TOFFEE TERMS AND CONDITIONS

Effective Date: October 13, 2025

Last Updated: November 21, 2025

1. INTRODUCTION AND ACCEPTANCE

These Terms and Conditions (“Terms”) constitute a legally binding agreement between you (“User”, “you”, or “your”) and Galactica Games Inc., a Delaware corporation, together with its affiliates Galactica Games Limited (Ireland) and Galactica Games (UK) Ltd (collectively, “Galactica”, “we”, “us”, or “our”), governing your use of the Toffee Wallet (the “Wallet”)and Toffee Services.

By creating a Wallet account, loading funds, or using the Wallet in any manner, you acknowledge that you have read, understood, and agree to be bound by these Terms. If you do not agree to these Terms, you must not use the Wallet.

These Terms apply globally to all Users in the United States, European Union member states, and the United Kingdom. Jurisdiction-specific terms are set forth in Sections 12, 13, and 14 below and form part of these Terms.

2. DEFINITIONS

“Account” means your Toffee Wallet account through which you may load, hold, and use Wallet Funds.

“AML/CFT” means Anti-Money Laundering and Counter-Terrorist Financing laws, regulations, and compliance programs.

“Bonus Funds” or “Promotional Credits” means promotional value granted by Galactica as part of marketing promotions, cashback rewards, referral bonuses, or other incentive programs, as further described in Section 6A.

“Closed-Loop Network” means the restricted network of approved merchants and service providers within the Galactica ecosystem where the Wallet may be used.

“Loaded Funds” means U.S. Dollar funds that you have loaded into your Wallet using approved payment methods, representing your actual money transferred into the Wallet, as further described in Section 6A.

“Network Merchants” means those merchants, vendors, and service providers who have been approved by Galactica to accept Wallet Funds within the Closed-Loop Network.

“Wallet” or “Toffee Wallet” means the prepaid access digital wallet service operated by Galactica.

“Wallet Funds” means the U.S. Dollar (USD) denominated balance held in your Account, which may be used to purchase goods and services from Network Merchants.

“You” or “User” means any natural person who creates, loads, or uses a Wallet Account.

3. NATURE OF THE WALLET

3.1 Prepaid Access and Closed-Loop Structure

The Wallet is a prepaid access, closed-loop digital wallet. It is not a bank account, deposit account, credit facility, or stored value card that can be used for general commercial purposes. Wallet Funds:

• Are denominated in U.S. Dollars (USD);

• May only be used to purchase goods and services from Network Merchants within the Closed-Loop Network;

• Cannot be withdrawn, redeemed for cash, or transferred to bank accounts;

• Cannot be used for person-to-person transfers outside the Closed-Loop Network;

• Cannot be used at merchants, retailers, or service providers outside the approved Network Merchants.

3.2 Regulatory Classification

The Wallet is a closed-loop prepaid access product offered under applicable financial regulations in the United States, European Union (Ireland), and the United Kingdom.

United States: The Wallet constitutes “prepaid access” as defined in 31 C.F.R. § 1010.100(ff)(4) under the Bank Secrecy Act and is subject to Financial Crimes Enforcement Network (FinCEN) oversight.

European Union (Ireland): Galactica Games Limited (Ireland) operates under the limited network exemption pursuant to Article 3(k) of Directive (EU) 2015/2366 (Second Payment Services Directive, “PSD2”) and Regulation 3(2)(d) of the European Communities (Payment Services) Regulations 2018 (S.I. No. 6 of 2018).

United Kingdom: Galactica Games (UK) Ltd operates under the limited network exemption pursuant to Regulation 3(k) of the Payment Services Regulations 2017 (SI 2017/752) and Regulation 3(l) of the Electronic Money Regulations 2011 (SI 2011/99).

3.3 Not Insured Deposits

Wallet Funds are not deposits and are not insured under the Federal Deposit Insurance Corporation (FDIC), Financial Services Compensation Scheme (FSCS), or any other deposit insurance scheme. All Wallet Funds are held in pooled “for-benefit-of” (FBO) accounts with regulated financial institutions.

4. ELIGIBILITY AND ACCOUNT REGISTRATION

4.1 Age Requirements

You must meet the following age requirements to create and use a Wallet Account:

• Primary Account Holder: You must be at least [18] years of age.

• Minor Account with Guardian Consent: Users between [13] and [17] years of age may create and use a Wallet Account with the express consent and supervision of a parent or legal guardian. The parent or legal guardian must register the Account on behalf of the minor and accepts full responsibility for all Account activity.

4.2 Registration Requirements

To create a Wallet Account, you must provide:

• A valid mobile phone number, which is used to register and verify your account; and ;

• Location information, collected automatically to confirm your country or region of access.

Before you can load funds or complete your first top-up, we will also request additional information to comply with our identity verification and regulatory requirements, including:

• Your full legal name; and

• Your date of birth.

Providing an email address is optional and only required if you choose to enable multi-factor authentication (MFA) or request communication by email.

4.3 Enhanced Due Diligence

We reserve the right to require Enhanced Due Diligence (“EDD”) at our sole discretion, including but not limited to:

• Identity verification (IDV) through document upload and facial recognition technology;

• Document verification (DocV) of government-issued identification;

• Address verification;

• Source of funds verification;

• Additional information as required for AML/CFT compliance.

We utilize third-party service providers, including Onfido, for identity verification purposes. EDD may be required before you can load funds, use the Wallet, or if your Account activity triggers our risk-based monitoring systems.

4.4 Accuracy of Information

You represent and warrant that all information you provide is accurate, current, and complete. You agree to promptly update your Account information if any changes occur. Failure to provide accurate information or to update your information may result in Account suspension or termination.

4.5 Account Restrictions

You may not:

• Create multiple Accounts without our prior written consent;

• Use the Wallet for any unlawful purpose;

• Allow any other person to use your Account;

• Create an Account if you have been previously suspended or terminated from the Wallet;

• Use the Wallet if you are located in, or a resident of, any jurisdiction where such use is prohibited by law.

5. LOADING WALLET FUNDS

5.1 Approved Funding Methods

You may load Wallet Funds using the following approved payment methods:

• Debit cards;

• Credit cards;

• Bank transfers (ACH, SEPA, or Faster Payments, as applicable);

• Other payment methods we may approve from time to time.

5.2 Transaction Limits

Your ability to load Wallet Funds is subject to the following limits, which are determined by applicable regulatory requirements for closed-loop prepaid access and limited network exemptions:

United States: Pursuant to 31 C.F.R. § 1010.100(ff)(4), daily load limits and maximum wallet balance limits apply. Specific limits will be displayed in your Account interface.

