Legal Notice

Last updated: July 2025

1. Identifying Information of the Website Owner

In compliance with Article 10 of Law 34/2002, of July 11, on Information Society Services and Electronic Commerce (hereinafter, LSSI-CE), the User is informed of the identifying data of the owner of this website:

• Company name: Clovr Labs, S.L.
• Tax ID: B67306894
• Registered office: Camino Can Minguet, No. 72, 08173, Sant Cugat del Vallès (Barcelona), Spain
• Contact email: info@elenpay.tech
• Website: https://elenpay.tech
• Main activity: Development of technological solutions for the management and use of crypto assets.
• Registry data: Registered in the Commercial Registry of Barcelona (pending final registration).

2. Purpose of the Website

The purpose of this website is to provide information about the technological solutions and services that Clovr Labs, S.L. (ElenPay) intends to offer once it obtains the corresponding authorization as a crypto asset service provider, in accordance with Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (MiCA).

Currently, ElenPay is in the regulatory development phase and does not provide active crypto-asset-related services to end users.

The main purposes of the website are:

• To disseminate corporate and project information
• To facilitate contact with potential users, investors and collaborators
• To allow registration of users interested in pre-registration phases, waiting lists or beta access
• To offer educational content on Lightning Network, blockchain, and related technologies

Access to the website is free of charge. Use of the website implies acceptance of this Legal Notice and the applicable Privacy and Cookie Policies.

3. Website Terms of Use

The User undertakes to use the website diligently, correctly and lawfully, and in particular, undertakes to:

• Not carry out illegal activities or activities contrary to good faith, morality, public order or generally accepted standards of conduct
• Not reproduce, copy, distribute, make available to third parties, publicly communicate, transform or modify the contents of the site without express authorization from ElenPay, except in legally permitted cases
• Not delete, hide or manipulate legal notices, copyright indications or other identifying data of ElenPay or third parties
• Not introduce viruses, malicious code or any other system that could damage or alter the operation of the website
• Not attempt to access restricted areas of the website or ElenPay's computer systems without authorization
• Not perform reverse engineering, decompilation or any other action aimed at obtaining the source code of the website or its tools
• Provide truthful, accurate, complete and up-to-date information in enabled forms

ElenPay reserves the right to suspend, restrict or cancel access to the website of any User who fails to comply with these conditions, without prior notice and without this generating any right to compensation.

4. Intellectual and Industrial Property

All contents of the website, including, but not limited to, texts, photographs, graphics, images, icons, technology, software, links, and other audiovisual or sound contents, as well as its graphic design and source codes, are the intellectual property of Clovr Labs, S.L. or third parties who have authorized their use, and are protected by Spanish and international laws on intellectual and industrial property.

It is expressly prohibited:

• The use of any of the contents of the website for commercial or advertising purposes without express authorization from ElenPay
• The reproduction, distribution, modification, assignment or public communication of the contents without prior consent
• The use of trademarks, trade names, logos or any other distinctive sign of ElenPay without written authorization

In the event that the User wishes to make a use other than that permitted, they must request prior written authorization from ElenPay via email: info@elenpay.tech

Trademarks, trade names or distinctive signs of third parties that may appear on the website are the property of their respective owners, and their presence does not imply that ElenPay has any rights over them or endorses or recommends them.

5. Limitation of Liability

ElenPay is not responsible, unless there is duly proven fraud or gross negligence, for the following aspects:

• The continuity, availability or infallibility of the website, which may be interrupted by technical problems, updates, maintenance or causes beyond its control
• The absence of errors in the contents of the website, nor the correction of any defect that may occur
• The absence of viruses, malware or any other element that could damage Users' computer systems. However, ElenPay adopts reasonable technical measures to prevent this
• The use that Users may make of the contents of the website and the consequences derived therefrom
• Damage and losses resulting from unauthorized access or fraudulent use of user accounts by third parties
• Contents hosted on third-party websites accessible through links from this website, over which ElenPay has no editorial control

ElenPay strives to keep the information on the website updated and error-free, but does not guarantee the accuracy, validity, completeness or usefulness of the information contained. Users must verify any information before making decisions based on it.

