Terms of Service

These Terms of Service (“Agreement”) govern your use of the technology platform and related services provided by TreasuryPath Inc. (“TreasuryPath,” “Company,” “we,” “us,” or “our”). By registering for, accessing, or using the Services, you (“Client,” “you,” or “your”) agree to be legally bound by this Agreement. If you do not agree to these terms, you may not use the Services.

Definitions

“Affiliate” means, with respect to any entity, any other entity that directly or indirectly controls, is controlled by, or is under common control with such entity.

“AI Features” means any artificial intelligence, machine learning, or automated analysis features made available through the Platform, including cash forecasting, anomaly detection, scenario simulation, smart payment routing, and AI-generated reports.

“AML/KYC Laws” means applicable U.S. federal and state anti-money laundering, Bank Secrecy Act, know-your-customer, customer identification program, beneficial ownership identification, and similar laws and regulations applicable to the Services.

“API” means TreasuryPath’s application programming interface, including all related documentation, tools, and credentials, but excluding any Client-built applications that use the API.

“Chargeback” means any return, refund, clawback, reversal, or dispute of a payment transaction, including but not limited to ACH returns, wire reversals, and regulatory clawbacks, in each case not caused by TreasuryPath’s breach, gross negligence, or willful misconduct.

“Client Data” means all data, information, and materials provided by Client or collected through Client’s use of the Services, excluding Transaction Data.

“Compliance Laws” means applicable U.S. federal and state financial services laws and regulations, including AML/KYC Laws, OFAC sanctions regulations, and privacy laws, in each case to the extent applicable to Client’s use of the Services.

“Confidential Information” means any non-public information disclosed by one party to the other that is designated as confidential or that reasonably should be understood to be confidential given the nature of the information and circumstances of disclosure. TreasuryPath’s Confidential Information includes the Platform, API, pricing, product roadmap, and proprietary business data. Client’s Confidential Information includes Client Data and Transaction Data.

“Documentation” means all user manuals, technical specifications, API documentation, and other materials provided by TreasuryPath relating to the Services.

“Licensed Provider” means a regulated financial institution or money services business that provides payment processing, ACH origination, wire transfer, compliance monitoring, fund custody, or other licensed financial services in connection with the Platform.

“Platform” means TreasuryPath’s proprietary software-as-a-service technology platform for treasury management, including all modules, interfaces, AI Features, APIs, and related tools made available to Client under this Agreement.

“Service Partners” means Licensed Providers and all other third-party technology, data, infrastructure, and financial service providers whose services are incorporated into or accessed through the Platform, including without limitation bank connectivity aggregators, stablecoin infrastructure providers, and payment network operators.

“Services” means access to and use of the Platform, including: bank account aggregation and cash visibility; ACH payment initiation (debit and credit); domestic and international wire transfer initiation; payment approval workflow management; foreign exchange management; the TPUSD stablecoin product (subject to the TPUSD Product Terms); AI Features; API access; and related technology services, in each case as made available by TreasuryPath from time to time.

“Third-Party Terms” means the terms of service, user agreements, and other contractual terms of Service Partners applicable to Client’s use of their services through the Platform.

“TPUSD” means a USD-denominated stablecoin issued by Brale Inc. and made accessible to Clients through the Platform, subject to the TPUSD Product Terms.

“Transaction Data” means payment instructions, transaction details, and related financial data processed through the Services.

Service Description and Regulatory Framework

Nature of Services

TreasuryPath provides a technology platform only. We are not a bank, credit union, money services business, money transmitter, or other regulated financial institution. TreasuryPath is not engaged in the transmission of money. We do not hold, custody, or control Client funds. We do not provide financial advice, investment advice, legal advice, or tax advice. TreasuryPath may conduct platform-level risk monitoring for its own operational and security purposes; it does not conduct BSA/AML compliance monitoring or file suspicious activity reports on behalf of clients. Those obligations are performed exclusively by Licensed Providers.

Service Partners

The Services are delivered in part through Service Partners. Key current Service Partners include:

• Airwallex US, LLC (NMLS #1928093) - Payment processing, ACH origination, wire transfer, and foreign exchange services for US customers. Airwallex is a licensed money transmitter in most states. Airwallex’s terms are available at airwallex.com/us/terms. State license information is available at airwallex.com/us/state-licenses.
• Evolve Bank & Trust (Member FDIC) - Sponsor bank for TreasuryPath payment accounts.
• Brale Inc. - Stablecoin infrastructure and TPUSD issuance. Brale’s terms govern TPUSD transactions.
• Plaid Inc. - Bank account data aggregation and connectivity. Plaid’s End User Privacy Policy applies at plaid.com/legal/end-user-privacy-policy.
• Quiltt Inc. - Supplemental bank account connectivity.

