These general terms and conditions for the use of electronic money EURØP electronic money (hereinafter referred to as the “EURØP T&Cs”) govern all relations between:

• On the one hand, Salvus SAS, trading as Schuman Financial, a simplified joint stock company incorporated under the laws of France, with the registered number 920 017 134 at the Registry of Commerce and Companies of Paris, and its registered office at 9, rue du 4 Septembre, in 75002 Paris, France, authorised to carry on business as an electronic money institution approved by the Autorité de Contrôle Prudentiel et Résolution (ACPR) under articles L.526-1 et seq. of the Monetary and Financial Code, and under the register number 739803 hereinafter “Schuman”, or the “Issuer“);

AND

• On the other hand, any natural or legal person who uses electronic money issued by the Issuer, hereinafter referred to as the “Holder”;

Together hereinafter referred to as “the Parties”.

The purpose of the EURØP T&Cs is to describe the terms and conditions of use and redemption from the Issuer of EURØP electronic money (the “Electronic Money” or “EURØP”) between Schuman and the Holder.

Together with Schuman’s EURØP White Paper (link enclosed), Privacy Policy, Cookie Policy, Redemption Policy, and any other terms and conditions referred to in these EURØP T&Cs, and any Schuman Financial documentation available on the Schuman Website (as defined hereinafter), the EURØP T&Cs express all the obligations and rights of the Parties.

The Holder acknowledges and agrees to be bound by each of these individual terms, agreements and policies.

The Holder is advised to print or download and keep a copy of these General Terms and Conditions for future reference. They may also request to receive these General Terms and Conditions by email at support@schuman.io.

These EURØP T&Cs and all communications are provided in English. Any translations are for convenience only. The English version of these EURØP T&Cs governs the Holder’s use of the services and takes precedence over any translated versions.

In these EURØP T&Cs, the terms and expressions identified by a capital letter have the meaning indicated below, whether they are used in the singular or in the plural:

• Wallet Terms & Conditions: refers to the general conditions of use of a wallet concluded between the User and a wallet provider, governing in particular interactions with the wallet provider and the validation of Transactions.
• Third-Party: refers to a third-party professional who accepts, on their website or at their point of sale, to be paid by Schuman on behalf of the Holder requesting a refund of the Electronic Money.
• Holder: refers to any legal entity represented by a person with the rights to represent it and to bind it, or any natural person of legal age and capacity acting on its behalf for non-business purposes and having subscribed to these EURØP T&Cs.
• Crypto-asset Trading Platform: refers to any exchange or platform that independently chooses to make the EURØP available to its users without any contractual agreement with the Issuer.
• Personal Data: means any information relating to an identified or identifiable natural person as the Holder, as defined in Article 4(1) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This includes any information by which a Holder can be identified, directly or indirectly, by reference to an identifier or to one or more factors specific to him or her.
• KYC: refers to the legal obligations relating to the knowledge of the Holder resulting from articles L.561-5 and L.561-5-1 of the French Monetary and Financial Code corresponding to the following obligations: identification and verification of the identity of the Holder and, where applicable, of the beneficial owner of the business relationship, as well as knowledge of the purpose and nature of the business relationship and any other relevant information. The verifications and controls carried out upon entering into a relationship with Holders and, where applicable, during the course of the business relationship are adapted by the Issuer or the Crypto-asset Trading Platform depending on whether the Holder is a natural person or a legal entity. These checks and controls thus take account of the status of the Holder to determine the nature and extent of the information to be collected to identify and verify the identity of the Holder and, where applicable, its beneficial owner.
• Applicable Laws on the Protection of Personal Data: refers to (i) GDPR, (ii) the updated Law n°78-17 known as the Data Protection Act of 6 January 1978, and (iii) any other subsequent applicable legislation that may supplement and/or replace the aforementioned texts.
• Electronic Money: refers to stablecoin EURØP, a monetary value stored in electronic form on the Issuer’s server and representing a claim by the Holder against the Issuer. The Electronic Money is issued by the Issuer in exchange for the surrender of funds by the Holder.
• Transaction: means the operation whereby a Holder exchanges EURØP or uses EURØP to make a payment.
• Wallet: refers to a digital tool, either software or hardware, used to store cryptographic keys and manage digital assets, such as EURØP. It allows the User to send, receive, and track transactions on blockchain networks.
• Third-Party Wallet: refers to a wallet provided by a service provider that is not affiliated with the Issuer or Crypto-asset Trading Platform, used by the User to store and manage digital assets like EURØP.
• Website: refers to the website published by Schuman at the following URL address: https://www.schuman.io.

Electronic Money is issued by Schuman, approved as an electronic money institution, in exchange for funds and listed by partner Crypto=asset Trading Platforms to their users.

Holders may verify the Issuer’s authorisation by contacting the ACPR, 4 Place de Budapest – 75009 Paris, or by visiting https://www.regafi.fr/spip.php?rubrique1.

Electronic Money can be purchased directly by qualified business clients from Schuman or by individuals and businesses on a Crypto-asset Trading Platform in exchange for cash.

The Holder will be able to receive EURØP in the Crypto-asset Trading Platform’s Wallet or in a Third-Party Wallet provided that the latter has carried out a full KYC.

The Electronic Money will then be able to circulate freely without restriction.

In the context of a Transaction with a Third-Party beneficiary, the Holder will be deemed to request reimbursement of his Electronic Money from the Issuer and to request the Issuer to pay the Third-Party beneficiary in cashless money on his behalf.

The Issuer reserves the right to block the redemption of Electronic Money and the transfer from the Wallet at any time, in particular in the event of use that does not comply with these EURØP T&Cs or in the event of suspected or proven fraudulent use.

Holders may obtain reimbursement of their Electronic Money directly from the Issuer, provided they have satisfied KYC requirements and met the requirements defined by the Redemption Policy.

Redemption is made at the nominal value of the Electronic Money units, subject to current transactions. It will not be possible to change the value of the Electronic Money, as one EURØP unit always represents one euro.

The refund is made by transfer to an account opened in the name of the Holder, the IBAN of which is provided by the Holder under his responsibility. By way of derogation, the Holder, who is a natural person not acting for professional purposes, may request reimbursement in cash. In this case, the Issuer may send a postal order or use any other money transmission service allowing cash withdrawal.

In view of the provisions relating to the AML-CFT requirements, the Issuer reserves the right to make repayment subject to the provision of any other document enabling the identity of the Holder or the lawfulness of the transaction to be verified or confirmed.

The reimbursement will be sent to the Holder after the completed reimbursement request, accompanied, where applicable, by all the supporting documents requested.

These EURØP T&Cs constitute a contract between the Issuer and the Holder, which shall remain in force until the Electronic Money subscribed to is used or redeemed.

The current EURØP T&Cs can be consulted at any time on the Website.

The Website is accessible by the Holder 24 hours a day, 7 days a week, all year round, except in the event of maintenance or force majeure.

The fact that the Issuer does not avail itself at a given time of any clause of the EURØP T&Cs may not be interpreted as a waiver of the right to avail itself of such clause at a later date.

The Issuer reserves the right to amend these EURØP T&Cs at any time. In this case, the amended EURØP T&Cs will be available for consultation on the Website no later than 2 (two) months prior to the date proposed for their entry into force, unless such amendment is imposed by a law or regulation of immediate application.

If no objection is raised by the Holder within this period, the modified EURØP T&Cs is deemed to have been accepted.

If the Holder refuses the proposed amendment or for any other reason, they may terminate these EURØP T&Cs, free of charge, by contacting the Issuer using the contact details indicated in the Claims section of this document. This request does not affect all debits (fees, subscriptions, payments) for which the Holder remains liable.

The Holder’s death or legal incapacity terminates these EURØP T&Cs as soon as the Issuer is notified thereof. Unless the rightful claimants or the notary in charge of the estate agree to honour them, Transactions carried out after the Holder’s death or legal incapacity are deemed not to have been authorised.

The Issuer and the Crypto-asset Trading Platforms exclude all liability for goods or services paid for using Electronic Money and provided by Third-Parties. It is the responsibility of the Holder to resolve any dispute of any nature concerning these goods or services with the Third-Parties.

Under no circumstances may the Issuer or the Crypto-asset Trading Platforms be held liable for disputes with Third-Parties.

The Transactions recorded by the Issuer’s computer systems constitute proof of the Transactions actually carried out using Electronic Money.

In the event of a dispute regarding the use of EURØP, in particular, due to an unauthorised or incorrectly executed Transaction, the Holder may send a complaint by email to support@schuman.io or by post to the Issuer within 13 months of the date of the disputed transaction.

After validation of the dispute by the Issuer, the Issuer will pay the Holder an amount of EURØP equivalent to the disputed transaction.

The Issuer may be exonerated from all or part of its liability by proving that the non-performance or improper performance of the contract is attributable either to the Holder, or to the unforeseeable and insurmountable act of a third party to the contract, or to a case of force majeure, as defined in the Force Majeure section of this document.

For any questions, information or complaints, the Issuer’s Customer Service is available to the Holder:

• By email to the following address: support@schuman.io
• By telephone at +33 (0)9 80 80 22 84 (price of a local call from a landline) from 9:00 to 16:00 Central European Time, from Monday to Friday.
• Via the section Contact Us of the website at https://schuman.io/contact/.

The Issuer processes the Holder’s Personal Data in accordance with (i) the Applicable Laws on the protection of personal data and (ii) its Personal Data protection policy accessible at the following address: https://schuman.io/privacy-policy/.

Pursuant to Article L. 526-35 of the French Monetary and Financial Code, any person who participates in the management or direction of the Issuer or who is employed therein is bound by professional secrecy. In addition to the cases where the law so provides, the Issuer may communicate information covered by professional secrecy to the persons with whom it negotiates, concludes, or executes the following transactions, where such information is necessary for such transactions:

• Acquisitions of shareholdings or control in electronic money institutions;
• Disposal of assets or business;
• Assignment or transfer of contracts;
• Service contracts concluded with a third party with a view to entrusting it with important operational functions; or
• During the study or preparation of any type of contract or transaction, provided that these entities belong to the same group as the author of the communication.

In addition to the cases mentioned above, the Issuer or the Crypto-asset Trading Platforms may communicate information covered by professional secrecy on a case-by-case basis and only when the persons concerned have expressly authorised them to do so.

Persons receiving information covered by professional secrecy which has been provided to them for the purposes of one of the above-mentioned operations must keep such information confidential, whether or not the above-mentioned operation is successful. However, in the event that the aforementioned transaction is successful, these persons may, in turn, communicate the information covered by professional secrecy, under the same conditions as those referred to above, to the persons with whom they negotiate, conclude or execute the aforementioned transactions.

When listing Electronic Money, the Issuer or a Crypto-asset Trading Platform shall first carry out a full KYC of the Holder, including identifying and verifying the identity of these customers, gathering information relating to the purpose and nature of this relationship, and respond within 5 business days to update this information throughout the duration of the relationship where applicable.

The Holder undertakes to provide the Issuer or the Crypto-asset Trading Platforms, as the case may be, with any information that may be reasonably requested for KYC purposes for knowledge of the customer and the nature of the business relationship on the purpose of the operations or Transactions carried out, the origin and destination of the funds, and the identity of the Holder by producing, as the case may be, any documentary evidence.

