JEWEL TERMS OF USE AGREEMENT

Welcome to the website and Jewel Online Banking app of Jewel Bancorp Limited ("Site"). Your use of this Site and its services ("Services") will be subject to the following terms and conditions. Please read them carefully. By accessing this Site or using any Service, you are agreeing to these terms, which represent the Terms of Use Agreement between you and us (the "Agreement"). If you do not want to be bound by this Agreement, you should leave this Site.

Throughout this Agreement, the words “you,” “your,” and “yours” refer to users of the Site. “Jewel Bancorp,” “Jewel,” “we,” “us,” “our,” and “Bank” refer to Jewel Bancorp Limited. Jewel Bancorp's products and services are available only in those jurisdictions where they may be legally offered or obtained.

Our banking products and services have not been registered or licensed under any United States securities legislation and are not being offered, directly or indirectly, in the United States or in any of its territories or possessions or areas subject to its jurisdiction or to its citizens or persons thereof. "United States" is herein defined meaning the United States of America (including the States and the District of Columbia), its territories, its possessions and other areas subject to its jurisdiction including the Commonwealth of Puerto Rico and "US person" includes any national, citizen or resident of the United States, a corporation, partnership or other entity created or organised in and under the laws of the United States or any political subdivision thereof, and any estate or trust which is subject to United States federal income taxation regardless of the source of its income.

Limitation of Liability

THE SITE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. NEITHER JEWEL BANCORP LTD. NOR ITS AFFILIATES OR SERVICE PROVIDERS MAKE ANY WARRANTY, EXPRESS OR IMPLIED REGARDING THIS SITE, ITS CONTENT, THE SERVICES, THE GOODS OR SERVICES ADVERTISED BY THIRD PARTIES VIA THIS SITE OR LINKED SITES, OR THE SUBJECT MATTER OF THIS AGREEMENT. ALL WARRANTIES, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, ARE EXPRESSLY DISCLAIMED TO THE GREATEST EXTENT PERMITTED BY LAW. WE ASSUME NO RESPONSIBILITY FOR THE UNAVAILABILITY OF THIS SITE, FOR VIRUSES CREATED BY THIRD PARTIES, OR FOR INFORMATION PROVIDED BY THIRD PARTIES. NO CONTENT AVAILABLE AT OR THROUGH THE SITE SHALL CREATE ANY WARRANTY.

EXCEPT TO THE EXTENT OTHERWISE REQUIRED BY LAW, WE WILL NOT BE LIABLE TO YOU FOR ANY CONSEQUENTIAL, INDIRECT, SPECIAL, INCIDENTAL OR SIMILAR DAMAGES, WHETHER OR NOT THEY ARE FORESEEABLE, INCLUDING CLAIMS FOR LOSS OF GOODWILL, PROFITS, DATA, USE OF MONEY OR PRODUCTS, STOPPAGE OF WORK OR IMPAIRMENT OF ASSETS, WHETHER ARISING OUT OF BREACH OF EXPRESS OR IMPLIED WARRANTY, BREACH OF CONTRACT, NEGLIGENCE, MISREPRESENTATION, STRICT LIABILITY OR OTHERWISE.

Jewel Bancorp has designed our site to be both accurate and user friendly to the best extent possible. However, to the fullest extent permitted under law, we disclaim all express or implied warranties that this Site is accurate, complete, or up to date and all liability arising thereunder.

The fact that information, products or services are reviewable and accessible on this Site does not necessarily mean that:

• a) You should rely on the information.
• b) The products and services that we provide are suitable for you.
• c) The services on this Site are still available.
• d) The services available may not have changed materially.

This Site may contain various links to third party websites which are hosted and maintained independently. We have no control over the content or security of any such site and you link to such websites at your own risk.

Any personal data provided by you in response to this Site or otherwise may be held and processed by us, and will not be used other than for the purposes as described in our Privacy Policy . Further information on the collection and use of personal data by Jewel is contained in our Privacy Policy. The contents of this Site, including this Terms of Use and the Jewel Privacy Policy, are subject to change by us without notification.