For Users located in the United States, the maximum Wallet load per day and the maximum Wallet balance are each limited to USD $2,000 per User across all eligible devices.
This limit is applied to maintain the Wallet’s classification as closed-loop prepaid access under FinCEN regulations (31 C.F.R. § 1010.100(ff)(4)). Loads or balances above this amount are not permitted.

European Union (Ireland): Pursuant to PSD2 Article 3(k) and S.I. No. 6 of 2018, Regulation 3(2)(d), load and balance limits apply to maintain limited network exemption status. If the total payment volume across Galactica’s operations in the EU exceeds €1,000,000 per annum, we will notify the Central Bank of Ireland pursuant to Regulation 3(4).

United Kingdom: Pursuant to PSRs 2017 Regulation 3(k), load and balance limits apply to maintain limited network exemption status.

Specific applicable limits include:

• Minimum load amount: $1 / €1 / £1

• Maximum load amount per transaction: $500 / €500 / £500

• Maximum daily load amount: $2,000 / €1,000 / £1,000

• Maximum Wallet balance: $2,000 / €1,000 / £1,000

These limits are designed to maintain Toffee Wallet’s eligibility for closed-loop or limited-network exemptions under FinCEN (31 C.F.R. §1010.100(ff)(4)), PSD2 Article 3(k) and S.I. No. 6 of 2018 (Ireland), and the U.K. Payment Services Regulations 2017 (Reg 3(k)). We may adjust these limits from time to time for operational, security, or compliance reasons.

Modification of Limits and Account Controls
We may adjust, reduce, or increase your transaction, load, or balance limits at any time for risk, security, or regulatory reasons, including to prevent fraud, comply with law, or protect the integrity of the Wallet.

Changes to limits may take effect immediately if necessary for fraud prevention, security, or compliance purposes. We will notify you of any material change to your limits as soon as reasonably possible, subject to applicable legal requirements.

We may also temporarily or permanently freeze, block, or restrict your Wallet or specific transactions if we reasonably suspect unauthorized activity, fraud, money laundering, or other prohibited conduct, or if required by law or a payment network.

Notice of Limit Changes
If we change your limits or restrict your account, we will notify you through the Toffee Wallet app, by SMS to your registered mobile number, or by email if you have provided one. Notification by any of these methods constitutes valid notice.

5.3 Authorization and Processing

When you load Wallet Funds, you authorize us to charge your selected payment method. Load transactions are typically processed immediately, but may take up to [3-5] business days depending on the payment method used. We are not responsible for delays caused by third-party payment processors or financial institutions.

5.4 Failed Transactions

If a load transaction fails due to insufficient funds, invalid payment information, or any other reason, we may retry the transaction or cancel it. You are responsible for ensuring sufficient funds are available in your funding source.

5.5 Reversals and Chargebacks

If a load transaction is reversed, charged back, or disputed by your funding source, we reserve the right to:

• Immediately deduct the corresponding amount from your Wallet balance;

• Suspend or terminate your Account;

• Charge you fees and expenses incurred in connection with the reversal or dispute;

• Take legal action to recover any losses.

You agree to reimburse us for any losses resulting from unauthorized chargebacks or fraudulent disputes.

6. USING WALLET FUNDS

6.1 Closed-Loop Restrictions

Wallet Funds may only be used to purchase goods and services from Network Merchants within the Closed-Loop Network. Network Merchants include:

• In-game purchases within Galactica games and applications;

• Goods and services from approved third-party merchants within the Galactica ecosystem;

• Other goods and services as designated by Galactica from time to time.

A current list of Network Merchants is available within the Wallet interface and on our website.

6.2 Prohibited Uses

You may not use Wallet Funds for:

• Cash withdrawals or cash equivalents;

• Purchases at merchants outside the Closed-Loop Network;

• Person-to-person transfers (except as expressly permitted within the Galactica ecosystem);

• Gambling, adult content, or illegal goods or services;

• Money laundering, terrorist financing, or any unlawful purpose;

• Purchases that violate any applicable law or regulation.

6.3 Transaction Authorization

When you make a purchase using Wallet Funds, you authorize us to deduct the purchase amount from your Wallet balance. Transactions are processed in real-time and are generally irreversible once completed.

6.4 Insufficient Funds

If your Wallet balance is insufficient to complete a transaction, the transaction will be declined. We do not offer credit or overdraft facilities.

6.5 Merchant Disputes

Disputes regarding goods or services purchased from Network Merchants must be resolved directly with the merchant. Network Merchants are independent sellers. Galactica is not responsible for the quality, delivery, or other aspects of goods or services provided by Network Merchants. Any disputes must be resolved directly with the merchant.

However, we will make reasonable efforts to assist in facilitating communication with merchants and to help achieve a satisfactory resolution for you.

6A. WALLET BALANCE AND FUND TYPES

6A.1 Types of Wallet Funds

Your Wallet balance may consist of two types of funds:

(a) Loaded Funds: U.S. Dollar funds that you have loaded into your Wallet using approved payment methods as described in Section 5. Loaded Funds represent your actual money transferred into the Wallet.

(b) Bonus Funds (or Promotional Credits): Promotional value granted to you by Galactica as part of marketing promotions, cashback rewards programs, referral bonuses, or other incentive programs. Such programs may be sponsored or funded by third-party partners, but all Bonus Funds are granted by Galactica and subject to these Terms:

• Are not purchased or loaded by you;

• Cannot be withdrawn, redeemed for cash, or transferred outside the Wallet;

• May have expiration dates or specific usage restrictions as stated in the applicable promotion terms;

• Do not constitute prepaid access or stored value for regulatory purposes under 31 C.F.R. § 1010.100(ff)(4) (United States), PSD2 Article 3(k) (EU), or PSRs 2017 Regulation 3(k) (UK).

6A.2 Priority of Fund Usage (Waterfall)

When you make a purchase using your Wallet, funds will be applied in the following order of priority:

First: Loaded Funds. Purchases, including any applicable taxes, are paid first from your available Loaded Funds balance.

Second: Bonus Funds. If your Loaded Funds balance is insufficient to cover the full transaction amount, any remaining amount will be deducted from your available Bonus Funds (if applicable and permitted by the promotion terms).

