Regulamento exemplo

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7k is a casino and sports betting website in Finland.

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Terms and Conditions of Use of Novawave Technology N.V.

Last Updated Date: December 10, 2025

1. ACCEPTANCE

1.1. The provisions contained in these “General Terms and Conditions of Novawave Technology N.V. Services” (\"Terms\") govern the services provided by Novawave Technology N.V., a company incorporated under the laws of Curaçao with company number 162293, with its registered office at Schottegatweg Oost 10 Unit 1-9 Bon Bini Business Center, Curaçao, to Internet users (Users) and their use by Users, through the online platform operated by Novawave Technology N.V., including, but not limited to state77.com.

1.2. The User may only use the services provided by Novawave Technology N.V. after expressly agreeing to these Terms.

1.3. The sections set out below are complementary to these Terms and may contain relevant information about the use and operation of the Services in addition to those provided in these Terms. Therefore, the User undertakes to become aware of their full content.

2. SERVICES

2.1. The Services offered through the platform consist of:

a. Supplying, marketing, promoting, managing, supporting and operating all types of remote gaming activities, comprising all types of games, betting and other interactive games.

b. Acting as an online software gaming provider in the widest sense of the word, for clients established or residing outside of Curaçao.

2.2. Novawave Technology N.V. holds a valid Certificate of Operation from the Curaçao Gaming Control Board. Novawave Technology N.V. has an application (OGL/2024/547/0446) for a gaming license in progress with the Curaçao Gaming Authority. Until that process is concluded, based on a transitional arrangement outlined in the National Ordinance on Games of Chance (Landsverordening op de Kansspelen, P.B. 2024, no. 157), the company is permitted to continue its operations under this Certificate of Operation.

2.3. Any questions about the Services offered can be resolved through the platform itself or through the Customer Service Center (via telephone contact, email or chat), whose details will be made available on the platform.

3. CONDITION FOR PARTICIPATION

3.1. To use the Services, the User must be a natural person, over 18 years of age, and legally capable. Prior registration on the platform will be necessary, simply by following the instructions contained in the \"How to Participate\" section or equivalent.

3.2. The User guarantees and is responsible for the veracity, accuracy, validity and authenticity of the data contained in the registration filled out by them, committing to keep it duly updated.

3.2.1. Novawave Technology N.V. assumes no obligation to police or supervise the information provided by the User, but may, at its sole discretion, exclude information that appears to be untrue or offensive.

4. PLATFORM ACCESS PASSWORDS

4.1. The password used by the User is personal and non-transferable, and it is the User's responsibility not to pass it on to third parties, for their own security.

4.2. It is forbidden to pass on the access password to third parties.

4.3. The access password must meet the security requirements informed at the time of registration (e.g., minimum of 08 (eight) digits; 1 (one) uppercase letter; 1 (one) lowercase letter; and at least 1 (one) number).

4.4. Novawave Technology N.V. will not have access to the User's personal password, as their personal password is encrypted. No employee or representative of Novawave Technology N.V. is authorized to request, for any reason whatsoever, the User's password.

4.5. The password may be changed by the User at any time, through the Digital Platform.

4.6. The User undertakes to immediately inform Novawave Technology N.V. of the loss, theft or misplacement of the password, so that the appropriate measures can then be taken. Until Novawave Technology N.V. is informed of such occurrence, the User will be responsible for any act/omission resulting from the use of their password.

4.7. The User undertakes not to authorize, and to take all measures within their reach to prevent their registration from being accessed and/or used by any third parties, paying special attention to access and/or use via mobile application, being responsible for any assignment of their private password.

5. GAME AND BETTING MODALITIES

5.1. Novawave Technology N.V. will make various game and betting modalities available on its Digital Platform, in accordance with applicable licenses and regulations. The specific rules for each game and bet will be detailed on the platform itself.

5.1.1. It is the responsibility of Novawave Technology N.V. to include, change and even exclude services and/or products from the Digital Platform, regardless of prior notice, and the User has no right to indemnification and/or reimbursement for the changes made.

5.1.2. Bets and participation in games may be placed on the Novawave Technology N.V. Digital Platform within the deadlines and conditions established for each specific game or event, as informed on the platform.

5.2. In case of impossibility of processing bets or games in a timely manner for the event chosen by the USER, due to unforeseeable circumstances or force majeure, such as technical and/or operational problems, adverse weather conditions, exclusive fault of a third party, among others, Novawave Technology N.V. is exempt from any liability, automatically canceling the bets placed with a full refund of the amount paid.

5.3. Novawave Technology N.V. will be responsible for the registration and processing of bets placed on its platform.

5.4. In extraordinary situations, if a game or betting modality is discontinued, Novawave Technology N.V. undertakes to return the amount wagered to the User's account in the form of platform credit or bank deposit, according to internal policies.

5.5. Under no other circumstances will amounts already disbursed, whether as payment for Services, be returned to Users, except for extraordinary reasons duly justified, considering the deadlines stipulated in Chapter 6 below.

6. CANCELLATION AND WITHDRAWAL

6.1. Once bets are confirmed on the Novawave Technology N.V. Digital Platform, no refund or cancellation of any betting modality will be allowed, except in the situations mentioned in item 6.2 of these Terms of Use or in the specific rules of each game.

6.2. The refund and/or cancellation of bets will only be allowed in the following ways: (i) within the withdrawal period established for each game/bet, if applicable and explicitly informed on the platform; (ii) in cases of proven technical failure of the platform that prevents the bet from being placed; or (iii) as determined by Novawave Technology N.V.'s fair gaming policies.

6.3. Refunds or withdrawals of bets will not be allowed after the start of the event or draw to which the bet refers.

6.4. If any suspicious actions constituting fraud (inconsistencies or irregularities in the purchase/bet) are detected, Novawave Technology N.V. reserves the right to cancel the order immediately.

6.5. Refunds and/or cancellations allowed under item 6.2 above must be requested through Novawave Technology N.V.'s customer service channels, whose details will be made available on the platform.

7. REMUNERATION FOR SERVICES

7.1. For the provision of services offered to Users, Novawave Technology N.V. will receive a fixed remuneration consisting of the difference between the total amount paid by the User and the operational costs and/or commissions retained by Novawave Technology N.V. for the execution of the respective bet or game participation.

7.1.1. The remuneration does not include any expenses with bank transfers, taxes or others possibly due as a result of the withdrawal and/or payment of prizes to winning Users.

7.2. In case of a prize, Novawave Technology N.V. may retain a commission on the prize, as detailed in the specific rules of each game or bet.

7.3. Novawave Technology N.V. may charge access fees or participation fees for certain games, with all informative content (tips, information, statistics, etc.) being accessed free of charge, unless otherwise stated.

8. PAYMENT OF BETS

8.1. Payments for bets are processed by specialized payment methods, which facilitate communication between credit/debit card issuers and the Novawave Technology N.V. Platform, or by other payment methods made available.

8.2. All transactions are submitted to risk assessment by the specialized service provider, without any direct participation or influence from Novawave Technology N.V. in the credit approval process, reserving the final acceptance of the transaction.

8.3. Payment for the services available on the Platform may be made through the payment methods offered on the platform (e.g., PIX, credit card, e-wallets), within the deadlines and conditions specified for each game or bet.

