, technical, and physical measures to protect your event-related Personal Information from unauthorized access, disclosure, or misuse. No system is completely secure, so please report any concerns to us immediately at security@assetcard.io.

9. Retention

We retain event-related Personal Information only as long as necessary to manage the event, follow up with participants, comply with applicable laws, and protect our legal interests.

10. Contact Us

For questions about this Events Privacy Notice or to exercise your privacy rights:

Email: support@assetcard.io

Mail: ACwallet Inc. d/b/a Asset Card

Attn: Privacy Counsel

28 West 23rd Street, Floor 2

New York, NY 10010

If the event is co-hosted, both Asset Card and the cohost may act as independent data controllers. You will be informed at the time of registration if this applies.

1. Introduction

We appreciate your interest in joining Asset Card. This Applicant Privacy Notice explains what Personal Data we collect during our application and recruitment process, how we use it, and your rights.

2. Applicability

This notice applies to individuals applying for roles with ACwallet Inc. d/b/a Asset Card or its affiliates. It does not apply to customers or users of our services. For that, refer to our Privacy Policy.

3. Personal Data We Collect

We collect Personal Data from the following sources:

• Directly from you (e.g., resume, cover letter, application form, interviews)

• Automatically through our website or application system (e.g., cookies)

• Third parties, such as references, background check services, and public sources like LinkedIn

Examples include:

• Identifiers (e.g., name, email, phone)

• Employment, education, and compensation history

• Demographic or sensitive data (if voluntarily submitted)

• Technical data from devices or browsers

• Communications and assessments

4. How We Use Your Personal Data

We use your Personal Data to:

• Evaluate qualifications and fit for roles

• Verify identity, conduct interviews, and communicate with you

• Improve our hiring process and ensure legal compliance

• Consider you for future opportunities

• Fulfill legal obligations and protect our interests

• Ensure inclusive, non-discriminatory hiring practices

Asset Card is an equal opportunity employer. We do not discriminate on the basis of race, gender, age, disability, religion, sexual orientation, or any other protected status.

If hired, your data becomes part of your employee record.

5. Automated Processing

We may use automated tools or AI-based systems to assist with applicant screening (e.g., keyword matching or skills scoring). These tools do not make final decisions, but support our team in identifying qualified candidates. You may request a human review of any decision affecting you.

6. Third-Party Platforms

If you apply through a third-party job board or recruitment service (e.g., LinkedIn, Indeed), their privacy policies also apply. We are not responsible for how those platforms collect or process your data prior to submission to Asset Card.

7. Disclosure of Personal Data

We may share your Personal Data with:

• Internal teams involved in hiring

• Service providers (e.g., recruitment platforms, background checks)

• Legal authorities as required

• References and other third parties you’ve authorized

All service providers are contractually bound to protect your information.

8. Your Rights and Choices

Depending on your location, you may have the right to:

• Access, correct, or delete your Personal Data

• Object to or restrict processing

• Withdraw consent where applicable

• Appeal decisions related to your privacy requests

To exercise these rights, email support@assetcard.io. We may need to verify your identity before fulfilling your request.

You may opt out of text/SMS communication at any time by replying "STOP." For help, reply "HELP" or visit our support page.

9. International Data Transfers

Your Personal Data may be stored or processed outside your country. Where required, we implement safeguards like Standard Contractual Clauses or rely on adequacy decisions. If you are in Quebec, your data may be stored outside of the province.

10. Lawful Basis for Processing

We rely on:

• Your consent

• Performance of a contract

• Legal obligations

• Legitimate interests

11. Security

We take steps to protect your data through encryption, access control, and monitoring. No system is completely secure, so please report concerns to security@assetcard.io.

12. Retention

We retain applicant data for up to 3 years after the hiring decision unless you request earlier deletion or a longer period is required by law. If hired, your data becomes part of your employment record.

13. Changes to This Privacy Notice

We may update this Notice periodically. We’ll notify you of material changes by updating the date above and posting notices where appropriate.

14. Contact Us; Data Controller

For questions or to exercise your rights:

Email: support@assetcard.io

Mail: ACwallet Inc. d/b/a Asset Card

Attn: Privacy Counsel

28 West 23rd Street, Floor 2

New York, NY 10010

15. California Notice at Collection

A. Categories of Personal Data: Identifiers, education, employment, geolocation, internet activity, communications, and health data (for accommodations).

B. Business Purposes for Use: Hiring, operations, security, fraud prevention, legal compliance.

C. Your Rights: Access, correction, deletion, and non-discrimination. We do not sell or share applicant data. To opt out of tracking on our website, visit Your Privacy Choices.

D. Authorized Agent: You may authorize someone to act on your behalf by providing written consent and identity verification.

1. Introduction

Your privacy is important to Asset Card, and we are committed to managing your Personal Data responsibly. In connection with your work with Asset Card, we collect, process, and store data that identifies or could reasonably identify or be linked to you, your household, or devices ("Personal Data"). This Contractor Privacy Notice explains how we handle this data.