TreasuryPath will provide thirty (30) days’ prior written notice of material changes to Service Partner arrangements that affect fund custody, payment processing, or KYC/identity verification services. For non-material operational changes, TreasuryPath may update Service Partners without advance notice. If a material Service Partner change adversely affects your use of the Services, you may terminate this Agreement by providing written notice to TreasuryPath within thirty (30) days of receiving notice of such change.

Use of the Services constitutes acceptance of the applicable Third-Party Terms for each Service Partner whose services you access. TreasuryPath has no control over Service Partner decisions, performance, availability, or compliance actions. Service Partners may independently approve, reject, suspend, or terminate your access to their services.

FDIC Disclosure

TreasuryPath is not a bank and is not FDIC-insured. Client funds held in TreasuryPath payment accounts are held at Evolve Bank & Trust, Member FDIC. Standard FDIC deposit insurance covers up to $250,000 per depositor per insured institution, per account ownership category, subject to applicable FDIC eligibility requirements. Where funds are held in omnibus or for-benefit-of (FBO) structures, pass-through FDIC coverage is subject to satisfaction of FDIC requirements regarding account titling, recordkeeping, and applicable regulatory conditions - coverage is not guaranteed and clients should not assume all balances are insured. FDIC insurance protects against the failure of an insured bank, not against losses resulting from market fluctuations, fraud, unauthorized transactions, or erroneous payment instructions. Clients with balances that may exceed applicable coverage limits should consult their financial advisor.

TPUSD is not a bank deposit and is not eligible for FDIC insurance or any government guarantee. See the TPUSD Product Terms for applicable disclosures.

TPUSD Product

Client’s access to and use of TPUSD is governed by the TPUSD Product Terms available at treasurypath.com/resources/tpusd-terms, which are incorporated into this Agreement by reference. The following additional terms apply:

• TPUSD is issued by Brale Inc. TreasuryPath provides the technology interface through which Clients may access TPUSD; TreasuryPath is not the issuer of TPUSD and makes no representations regarding the reserves, value, or regulatory status of TPUSD.
• TPUSD is not a bank deposit, is not FDIC-insured, and does not carry any guarantee of value from TreasuryPath or any government entity.
• Redemption of TPUSD to USD is processed via Brale’s ACH credit rails and is subject to NACHA settlement timelines (standard 1-3 business days) and Brale’s processing windows for Same-Day ACH.
• Blockchain transactions are irreversible. TreasuryPath is not responsible for TPUSD transferred to incorrect addresses or lost due to user error, protocol failures, or third-party actions.
• Regulatory treatment of stablecoins is evolving. TreasuryPath may modify or discontinue the TPUSD product if required by applicable law or regulatory guidance, without liability, subject to the Regulatory Changes section below.

AI Features Disclaimer

AI Features provide automated analysis, forecasts, and recommendations based on Client Data and platform algorithms. AI-generated outputs are provided for informational purposes only. TreasuryPath does not warrant the accuracy, completeness, or fitness for any purpose of AI-generated outputs. Client is solely responsible for independently verifying AI outputs before making financial or operational decisions. AI Features are not a substitute for professional financial, legal, tax, or investment advice.

No Financial Services

TreasuryPath does not:

• Hold, custody, or control Client funds (these are held by Licensed Providers)
• Process payments or money transfers (these are performed by Service Partners)
• Provide banking, lending, or investment services
• Make credit or underwriting decisions
• Conduct BSA/AML compliance monitoring or file suspicious activity reports on behalf of clients
• Provide financial, investment, legal, tax, or regulatory advice

Client Eligibility and Representations

Eligibility Requirements

The Services are designed and intended for business use only. Individuals may not use the Services in a personal or consumer capacity.

