P2P Payments

1. Purpose and Scope

1.1. These Terms and Conditions — P2P Payments (the "P2P Terms") govern exclusively your access to and use of the P2P Payments feature within the Luca Money application (the "App"), operated by Luca Money ("Luca", "we", "us"). P2P Payments allows you to add Digital Dollars to your Luca Account using local currency, withdraw Digital Dollars to a local bank or payment account, and pay QR codes in supported countries.

1.2. The P2P Terms supplement Luca's general Terms and Conditions (the "General Terms"), available at www.lucamoney.com/termsAndConditions. Anything not addressed here is governed by the General Terms. In the event of any conflict regarding P2P Payments, these P2P Terms prevail.

1.3. By starting a buy, sell or QR payment order through the App, you confirm that you have read, understood and accepted these P2P Terms. If you do not agree, do not use the feature.

2. Definitions

3. Nature of the Service and Luca's Role

3.1. Luca only provides a technology interface, integrated into the App, that connects your Luca Account to P2P.me. Luca is not a Protocol Operator, a Merchant, an exchange, a broker, a money transmitter, a remittance company or a payment institution, and is not a party to any Order.

3.2. Each Order is executed between you and a Merchant. P2P.me assigns the Merchant automatically, based on criteria such as the Digital Dollars the Merchant has staked and its reputation. You do not choose the Merchant, and the App may not show who fulfills your Order.

3.3. Luca never receives, holds or transfers local currency. Local currency moves only between your own bank or payment account and the Merchant's account through the Payment Rail.

3.4. Your Luca Account is self-custodial. When you confirm a Sell Order or a QR Payment, your Digital Dollars leave your Luca Account and are locked in the Escrow until the Order is completed, cancelled or resolved. While they are in the Escrow, neither you nor Luca can move or recover them.

3.5. P2P Payments is presented with Luca's design and may not show the P2P.me brand at each step. This does not change the nature of the service: P2P.me, the Protocol Operators and the Merchants are third parties.

3.6. Matching, Order Windows, limits, fees, Reputation tiers, dispute rules and the countries and Payment Rails available are set by P2P.me and its governance, and may change at any time without notice to Luca or to you. Luca does not control them.

3.7. Nothing in the App constitutes financial, legal or tax advice. Luca is not responsible for acts or omissions of the Protocol Operators, Merchants, QR beneficiaries, banks, Payment Rails, price oracles, Circle or the Base network.

4. Eligibility and Restrictions

4.1. To use P2P Payments you must meet, and continue to meet for as long as you use it, all of the following requirements:

1. Be an individual at least 18 years old with legal capacity to enter into contracts.
2. Have completed Luca's identity verification (KYC) and keep your information up to date.
3. Be the sole holder of every bank or payment account you use in an Order, and use accounts in your own name only.
4. Not be a "U.S. Person" as defined in Regulation S under the U.S. Securities Act of 1933, nor reside in, be located in or operate from the United States or its territories.
5. Not be, or act on behalf of, any person or entity included on sanctions lists, including the Specially Designated Nationals (SDN) List and other lists maintained by the U.S. Treasury's Office of Foreign Assets Control (OFAC), the United Nations Security Council, the European Union or the United Kingdom, nor be owned or controlled by any such person or entity.
6. Not be, or act on behalf of, a sanctioned government, agency or state-owned enterprise, nor be a Politically Exposed Person (PEP).
7. Not reside in or operate from a jurisdiction subject to comprehensive sanctions, or where P2P Payments is prohibited or restricted by applicable law, by the Protocol Operators or by Luca.
8. Not use funds of illicit origin, and not trade on behalf of or for the benefit of third parties.

4.2. P2P.me may require additional verifications, including zero-knowledge proofs of social media or identity accounts provided by third parties such as Reclaim Protocol. Your limits depend on these verifications and on your Reputation. Luca does not control these verifications and cannot guarantee their result.

4.3. Luca may request additional information or documentation at any time, including proof of the origin of funds, and may deny, limit or cancel access to P2P Payments if you fail to provide it or if there are signs of non-compliance, without being required to state the reason where the law prohibits it.

4.4. You may not use VPNs, proxies or other tools to conceal your location or circumvent these restrictions. If you stop meeting any requirement, you must notify us immediately and stop using P2P Payments.

4.5. The countries, Payment Rails and QR networks available are those shown in the App at the time of each Order, and may be added, changed or removed without notice.

