ORO TECHNOLOGIES LLC

GLOBAL PAYMENTS, BILLING, SETTLEMENTS, REFUNDS AND FINANCIAL COMPLIANCE FRAMEWORK

Global Marketplace Financial Operations, Payment Processing, Refunds and Billing Policy

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Last Updated: May 2026
Effective Immediately

This Global Payments, Billing, Settlements, Refunds and Financial Compliance Framework (the “Policy,” the “Financial Framework,” or the “Payments and Refunds Policy”) constitutes a legally binding, globally applicable, continuously enforceable, and internationally integrated financial operations framework governing all payment-related, billing-related, settlement-related, refund-related, transactional, operational, accessibility-related, and financial compliance activities conducted through the digital ecosystem operated by ORO TECHNOLOGIES LLC, together with its subsidiaries, affiliated entities, independent operators, contractors, technological partners, payment integrations, licensors, service providers, authorized representatives, and internationally connected operational structures (collectively, “ORO,” the “Company,” or the “ORO Corporate Group”).

This Policy forms an integral component of the unified global legal architecture governing the ORO Platform and shall be interpreted together with:

• the Terms and Conditions;

• the Global Privacy and Data Governance Policy;

• the Accessibility & Voice Technology Policy;

• the Global Safety, S.O.S. and Emergency Framework;

• the Community Guidelines and Global Code of Conduct;

• the Driver and Provider Terms;

• and all related disclosures, notices, operational policies, appendices, and legal frameworks published by ORO.

By accessing, downloading, registering for, interacting with, or using the Platform through any website, mobile application, voice interface, accessibility system, API integration, payment integration, communication infrastructure, or technological channel, all Users, Drivers, Providers, Couriers, Merchants, Corporate Clients, Contractors, Third-Party Operators, and other participants expressly acknowledge, understand, and irrevocably agree to be legally bound by this Policy.

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1. GLOBAL MARKETPLACE FINANCIAL STRUCTURE

ORO operates exclusively as a digital technology platform and marketplace intermediary facilitating communication, coordination, accessibility-oriented interactions, payment facilitation, and technological integration between independent third-party participants.

ORO is NOT:

• a bank;

• a deposit-taking institution;

• a money transmitter;

• a money services business (MSB), except where mandatory law expressly requires limited registration or compliance;

• a fiduciary institution;

• an escrow company;

• an investment platform;

• a lending institution;

• a remittance operator;

• a stored-value issuer;

• a financial advisor;

• a brokerage institution;

• an insurance company;

• or a financial custodian.

All payment processing, transaction execution, settlements, authorizations, reversals, anti-fraud monitoring, currency conversion, and financial operations are executed through independent third-party financial institutions, payment processors, merchant acquirers, banks, payment gateways, card networks, licensed processors, and financial infrastructure providers operating under their own regulatory obligations and legal responsibility.

To the maximum extent permitted by applicable law:

• ORO does not independently hold customer funds in custody;

• ORO does not create bank accounts for users;

• ORO does not guarantee uninterrupted financial availability;

• ORO does not operate financial clearing systems;

• ORO does not assume fiduciary obligations toward users or providers;

• and ORO does not guarantee transaction approval or settlement continuity.

Nothing within the Platform shall be interpreted as creating:

• a banking relationship;

• a fiduciary relationship;

• an escrow relationship;

• an investment relationship;

• a custodial relationship;

• or a guaranteed financial obligation.

​Nothing in this Policy shall be interpreted as an admission, representation, or acknowledgment that ORO Technologies LLC is a money transmitter, money services business (MSB), payment institution, electronic money institution, financial intermediary, regulated financial entity, or similar licensed financial service provider under any jurisdiction unless such status is expressly required by applicable law.​

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2. MULTI-JURISDICTIONAL FINANCIAL COMPLIANCE

ORO operates under a decentralized global marketplace structure involving multiple jurisdictions, currencies, payment infrastructures, financial regulations, tax obligations, consumer-protection standards, and operational frameworks.

Accordingly, transactions conducted through the Platform may be subject to:

• local laws;

• state laws;

• federal laws;

• international sanctions programs;

• anti-money laundering regulations;

• payment-network rules;

• banking compliance obligations;

• accessibility regulations;

• digital-platform regulations;

• tax-reporting requirements;

• consumer-protection laws;

• cybersecurity regulations;

• cross-border financial restrictions;

• and marketplace compliance standards.

Users expressly acknowledge that:

• payment availability may vary by jurisdiction;

• certain financial features may be restricted geographically;

• settlement timing may differ internationally;

• payment methods may not be universally available;

• regulatory restrictions may affect transactions;

• and local law may impose additional operational requirements.

