Currency Conversion Disclosure

Last updated: September 1, 2026

1. Purpose and scope

This disclosure explains how currency conversion works on the Daba platform, what Daba does and does not do, and the limitations and risks that apply. It forms part of, and should be read together with, the Daba Terms of Service and the Daba Fee Schedule. By initiating a currency conversion on the platform, you confirm that you have read, understood and accepted this disclosure.

In this disclosure, “Daba”, “we” and “us” mean Daba Markets Inc. and, where relevant, its affiliates. “You” means the holder of a Daba account.

2. What the currency conversion function is

The Daba platform includes a function that allows you to convert a balance held in your account from one supported currency into another, so that you can fund or settle investment services denominated in a different currency.

The function exists solely to facilitate your access to investment services available through the platform. It is an operational convenience, not a product we sell.

3. What Daba is not

Daba is not a currency exchange business, a bureau de change, a foreign exchange broker or dealer, a money services business or a money transmitter. Daba does not:

  • operate a foreign exchange desk or trading book;
  • make markets, quote proprietary prices or take positions in any currency;
  • offer currency conversion as a standalone product, independently of the use of investment services on the platform;
  • provide remittance, money transfer or payment services to third parties;
  • hold itself out as being able to convert any particular currency on demand.

The conversion function may not be used as a means of transferring value to any person other than yourself, or as a substitute for a remittance or payment service. We may decline, reverse or report any instruction that appears to be used for that purpose, and may close accounts used in that way.

4. Conversions are executed by third-party providers

Every currency conversion initiated on the platform is executed by one or more independent third-party financial service providers. Daba transmits your instruction to the relevant provider and reflects the outcome in your account. Daba does not itself execute the conversion and does not control the terms on which it is executed.

The identity, capacity, pricing, cut-off times, operating hours and internal policies of these providers are outside Daba’s control. Providers may be added, suspended, changed or removed at any time, with or without notice. Daba does not act as agent, guarantor or surety for any provider, and gives no warranty as to any provider’s performance, solvency or continued availability.

5. Currency availability is not guaranteed

The fact that a currency is supported for the purpose of holding a balance, receiving funds, or accessing a particular investment service does not mean that conversion into or out of that currency is available.

Availability of any currency or currency pair depends on whether a provider is willing and able to execute that conversion at the relevant time, and may vary according to:

  • the currency pair and the direction of the conversion;
  • the amount involved, including minimum and maximum thresholds;
  • the time of day, day of the week, and local market and banking holidays;
  • provider liquidity, capacity and risk appetite at that moment;
  • applicable law, exchange controls and regulatory requirements in the relevant jurisdictions.

Availability may be withdrawn at any time without notice. Daba gives no undertaking that any currency pair will be available at any given time, at any particular frequency, or at all. Availability on a previous occasion is not an indication of future availability.

This applies with particular force to currencies subject to exchange controls, limited convertibility or restricted liquidity, including but not limited to the West African CFA franc (XOF), the Central African CFA franc (XAF) and the Nigerian naira (NGN). Deposits may be accepted in a currency for which conversion is not, or ceases to be, available.

6. Exchange rates

Daba does not set exchange rates. The rate applied to your conversion is the rate made available by the executing provider at the time of execution. That rate incorporates the provider’s own margin or spread, which is not separately itemised and which Daba does not control.

Daba seeks to obtain competitive rates for its users. Daba does not represent, warrant or guarantee that any rate obtained is the best rate available in the market, or that it corresponds to, or bears any particular relationship to, the interbank rate, the mid-market rate, or any published, official or reference rate.

Any rate shown to you before you confirm a conversion is indicative only. The rate applied is the rate prevailing at the moment of execution, which may differ, favourably or unfavourably, from any rate previously displayed, quoted, estimated or communicated to you. Daba does not guarantee, fix, lock or hedge any rate, and does not offer forward contracts, hedging, rate-protection or rate-guarantee arrangements of any kind.

7. Timing and settlement

Conversions are not necessarily instantaneous. Execution and settlement times depend on the provider, the currency pair, banking hours, market conditions, settlement infrastructure, and any compliance checks that may be required.

Daba gives no undertaking as to the time within which any conversion will be executed or settled. Conversions may be delayed, and in some cases may not complete at all, for reasons outside Daba’s control.

You should not rely on a conversion completing within any particular period. In particular, where you intend to use converted funds to meet a subscription window, offer period, order deadline, settlement date or other time-sensitive obligation, you are responsible for initiating the conversion sufficiently in advance. Daba accepts no liability for any loss, missed allocation, missed deadline, failed order or lost opportunity arising from the timing of a conversion.

8. Fees and total cost

Daba may charge a fee for facilitating a conversion. Where a fee applies, it is disclosed to you before you confirm the conversion and is set out in the Daba Fee Schedule.

The Daba fee is separate from, and additional to, the provider’s margin, which is embedded in the exchange rate itself and is not shown as a separate line item. The total cost of a conversion to you therefore comprises both the Daba fee and the provider’s embedded margin. You should assess the outcome of a conversion by reference to the net amount received, not by reference to the stated fee alone.

9. Conversions are final

Once a conversion has been executed it is final and cannot be cancelled, reversed, amended, re-priced or refunded, whether because the rate moved, because you changed your mind, or because you entered the instruction in error.

