Annex A: Interoperability Agreement for Account Disabling and Fund Withdrawal

This annex forms an integral part of the El Dorado Empresas Terms and Conditions and establishes the procedure applicable in the different account disabling scenarios, as well as the treatment of digital assets, balances and data associated with the User's account within the Platform.

Scope according to the Self-Custodial model

According to the Terms and Conditions of Service, El Dorado Empresas is a self-custodial business platform, through which the User retains exclusive control of their digital assets, private keys and access credentials at all times.

Classification of account disabling events

An account may be disabled in the following ways:

  1. Voluntary closure at the User's request

This option is only available when a User voluntarily decides to request the cancellation, closure, or disabling of their account. The procedure established by the Platform is explained below:

If there are available balances or funds:

  • The User may request the closure of their account by means of written communication sent to the Customer Service Department (ATC) of El Dorado.
  • Once the request is received, a service ticket is opened and ATC will inform the User that they have a period of no more than fifteen (15) calendar days from the notification to withdraw or give final destination to all the funds in their account.
  • Once this period has ended, the account will be disabled and the User will not be able to access the application or the Dashboard.
  • After the liquidation or withdrawal of said funds, El Dorado will close the User's account, which will be duly informed through the email registered on the Platform.

The aforementioned timeframe applies only to balances or funds that have not yet been processed through the corresponding banking network. According to El Dorado Empresas' Terms and Conditions, once a payment order has passed the Multisig approval process and has been processed through the banking network, the User acknowledges that the instruction is irrevocable, and El Dorado does not guarantee the possibility of stopping, canceling, or reversing a SWIFT payment in transit. Consequently, this timeframe does not apply to, nor does it suspend, the processing of payment orders that were already sent to the banking network prior to the closure request.

In case there are no balances or funds available:

  • The User may request the closure of their account by means of written communication sent to the Customer Service Department (ATC) of El Dorado.
  • Once the request is received, ATC will send an email confirmation to the User indicating that their account has been disabled.

Payment orders that have passed the Multisig approval process and have been executed on the banking network upon request for closure are irrevocable; therefore, El Dorado does not guarantee the possibility of stopping, canceling, or reversing a SWIFT payment in transit.

  1. Involuntary closure due to violation of the Terms and Conditions

If the Platform detects any indication of fraud, scams, suspicious activity, misuse of the system, or any other violation of the Terms and Conditions, El Dorado will disable or ban the User's account without prior notice. With disabling the account, the User will no longer be able to use the application or the Dashboard.

When an account ban is due to a violation of the Platform's Terms and Conditions for reasons unrelated to illegal activities, the User will have a period of no more than fifteen (15) calendar days to withdraw or dispose of all funds in their account. This period may be modified at any time at El Dorado's discretion, depending on the specific circumstances of each case. Once this period has elapsed, El Dorado will proceed with the permanent closure of the account.

In the event that the banning and closure of the User's account is due to situations of fraud, attempted fraud, suspicious operations, and any other similar illicit activity, El Dorado will immediately disable the User's access to the Dashboard and the Platform, and will evaluate the corresponding legal measures.

  1. Closure due to the User's inability to access the account

In the event that the User cannot access their account for reasons beyond their control and that of El Dorado, such as the loss of access credentials to the Platform or the registered email address, and for this reason requests the closure of their account, the following procedure will apply:

  • The User must contact the Customer Service Department and initiate an identity validation process to verify that they are the account holder, thereby enabling the corresponding account closure process to begin.
  • Notwithstanding the foregoing, given the self-custodial nature of the Platform, the User acknowledges and accepts that El Dorado has no custody, control, or access to the User's Crypto Assets, nor can it intervene in, reverse, or recover transactions once executed on the corresponding network. Consequently, in the event of loss, misplacement, or inability to access the account or the credentials necessary to access the Crypto Assets, the User acknowledges and accepts that El Dorado does not have the technical means to recover said Crypto Assets. In such circumstances, El Dorado will not be liable for any losses, damages, or harm arising from such inability to recover the assets.

2. Additional provisions

2.1. Once the account is disabled or cancelled, whatever the reason, all data from this account and other payment information registered by the User on the Platform will also be disabled.

2.2. The closure of the account, whatever its cause, does not exempt the User from compliance with outstanding contractual or legal obligations with third parties or with El Dorado regarding the services provided.

Last updated: September 17, 2026

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