Master Services Agreement

1. Definitions

2. The Doro Platform

2.1 What Doro provides

Doro is a software platform that orchestrates real estate transactions between verified UAE real estate businesses and their counterparties. Doro provides:

• Tools for Agencies and Agents to create and manage transactions
• Payment link generation for use with Buyers
• Identity verification orchestration via licensed third parties
• Document ingestion, classification, and verification
• Transaction record-keeping and audit trail
• Notification and communication infrastructure across web, email, and WhatsApp
• A platform for orchestrating multi-party commission distribution among parties to a Transaction

2.2 What Doro does not do

Doro does not custody, hold, receive, pool, convert, or transmit funds at any stage. All movement of money in connection with a Transaction, across every Leg, is performed by one or more PSP Partners operating under their own regulatory authorisations. No account used to receive, hold, or transmit funds in connection with a Transaction is owned or controlled by Doro.

Doro does not make the regulated approval decision on whether a Transaction may proceed. Identity verification outcomes, sanctions screening decisions, wallet screening decisions, source of funds assessments, and settlement instructions are determined by the PSP Partners. Where a Transaction involves more than one PSP Partner, each makes its own regulated decision in respect of its own Leg. Doro receives those outcomes and acts on them.

Doro is registered in the DIFC as a software house. Doro is not a Dubai Financial Services Authority Authorised Firm and does not perform DFSA-regulated activities. Doro does not hold itself out as a payment provider, money services business, or virtual asset service provider.

2.3 The platform participation decision

Notwithstanding section 2.2, Doro reserves the right to decline to provide its Service to any party or in respect of any Transaction. A payment link created on the Doro Platform is not guaranteed to become live or active. If Doro's internal controls surface concerns about the originating Agency, the documentation, the Buyer profile, the transaction pattern, or any other factor, Doro will decline to issue or maintain the link, and the Transaction will not proceed through Doro.

A Buyer may pay through the Doro Platform only if (a) Doro is willing to provide its Service for the Transaction, and (b) each PSP Partner required for the Transaction approves the regulated activity for its Leg in accordance with its own controls. Doro or any PSP Partner in the chain can decline; none can compel another to proceed. The decline of any Leg by the responsible PSP Partner prevents the Transaction from proceeding through the Platform.

3. Eligibility and account creation

3.1 Agency eligibility

An Agency is eligible to use the Doro Platform only if it:

• Holds an active UAE trade licence (DED, free zone, or DIFC)
• Is registered with the Dubai Land Department
• Provides verified beneficial ownership information for all persons holding 25% or more of the Agency
• Identifies authorised representatives with appropriate authority to bind the Agency
• Provides a verified Agency bank account with holder name matching the trade licence
• Operates exclusively in the UAE real estate market

Doro reserves the right to verify any of the above information against public registries and licensed third-party providers, and to decline or terminate access where verification cannot be completed satisfactorily.

3.2 Agent eligibility

An Agent is eligible to use the Doro Platform only if they:

• Are 18 years of age or over
• Hold a valid Emirates ID, verified through UAE PASS
• Hold an active RERA broker registration where required for their activities
• Are affiliated with an Agency that is itself eligible under section 3.1

Agents access the Platform under the umbrella of their Agency. The Agency is responsible for the conduct of its Agents on the Platform.

3.3 Buyer and Seller eligibility

A Buyer or Seller is eligible to engage with a Doro Transaction only if they:

• Are 18 years of age or over
• Are introduced to Doro through a verified Agency (Buyers and Sellers do not have direct access to the Platform outside of an active Transaction)
• Successfully complete identity verification through the PSP Partner or PSP Partners responsible for the Transaction
• Are not subject to sanctions or other restrictions identified through screening

3.4 No use by minors

The Doro Platform is not available to any individual under the age of 18. We verify the age of all Agents and Buyers as part of our verification processes. We do not knowingly permit minors to use the Platform.

3.5 Geographic scope

The Doro Platform is operated for properties located in the UAE. Transactions involving properties outside the UAE are not currently supported and may be declined.

4. The Service and how it is used

4.1 Use by Agencies

An Agency may use the Doro Platform to:

• Create Transactions and generate payment links for Buyers
• Manage Agent access, performance, and commission allocation
• Receive notifications, audit reports, and financial summaries
• Approve or decline transactions originated by its Agents
• Configure Agency-specific compliance and approval rules

The Agency is responsible for the accuracy of all data it submits to the Platform, including transaction details, banking information, and commission allocations.