8.3.1. Installment payments for purchases on the platform are not permitted; only single payments are accepted, unless expressly indicated otherwise for specific promotions.

8.4. After payment confirmation, Novawave Technology N.V. will register the games selected by the User.

8.4.1. The registration of the game will be informed to the user via email and/or notification on the platform, confirming that the game has been duly registered.

8.4.2. The payment receipt is not proof of game registration, as informed in item 8.4.1. above.

8.4.3. The User can also track the process of their game by accessing \"My Account\" > \"My Orders\" or equivalent and checking if the selected game appears as “confirmed”.

9. PRIZES AND PRIZE REDEMPTION ON THE PLATFORM

9.1. In case of a prize, Novawave Technology N.V. will notify the winning User via the email and/or telephone number provided in their registration. The User may request the respective credit to their platform account or to their bank account, subject to the provisions below.

9.1.1. Novawave Technology N.V. will have a period of up to 5 (five) business days, counted from the User's request for credit, to carry out the bank transfer of the prize to the User, and this period may be extended in cases of large payment volumes or additional security verifications.

9.2. The bank account used for receiving amounts must necessarily be held by the User who placed the winning bet, as per the registration made on the Portal. No amount will be delivered to the User in cash, nor will it be deposited into bank accounts held by third parties.

9.3. Prizes will be paid by Novawave Technology N.V. directly to the User, according to the specific rules of each game and the platform's payment policies.

9.4. Novawave Technology N.V. will define limits for prize redemption directly on the platform and for redemptions that require contact with support, with these limits being informed on the platform and subject to change at Novawave Technology N.V.'s discretion and without prior notice.

9.5. For high-value prizes, Novawave Technology N.V. may require additional identity verification procedures and/or request the User to appear in person at a designated location for prize collection, or to formally authorize the prize withdrawal for subsequent credit to their bank account. The deadlines for bank account credit may vary from 5 (five) to 10 (ten) business days, or more, depending on the analysis and security procedures.

9.6. For prize receipt purposes, the total prize amount of the winner will be considered.

9.7. Prizes can only be redeemed in their entirety and cannot be partially redeemed, unless otherwise specified in the rules of specific games.

9.8. Amounts resulting from prizes may be credited to the User's account on the Novawave Technology N.V. Platform for use in new purchases or games, if this option is made available. Otherwise, this amount is exclusively for redemption.

9.9. Bank transfers made by Novawave Technology N.V. to Users, resulting from prize amounts, will be subject to bank fees already established by the competent regulatory agency.

10. ACCESS TO SERVICES

10.1. Novawave Technology N.V. may, at its sole discretion, at any time, and without the need for prior communication to the User:

10.1.1. Terminate, modify or suspend, totally or partially, the User's access to the Application, or even to the platform, when said access or registration is in violation of the conditions established in these Terms.

10.1.2. Exclude, totally or partially, the information registered by the User that is not in accordance with the provisions of these Terms.

10.2. At any time, provided that authorized by the User, Novawave Technology N.V. may send the User email messages or other informative, commercial and/or promotional correspondence, unless the User expressly does not consent to the use of their data for sending mailings. If the client no longer wishes to receive emails, they can deactivate them by following the procedure indicated on the platform.

10.3. Communication automatically sent in response to a specific User action, such as a purchase confirmation or order status update, cannot be unsubscribed, as it contains essential information related to the transaction performed.

11. LIMITATIONS OF USE

11.1. The User may not:

a) Use the Novawave Technology N.V. Platform to disclose information in any way that may imply a violation of applicable regulations, rights of Novawave Technology N.V. and/or any third parties, nor may they produce or disseminate illegal, immoral, inappropriate or offensive content;

b) Copy, assign, sublicense, sell, lease or pledge, reproduce, donate, alienate in any way, transfer totally or partially, under any modalities, gratuitously or onerously, temporarily or permanently, the Novawave Technology N.V. Platform, as well as its modules, parts, manuals or any information related thereto;

c) Employ software, techniques and/or artifices with the intent to unduly use the Novawave Technology N.V. Platform for practices harmful to Novawave Technology N.V. or third parties;

d) Reproduce, adapt, modify and/or employ, in whole or in part, for any purpose, the Novawave Technology N.V. Platform or any content of the platform without the express authorization of Novawave Technology N.V.;

e) Publish or transmit any file that contains viruses, worms, Trojan horses or any other contaminating or destructive program, or that may otherwise interfere with the proper functioning of the Novawave Technology N.V. Platform;

f) Perform reverse engineering.

12. LIMITATION OF LIABILITY AND INDEMNIFICATION

12.1. Novawave Technology N.V. will not be liable, under any circumstances, not even jointly or subsidiarily:

a) For any losses suffered by the User due to decisions made based on the information provided on the platform or Application;

b) For any losses suffered by the User due to failures in the computer system, telephony or servers that are independent of Novawave Technology N.V.'s fault, or in its connectivity to the internet in general, and the User must maintain, at their own expense, a telecommunication line, modem, communication software, email address and other resources necessary for communication with Novawave Technology N.V.;

c) For any losses suffered due to fraud committed by third parties, and the User must maintain, at their own expense, software and measures for protection and prevention against viruses, Worms, etc.;

d) For situations of unforeseeable circumstances or force majeure.

12.2. Novawave Technology N.V. DOES NOT guarantee that the functions contained in the Platform meet all User needs, that the operation of the Platform will be uninterrupted or error-free, that any functionality will continue to be available, that defects in the Platform will be corrected or that the Platform will be compatible or work with any Application, third-party applications or services.

12.3. The User agrees to defend, indemnify and hold harmless Novawave Technology N.V. and its affiliates, directors, employees and agents, from and against any charges, actions or demands, including, but not limited to reasonable attorneys' fees, resulting from: (i) their eventual improper use of the platform and the Application, or (ii) their violation of the conditions now agreed upon.

12.4. In no event will Novawave Technology N.V. be liable for personal damages or any incidental, special, indirect or consequential damages, lost profits, including, without limitation, damages for loss of profit, corruption or loss of data, failure to transmit or receive data, loss of chance, business interruption or any other commercial loss or damage, arising out of or related to their use or inability to use the Application, for any other reason.

12.5. In the event that Novawave Technology N.V. is compelled, by a final judicial decision, to indemnify or reimburse the User for damages suffered, despite the provisions of item 12.2 above, the amount owed to the User will be limited to 20% (twenty percent) of the total amounts actually paid by the User to Novawave Technology N.V. in the 12 (twelve) months prior to the harmful event.

13. TERMS OF USE OF OTHER PARTNERS AND THIRD PARTIES

13.1. The Novawave Technology N.V. Platform or Application may contain links to partner companies, and these have their own terms and conditions.

13.2. Novawave Technology N.V. is not responsible for the terms and conditions of use of any other website that is related to Novawave Technology N.V., whether through links or other forms of dissemination and access.

14. VALIDITY

14.1. These Terms will be effective for an indefinite period, from the User’s acceptance, and may be modified or terminated unilaterally by Novawave Technology N.V. at any time, without any burden, upon simple communication through the Portal itself or by message to the email indicated in the User’s personal registration.