5. Operation

5.1. Buy Orders. You choose the amount and the Payment Rail, and the App shows you the payment details of the assigned Merchant. You must send the exact amount, in a single transfer, from an account in your own name, within the Order Window. Once the Merchant confirms receipt, the Escrow releases the Digital Dollars to your Luca Account.

5.2. Sell Orders. You choose the amount and enter the details of a bank or payment account in your own name. When you confirm, your Digital Dollars are locked in the Escrow. The Merchant sends the local currency to your account and confirms the payment, and the Escrow then releases your Digital Dollars to the Merchant. You do not confirm receipt in the App. Check the funds in your own bank app; if they did not arrive, open a dispute within the Order Window.

5.3. QR Payments. When you scan a supported QR code, the App shows you the amount in local currency and its equivalent in Digital Dollars. When you confirm, your Digital Dollars are locked in the Escrow and a Merchant pays the QR beneficiary through the Payment Rail. The beneficiary receives the payment from the Merchant, not from Luca. You are responsible for checking the QR, the beneficiary and the amount before confirming.

5.4. Exchange rate. The rate is set by P2P.me from reference prices aggregated by third-party oracles from centralized and peer-to-peer markets. It may differ, sometimes significantly, from official rates published by central banks (such as the Banco Central de Venezuela) and from rates offered by banks or other platforms. Quotes expire after a short time, and if the reference price changes sharply or the oracle fails, the Order may be paused, re-quoted or cancelled.

5.5. Fees. The amount you will pay or receive, including the P2P.me and Merchant spread and any Luca fee, is shown before you confirm each Order. Your bank or payment provider may charge its own fees, and network fees may apply.

5.6. Limits. Minimum and maximum amounts apply per Order, per day and per period. They vary by country, Payment Rail, verification level and Reputation, and are shown in the App. Payment Rails may also have their own daily limits, such as Pago Móvil limits set by each bank. Luca may set limits lower than those of P2P.me.

5.7. Timing. Most Orders are completed in minutes, but timing depends on Merchant availability, the Payment Rail and the network, and is not guaranteed. If no Merchant accepts an Order, or a step is not completed within its Order Window, the Order expires. If a Sell Order or QR Payment expires before any local currency was sent, the Digital Dollars are returned to your Luca Account. If a Luca fee was charged on that Order, it is not returned automatically: Luca support refunds it. If you paid a Buy Order that expired, including one you did not mark as paid on time, contact Luca support with the Order number and proof of payment. Any refund of local currency is made by the Merchant under P2P.me's process and is not guaranteed.

5.8. Finality. Orders recorded on the network are irreversible. Luca cannot cancel, reverse or modify an Order once confirmed.

6. Your Obligations

6.1. When using P2P Payments you must:

1. Pay and receive local currency only from and to accounts in your own name.
2. Send the exact amount shown, in a single transfer, to the exact details shown in the App for that Order, including any reference requested.
3. Mark a Buy Order as paid only after the transfer has actually left your account.
4. Check in your own bank or payment app that the local currency of a Sell Order arrived, and open a dispute within the Order Window if it did not. A screenshot, notification or message is not proof of payment.
5. Keep receipts, bank statements and any other proof of each Order for at least 180 days.
6. Respond within the Order Window to any request related to an Order or a dispute.
7. Keep your device, App access and recovery credentials secure.

6.2. You may not use P2P Payments to:

1. Launder money, finance terrorism, evade sanctions or taxes, or commit fraud.
2. Receive or send funds from or to third parties, including funds received from people you do not know.
3. Pay for illegal goods or services, or for any activity prohibited by the General Terms.
4. Act as an exchange, money transmitter, remittance agent or Merchant without authorization, or resell P2P Payments to others.
5. Submit false claims or proofs of payment, or make payments with the intention of reversing them later.
6. Settle an Order or contact a Merchant outside the App.

6.3. Luca, the Protocol Operators and Merchants will never ask you to confirm an Order before receiving your funds, send additional amounts, use another account or complete an Order outside the App. Treat any such request as a scam and report it to Luca through the support chat in the App.

7. Disputes, Reversals and Bank Account Freezes

7.1. Opening a dispute. You may open a dispute from the App, within the Order Window, if you marked a Buy Order as paid in the App on time and did not receive your Digital Dollars, or if your Digital Dollars were locked in a Sell Order or QR Payment and the local currency was not received. If you paid a Buy Order but did not mark it as paid on time, the protocol does not accept a dispute; see Section 5.7.