United States Example:

If your Wallet contains $100 in Loaded Funds and $30 in Bonus Funds, and you make a $110 purchase (before tax) in a jurisdiction with 10% sales tax:
• Purchase price: $110.00
• Sales tax (10%): $11.00
• Total amount charged to your Wallet: $121.00
• Deduction from Loaded Funds: $100.00
• Deduction from Bonus Funds: $21.00
• Remaining balance: $0.00 Loaded Funds and $9.00 Bonus Funds

European Union / United Kingdom Example:

If your Wallet contains €100 in Loaded Funds and €30 in Bonus Funds, and you make a €100 purchase (before VAT) with 20% VAT:
• Purchase price: €100.00
• VAT (20%): €20.00
• Total amount charged to your Wallet: €120.00
• Deduction from Loaded Funds: €100.00
• Deduction from Bonus Funds: €20.00
• Remaining balance: €0.00 Loaded Funds and €10.00 Bonus Funds

If your total Wallet balance (Loaded Funds plus Bonus Funds) is insufficient to complete the transaction, the transaction will be declined.

Bonus Funds are not treated as discounts or price reductions for tax purposes. All applicable taxes are calculated on the full transaction value paid from Loaded Funds and, where applicable, Bonus Funds.

6A.3 Separate Accounting

Loaded Funds and Bonus Funds are tracked separately in your Wallet. You can view your Loaded Funds balance and Bonus Funds balance separately in your Account interface.

6A.4 Bonus Fund Terms

Bonus Funds are subject to additional terms and conditions, which may include:

• Expiration dates (typically 90 days from grant date, unless otherwise specified);

• Minimum purchase requirements;

• Restrictions on eligible goods or services;

• Limitations on combining with other offers;

• Forfeiture upon Account termination or violation of these Terms.

Specific terms for each bonus or promotion will be provided at the time the Bonus Funds are granted and will be visible in your Account interface.

6A.5 No Cash Value for Bonus Funds

Bonus Funds have no cash value and cannot be:

• Withdrawn or redeemed for cash;

• Transferred to bank accounts or other payment methods;

• Transferred to other users (unless expressly permitted within the Galactica ecosystem);

• Refunded if not used before expiration;

• Applied toward fees (except as specifically stated in a promotion).

6A.6 Regulatory Classification

United States: Bonus Funds do not constitute “prepaid access” under 31 C.F.R. § 1010.100(ff)(4) because they cannot be retrieved, transferred, or redeemed for cash.

European Union (Ireland): Bonus Funds do not constitute “payment instruments” under PSD2 because they are promotional credits that cannot be used outside the limited network or redeemed for monetary value.

United Kingdom: Bonus Funds do not constitute “electronic money” under the EMRs 2011 because they are not issued on receipt of funds and cannot be redeemed for cash.

6A.7 Tax Treatment

General:
Loading funds into your Wallet is a non-taxable transfer of existing money. Taxes apply only when Wallet Funds are used to purchase taxable goods or services.

United States:

• Loaded Funds: Not reported as income. Any applicable taxes arise only when Loaded Funds are used to buy taxable goods or services.

• Bonus Funds: Not considered discounts or rebates. They may be treated as promotional rewards or incentives. If the total value of Bonus Funds granted to you exceeds $600 in a calendar year, Galactica may issue IRS Form 1099-MISC or 1099-NEC as required by the Internal Revenue Code § 6041 and related IRS regulations. You are responsible for determining and reporting any tax obligations associated with such promotional rewards.

European Union / United Kingdom:
Bonus Funds are treated as promotional incentives. They do not constitute taxable income for VAT or income-tax purposes under current law.

You are solely responsible for determining and fulfilling any personal tax obligations that may arise from your use of the Wallet.

6A.8 Refunds and Returns

If you return goods or cancel services purchased with Wallet Funds:

• Loaded Funds used in the transaction will be returned to your Wallet as Loaded Funds;

• Bonus Funds used in the transaction will be returned to your Wallet as Bonus Funds, subject to the original expiration date and promotion terms;

• If the original Bonus Funds have expired, the portion of the refund attributable to expired Bonus Funds will be forfeited and will not be restored to your Wallet;

• Refunds are subject to the merchant’s return policy. Network Merchants may impose restocking fees or other charges.

6A.9 Restrictions on Bonus Funds

We reserve the right to:

• Set maximum aggregate Bonus Fund limits per User;

• Restrict Bonus Funds to specific categories of goods or services;

• Limit the frequency or amount of Bonus Fund grants;

• Modify, suspend, or terminate any promotional program at any time with notice;

• Investigate and forfeit Bonus Funds obtained through fraudulent means, abuse of promotional terms, or violation of these Terms.

If we reasonably believe you have abused promotional programs or obtained Bonus Funds through fraud or deception, we may:

• Forfeit all Bonus Funds in your Account;

• Recover the value of improperly obtained Bonus Funds from your Loaded Funds;

• Suspend or terminate your Account pursuant to Section 10.

6B. Partner-Funded Promotional Value and SMS-Based Campaigns

6B.1 Overview
From time to time, Galactica may distribute promotional value funded by third-party partners (“SMS Campaign Bonus”) through SMS-based onboarding flows, digital claim links, Wallet Passes, or similar mechanisms.
SMS Campaign Bonus is issued by Galactica under these Terms and may only be used within the Closed-Loop Network.

6B.2 U.S. Residency and U.S. Location Requirement
SMS Campaign Bonus is available only to individuals who are (i) U.S. citizens or U.S. permanent residents, and (ii) physically located in the United States at the time of claiming or redeeming the reward.
Users outside the United States may not access, download, claim, or redeem SMS Campaign Bonus.

6B.3 Registration Through SMS Campaign Flows
When a User submits their phone number in an SMS-based onboarding flow or clicks a claim button associated with a promotional offer, the User:
(a) consents to receive SMS messages from Galactica;
(b) agrees to these Terms and the Privacy Policy;
(c) may receive a Wallet Pass (e.g., Apple Wallet pass) which facilitates notifications; and
(d) is registered for or added to the Wallet waitlist or promotional program.
A Wallet Pass does not constitute stored value and does not itself contain or grant monetary balance.

6B.4 Partner Funding and No Third-Party Contracting Rights
SMS Campaign Bonus may be funded in whole or in part by third-party partners.
All promotional value is issued solely by Galactica, and no third party becomes a party to these Terms or acquires any rights or obligations under them.

6B.5 Campaign-Specific Spend Caps and Contribution Requirements

SMS Campaign Bonus may not be used to pay the full price of any product or service unless expressly stated in the offer.
Each promotional campaign may specify mandatory User Contribution Requirements, including, but not limited to, one or more of the following:

(a) Percentage Contribution Requirement:
The User must pay a minimum percentage of the total product or service price using their Loaded Funds (e.g., the SMS Campaign Bonus may cover no more than 50% of the purchase price, or such other percentage as specified for the campaign).

(b) Maximum Promotional Contribution:
The SMS Promotional Value may be applied only up to a maximum amount per transaction (e.g., “up to $50” or “up to $20 per item”), even if the User’s promotional balance is higher.