About Jewel Bancorp Limited, Bermuda

The Bank is registered as a Bermuda exempted company limited by shares pursuant to the Bermuda Companies Act 1981 (as amended) and is licensed to conduct banking business pursuant to the Bermuda Banks and Deposit Companies Act 1999 (as amended) and to conduct digital assets business in or from within Bermuda pursuant to a Class F licence issued by the Bermuda Monetary Authority (the "BMA") pursuant to the Digital Asset Business Act 2018 (as amended). Jewel is also a participant in the Bermuda Deposit Insurance Scheme. The Scheme offers protection for eligible Bermuda Dollar deposits of up to $25,000. Full details of the Scheme are available at www.bdic.bm.

The registered office address of the Bank is Park Place, 55 Par La Ville Road, Hamilton HM11, Bermuda and the principal office and headquarters of Jewel Bancorp are located at The Swan Building, 26 Victoria Street, Hamilton, HM 12, Bermuda.

Fraud Prevention and Account Security

Customer Awareness Requirements & Phishing

Jewel will never email you a link or send you an SMS/text asking for your personal information, such as your Jewel Online Banking credentials and passwords. If you receive an email or text asking for such information, or that is otherwise suspicious, please forward it to security@dltjewel.com or contact your Client Relationship Manager. For your own security, you are also requested to block the sender and report their email text via the device it was delivered to. Always access Jewel Online Banking through the link on our Site or by typing the address www.dltjewel.com directly into your browser.

By using this Site and Jewel Online Banking, you agree as follows:

• a) to notify us immediately if you become aware of any unauthorised use of your account, any breach in the confidentiality of your account records, or any breach or attempted breach of security involving the Site or the Services;
• b) that you will not attempt to access the non-public areas of this Site or any other user's password-protected information;
• c) not to give your login credentials to anyone. If you are contacted by someone who states they are calling from the Bank or you receive an email, you should not give them any information. You must contact the Bank in the event you notice suspicious account activity or experience customer information security-related events;
• d) not to provide Personal Information (as defined in our Privacy Policy) or Personal Financial Information, which may include any government assigned identity number, account number or passwords, over the phone or the Internet if you did not initiate the contact;
• e) not to click on a link provided in an email you believe is fraudulent. It may contain some type of malicious software that can contaminate your computer.

Do not be intimidated by an email or caller who suggests dire consequences if you do not immediately provide or verify financial information. If you believe the contact is legitimate, go to Jewel's website by typing in the site address www.dltjewel.com directly or using a page you have previously bookmarked, instead of a link provided in the email. If you fall victim to an attack, act immediately to protect yourself. Alert the Bank Security Team immediately via email security@dltjewel.com as soon as possible. Place fraud alerts on your credit files. Monitor your credit files and monthly statements very closely.

User ID and Password Requirements

To utilise this Site, users must:

• a) Create a "strong" password with at least eight characters that includes a combination of mixed case letters, numbers, and special characters.
• b) Change your password frequently.
• c) Never share username and password information with third-party providers.
• d) Avoid using an automatic login feature that saves usernames and passwords.

Business Email Compromise Requirements

Jewel Bancorp conducts ongoing monitoring of threats to its business. All online banking customers should be aware of the Business Email Compromise (the "BEC"), which is a sophisticated scam targeting businesses, particularly banking businesses that regularly perform wire transfer payments. The fraudulent wire transfer payments sent to foreign banks may be transferred several times but are quickly dispersed.

The victims of the BEC scam range from small to large businesses. These businesses may purchase or supply a variety of goods, such as textiles, furniture, food, and pharmaceuticals. This scam impacts both ends of the supply chain, as both supplies and money can be lost and business relations may be damaged.

To help protect you and your business from becoming victims of the BEC scam:

• a)Avoid Free Web-Based Email: Establish a company website domain and use it to establish company email accounts in lieu of free, web-based accounts.
• b) Be careful what is posted to social media and company websites, especially job duties/descriptions and out of office details.
• c) Be suspicious of requests for secrecy or pressure to take action quickly.
• d) Consider additional IT and Financial security procedures and 2-step verification processes including:
  

   

  Out-of-Band Communication: Establish other communication channels, such as telephone calls, to verify significant transactions. Arrange this second-factor authentication early in the relationship and outside the email environment to avoid interception by a hacker.