ORO reserves the unrestricted right, to the maximum extent permitted by law, to:

• restrict financial functionality;

• impose transaction limitations;

• require additional verification;

• regionalize payment systems;

• suspend transactions;

• delay settlements;

• refuse payment methods;

• or implement enhanced compliance measures,

where reasonably necessary to preserve:

• legal compliance;

• financial integrity;

• operational stability;

• cybersecurity protection;

• anti-fraud enforcement;

• sanctions compliance;

• or platform security.

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3. THIRD-PARTY PAYMENT PROCESSORS AND FINANCIAL INFRASTRUCTURE

All financial transactions conducted through the Platform may be processed, facilitated, routed, authorized, monitored, settled, reversed, delayed, restricted, reviewed, rejected, or verified by independent third-party financial service providers.

Such providers may include:

• banks;

• merchant acquirers;

• card networks;

• payment gateways;

• payment facilitators;

• digital-wallet providers;

• settlement processors;

• anti-fraud providers;

• compliance providers;

• cross-border payment infrastructures;

• identity-verification systems;

• tax-compliance systems;

• and cloud-based financial infrastructures.

These entities operate independently from ORO and remain solely responsible for:

• their operational systems;

• financial infrastructure;

• cybersecurity measures;

• compliance procedures;

• transaction approvals;

• settlement timing;

• fraud monitoring;

• regulatory obligations;

• service availability;

• and payment-processing functionality.

By using the Platform, Users expressly authorize ORO and its designated financial infrastructure providers to:

• initiate payment instructions;

• process charges;

• facilitate collections;

• apply authorization holds;

• conduct delayed billing;

• process recurring payments where applicable;

• execute reversals;

• process refunds;

• conduct fraud screening;

• verify transactions;

• analyze transactional risk;

• and apply operational or compliance restrictions.

Users further acknowledge that third-party financial providers may independently:

• reject transactions;

• require identity verification;

• delay settlements;

• impose fees;

• limit transaction volume;

• freeze activity;

• or suspend financial operations,

without prior notice and outside the direct operational control of ORO.

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3A. PAYMENT PROCESSOR INDEPENDENCE

ORO Technologies LLC does not control and shall not be responsible for the independent decisions, actions, restrictions, reviews, investigations, reserve requirements, account limitations, payment holds, settlement delays, fund freezes, compliance determinations, risk assessments, chargeback determinations, or account terminations imposed by any third-party payment processor, financial institution, acquiring bank, card network, payment facilitator, or financial infrastructure provider.

Users acknowledge that payment processors operate under independent regulatory obligations and maintain sole authority over their internal risk-management and compliance decisions.

Any dispute regarding processor actions must be directed to the applicable financial provider unless otherwise required by law.

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3B. PAYMENT METHOD AVAILABILITY

ORO does not guarantee the continued availability of any specific payment method, card network, digital wallet, banking channel, processor, payment facilitator, currency, or settlement mechanism.

Payment methods may be added, modified, restricted, suspended, regionalized, or discontinued at any time.

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3C. NO GUARANTEE OF FINANCIAL SERVICE AVAILABILITY

Users acknowledge that payment services, financial functionality, transaction processing, billing systems, settlement mechanisms, payout systems, banking integrations, digital wallets, card processing systems, and related financial infrastructure may become temporarily or permanently unavailable due to factors beyond ORO’s control.

Such factors may include:

financial institution actions;

processor outages;

network failures;

regulatory restrictions;

governmental actions;

banking interruptions;

cybersecurity incidents;

telecommunications disruptions;

force majeure events;

third-party service failures;

or infrastructure maintenance.

ORO does not guarantee uninterrupted availability of any financial functionality and shall not be liable for losses arising from temporary or permanent financial service interruptions beyond its reasonable control.

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3D. PAYMENT PROCESSOR LIABILITY DISCLAIMER

Users expressly acknowledge that ORO Technologies LLC does not own, operate, control, supervise, manage, audit, or guarantee the services provided by any third-party payment processor, financial institution, acquiring bank, payment facilitator, card network, digital wallet provider, banking partner, settlement provider, or financial infrastructure operator.

All payment processing services are performed independently by such third parties under their own legal, regulatory, operational, cybersecurity, and financial responsibilities.

Accordingly, ORO shall not be liable for any losses, damages, delays, transaction failures, payment interruptions, settlement errors, processor outages, banking restrictions, compliance actions, account limitations, fund holds, reserve requirements, transaction reviews, rejected payments, processor investigations, financial institution decisions, regulatory interventions, chargeback determinations, fraud-prevention actions, currency conversion discrepancies, or other financial events arising from the conduct or operation of independent third-party financial service providers.

