1. About Rhoam and These Terms

1.1 Who We Are

Rhoam is an AI-native financial platform providing digital financial services including multi-currency accounts, cross-border payments, open banking, crypto services, card issuance, and AI-powered financial assistance through Rhoami.

Rhoam operates through two legal entities:

Rhoam operates across global markets through a combination of its own capabilities and a carefully selected network of licensed and regulated financial institutions, payment processors, and infrastructure providers. In certain jurisdictions, Rhoam provides services directly. In others, services are delivered in whole or in part through licensed partners who hold the relevant regulatory approvals required in their respective markets, with Rhoam leveraging those frameworks to extend its reach and ensure every user is served within a compliant, regulated structure. Whichever model applies to you, the standard of service, security, and protection you receive remains the same. We will always be transparent about which entity — Rhoam or a regulated partner — is providing your services in any given jurisdiction.

References to "Rhoam", "we", "us", or "our" refer to the Rhoam entity serving you in your jurisdiction.

1.2 Acceptance of Terms

By registering for an account, accessing, browsing, or using the Rhoam Platform in any way, you acknowledge that you have read, understood, and agree to be bound by:

• These Terms and Conditions
• Our Privacy Policy (rhoam.money/privacy)
• Our Cookie Policy (rhoam.money/cookies)
• Any product-specific terms applicable to services you use
• Any applicable fees schedule published on the Platform

These documents collectively form the agreement between you and Rhoam (the "Agreement").

1.3 Changes to These Terms

We may update these Terms to reflect changes in law, our services, or business practices. For material changes that adversely affect you, we will provide at least 30 days' advance notice where required by law, by:

• Email to your registered email address
• In-app notification
• Prominent notice on our website

Continued use of the Platform after the effective date of updated Terms constitutes your acceptance. If you disagree with any changes, you must stop using the Platform and close your account.

2. Eligibility and Account Registration

2.1 Eligibility

To use the Rhoam Platform, you must:

• Be at least 18 years of age (or the age of majority in your jurisdiction, whichever is higher)
• Have the legal capacity to enter into a binding contract
• Not be a resident of, or accessing the Platform from, a jurisdiction where our services or the services of our partners are prohibited or restricted by law
• Not be on any applicable sanctions list or otherwise prohibited from receiving financial services
• Provide accurate, truthful, and complete information during registration and throughout your use of the Platform

We reserve the right to verify your eligibility at any time and to restrict or terminate access if eligibility requirements are not met.

2.2 Account Registration

To access most Platform features, you must create an account. You agree to:

• Provide accurate, current, and complete personal information
• Maintain and promptly update your account information
• Keep your login credentials and any one-time passwords (OTPs) strictly confidential — Rhoam staff will never ask for your OTP or password
• Not share your account with any other person
• Notify us immediately at support@rhoam.money if you suspect any unauthorised access

You are responsible for all activity that occurs under your account.

2.3 Identity Verification (KYC/AML)

As a platform operating in the financial services space and working with licensed and regulated partners across multiple jurisdictions, the verification of your identity is a fundamental requirement before you can access certain features or transaction limits. You agree to:

• Submit valid government-issued identification documents as requested
• Provide proof of address and other documentation as required
• Cooperate with any enhanced due diligence (EDD) requests
• Allow us to verify your identity through third-party identity verification providers

We reserve the right to limit, suspend, or close your account if you fail to complete KYC, if documents cannot be verified, or if we have concerns about potential financial crime. We are not liable for any loss arising from account restrictions imposed for compliance reasons.

2.4 Business Accounts

Businesses and organisations may apply for a Rhoam business account. Additional verification requirements apply, including company registration documents, proof of address, and identification of directors, shareholders, and beneficial owners. The individual registering on behalf of a business warrants that they have authority to bind that entity to these Terms.