2. Applicability

This notice applies to individual contractors, consultants, and contingent workers ("Contractors") of ACwallet Inc. d/b/a Asset Card. It does not apply to job applicants, employees, or users of our services.

3. Personal Data We Collect

A. From You:

• Contact info: name, phone, email, address, emergency contact

• Employment data: job title, resume, contract terms, certifications

• Financial data: tax details, compensation, reimbursement info

• Sensitive data: criminal records (if applicable)

• Communications and work product (which may be retained for business or compliance purposes)

B. From Third Parties:

• Background check providers, references, and public sources (e.g., LinkedIn)

C. Automatically:

• Cookies, device/browser fingerprints, login timestamps, usage logs from internal tools, and facility access records if applicable

4. How We Use Personal Data

We use Personal Data to:

• Fulfill our contract with you

• Provide access to communication and productivity tools (e.g., Slack, Google Workspace)

• Verify identity and conduct background checks

• Administer compensation, support, and business operations

• Protect our legal rights, ensure compliance, and maintain security

• Retain work product and communications for business or regulatory purposes

5. Disclosure of Personal Data

We may share your Personal Data with:

• Affiliates

• Service providers (e.g., onboarding, collaboration tools, payment processors)

• Investors (as necessary for diligence or compliance)

• Legal authorities and regulators

• Other parties with your consent

All vendors and service providers are contractually required to maintain appropriate data protection standards.

6. Your Rights and Choices

Depending on your jurisdiction, you may:

• Access, correct, or delete your Personal Data

• Restrict or object to processing

• Withdraw consent

• Appeal privacy request decisions

To exercise these rights, email support@assetcard.io. We may need to verify your identity first.

7. International Data Transfers

Your Personal Data may be transferred outside your country, including to the U.S. We apply safeguards such as Standard Contractual Clauses or adequacy decisions where required. Quebec residents should note that data may be stored outside the province.

8. Lawful Basis for Processing

We rely on:

• Performance of a contract

• Legal obligations

• Your consent

• Legitimate interests (e.g., managing contractor relationships, ensuring security)

9. Security

We implement organizational, technical, and physical safeguards to protect your Personal Data. However, no system is fully secure. Report concerns to security@assetcard.io.

10. Retention

We retain contractor records for up to three (3) years after the engagement ends unless longer retention is required by law (e.g., tax or compliance reasons). For details, contact support@assetcard.io.

11. Contact Us; Data Controller

Email: support@assetcard.io

Mail: ACwallet Inc. d/b/a Asset Card

Attn: Privacy Counsel

28 West 23rd Street, Floor 2

New York, NY 10010

12. California Notice at Collection

A. Categories of Personal Information:

• Identifiers (name, contact, device ID)

• Employment and education info

• Financial data (compensation, tax, bank info)

• Internet and device usage

• Geolocation (e.g., IP address)

• Audio/video from virtual meetings or cameras

• Communications and inferences

B. Business Purposes for Disclosure:

• Operations, compensation, compliance, security, and fraud prevention

C. Your Rights:

• Know, access, correct, or delete Personal Data

• No discrimination for exercising rights

• Asset Card does not sell or share contractor Personal Data

D. Authorized Agent:

You may authorize someone to act on your behalf by providing written permission and identity verification.

Do Not Call Policy

ACwallet Inc. d/b/a Asset Card ("Asset Card," "we," "our," or "us") is committed to protecting and respecting individuals’ privacy. As part of that commitment, we strive to comply with applicable federal and state Do Not Call ("DNC") laws and regulations.

This policy applies to promotional or telemarketing calls. Calls related to account servicing, fraud prevention, or compliance may still occur, even if your number is on our Do Not Call list. This policy also applies to promotional text messages sent via SMS, where applicable under the Telephone Consumer Protection Act (TCPA).

We maintain procedures to uphold DNC compliance, including maintaining an internal list of individuals who request not to receive telemarketing calls or SMS messages from us or made on our behalf. We will honor any valid DNC request.

We train employees and require service providers who conduct outreach on our behalf to follow this policy. Training is reviewed periodically, and compliance with DNC rules is mandatory. Asset Card also conducts an annual review of our DNC compliance procedures to ensure alignment with current laws and industry standards.

Anyone making telemarketing calls on behalf of Asset Card must provide their name, the name of the entity on whose behalf the call is being made, and a contact telephone number or address for that entity.

Exemptions: Certain calls may be exempt from DNC restrictions under applicable laws, such as calls to business numbers or to individuals with whom we have an existing business relationship.

How to Submit a Do Not Call Request

You may request, by phone or in writing, that Asset Card stop calling or texting you and add your number(s) to our internal DNC list. While we will ask for your name, address, and telephone number, we will process your request even if only a telephone number is provided. We can only place the numbers you share on the list, so please include all phone numbers you wish to block.

We will not share the information you provide in your DNC request except as required to implement the request or by law.