Holders are informed that no Transaction or refund of Electronic Money can be ordered if the Holder has not first undergone a KYC check by the Issuer or Crypto-asset Trading Platform.

The texts and graphic elements, their assembly on the Website, and the Website itself are the exclusive property of the Issuer and are protected under the applicable copyright legislation. The logos and distinctive signs of the Issuer are protected under trademark law.

Any deterioration of the elements present on the Website or of the Website, as well as, in the absence of express authorisation, any reproduction, downloading, copying, modification or commercial use, in whole or in part, of the various elements of the Website are prohibited and expose their author(s) to legal action.

Under no circumstances do the EURØP T&Cs authorise the reproduction, modification or commercial use of the various elements of the Website.

By accessing the Website, the Issuer grants the Holder a licence to use the Website subject to the following conditions:

• a private, personal and non-transferable right to use the content of the Website or any of its component parts;
• a reproduction right for storage for the purpose of reproduction on a single-user screen, in one copy, for backup copies or hard copies; and
• any use of documents from the Website must mention the source.

Any other use of the texts and graphic elements, their assembly on the Website, and the Website itself, is prohibited, in particular, for commercial purposes, use in a network, or repeated and systematic extraction of elements from the Website carried out in contravention of the provisions of the Law of 1 July 1998 concerning the legal protection of databases.

Any use of the Website contrary to the provisions of this article constitutes an infringement of copyright, for which the person committing such an infringement (“Counterfeiter”) may be held liable. Civil and criminal penalties may be imposed on any Counterfeiter.

Force majeure events are defined in accordance with Article 1218 of the French Civil Code as events that are unforeseeable, beyond the parties’ control, and external, which make it impossible to perform the obligations under these EURØP T&Cs.

If a force majeure event occurs:

• The Issuer’s obligations under this agreement will be suspended; and
• If the event persists for more than one (1) month, the Issuer’s obligations may be terminated. Except for the Issuer’s obligation to redeem Electronic Money, the Issuer shall not be held liable for non-performance of the contract due to a force majeure event.

The party affected by a force majeure event must promptly notify the other party of its occurrence and the measures being taken to mitigate its effects.

The EURØP T&Cs are governed by French law.

In the event of a dispute arising between the Holder and the Issuer in connection with the performance hereof, each of the two Parties shall endeavour to attempt to settle the dispute amicably.

If the Holder and the Issuer are unable to reach an agreement, and in accordance with Article L.316- 1 of the French Monetary and Financial Code, the Holder may refer the matter free of charge to the mediator of the French Association of Payment and Electronic Money Institutions (“AFEPAME”):

Association AFEPAME – Mediator
36, rue Taitbout
75009 Paris, France

A consumer mediator may be contacted 2 months after the submission of a first written complaint, regardless of the contact person or department to which the complaint was addressed, and irrespective of whether a response has been provided.

In principle, the mediation shall be concluded within ninety (90) days from the date on which the mediator notifies the Parties of his referral, in accordance with article R.612-5 of the French Consumer Code.

It should be noted that recourse to mediation by the Holder is only an option, and not a prerequisite for referral to the courts and that the Parties may, in any event, withdraw from the mediation process at any time.

In the absence of an amicable agreement between the Parties via one of these voluntary procedures, the dispute will be submitted to the French courts.

This website is operated by Schuman Financial, a company registered in France. By accessing and using this website, you agree to comply with the following legal terms and conditions. If you do not agree with these terms, please do not use this website.

Salvus SAS, which trades under the name Schuman Financial
920 017 134 R.C.S. Paris

9 rue du Quatre-Septembre
75002 Paris
France

Telephone: +33 (0)9 80 80 22 84
Email: legal@schuman.io

Commercial Register Number: 920 017 134
Registered in Registre du commerce et des sociétés (R.C.S) in Paris under number 920 017 134

All content on this website, including but not limited to text, images, graphics, logos, and software, is the property of Schuman Financial or its licensors and is protected by copyright, trademark, and other intellectual property laws. Unauthorized use of any content on this website is strictly prohibited.

Schuman Financial makes every effort to ensure that the information provided on this website is accurate and up-to-date. However, we make no warranties or representations as to the accuracy, completeness, or reliability of any information on this site. Use of this website and its content is at your own risk. Schuman Financial shall not be liable for any damages, including but not limited to direct, indirect, incidental, consequential, or punitive damages arising from the use or inability to use this website.

This website may contain links to external websites. Schuman Financial has no control over the content of these external sites and assumes no responsibility or liability for the information or services provided by such external websites. The inclusion of any link does not imply endorsement by Schuman Financial.

Schuman Financial is committed to protecting your privacy and personal data. Please refer to our Privacy Policy for information on how we collect, use, and protect your data.

These terms and conditions are governed by the laws of France. Any disputes arising from the use of this website or the interpretation of these terms shall be subject to the exclusive jurisdiction of the courts in Paris, France.

Schuman Financial reserves the right to modify these legal terms at any time without prior notice. It is your responsibility to regularly review these terms to ensure you are aware of any changes. Your continued use of this website following any modifications constitutes your acceptance of the revised terms.

These General Terms and Conditions and Framework Contract for the Issuance, Use and Redemption of EURØP Electronic Money (the “Payments T&Cs”) govern all relations between:

• • On the one hand, Salvus SAS, trading as Schuman Financial, a simplified joint stock company incorporated under the laws of France, with the registered number 920 017 134 at the Registry of Commerce and Companies of Paris, and its registered office at 9, rue du 4 Septembre, 75002 Paris, France, authorised to carry on business as an electronic money institution approved by the Autorité de Contrôle Prudentiel et Résolution (ACPR) under articles L.526-1 et seq. of the Monetary and Financial Code, and under the register number 739803, and operating the Platform, hereinafter the “Issuer”, the “Company”, “Schuman”, “We”, “us”, or “our”;

AND

• On the other hand, any natural or legal person who has been granted specific access to services related to payment provided by Schuman, via the electronic money tokens issued by the Issuer under the name EURØP Electronic Money Token (EMT) or the electronic money units issued by the Issuer under the name EUR, hereinafter the “User”, “Holder”, “Client”, or “You”;

Together hereinafter referred to as “the Parties”.

For the purposes of French law, these Payments T&Cs constitute a framework contract (contrat cadre
de monnaie électronique) as defined under the Monetary and Financial Code.

For the purposes of Regulation (EU) 2023/1114 of 31 May 2023 on markets in crypto-assets (“MiCA”), EURØP qualifies as an Electronic Money Token (EMT), meaning a crypto-asset that purports to maintain a stable value by reference to the euro, and which constitutes electronic money under EU and French law.

For the purposes of Directive 2009/110/EC of 16 September 2009 on the taking up, pursuit and prudential supervision of the business of electronic money institutions (“EMD II”), EUR qualifies as electronic money, meaning a monetary value stored electronically, issued on receipt of funds for the purpose of making payment transactions, and accepted by persons other than the issuer.

The purpose of these Payments T&Cs is to define the terms and conditions governing the issuance, use, storage, and redemption of EURØP and EUR (the “Electronic Money“), between the Issuer and the Holder in the context of payments services.

These Payment T&Cs constitute an addendum to the main General Terms and Conditions and Framework Contract for the Access and Use of the Schuman Platform (the “Platform T&Cs”).

These Payments T&Cs constitute a framework contract (contrat-cadre de monnaie électronique). within the meaning of Articles L.315-1 and L.522-7 of the French Monetary and Financial Code, setting out the rights and obligations of the Parties with respect to the Electronic Money.

Schuman issues, manages, and redeems Electronic Money in the form of EURØP and EUR. Schuman does not provide payment services within the meaning of Article L.314-1 of the French Monetary and Financial Code (PSD2). Any movement of fiat currency occurs exclusively in connection with the issuance or redemption of Electronic Money. These Payment T&Cs do not create or govern a payment account.

These Payments T&Cs form part of the contractual framework together with the EURØP T&Cs, EURØP White Paper, Privacy Policy, Cookie Policy, Redemption Policy, and any other Schuman Financial documentation referred to herein and available on the Issuer’s website (the “Website”). They collectively set out all the rights and obligations of the Parties. In case of inconsistency between these Payments T&Cs, the EURØP T&Cs or Schuman’s EURØP White Paper, Privacy Policy, Cookie Policy, Redemption Policy, and any other T&Cs or Policy referred to in these Payments T&Cs, the Payments T&Cs shall prevail for the special provisions it contains unless a specific provision provides otherwise.

The Holder acknowledges and agrees to be bound by each of these documents and policies. The Holder is advised to download and retain a copy of these Payments T&Cs on a Durable Medium.

These Payments T&Cs and all related communications are provided in English. Any translations are for convenience only. The English version governs and prevails.

In these Payment T&Cs, the terms and expressions identified by a capital letter have the meaning indicated below, whether they are used in the singular or in the plural, or, if not defined here, can be found defined in the Platform T&Cs:

• • Account / Electronic Money Account: an internal reference maintained by the Issuer to record the issuance, use, and redemption of Electronic Money in the name of the Holder. The Account is not a deposit, current, savings, or payment account, does not bear interest, and cannot be overdrawn. Electronic Money Account is an internal ledger maintained by the Issuer and should not be confused with a blockchain Wallet controlled by the Holder.
  • Applicable laws on the protection of personal data: refers to (i) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (“GDPR”), (ii) the updated Law n°78-17 known as the Data Protection Act of 6 January 1978, and (iii) any other subsequent applicable legislation that may supplement and/or replace the aforementioned texts.
  • Authentication: the procedures implemented by the Issuer to verify the identity of the Holder or the validity of a Transaction.
  • Business Day: a calendar day, excluding Saturdays, Sundays, and public holidays in France, on which payment systems are open for the execution of Transactions.
  • Consumer Holder: a Holder who is a natural person acting exclusively for personal, non-business purposes.
  • Crypto-asset Trading Platform: refers to any exchange or platform that independently chooses to make the EURØP available to its users without any contractual agreement with the Issuer.
  • Durable Medium: any instrument allowing the Holder to store information addressed personally to them in a way that is accessible for future reference for a period adequate for its purpose and allowing unchanged reproduction of the information stored (for example, PDF).
  • Electronic Money: refers to stablecoin EURØP, a monetary value stored in electronic form on the Issuer’s server and representing a claim by the Holder against the Issuer. The Electronic Money is issued by the Issuer in exchange for the surrender of funds by the Holder. In contrast, EUR designates a standard unit of electronic money under EMD II, recorded off-chain within the Issuer’s systems and not qualifying as an EMT under MiCA.
  • Holder: refers to any legal entity represented by a person with the rights to represent it and to bind it, or any natural person of legal age and capacity acting on its behalf for non-business purposes and having subscribed to these Payments T&Cs.
  • KYC: refers to the legal obligations relating to the knowledge of the Holder resulting from articles L.561-5 and L.561-5-1 of the French Monetary and Financial Code corresponding to the following obligations: identification and verification of the identity of the Holder and, where applicable, of the beneficial owner of the business relationship, as well as knowledge of the purpose and nature of the business relationship and any other relevant information. The verifications and controls carried out upon entering into a relationship with Holders and, where applicable, during the course of the business relationship are adapted by the Issuer or the Crypto-asset Trading Platform depending on whether the Holder is a natural person or a legal entity. These checks and controls thus take account of the status of the Holder to determine the nature and extent of the information to be collected to identify and verify the identity of the Holder and, where applicable, its beneficial owner.
  • Third-Party: refers to a third-party professional who accepts, on their website or at their point of sale, to be paid by Schuman on behalf of the Holder requesting a refund of the Electronic Money.
  • Order Form: The list of fees, charges, and limits applicable to the services, which is agreed directly with the Client and modified from time to time as agreed with the Client.
  • Personal Data: means any information relating to an identified or identifiable natural person as the Holder, as defined in Article 4(1) of the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This includes any information by which a Holder can be identified, directly or indirectly, by reference to an identifier or to one or more factors specific to him or her.
  • Professional Holder: a Holder acting for professional, commercial, industrial, artisanal, or liberal purposes.
  • Strong Authentication: authentication based on the use of two or more independent elements categorised as knowledge (something only the Holder knows), possession (something only the Holder has), and inherence (something the Holder is).
  • Third-Party Wallet: refers to a wallet provided by a service provider that is not affiliated with the Issuer or Crypto-asset Trading Platform, used by the User to store and manage digital assets like EURØP.
  • Transaction: means the operation whereby a Holder exchanges EURØP or uses EURØP to make a payment.

