Terms & Conditions

W PAYMENTS: We are a comprehensive software infrastructure (SaaS) provider and a B2B technology orchestrator, enabling telematic management, routing of fund disbursement instructions, and the provision of advanced technological solutions for international collections processes. Our architecture allows our users' working capital to move with agility, clarity, and security, through payment data management operations, cross border, and early settlement facilitation, which lets us offer effective, inclusive processes suitable for SMEs, micro-SMEs, and independent professionals.

This agreement is intended to make known the strict rules governing the terms and conditions under which W PAYMENTS' technological services are licensed and integrated. For that reason, it is imperative that the user carefully and thoroughly review the use policies and risk assumptions consolidated in this document. If you access this portal and the W PAYMENTS interfaces, it means you expressly, unambiguously, and in full agree to these terms and conditions (hereinafter "T&C") set out below. If you do not agree with all of these provisions, please immediately refrain from accessing this portal and our services.

Protecting your operational privacy is an unbreakable pillar for W PAYMENTS. We encourage you to review our Comprehensive Personal Data Processing Policy so you can understand our institutional rigor in maintaining corporate confidentiality and the use of your information properly protected within financial ecosystems.

SECTION 1. GENERAL OVERVIEW

W PAYMENTS states that:

1. It is a technology platform legally operated and managed by TWC INTERNATIONAL LLC, a limited liability company organized under the laws of the State of Wyoming, United States of America. Given its exclusively technological nature, W PAYMENTS is not a financial services provider in the Republic of Colombia or in any other jurisdiction, nor does it carry out material operations of fund raising, fiduciary holding, or public asset management, and therefore it is not subject to the inspection, control, and oversight of the Financial Superintendency of Colombia.

2. It has the status of Technology Orchestrator and authorized data transmission facilitator, acting through a technological mandate on behalf of the Partner to channel payment instructions to Third-Party Partners, Acquiring Entities, banks, and payment rail providers, who are solely responsible for the custody and settlement of the funds.

3. It is a Software as a Service (SaaS) provider that, through its platform, offers visibility into payment receipt and disbursement management, data analytics, and related telematic services, backed by technical Banking As A Service (BaaS) integrations.

4. It does not carry out any regulated financial activity or provide postal money order, foreign exchange market intermediation (FX/IMC), or securities services. Nor does it expressly or implicitly authorize third parties to use the technological Services to disguise such purposes.

5. W PAYMENTS does not raise funds or receive bank deposits directly from the public. The financial flows processed in the ecosystem are managed under a technological mandate on behalf of the corresponding Partner, with the Platform acting as a conduit for instructions so the proper settlement can be made into the destination accounts in accordance with these Terms and Conditions.

6. The Services are licensed solely and exclusively to commercial Partners who have passed strict due diligence controls and are properly certified with their corporate data and bank accounts.

7. It does not require Partners to accept a specific brand of credit, debit, prepaid, or gift cards to access the Services, and the activation of such payment methods is subject to the acquiring networks of the Third-Party Partners.

8. W PAYMENTS only allows the Partner to route transactions through the payment methods previously authorized by the integrated Acquiring Entities.

9. The Services are enabled so that natural or legal persons ("Partners") can orchestrate the monetization of payments invoiced on the Acquiring Entities' platforms, assuming 100% of the transaction risk, without prejudice to the conditions set forth in these T&C.

10. It is not a party to, and does not materially or legally intervene in, the contracts or commercial agreements that the Partner enters into directly with acquiring entities or content platforms, maintaining absolute autonomy and harmlessness.

11. It guarantees constant monitoring of its interfaces (APIs) to identify and mitigate possible technical errors, ensuring the quality and protection of the network against cyber security threats.

The Partner declares and warrants under oath that:

1. They are of legal age, act in their own legal capacity or on behalf of their corporation, and have full legal, financial, and administrative capacity to contract and become bound in the corresponding capacity in which they act.

2. They know and accept that the authorizations, data routing mandates, and discounting powers granted under these T&C will remain fully in force until a Final Cancellation or a duly completed Voluntary Cancellation is applied.

3. They know and accept that the software license and the Services are provided exactly as described in these T&C, with no other express or implied warranty regarding the infallibility of third-party banking networks.