15. INACTIVE ACCOUNTS AND FEE CHARGES

15.1. If the User keeps their account unused for more than 180 (one hundred and eighty) days, Novawave Technology N.V. may charge a monthly fee applicable to account maintenance.

15.1.1. For the purpose of charging the monthly fee in clause 15.1 above, an unused account is considered to be an account where there has been no movement of balance or participation in games for more than 180 (one hundred and eighty) days.

15.2. Said fee provided for in clause 15.1 above will be charged by debiting the balance credited to the User's account, whether it is credit received through prizes or credit purchased by the User for use on the Platform.

15.2.1. The debit of the fee provided for in this chapter will be made monthly up to the limit of the balance contained in the User's account.

15.2.2. If there is no balance remaining in the User's account, Novawave Technology N.V. may render the User's account inactive until new purchases or movements are made on the Novawave Technology N.V. Platform.

16. PREVENTION OF MONEY LAUNDERING AND PROHIBITED EVENTS

16.1. Transaction Monitoring:

16.1.1. Novawave Technology N.V. is committed to maintaining a fair and ethical online environment. Recognizing the importance of integrity in our services, we have implemented rigorous measures to monitor transactions and prevent money laundering. If, in our reasonable discretion, we determine that a user has been involved in any Prohibited Event, we reserve the right to:

a) Annul any transaction associated with the Prohibited Event.

b) Retain all or part of the balance in any account or registration with Novawave Technology N.V. used by the user.

16.1.2. Novawave Technology N.V. will carry out additional verification procedures for any transaction or transactions and reserves the right to carry out these verification procedures even in the case of lower payments. All transactions will be verified to prevent money laundering.

16.2. Defined Prohibited Events:

For the purposes of this section, Prohibited Events are considered to be:

16.2.1. If at any time the user provides incorrect or misleading registration details for their Account;

16.2.2. If at any time the user fails to meet or comply with any of the verification requirements and/or any verification or request for information reasonably necessary to meet our legal, regulatory or internal requirements;

16.2.3. If the user deliberately or fraudulently holds one or more duplicate accounts;

16.2.4. If it is discovered or there are reasons to believe that the security of the user's account has been compromised, for example, because the user failed to maintain the confidentiality and security of their Login credentials;

16.2.5. If it is discovered or there are reasons to believe that the user has violated the security of another user's account;

16.2.6. If a fraudulent chargeback and/or return notification is received through a payment method used in the user's account;

16.2.7. If it is discovered or there are reasons to believe that the user has abused or taken advantage of any error, malfunction or interruption;

16.3. User Obligations:

Immediately inform Novawave Technology N.V. of any suspicion or knowledge of a Prohibited Event committed by any user.

Cooperate reasonably in investigations, providing the requested information.

16.4. Restriction, Suspension and Termination of Accounts:

16.4.1. Novawave Technology N.V. reserves the right to restrict, suspend or terminate user accounts in situations that compromise the integrity of gaming services. Such measures may include:

a) Restriction of access to certain games or functionalities.

b) Temporary suspension of the account.

c) Permanent termination of the account.

16.4.2. Reasons for Restriction, Suspension or Termination:

a) Participation in Prohibited Events.

b) Violation of Novawave Technology N.V.'s usage policies.

c) Activities that compromise the security or integrity of the services.

d) Non-compliance with legal or regulatory requirements.

16.4.3. Communication to the User:

16.4.3.1. We will communicate to the user the specific reason for any restriction, suspension or termination of account, whenever possible.

17. GENERAL RULES, APPLICABLE LAW AND CHOICE OF FORUM

17.1. By using the Services, the User undertakes to act responsibly and moderately, as well as to respect the law, morality and good customs.

17.2. The provisions contained herein and any other policies disclosed by Novawave Technology N.V. constitute the rules that specifically govern the relationship between the User and Novawave Technology N.V., superseding and revoking any and all understandings, proposals, agreements, negotiations and discussions that may have occurred previously between the parties, so that the User is presumed to have full knowledge and irrevocable and irreversible consent.

17.3. The relationship between the User and Novawave Technology N.V. is governed by the laws of Curaçao, where the company is incorporated.

17.4. Due to national and international rules for the prevention of money laundering and the financing of criminal activities, Novawave Technology N.V. may voluntarily share with governmental bodies information in any way related to the registration, operations and eventual prizes of its Users. It may also forward any information of which it is aware, and which may be requested by governmental bodies, regardless of notification or warning to the User.

17.5. The inability or impossibility of Novawave Technology N.V. to exercise or enforce any right or provision contained herein does not constitute a waiver of that right or provision.

17.6. The declaration of nullity or unenforceability of any item, term or provision contained herein will not imply the nullity or unenforceability of any other items, terms or provisions contained herein, which will remain in full force and whose effects will not be affected.

17.7. The User does not acquire any intellectual property rights over or in any way related to the platform, the Application or any functionality or component that may be made available by Novawave Technology N.V.

17.7.1. Under no circumstances will the User have access to the source code of the Application, as it is the intellectual property of Novawave Technology N.V.

17.8. Any and all content made available by Novawave Technology N.V., on the platform or in the Application, including, but not limited to texts, graphics, images, logos, icons, photographs, editorial content, notifications, software and any other material, belong exclusively to Novawave Technology N.V., and are protected by applicable law regarding intellectual property and copyrights.

17.9. Novawave Technology N.V. is not a financial institution.

17.10. Novawave Technology N.V. and its contracted collaborators undertake to act in accordance with the legislation in force on the protection of data relating to an identified or identifiable natural person (\"Personal Data\") and the determinations of the Regulatory/Supervisory Bodies on the matter, especially the provisions of the applicable data protection law, as well as other applicable personal data protection laws, norms and policies.

17.10.1. In this sense, Novawave Technology N.V. has a document called Privacy Policy (\"Policy\") that explains clearly and accessibly how your information and data will be collected, used, shared and stored through our systems. The Privacy Policy can be consulted at any time.

17.11. The parties elect the forum of Curaçao as the sole competent to resolve any disputes and/or demands that may involve the Parties in relation to the use of the Services and access to the platform.

17.12. The User declares to be aware of the rights and obligations arising from these Terms, having read, understood and accepted all terms and conditions.

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RESPONSIBLE GAMBLING POLICY.

NovaWave Technology N.V.

Domain: www.fi.7k.bet

Effective Date: 29 January 2026

NovaWave Technology N.V., a private limited liability company (Naamloze Vennootschap – N.V.), duly incorporated under the laws of Curaçao, registered with the Curaçao Chamber of Commerce and Industry under registration number 162293, with its registered office at Schottegatweg Oost 10, Unit 1–9, Bon Bini Business Center, Curaçao (“NovaWave”, “Company”, “we”, “our” or “us”), hereby establishes this Responsible Gambling Policy, applicable to all activities, systems, controls and procedures related to the operation and governance of the domain www.fi.7k.bet, in connection with the Finnish regulatory environment and internationally accepted standards of player protection.

1. PURPOSE, OBJECTIVES AND REGULATORY PHILOSOPHY

This Responsible Gambling Policy has been formally adopted to define, document and operationalize NovaWave’s commitment to responsible gambling, consumer protection and harm prevention, ensuring that gambling-related activities are conducted in a lawful, ethical, transparent and socially responsible manner.

