TrustSquare

trustsquare.co

Terms of Use /

End User License Agreement (EULA)

Version 1.14 · Last updated 20 August 2026 · Governing law: Republic of South Africa · Country Schedules: United Kingdom · United States · Australia · France · Portugal · New Zealand · Argentina

Operator: TrustSquare (Pty) Ltd · Registration No. 2026/340128/07

Up-front disclosure — this Platform is designed, built and operated with artificial intelligence

You are told this first, before the definitions, because you should not have to find it in a schedule. Artificial intelligence (AI) was used to design and build this Platform, its interface, its written content and this Agreement, under human direction and with the Operator remaining fully accountable for every word. AI image and video generation was used to create photographs and footage shown in demonstration listings, help material, category artwork and marketing — these depict imagined subjects, not real people, properties or items. The Platform also uses AI in live operation and offers optional AI features you may choose to use and pay for.

None of this changes your rights. Your content remains yours and is never supplied to anyone for AI model training (Section 8.3). No AI output decides anything against you without human review (Section 7.6). Paid AI features are optional and priced before you confirm (Section 5.5). The full disclosure is Section 7.7.

1. Definitions & Interpretation

1.1 Definitions

In this Agreement, the following terms have the meanings assigned to them below:

1.2 Interpretation

• References to statutes include amendments and subordinate legislation made under them.

• The singular includes the plural and vice versa.

• Headings are for convenience only and do not affect interpretation.

• "Including" and similar expressions are not words of limitation.

• References to days mean calendar days unless stated as "business days" (Monday to Friday, excluding South African public holidays).

• References to USD are to United States Dollars; references to ZAR or Rand are to South African Rand.

2. Platform Identity, Scope & Acceptance

2.1 Platform Identity

The Platform is operated by TrustSquare (Pty) Ltd (registration number 2026/340128/07, 6 Villa Christiaan, 98 Manie Road, Elarduspark, Pretoria, Gauteng, 0181) and provides an anonymity-first marketplace connecting Buyers and Sellers across multiple categories including real estate, tutoring, services, casual work, Adventures (accommodation and experiences), and Collectors (physical and digital collectibles).

2.2 Scope of These Terms

This EULA governs your access to and use of the Platform via mobile applications, web services, APIs, and all related functionality. It must be read together with the Platform's Privacy Policy at trustsquare.co/privacy.

2.3 Role of the Platform

The Platform facilitates connections between Buyers and Sellers. It is not a party to any transaction and does not:

• Own, control, or take title to any listing, property, service, or experience offered by Sellers

• Represent, employ, or create an agency relationship with Buyers or Sellers

• Guarantee the outcome, quality, safety, legality, or suitability of any transaction

• Act as a financial intermediary between Users for non-Tuppence transactions

2.4 EULA Acceptance Gate — Mandatory Before Registration

You must read and accept this EULA before your registration is created on the Platform. The acceptance process is as follows:

1. You receive a Magic Link via email or click a sign-up link on the Platform.

2. On clicking the link, an EULA acceptance screen is presented as the first step before any registration or listing data is created.

3. You must tick "I have read and agree to the Terms of Use / EULA and Privacy Policy" and click "Accept and Continue".

4. The Platform records your acceptance timestamp and EULA version number. This record is stored in the Platform's database and constitutes your binding agreement.

5. Clicking "Accept and Continue" constitutes your electronic signature on this Agreement per Section 4 of the ECT Act.

2.5 Eligibility

By accepting this EULA you represent and warrant that:

• You are at least 18 years of age;

• You have the legal capacity to enter binding agreements under South African law;

• You are not subject to sanctions, a court order barring Platform use, or a prohibition on your profession;

• If registering on behalf of a legal entity, you have authority to bind that entity;

• All information you provide is accurate, complete, and not misleading.

2.6 Nature and Limits of the Introduction Service — Not a Referral

The Introduction service is a single, limited, once-off service. Its nature and limits are as follows:

• The sole service the Platform renders in respect of an Introduction is the once-off facilitation of a bilateral exchange of contact details between one Buyer and one Seller, as described in Sections 3.2 and 5.1.

• The Introduction fee is a single, fixed, once-off charge of 1 Tuppence (USD $2.00). No further fee, commission, percentage, success fee, or other amount is or will become payable to the Platform in respect of that Introduction or any transaction, relationship, or dealing that may follow it.

• The Platform’s performance is complete, and the Introduction service is fully rendered and discharged, at the moment contact details are made available to both parties under Section 3.2. The Platform has no continuing duty, involvement, or interest in anything that follows.

An Introduction is not a referral. For the avoidance of doubt, an Introduction does not constitute, and may not be construed as:

• a referral, recommendation, endorsement, or vouching for any User, listing, or offering;

• advice of any kind, including financial, investment, credit, legal, property, or other professional advice;

• vetting, due diligence, or verification of any User or listing beyond the limited good-faith credential review described in Section 7.4;

• brokerage, agency, mandate, or intermediary services of any kind; or

• a warranty or assurance of any outcome, quality, safety, or legality.

The Trust Score and any badge are automated informational signals only and are not endorsements or recommendations. Any decision to engage or transact with a User introduced via the Platform is made solely on your own judgment and at your own risk.

3. User Accounts, Anonymity & Identity Verification

3.1 Anonymity Principle — Mode B

The Platform is built on an anonymity-first model. When you create a Seller account, your identity — name, email, business name, contact details, and exact location — is not revealed to Buyers. Your public profile shows only:

• An emoji avatar (randomly assigned)

• Your category (e.g. Property, Adventures Accommodation)

• Your Trust Score (0–100)

• Your suburb or city (general location only)

• A certification badge if verified credentials have been approved (see Section 7.3)

No photo. No name. No contact details. No personal identifiers — until both parties complete the bilateral acceptance described in Section 3.2.

3.2 Bilateral Identity Reveal — The Acceptance Gate

A Seller's identity is revealed to a Buyer only when both of the following occur simultaneously:

• The Buyer sends the Seller an Introduction request, and

• The Seller accepts that Introduction (within the applicable response window).

At the moment of bilateral acceptance, each party is shown the other's full name, email address, phone number, suburb/city, and — for Sellers — any verified professional credentials. Until both parties accept, full anonymity is maintained.

3.3 Prohibited Circumvention of Anonymity

You may not attempt to reveal your identity to the other party before bilateral acceptance. Prohibited actions include:

• Including your name, phone number, business name, or contact email in listing text or titles

• Linking to external social media profiles that identify you by name

• Communicating via off-platform channels before Introduction acceptance

Exception: Professional licence numbers and certification badges may be displayed as part of the credential system (Section 7.4). These are anonymity-neutral: they signal verified quality without revealing personal identity.