4.2 Use by Agents

An Agent may use the Doro Platform to:

• Create Transactions on behalf of their Agency, subject to the Agency's configured approval workflow
• Forward documents, communications, and other transaction context to Doro through the supported interfaces (web, WhatsApp, email)
• Communicate with Buyers and Sellers through Doro-mediated channels
• View transaction status and commission entitlements

The Agent is responsible for the accuracy of all data they submit, including transaction details and the identity and bank details of Sellers.

4.3 Use by Buyers

A Buyer engaging with a Doro payment link may use the Platform to:

• Complete identity verification through the PSP Partner or PSP Partners responsible for the Transaction and their verification providers
• Submit source of funds documentation where required
• Provide payment instructions in a supported currency or asset, including the Instruction described in section 17.3
• Receive transaction status updates and final settlement confirmation
• Communicate with Doro through the supported interfaces

The Buyer's use of the Platform is limited to the specific Transaction associated with the payment link they received, including any Tranches comprising that Transaction. Section 17 sets out the terms that apply specifically to Buyers.

4.4 Use by Sellers

A Seller in a Doro Transaction may use the Platform to:

• Confirm receipt details (bank account, holder name)
• Receive transaction status updates and settlement confirmation
• Receive sale documentation and audit trail
• Communicate with Doro through the supported interfaces

4.5 The WhatsApp interface

Doro provides a WhatsApp interface for communications, document forwarding, and conversational interactions with the Platform. Users of the WhatsApp interface acknowledge that:

• Messages, voice notes, documents, and forwarded content are processed by Doro and form part of the audit trail
• Voice notes may be transcribed for filing and verification
• Forwarded documents are classified, extracted, and cross-referenced
• WhatsApp itself processes the underlying communications as a platform; Meta's terms apply to that processing
• The same functions are available through the web Platform for users who prefer not to use WhatsApp

Users of the WhatsApp interface are responsible for forwarding only content that relates to legitimate Doro transactions and for ensuring they have the right to share third-party content (for example, documents containing the personal data of a Buyer or Seller).

5. Fees and payment

5.1 Doro's platform fee

Doro charges a platform fee for use of the Service in connection with each completed Transaction. The platform fee is calculated as a percentage of the Transaction value or as otherwise specified at the time the Transaction is created.

The platform fee varies based on factors including the payment method used (cryptocurrency or fiat), the source and destination jurisdictions of funds, the number of Legs and PSP Partners in the settlement route, and the configuration agreed with the Agency. The specific fee applicable to a Transaction is disclosed before the Agency commits to the Transaction.

5.2 Allocation of the platform fee

Allocation of the Doro platform fee among the parties to a Transaction (Agency, Agent, Seller) is determined by the Agency that creates the payment link, in accordance with the Agency's commercial agreements with the Seller and its Agents. Doro's role is limited to processing the allocation as configured.

5.3 Collection and PSP Partner charges

The Doro platform fee is collected by a PSP Partner at the point of settlement and remitted to Doro as a B2B payment for software services. Where a Transaction involves more than one PSP Partner, the fee may be collected by whichever PSP Partner the settlement route provides for, and remitted to Doro on a business-to-business basis. Doro does not directly receive funds from Buyers or Sellers.

Each PSP Partner charges for the regulated activity it performs on its Leg, including any currency conversion or virtual asset conversion spread. Where those charges form part of the amount payable by a Buyer, they are included within the single all-inclusive figure disclosed to the Buyer under section 17.5. As between businesses, PSP Partner charges are settled between Doro and the relevant PSP Partner or reflected in the amount required from the Buyer, and are not billed separately to the Buyer.

5.4 No fees in absence of completed Transaction

The platform fee is charged only on completed Transactions. No fee is charged for Transactions that do not complete (for example, where a payment link is created but the Buyer does not pay, or where the Transaction is declined by Doro or a PSP Partner). Where a Transaction is completed in Tranches, the platform fee is charged in respect of each completed Tranche as set out at the time the Transaction is created.

5.5 No setup or recurring fees

Doro does not currently charge setup fees, monthly minimums, or subscription fees. We may introduce such fees in the future, in which case the relevant Agency will be notified at least 30 days in advance and may terminate this Agreement before the new fees take effect.

5.6 No refunds

Doro does not custody or control funds. Refund decisions in respect of a Transaction are made by the PSP Partner that holds or processed the relevant funds, in accordance with that PSP Partner's own terms. Doro will assist in coordinating refund requests but does not guarantee refund outcomes and does not refund the Doro platform fee on completed Transactions.

6. Service availability and performance

6.1 Target availability

Doro targets 99% uptime of the Platform on a monthly basis, measured across the core Service functions (account access, Transaction creation, payment link issuance, status updates).