7.2. How disputes are resolved. Disputes are decided under the rules of P2P.me, not by Luca. You submit your evidence through Luca's support chat in the App, and Luca forwards it to P2P.me. As a general rule, the party claiming that a payment was made must prove it, and the other party may present evidence to the contrary. Administrators or jurors authorized by P2P.me issue an on-chain decision that releases the Digital Dollars in the Escrow to you or to the Merchant. That decision may only be appealed as P2P.me's rules allow.

7.3. Luca's role. Luca will help you open the dispute, submit evidence and follow its status, and may share with P2P.me the information needed for that purpose. Luca does not decide disputes, cannot reverse a decision and does not guarantee any result, timing or refund. Insurance or compensation mechanisms of P2P.me, if any, are governed by its own rules and are not guaranteed by Luca.

7.4. False claims. If you mark a payment as made without having made it, submit false evidence or reverse a payment after the Order is completed, you may lose Reputation, have your limits reduced, lose access to P2P Payments and be liable for the resulting losses.

7.5. Reversals by banks and payment systems. Some Payment Rails allow a payment to be reversed after it is received. For example, in Brazil the PIX Special Return Mechanism (MED) allows a payer to request the return of a PIX transfer for up to 80 days, and the amount may be blocked in, and taken from, the receiving account even if it has already been transferred onward. If a payment you sent or received in an Order is reversed, blocked or claimed by a bank, a payment system or an authority, you must resolve it directly with that institution. Luca cannot stop or reverse it, and may suspend your access to P2P Payments while it is reviewed.

7.6. Bank account freezes. In a P2P transaction you receive local currency from, or send it to, a third party you do not know. If those funds are later linked to fraud or another crime, your bank or the authorities may freeze, block or place a lien on your bank account, even if you acted in good faith. This risk has been widely reported, among others, with UPI transfers in India and with PIX in Brazil. The freeze may affect your whole account and last for an extended period. Luca has no control over these measures, cannot request their release and is not responsible for their consequences. If it happens, contact your bank, keep all proof of the Order and contact Luca through the support chat in the App.

7.7. Payment errors. If you send local currency to a wrong account, send an incorrect amount or pay a wrong QR code, Luca cannot recover those funds. Any recovery depends on the Merchant, the beneficiary or your bank.

8. Risks

8.1. Using P2P Payments involves significant risks and you may lose part or all of the amount of an Order. By using the feature, you acknowledge and accept, among others, the following risks:

• Counterparty: Merchants are independent third parties. A Merchant may fail to pay, pay late, pay a wrong amount or act in bad faith. The dispute process reduces this risk but does not eliminate it.
• Third-party funds: the local currency you receive comes from a Merchant whose own funds may have an origin you cannot verify. If those funds are linked to fraud or crime, your bank account may be frozen or the amount claimed back, as described in Section 7.
• Reversals: some Payment Rails allow payments to be reversed or blocked days or weeks after they are received, after the Order has already been completed on the network.
• Protocol control: according to the Protocol Operators' public disclosures, upgrades and the emergency pause of the P2P.me smart contracts are controlled by a single administrative key held by Open Horizons Foundation, with a migration to multi-signature or time-locked control announced but not guaranteed. Whoever controls that key can change or pause the protocol, and its loss or misuse could affect Orders in progress.
• Governance: holders of the P2P.me token may vote to change fees, limits, Merchant rules, dispute rules and other parameters. These changes may affect you and Luca does not take part in them.
• Smart contracts: the Escrow and other contracts may contain bugs or be exploited, which could result in the loss of Digital Dollars locked in an Order. According to the Protocol Operators' public disclosures, the protocol has undergone a limited-scope security review, and full independent audits had been announced but not completed. No review guarantees the absence of vulnerabilities.
• Oracles and pricing: the exchange rate depends on third-party price feeds that may fail, be delayed or be manipulated, which may result in an unfavorable rate or the pause or cancellation of an Order.
• Liquidity: when few Merchants are active, spreads may widen, Orders may take longer or may not be fulfilled at all.
• Exchange rates and controls: rates may differ significantly from official rates, and some countries have foreign exchange controls or reporting rules that may apply to you.
• Regulatory: according to their own disclosures, the Protocol Operators are not licensed as virtual asset service providers in any jurisdiction. Regulatory changes or enforcement actions in any country may restrict, condition or end P2P Payments, or affect Payment Rails, Merchants or users.
• Third-party dependencies: P2P Payments depends on the Protocol Operators, Merchants, banks, Payment Rails, verification providers, oracles, the Base network and Circle as issuer of USDC. Any of them may fail, change their rules or stop operating.
• Digital Dollars: USDC is issued by a third party, may be frozen by its issuer at specific addresses and may lose its parity with the U.S. dollar.
• Privacy: Orders are recorded on a public blockchain and cannot be deleted. The Merchant will see the name and account details involved in the local currency transfer.
• Fraud and impersonation: third parties may impersonate Luca, the Protocol Operators or Merchants to obtain your funds or data.
• Technology: failures, congestion or attacks on the Base network, the App or the Payment Rails may delay, block or cause Orders to fail.
• Self-custody: if you lose access to your Luca Account, your Digital Dollars may be irretrievably lost.
• No guarantees: Digital Dollars and Orders are not bank deposits, are not covered by deposit insurance or investor compensation schemes, and are not guaranteed by Luca or the Protocol Operators.