3. Rhoam Services

3.1 Overview of Services

Subject to eligibility, KYC completion, and applicable restrictions, Rhoam may offer the following services, which are delivered in whole or in part through our network of licensed and regulated partners:

Payments and Transfers

• Domestic and international money transfers
• Cross-border remittances to supported corridors
• Peer-to-peer payments between Rhoam users via Rhoam ID
• Scheduled and recurring payment instructions

Account Services

• Digital multi-currency wallet and account management
• Virtual account numbers and local account details (where available and subject to partner availability)
• Real-time transaction notifications and statements

Open Banking and Connectivity

• Connection to external bank accounts via open banking (UAE and other supported jurisdictions via our licensed open banking partners)
• Account information aggregation and transaction analysis
• Payment initiation from linked accounts

Crypto Services

• Purchase and sale of supported digital assets (delivered through our regulated crypto infrastructure partners who hold applicable licences and approvals in their respective jurisdictions)
• Transfer of digital assets to and from external wallets
• Crypto-fiat conversion via our licensed infrastructure partners

Card Services

• Virtual and physical payment cards issued through our licensed card issuing partners
• Contactless payments via Apple Pay, Google Pay, and other supported wallets

Rhoami AI

• AI-powered financial assistant providing transaction analysis, spending insights, FX guidance, and financial recommendations
• Autonomous features (scheduled payments, rate alerts, agentic actions) available on qualifying subscription tiers
• Rhoami operates in English and multiple languages including Arabic, Urdu, Tagalog, Bengali, and Malay

The availability of specific Services may vary by country or region and is subject to the coverage of our licensed partner network. We will always clearly indicate which Services are available to you based on your location and account type.

3.2 Partner Licensing

From time to time, Rhoam may deliver certain services through licensed and regulated third-party partners. Where this is the case, those partners hold the relevant licences and regulatory approvals in their respective markets. You may in such circumstances also be subject to the terms and compliance obligations of the applicable partner. We will make relevant partner information available to you upon request.

3.3 Service Availability

We aim to provide a reliable and continuously available Platform, but we do not guarantee uninterrupted access. The Platform may be temporarily unavailable due to scheduled maintenance, unplanned technical issues, third-party provider outages, or regulatory requirements. We will use reasonable efforts to restore services promptly and are not liable for losses arising from unavailability beyond our reasonable control.

3.4 AI Services Disclaimer

Rhoami is designed to assist you with financial information and task execution. Rhoami does not provide regulated financial advice, investment recommendations, or tax guidance. Information provided by Rhoami is for informational and assistance purposes only. You should seek independent professional advice before making financial decisions. Rhoami may make errors; you should verify important information before acting on it.

3.5 Changes to Services

We may modify, discontinue, or add features and services at any time. For material changes that adversely affect you, we will provide at least 30 days' notice where required by law or regulation.

4. Payments, Fees, and Currency

4.1 Subscription Tiers

Rhoam offers the following subscription tiers. Features, limits, and pricing for each tier are published at rhoam.money/pricing and updated periodically with advance notice:

• Sapphire (Free): Core platform access at no charge
• Signature: Full banking, open banking, and Rhoami Pro features — charged monthly as per published pricing
• Reserve: Agentic AI, premium card, and priority service — charged monthly as per published pricing

Subscription fees are charged in advance. By subscribing, you authorise Rhoam to charge the applicable fee to your Rhoam account balance or linked funding source on a recurring basis.

4.2 Transaction Fees

Some transactions are subject to fees as set out in our Fees Schedule at rhoam.money/fees. Fees may include transaction fees, currency conversion margins, and third-party network charges. We will always disclose applicable fees before you confirm a transaction.

4.3 Currency Exchange

When you exchange currencies, Rhoam applies an exchange rate that includes a margin above the interbank rate. This margin is part of our revenue. The exact rate and margin will be shown to you before you confirm. Exchange rates fluctuate; the rate quoted is only valid for the period stated at the time of the quote.

4.4 Payment Instructions

When you submit a payment instruction, you authorise Rhoam to debit the specified amount plus applicable fees. You are responsible for ensuring the accuracy of all payment details including recipient account numbers, IBANs, names, and amounts. Rhoam is not liable for losses arising from incorrect payment details you provide.

4.5 Transaction Limits

We apply transaction and account limits based on your KYC status, subscription tier, account type, jurisdiction, and risk profile. Current limits are displayed in your account settings. Limits may be adjusted with notice.

4.6 Cancellations and Refunds

Once a payment instruction is submitted and processing has commenced, it may not be possible to cancel or reverse it. Our ability to refund or reverse a transaction depends on the payment network used and the transaction status at the time of the request. Fees already charged may not be refundable.

4.7 Funding Your Account

You may fund your Rhoam account via bank transfer, debit card, or open banking payment initiation. All funding sources must be in your own name; we do not accept third-party funding unless explicitly permitted. We may return funds if we are unable to verify their source or if they raise compliance concerns.