6.2 Excluded events

Target availability does not apply to:

• Planned maintenance for which we have provided reasonable advance notice
• Outages of third-party services on which the Platform depends, including PSP Partners, identity verification providers, cloud infrastructure, WhatsApp, and email infrastructure
• Force majeure events, including natural disasters, war, civil disturbance, government action, or internet infrastructure failure
• User error or misuse of the Service
• Issues caused by user-side software, hardware, or network configuration

6.3 No service credits or financial remedies

Where Doro fails to meet target availability, no service credits, refunds, or other financial remedies are payable. Persistent or material availability failures may give the Agency the right to terminate this Agreement under section 11.

6.4 Settlement timing

Doro does not guarantee a specific settlement timeline. Actual settlement of a Transaction depends on the Buyer's payment method, the processing time of each PSP Partner in the chain, banking and network cut-off times, and other factors outside Doro's control.

7. Compliance obligations of the Agency

The Agency commits, for itself and on behalf of its Agents, to:

• Maintain its UAE trade licence, DLD registration, and (where applicable) RERA registration in good standing
• Notify Doro promptly of any material change in its corporate structure, regulated status, or beneficial ownership
• Comply with all applicable UAE law, including UAE Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and the Financing of Illegal Organisations and Cabinet Resolution No. 134 of 2025, in each case as amended or replaced from time to time, and any applicable RERA, DLD, and DFSA regulations
• Provide accurate and complete information about itself, its Agents, and each Transaction
• Verify the identity of Sellers and the validity of Sellers' bank account details
• Ensure that Agents using the Platform are 18 or over, hold valid Emirates IDs, and (where required) hold active RERA registrations
• Forward documents and communications to Doro only where the Agency has the right to do so
• Cooperate with Doro on any compliance investigation, audit, or inquiry from a regulator or counterparty
• Promptly escalate to Doro any suspicion of money laundering, terrorist financing, sanctions evasion, fraud, or other unlawful activity
• Not disclose to a Buyer, Seller, or other third party that a Transaction has been escalated for review or that a suspicious activity report has been or may be filed (the no tipping off rule under UAE AML law)
• Maintain confidentiality of all Doro materials and platform access credentials

For an overview of how these obligations sit alongside Doro's own controls, see our compliance overview.

8. Acceptable use

The Agency, its Agents, and any Buyer or Seller using the Platform must not:

• Use the Platform for any illegal purpose
• Use the Platform to facilitate money laundering, terrorist financing, sanctions evasion, fraud, or any other unlawful activity
• Submit false, misleading, or fraudulent information
• Attempt to bypass Doro's controls, access controls, or compliance checks
• Reverse engineer, decompile, or disassemble the Platform, except to the extent permitted by applicable law
• Resell, sublicense, or otherwise transfer access to the Platform to a third party
• Use the Platform for transactions other than UAE real estate transactions, except where Doro has expressly agreed in writing
• Use the Platform to facilitate transactions involving sanctioned persons or jurisdictions
• Interfere with the operation of the Platform or attempt to gain unauthorised access
• Use the Platform to harass, threaten, or harm any other party
• Forward or upload content for which the user does not have the legal right to share
• Misrepresent themselves to Doro or to any other party in connection with a Transaction

Breach of any of the above is a material breach of this Agreement and grounds for immediate termination by Doro.

9. Intellectual property

9.1 Doro's intellectual property

Doro owns and retains all intellectual property rights in the Platform, the Service, the brand, the documentation, and any improvements, modifications, or derivative works. Use of the Service does not transfer any intellectual property rights to the Agency or any other user.

Doro grants the Agency a limited, non-exclusive, non-transferable, revocable licence to use the Platform in accordance with this Agreement during the term of the Agreement.

9.2 Agency's data

The Agency retains ownership of the Transaction data it submits to the Platform. The Agency grants Doro a licence to use that data for the purpose of operating the Service, complying with Doro's legal obligations, and improving the Platform.

9.3 Aggregated and anonymised data

Doro may use aggregated and anonymised data derived from Platform activity (including Transaction patterns, fraud signals, and operational metrics) for the purpose of improving the Platform, training models that support Doro's controls, conducting analytics, and developing new features. Such data does not identify any specific Agency, Agent, Buyer, Seller, or Transaction. Doro does not sell or license such data to third parties for marketing or commercial exploitation.

9.4 Feedback

If the Agency or any user provides Doro with feedback, suggestions, or ideas regarding the Platform, the Agency assigns to Doro all rights in such feedback and grants Doro the right to use it without restriction.

