Terms of Service and Privacy Policy

Last updated: April 17, 2026 | Version 2.0.0 These Terms of Service ("Terms") form a legally binding agreement between Bloc Claims LLC, a Texas limited liability company ("Bloc Claims," "Company," "we," "us," or "our"), and you ("you," "your," or "User"), governing your access to and use of the websites, applications, and services operated by Bloc Claims at onboard.ftxclaims.com, oa.ftxclaims.com, ftxclaims.com, and any related properties (collectively, the "Platform"). By creating an account, clicking "I Accept," or otherwise using any part of the Platform, you represent that you have read, understood, and agreed to these Terms, our Privacy Policy, the binding Arbitration Agreement, and the Consent to Data Processing & Electronic Communications set forth below (collectively, the "Agreement"). If you do not agree to every part of the Agreement, do not create an account and do not use the Platform. ## 1. Important Preliminary Disclosures — Please Read First **1.1 We are not FTX.** Bloc Claims is an independent third-party claims buyer. We are NOT affiliated with, owned by, controlled by, endorsed by, sponsored by, or acting on behalf of FTX Trading Ltd., West Realm Shires Services Inc., Alameda Research, any of their affiliates or subsidiaries, the FTX bankruptcy estate, the FTX debtors, the joint liquidators, any bankruptcy trustee, or any court. Filings in the FTX bankruptcy proceedings are made with, and claims in those proceedings are resolved by, the FTX estate and the supervising court — not by Bloc Claims. **1.2 We are not your lawyer, accountant, tax advisor, or financial advisor.** Nothing on the Platform is legal, tax, accounting, investment, or financial advice. No attorney-client relationship, fiduciary relationship, advisory relationship, or relationship of trust and confidence is created by your use of the Platform, by any communication with Bloc Claims personnel, or by your acceptance of these Terms. You are strongly encouraged to consult your own independent legal, tax, and financial advisors before selling or assigning any claim, before accepting any offer from Bloc Claims, and before making any other decision based on information obtained from the Platform. **1.3 Our business is purchasing claims.** Bloc Claims may offer to purchase your rights to payment or distribution from the FTX bankruptcy estate (your "Claim") in exchange for a cash (USDC) payment. An offer from Bloc Claims, if made, is an offer to buy. You are under no obligation to accept any offer, to sell your Claim, or to continue using the Platform. You may choose to pursue your Claim yourself directly with the FTX estate and its designated agents at no cost through those estate-operated channels. **1.4 You may get less than the estate's eventual distribution.** Any purchase price offered by Bloc Claims reflects, among other things, time value of money, litigation risk, collection risk, operational cost, jurisdictional risk, and our profit margin. The amount we offer you may be — and in many cases will be — materially less than the face value of your Claim and may be materially less than the distribution the FTX estate eventually pays to claimholders generally. You acknowledge and accept this risk. You expressly waive any claim that our offer is inadequate, unconscionable, or unfair on the basis that it is less than the estate's ultimate distribution. **1.5 Restricted jurisdictions only.** The Platform is designed exclusively for individual creditors who reside in or hold passports from jurisdictions designated as restricted by the FTX estate. We do not serve, and we will refuse to transact with, individuals or entities located in, organized in, or subject to the jurisdiction of any country, region, or list subject to comprehensive U.S., EU, UN, or UK sanctions (including, without limitation, Cuba, Iran, North Korea, Syria, the so-called Donetsk People's Republic, the so-called Luhansk People's Republic, Crimea (Sevastopol), and any other region subject to comprehensive sanctions), and we will refuse to transact with any person or entity designated on the U.S. Treasury OFAC Specially Designated Nationals List, the U.S. Commerce Department Entity List or Denied Persons List, the EU Consolidated List, the UN Security Council Sanctions List, or the UK HM Treasury Consolidated List (collectively, "Sanctions Lists"). ## 2. Modification of the Agreement We may modify the Agreement from time to time. The "Last updated" date at the top of each section reflects the effective date of the current version. Material modifications will be communicated to you by email to the address associated with your account and/or by prominent notice on the Platform. Your continued use of the Platform after the effective date of a modification constitutes your acceptance of the modified Agreement. If you do not agree to a modification, your sole and exclusive remedy is to cease using the Platform and to close your account; provided that any purchase agreement you have already signed remains governed by the version of the Agreement in effect at the time you signed that purchase agreement unless the modification expressly states otherwise. ## 3. Eligibility You represent and warrant, on your own behalf and on a continuing basis for as long as you use the Platform, that: (a) You are a natural person (not an entity, trust, partnership, estate, or organization) at least eighteen (18) years of age, or the age of majority in your jurisdiction if higher, with full legal capacity to enter into and perform the Agreement; (b) You are an individual creditor of the FTX bankruptcy estate, holding a bona fide Claim in your own name, free and clear of any lien, security interest, encumbrance, prior assignment, option, pledge, or other adverse interest; (c) You have not previously sold, assigned, pledged, or otherwise transferred the Claim or any portion of it or any interest in it to any other person or entity; (d) You are not an employee, contractor, officer, director, family member of the same, or agent of FTX Trading Ltd., any of its affiliates, any successor entity, the FTX bankruptcy estate, any joint liquidator, any bankruptcy trustee, or any court-appointed fiduciary with respect to the FTX estate; (e) You are not listed on, and you are not owned or controlled (directly or indirectly, individually or in the aggregate, by 50% or more) by any person or entity listed on, any Sanctions List, and you are not acting directly or indirectly on behalf of any such person or entity; (f) You are not located in, organized in, resident in, or a national of any country, region, or jurisdiction subject to comprehensive U.S., EU, UN, or UK sanctions; (g) Your use of the Platform does not violate any law applicable to you, including, without limitation, the laws of the country in which you reside and any applicable export control or sanctions laws; and (h) You are submitting one Claim only and have not created, and will not create, more than one account on the Platform. We reserve the right to verify any of the foregoing at any time and to suspend or terminate your account, and to decline or rescind any purchase offer, if we determine in our sole discretion that any representation is or has become untrue, incomplete, or misleading. ## 4. Account Registration & Security **4.1 Account creation.** To use the Platform, you must register an account with a valid email address, a strong password, and mandatory time-based one-time password ("TOTP") two-factor authentication ("2FA"). You are responsible for maintaining the accuracy of your account information and for promptly notifying us of any changes (including changes to your legal name, country of residence, passport country, mailing address, or payout address). **4.2 Account security.** You are solely responsible for maintaining the confidentiality of your account credentials, including your password, 2FA seed/device, and any recovery codes. You agree (i) not to share your credentials with any third party; (ii) not to use or permit the use of your account by any person other than you; (iii) to use only devices and networks that you reasonably believe to be secure; and (iv) to notify Bloc Claims immediately at the contact address in Section 24 of any suspected or actual unauthorized access to or use of your account. You are responsible for all activity that occurs under your account, whether or not authorized by you, unless and until you have notified us and we have had a reasonable opportunity to suspend the account. **4.3 No impersonation.