Legal Terms & Regulatory Disclaimers

ENNEVIA is a brand operated by ENNEVIA Finance Holding Ltd, a subsidiary of XCIX Enneagram Capital. ENNEVIA is a financial-technology aggregator and super-app that connects users to third-party regulated financial institutions. ENNEVIA itself is not licensed or authorised to conduct any regulated financial activity.

Nothing on this platform constitutes financial advice, an offer of securities to the public, a solicitation to invest, a deposit-taking activity, or a guarantee of any financial outcome. All references to financial products describe services that are, or will be, delivered by licensed partner institutions.

ENNEVIA acts solely as an aggregator, introducer and technology provider. It does not hold, control, receive or transmit customer funds in connection with regulated financial services, except for founding-membership payments and referral rewards as described herein.

ENNEVIA is not liable for the acts, omissions, solvency, regulatory compliance, misconduct, errors or defaults of any third-party regulated partner, nor for any loss arising from a partner's refusal to onboard a user, freeze an account, reverse a transaction, or decline a product. Each partner retains sole responsibility for its own regulatory duties, KYC/AML decisions, credit decisions, safeguarding and customer protections.

The promotional preferred dividend shares referenced on this platform are not offered pursuant to a prospectus approved under Regulation (EU) 2017/1129 (the Prospectus Regulation) or any equivalent regime. Any allocation of promotional preferred shares is intended to fall within available exemptions from the prospectus requirement and is subject to legal availability, board approval and the qualification criteria set out in these terms.

No communication on this platform constitutes a public offer or a solicitation of an investment. No securities are offered, sold or delivered until and unless a legally valid share grant is executed. The optional paid securities subscription module is disabled by default and may only be activated jurisdiction-by-jurisdiction following legal approval.

Purchasing a founding membership does not make you a shareholder. A member becomes a shareholder only after a legally valid preferred-share grant or a separately authorised securities subscription.

Promotional preferred shares are dividend-right shares only. They carry no general management rights, no board-control rights, no guaranteed redemption, no guaranteed return and no guaranteed dividend. Dividends may be paid only from legally distributable profits following valid board/shareholder approval and corporate-law compliance. The earliest potential dividend window is 18 months after the actual ENNEVIA launch date.

Share qualification requires, after launch: (i) active founding-member status; (ii) completed KYC; (iii) at least 10 qualifying transactions; (iv) €100/month contributions to an eligible licensed-partner savings product for 6 consecutive months; (v) country/securities eligibility; (vi) no fraud or referral abuse; and (vii) board approval. The status path is: Pending → Qualified → Board Review → Approved → Share Granted. All steps must be completed as shown in the platform roadmap and timeline; no share is issued before launch.

Crypto-asset services (on-ramp, off-ramp, wallets, custody, exchange, stablecoins) are provided exclusively through EU MiCA-authorised Crypto-Asset Service Providers (CASPs) or equivalent licensed Virtual Asset Service Providers (VASPs) in non-EU jurisdictions. ENNEVIA is not a CASP or VASP and does not custody, exchange or transmit crypto-assets on its own behalf.

Any crypto contribution to the ENNEVIA omnibus fundraising wallet is a voluntary contribution to the founding-membership programme and is not a regulated crypto-asset service, an investment, or a deposit. Crypto contributions are subject to the manual confirmation process described in Section 13.

Electronic money, e-wallets, stored value and card-issuing services referenced on the platform are provided by licensed Electronic Money Institutions (EMIs). ENNEVIA is not an EMI and does not issue e-money. Customer funds held in connection with such services are safeguarded by the relevant licensed EMI in accordance with applicable law, and are not held by, or owed by, ENNEVIA.

Payment-initiation, account-information, acquiring and money-transfer services are provided by licensed Payment Service Providers (PSPs) authorised under Directive (EU) 2015/2366 (PSD2) or equivalent national law. ENNEVIA is not a payment institution and does not execute payment transactions as a regulated activity.

Merchant acquiring, POS, settlement and merchant-services activity is conducted by licensed Money Service Providers / Merchant Service Providers (MSPs) and acquirers. ENNEVIA provides technology and introductions only and is not a party to merchant-acquiring agreements.

