CALIFORNIA DIGITAL FINANCIAL ASSET DISCLOSURE STATEMENT AND ACKNOWLEDGMENT

Effective Date: July 1, 2026

This California Digital Financial Asset Disclosure Statement and Acknowledgment (this "Disclosure Statement") is provided by Stillman Digital Inc., a Wyoming corporation with a business address at 1603 Capitol Ave, Unit 402A, Cheyenne, WY 82001 ("Stillman Digital," "Stillman," "we," "us," or "our"), to each California resident customer, counterparty, authorized user, or other person to whom Stillman Digital provides digital financial asset business activity within the meaning of the California Digital Financial Assets Law.

This Disclosure Statement is intended to be provided separately from Stillman Digital's Digital Asset Purchase, Sale & Custody Agreement, Terms of Use, Fee Schedule, Privacy Policy, trade confirmations, account statements, and other customer-facing materials. It is intended to describe, in a clear and conspicuous manner, certain disclosures required under California Financial Code Section 3501 and related provisions of the California Digital Financial Assets Law.

This Disclosure Statement does not replace the Digital Asset Purchase, Sale & Custody Agreement or any applicable trade confirmation, fee schedule, account documentation, onboarding documentation, custody terms, or written instructions between you and Stillman Digital. If any term of this Disclosure Statement is inconsistent with a mandatory requirement of applicable California law, California law will control solely to the extent required.

1. Covered Services

Stillman Digital provides spot digital asset over-the-counter trading, clearing, settlement, and custody-related services to eligible customers. Stillman Digital generally operates as a principal OTC trading desk. This means that, unless otherwise agreed in writing, trades are bilateral transactions between you and Stillman Digital. Stillman Digital does not operate a public order book, does not provide direct market access to an exchange, and does not act as your financial, investment, tax, legal, or trading adviser.

Depending on the services approved for your account and made available by Stillman Digital from time to time, Stillman Digital may provide some or all of the following services:

(a) bilateral purchase and sale of supported digital assets;

(b) spot OTC trade execution;

(c) clearing and settlement of digital asset transactions;

(d) custody or hosted-wallet services for supported digital assets;

(e) receipt and transfer of fiat currency in connection with supported digital asset transactions;

(f) trade settlement facilitation involving approved liquidity providers, custodians, exchanges, trading venues, banking partners, or other third-party service providers;

(g) account access through approved communication channels, web-based interfaces, APIs, or other systems maintained or authorized by Stillman Digital; and

(h) related reporting, balance, transaction-history, reconciliation, and support functions.

Stillman Digital may determine, in its sole discretion and subject to applicable law, which digital assets, fiat currencies, transaction types, settlement methods, communication channels, order types, custody arrangements, and customer types it supports. Stillman Digital may decline, suspend, restrict, reverse, correct, block, or delay any transaction or service where it determines that doing so is required or advisable for legal, regulatory, sanctions, anti-money laundering, fraud prevention, market integrity, operational, security, risk management, or customer-protection reasons.

2. Fees and Charges

Stillman Digital may assess fees, charges, spreads, commissions, custody-related fees, transaction fees, network fees, wire fees, banking fees, third-party fees, withdrawal fees, settlement fees, or other charges in connection with its services.

Fees may be set forth in one or more of the following places:

(a) the applicable fee schedule;

(b) the price quote provided to you before execution;

(c) the confirmation of execution;

(d) the trade confirmation;

(e) your account interface or transaction history;

(f) written communications between you and Stillman Digital; or

(g) other applicable service documentation.

For each executed trade request, fees may be assessed at the time you place the trade request, at execution, at settlement, upon withdrawal, or at another time disclosed to you. Fees may be determined by a combination of factors, including transaction size, historic trading volume, assets held in your account, liquidity, volatility, market conditions, asset type, settlement timing, settlement method, third-party costs, and any negotiated or account-specific pricing terms.

Stillman Digital may include its commission, spread, markup, markdown, or other compensation in the price quote, or may disclose fees separately. The estimated applicable fees may be included in the confirmation of execution, and the actual applicable fees will be disclosed in the trade confirmation, transaction record, account history, or other applicable record provided to you.