4. All corporate and tax information, and the data provided to W PAYMENTS, are true; therefore, the attached documents are authentic, accurate, and verifiable. They authorize exhaustive verification before any authority, entity, or national or foreign intelligence provider. The Partner agrees to update their information at least once a year, or immediately when a material change occurs.

5. They know, understand, and irrevocably submit to W PAYMENTS' Comprehensive Personal Data Processing Policy.

6. They know and accept that W PAYMENTS may, at any time, verify with Information and Risk Operators, credit bureaus, or any other entity that manages databases, everything related to their current, past, and future financial, commercial, and credit behavior.

7. They understand that W PAYMENTS does not act under any mandate to promote, market, or operate businesses in a specific sector, nor does it operate as a sales representative, commission agent, or commercial agent of the Partner.

8. The Partner will, at all times and under all circumstances, act on their own behalf and at their own risk before their end customers and before the acquiring entities.

9. They have all required operating permits, licenses, and tax registrations according to the activity or business purpose they carry out. The Partner assumes full and absolute legal and financial liability for failing to obtain such permits.

10. They know and accept that this legal relationship is strictly of a B2B (Business to Business) commercial nature. The Partner carries out their activity autonomously and independently, using their own personnel, with no legal, labor, or administrative subordination whatsoever between W PAYMENTS and the Partner, their employees, and dependents. Concepts such as fees, salaries, subsidies, social security enrollments, and compensation will be borne exclusively by the Partner.

11. W PAYMENTS has no involvement in the actions arising from the ordinary course of the Partner's business, nor in pricing, chargebacks, or commercial policies imposed by the Acquiring Entity.

12. They know and accept that W PAYMENTS reserves the absolute and discretionary right to reject, delay, or deny their registration request to create or activate the W PAYMENTS Account.

13. They agree NOT to use the Services, directly or indirectly, for any fraudulent, unlawful, money laundering, or technically destabilizing purpose of the Services.

14. They know and understand in a non-negotiable manner that the Acquiring Entities, processing networks, and financial entities linked to the settlement of collections are NOT subcontractors of W PAYMENTS, but rather independent third-party infrastructures.

15. The Partner knows and accepts that these T&C are made available to them through electronic support, and that their electronic acceptance, the use of credentials, and all activity through cryptographic logs within the W PAYMENTS Account, constitute full proof of contractual intent and may be used by W PAYMENTS before authorities as irrefutable evidentiary elements.

SECTION 2. THE SERVICES

As a Technology Orchestrator and B2B integrator, W PAYMENTS: a). Provides the Partner with telematic tools to streamline the visibility of invoiced monetization; b). Algorithmically processes transactions and payment traceability; c). Executes a technological instruction mandate, acting on behalf of the Partner to channel orders to Third-Party Partners so they can settle into the deposit account the funds arising from the Partner's commercial activity; d). Instructs the disbursement of Net Income to the bank account indicated by the Partner; e). Instructs the automatic debit and withholding of Discounts, fees, and corresponding Amounts from Gross Income, as set forth in these T&C.

Technology Solution. W PAYMENTS has developed and licenses a patented Technology Solution that the Partner may use solely and strictly under the stipulations and technical limits established in these T&C. The Solution includes: a). A comprehensive platform for verification (KYB), creation, and activation of the W PAYMENTS Account, and b). Application Programming Interfaces (APIs) and data processing tools to facilitate communication with Acquiring Entities.

In any case, the Services will be those functionally available at the time the Partner activates their Account, or those that may be operationally implemented in the future. W PAYMENTS reserves the unilateral and unappealable right to temporarily suspend use of the Services for network security reasons, server maintenance, software updates, or force majeure events. W PAYMENTS is not responsible for unavailability, latency, or possible technical failures presented by Acquiring Entities, processor brands, or the underlying interbank networks.

SECTION 3. THE W PAYMENTS ACCOUNT

Account Creation. Access is strictly reserved for those natural or legal persons who carry out duly authorized commercial activities and who do not have a fraud history or who have not been subject to Suspension by W PAYMENTS. The onboarding process requires providing corporate data and establishing cryptographic login credentials.