To use the Services, you must:

• Be a business entity duly organized and in good standing under applicable law
• Have authority to enter into this Agreement and perform your obligations hereunder
• Maintain all necessary licenses and permits for your business operations
• Meet Service Partner onboarding and compliance requirements

Ongoing Representations

You represent, warrant, and covenant that:

• All information provided to TreasuryPath and Service Partners is true, accurate, complete, and current
• You will promptly update any information that becomes inaccurate or incomplete
• Your use of the Services complies with all applicable Compliance Laws
• You are not subject to sanctions or prohibited person lists maintained by OFAC or other applicable authorities
• You will not use the Services for prohibited activities as described in this Agreement
• You have implemented appropriate AML/KYC compliance programs for your business

Account Registration and Verification

Account Creation

You must create an account to access the Services. You are responsible for maintaining the confidentiality and security of your account credentials and for all activities conducted through your account.

Verification Process

You authorize TreasuryPath and Service Partners to conduct identity verification (KYB/KYC), background checks, beneficial ownership screening, and compliance screening as required for onboarding and ongoing monitoring. You authorize TreasuryPath and Service Partners to request additional documentation as reasonably required and to share information with regulatory authorities and law enforcement as required by applicable law. Data collected in connection with verification may be processed by Service Partners and their subprocessors in accordance with applicable Third-Party Terms and TreasuryPath’s Privacy Policy.

Account Approval

Service Partners have sole and absolute discretion to approve, reject, suspend, or terminate your account or access to their services for any reason, including compliance, risk, or operational concerns. TreasuryPath has no ability to override Service Partner decisions.

Platform Access and API Services

License Grant

Subject to your compliance with this Agreement, TreasuryPath grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Platform and API solely for your internal business purposes during the term of this Agreement.

API Usage

You must:

• Safeguard API keys and credentials and not share them with unauthorized parties
• Comply with rate limits, usage restrictions, and security requirements in the Documentation
• Implement appropriate security measures for systems accessing the API
• Not reverse engineer, decompile, or disassemble the API or Platform

This Agreement does not restrict your right to build Client applications that interface with the API in accordance with the Documentation.

Platform Availability

We do not guarantee continuous, uninterrupted, or error-free operation of the Platform. Platform availability may be affected by Service Partner outages, banking system disruptions, regulatory requirements, scheduled maintenance, or other causes beyond TreasuryPath’s control. We will use commercially reasonable efforts to provide advance notice of scheduled maintenance.

Fees and Payment Terms

TreasuryPath Fees

You agree to pay all applicable fees as specified in your order form or service plan. TreasuryPath may modify fees applicable to your account by providing at least thirty (30) days’ prior written notice. Fee changes do not apply to fees locked under a separately executed order form during the applicable lock period. All fees are non-refundable except as expressly stated in your order form or as required by applicable law.

Service Partner Fees

Service Partners may impose separate fees, reserves, holdbacks, and charges for their services. You are responsible for all Service Partner fees and charges. TreasuryPath will use reasonable efforts to make you aware of known Service Partner fees applicable to your use of the Services.

Payment of Fees

Fees are due according to the payment terms in your order form or service plan. Undisputed invoices not paid within thirty (30) days of the due date accrue interest at the lesser of 1.5% per month or the maximum rate permitted by law. TreasuryPath may suspend Services for non-payment after providing written notice and a ten (10) day opportunity to cure. You are responsible for all applicable taxes on fees paid to TreasuryPath.

Client Obligations and Use Restrictions

Prohibited Activities

You may not use the Services for:

• Unlawful, fraudulent, or deceptive activities
• Money laundering, terrorist financing, sanctions evasion, or any activity prohibited by OFAC or applicable AML/KYC Laws
• Processing payments for illegal goods or services
• Gambling, adult content, or other high-risk activities as defined in TreasuryPath’s Acceptable Use Policy (published at treasurypath.com/resources/acceptable-use) unless specifically pre-approved in writing by TreasuryPath
• Activities that violate applicable Third-Party Terms or Compliance Laws
• Circumventing compliance, monitoring, or risk controls

System Security

You must implement and maintain reasonable administrative, technical, and physical security measures to protect your account, API access, and data. You must immediately notify TreasuryPath of any security breaches, unauthorized access, or suspected compromise of your account credentials.

Confidentiality

Obligations

Each party agrees to: (a) hold the other party’s Confidential Information in strict confidence using at least the same degree of care it uses for its own confidential information of similar sensitivity (but no less than reasonable care); (b) not disclose Confidential Information to any third party without the disclosing party’s prior written consent, except to employees, contractors, Affiliates, or advisors who have a need to know and are bound by confidentiality obligations no less protective than those in this Agreement; and (c) use the other party’s Confidential Information only for purposes of performing obligations or exercising rights under this Agreement.