5. Rhoam ID

Rhoam ID is your unique username within the Rhoam ecosystem (in the format @username). It enables:

• Instant peer-to-peer transfers to other Rhoam users without requiring bank account details or IBANs
• In-app messaging and social finance features including group chats and bill splitting (on qualifying tiers)
• A shareable payment link for requesting money

You are responsible for the accuracy of the Rhoam ID you use when sending payments. Payments sent to an incorrect Rhoam ID may not be recoverable. Rhoam IDs must comply with our acceptable use standards and may not impersonate another person or brand.

6. Prohibited Activities

You must not use the Rhoam Platform for any of the following. Violation may result in immediate account suspension, termination, and referral to relevant authorities.

6.1 Illegal and Fraudulent Use

• Money laundering, terrorist financing, or proliferation financing
• Fraud, identity theft, or impersonation
• Sanctions evasion or transacting with sanctioned individuals, entities, or jurisdictions
• Any activity that is illegal under UAE law, your home jurisdiction law, or applicable international law

6.2 Misuse of the Platform

• Using the Platform for pyramid schemes, Ponzi schemes, or any multi-level marketing arrangement prohibited by law
• Purchasing or selling illegal goods or services
• Processing transactions on behalf of third parties without our prior written consent
• Structuring multiple smaller transactions to bypass transaction limits or AML thresholds
• Providing false, misleading, or incomplete information to Rhoam

6.3 Technical Misuse

• Attempting to gain unauthorised access to any part of the Platform or its underlying systems
• Introducing malware, viruses, or any malicious code
• Scraping, crawling, or harvesting data from the Platform without written permission
• Reverse engineering, decompiling, or disassembling any part of our software
• Interfering with the operation of the Platform or other users' access to it
• Attempting to manipulate, deceive, or abuse Rhoami AI systems

6.4 Gambling and High-Risk Activities

Use of Rhoam for online gambling, unlicensed investment schemes, or other high-risk financial activities that are restricted or prohibited in the UAE or other relevant jurisdictions is not permitted.

7. Intellectual Property

7.1 Rhoam's Intellectual Property

All intellectual property rights in the Rhoam Platform — including software, code, design, trademarks, logos, brand name, Rhoami AI, and documentation — are owned by or licensed to Rhoam. Nothing in these Terms grants you any right, title, or interest in Rhoam's intellectual property other than the limited licence to use the Platform described below.

7.2 Licence to Use

We grant you a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform solely for your personal or business financial management purposes in accordance with these Terms. This licence does not include the right to sublicense or sell access, use the Platform to build a competing product, or copy or create derivative works of Platform content.

7.3 Your Content

Any content you submit to the Platform remains yours. By submitting it, you grant us a non-exclusive, worldwide licence to use, process, and store that content solely for the purpose of providing the Services.

8. Privacy and Data Protection

Your privacy is important to us. How we collect, use, store, and share your personal data is set out in our Privacy Policy at rhoam.money/privacy, which forms part of this Agreement.

By using the Platform, you acknowledge and consent to our data practices as described in the Privacy Policy. We process personal data in accordance with applicable data protection laws including UAE Federal Law No. 45 of 2021, the DIFC Data Protection Law 2020 (where applicable), the ADGM Data Protection Regulations 2021 (where applicable), the EU GDPR (for EU residents), the Australian Privacy Act 1988 and APPs (for Australian users), and all other applicable data protection laws.

9. Account Security

9.1 Your Security Responsibilities

You are responsible for maintaining the security of your account. You must:

• Use a strong, unique password and not reuse it across other services
• Enable multi-factor authentication (MFA) — this is required for full Platform access
• Never share your account credentials, OTPs, or verification codes with anyone — including anyone claiming to be Rhoam staff
• Log out when using shared or public devices
• Keep your device operating system and Rhoam app updated
• Notify us immediately at support@rhoam.money if you suspect your account has been compromised

9.2 Unauthorised Access

If you believe your account has been compromised or you notice unauthorised transactions, notify us immediately. We will act promptly to secure your account. We are not liable for losses arising from your failure to maintain account security or to promptly report a suspected compromise.

9.3 Our Security Measures

We implement appropriate technical and organisational security measures including encryption in transit (TLS 1.3) and at rest (AES-256), MFA, regular penetration testing, and strict access controls. No system is completely secure and we cannot guarantee absolute protection against all possible threats.