** You agree not to impersonate any other person, use another person's credentials, create an account on behalf of another person, register using falsified identity information, or otherwise misrepresent your identity, residence, citizenship, or relationship to the Claim. Violation of this Section 4.3 is a material breach of the Agreement and may constitute fraud, identity theft, or wire fraud under applicable law. ## 5. The Claims Purchase Process **5.1 Gate-locked submission flow.** The Platform guides you through a sequential, gate-locked submission flow consisting of: (i) acceptance of the Agreement; (ii) country-of-residence and passport-of-nationality declarations; (iii) upload of your electronic Proof of Claim; (iv) upload of a KYC status screenshot from the FTX estate's claims portal; (v) upload of an account settings, profile, account details, or account dropdown screenshot from the FTX estate's claims portal; (vi) completion and upload of an IRS Form W-8BEN (or, where applicable, another appropriate IRS tax form); (vii) identity verification, anti-money-laundering ("AML") screening, politically-exposed-person ("PEP") screening, and proof-of-address verification through our third-party provider Veriff; (viii) cross-reference verification of the information you have submitted; (ix) collection of your USDC payout address and, where required, execution of a centralized-exchange certification addendum; (x) receipt of a pre-filled purchase agreement for your review and, if you choose, execution; (xi) review and signature of an initial 1 USDC payment invoice; and (xii) review and signature of one or more balance payment invoices, which may be split into a series of payments. **5.2 Admin review and right to reject.** Each step of the submission flow is subject to our administrative review. We may approve, request resubmission, request additional information, reject, or escalate any step in our sole and absolute discretion. We are not obligated to explain the basis for any rejection other than to provide a general category (e.g., "signature missing," "citizenship country mismatch"). We are under no obligation to purchase any Claim, to extend any offer, to complete any purchase, or to continue your flow. A rejection at any step does not give rise to any cause of action, any duty of good faith performance, or any claim for detrimental reliance. **5.3 Resubmission cap.** You may resubmit any rejected step up to a maximum of five (5) times per step. After the fifth rejection, that step will lock and your flow will be escalated for manual review. Escalation does not guarantee approval. We may determine, at our sole discretion, that your Claim is ineligible for purchase or that we are unable to complete verification to our satisfaction and close your file. **5.4 Pricing.** Any purchase offer will be stated in U.S. dollars (or in USDC at a stated USD-equivalent), in a written purchase agreement that you must separately accept and execute. The offer amount is determined by Bloc Claims in its sole discretion based on factors including the face amount of your Claim, the FTX estate's estimated distribution schedule, jurisdictional risk, AML/KYC results, time value of money, and our margin. You are under no obligation to accept any offer. You may negotiate, decline, or accept. If you decline, you may withdraw your Claim from the Platform at any time prior to execution of the purchase agreement; provided that any information already submitted and any audit records will be retained in accordance with our Privacy Policy. **5.5 Execution and assignment.** If you accept an offer and execute the purchase agreement, you irrevocably assign, transfer, and convey to Bloc Claims all of your right, title, and interest in and to the Claim, including without limitation the right to receive any and all distributions from the FTX bankruptcy estate and any successor, upon payment of the agreed purchase price in USDC to the payout address and network you specified and verified during the submission flow. The purchase is effective as of the date of payment confirmation on-chain, and is thereafter final and irrevocable. You further agree, at Bloc Claims's request and sole cost, to execute any additional documents and to take any further actions that may be reasonably required to give effect to the assignment or to enable Bloc Claims to enforce the Claim. **5.6 Post-payment obligations.** After payment of the purchase price, you agree (i) to forward to Bloc Claims any communication, check, distribution, notice, or other item received by you from or on behalf of the FTX estate in respect of the Claim, promptly and in its original form; (ii) not to take any action with respect to the Claim without Bloc Claims's prior written consent, including without limitation not filing any amended proof of claim, not communicating with the estate about the Claim, and not voting on any plan of reorganization; (iii) to execute any further instruments of transfer reasonably requested by Bloc Claims; and (iv) to cooperate with Bloc Claims in connection with any proof or prosecution of the Claim. **5.7 Payout address verification.** You are solely responsible for the accuracy and correctness of your USDC payout address, the network/chain you select, and any centralized-exchange account information (including account holder name) you provide. Bloc Claims will perform reasonable verification steps, including confirming the payout address with you before transmitting funds and, for jurisdictions designated as high-risk, requiring payment to a centralized-exchange account where the named account holder matches the creditor name on the Claim. We are not responsible for, and you release us from any liability arising out of, (i) loss of funds due to your submission of an incorrect address; (ii) loss of funds due to your selection of the wrong network/chain; (iii) loss of funds due to fraud, negligence, insolvency, or act or omission of any centralized exchange, self-custodial wallet provider, or other third party; (iv) loss of funds due to your failure to respond to a confirmation request; or (v) any freezing, seizure, forfeiture, confiscation, or reversal of funds by any government authority, bank, exchange, or blockchain network operator. ## 6. Representations & Warranties by You In addition to the representations in Section 3, you represent and warrant, on the date you submit each step of the submission flow, on the date you execute any purchase agreement, and on a continuing basis thereafter, that: (a) Each document you upload to the Platform is authentic, unaltered, accurate, and complete in all material respects; no document has been forged, falsified, backdated, or otherwise manipulated; and each signature affixed to any document is your own, applied with intent to sign; (b) You have the full right, power, and authority to submit each document and to sell and assign the Claim, and no consent, approval, or authorization of any third party (including without limitation a spouse, joint holder, beneficiary, trustee, or creditor) is required for you to do so; (c) The Claim is valid, unimpaired, not subject to any defense, setoff, disallowance, or reduction (other than as disclosed by the FTX estate), and has not been released, waived, transferred, encumbered, or otherwise impaired; (d) All information you provide regarding your country of residence, country of citizenship, tax residency, legal name, address, and contact details is true, accurate, and complete; (e) You are not required to report or obtain authorization for this transaction from any foreign currency, foreign exchange, or capital controls authority in your country of residence that would prohibit the transaction, or if you are, you have obtained any such authorization and will comply with any such reporting requirement at