Gemini Galactic Markets User Agreement

June 3, 2026

Welcome to Gemini Stocks!

• Money Service Business (“MSB”) regulations under the Financial Crimes Enforcement Network (“FinCEN”);

• State money transmission and virtual currency laws;

• Laws, regulations, and rules of relevant tax authorities;

• Applicable regulations and guidance set forth by FinCEN;

• The Bank Secrecy Act of 1970 (“BSA”);

• The USA PATRIOT Act of 2001 (“Patriot Act”);

• AML/CTF provisions as mandated by U.S. federal law and any other rules and regulations regarding AML/CTF;

• Issuances from the Office of Foreign Assets Control (“OFAC”);

• Issuances from the National Futures Association (“NFA”);

• Issuances from the Financial Industry Regulatory Authority (“FINRA”); and

• The Commodity Exchange Act (“CEA”).

• You are unable to present acceptable government-issued photo identification;

• The identification documents you present are unfamiliar or cannot be verified;

• You open your Investing Account without appearing in person;

• The documents presented raise questions about your identity that cannot be resolved through documentary review alone; or

• Other circumstances at the discretion of Gemini Galactic's compliance personnel where standard documentary verification is insufficient.

• Decline to open your Investing Account;

• Impose restrictions on your account while verification attempts continue; or

• Close your account if verification cannot be completed within a reasonable period.

• Fictitious Accounts. Accounts may not be opened in a fictitious name or in any name other than the true legal name of the account owner. All accounts must be opened in the name of the actual beneficial owner of the account. Accounts styled in a name that does not correspond to the legal identity of the owner are unacceptable and will be rejected or closed.

• Accounts for Minors. Investing Accounts may not be opened in the name of a person under the age of 18. Gemini Galactic does not currently offer custodial accounts, UGMA accounts, or UTMA accounts. If Gemini Galactic determines that an account has been opened by or on behalf of a minor, the account will be closed and assets will be returned in accordance with applicable law.

• Single Owner Requirement. Each Investing Account must be opened for the benefit of a single individual account holder. You represent that you are the sole beneficial owner of your Investing Account and that the account is maintained solely for your own benefit and not for the benefit of any other person or entity, except as otherwise expressly permitted under this Agreement.

1. All information provided by you to us from time to time, including Account Information, is accurate, true and complete.

2. You are the only person with any interest in the Investing Account and the Investing Account is solely for your benefit and not the benefit of others.

3. You are of legal age under the laws of the state where you reside and are authorized to enter into this Agreement.

4. Neither you, nor any member of your immediate family, is an employee of (i) any exchange, (ii) any corporation of which any exchange owns a majority of the capital stock, (iii) a member of any exchange or self-regulatory organization, (iv) a member of any firm or member corporation registered on any exchange, (v) a bank, trust company, insurance company or any corporation, firm or individual engaged in the business of dealing either as a broker-dealer or as principal in securities.

5. Neither you, nor any member of your immediate family, is an associated person of a broker-dealer. If you are employed by or associated with another FINRA member firm or broker-dealer, you represent that you have obtained any approval required by your employer prior to opening this Investing Account, and you agree to provide us with a copy of any required authorization letter from your employer upon request. You further acknowledge that if you are employed by or associated with another broker-dealer, Gemini Galactic is required under FINRA Rule 3210 to notify that firm of the existence of your Investing Account and to provide duplicate account confirmations, statements, and other information as requested by your employing firm.

6. Neither you, nor any member of your immediate family, is an officer, director or 10% stockholder of any publicly traded company.

7. You are not a Securities Professional (as defined in the Gemini Market Data Agreement).

8. You are not a “politically exposed person” or otherwise on any restricted list under applicable Office of Foreign Assets Control rules and regulations.

1. provide any investment advice in connection with your Investing Account;

2. recommend any security, transaction, strategy, or orders;

3. solicit orders;

4. act as a market maker in any security; or

5. make discretionary trades on your behalf.

• Free credit balances in your Investing Account will be automatically swept into your Gemini Galactic Balance held for your benefit by the applicable Gemini Exchange Entity, as described in the Zero-Balance Account section above; and

• Gemini Galactic may change the products or arrangements available under the sweep program at any time, subject to the 30-day advance notice requirement described below.