Your DNC request will be processed within ten (10) business days of receipt and will remain in effect for at least five (5) years. Asset Card may retain opt-out records longer than five years to satisfy compliance or recordkeeping obligations. If you change or add numbers, you must notify us to update the DNC list accordingly.

National Do Not Call Registry

In addition to our internal list, you may register your residential phone number on the National Do Not Call Registry by calling 888-382-1222 or visiting www.donotcall.gov.

Contact Us

If you have questions or would like to receive a printed copy of this Do Not Call Policy, please contact us:

Email: support@assetcard.io

Mail: ACwallet Inc. d/b/a Asset Card

Attn: Privacy Team

28 West 23rd Street, Floor 2

New York, NY 10010

This Authorized User Cardholder Addendum (the “Addendum”) is incorporated into and forms part of the Authorized User Agreement. Capitalized terms not otherwise defined herein have the meanings set forth in the Asset Card User Terms.

The Asset Card is a business charge card issued to the Accountholder through Asset Card's platform. Cards are issued by Celtic Bank, a Utah-chartered, FDIC-insured bank located in Salt Lake City, Utah (the "Issuer"). Card issuance is managed by Stripe, Inc. (“Stripe”), and the program is facilitated by ACwallet Inc. d/b/a Asset Card ("Asset Card," "we," "us," or "our").

These Terms apply to your use of any card issued through the Asset Card platform. "You" or "your" refers to an authorized individual (such as an Administrator or employee) who has been issued a card under the Accountholder’s Asset Card Account.

1. Definitions

• Card: A digital or physical business charge card issued by Celtic Bank.

• Card Account: A sub-account linked to your Asset Card Account.

• Card Limits: Authorized spending limits set by the Accountholder or Administrator.

• Charge: A transaction initiated using the Card.

• Transaction: A request to make a payment for goods, services, or other permitted expenses.

2. Your Card and Card Account

The Card is linked to the Accountholder’s Asset Card Account and may be used only for authorized business purposes. Personal use is strictly prohibited. You are not personally liable for charges made with the Card, but all use must remain within authorized Card Limits. The Card must be activated prior to use, and improper or prohibited use may result in suspension or cancellation.

3. Account Opening Requirements

To comply with U.S. federal law, personal information must be collected to verify your identity. This may include your name, address, date of birth, and government-issued identification. This information is securely processed through Stripe and shared with the Issuer (Celtic Bank) for regulatory compliance.

4. Using Your Asset Card

Cards must be used solely on behalf of the Accountholder. Use outside of business purposes or in violation of Card Limits is prohibited. Asset Card, Stripe, or the Issuer may suspend or cancel your Card at any time due to suspicious, unauthorized, or noncompliant activity.

5. Card Account Holds

Certain transactions, such as hotel or fuel purchases, may place a temporary hold for an amount greater than the actual charge. These holds may reduce your available spending limit until released by the merchant.

6. Card Security

You are responsible for safeguarding the Card details, including the number, expiration date, CVV, and any PIN. Notify your Administrator immediately if the Card is lost, stolen, or compromised.

7. Data Privacy

Asset Card will handle your Personal Data according to our Privacy Policy. The Issuer’s use of data is governed by the Celtic Bank Privacy Policy. By using the Card, you consent to both policies.

If you have questions regarding this Addendum, please contact us at:

Email: support@assetcard.io

Mail: ACwallet Inc. d/b/a Asset Card, 28 West 23rd Street, Floor 2, New York, NY 10010

This Authorized User Agreement (the "Terms") forms a binding agreement between ACwallet Inc., d/b/a Asset Card ("Asset Card," "we," "us," or "our") and you that governs your access to and use of an Account and related Services.

Asset Card provides Services to the business entity (the "Accountholder") that has authorized your access. You are not a direct customer of Asset Card, and any issues related to the Services or charges must be addressed with the Accountholder. Your access is solely for the benefit of the Accountholder and subject to their discretion.

NOTICE OF ARBITRATION AGREEMENT AND CLASS ACTION WAIVER:

By using the Services, you agree to resolve disputes on an individual basis via binding arbitration. Please review Section 7 carefully.

1. Definitions

• Account: An Asset Card account maintained for the Accountholder.

• Administrator: A User appointed by the Accountholder to manage Services. Administrators may issue or revoke access, set limits, and manage Users.

• Card Network: Payment card networks including Visa U.S.A., Inc. and/or Visa International.

• Data: Information provided in connection with the Services.

• Dispute: Any dispute between you, the Accountholder, and Asset Card.

• Issuer: The FDIC-insured bank that issues the Asset Card Payment Card (Celtic Bank).

• Personal Data: Identifiable information relating to a person.

• Asset Card Payment Card / Card: Physical or virtual business payment cards issued by the Issuer and managed through the Accountholder’s Account.

• Services: Services provided by Asset Card to the Accountholder or to you at their direction.

• User: An individual authorized by the Accountholder to access the Services.