Users agree that any dispute relating exclusively to payment processor operations may be subject to the terms, policies, procedures, and dispute-resolution mechanisms established by the applicable financial provider.

Nothing in this Policy shall be interpreted as creating joint liability, agency, partnership, fiduciary responsibility, financial guarantee, or operational control between ORO and any third-party financial service provider.

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4. LIMITED PAYMENT COLLECTION AUTHORITY

To the maximum extent permitted by applicable law, ORO acts solely as a limited payment collection agent for independent third-party Providers in connection with transactions facilitated through the Platform.

Except where mandatory law expressly requires otherwise:

• payments are not held in escrow;

• funds are not maintained as fiduciary deposits;

• funds are not held in trust;

• Users do not establish financial accounts with ORO;

• and ORO does not act as a custodian of funds.

Payment obligations shall generally be deemed satisfied once payment instructions have been successfully transmitted to the designated third-party processor or financial infrastructure provider.

Acceptance of payment by ORO or its designated payment processor shall, to the maximum extent permitted by applicable law, be deemed equivalent to payment made directly to the applicable independent Provider.

ORO does not guarantee:

• uninterrupted payment availability;

• banking continuity;

• processor uptime;

• settlement timing;

• withdrawal availability;

• cross-border processing continuity;

• or financial institution performance.

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4A. PAYOUT LIMITATION DISCLAIMER

ORO does not guarantee successful payout delivery, withdrawal availability, bank acceptance, account eligibility, or uninterrupted transfer functionality.

Payout failures may result from banking restrictions, account errors, processor limitations, compliance reviews, sanctions screening, telecommunications failures, cybersecurity events, governmental actions, or third-party infrastructure interruptions.

ORO shall not be liable for delays or failures caused by third-party financial institutions.

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5. FEES, BILLING STRUCTURE, COMMISSIONS AND PLATFORM CHARGES

ORO reserves the unrestricted right, to the maximum extent permitted by applicable law, to establish, modify, adjust, increase, reduce, suspend, regionalize, or introduce fees, pricing structures, commissions, operational charges, or marketplace-related financial mechanisms associated with Platform operations.

Applicable fees may include, without limitation:

• service fees;

• marketplace fees;

• booking fees;

• cancellation charges;

• waiting-time charges;

• accessibility-related operational costs;

• voice-system operational charges;

• safety-related fees;

• fraud-prevention costs;

• cross-border processing costs;

• subscription fees;

• premium-feature charges;

• payment-processing fees;

• currency-conversion charges;

• tax-recovery charges;

• regulatory-compliance costs;

• platform access charges;

• and dynamic pricing adjustments.

Pricing and charges may vary depending on:

• geographic location;

• local regulations;

• provider availability;

• operational demand;

• accessibility requirements;

• technological infrastructure;

• market conditions;

• traffic conditions;

• weather conditions;

• cybersecurity risks;

• payment infrastructure costs;

• or algorithmic pricing systems.

ORO does not guarantee:

• fixed pricing;

• uninterrupted availability of discounts;

• continuous promotions;

• static fee structures;

• or uninterrupted marketplace conditions.

Estimated pricing displayed through the Platform may not constitute final pricing.

Final charges may vary due to:

• route changes;

• waiting time;

• tolls;

• taxes;

• accessibility accommodations;

• operational adjustments;

• voice-confirmation errors;

• dynamic marketplace conditions;

• or third-party operational variables.​​

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5A. RECEIPTS AND TRANSACTION RECORDS

Electronic receipts, transaction summaries, invoices, account statements, trip summaries, and payment confirmations generated through the Platform are provided for informational and operational purposes only.

Such records may contain delays, omissions, technical discrepancies, processor-generated adjustments, or third-party data dependencies.

Users remain responsible for independently verifying information where required for accounting, tax, legal, or regulatory purposes.

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6. VOICE-BASED TRANSACTIONS, ACCESSIBILITY PAYMENTS AND AI-ASSISTED INTERACTIONS

Because the Platform operates under a voice-first and accessibility-centered technological structure intended to facilitate inclusive use for elderly individuals, persons with disabilities, accessibility-dependent users, and voice-assisted participants, certain payment-related interactions may occur through:

• voice commands;

• conversational interfaces;

• AI-assisted systems;

• accessibility tools;

• simplified interaction systems;

• automated confirmations;

• or speech-recognition technologies.