• • Wallet: refers to a digital tool, either software or hardware, used to store cryptographic keys and manage digital assets, such as EURØP. It allows the User to send, receive, and track transactions on blockchain networks.
  • Wallet Terms & Conditions: refers to the general conditions of use of the Wallet concluded between the User and the Wallet provider, governing in particular interactions with the Wallet provider and the validation of Transactions.
  • Website: refers to the Website published by Schuman at the following URL address: https://www.schuman.io

The issuance and use of Electronic Money is subject to the Holder completing the subscription process, which includes acceptance of these Payments T&Cs and the successful completion of Know Your Customer (KYC) or Know Your Business (KYB) checks in accordance with applicable AML/CTF legislation.
The Issuer may require the Holder to provide, depending on their status as an individual or a legal entity, documents including but not limited to:

• Proof of identity and residence for natural persons;
• Articles of association, certificate of incorporation, proof of registered office, and details of
  directors and ultimate beneficial owners for legal entities;
• Any other supporting documentation required under applicable law or by the Issuer for the purpose of verifying identity, beneficial ownership, source of funds, and the nature and purpose of the business relationship.

The Issuer reserves the right to refuse or suspend the establishment of a business relationship where documents or information are incomplete, inconsistent, or not compliant with applicable law.

Acceptance of these Payments T&Cs constitutes the Holder’s agreement to enter into this framework contract with the Issuer.

Electronic Money is issued by Schuman, approved as an electronic money institution, in exchange for funds and, for EURØP, listed by partner Platforms to their users.
Holders may verify the Issuer’s authorisation by contacting the ACPR, 4 Place de Budapest – 75009 Paris, or by visiting https://www.regafi.fr/spip.php?rubrique1

5.1 Account opening
You must be 18 or over and a legal resident in a country approved for Schuman Account access, as confirmed during your onboarding.

When you request the opening of an Account, Schuman (or a third party acting on our behalf) will ask for information about you and the source of the funds used to load your Account. This is required to meet Schuman‘s legal and regulatory obligations, including those relating to anti-money laundering and counter-terrorist financing. Schuman‘s Privacy Policy explains how we use and protect your personal data for these and other purposes.

Once we have obtained and verified the necessary information, we will open your Account. You may not:

• open more than one Schuman Account;
• create a named account on behalf of any other person or entity that has not already been
  onboarded by Schuman; or
• open a new Schuman Account if a previous account has been closed by us.

Your Schuman Account allows you to hold and use EUR, a standard unit of electronic money under DME II, to access EURØP, an EMT issued in accordance with MiCA, and process payments to first or third-party beneficiaries.

You may use your Schuman Account to process cross border remittances to third party beneficiaries in the EU.

To comply with our ongoing regulatory obligations, we may occasionally request additional information or documentation (for example, if your activity or transaction volume increases). Please provide this information promptly to avoid any interruption in the use of your Account or our services.

5.2 Purchase of Electronic Money
Electronic Money can be purchased directly by qualified business clients from Schuman or, for EURØP, by individuals and businesses on a Crypto-asset Trading Platform in exchange for cash.

The Holder will be able to receive EURØP in the Crypto-asset Trading Platform’s Wallet or in a Third-Party Wallet provided that the latter has carried out a full KYC.

The Electronic Money will then be able to circulate freely without restriction.

5.3 Payment linked to Electronic Money
In the context of a Transaction with a Third-Party beneficiary, the Holder will be deemed to request the redemption of their Electronic Money from the Issuer and to designate the Third-Party beneficiary as the beneficiary of such redemption. The corresponding settlement constitutes redemption of Electronic Money and not the execution of a payment service.

The Issuer reserves the right to block the redemption of Electronic Money and the transfer from the Wallet at any time, in particular in the event of use that does not comply with these Payments T&Cs or in the event of fraudulent use.

Electronic Money is only issued upon actual receipt of cleared funds by the Issuer and credited to the Holder’s Electronic Money Account at par value.

The Issuer may refuse to issue or execute a Transaction where KYC/AML/CTF obligations are incomplete, where there is suspected fraud or misuse, or where a legal prohibition applies.

When the Holder uses any Issuer-provided interface requiring credentials, Strong Authentication may be required in accordance with applicable regulation. Strong Authentication may be required when the Holder accesses Issuer-provided interfaces or places redemption requests. This relates solely to access and security of Issuer systems and does not constitute Strong Customer Authentication for PSD2 payment instruments, which the Issuer does not provide.

5.4 Schuman Card Services
The Schuman card (the “Card”) is a payment instrument linked to your Schuman Account. It allows you to make payment transactions with Third-Parties in the same way as with any other payment card, but it operates as a linked service to your electronic money balance.

Each card payment automatically triggers a request for redemption of the corresponding amount of EUR (your electronic money) held in your Account. Upon receipt of your redemption request, Schuman redeems the equivalent value of EUR at par and immediately transfers the corresponding fiat funds to the Third-Party through the relevant payment network.

Accordingly, the use of the Schuman Card does not constitute a separate payment service. It is a linked functionality allowing you to obtain redemption of your electronic money, with the reimbursed funds being paid directly to the designated Third-Party.

You may only use the Schuman Card for transactions denominated in EUR and funded from your available electronic money balance. The Card cannot be used to spend EURØP directly, but you may first convert EURØP into EUR and then use your Card.

Your Schuman Card remains the property of Schuman and may only be used by you, the Account Holder. You must keep your Card and security details safe and without delay notify us through the Schuman App if your Card is lost, stolen or misused.

5.5 No Interest on Electronic Money
Electronic Money held in the Holder’s Account does not constitute a deposit or a current account and does not generate any interest or other financial return, monetary or otherwise, in favour of the Holder.

Holders may obtain redemption of their Electronic Money directly from the Issuer, provided they have satisfied KYC requirements and, for EURØP, met the requirements defined by the Redemption Policy.

Redemption is made at the nominal value of the Electronic Money units, subject to current transactions. It will not be possible to change the value of the Electronic Money, as one Electronic Money token or unit always represents one euro.

The refund is made by transfer to an account opened in the name of the Holder, the IBAN of which is provided by the Holder under their responsibility, or, where instructed by Holder, payment to a Third-Party beneficiary. By way of derogation, the Holder, who is a natural person not acting for professional purposes, may request reimbursement in cash. For Consumer Holders, the Issuer may arrange cash payout via a third-party provider, solely as a redemption method. The Issuer does not itself provide money remittance services.

In view of the provisions relating to the AML-CFT requirements, the Issuer reserves the right to make redemption subject to the provision of any other document enabling the identity of the Holder or the lawfulness of the transaction to be verified or confirmed.

The redemption will be sent to the Holder after the completed redemption request, accompanied, where applicable, by all the supporting documents requested.

Redemption orders are executed no later than the end of the next Business Day following valid receipt of the Holder’s request, subject to AML/CTF checks and the availability of complete information.

Where feasible, the Issuer may return funds using the same method originally used to provide them (e.g. transfer to the Holder’s designated IBAN), without providing payment services.

Consumer Holders may request reimbursement in cash under Article L.315-1 of the French Monetary and Financial Code.

Specifically for Consumer Holders, the Issuer ensures that all operations required to manage the electronic money defined in article L. 315-1 of the of the French Monetary Code comply with the accessibility requirements set out in article L. 412-13 of the French Consumer Code.

A Holder who is a natural person acting for purposes outside their trade, business, craft, or profession (a Consumer Holder) has the right to withdraw from these Payments T&Cs without penalty and without giving any reason within 14 calendar days from the date of acceptance.

If the Consumer Holder wishes to exercise this right, they must notify the Issuer within the withdrawal period using the contact details provided in Section 9.

Where the Consumer Holder has already requested or received the issuance of Electronic Money during this withdrawal period, withdrawal will result in termination of these Payments T&Cs. In such case, only the proportional costs for services actually provided before the withdrawal was exercised may be charged.

For EURØP, any redemption following the exercise of this right of withdrawal will be carried out in accordance with the Issuer’s Redemption Policy, which sets out the detailed procedures, timeframes, and conditions applicable to redemption.

By requesting the issuance or use of Electronic Money before the expiry of the withdrawal period, the Consumer Holder expressly agrees that these Payments T&Cs take effect immediately.

The Holder must take all reasonable steps to keep their personalised security credentials (including passwords, access codes, or other authentication data provided by the Issuer) safe and confidential.

The Holder must notify the Issuer without undue delay of any loss, theft, misappropriation, or unauthorised use of their credentials, using the contact details in Section 10 (“Customer Relations”).

Upon such notification, the Issuer will block the relevant credentials and investigate the reported incident.

Liability rules for unauthorised transactions:

• Prior to notification: the Holder bears losses up to a maximum of EUR 50, unless the Holder acted
  fraudulently or with gross negligence.
• After notification: the Issuer bears all losses, unless the Holder acted fraudulently.
• Professional Holders: where the Holder is not a Consumer Holder, liability is governed by applicable law and the terms of this Section.

The Issuer may require Strong Authentication for certain operations in accordance with applicable regulations.

The Holder shall not bear any financial consequences of unauthorized transactions where the loss, theft, or misappropriation of credentials could not reasonably have been detected prior to the transaction or is due to a Schuman-side breach or Schuman’s fraud, wilful misconduct, gross negligence, or any applicable law or regulation.

The Issuer provides the Holder with access to information relating to the issuance, use, and redemption of their Electronic Money.

The Issuer provides Holders with access to their balance and transaction history via a secure online portal. This information is made available on an ongoing basis and can be downloaded by the Holder on a Durable Medium. Transaction information remains accessible for at least thirteen (13) months from the date of execution, in line with applicable archiving obligations. This availability does not create or imply the provision of a payment account within the meaning of PSD2.

These Payments T&Cs constitute a contract between the Issuer and the Holder, which shall remain in force until the Electronic Money subscribed to is used or redeemed.

These Payment T&Cs are concluded for an indefinite duration as a framework contract for the issuance and use of Electronic Money.

The Holder may terminate these Payment T&Cs at any time by giving the Issuer 30 days’ notice, free of charge.

The Issuer may terminate these Payment T&Cs by giving the Holder two months’ notice, except in the event of serious breach, fraud, AML/CTF concerns, or other lawful grounds justifying immediate termination.