2. Access to Services

• You may only access Services authorized by the Accountholder.

• You are responsible for maintaining secure credentials and may not bypass security or use Services outside your authorization.

3. Use of Services

• Services are designed for business use only in support of the Accountholder’s financial operations.

• If required to connect a personal bank account (e.g., for reimbursement), you must ensure all information is accurate.

• Misuse of Services, including fraudulent transactions, may result in immediate termination of access and further investigation.

4. Security & Data Privacy

• Keep login credentials and any related access codes confidential.

• Personal Data is handled according to the Asset Card Privacy Policy.

• If you suspect misuse or a security breach, report it to: security@assetcard.io.

5. Compliance with Law and Platform Terms

• You must comply with all applicable laws and platform policies, including any Acceptable Use Policy (AUP) if provided.

6. Notices

• You agree to receive all notices electronically.

• Legal notices can be sent to:

  General Counsel

  Asset Card

  28 West 23rd Street, Floor 2

  New York, NY 10010

  support@assetcard.io

7. Dispute Resolution by Binding Arbitration and Class Action Waiver

• Disputes must be resolved through individual arbitration under the AAA Commercial Arbitration Rules.

• No class or collective actions are permitted.

• Exceptions: Small claims court filings and efforts to collect debt.

8. Governing Law

• These Terms are governed by the laws of the State of New York, with arbitration under the Federal Arbitration Act.

9. Severability

• If any part of these Terms is deemed invalid, the rest will continue in full effect.

10. Entire Agreement

• These Terms represent the entire agreement between you and Asset Card regarding your access and use of Services.

11. Changes to These Terms

• We may modify these Terms at any time. Material updates will be communicated appropriately.

12. Prohibited Persons

• You confirm you are not subject to sanctions or on any prohibited list (e.g., OFAC).

13. Assignment

• Asset Card may assign these Terms without notice. You may not assign without our prior written consent.

14. Disclaimer of Warranties

• Services are provided “as is” with no warranties. Asset Card disclaims liability for your individual use.

15. Third-Party Sites or Services

• We are not responsible for any third-party services you access through the platform.

16. Limitation of Liability

• Asset Card will not be liable for indirect, special, incidental, or consequential damages.

17. Feedback

• If you provide feedback, we may use it without obligation or compensation.

18. Customer Service

• Contact your Administrator for all account and service matters.

• For technical or security issues, reach out to: support@assetcard.io

Asset Card Accountholder Terms

These Asset Card Accountholder Terms (the "Terms") constitute a legal agreement between Celtic Bank Corporation ("Issuer") and the business entity that has applied for and qualified to participate in the Asset Card spend management program (the "Program") and has opened a Program Account ("Accountholder"). Access to the Program is provided by ACwallet Inc. d/b/a Asset Card ("Platform Provider"), through Stripe, Inc., acting as program manager ("Program Manager"). In these Terms, "we," "us," or "our" refers collectively to Issuer, Platform Provider, and Program Manager. Capitalized terms not defined herein are provided in Section 12 below.

1. Overview of the Program

1.1 Generally

Accountholders can request and receive physical and virtual Cards issued by the Issuer under the Asset Card Program. Authorized Users may use these Cards to make eligible business purchases, subject to credit limits and compliance with these Terms. Repayment is made through a designated payment source. Asset Card facilitates the setup, management, and oversight of these Cards and Accounts in collaboration with the Issuer and Program Manager.

1.2 Agreement

These Terms supplement other agreements you may have with us, including the Platform Agreement between you and Asset Card.

2. Registration

2.1 Generally

Accountholder represents that it is a valid business enterprise using the Program solely for business purposes. Accountholder must provide complete and accurate information about its business, administrators, authorized users, and beneficial owners upon request. Failure to provide updated or accurate information may result in suspension or termination.

2.2 Information from Third Parties

We are authorized to retrieve and verify Accountholder information via third-party sources, including credit reporting agencies. This may be repeated periodically for underwriting or compliance purposes.

3. Using the Program

3.1 Restricted Businesses and Activities

Cards may not be used for unlawful, personal, or prohibited activities. Asset Card and Issuer may block or restrict certain merchant categories or regions, including OFAC-restricted areas.

3.2 Compliance

Accountholder must comply with all applicable laws, Card Network Rules, and Program Guidelines, including AML/KYC requirements.

3.3 Cards and Program Account

All Cards are linked to your Program Account. Credit extended via Card usage must be repaid in accordance with your payment terms. All Cards remain the property of the Issuer and can be suspended or revoked at any time.

3.4 Limits and Available Spend

• Total Spending Limit: A maximum aggregate limit across all Cards.

• Daily/Card Limits: Set and adjusted by Asset Card as needed.

• Available Spend: Determined based on your current balance, holds, and limits.

3.5 Other Limits

We may limit usage by merchant type, transaction size, or frequency. Some Charges may result in holds (e.g., hotel or car rentals) that reduce your available balance until released.