Users expressly acknowledge and agree that voice technologies and AI-assisted systems are inherently probabilistic and subject to:

• speech-recognition inaccuracies;

• accidental activations;

• environmental interference;

• language variability;

• accent interpretation limitations;

• device-level restrictions;

• operating-system limitations;

• connectivity interruptions;

• delayed processing;

• AI-generated inaccuracies;

• accessibility-system limitations;

• or technological malfunctions.

ORO does not guarantee:

• uninterrupted voice-recognition accuracy;

• perfect speech interpretation;

• flawless transaction execution;

• uninterrupted AI functionality;

• continuous accessibility-system availability;

• or successful transaction confirmation under all conditions.

Users remain solely responsible for:

• reviewing available confirmations;

• maintaining device security;

• safeguarding authentication credentials;

• monitoring payment activity;

• and verifying transaction details where technically feasible.

To the maximum extent technically feasible, voice interactions activate only through:

• user interaction;

• device permissions;

• operating-system authorization;

• accessibility settings;

• or intentional voice activation.

ORO does not intentionally engage in covert passive listening or unauthorized background financial surveillance.

Users further acknowledge that voice-based interactions, accessibility systems, AI-assisted interfaces, speech-recognition technologies, simplified user experiences, and disability-support functionalities may be subject to technological limitations, inaccuracies, delays, interruptions, environmental interference, or unintended inputs.

To the maximum extent permitted by applicable law, isolated voice-recognition inaccuracies, accessibility-system limitations, speech-interpretation errors, or AI-assisted operational discrepancies shall not automatically entitle a User to refunds, compensation, damages, charge reversals, service credits, or financial recovery unless expressly required by applicable law or determined by ORO after review of the specific circumstances.

Nothing in this section shall prevent ORO from issuing discretionary refunds, credits, billing adjustments, account corrections, promotional credits, or goodwill accommodations where ORO determines, in its sole discretion, that such action is appropriate under the circumstances.

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7. PAYMENT AUTHORIZATION AND USER CONSENT

By initiating, authorizing, confirming, or facilitating transactions through the Platform, Users expressly authorize ORO and its designated financial partners to:

• charge designated payment methods;

• conduct temporary pre-authorizations;

• process delayed charges;

• execute post-service adjustments;

• collect outstanding balances;

• offset unpaid obligations;

• apply taxes and governmental charges;

• conduct fraud reviews;

• verify payment methods;

• and process refunds or reversals where applicable.

Users remain solely responsible for ensuring that:

• payment methods remain active and valid;

• sufficient funds are available;

• billing information is accurate;

• financial authorization is lawful;

• and use of the payment method is properly authorized.

Unauthorized use of payment instruments is strictly prohibited and may result in:

• immediate transaction restriction;

• suspension of Platform access;

• reporting to financial institutions;

• fraud investigation;

• cooperation with authorities;

• legal action;

• or permanent account termination.

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8. FRAUD PREVENTION, AML, KYC AND FINANCIAL SECURITY CONTROLS

To preserve marketplace integrity, cybersecurity resilience, financial compliance, accessibility security, and anti-fraud protection, ORO reserves the unrestricted right to implement:

• Anti-Money Laundering (AML) controls;

• Know Your Customer (KYC) procedures;

• sanctions screening systems;

• fraud-detection algorithms;

• suspicious-activity monitoring;

• behavioral analytics;

• device verification;

• transaction-risk scoring;

• identity-verification technologies;

• cybersecurity systems;

• accessibility-integrity protections;

• and automated financial monitoring systems.

ORO may delay, reject, reverse, suspend, restrict, freeze, investigate, or report transactions where reasonably necessary to comply with:

• applicable law;

• sanctions regulations;

• anti-fraud obligations;

• court orders;

• governmental requests;

• payment-network rules;

• cybersecurity obligations;

• or regulatory directives.

Users expressly acknowledge that ORO may cooperate with:

• financial institutions;

• payment processors;

• regulators;

• law-enforcement agencies;

• anti-fraud entities;

• cybersecurity providers;

• sanctions-screening systems;

• and governmental authorities,

in connection with:

• fraud investigations;

• suspicious-activity reporting;

• sanctions compliance;

• financial-crime prevention;

• accessibility abuse prevention;

• or operational security.

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8A. NO GUARANTEE OF FRAUD PREVENTION

While ORO may implement fraud-prevention, risk-management, identity-verification, behavioral-analysis, cybersecurity, and compliance systems, no system is capable of detecting or preventing all fraudulent, deceptive, malicious, unauthorized, criminal, or abusive activity.