Upon termination, any outstanding Electronic Money will be redeemed at par value in accordance with the Redemption Policy.

The Issuer reserves the right to amend these Payment T&Cs at any time.

In this case, the amended Payment T&Cs will be available for consultation by email no later than two (2) months prior to the proposed date of entry into force, unless such amendment is imposed by a law or regulation of immediate application.

If no objection is raised by the Holder within this period, the modified Payment T&Cs are deemed to have been accepted.

If the Holder refuses the proposed amendment, they may terminate these Payment T&Cs free of charge, by contacting the Issuer using the contact details indicated in Section 13 (“Customer Relations”). Termination will result in redemption of any outstanding Electronic Money at par value in accordance with the Redemption Policy.
This request for termination does not affect debits already due (fees, subscriptions, payments) for which the Holder remains liable.

The death or legal incapacity of the Holder terminates these Payment T&Cs as soon as the Issuer is notified thereof. Unless the rightful claimants or the notary in charge of the estate agree to honour them, Transactions carried out after the Holder’s death or legal incapacity are deemed not to have been authorised.
The Issuer may also terminate these Payment T&Cs with two (2) months’ notice, without prejudice to immediate termination in the event of serious breach, fraud, AML/CTF concerns, or other lawful grounds.

The Issuer and the Crypto-asset Trading Platform exclude all liability for goods or services paid for using Electronic Money and provided by Third-Parties. It is the responsibility of the Holder to resolve any dispute of any nature concerning these goods or services with the Third-Parties.

Under no circumstances may the Issuer or the Crypto-asset Trading Platform be held liable for disputes with Third-Parties.

The Transactions recorded by the Issuer’s computer systems constitute proof of the Transactions actually carried out using Electronic Money.

In the event of a dispute regarding the use, transfer, or redemption of EURØP, the Holder may submit a complaint by email to support@schuman.io

After validation of the dispute by the Issuer, the Issuer will pay the Holder an amount of EURØP equivalent to the disputed transaction, subject to the provisions of these General Terms and Conditions.

The Issuer may be exonerated from all or part of its liability by proving that the non-performance or improper performance of the contract is attributable either to the Holder, or to the unforeseeable and insurmountable act of a third party to the contract, or to a case of force majeure, as defined in Section 18 (“Force Majeure”).

The Issuer will acknowledge receipt of a complaint within ten (10) Business Days of its receipt and will provide a substantive response within fifteen (15) Business Days. In exceptional cases where the Issuer cannot provide a response within this period, it will send an interim reply stating the reasons for the delay and indicating when the

Holder can expect a final response, which shall in any event be provided within thirty-five (35) Business Days.

Where a complaint relates to an unauthorised operation executed through Issuer-managed credentials, the Issuer will re-credit the Holder’s Account without undue delay following receipt of the complaint, unless there are reasonable grounds to suspect fraud on the part of the Holder.

For any questions, information, or complaints, the Issuer’s Customer Service is available to the Holder through the following channels:

• • • By email at: support@schuman.io
    • By telephone at: +33 (0)9 80 80 22 84 (local call rate from a landline), Monday to Friday from 9:00 to 16:00 Central European Time
    • Via the online form in the “Contact us” section of the Website: https://schuman.io/contact/

The Issuer makes these General Terms and Conditions and related communications available to the Holder in a form that enables them to be stored on a Durable Medium (for example, by email or by downloading a PDF from the Website). The Holder may at any time request a copy of these General Terms and Conditions or other contractual documents on a Durable Medium using the contact details in this Section.

The Issuer processes the Holder’s Personal Data in accordance with applicable laws on the protection of personal data, including Regulation (EU) 2016/679 of 27 April 2016 (the “GDPR”) and the French Data Protection Act of 6 January 1978 as amended.

Personal Data is collected and processed for the purposes of:

• providing Electronic Money issuance, use, and redemption services,
• fulfilling legal and regulatory obligations, including anti-money laundering and counter-terrorist financing (AML/CTF),
• carrying out fraud prevention and security checks,
• responding to requests, complaints, or disputes; and
• complying with any obligations to competent supervisory or judicial authorities.

The Holder’s Personal Data may be transmitted to the Issuer’s service providers, partners, and subcontractors strictly for the purposes listed above, and to competent authorities when legally required.

The Holder retains all rights under the GDPR, including the right of access, rectification, erasure, restriction of processing, portability, and the right to object to processing of their Personal Data, subject to legal and contractual limitations. These rights may be exercised by contacting the Issuer using the details in Section 13 (“Customer Relations”).

The Issuer’s detailed Personal Data protection policy is accessible at:
https://schuman.io/privacypolicy

In accordance with Article L.526-35 of the French Monetary and Financial Code, any person who participates in the management or direction of the Issuer or who is employed by the Issuer is bound by professional secrecy.

The Issuer may only disclose information covered by professional secrecy in cases where the law so provides, or with the express authorisation of the Holder.

The Issuer may also communicate information covered by professional secrecy to third parties where such disclosure is strictly necessary for:

• the negotiation, conclusion, or execution of transactions involving acquisitions of shareholdings or control in electronic money institutions, disposals of assets or businesses, assignments or transfers of contracts, or service contracts with a third party entrusted with important operational functions;
• the study or preparation of any type of contract or transaction, provided that the recipients of the information belong to the same group as the Issuer;
• compliance with AML/CTF obligations or instructions of competent authorities.

Persons receiving information covered by professional secrecy must treat it as confidential, whether or not the relevant transaction is completed. If the transaction is completed, such persons may, in turn, communicate the information under the same conditions to those with whom they negotiate, conclude, or execute the transaction.

When issuing or listing Electronic Money, the Issuer or the Crypto-asset Trading Platform shall first carry out full Know Your Customer (KYC) checks on the Holder. This includes identifying and verifying the identity of the Holder, gathering information relating to the purpose and nature of the business relationship, and updating this information throughout the duration of the relationship, where applicable.

The Holder undertakes to provide the Issuer or the Crypto-asset Trading Platform, as the case may be, with any information necessary to update knowledge of the Holder and the nature of the business relationship, including the purpose of operations, the origin and destination of funds, and the identity of the Holder and, if applicable, their beneficial owners, by producing supporting documents where required.

Holders are informed that no Transaction or redemption of Electronic Money can be executed if the Holder has not first undergone a KYC check by the Issuer or the Crypto-asset Trading Platform.

The Issuer reserves the right to suspend or delay the issuance, redemption, or execution of Transactions pending completion of AML/CTF checks, or where legal or regulatory reporting obligations apply.

Where required by law, information concerning the Holder and their Transactions may be transmitted to the competent authorities in France and abroad in accordance with AML/CTF obligations.

The texts and graphic elements, their assembly on the Website, and the Website itself are the exclusive property of the Issuer and are protected under applicable copyright legislation. The logos and distinctive signs of the Issuer are protected under trademark law.

Any deterioration of the elements present on the Website or of the Website itself, as well as any unauthorised reproduction, downloading, copying, modification, or commercial use, in whole or in part, of the various elements of the Website, is prohibited and exposes the author(s) to legal action.

These General Terms and Conditions do not authorise the reproduction, modification, or commercial use of any elements of the Website.

By accessing the Website, the Issuer grants the Holder a licence to use the Website subject to the following conditions:

• a private, personal, and non-transferable right to use the content of the Website or any of its component parts;
• a reproduction right for storage for the purpose of reproduction on a single-user screen, in one copy, for backup copies or hard copies;
• any use of documents from the Website must mention the source.

Any other use is prohibited, including commercial use, use in a network, or repeated and systematic
extraction of elements from the Website in contravention of applicable law.

Any use of the Website contrary to this Section constitutes an infringement of copyright for which the infringer may be held liable. Civil and criminal penalties may be imposed on any infringer.

Force majeure events are defined in accordance with Article 1218 of the French Civil Code as events that are unforeseeable, beyond the Parties’ control, and external, which make it impossible to perform the obligations under these General Terms and Conditions.

If a force majeure event occurs:

• The Issuer’s obligations under these General Terms and Conditions will be suspended;
• If the event persists for more than one (1) month, the Issuer’s obligations may be terminated.

The Issuer shall not be held liable for the non-performance of the contract due to a force majeure event.

The Party affected by a force majeure event must promptly notify the other Party of its occurrence and the measures being taken to mitigate its effects.

These Payment T&Cs are governed by French law.

In the event of a dispute arising between the Holder and the Issuer in connection with the performance of these Payment T&Cs, the Parties shall first seek to resolve the dispute amicably.

If the Holder and the Issuer are unable to reach an agreement, and in accordance with Article L.316-1 of the French Monetary and Financial Code, the Holder may refer the matter free of charge to the mediator of the French Association of Payment and Electronic Money Institutions (“AFEPAME”):

Association AFEPAME – Mediator
36, rue Taitbout
75009 Paris, France

Mediation is conducted in accordance with Articles L.612-1 et seq. of the French Consumer Code. In principle, mediation shall be concluded within ninety (90) days from the date on which the mediator notifies the Parties of their referral, in accordance with Article R.612-5 of the French Consumer Code.

Recourse to mediation is optional and does not affect the Holder’s right to bring proceedings before the competent French courts. The Parties may withdraw from the mediation process at any time.

In the absence of an amicable settlement or mediation, any dispute shall be submitted to the competent French courts.

All funds received by the Issuer in exchange for the issuance of Electronic Money are safeguarded in accordance with Article L.526-32 of the French Monetary and Financial Code.

Funds are deposited without delay in one or more segregated accounts opened with credit institutions established in the European Economic Area and are protected against the claims of the Issuer’s creditors, including in insolvency proceedings.

The Holder acknowledges and accepts that safeguarding measures apply only to funds received in exchange for the issuance of Electronic Money, and not to Electronic Money once transferred to another Holder or held in a Third-Party Wallet.

The safeguarding of funds received in exchange for the issuance of Electronic Money does not grant Holders any proprietary rights over the safeguarded accounts or underlying assets. Holders retain a contractual claim for redemption against the Issuer in accordance with applicable law.

The issuance and redemption of Electronic Money is provided free of charge for Holders acting as Consumer Holders. For Holders acting as Professional Holders, certain optional services such as automated minting or burning of Electronic Money may be subject to fees as agreed on a contractual basis. The Issuer reserves the right to deduct such fees from the Holder’s Electronic Money balance or to invoice the Holder directly, in accordance with the Order Form. All applicable fees, limits, and exchange rates are set out in the Order Form. Any modification of applicable fees or charges will be notified to the Holder within a reasonable period of time before the proposed effective date. If the Holder does not accept the proposed changes, the Holder may terminate these Payment T&Cs free of charge before the changes takes effect, with redemption of their remaining Electronic Money at par value.

Evidence: Data and records generated or stored by the Issuer’s systems in a secure and inalterable manner constitute proof of instructions, transactions, notices, and balances between the Parties.

Severability: If any provision of these Payment T&Cs is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect. The invalid provision shall be replaced by a valid provision reflecting as closely as possible the original intent of the Parties.

Non-assignment: The Holder may not assign or transfer their rights or obligations under these Payment T&Cs without the Issuer’s prior written consent. The Issuer may assign its rights and obligations to another authorised electronic money institution subject to applicable law and will provide the Holder with at least thirty (30) days’ prior written notice of any such assignment.