your sole cost; and (f) You have read and understood the Agreement in its entirety, you have had the opportunity to consult (or have consulted) independent legal, tax, and financial advisors of your choosing, and you are entering into the Agreement freely, voluntarily, and without duress, coercion, or undue influence. You acknowledge that Bloc Claims is relying on each of these representations and warranties in agreeing to provide the Platform and in offering to purchase any Claim. You agree that each representation and warranty survives termination of the Agreement and completion of any purchase. ## 7. Prohibited Conduct You agree not to, and not to assist or permit any third party to: (a) submit false, fraudulent, forged, altered, or misleading information or documents; (b) create more than one account; (c) circumvent, attempt to circumvent, or interfere with any security, access control, rate limit, verification, or gate-lock mechanism of the Platform; (d) reverse-engineer, decompile, disassemble, probe, scan, or test the vulnerability of the Platform; (e) use the Platform to submit any Claim that has already been sold, assigned, or pledged, or that is subject to any competing claim; (f) use any automated means (including bots, scrapers, or crawlers) to access the Platform; (g) introduce any virus, malware, Trojan horse, ransomware, or other malicious code; (h) harass, threaten, or abuse any Bloc Claims personnel; (i) use the Platform in any manner that violates any applicable law; (j) submit any personal data of any third party without that person's express written consent; (k) access the Platform from a jurisdiction from which access is prohibited; or (l) use the Platform in any way not expressly authorized by the Agreement. Any violation of this Section 7 is a material breach and may be reported to law enforcement, financial regulators, the FTX estate, and/or your resident jurisdiction's authorities. We may suspend or terminate your account and withhold or rescind any offer upon any actual or suspected violation, without notice or liability. ## 8. Intellectual Property The Platform, including its software, source code, design, layout, graphics, text, logos, trademarks, service marks, and all other content (other than content you upload), and all intellectual property rights in any of the foregoing, are owned by or licensed to Bloc Claims and are protected by U.S. and international copyright, trademark, and other laws. Subject to your compliance with the Agreement, Bloc Claims grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Platform solely for the purpose of evaluating and, if you choose, selling your Claim to Bloc Claims. No other rights are granted. All rights not expressly granted are reserved. You may not reproduce, distribute, display, adapt, modify, create derivative works of, sell, or commercially exploit the Platform or any portion of it. With respect to any content, document, or information you upload to the Platform (your "User Content"), you grant Bloc Claims a worldwide, royalty-free, fully paid-up, non-exclusive, sublicensable, transferable license to use, reproduce, store, process, transmit, modify, and create derivative works of that User Content, solely as necessary to operate the Platform, to verify and process your Claim, to generate a purchase agreement, to comply with law, to exercise our rights under the Agreement, and to defend against any claim or dispute. You represent and warrant that you have all rights necessary to grant this license and that your User Content does not infringe or misappropriate any third party's rights. ## 9. Third-Party Services The Platform integrates with and relies on third-party service providers, including without limitation Veriff for identity verification, AML/PEP screening, and proof of address; Vercel, Inc. for hosting, edge computing, and document storage (Vercel Blob); Neon, Inc. for database hosting; Google LLC for AI document parsing (via the Vercel AI Gateway, with zero-data-retention enabled); Resend, Inc. for transactional email; the American Arbitration Association for dispute resolution; and the USDC issuer (Circle Internet Financial, LLC) and various blockchain networks for payment. Your use of any third-party service may be subject to that third party's own terms and privacy policies. Bloc Claims does not control these third parties and, to the maximum extent permitted by law, disclaims any and all liability for their acts, omissions, outages, breaches, or failures. We may change third-party providers at any time in our sole discretion. ## 10. Suspension & Termination We may suspend, restrict, or terminate your access to the Platform, your account, and/or any pending submission flow, and we may decline or rescind any purchase offer, at any time, for any or no reason, including without limitation: (a) your breach of the Agreement; (b) suspected fraud, money laundering, sanctions violation, or other illegal activity; (c) a determination that you are ineligible; (d) a legal or regulatory requirement; (e) a request from law enforcement, a regulator, or a court; (f) a risk to the security or integrity of the Platform; or (g) cessation, modification, or reorganization of our business. Termination of your account does not terminate any fully executed purchase agreement. You may terminate your account at any time by contacting us at the address in Section 24, subject to our retention rights under the Privacy Policy and applicable law. Upon termination, Sections 1, 6, 7, 8 (as to User Content license necessary to retain records), 11 through 23, and any other provision that by its nature should survive termination, will survive. ## 11. Disclaimer of Warranties **TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE PLATFORM AND ALL SERVICES, CONTENT, OFFERS, AND MATERIALS ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITH ALL FAULTS, AND WITHOUT ANY WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE. BLOC CLAIMS AND ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, CONTRACTORS, AGENTS, SUPPLIERS, AND LICENSORS (COLLECTIVELY, THE "BLOC PARTIES") EXPRESSLY DISCLAIM ALL WARRANTIES, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, QUIET ENJOYMENT, TITLE, NON-INFRINGEMENT, ACCURACY, COMPLETENESS, RELIABILITY, AVAILABILITY, SECURITY, AND ANY WARRANTY ARISING FROM COURSE OF DEALING, COURSE OF PERFORMANCE, OR USAGE OF TRADE.** **WITHOUT LIMITING THE FOREGOING, THE BLOC PARTIES MAKE NO REPRESENTATION OR WARRANTY THAT: (i) THE PLATFORM WILL BE UNINTERRUPTED, SECURE, TIMELY, OR ERROR-FREE; (ii) ANY DATA, DOCUMENT, OR INFORMATION WILL BE ACCURATE, COMPLETE, OR RELIABLE; (iii) ANY PURCHASE OFFER WILL BE MADE, OR IF MADE WILL REFLECT ANY PARTICULAR VALUATION OR METHODOLOGY; (iv) THE PLATFORM IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS; (v) ANY ERRORS WILL BE CORRECTED; OR (vi) THE PLATFORM WILL MEET YOUR REQUIREMENTS OR EXPECTATIONS. ANY RELIANCE ON THE PLATFORM IS AT YOUR SOLE RISK.** Some jurisdictions do not allow the exclusion of certain warranties. To the extent any implied warranty cannot be disclaimed under applicable law, its duration is limited to the shortest period permitted by that law. ## 12. Limitation of Liability **TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT SHALL ANY OF THE BLOC PARTIES BE LIABLE TO YOU OR TO ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, LOSS OF REVENUE, LOSS OF BUSINESS, LOSS OF GOODWILL, LOSS OF DATA, LOSS OF USE, DIMINUTION IN VALUE, OR COST OF SUBSTITUTE GOODS OR SERVICES, ARISING OUT OF OR RELATING TO THE AGREEMENT, THE PLATFORM, OR ANY PURCHASE OFFER, WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, STATUTE, OR ANY OTHER THEORY, AND EVEN IF A BLOC PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.** **TO THE MAXIMUM EXTENT PERMITTED BY LAW, THE TOTAL AGGREGATE LIABILITY OF THE BLOC PARTIES TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THE AGREEMENT OR THE PLATFORM, IN THE AGGREGATE AND IN ANY AND ALL CIRCUMSTANCES, WILL NOT EXCEED THE GREATER OF (A) THE AMOUNT ACTUALLY PAID BY BLOC CLAIMS TO YOU UNDER AN EXECUTED PURCHASE AGREEMENT IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS (US$100.00).