Product availability is governed by the ENNEVIA jurisdiction engine and varies by country. The platform is designed to operate across, and connect users to licensed partners in, the following jurisdictions (subject to local law and partner availability):

• European Union (EU) — all member states, under MiCA, PSD2, the EMI framework and the Prospectus Regulation.
• European Economic Area (EEA) — including EFTA states, on a passporting basis where applicable.
• Latin America — every South American country, including Argentina, Brazil, Chile, Colombia, Peru, Uruguay, Ecuador, Paraguay, Bolivia, Venezuela and Guyana.
• British Virgin Islands (BVI) — for corporate and holding structures.
• United Arab Emirates (UAE) — including ADGM and DIFC frameworks.
• Indonesia — subject to OJK and Bappebti requirements.
• Japan — subject to FSA and JVCEA/PSBA requirements.
• South Korea — subject to the Digital Asset Basic Act and FIU requirements.

Where a product is not available in your country, the platform automatically restricts it. ENNEVIA makes no representation that any product is available where it is not enabled by the jurisdiction engine.

All regulated financial services are delivered by third-party licensed partners — including banks, EMIs, PSPs, CASPs/VASPs, insurers, credit providers and acquirers. ENNEVIA is an introducer and technology layer only. Key regulatory relationships include FINTRAC (MSB registration, Canada) as principal regulator, the Reserve Bank of India (payment rails via BPAY), and the Malta Financial Services Authority (MFSA) and Bank of Latvia (Latvijas Banka) as whitelabel partner regulators under the EU EMI framework supervised by the European Banking Authority (EBA).

To the maximum extent permitted by law, ENNEVIA is not responsible for any misconduct, negligence, insolvency, regulatory breach, fraud or default of any partner, and is not liable for any consequential loss arising from a partner relationship. Users enter into relationships with partners on the partners' own terms, and each partner is solely responsible for its regulatory conduct and customer protections.

The founding-membership fee is a one-time payment for lifetime access benefits. It is not a deposit, savings, investment, share subscription, or a promise of any financial return. Membership revenue is held in the Membership Ledger and is never treated as a customer savings balance or deposit.

The fundraising conducted through founding memberships is strictly to allow founding members to take part in the ENNEVIA vision and to fund the build-out of the ecosystem ahead of the planned January 2027 launch. Membership does not guarantee approval for a bank account, card, lending, savings yield, insurance, crypto account, investment return, or receipt of securities. Regulated partners retain their own KYC, AML, credit and eligibility decisions.

The membership fee is non-refundable except where required by law. Four ledgers are maintained separately and never mixed: Membership, Referral Rewards, Customer Financial Account (held by licensed partners), and Securities.

Referral rewards are calculated only on net eligible lifetime-membership revenue. They are never calculated on deposits, savings, account balances, HYSA, securities purchases, share subscriptions, lending balances, insurance premiums (unless separately authorised), crypto purchases or investment assets.

Rewards are credited as Pending and become withdrawable only after: the referred member's payment has settled; fraud/risk checks pass; chargeback/refund conditions are satisfied; the referrer's KYC is complete; and wallet/address checks pass. A configurable settlement delay may apply. Self-referral, circular networks and referral abuse are prohibited and result in frozen or reversed rewards.

Referral percentages are set per founding round and may decline over time. Calculations shown on the platform are illustrative examples, not guaranteed earnings. No referral commissions are paid on securities subscriptions.

As an alternative to card payment, a founding member may contribute to the ENNEVIA fundraising programme by sending crypto-assets to the ENNEVIA Super Omnibus Wallet address displayed at checkout. The member selects an asset and network, sends the contribution, and records the transaction hash and amount on the platform.

Crypto contributions are manually confirmed. A membership created via crypto contribution remains in pending status until the ENNEVIA team verifies the on-chain transaction. ENNEVIA does not guarantee real-time confirmation and is not liable for funds sent to an incorrect network or address, or for underpayment. Once confirmed, the membership is activated and referral rewards (if any) are calculated and credited as pending.