(c) Product- or Merchant-Specific Caps:
Limits may vary depending on the item, merchant, game, or category of goods.
Certain items may allow a lower promotional percentage or a lower promotional maximum.

(d) Campaign-Specific Limits:
Each promotional campaign may set its own caps, contribution requirements, minimum spend rules, or other conditions.

The applicable limits for each offer will be displayed on the corresponding campaign page, claim screen, or promotional interface.
Where a campaign specifies different limits than these Terms, the campaign-specific limits will apply for that promotion only.

6B.6 Closed-Loop Use Only
SMS Campaign Bonus may be used only within the Closed-Loop Network to purchase eligible goods and services.
It cannot be withdrawn, redeemed for cash, transferred to other Users, or used outside participating merchants.

6B.7 Non-Transferability, Expiration, and Forfeiture
SMS Campaign Bonus:
• has no cash value;
• may expire if not used by the date shown in the campaign details;
• may be cancelled if associated conditions are not met;
• may be revoked in cases of fraud, misuse, or ineligible participation; and
• is forfeited upon Account closure.

6B.8 How Campaign Bonus Works
SMS Campaign Bonus is promotional-only and does not represent stored value, Wallet Funds, or Bonus Funds unless explicitly stated for a particular campaign.

Receiving an SMS with promotional value, adding a Wallet Pass, or joining a waitlist does not create or load any balance into a User’s Toffee Wallet Account.

SMSCampaign Bonus may be redeemable only within the designated campaign environment (such as a microstore or partner interface) and may never enter the Wallet as spendable Bonus Funds.

7. FEES AND CHARGES

7.1 Fee Schedule

The Wallet is subject to the following fees, which may be deducted from your Wallet balance:

• Issuance Fee: $0.00 ; £0.00 ; €0.00

• Load Fee: $0.00 ; £0.00 ; €0.00 per transaction or 0% of load amount

• Monthly Maintenance Fee: $0.75 ; £0.50 ; €0.65

• Inactivity Fee: $0.00 ; £0.00 ; €0.00 per month after 2 months of inactivity

• Customer Support Fee: $0.00 ; £0.00 ; €0.00 for certain non-standard support requests

• Account Closure Fee: $10.00 ; £6.00 ; €7.00, or the remaining account balance if lower**.**

• Other Fees: As published in the Wallet interface from time to time

A complete, current fee schedule is available within your Wallet Account and on our website.

7.2 Fee Changes

We reserve the right to modify fees at any time upon at least 30 days’ prior written notice to you via email or notification in the Wallet interface. Your continued use of the Wallet after the notice period constitutes acceptance of the new fees.

7.3 Fee Deduction

Fees will be automatically deducted from your Wallet balance on the applicable due date. If your Wallet balance is insufficient to cover applicable fees, we may suspend your Account until fees are paid.

All fees are deducted from Loaded Funds only. Bonus Funds cannot be used to pay fees unless expressly stated in a specific promotion.

8. TAX TREATMENT

8.1 Tax Point at Purchase

Loading funds into your Wallet is a non-taxable transfer of existing funds. Taxes apply only when Wallet Funds are used to purchase taxable goods or services. Adding money to your wallet is transferring existing funds into a prepaid wallet and as such does not constitute a taxable purchase.

8.2 Sales Tax, VAT, and Consumption Taxes

Applicable sales tax, VAT, or other consumption taxes are calculated on the total purchase amount before applying any Bonus Funds. Taxes are charged based on the total price of goods or services, regardless of whether part of the transaction is funded with Bonus Funds.

United States: Sales tax is calculated on the total purchase price of taxable goods or services. Specific treatment may vary by state.

European Union / United Kingdom: VAT is calculated on the total purchase price in accordance with the applicable VAT legislation.

The total transaction amount, including all applicable taxes, will be displayed before you complete a purchase. We utilize integrated tax calculation APIs to determine applicable taxes based on:

• The jurisdiction where the transaction occurs;

• The nature of the goods or services purchased;

• Applicable tax rates in effect at the time of purchase.

United States Example:

If your Wallet contains $100 in Loaded Funds and $30 in Bonus Funds, and you make a $110 purchase (before tax) in a jurisdiction with 10% sales tax:
• Purchase price: $110.00
• Sales tax (10%): $11.00
• Total amount charged to your Wallet: $121.00
• Deduction from Loaded Funds: $100.00
• Deduction from Bonus Funds: $21.00
• Remaining balance: $0.00 Loaded Funds and $9.00 Bonus Funds

European Union / United Kingdom Example:

If your Wallet contains €100 in Loaded Funds and €30 in Bonus Funds, and you make a €100 purchase (before VAT) with 20% VAT:
• Purchase price: €100.00
• VAT (20%): €20.00
• Total amount charged to your Wallet: €120.00
• Deduction from Loaded Funds: €100.00
• Deduction from Bonus Funds: €20.00
• Remaining balance: €0.00 Loaded Funds and €10.00 Bonus Funds

8.3 Tax Reporting

United States: Pursuant to relevant laws, we may be required to report certain transactions to the Internal Revenue Service (IRS). We will issue Form 1099-K or other applicable tax forms if your transactions meet IRS reporting thresholds.

European Union: We will issue VAT invoices as required by law.

United Kingdom: We will issue VAT invoices as required by law.

8.4 User Responsibility

You are solely responsible for determining your tax obligations pertaining to the Bonus Funds you earn and for reporting and paying all applicable taxes. We recommend consulting a qualified tax professional regarding your use of the Wallet.

9. ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING

9.1 AML/CFT Program

Galactica maintains a comprehensive, written AML/CFT program consistent with:

• United States: The Bank Secrecy Act (31 U.S.C. § 5311 et seq.) and FinCEN regulations (31 C.F.R. § 1010.100(ff) and § 1022.210);

• European Union: Directive (EU) 2015/849 (Fourth Anti-Money Laundering Directive, as amended by Directive (EU) 2018/843) and national implementing legislation;

• United Kingdom: Proceeds of Crime Act 2002, Terrorism Act 2000, and The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692).

9.2 Know Your Customer (KYC)

As part of our AML/CFT obligations, we conduct Know Your Customer (KYC) checks on all Users. You agree to provide any information or documentation we reasonably request for KYC purposes. For situations where Enhanced Due Diligence (EDD) is required, we use recognised third party vendors to validate your identity.

9.3 Transaction Monitoring

We monitor all transactions for suspicious activity, including but not limited to:

• Unusual transaction patterns;

• Rapid movement of funds;

• Transactions inconsistent with your profile;

• Potential money laundering or terrorist financing indicators.