10. Confidentiality

10.1 Confidential information

Each party may receive confidential information from the other in connection with this Agreement, including (in Doro's case) information about the Platform, controls, partner stack, and pricing, and (in the Agency's case) information about the Agency's operations, Transactions, and counterparties.

10.2 Obligations

Each party will:

• Use the other party's confidential information only for the purpose of this Agreement
• Protect it with at least the same standard of care it uses for its own confidential information, and in no event less than reasonable care
• Not disclose it to third parties except to employees, advisors, and contractors who have a need to know and are bound by confidentiality obligations at least as strict as those in this Agreement
• Return or destroy the other party's confidential information on termination of this Agreement, except where retention is required by law

10.3 Exclusions

The obligations above do not apply to information that is:

• Already in the receiving party's possession without an obligation of confidentiality
• Independently developed by the receiving party without use of the disclosing party's confidential information
• Publicly available through no breach by the receiving party
• Required to be disclosed by law, regulation, or court order (in which case the receiving party will give the disclosing party reasonable advance notice where lawful)

11. Term and termination

11.1 Term

This Agreement begins when the Agency creates an account on the Doro Platform and continues until terminated in accordance with this section.

11.2 Termination by the Agency

The Agency may terminate this Agreement at any time, for any reason, by providing 30 days' prior written notice to Doro at compliance@paywithdoro.com. The Agreement remains in effect during the notice period.

11.3 Termination by Doro

Doro may terminate this Agreement:

• At any time, for any reason, by providing 30 days' prior written notice to the Agency
• Immediately, on written notice, where the Agency has materially breached this Agreement, including breaches of section 7 (Compliance obligations), section 8 (Acceptable use), or section 10 (Confidentiality)
• Immediately, on written notice, where the Agency or any beneficial owner is subject to sanctions, regulatory enforcement, or insolvency
• Immediately, on written notice, where Doro reasonably determines that continued provision of the Service would expose Doro, its partners, or its users to material legal, regulatory, or reputational risk

11.4 In-flight Transactions

On termination of this Agreement:

• Doro will complete the processing of any Transactions where a payment link has been issued to a Buyer at the time of termination, subject to the regulated decisioning of each PSP Partner, and including any remaining Tranches of a Transaction already underway
• The Agency may not create new Transactions after termination takes effect
• Doro retains the right to decline to complete an in-flight Transaction or Tranche where Doro reasonably determines that completion would breach applicable law or expose any party to material risk

11.5 Effect of termination

On termination:

• The Agency's access to the Platform ends
• The Agency has 30 days to export its Transaction data through Doro's data export tools
• After 30 days, Doro will retain Agency data only as required by Doro's retention policy (described in our Privacy Policy) and will delete data not subject to retention obligations
• Each party returns or destroys the other's confidential information, subject to retention obligations
• Sections 8 (Acceptable use), 9 (Intellectual property), 10 (Confidentiality), 12 (Liability), 13 (Indemnity), 15 (Governing law), 17 (Buyer terms), and any other section that by its nature should survive will survive termination

12. Liability

12.1 Cap on liability

To the maximum extent permitted by law, the aggregate liability of each party to the other under or in connection with this Agreement is capped at the total amount of fees paid by the Agency to Doro in the 12 months preceding the event giving rise to the claim, or USD 50,000, whichever is greater.

12.2 Excluded damages

Neither party is liable to the other for any indirect, consequential, special, incidental, or punitive damages, including loss of profits, loss of revenue, loss of business opportunity, loss of goodwill, or loss of data, even if the party has been advised of the possibility of such damages.

12.3 Carve-outs

The cap in section 12.1 and the exclusions in section 12.2 do not apply to liability arising from:

• Gross negligence or willful misconduct
• Breach of confidentiality (section 10)
• Indemnity obligations (section 13)
• Fraud
• Liability that cannot be limited or excluded under applicable law

12.4 Doro's specific exclusions

Without limiting the generality of section 12.2, Doro is not liable for:

• Decisions made by PSP Partners, including KYC outcomes, sanctions decisions, wallet screening, source of funds assessments, and settlement decisions, in respect of any Leg
• Failures of third-party services on which the Platform depends
• Any loss arising from the Agency's, an Agent's, a Buyer's, or a Seller's misuse of the Platform or breach of this Agreement
• Any loss arising from inaccurate or incomplete information provided by the Agency or its Agents
• Outcomes of Transactions, including the failure of a Transaction or any Tranche to complete or the failure of any party to perform their obligations
• Loss arising from market movements, currency conversion rates, virtual asset conversion spreads, or fees charged by third parties
• Tax consequences of any Transaction for any party