ORO does not guarantee the prevention, detection, identification, or elimination of fraud.

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8B. NO GUARANTEE OF PAYMENT SECURITY

While ORO may implement commercially reasonable cybersecurity measures, payment-security controls, fraud-prevention systems, encryption technologies, authentication mechanisms, monitoring tools, and financial safeguards, no payment system, financial infrastructure, banking network, telecommunications provider, cloud environment, cybersecurity program, or technological system can be guaranteed to be completely secure.

ORO does not warrant or guarantee that financial transactions, payment credentials, account information, settlement processes, processor communications, banking operations, or financial infrastructure will be immune from cyberattacks, unauthorized access, fraud, phishing, account compromise, processor failures, telecommunications interruptions, data breaches, system vulnerabilities, or other security-related events.

Users acknowledge and accept the inherent risks associated with electronic commerce, digital payments, online financial systems, and third-party financial infrastructure.

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8C. ACCOUNT COMPROMISE AND USER SECURITY RESPONSIBILITY

Users remain solely responsible for maintaining the confidentiality and security of:

account credentials;

authentication methods;

voice authentication mechanisms;

devices;

passwords;

access codes;

linked payment methods;

and financial account information.

ORO shall not be liable for unauthorized transactions resulting from:

credential sharing;

device loss;

account compromise;

social engineering;

phishing attacks;

malware infections;

unauthorized device access;

or user negligence.

Users agree to notify ORO promptly upon becoming aware of any suspected unauthorized account activity.

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9. SANCTIONS, PROHIBITED TRANSACTIONS AND RESTRICTED ACTIVITIES

The Platform may not be used in violation of:

• United States sanctions laws;

• OFAC regulations;

• anti-terrorism financing laws;

• export-control laws;

• anti-corruption regulations;

• anti-money laundering frameworks;

• prohibited-jurisdiction restrictions;

• or international financial-crime regulations.

Users may not use the Platform to:

• conceal illegal activity;

• evade sanctions;

• launder funds;

• process unauthorized commercial activity;

• conduct fraudulent transactions;

• manipulate financial systems;

• exploit accessibility-related systems for fraud;

• or facilitate unlawful activity.

ORO reserves the unrestricted right to:

• block transactions;

• freeze operational activity;

• restrict accounts;

• suspend financial access;

• reject settlements;

• preserve evidence;

• cooperate with authorities;

• or terminate services,

where transactions, jurisdictions, users, or activities present:

• legal risk;

• regulatory risk;

• operational risk;

• reputational risk;

• cybersecurity risk;

• or financial-compliance concerns.

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10. REFUNDS, CANCELLATIONS, BILLING ADJUSTMENTS AND REVERSALS

Refunds, credits, promotional adjustments, billing corrections, cancellations, charge reversals, offsets, partial refunds, account balancing measures, or settlement adjustments may be granted solely:

• in accordance with applicable law;

• subject to operational review;

• pursuant to fraud-prevention procedures;

• and under Platform policies and payment-processor limitations.

Except where mandatory law expressly requires otherwise:

• completed transactions are generally final and non-refundable;

• promotional incentives have no cash value unless expressly stated;

• estimated pricing does not guarantee final pricing;

• and refund eligibility may be limited.

ORO reserves the unrestricted right to:

• deny refund requests;

• partially approve refunds;

• reverse duplicate payments;

• recover overpayments;

• offset negative balances;

• withhold disputed amounts;

• delay settlements pending investigation;

• apply reserve balances;

• reverse transactions suspected of fraud;

• and correct billing errors.

Users and Providers agree to cooperate fully in any:

• billing investigation;

• fraud review;

• chargeback investigation;

• refund review;

• accessibility-related dispute;

• or financial compliance process.

Chargebacks, payment disputes, or fraudulent refund activity may result in:

• account suspension;

• recovery proceedings;

• debt collection measures;

• legal reporting;

• restricted Platform access;

• or permanent termination.

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10A. CHARGEBACKS, RESERVE ACCOUNTS, SET-OFF RIGHTS AND RECOVERY PROCEDURES

To preserve marketplace integrity, payment-system stability, fraud prevention, regulatory compliance, and financial risk management, ORO reserves the right, to the maximum extent permitted by applicable law, to establish temporary reserves, payment holds, rolling reserves, settlement delays, security balances, or other financial protection mechanisms where reasonably necessary.

Without limitation, ORO may establish such measures when transactions involve:

chargebacks;

payment disputes;

fraud investigations;

high-risk activity;

excessive refund requests;

identity-verification concerns;

regulatory compliance reviews;

unusual transaction patterns;

accessibility-system abuse;

voice-system manipulation;

or elevated operational risk.

