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TERMS AND CONDITIONS

Last updated: November 27, 2025

These Terms constitute a legally binding agreement between You ("User") and PT Delapan Aset Digital, including all its affiliates, subsidiaries, and other related entities, as well as PT Agrodana Futures as a licensed Futures Broker (collectively referred to as "We" or "Us"). By accessing or using the Lumen Application, services, features, or products We provide, You represent that You have read, understood, and agree to be bound by these Terms and Conditions. Use of the Application also means that You agree to comply with all applicable regulations, guidelines, and additional policies, including but not limited to Trading Rules, Privacy Policy, Risk Management Policy, and other terms We establish from time to time. You understand that futures brokerage transaction services available through the Application are provided in cooperation with PT Agrodana Futures, which is licensed and supervised by Bappebti, and is subject to the provisions of the Financial Services Authority (OJK) and Bank Indonesia (BI) in accordance with their respective authorities. Accordingly, account opening, identity verification, transaction processing, reporting obligations, and other legal obligations will be processed in accordance with applicable regulatory provisions. By continuing to use the Application, You also acknowledge and accept that every transaction activity carries risks, and all such risks are entirely Your responsibility as a User.

Application Usage

Users are required to use the Application responsibly and in accordance with applicable laws and regulations. The Application may only be used for lawful purposes, namely to access technology services facilitated by PT Delapan Aset Digital as well as futures transaction services available to Users after Users are registered and accepted as Customers of PT Agrodana Futures in accordance with applicable provisions. We reserve the right to restrict, suspend, or refuse User access to part or all of the Application's features if there is suspected abuse, violation of terms, fraud attempts, or other activities that may pose risks to Users, the system, Us, or other parties, as long as such action is necessary to maintain security, service integrity, and compliance with laws and regulations.

User Account Confidentiality

Users are fully responsible for maintaining the confidentiality and security of their Account, including but not limited to username, password, PIN, OTP codes, and other authentication methods used to access the Application. Users are required to ensure that all authentication information is stored securely, not shared with any party, and not used on unprotected devices. Users are prohibited from lending, transferring, or providing Account access to any party in any form. Any use, activity, instruction, or transaction that occurs through a User's Account, including if conducted by other parties who gain access through the User's device or information, will be deemed valid and will be the User's full responsibility. We are not responsible for losses, misuse, unauthorized transactions, or unauthorized access arising from User negligence in maintaining Account security, authentication information, or devices used to access the Application. If a User becomes aware of or suspects a security breach, unauthorized access, or compromise of authentication information ("breach"), the User must immediately update such security information and/or contact Our official support service for further protective measures. Users are also advised to always be vigilant against all forms of fraud, phishing, account takeover attempts, or parties impersonating Us through unofficial channels. We will never ask Users to disclose passwords, OTP codes, confidential information, send funds to personal accounts, or provide remote access to User devices. Users must ensure that all communications originate from official sources and not provide sensitive information to any unverified parties. Any losses arising from fraud, manipulation, social engineering, or actions of other parties beyond Our control are the User's responsibility to the extent permitted by law. If Users receive suspicious messages, calls, or interactions, Users must ignore them and immediately report them through official support channels so that handling measures can be taken to maintain Account and system security.

Personal Information

Any personal information You provide will be managed in accordance with our Privacy Policy. By using the application, You consent to the collection, use, and processing of personal data as described in that policy.

Fees

Users understand and agree that in conducting transactions through the Application, certain fees will be charged in accordance with the provisions applicable to PT Agrodana Futures as a licensed Futures Broker, including but not limited to transaction fees, commission fees, spread fees, overnight fees, position holding fees (swap), liquidation fees, account maintenance fees, and other fees determined by futures exchanges, clearing institutions, and/or regulators. The amount of fees may differ for each type of product or service and may be updated from time to time based on operational policies, exchange provisions, clearing institution provisions, or applicable laws and regulations. Information regarding applicable fees will be displayed through the Application or other official channels, and Users are deemed to have understood and agreed to all such fees at the time of conducting transactions. Users agree that all fees, commissions, and payment obligations arising from trading activities are entirely the User's responsibility. The Company reserves the right to make direct deductions from the User's account balance to fulfill arising fee obligations, including fees resulting from open positions subject to adjustments, margin calls, or automatic liquidation. Users hereby agree that under certain conditions, including market volatility, changes in exchange requirements, or adjustments to regulatory policies, fees may increase, change, or be imposed automatically and without prior notice to the extent permitted by applicable provisions. Users understand that failure to fulfill fee, commission, or margin obligations may result in automatic actions such as transaction restrictions, temporary service suspension, order rejection, or position liquidation by the system in accordance with applicable provisions. By using the Application, Users agree that these fee provisions are an inseparable part of the futures trading mechanism and that any fees incurred are part of a legitimate transaction process and must be paid by Users.