9.4 Suspicious Activity Reporting

If we detect suspicious activity, we are legally obligated to file Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with the appropriate authorities. We are prohibited by law from informing you if we file such a report.

9.5 Sanctions Screening

We screen all KYC Users against:

• OFAC (Office of Foreign Assets Control) sanctions lists;

• EU sanctions lists;

• UK HM Treasury sanctions lists;

• United Nations sanctions lists;

• Other applicable sanctions and watch lists.

If you are identified on any sanctions list, or if you conduct transactions involving sanctioned persons or jurisdictions, your Account will be immediately suspended or terminated, and we will report the matter to the appropriate authorities as required by law.

10. ACCOUNT SUSPENSION AND TERMINATION

10.1 Suspension by Galactica

We reserve the right to suspend your Account immediately, without prior notice, if:

• We suspect fraudulent, suspicious, or unlawful activity;

• Your Account activity triggers our AML/CFT monitoring systems;

• You violate these Terms;

• You provide false or misleading information;

• We are required to do so by law, regulation, or court order;

• Your funding source initiates a chargeback or payment reversal;

• We reasonably believe suspension is necessary to protect Galactica, other Users, or third parties.

10.2 Termination by Galactica

We reserve the right to terminate your Account at any time, with or without cause, upon written notice to you. Grounds for termination include, but are not limited to:

• Repeated violations of these Terms;

• Confirmed fraudulent or unlawful activity;

• Failure to complete required identity verification;

• Extended period of Account inactivity;

• Business or operational reasons.

10.3 Termination by You

You may terminate your Account at any time by contacting Customer Support at support@toffeewallet.com or +1 585 542 7828. Upon termination by you, you may use any remaining Wallet balance to purchase goods or services from Network Merchants within thirty (30) days, after which any remaining balance may be forfeited in accordance with applicable unclaimed property laws.

10.4 Effect of Suspension or Termination

Upon suspension or termination of your Account:

• You will no longer be able to access your Account or use Wallet Funds;

• Any pending transactions may be cancelled;

• We may retain information as required by law or for legitimate business purposes;

• You remain liable for any outstanding fees, obligations, or liabilities.

10.5 Return of Funds

If your Account is suspended or terminated due to suspected fraud or violation of these Terms, we will conduct an investigation. If the investigation confirms fraudulent or unlawful activity, we will return any remaining Wallet Funds to the original funding source, less any applicable fees, losses, or amounts owed to us.

If your Account is terminated for non-fraudulent reasons, we will make reasonable efforts to return remaining Wallet Funds to you, subject to applicable fees and our ability to verify your identity and funding source.

Upon Account suspension or termination, only Loaded Funds will be eligible for return. Bonus Funds have no cash value and will be forfeited upon Account closure. Any Bonus Funds remaining in your Account at the time of termination will be cancelled and cannot be recovered.

11. INACTIVITY

11.1 Inactivity Period

Your Account will be considered inactive if there are no transactions (loads or purchases) for a period of sixty (60) consecutive days.

11.2 Inactivity Fees

After sixty (60) days of inactivity, we may charge an Inactivity Fee as defined in Appendix A – Schedule of Fees, which will be deducted from your Wallet balance, until:

• You resume Account activity;

• Your Wallet balance reaches zero; or

• Your Account is closed.

Inactivity fees are subject to applicable legal requirements in your jurisdiction and will not reduce your Wallet balance below any minimum amount required by law. Inactivity Fees will be deducted from Loaded Funds only. Bonus Funds will not be used to pay fees. Bonus Funds may expire separately according to their original expiration terms during periods of inactivity. If your Account contains only Bonus Funds and those funds have expired, we may close your Account without further notice.

11.3 Escheatment and Unclaimed Property

If your Account remains inactive and we are unable to contact you, we may be required to remit your Wallet balance to the appropriate government authority as unclaimed property pursuant to:

• United States: State unclaimed property laws;

• European Union / Ireland: Dormant Accounts Acts 2001-2012;

• United Kingdom: Dormant Bank and Building Society Accounts Act 2008.

We will make reasonable efforts to contact you before remitting funds as unclaimed property, in accordance with applicable law.

12. UNITED STATES-SPECIFIC TERMS

12.1 Regulatory Compliance

The Wallet constitutes “prepaid access” as defined in 31 C.F.R. § 1010.100(ff)(4) and is subject to the Bank Secrecy Act (31 U.S.C. § 5311 et seq.) and FinCEN regulations.

Galactica Games Inc. implements and maintains a written AML program pursuant to 31 C.F.R. § 1022.210, including:

• Policies, procedures, and internal controls;

• Designation of a compliance officer;

• Ongoing employee training;

• Independent audit function.

12.2 Use Abroad

If you are a U.S. resident traveling temporarily outside the United States, you may continue to use the Wallet in accordance with these Terms. However, extended or permanent foreign residence may subject you to additional regulations and reporting requirements.

12.3 State Licensing

Galactica Games Inc. holds or is exempt from money transmitter licenses as required by applicable state laws. Users in certain states may be subject to additional state-specific terms or limitations.

12.4 Governing Law

These Terms, as they apply to U.S. Users, are governed by and construed in accordance with the laws of the State of Delaware and the federal laws of the United States, without regard to conflict of law principles.

13. EUROPEAN UNION (IRELAND)-SPECIFIC TERMS

13.1 Regulatory Status

Galactica Games Limited (Ireland) operates under the limited network exemption pursuant to:

• Article 3(k) of Directive (EU) 2015/2366 (PSD2); and

• Regulation 3(2)(d) of the European Communities (Payment Services) Regulations 2018 (S.I. No. 6 of 2018).

The Wallet is exempt from payment services regulation because it is a limited network instrument that can only be used to purchase goods or services from Network Merchants within a restricted network of providers with a direct commercial agreement with Galactica.

13.2 Limited Network Scope

The Wallet may only be used to purchase goods or services from Network Merchants within the Galactica ecosystem. Any expansion beyond the limited network that would cause the Wallet to lose its exemption will be subject to prior notification to the Central Bank of Ireland.

If the total payment volume for Galactica’s operations in the European Union exceeds €1,000,000 per annum, we will notify the Central Bank of Ireland pursuant to Regulation 3(4) of S.I. No. 6 of 2018.

13.3 Data Protection and Privacy

Personal data is processed in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”). Our Privacy Policy, which forms part of these Terms, sets forth how we collect, use, and protect your personal data.