** The limitations and exclusions in this Section 12 apply regardless of whether the essential purpose of any limited remedy has failed. You acknowledge that the limitations of liability in this Section 12 are a material and bargained-for basis on which Bloc Claims is willing to provide the Platform to you, and that they allocate the risks between the parties. Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages; to the extent any such exclusion or limitation cannot be enforced under applicable law, the Bloc Parties' liability is limited to the minimum amount permitted by that law. ## 13. Indemnification You agree to defend, indemnify, and hold harmless the Bloc Parties from and against any and all claims, demands, actions, investigations, liabilities, losses, damages, judgments, settlements, fines, penalties, costs, and expenses (including reasonable attorneys' fees, expert fees, and court costs) (collectively, "Losses") arising out of or relating to: (a) your breach of the Agreement; (b) any inaccuracy or breach of any representation or warranty you have made; (c) your violation of any applicable law; (d) your violation of any right of a third party (including, without limitation, intellectual property, privacy, or publicity rights); (e) any User Content you upload; (f) any dispute between you and any third party (including, without limitation, the FTX estate, a joint liquidator, a spouse, joint holder, prior assignee, or tax authority) concerning the Claim; (g) any tax, withholding, reporting, or regulatory obligation arising from your receipt of any payment; or (h) any fraudulent, misleading, or unauthorized use of your account. We reserve the right, at our sole cost, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you. In that event, you will cooperate with our defense. You will not settle any matter affecting the Bloc Parties without our prior written consent. ## 14. Time Limitation on Claims **TO THE MAXIMUM EXTENT PERMITTED BY LAW, ANY CAUSE OF ACTION OR CLAIM YOU MAY HAVE ARISING OUT OF OR RELATING TO THE AGREEMENT OR THE PLATFORM MUST BE COMMENCED WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES; OTHERWISE, THAT CAUSE OF ACTION OR CLAIM IS PERMANENTLY AND FOREVER BARRED. THIS LIMITATION APPLIES WITHOUT REGARD TO ANY LONGER STATUTE OF LIMITATIONS OTHERWISE APPLICABLE.** ## 15. Anti-Reliance; Entire Agreement; Integration You acknowledge and agree that you are not entering into the Agreement in reliance on any statement, representation, warranty, covenant, or promise not expressly set forth in the Agreement. No oral statement, marketing statement, or statement by any Bloc Claims representative creates any obligation of any kind except to the extent reduced to writing and signed by an authorized officer of Bloc Claims. The Agreement, together with any signed purchase agreement, constitutes the entire agreement between you and Bloc Claims with respect to its subject matter and supersedes all prior and contemporaneous agreements, understandings, negotiations, and discussions, whether oral or written. ## 16. No Fiduciary or Advisory Relationship Nothing in the Agreement creates, and the parties do not intend to create, any joint venture, partnership, employment, agency, fiduciary, advisory, or trust relationship between you and Bloc Claims. Each party is and remains an independent party dealing at arm's length. Bloc Claims owes you no fiduciary duty, no duty of disclosure beyond those expressly set forth in the Agreement and required by law, and no duty of best execution. Any interest of Bloc Claims and any interest of yours are, and will be, adverse with respect to the pricing of the Claim. ## 17. Force Majeure Neither party will be liable for any delay or failure to perform any obligation under the Agreement (other than the obligation to pay money) to the extent caused by an event beyond its reasonable control, including acts of God, earthquake, flood, fire, war, civil unrest, terrorism, insurrection, rebellion, sabotage, pandemic, epidemic, quarantine, government order, embargo, sanctions action, blockchain fork or reorganization, outage of a third-party provider (including Veriff, Vercel, Neon, a blockchain network, or a USDC issuer), internet outage, denial-of-service attack, or any other event that was not reasonably foreseeable and could not have been prevented by reasonable precautions. ## 18. Assignment You may not assign, transfer, or delegate any of your rights or obligations under the Agreement, in whole or in part, by operation of law or otherwise, without our prior written consent. Any purported assignment in violation of this Section 18 is null and void. We may assign, transfer, or delegate any of our rights or obligations under the Agreement, in whole or in part, without your consent, to any affiliate, to any successor-in-interest (whether by merger, acquisition, reorganization, or sale of assets), or to any financing source. ## 19. Notices Notices to Bloc Claims must be sent by email to contact@ftxclaims.com with a courtesy copy to contact@ftxclaims.com and by registered mail to Bloc Claims LLC, Attn: Legal Department, 1309 Coffeen Avenue, Ste 1200, Sheridan, WY 82801. Notices to you may be sent by email to the address associated with your account and/or by posting to the Platform. Email notices are deemed given on the business day sent (or the next business day if sent outside business hours). Notices by registered mail are deemed given three (3) business days after deposit. ## 20. Electronic Communications, Records & Signatures You consent to receive communications from Bloc Claims in electronic form and agree that all Agreements, notices, disclosures, purchase agreements, tax forms, and other records we provide to you electronically satisfy any legal requirement that such communication be in writing. Your electronic signature (including click-to-accept, typed name, drawn signature, or cryptographically-signed acknowledgment) has the same legal effect as a handwritten signature, as provided under the U.S. Electronic Signatures in Global and National Commerce Act (15 U.S.C. § 7001 et seq.), the Uniform Electronic Transactions Act as adopted in Texas, and any applicable international equivalents (including eIDAS in the EEA, where applicable). ## 21. Governing Law The Agreement, and any non-contractual obligations arising out of or relating to it, are governed by and construed in accordance with the laws of the State of Texas, U.S.A., without regard to its conflict-of-laws principles. The United Nations Convention on Contracts for the International Sale of Goods does not apply. Subject to the Arbitration Agreement in the next section, the state and federal courts located in Harris County, Texas, have exclusive jurisdiction over any action arising out of or relating to the Agreement that is not subject to arbitration, and you consent to the personal jurisdiction of those courts and waive any objection based on inconvenient forum. ## 22. Severability; Waiver; Headings; Construction If any provision of the Agreement is held to be invalid, illegal, or unenforceable, that provision will be modified, if possible, to the minimum extent necessary to make it valid, legal, and enforceable, or if that is not possible, severed; in either case, the remainder of the Agreement will continue in full force and effect. No waiver by any party of any breach or default is or will be deemed a waiver of any other or subsequent breach or default. Headings are for convenience only and do not affect interpretation. The Agreement will be construed without regard to any rule requiring construction against the drafter. "Including" means "including without limitation." References to a statute include its successor provisions. ## 23. No Third-Party Beneficiaries The Agreement is for the benefit of the parties and their permitted successors and assigns, and confers no rights on any third party, except that the Bloc Parties are express third-party beneficiaries of Sections 11, 12, and 13 and may enforce those provisions directly. ## 24. Contact Bloc Claims LLC Legal Department Email: contact@ftxclaims.com General: contact@ftxclaims.com Wyoming address of record: 1309 Coffeen Avenue, Ste 1200, Sheridan, WY 82801.

