Thank you for choosing Supra. This document contains the Terms and Conditions for the use of the Website and Platform by Customers and Users, as well as the rights and obligations associated with accessing, browsing, or using this Website, the Platform, and/or the Services, in accordance with the applicable law in the Republic of Colombia.

We ask Users and Customers to carefully read this document before exploring or using the Website or Platform. If you do not agree with the provisions outlined herein, please refrain from using the Website and Platform. If you are under the legal age, kindly refrain from using the services that Supra offers through the Website and Platform, as they are exclusively intended for individuals acting as importers or exporters of goods or services in the Republic of Colombia.

By accessing, browsing, or using this Website, the Platform, and/or the Services, the User and Customer acknowledge that they have read, understood, and accepted these Terms and Conditions. Therefore, by using the Website, Platform, and Services, they commit to complying with the terms and conditions detailed in this document. Welcome!

Definitions:

“Affiliate”: in relation to any legal entity, (i) any subsidiary, branch, or direct or indirect subsidiary; and (ii) any other legal entity that directly or indirectly controls, is controlled by, or is under common control with it, as defined in articles 260 and 261 of the Colombian Commercial Code, or the rules that modify, repeal, or replace them.

“Client”: any individual who has completed the registration process on the Platform and, at Supra’s sole discretion, meets the criteria to be considered a Supra client, including providing the documentation required by Supra and granting a mandate to Supra.

“Contents”: all forms of information or data disclosed on the Website and Platform, including but not limited to text, images, photos, logos, designs, animations, videos, and audios.

“Mandate Agreement”: the contract by which every Client grants a representation mandate to Supra to collect funds, make transfers or withdrawals, carry out mandatory or voluntary channeling operations, and, in general, execute all Services requested by the Client.

“Account”: the repository of information held and managed by Supra, where all transactions and payments made through Supra, or originating from the financial service or product provided by an entity associated with Supra, are recorded. Depending on the Services a Client contracts through Supra, the Account may be managed and held by an Entity Associated with Supra. In such cases, Supra will act solely as a digital correspondent.

“Entity Associated with Supra”: entities, both financial and non-financial, that partner with Supra to offer services and products related to the Services.

“Online Payment”: any payment made through Supra, whether on the Platform or on other online platforms owned by Supra or Entities Associated with Supra, using an internet connection.

“Person”: any natural person of legal age or any legal entity, national or foreign, including but not limited to commercial and civil societies, existing or de facto corporations, foundations, autonomous trusts, and any other entity with legal capacity according to the laws of the place where it is organized.

“Platform”: the technological infrastructure developed by Supra for the Client to access the Services provided by Supra, as well as to receive and send documents related to such Services, available through the website https://supra.la/ or any other means that Supra may notify to the Client from time to time.

“Representative”: with respect to a legal entity, its respective officers, shareholders, members, directors, trustees, advisors, employees, lawyers, agents, sub-agents, and Affiliates.

“Balance”: the balances displayed on the application corresponding to the Client’s balance in the account with an Associated Entity. The User may use this balance through the Platform.

“Services”: all online services that Supra provides to the Client through the Website or the Platform, including, without limitation, the payment aggregation service through which a Client delegates the processing and/or channeling of payment for one or more mandatory or voluntary channeling operations, in accordance with the applicable law of the Republic of Colombia, or in general any interaction between Supra and the Client through the Website or the Platform.

“Website”: Supra’s website, located at https://supra.la/ or at any other URL that Supra may designate at its discretion and without limitation.

“Supra”: collectively, SuPago S.A.S., Supra Negocios S.A.S., and any of its Affiliates.

“Terms and Conditions” or “T&C”: this set of conditions, terms, commitments, and policies that regulate the use of Supra by Clients and Users, as updated from time to time.

“User”: any individual browsing the Website or the Platform who has not completed the process to become a Client. Users may authenticate within the Website or the Platform with their credentials to have a personalized user experience that meets their needs or for identity verification but may not contract for the provision of Services.