Account Activation. To route data through the API, an "Active" Account must be held. The Partner must complete and attach all information required in the compliance forms (SAGRILAFT). W PAYMENTS will validate the information using forensic tools. If there are indications of false documents, inconsistencies, or if the Partner refuses to update data, W PAYMENTS reserves the right not to activate, deactivate, or apply Final Cancellation to the account, without assuming any liability for lost profits resulting from this security measure. If criminal indicators are detected, the Partner expressly authorizes immediate reporting to Financial Intelligence Units.

Custody of credentials and use of the Account. The Partner assumes the objective, exclusive, and non-delegable responsibility of safeguarding their password and API keys. Any settlement or routing order made from the W PAYMENTS Account will be presumed in law as executed, authentic, and expressly authorized by the holder Partner, with no contrary evidence admissible against W PAYMENTS' technological execution.

Nature, scope, and currency of the Account. The W PAYMENTS Account is a graphical and user environment within the SaaS infrastructure. The account operates under a nominal base currency denominated in United States Dollars (USD), used as a technical reference index for recording, calculating, and valuing transactions. The Partner unambiguously accepts that the W PAYMENTS Account is not a bank account, is not a fiduciary electronic wallet, and is not a deposit account covered by government deposit insurance. The values reflected in the dashboard constitute a "technological mirror" of the funds that are in transit or materially held by Third-Party Partners.

Dashboard, visibility, and reports. The interface provides visibility into balances in the process of clearing, cryptographic transaction history, preventive holds, and access to the Access Tools.

SECTION 4. ACCESS TOOLS

W PAYMENTS makes advanced service modules available to the Partner to enable functionality within their account. Through these algorithmic tools, the Partner can monitor, reconcile chargebacks, and access exceptional services such as the advance settlement of confirmed receivables ("Pay Me Now"), allowing cash flow to move faster over a given billing period, subject to the rigorous risk policies established for that operational tool.

SECTION 5. SPECIAL CONDITIONS OF THE BUSINESS SERVICE

Partner declarations: The Partner:

1. Knows, accepts, and grants W PAYMENTS a technological, representative, and special mandate to channel and manage the payment instructions made by the Acquiring Entities.

2. Irrevocably authorizes W PAYMENTS to, through such technological mandate, instruct Third-Party Partners regarding the receipt, settlement, disbursement, reversal, or withholding of the flows.

3. Knows and authorizes W PAYMENTS to instruct the automatic debit of its settlements for all Discounts, penalties, and fees that may apply under these T&C.

4. Grants irrevocable authorization for W PAYMENTS to instruct the blocking or freezing of funds with Third-Party Partners when an investigation begins due to a fraud alert, chargeback, or request from authorities. The funds will remain immobilized until the technical conclusion of the audit.
   
   
   

Discounts and Amount: On the gross volume processed by the Third-Party Partners during settlement periods, the Discounts will be executed (network financial costs, acquiring fees, taxes, and bank commissions). The Partner will be instructed to receive the disbursement of Net Income.

The Partner will pay W PAYMENTS a Technology Fee (the "Amount") in consideration for the software license and orchestration. The Amount consists of a percentage value over the transaction volume and/or a fixed value per API call or transaction. 

The Partner irrevocably authorizes the source deduction of this Amount directly from the clearing flows, prior to disbursement. The Amount does not include the tax obligations or applicable legal tax withholdings of the Partner.

Billing plans: W PAYMENTS will instruct the corresponding Disbursement to the Third-Party Partners toward the account designated by the Partner within an estimated operating term of up to five (5) business days counted from the effective and material release of the funds by the Acquiring Entity. As a risk control policy (AML), the first Disbursement from a new account will be executed after a preventive maturation period of five (5) calendar days following the first transaction.

Disbursements to the Partner's deposit account:

• Disbursement Account: The Partner must certify a legitimate bank account at one of the enabled institutions. The account holder must strictly be the natural or legal person who signed up for the W PAYMENTS Account.

• Operational traceability and verification requirements: Any local or cross-border settlement request is subject to the anti-money laundering manuals (SAGRILAFT). W PAYMENTS and correspondent banks may request documentary support for the source of funds. Failure to provide information authorizes the immediate blocking of the disbursement without liability on the part of the Company.

• Clearing times: Disbursements do NOT operate automatically. They are subject to clearing houses (ACH/SWIFT). If a transaction is held in "pending authorization" status by processing networks, the settlement time is suspended until release.

