Governance & Regulatory Framework

Updated 15/07/2025

The operations and services provided through the platform are governed by a multi-entity structure, ensuring compliance with applicable financial regulations across jurisdictions and maintaining transparency in responsibility allocation.

1. Platform Governance

The mobile application and its associated technology infrastructure are developed and operated by RVFINGROUP Pte Ltd (UEN: 202339456H), a Singapore-based company specializing in technology and marketing services.

2. Infrastructure and API Services

The core infrastructure and API layer of the platform is provided by Aerapass Pte Ltd (Registration No.: 201816520G). This entity is responsible for enabling backend functionality and secure connectivity across various service modules. By interacting with features powered by Aerapass APIs, users are subject to Aerapass Pte Ltd’s Terms of Use and Privacy Policy.

3. Virtual Asset (Cryptocurrency) Services

All services related to virtual assets, including exchange functionality and wallet operations, are provided by RVFINGROUP sp. z o.o. (Registration No.: 0001116929), a licensed Virtual Asset Service Provider (VASP) registered in Poland under license number RDWW-1428.

This entity is responsible for:

• Customer onboarding for crypto services

• Implementation of Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures

• Ensuring compliance with Polish and EU virtual asset regulations

Use of virtual asset services constitutes acceptance of RVFINGROUP sp. z o.o.’s Terms of Use and Privacy Policy.

4. Fiat Services and Payment Infrastructure

Fiat-related operations, including payment card issuance, account top-ups, and transaction handling, are carried out by Aerapass sp. z o.o. (Registration No.: 0001120590). Aerapass is a regulated Virtual Asset Service Provider under the supervision of the Polish Financial Supervision Authority (KNF).

Key responsibilities include:

• Managing fiat payment flows

• Conducting AML/KYC checks in line with EU directives

• Coordinating with licensed partners for card issuing and transaction processing

5. Card Issuance and Financial Institution Partnership

Payment cards are issued in collaboration with Quicko Sp. z o.o. (KRS: 0000350151, NIP: 5213540295, REGON: 142004870), a licensed payment institution in Poland.

This card program is operated jointly with Aerapass sp. z o.o., which ensures secure card issuance and compliance with all regulatory obligations.

Card activation and usage are subject to Quicko Sp. z o.o.’s Terms of Use and Privacy Policy.