3.6 International Use

Use outside the U.S. may be limited. Foreign transactions are converted to USD using the applicable Card Network's exchange rate on the settlement date.

3.7 Payment Terms

• Account Statements: Viewable in the Dashboard.

• Amounts Due: Pay the full outstanding balance in USD by the due date shown.

• Method of Payment: Payments are debited as per Program Manager instructions. Failure to pay may result in penalties and account suspension.

3.8 Fees and Penalties

Fees may include issuance/replacement, late fees, international use, misuse, and maintenance charges.

3.9 Disputing Charges

Disputes must be raised within 60 days of the charge posting. You should attempt to resolve with the merchant first. If unresolved, file a chargeback via Asset Card Support. Provisional credits may apply at our discretion.

4. Authorized Users

4.1 Generally

Authorized Users must accept the applicable Authorized User Terms. You are responsible for their compliance and activity.

4.2 Servicing

Asset Card manages all user inquiries, including lost/stolen card reports. Accountholder indemnifies Issuer for issues arising from Authorized User disputes.

5. Data Privacy

See the Celtic Bank Privacy Policy and Asset Card’s Privacy Policy for how data is used, collected, and stored. Accountholder is responsible for obtaining consent from users before sharing personal data.

6. Trademarks

If you add custom logos or branding to Cards, you must own or have rights to those marks and grant us permission to use them for Program purposes.

7. Disclaimer

We disclaim all warranties not expressly stated herein. We do not guarantee uninterrupted or error-free service.

8. Limitation of Liability

We are not liable for indirect, incidental, or consequential damages. Our aggregate liability will not exceed fees paid by you over the prior three months.

9. Indemnification

You agree to defend, indemnify, and hold harmless the Issuer, Asset Card, and related parties against losses or claims arising from your or your users’ actions, breaches, or violations.

10. Governing Law & Disputes

10.1 Governing Law

Utah law governs, excluding conflict rules.

10.2 Arbitration

All disputes (excluding IP issues) are subject to binding arbitration in San Francisco, California, under AAA rules. Class actions and jury trials are waived.

11. General

11.1 Notices

Sent electronically via your Dashboard or registered contact email.

11.2 Severability

Invalid provisions are severed; the remainder survives.

11.3 Assignment

You may not assign your Account or obligations without prior written consent. We may assign freely.

11.4 Updates

Terms may be updated and published through the Dashboard or website. Continued use constitutes acceptance.

11.5 Term and Survival

These Terms remain in effect until your Account is closed and all dues are settled. Provisions related to liability and data survive termination.

12. Definitions

• Account: Your Asset Card Program Account.

• Accountholder: The business entity participating in the Program.

• Card: A physical or virtual payment card issued under this Program.

• Card Network: Visa U.S.A., Inc., or any other applicable network.

• Charges: Payments made using a Card.

• Dashboard: The user interface provided to manage your Account.

• Issuer: Celtic Bank Corporation.

• OFAC: Office of Foreign Assets Control.

• Platform Provider: ACwallet Inc. d/b/a Asset Card.

• Program: The Asset Card spend management platform.

• Program Account: The credit line and sub-accounts under the Program.

• Program Guidelines: Policies, schedules, or restrictions provided by Asset Card or the Issuer.

• Program Manager: Stripe, Inc., acting on behalf of the Issuer.

Asset Card Partnership Agreement

This Partnership Agreement (the "Agreement") governs your participation in the Asset Card Partner Program. This Agreement is between you ("Partner") and ACwallet Inc., d/b/a Asset Card ("Asset Card," "we," "our," or "us"). Partner and Asset Card are referred to collectively as the "Parties" and individually as a "Party."

By participating in the Partner Program or referring Leads to Asset Card, you agree to this Agreement. Capitalized terms are defined in Section 21.

1. Partnership Program Obligations

Partner will:

(a) refer Leads through approved Asset Card methods;

(b) maintain accurate records;

(c) accurately represent Asset Card and our Services;

(d) promote our Services positively; and

(e) pre-qualify Leads using our provided guidelines.

2. Marketing and Communication

2.1 General Obligations

All marketing must be pre-approved by Asset Card. Public statements or use of Asset Card branding requires written consent.

2.2 Responsibilities of Parties

Asset Card communicates with its users; Partner communicates with its own users.

2.3 Fees

Partner may not imply fees charged to Leads are Asset Card fees unless approved in writing.

2.4 Compensation

[Insert customized language here to describe how this Partner will be compensated — e.g., flat fee, rev share, performance-based, etc.]

3. Compliance

Partner will not promote Asset Card using misleading, illegal, or unethical methods, nor will it target prohibited categories such as adult content, hate speech, or discriminatory content. Partner must have written consent to refer any Lead.

4. Trademarks and IP

4.1 License

Asset Card grants a limited, non-exclusive, non-transferable, revocable license to use Asset Card trademarks for promoting our Services.