Last updated: April 17, 2026 | Version 2.0.0 Bloc Claims LLC ("Bloc Claims," "we," "us," or "our") takes your privacy seriously. This Privacy Policy explains what personal information we collect, how we use it, who we share it with, how long we keep it, and what rights you have in connection with it. This Privacy Policy is part of our Agreement and applies to your use of onboard.ftxclaims.com, oa.ftxclaims.com, ftxclaims.com, and any related services (the "Platform"). Capitalized terms not defined here have the meanings given in the Terms of Service. ## 1. Who We Are; Controller Bloc Claims LLC is the data controller of the personal information described in this Privacy Policy, except where we act as a processor on behalf of another controller (for example, when we receive KYC results from Veriff, we act as controller of our own records; Veriff acts as controller of Veriff's records). You may contact us at contact@ftxclaims.com or at 1309 Coffeen Avenue, Ste 1200, Sheridan, WY 82801. ## 2. Scope This Privacy Policy applies to personal information we collect from or about you through the Platform, through communications with our personnel (including email, phone, and support tickets), and through our third-party service providers in connection with the Platform. It does not apply to: (a) information collected by third parties through their own websites or services, even if linked from the Platform (such information is governed by those third parties' own privacy policies); (b) information that is not personal information under applicable law; (c) information about our employees, contractors, and prospective employees (covered by separate notices); or (d) information that has been aggregated or de-identified such that it is no longer personal information. ## 3. Personal Information We Collect We collect the following categories of personal information: **3.1 Account & identity information.** Your full legal name, email address, password (in hashed form only — we never see your cleartext password), 2FA seed/device identifier, country of residence, country or countries of citizenship (including multi-passport information), and any contact information you provide. **3.2 Claim information.** Your FTX claim number, claim amount, debtor entity, creditor name as it appears on the Claim, and supporting documents (including your electronic Proof of Claim PDF). **3.3 KYC/AML information.** Through our identity-verification provider Veriff, we receive: government-issued identity document images (passport, national ID, driver's license, or equivalent); a liveness-detection "selfie" and biometric signature derived from it; document authenticity scores; AML and PEP screening results; sanctions screening results; proof-of-address document images (utility bill, bank statement, or government correspondence); extracted text and structured data from the foregoing; and Veriff's determination of whether you passed or failed each screening. **3.4 Tax information.** Information you provide on IRS Form W-8BEN or equivalent, including your foreign or U.S. tax identification number, treaty claim, country of tax residence, and signature. **3.5 Screenshot and ancillary information.** Your FTX claims portal KYC status screenshot, including any metadata (such as visible URL, status text, and displayed name) that appears in the image. **3.6 Payout information.** Your USDC wallet address, the blockchain network you select, the centralized-exchange account holder name (where required), and on-chain transaction references. **3.7 AI-extracted information.** When you upload a document, the Platform sends that document to an AI document parser (Google's Gemini 3.1 Pro Preview model, invoked through the Vercel AI Gateway with zero-data-retention enabled) to extract structured data such as names, addresses, claim numbers, amounts, and signature presence. The extracted structured data is stored by us and is presented to our administrators for review. The raw document continues to be stored in our document storage. **3.8 Usage & technical information.** IP address; browser type and version; operating system; device identifier; referrer URL; pages and resources accessed; timestamp of access; interaction events (such as scroll events used to verify that you have read the Agreement); session identifiers; and error logs. **3.9 Audit information.** Every material action you take on the Platform — including account creation, login, document upload, step submission, agreement acceptance, and payout address changes — is recorded in an audit log with your user ID, the action type, the timestamp, the IP address, and relevant metadata. Administrative actions taken by our personnel are similarly recorded. **3.10 Communications.** Emails, chat messages, and support tickets you exchange with us. We do not knowingly collect personal information about children under 18. The Platform is not directed to children. ## 4. How We Use Personal Information We use personal information for the following purposes: (a) To provide the Platform, authenticate you, operate the submission flow, and communicate with you; (b) To verify your identity, residence, and citizenship, and to screen for sanctions, PEP status, and AML red flags, in each case as required by law and by our internal risk policies; (c) To cross-reference the information you submit for consistency across documents and declarations; (d) To evaluate your Claim, formulate a purchase offer (if we choose to offer), and generate a pre-filled purchase agreement; (e) To process payment in USDC to your specified address and network; (f) To maintain our audit logs and records, to detect and investigate fraud, abuse, and security incidents, and to enforce the Agreement; (g) To comply with our legal obligations, including anti-money-laundering, counter-terrorist-financing, sanctions, tax, and court-order obligations; (h) To establish, exercise, and defend legal claims, including defending ourselves in any litigation, arbitration, investigation, or regulatory proceeding; (i) To perform analytics on aggregated and de-identified data to improve the Platform; (j) For any other purpose expressly disclosed to you at the point of collection and to which you have consented (where consent is the legal basis). We will not sell your personal information. We will not share your personal information with advertisers. We do not use your personal information to train any foundation AI model; the AI parser uses zero-data-retention and does not train on your inputs. ## 5. Legal Bases for Processing (EEA/UK Residents) If you are in the European Economic Area, the United Kingdom, or another jurisdiction with a similar legal framework, the legal bases on which we rely to process your personal information include: (a) **performance of a contract** (the Agreement and any purchase agreement); (b) **compliance with a legal obligation** (including AML, sanctions, and tax laws); (c) **our legitimate interests** (including in operating the Platform, preventing fraud, defending legal claims, and protecting the security of the Platform), balanced against your interests and fundamental rights; and (d) your **consent**, where expressly requested (which you may withdraw at any time without affecting the lawfulness of prior processing). ## 6. Who We Share Personal Information With We share personal information only with the following categories of recipients: (a) **Sub-processors and service providers** engaged by us to support the Platform, including: Veriff (identity verification, AML/PEP screening, proof of address); Vercel, Inc. (hosting, edge computing, document storage via Vercel Blob, AI Gateway); Neon, Inc. (PostgreSQL database hosting); Google LLC (AI inference via Vercel AI Gateway; zero-data-retention enabled); Resend, Inc. (transactional email); and such other providers as we may engage from time to time, under written contracts that require them to protect the information and process it only as instructed. (b) **Payment counterparties**, including the centralized exchange you designate (where applicable), to the extent necessary to verify the account holder name and transmit the USDC payout. (c) **Governmental and judicial authorities**, where we reasonably believe disclosure is required by law, subpoena, court order, regulatory request, or to respond to an ongoing investigation or proceeding. (d) **Professional advisors**, including our attorneys, accountants, auditors, and insurers, under obligations of confidentiality, where disclosure is reasonably necessary to obtain their advice