Geoblock Notice

1. Purpose of This Notice

This Geoblock Notice (this “Notice”) sets out the jurisdictional restrictions that apply to the Vimen interface at app.vimen.org (the “Interface”) and to the basket tokens minted by the Vimen protocol on Robinhood Chain (chain id 4663) (the “Basket Tokens”), the classes of persons to whom access is denied, and the manner in which those restrictions are enforced. This Notice forms part of, and is incorporated by reference into, the Terms of Use. In the event of any conflict between this Notice and the Terms of Use with respect to jurisdictional restrictions, this Notice prevails. Capitalized terms not defined here have the meanings given in the Terms of Use.

2. Definition of “US Person”

For purposes of this Notice, “US Person” has the meaning given to “U.S. person” in Rule 902(k) of Regulation S under the United States Securities Act of 1933, as amended (“Regulation S”), and includes, without limitation: (a) any natural person resident in the United States; (b) any partnership or corporation organized or incorporated under the laws of the United States; (c) any estate of which any executor or administrator is a US Person; (d) any trust of which any trustee is a US Person; (e) any agency or branch of a foreign entity located in the United States; (f) any non-discretionary account or similar account (other than an estate or trust) held by a dealer or other fiduciary for the benefit or account of a US Person; (g) any discretionary account or similar account (other than an estate or trust) held by a dealer or other fiduciary organized, incorporated, or (if an individual) resident in the United States; and (h) any partnership or corporation organized or incorporated under the laws of any foreign jurisdiction which is formed by a US Person principally for the purpose of investing in securities not registered under the Securities Act. References to the “United States” include the United States of America, its states, territories, and possessions, and the District of Columbia.

3. Restricted Persons

The Interface may not be accessed or used by, and the Basket Tokens are not offered, sold, minted to, or made available to, any of the following (each, a “Restricted Person”): (a) any US Person; (b) any person physically located in, resident in, incorporated in, or organized under the laws of the United States at the time of access; (c) any person located in, resident in, a national of, or organized under the laws of any jurisdiction subject to comprehensive sanctions administered by the United States Office of Foreign Assets Control, the United Nations Security Council, the European Union, or His Majesty’s Treasury, including, as of the date of this Notice and by way of illustration and not limitation, Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions; (d) any person named on any applicable sanctions or restricted-party list, including the OFAC Specially Designated Nationals and Blocked Persons List; (e) any person owned or controlled, directly or indirectly, by one or more persons described in (a) through (d); and (f) any person acting for the account or benefit of, or at the direction of, any person described in (a) through (e).

4. No Offer or Sale into Restricted Jurisdictions

The Basket Tokens have not been and will not be registered under the United States Securities Act of 1933 or with any securities regulatory authority of any state or other jurisdiction of the United States, and have not been approved, registered, or qualified in any other restricted jurisdiction. The Basket Tokens are not offered or sold, and will not be offered or sold, directly or indirectly, within the United States or to, or for the account or benefit of, US Persons, or within any other restricted jurisdiction. No communication on the Vimen website, in the documentation, or through any associated channel is directed at any Restricted Person, and no such communication constitutes an offer or solicitation in any jurisdiction where such an offer or solicitation would be unlawful.

5. How Enforcement Works

The restrictions in this Notice are enforced at the application layer of the Interface through a combination of measures, including: (a) IP-based geolocation, under which the apparent country or region of origin of each connection is derived from the connecting IP address and access is refused where that location corresponds to a restricted jurisdiction; (b) self-certification, under which each user is required, before transacting, to represent and certify that the user is not a Restricted Person and is not acting for the account or benefit of any Restricted Person; and (c) such additional screening measures as may be implemented from time to time, including blocking of wallet addresses identified on applicable sanctions lists. These measures operate at the Interface layer. The underlying protocol is autonomous, immutable software on a public blockchain, and no party has the ability to impose equivalent controls at the contract level; redemption of Basket Tokens, in particular, is ungated by design.