Limitation of Liability

Users understand that futures contract trading is a high-risk activity that may result in partial or total loss of funds due to price fluctuations, market volatility, changes in liquidity, and applicable margin and liquidation provisions. In using the Application, Users acknowledge that the Company provides a technology platform to access trading services conducted in accordance with applicable laws and regulations. Although We strive to provide reliable, secure, and always available services, Users understand that system availability, transaction smoothness, price data accuracy, and process speed may be affected by various factors, including market conditions, regulatory policies, exchange provisions, operational processes, and performance of supporting systems and infrastructure. Users also understand that any form of modification, manipulation, alteration of device or application settings, use of unauthorized third-party services, jailbreaking, rooting, or other actions that change how the Application works may cause disruptions, functional limitations, or security risks beyond Our control. Any unauthorized access, suspicious activities, or transactions occurring due to unprotected User devices, networks, or credentials are entirely the User's responsibility. Accordingly, Users agree that We are not responsible for losses, delays, transaction failures, price differences, loss of access, or any trading results arising from use of the Application, market conditions, or resulting from User modifications, unauthorized access, or User device failures, to the extent permitted by law. All information, prices, and data displayed on the Application are informational in nature and may experience delays, discrepancies, or differences from actual prices at the time of execution. All investment decisions and transactions are the User's independent decisions and are entirely at the User's risk. By continuing to use the Application, Users hereby agree that the Company, including directors, commissioners, employees, affiliates, partners, contractors, technology service providers, and other parties cooperating with Us, are released from any claims, demands, liabilities, or losses arising from or related to use of the Application, except as expressly required by applicable laws and regulations. This limitation of liability applies fully to the extent permitted by law.

Force Majeure

The Application and services may experience obstacles, disruptions, delays, or become inaccessible due to events or conditions beyond Our ability, power, or control ("Force Majeure"). Force Majeure includes, but is not limited to, natural disasters; fires; floods; storms; hurricanes; disease outbreaks, epidemics, or pandemics; strikes; industrial actions; riots; security disturbances; war; civil unrest; disruptions or failures of electricity supply, telecommunications networks, or service-supporting infrastructure; disruptions, failures, or suspensions of systems at exchanges, clearing institutions, futures commodity markets, financial institutions, or related financial service institutions; policies, actions, instructions, restrictions, or decisions of authorized government or regulatory bodies; changes in laws and regulations; significant changes in economic or market conditions; and failures or disruptions to systems, infrastructure, or technology necessary to enable services to operate. In the event of Force Majeure, Users understand and agree that We are not responsible for delays, failures, or inability to provide services directly or indirectly caused by such Force Majeure, and Users hereby release any claims, demands, or liabilities arising from or related to Force Majeure.

Disclaimer

Any information, analysis, projections, opinions, or statements available through the Application, including those describing the potential performance of a futures instrument, cannot be regarded as a guarantee of future results or performance. Historical performance does not reflect or guarantee future performance. Users are advised to obtain professional advice regarding legal, taxation, accounting, or risk assessment before making investment decisions or using any services available within the Application. We do not conduct research tailored to the specific investment objectives, financial needs, personal situation, or risk profile of Users. Any analytical tools, calculations, data, or information available in the Application are provided solely as general assistance tools. Analysis results may be influenced by various factors, including investment strategies, market conditions, interest rates, economic policies, and other external factors beyond Our control. Therefore, We do not guarantee that a product will achieve targets or performance as displayed by such analytical tools. Every futures instrument carries risks, including the potential for partial or total capital loss. Users must ensure that they understand such risks and obtain adequate information before making investment decisions.

