Payments Disclosure

Last updated: September 1, 2026

1. Purpose and scope

This disclosure explains how payments to Daba work, what Daba does and does not do, and the limitations and risks that apply when you fund your account. It forms part of, and should be read together with, the Daba Terms of Service, the Daba Fee Schedule and the Daba Currency Conversion Disclosure. By initiating a payment to Daba, 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. “Payment provider” means any third-party bank, payment institution, card scheme, acquirer, electronic money institution, mobile money operator or other financial service provider through which a payment to Daba is made or processed.

2. What the payment function is

The Daba platform allows you to fund your own account with us, using payment methods that we are able to make available from time to time in your country and currency. Funding your account is a step towards accessing investment, intelligence and educational services on the platform. It is not a service we provide to you or to anyone else independently of that purpose.

3. What Daba is not

Daba is not a bank, a payment institution, a payment service provider, an electronic money institution, a card acquirer, a money services business or a money transmitter. Daba does not:

• provide payment, collection, remittance or money transfer services to you or to any third party;
• operate payment infrastructure, issue payment instruments or hold funds as a payment service;
• process, authorise, clear or settle any payment;
• control whether a payment is accepted, declined, delayed, returned or reversed by a payment provider;
• accept payments on behalf of any person other than itself.

Daba accepts payments for its own account, as the recipient, through licensed third-party payment providers. The platform may not be used to send money to any person other than Daba, to receive money from Daba other than by way of a withdrawal to an account in your own name, or as a channel for transferring value between persons. We may decline, return or report any payment that appears to be used for such a purpose, and may close accounts used in that way.

4. Payments are processed by third-party providers

Every payment made to Daba is processed by one or more independent third-party payment providers. Daba does not process payments. Our role is limited to making a payment method available where we are able to do so, and to applying a payment to your account once it has been received, identified and verified.

The terms, capacity, pricing, cut-off times, operating hours, security requirements, authorisation decisions and internal policies of payment providers are set by those providers and 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 payment provider, and gives no warranty as to any provider’s performance, availability, solvency or conduct.

Your payment is also subject to the terms and conditions of your own bank or payment provider. Those terms govern your relationship with that provider and Daba is not a party to them.

5. Availability of payment methods is not guaranteed

The payment methods shown on the platform are those we are able to offer at a given moment. The fact that a method, currency or country was available previously, is available to another user, or is displayed in marketing or help material, does not mean it is or will remain available to you.

Availability depends on whether a payment provider is willing and able to process the payment, and may vary according to:

• your country of residence, your nationality and the country of your payment provider;
• the currency, the amount, and any minimum or maximum thresholds;
• the payment method and the identity of your bank or provider;
• the time of day, day of the week and local banking or market holidays;
• provider capacity, risk appetite and commercial policy at that moment;
• applicable law, exchange controls, sanctions and regulatory requirements.

We may add, suspend, restrict or withdraw any payment method at any time, without notice and without liability. We give no undertaking that any payment method will be available at any given time, in any given country or currency, or at all. Availability of a payment method for funding does not imply availability of the same method for withdrawal, or availability of currency conversion in that currency.

6. How to pay — required steps

To ensure your payment can be identified and applied to your account, you must:

• hold a Daba account that has completed identity verification;
• initiate the payment from within the platform, using the payment flow shown, rather than sending funds independently;
• use the exact payment details, reference, amount and currency generated for that payment;
• complete each step shown, including any confirmation, authentication or upload step;
• submit proof of payment where the platform requests it.

A payment sent outside the platform’s payment flow, without the correct reference, or before verification has been completed, cannot be reconciled to your account. We have no means of identifying such a payment or attributing it to you. It will not be credited, and will be handled in accordance with section 9 below.

7. Payments must be made from an account in your own name

You may fund your account only from a bank account, card or payment account held in your own name and matching the identity verified on your Daba account.