  Digital Signatures: Both entities on either side of transactions should use digital signatures. However, this will not work with web-based e-mail accounts. Additionally, some countries ban or limit the use of encryption.

  Delete Spam: Immediately delete unsolicited e-mail (spam) from unknown parties. Do NOT open spam email, click on links in the email, or open attachments. These often contain malware that will give subjects access to your computer system.

  Forward vs. Reply: Do not use the "Reply" option to respond to any business emails. Instead, use the "Forward" option and either type in the correct e-mail address or select it from the e-mail address book to ensure the intended recipient's correct e-mail address is used.

• e) Significant Changes: Beware of sudden changes in business practices. For example, if a current business contact suddenly asks to be contacted via their personal email address when all previous official correspondence has been on a company email, the request could be fraudulent. Always verify via other channels that you are still communicating with your legitimate business partner.

Other Business Protection Requirements

It is highly recommended that commercial online banking customers perform risk assessments and controls evaluations periodically to help identify potential threats and to determine the strength of their controls.

This can be done as follows:

• a) by educating your employees on the risks.
• b) by creating and maintaining proper user account controls.
• c) be ensuring that you review all transactions,
• d) by installing and maintaining proper antivirus/security software on all systems/networks that access online banking. and
• e) by never sending personal or sensitive information via email.

General Fraud Prevention and Security Requirements

• a) Do not use public or other unsecured computers for logging into Jewel Bancorp Online Banking.
• b) Check the last login date/time every time you log in.
• c) If the system does not recognize your computer or location, you will be asked to provide additional information to log into Jewel Bancorp Online Banking. This may include Out-of-Band Authentication via phone or SMS text message or answering more sophisticated (Out-of-Wallet) challenge questions.
• d) Review account balances and detail transactions regularly (preferably daily) to confirm payment and other transaction data and immediately report any suspicious transactions to your financial institution.
• e) View transfer history available by viewing account activity information.
• f) [Whenever possible, use Bill Pay instead of checks to limit account number exposure and to obtain better electronic record keeping.
• g) Take advantage of and regularly view system alerts; examples include:
  • i) balance alerts.
  • ii) password change alerts.
  • iii) transfer alerts.
• h) Do not use account numbers, your social security number (or equivalent), or other account or personal information when creating account nicknames or other titles.
• i) Use the historical reporting features of your online banking application on a regular basis to confirm payment and other transaction data.
• j) Never leave a computer unattended while using Jewel Bancorp Online Banking.
• k) Never conduct banking transactions while multiple browsers are open on your computer.

Phishing, Spyware And Malware Avoidance Requirements

• a) Do not open email from unknown sources.
• b) Be suspicious of emails purporting to be from a financial institution, government department, or other agency requesting account information, account verification, or banking access credentials such as user names, passwords, PIN codes, and similar information. Opening file attachments or clicking on web links in suspicious emails could expose your system to malicious code that could hijack your computer.
• c) Never respond to a suspicious email or click on any hyperlink embedded in a suspicious email. Call the purported source if you are unsure who sent an email.
• d) If an email claiming to be from your financial organisation seems suspicious, check with your financial organisation.
• e) Install anti-virus and spyware detection software on all computer systems. Free software may not provide protection against the latest threats compared with an industry standard product.
• f) Update all of your computers regularly with the latest versions and patches of both anti-virus and anti-spyware software.
• g) Ensure computers are patched regularly, particularly operating systems, browsers, and key applications.
• h) Install a dedicated, actively managed firewall, especially if using a broadband or dedicated connection to the Internet, such as DSL or cable. A firewall limits the potential for unauthorised access to your network and computers.
• i) Check your settings and select, at least, a medium level of security for your browsers.
• j) Clear the browser cache before starting any Jewel Online Banking session to eliminate copies of web pages that have been stored on the hard drive. How the cache is cleared depends on the browser and version you are using. This function is generally found in the browser's preferences menu.
• k) Be advised that you will never be presented with a maintenance page after entering login credentials. Legitimate maintenance pages are displayed when first reaching the URL and before entering login credentials.
• l) Jewel Bancorp Online Banking does not use pop-up windows to display login messages or errors. They are displayed directly on the login screen.
• m) Jewel Bancorp Online Banking never displays pop-up messages indicating that you cannot use your current browser.
• n) Be aware that repeatedly being asked to enter your user ID or password are signs of potentially harmful activity.