Stillman Digital will provide at least 14 days' prior notice before making a change to its fee schedule, terms and conditions, or policies applicable to your account if the change has a material impact on digital financial asset business activity with you, unless a shorter period is required or permitted by applicable law or the change is necessary due to exigent legal, regulatory, security, operational, market, or risk-management circumstances.

3. Insurance, Government Guarantees, and Asset Protection

3.1 Digital Assets Are Not Government-Insured

Digital assets held, purchased, sold, transferred, exchanged, or stored through Stillman Digital are not legal tender and are not insured or guaranteed by the Federal Deposit Insurance Corporation, the National Credit Union Share Insurance Fund, the Securities Investor Protection Corporation, the State of California, the United States, or any other governmental agency.

Digital assets may lose some or all of their value. Stillman Digital does not guarantee the value, liquidity, availability, marketability, transferability, or redeemability of any digital asset.

3.2 Client Cash

Where Stillman Digital holds client cash, Stillman Digital may hold such cash in one or more omnibus accounts or segregated client accounts at insured depository institutions, banking partners, trading venues, liquidity providers, or other approved service providers. Stillman Digital may maintain books and records designed to identify customer interests and, where applicable, to support pass-through deposit insurance treatment for eligible fiat balances.

However, Stillman Digital does not guarantee that pass-through FDIC insurance or any other deposit insurance will apply to client cash. Availability of any such coverage may depend on applicable law, account titling, account records, bank records, customer eligibility, deposit insurance limits, the conduct and records of third parties, and other factors outside Stillman Digital's control.

3.3 Private Insurance

Stillman Digital may, from time to time, make available private insurance, asset-protection, transaction-screening, disaster-recovery, or similar services through third-party providers, including coverage or services intended to address certain theft, cybertheft, compromised-address, key-recovery, or disaster-recovery risks.

Any such coverage is subject to the applicable provider's policy terms, limits, exclusions, conditions, deductibles, claims procedures, underwriting requirements, coverage triggers, and availability. Unless Stillman Digital expressly confirms otherwise in writing for your account or transaction, no private insurance coverage should be assumed to apply to your digital assets, fiat currency, transaction, custody arrangement, withdrawal, transfer, or account.

Upon your request, Stillman Digital will provide available terms of any applicable private insurance policy or coverage arrangement in a manner reasonably designed to allow you to understand the specific insured risks, exclusions, and limitations that may affect partial or full coverage of your assets.

4. Irrevocability of Transfers and Exchanges

Digital asset transfers and blockchain transactions are generally irreversible once initiated, broadcast, confirmed, or otherwise accepted by the applicable digital asset network. If you send digital assets to an incorrect address, incompatible wallet, unsupported network, non-whitelisted address, sanctioned address, compromised address, or unintended recipient, Stillman Digital may be unable to reverse, cancel, recover, or retrieve the assets.

A transaction may also become irrevocable before the applicable asset or fiat currency is received by the intended recipient, depending on the applicable network, bank, liquidity provider, trading venue, custodian, settlement process, or other third-party system.

Notwithstanding the foregoing, Stillman Digital may have contractual or operational rights to void, correct, re-price, reverse, cancel, block, delay, or claw back a transaction or transfer in certain circumstances. These circumstances may include pricing errors, execution errors, routing errors, settlement errors, duplicate settlement, erroneous delivery, network replay, chain reorganizations, network congestion, exchange outages, clearly erroneous prints, compliance restrictions, sanctions concerns, fraud alerts, suspicious activity, regulatory instructions, legal process, or unauthorized or mistaken transfers. The existence of these rights does not guarantee that Stillman Digital will be able to reverse or recover any transaction or transfer.

5. Unauthorized, Mistaken, or Accidental Transfers or Exchanges

5.1 Stillman Digital's Liability

Stillman Digital's liability for an unauthorized, mistaken, or accidental transfer or exchange is governed by the Digital Asset Purchase, Sale & Custody Agreement, the applicable trade confirmation, any applicable custody terms, this Disclosure Statement, and applicable law.