3.4 Deferred KYC — FICA Compliance Model

South Africa's FICA requires customer identification before a business relationship commences. The Platform interprets "business relationship" as the first Introduction acceptance (i.e. the first transaction), not account creation. This interpretation must be confirmed by legal counsel before publication.

Under this model, full identity verification is deferred as follows:

• Before first Introduction acceptance: account requires verified email only. Full identity is not yet required.

• After first Introduction acceptance: FICA-compliant identity verification is initiated within 24 hours. This must be completed within 5 business days. If verification fails or is not completed, the Introduction is cancelled. Tuppence already spent remains spent.

3.5 Identity Verification Process

After accepting your first Introduction, you will be asked to provide:

6. A government-issued identity document (South African Smart Card ID, passport, or driver's licence);

7. Proof of address dated within 3 months (utility bill, bank statement, or lease agreement);

8. A liveness check (selfie with ID via the Platform's third-party verification partner).

Verification is normally completed within 3 business days. Your identity documents are encrypted in transit (TLS 1.3), stored on the Platform's server (Hetzner CPX32, Germany — upgraded from CPX22 on 25 May 2026), and accessible only to the Platform's compliance team. Documents are retained for 7 years per FICA requirements and then securely deleted.

3.5A Home Affairs Identity Verification — Optional, Paid, and What It Means

The Platform offers Sellers an optional verification of their identity number against the South African Department of Home Affairs National Population Register (“NPR”). It costs 1 Tuppence and is offered at the point of identity-document upload.

Identity on the Platform has three distinct states, and only the third may be described to a Buyer as “verified”:

• Submitted — an identity number has been provided and is correctly formed. Nothing has been checked.

• Document checked — an automated check has read the uploaded document and found it legible and internally consistent with the details given. This does not confirm that the document is genuine, that the identity number exists, or that it belongs to the person who submitted it.

• Home Affairs verified — the identity number has been confirmed against the NPR. Only this state earns the verified badge.

What an NPR pass does and does not prove. A pass confirms that the identity number exists in the population register and that the recorded surname and initials match those submitted. It does not prove that the person using the account is the holder of that identity. The Platform does not represent otherwise, and no Buyer should treat the badge as a guarantee of any Seller’s conduct, solvency, or the existence or condition of any advertised property.

Verification is voluntary and is never a barrier. A Seller who does not verify keeps their listing and can still receive Introductions. The Platform does not withhold, suspend, or downrank a listing for want of verification. A Seller who declines simply forgoes the badge, and accepts that Buyers may prefer verified Sellers.

Buyer acknowledgement. Where a Buyer proceeds with a Seller who is not Home Affairs verified, the Platform will tell them so plainly before the Introduction completes. The decision to proceed is the Buyer’s, and the risk of proceeding is the Buyer’s. The Platform does not vet, inspect, or guarantee any property, and this Section must be read with Section 2.6 (Not a Referral) and Section 4.1 (Seller Responsibility).

Deposits and payments. The Platform is an introductory service. It never holds, receives, escrows, or refunds any deposit, rent, booking fee, or purchase price for any listed property, good, or service — the only money it handles is Tuppence, its own credit. Any payment a Buyer makes to a Seller is made entirely outside the Platform and at the Buyer’s own risk. Buyers are strongly advised never to pay a deposit for accommodation they have not seen or independently confirmed, and the Platform can offer no recovery, reversal, or compensation in respect of any such payment.

One check per identity, and duplicates. An identity number is verified once. The Platform stores a one-way cryptographic hash of the number — never the number itself — so that a repeat request is answered from the existing record at no further charge. If the same identity number is presented on a different account, that account does not inherit the verification: the claim is flagged for manual review, no badge is granted, and no charge is made.

POPIA consent. By requesting NPR verification you give informed, specific, opt-in consent for the Platform and its verification provider to submit your identity number and name to the Department of Home Affairs for the sole purpose of confirming your identity, and to record the outcome. This consent is given only when you request the check; it is not given by accepting this EULA. Verification results are retained as part of your account record under Section 9.

Availability. Verification depends on a third-party provider and on Home Affairs systems. Where the check cannot be completed, no charge is made and no badge is granted. The Platform does not guarantee availability and is not liable for any loss arising from a check being unavailable, delayed, or inconclusive.

3.6 Regulatory Disclosure

Notwithstanding the anonymity principle, the Platform may disclose your identity and account data to the South African Police Service, National Prosecuting Authority, Financial Intelligence Centre, courts, SARS, or FSCA, upon receipt of a lawful court order, administrative demand, or equivalent legal process. You will be notified of any such disclosure within 30 days unless the order prohibits notification.

3.7 User Responsibilities

You are responsible for all activity conducted under your account. You must not share your account credentials with any other person. You must notify the Platform immediately at [email protected] if you suspect unauthorised access to your account.

4. Listings, Content Accuracy & Categories

4.1 Seller Responsibility

You are solely responsible for the accuracy, completeness, legality, and currency of your listing content, including all descriptions, prices, photos, availability, and credential claims. The Platform does not verify listing content and makes no representations as to its accuracy.

4.2 Platform Moderation Rights

The Platform reserves the right to:

• Remove, hide, or edit any listing that violates this EULA, applicable law, or Platform policies;

• Suspend or terminate a Seller's account for repeated or serious violations;

• Reorder or prioritise listings in search results based on Trust Score and other ranking factors (see Section 12);

• At its discretion, refuse to onboard any prospective Seller.

4.3 Prohibited Listing Content

You may not list content that:

• Is false, misleading, deceptive, or fraudulent;

• Infringes the intellectual property rights of any third party;

• Promotes illegal goods, services, or activities;

• Contains obscene, defamatory, hateful, or discriminatory material;

• Includes personal contact details in violation of Section 3.3;

• Claims professional credentials you do not hold.

4.4 Categories — Open-Ended Strings

The Platform's category system is open-ended. Current and planned categories include Property (Estate Agents), Tutors, Services, Casuals, Adventures Accommodation, Adventures Experiences, and Collectors. New categories may be added at any time with notice to Users. Category strings are read dynamically from the Platform's data and are never hardcoded. Each category may have specific rules, introduction models, and Trust Score mechanics as described in Section 12.

4.5 Listing Photo Standards — All Categories

Listings in the Adventures category (Accommodation and Experiences) are strongly encouraged to include high-quality photos. By uploading photos to any listing, in any category (including Adventures and Collectors), you confirm that:

• You are the copyright owner of the photos, or have explicit written permission from the copyright holder to use them commercially;

• The photos accurately represent the property or experience as of the listing date;

• The photos do not contain personally identifiable information that would breach Section 3.3.