• Exemption for incorrect data: The Partner fully releases W PAYMENTS from any delays, exchange losses, or interbank rejections arising from providing incorrect account numbers or an incorrect SWIFT code.

• Abandoned balances: If the Partner has available funds and the account remains inactive for twelve (12) uninterrupted months, they irrevocably authorize forced settlement to the last registered bank account, assuming the operating costs of such disbursement.

• Preventive holds (Rolling Reserves) and fraud: The Partner authorizes the retention of flows for a term of up to one hundred twenty (120) calendar days in the event of chargeback spikes, franchise alerts, or unusual activity. These blocked funds will not generate interest recognition or monetary indexation.

• Acquiring disputes: The commercial, financial, and legal risk of payments is assumed 100% by the Partner. Any fine, penalty, or chargeback imposed by the franchises will be immediately passed on to the Partner and debited from their future balances through the granted technological discount mandate.

• Operational support: In the event of fraud audits, the Partner agrees to provide commercial supporting documentation within the peremptory five (5) business days after the request.

SECTION 6. PARTNER RESPONSIBILITIES

The Partner, without prejudice to other obligations, unconditionally agrees to: (i) Assume the accounting, legal, and tax management of their business; (ii) Maintain the transaction information, trade secrets, and technical architecture of the Platform in strict and absolute confidence; (iii) Safeguard the commercial records for the legal evidentiary period in order to respond to disputes and chargebacks; (iv) Ensure the alignment of their quality policies with the Consumer Statute regime (Law 1480); (v) Deploy corporate cybersecurity protocols on their own networks to prevent breaches and malicious code injections; and (vi) Diligently apply all software updates and security patches required by W PAYMENTS.

SECTION 7. FRAUD PREVENTION

The global payments ecosystem severely penalizes fraud. The Partner understands and accepts that any violation of the fraud thresholds of acquiring networks may result in institutional punitive fines. The Partner agrees to indemnify, hold harmless, and immediately reimburse W PAYMENTS and TWC INTERNATIONAL LLC for any fine, surcharge, or sanction imposed by processing networks arising from their transaction volume.

Investigations for Security Alerts: In the event of a reasonable suspicion of a security breach, impersonation, or credential compromise in the Partner's systems, W PAYMENTS will have the authority to require a forensic technical audit of the Partner's infrastructure, and the latter must fully cooperate corporately.

SECTION 8. UNLAWFUL AND PROHIBITED ACTIVITIES

The use of the technological infrastructure for activities outside legality and the T&C is absolutely and strictly prohibited.

Anti-Money Laundering and Terrorist Financing Prevention: W PAYMENTS, in line with global and local financial standards (SAGRILAFT), imposes a zero-tolerance policy. The Partner declares under oath that: (a) They implement measures to prevent their flows from serving as an instrument to conceal money from illicit origin; (b) They have no convictions and are not involved in criminal, disciplinary, or tax investigations for money laundering, corruption, drug trafficking, or terrorism; and (c) They do not appear on restrictive lists administered by national or foreign authorities. Any falsity in this declaration will authorize W PAYMENTS to activate Final Cancellation and freeze operational flows, immediately reporting to the competent authorities.

Prohibited Activities: The use of the API to channel payments associated with the following is expressly prohibited:

• Extraction, refining, or large-scale trade of gold, emeralds, and precious metals.

• Manufacture and sale of weapons, ammunition, or military material.

• Material recovery, scrap trade, and industrial waste.

• Unregulated exchange operations, Forex, and unlicensed exchange houses.

• Betting platforms, online casinos, or gambling games without authorization from Coljuegos.

• Commercialization of pharmaceutical products and biological material or wildlife.

SECTION 9. CANCELLATION, DEACTIVATION, AND SUSPENSION

W PAYMENTS reserves the discretionary, unilateral, and corporate authority to apply containment measures over access to the Platform.

• Voluntary Cancellation: The Partner may request commercial disengagement, conditioned sine qua non on there being no outstanding balances owed to W PAYMENTS, no pending chargebacks, and no open regulatory disputes.

• Final Cancellation: The Company may terminate the contract and permanently block user access, making the creation of new accounts within the W PAYMENTS ecosystem impossible for life.

• Deactivation: Temporary technical freezing applied when the Partner presents transactional inactivity of more than twelve (12) uninterrupted months.