Confidential Information may also be disclosed to a prospective acquirer or investor in connection with a bona fide M&A or financing transaction, provided such recipient is bound by written confidentiality obligations no less protective than those in this Agreement.

AI Training Restriction

TreasuryPath will not use Client Data or Transaction Data to train generalized AI or machine learning models made available to third parties without Client’s prior written consent. TreasuryPath may use anonymized, aggregated data derived from Client’s use of the Services that does not identify Client or any individual to improve and develop its products and services.

Exclusions

Confidential Information does not include information that: (a) is or becomes publicly known through no breach of this Agreement; (b) was rightfully known by the receiving party before disclosure without restriction; (c) is rightfully obtained from a third party without restriction on disclosure; or (d) is independently developed by the receiving party without reference to or use of the disclosing party’s Confidential Information.

Required Disclosure

If required by law, regulation, or court order to disclose Confidential Information, the receiving party will, to the extent permitted by law and practicable, provide prompt prior written notice to the disclosing party and cooperate with efforts to seek a protective order or other appropriate relief.

Injunctive Relief

Each party acknowledges that unauthorized disclosure or use of Confidential Information may cause irreparable harm for which monetary damages may be an inadequate remedy, and that either party may seek injunctive or other equitable relief in any court of competent jurisdiction without first exhausting informal resolution or arbitration.

Return or Destruction

Upon termination of this Agreement or upon the disclosing party’s written request, the receiving party will promptly return or destroy all Confidential Information of the disclosing party in its possession or control, and will certify such return or destruction in writing upon request. Each party may retain: (a) archival or backup copies created in the ordinary course of business, subject to continuing confidentiality obligations; and (b) Confidential Information required to be retained under applicable law or regulation.

Survival

Confidentiality obligations survive termination of this Agreement. Obligations with respect to trade secrets continue for as long as the information constitutes a trade secret under applicable law. Obligations with respect to other Confidential Information continue for three (3) years following termination.

Risk Allocation and Liability Framework

Client Risk Assumption

You acknowledge and agree that:

• You bear responsibility and liability for Chargebacks, returns, reversals, disputes, and related losses, fees, and expenses, except to the extent directly caused by TreasuryPath’s breach of this Agreement, gross negligence, or willful misconduct
• You are solely responsible for compliance with all applicable laws and regulations governing your business and use of the Services
• Payment timing, processing, and availability depend on Service Partners and external payment networks over which TreasuryPath has no control
• AI Features provide informational outputs only; you are solely responsible for decisions made in reliance on AI outputs
• The Platform is provided on an “as is” basis without guarantees of performance, availability, or compatibility

Indemnification by Client

You agree to indemnify, defend, and hold harmless TreasuryPath and its officers, directors, employees, and agents from and against any third-party claims, losses, damages, liabilities, and expenses (including reasonable attorneys’ fees) arising directly from: (a) your material breach of this Agreement; (b) your violation of applicable laws or regulations; (c) Chargebacks or transaction disputes arising from your instructions or your clients’ actions; or (d) your gross negligence or willful misconduct in connection with the Services.

Indemnification by TreasuryPath

TreasuryPath agrees to indemnify, defend, and hold harmless Client and its officers, directors, employees, and agents from and against any third-party claims, losses, damages, liabilities, and expenses (including reasonable attorneys’ fees) arising from a claim that the Platform, as provided by TreasuryPath and used by Client in accordance with this Agreement and the Documentation, infringes any U.S. patent, copyright, trademark, or trade secret of a third party. This indemnity does not apply to claims arising from Client modifications, Client Data, third-party components, or combinations not authorized by TreasuryPath.

Limitation of TreasuryPath Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

• TreasuryPath shall not be liable for any indirect, incidental, special, punitive, or consequential damages, including lost profits, loss of data, or business interruption, even if advised of the possibility of such damages.
• TreasuryPath’s total aggregate liability for any and all claims arising under this Agreement shall not exceed the greater of (a) the fees paid by Client to TreasuryPath in the twelve (12) months immediately preceding the event giving rise to the claim, or (b) $5,000.
• TreasuryPath is not liable for acts, omissions, errors, or decisions of any Service Partner, except to the extent such acts or omissions were directly caused by TreasuryPath’s own breach of this Agreement, negligence, or willful misconduct in selecting, configuring, or instructing such Service Partner.