Under the GDPR, you have the following rights:

• Right of Access (Article 15): You may request confirmation of whether we process your personal data and obtain a copy of such data;

• Right to Rectification (Article 16): You may request correction of inaccurate personal data;

• Right to Erasure (Article 17): You may request deletion of your personal data in certain circumstances;

• Right to Restriction of Processing (Article 18): You may request restriction of processing in certain circumstances;

• Right to Data Portability (Article 20): You may request that we transfer your personal data to another controller;

• Right to Object (Article 21): You may object to processing based on legitimate interests or for direct marketing purposes;

• Right to Withdraw Consent (Article 7): Where processing is based on consent, you may withdraw consent at any time.

To exercise your rights, please contact us at support@toffeewallet.com.

You also have the right to lodge a complaint with the Data Protection Commission (Ireland) at www.dataprotection.ie.

13.4 Consumer Protection

You are entitled to consumer protection under EU law, including Directive 2011/83/EU on consumer rights. If you believe your consumer rights have been violated, you may file a complaint with the Competition and Consumer Protection Commission (Ireland) at www.ccpc.ie.

13.5 Governing Law and Jurisdiction

These Terms, as they apply to EU Users, are governed by and construed in accordance with the laws of Ireland. Subject to Section 15 (Dispute Resolution), disputes shall be subject to the exclusive jurisdiction of the courts of Ireland.

14. UNITED KINGDOM-SPECIFIC TERMS

14.1 Regulatory Status

Galactica Games (UK) Ltd operates under the limited network exemption pursuant to:

• Regulation 3(k) of the Payment Services Regulations 2017 (SI 2017/752); and

• Regulation 3(l) of the Electronic Money Regulations 2011 (SI 2011/99).

The Wallet is exempt from payment services and electronic money regulation because it is a limited network instrument that can only be used to purchase goods or services from Network Merchants within a restricted network.

14.2 Limited Network Scope

The Wallet may only be used to purchase goods or services from Network Merchants within the Galactica ecosystem. The Wallet cannot be used for general commercial purposes.

14.3 Data Protection and Privacy

Personal data is processed in accordance with:

• The UK General Data Protection Regulation (UK GDPR);

• The Data Protection Act 2018.

Our Privacy Policy, which forms part of these Terms, sets forth how we collect, use, and protect your personal data.

Under UK GDPR, you have the following rights:

• Right of Access: You may request confirmation of whether we process your personal data and obtain a copy of such data;

• Right to Rectification: You may request correction of inaccurate personal data;

• Right to Erasure: You may request deletion of your personal data in certain circumstances;

• Right to Restriction of Processing: You may request restriction of processing in certain circumstances;

• Right to Data Portability: You may request that we transfer your personal data to another controller;

• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes;

• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time.

To exercise your rights, please contact us at support@toffeewallet.com.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.

14.4 Financial Ombudsman Service

If you are dissatisfied with our handling of a complaint, you may be eligible to refer your complaint to the Financial Ombudsman Service. More information is available at www.financial-ombudsman.org.uk.

14.5 Governing Law and Jurisdiction

These Terms, as they apply to UK Users, are governed by and construed in accordance with the laws of England and Wales. Subject to Section 15 (Dispute Resolution), disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.

15. DISPUTE RESOLUTION AND ARBITRATION

15.1 Informal Resolution

Before initiating formal dispute resolution proceedings, you agree to contact us at support@toffeewallet.com or +1 585 542 7828 to attempt to resolve any dispute informally. We will make good faith efforts to resolve disputes within 30 days of receiving notice.

15.2 Binding Arbitration (U.S. Users Only)

This Section 15.2 applies only to Users located in the United States.

YOU AND GALACTICA GAMES INC. AGREE THAT ANY DISPUTE, CLAIM, OR CONTROVERSY BETWEEN YOU AND US ARISING OUT OF OR RELATING TO THESE TERMS OR THE WALLET SHALL BE RESOLVED EXCLUSIVELY THROUGH BINDING ARBITRATION, EXCEPT AS OTHERWISE PROVIDED IN THIS SECTION.

15.2.1 Scope of Arbitration

Any dispute, claim, or controversy arising out of or relating to these Terms, the Wallet, or your relationship with us (collectively, “Disputes”) shall be resolved by binding arbitration administered by the American Arbitration Association (“AAA”) in accordance with the AAA Consumer Arbitration Rules, except as modified by these Terms.

Disputes include, but are not limited to, claims based in contract, tort, statute, fraud, misrepresentation, or any other legal theory.

15.2.2 Exceptions to Arbitration

Notwithstanding Section 15.2.1, the following Disputes are not subject to arbitration and may be brought in court:

• Claims in small claims court, provided the matter remains in small claims court and proceeds only on an individual basis;

• Claims seeking injunctive or equitable relief for the alleged unlawful use of intellectual property;

• Any claim related to or arising from allegations of theft, piracy, invasion of privacy, or unauthorized use of the Wallet.

15.2.3 Arbitration Procedures

The arbitration will be conducted by a single arbitrator. The arbitration shall be held in Delaware, USA, or at another location mutually agreed upon. The arbitration shall be conducted in English.

The arbitrator’s decision shall be final and binding on the parties and may be entered as a judgment in any court of competent jurisdiction.

15.2.4 Waiver of Class Actions and Jury Trial

YOU AND GALACTICA GAMES INC. AGREE THAT EACH PARTY MAY BRING CLAIMS AGAINST THE OTHER ONLY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, OR REPRESENTATIVE ACTION.

YOU AND GALACTICA GAMES INC. HEREBY WAIVE ANY RIGHT TO A JURY TRIAL.

15.2.5 Costs and Fees

Each party shall bear its own costs and attorneys’ fees unless otherwise awarded by the arbitrator in accordance with applicable law. The AAA’s filing fees and arbitrator’s fees shall be allocated in accordance with AAA rules.

15.2.6 Governing Law

The arbitration shall be governed by the Federal Arbitration Act, 9 U.S.C. § 1 et seq., and not by state arbitration law.

15.2.7 Opt-Out Right

You have the right to opt out of this arbitration agreement by sending written notice of your decision to opt out to support@toffeewallet.com within 30 days of first accepting these Terms. Your notice must include your name, email address, and a clear statement that you wish to opt out of this arbitration agreement. If you opt out, this arbitration agreement will not apply to you, but all other terms of these Terms will remain in effect.

15.2.8 Severability

If any portion of this arbitration agreement is found to be unenforceable, the remainder shall continue in effect, except that if the class action waiver is found to be unenforceable, the entire arbitration agreement (but not the remainder of these Terms) shall be null and void.

15.3 Dispute Resolution (EU and UK Users)

This Section 15.3 applies only to Users located in the European Union or United Kingdom.