NovaWave expressly recognizes that gambling is an activity that carries inherent risks, including but not limited to compulsive behavior, financial loss, emotional distress and social harm. Accordingly, the Company adopts a preventive, risk-based and player-centric approach, designed to:

a) prevent underage gambling and unauthorized access;

b) ensure that players are able to make informed and conscious decisions;

c) provide effective tools that allow players to control time and money spent;

d) identify early indicators of harmful or problematic gambling behavior;

e) intervene proportionately and responsibly when risk indicators arise;

f) align operations with Finnish public policy objectives aimed at reducing gambling-related harm;

g) ensure accountability, traceability and auditability of all responsible gambling measures.

This Policy is intended to function not merely as a formal declaration, but as a living operational framework, continuously monitored, tested, improved and enforced across the organization.

2. FINNISH LEGAL FRAMEWORK AND TERRITORIAL COMPLIANCE

2.1 Exclusive-right system currently in force

At the date of entry into force of this Policy, gambling services in mainland Finland are governed by an exclusive-right (monopoly) system, under which Veikkaus Oy holds the exclusive legal right to provide gambling services. Under this framework, the provision and marketing of gambling services to persons located in Finland by non-authorized operators is prohibited.

NovaWave fully acknowledges this legal framework and therefore adopts strict territorial compliance measures, ensuring that:

a) the Company does not intentionally target, market or promote gambling services to persons physically located in Finland unless duly authorized;

b) marketing strategies, branding, affiliates and advertising practices are structured to avoid unlawful Finnish targeting;

c) technical controls are applied to reduce the risk of access from restricted territories;

d) compliance decisions are documented and reviewed by the compliance function.

2.2 Regulatory reform and future licensing regime

Finland is in the process of implementing a structural reform of its gambling legislation, transitioning from the monopoly model to a multi-license regulatory system, with licensing applications expected to open in 2026 and licensed operations commencing thereafter.

NovaWave commits that, should it seek authorization under the future Finnish licensing regime:

a) all mandatory responsible gambling obligations will be fully implemented prior to commencement of licensed operations;

b) this Policy will be reviewed and updated to reflect binding Finnish licensing conditions, including centralized self-exclusion, mandatory spending limits, enhanced identification mechanisms and reporting obligations;

c) additional technical integrations required by Finnish authorities will be implemented without delay.

Until such authorization is formally obtained, NovaWave will maintain a conservative compliance posture, prioritizing harm prevention and legal conformity.

3. SCOPE OF APPLICATION AND GOVERNANCE

This Policy applies to:

a) all gambling products, platforms and services operated by NovaWave under www.fi.7k.bet;

b) all NovaWave employees, directors, officers and agents;

c) all third parties acting on behalf of NovaWave, including affiliates, payment service providers, customer support vendors, verification service providers and technology partners;

d) all stages of the player lifecycle, from registration to account closure.

Responsibility for the implementation and oversight of this Policy rests with the Compliance and Risk Management Function, supported by senior management.

4. CORE PRINCIPLES OF RESPONSIBLE GAMBLING

NovaWave’s responsible gambling framework is based on the following foundational principles:

4.1 Protection of minors

Gambling is strictly prohibited for individuals under the age of 18 years. Preventing access by minors is a fundamental requirement of Finnish public policy and international best practice.

4.2 Transparency and informed choice

Players must be provided with clear, accurate and accessible information regarding gambling products, rules, probabilities, risks and player-protection mechanisms, enabling fully informed participation.

4.3 Player autonomy and empowerment

Players must retain control over their gambling activity through accessible tools that allow them to manage spending, time and participation.

4.4 Early detection of harmful behavior

NovaWave actively monitors gambling behavior to detect early signs of problematic or compulsive gambling.

4.5 Proportional and ethical intervention

When risks are identified, interventions must be proportionate, respectful and aimed at harm reduction rather than revenue maximization.

4.6 Accountability and evidence

All responsible gambling actions must be documented, traceable and available for audit and regulatory review.

5. AGE VERIFICATION AND IDENTITY CONTROLS

5.1 Minimum age requirement

Only individuals aged 18 years or older are permitted to register and participate in gambling activities.

5.2 Identity verification procedures

NovaWave applies robust Know Your Customer (KYC) and identity verification procedures designed to:

a) confirm age and identity;

b) prevent fraud, identity misuse and multiple account creation;

c) enforce self-exclusion and limit controls;

d) support responsible gambling monitoring and AML compliance.

Verification may occur at registration, prior to withdrawals, upon reaching defined thresholds, or when risk indicators arise.

5.3 Continuous monitoring

NovaWave may apply ongoing verification, behavioral analysis and device monitoring to ensure continued compliance and to detect attempts to circumvent controls.

6. PLAYER-CONTROLLED RESPONSIBLE GAMBLING MEASURES

6.1 Financial limits

Players are provided with tools to set daily, weekly and monthly deposit and spending limits. These limits are designed to reduce impulsive gambling and excessive expenditure.

Limit increases are subject to protective waiting periods, while reductions take effect immediately.

6.2 Time management and reality checks

NovaWave provides session monitoring tools, including reminders and notifications that inform players of time spent and gambling outcomes, promoting self-awareness.

6.3 Cooling-off periods

Players may voluntarily suspend their gambling activity for predefined periods. During cooling-off periods, access to gambling is blocked and marketing communications are restricted.

6.4 Self-exclusion

Players may self-exclude for extended periods. Where required by Finnish law, NovaWave will integrate and enforce centralized self-exclusion mechanisms.

7. OPERATOR-LED MONITORING AND INTERVENTION

NovaWave actively monitors gambling behavior to identify risk indicators such as escalating deposits, prolonged sessions, loss chasing and signs of distress.

When such indicators are detected, NovaWave may implement graduated interventions, including warnings, direct outreach, mandatory limits, account restrictions or suspension.

All interventions are documented and reviewed to ensure consistency and effectiveness.

8. MARKETING, ADVERTISING AND COMMUNICATION CONTROLS

NovaWave adopts strict controls to ensure that marketing activities:

a) do not target minors or vulnerable individuals;

b) do not misrepresent gambling outcomes;

c) do not encourage excessive or irresponsible gambling;

d) comply with Finnish restrictions on unauthorized gambling marketing;

e) respect player protection measures and exclusions.

9. CUSTOMER SUPPORT AND STAFF TRAINING

Customer support personnel receive mandatory training on responsible gambling principles, intervention techniques, Finnish legal constraints and confidentiality obligations.

Support staff are empowered to prioritize player protection over commercial considerations.

10. DATA PROTECTION AND CONFIDENTIALITY

Personal data processed for responsible gambling purposes is handled in accordance with applicable data protection laws and internal privacy policies, with strict access controls and security measures.

11. COMPLAINTS, RECORDKEEPING AND AUDITABILITY

NovaWave maintains procedures for receiving, investigating and resolving complaints related to responsible gambling, with full documentation retained for audit and regulatory review.

12. REVIEW, GOVERNANCE AND CONTINUOUS IMPROVEMENT

This Policy is reviewed at least annually, and whenever changes in Finnish law, regulatory expectations or operational risk require revision.