Wireless Network Management Requirements

Wireless networks can provide an unintended open door to your network. Unless a valid business reason exists for wireless network use, it is recommended that all wireless networks be disabled. If a wireless network is to be used for legitimate business purposes, it is recommended that wireless networks be secured as follows:

• a) Change the wireless network hardware (router/access point) administrative password from the factory default to a complex password. Save the password in a secure location as it will be needed to make future changes to the device.
• b) Disable remote administration of the wireless network hardware (router/access point).
• c) If possible, disable broadcasting the network SSID.
• d) If your device offers WPA encryption, secure your wireless network by enabling WPA encryption of the wireless network. If your device does not support WPA encryption, enable WEP encryption.
• e) If only known computers will access the wireless network, consider enabling MAC filtering on the network hardware. Every computer network card is assigned a unique MAC address. MAC filtering will only allow computers with permitted MAC addresses access to the wireless network.

Mobile Banking Requirements

• a) Beware of sophisticated phishing attempts involving fake or spoofed mobile apps presenting as Jewel Bank or its affiliates. To avoid downloading a spoof app, use the official app stores the Apple App Store or Google Play) to download the Jewel Online Banking app.
• b) Ensure that all software on your phone, including the phone operating system, is up to date.
• c) We recommend that you do not "jailbreak" your phone or otherwise disable its built-in security features.
• d) Ensure your mobile device is protected with a password or passcode and that the device auto-locks when it is not in use.
• e) Configure your device so it does not automatically connect to new wireless networks.
• f) Never send any personal information via text message or via email messaging.
• g) Do not open messages from an unknown sender, and do not click on unfamiliar links.

Internet Cookies and Jewel Bancorp

Cookies, HTTP cookies, or internet cookies are small pieces of text sent to your browser by a website you visit. They allow websites to remember information about your visit, which can both make it easier to visit the site again and make the site more useful to you. They are built specifically for Internet web browsers to track, personalise, and save information about each user's session.

Jewel Bancorp takes client and end user privacy and the information we gather about clients and end users very seriously. We are committed to protecting the privacy of clients using our Site and ensuring that all transactions are as secure as possible.

We gather information about visitors to our servers hosting Jewel Bancorp Sites for internal tracking purposes, to evaluate our Sites’ technical capabilities, to make our Sites useful to you, and to respond to specific requests for information or services.

We use cookie technology to learn certain information about visitors to our Sites. This information helps us provide an online service best suited to the devices from which users are connecting, and assists us in preventing and detecting fraud. The information we collect includes data about users’ domains, web browsers and devices used, as well as the dates and times of visits to our Site, the pages on our Site that are visited, and items that are downloaded from those pages.

We do not use cookies to track [Client or end users] online activities after leaving our sites, and we do not store personal information in them that others could read and understand. We do not sell or distribute cookie information.

The data contained within cookies is encrypted so it may not be tampered with or viewed by another party. Only servers hosting the Jewel Site may read these cookies; your web browser ensures that these cookies are not sent to other websites.

You can change your browser settings to refuse cookies or let you know each time a website tries to set a cookie. However, refusing cookies in this way may mean all or parts of websites may not work properly or as quickly as they otherwise would.

Cookie Types

Session cookies

Session cookies are stored in your browser only for the period that you are connected to a website. They are used to guide the dialogue from page to page, and control the logout process on password-protected sites. When you click “logout,” the session cookie expires. To perform further enquiries or transactions, you must log back in, which establishes a new session cookie. Session cookies are also time-sensitive; after a set period of inactivity, the session cookie will expire and you will be logged out of the site automatically.

Jewel Bancorp Online Banking, our secure online banking Site uses session cookies. By using these services, you are agreeing to the use of session cookies. In addition to cookies we use on our Site, we may also use cookies when we send you emails or electronic “push” notifications. This enables us to know whether you have opened an email notification and how you have interacted with it. Cookies may be set on your device if you enable images or click on a link within the email. You can set your cookie preferences within the browser you use for communications with Jewel Bancorp.