Regulatory Cooperation: The Holder acknowledges that Schuman operates under the supervision of the ACPR and may be required to provide information relating to the Holder or their Transactions to competent authorities in accordance with applicable regulatory obligations.

Third-Party Wallet Risk: Where Electronic Money is held or transferred through a Third-Party Wallet, the Issuer has no control over the custody, security, or operation of such wallet. The Holder acknowledges that the use of Third-Party Wallets is at their own risk and subject to the terms and conditions of the relevant wallet provider.

These General Terms and Conditions and Framework Contract for the Access and Use of the Platform (hereinafter referred to as the “Platform T&Cs”) govern all relations between:

• • On the one hand, Salvus SAS, trading as Schuman Financial, a simplified joint stock company incorporated under the laws of France, with the registered number 920 017 134 at the Registry of Commerce and Companies of Paris, and its registered office at 9, rue du 4 Septembre, 75002 Paris, France, authorised to carry on business as an electronic money institution approved by the Autorité de Contrôle Prudentiel et Résolution (ACPR) under articles L.526-1 et seq. of the Monetary and Financial Code, and under the register number 739803, and operating the Platform, hereinafter the “Company”, “Schuman”, “Issuer”, “We”, “us”, or “our”;

AND

• On the other hand, any natural or legal person who accesses, browses, or uses the Schuman Financial Platform, hereinafter the “User”, “Client”, “Holder” or “you” (see definitions hereunder);

Together hereinafter referred to as “the Parties”.

The purpose of these Platform T&Cs is to describe the terms and conditions under which Schuman grants the Client and its Users access and use to its proprietary software interface (the “Platform”) for the purpose of managing EURØP electronic money tokens (“EURØP”) and EUR units.

These Platform T&Cs govern the technical tools, access credentials (including the facilitation of vIBANs), and interfaces provided to manage the EMT. These Platform T&Cs form an addendum to, and must be read together with, the General Terms and Conditions of Use of Electronic Money Token EURØP (the “EURØP T&Cs”), Schuman’s EURØP White Paper, Privacy Policy, Cookie Policy, Redemption Policy, and any other T&Cs or Policy referred to in these Platform T&Cs and any Schuman Financial documentation available on the Schuman website (the “Website”). In case of inconsistency between these Platform T&Cs, the EURØP T&Cs, or Schuman’s EURØP White Paper, Privacy Policy, Cookie Policy, Redemption Policy, and any other T&Cs or Policy referred to in these Platform T&Cs, the provisions of Applicable Law shall prevail first. Subject to the foregoing, the EURØP T&Cs shall prevail with respect to all matters relating to the legal characteristics of the Electronic Money Token, including in particular Holder rights, redemption rights, unauthorised transactions, and statutory protections applicable to Electronic Money. These Platform T&Cs shall prevail with respect to the technical access to and operational use of the Platform, including platform access, technical functionality, credentials, vIBAN allocation and management, and the Automint/Autoburn processes, unless a specific provision expressly provides otherwise.

In these Platform T&Cs, the terms and expressions identified by a capital letter have the meaning indicated below, whether they are used in the singular or in the plural, or, if not defined here, can be found defined in the EURØP T&Cs:

• Actions of Third Parties: means any act, omission, delay, or failure to perform by any third party external to the Client or Schuman, including, but not limited to, Blockchain Network operators, payment processors, or banking partners, provided such act, omission, delay, or failure is outside the reasonable control of Schuman.
• AML: stands for anti-money laundering and refers to the laws, regulations, and internal processes designed to prevent criminals from disguising illegally obtained funds as legitimate income.
• Applicable Law: All relevant laws, regulations, directives, and rules in effect in France and the European Union relating to the services.
• Automint/Autoburn: designs the automated technical processes triggered by the Platform, whereby EURØP is minted upon the reconciliation of a fiat deposit, or burned upon a redemption request, in accordance with the Issuer’s operational rules.
• Blockchain Network: refers to the underlying distributed ledger technology, including but not limited to Ethereum, Polygon, Avalanche, Solana, Plasma and XRPL, on which EURØP is issued and transacted.
• Client: refers to a corporate customer or eligible individual who has successfully completed Schuman’s onboarding and KYC/KYB process, and who is approved by Schuman Financial to access the Platform. For the purposes of the Redemption Policy, a Client constitutes a “Customer”.
• Credentials: correspond to the unique identification elements, including but not limited to username, password, API keys, and 2FA tokens, provided to or created by the User to access the Platform.
• CTF: stands for countering the financing of terrorism and refers to the laws, regulations, and internal processes designed to restrict funding for terrorist organizations. CTF is often referenced together with AML as AML/CTF.
• Digital Assets: refer to any digital representation of value that is recorded on a cryptographically secured distributed ledger or similar technology, including, but not limited to, EURØP and other cryptocurrencies, tokens, or digital securities.
• Electronic Money/ Electronic Money Token: refers to a monetary value stored in electronic form and representing a claim by the Holder against the Issuer. The Electronic Money is issued by the Issuer in exchange for the surrender of funds by the Client.
• Force Majeure: means an event or circumstance, or a combination of events and circumstances, that is beyond the reasonable control of a Party and that materially and adversely affects the performance of the obligations under these Platform T&Cs, including, but not limited to, acts of God, fire, flood, war, civil disturbance, acts of terrorism, epidemic, pandemic, significant labour disputes, widespread failures of the internet or utility infrastructure, or regulatory changes that prohibit or materially restrict the Services.
• Holder: refers to any legal entity represented by a person with the rights to represent it and to bind it, or any natural person of legal age and capacity acting on its behalf for non-business purposes and having subscribed to these Platform T&Cs, as defined in Section 1 of the EURØP T&Cs. A Client is typically a Holder, but a Holder may not necessarily be a Client, e.g. if a Holder holds tokens in a Third-Party Wallet without Platform access.
• Intellectual Property Rights: refers to all intellectual property rights throughout the world including patents, copyrights, design rights, utility rights, trademarks, service marks, trade names, domain names, trade secrets, know-how, and all other proprietary rights, including registrations and applications for the foregoing.
• Issuer: Salvus SAS, a simplified joint stock company incorporated under the laws of France with the registered number 920 017 134 at the Registry of Commerce and Companies of Paris and its registered office at 9 rue du 4 Septembre in Paris (75002), authorised to carry on business as an electronic money institution approved by the Autorité de Contrôle Prudentiel et Résolution (ACPR) under articles L.526-1 et seq. of the Monetary and Financial Code, and under the register number 739803, as detailed in the EURØP T&Cs.
• KYC: refers to the legal obligations relating to the knowledge of the Client resulting from articles L.561-5 and L.561-5-1 of the French Monetary and Financial Code corresponding to the following obligations: identification and verification of the identity of the Client and, where applicable, of the beneficial owner of the business relationship, as well as knowledge of the purpose and nature of the business relationship and any other relevant information. The verifications and controls carried out upon entering into a relationship with Clients and, where applicable, during the course of the business relationship are adapted by the Issuer or the Crypto-asset Trading Platform, depending on whether the Client is a natural person or a legal entity. These checks and controls thus take account of the status of the Client to determine the nature and extent of the information to be collected to identify and verify the identity of the Client and, where applicable, its beneficial owner.
• Platform: refers to the web-based interface, API, server, and mobile application services, owned and/or operated by Schuman, providing access to the Services, including vIBAN management and wallet integration.
• Services: refers to the suite of technical features and functions provided by Schuman via the Platform to the User, as defined by Section 4 (Platform Services and Features), for the purpose of managing EURØP Electronic Money Tokens and EUR units.
• Smart Contract: refers to a self-executing computer program deployed on a Blockchain Network that automates the management of EURØP. Schuman’s Smart Contracts are subject to upgrades and modifications by Schuman at any time to, inter alia, ensure security and compliance.
• User: refers to any natural person acting as an authorized representative of a Client, who accesses, or uses, the Platform.
• vIBAN (Virtual IBAN): refers to a unique, dedicated virtual international bank account number assigned to a Client by Schuman, to facilitate the automated reconciliation of EUR deposits and withdrawals for the purpose of minting or redeeming EURØP.
• Whitelisted Account: refers to an international bank account number designated by the Client for fiat withdrawals that has been verified, approved, and registered by Schuman, subject to satisfactory KYC/KYB checks, to ensure compliance and security.

Schuman provides the following technical services via the Platform:

4.1. EUR Balance and Automated Management: the Platform provides a dashboard reflecting the Client’s EUR and EURØP positions. The Client acknowledges that the “EUR Balance” displayed corresponds to funds held in accordance with the EURØP T&Cs. The Platform automates the reconciliation of these funds to trigger Automint and Autoburn functions. Funds received in exchange for the issuance of EURØP constitute safeguarded funds and are held in accordance with the safeguarding regime applicable to electronic money institutions under the French Monetary and Financial Code and the EURØP T&Cs. The “EUR Balance” displayed on the Platform is informational and does not affect the safeguarding status of such funds.

4.2. vIBAN Deposits and Withdrawals: Schuman assigns vIBANs to individual Clients to categorize their positions and facilitate funding.

4.3. Deposits: funds sent to the Client’s designated vIBAN are automatically detected by the Platform to initiate the minting of EURØP from the client. All automated minting is subject to the Issuer’s operational rules and required regulatory screening checks, which may impact reconciliation speed.

4.4. Withdrawals: clients may instruct EUR withdrawals to their Whitelisted external bank accounts directly via the Platform interface. Schuman reserves the right to refuse or delay any withdrawal instruction as required for security, compliance, or regulatory reasons.

4.5. Whitelisting and Security: to ensure security and compliance, the Platform only permits withdrawals to bank accounts that have been verified by Schuman and deemed compliant for funding and withdrawals (“Whitelisted Accounts”). Clients may submit new accounts for whitelisting via the Platform, subject to satisfactory KYC/KYB verification.

4.6. Crypto Wallet Management: the Platform allows Clients to associate public blockchain addresses (“Digital Wallets”) with their Whitelisted Account.

Self-Custody: unless explicitly stated otherwise, Schuman does not hold private keys to User Wallets. You are solely responsible for the security of your Crypto Wallet credentials.

Multi-Chain Support: the Platform supports transactions on multiple networks, including, but not limited to XRPL, Ethereum, Polygon, Solana, Plasma and Avalanche. The User is responsible for selecting the correct network for their intended transaction, and acknowledges that any asset loss resulting from an incorrect selection is solely the User’s responsibility.

For token deposits or transfers via the Solana blockchain, Clients must use an externally owned account (“EOA”) under their direct control, meaning a wallet address controlled through the Client’s private keys and capable of directly signing and initiating transactions without the use of smart contracts or automated programs. Deposits from exchanges, multi-sender tools, smart contracts, or non-EOA wallets will result in permanent loss of funds, with no recovery provided by Schuman. The Client acknowledges and agrees that any such transfer is made at its sole risk and may result in the permanent and irreversible loss of the relevant funds, without any liability or recovery obligation on the part of Schuman.

As a condition to access the Services, you acknowledge, understand, and agree to the following:

5.1. Acceptance of Terms and Modification of Terms

5.1.1. Acceptance of Terms
By accessing the Platform, you acknowledge that you have read, understood, and accepted these Platform T&Cs and the complementary EURØP T&Cs. Details of where these can be found are listed in the appendix of this document. If you do not accept these Platform T&Cs and subsequent updates, you are not authorized to use the Platform.