4.6 Listing Lifecycle — Seven States

Every listing exists in exactly one of seven states: DRAFT, LIVE, PAUSED, FADE-OUT, WITHDRAWN, BLOCKED, or ARCHIVED. The Platform may transition a listing between states automatically (system-triggered) or manually (administrator-initiated) in accordance with this Section, Section 4.8 and Section 14.5. Buyers only ever see and interact with listings in the LIVE state.

Draft listings are invisible to Buyers and expire automatically after 30 days. A withdrawn listing may be reactivated by the Seller within 90 days, after which it is archived. ARCHIVED is a permanent, terminal state: an archived listing cannot be reactivated under any circumstances, and its data is retained as described in Section 9.4.

4.7 Listing Count Limits by Subscription Tier

The number of simultaneously active (LIVE or PAUSED) listings is governed by the Seller's subscription tier: Free tier ($0/month) — maximum 2 listings; Starter tier ($5/month) — maximum 10 listings; Pro tier ($20/month) — maximum 30 listings; Agency tier (free of charge, verification required) — 10 listings base, with a cap that grows with the agency's Trust Score, subject to Platform review.

Starter and Pro Sellers may purchase additional listing capacity at 2 Tuppence per batch of 20 extra listings. Batches stack and are permanent. Extra slots are not available on the Free tier. An attempt to publish beyond the applicable cap will be rejected with an in-app upgrade or batch-purchase option; no charge is made for a rejected publish.

4.8 Listing Fade-Out (Inactivity)

A listing enters FADE-OUT when no introduction request has been received on it AND no Seller sign-in has been recorded within the inactivity window for the Seller's current tier: Free — 30 days; Starter — 60 days; Pro — 90 days; Agency — 90 days. The inactivity clock continues to run while a listing is PAUSED.

A warning email is sent to the Seller's registered address 7 days before the window closes. On entering FADE-OUT the listing is hidden from Buyers immediately and a second notice is emailed. The Seller has 14 days from being hidden to restore the listing (one tap, free of charge, any tier). If no action is taken within those 14 days the listing is automatically and permanently ARCHIVED.

4.9 Introduction Responsiveness

The introduction model requires Sellers to respond to introduction requests within 48 hours. An introduction left unanswered for 48 hours incurs a 5-point Trust Score penalty, applied to the displayed score and visible in the Seller's public evidence ledger. The penalty eases 90 days after it was incurred; recovery is time-based only and cannot be offset by additional credentials.

If the introduction remains unanswered at 96 hours it is removed and both parties are informed: the Buyer is told the introduction could not be made and is not charged; the Seller is told the introduction has been lost and the penalty stands. Three or more ignored introductions within any rolling 30-day window constitute blocking cause B3 under Section 14.5.

5. Transactions & Tuppence — The Introduction Currency

5.1 How Tuppence Works

All Platform transactions are denominated in Tuppence. 1 Tuppence (1T) = USD $2.00 (fixed). This rate does not change and does not fluctuate with currency markets.

The Tuppence model works as follows:

9. A Buyer sends an Introduction request to a Seller at no immediate cost. No Tuppence is deducted from the Buyer's balance at the time of sending. In the Casuals category, the roles are described as Requester (the person seeking help, who pays the 1T) and Helper (the person who listed their availability, who accepts). The Tuppence mechanics are identical — the party seeking the service always pays, the listed party always accepts.

10. If the Seller accepts the Introduction, 1T is deducted from the Buyer's Tuppence balance and credited to the Seller's Tuppence Wallet. Both parties' contact details are then revealed to each other. This is the only event that triggers a Tuppence deduction. (In Casuals: if the Helper accepts the Requester's Introduction, 1T is deducted from the Requester's balance and credited to the Helper's Wallet. The mechanics are identical.)

11. If the Seller declines or does not respond within the 48-hour window, no Tuppence is deducted from the Buyer's balance. The Introduction closes with no charge to either party.

12. No further Platform fee applies to any subsequent transaction between Buyer and Seller. All post-Introduction transactions occur independently of the Platform.

5.2 Tuppence Restrictions

Tuppence is subject to the following restrictions:

• Non-transferable: Tuppence cannot be transferred between User accounts;

• Non-redeemable for cash (current state): Tuppence cannot currently be converted to ZAR or any other currency. [Note: Cash-out functionality may be introduced in future, subject to FSCA compliance and updated terms];

• Platform-exclusive: Tuppence has no monetary value outside the Platform and cannot be used on any other platform;

• Non-inheritable and non-assignable: Tuppence cannot be inherited or transferred on account closure;

• No expiry of purchased or earned Tuppence (current state): Tuppence you buy or earn does not expire unless the Platform closes or your account is terminated for breach. Granted Tuppence is different: monthly subscription allowances and promotional grants are non-rolling — any unused granted Tuppence is reset to zero when your next monthly allowance is credited, so allowances do not accumulate. This reset applies only to granted Tuppence, never to Tuppence you have purchased or earned.

5.3 Introduction Model by Category

The introduction model differs by category. The Platform reserves the right to update these models with notice:

5.4 ECT Act §44 — Scope and Applicability to TrustSquare

The ECT Act §44 7-day cooling-off right applies to agreements for the supply of goods or services concluded electronically. TrustSquare supplies one service only: the Introduction. The 1 Tuppence is committed (held) when the Buyer requests the Introduction and is burned at the moment the service is delivered — when the Seller accepts. That burned Tuppence is the fee for the completed service and is not subject to reversal under ECT Act §44. Until delivery, the Tuppence is only held, not spent.

• If the Seller has not yet accepted the Introduction, the Buyer may withdraw the request by emailing [email protected] with the subject line "WITHDRAW: [Introduction ID]". Only a hold was placed; it is released in full and no Tuppence is burned.

• Any right the Buyer may have to cancel or reverse the underlying transaction with the Seller (for example, a property rental agreement, tutor engagement, or service contract) is a matter between the Buyer and the Seller under the CPA, the NCA, or any other applicable law. TrustSquare is not a party to that transaction and has no obligation or liability in connection with it.

TrustSquare's Introduction fee is earned and final on delivery (Seller acceptance); the hold is burned at that point. Before delivery it is only held, and is released if the Introduction is declined or expires. No reissuance of Tuppence is made on the basis of what occurs between Buyer and Seller after the Introduction is completed. Post-acceptance disputes — including any claim that a deal was not concluded, that goods or services were not delivered, or that either party acted in bad faith — are matters for the parties themselves and, if necessary, the National Consumer Commission or a competent court. TrustSquare's liability in such cases is limited as set out in Section 10.