Subject to applicable law, Stillman Digital is not responsible for losses arising from:

(a) your mistaken, inaccurate, incomplete, unauthorized, or fraudulent instructions;

(b) instructions submitted by an authorized user or person appearing to have authority over your account;

(c) your failure to maintain accurate account, wallet, banking, contact, or authorized-user information;

(d) your transfer of digital assets to an incorrect, unsupported, incompatible, compromised, non-whitelisted, or unintended wallet address;

(e) your loss, compromise, or misuse of private keys, credentials, passwords, devices, accounts, communication channels, wallets, or banking access before assets are transferred into Stillman Digital's custody;

(f) network congestion, chain reorganizations, protocol failures, forks, validator issues, smart contract errors, node failures, exchange outages, market disruption events, or third-party system failures;

(g) actions or omissions of exchanges, custodians, wallet technology providers, banking partners, liquidity providers, compliance vendors, communication platforms, or other third parties, except to the extent liability cannot be disclaimed under applicable law;

(h) your failure to notify Stillman Digital promptly after discovering a suspected unauthorized, mistaken, or accidental transfer or exchange;

(i) market movement, slippage, liquidity conditions, volatility, timing differences, or changes in asset value; or

(j) legal, regulatory, sanctions, law-enforcement, court-ordered, or compliance-related holds, freezes, delays, rejections, or restrictions.

The foregoing does not limit any express custodial obligation that Stillman Digital has accepted under a signed agreement with you, and does not limit any non-waivable right or remedy you may have under applicable law.

5.2 Your Responsibility to Provide Notice

You must notify Stillman Digital immediately if you believe that any transfer, exchange, withdrawal, deposit, trade request, trade confirmation, account activity, authorized-user activity, wallet address, bank account, or communication is unauthorized, mistaken, accidental, fraudulent, incorrect, or otherwise in error.

Notice should be provided through one or more of the following methods:

Email: [email protected]

Toll-Free Telephone: 305-413-9706

Your notice should include, to the extent available:

(a) your name and account identifier;

(b) the relevant transaction ID, trade confirmation, wallet address, bank account, or blockchain hash;

(c) the date, time, asset, amount, and value of the transaction;

(d) a description of why you believe the transfer or exchange was unauthorized, mistaken, accidental, fraudulent, or otherwise in error;

(e) copies of any relevant communications, confirmations, screenshots, or records; and

(f) current contact information where Stillman Digital may reach you.

Failure to provide prompt, complete, and accurate notice may reduce the likelihood that Stillman Digital can investigate, stop, reverse, recover, correct, or mitigate the transaction or any related loss.

5.3 Basis for Any Recovery

Any recovery from Stillman Digital in connection with an unauthorized, mistaken, or accidental transfer or exchange will be determined under the applicable agreement, applicable trade confirmation, custody terms, this Disclosure Statement, and applicable law.

Stillman Digital does not guarantee recovery of digital assets or fiat currency sent to an incorrect address, wrong account, unauthorized recipient, unsupported network, third-party wallet, liquidity provider, trading venue, or bank. Where Stillman Digital determines that an error occurred, Stillman Digital may, in its discretion and subject to applicable law, attempt to correct the error by canceling, re-pricing, reversing, voiding, clawing back, setting off, crediting, debiting, or otherwise adjusting the affected transaction or account.

Recovery may be unavailable, partial, delayed, or subject to third-party cooperation, network functionality, asset availability, regulatory restrictions, insurance terms, legal process, or other limitations.

5.4 Error Resolution Process

Stillman Digital will review notices of unauthorized, mistaken, or accidental transfers or exchanges using commercially reasonable procedures appropriate to the nature of the issue. Stillman Digital may request additional information, documentation, verification, or instructions from you before taking action.

Stillman Digital may decline to process or may delay any request that it reasonably believes is incomplete, inaccurate, fraudulent, suspicious, unauthorized, prohibited by law, inconsistent with compliance obligations, or likely to cause harm to Stillman Digital, you, another customer, or a third party.

6. Updating Contact Information

You are responsible for keeping your contact information, authorized-user information, wallet addresses, bank account information, settlement instructions, and communication channels accurate and current.

You may update your contact information by contacting Stillman Digital through:

Email: [email protected]

Mailing Address: Stillman Digital Inc., 1603 Capitol Ave, Unit 402A, Cheyenne, WY 82001

Stillman Digital may require additional verification before accepting changes to contact information, authorized-user information, bank account information, wallet addresses, whitelisted addresses, or settlement instructions.