5.1.2. Modification of Terms
The Issuer reserves the right to amend these Platform T&Cs at any time. In this case, the amended Platform T&Cs will be available for consultation on the Website no later than two (2) months prior to the proposed date of entry into force, unless such amendments are imposed by operational necessity, law, or regulation, that require immediate application.

If no objection is raised by the Client within the consultation period, the modified Platform T&Cs are deemed to have been accepted. If the Client refuses the proposed amendment, the Client may terminate these Platform T&Cs free of charge, by contacting the Issuer using the contact details indicated in Contact section of this document, unless the Client has agreed to specific terms with Schuman as part of a signed contract. Termination will result in redemption of any outstanding Electronic Money at par value in accordance with the Redemption Policy.

5.1.3. Early Termination Rights
Any request for termination pursuant to Article 12 below does not affect debits already due (including fees, subscriptions, payments) for which the Client remains liable.
The Client’s liquidation/bankruptcy, legal incapacity, or death, terminate these Platform T&Cs as soon as the Issuer is notified thereof. Unless the rightful claimants, the notary in charge of the estate, or the appointed liquidator agree to honour them, transactions carried out after such notification are deemed not to have been authorised.
The Issuer may also terminate these Platform T&Cs with two (2) months’ notice, without prejudice to immediate termination in the event of i) a requirement by a regulator, ii) an incurable breach, or fraud, by the Client, iii) substantiated AML/CTF concerns, or iv) other mandatory requirements under Applicable Laws or regulations. Issuer shall provide the Client with prompt written notice of any termination or suspension unless prohibited by law, rule, or regulation.

5.1.4. Technical Updates
Schuman may update the content, features, or technical specifications of the Platform to improve the Services. These updates do not constitute a modification of the legal conditions unless such updates materially affect the Client’s rights. Schuman will provide commercially reasonable advance written notice of material updates to the Platform.

5.2. Eligibility and Credentials

• Age Requirement: you must be at least eighteen (18) years old to register as a Client or use the
  services as a User.
• Geographic Restrictions: you may not access or use the Services if you are located in a country where Schuman is legally restricted from providing the Services, or if your jurisdiction is subject to economic sanctions (“Prohibited Jurisdictions”). Schuman reserves the right to terminate access immediately upon any change in your legal status, or location, that violates this clause, or if the location you are based becomes a jurisdiction where Schuman is legally restricted from providing the Services.
• Eligibility and Categorization: access to the Platform is granted on an individual basis determined by Schuman. Schuman uses vIBANs and other diligence data to categorize Clients and Users, and determine the applicable permissions and limits.
• User Account and Security: to access the Services, the user must log in using the identification details provided by Schuman. Clients are solely responsible for maintaining the confidentiality of their login details and all activities that take place under their account.
• Technical details: account creation is performed by Schuman Financial upon completion of due diligence. The authentication service utilises a 2FA module, operated by Trustbuilder or a similar provider.

5.3. Client Commitments and Warranties

• Lawful Use and Prohibited Activities: your use of the Services must comply with all Applicable
  Laws, rules, and regulations, as well as all other applicable Schuman T&Cs.
• Digital Asset Ownership: you have full ownership of or valid authorization to use any Digital
  Assets employed in connection with the Services, and all such assets were legally obtained.
• Information Accuracy: all information you provide is, to the best of your knowledge, accurate,complete, and up to date.
• Security Measures: you will maintain the security and confidentiality of your private keys, passwords, API keys, and other credentials associated with your account, and you shall bear sole responsibility for any loss resulting from the compromise of such private keys, passwords, API keys, or other credentials unless the compromise is due in any part to a Schuman-side breach or Schuman’s fraud, wilful misconduct, gross negligence, any Applicable Law or regulation, or breach of the terms of a separate agreement between Schuman and the Client.
• Independent Judgment: you will exercise your own judgment and will not rely on any information received through the Services as a recommendation (financial, investment, or otherwise)
• Legal Compliance: you will comply with all Applicable Laws, rules, and regulations, regarding transactions, including determining the accredited investor status of investors and the compliance of investments with local laws.
• Professional Advice: you will seek appropriate professional advice, such as legal, tax, or accounting counsel, to protect your interests.
• No Endorsements: you will not treat any content, email, or information received through the Services as an endorsement or recommendation by Schuman unless explicitly stated.

You agree that you will not knowingly engage in, encourage, induce, or assist others in engaging in any of the following prohibited activities in using the Services:

6.1. Financial Crime and Sanctions Circumvention

• Prohibited Financial Activities: engage in any transaction intended to disguise the proceeds of illegal activity, or use the Services for money laundering, terrorist financing (AML/CFT violations), or any activity related to sanctioned persons or entities.
• Sanctions Evasion: violate any applicable sanctions program, including those enforced by the European Union, OFAC, or the United Nations, or attempt to access or use the Platform from any Prohibited Jurisdiction.
• Structuring: use the Platform to execute multiple transactions designed to avoid regulatory reporting requirements (e.g., structuring deposits or withdrawals).

6.2. Digital Asset and Market Integrity

• Market Manipulation: engage in or facilitate wash trading, spoofing, layering, front-running, or
  any other form of market manipulation related to EURØP or EUR transactions.
• Smart Contract Exploitation: attempt to exploit, bypass, or interfere with the functionality of any
  Smart Contract or Blockchain Network underlying the EURØP issuance.
• Wallet Harvesting: attempt to gain unauthorized access to any other Client’s or User’s private keys, Credentials, or Crypto Wallets.
• Chain Interoperability Abuse: intentionally send EURØP over an incorrect blockchain network with the intent to harm another party or the system.

6.3. Misuse of Platform Access and Data

• Unauthorized Use of vIBANs: sell, lease, share, or transfer, your unique vIBAN, or Credentials, to
  any third party who is not the approved Client or an authorized representative thereof.
• Impersonation: impersonate or attempt to impersonate Schuman, a Schuman representative or
  affiliate, a Schuman employee, another User, or any other person or entity.
• False Information: falsify, omit, or provide misleading information requested by Schuman during
  registration or related to your activities on the Platform or Services.
• Unauthorized Access & Interference: use a robot, bot, spider, or other automatic device, to monitor or copy materials on the Services for unauthorized purposes, or reverse-engineer, decompile, or disassemble software running on the Platform.
• Disruption: restrict or inhibit anyone’s use or enjoyment of the Services, or engage in conduct that may harm, offend, or expose Schuman, other Clients, or other Holders, to liability.

6.4. General Unlawful Conduct

• Illegal Activities: engage in transactions that violate any Applicable Law, rule, or regulation, including laws related to data export, or use the Services to disguise the proceeds of, or further, any breach of law or regulation, or to deal in contraband Digital Assets, funds, or proceeds, including transactions intended for tax evasion.
• Harm to Minors: exploit, harm, or attempt to exploit minors, through inappropriate content, requests for personal information, or any other means.
• Infringement or Harm: infringe upon the Intellectual Property Rights of others, or engage in illegal, threatening, fraudulent, or harmful activities.
• Unauthorized Funds: use funds or other value on the Platform that were not legally obtained or do not belong to you.
• Detrimental Conduct: engage in conduct that is detrimental to Schuman, other Users, or third parties.

7.1. Automated Execution (Automint / Autoburn): the Client acknowledges that the Platform uses automated technologies to mint EURØP in exchange for EUR fiat (“Automint”) and to redeem fiat in exchange of EURØP (“Autoburn”) under the following terms:

• Mint Trigger: a credit to any of the Client’s assigned vIBANs constitutes an immediate, irrevocable instruction to mint EURØP from the Client.
• Burn Trigger: a withdrawal request submitted through the Platform constitutes an immediate, irrevocable instruction to burn EURØP and release the corresponding fiat funds.
• Irrevocability: due to the real-time nature of these automated processes, instructions typically cannot be cancelled, reversed, or amended, once initiated. The Client is solely responsible for ensuring the accuracy of all transaction details (including beneficiary details and amounts) prior to execution.

In any case, nothing in these Platform T&Cs shall limit or waive a Holder’s statutory right to redeem Electronic Money at par value at any time, as set out in the Redemption Policy and Article 49 of MiCAR.

7.2. Transaction Thresholds and Manual Review: to comply with AML/CTF regulations and internal risk management policies, Schuman distinguishes transaction orders based on tiered processing limits (the “Tiered Processing Limits”):

• Automated Tier: transactions below a certain monetary threshold (the “Automated Limit”) are usually processed automatically by the Platform and therefore constitute Automint or Autoburn transactions.
• Regulated Review Tier: transactions exceeding the Automated Limit will be flagged for manual review (“Regulated Procedure”) by Schuman’s compliance team and may be subject to longer execution time, or where relevant, may be suspended or cancelled.
• Modification of Limits: The Client acknowledges that the Automated Limit is subject to change at any time by Schuman, without prior notice, depending on market conditions, regulatory updates, or security assessments. The current applicable limits depend on the client current and expected activity.
• Manual Review: manual reviews under the Regulated Review Tier shall be conducted in accordance with the KYC/KYT verification procedures set out in the Redemption Policy.

7.3. Security and Liability for Automation

• Client Error: Schuman is not liable for losses resulting from the Client sending funds to the wrong
  vIBAN or withdrawing fiat currency to an incorrect bank account.
• Unauthorized Access: the Client accepts that if a third-party gains access to their API keys or Credentials, such third party may trigger instant Automint/Autoburn functions. Schuman is not liable for such unauthorized transactions executed prior to the Client notifying Schuman to freeze the account and Schuman confirming implementation of this freeze unless such third-party access to API keys or credentials is due in any part to a Schuman-side breach or Schuman’s fraud, wilful misconduct, gross negligence, a breach of any Applicable Law or regulation, or a breach of any agreement between Schuman and the Client.
• System Latency: while the Platform aims for instant processing, the Client acknowledges that delays due to external banking systems (such as, inter alia, a failure or delay in processing times), or due to Blockchain congestion, are outside Schuman’s control.

7.4. Reconciliation and Conclusive Evidence: Schuman performs daily reconciliation of all vIBANs, Reserve Accounts, and Token balances. In the event of a dispute regarding the timing or amount of a transaction, data and records generated or stored by the Issuer’s systems in a secure manner (“Conclusive Evidence”) constitute proof of instructions, transactions, notices, and balances between the Parties. These records shall prevail over the Client’s internal records, barring a technical error demonstrated by the Client.

7.5. Operational Model and Elimination of Third-Party Treasury Accounts: the Platform operates a direct settlement minting model, in which fiat funds sent to a client’s vIBAN are automatically reconciled by Schuman’s internal treasury system without the use of any intermediary client deposit account (“CDA”), pooled treasury structure, or third-party settlement account.

8.1. Platform Availability and Technical Failures: Schuman strives to ensure the Platform is available 24/7. However, access may be suspended temporarily for maintenance, upgrades, regulatory, technical, or security reasons. Schuman does not guarantee that the Platform will be error-free or uninterrupted and is not liable for delays or losses caused by technical failures, system downtime, or interruption of the services unless caused in any part by a Schuman-side breach or Schuman’s fraud, wilful misconduct, gross negligence, or breach of any Applicable Law or regulation, or a breach of any agreement between Schuman and the Client.