ORO further reserves the right to offset, deduct, recover, withhold, recoup, or set off any amount reasonably believed to be owed to ORO, payment processors, financial institutions, users, providers, merchants, governmental authorities, or other affected parties from any future settlements, credits, promotional balances, incentive programs, earnings, reimbursements, or amounts otherwise payable through the Platform.

Users and Providers expressly authorize ORO to recover losses, fees, fines, penalties, chargeback costs, dispute expenses, collection costs, fraud-related losses, operational damages, or compliance-related liabilities arising from their conduct, transactions, account activity, or violations of Platform policies.

Nothing in this section shall obligate ORO to maintain reserve balances, provide financial guarantees, insure transactions, or assume financial responsibility for third-party payment failures.

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10B. DISPUTED TRANSACTIONS AND INVESTIGATION RIGHTS

ORO reserves the right to investigate any disputed transaction, refund request, chargeback, billing discrepancy, payment complaint, accessibility-related transaction claim, voice-confirmation dispute, or suspected financial irregularity.

Users and Providers agree to cooperate fully with any investigation and to provide supporting documentation where reasonably requested.

Failure to cooperate may result in:

denial of refund requests;

account restrictions;

transaction reversals;

temporary suspension;

or permanent account termination.

ORO may rely upon system logs, transaction records, payment processor data, voice interaction records, accessibility-system records, account activity, and other relevant evidence when evaluating disputes.

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11. CASH PAYMENTS AND OFF-PLATFORM TRANSACTIONS

Where expressly enabled by ORO and permitted by applicable law, certain transactions may be completed using cash payment methods or other approved payment mechanisms.

However, ORO:

• does not supervise cash handling;

• does not verify off-platform payments;

• does not insure cash exchanges;

• does not guarantee transaction completion;

• does not control off-platform agreements;

• and does not assume liability for off-platform disputes.

Any off-platform transaction is undertaken exclusively:

• at the sole risk of the involved parties;

• outside the operational control of ORO;

• and without any financial guarantee from ORO.

ORO may restrict or prohibit off-platform solicitation where reasonably necessary to preserve:

• platform integrity;

• anti-fraud enforcement;

• user safety;

• regulatory compliance;

• or marketplace operations.

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12. TAXES, REPORTING OBLIGATIONS AND FINANCIAL RESPONSIBILITY

Users and independent Providers remain solely responsible for:

• determining applicable taxes;

• reporting income;

• maintaining financial records;

• satisfying tax obligations;

• obtaining professional tax advice;

• complying with local regulations;

• and fulfilling governmental reporting obligations.

ORO does not provide:

• accounting services;

• investment advice;

• tax advisory services;

• legal tax opinions;

• financial planning;

• or fiduciary financial guidance.

Where legally required, ORO reserves the unrestricted right to:

• collect tax documentation;

• request taxpayer information;

• apply withholding obligations;

• issue tax forms;

• report transactions to authorities;

• comply with governmental requests;

• and preserve financial records.

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12A. PROVIDER EARNINGS, REVENUE EXPECTATIONS AND MARKETPLACE PARTICIPATION DISCLAIMER

ORO operates solely as a technology marketplace platform and does not guarantee any level of economic activity, service requests, user demand, bookings, transaction volume, profitability, revenue generation, commercial success, customer acquisition, earnings potential, business growth, or financial outcomes for any Provider, Driver, Courier, Merchant, Business Partner, Independent Contractor, or other participant.

Participation in the Platform does not create any entitlement to:

minimum earnings;

guaranteed income;

minimum bookings;

fixed compensation;

employment benefits;

commercial opportunities;

or continued marketplace access.

Marketplace activity depends on numerous factors outside the control of ORO, including:

user demand;

market conditions;

competition;

pricing decisions;

provider availability;

regulatory restrictions;

economic conditions;

accessibility requirements;

voice-technology usage patterns;

consumer behavior;

and third-party operational factors.

All Providers participate in the Platform at their own independent commercial risk and remain solely responsible for evaluating the economic suitability of their participation.

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12B. NO TAX WITHHOLDING OBLIGATION

Except where expressly required by applicable law, ORO assumes no responsibility to calculate, collect, remit, withhold, report, or pay taxes on behalf of independent Providers, Drivers, Merchants, Couriers, or Users.

Each participant remains solely responsible for determining and satisfying all tax obligations arising from their activities conducted through the Platform.