5.5 AI Feature Tuppence — Optional, Per-Use, Separate from Introductions

The Platform offers an optional AI-assisted feature ("AdvertAgent" or equivalent) that allows Sellers to access artificial intelligence support for listing creation, optimisation, and related tasks. AI Feature usage is charged in Tuppence and is governed by the following rules, which are distinct from and independent of the Introduction Tuppence model:

5.6 Tuppence and the Platform — Not a Financial Intermediary

The Platform is not a financial intermediary between Users. Tuppence transactions — whether Introduction Tuppence or AI Feature Tuppence — are not financial products, loans, credit facilities, or investment instruments. Post-Introduction transactions (e.g. a rental payment, a coaching fee, a booking deposit) take place entirely outside the Platform between Buyer and Seller. The Platform has no involvement in, visibility of, or liability for such transactions. Tuppence is non-refundable and cannot be exchanged back into money; it is prepaid consideration for Platform services, not a deposit, financial product, or instrument. A released hold returns un-spent Tuppence, never cash.

5.7 Tuppence Holds and Reversals

The Platform may temporarily hold or reverse Tuppence transactions to prevent fraud, address system errors, or correct processing anomalies. The Platform will notify affected Users within 48 hours of any hold or reversal and will resolve the matter within 5 business days.

6. Fees, Subscriptions & Payment

6.1 Fee Disclosure

The Platform charges only for the following, which are presented to you before the transaction is confirmed:

• Introduction Tuppence: 1T (USD $2) per Introduction — committed (held) on the Buyer's balance when the request is made and burned only upon Seller acceptance / delivery (Section 5.1–5.4). The hold is released on decline, expiry or non-response — no Tuppence is burned in those cases;

• AI Feature Tuppence: per use, in Tuppence, capped (Free / 2T / 3T / 5T) and shown before use; everyday in-app guidance is free (Section 5.5);

• Buyer subscription fees for premium access tiers (see Section 6.2);

• Seller AI feature subscription fees, if elected (see Section 5.5);

• Any future Tuppence top-up or purchase fees (subject to updated terms and FSCA compliance).

There are no hidden fees, listing fees, commissions, or booking percentages payable by you. The Platform earns from Introduction fees, subscriptions, paid AI features, and, where disclosed, referral commissions paid to the Platform by third-party providers under Section 6.1A. Such commissions are never added to any price you pay. Advanced AI features are a priced service (per use, capped), separate from the Introduction fee (see Section 5.5).

6.1A Third-Party Referral (Affiliate) Links

• Distinct from Introductions. Some outbound links on the Platform (for example flight fares, tours, transfers, or accommodation shown for travel planning) lead to third-party providers' own websites or apps. Following such a link is not an Introduction, no Tuppence is charged for following it, and Section 2.6 is unaffected by this Section.

• Commission disclosure. Where so marked, these are referral ('affiliate') links: if you complete a booking or purchase on the provider's own site or app, the provider may pay the Platform a commission. That commission is paid by the provider, not by you, and is never added to the price you pay.

• The Platform is not the seller. The Platform is not the seller, agent, or organiser of, and is not a party to, any transaction you conclude with such a provider. The provider's own terms, privacy policy, and consumer protections govern that transaction. The Platform's role remains information and introduction only.

• Indicative information. Any prices, fares, schedules, or availability shown on the Platform for such third-party services are indicative, cached information for planning purposes only; the binding price and availability are those shown by the provider at the time of booking.

6.1B Partner Content Displayed on the Platform

• What it is. In addition to outbound links (Section 6.1A), the Platform may display Partner Content — photographs, descriptions, prices, reviews, and availability supplied by third-party brands (for example tour, activity, transfer, or accommodation providers) under licence — directly within Platform pages, including in response to a Buyer's travel enquiry.

• Openly branded — outside Mode B. Partner Content is always presented under the supplying brand's own name and marking. The Anonymity Gate / Mode B (Section 3.1) applies to Sellers holding accounts on the Platform; a partner brand is not a Seller, holds no Seller account, and is never anonymised. No Introduction is offered, required, or charged in respect of Partner Content.

• Booking and commission. Any booking of Partner Content is concluded on the provider's own site or app under Section 6.1A, whose terms — commission disclosure, the Platform not being the seller, and the indicative nature of displayed information — apply equally to Partner Content.

• Clear separation. The Platform keeps Partner Content visually and functionally distinct from Seller listings, so a Buyer can always tell an anonymous Seller advert (an Introduction product) from openly-branded Partner Content (a referral product).

6.2 Buyer Subscription Tiers

Introduction fees apply per Introduction regardless of subscription tier (Section 6.1); the Buyer subscription controls search and wishlist geographic reach only.

6.3 Tuppence Service Credit Reissuance (not a Refund)

Tuppence is a non-transferable, non-redeemable platform service credit. It is not money. No Tuppence is deducted from a Buyer's balance unless and until the Seller explicitly accepts the Introduction. If the Seller declines or does not respond, no charge arises and no reissuance is necessary. The Platform will reissue Tuppence units (not ZAR) to a Buyer's balance as a discretionary service credit only in the following circumstances:

• Seller did not respond to the Introduction within the 48-hour window — no Tuppence was deducted (the charge only fires on acceptance), so no reissuance is required; the Introduction closes automatically with no charge to the Buyer;

• Seller declined the Introduction — no Tuppence was deducted (the charge only fires on acceptance), so no reissuance is required; the Introduction closes with no charge to the Buyer;

• Buyer withdraws the Introduction request before Seller acceptance (per Section 5.4) — no Tuppence was deducted, so no reissuance is required; the Introduction closes with no charge;

• Tuppence is not reissuable under any circumstance. Spending Tuppence on an Introduction request or AI feature consumes the Tuppence regardless of outcome. This is the consideration for the buyer-commitment signal that underpins the Platform’s anti-spam design.

• The Platform terminates your account for convenience under Section 14.3 — unused Tuppence is retained for 24 months and restored in full on re-registration with the same verified identity; no Tuppence is forfeited, and no cash payment or ZAR conversion is made (see Section 14.3).

Tuppence already credited to a Seller's Wallet upon acceptance of an Introduction is not reissuable under any circumstances. Tuppence is not redeemable for cash under any circumstances. Tuppence balances accrue no interest. Unused Tuppence expires after 24 consecutive months of account inactivity (no login, no Introduction, no purchase). The Platform will notify you by email not less than 30 days before expiry. Tuppence may not be used by a Buyer to settle any obligation owed to a Seller outside of the Platform's Introduction flow; any purported such arrangement is void and of no effect. Nothing in this Section 6.3 creates a contractual right of repayment of money paid; all reissuances described above are discretionary platform actions exercised by TrustSquare (Pty) Ltd in accordance with its consumer-protection obligations and SARB interpretive guidance on stored-value service credits. Once a Seller has accepted an Introduction and 1T has been deducted from the Buyer's balance, that deduction is final and irrevocable. Any subsequent agreement between Buyer and Seller to act as though the Introduction did not occur, to conduct their transaction outside the Platform in order to avoid the Tuppence charge, or to request a reversal on the grounds that no transaction ultimately took place between them, does not entitle either party to a reissuance. The accepted risk of an Introduction not resulting in a completed transaction is borne by the accepting party — the Seller in standard categories, the Helper in the Casuals category.