8.2. Accuracy of Information and Prevailing Records: while Schuman makes every effort to ensure accuracy, the data displayed on the Platform (including EUR/EURØP balances, transaction history, and blockchain network transaction status) is provided for information purposes only. In the event of a discrepancy between the Platform display and the irrevocable records, the blockchain network or the Issuer’s core banking system (as applicable based on the nature of the data) shall prevail.

8.3. Exclusion of Liability: to the fullest extent permitted by Applicable Law (and without prejudice to the specific liability rules in the EURØP T&Cs regarding unauthorized transactions), Schuman shall not be liable for any direct, indirect, special, incidental, punitive, or consequential losses, including but not limited to:

• Losses arising from your use of a compromised device or network;
• Errors made by a User (e.g., inputting incorrect Wallet Addresses, selecting the wrong Blockchain
  Network, or inputting incorrect withdrawal details);
• Losses caused by market volatility, liquidity fluctuations or changes in trading dynamics; or
• Losses resulting from Actions of Third Parties (including blockchain network operators, payment processors, or banking partners) or Force Majeure events (including acts of God, war, and regulatory changes);

provided such losses are not due in any part to a Schuman-side breach or Schuman’s fraud, wilful misconduct, gross negligence, or breach of any Applicable Law or regulation, or a breach of any agreement between Schuman and the Client.

8.4. Risk Acknowledgement and Disclaimers: by using the Services, you expressly acknowledge and agree to the following inherent risks:

• Cryptographic and Network Risks: you understand the inherent risks associated with cryptographic and blockchain-based systems and the specific blockchain network supporting EURØP. Schuman is not responsible for the operation, functionality, security, or availability of these underlying networks.
• Blockchain Changes: Blockchain Networks are subject to changes, such as “forks,” that may impact the services and the value or transferability of EURØP. Schuman is not liable for consequences arising from such changes.
• Transaction Costs and Risks: You are solely responsible for all on-chain transaction costs associated with transfers of EURØP or other Digital Assets, and Schuman is not liable for variable costs or delays inherent to the Blockchain Networks.
• Development Risks: You acknowledge that the Platform and Services are subject to ongoing development and technological risks, which may lead to delays or incorrect information display. You assume sole responsibility for any potential consequences arising from these risks.

8.5. Security, Self-Custody, and No Recovery

• Private Key Security: You are solely responsible for securing your private keys and Credentials. Losing control of your private keys may result in permanent and irreversible loss of access to your Digital Assets.
• No Recovery: nor Schuman nor its affiliated entities and partners are expected to be able to retrieve or protect your digital assets if your private keys are lost or compromised.
• Account Security: you are responsible for maintaining the confidentiality of your account information and all activities under your account. Schuman is not liable for losses due to unauthorised use of your account, password, or private keys, even if without your knowledge, unless such losses are due in any part to a Schuman-side breach or Schuman’s fraud, wilful misconduct, gross negligence, or breach of any Applicable Law or regulation, or a breach of any agreement between Schuman and the Client.

The Client shall notify Schuman without undue delay upon becoming aware of any loss, theft, or unauthorised use of Credentials or API keys. Upon receipt of such notice, Schuman will implement reasonable measures to restrict access, subject to technical feasibility and Applicable Law. Allocation of liability for unauthorised payment transactions (if any) is governed by the EURØP T&Cs.

8.6. No Investment or Professional Advice: Schuman is not a registered broker-dealer, investment advisor, or manager. We do not offer investment advice, participate in transactions, or recommend specific investments. Information on the Platform is for informational purposes only and should not be construed as investment, legal, tax, or professional advice. You should seek independent professional advice before making financial decisions related to the Services. Schuman owes no fiduciary duties to you and expressly disclaims any such duties.

8.7. Pricing, Payments, and Fees: the use of the Platform may be subject to charges agreed upon separately between the Client and Schuman. Specifically, for Clients requesting or utilizing automated minting or burning services, these optional services may be subject to fees as agreed on a contractual basis. You are responsible for all on-chain transaction costs associated with on-chain transfers of any Digital Assets and all other fees reflected on the Platform at the time of your use of the Services.

8.8. Service Suspension and Termination: Schuman may, at its sole discretion, modify, suspend, or disable the Services, in whole or in part, temporarily or permanently, for any reason, including security or compliance checks. Upon termination of your access to the Platform, any of your Platform usage rights immediately cease. Schuman is not liable for any losses resulting from service. modifications or termination.

8.9. Waiver of Claims: by using the Services, you irrevocably waive, release, and discharge all claims against Schuman and its affiliates, directors, officers, employees, and agents, related to any of the risks and disclaimers outlined in this section.

8.10. Mandatory law carve-out. Nothing in these Platform T&Cs shall exclude or limit Schuman’s liability where such exclusion or limitation is prohibited by Applicable Law, including in cases of fraud, gross negligence, wilful misconduct, or breach of mandatory regulatory obligations.

Schuman is committed to processing personal data in accordance with the General Data Protection Regulation (“GDPR”) and applicable financial services legislation.
This section summarises key aspects of Schuman’s data processing; for full details, please refer to the Platform Privacy Policy.

9.1. Controller and Contact: the controller responsible for your data is Salvus SAS. For any questions regarding data protection, Schuman’s Data Protection Officer (DPO) can be contacted at: dpo@schuman.io

9.2. Purposes of Processing: Schuman processes personal data for the following strictly defined purposes:

• Contract Performance: to manage your account, verify permissions, and process EURØP minting and redemption instructions;
• Legal Compliance: to fulfil AML/CFT obligations, including identity verification (KYC/KYB), sanctions screening, and transaction monitoring; and
• Legitimate Interests: to secure the Platform against fraud and cyber-attacks, and to maintain technical logs for system integrity.

9.3. Data Categories and Retention: In accordance with our legal obligations, data is retained for specific periods:

• Customer Due Diligence & Transaction Data: (Identity documents, corporate registry info, and transaction records) are retained for five (5) years after the end of the business relationship, or up to ten (10) years where required by specific regulations.
• Technical and Security Logs: (IP addresses, access logs, and device info) are retained for up to two (2) years, unless required for security investigations.
• Support Communications: Retained for the duration of the business relationship plus two (2) years.

9.4. Data Processing Locations and Recipients
Locations: personal data is primarily processed on secure infrastructure located in France and
Switzerland.
Recipients: we share data on a strict need-to-know basis with authorized service providers, including, but not limited to, Banking Circle (payment services), Dotfile (identity verification), and Lukka (transaction monitoring).

9.5. Professional Secrecy: pursuant to Article L.526-35 of the French Monetary and Financial Code, any person who participates in the management or direction of the Issuer or who is employed therein is bound by professional secrecy.

In addition to the cases where the law so provides, the Issuer may communicate information covered by professional secrecy to the persons with whom it negotiates, concludes or executes the following transactions where such information is necessary for such transactions:

• Acquisitions of shareholdings or control in electronic money institutions;
• Disposal of assets or business;
• Assignment or transfer of contracts;
• Service contracts concluded with a third party with a view to entrusting it with important operational functions; and
• During the study or preparation of any type of contract or transaction, provided that these entities belong to the same group as the author of the communication.

In addition to the cases mentioned above, the Issuer or the Crypto-asset Trading Platform may communicate information covered by professional secrecy on a case-by-case basis and only when the persons concerned have expressly authorised them to do so.
Persons receiving information covered by professional secrecy which has been provided to them for the purposes of one of the above-mentioned operations must keep it confidential, whether or not the above-mentioned operation is successful. However, in the event that the aforementioned transaction is successful, these persons may, in turn, communicate the information covered by professional secrecy, under the same conditions as those referred to above, to the persons with whom they negotiate, conclude or execute the aforementioned transactions.
As described in the Privacy Policy, where data transfers outside the EEA occur, appropriate safeguards are implemented and data subjects have rights of access, rectification, erasure, restriction, portability, and objection, subject to legal limitations, and may lodge a complaint with the CNIL.

10.1. Ownership: The Platform, including its source code, visual interface, API structure, Schuman trademarks, and all related content, remains the exclusive property of Schuman (or its licensors/affiliates). You acknowledge that you have no ownership rights in the Platform other than the limited right to use it in accordance with these terms.

10.2. Limited License: Subject to these Platform T&Cs, Schuman grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Platform solely for the purpose of managing your EURØP and EUR positions. Any use of the Platform not expressly permitted by these terms is a breach of this license and may violate copyright, trademark, and other laws.

11.1. Monetary Cap on Liability: to the maximum extent permitted by , the total cumulative liability of Schuman, its affiliates, licensors, officers, and directors to you for any claim arising out of or relating to these Platform T&Cs or the Services, regardless of the form of action, shall not exceed the lesser of: (a) one hundred euros (€100); or (b) the total amount of fees paid by you to Schuman in the twelve (12) months preceding the event giving rise to the claim. This liability cap applies strictly to platform technical failures and does not affect Holders’ claim on the underlying funds.

11.2. Indemnification: You agree to defend, indemnify, and hold harmless Schuman from and against all third-party claims, and resulting damages, obligations, losses, liabilities, costs, and expenses (including reasonable attorney’s fees) arising out of or relating to:

• Your material violation of these Platform T&Cs;
• Your unauthorized use or intentional misuse of the Platform and Services;
• Your violation of any third-party right, including any copyright, property, or privacy right; or
• Any claim that your use of the Platform or Services caused damage to a third party; provided that You have no obligation to indemnify Schuman under this Section to the extent that any such claim arises in any part from Schuman’s fraud, wilful misconduct, gross negligence, or breach of any Applicable Law or regulation.

12.1. Termination by Client: You may terminate your access to the Platform at any time by ceasing to use the Services and notifying Schuman in writing to close your account.

12.2. Termination by Schuman: Schuman reserves the right to suspend or terminate your access to the Platform (i) immediately, with or without notice, in the event of a material non-remediable breach , or (ii) upon thirty (30) days’ written notice for a material remediable breach that remains uncured at the end of such period, of these Platform T&Cs, the General Terms and Conditions of Use of Electronic Money Token EURØP, or the EURØP MiCA Redemption Policy;

Schuman is required to prevent restricted persons from holding EURØP. A restricted person is any person who is:

• not able to provide sufficient or consistent information in order to be identified and verified by Schuman in accordance with Applicable Laws;
• subject or target to sanctions, or owned or controlled by an entity subject to sanctions, including persons named at any time in any sanctions-related list maintained by France, the European Union and any other countries in compliance with Schuman’s AML CFT Policies;
• located, organised or resident in a country, territory or geographical region which is itself the subject or target in the Schuman Prohibited Countries List (www.schuman.io/prohibited-countries); or
• initiating a suspicious transaction according to the meaning of Applicable Laws.

Clients may submit any complaint via the contact form available at https://schuman.io/contact/, by email at support@schuman.io, by telephone at +33 (0)9 80 80 22 84, or by post to Salvus SAS, 9 Rue du Quatre Septembre, 75002 Paris, France.

Complaints are handled free of charge. Schuman will acknowledge receipt within five (5) business days and aims to provide a final response within fifteen (15) business days.

If the Client is not satisfied with the response, or in the absence of a response within the above timeframe, the Client may refer the matter free of charge to the Médiateur de l’AFEPAME or the AMF Ombudsman, without prejudice to the right to bring proceedings before the competent courts as provided in Section 13.

The Platform T&Cs and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) shall be governed by and construed in accordance with French law.