  •  Use of Supra

Through Supra, in its exclusive capacity as an aggregator, the Client may (a) access technologies that allow the use of payment and collection instruments, (b) send payment orders or fund transfers on behalf of third parties, (c) transfer and receive balances to and from individuals and companies in Colombian territory or abroad, in all cases, (1) of mandatory or voluntarily channelable operations in Colombian pesos or foreign currencies, to one or more recipients residing or not residing in the Republic of Colombia, and (2) using electronic means, including bank transfers/ACH, debits to accounts, credit or debit cards issued by different banking entities and under different franchises, as offered by Supra from time to time.

  • In accordance with the applicable regulations and the regulations issued from time to time by the Banco de la República, the Service provided by Supra, as an aggregator, is carried out under a mandate granted by the Client to Supra to collect funds and make the transfers or withdrawals ordered, whether immediate or future. The Client acknowledges and accepts that (a) the collection and transfers made by Supra are made on behalf and for the benefit of the Client, and (b) the currency channeling carried out by Supra before an IMC is done on behalf and representation of the Client, who is the holder of the mandatory channeling operation.
  • The initial access to the use of Supra’s Services available on the Platform is conditioned on (i) the acceptance of these T&C by the Client, which will be deemed accepted at the moment the Client accesses the Platform, and (ii) the acceptance of the Mandate Agreement. Subsequent to the Client’s initial access, Supra may modify the T&C and/or the Mandate Agreement, which will be notified to the Client, and such modifications must be expressly accepted by the Client to continue using the Services.
  • Electronic payments made by a Client are aggregated, processed, and/or dispersed by Supra and/or Entities Associated with Supra, who receive data from bank accounts and credit cards through the Platform and/or the platforms of Entities Associated with Supra. In this sense, it may be Supra or an Entity Associated with Supra that receives payment orders or credit or debit instructions to debit or receive funds associated with a transaction from a Client’s account at a banking institution.
  • These T&C exclusively regulate the relationship between Supra and the Client, so the Client accepts and declares that its relationship with any Entity Associated with Supra is subject to the terms and conditions that, in accordance with their internal policies, are made available to the Client by Entities Associated with Supra.
  • The Client agrees that once Supra has (a) communicated the exchange rate to the Client to channel the transfers or withdrawals under the mandate granted by the Client to Supra and/or the price of the Services for a specific operation (which may or may not be included in the exchange rate), and (b) the Client has ordered the execution of a transfer or withdrawal, it will be understood for all purposes that the Client (1) accepted the conversion exchange rate of Colombian pesos or foreign currencies and the price of the Services, and (2) the transfer order constitutes an irreversible order for Supra, so the Client is obliged to transfer to Supra the total value at the agreed exchange rate and the price of the Service, as quoted by Supra and accepted by the Client concurrently or prior to the acceptance referred to in (1) above.
  • Payments made by a Client to Supra are subject to verification of effective entry into Supra’s accounts or an Entity Associated with Supra. In the event that the entry of funds is not recorded or is incomplete, the payment will be deemed as not paid or partially paid, as applicable, and the Client will not be considered released from its obligation to make the total or partially pending payment until it is made and its entry is verified.

 

  • Service Description. To use Supra’s Services, the Client must:

Have a device with the minimum technical specifications required by Supra, which may be modified at any time by Supra and are as of the last update: [specifications].

Minimum Suggested Operating Systems:

Windows 10 y 11

macOS Catalina

iOS latest three versions (15.8, 16.7.2, 17.1.1)

iPadOS latest three versions (15, 16, 17)

Android latest three versions (10-11, 12, 13)

Recommended Browsers:

Google Chrome latest 3 versions or released during the last 12 months (117, 118, 119)

Microsoft Edge latest 3 versions or released during the last 12 months (118, 119, 120)

Safari latest 3 versions or released during the last 12 months (16.6, 17.x)

To access the Website and initiate the registration process through the contact channels provided by Supra, the Client should:

  • Accept Supra’s internal policies, including, but not limited to, the personal data processing policy and Supra’s information processing policy, available on the Website.
  • Carefully read the Terms and Conditions and the Mandate Agreement, giving free and informed consent to both.
  • Create and register a personal and non-transferable password that will allow them to access their Account at any time from any compatible mobile device.

Following the Client’s instructions, Supra will order the channeling of Balances to banks, postal money order operators, bank and non-bank correspondents, and stockbrokers, either on behalf of the Client or third parties to whom the Client has a payment obligation. In any case, such orders can only be executed through Supra and in relation to the Balances or the payment methods or credit systems enabled in Supra for each Client.