4.2 Ownership

Asset Card retains all rights and goodwill in its IP and Marks. Partner gains no additional rights.

5. Confidentiality

5.1 Obligations

Both Parties agree to protect each other’s Confidential Information for two years post-termination (indefinitely for PII).

5.2 Exceptions

Confidentiality does not apply to information already known, independently developed, or disclosed by law.

5.3 Privacy

Each Party will protect PII per their privacy policies and notify the other of material changes.

5.4 Breach Notification

Each Party must report suspected data breaches involving Confidential Information or PII within 24 hours.

5.5 Data Destruction

Upon termination, each Party must return or destroy the other Party’s Confidential Information.

5.6 Enforcement

A Party may terminate the Agreement and seek legal relief for breaches of confidentiality.

5.7 Records

Both Parties must retain performance records for two years after termination and cooperate in good faith to resolve discrepancies.

5.8 Audit Rights

Asset Card reserves the right to audit Partner’s referral activity and compliance with this Agreement upon reasonable notice.

6. Warranties; Disclaimer

Each Party represents it has the authority and legality to enter into this Agreement and perform its obligations. EXCEPT AS EXPRESSLY STATED, ALL WARRANTIES ARE DISCLAIMED, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.

7. Indemnification

Each Party agrees to indemnify the other against third-party claims arising from its breach, misconduct, or legal violations.

8. Limitation of Liability

EXCLUDING CONFIDENTIALITY BREACHES AND INDEMNITY, NEITHER PARTY’S LIABILITY WILL EXCEED THE GREATER OF $10,000 OR THE FEES PAID IN THE THREE MONTHS BEFORE THE CLAIM. NEITHER PARTY IS LIABLE FOR INDIRECT OR CONSEQUENTIAL DAMAGES.

9. Termination

This Agreement is effective until terminated. Either Party may terminate at any time with notice. Asset Card may suspend the Partner Program or modify terms in its sole discretion.

10. Governing Law

New York law governs. Exclusive venue is New York, NY courts, subject to the arbitration terms below.

11. Dispute Resolution

Disputes will first be addressed via escalation. If unresolved, they will be submitted to arbitration in New York under JAMS rules. The arbitration must be initiated within [INSERT TIME LIMIT] of the dispute arising. The prevailing Party is entitled to recover attorneys’ fees and costs.

12. Waiver of Jury Trial

Each Party waives the right to a jury trial. The prevailing Party in litigation is entitled to reasonable attorneys’ fees.

13. Relationship of the Parties

13.1 Independent Contractors & Non-Solicitation

This Agreement does not create an agency, partnership, or employment relationship. The Parties are independent contractors. During the term of this Agreement and for twelve (12) months thereafter, neither Party shall solicit for employment any employee of the other Party without prior written consent.

14. Notices

You may contact Asset Card at legal@assetcard.io. Notices from Asset Card will be sent to your Console admin contact.

15. Assignment

Neither Party may assign rights or obligations without written consent. Permitted assignments are binding on successors.

16. Enforcement

A Party’s failure to enforce any right will not waive future enforcement.

17. Severability

Invalid provisions will be severed; the remainder of the Agreement remains enforceable.

18. Force Majeure

Neither Party is liable for delays beyond their control, such as natural disasters or strikes.

19. Entire Agreement

This Agreement is the entire agreement between the Parties and supersedes all prior discussions. Modifications must be in writing.

20. Counterparts

This Agreement may be executed electronically or in counterparts.

21. Definitions

• Confidential Information: Proprietary or non-public info disclosed by one Party to the other.

• Console: Asset Card’s web-based admin platform.

• Customer Information: Any information about users shared between the Parties.

• IP: Intellectual property including trademarks, patents, know-how, and copyrights.

• Lead: A business entity referred to Asset Card that meets eligibility requirements.

• Partner: The entity agreeing to this Agreement.

• Partner Services: Services provided by Partner to its customers.

• Asset Card Services: Spend management, cards, and financial tools offered by Asset Card.

• Asset Card User: Any business using Asset Card services.

These Terms of Service (“Terms”) govern your use of the Asset Card platform, operated by ACwallet LLC, doing business as Asset Card (“Asset Card,” “we,” or “us”). By accessing or using Asset Card, you agree to these Terms.

1. Overview of Services

Asset Card provides digital expense management tools tailored to project-based businesses. Users can create digital spend cards, assign them to specific projects, and categorize expenses in real time.

2. Digital Card Issuance and Usage

By using Asset Card, you may request digital spend cards issued through our platform. These cards are managed and provisioned via our financial partner, Stripe. You agree to use these cards solely for authorized business-related transactions. Unauthorized use of digital cards is prohibited and may result in account suspension or termination.

3. Bank Account Linking and Stripe Services

Asset Card leverages Stripe Financial Connections and Stripe Treasury to provide financial infrastructure and bank account integrations. By linking your business bank account, you authorize Stripe and Asset Card to access, initiate transfers, and facilitate payments on your behalf. You must ensure that all linked accounts are valid and owned by your business.

