Cleva Technologies Inc. (“Cleva”, “We”, “Our”) is a technology platform that enables Users to operate a USD wallet, convert and transfer USD to their local currency account, and use a dollar card for online purchases (collectively, "Services"). To encourage and reward a savings culture, Cleva has introduced the Cleva Pots feature (“Cleva Pots”), which allows users to save or set aside funds from their USD wallet into designated virtual wallets. This Cleva Pots Policy ("Policy") governs the use of the Cleva Pots feature and sets out the applicable terms, conditions, and processes related to eligibility, access, and management of Cleva Pots. By using the Cleva Pots feature, you confirm that you have reviewed this Policy. We encourage you to read it to understand your rights and obligations. By accessing the platform and clicking 'I Agree,' you confirm that you have reviewed this Policy and accept its terms and conditions.

We may make changes to this Policy from time to time and when we do, we may notify you through your registered email address on the Platform of the revisions made to this Policy. However, you understand that this may not always be practicable and when that occurs, you agree to waive your right to notification. It is your responsibility to review this Policy frequently and to stay informed of all changes which may be made to it. By using our services after a revision has been made to this Policy, you consent to be bound by the changes we made.

The following words shall have the meaning assigned to them in this Policy:

3.1

“AML/CFT/CPF” means anti-money laundering, counter-terrorism financing, counter-proliferation financing, sanctions compliance, and any related financial crime prevention laws, regulations, and regulatory guidance applicable to Cleva or our Licensed Partners.

3.2

“Business Day” means any day other than a Saturday, Sunday, or public holiday in the jurisdiction of our Licensed Partners.

3.3

“Cleva” means Cleva Technologies Inc., the technology platform operator providing the digital interface for the Cleva Pots feature.

3.4

“Cleva Platform” means the web and/or mobile application operated by Cleva through which Users access their USD wallet and the Cleva Pots feature.

3.5

“Customer” or “User” means any individual or business entity that has successfully completed Cleva’s onboarding requirements, who operates a Cleva wallet and is authorised to use the Cleva Pots feature.

3.6

“Cleva Account” or “Cleva USD Account” or “Cleva USD Wallet” means the primary USD-denominated wallet made available to a User on the Cleva Platform from which funds may be transferred into Cleva Pots.

3.7

“Cleva Pots” means the digital savings wallet within the User’s Cleva wallet on the Cleva Platform that allows Users to allocate funds from their Cleva USD Wallet for savings and Cleva rewards.

3.8

“Fraudulent Activities” means any actions that violate Cleva’s policies, including but not limited to unauthorized transactions, abuse or misuse of Cleva Pots, or any attempts to manipulate the savings feature for illicit purposes. This also includes transactions flagged by Cleva, Cleva’s Licensed Partners, or other monitoring systems as suspicious or fraudulent. Fraudulent activities may include any action which involves the exploitation of loopholes within the Cleva platform.

3.9

“Licensed Partners” means the licensed financial institution engaged by Cleva to provide custody, funds management, and settlement services in respect of funds allocated to the Cleva Pots.

3.10

“Reward” means the returns accrued on funds held in the Cleva Pots, credited to Customers in accordance with this Policy.

3.11

“Reward Rate” means the rate used to calculate Rewards on balances held in the Cleva Pots, as disclosed and reviewed from time to time.

3.12

“Segregated Account” means a designated account held with our Licensed Partners in which Customer funds allocated to the Cleva Pots are held separately from Cleva’s operational funds.

3.13

“US Treasury-Backed Instruments” means United States government treasury securities and any other investment instruments, whether low-risk or otherwise, administered by our Licensed Partners in accordance with its regulatory authorisation.

The following words shall have the meaning assigned to them in this Policy:

4.1

Cleva Pots is a non-custodial feature operated by Cleva solely as a technology provider. All customer funds allocated to Cleva Pots are held in segregated accounts with our licensed partners. Cleva does not hold customer funds in its own name.

4.2

Funds allocated to Cleva Pots are placed by our licensed partners into US Treasury-backed instruments or other comparable low-risk assets, in accordance with our Licensed Partners’s regulatory authorization and internal investment mandate.

4.3

Cleva does not act as an investment adviser, asset manager, custodian, or deposit-taking institution. Our role is limited to providing the technology interface through which Users access, view, and manage the Cleva Pots feature.

4.4

Cleva Pots does not constitute a bank account, investment product, fixed deposit, or insured deposit product. Funds allocated to Cleva Pots are not insured, except to the extent expressly stated by our Licensed Partners.

5.1

Funds are first credited to the User’s main Cleva USD wallet.

5.2

Users may then transfer a portion or all of their USD wallet balance into their Cleva Pots wallet through the Cleva platform. Third-party deposits directly into a User’s Cleva Pots wallet are not permitted.

5.3

Upon successful transfer the transferred amount transfer is reflected in the User’s Cleva Pots; and

5.4

Returns begin to accrue one (1) day after funds are successfully transferred into the Cleva Pots.

5.5

Users may withdraw funds from their Cleva Pots to their main USD wallet at any time, subject to internal processing timelines and applicable compliance review. From the main wallet, Users may transfer funds to authorised external accounts in accordance with our Terms of Service.

6.1

Balances allocated to Cleva Pots earn returns accrued on the underlying assets held by our licensed partners.