Rights of the Client and User:

In the use of the Website and/or the Platform, the Client and/or User, as applicable, have the right to:

  • Personal, exclusive, and non-transferable use of the Platform within the limits and conditions provided.
  • Access to the Platform and their Account, as available.
  • Access transparent, clear, truthful, up-to-date, timely, and verifiable advertising and information about the specific features of the Service.
  • Receive, as requested by the Client, guidance, information, or education on the use of the Platform, as well as on the content of these T&C and the Mandate Agreement.
  • Print or retain transaction receipts as proof of payment for relevant purposes.
  • Review the history of their Online Payment transactions.
  • Edit their profile on the Platform.
  • Present respectful inquiries, requests, complaints, or claims through the Platform or, if necessary, through the means indicated there, to Supra or Entities Associated with Supra, as applicable, and to the competent authorities.
  • Engage in any other legally permitted and/or offered activity by Supra or Entities Associated with Supra.

Duties of the Client and User:

In the use of the Website and the Platform, the Client and/or User, as applicable, must:

  • Use the Platform properly, following the parameters established in these T&C and any other recommendations communicated by Supra to the Client and/or User. In this regard, the Client and/or User cannot use the Platform for (a) any illegal activity according to applicable law; (b) payments in virtual currency or stored value (e.g., Bitcoin); or (c) any payment or activity that Supra or Entities Associated with Supra determine as risky.
  • Provide all information requested by Supra, whether or not personal data, truthfully, accurately, and completely through the Platform for the proper provision of the Service.
  • Possess a current account, savings account, or credit card in, or issued by, one of the banking entities affiliated with Supra or Entities Associated with Supra.
  • Have their keys and other requirements required by the respective banking entity enabled for the execution of electronic payments.
  • Have the necessary physical means to use the Service through the internet.
  • Immediately inform Supra and the Entity Associated with Supra where the Client has their financial products about the loss or theft of the phone and/or mobile device used to access the Platform, for the purpose of temporarily blocking the Client’s Account. If the Client does not promptly notify Supra or the respective Entity Associated with Supra, transactions carried out by third parties with access to their information and device will be considered valid and successful, and can only be contested in case of failures attributable to Supra.
  • Act with the utmost diligence, take necessary precautions, and comply with the security recommendations periodically provided by Supra, Entities Associated with Supra, and competent authorities to prevent unauthorized third parties from accessing the Platform, as well as any relevant data or information of the Service. This includes, but is not limited to, regularly changing security passwords to access and use the Platform, with the understanding that the custody and confidentiality of the access password created by the Client for the use of Supra is the exclusive responsibility of the Client.
  • Conduct transactions through the Platform only with secure networks and from personally used devices, avoiding the use of public or untrusted networks, as well as third-party devices that are not absolutely trustworthy.
  • Report to Supra any dissatisfaction and/or alteration in the use of the Service, including, but not limited to, any unauthorized or fraudulent transaction carried out through Supra, of which the Client is aware or should have been aware.
  • Periodically review Supra’s Terms and Conditions.
  • Review and accept changes and modifications to the Mandate Agreement, for which Supra will provide prior notice through the Platform or by sending a notification to the email address provided by the Client.
  • Comply at all times with applicable law when using the Service.
  • Declarations of the Client and/or User:

The Client and/or User accepts, declares, and acknowledges in favor of Supra on each date the Client and/or User accesses the Website, the Platform, or uses the Service, and each time a modification to these T&C is made, the following:

  • They have the corporate and legal authority and capacity, as well as all required government licenses, authorizations, and consents to use the Services, as may be required.
  • Supra has previously informed the Client and/or User of these usage T&C, and they have been made available on the Platform.
  • In providing the Service, Supra acts as an agent of the Client, and, in that capacity, the collection of funds, payment orders, and the channeling of currencies are carried out on behalf and in representation of the Client.
  • Supra may charge and invoice a commission for the Services provided to the Client.
  • Transactions and electronic payments made through Supra or Entities Associated with Supra may be subject to minimum and maximum values, according to the terms and conditions of Entities Associated with Supra and/or associated banking entities.
  • In providing the Service, Supra may establish agreements with different intermediaries and partners involved in the execution of the transaction, including, but not limited to, franchises, payment networks, payment gateways, processors, virtual wallets, postal networks, payment service providers, payment facilitators, and financial entities. The Client accepts and adheres to the policies, requirements, and limitations imposed by these entities on their activity within the Service.
  • Supra is not responsible for the administration and management of the payment instrument system of the financial products of Entities Associated with Supra.
  • For the provision of the Service, and in accordance with the Client’s orders, Supra may debit the Client’s Balances for the payment of the Client’s obligations, for which it is understood that authorization has been granted.
  • Any confirmation, withdrawal, and/or reversal of payments managed through Supra, or through payment methods by Supra, will be carried out after the reconciliation of the Balances of the accounts and sub-accounts by Supra, and with the prior authorization and instruction of Entities Associated with Supra.
  • The use of Supra by Clients and/or Users, under no circumstances, transfers ownership or a license for the use of trademarks, distinctive signs, works, and in general, all material subject to the protection of the legal regime of intellectual property owned by Supra, Entities Associated with Supra, and/or any ally or business participating in the Platform.
  • Supra has no obligation to pay or recognize any type of interest or remuneration related to the Balances of the Clients, regardless of whether the Entity Associated with Supra does, as Supra does not directly receive or manage any sums but acts as an agent of the Client for the execution of an immediate or future payment.
  • At any time, Supra may choose not to provide Services to the Client and/or User and decide not to authorize transactions it considers to violate its terms and conditions, including, but not limited to, if they are carried out for unauthorized, illegal, or criminal purposes.
  • Supra is not (a) a financial institution supervised by the Financial Superintendence of Colombia, (b) an authorized foreign exchange market intermediary, or (c) a professional in the buying and selling of currencies.
  • The Services that the Client and/or User acquires through the Platform will be for exclusive and personal use.

Declarations of Supra:

Supra declares in favor of the Client on each date the Client uses the Service, and each time a modification to these T&C is made, the following:

  • Supra does not provide deposit collection, postal or stock market services.
  • Supra is not a financial institution subject to the supervision of the Financial Superintendence of Colombia.
  • Supra is not a foreign exchange market intermediary, nor does it provide currency channeling services, so it is limited to acting in accordance with the payment orders of the Client as an aggregator payment service provider for the channeling through an IMC, in its capacity as an agent, of operations that are mandatorily or voluntarily channelable by the Clients.
  • Supra is not a professional in the buying and selling of currencies, so the object of the Service is not to offer currencies to its Clients.

 

  • Limitation of Liability of Supra:
  • Compatibility of the Website and Platform: Supra does not guarantee the compatibility of the Website, the Platform, its Contents, and Services with any hardware and software.
  • Viruses and Harmful Elements: The Contents and Services of the Website and the Platform are not guaranteed to be free of viruses or other elements that may cause alterations in the User’s and Client’s computer system. Supra is not responsible for damages caused in such events.
  • Availability and Continuity of the Service: Supra does not guarantee the availability and continuous uninterrupted operation of the Website or the Platform. Therefore, it will not be responsible for damages suffered by the User and the Client, resulting from the lack of availability or continuity of the operation of the Website or the Platform.
  • External Links: The Website and the Platform may contain references and/or links to social networks and other websites owned by third parties. Supra does not endorse, recommend, or make its own the contents or services offered by such linked websites. Supra assumes no responsibility for damages resulting from the use of such linked websites and social networks.
  • User Control: Supra does not assume the obligation to control the User or the Client in the use of the Website or the Platform, its Content, and Services.
  • Validation of Payment Information: Supra is not obligated to validate the information of payments made by the Client through the Platform.
  • Information Security: Supra will not be responsible for failures in the security and protection policies of the information of Entities Associated with Supra and/or affiliated banks during the provision of the Service.
  • Improper Use of Identification Keys: Supra is not responsible for the improper use of identification and access keys by Clients, nor for the consequences arising from their misuse, loss, or improper use by an Entity Associated with Supra or any unauthorized third party.
  • Changes in Payment Methods: Supra is not responsible for changes in electronic payment methods made without prior notice by Entities Associated with Supra.
  • Failures Attributable to Entities Associated with Supra: Supra is not responsible for failures, suspensions, limitations, or incapacity of the Service attributable to Entities Associated with Supra.
  • Currency Violations: Supra will not be responsible for currency violations incurred by a Client when making a payment through the Platform.
  • Third-Party Agreements: As Supra may establish agreements with various intermediaries and allies involved in transaction execution, it is not responsible for damages or losses caused by any of these actors or any third party not affiliated with Supra.