• Represent or imply that your Investing Account is similar to or the same as a checking or savings account at a bank;

• Represent or imply that your Investing Account is a bank deposit account insured by the FDIC; or

• Represent that swept funds are guaranteed against loss of value.

• Your account must be maintained at a valid address at which you can receive account communications. Acceptable addresses include a residential or business street address. If no street address exists or is available, an APO or FPO box number, or the residential or business street address of a next of kin or other contact individual, is acceptable.

• If you provide a P.O. Box as your mailing address, you must also provide a valid street address on your account. A P.O. Box alone is not sufficient as your sole address on file, except in the limited circumstance where you reside in a rural area in which a P.O. Box is the only address available, which must be noted on your account application. If you provide only a P.O. Box and fail to provide a street address when required, Gemini Galactic may restrict your account until a valid street address is provided.

• Your account may not be addressed solely to Gemini Galactic, to any Gemini Galactic employee or registered representative, or care of (c/o) any other person, unless you provide written authorization requesting such an address. Accounts addressed to a Gemini Galactic employee are permitted only where the account is maintained for the direct beneficial ownership of that employee.

• Accounts with no balance. If your Investing Account has no securities positions and no cash balance, it may be considered dormant after 12 consecutive months of inactivity. Gemini Galactic, in its sole discretion, may send written notice to your email address of record and, if different, your mailing address of record, informing you that your Investing Account has been identified as dormant and will be closed if you do not take action within 30 days of the date of the notice. You may prevent closure by logging into your account or initiating any account activity within that 30-day period.

• Accounts with a balance. If your Investing Account holds any securities positions or cash balance, it may be considered dormant after 24 consecutive months of inactivity. Gemini Galactic, in its sole discretion, may send written notice to your email address of record and, if different, your mailing address of record, informing you that your Investing Account has been identified as dormant and will be closed if you do not take action within 60 days of the date of the notice. You may prevent closure by logging into your account, placing an order, making a deposit or withdrawal, or otherwise initiating any account activity within that 60-day period.

• Upon receiving notice of your death, Gemini Galactic will treat all assets in your Investing Account as frozen. No orders will be accepted, and no funds or securities will be disbursed from your account, until Gemini Galactic has received all required documentation and legal distribution of your account assets has been determined in accordance with applicable law.

• All open orders pending in your Investing Account at the time Gemini Galactic receives notice of your death will be canceled immediately.

• Distribution of your account assets to your estate or beneficiaries will require submission of certain documentation, which may include a certified copy of your death certificate, letters testamentary or letters of administration issued by a court of competent jurisdiction, tax waivers or other documentation required under applicable state law, and any other documentation Gemini Galactic or the Carrying Broker reasonably requires to verify the authority of the person or entity seeking to act on behalf of your estate. Gemini Galactic will not release assets from your account until all required documentation has been received and reviewed to its satisfaction.

• Gemini Galactic and the Carrying Broker shall not be liable for any losses, including losses resulting from market fluctuations, occurring during the period in which your account is frozen pending receipt of required documentation and determination of proper distribution.

• If you wish to designate a person who should be contacted in the event of your death in connection with your account, you may provide that information through your Trusted Contact Person designation. Please note that a Trusted Contact Person does not have authority over your account and cannot direct the distribution of your account assets. Proper legal documentation as described above will be required regardless of any Trusted Contact Person designation.

• If your Investing Account is held jointly with another person, the rights of the surviving account holder(s) will be determined in accordance with the account type designation and applicable state law. Gemini Galactic may require documentation establishing the surviving account holder's rights before permitting further transactions in the account.

• We will verify transfer requests to confirm the accuracy and authenticity of instructions before processing.

• We may contact you directly to confirm that a transfer request was initiated by you, particularly if the request is received shortly after your account was opened, if it follows unusual changes to your account communication preferences, or if other indicators of potential fraud are present.

• We monitor for patterns of accounts moving to the same receiving firm in ways that may indicate coordinated fraudulent activity.

• Repeated rejections of transfer instructions you did not initiate.