13. Indemnity

13.1 Agency indemnity

The Agency will indemnify and hold Doro harmless from any third-party claim, loss, damage, or expense (including reasonable legal fees) arising from:

• The Agency's or any Agent's breach of this Agreement
• The Agency's or any Agent's breach of applicable law
• The Agency's or any Agent's misrepresentation, fraud, or other misconduct
• Any claim by a Buyer, Seller, or counterparty against Doro arising from acts or omissions of the Agency or any Agent
• Any claim by a regulator arising from the Agency's failure to maintain its required licences or comply with regulatory obligations

13.2 Doro indemnity

Doro will indemnify and hold the Agency harmless from any third-party claim, loss, damage, or expense (including reasonable legal fees) arising from:

• Doro's breach of this Agreement
• A claim that the Platform infringes a third party's intellectual property rights, except where the claim arises from the Agency's misuse of the Platform

13.3 Indemnity procedure

The party seeking indemnity must:

• Notify the indemnifying party promptly in writing of the claim
• Allow the indemnifying party to control the defence and settlement of the claim
• Cooperate reasonably in the defence

The indemnifying party may not settle a claim in a way that imposes any obligation on the indemnified party without the indemnified party's consent.

13.4 Cap on indemnity

The cap on liability in section 12.1 applies to indemnity obligations under this section, except where the underlying claim falls within a carve-out in section 12.3.

14. Data protection

The processing of Personal Data in connection with this Agreement is governed by Doro's Privacy Policy, available at paywithdoro.com/legal/privacy. The Privacy Policy forms part of this Agreement and is binding on the parties.

The Agency acknowledges that:

• Doro acts as data controller for Personal Data processed in connection with the Platform, save that, in respect of the identity verification documents and biometric data a Buyer submits to a PSP Partner or its verification provider, that PSP Partner or provider acts as controller for that data as described in section 17.8
• Doro engages processors and shares data with independent controllers as set out in the Privacy Policy, section 7
• The Agency is independently responsible for its own data protection obligations to its Agents and counterparties
• Where the Agency provides Doro with Personal Data of third parties, the Agency warrants that it has the right to do so and has provided any required notices to those third parties

15. Governing law and dispute resolution

This Agreement is governed by the laws of the DIFC. Any dispute arising from or in connection with this Agreement is subject to the exclusive jurisdiction of the DIFC Courts.

The parties will attempt in good faith to resolve any dispute through direct discussion between authorised representatives before commencing formal proceedings.

A Buyer's contractual relationship with a PSP Partner, and any dispute concerning a Leg performed by that PSP Partner, is governed by that PSP Partner's own terms and the governing law and forum stated in them, which may differ from the governing law and forum of this Agreement.

16. General

16.1 Entire agreement

This Agreement, together with the Privacy Policy and any other documents expressly incorporated by reference, constitutes the entire agreement between the parties and supersedes any prior agreements or understandings. The terms of each PSP Partner apply to the Buyer in addition to this Agreement as set out in section 17.

16.2 Variation

Doro may vary this Agreement from time to time. Material changes will be notified to the Agency at least 30 days before they take effect. The Agency's continued use of the Platform after the effective date of a change constitutes acceptance of the change. If the Agency does not accept a material change, the Agency may terminate this Agreement under section 11.2.

16.3 Severability

If any provision of this Agreement is held to be invalid or unenforceable, the remaining provisions remain in full force and effect.

16.4 No waiver

A failure or delay by either party to enforce any provision of this Agreement does not constitute a waiver of that provision or of any other provision.

16.5 Assignment

The Agency may not assign or transfer this Agreement, in whole or in part, without Doro's prior written consent. Doro may assign this Agreement, in whole or in part, to an affiliate or to a successor in connection with a merger, acquisition, or sale of substantially all of its assets.

16.6 Notices

Notices to Doro under this Agreement should be sent to compliance@paywithdoro.com and to Doro Technologies Ltd, Innovation One, Level 1, Zaa'beel Second, DIFC, Dubai, UAE. Notices to the Agency will be sent to the email and postal address provided by the Agency at registration or as updated through the Platform.

16.7 Force majeure

Neither party is liable for any failure or delay in performing its obligations under this Agreement to the extent the failure or delay is caused by a force majeure event, including natural disasters, war, terrorism, civil disturbance, government action, pandemic, internet infrastructure failure, or other event outside the affected party's reasonable control.

16.8 Independent contractors

The parties are independent contractors. Nothing in this Agreement creates a partnership, joint venture, agency, or employment relationship between the parties. No PSP Partner is an agent of Doro, and Doro is not an agent of any PSP Partner.

16.9 Third-party rights

Except as expressly provided in this Agreement, no third party has any rights under this Agreement.