Users in the EU and UK are not bound by the arbitration provisions in Section 15.2. EU and UK Users may pursue disputes through the courts in accordance with Sections 13.5 and 14.5, or through alternative dispute resolution mechanisms as provided by law.

EU Users: You may access the European Commission’s Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr/.

UK Users: You may be eligible to refer complaints to the Financial Ombudsman Service (see Section 14.4).

16. INTELLECTUAL PROPERTY

16.1 Ownership

The Wallet, including all software, technology, content, trademarks, service marks, logos, and other intellectual property (collectively, “Galactica IP”), is owned by or licensed to Galactica and is protected by copyright, trademark, patent, trade secret, and other intellectual property laws.

16.2 Limited License

Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Wallet for personal, non-commercial purposes.

16.3 Restrictions

You may not:

• Copy, modify, distribute, sell, or lease any part of the Wallet or Galactica IP;

• Reverse engineer, decompile, or disassemble the Wallet;

• Remove, alter, or obscure any proprietary notices on the Wallet;

• Use the Wallet or Galactica IP for any unlawful purpose;

• Use automated systems (bots, scrapers, etc.) to access the Wallet;

• Interfere with or disrupt the Wallet or servers or networks connected to the Wallet.

17. PRIVACY AND DATA PROTECTION

17.1 Privacy Policy

Our collection, use, and protection of your personal data is governed by our Privacy Policy, which is incorporated into these Terms by reference. By using the Wallet, you consent to the practices described in the Privacy Policy.

17.2 Data Sharing

We may share your personal data with:

• Service providers who assist in operating the Wallet (e.g., identity verification, payment processing, tax compliance);

• Network Merchants to facilitate transactions;

• Law enforcement, regulatory authorities, or other third parties as required by law or to protect our rights;

• Affiliates within Galactica for business purposes.

17.3 International Data Transfers

Data Controller: Galactica Games Inc. and its affiliates Galactica Games Limited (Ireland) and Galactica Games (UK) Ltd act as the data controllers, determining the purposes and means of processing your personal data.

We use Google Cloud Platform (GCP) as our secure cloud-hosting and encryption provider. GCP acts as a data processor under our instructions and in accordance with its Data Processing and Security Terms, certified under ISO 27001 and other international standards.
Your personal data may be transferred outside your home country, including the United States.
All transfers of personal data outside the European Economic Area (EEA) and the UK are protected through the EU Standard Contractual Clauses (EU 2021/914) and the UK International Data Transfer Addendum, ensuring equivalent safeguards for your information.
These technical and contractual measures – including end-to-end encryption, access controls, and continuous monitoring - ensure the confidentiality, integrity, and availability of your personal data while stored on GCP’s infrastructure.

17.4 Data Retention

We retain your personal data for as long as necessary to provide the Wallet, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary based on data type and regulatory requirements.

18. SECURITY

18.1 Account Security

You are responsible for maintaining the confidentiality of your Account credentials (email, password, phone number, authentication codes). You agree to:

• Use a strong, unique password;

• Enable multi-factor authentication if available;

• Not share your Account credentials with any third party;

• Immediately notify us if you suspect unauthorized access to your Account.

18.2 Unauthorized Transactions

If you believe there has been unauthorized access to your Account or unauthorized transactions, you must notify us immediately at support@toffeewallet.com or +1 585 542 7828.

United States: Your liability for unauthorized transactions is governed by 15 U.S.C. § 1693g (Electronic Fund Transfer Act). You may be liable for up to $50 if you notify us within 2 business days, up to $500 if you notify us within 60 days, or for all losses if you fail to notify us within 60 days.

European Union / UK: Your liability for unauthorized transactions is governed by PSD2 (EU) and PSRs 2017 (UK). You are not liable for unauthorized transactions unless you acted fraudulently or with gross negligence.

18.3 Security Measures

We implement industry-standard security measures to protect your Account and personal data, including encryption, access controls, and monitoring. However, no system is completely secure, and we cannot guarantee the absolute security of your data.

19. LIMITATION OF LIABILITY

19.1 Disclaimer of Warranties

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE WALLET IS PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

WE DO NOT WARRANT THAT:

• The Wallet will be uninterrupted, secure, or error-free;

• Defects will be corrected;

• The Wallet is free from viruses or other harmful components;

• Results obtained from use of the Wallet will be accurate or reliable.

19.2 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, GALACTICA, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AND LICENSORS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, REVENUE, DATA, OR USE, ARISING OUT OF OR RELATED TO THESE TERMS OR THE WALLET, WHETHER BASED IN CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, OUR TOTAL LIABILITY TO YOU FOR ANY CLAIMS ARISING OUT OF OR RELATED TO THESE TERMS OR THE WALLET SHALL NOT EXCEED THE LESSER OF:

• The AMOUNT OF WALLET FUNDS IN YOUR ACCOUNT AT THE TIME THE CLAIM AROSE; OR

• USD $500.

19.3 Exceptions

Some jurisdictions do not allow the exclusion or limitation of certain warranties or liabilities. In such jurisdictions, the exclusions and limitations in this Section 19 shall apply only to the extent permitted by law.

European Union / UK Users: Nothing in these Terms excludes or limits our liability for:

• Death or personal injury caused by our negligence;

• Fraud or fraudulent misrepresentation;

• Any liability that cannot be excluded or limited under applicable law.

20. INDEMNIFICATION

You agree to indemnify, defend, and hold harmless Galactica, its affiliates, officers, directors, employees, agents, and licensors from and against any claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to:

• Your use or misuse of the Wallet;

• Your violation of these Terms;

• Your violation of any law or regulation;

• Your violation of any third-party rights;

• Any content or information you provide through the Wallet;

• Any disputes between you and Network Merchants.

We reserve the right to assume the exclusive defense and control of any matter subject to indemnification by you, in which case you agree to cooperate with our defense of such claim.

21. MODIFICATIONS TO TERMS

21.1 Right to Modify

We reserve the right to modify, amend, or update these Terms at any time. If we make material changes, we will provide notice by:

• Posting the updated Terms on our website;

• Sending an email notification to the email address associated with your Account; or

• Displaying a notice in the Wallet interface.

21.2 Effective Date of Changes

Material changes will become effective 30 days after notice is provided, unless a longer period is required by law. Non-material changes will become effective immediately upon posting.

21.3 Acceptance of Changes

Your continued use of the Wallet after changes become effective constitutes acceptance of the modified Terms. If you do not agree to the modified Terms, you must terminate your Account before the changes become effective.

22. GENERAL PROVISIONS

22.1 Entire Agreement

These Terms, together with our Privacy Policy and any other policies or guidelines incorporated by reference, constitute the entire agreement between you and Galactica regarding the Wallet and supersede all prior agreements, understandings, and communications.