6.4 Payment Processor

Tuppence purchases (when enabled) and subscription payments are processed by Paystack (a registered payment service provider in South Africa). By making a payment on the Platform, you agree to Paystack's terms and privacy policy. The Platform is not responsible for payment processing errors, delays, or security incidents attributable to Paystack.

6.5 Taxes

You are solely responsible for determining and remitting all taxes arising from your use of the Platform, including income tax, VAT, and any withholding obligations. The Platform does not withhold or remit taxes on your behalf. You may request a Tuppence transaction history statement for tax purposes by emailing [email protected].

6.6 Direct Marketing Compliance (CPA 2026 Amendment)

The Platform complies with the direct marketing provisions of the Consumer Protection Act No. 68 of 2008. Every promotional communication sent by the Platform includes an unsubscribe mechanism. Opt-out requests are processed within 5 business days.

By creating an account you opt in to Introduction notification emails and Platform marketing. You may opt out at any time via your account settings or by emailing [email protected] with the subject "OPT-OUT".

7. Professional Credentials, Certification & AI Features

7.1 Professional Licensing Obligations

If your category requires professional registration or licensing under South African law, you agree to hold the required licence at the time of listing and keep it valid throughout your use of the Platform. Known licensing requirements include:

7.2 Licence Attestation

At account creation, you attest that you hold all required professional licences and that you are not barred by law from practising your profession. False attestation is grounds for immediate account termination and may give rise to civil or criminal liability. The Platform reserves the right to verify your licence through official registers (e.g. EAAB database).

7.3 Adventures Certification Uplift — Trust Score Bonus

Sellers in the Adventures category (Accommodation and Experiences) may upload verifiable credentials to earn a Trust Score bonus that increases listing visibility. This mechanism is specific to Adventures and does not apply to other categories without a separate platform decision.

Bonus certification types and indicative Trust Score awards:

7.4 Certification Upload & Review Process

To claim a certification bonus:

13. Upload a photo or PDF of your certificate during Adventures onboarding or from your Seller profile.

14. The certification is marked Pending Review. The Trust Score bonus is not applied until an administrator has reviewed and approved the certification.

15. Review is normally completed within 5 business days.

16. On approval, the bonus is applied to your Trust Score and your listing re-ranks accordingly.

17. If a certificate expires or is revoked, you must notify the Platform within 5 business days. The Platform may withdraw the bonus and adjust your Trust Score.

7.5 Anonymity and Credentials

Certification badges (e.g. a shield icon with star count or certification abbreviation) are visible on your listing card to Buyers before Introduction acceptance. This is a deliberate exception to the anonymity principle: the badge signals verified quality without revealing your personal identity. Your underlying certificate and personal details are stored by the Platform but are never disclosed to Buyers until bilateral acceptance.

7.6 AI-Assisted Features

The Platform may use artificial intelligence and machine learning to assess listing quality, detect duplicate listings or potential fraud, provide category recommendations, and surface relevant listings to Buyers. AI features do not make final decisions: the Platform retains override authority, and no AI-generated output is used to permanently penalise a User without human review. You may not use automated tools, bots, or scripts to interact with the Platform.

7.7 Disclosure of the Platform's Own Use of Artificial Intelligence

Sections 5.5 and 7.6 describe AI features offered to you. This section discloses how TrustSquare itself uses AI to make and run the Platform. It is given voluntarily and in full, because a platform whose product is trust cannot conceal its own methods.

• Design and construction. The Platform — its software, user interface, written content, help material and legal documentation, including this Agreement — was designed and built with substantial AI assistance under human direction. AI assistance does not dilute the Operator's accountability: responsibility for every provision of this Agreement and for the conduct of the Platform rests with TrustSquare (Pty) Ltd.

• Imagery and video. Photographs, illustrations and video used in demonstration listings, onboarding and help content, category artwork and marketing material were in many cases created using AI image and video generation. They depict imagined subjects. They are not photographs of real people, properties, vehicles, animals or items, and any resemblance to a real person or property is unintended and coincidental.

• Demonstration listings are not offerings. Sample listings supplied by the Platform are shown only in the Platform's demonstration mode, which displays a persistent on-screen "Demo mode" banner, and are excluded from ordinary live browsing. They are not real offerings, no Seller stands behind them, and no Introduction or transaction can be concluded against them.

• Provenance markers. Media produced by AI tools commonly carries provenance information embedded by the generating tool — visible credit, embedded C2PA content credentials, or an invisible watermark detectable by the provider. Where such markers are present in media the Platform publishes, the Platform does not strip, alter or attempt to defeat them, and does not present AI-generated media as photography of a real subject.

• AI in live operation. The Platform's operational use of AI is governed by Section 7.6, and optional paid AI features by Section 5.5. This section discloses; it does not extend those permissions.

• Your content is not training material. The Platform does not supply Your Content to any third party for the training of AI models, and does not use Your Content to train models for use outside the Platform (Section 8.3).

• What you may not do. You may not upload AI-generated or AI-altered media that misrepresents the condition, appearance, location, provenance or existence of anything you list, in any category. Ordinary enhancement of a genuine photograph — cropping, straightening, exposure and colour correction — is permitted; generating a subject, or altering one so as to change what a Buyer would encounter, is not. This applies in addition to the warranties in Sections 8.4 and 8.7, and a listing breaching it may be removed under Section 8.8.

8. User-Uploaded Content, Photo Rights & IP Indemnity

8.1 Your Copyright Ownership

You retain full copyright ownership of all content you upload to the Platform, including listing photos, videos, descriptions, and other media ("Your Content"). Nothing in this EULA transfers copyright ownership from you to the Platform.

8.2 Licence Granted to the Platform — Full In-Platform Use

By uploading Your Content to the Platform, you grant the Platform and its affiliates, sub-contractors, and technical service providers a non-exclusive, worldwide, royalty-free, perpetual, irrevocable licence to use Your Content in the following ways across all current and future TrustSquare applications and platform features:

• Store, host, cache, and back up Your Content on Platform servers and content delivery networks;

• Display and present Your Content on all Platform screens, listing cards, search results, category browsers, Buyer-facing views, and Seller dashboards — across web, mobile, and any future application in the TrustSquare product family;

• Technically process Your Content as needed for Platform operation: resizing, cropping, compression, format conversion, thumbnail generation, and watermarking for display optimisation — without material alteration of the substantive content;

• Use Your Content within Platform-internal promotional and discovery features, including featured listings, category highlights, onboarding screens, and in-app recommendations shown to Platform Users;

• Reproduce and distribute Your Content solely within the Platform ecosystem to facilitate the connection between Buyers and Sellers;

• Retain a cached or archived copy of Your Content for legal, compliance, audit, or dispute resolution purposes for up to 7 years after your account is closed, as required by applicable law.