13. FINAL PROVISIONS

This Responsible Gambling Policy enters into force on 26 January 2026 and is binding on all NovaWave personnel and partners involved in the operation of www.fi.7k.bet.

GLOSSARY:

1. Responsible Gambling

A framework of policies, procedures and tools designed to prevent gambling-related harm and promote safe participation.

2. Player

Any individual who registers for or uses gambling services offered by NovaWave.

3. Minor

An individual under the age of 18 years.

4. KYC (Know Your Customer)

Procedures used to verify the identity and age of players.

5. Self-Exclusion

A voluntary measure by which a player blocks access to gambling services for a defined period.

6. Cooling-off Period

A temporary suspension of gambling activity initiated by the player.

7. Deposit Limit

A financial control that restricts the amount of money a player may deposit within a specified period.

8. Loss Chasing

A behavior pattern where a player continues or increases gambling activity in an attempt to recover losses.

9. Risk Indicator

A behavioral or transactional signal suggesting elevated risk of gambling-related harm.

10. Intervention

Any action taken by the operator to reduce gambling-related harm, including warnings, limits or account restrictions.

11. Centralized Self-Exclusion Register

A regulatory system that applies self-exclusion across multiple licensed operators.

12. Vulnerable Individual

A person who may be at increased risk of gambling-related harm due to behavioral, financial or personal factors.

13. Territorial Compliance

Measures applied to ensure gambling services are offered only in jurisdictions where legally permitted.

14. Auditability

The ability to demonstrate compliance through documented evidence and records.

15. Finnish Gambling Reform

The legislative process transitioning Finland from a monopoly gambling system to a licensed market.

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PRIVACY AND PERSONAL DATA PROTECTION POLICY.

NovaWave Technology N.V.

Domain: www.fi.7k.bet

Date: 28 January 2026

1. General statement and commitment to data protection.

This Privacy and Personal Data Protection Policy sets forth the principles, obligations and operational guidelines adopted by NovaWave Technology N.V. in relation to the processing of personal data carried out through the domain www.fi.7k.bet. NovaWave recognizes that the protection of personal data is a fundamental right and an essential element of trust in digital services, particularly in environments that involve user registration, online interaction, authentication mechanisms, financial transactions and security monitoring.

NovaWave is fully committed to conducting all personal data processing activities in a lawful, fair and transparent manner, strictly in accordance with the General Data Protection Regulation and the applicable data protection legislation in force in Finland. This Policy reflects NovaWave’s internal governance framework for privacy and data protection and demonstrates its commitment to accountability, proportionality, security and respect for the rights and freedoms of natural persons.

2. Applicable legal framework.

All personal data processing activities performed by NovaWave in connection with the operation of the website www.fi.7k.bet are governed by Regulation (EU) 2016/679, the General Data Protection Regulation, which applies directly and uniformly throughout the European Union and the European Economic Area, including Finland.

In addition to the GDPR, NovaWave complies with the Finnish Data Protection Act 1050/2018, which supplements the GDPR at national level and establishes specific provisions concerning supervision, remedies, procedures and certain national options permitted under European law.

Where personal data processing involves the storage of information or access to information stored on the user’s terminal equipment, such as through cookies or similar technologies, NovaWave also observes the applicable Finnish legislation on electronic communications and privacy in digital services, including the Act on Electronic Communications Services and related regulatory guidance issued by Finnish authorities.

3. Identification of the data controller.

For the purposes of the GDPR and applicable Finnish data protection legislation, the data controller responsible for determining the purposes and means of the processing of personal data described in this Policy is:

NovaWave Technology N.V., a limited liability company duly registered with the Curaçao Chamber of Commerce and Industry under registration number 162293, with its registered address at Schottegatweg Oost 10, Unit 1-9, Bon Bini Business Center, Curaçao.

NovaWave acts as the central entity responsible for defining data protection policies, ensuring compliance with applicable laws, implementing technical and organizational measures and responding to data subject requests relating to the processing of personal data carried out through www.fi.7k.bet.

4. Scope of this Policy.

This Policy applies to all personal data processing activities carried out by NovaWave in connection with the provision, administration, maintenance and security of the services made available through the domain www.fi.7k.bet. It applies to all users, visitors, customers, partners and any other individuals whose personal data is processed in the context of these services.

The Policy applies regardless of the form or medium through which personal data is collected, whether online or offline, whether provided directly by the data subject or obtained indirectly from authorized third parties, and regardless of the technologies or systems used for processing.

This Policy must be read together with other contractual or informational documents published by NovaWave, including terms and conditions and specific notices, without prejudice to the primacy of mandatory data protection laws.

5. Types of personal data processed.

Depending on the nature of the relationship established with the data subject and the functionalities used on www.fi.7k.bet, NovaWave may process different categories of personal data.

Personal data provided directly by users may include identification data such as full name, date of birth, nationality and preferred language, as well as account-related data such as username, authentication credentials and account settings. Contact data such as email address, telephone number and residential address may also be processed for communication and support purposes.

Where required for security, compliance or verification purposes, NovaWave may process verification data, including copies or extracts of identification documents, proof of address, age verification information and payment-related verification data. Such processing is strictly limited to what is necessary to meet legal, regulatory and contractual requirements.

During the use of the website, NovaWave may automatically process technical and usage data, including IP address, device identifiers, browser and operating system information, access timestamps, navigation data, interaction logs and approximate location data derived from technical parameters. This information is used primarily to ensure service stability, prevent fraud, detect security incidents and improve the overall performance and reliability of the platform.

In certain circumstances, NovaWave may also receive personal data from third-party service providers, such as payment service providers, identity verification partners, fraud prevention services or analytics providers, always subject to appropriate contractual arrangements and legal safeguards.

6. Purposes of processing and legal grounds.

NovaWave processes personal data exclusively for specific and legitimate purposes and always on the basis of one or more lawful grounds provided for under the GDPR.

Personal data is processed to perform contractual obligations entered into with users, including the creation and management of user accounts, authentication and access control, provision of services requested by the user, processing of transactions and delivery of customer support.

Personal data is also processed to comply with legal obligations to which NovaWave is subject, including obligations related to security, record keeping, auditing, prevention of unlawful activities and compliance with lawful requests from competent authorities.

For purposes related to the protection of NovaWave’s infrastructure, users and services, personal data may be processed on the basis of NovaWave’s legitimate interests, including the prevention of fraud, detection of suspicious behavior, enforcement of contractual terms, cybersecurity monitoring and protection of systems against misuse or abuse.

Where processing activities are not strictly necessary for contractual performance or legal compliance, such as certain analytics or marketing activities, NovaWave relies on the data subject’s consent, which may be withdrawn at any time in accordance with applicable law.

7. Processing of children’s data and age requirements.

NovaWave does not intentionally target or provide its services to individuals who do not meet the applicable legal age requirements.

Under Finnish law, where the processing of personal data is based on consent in relation to the direct offering of information society services to a child, the minimum age for valid consent is thirteen years. Where this threshold is not met, consent must be provided or authorized by a holder of parental responsibility.

NovaWave reserves the right to implement appropriate age verification mechanisms and to restrict, suspend or terminate access to the services where age requirements are not satisfied or where inaccurate information has been provided.