4. User Data and Privacy

We take your privacy seriously. Asset Card does not sell, rent, or share your personal or business data with third parties for marketing purposes. Your data is stored securely and used solely for the purpose of providing and improving our services. For full details, please see our Privacy Policy.

5. Payment Authorization and Security

You are responsible for authorizing all transactions initiated through your Asset Card account. We use two-factor authentication (2FA) and One-Time Password (OTP) technology for added security. Unauthorized or suspicious activity must be reported immediately. Asset Card and Stripe may delay or refuse to process a transaction if we suspect fraud or noncompliance with these Terms.

6. Receipt Uploads and AI-Powered Processing

To improve expense tracking, users may be required to upload receipts for purchases. Asset Card uses Google Cloud and proprietary OCR technology to scan and extract relevant data from uploaded receipts, which are then automatically categorized and matched to the appropriate transaction. By using this feature, you consent to the use of automated tools to process uploaded documents.

7. Prohibited Activities

Users may not:

• Misuse or tamper with the Service

• Use false information or impersonate others

• Engage in fraudulent activity or unauthorized transactions

8. Account Suspension and Termination

We reserve the right to suspend or terminate your access to the Service for violations of these Terms, suspected fraud, or unlawful behavior. You remain responsible for any outstanding transactions or obligations incurred prior to termination.

9. Limitation of Liability

Asset Card is provided “as is” without warranties of any kind. To the maximum extent permitted by law, Asset Card disclaims all liability for any loss or damage resulting from your use of the Service, including any transaction errors, delays, or unauthorized use.

10. Contact Us

If you have any questions about these Terms, please contact us at:

support@assetcard.io

11. Earnings on Held Funds

Funds held in your Asset Card Wallet or linked accounts may be placed in pooled custodial accounts with our financial partners. These funds may generate interest or yield. Asset Card may retain any such earnings and is not obligated to share them with users.

12. Governing Law

These Terms are governed by the laws of the State of New York, without regard to its conflict of law provisions.

This Asset Card Referral Program Agreement (the "Agreement") governs your participation in the Asset Card Referral Program (the "Referral Program") and is between you ("Company," "you," or "your") and ACwallet Inc., d/b/a Asset Card ("Asset Card," "we," "our," or "us"). This Agreement is distinct from the Asset Card Partner Program and any formal affiliate or partnership agreements. Companies interested in commercial partnerships should contact support@assetcard.io.

By sending or using a referral link, you agree to be bound by this Agreement. This Agreement supplements the Asset Card Platform Agreement and is incorporated into it by reference. In the event of a conflict, this Referral Program Agreement will govern. Capitalized terms not defined herein have the meaning given in the Platform Agreement.

1. Eligibility

To participate in the Referral Program, you must:

• Have an active Asset Card account in good standing;

• Ensure all Users distributing referral links are at least 18 years old and authorized to act on your behalf.

2. Qualifying Referrals

You will receive a unique referral link (the "Referral Link") to share with potential customers. A Qualifying Referral must:

• Be a business engaged in commercial activity;

• Not have previously registered with Asset Card;

• Complete registration through your Referral Link;

• Pass Asset Card’s KYC and underwriting review;

• Complete at least $1,000 in statement payments (excluding chargebacks and returns).

You may not:

• Share Referral Links through paid search ads, affiliate networks, or unsolicited email (spam);

• Use the link to self-refer or register affiliated businesses;

• Misrepresent your relationship with Asset Card.

You represent that any individual you refer has consented to receive information and that all outreach complies with applicable laws.

3. Referral Bonus

For each Qualifying Referral, you may receive a Referral Bonus, as posted on the promotion page when the Referral Link was generated. Referral Bonuses may include:

• Virtual cards, statement credits, or other benefits;

• Bonuses issued to you or your authorized User;

• Expiration or additional conditions from third-party providers.

Bonuses may take up to eight (8) weeks to process and are subject to review. Asset Card reserves the right to decline bonuses if referral criteria are not met.

4. Milestone Gifts

You may be eligible for Milestone Gifts based on your total number of Qualifying Referrals. Gifts are:

• Non-transferable and shipped to your provided address;

• Subject to substitution at Asset Card’s discretion;

• Not replaced if lost, damaged, or undeliverable;

• Taxable income for which you are responsible.

5. Taxes

You are solely responsible for reporting Referral Bonuses and Milestone Gifts as income. Asset Card may issue IRS Form 1099 or equivalent if required by law.

6. Privacy

All personal and referral information will be handled in accordance with the Asset Card Privacy Policy. You are responsible for protecting any personal data you share with us and for securing consent where necessary.

7. Intellectual Property

Asset Card retains all rights to its intellectual property. You are granted a limited, revocable, nontransferable license to use the Referral Link solely for lawful participation in the Referral Program. Any unauthorized use is grounds for removal and legal action.