10. Suspension, Termination, and Account Closure

10.1 Your Right to Close Your Account

You may close your Rhoam account at any time through the in-app account closure process or by contacting support@rhoam.money. Any remaining balance must be withdrawn to an account in your name before closure. We will process your request within a reasonable timeframe, subject to any pending transactions or compliance holds.

10.2 Our Right to Suspend or Terminate

We may suspend or terminate your account or access to the Platform, with or without notice, if:

• You breach any provision of these Terms
• We are required to do so by applicable law, regulation, a competent authority, or a licensed partner
• We have reasonable grounds to suspect fraud, money laundering, or other financial crime
• You fail to complete or maintain required KYC verification
• Your account is used for activities prohibited under Section 6
• We or our relevant licensed partners cease to offer services in your jurisdiction
• We reasonably believe that maintaining your account creates legal, regulatory, or reputational risk

Where permitted by law, we will give you reasonable advance notice of suspension or termination unless doing so would compromise a fraud or crime investigation or is otherwise prohibited by applicable law.

10.3 Effect of Termination

Upon termination: your access to the Platform will cease; pending transactions may be cancelled; we will return any remaining balance to you (less applicable fees) within a reasonable timeframe subject to compliance holds; and your obligations under provisions intended to survive termination — including limitations of liability, dispute resolution, and intellectual property — will continue.

11. Disclaimers and Limitation of Liability

11.1 Services Provided As Is

The Platform and Services are provided on an "as is" and "as available" basis. To the fullest extent permitted by applicable law, Rhoam makes no warranties, express or implied, including warranties of merchantability, fitness for a particular purpose, or non-infringement.

11.2 Limitation of Liability

To the maximum extent permitted by applicable law, Rhoam and its officers, directors, employees, agents, affiliates, partners, and service providers shall not be liable for:

• Indirect, incidental, special, consequential, or punitive damages
• Loss of revenue, profits, data, business, or goodwill
• Losses arising from your reliance on information provided on the Platform, including information provided by Rhoami AI
• Losses arising from third-party actions including fraud by third parties
• Losses resulting from your failure to safeguard your account credentials or OTPs
• Delays or failures caused by circumstances beyond our reasonable control
• Losses arising from partner or third-party provider outages (including open banking providers, card networks, payment rails, or licensed partner infrastructure)

Where liability cannot be entirely excluded under applicable law, our total aggregate liability to you for all claims arising from or related to these Terms or the Services shall not exceed the greater of: (a) the total fees paid by you to Rhoam in the 12 months preceding the event giving rise to the claim; or (b) USD 500.

11.3 Indemnification

You agree to indemnify, defend, and hold harmless Rhoam, its partners, and their respective affiliates, officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, and expenses (including reasonable legal fees) arising out of or in connection with: (a) your use of the Platform; (b) your breach of these Terms; (c) your violation of applicable law; or (d) any content or information you provide through the Platform.

11.4 No Financial Advice

Rhoam does not provide financial, investment, tax, or legal advice. Nothing on the Platform, and nothing communicated by Rhoami AI, constitutes a recommendation or advice to purchase, sell, or hold any financial product. You should seek independent professional advice before making any financial decisions.

12. Regulatory and Compliance Matters

12.1 Partner Licensing and Regulatory Framework

Rhoam delivers financial services through a network of partners who hold licences and regulatory approvals across multiple jurisdictions. These partners are regulated by the relevant financial services authorities in the markets where they operate. Rhoam leverages these partner licences and regulatory frameworks to make services available to you. The specific licensed partner applicable to your services may vary depending on your jurisdiction and the service in question. Details of the relevant licensed partner entity can be provided upon request.

12.2 AML and Compliance

Rhoam and its partners operate in compliance with applicable anti-money laundering (AML), counter-terrorism financing (CTF), and sanctions laws, including applicable FATF standards and the requirements of the jurisdictions in which our partners operate. As part of this framework, we are required to verify the identity of our customers, monitor transactions, screen against sanctions lists, and where required, report suspicious activity to relevant financial intelligence units.

We may be required to freeze, block, or return funds and to disclose information about you or your transactions to regulatory authorities without prior notice to you.