In the event of a dispute, the Parties shall first seek an amicable resolution. Failing this, and subject to specific consumer protections where applicable the dispute will be submitted to the French courts.

For any questions regarding these Platform T&Cs, to report a technical issue, or to exercise your rights, please contact us at:

Salvus SAS Address: 9 rue du 4 Septembre, 75002 Paris, France
General Inquiries: contact@schuman.io
Data Protection: dpo@schuman.io

Salvus SAS is a company incorporated under the laws of France with registration number 920 017 134 at the Paris Registry of Commerce and Companies, with its registered office located at 9 rue du Quatre Septembre, 75002 PARIS (“Schuman”). Schuman is licensed by the French Autorité de contrôle prudentiel et de résolution (ACPR) as an electronic money institution (établissement de monnaie électronique) under articles L.526-1 et seq. of the French Monetary and Financial Code.

Terms capitalised in the Redemption Policy are defined as in the EURØP white papers.

In this policy, EURØP is referred to as the “Schuman EMT”. Natural persons holding Schuman EMT, whether EURØP or other EMTs, are identified as “Schuman EMT Holders”. Among these, a natural person acting for personal purposes outside of trade, business, craft, or profession and holding EURØP or other Schuman EMT is referred to as a “Retail Holder”.

1.1. Pursuant to Article 49 of MiCAR2, all Schuman EMT Holders have a right of redemption of their Schuman EMT at any time and at par value, subject to the conditions set out in the present policy.

1.2. Schuman’s Customers, i.e. holders that agreed to the Terms of Use of the Schuman platform or sign a Services Agreement with Schuman (the “Customers”) shall exercise their redemption right in compliance with the Terms of Use of their Schuman Financial Order Management Platform (“Schuman OMP”) Account and/or the applicable Services Agreement directly with Schuman.

1.3. Schuman EMT Holders other than Customers shall exercise their redemption right with respect to the Schuman EMT against Schuman in accordance with the following Sections.

At any time, Schuman EMT Holders may buy and/or sell the Schuman EMT via Crypto-asset Trading Platforms accepting EURØP and/or Schuman EMT trading.

2.1. Schuman EMT Holders (other than Retail Holders)

To redeem their Schuman EMT, Schuman EMT Holders, other than Retail Holders, shall open a Schuman OMP Account to access redemption-only service and agree to the Terms of Use of the Schuman OMP.
Schuman EMT Holders, other than Retail Holders, shall meet the criteria to open a Schuman OMP Account to redeem their Schuman EMT, including but not limited to the previous KYC and KYT, as further specified in this policy.

2.2. Retail Holders

Retail Holders may redeem the Schuman EMT directly from Schuman Financial by filling out the redemption form on Schuman’s website.

Retail Holders shall meet the criteria further specified in the present Redemption Policy to redeem the Schuman EMT. Schuman shall assess the eligibility of the relevant Retail Holder for redemption based on the information provided in such form and in accordance with the criteria set out. This includes the provision of a valid public key of the wallet holding the Schuman EMT.

Upon confirmation of eligibility, Schuman shall perform the mandatory verifications of the identity of the Retail Holder and other checks (KYC and KYT).

2.3. Eligibility criteria for redemption request of Retail Holders

Schuman has to abide by different regulations and Applicable Laws depending on the location of the Retail Holder.

In order to ensure compliance with Applicable Laws, including the anti-money laundering (“AML”) and counter-terrorist financing (“CTF”) requirements, the redemption of Schuman EMT will be performed if the Retail Holder can provide accurate information for the KYC and KYC verifications to be performed and validated by Schuman.

Retail Holder shall also provide an IBAN and BIC/Swift code from an EEA Bank Account for a SEPA transfer of funds.

3.1. Prior to the redemption of the Schuman EMT, Schuman shall perform:

3.1.1. Identification and verification of identity of the Schuman EMT Holders in compliance with Schuman’s AML CFT Policies and Applicable Laws (Schuman will carry out all relevant checks, reviews and internal processes);

3.1.2. Transaction monitoring verifications;

3.1.3. Verifications related to asset freezing measures;

3.1.4. Any other action required for the purpose of complying with all Applicable Laws.

3.2. In cases where the actions referred to in paragraph 3.1 would (upon Schuman carrying out all relevant internal checks, review and internal processes) reveal inconsistencies and/or AML, CFT or sanctions circumvention risks, the redemption of the Schuman EMT will be subject to further assessment in compliance with the applicable laws.

While there is no minimum threshold for redemption, Schuman Financial reserves the right to review and prohibit multiple successive redemption requests if they lack a justifiable reason or are evidently intended to disrupt Schuman Financial’s services or adversely affect the usage or availability of EURØP. If such a prohibition is enacted, Schuman Financial will provide the affected party with a clear explanation of the decision.

4.1. For Schuman EMT Holders, other than Retail Holders, redemption will be performed on the Schuman OMP Account open by the Schuman EMT Holders in accordance with the Terms of Use of the Schuman OMP Account of Schuman.

4.2. For Retail Holders, Schuman will request Retail Holders to provide bank details that comply with the Redemption Policy and sign an electronic form to attest that:

• Their bank account details are correct
• They are the beneficiary on the bank account
• If requesting a EURØP redemption, the bank account is able to accept SEPA payments (only standard acceptable)
• Accept that any potential charges or other fees (e.g. currency conversion or incoming deposit fees) charged by the Holder’s bank are not the responsibility or in the control of Schuman and, therefore, the responsibility of the Holder.

Schuman will provide Retail Holders with a unique deposit wallet address generated by Schuman. Retail Holder shall deposit the Schuman EMT(s) it wishes to redeem to this address.

Upon receipt of the Schuman EMT(s) on the deposit address, Schuman will perform relevant verifications on the Schuman EMT(s) including on previous transactions on the Schuman EMT(s). Once verifications are performed and all redemption eligibility criteria are met, Schuman will provide payment to the Retail Holder to their bank account.

This process is expected to take no more than 5 business days unless discrepancies are identified during the redemption process.

5.1. KYC, KYT, and Asset Freeze

5.1.1. Redemption of Schuman EMT shall be subject to the identity checks, transactions monitoring verifications and other actions referred to in Section 5.

5.1.2. Schuman is required to prevent restricted persons from holding Schuman EMT. A restricted person is any person who is:

a. not able to provide sufficient or consistent information in order to be identified and verified by Schuman in accordance with Applicable Laws;

b. subject or target to sanctions, including persons named at any time in any Sanctions-related list maintained by France, the European Union and any other countries in compliance with Schuman’s AML CFT Policies; or

c. located, organised or resident in a country, territory or geographical region which is itself the subject or target in the Schuman Prohibited Countries List (www.schuman.io/prohibited-countries); or

d. initiating a suspicious transaction according to the meaning of Applicable Laws; or

e. owned or controlled by any such person or persons listed above.

Together, the “Restricted Persons”.

5.1.3. In the event that a Restricted Person has acquired Schuman EMT in breach of the EURØP white paper, Schuman EMT Holder(s) qualified as Restricted Person may not redeem the Schuman EMT.

5.2. Schuman EMT Holders that do not meet redemption requirements as defined in this Redemption Policy will be denied their Schuman EMT redemption request. In case of complaints or disputes with regard to the execution of the Redemption Policy, Schuman EMT Holders shall refer to Section “Complaints & Disputes” of the EURØP white paper.

6.1. Given the decentralised and open-source nature of Schuman’s e-money tokens, it is possible for unaffiliated third parties to develop an alternative or equivalent version of Schuman EMT on a EURØP-supported blockchain or on an unsupported blockchain (a “Copy“), operating independently from Schuman. Likewise, an unaffiliated party may issue an asset that claims to be collateralised by or incorporate Schuman EMT in its structure (a “Wrapper”). Schuman exclusively supports Schuman EMT and bears no obligation to support any Copies of Schuman EMT or Wrappers. Schuman assumes no responsibility for any loss of value that may arise from the use of such Copies or Wrappers.

6.2. Due to the decentralised and open-source nature of the blockchains on which Schuman EMTs are supported, an unaffiliated third party may create an alternative version of the blockchain (“Fork”). In the event of a Fork affecting one of the EURØP-supported blockchains, Schuman may be required to suspend all activities relating to the affected Schuman EMT for an extended period until Schuman, at its sole discretion, determines that full functionality can be restored (“Downtime”). This Downtime may commence immediately upon a Fork, potentially with minimal or no prior notice, during which Schuman EMT Holders will be unable to engage in various activities involving EURØP and/or other Schuman EMTs. In the case of a Fork on one of the EURØP-supported blockchains and/or Schuman EMT-supported blockchains, Schuman reserves the exclusive right, at its sole discretion, to decide which Fork, if any, it will support.

7.1. Schuman reserves the right to amend any provision of this Redemption Policy at any time by posting the updated version, including a revised date, on Schuman’s webpage and following the procedures outlined in Part D of the EURØP white paper.

7.2. Changes to the Redemption Policy will take effect and be deemed accepted by Schuman EMT Holders upon their first access or use of EURØP following the initial posting of the revised policy. These amendments shall apply on a forward-looking basis to transactions initiated after the posting date. If a Schuman EMT Holder does not agree with any such modifications, the Holder’s sole and exclusive remedy will be to cease the use of EURØP/Schuman EMT and close their account on the Schuman platform (if applicable). Schuman EMT Holders acknowledge that Schuman shall bear no liability to them or any third party for any losses incurred as a result of modifications to the Redemption Policy.

7.3. For any Material Change to this Redemption Policy, Schuman shall provide advance notice to Schuman EMT Holders via Schuman’s webpage prior to the change becoming effective. For these purposes, a “Material Change” is a significant modification that does not include (i) changes that benefit Schuman EMT Holders, (ii) amendments necessary to comply with Applicable Laws or regulatory requirements, (iii) the introduction of a new product or service, or (iv) clarifications to existing terms.

7.4. Should any significant new factor, material error, or substantial inaccuracy that could impact the evaluation of Schuman EMT arise within the Redemption Policy, Schuman shall promptly notify the competent authorities with the revised policy.

8.1. This Redemption Policy may be automatically amended or suspended by implementation of the Recovery Plan and/or the Redemption Plan in accordance with Article 55 of MiCAR.

8.2. In this scenario, Schuman EMT redemption will be managed as defined in the Schuman Recovery or Redemption Plans (as required by competent authorities) to ensure the timely implementation of recovery actions.

8.3. Schuman EMT Holders shall refer to Sections 4.3 and 4.4. of the EURØP white paper.

9.1 This Redemption Policy is governed by and shall be construed in accordance with the laws of France (“Applicable Laws”). Any dispute arising under this Redemption Policy shall be subject to the exclusive jurisdiction of the Commercial Courts of Paris, France, except where otherwise restricted by Applicable Laws.

9.2 This Redemption Policy is subject to compliance with the laws, regulations, and rules of any relevant governmental or regulatory authority, including, but not limited to, applicable tax laws, AMF CFT provisions, and sanctions. Schuman EMT Holders agree to adhere to this Redemption Policy and to abide by all Applicable Laws and regulations. Continued compliance with this Redemption Policy, the EURØP white paper, and all Applicable Laws and regulations is a condition of holding and transacting with Schuman EMTs.

1 As defined in MiCAR for “retail holder”.
2 Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (“MiCAR”)