Indemnity: The Client and User will hold Supra and its Representatives harmless from any costs, expenses, or disbursements incurred by them and/or by Supra with respect to the initiation of a demand, claim, lawsuit, legal process, conviction, litigation, or legal action of any kind, by a User, a Client, or a third party, alleging Supra’s or its Representatives’ liability for any matter that, in accordance with this document, is not the responsibility of Supra.

In such events, Supra and/or its Representatives may call upon the User and/or the Client to indemnify or defend them, assuming the defense of Supra from that moment.

For the purposes mentioned above, the concept of cost, expense, or disbursement includes, but is not limited to, losses, obligations, expenses, taxes, and reasonable costs incurred in hiring accountants, lawyers, and experts, as well as paying legal fees, accommodation, and transportation, in preparing the defense in a demand, claim, lawsuit, legal process, conviction, litigation, or legal action.

Foreign Exchange Matters:

If, at any time, the Client makes a payment through the Platform that constitutes a mandatory or voluntarily channelizable payment, in accordance with applicable law, the Client must ensure, as applicable, to (i) comply with exchange regulations, (ii) that the channeling of the payment being made is authorized and releases the obligation to channel through mechanisms allowed by applicable law, and (iii) submit the corresponding reports to the competent authority. In any case, since Supra is not a foreign exchange market intermediary or a professional in the buying and selling of currencies, Supra will not assume any responsibility regarding the channeling of payments through the use of the Platform, nor will it be liable for exchange violations imposed on the Client, other than the actions that, under applicable law, Supra is required to perform as an aggregator of payment services provider. Supra acts as an aggregator of payment services provider under current exchange regulations, and, in that regard, it is presumed that the exchange of currencies and the exchange declarations it submits are made on behalf and on behalf of the Client as the holder of the mandatory or voluntarily channelizable operation.

Taxes:

All taxes and levies caused by payments made through the Platform will be assumed in full by the Client, which will be informed by Supra at the time of contracting the Service.

Refund, Reversal, and Cancellation of Payments:

As Supra provides a payment aggregation service, and the orders placed by the Client are irreversible, any request for refund, reversal, and/or cancellation of payments made through Supra must be directed directly to the provider of goods or services of the Client, or any person benefiting from a transfer or transfer by the Client. In any case, Supra will make its best efforts to support any request for refund, reversal, and/or cancellation of payments, without this implying an obligation of results for Supra.

Supra may decline or delay the execution of processing a refund instruction if the Client is subject to insolvency proceedings.

The processing times for refunds may vary depending on the payment method used, the time elapsed since the initial payment, and the refund request, as well as the processing times by payment processors, including financial entities, Entities Associated with Supra, and Clients. Therefore, Supra assumes no responsibility for the time required to carry out activities associated with the refund process.

Supra reserves the right not to generate refunds for payments made using the Service.

In no case will Supra be obliged to pay interest or returns of any kind for payments that have been refunded or reversed.

The Client is responsible and must assume all costs, expenses, fees, fines, or penalties, regardless of the term, incurred with respect to any refund, reversal, or cancellation of payment transactions.

Free Access and Use of the Website:

Access to the Website is free and does not require prior subscription. However, some services offered through the Platform require registration and/or payment, such as, but not limited to, the request, processing, and granting of quotas, as indicated when the User or Client wishes to access these services.