7. Timing of Transfers, Exchanges, Debits, Credits, and Settlement

The date or time when you initiate an instruction to make a transfer or exchange may differ from the date or time when:

(a) Stillman Digital receives the instruction;

(b) Stillman Digital provides a price quote;

(c) you accept the price quote;

(d) Stillman Digital confirms execution;

(e) your account is debited;

(f) your account is credited;

(g) the applicable bank, custodian, wallet provider, trading venue, liquidity provider, or digital asset network processes the transaction;

(h) a blockchain transaction is broadcast, pending, confirmed, final, or irreversible;

(i) settlement occurs; or

(j) the transaction appears in your transaction history, account statement, trade confirmation, or other record.

Timing may be affected by business hours, banking hours, blockchain confirmation times, network congestion, liquidity availability, transaction screening, sanctions review, anti-money laundering review, fraud controls, whitelisting procedures, third-party delays, outages, market conditions, order size, asset type, settlement method, and other operational or compliance factors.

8. Stop-Payment Rights and Revocation of Authorization

Digital asset transfers and exchanges are generally not subject to traditional stop-payment rights once initiated, executed, broadcast, confirmed, or settled.

Unless Stillman Digital expressly agrees otherwise in writing, you generally do not have a right to stop payment, revoke authorization, cancel, reverse, or modify a transaction after:

(a) you accept a price quote and Stillman Digital confirms execution;

(b) Stillman Digital debits your account;

(c) Stillman Digital credits your account;

(d) Stillman Digital initiates settlement;

(e) a blockchain transfer is broadcast or confirmed;

(f) fiat funds are released to a bank, payment provider, liquidity provider, or other third party; or

(g) the applicable transfer or exchange otherwise becomes irrevocable.

If you have authorized a future, recurring, or preauthorized transfer, you may revoke that authorization only by providing written notice to Stillman Digital in the manner specified in the applicable agreement or authorization, and sufficiently in advance of the scheduled transfer for Stillman Digital to act on the request. Unless otherwise required by applicable law, Stillman Digital may require at least three business days' advance notice to process a stop-payment or revocation request for a future or preauthorized transfer.

Stillman Digital may reject any stop-payment, revocation, cancellation, or reversal request where the transaction has already been executed, settled, broadcast, confirmed, processed, or otherwise become irreversible, or where honoring the request would violate applicable law, create legal or compliance risk, or conflict with Stillman Digital's contractual or operational obligations.

9. Receipts, Trade Tickets, Confirmations, and Transaction Records

You have the right to receive a receipt, trade ticket, trade confirmation, transaction record, account statement, or other evidence of each transfer or exchange, as applicable.

For each executed transaction, Stillman Digital will provide a trade confirmation, transaction confirmation, account-history entry, downloadable record, or other written or electronic record containing information appropriate to the transaction. Such record may include:

(a) the name and contact information of Stillman Digital;

(b) Stillman Digital's toll-free telephone number;

(c) the type of transaction;

(d) the digital asset, fiat currency, or other asset involved;

(e) the value, date, precise time, and amount of the transaction;

(f) the price quote or execution price, if applicable;

(g) the payment amount or settlement amount, if applicable;

(h) the fees charged for the transaction, including conversion charges, indirect charges, network fees, transaction fees, commissions, spreads, markups, markdowns, or other applicable fees;

(i) applicable wallet addresses, bank accounts, settlement instructions, blockchain transaction IDs, or reference numbers, where appropriate;

(j) the settlement date or expected settlement date, where applicable; and

(k) any other information Stillman Digital determines to include or is required to provide by applicable law.

Stillman Digital may provide confirmations electronically, including through email, account statements, account dashboards, APIs, downloadable reports, secure communications, or transaction-history records. You should download and retain copies of all confirmations and transaction records.

10. Material Changes; Right to 14 Days' Prior Notice

You have the right to receive at least 14 days' prior notice of any change to Stillman Digital's fee schedule, terms and conditions, or policies applicable to your account if the change has a material impact on digital financial asset business activity with you.