8.3 What the Platform Will Never Do With Your Content

Notwithstanding the broad licence in Section 8.2, the Platform gives you the following unconditional commitments:

• The Platform will never sell, license, or transfer Your Content to any third party as photo stock, stock imagery, or for any independent commercial purpose outside the Platform;

• The Platform will never provide Your Content to stock photography agencies, image libraries, data brokers, advertising networks, or any external commercial entity;

• The Platform will never use Your Content in external advertising or marketing campaigns — print, digital, social media, or otherwise — without your express prior written consent given separately from this EULA;

• The Platform will never sell, license, or supply Your Content to any third party for the training, fine-tuning, or evaluation of artificial intelligence or machine-learning models, and will never use Your Content to train a model for use outside the Platform. In-Platform processing described in Sections 7.6 and 7.7 — quality, duplicate and fraud signals, categorisation and relevance — is not training material for external models;

• The Platform will never create derivative works from Your Content for sale or distribution outside the Platform.

8.4 User Warranty — Ownership and Right to Upload

By uploading any photo, image, video, or other media to the Platform, you make the following legally binding warranties to the Platform on each occasion of upload:

18. You are the sole and original copyright owner of the uploaded content, OR you hold a valid, written, transferable licence from the copyright owner that expressly authorises you to grant the licence in Section 8.2;

19. The content does not infringe any copyright, moral right, trade mark, design right, personality right, right of privacy, right of publicity, or any other intellectual property or personal right of any third party anywhere in the world;

20. You have obtained all necessary consents from any identifiable persons appearing in photos (including model releases where required) and from any property owners whose property is depicted, where such consent is required by applicable law;

21. The content is not defamatory, obscene, unlawful, threatening, harassing, or otherwise in violation of any applicable law;

22. Your upload does not violate any confidentiality obligation, court order, or contractual restriction binding on you;

23. You have the full legal capacity and authority to grant this licence and to make these warranties.

These warranties are given by you each time you upload content. They are ongoing and must remain true for as long as Your Content remains on the Platform. If any warranty becomes false after upload (for example, because a third party asserts copyright), you must notify the Platform immediately at [email protected] and request removal of the affected content.

8.5 IP Indemnity — User's Full Liability for Infringing Uploads

The Platform accepts no liability for any intellectual property infringement arising from content uploaded by Users. You agree to fully indemnify, defend, and hold harmless the Platform, its directors, officers, employees, agents, and technical service providers from and against all claims, demands, proceedings, losses, damages, costs, and expenses (including reasonable legal fees) arising from or in connection with:

• Any claim by a third party that Your Content infringes that party's copyright, trade mark, design right, patent, moral right, right of privacy, right of publicity, or any other intellectual property or proprietary right;

• Any claim arising from your failure to obtain required model releases, property releases, or other consents for content depicted in your photos;

• Any breach of the warranties in Section 8.4;

• Any use by the Platform of Your Content in accordance with the licence granted in Section 8.2 that is subsequently alleged to infringe a third-party right because of your failure to hold the necessary rights at the time of upload;

• Any takedown notice, DMCA claim, or equivalent IP enforcement action filed against the Platform as a result of Your Content.

This indemnity obligation survives the termination of your account and this EULA. The Platform reserves the right to assume exclusive control of the defence of any indemnified claim at your cost, in which case you agree to cooperate fully with the Platform's defence.

8.6 Platform's IP Enforcement Response (Notice and Takedown)

If a third party believes that content on the Platform infringes their intellectual property rights, they may submit a written notice to [email protected] including: a description of the allegedly infringing content and its location on the Platform; evidence of the claimant's ownership of the right allegedly infringed; and a statement that the claimant has a good-faith belief that the use is not authorised. The Platform will:

24. Acknowledge receipt within 1 business day;

25. Investigate within 5 business days;

26. Disable access to content that, on reasonable assessment, appears to infringe a third-party right;

27. Notify the User who uploaded the content of the takedown and the reason;

28. Provide the User with an opportunity to submit a counter-notice if they dispute the claim.

The Platform's response to a takedown notice does not constitute an admission of liability. The Platform acts as an intermediary in good faith and its actions are taken in compliance with the ECT Act Section 79 safe harbour provisions.

8.7 Listing Photo Standards — All Categories

Adventures listings (Accommodation and Experiences) are photo-intensive by nature. In addition to the warranties in Section 8.4, Sellers listing Adventures content additionally confirm by each upload that:

• Photos accurately and honestly represent the accommodation, property, or experience as at the date of upload and have not been digitally manipulated in a way that materially misrepresents what a guest would encounter;

• No photo depicts a property or experience that the Seller does not have the right to offer on the Platform;

• For accommodation photos: the Seller has the right to permit guests to access and stay in the depicted property;

• For experience photos: the photos depict activities that the Seller is qualified and authorised to offer.

8.8 Content Removal

If you delete a listing, the associated photos and media are removed from public display within 48 hours. If you delete your account, all publicly visible links to Your Content are removed. Cached content on third-party CDN networks may persist for up to 30 days before expiry.

Content required for legal, compliance, or dispute purposes is retained for up to 7 years after account closure per Section 8.2 and applicable law. This retained content is not accessible to the public or to other Users.

8.9 Platform's Own Intellectual Property

All Platform software, source code, design systems, trade marks, trade names, logos, and proprietary content are the property of the Operator or its licensors and are protected by South African and international intellectual property law. Nothing in this EULA grants you any right to use the Platform's intellectual property other than as strictly necessary to use the Platform in accordance with this EULA. Unauthorised reproduction, reverse-engineering, or commercial use of the Platform's intellectual property is strictly prohibited and may give rise to civil and criminal liability.

8.10 Collectables Reference Library

Within the licence granted in Section 8.2 (and without limiting the commitments in Section 8.3), photographs uploaded to Collectors listings may be included in the Platform’s anonymised reference features — set galleries, theme browsers, and set-completeness views (collectively, the “Reference Library”). The Reference Library exists to help collectors see what complete sets look like, select themes, and identify items.

• Anonymised use only: Reference Library images are not attributed to you, are stripped of embedded metadata (including location data), and are not linked to your identity, account, or listings.

• In-Platform and free to view: the Reference Library is a Platform feature, freely viewable, and is never sold, licensed, or supplied to any third party — the Section 8.3 commitments apply to it in full.