Correct Use of the Website and Platform:

The User and the Client undertake to use the Website, the Platform, its Contents, and the Services offered in accordance with applicable law and the conditions set forth in this document. The User and the Client are solely responsible for the use they make of the Content of the Website, the Platform, and the Services offered therein. The User and the Client shall refrain from using the Website or the Platform improperly, including, but not limited to, actions such as:

  • Reproducing, copying, or distributing the Content of the Website or the Platform or any part thereof.
  • Transforming or modifying the Content of the Website or the Platform.
  • Using the Website or the Platform for any commercial purpose other than requesting Services.
  • Providing false, inaccurate, insufficient, or incorrect data that may mislead Supra or a third party.
  • Sending or transmitting on the Website or the Platform, obscene, defamatory, slanderous, libelous, or discriminatory content against Supra and/or any third party.
  • Introducing or spreading computer viruses or any other code of a destructive nature on the network.
  • Acting in any way against the Website, the Platform, its technological platform, or its information systems.
  • Altering, blocking, or performing any other act that prevents the display of any Content or access to any Service of the Website or the Platform.
  • Conducting computer attacks, interception of communications, unauthorized use of terminals, or identity theft.
  • Acts that intentionally cause harm to the experience of other Users or Clients and affect the provision of Supra’s services.
  • Acts that cause or attempt to cause a condition of service denied to other Users or Clients.
  • Accessing or attempting to access third-party data and information.
  • Destroying, modifying, or attempting to destroy or modify data and information of third parties.

Intellectual Property Rights:

The User and/or Client acknowledges and accepts that all intellectual property rights related to inventions, distinctive signs, trademarks, logos, works, designs, software, developments, as well as any other intangible asset linked to the object and operation of Supra’s Website and Platform, belong to Supra or any person who is the legitimate owner of them and authorizes their use by Supra on the Website or the Platform.

In no case does access to the Website or the Platform or the use of the Services it offers imply a waiver, transmission, license, or total or partial assignment of such rights unless expressly stated otherwise. Any use, copy, alteration, transformation, exploitation, reproduction, distribution, or public communication of any of the Content of the Website or the Platform not expressly authorized by the owner is prohibited.

Use of Cookies and Similar Technologies:

Supra may use cookies and other similar technologies, both on the Website, the Platform, its Content, and its Services, as well as in emails sent to Users and Clients, for purposes such as authentication, recording activities on the Website or the Platform, improving its functionality, optimizing the Services offered, analyzing market trends, analyzing demographic information about those who visit the Website and the Platform and use the Services it offers, evaluating the effectiveness of its advertising, determining who has opened the email sent and the format in which it is done. These tools allow obtaining, among other things, information regarding the type of browser and operating system used, the IP address, the time spent on the Website or the Platform, and the number of visits made to the Website and the Platform.

The User and the Client can configure their browser to disable and delete cookies. In this case, even though it will be possible to continue visiting the Website and the Platform, access to certain features or the possibility of applying to certain areas of the Website or the Platform may be restricted. If you want to learn more about the use of cookies or how to configure your web browser, please visit the website www.allaboutcookies.org.

Personal Data:

The User and/or Client authorizes Supra freely, voluntarily, previously, explicitly, to collect, store, use, circulate, delete, and in general, process personal, sensitive, financial, credit, or commercial data that has been or will be provided, by virtue of legal, contractual, commercial relationships, or any other that arises, in the development and execution of the purposes described in the signed contract.

This authorization for the processing of personal data extends during the entire time in which a link may be consolidated or persists due to any circumstance related to the purposes for which the personal data was initially provided.

Likewise, Supra may make the necessary consultations, reports, and updates in different restrictive lists and databases of behavior, commercial quota, payment habits, bank account(s) management, and, in general, the compliance with pecuniary obligations.

The User and/or Client also accepts that they have been informed and are aware of the rights granted by the legal system to the owner of personal data, including the right to know, update, and rectify personal data against the responsible party or the person in charge of processing. This right may be exercised, among others, regarding partial, inaccurate, incomplete, fractionated data that leads to error, or data whose treatment is expressly prohibited or has not been authorized.

In addition, the User and/or Client acknowledge that, in cases where it is necessary to exercise the aforementioned rights, the respective request can be made through the mechanisms provided for this purpose by Supra, according to the information on policies and procedures for the administration of personal data, freely available on the Website.

Protection of Personal Information:

The information provided by the User and/or Client when registering on the Platform is technologically safeguarded and can only be accessed by the User and/or Client through a password or, in cases where the User and/or Client requires it, by members of the team designated for this task.