12.3 Sanctions

We cannot provide services to individuals or entities subject to applicable sanctions, or in connection with transactions involving sanctioned jurisdictions. We screen all users and transactions against relevant sanctions lists including the UAE EOCN list, OFAC (US), OFSI (UK), and EU consolidated lists. If you are or become a sanctioned person or entity, we will terminate your account immediately and without liability.

12.4 Tax Compliance

You are responsible for determining and meeting all tax obligations arising from your use of the Platform in your jurisdiction. Rhoam does not provide tax advice. Where required by law or by our partners' regulatory obligations, transaction information may be reported to tax authorities under CRS, FATCA, and equivalent regimes.

12.5 Crypto Services

Crypto services are delivered through our regulated crypto infrastructure partners, who hold applicable licences and approvals in their respective jurisdictions. In the UAE, crypto asset services are made available through partners operating under applicable regulatory frameworks including VARA oversight. Crypto services may not be available in all jurisdictions. Full Travel Rule compliance and blockchain analytics are applied to qualifying transactions in accordance with FATF standards and our partners' regulatory obligations.

13. Force Majeure

Rhoam shall not be liable for any failure or delay in performing its obligations where such failure or delay results from causes beyond its reasonable control, including acts of God, war, terrorism, civil unrest, government action, pandemic, widespread internet or telecommunications failure, third-party payment network outages, partner infrastructure disruptions, or regulatory intervention. We will use reasonable endeavours to resume normal service as soon as practicable.

14. Governing Law and Dispute Resolution

14.1 Governing Law

These Terms are governed by and construed in accordance with the laws of the United Arab Emirates, specifically the laws applicable in the emirate of our registered office, without regard to conflict of laws principles. For users who are residents of the European Union or Australia, their statutory consumer rights under applicable local law are not affected.

14.2 Informal Resolution

If you have a complaint or dispute, please contact us first at support@rhoam.money. We will endeavour to resolve complaints within 15 business days. For complex matters, we may require up to 45 business days and will keep you informed of progress throughout.

14.3 Formal Dispute Resolution

If we are unable to resolve a dispute informally, disputes shall be referred to and finally resolved by arbitration administered in accordance with the rules of the relevant arbitration centre in the UAE. The seat of arbitration shall be Dubai. The language of arbitration shall be English.

14.4 Australian Users

Australian users who are consumers may have additional rights under Australian Consumer Law (ACL) and may escalate unresolved complaints to the Australian Financial Complaints Authority (AFCA) or the relevant financial services regulator.

14.5 EEA and UK Users

Nothing in these Terms affects your statutory rights as a consumer under applicable EU or UK law. EEA users retain the right to submit complaints to their national financial services regulator and to use the EU Online Dispute Resolution platform.

14.6 All Other Jurisdictions

If you access Rhoam from a jurisdiction not specifically referenced above, these Terms shall apply to the fullest extent permitted by local law. You retain any mandatory statutory rights applicable in your jurisdiction that cannot be contractually excluded.

15. General Provisions

15.1 Entire Agreement

These Terms, together with our Privacy Policy, Cookie Policy, and any applicable product-specific terms and fees schedules, constitute the entire agreement between you and Rhoam with respect to the Platform and supersede all prior agreements, representations, and understandings.

15.2 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable, that provision shall be modified to the minimum extent necessary to make it enforceable, or severed, and the remaining provisions shall continue in full force.

15.3 Waiver

Our failure to enforce any provision of these Terms on a particular occasion does not constitute a waiver of our right to enforce it in the future.

15.4 Assignment

You may not assign or transfer any of your rights or obligations under these Terms without our prior written consent. Rhoam may assign its rights to an affiliate, successor, or acquirer in connection with a merger, acquisition, or sale of assets, with reasonable notice to you.

15.5 App Store Terms

When you download the Rhoam app, additional terms from Apple (App Store) or Google (Google Play) may apply. These Terms are between you and Rhoam; Apple and Google are not parties and have no obligation to provide support for the app. In the event of a conflict, these Terms shall prevail to the extent permitted.

15.6 Language

These Terms are provided in English. Where we are required to provide a translation, the English version shall prevail in the event of any conflict.

16. Contact Us

Rhoam Money FZE (UAE entity) / Rhoam Money Pty Ltd (Australian entity)

• General support and account queries: support@rhoam.money
• Legal and compliance enquiries: legal@rhoam.money
• Privacy enquiries: privacy@rhoam.money
• Website: www.rhoam.money