16.10 Counterparts and electronic acceptance

The Agency's acceptance of this Agreement through the account creation flow on the Platform, and a Buyer's acceptance through the payment flow, each constitutes a binding electronic agreement enforceable under DIFC law. Where the payment flow requires the Buyer to accept the terms of one or more PSP Partners and to give the Instruction, each such acceptance and the Instruction are recorded with the associated identifiers (including timestamp and, where captured, IP address and email) and form part of the Transaction audit trail.

17. Buyer terms

This section applies specifically to Buyers. A Buyer accepts this section by proceeding with payment through a Doro payment link. Where this section addresses a matter also addressed elsewhere in this Agreement, this section prevails for the Buyer in respect of that matter. Defined terms in section 1 apply.

17.1 The nature of Doro's role to a Buyer

Doro provides a software platform that orchestrates the steps of a real estate payment. Doro does not at any stage custody, hold, receive, pool, convert, or transmit a Buyer's funds. The entire flow of funds is handled exclusively by one or more PSP Partners operating under their own regulatory authorisations. Where a Transaction is settled through more than one PSP Partner, it proceeds as a sequence of Legs: for example, a first PSP Partner receives the Buyer's fiat into a Virtual Account in the Buyer's name and converts it, and a further PSP Partner receives the converted proceeds and completes conversion and settlement in the destination market. A Buyer's funds move between the Buyer and the PSP Partners, and onward to the Seller and other recipients, without passing through any account owned or controlled by Doro.

Doro does not make the regulated decision as to whether a Buyer's payment may proceed. Identity verification, sanctions and screening determinations, source of funds assessment, and the final settlement decision for each Leg are made by the PSP Partner responsible for that Leg. Doro receives those outcomes and acts on them. Separately, Doro may decline to provide its platform for a Transaction even where the PSP Partners would proceed. The issuance of a payment link is not a guarantee that a Transaction will complete.

17.2 Verification, screening, and acceptance as conditions of payment

Before a payment link becomes live and available to a Buyer for funding, the following conditions must be satisfied:

• Doro platform screening.Doro conducts checks to decide whether it is willing to provide its platform for the Transaction. These are platform-eligibility and fraud-prevention checks and are not a regulated customer due diligence determination. Doro's decision governs only participation on the Platform.
• PSP Partner due diligence.Each PSP Partner responsible for a Leg conducts the regulated customer due diligence required for its own regulated activity, including identity verification (document verification and biometric liveness conducted through that PSP Partner's regulated verification provider), sanctions, PEP, and adverse media screening, wallet screening where a Leg involves a virtual asset, and assessment of source of funds where required. The regulated decision on whether the payment may proceed on each Leg rests with the PSP Partner responsible for that Leg.
• Acceptance of applicable terms. The Buyer must accept this Agreement and the terms of each PSP Partner (and of any sub-provider engaged by a PSP Partner, such as an institution providing the fiat account) that applies to the Transaction. Acceptance of each applicable set of terms is a condition precedent to the payment link becoming live.
• The Instruction. The Buyer must give the Instruction described in section 17.3.

Successful completion of all applicable platform screening, verification, and regulated checks by Doro and by each PSP Partner, together with all required acceptances and the Instruction, is a condition precedent to a payment link becoming live. No payment may be funded until those conditions are met. Where any check returns a failed, inconclusive, or escalated result, the link will not be made available or will be suspended, and the Transaction will not proceed through the Platform. Screening may continue through to settlement, and a new flag arising before settlement may result in suspension or termination of the Transaction or of any remaining Tranche.

17.3 Payment, the flow of funds, and the Buyer's Instruction

A Buyer may fund payment in a supported fiat currency or, where available, a supported virtual asset. Where payment by virtual asset is available, the Buyer is presented with the supported assets and actively selects the chosen asset as an express step within the payment flow before executing payment. The supported assets available are displayed within the payment flow at the time of the Transaction.

Where funding is made by Virtual Account or IBAN, that account is made available by or through the responsible PSP Partner in the Buyer's own name. No account used to receive, hold, convert, or transmit the Buyer's funds at any point in the chain is owned or controlled by Doro.

As part of the payment flow, the Buyer gives the Instruction: by funding the Transaction, the Buyer instructs and authorises the relevant PSP Partner or PSP Partners to receive the Buyer's funds, to convert them where conversion is required for the Transaction, and to transfer the proceeds onward to the destination specified for the Transaction, including across successive Legs where the settlement route involves more than one PSP Partner. The destination for each Leg is set by the responsible PSP Partner and displayed to the Buyer, and the Buyer is not required to specify a wallet address or destination of their own. The Instruction is recorded as part of the Transaction audit trail.