The User and/or Client is solely responsible for maintaining their password and account information. To reduce risks, Supra recommends that the User and/or Client log out of their account and close the browser window when they finish their activity, especially if they share their computer with someone or use a computer in a public place.

Although Supra’s Website and Platform have a technological protection system from its servers to the internet exit, no transmission over the internet can guarantee 100% security. Supra cannot guarantee that the information entered on its Website or transmitted using its Platform is completely secure, and the User and/or Client use it at their own risk.

Compliance with Anti-Corruption, Money Laundering, and Terrorism Financing Provisions:

The Client and/or User acknowledges, understands, and voluntarily and unequivocally accepts that Supra, in compliance with its legal obligation to prevent and control money laundering and the financing of terrorism, may unilaterally and without prior notice terminate the provision of the Service when the Client and/or User, their legal representatives, executives, partners, accountants, Tax Auditors, and/or administrators:

Have been included in any of the internationally published sanction lists, including the Specially Designated Nationals and Blocked Persons List, the Sectoral Sanctions Identifications List, the Non-SDN Lists of the U.S. Department of the Treasury, the Consolidated List of Financial Stations Targets of His Majesty’s Treasury of the United Kingdom, the List of Sanctioned Firms and Individuals of the Inter-American Development Bank Group’s Sanctions Committee, the Listing of Ineligible Firms and Individuals of the World Bank Group, the Bulletin of Taxpayers of the General Comptroller of Colombia, or the government authority that performs its functions, only when taxpayers have been sanctioned for a violation of anti-corruption, money laundering, and terrorism financing provisions, the United Nations Security Council’s list of designated individuals, any list associated with individuals involved in money laundering, terrorism financing, corruption, or similar matters of the United Nations or the European Union, and any other list of general recognition replacing any of the above, as well as other mandatory lists in the Republic of Colombia.

Have been convicted, sanctioned, or charged by a competent authority for the violation or alleged violation of any anti-corruption, money laundering, and terrorism financing provisions.

Have carried out transactions and/or maintain a business relationship with a Person included in the lists mentioned in point (i) above and/or linked to the illicit activities described in point (ii) above.

No Waiver:

The failure to exercise or delay in exercising any right, power, or privilege of Supra shall not be construed as a waiver, nor does the individual or partial exercise of such rights prevent the subsequent exercise of the same or any other right, power, or privilege of Supra.

Communications:

Unless otherwise agreed, any notice or communication required or permitted under these terms and conditions that is addressed to Supra must be made through the Platform, and/or alternatively, by email to [email protected]. Notwithstanding the foregoing, Users and/or Clients must make their best efforts to ensure that notifications are made through the Platform.

The User’s and/or Client’s notification information will be as indicated on the Platform.

The sending of any notice or communication will be considered effective on the date of dispatch by the sender, under the understanding that if such communication, notice, or notification is not made during the normal business hours of the recipient, such communication will be deemed delivered on the next Business Day.

Any change in notification data must be notified with two (2) Business Days’ notice before the effective date of such modification.

Modifications, Suspension, and Cancellation:

Supra may limit, expand, or modify these Terms and Conditions of Service in all its terms. In such a case, Supra will notify the Client by publication on the Platform. If, within five (5) business days from the date of publication of the respective notice, the Client does not unilaterally terminate the Service and/or continues to execute it, it will be understood that the Client unconditionally accepts such modifications, limitations, deletions, or additions.

Similarly, Supra may suspend, limit, or cancel the Service by notifying the Client through publication on the Platform. In this case, the suspension, limitation, or cancellation will take effect on the calendar day immediately following the date of publication or sending of the notice. Supra assumes no responsibility for the delay, damages, inconveniences, or harm that the Client or any third party may suffer due to the suspension, limitation, or cancellation of the Service. In no event will it be understood that the Client is released, in whole or in part, from any payment obligations it has with Supra due to the suspension, limitation, or cancellation of the Service.

Law and Applicable Jurisdiction:

For any action or claim, the place where these terms and conditions are understood to be accepted and the domicile of the parties will be the city of Bogotá D.C., Colombia, and any dispute arising from its interpretation or application will be subject to the applicable Colombian regulations and the judges of the Republic of Colombia.

Last Update: December 6, 2023.

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