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13. CROSS-BORDER TRANSACTIONS, CURRENCY CONVERSION AND FINANCIAL INTERRUPTIONS

Due to the international nature of the Platform, transactions may involve:

• multiple currencies;

• international banking systems;

• cross-border settlement networks;

• intermediary banks;

• fluctuating exchange rates;

• regional processing restrictions;

• international transfer limitations;

• and governmental financial controls.

Users expressly acknowledge that:

• exchange rates may fluctuate;

• intermediary fees may apply;

• settlements may be delayed;

• taxes may vary internationally;

• banking restrictions may affect transfers;

• and governmental measures may disrupt financial operations.

ORO does not guarantee:

• exchange-rate stability;

• uninterrupted banking availability;

• continuous cross-border processing;

• processor uptime;

• or settlement timing.

Financial operations may be interrupted due to:

• force majeure events;

• cybersecurity incidents;

• banking outages;

• sanctions restrictions;

• telecommunications failures;

• public emergencies;

• governmental actions;

• cloud-infrastructure failures;

• or third-party infrastructure disruptions.

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13A. DIGITAL ASSETS AND CRYPTOCURRENCY DISCLAIMER

Unless expressly enabled by ORO, the Platform does not support cryptocurrencies, digital assets, blockchain-based payment instruments, tokens, stablecoins, or decentralized financial products.

Any unauthorized attempt to use such instruments in connection with the Platform is undertaken solely at the user's risk.

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13B. FOREIGN EXCHANGE RISK DISCLAIMER

Where transactions involve multiple currencies, exchange-rate fluctuations may occur before authorization, settlement, payout, refund processing, reversal processing, or final transaction completion.

Users acknowledge that exchange-rate differences may result in variations between estimated amounts and final processed amounts.

ORO does not control currency-conversion rates applied by banks, card networks, payment processors, financial institutions, or settlement providers and shall not be liable for foreign-exchange losses, conversion discrepancies, intermediary fees, or currency-related adjustments.

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14. ACCESSIBILITY, ELDERLY USERS AND VULNERABLE USER FINANCIAL DISCLAIMERS

The Platform may include accessibility-oriented financial tools intended to facilitate usability for:

• elderly individuals;

• visually impaired users;

• users with limited mobility;

• users requiring simplified interactions;

• and accessibility-dependent populations.

Such tools are assistive technologies only.

ORO does NOT provide:

• financial guardianship;

• fiduciary supervision;

• cognitive monitoring;

• payment supervision services;

• financial-care services;

• financial decision-making assistance;

• or human oversight of user spending behavior.

Users requiring:

• financial supervision;

• assisted decision-making;

• legal guardianship;

• cognitive assistance;

• or specialized care services

must independently obtain appropriate legal, medical, or professional assistance where necessary.

The User expressly acknowledges that all payment systems and digital financial technologies contain inherent risks and technological limitations.

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14A. PROMOTIONAL CREDITS, INCENTIVES, DIGITAL BENEFITS AND NON-MONETARY PLATFORM VALUE

From time to time, ORO may offer promotional credits, incentive programs, discounts, loyalty benefits, referral rewards, accessibility-support incentives, bonus programs, digital credits, coupons, vouchers, account benefits, marketplace incentives, or other promotional mechanisms.

Unless expressly required by applicable law or expressly stated otherwise by ORO in writing, such benefits:

do not constitute money;

do not constitute stored value;

do not constitute deposits;

do not constitute electronic money;

do not constitute prepaid financial instruments;

do not accrue interest;

are not transferable;

are not redeemable for cash;

and possess no independent monetary value outside the Platform.

ORO reserves the unrestricted right to modify, suspend, revoke, expire, replace, regionalize, limit, or terminate any promotional benefit, incentive program, digital credit, or non-monetary value mechanism at any time, subject only to mandatory legal requirements.

Users acknowledge that promotional benefits are provided solely as optional marketplace incentives and shall not create vested rights, financial expectations, contractual guarantees, or ownership interests.

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15. LIMITATION OF LIABILITY AND FINANCIAL RISK ALLOCATION

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ORO TECHNOLOGIES LLC, ITS AFFILIATES, LICENSORS, OPERATORS, CONTRACTORS, TECHNOLOGY PARTNERS, PAYMENT INTEGRATIONS, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SUCCESSORS, AND ASSIGNS SHALL NOT BE LIABLE FOR:

• indirect financial losses;

• consequential damages;

• lost profits;

• lost revenue;

• business interruption;

• chargeback losses;

• banking disruptions;

• processor failures;

• delayed settlements;

• unauthorized third-party conduct;

• fraudulent activity;

• accessibility-related payment errors;

• AI inaccuracies;

• voice-command misinterpretation;

• cybersecurity incidents;

• financial institution failures;

• telecommunications interruptions;

• currency fluctuations;

• regulatory actions;

• sanctions restrictions;

• or technological limitations.