The foregoing liability limitations do not apply to: (a) either party’s breach of its confidentiality obligations under this Agreement; (b) either party’s gross negligence, willful misconduct, or fraud; (c) TreasuryPath’s data security obligations; or (d) either party’s indemnification obligations under this Agreement.

Data Handling and Privacy

Data Ownership and License

You retain ownership of Client Data. You grant TreasuryPath a non-exclusive, worldwide, royalty-free license to use Client Data solely to: (a) provide the Services; (b) comply with legal obligations; and (c) enforce this Agreement. TreasuryPath may use anonymized, aggregated data derived from your use of the Services that does not identify you or any individual to improve and develop its products and services, subject to the AI Training Restriction in the Confidentiality section.

Data Security

TreasuryPath will implement and maintain reasonable administrative, technical, and physical safeguards designed to protect Client Data and Transaction Data against unauthorized access, disclosure, or destruction. In the event of a confirmed security incident involving unauthorized access to Client Data or Transaction Data, TreasuryPath will notify Client within seventy-two (72) hours of confirming the incident (subject to any law enforcement hold) and will cooperate with Client’s reasonable investigation and remediation efforts. TreasuryPath will ensure that any subcontractors who process Client Data on its behalf are bound by data protection obligations no less protective than those in this Agreement.

Service Partner Data Sharing

You acknowledge that Service Partners collect and process Client Data and Transaction Data directly and independently in accordance with their own terms and privacy policies. Service Partners may share data with regulators, law enforcement, and third parties as required by applicable law. TreasuryPath may receive limited Transaction Data from Service Partners for platform functionality, reporting, and support purposes.

Privacy Compliance

Our collection and use of personal information is governed by our Privacy Policy, available at treasurypath.com/resources/privacy-policy, which is incorporated into this Agreement by reference. You must comply with all applicable privacy and data protection laws in connection with your use of the Services, including with respect to any personal data of your employees, contractors, or clients that you submit through the Platform.

To the extent applicable, TreasuryPath processes personal information on Client’s behalf as a “service provider” under the California Consumer Privacy Act (CCPA) and as a “processor” under applicable data protection laws. TreasuryPath will not sell or share personal information processed on Client’s behalf, use it for commercial purposes outside this Agreement, or retain, use, or disclose it beyond what is necessary to provide the Services.

Intellectual Property

TreasuryPath IP

The Platform, API, Documentation, AI Features, and all related intellectual property are and remain the exclusive property of TreasuryPath and its licensors. No ownership rights are transferred to you under this Agreement.

Restrictions

You may not:

• Copy, modify, distribute, or create derivative works of TreasuryPath’s Platform, API, or Documentation
• Reverse engineer, decompile, or disassemble the Platform or API
• Use TreasuryPath trademarks or service marks without prior written permission
• Remove or alter any proprietary notices or labels

Feedback

If you provide TreasuryPath with feedback, suggestions, or ideas regarding the Services, you grant TreasuryPath a non-exclusive, perpetual, irrevocable, royalty-free, transferable, and sublicensable license to use and incorporate such feedback into its products and services without compensation or attribution to you.

Disclaimers and Warranties

Disclaimer of Warranties

THE SERVICES, INCLUDING THE PLATFORM, API, AI FEATURES, AND ACCESS TO THE TPUSD PRODUCT, ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, TREASURYPATH DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, TITLE, AND THOSE ARISING FROM COURSE OF DEALING OR USAGE OF TRADE.

No Service Guarantees

TreasuryPath does not warrant that:

• The Services will be uninterrupted, timely, secure, or error-free
• Any Service Partner will approve your account or process any particular transaction
• AI Features will produce accurate, complete, or reliable outputs
• The Services will meet your specific requirements or business objectives
• Any defects or errors will be corrected within a specified time

Regulatory Changes

TreasuryPath operates in a rapidly evolving regulatory environment. If any applicable law, regulation, order, or guidance from a regulatory authority makes it impractical or unlawful for TreasuryPath or any Service Partner to provide all or any portion of the Services as currently offered, TreasuryPath may, without liability, modify, suspend, or discontinue the affected Services. TreasuryPath will use commercially reasonable efforts to provide advance written notice of such changes and to minimize disruption to Client’s operations. This provision applies without limitation to changes affecting stablecoin products, payment operations, bank sponsorship arrangements, or money transmission requirements.