Persistent cookies

Persistent cookies are used for many purposes. They are stored on your computer until they expire or until you remove them. Persistent cookies store your personal preferences, such as language or location, to make subsequent visits to a website easier. They may also be used to remember your responses to questions you have been asked previously, such as a request to update your contact information. A persistent cookie will prevent you from being asked to complete the same information every time you visit a website.

Jewel Bancorp Sites may use persistent cookies to capture your location preferences. Persistent cookies can be disabled by you by managing your cookie preferences.

Some Jewel Bancorp Online Banking cookies are strictly necessary for our Site to operate properly, to verify your identity, to maintain your security and privacy, and to comply with regulatory obligations. Without this data, the services you have asked for cannot be provided.

By using our Site, you agree to the use of strictly necessary cookies. It is possible to disable all cookies in your browser settings, including strictly necessary cookies, but doing so will cause the Site to not work properly.

Jewel Bancorp also can utilise profile cookies that enable us to remember choices you make to personalise your experience and provide services you’ve asked for. These cookies are used to provide you with a more efficient, customised experience with this site.

If you previously accepted the use of a certain category of cookie, and now wish to refuse it, that won’t automatically delete cookies downloaded to your device in the past. We may still use the information collected when you had previously provided your consent. When you change your settings to disable other-than strictly necessary cookies, we will update our systems as soon as reasonably possible to stop using those cookies to capture any further data.

First and Third Party Cookies

First party cookies are set by websites you visit, third party cookies are delivered by outside organisations, such as social media providers, search engines and advertisers, subject to their respective terms of use. Please click here to manage your Jewel cookie preferences.

For further information on how Jewel Bancorp uses cookies or on how Jewel Bancorp will use your personal information, please refer to the Jewel Bancorp Privacy Policy.

Copyright, Laws and Site Guidelines

All material included in the Site is owned by or licensed to Jewel Bancorp Limited unless otherwise noted. Among other things, except to the extent required for the limited purpose of reviewing material on our Site, electronic reproduction, adaptation, distribution, performance or display is prohibited. Commercial use of any content is prohibited.

You agree to comply with the laws that apply to your use of this Site and its Services. You also agree not to engage in any activities that: encourage a violation of any law or regulation by others; abuse, harass, stalk, defame, impersonate or invade the privacy of another; infringe the rights of any third party, including intellectual property, business, contractual and fiduciary rights; are in any way connected with the transmission of "junk mail," "spam," "pyramid scheme" solicitations, chain letters, or any other mass distribution of unsolicited e-mail; interfere with the functioning of the Site or any linked website; or involve sending abusive, obscene, hateful or otherwise offensive content by means of any Service. You also agree to comply with the rules of the internet service providers, networks, hosting and telecommunication services, servers, computer databases, and websites that you access or use in conjunction with this Site and/or the Services.

Intellectual property laws protect original material that we post on this Site. You are granted a non-exclusive licence to access the content on this Site and to print copies of any content only for your personal use. Except as expressly provided above, we reserve all rights to original material we post on this Site.

Jewel Bank is a brand name of Jewel Bancorp Limited and all rights in and to Jewel vest in Jewel Bancorp Limited. Other than as provided above you may not use or reproduce the Jewel Bancorp logo or brand name.

Modifications to Jewel Terms of Use

Jewel Bancorp reserves the right to amend, modify or discontinue its terms of use, including our cookie policy, at any time, for any reason. The content and services found on this Site, including the legal notices, are subject to change at any time without notification. You agree to revisit this page regularly and your continued access to the Site will mean that you agree to the changes.

Severability. If any provision of this Agreement is found to be invalid or unenforceable, the remainder of this Agreement will continue in effect.

Waiver. Any waiver of the provisions of this Agreement by us must be in writing to be valid. No waiver will occur as a result of a usage of trade, custom or practice.

Termination

We may terminate your use of the Site and Jewel Bancorp Online Banking at any time without cause. The terms of this Agreement will continue to apply following its termination to any obligations incurred or arising prior to its termination.