• Continuity: images already incorporated into the Reference Library may remain after the source listing is removed or the contributing account is closed, per the licence in Section 8.2, so that reference galleries do not degrade as accounts come and go.

• Future uploads: you may withdraw Reference Library inclusion for future uploads at any time via your account settings or by emailing [email protected]; withdrawal does not affect images already incorporated.

• Third-party rights: artwork, names, and logos appearing on collectable items remain the property of their respective rights-holders (for example, trading-card publishers). The Reference Library is an unofficial, free-to-access reference and is not endorsed by, affiliated with, or sponsored by any rights-holder. The notice-and-takedown process in Section 8.6 applies to Reference Library content.

9. Privacy, Data Protection & POPIA Compliance

9.1 Privacy Policy

The Platform's full Privacy Policy is available at trustsquare.co/privacy and is incorporated into this EULA by reference. In the event of any conflict between this EULA and the Privacy Policy regarding personal data matters, the Privacy Policy prevails.

Country privacy supplements: for Users habitually resident in the United Kingdom, the United States, or Australia, the additional privacy provisions of the applicable Country Schedule (UK GDPR / Data Protection Act 2018; US state privacy laws including the CCPA/CPRA; the Australian Privacy Act 1988 and APPs) apply together with the Privacy Policy.

9.2 Data We Collect and Why

9.3 POPIA Consent

By accepting this EULA, you give informed, specific, opt-in consent (as required by POPIA) to the processing described in Section 9.2. You specifically consent to deferred identity verification as described in Section 3.4. You may withdraw any consent by deleting your account (Section 14.1), subject to legally mandated retention periods.

9.4 Data Retention

• Active accounts: identity and transaction data retained for account lifetime plus 7 years (FICA requirement);

• Deleted accounts: personal data anonymised or deleted within 30 days, except where a legal hold applies;

• Certification documents: retained while account is active; deleted on account closure unless a regulatory hold applies;

• Usage analytics: 30 days (anonymised at collection);

• All data: permanently deleted after applicable retention period expires.

9.5 Third-Party Disclosure

Personal data is disclosed only to:

• South African regulatory and law enforcement bodies on lawful demand (SAPS, NPA, FIC, SARS, FSCA, Information Regulator);

• Other Users, only after bilateral Introduction acceptance (Section 3.2);

• Payment processors (Paystack) for transaction processing, under data processing agreement;

• Service providers (Cloudflare R2 (primary) and Hetzner local disk (redundant mirror) for photo storage; email delivery provider) under data processing agreements and POPIA-compliant terms;

• The Platform's identity verification partner (Section 3.5) for KYC processing.

Personal data is never sold to third parties.

9.6 International Data Transfers

Platform servers are hosted on Hetzner (currently CPX22, upgrading to CPX32 on 25 May 2026), located in Germany (EU). Photo storage uses a write-to-both architecture: Cloudflare R2 (EU-based CDN, primary) with automatic failover to a Hetzner local disk mirror on the same EU-hosted server. All storage is EU-based and governed by GDPR, which provides an adequate level of protection recognised under POPIA. Data Processing Agreements are in place with Cloudflare and Hetzner.

9.7 Your POPIA Rights

You have the following rights under POPIA, exercisable by emailing [email protected]:

• Access: request a copy of your personal data in machine-readable format (CSV or JSON);

• Correction: update inaccurate data via your profile settings or by contacting support;

• Deletion (Right to be Forgotten): request deletion of your account and data within 30 days, subject to legal holds;

• Object: opt out of marketing communications, analytics, or specific processing activities;

• Lodge a complaint with the South African Information Regulator at inforegulator.org.za.

Requests are processed within 20 business days.

9.8 Data Security

The Platform employs TLS 1.3 encryption in transit, server-side encryption at rest, role-based access controls, and daily encrypted backups to Cloudflare R2 with 14-day retention. Photos are stored redundantly on both Cloudflare R2 and a Hetzner local disk mirror, ensuring availability even if either storage layer is temporarily unreachable. Security controls are reviewed periodically.

9.9 Data Breach Notification

In the event of a data breach that compromises the confidentiality, integrity, or availability of your personal data, the Platform will notify you by email and notify the South African Information Regulator within 30 days of becoming aware of the breach, as required by POPIA. The notification will describe the nature of the breach, the data affected, and the steps taken or planned.

10. Disputes, Enforcement & Liability

10.1 User Disputes

Disputes about listing content, transaction outcomes, service quality, or post-Introduction conduct are between the relevant Users. The Platform may, at its discretion, assist in facilitating communication but does not adjudicate, arbitrate, or guarantee any outcome in User-to-User disputes.

10.2 Platform Enforcement

The Platform may take the following enforcement steps in response to violations of this EULA or applicable law, in escalating order:

29. Warning notice by email;

30. Temporary listing suspension;

31. Trust Score reduction;

32. Account suspension;

33. Permanent account ban and data deletion;

34. Referral to law enforcement or regulatory authorities.

10.3 Pre-Dispute Negotiation (60 Days)

Before either party initiates arbitration or litigation in connection with any dispute arising out of or relating to this EULA, the disputing party must send a written claim to the other party (or to [email protected] for disputes involving the Platform) describing the dispute in reasonable detail. The parties have 60 days from the date the claim is received to resolve the dispute by negotiation in good faith. This requirement does not apply to applications for urgent injunctive relief, IP infringement claims, or fraud.

10.4 Binding Arbitration

If the 60-day negotiation period expires without resolution, disputes between a User and the Platform shall be resolved by binding arbitration conducted in English under the rules of the South African Arbitration Foundation (SAAF), with the seat of arbitration in Cape Town, South Africa. The arbitrator shall be a practising South African attorney or advocate with at least 5 years' experience in commercial or technology law. Arbitration proceedings are confidential. Each party bears its own legal costs; the SAAF's arbitrator fees are split equally unless the arbitrator finds that one party acted in bad faith.

10.5 Consumer Protection Act Override

Nothing in this Section limits any rights you have under the Consumer Protection Act No. 68 of 2008 (CPA), including the right to approach the National Consumer Commission or the right to bring a claim in a Magistrate's Court for claims under ZAR 10,000. Any cooling-off or cancellation rights in respect of the underlying transaction between Buyer and Seller (property rental, tutor engagement, service contract, etc.) are rights exercisable against the Seller, not against TrustSquare. See Section 5.4.

10.6 Limitation of Liability

To the fullest extent permitted by South African law, the Platform's total aggregate liability to you in any 12-month period shall not exceed:

• For Sellers: the total Tuppence earned and credited to your Wallet during that period, valued at USD $2 per Tuppence; or

• For Buyers or other Users: ZAR 500.