8. Disclosure and sharing of personal data.

Personal data processed by NovaWave may be shared with third parties only where such sharing is necessary for the purposes described in this Policy and where appropriate safeguards are in place.

Such recipients may include service providers acting as data processors on behalf of NovaWave, including hosting providers, payment processors, identity verification services, customer support platforms, analytics providers, security vendors and professional advisors. All such parties are contractually bound to process personal data solely on NovaWave’s instructions and in compliance with applicable data protection laws.

Personal data may also be disclosed to public authorities, courts or law enforcement bodies where such disclosure is required by law or is necessary for the establishment, exercise or defense of legal claims.

NovaWave does not engage in the sale of personal data.

9. International transfers of personal data.

Due to the international nature of NovaWave’s corporate structure and service provider network, personal data may be transferred to and processed in jurisdictions outside Finland and outside the European Economic Area.

In all cases of international data transfers, NovaWave ensures that appropriate legal mechanisms and safeguards are implemented in accordance with the GDPR, including the use of adequacy decisions, standard contractual clauses approved by the European Commission and supplementary technical and organizational measures designed to ensure an equivalent level of data protection.

10. Data retention and storage principles.

NovaWave retains personal data only for as long as necessary to achieve the purposes for which it was collected and processed, taking into account legal, regulatory, contractual and operational requirements.

Retention periods vary depending on the nature of the data and the applicable obligations. Once personal data is no longer required, it is securely deleted, anonymized or otherwise rendered irreversibly inaccessible, unless continued retention is required by law.

11. Use of cookies and similar technologies.

The website www.fi.7k.bet uses cookies and similar technologies to ensure proper technical functionality, enhance security, remember user preferences and analyze website performance.

In accordance with Finnish legislation, non-essential cookies and similar technologies are used only after users have been provided with clear and comprehensive information and, where required, have given their consent. Users may manage their preferences through available tools and browser settings.

12. Information security and breach management.

NovaWave implements appropriate technical and organizational security measures designed to protect personal data against unauthorized access, accidental loss, alteration or disclosure. These measures are proportionate to the risks associated with the processing activities and are subject to regular review.

In the event of a personal data breach, NovaWave applies internal incident response procedures to assess the impact and, where required by law, notify the competent supervisory authority and affected data subjects within the legally prescribed timeframes.

13. Rights of data subjects.

In accordance with Regulation (EU) 2016/679 (General Data Protection Regulation) and the Finnish Data Protection Act (Act 1050/2018), NovaWave recognizes and fully respects the rights of data subjects as fundamental elements of the lawful, fair and transparent processing of personal data. The exercise of these rights is directly connected to the core data protection principles established by the GDPR, including the principles of lawfulness, fairness and transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality, and accountability.

Data subjects have the right to obtain confirmation as to whether or not their personal data is being processed by NovaWave and, where that is the case, the right to access such personal data. This right of access includes the ability to receive clear and comprehensive information about the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipients to whom the personal data has been or will be disclosed, the envisaged period for which the personal data will be stored or the criteria used to determine that period, as well as information about the existence of automated decision-making processes, where applicable. The right of access is intended to ensure transparency and to enable data subjects to verify the lawfulness of the processing.

Data subjects also have the right to request the rectification of inaccurate personal data concerning them without undue delay, as well as the right to have incomplete personal data completed, taking into account the purposes of the processing. This right reflects the principle of accuracy and ensures that personal data processed by NovaWave remains correct, up to date and relevant.

Under the conditions established by the GDPR, data subjects may request the erasure of their personal data, commonly referred to as the “right to be forgotten”. This right applies, for example, where personal data is no longer necessary in relation to the purposes for which it was collected or processed, where the data subject withdraws consent on which the processing is based and there is no other legal ground for the processing, or where the personal data has been unlawfully processed. The exercise of this right is subject to legal and regulatory exceptions, including situations where retention is required to comply with a legal obligation or to establish, exercise or defend legal claims.

Data subjects have the right to request the restriction of the processing of their personal data in certain circumstances, such as where the accuracy of the personal data is contested, where the processing is unlawful and the data subject opposes erasure, or where the data is no longer needed by NovaWave but is required by the data subject for the establishment, exercise or defense of legal claims. When processing is restricted, the personal data may, with the exception of storage, only be processed with the data subject’s consent or for limited legally permitted purposes.

Where the processing of personal data is based on legitimate interests, data subjects have the right to object at any time to such processing on grounds relating to their particular situation. NovaWave will then assess whether it has compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or whether the processing is necessary for the establishment, exercise or defense of legal claims. Data subjects also have an unconditional right to object to the processing of their personal data for direct marketing purposes.

Where applicable, and where the processing is based on consent or on a contract and is carried out by automated means, data subjects have the right to data portability. This right allows data subjects to receive their personal data in a structured, commonly used and machine-readable format and to transmit that data to another controller, where technically feasible, without hindrance from NovaWave. The purpose of this right is to strengthen user control over personal data and promote interoperability between services.

When the processing of personal data is based on consent, data subjects have the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal and does not apply where processing is based on another lawful ground provided for under the GDPR.

All requests relating to the exercise of data subject rights may be submitted through the contact channels made available by NovaWave. Such requests will be handled in a transparent, diligent and timely manner, in accordance with the procedures and time limits established by the GDPR and Finnish data protection law. NovaWave may request additional information to verify the identity of the requester in order to ensure the security and confidentiality of personal data and to prevent unauthorized disclosure.

14. Amendments to this Policy.

NovaWave may update this Privacy and Personal Data Protection Policy to reflect changes in applicable legislation, regulatory guidance, technological developments or internal practices. Any updated version will be published on www.fi.7k.bet and will indicate the date on which it becomes effective.

GLOSSARY:

Personal data means any information relating to an identified or identifiable natural person, including information that can directly or indirectly identify an individual by reference to identifiers such as a name, identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Processing refers to any operation or set of operations performed on personal data, whether by automated means or not, including but not limited to collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, restriction, erasure or destruction of personal data.

Data subject is the identified or identifiable natural person to whom the personal data relates and whose data is processed by the data controller in the context of the services provided.

Data controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Data processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller and strictly in accordance with its documented instructions.

GDPR refers to Regulation (EU) 2016/679 of the European Parliament and of the Council, known as the General Data Protection Regulation, which establishes the legal framework for the protection of personal data within the European Union and the European Economic Area.

Finnish Data Protection Act refers to Act 1050/2018 of Finland, which supplements and specifies the application of the GDPR at national level, including provisions on supervision, procedures and remedies.

Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

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ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING POLICY.

(PLD-FT / AML-CTF)

NovaWave Technology N.V.

Domain: www.fi.7k.bet

Date: 26 January 2026

1. Purpose, scope, and zero tolerance commitment

1.1. This Anti-Money Laundering and Counter-Terrorist Financing Policy (the “Policy”) establishes the governance principles, mandatory controls, operational procedures, and accountability rules adopted by NovaWave Technology N.V. (“NovaWave”, “Company”, “we”, “our”) to prevent, detect, deter, and respond to money laundering, terrorist financing, and related financial crime risks in connection with the operation of the domain www.fi.7k.bet (the “Platform”) and any associated services, channels, tools, and customer-facing or back-office processes.