or services. (e) **Successors**, in connection with a merger, acquisition, reorganization, financing, sale of assets, or similar transaction. (f) **To defend our rights**, including to establish, exercise, or defend legal claims, to enforce the Agreement, to protect the Platform against fraud, abuse, or security threats, and to protect the rights, property, or safety of Bloc Claims, our users, or others. We do not share personal information with any other third party except with your express consent. ## 7. International Transfers Bloc Claims operates primarily in the United States. By using the Platform, you understand and agree that your personal information will be transferred to, stored in, and processed in the United States and potentially in other jurisdictions where our sub-processors operate. Laws in these jurisdictions may differ from, and may not provide protections equivalent to, those in your country of residence. Where required by applicable law, we rely on appropriate safeguards for international transfers, including the European Commission's Standard Contractual Clauses (or the UK International Data Transfer Addendum, as applicable) and equivalent mechanisms. You may request a copy of the applicable safeguards by contacting us at the address in Section 14. ## 8. Retention We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to: (a) provide the Platform and complete any purchase; (b) comply with our legal, tax, accounting, AML, and regulatory obligations (which typically require retention for at least five to seven years and, in some jurisdictions, longer); (c) establish, exercise, or defend legal claims (which may require retention for the duration of applicable statutes of limitations and any extensions); (d) maintain the integrity of our audit and compliance records; and (e) prevent fraud and secure the Platform. When we no longer have a lawful basis to retain your personal information, we will delete it or irreversibly de-identify it. Backup copies may persist for a limited period after deletion in accordance with our standard backup cycles. ## 9. Security We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include: encryption at rest and in transit; at-the-database-level field encryption for sensitive personal data; role-based access controls with least-privilege principles; mandatory two-factor authentication for user accounts; separate and more restrictive access controls for administrative personnel; application-layer rate limiting; audit logging of all access to sensitive data; regular security reviews; vendor due diligence; and incident-response procedures. No method of transmission or storage, however, is 100% secure. We cannot guarantee the absolute security of any information, and you transmit personal information to us at your own risk. ## 10. Your Rights Depending on your jurisdiction, you may have the following rights with respect to your personal information: (a) **access** — to know what personal information we hold about you and to receive a copy; (b) **rectification** — to correct inaccurate or incomplete information; (c) **erasure** — to request deletion, subject to our retention rights and legal obligations; (d) **restriction** — to limit our processing in certain circumstances; (e) **portability** — to receive your information in a structured, commonly-used, machine-readable format; (f) **objection** — to object to processing based on legitimate interests; (g) **withdrawal of consent** — where processing is based on consent, to withdraw that consent at any time; (h) **not to be subject to solely automated decision-making** with legal or similarly significant effects (we do make some automated decisions in the submission flow, but material decisions — including whether to extend any purchase offer — are ultimately made by a human administrator); and (i) **to lodge a complaint** with a supervisory authority (EEA/UK) or with your state attorney general (in the United States). California residents have specific rights under the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, the right to limit use and disclosure of sensitive personal information, and the right to non-discrimination. We do not "sell" or "share" personal information as those terms are defined under the CCPA. California residents may exercise their CCPA rights by contacting us at contact@ftxclaims.com. To exercise any right, contact us at contact@ftxclaims.com. We will respond within the time period required by applicable law (generally 30 days, extendable where permitted). We may require you to verify your identity before we act on a request. We may decline a request where an exception applies under applicable law, including where retention is required by AML, tax, or other legal obligations, or where the request would disproportionately harm our ability to defend legal claims. ## 11. Cookies & Similar Technologies The Platform uses strictly-necessary cookies and local storage to operate, including to authenticate your session, remember your preferences, and enforce 2FA. We do not use advertising cookies. We do not use cross-site tracking. We do not share cookie or device data with advertising networks. ## 12. Do-Not-Track We do not respond to browser "Do Not Track" signals because there is no industry-standard interpretation of them. However, as stated above, we do not engage in cross-site tracking or behavioral advertising. ## 13. Changes to this Privacy Policy We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects the effective date of the current version. Material changes will be communicated to you by email and/or by prominent notice on the Platform. Your continued use of the Platform after the effective date of a change constitutes your acceptance of the updated Privacy Policy. ## 14. Contact Bloc Claims LLC Privacy Team Email: contact@ftxclaims.com Legal: contact@ftxclaims.com Postal: 1309 Coffeen Avenue, Ste 1200, Sheridan, WY 82801.

Last updated: April 17, 2026 | Version 2.0.0 **PLEASE READ THIS ARBITRATION AGREEMENT CAREFULLY. IT SIGNIFICANTLY AFFECTS YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT, YOUR RIGHT TO A JURY TRIAL, AND YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION OR REPRESENTATIVE PROCEEDING.** ## 1. Agreement to Arbitrate You and Bloc Claims LLC ("Bloc Claims") agree that any and all disputes, claims, or controversies of any kind, whether based in contract, tort, statute, fraud, misrepresentation, consumer protection, unfair competition, or any other theory, whether arising before, during, or after our relationship, that arise out of or relate in any way to the Agreement, to the Platform, to your Claim, to any purchase offer, to any communication between you and Bloc Claims, to the advertising or marketing of the Platform, or to the validity, enforceability, scope, or termination of this Arbitration Agreement (collectively, a "Dispute"), will be resolved exclusively through final and binding individual arbitration, and not by lawsuit in court, class action, collective action, mass action, or representative proceeding, except as expressly provided in Section 8 below. ## 2. Informal Resolution Required First Before initiating arbitration, you agree to attempt to resolve the Dispute informally for at least sixty (60) days. You must first send a written "Notice of Dispute" by email to contact@ftxclaims.com with a copy by registered mail to the address in Section 24 of the Terms of Service. The Notice of Dispute must include: (a) your full legal name and account email; (b) a detailed description of the Dispute; (c) the specific relief you are seeking; and (d) your signature. We will respond within thirty (30) days. If we do not reach a resolution within sixty (60) days of our receipt of your Notice of Dispute, either party may commence arbitration as described below. Compliance with this Section 2 is a precondition to arbitration. Failure to comply may be raised as a defense by either party. The statute of limitations and any filing-fee deadline will be tolled during the informal-resolution period. ## 3. Rules & Administrator Arbitration will be administered by the American Arbitration Association ("AAA") under the AAA Consumer Arbitration Rules then in effect, as modified by this Arbitration Agreement. The AAA rules are available at https://www.adr.org/consumer. If the AAA is unavailable or unwilling to administer the arbitration consistent with this Arbitration Agreement, the parties will select an alternative reputable arbitration administrator (such as JAMS) by mutual agreement or, failing