We do not accept payments made by or on behalf of third parties. Where a payment is received from a name that does not match the verified account holder, we will not apply it. Such payments will be returned to the originating account where it is operationally possible to do so, and may be reported where we are required to do so by law.

Equally, you must not permit any other person to fund your account, or share your payment instructions or reference details with any other person. Payment details generated for you are personal to you and to that specific payment.

8. Proof of payment

For certain payment methods we require proof of payment before a payment can be applied. Where requested, you must provide a complete, legible and unaltered document issued by your payment provider showing the sender name, the recipient, the date, the amount, the currency and the payment reference.

We may decline documents that are incomplete, cropped, edited, illegible or inconsistent with the payment received. We may request further information or documentation concerning your identity, your source of funds, or the purpose of the payment, and may decline, delay or suspend the crediting of a payment pending a satisfactory response.

9. Unidentified and unattributable payments

Where we receive funds that we are unable to identify or attribute to a verified account holder, those funds are not credited to any account. We will attempt to identify the sender and, where we can, we will contact them.

If the payment cannot be attributed and verified within a reasonable period, or within any deadline we notify to you, the funds will be returned to the originating account. Any charges applied by payment providers or intermediary banks in connection with the return are borne by the sender and may be deducted from the amount returned. An amount returned may therefore be less than the amount sent, and may be returned in a different currency and at a different rate.

10. Verification before funds are applied

Funds are not applied to an account that has not completed identity verification, or whose verification has lapsed, failed or been suspended. Completing a payment does not complete, accelerate or substitute for verification. Where you pay before verification is complete, your funds are held unapplied until verification is completed or, failing that, returned in accordance with section 9.

11. Fees, charges and pricing

The cost of a payment to you may comprise several elements, only some of which are within our control:

• any Daba fee, which is set out in the Daba Fee Schedule and disclosed before you confirm;
• fees charged by the payment provider processing the payment;
• fees charged by your own bank or payment provider, including card issuer charges, cross-border fees and cash-advance treatment;
• charges applied by intermediary or correspondent banks, which may be deducted in transit without notice to us;
• any currency conversion margin applied by your provider or by ours.

Daba does not set, control or receive the fees charged by payment providers, your bank or intermediary banks, and cannot always know them in advance. Amounts deducted in transit reduce the sum we receive, and only the sum actually received by us can be credited to your account. The amount credited may therefore be less than the amount you sent.

Pricing set by payment providers may change at any time, with or without notice to us. Any fee indication shown on the platform in respect of a third-party charge is indicative only. Our own fees may be varied in accordance with the Terms of Service.

12. Timing

Payments are not necessarily instantaneous. The time taken for a payment to reach us, be identified and be applied to your account depends on the payment method, the providers involved, banking hours, settlement infrastructure, and any verification or compliance checks required.

We give no undertaking as to the time within which any payment will be received, identified, verified or applied. Where you intend to use funds to meet a subscription window, offer period, order deadline or other time-sensitive obligation, you are responsible for paying sufficiently in advance. We accept no liability for any loss, missed allocation, missed deadline, failed order or lost opportunity arising from the timing of a payment.

13. Failed, delayed, returned and misdirected payments

A payment may be declined, delayed, blocked, returned or frozen by a payment provider, by your own bank, or by an intermediary bank, for reasons which are theirs and which are frequently not disclosed to us. We are not informed of, and cannot influence, those decisions.

Where a payment is sent to incorrect details, or with an incorrect or missing reference, recovery depends entirely on the providers involved and may not be possible. We will assist you in making enquiries where we reasonably can, but we cannot compel any provider to act and give no undertaking that funds will be recovered.

14. Chargebacks, disputes and reversals

If you have a question or concern about a payment, contact us first at the address in section 21. Most issues can be resolved directly and more quickly than through a payment provider’s dispute process.

