Geographic Access & Transaction Restrictions Policy

1. Purpose

This Geographic Access & Transaction Restrictions Policy ("Policy") sets out the rules governing jurisdiction-based access to certain payment methods and crypto-asset transaction services made available through the PayAiro Inc platform.

This Policy is intended to ensure compliance with applicable United States federal and state laws, the regulatory and contractual requirements imposed by PayAiro Inc's licensed third-party service providers, as well as fraud prevention and security.

2. Scope and Applicability

This Policy applies to all users accessing the PayAiro Inc platform, website, mobile applications, or related services ("Users"); and

3. No Custody or Control of Funds

PayAiro Inc is a non-custodial fintech platform. Accordingly:

• PayAiro Inc does not hold, store, or transmit customer funds or digital assets;
• All fiat payment processing is performed by licensed third-party payment processors and sponsor partners;
• All crypto-asset custody services are provided by licensed third-party custodians.

At no time does PayAiro Inc take possession of, or exercise custody or control over, customer funds or crypto-assets.

4. Geographic Eligibility Requirement

Certain payment methods and transaction functionalities including but not limited to, Google Pay, debit cards, Apple pay, and similar U.S.-issued payment instruments are available only to Users who are physically located within the United States at the time of the transaction.

Users located outside the United States are not eligible to access or use such payment methods for transacting on the PayAiro Inc platform.

5. Location Verification

To enforce geographic eligibility, the users acknowledge and agree the reasonable use of verification mechanisms by PayAiro Inc and its third-party service providers, which includes:

• IP address analysis;
• Device-level location signals;
• Payment instrument issuer location;
• Device sensors and beacons;
• User provided information location;
• Transaction location data from payment processors;
• Risk-based compliance and fraud detection tools.

If a User's physical location cannot be reliably verified as being within the United States, PayAiro Inc may deny access to applicable payment methods or transaction features.

6. Prohibition on Circumvention

Users shall not attempt to circumvent geographic restrictions by any means, including:

• Use of VPNs, proxies, or anonymization services;
• Location spoofing or falsification;
• Misrepresentation of residence or physical location.

Any attempt to circumvent or bypass geographic controls constitutes a material violation of this Policy and the Terms of Service.

7. Regulatory and Partner Compliance

Geographic access restrictions under this Policy are imposed to comply with:

• Applicable U.S. federal and state financial, payments, and digital asset laws;
• Anti-money laundering (AML) and sanctions compliance requirements;
• Contractual obligations imposed by PayAiro Inc's licensed payment processors, custodians, and sponsor partners;
• Fraud prevention and security measures;
• Service delivery;
• Payment Card Industry Standards.

Availability of payment methods is subject to ongoing regulatory requirements and partner policies, and may change without notice.

8. Right to Restrict, Suspend, or Terminate Access

PayAiro Inc reserves the right, at its sole discretion, to:

• Restrict or suspend access to payment methods or transaction services;
• Block or reverse attempted transactions where permitted by law;
• Terminate user access for violations of this Policy.

For the purposes of fraud prevention and security, such actions may be taken without prior notice where required to meet legal or compliance obligations. The user may reach us at grievance@payairo.com to resolve any issue under this clause.

Policy Updates

This Policy may be amended from time to time to reflect changes in operational processes, regulations, or market conditions. Updated versions will be published on our website, and the "Last Updated" date will be revised accordingly.

Your continued use of PayAiro services after such updates constitutes your acceptance of the revised policy.

Last Updated: 16 January 2026