22.2 Assignment

You may not assign, transfer, or delegate these Terms or your Account without our prior written consent. We may assign, transfer, or delegate these Terms or our rights and obligations without restriction.

22.3 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect.

22.4 Waiver

Our failure to enforce any provision of these Terms shall not constitute a waiver of that provision or any other provision. No waiver shall be effective unless in writing and signed by an authorized representative of Galactica.

22.5 Force Majeure

We shall not be liable for any failure or delay in performance due to causes beyond our reasonable control, including but not limited to acts of God, war, terrorism, civil unrest, labor disputes, government actions, network or system failures, or natural disasters.

22.6 Relationship of Parties

Nothing in these Terms creates a partnership, joint venture, agency, or employment relationship between you and Galactica. You are an independent user of the Wallet.

22.7 Third-Party Rights

These Terms do not confer any rights or remedies upon any person or entity other than you and Galactica, except as expressly provided herein.

22.8 Notices

All notices to you will be sent to the email address or phone number associated with your Account. Notices to us must be sent to:

Galactica Games Inc., 447 Broadway, Fl 2 #1817, New York, NY 10013
Galactica Games Limited, Greyfriars, Waterford City, Waterford, X91 K2WV
Galactica Games (UK) Ltd, 128 City Road, London, United Kingdom, EC1V 2NX
or via
Email: support@toffeewallet.com
Phone: +1 585 542 7828

You are responsible for ensuring your contact information is current and accurate.

22.9 Language

These Terms are drafted in English. If these Terms are translated into any other language, the English version shall prevail in the event of any conflict or ambiguity.

22.10 Headings

Section headings are for convenience only and do not affect the interpretation of these Terms.

22.11 Survival

Provisions of these Terms that by their nature should survive termination shall survive, including but not limited to Sections 9, 15, 16, 17, 19, 20, and 22.

22.12 Electronic Communications

By creating a Wallet account, you agree that all disclosures, notices, and other communications may be provided electronically via email or in-app notification. You may withdraw consent by contacting support@toffeewallet.com, but doing so may limit your ability to use the Wallet.

23. CONTACT INFORMATION

If you have questions, concerns, or complaints regarding the Wallet or these Terms, please contact us:

Galactica Games Inc. (United States)
Email: support@toffeewallet.com
Phone: +1 585 542 7828

Galactica Games Limited (Ireland)
Email: support@toffeewallet.com
Greyfriars, Waterford City, Waterford, X91 K2WV

Galactica Games (UK) Ltd
Email: support@toffeewallet.com
128 City Road, London, United Kingdom, EC1V 2NX

24. ACKNOWLEDGMENT AND ACCEPTANCE

BY CREATING A WALLET ACCOUNT, LOADING FUNDS, OR USING THE WALLET IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS AND OUR PRIVACY POLICY.

IF YOU DO NOT AGREE TO THESE TERMS, YOU MUST NOT USE THE WALLET.

Effective Date: October 13, 2025

Last Updated: October 13, 2025

Appendix A – FEE SCHEDULE

Appendix B – Regulatory Reference Table

Appendix C – Electronic Communications Disclosure

We deliver account notices, legal disclosures, and updates electronically by email, website, or in-app notification.
By creating a Toffee Wallet account, you consent to receive communications in electronic form and agree that such delivery satisfies all legal notice requirements.
You may withdraw consent by contacting support@toffeewallet.com ; doing so may limit your ability to use the Wallet.
We retain copies of all notices in accordance with our record-keeping policy.

ADDENDUM D: Bolt Promotional Credit Campaigns

Effective Date: 21 November 2025
Last Updated: 21 November 2025

This Addendum supplements and forms part of the Toffee Terms & Conditions and applies to the Bolt Promotional Campaign and any associated promotional features operated by Toffee.

1. Campaign Overview

1.1. The Bolt Campaign provides eligible users with promotional credit (“Bolt Credit”) after completing the steps displayed in the campaign interface (e.g., confirming a mobile number or creating an account).

1.2. Bolt Credit is not cash, is non-withdrawable, and may only be used as a promotional discount applied at checkout within Toffee Wallet.

2. Current Redemption Rules (Bolt Campaign)

2.1. Bolt Credit may be applied across multiple eligible purchases until the user’s total promotional balance is fully used or expires.

2.2. For each individual purchase, Bolt Credit may be used for up to 50% of the value of that purchase, not exceeding the user’s remaining Bolt Credit balance.

Example:

• The user has $50 Bolt Credit.
• Purchase A costs $40 → the user may apply up to $20 (50%).
• Remaining balance $30.
• Purchase B costs $20 → the user may apply up to $10 (50%).
• Remaining balance $20.
• Continue until balance reaches zero or expires.

2.3. These redemption rules, values, limits, and percentages are subject to change at any time at Toffee’s discretion.

3. Additional Campaigns

3.1. Toffee may introduce additional promotional programmes related to the Bolt Campaign, including but not limited to:

• Referral bonuses,
• Reward-for-action campaigns,
• Sign-up bonuses,
• Time-limited or recurring promotional credits, or
• Other incentive features.

3.2. Any referral campaign introduced by Toffee will operate under this Addendum and Section 6B of the Toffee Terms unless separate terms apply.

4. Expiration

4.1. Bolt Credit expires automatically when:

• The countdown timer displayed in the campaign interface reaches zero, or
• Any earlier expiration date communicated by Toffee.

4.2. Expired Bolt Credit has no value and cannot be reinstated.

5. Restrictions

5.1. Bolt Credit may not be:

• Withdrawn, redeemed for cash, or exchanged;
• Transferred to another user;
• Used outside Toffee ecosystem;
• Combined with other promotional credits unless specifically permitted.

5.2. Toffee may apply product, merchant, or game-specific exclusions.

6. Fraud, Misuse, and Account Issues

6.1. Toffee may revoke Bolt Credit, freeze or close an account, or decline a redemption if misuse, fraud, ineligibility, or violation of Toffee’s Terms is suspected.

6.2. If identity verification is required and cannot be completed, Toffee may decline to issue or redeem Bolt Credit.

7. Modification and Termination

7.1. The Bolt Campaign will operate from 21 November 2025 until Toffee ends or replaces it.

7.2. Toffee may modify, suspend, or terminate the Bolt Campaign — including its value, redemption limits, duration, eligibility, or applicable products — at any time, with changes effective when posted in the app or on the Toffee Terms page.

8. Governing Terms

8.1. This Addendum forms part of the Toffee Terms & Conditions.
8.2. If there is a conflict between this Addendum and the main Terms, this Addendum governs only for the Bolt Campaign and related promotional credits.