• Preventive Suspension: Network protection measure applied when the Partner exceeds industry fraud thresholds, fails to complete KYB/KYC update processes, or engages in transactions classified as suspicious. Routed funds will remain blocked in the Third-Party Partners' custody infrastructure for up to one hundred twenty (120) days while the forensic investigation is resolved.

SECTION 10. LIMITATION OF LIABILITY

W PAYMENTS commits to providing its services under commercially reasonable availability parameters, but it does not guarantee the technical infallibility of the internet or banking networks. Under no circumstances shall W PAYMENTS, TWC INTERNATIONAL LLC, their officers, subsidiaries, or developers be liable for indirect damages, lost profits, consequential damages, punitive damages, incidental damages, loss of business opportunity, loss of data, or reputational harm arising from the use, unavailability, or interruption of the API, gateway failures, hacks, code injections, compliance blocks (AML), or force majeure events. The Partner unconditionally accepts that the aggregate, maximum, and total liability of W PAYMENTS for any failure directly attributable to fraud or gross negligence duly proven in court shall be strictly limited and capped at twenty percent (20%) of the net technology fees paid by the Partner during the twelve (12) months immediately preceding the event causing the damage.

SECTION 11. FUNDS IN TRANSIT; NO CUSTODY OR OWNERSHIP OVER THE RESOURCES

In observance of its legal and technical nature:

1. W PAYMENTS does not act as a bank, fiduciary, financial entity, remittance company, or institutional custodian.

2. The processed resources are routed exclusively for the technical purpose of facilitating their settlement through regulated payment rail providers.

3. W PAYMENTS does not acquire ownership, title, credit rights, or discretionary patrimonial control over the Partner's funds.

4. The transitory passage of funds through operational clearing accounts does not constitute fundraising, irregular deposit, or trust relationship.

5. Retention, compliance, Compliance rejection, or blocking processes are carried out in accordance with the strict regulatory frameworks of the bank Third-Party Partners.

6. The Company shall not be liable in any way for delays, reversals, or seizures imposed by the FIU, the Colombian tax authority (DIAN), or correspondent banks on transit flows.

SECTION 12. SERVICE FEES AND CURRENCY CONVERSION 

12.1 W PAYMENTS fees. The Company incurs and charges technology fees for providing its technical facilitation services, B2B orchestration, instruction routing, and licensing of its software infrastructure (SaaS). These fees are settled in accordance with the cost structure informed to and accepted by the Partner at the time of onboarding or the activation of the corresponding module. 

12.2 Third-party costs. The net fees applicable to the Partner may incorporate, reflect, or be inherently affected by the operating costs associated with regulated Third-Party Partners. This includes, without limitation, the margins of payment rail providers, acquiring entity commissions (Interchange++), liquidity providers, clearing mechanisms (ACH/SWIFT), and compliance audit costs. 

12.3 Currency conversion (FX). W PAYMENTS is not a Foreign Exchange Market Intermediary (FX/IMC), does not provide independent foreign currency purchase and sale services (Forex), does not act as an exchange house, and does not set or guarantee conversion rates. Any currency conversion that becomes operationally necessary for settling a transaction will be carried out exclusively by the financial Third-Party Partners, governed by their own terms, spread policies, and regulatory frameworks. 

12.4 Estimated nature of values. The Partner understands and accepts that the values displayed in the dashboard, the balances in the settlement process, or the projected net amounts are strictly referential or estimated in nature. These values may undergo mathematical changes between the time of authorization on the network and their effective settlement, as a direct result of market exchange-rate fluctuations, interbank processing times, or third-party tax withholdings. 

12.5 No guarantee on rates or outcomes. The Company does not guarantee under any circumstance the obtaining of any specific, preferential, or favorable exchange rate (TRM). W PAYMENTS rejects any patrimonial liability for exchange-rate differences, market volatility, slippage, or additional costs arising from conversion executed by the banking network. 

12.6 Non-transferability of benefits and internal concepts. The Partner declares that they know and accept that any logical balance, display, estimate, or fee reflected within the W PAYMENTS Account is for exclusive technical use within the Platform's closed ecosystem. Consequently, these logical balances are not transferable, assignable, negotiable, or endorsable to third parties. Under no legal interpretation do these concepts constitute a security, a tradable financial asset, or an enforceable credit right against third parties outside the operational execution described in these T&C.