If you convert an amount and subsequently convert it back, you may receive materially less than the amount you began with, as a result of rate movements, spreads and fees on both legs. This is true even where no time has elapsed.

10. Currency risk

Exchange rates fluctuate, sometimes sharply and without warning. The value of a balance held in one currency, measured in another currency, may fall as well as rise.

Currency risk is independent of the performance of any investment. You may lose money as a result of exchange rate movements alone, even where the underlying investment has performed positively, and the effect of currency movements may exceed any investment return.

11. Regulatory and jurisdictional restrictions

Currency conversion may be restricted, conditioned or prohibited by law in certain jurisdictions, including under exchange control regimes, capital movement rules and sanctions regimes. Certain conversions may require regulatory documentation, authorisation or reporting.

You are responsible for ensuring that any conversion you instruct is lawful under the laws applicable to you, including in your country of residence and of nationality. Daba may decline any conversion where it considers, in its sole discretion, that the conversion may be unlawful, may breach a sanctions requirement, or where required documentation or information has not been provided.

12. No advice

Nothing in the conversion function, and nothing displayed on the conversion screen, constitutes investment, financial, tax, legal or currency advice, or a recommendation or solicitation to convert at any particular time, in any particular amount, or at any particular rate.

Daba expresses no view on the future direction of any exchange rate. Decisions to convert are yours alone. You should consider taking independent professional advice where appropriate.

13. Verification, source of funds and account status

The conversion function is available only on accounts that have completed identity verification and remain in good standing. Daba may at any time request information or documentation concerning your identity, your source of funds or the purpose of a conversion, and may decline, delay or suspend a conversion pending a satisfactory response.

14. Suspension, limits and refusal

Daba may at any time, at its discretion, without prior notice and without liability to you:

  • suspend, restrict or withdraw the conversion function in whole or in part, for all users or for any user;
  • remove or suspend any currency or currency pair;
  • impose or vary minimum or maximum amounts, frequency limits or aggregate limits;
  • decline to transmit any instruction.

Reasons may include provider unavailability or withdrawal, market disruption or volatility, liquidity constraints, regulatory or legal requirements, sanctions screening, suspected fraud or misuse, incomplete verification, unpaid amounts, or technical failure.

15. Errors, mispricing and technical failure

Where a conversion is executed at a manifestly erroneous rate, meaning a rate materially different from the prevailing market rate for that pair at that time, or as a result of a technical error, data feed failure, system malfunction or duplicated instruction, Daba reserves the right, acting in coordination with the relevant provider, to correct, adjust, cancel or reverse the affected transaction. Daba will notify you where it does so and will explain the basis of the correction.

You may not rely on, and may not seek to benefit from, a rate that you knew or ought reasonably to have known was erroneous.

16. Your responsibilities

Before confirming a conversion, you are responsible for:

  • checking that the currency pair, direction and amount are correct;
  • understanding that the rate applied will be the rate at execution, not the rate displayed;
  • understanding the total cost, including both the Daba fee and the embedded provider margin;
  • allowing sufficient time for any deadline you intend to meet;
  • satisfying yourself that the conversion is lawful and appropriate for you.

17. Limitation of liability

To the fullest extent permitted by applicable law, Daba shall not be liable for any loss, damage, cost or expense arising out of or in connection with:

  • the exchange rate obtained on any conversion, or any difference between that rate and any indicative, displayed, published or reference rate;
  • the unavailability, suspension, withdrawal or removal of any currency, currency pair or the conversion function generally;
  • any delay in execution or settlement, or any failure of a conversion to complete;
  • the acts, omissions, errors, default, suspension, insolvency or regulatory action of or against any third-party provider;
  • any movement in exchange rates before, during or after a conversion;
  • any missed subscription, allocation, deadline, order or opportunity;
  • any indirect, consequential, special or incidental loss, or any loss of profit, revenue, anticipated saving or opportunity.

Nothing in this disclosure excludes or limits any liability for fraud or fraudulent misrepresentation, for wilful misconduct or gross negligence, for death or personal injury caused by negligence, or any other liability which cannot lawfully be excluded or limited, including under applicable consumer protection legislation.

18. Complaints

If you are dissatisfied with a conversion, contact us at [email protected] with your account details, the transaction reference and a description of the issue. We will acknowledge your complaint and respond substantively. Where a complaint concerns the conduct of a third-party provider, we will tell you so and will assist you in raising it with that provider.

19. Changes to this disclosure

We may update this disclosure from time to time. The current version is always available at the address above, and the date of last update is shown at the top. Where a change is material we will notify you through the platform or by email before it takes effect. Your continued use of the conversion function after a change takes effect constitutes acceptance of the revised disclosure.

20. Entities and governing law

The Daba platform is operated by Daba Markets Inc., a company incorporated in Delaware, USA. Investment advisory services, where provided, are provided by Daba Advisors LLC, an investment adviser registered with the U.S. Securities and Exchange Commission (CRD No. 319371). Currency conversion is facilitated by Daba Markets Inc. and its affiliates dependent on jurisdiction and executed by independent third-party providers as described above.

This disclosure is governed by the laws of state of Delaware, United States of America, without prejudice to any mandatory protections available to you under the law of your country of residence.