Prohibitions

Users are prohibited from taking any actions that may violate Our Intellectual Property rights, including but not limited to: • Copying, modifying, duplicating, distributing, or reproducing all or part of the Application, source code, interface design, educational materials, or any content provided through the Application without written permission from Us; • Conducting reverse engineering, decompilation, disassembly, accessing source code, or attempting to obtain the structure, algorithms, or design of the Application in any way; • Creating derivative works based on the Application or Our systems; • Transferring, selling, sublicensing, or providing access to the Application to other parties without Our consent; • Using automated methods or other technologies (bots, crawlers, scripts) to access, imitate, or collect data from the Application without permission. Violation of these provisions constitutes a legal violation and gives Us the right to take civil or criminal legal action, including termination of User access.

Other Provisions

We may from time to time provide information, educational materials, promotional offers, feature recommendations, or other marketing content through the Application, email, notifications, or available official communication channels. All such information is provided for general information purposes only and is not intended as investment advice, transaction recommendations, or guarantees of any results; trading decisions are entirely the User's decisions. Users may choose to stop receiving marketing materials at any time through available settings, without affecting the continuity of operational communications or important notifications legally required. In order to maintain security, integrity, and compliance with applicable laws and regulations, We have the authority to impose restrictions, suspension, freezing, or temporary termination of part or all of User access to the Application if there are suspected violations of terms of use, unusual activities, security risks, regulatory requests, or other circumstances requiring preventive action. Any such actions are taken in good faith to protect Users, maintain system security, and fulfill applicable legal obligations. If Users experience technical, operational difficulties, or have questions regarding use of the Application, Users may contact customer service through available official support channels. We will strive to provide responses within a reasonable time and resolve issues in accordance with applicable provisions, however Users understand that handling time may vary depending on issue complexity, security verification processes, and regulatory provisions. Any complaints or disputes arising from use of the Application will be resolved first through internal resolution mechanisms, before following further processes in accordance with applicable law. Provisions in the Application may be updated, adjusted, or enhanced from time to time in line with service developments, operational policies, legal obligations, or regulatory provisions. Users are advised to review such updates periodically, and continued use of the Application constitutes User consent to the latest terms. If there are parts of these Terms that are declared invalid or unenforceable by valid judgment, other parts will remain valid to the extent permitted by law. All these provisions apply as a whole and remain binding as long as Users use the Application.

User Statement

By using the Application and/or opening an Account, Users represent that Users are at least 21 (twenty-one) years old or married so are deemed legally capable to perform civil acts, and are not under guardianship, custody, or other conditions that limit Users' legal capacity. Users also represent that all information provided in the registration process is true, complete, accurate, and accountable, and that Users are not involved in legal disputes, bankruptcy, or other circumstances prohibited by laws and regulations from opening or using futures transaction services. Users warrant that Users are not restricted or prohibited parties, including but not limited to regulatory prohibited lists, suspected crime lists, national or international sanction lists, terrorism financing lists, or money laundering prevention lists as determined by authorized institutions. Users hereby represent that Users are not and do not act for the benefit of other parties included in the Politically Exposed Person (PEP) category or parties subject to special restrictions, unless this has been honestly stated and verified in accordance with applicable legal provisions. Users understand and agree that the Company has the right to conduct additional verification, request supporting documents, reject registration, suspend access, or close Accounts if data discrepancies, indications of legal violations, or non-compliance with regulatory provisions are found. By continuing to use the Application, Users represent that all these statements are true and will remain true as long as Users use the services.

Contact Us

If you have questions, requests, or complaints, you can contact us through:

Address

Menara Batavia Lt. 3A, Jl. K.H. Mas Mansyur No.Kav. 126, Karet Tengsin, Kec. Tanah Abang, Kota Jakarta Pusat 10220

We will strive to provide a response as quickly as possible in accordance with applicable provisions.

I hereby confirm that I have read, understood, and accepted all contents of the Lumen Terms and Conditions.