• A transfer request appearing on your account shortly after the account was opened.

• Changes to your account contact information, including email address or phone number, that you did not make.

• Communications you did not expect regarding a transfer, particularly emails containing significant spelling or grammatical errors or reflecting a different writing style than prior communications.

• You will use Market Data solely in accordance with the Gemini Market Data Agreement;

• You will not redistribute, retransmit, publish, or commercially exploit Market Data unless separately authorized in writing by Gemini; and

• You will promptly notify Gemini Galactic if your status changes such that you no longer qualify as a Non-Professional Subscriber under applicable market data rules.

• Your current retirement status, or if not yet retired, when you plan to retire;

• Your anticipated income needs during retirement and the sources of that income;

• Whether you have prospects for future employment that may supplement your retirement income;

• Whether you currently support any dependents;

• Anticipated healthcare or other significant future expenses; and

• Whether you have a will, trust, or financial power of attorney in place.

• Attribution to Gemini, and

• A hyperlink to Gemini.com, when possible.

• An account is opened for, or Gemini Galactic subsequently determines that an account is held by, a person or entity on an OFAC list or other applicable Governmental Watchlist;

• The owner of an existing account is added to an OFAC list or other applicable Governmental Watchlist after the account is opened;

• A security held in your Investing Account is identified as being subject to blocking requirements because the issuer is the subject of OFAC sanctions; or

• You request a transfer of funds or securities to a person or entity that is a Sanctioned Person or is located in a Prohibited Jurisdiction.

• All open orders in your account will be canceled immediately;

• Your account will be restricted and no new transactions will be permitted;

• Funds and securities subject to blocking requirements will be frozen and may not be withdrawn, transferred, or otherwise disposed of until the blocking requirement is lifted or Gemini Galactic receives guidance from OFAC or a court of competent jurisdiction permitting release; and

• Gemini Galactic will notify you to the extent permitted by applicable law. Please note that in certain circumstances, applicable law may prohibit Gemini Galactic from disclosing the reason for blocking.

General Provisions

Disclaimer of Warranties

Disclaimer of Liability

Reasonable Care

Force Majeure

Indemnities

Legal Costs

Entire Agreement

Separately Negotiated Arrangements

Assignment

Relationship of the Parties

Injunctive Relief

Severability

Change of Control

Survival

Miscellaneous

English Language Controls

Written Notice

Business Day

Non-Waiver of Rights

Governing Law

Dispute Resolution

• All parties to this agreement are giving up the right to sue each other in court, including the right to a trial by jury, except as provided by the rules of the arbitration forum in which a claim is filed.

• Arbitration awards are generally final and binding; a party's ability to have a court reverse or modify an arbitration award is very limited.

• The ability of the parties to obtain documents, witness statements, and other discovery is generally more limited in arbitration than in court proceedings.

• The arbitrators do not have to explain the reason(s) for their award unless, in an eligible case, a joint request for an explained decision has been submitted by all parties to the panel at least 20 days prior to the first scheduled hearing date.

• The panel of arbitrators may include a minority of arbitrators who were or are affiliated with the securities industry.

• The rules of some arbitration forums may impose time limits for bringing a claim in arbitration. In some cases, a claim that is ineligible for arbitration may be brought in court.

• The rules of the arbitration forum in which the claim is filed, and any amendments thereto, shall be incorporated into this agreement.

• TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAWS AND REGULATIONS, HEREBY IRREVOCABLY WAIVE ALL RIGHT TO TRIAL BY JURY AS TO ANY ISSUE RELATING HERETO IN ANY ACTION, PROCEEDING, OR COUNTERCLAIM ARISING OUT OF OR RELATING TO THIS USER AGREEMENT OR THE SERVICES THAT GEMINI PROVIDES OR ANY OTHER MATTER INVOLVING US HERETO, AND

• SUBMIT TO THE EXCLUSIVE JURISDICTION AND VENUE OF THE FEDERAL OR STATE COURTS LOCATED IN NEW YORK COUNTY, NEW YORK AND YOU AGREE NOT TO INSTITUTE ANY SUCH ACTION OR PROCEEDING IN ANY OTHER COURT IN ANY OTHER JURISDICTION.