SECTION 13. INTELLECTUAL PROPERTY

TWC INTERNATIONAL LLC and its affiliates are the absolute, worldwide, and exclusive owners of all copyrights, patents, trade secrets, source codes, logos, and algorithms integrated into the W PAYMENTS ecosystem. Acceptance of these T&C grants the Partner a strictly precarious, revocable, non-transferable, and non-exclusive license to use the telematic interface. The Partner is strictly prohibited from decoding, reverse engineering, sublicensing, or commercializing the Company's Intellectual Property.

SECTION 14. AUTHORIZATION FOR PERSONAL DATA MANAGEMENT

The Partner, acting with binding legal capacity, declares that they know, submit to, and fully accept W PAYMENTS' Comprehensive Personal Data Processing Policy.

• Express Authorization: They irrevocably authorize the Company to collect, store, transmit, and transfer their corporate information across borders (Law 1581 of 2012 / Law 1266 of 2008) to Third-Party Partners and authorities.

• Operational and Analytical Purposes: They authorize the use of the data for KYC/KYB execution, biometric matching, commercial risk profiling, credit bureau reporting, data analytics, and algorithmic structuring.

• Ownership Declaration: They acknowledge the optional nature of responses regarding sensitive data, understanding, however, that the technical refusal to liveness check (biometrics) processes prevents the provision of the Services.

SECTION 15. OTHER PROVISIONS

Foreign exchange obligations: It is the Partner's exclusive, non-delegable, and own-risk obligation to strictly comply with the foreign exchange control regime. The Partner assumes responsibility for filing foreign exchange declarations before the Bank of the Republic of Colombia or its jurisdictional equivalent. W PAYMENTS remains harmless against DIAN sanctions for the Partner's foreign exchange violations.

Modification of the T&C: W PAYMENTS reserves the unilateral corporate prerogative to amend, add, or remove operational clauses of these T&C. Such modifications will take effect ten (10) calendar days after their electronic publication. Continued use of the API after that period constitutes a novation of acceptance.

Dispute Resolution and Jurisdiction: For purposes of the material operation and commercial claims of Partners domiciled in Colombia, the parties voluntarily submit to the commercial laws of that Republic, agreeing to the jurisdiction of the ordinary courts of the city of Medellín. Such territorial submission applies strictly to operational disputes without implying the lifting of the corporate veil or the waiver by TWC INTERNATIONAL LLC of the commercial, corporate, and tax protections inherent to its jurisdiction of origin and incorporation, Wyoming, United States.

Comprehensive Indemnity (Hold Harmless): The Partner jointly and severally agrees to defend, compensate, and keep W PAYMENTS, TWC INTERNATIONAL LLC, their shareholders, officers, and providers completely harmless from: (i) Fines or penalties imposed by processing networks (Visa/Mastercard); (ii) Tax authority investigations for tax evasion; (iii) Labor, civil, or commercial claims filed by third parties, models, or the Partner's clients; and (iv) Disputes arising from intellectual property infringements, copyright, or publication of unauthorized material through their financial flows.

Assignment and Entire Agreement: The Partner has no authority to assign, transfer, or endorse their contractual position or their W PAYMENTS Account. The Company may freely assign these T&C to any parent company, subsidiary, or acquiring third party. This document constitutes the complete and entire agreement between the parties, superseding any prior verbal negotiations.

SECTION 16. SPECIAL, EXCEPTIONAL, AND CONDITIONAL SERVICES 

The modules described in this section are eminently special, exceptional, and conditioned on risk thresholds. Therefore, they do not form part of the ordinary core of W PAYMENTS' basic Services and are not available in an unrestricted or permanent manner to all Partners. The activation, continuity, timelines, and modalities of these services will at all times be subject to Compliance audits, risk criteria, and technical availability determined by W PAYMENTS, which reserves the power to suspend or discontinue them without this generating any acquired right or expectation in favor of the Partner.

16.1 DIGITAL ASSET SETTLEMENT SERVICE 

16.1.1 Nature of the service.It constitutes a strictly operational and technical mechanism designed to allow the Partner to instruct the settlement of their operational income through stable-value digital assets (stablecoins). This service does not constitute financial intermediation, cryptoasset purchase and sale (trading), digital custody, investment advice, or fundraising. 