6. Circumvention Prohibited

Any attempt to circumvent the measures described in Section 5 is strictly prohibited. Without limitation, you may not: (a) use a virtual private network, proxy server, relay, Tor exit node, or any similar tool or technique to disguise or misrepresent your location for the purpose of accessing the Interface from a restricted jurisdiction; (b) provide false, misleading, or incomplete information in any self-certification; (c) access the Interface on behalf of, or relay transactions for, a Restricted Person; or (d) assist, encourage, procure, or enable any other person to do any of the foregoing.

7. Circumvention Is at Your Sole Risk; No Entitlement to Redress

Any person who circumvents or attempts to circumvent the restrictions in this Notice does so entirely at that person’s own risk. Such a person: (a) acts in material breach of the Terms of Use and of this Notice; (b) acquires no rights, entitlements, claims, or remedies of any kind against Vimen or any of its contributors, maintainers, developers, or service providers, whether in respect of losses, frozen or restricted assets, inaccessible tokens, or otherwise; (c) shall not be entitled to any redress, compensation, restitution, or assistance in respect of any consequence of such circumvention; and (d) bears sole responsibility for any violation of Applicable Law resulting from such circumvention, including securities and sanctions laws, and shall indemnify the indemnified parties identified in the Terms of Use against any resulting claims.

8. Representations on Each Access

Each time you access the Interface, and each time you submit a transaction through it, you represent, warrant, and covenant that: (a) you are not a Restricted Person; (b) you are not accessing the Interface from a restricted jurisdiction; (c) you are not using any tool or technique to disguise your location; (d) you are acting solely for your own account and not for the account or benefit of any Restricted Person; and (e) all information provided in any self-certification is true, accurate, and complete. These representations are deemed repeated on each access and each transaction and survive the termination of your access to the Interface.

9. Relationship to Underlying Stock Token Restrictions

The Basket Tokens are backed by tokenized Stock Tokens issued by Robinhood Assets (Jersey) Ltd. Those Stock Tokens are debt instruments of their issuer and are themselves subject to the issuer’s own terms, transfer restrictions, eligibility requirements, and jurisdictional limitations, which are independent of, and in addition to, the restrictions in this Notice. The issuer’s restrictions may be broader or narrower than ours, may change without notice to us, and may be enforced by the issuer through its own technical or legal means, potentially including the freezing or restriction of Stock Tokens held by protocol contracts. Compliance with this Notice does not constitute, and must not be relied upon as, compliance with the issuer’s restrictions, and holders of Basket Tokens bear the full risk of issuer-level restrictions as described in the Terms of Use.

10. No Reliance; No Waiver

The operation, availability, or accessibility of the Interface from any location at any time shall not be construed as a representation that access from that location is permitted, as an offer into that location, or as a waiver of any restriction in this Notice. Any failure of the geolocation or certification measures to detect or block a given access attempt is a technical limitation, not a permission, and does not create any estoppel, course of dealing, or entitlement. We reserve the right to block, suspend, or terminate access by any person at any time, without notice and without liability.

11. Changes to the Restricted Jurisdictions

The list of restricted and sanctioned jurisdictions is subject to change as sanctions regimes, regulatory guidance, and legal assessments evolve. We may add or remove jurisdictions, adjust enforcement measures, and update this Notice at any time by posting a revised version with an updated “Last updated” date. It is your responsibility to review this Notice before each use of the Interface. Continued use after a revision constitutes acceptance of the revised Notice.

12. Severability and Interpretation

If any provision of this Notice is held invalid or unenforceable in any jurisdiction, that provision shall be enforced to the maximum extent permissible, the remaining provisions shall remain in full force, and the invalidity shall not affect the application of this Notice in any other jurisdiction. Headings are for convenience only. The words “include” and “including” are to be read as followed by “without limitation.”

13. Contact

Questions about this Notice, including questions from persons uncertain of their status under Section 2 or Section 3, may be directed to @vimenprotocol on X. Nothing in any response constitutes legal advice, and you remain solely responsible for determining your own status under Applicable Law.