Where payment requires conversion, that conversion is performed by the responsible PSP Partner, and the applicable rate and any associated spread or charge are determined by that PSP Partner. Indicative rates are displayed within the payment flow before the Buyer executes payment. All funds transmitted by a Buyer are received and handled solely by the PSP Partners, each of which is responsible under its own regulatory authorisation for the receipt, conversion, custody during processing, and onward settlement of funds on its Leg.

17.4 Multi-tranche and off-plan Transactions

A Transaction may be funded in a single payment or, where the purchase requires it (for example an off-plan purchase), in Tranches comprising an initial deposit followed by scheduled further payments over time. Where a Transaction is funded in Tranches:

• Each Tranche is a payment within the same Transaction and is subject to the same conditions in section 17.2, including screening that may continue through to settlement of each Tranche.
• The Buyer opts in to each Tranche. Notice to fund a subsequent Tranche may be initiated by the Buyer, the Agency, or a developer, and the Buyer confirms and funds the Tranche through the Platform.
• The Buyer's verification may be reused across Tranches as described in section 17.8, so that the Buyer is not required to repeat full identity verification for each Tranche, subject to any re-verification or liveness step a PSP Partner requires.
• The Virtual Account or account details used for the Transaction may remain available for subsequent Tranches, at the discretion of the responsible PSP Partner and subject to that PSP Partner's terms.
• The Instruction given under section 17.3 applies to each Tranche of the Transaction unless the Buyer is required to give a fresh Instruction for a Tranche.

17.5 Fees to a Buyer

Any fee applicable to a Buyer's Transaction, including Doro's platform fee and any PSP Partner charge or conversion spread that forms part of the amount payable by the Buyer, is disclosed within the payment flow as a single, all-inclusive figure before the Buyer executes payment. A Buyer will not be charged any fee not disclosed prior to payment. Fees are collected by a PSP Partner as part of settlement; a Buyer makes no separate payment directly to Doro and no separate payment to a PSP Partner beyond the disclosed all-inclusive amount for the Transaction or Tranche. No fee is charged where a Transaction or Tranche does not complete.

17.6 Settlement timing, delays, short payments, and resolution

Doro does not guarantee a settlement timeline. The time to complete a Transaction depends on the payment method, the processing time of each PSP Partner in the chain, banking and network cut-off times, and other factors outside Doro's control. Status updates are provided as the Transaction progresses.

Where a payment arrives short (including as a result of foreign exchange differences or intermediary bank charges), is returned, is delayed, or is flagged or held by a bank or a PSP Partner, a top-up payment, a repeat payment, or the provision of further information may be required before the Transaction or Tranche can proceed. Responsibility for investigating and resolving any such matter, and for any request for further information in respect of funds, sits with the PSP Partner responsible for the affected Leg, in accordance with that PSP Partner's procedures and regulatory obligations. Doro will surface the status to the Buyer and Agency and coordinate the next step through the Platform, but Doro is not responsible for the shortfall, for any second or repeat payment, or for any resulting delay, and does not custody or control the affected funds.

Where funds are affected by an issue arising within a PSP Partner's handling of a Leg, recourse in respect of those funds lies against that PSP Partner under its own terms and, where it maintains such cover, its insurance arrangements. Doro does not custody or control the funds, is not an insurer of the flow of funds, and is not responsible for resolving matters concerning the handling of funds.

17.7 Refunds to a Buyer

Because Doro does not custody or control funds, refund and reversal decisions rest with the PSP Partner that holds or processed the relevant funds, in accordance with that PSP Partner's terms. Where a Transaction is settled through more than one PSP Partner and funds have moved along the chain, a refund or reversal in respect of a Leg lies against the PSP Partner that holds the funds for that Leg, and recovery may depend on the stage the funds have reached in the chain. Doro will assist in coordinating a refund request across the relevant PSP Partners but does not guarantee any particular outcome or timeframe and does not guarantee recovery once funds have moved to a downstream PSP Partner. The platform fee on a completed Transaction or Tranche is non-refundable.

17.8 Buyer data and reuse of verification

The processing of a Buyer's Personal Data is governed by the Privacy Policy at paywithdoro.com/legal/privacy. To meet applicable AML, CTF, and sanctions obligations, a Buyer's Personal Data and Transaction information are processed by Doro and shared with the PSP Partners and their regulated service providers, and may be retained for the periods required by applicable law.

Identity verification documents and biometric data that a Buyer submits for verification are collected and held by the PSP Partner responsible for the relevant Leg, or by that PSP Partner's regulated verification provider, which acts as controller for that data. Doro orchestrates the verification but is not the controller of those identity documents and biometric records.