16.1.2 W PAYMENTS' role. The Company acts exclusively as a telematic facilitator and orchestrator of the process. W PAYMENTS does not at any time assume fiduciary custody, control, or holding of the digital assets. W PAYMENTS does not manage private wallets, does not custody cryptographic keys (Private Keys), and does not guarantee secondary market liquidity. 

16.1.3 Enabled digital assets. Orchestration is restricted to the use of parity or stable-value digital assets (e.g., USDC, USDT), or those that the infrastructure determines to be technically and operationally viable in the future. 

16.1.4 Irreversibility of the operation. Any settlement instruction routed to a blockchain network is final and immutable. Once the order is confirmed by the Partner, the decentralized nature of the technology makes reversal technically impossible. 

16.1.5 Execution timelines and validations. W PAYMENTS will have an operating window of up to three (3) business days, counted from receipt of the instruction, to route the settlement. During this period, fraud prevention validations, source-of-funds controls, and regulatory compliance (AML) will be carried out. 

16.1.6 Risks assumed by the Partner. The Partner assumes one hundred percent (100%) of the exposure and inherent risks, including market variations, operational failures of blockchain networks (congestion, gas fees), and the absolute loss of funds resulting from typographical errors in providing the destination wallet address. 

16.1.7 Disclaimer of liability. W PAYMENTS is fully released from civil, contractual, or extra-contractual liability for patrimonial losses, hacks to decentralized networks, or the technical impossibility of recovering digital assets once the operation has been routed. 

16.1.8 Regulatory compliance and source of funds. The Partner warrants under oath that the funds subject to conversion and settlement come from the ordinary and lawful course of their business. W PAYMENTS retains the absolute right to block the order and freeze the account if the algorithms detect exposure to Dark Web addresses or wallets sanctioned by OFAC.

16.2 PAY ME NOW 

16.2.1 Nature of the service. It is an operational and exceptional facilitation tool structured to allow the Partner to instruct the early settlement of pending balances and confirmed receivables, thereby energizing their working capital. This service is NOT, and may not be judicially interpreted as, a credit service, commercial loan, fundraising, foreign exchange market (Forex), or investment mechanism. 

16.2.2 Condition and activation. Access to this module is purely discretionary. Activation is subject to the Partner's internal risk ratings and their chargebacks history. 

16.2.3 Receipt hours. Instructions will be processed in strict compliance with clearing house hours: Monday to Friday, from 8:00 a.m. to 1:00 p.m. (Republic of Colombia time). Business days shall be those that are business days concurrently in Colombia and in the United States of America. 

16.2.4 Service modes. Subject to risk enablement, the Partner may route instructions under:

Standard Pay Me Now: Instructions received during business hours are estimated to settle within up to one (1) business day. Outside business hours, up to two (2) business days. The TRM imposed by Third-Party Partners at the exact time of material execution will apply.

Priority Pay Me Now: Instructions during business hours are estimated to settle the same day, subject to banking network congestion. Outside business hours, up to one (1) business day. The TRM in effect at the time of material execution will apply. The Company does not guarantee margins or economic outcomes. 

16.2.5 Cancellations and modifications.Once the Partner triggers the instruction in the API, the order is irrevocable. Any request from the Partner to modify the destination banking information (subject to technical feasibility) will incur an administrative and operational cost of five United States dollars (USD $5.00), an amount that will be debited automatically. 

16.2.6 Errors attributable to the Partner. Any order rejected by the banking network due to incorrect information, inconsistencies in account numbers, or failures attributable to the Partner's negligence will generate an operational penalty of five dollars (USD $5.00), debited directly from the settlement. 

16.2.7 Settlement deduction. The capital advanced through this module will be cross-applied and deducted automatically and irrevocably from the next regular settlement of funds processed by the Third-Party Partners in favor of the Partner. If the flow is insufficient, W PAYMENTS will execute the deduction in subsequent billing cycles. 

16.2.8 Validations and controls. W PAYMENTS retains the non-negotiable authority to suspend, defer, or reject "Pay Me Now" instructions if the Compliance systems trigger alerts of money laundering (ML/TF), spikes in transaction fraud, or operational inconsistencies.

EFFECTIVE DATE This Terms and Conditions Policy was approved on January 30, 2026 and takes effect as of that same date.