Stillman Digital may provide notice through email, account notice, secure message, website posting, account portal, updated disclosure, updated fee schedule, amendment to applicable terms, or another written or electronic record.

Stillman Digital may implement changes on shorter notice where required or permitted by applicable law, where the change is beneficial to you, where the change is necessary to address an emergency, fraud risk, security risk, market disruption, legal or regulatory requirement, sanctions issue, third-party service interruption, unsupported asset, network issue, or other exigent circumstance, or where you separately agree to the change.

11. Digital Assets Are Not Legal Tender

No digital financial asset is currently recognized as legal tender by the State of California or the United States.

Digital assets are not issued or guaranteed by the State of California or the United States. The value of digital assets may fluctuate significantly, and you may lose the entire value of digital assets that you buy, sell, transfer, exchange, or store through Stillman Digital.

12. Service Outages Affecting 10,000 or More Customers

During the 12 months preceding the effective date of this Disclosure Statement, Stillman Digital has identified the following instances, if any, in which Stillman Digital's service was unavailable to 10,000 or more customers seeking to engage in digital financial asset business activity due to a service outage on the part of Stillman Digital:

No Reportable Outages: Stillman Digital has not identified any such reportable service outage during the prior 12 months.

13. Custody, Omnibus Holdings, Segregation, and Third-Party Providers

Where Stillman Digital provides custody services, Stillman Digital may hold supported digital assets using one or more wallets, vaults, omnibus wallets, client-specific vaults, third-party custody technology platforms, exchanges, trading venues, liquidity providers, or other approved service providers.

Stillman Digital currently uses third-party wallet and custody technology providers, including Fireblocks Ltd., to support the storage, transfer, and security of certain digital assets. Stillman Digital may change, add, or remove custody technology providers, wallet providers, exchanges, liquidity providers, banking partners, or other third-party service providers from time to time.

Assets may be held in omnibus arrangements or in client-specific custody arrangements, depending on the account type, asset, service, transaction, and operational requirements. In an omnibus arrangement, your interest may be reflected on Stillman Digital's books and records rather than through an identifiable claim to a specific on-chain asset unit. Stillman Digital may maintain internal ledgers and reconciliation records designed to identify customer interests and distinguish customer assets from Stillman Digital's own assets.

Stillman Digital may hold customer assets on a fully backed basis as provided in the applicable agreement, but digital asset custody remains subject to technological, operational, cybersecurity, legal, insolvency, third-party, and market risks. Digital assets held through a third-party technology platform, exchange, liquidity provider, or trading venue may be subject to the acts, omissions, insolvency, outages, restrictions, rules, records, or failures of those third parties.

14. Risks of Digital Financial Asset Activity

Digital financial asset activity involves significant risks. You should carefully consider whether digital asset trading, custody, transfer, exchange, or settlement activity is appropriate for you.

Material risks include, without limitation:

(a) market volatility and loss of value;

(b) lack of legal tender status;

(c) lack of government insurance for digital assets;

(d) liquidity risk;

(e) settlement risk;

(f) network congestion, forks, chain reorganizations, validator issues, protocol failures, smart contract bugs, or other distributed-ledger risks;

(g) irreversible transfers;

(h) incorrect, unsupported, incompatible, or compromised wallet addresses;

(i) loss, theft, or compromise of private keys, credentials, accounts, devices, or communication channels;

(j) cyberattacks, hacking, malware, phishing, social engineering, or unauthorized access;

(k) delays, outages, or failures involving Stillman Digital, a bank, a custodian, a wallet technology provider, a liquidity provider, a trading venue, a blockchain analytics provider, a compliance vendor, or another third party;

(l) regulatory uncertainty and changes in law;

(m) sanctions, anti-money laundering, law-enforcement, tax, and reporting restrictions;

(n) insolvency or credit risk of Stillman Digital or a third party;

(o) errors in communication, trade requests, order handling, trade confirmations, settlement instructions, or account records;

(p) algorithmic execution, API, latency, data, pricing, or connectivity risks;

(q) conflicts of interest, including those arising from Stillman Digital acting as principal; and

(r) the possibility that audits, attestations, internal ledgers, or reconciliations may be delayed, inaccurate, incomplete, or subject to assumptions.