To avoid requiring a Buyer to complete full identity verification more than once, the Buyer's verification may, with the Buyer's consent given in the flow, be shared and reused: (a) across more than one PSP Partner involved in the same Transaction, so that a second PSP Partner in the chain can rely on and re-run its own checks against verification already completed rather than requiring the Buyer to start again; and (b) across successive Tranches of the same Transaction. Where verification is reused, a PSP Partner may still require the Buyer to complete a liveness check or other confirmation step to confirm ownership of the verified identity. Each receiving PSP Partner runs its own regulated checks against the shared verification and makes its own regulated decision.

Where a Buyer communicates with Doro or an Agent through any supported channel, including WhatsApp, the content of those communications may form part of the Transaction record and audit trail.

17.9 Buyer acceptable use

A Buyer must not use a payment link for any unlawful purpose or to facilitate money laundering, terrorist financing, sanctions evasion, or fraud; must not submit false, misleading, or fraudulent information or documentation; must not attempt to circumvent any identity verification, screening, or fraud control of the Platform or any PSP Partner; and must not misrepresent their identity, the source of their funds, or their relationship to the Transaction. Section 8 applies to Buyers in addition to this section.

17.10 Liability to a Buyer

To the maximum extent permitted by law, Doro is not liable to a Buyer for any decision made by a PSP Partner or its service providers in respect of any Leg; for the receipt, custody, conversion, handling, delay, loss, or onward transmission of funds, which are the responsibility of the PSP Partners; for a payment that arrives short or is returned, flagged, or held, or for any resulting top-up or repeat payment; for loss arising from virtual asset price movements, conversion or exchange rates, spreads, or third-party charges; for the irreversibility of a blockchain transaction or a payment made to an incorrect address, amount, or asset; for the failure of a Transaction or any Tranche to complete; for the unavailability or failure of any third-party service on which the Platform depends; or for any tax consequence of a Transaction.

The exclusions in section 12.2 and in this section apply to Doro's liability to a Buyer. Subject to those exclusions, and to the maximum extent permitted by law, Doro's total aggregate liability to a Buyer under or in connection with a Transaction is limited to the Doro platform fee attributable to that Transaction. The USD 50,000 floor in section 12.1 does not apply to Doro's liability to a Buyer. Nothing in this section limits any liability that cannot be limited or excluded under applicable law, or any liability arising from Doro's fraud, gross negligence, or willful misconduct.

17.11 Acknowledgement of virtual asset and settlement risks

Where a Buyer funds a Transaction in a virtual asset, or where conversion of a virtual asset forms part of the settlement on any Leg, the Buyer acknowledges and accepts that:

• Virtual assets are not legal tender and are not backed or insured by any government, central bank, or deposit protection scheme.
• Blockchain transactions are irreversible. A payment sent to an incorrect address, or in an incorrect amount or asset, may not be recoverable.
• The value of a virtual asset can move materially between the time a rate is displayed and the time the payment is executed and converted. The applicable rate and any spread are set by the responsible PSP Partner.
• Where a stablecoin (for example USDC or USDT) is used in the settlement, the asset is intended to hold a fixed value against a reference currency but may deviate from that peg, and its value depends on the financial health of its issuer and that issuer's banking partners.
• There is no guarantee of liquidity. It may be difficult or impossible to convert or settle the asset at the time or rate the Buyer expects.
• Settlement timing is not guaranteed. Virtual asset transactions occur on decentralized networks that may experience congestion, delays, or failures, and neither those networks nor any PSP Partner's service is guaranteed to be available at any given time. Timing also depends on each PSP Partner's processing and banking cut-off times.
• The Buyer is exposed to counterparty, cybersecurity, and regulatory risk, including the risk that a market maker, liquidity provider, custodian, banking partner, or payment processor engaged by a PSP Partner fails to perform.
• The Buyer is responsible for safeguarding its own credentials and for the accuracy of the payment details it submits.
• Virtual asset transactions may be recorded on a public ledger, which can affect the privacy and anonymity of the payment.
• Each Leg of the Transaction is carried out by a PSP Partner and its third-party providers (including custodians and banking partners) under their own terms of service and risk disclosures, which apply to the Buyer in addition to this Agreement and which include asset-specific risk disclosures for the asset used. Doro is not responsible for any loss arising from those third-party providers. The Buyer should review those terms and should take independent legal, financial, and tax advice where appropriate.

These risks sit with the Buyer and the PSP Partners that perform the regulated activity. Doro provides software only and does not assume any of these risks.