agreement, by petition to the courts of Harris County, Texas. ## 4. Place & Form of Hearing The arbitration seat is Harris County, Texas, U.S.A. Any in-person hearing will take place in Harris County, Texas; provided that either party may request that the hearing be conducted by videoconference or that the arbitration proceed solely on written submissions, and the arbitrator will grant such a request absent a compelling reason not to. Remote participation will not be treated as disadvantageous to either party. ## 5. Arbitrator The arbitration will be conducted by a single neutral arbitrator. The arbitrator must be either a retired judge or an attorney with at least ten (10) years' experience in commercial or consumer arbitration. The arbitrator will be selected in accordance with the AAA rules. The arbitrator has authority to award any remedy that would be available in an individual action in court, except as otherwise limited by this Arbitration Agreement. The arbitrator may not consolidate proceedings, preside over any form of class, collective, or representative action, or award relief to or against anyone who is not a party to the individual arbitration. The arbitrator's award will be in writing, will include a concise statement of reasons, and will be final and binding, subject only to the narrow review provided by the Federal Arbitration Act, 9 U.S.C. § 1 et seq. ## 6. Delegation of Threshold Issues The arbitrator (and not any court) has exclusive authority to resolve any dispute concerning the interpretation, applicability, enforceability, scope, or formation of this Arbitration Agreement, including any claim that all or any part of it is void or voidable; provided that a court of competent jurisdiction (and not the arbitrator) will decide (i) whether the Class Action Waiver in Section 7 is enforceable and (ii) whether a particular Dispute falls within the small-claims carve-out in Section 8(b). If the Class Action Waiver is found unenforceable with respect to any claim, that claim will be severed and proceed in court (with all other claims remaining in arbitration). ## 7. Class Action & Representative Proceeding Waiver **YOU AND BLOC CLAIMS EACH AGREE THAT ANY DISPUTE WILL BE RESOLVED ONLY IN AN INDIVIDUAL ARBITRATION OR INDIVIDUAL ACTION (AS PERMITTED BY SECTION 8 BELOW). NEITHER YOU NOR BLOC CLAIMS MAY BRING A DISPUTE AS A PLAINTIFF OR A CLASS MEMBER IN ANY CLASS, COLLECTIVE, MASS, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING, OR AS A PRIVATE ATTORNEY GENERAL. THE ARBITRATOR MAY NOT CONSOLIDATE OR JOIN CLAIMS OF MORE THAN ONE PERSON AND MAY NOT PRESIDE OVER ANY FORM OF CLASS OR REPRESENTATIVE PROCEEDING. THIS CLASS ACTION WAIVER IS AN ESSENTIAL PART OF THIS ARBITRATION AGREEMENT. IF THIS WAIVER IS FOUND UNENFORCEABLE, THEN THE ENTIRETY OF THIS ARBITRATION AGREEMENT WILL BE NULL AND VOID, EXCEPT THAT THE CLASS ACTION WAIVER WILL REMAIN IN FORCE AND DISPUTES WILL BE ADJUDICATED IN COURT IN HARRIS COUNTY, TEXAS, ON AN INDIVIDUAL BASIS ONLY.** ## 8. Carve-Outs The parties' agreement to arbitrate does not apply to, and the following matters may be brought in court: (a) Either party's action to enforce, protect, or determine the ownership of intellectual property rights (including copyright, trademark, patent, and trade secret) or to obtain temporary, preliminary, or permanent injunctive relief; (b) An individual action in small-claims court in Harris County, Texas, so long as (i) the action remains in small-claims court, (ii) it is brought on an individual basis only, and (iii) the amount in controversy falls within the jurisdictional limit; and (c) Any action expressly required to be brought in court under applicable non-waivable law. ## 9. Mass Filing Procedures If twenty-five (25) or more similar Disputes are filed against Bloc Claims by or with the same or coordinated counsel within a 180-day period (a "Mass Filing"), the parties agree to the following procedures in lieu of the standard AAA procedures, which are essential to ensure fair, orderly, and efficient resolution and to prevent procedural abuse: **9.1 Bellwether.** The parties will select, in good faith, sixteen (16) Disputes (eight by you collectively and eight by Bloc Claims) to proceed as bellwether arbitrations in a first round. All other Disputes will be stayed pending resolution of the first-round bellwethers. No statute of limitations or filing-fee obligation will run against any stayed Dispute during the stay. **9.2 Mediation.** After the first round of bellwethers is decided, the parties will engage in a single, confidential, non-binding mediation of the remaining Disputes with a neutral mediator selected by agreement (or, failing agreement, by the AAA). **9.3 Subsequent rounds.** If mediation does not resolve the remaining Disputes, the parties will select a second round of bellwethers using the same procedure. The process continues until all Disputes are resolved. **9.4 Filing-fee allocation.** Notwithstanding any conflicting AAA rule, Bloc Claims is not required to pay the AAA's mass-filing fees that exceed what would be paid in sixteen individual consumer arbitrations at any given time. Claimants whose cases are stayed will not be required to pay additional filing fees during the stay. **9.5 Abuse.** Either party may petition a court of competent jurisdiction for an order enforcing these procedures. A court may also decline to compel arbitration and may dismiss or stay the action if it determines that the Mass Filing procedures described above are being violated or abused. ## 10. Jury Trial Waiver **TO THE FULLEST EXTENT PERMITTED BY LAW, YOU AND BLOC CLAIMS EACH IRREVOCABLY AND UNCONDITIONALLY WAIVE ANY RIGHT TO TRIAL BY JURY OF ANY DISPUTE, REGARDLESS OF WHETHER THE DISPUTE PROCEEDS IN COURT (PURSUANT TO A CARVE-OUT OR OTHERWISE).** ## 11. Fees & Costs Filing, administrative, and arbitrator fees will be allocated in accordance with the AAA Consumer Arbitration Rules. Each party will bear its own attorneys' fees and expenses, except where (a) an applicable statute provides a right to recover reasonable attorneys' fees, (b) the arbitrator determines that a claim or defense was frivolous or asserted for an improper purpose (in which case the arbitrator may shift fees as permitted by Federal Rule of Civil Procedure 11 or its state-law analog), or (c) the parties otherwise agree in writing. ## 12. Confidentiality The existence, contents, and result of any arbitration are confidential and will not be disclosed by any party except (a) as required by law, subpoena, or court order; (b) to a party's attorneys, accountants, or insurers under a duty of confidence; (c) to the extent necessary to enforce or challenge the award; or (d) with the other party's written consent. This confidentiality provision does not prevent you from making any disclosure required by law, including any disclosure to a regulator or governmental authority, and nothing in this Arbitration Agreement restricts any disclosure protected by applicable whistleblower laws. ## 13. Opt-Out You may opt out of this Arbitration Agreement by sending a written opt-out notice to contact@ftxclaims.com and by registered mail to the address in Section 24 of the Terms of Service, within thirty (30) days of the date on which you first accept the Agreement. Your opt-out notice must include your full legal name, your account email, and a clear statement that you are opting out of this Arbitration Agreement. If you opt out, the remainder of the Agreement (including the class action waiver and the jury trial waiver) will remain in effect, and Disputes will be resolved in the state or federal courts located in Harris County, Texas. Opting out of arbitration has no other effect on the Agreement or on your ability to use the Platform. ## 14. Severability; Survival If any provision of this Arbitration Agreement (other than the Class Action Waiver, which is governed by Section 7) is found unenforceable, that provision will be severed and the remainder of the Arbitration Agreement will continue in full force and effect. This Arbitration Agreement survives termination of the Agreement and will continue to apply to all Disputes that arose before or after termination. ## 15. Federal Arbitration Act This Arbitration Agreement involves interstate commerce and is governed by the Federal Arbitration Act, 9 U.S.C. § 1 et seq. (the "FAA"). To the extent state law applies, it is the law of the State of Texas. The FAA, not any state law governing arbitration, governs the interpretation and enforcement of this Arbitration Agreement.