The omnibus wallet is a collection account. ENNEVIA is not a custodian of customer balances — contributions are non-refundable membership payments, not deposits or investments, and do not confer any right to a return.

Referral rewards are held in the ENNEVIA Rewards Wallet. Withdrawals and distributions are processed manually by the ENNEVIA team. A member submits a withdrawal request specifying asset (EUR, USDC or EURC), amount and destination wallet/address.

Requests are reviewed against KYC, sanctions screening, fraud status and settlement conditions before approval and payout. ENNEVIA may reject, delay or reverse a withdrawal where fraud, sanctions, chargeback or compliance concerns exist. Payouts in crypto are made via regulated payout providers where legally permitted.

To the maximum extent permitted by law, ENNEVIA, its holding company, subsidiaries, officers, employees and affiliates shall not be liable for any indirect, incidental, special or consequential damages, or for any loss arising from: (a) the conduct or misconduct of any third-party regulated partner; (b) regulatory actions affecting partners or products; (c) the unavailability of a product in a jurisdiction; (d) the non-grant of a promotional preferred share; (e) crypto contributions sent to an incorrect address; (f) referral fraud or abuse; or (g) any decision by a partner to decline, freeze or close a user relationship.

ENNEVIA's aggregate liability in connection with the platform, to the extent permitted by law, is limited to the membership fee paid by the relevant member.

You acknowledge that: founding membership is not an investment and carries no expectation of return; promotional preferred shares may never be granted and carry no guaranteed dividend; crypto contributions may be lost if sent incorrectly and are subject to market and regulatory risk; partner financial products carry their own risks disclosed by the relevant partner; and regulatory frameworks (including MiCA, PSD2, EMI rules and prospectus requirements) may change and affect product availability.

ENNEVIA maintains a risk-based Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) policy aligned with the Financial Action Task Force (FATF) recommendations, EU AML Directives (AMLD), and applicable national laws in each operating jurisdiction.

Our AML framework includes: (i) Know Your Customer (KYC) and Know Your Business (KYB) verification for all members and contributors; (ii) sanctions and PEP screening against relevant watchlists; (iii) ongoing transaction monitoring; (iv) suspicious activity reporting to the relevant Financial Intelligence Unit where required; (v) enhanced due diligence for high-risk jurisdictions, products and relationships; and (vi) record-keeping in accordance with applicable retention requirements.

ENNEVIA will not issue KYC-gated cards or accounts until regulations permit. All regulated AML/KYC processes for financial products are executed by our licensed partner institutions (EMIs, banks, CASPs/VASPs), which retain sole responsibility for their own compliance obligations. ENNEVIA acts as a technology layer and introducer, applying its own membership-level screening in support of — but not as a substitute for — partner compliance.

Members and contributors consent to identity verification, screening and ongoing monitoring as a condition of participation. Suspicious, fraudulent or non-compliant activity may result in account suspension, reward reversal, withdrawal refusal and reporting to authorities.

Certain contributions to ENNEVIA may be structured under a SAFE (Simple Agreement for Future Equity) standard agreement, based on the Y Combinator SAFE template as adapted for the relevant jurisdiction. A SAFE is not equity, a debt instrument, or a deposit — it is a standard instrument granting the right to receive future equity in a qualifying funding round or liquidity event, subject to the terms of the SAFE.

By subscribing as a contributor and completing a contribution, each contributor accepts the applicable SAFE standard agreement as presented at checkout or in the contributor dashboard. The SAFE terms — including valuation cap, discount, pro-rata rights and qualifying events — are set out in the SAFE document itself and are binding upon acceptance.

A SAFE does not constitute a share, security, deposit or investment guarantee. It carries no guaranteed return, no guaranteed conversion, and no guarantee that a qualifying event will occur. Contributors should read the SAFE document carefully and seek independent legal and financial advice before subscribing. The SAFE is accepted electronically and a copy is made available to each contributor upon completion.

These terms may be updated from time to time. Material changes will be notified to members. These terms, together with the platform's privacy policy and any partner-specific terms, constitute the entire agreement regarding use of the ENNEVIA platform. Any dispute is subject to the governing law specified in the platform's terms of use and the jurisdiction of the user's relationship with the relevant licensed partner.