8. Right to Withhold or Cancel Bonuses

Asset Card reserves the right to:

• Cancel, withhold, or adjust Referral Bonuses or Milestone Gifts;

• Suspend or terminate participation if any activity is deemed fraudulent, misleading, unethical, or in violation of this Agreement or applicable law;

• Revoke access to the Referral Program without notice.

9. Termination

This Agreement and the Referral Program may be suspended, modified, or terminated at any time by Asset Card. Termination does not impact earned bonuses prior to termination unless fraud or violation has occurred.

10. Governing Law

This Agreement is governed by the laws of the State of New York, excluding conflicts of law principles.

11. Dispute Resolution

In the event of a dispute, the parties agree to resolve disputes via escalation and, if necessary, binding arbitration. Arbitration will be conducted under [insert chosen arbitration body, e.g., AAA or JAMS] in [insert timeframe], in New York, NY. Each party waives the right to a jury trial and agrees that class or collective actions are not permitted.

12. Entire Agreement

This Agreement constitutes the entire agreement between you and Asset Card regarding the Referral Program. It supersedes any prior agreements or understandings related to the subject matter.

13. Defined Terms

• Referral Link: The unique URL issued by Asset Card for the Referral Program.

• Referral Bonus: Consideration (e.g., virtual card, credit) granted for a Qualifying Referral.

• Qualifying Referral: A referred business that meets the eligibility and transaction criteria.

• Milestone Gifts: Physical or digital rewards granted after a certain number of Qualifying Referrals.

• User: Anyone authorized by you to participate in the Referral Program on your behalf.

This Acceptable Use Policy (“Policy”) describes prohibited and restricted business activities for users of services provided by ACwallet Inc., d/b/a Asset Card (“Asset Card,” “we,” “our,” or “us”). All customers must comply with this Policy as a condition of their use of Asset Card products and services.

Asset Card reserves the right to determine whether any business or activity poses a risk to our platform, reputation, compliance obligations, or financial partners.

If you are unsure whether your business is eligible, please contact: support@assetcard.io

1. Prohibited Activities

Companies primarily engaged in the following activities may not use Asset Card services under any circumstances:

A. Financial and Regulatory Risks

• Engaging with entities, individuals, or countries sanctioned by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC), or any other applicable sanctions list.

• Use of services in violation of Anti-Money Laundering (AML), Know Your Customer (KYC), or Counter-Terrorist Financing (CTF) regulations.

• Creating or using accounts to conceal beneficial ownership or mask business identity.

• Use of Asset Card for personal, household, or non-commercial purposes.

• Operation of money services businesses, including currency exchange, cash disbursement, or money order issuance.

B. Illegal or Unethical Activity

• Sale or distribution of Schedule I controlled substances, or Schedule II–V substances without valid licensing (per the U.S. DEA).

• Production or sale of synthetic drugs, drug paraphernalia, or tools designed to mimic illegal drug effects.

• Unauthorized marijuana production, sales, or distribution, even in states where legal, unless fully licensed and compliant.

• Prostitution, escort services, or unregulated adult entertainment.

• Counterfeit goods, unauthorized resellers, or “grey market” products.

• Use of services for illegal activity or any action that violates applicable law.

C. High-Risk Business Models

• Gambling, lotteries, betting, sweepstakes, or games of chance without approved regulatory licenses.

• Get-rich-quick schemes, multi-level marketing (MLM), or deceptive business practices.

• High-frequency automated purchasing or “bot” reselling on behalf of third parties.

• Drop-shipping operations lacking inventory control or with high chargeback risk.

• Businesses deemed to offer services competitive with Asset Card.

D. Physical Products & Services

• Sale, production, or distribution of firearms, ammunition, weapons, or related accessories (as determined by Asset Card).

• Massage parlors, unless clearly operating as licensed wellness centers.

2. Restricted Activities

Businesses engaged in the following activities may require enhanced due diligence, documentation, or be subject to additional restrictions or account limitations:

• Cryptocurrency trading, purchase, sale, or mining operations.

• Dealers in conflict minerals, precious metals, or rare stones.

• Religious organizations primarily operating places of worship.

• Municipalities, state agencies, or local government bodies.

• Political organizations, including PACs or campaign fundraising operations.

• Businesses selling tobacco, vaping, or e-cigarette products.

• Pharmaceutical manufacturers or distributors.

• Professional service providers, such as law firms, consultants, or investment advisors.

• Any other business deemed high-risk at Asset Card’s sole discretion.

3. Enforcement and Changes

Asset Card may deny access, suspend accounts, or revoke services based on violations or perceived risk.

We reserve the right to:

• Modify this Policy at any time, with updates posted to our website.

• Evaluate businesses on a case-by-case basis, even if not explicitly listed above.

• Take enforcement action at our sole discretion, without notice.

4. Contact and Questions

If you have questions about this Policy or your eligibility to use Asset Card, please contact:

📩 support@assetcard.io

🌐 Or visit: https://assetcard.io