Suspension and Termination

TreasuryPath Termination Rights

We may immediately suspend or terminate your access to the Services for:

• Material breach of this Agreement not cured within ten (10) days of written notice (or immediately for breaches involving fraud, illegal activity, or security incidents)
• Compliance, risk management, or security reasons
• Suspension or termination of services by a Service Partner
• Violation of Compliance Laws or prohibited activities
• For convenience upon thirty (30) days’ prior written notice

Effects of Termination

Upon termination of this Agreement:

• Your right to access and use the Services immediately ceases
• You remain liable for all fees, Chargebacks, and outstanding obligations incurred prior to termination
• TreasuryPath will provide Client Data in a standard machine-readable format upon written request made within thirty (30) days of termination; TreasuryPath will have no obligation to retain Client Data after sixty (60) days following termination
• Pending transactions at the time of termination will be processed or cancelled in accordance with Service Partner procedures; any outstanding TPUSD balance must be redeemed by Client in accordance with the TPUSD Product Terms prior to account closure
• Survival provisions remain in effect as specified below

Survival

The following provisions survive termination of this Agreement for any reason: Definitions, Confidentiality (for the periods specified therein), Risk Allocation and Liability Framework, Data Handling and Privacy, Intellectual Property, Disclaimers and Warranties, and Dispute Resolution.

Dispute Resolution

Informal Resolution

Before initiating formal proceedings, the parties will attempt to resolve any dispute through good-faith negotiation for a period of thirty (30) days following written notice of the dispute.

Binding Arbitration

Any dispute not resolved informally shall be submitted to and finally resolved by binding arbitration administered by JAMS. Claims under $250,000 shall be administered under JAMS Streamlined Arbitration Rules. Claims of $250,000 or more shall be administered under JAMS Comprehensive Arbitration Rules. The arbitration shall be conducted in New York, New York, with one arbitrator mutually selected by the parties (or appointed by JAMS). The parties each agree to pay one-half of JAMS administrative and arbitrator fees, subject to reallocation by the arbitrator for good cause. The arbitrator shall have authority to determine the arbitrability of any dispute. The arbitrator’s award shall be final and binding and may be entered as a judgment in any court of competent jurisdiction.

Class Action Waiver

YOU WAIVE ANY RIGHT TO PARTICIPATE IN ANY CLASS ACTION, REPRESENTATIVE PROCEEDING, COLLECTIVE ARBITRATION, OR PRIVATE ATTORNEY GENERAL ACTION. DISPUTES MUST BE BROUGHT SOLELY ON AN INDIVIDUAL BASIS. IF THIS WAIVER IS FOUND UNENFORCEABLE, THE ARBITRATION PROVISION SHALL NOT APPLY TO THAT CLAIM.

Jury Trial Waiver

TO THE EXTENT ANY DISPUTE IS BROUGHT IN COURT, EACH PARTY IRREVOCABLY WAIVES ANY RIGHT TO A TRIAL BY JURY IN ANY ACTION, PROCEEDING, OR CLAIM ARISING UNDER OR RELATING TO THIS AGREEMENT.

Exceptions

Either party may seek immediate injunctive or other equitable relief in any court of competent jurisdiction to protect intellectual property rights or Confidential Information, without first exhausting the negotiation or arbitration process and without waiving any right to subsequently submit the matter to arbitration. Either party may also bring qualifying claims in small claims court in lieu of arbitration.

Arbitration Costs

For claims that do not exceed $25,000, TreasuryPath will pay all JAMS filing and administrative fees, provided the claim is not found by the arbitrator to be frivolous. For claims exceeding $25,000, the parties each agree to pay one-half of JAMS administrative and arbitrator fees, subject to reallocation by the arbitrator for good cause.

Opt-Out

If you do not wish to be bound by the mandatory arbitration provision, you may opt out by sending written notice to legal@treasurypath.com within thirty (30) days of first accepting this Agreement. Opting out of arbitration does not affect any other provision of this Agreement.

General Provisions

Governing Law

This Agreement is governed by the laws of the State of Delaware, without regard to its conflict of law principles.