Stillman Digital does not provide investment, legal, tax, accounting, trading, financial, fiduciary, or other advisory services. You are solely responsible for determining whether any digital asset transaction, custody arrangement, transfer, or exchange is appropriate for you.

15. Compliance Holds, Blocking, Rejection, and Reporting

Stillman Digital may delay, reject, cancel, reverse, freeze, block, restrict, or report any transaction, account, asset, wallet address, bank account, transfer, withdrawal, deposit, or customer relationship where Stillman Digital determines, in good faith, that doing so is appropriate or required for sanctions, anti-money laundering, fraud prevention, counter-terrorist financing, market integrity, cybersecurity, regulatory, legal, risk-management, law-enforcement, tax, or other compliance reasons.

Stillman Digital may request additional information, documentation, source-of-funds information, source-of-wealth information, beneficial ownership information, wallet information, transaction details, tax documentation, or other records from you. Failure to provide requested information may result in delayed, restricted, rejected, frozen, blocked, or terminated services.

Stillman Digital may disclose information to regulators, law-enforcement authorities, banking partners, custodians, liquidity providers, exchanges, compliance vendors, affiliates, or other third parties where permitted or required by applicable law or by Stillman Digital's agreements.

16. Customer Acknowledgment

By checking the acknowledgment box presented with this Disclosure Statement, you acknowledge and agree that:

(a) you received this Disclosure Statement separately from Stillman Digital's other terms, policies, and disclosures;

(b) you were provided this Disclosure Statement electronically in a form that you may download, print, and keep;

(c) you understand that digital assets are not legal tender and are not government-insured;

(d) you understand that digital asset transfers and exchanges may be irreversible;

(e) you understand that Stillman Digital's fees and charges may vary based on the transaction, account, asset, liquidity, volatility, settlement method, and other factors;

(f) you understand that Stillman Digital may use third-party providers, including custody technology providers, banks, trading venues, liquidity providers, exchanges, analytics providers, and compliance vendors;

(g) you understand your obligation to provide prompt notice of any suspected unauthorized, mistaken, or accidental transfer or exchange;

(h) you understand that recovery may be unavailable, partial, delayed, or subject to contractual, legal, operational, network, third-party, or insurance limitations;

(i) you understand that you have the right to receive a trade confirmation, receipt, trade ticket, transaction record, or other evidence of each transfer or exchange;

(j) you understand that you have the right to receive at least 14 days' prior notice of material changes to Stillman Digital's fee schedule, terms and conditions, or account policies, subject to applicable law and exigent circumstances; and

(k) you have had the opportunity to download, print, save, and review this Disclosure Statement before engaging in digital financial asset business activity with Stillman Digital, and you understand that by checking the acknowledgment box you are providing your binding acknowledgment and agreement to the terms of this Disclosure Statement.

Locations
United States
  • Stillman Digital Inc.
  • Wyoming, United States
  • Reg: 2022-001201503
Bermuda
  • Stillman Digital Bermuda Ltd.
  • Hamilton, Bermuda
  • Reg: 202302762

FinCEN Number: 31000323177611
NMLS Number: 2383034
FINTRAC: M22669214
Revenue Québec Number: 22227
ALERT TO ALL STILLMAN DIGITAL CLIENTS

Please be aware that a Brazil-based firm operating as Stillman Intermediations Brazil LTDA, Telephone: +55 11 9 332 75363, +55 47 3047 4704, Website: www.stillmancriptobrazil.com, is apparently purporting to be part of the Stillman Digital group of affiliate companies.

This is not the case — neither Stillman Digital Inc. nor Stillman Digital Bermuda Ltd. have any connection with this entity. Stillman Digital Bermuda Ltd. has informed the Bermuda Monetary Authority which publishes warnings on its website at https://www,bma.bm/warning-list. Should any Stillman Digital clients be contacted by anyone from this firm please contact us immediately at [email protected]

The material provided on this website is provided for information purposes only and does not constitute an offer or solicitation for the purchase of any crypto assets or any form of financial instruments referencing crypto assets. The information on this website is not directed at nor intended for distribution to, or use by, any person resident in any country or jurisdiction where such distribution or use would be contrary to local law or regulation.

Not all products and services referenced on this website are available in every jurisdiction.

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