1.2. NovaWave maintains a strict zero tolerance stance against any attempt to use the Platform to launder proceeds of crime, finance terrorism, evade sanctions, commit fraud, abuse the financial system, or otherwise conduct illicit activity. The Company’s approach is preventive and risk-based. We apply controls proportionate to the nature, size, complexity, and risk profile of our operations, recognizing that effective AML-CTF controls must be practical, evidence-based, and continuously improved.

1.3. This Policy applies to all directors, officers, managers, employees, contractors, agents, and service providers acting for or on behalf of NovaWave, including payment, verification, screening, customer support, risk, compliance, and technology functions. It also applies to any third party performing outsourced activities that may affect AML-CTF risk, including onboarding, identity verification, payment processing, transaction monitoring, and customer communications.

2. Finland-specific legal and regulatory framework for operations involving Finland

2.1. Because the Platform is intended to be used in Finland through the .fi-facing domain and Finnish market exposure, NovaWave’s AML-CTF framework is aligned with the Finnish legal system and supervisory expectations applicable to business activities conducted in or directed to Finland.

2.2. The principal Finnish statute governing prevention of money laundering and terrorist financing is the Act on Preventing Money Laundering and Terrorist Financing (444/2017) (the “Finnish AML Act”), which establishes obligations for risk assessment, customer due diligence, ongoing monitoring, internal controls, and cooperation with competent authorities.

2.3. NovaWave’s internal reporting and escalation standards are designed to support compliance with the Finnish AML Act and the operational role of the Finnish Financial Intelligence Unit, which processes money laundering reports and operates in connection with the National Bureau of Investigation.

2.4. NovaWave also maintains alignment with the Finnish institutional framework for AML-CTF supervision and guidance, including supervisory principles and “current provisions, regulations and guidelines” published by the Finnish Financial Supervisory Authority (FIN-FSA) for sectors under its remit, recognizing that Finland’s AML framework is built on EU AML directives and FATF standards.

2.5. In addition to preventive obligations, NovaWave recognizes that money laundering conduct is criminalized under Finnish criminal law, including offences addressed in Finland’s Criminal Code framework on receiving and money laundering offences, and therefore treats any detected laundering patterns as matters requiring urgent escalation and preservation of evidence.

2.6. This Policy is written as an internal governance instrument and must be applied together with NovaWave’s Privacy and Personal Data Protection Policy, Information Security Policy, Risk Management Policy, Sanctions Policy (if adopted), and any additional procedures required by licensing or regulatory registrations relevant to operations directed to Finland. Where local obligations apply differently depending on activity classification, NovaWave will apply the highest standard necessary to ensure risk containment and regulatory defensibility.

3. Core principles of NovaWave’s AML-CTF program

3.1. NovaWave’s AML-CTF program is built on the following principles, applied throughout the lifecycle of the customer relationship and across all relevant processes.

3.2. The principle of a risk-based approach is central. NovaWave identifies, assesses, and manages ML-FT risks by considering customer risk, geographic risk, product and service risk, transaction risk, and delivery channel risk. The Finnish AML Act itself requires obliged entities to prepare and maintain risk assessments, and NovaWave mirrors this structure by maintaining documented risk assessment artifacts and ensuring that controls are proportionate to identified risks.

3.3. The principle of know your customer means that NovaWave seeks reasonable certainty regarding the identity of customers, the legitimacy of their activity, and the consistency of their behavior with expected usage. This includes the ability to detect inconsistencies and to refuse, suspend, or terminate relationships where risk cannot be mitigated.

3.4. The principle of continuous monitoring means that AML-CTF is not limited to onboarding. NovaWave monitors customer behavior and transactions on an ongoing basis, updating customer risk ratings and triggering enhanced controls when risk indicators emerge.

3.5. The principle of timely escalation and defensible decisions means that NovaWave maintains structured internal workflows to document why decisions were taken, what evidence supported those decisions, who approved them, and what follow-up actions occurred. This includes secure recordkeeping suitable for audit and regulatory review.

3.6. The principle of confidentiality and controlled disclosure means that suspicious activity handling must be managed on a strict need-to-know basis, preserving investigation integrity and minimizing tipping-off risk.

4. Governance, responsibilities, and accountability

4.1. Senior management and the board of directors (or equivalent governing body) are responsible for establishing a culture of compliance and ensuring that AML-CTF risk is managed as a strategic and operational priority. Management must ensure the availability of appropriate resources, including qualified personnel, tooling, training, and independent review capacity.

4.2. NovaWave designates a responsible compliance function to oversee AML-CTF implementation. This function must be sufficiently independent from revenue-generating operations, with authority to require controls, pause transactions, freeze accounts where permitted, refuse customer onboarding, and escalate matters to senior management when risk thresholds are exceeded.

4.3. Where required by applicable law or where adopted as best practice, NovaWave appoints a Money Laundering Reporting Officer or equivalent responsible person with defined responsibilities for internal case oversight, quality assurance, reporting governance, and liaison with competent authorities.

4.4. All staff with exposure to onboarding, payments, customer support, risk review, fraud prevention, and technology operations are required to cooperate with the AML-CTF program, comply with procedures, escalate red flags, and complete mandatory training. Failure to comply may result in disciplinary measures, contract termination, and, where relevant, referral to competent authorities.

5. Enterprise AML-CTF risk assessment and updates

5.1. NovaWave maintains an enterprise-level AML-CTF risk assessment that identifies inherent risks, evaluates the adequacy of controls, and determines residual risk. This assessment is reviewed regularly and updated when there are material changes, including changes to product features, payment methods, customer base composition, geographic targeting, regulatory requirements, or emerging typologies.

5.2. Risk assessment documentation is retained and made available internally for audit and governance. It is also structured to be producible to supervisory authorities if required, consistent with the Finnish AML Act’s emphasis on risk assessment and ongoing updates.

5.3. The risk assessment process includes a documented methodology, risk scoring criteria, control mapping, ownership assignment for remediation actions, and timelines for review and revalidation.

6. Customer due diligence, identification, and verification standards

6.1. NovaWave applies Customer Due Diligence (CDD) measures to identify and verify customers before establishing a business relationship and, where relevant, before enabling financial functionality or withdrawals. The depth of verification depends on risk level and on the specific operational and regulatory obligations applicable to the activity conducted in Finland.

6.2. Identification data typically includes customer name, date of birth, nationality, and address details, together with verification using reliable sources and appropriate methods. Where identity documents are used, NovaWave applies authenticity checks, liveness or fraud-detection controls, and consistency verification against user-provided data.

6.3. NovaWave conducts verification of payment method ownership where relevant to mitigate the risk of third-party funding, mule activity, chargeback laundering, and unauthorized payment use. The Company also uses controls to detect unusual patterns such as rapid account creation, high-velocity deposits, multiple accounts linked to shared identifiers, and repeated failed verification attempts.

6.4. NovaWave applies ongoing due diligence throughout the relationship, updating verification where risk increases, where anomalies arise, where the customer changes key profile information, or where regulatory or internal thresholds require re-verification.

7. Enhanced due diligence, high-risk customers, and special attention cases

7.1. NovaWave applies Enhanced Due Diligence (EDD) when higher risk is identified. Higher risk may arise from customer profile indicators, unusual transaction patterns, high-risk geographies, complex payment behavior, or other red flags consistent with money laundering typologies.