In particular, ElenPay does not offer financial, tax, legal or investment advice through the website. Published contents are purely informative and educational in nature, and should not be interpreted as investment recommendations or recommendations to purchase crypto assets.

Likewise, ElenPay shall not be liable for delays or impossibilities in the provision of services arising from regulatory modifications, regulatory changes, decisions by competent authorities or any other circumstance beyond its control.

6. Links to Third-Party Websites

The website may contain links to third-party web pages with the aim of facilitating access to additional information related to ElenPay services or educational content of interest.

ElenPay has no control over such third-party websites and, therefore, assumes no responsibility for:

• The contents, information, communications, opinions or services provided through those linked sites
• The operation, availability or accessibility of such websites
• The privacy policies, terms of use or contractual terms applicable on third-party sites
• Damage or losses that the User may suffer as a consequence of accessing third-party sites

Users are advised to carefully read the privacy policies, legal notices and terms of use of any third-party website before providing personal information or conducting transactions.

If the User becomes aware of the existence of any illegal, unlawful content, contrary to the law or that could constitute an infringement of third-party rights on any site linked from this website, they must immediately notify ElenPay at: info@elenpay.tech

7. Personal Data Protection

ElenPay's privacy and personal data protection policy is available separately and accessible from any page of the website.

The processing of personal data provided by Users through the website is carried out in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR), and Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (LOPDGDD).

Users may exercise their rights of access, rectification, erasure, restriction, portability, objection and not to be subject to automated decisions, under the terms established in the regulations, by contacting: info@elenpay.tech

For detailed information on the collection, processing, purposes, retention periods, transfer and applicable security measures, the User should consult the website's Privacy Policy.

8. Cookie Policy

The ElenPay website uses cookies and similar technologies to facilitate navigation, improve the User experience, perform usage analysis and enable the correct operation of certain functionalities.

Cookies may be own or third-party, session or persistent, and may have technical, personalization, analysis or advertising purposes.

The User can manage their cookie preferences through the configuration panel enabled on the website, as well as configure their browser to reject or delete cookies.

For detailed information on the cookies used, their type, purpose, ownership, duration and deactivation options, the User should consult the website's Cookie Policy.

9. ElenPay Regulatory Status

Clovr Labs, S.L. (ElenPay) is currently in the process of obtaining authorization as a crypto asset service provider, in accordance with Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets (MiCA).

As long as ElenPay has not received the corresponding authorization from the competent authority, it will not provide services regulated under the scope of the MiCA Regulation to end users, nor will it carry out operations with crypto assets that require such authorization.

The website is purely informative in nature and its purpose is to present the business project, allow the registration of interested parties and facilitate prior contact with future users and collaborators.

ElenPay does not guarantee specific deadlines for obtaining regulatory authorization, nor does it assume any responsibility for possible delays, denials or regulatory modifications that could affect its business model.

Once authorization is obtained, ElenPay will update this Legal Notice to reflect its status as an authorized provider and include all regulatory information required by current regulations.

10. Modifications to the Legal Notice

ElenPay reserves the right to modify, at any time and without prior notice, this Legal Notice, as well as the terms of use of the website, its contents, functionalities, services, design or configuration.

In the event that substantial changes are introduced that affect the rights or obligations of Users, ElenPay will endeavor to communicate such modifications through the website or by other appropriate means.

Access to and use of the website after modification of the Legal Notice will imply acceptance of the new terms and conditions.

Users are advised to periodically review this Legal Notice to be informed of possible changes.

Last update: July 2025

11. Applicable Law and Jurisdiction

This Legal Notice is governed by current Spanish legislation.

For the resolution of any controversy or conflict that may arise from access to or use of the website, ElenPay and the User, with express waiver of any other jurisdiction that may correspond to them, submit to the courts and tribunals of the User's domicile, if this is located in Spanish territory. In the event that the User has their domicile outside Spain, ElenPay and the User submit, with express waiver of any other jurisdiction, to the courts and tribunals of the city of Barcelona (Spain).

The foregoing is understood without prejudice to consumer and user protection legislation that may apply, and which establishes the mandatory jurisdiction of the courts of the consumer's domicile.

For any questions, suggestions or communications related to this Legal Notice, you can contact ElenPay through the contact means indicated in section 1 of this document.