6.2

Returns accrue daily and are credited into the User’s wallet on a monthly basis. Any monthly reward amount below the minimum specified amount on the Cleva Platform will be rolled over and added to the subsequent month’s accrual.

6.3

We credit all returns monthly into the User’s Cleva Pots balance.

6.4

The standard reward rate for Cleva Pots is up to the percentage disclosed on the Cleva Platform calculated on a per-annum basis for USD-denominated balances.

6.5

We may review and adjust reward rates from time to time based on market conditions, arrangements with our licensed partners, regulatory requirements, or operational considerations. We do not guarantee any minimum return, fixed yield, or the continued availability of any reward rate.

6.6

We apply internal controls and reconciliation processes to all reward calculations. Where an error occurs, We reserve the right to correct the affected reward calculations.

7.1

The Cleva Pots wallet is available exclusively to Users who maintain verified and active accounts on the Cleva platform. Cleva governs access to the Cleva Pots wallet through defined eligibility criteria, compliance obligations, and internal standards.

7.2

Continued access to the feature depends on compliance with these Terms, Cleva’s general Terms of Service, and all applicable laws and regulatory requirements.

7.3

We may suspend, restrict, or revoke access to Cleva Pots where necessary for regulatory compliance, risk management, fraud prevention, or other compliance-related purposes.

7.4

We apply a risk-based approach to customer eligibility and verification, ensuring access to Cleva Pots for only Users who meet our verification and compliance standards. These standards cover identity verification, account status, and adherence to applicable legal and regulatory requirements. Users with restricted, suspended, or non-compliant accounts shall not have access to Cleva Pots.

7.5

We rely on the completeness and accuracy of information collected during onboarding in line with our KYC requirements.

7.6

We reserve the right to amend eligibility criteria, impose restrictions, or suspend access to Cleva Pots as necessary to maintain regulatory compliance, manage risk, protect the platform, and safeguard the interests of Users, partners, and other stakeholders.

8.1

All transactions conducted through the Cleva Pots are subject to applicable anti-money laundering, counter-terrorism financing, counter-proliferation financing, and sanctions laws.

8.2

Cleva and our Licensed Partners may monitor, review, delay, block, or report transactions where required to comply with legal or regulatory obligations.

8.3

Users agree to provide accurate and complete information and to cooperate with any compliance reviews, verification requests, or inquiries relating to their use of the feature.

9.1

While funds are placed in US Treasury-backed instruments or similar low-risk assets, all financial products carry some level of risk.

9.2

Cleva shall not be responsible for investment performance of our Licensed Partners, market fluctuations affecting underlying assets; or regulatory actions impacting the structure or availability of Cleva Pots.

9.3

Users acknowledge that returns are not guaranteed and may vary from time to time.

10.1

Cleva is committed to safeguarding the personal and financial data of all Cleva Pots Users. Protecting customer information is integral to our operations and central to maintaining trust with customers, partners, and regulators. We operate in line with applicable laws and other relevant international standards.

10.2

We collect and process customer data strictly for purposes related to the operation of Cleva Pots, including account management, transaction processing, reward calculation, compliance monitoring, and reporting obligations. All data collected is proportionate, accurate, and relevant to our processing as outlined in our Privacy Notice.

10.3

We maintain technical and organizational measures to protect customer data against unauthorized access, disclosure, alteration, or destruction. Access to personal data is restricted based on roles and responsibilities, and all employees and contractors are required to adhere to strict confidentiality obligations.

10.4

We uphold customers’ rights regarding their personal data, including access, correction, and deletion requests, in line with applicable law. Requests are processed promptly, transparently, and in a manner that safeguards both customer and company interests.

11.1

All Cleva Pots Users have access to fair, transparent, and efficient mechanisms for raising concerns, resolving complaints, and addressing disputes.

11.2

We maintain multiple channels through which customers can submit complaints, including in-app reporting, email, and designated customer support lines. All complaints are acknowledged promptly, with timelines for investigation and resolution clearly communicated to the customer.

11.3

Where complaints involve our Licensed Partners or third-party service providers, We coordinate resolution in line with contractual agreements and compliance obligations.

12.1

Users must comply with all applicable laws and regulations and must not engage in any fraudulent, deceptive, or abusive practices. As players in the financial services industry, we uphold stringent measures to prevent the misuse of our services for fraudulent purposes such as money laundering, terrorism financing, proliferation financing, and other unlawful activities.

12.2

We will carry out comprehensive Customer Due Diligence (CDD) procedures to ensure compliance with Anti-Money Laundering (AML) and Countering Financing Terrorism (CFT) laws and regulations.

12.3

Additionally, we retain transaction records as required by law and to support law enforcement agencies during investigations where required.

We will not be liable for any damages, losses, or expenses arising out of or related to the Cleva Pots, including but not limited to the inability to access rewards or any technical issues related to the Cleva Pots.

You are solely responsible for any taxes, fees, or charges that may apply to the rewards you earn on the Cleva Pots. We may however, at our discretion, withhold or deduct any applicable taxes from rewards earned within the Cleva Pots, where required by applicable law.

This policy shall be governed and construed in accordance with the laws of the State of Delaware, United States.

If you have any questions, requests, or concerns regarding this Policy, please contact us atcontact@getcleva.com.