Last updated: April 17, 2026 | Version 2.0.0 By using the Platform, you provide the following affirmative consents and make the following acknowledgments. These are in addition to, and do not limit, the consents and acknowledgments made elsewhere in the Agreement. ## 1. Consent to Data Processing You expressly consent to the collection, use, storage, processing, and disclosure of your personal information as described in the Privacy Policy, for the purposes stated there. You understand that some of this processing involves special categories of personal data (such as biometric identifiers derived from your selfie during KYC, and government-issued identity documents containing data about citizenship and national origin), and you expressly consent to the processing of such special categories of personal data as necessary for identity verification, AML/PEP/sanctions screening, and fraud prevention. You understand that if you withdraw this consent, you will not be able to use the Platform. ## 2. Consent to International Transfer You expressly consent to the transfer, storage, and processing of your personal information in the United States and in any other jurisdiction where our sub-processors operate, including where those jurisdictions may not provide the same level of data protection as your country of residence. Where required by applicable law, we rely on appropriate safeguards for those transfers. ## 3. Consent to AI-Assisted Processing You understand and consent that documents you upload will be processed by an automated AI document parser (currently Google's Gemini 3.1 Pro Preview, invoked through the Vercel AI Gateway with zero-data-retention enabled) to extract structured data fields such as names, addresses, claim numbers, amounts, and signatures. You understand that the AI parser is used to assist human administrators and is not the sole basis for any material decision affecting you. You understand that AI outputs can be inaccurate, and you consent to our use of AI outputs as inputs to an ultimate human review. ## 4. Consent to Electronic Communications & Electronic Records You consent to receive all Agreements, notices, disclosures, tax forms, purchase agreements, transaction records, and other communications from Bloc Claims in electronic form (to the email address associated with your account, or by posting to the Platform), and you agree that all such electronic communications and records satisfy any legal requirement that they be provided in writing or retained in paper form. Your click-to-accept, typed-name, drawn-signature, or similar electronic signature has the same legal effect as a handwritten signature under the U.S. Electronic Signatures in Global and National Commerce Act (15 U.S.C. § 7001 et seq.), the Uniform Electronic Transactions Act as adopted in Texas, eIDAS (in the EEA, where applicable), and any applicable international equivalent. To access electronic records, you will need an internet-connected device, a current web browser, a valid email account, and (for PDF records) a PDF reader. You may request a paper copy of any record at a reasonable charge by contacting contact@ftxclaims.com. You may withdraw consent to electronic communications at any time by contacting us, but doing so will terminate your use of the Platform. ## 5. Acknowledgment of Sanctions Compliance You acknowledge that Bloc Claims is subject to U.S. sanctions law, including economic sanctions administered by the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC"), and to other applicable sanctions regimes. You acknowledge that Bloc Claims may be required to reject or cancel a transaction, freeze or block funds, or report a transaction to a governmental authority, in order to comply with sanctions law, and that Bloc Claims is not liable to you for any action taken in good-faith compliance with sanctions law, even if the action delays, blocks, or terminates your transaction or causes you to lose the value of the transaction. ## 6. Acknowledgment of No FTX Affiliation You acknowledge that Bloc Claims LLC is an independent third-party claims buyer and that Bloc Claims is not affiliated with, owned by, controlled by, endorsed by, or acting on behalf of FTX Trading Ltd., any FTX affiliate, the FTX bankruptcy estate, any joint liquidator, any bankruptcy trustee, or any court. You acknowledge that you may continue to pursue your Claim directly with the FTX estate without using Bloc Claims or the Platform. ## 7. Acknowledgment of Valuation Risk You acknowledge that any purchase price Bloc Claims may offer is determined in Bloc Claims's sole discretion and will typically be less — and may be materially less — than the face amount of your Claim and than the FTX estate's eventual distribution. You acknowledge that you are selling your Claim in exchange for present liquidity and in exchange for transferring to Bloc Claims the time, litigation, and collection risk associated with the Claim. You acknowledge that Bloc Claims's and your respective interests in the pricing of the Claim are adverse. ## 8. Acknowledgment of Opportunity to Consult Counsel You acknowledge that you have had a reasonable opportunity to consult (or actually have consulted) independent legal, tax, and financial advisors of your choosing concerning the Agreement and any purchase transaction. You acknowledge that any decision not to consult such advisors is your own. You are not relying on Bloc Claims or any Bloc Claims personnel for legal, tax, or financial advice. ## 9. Acknowledgment of Voluntary Participation You acknowledge that your participation in the Platform is voluntary; that you are under no obligation to sell your Claim; that you may decline any offer; that you may withdraw from the submission flow at any time before executing a purchase agreement; and that Bloc Claims has not pressured, coerced, threatened, or unduly influenced you. ## 10. Acknowledgment of Record-Keeping You acknowledge that the fact, date, IP address, and version number of your acceptance of the Agreement are recorded by Bloc Claims in its immutable audit logs, and you consent to that record-keeping. You acknowledge that such records are admissible in any proceeding as evidence of your acceptance. ## 11. Severability of Consents If any consent in this section is found invalid or unenforceable, that consent will be severed to the minimum extent necessary, and the remaining consents will continue in full force and effect. If a severance results in Bloc Claims being unable, as a legal or practical matter, to process your data and provide the Platform, Bloc Claims may terminate your account and close your file, subject to the retention obligations set out in the Privacy Policy and applicable law. ## 12. Questions Questions about the Agreement, your data, or your rights should be directed to: Bloc Claims LLC Email: contact@ftxclaims.com (legal matters) Email: contact@ftxclaims.com (privacy and data requests) Email: contact@ftxclaims.com (general inquiries)