Where you raise a dispute, chargeback, claim or reversal with a payment provider in respect of a payment that has been credited to your account, we may restrict your account, including access to any balance and the ability to transact, until the matter is resolved. Where the credited funds have already been applied, used or withdrawn, you remain liable to us for the amount concerned, and we may recover it from any balance held, set it off against amounts owed to you, or pursue recovery by any other lawful means.

Raising a dispute in respect of a payment that you authorised and for which the corresponding credit was received may result in the suspension or closure of your account. Nothing in this section affects any right you may have under applicable law or under the rules of your payment provider or card scheme; it sets out the consequences as between you and Daba.

15. Refunds

Where a refund is due, it will be made to the account from which the payment originated, in the currency in which it was received, and not to any other account, person or method. Refunds are subject to provider fees and, where a currency conversion is involved, to the rate available at the time of the refund. The amount refunded may therefore differ from the amount originally paid.

16. Refusal, limits and suspension

We may at any time, at our discretion, without prior notice and without liability to you:

• decline to accept any payment, or return any payment received;
• suspend, restrict or withdraw any payment method, in whole or in part, generally or for any user;
• impose or vary minimum or maximum amounts, frequency limits or aggregate limits;
• withhold the crediting of funds pending verification, enquiry or resolution of a dispute.

Reasons may include provider unavailability or withdrawal, regulatory or legal requirements, sanctions screening, suspected fraud or misuse, name mismatch, incomplete or failed verification, unusual or unexplained activity, or technical failure.

17. Errors and duplicate payments

Where a payment is credited in error, in a duplicate amount, in the wrong amount or to the wrong account, whether through technical failure, provider error or otherwise, we reserve the right to correct the position, including by reversing the credit or debiting the amount concerned from your balance. We will notify you where we do so and explain the basis of the correction. You may not retain, use or withdraw funds that you knew or ought reasonably to have known were credited in error.

18. Fraud and payment details obtained from other sources

Payment details for funding your account are generated within the platform and are specific to you and to a single payment. You should never rely on payment details obtained from any other source, including from another user, from social media, from messaging applications, from search results or from any person claiming to represent Daba.

We will never ask you to send funds to an account other than the one generated in the platform payment flow, and will never ask you to pay a person rather than Daba. We accept no liability for funds sent on details not generated in your own account, and such funds cannot be credited to you.

19. Your responsibilities

Before making a payment, you are responsible for:

• completing identity verification on your account;
• initiating the payment within the platform and using the exact details and reference generated;
• paying only from an account in your own name;
• checking the amount, the currency and the recipient details;
• understanding the total cost, including third-party fees and any conversion margin;
• allowing sufficient time for any deadline you intend to meet;
• retaining proof of payment and providing it when requested;
• satisfying yourself that the payment is lawful under the laws applicable to you.

20. 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 unavailability, suspension, withdrawal or removal of any payment method, currency or country;
• the decline, delay, blocking, freezing, return or reversal of any payment by any payment provider, bank or intermediary;
• the acts, omissions, errors, default, suspension, insolvency or regulatory action of or against any payment provider or bank;
• fees, charges or deductions applied by any payment provider, bank or intermediary;
• any payment sent otherwise than in accordance with sections 6, 7 and 18, including payments sent without a valid reference, before verification, from a third-party account, or on details not generated in the platform;
• any delay in the receipt, identification, verification or crediting of a payment;
• 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.

21. Complaints

If you are dissatisfied with a payment or with the handling of your funds, contact us at [email protected] with your account details, the payment reference and a description of the issue. We will acknowledge your complaint and respond substantively.

Where a complaint concerns the conduct, fees, decisions or timing of a payment provider or of your own bank, that complaint lies against that provider and must be raised with them. We will tell you where this is the case and will provide the records we hold to assist you.

22. 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 payment function after a change takes effect constitutes acceptance of the revised disclosure.

23. 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). Payments are received by Daba or its affiliates dependent on jurisdiction and processed by independent third-party payment providers as described above.

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