8.2. This list is not exhaustive. Only use P2P Payments for amounts you can afford to lose.

9. Freezing, Suspension and Termination of the Program

9.1. Discontinuation of the program. Luca may suspend, limit, modify or discontinue P2P Payments, in whole or in part, temporarily or permanently, in any country or for any Payment Rail, at any time and for any reason, including decisions of the Protocol Operators, lack of Merchants, security incidents, regulatory changes, requirements from banks or partners, or business reasons. Luca will endeavor to give you reasonable advance notice, unless the law or urgency prevents it.

9.2. Effects of discontinuation. Discontinuation does not affect the Digital Dollars in your Luca Account, which remain under your control in accordance with the General Terms. Orders already locked in the Escrow will be completed, refunded or resolved under the rules of P2P.me.

9.3. Pause by the Protocol Operators. The Protocol Operators may pause P2P.me, or any of its functions, at any time and without Luca's involvement. During a pause, new Orders may not be available and Orders in progress may be delayed until the protocol resumes.

9.4. Measures by P2P.me. P2P.me may, under its own rules, reduce your Reputation, block your address, reject Orders or resolve disputes against you. Luca is not responsible for these measures and cannot reverse them.

9.5. Suspension of your access. Luca may refuse or cancel an Order before it is locked in the Escrow, reduce your limits, or suspend or cancel your access to P2P Payments if you breach these P2P Terms or the General Terms, if you are no longer eligible, upon suspicion of fraud, money laundering or sanctions violations, if your bank account is the subject of a freeze or claim, or by order of a competent authority. In such cases, Luca may report the matter to the authorities as required by law.

9.6. Monitoring and information sharing. Luca and P2P.me may screen Orders, addresses and account details against sanctions lists and risk indicators. To execute your Orders, Luca shares with P2P.me and the assigned Merchant only the data strictly necessary, such as the amount, the Payment Rail, the account details you enter, your address on the network and any dispute evidence. Luca processes your data in accordance with its Privacy Policy, and the Protocol Operators in accordance with their own policies. Luca may disclose information about your use of P2P Payments when required by law or by a competent authority.

10. Taxes, Liability, Amendments and Contact

10.1. Taxes. You are solely responsible for determining and paying any taxes arising from your Orders, and for complying with foreign exchange and reporting rules in your country of residence. Luca does not withhold taxes on your behalf and does not provide tax advice.

10.2. Limitation of liability. To the maximum extent permitted by law, Luca shall not be liable for losses arising from acts or omissions of Merchants, the Protocol Operators, QR beneficiaries, banks or Payment Rails; reversals, blocks or freezes of bank accounts; dispute decisions; failures, pauses, upgrades or exploits of P2P.me, its smart contracts or oracles; failures of the Base network or of USDC; exchange rate movements; payment errors made by you; or the suspension or discontinuation of the program. The limitations of liability in the General Terms also apply to P2P Payments.

10.3. Indemnification. You agree to hold Luca harmless from any claims arising from your breach of these P2P Terms, false eligibility representations, the use of third-party accounts or funds, or any violation of laws or sanctions.

10.4. Amendments. Luca may amend these P2P Terms at any time by publishing them in the App or on its website. Your continued use of P2P Payments after publication constitutes acceptance of the changes.

10.5. Governing law and jurisdiction. The governing law and jurisdiction set out in the General Terms apply.

10.6. Contact. For questions or complaints about P2P Payments, an Order or a dispute, contact us through the support chat in the App and include the Order number and any proof of payment. Contact us immediately if your bank account is frozen after an Order, if you believe your Luca Account has been compromised, or if someone asks you to complete an Order outside the App.