7.2. EDD measures may include additional identity verification steps, request for supplementary documentation, enhanced scrutiny of source of funds information where appropriate, stricter transaction limits, delayed withdrawals pending review, and more frequent monitoring.

7.3. NovaWave also applies enhanced measures where customers are identified as politically exposed persons (PEPs) or where the relationship presents elevated corruption risk, recognizing that the risk-based approach requires proportionate enhancement of controls in such scenarios.

8. Transaction monitoring, behavioral monitoring, and typology-driven detection

8.1. NovaWave maintains transaction monitoring controls designed to detect patterns of placement, layering, and integration. Monitoring includes both automated detection logic and human review, supported by case management processes that ensure consistent documentation and timely decision-making.

8.2. Monitoring considers, among other indicators, transaction velocity, deposit-withdrawal cycles, unusually structured transactions, repeated small deposits potentially consistent with structuring, unusual funding sources, transaction reversals and chargebacks, rapid changes in customer details, abnormal device or IP switching, and repeated use of payment methods across multiple accounts.

8.3. NovaWave’s monitoring framework is updated based on evolving risk assessments and external typology guidance, including the broader Finnish and EU context that emphasizes detection, investigation support, and the role of FIUs in processing submitted reports.

8.4. Monitoring alerts are triaged and investigated using documented procedures. Investigations may result in outcomes including no action, account restriction, request for additional information, enhanced monitoring, relationship termination, or escalation for potential reporting, depending on the facts and risk.

9. Suspicious activity handling, escalation, and cooperation with Finnish authorities

9.1. NovaWave maintains internal procedures to identify, escalate, and handle suspicious activity. Suspicion can be triggered by monitoring alerts, staff observations, customer support interactions, payment anomalies, third-party intelligence, or external notifications.

9.2. Cases are escalated to qualified reviewers within the compliance function. The reviewer must assess available evidence, determine whether suspicion is reasonable, decide on risk-mitigation steps, and document the rationale. All steps must be traceable and auditable.

9.3. Where reporting is required under the applicable Finnish AML framework for the relevant activity classification, NovaWave’s procedures are designed to support reporting to the competent Finnish Financial Intelligence Unit, which processes money laundering reports in Finland.

9.4. NovaWave maintains confidentiality around suspicious activity handling and applies strict controls to prevent unauthorized disclosure, protecting both investigations and data subject rights.

10. Recordkeeping, audit trails, and evidence preservation

10.1. NovaWave retains records necessary to demonstrate the adequacy and effectiveness of its AML-CTF controls, including onboarding records, verification evidence, risk ratings, monitoring alerts, investigation files, decisions, approvals, communications related to AML-CTF reviews, and relevant transaction data.

10.2. Records are secured through access controls and technical measures designed to preserve integrity and confidentiality. Records are retained for periods required by applicable law and for as long as needed to support audits, dispute handling, regulatory inquiries, and legal claims.

10.3. NovaWave’s recordkeeping structure is designed to be consistent with risk assessment and documentation expectations embedded in the Finnish AML Act’s framework for obliged entities and supervision.

11. Training, awareness, and compliance culture

11.1. NovaWave provides periodic AML-CTF training to relevant personnel, ensuring that staff understand risks, typologies, internal escalation requirements, confidentiality obligations, and the consequences of non-compliance.

11.2. Training is documented and includes assessment mechanisms to confirm understanding, identify gaps, and improve program effectiveness. Training content is updated to reflect changes in risk and in Finland-related expectations, including the Finnish institutional setup where the FIU processes reports and supervisory authorities emphasize internal controls and risk management.

12. Independent review, testing, and continuous improvement

12.1. NovaWave conducts periodic internal reviews and, where appropriate, independent audits of the AML-CTF program to evaluate control effectiveness, alert quality, investigation consistency, recordkeeping integrity, and staff adherence.

12.2. Findings are documented, assigned to accountable owners, and tracked to closure with timelines and evidence of remediation. The program is updated to reflect lessons learned, emerging typologies, and regulatory developments.

13. Data protection, confidentiality, and lawful processing in AML-CTF operations

13.1. AML-CTF controls often require processing of personal data, including identification documents and monitoring signals. NovaWave processes such data with strict necessity and proportionality, limiting access to authorized personnel and applying security measures consistent with its privacy and information security frameworks.

13.2. AML-CTF processing is conducted in a manner designed to support both compliance and privacy by design, ensuring that only relevant data is collected, retained, and used, and that sensitive information is protected from unauthorized access.

14. Policy governance, versioning, and updates

14.1. This Policy enters into force on 26 January 2026 and is subject to review at regular intervals and whenever material changes occur in the Platform’s risk profile, Finland-related legal requirements, supervisory expectations, or operational model.

14.2. Updates require management approval and must be communicated internally to relevant stakeholders. Operational procedures and system configurations must be aligned with the most current approved version of the Policy.

GLOSSARY

Anti-Money Laundering (AML) refers to the laws, regulations, procedures, and controls designed to prevent and detect attempts to disguise the illicit origin of criminal proceeds.

Counter-Terrorist Financing (CTF) refers to the measures designed to prevent, detect, and disrupt the collection, movement, and use of funds intended to support terrorist acts, terrorist organizations, or terrorist-related activities, regardless of whether the funds originate from lawful or unlawful sources.

Money laundering refers to conduct intended to conceal, disguise, convert, transfer, or otherwise handle proceeds of crime so that the proceeds appear legitimate, often involving phases commonly described as placement, layering, and integration.

Finnish AML Act refers to the Act on Preventing Money Laundering and Terrorist Financing (444/2017), which establishes Finland’s preventive AML-CTF obligations, including risk assessment and internal control expectations for obliged entities.

Financial Intelligence Unit (FIU) refers to the authority that receives and processes money laundering reports and supports detection and investigation. In Finland, the FIU operates in connection with the National Bureau of Investigation.

Customer Due Diligence (CDD) refers to measures used to identify and verify customers and assess the risk associated with the business relationship.

Enhanced Due Diligence (EDD) refers to additional and more stringent verification and monitoring measures applied where higher risk of money laundering or terrorist financing is identified.

Politically Exposed Person (PEP) refers to an individual who holds or has held a prominent public function and who may present increased exposure to corruption-related risks, requiring enhanced scrutiny under risk-based AML-CTF controls.

Transaction monitoring refers to the systematic review and analysis of transactions and behavior to identify unusual patterns or activity consistent with money laundering, terrorist financing, fraud, or sanctions evasion.

Suspicious activity refers to conduct, transactions, or patterns that give rise to reasonable grounds to suspect money laundering, terrorist financing, or related financial crime, requiring escalation and documented review, and, where applicable, reporting consistent with the relevant AML-CTF framework.

Risk-based approach refers to allocating controls, monitoring intensity, and verification depth in proportion to identified risks, consistent with Finland’s statutory approach and EU/FATF standards.

FIN-FSA refers to the Finnish Financial Supervisory Authority, which publishes guidance and supervises AML-CTF compliance for sectors under its remit and outlines the broader Finnish AML-CTF framework and expectations on internal controls.

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