ALL PAYMENT SYSTEMS, BILLING STRUCTURES, SETTLEMENT MECHANISMS, AI SYSTEMS, ACCESSIBILITY TOOLS, VOICE INTERFACES, AND FINANCIAL FUNCTIONALITIES ARE PROVIDED STRICTLY ON AN “AS IS,” “AS AVAILABLE,” AND “WITH ALL FAULTS” BASIS WITHOUT WARRANTIES OF ANY KIND.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, ORO EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING:

• merchantability;

• fitness for a particular purpose;

• uninterrupted availability;

• non-infringement;

• continuous accessibility;

• uninterrupted payment processing;

• and flawless transaction execution.

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15A. MAXIMUM FINANCIAL LIABILITY CAP

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE TOTAL AGGREGATE LIABILITY OF ORO ARISING OUT OF OR RELATING TO PAYMENT SERVICES, BILLING, REFUNDS, SETTLEMENTS, OR FINANCIAL OPERATIONS SHALL NOT EXCEED THE LESSER OF:

(a) THE TOTAL AMOUNT OF PLATFORM FEES ACTUALLY RECEIVED BY ORO IN CONNECTION WITH THE SPECIFIC TRANSACTION GIVING RISE TO THE CLAIM; OR

(b) ONE HUNDRED UNITED STATES DOLLARS (USD $100).

THIS LIMITATION SHALL APPLY REGARDLESS OF THE LEGAL THEORY ASSERTED AND SHALL SURVIVE TERMINATION OF THE USER RELATIONSHIP TO THE MAXIMUM EXTENT PERMITTED BY LAW.

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15B. EXCLUSIVE REMEDY

To the maximum extent permitted by applicable law, any refund, credit, billing adjustment, transaction correction, account adjustment, or payment reversal expressly approved by ORO shall constitute the User’s sole and exclusive remedy for any payment-related claim arising from use of the Platform.

Nothing in this section shall limit rights that cannot be waived under applicable law.

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16. NO FINANCIAL GUARANTEES OR FIDUCIARY DUTIES

Nothing within the Platform, this Policy, or any Platform communication shall be interpreted as creating:

• fiduciary obligations;

• investment guarantees;

• insurance coverage;

• banking guarantees;

• guaranteed earnings;

• guaranteed revenue;

• guaranteed settlements;

• guaranteed marketplace demand;

• or guaranteed financial outcomes.

ORO does not guarantee:

• transaction approval;

• provider income;

• user purchasing capability;

• uninterrupted payment services;

• profitability;

• commercial success;

• or continuous financial availability.

All commercial activity facilitated through the Platform occurs at the independent risk of the involved parties.

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16A. REGULATORY ADAPTATION, FINANCIAL INFRASTRUCTURE MIGRATION AND COMPLIANCE MODIFICATION RIGHTS

Due to the continuously evolving nature of global financial regulation, payment-network standards, banking requirements, cybersecurity obligations, sanctions programs, accessibility regulations, consumer-protection laws, tax frameworks, digital-platform requirements, and technological infrastructure, ORO reserves the unrestricted right, to the maximum extent permitted by applicable law, to modify, suspend, replace, regionalize, restructure, migrate, discontinue, or adapt any payment-related functionality, financial infrastructure, settlement mechanism, billing process, processor relationship, verification procedure, currency support, payment method, compliance program, or operational financial feature.

Such modifications may be implemented where reasonably necessary to preserve:

legal compliance;

regulatory alignment;

consumer protection;

financial security;

anti-fraud protection;

operational continuity;

accessibility compliance;

cybersecurity resilience;

or marketplace integrity.

Users expressly acknowledge that regulatory changes may require immediate operational adjustments and that ORO shall not be liable for losses, delays, interruptions, restrictions, or changes arising from compliance with legal, regulatory, governmental, judicial, banking, payment-network, or technological requirements.

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16B. NO GUARANTEE OF REGULATORY APPROVAL

ORO does not guarantee that any payment method, processor, financial service provider, settlement mechanism, banking integration, accessibility-payment feature, voice-payment functionality, or marketplace financial feature will remain approved, authorized, permitted, or legally available in any jurisdiction.

Financial services may be modified, restricted, suspended, or discontinued where required by applicable law, regulatory authorities, payment networks, financial institutions, or governmental directives.