Modifications to This Agreement

We may modify this Agreement by posting updated terms at treasurypath.com/resources/terms-of-service and providing at least thirty (30) days’ prior written notice to Client. Your continued use of the Services after the effective date of any modification constitutes acceptance of the modified terms. If you do not agree to a modification, your sole remedy is to terminate this Agreement prior to the effective date of the modification. Notwithstanding the foregoing, TreasuryPath will not unilaterally modify the dispute resolution provisions, limitation of liability, indemnification obligations, or governing law without Client’s affirmative written consent, unless such modification is required by applicable law, regulatory mandate, or Service Partner requirement.

Individual Order Forms

Where Client has executed a separately signed order form or agreement with TreasuryPath, the terms of such order form govern with respect to the specific matters addressed therein (including pricing, term, arbitration forum, and governing law), and this Agreement governs all other matters.

Notice

Notices to TreasuryPath must be sent via email to legal@treasurypath.com or by certified mail to TreasuryPath Inc., Attn: Legal, at TreasuryPath’s principal place of business. Notices to Client will be sent to the email address on file in Client’s account. Notices are effective on the date received.

Relationship of the Parties

The parties are independent contractors. Nothing in this Agreement creates a partnership, joint venture, employment, agency, or franchise relationship between the parties.

No Third-Party Beneficiaries

This Agreement is for the sole benefit of the parties and their permitted successors and assigns. Nothing in this Agreement, express or implied, is intended to or shall confer upon any third party any legal or equitable right, benefit, or remedy of any nature.

Publicity

Neither party will issue any press release or public announcement regarding this Agreement or the relationship between the parties without the other party’s prior written consent, except as required by applicable law or stock exchange rules.

Export Compliance

Client agrees to comply with all applicable U.S. export control laws and regulations and OFAC sanctions programs. Client will not use the Services to facilitate transactions involving sanctioned countries, entities, or individuals.

Waiver

No failure or delay by either party in exercising any right under this Agreement constitutes a waiver of that right. Waivers must be in writing to be effective.

Assignment

Client may not assign or transfer this Agreement or any rights or obligations hereunder without TreasuryPath’s prior written consent. TreasuryPath may assign this Agreement in connection with a merger, acquisition, corporate restructuring, or sale of substantially all of its assets without Client’s consent. Any purported assignment in violation of this section is void.

Severability

If any provision of this Agreement is found to be invalid or unenforceable, that provision will be modified to the minimum extent necessary to make it enforceable, and the remainder of this Agreement will continue in full force and effect.

Electronic Communications

Client consents to receive all notices, disclosures, and communications from TreasuryPath electronically (by email or through the Platform) and agrees that electronic communications satisfy any legal requirement for written communications. Client consents to the use of electronic signatures.

Force Majeure

Neither party is liable for any delay or failure in performance resulting from causes beyond its reasonable control, including acts of God, government actions, regulatory changes, banking system outages, payment network failures, internet or telecommunications disruptions, natural disasters, or failures of Service Partners, provided the affected party gives prompt written notice and uses commercially reasonable efforts to resume performance.

Entire Agreement

This Agreement, together with any executed order forms, the Privacy Policy, and the TPUSD Product Terms (if applicable), constitutes the entire agreement between the parties with respect to the Services and supersedes all prior negotiations, representations, warranties, and agreements. In the event of a conflict between this Agreement and an executed order form, the order form controls with respect to the matters it addresses.

Acknowledgments

By using the Services, you acknowledge and confirm that:

• TreasuryPath is a technology platform provider only and is not a bank, money transmitter, or regulated financial institution
• Client funds in TreasuryPath payment accounts are held by Evolve Bank & Trust, Member FDIC, subject to standard FDIC coverage limits and eligibility requirements; TreasuryPath itself is not FDIC-insured
• Payment processing, ACH, wire transfer, and compliance services are provided by Service Partners, not TreasuryPath
• TPUSD is not a bank deposit, is not FDIC-insured, and is issued by Brale Inc., not TreasuryPath
• AI Features provide informational outputs only and are not financial, legal, investment, or tax advice
• You have read, understood, and agree to be bound by the Third-Party Terms applicable to each Service Partner whose services you access
• You assume full responsibility for all risks associated with your use of the Services except as expressly allocated to TreasuryPath in this Agreement

Contact Information:

TreasuryPath Inc.
Email: legal@treasurypath.com
Phone: +1 201-987-5629

Last Updated: March 24, 2026