The Platform is not liable for any of the following, whether arising in contract, delict, statute, or otherwise:

• Indirect, incidental, consequential, special, or punitive damages;

• Loss of profit, revenue, data, business opportunity, goodwill, or anticipated savings;

• Actions, omissions, or conduct of any Seller, Buyer, or third party;

• Platform unavailability, bugs, errors, or interruptions except where caused by the Platform's gross negligence;

• Regulatory fines or compliance costs arising from your own violations.

Nothing in this section limits the Platform's liability for death or personal injury caused by its own gross negligence or wilful misconduct, or for fraud.

10.7 ECT Act Safe Harbour (§79)

The Platform provides an intermediary service as defined in the ECT Act. The Platform does not initiate, select, or modify User-generated content (listings, photos, contact details). Subject to compliance with Section 10.8, the Platform is not liable for such User content.

10.8 Notice and Takedown

If you believe Platform content is illegal, infringes your rights, or violates this EULA, notify the Platform by email at [email protected] with a description of the content, its location on the Platform, and evidence supporting your claim. The Platform will: (i) confirm receipt within 24 hours; (ii) investigate within 48 hours; (iii) disable access to content found to be illegal; and (iv) notify you of the outcome.

11. Trust Score, Ranking & Enforcement Criteria

11.1 Trust Score System

Every Seller has a Trust Score (0–100) that reflects their reliability and compliance on the Platform. The score determines listing display position and the badge displayed on listing cards.

11.2 Score Factors

Trust Score is calculated algorithmically based on: time active on the Platform; number of accepted Introductions; response rate (percentage of Introductions responded to within 48 hours); average Buyer rating; formal complaint count; policy violations; and — for Adventures Sellers — approved certification bonuses (Section 7.3).

11.3 Trust Score Penalties

Penalties are applied automatically and in accordance with the introduction model for your category (see Section 5.3). Penalties decay over time: each penalty reduces by 50% every 90 days. Full recovery typically occurs within 180 days. The Platform does not manually waive penalties on User request. If you believe a penalty was applied in error, contact [email protected].

11.4 Account Suspension for Low Score

If your Trust Score falls below 0, your account is automatically suspended. To request reactivation, contact [email protected] after 30 days. You may alternatively delete your account and re-register after a 90-day waiting period.

11.5 Public Display

Your Trust Score and badge tier are visible to all Platform Users on your profile and listing card, before and after Introduction acceptance. This is an inherent part of the Platform's transparency model.

12. Tuppence — Regulatory Classification & Virtual Asset Status

12.1 Current Classification

TrustSquare acknowledges that Tuppence may be scrutinised by the Financial Sector Conduct Authority (FSCA) as a potential virtual asset. The Platform operates two distinct Tuppence flows: Introduction Tuppence (Buyer-to-Platform, mandatory marketplace fee) and AI Feature Tuppence (Seller-to-Platform, optional a per-use, capped charge (Free / 2T / 3T / 5T)). Both flows are assessed below. The Platform's current position is that neither constitutes a virtual asset under current FSCA classification, for the following reasons:

• Tuppence is non-transferable between Users (a key criterion for FSCA virtual asset classification is fungibility and transferability);

• Tuppence cannot be converted to cash or any other currency;

• Tuppence cannot be traded on any exchange;

• 1T = USD $2 is a fixed platform rate, not a market price.

12.2 If Reclassified

If the FSCA reclassifies Tuppence as a virtual asset or determines that the Platform requires a Crypto Asset Service Provider (CASP) licence, the Platform will:

35. Apply for the required FSCA licence within 180 days of the reclassification notice;

36. Update this EULA and the Privacy Policy to reflect new compliance obligations;

37. Notify all active Users of the regulatory status change by email;

38. Implement FICA-compliant KYC/AML screening as required.

12.3 NCA — Current Non-Applicability

Tuppence is currently earned through Introduction acceptance and is not purchased by Users via credit or installment. The National Credit Act (NCA) therefore does not apply to Tuppence in its current form. If a Tuppence purchase mechanism is introduced in future, the NCA's affordability assessment and disclosure obligations will apply, and fresh consent will be obtained from Users at that time.

12.4 No Financial Advice

The Platform does not provide financial, investment, or tax advice regarding Tuppence. You are responsible for understanding the legal and tax implications of Tuppence in your own jurisdiction. South African Users should consult SARS guidance on virtual assets and barter transactions.

13. Governing Law, Jurisdiction & Mandatory SA Law

13.1 Governing Law

This EULA is governed by and construed in accordance with the laws of the Republic of South Africa, without regard to its conflicts of law principles.

13.2 Mandatory SA Law Supremacy

The following South African Acts are mandatory public law and cannot be waived, contracted out of, or overridden by this EULA. If any provision of this EULA conflicts with these Acts, the relevant Act prevails to the extent of the conflict:

• Protection of Personal Information Act No. 4 of 2013 (POPIA)

• Consumer Protection Act No. 68 of 2008 (CPA)

• Electronic Communications and Transactions Act No. 25 of 2002 (ECT Act)

• Financial Intelligence Centre Act No. 38 of 1998 (FICA), as amended

• National Credit Act No. 34 of 2005 (NCA) — if and when applicable

• Financial Sector Regulation Act No. 9 of 2017 and subordinate FSCA regulations

• Constitution of the Republic of South Africa, Act 108 of 1996

For Users habitually resident in a Scheduled Country (Section 13.6), the mandatory laws identified in the applicable Country Schedule likewise cannot be waived and prevail over this EULA to the same extent.

13.3 Jurisdiction

You irrevocably and unconditionally consent to the non-exclusive jurisdiction of the High Court of South Africa and relevant Magistrate's Courts for the resolution of disputes not subject to arbitration under Section 10.4. For arbitrated disputes, the seat of arbitration is Cape Town, South Africa.

13.4 Contact

For legal notices and EULA-related communications: [email protected] or.

13.5 Your Responsibility for Local Laws

The Platform is operated from South Africa and is offered in the countries listed in Section 13.6 (the “Scheduled Countries”): South Africa, the United Kingdom, the United States, Australia, France, Portugal, New Zealand, and Argentina. For Scheduled Countries, the applicable Country Schedule grants you the mandatory local protections of your country automatically.

• If you access or use the Platform from a jurisdiction that is not a Scheduled Country, you do so on your own initiative and at your own risk, and the Platform makes no representation that the Platform, any listing, or any transaction is lawful, appropriate, or available there.

• In every jurisdiction, you remain solely responsible for ascertaining and complying with the laws and regulations that apply to you personally — including consumer-protection, tax, licensing, import/export, exchange-control, and data-protection laws — whether or not the Platform provides features that cater for them.

• Outside the Scheduled Countries, the Platform does not undertake to monitor legal or regulatory developments and may not be up to date with them at any given time.

• You indemnify the Platform against any claim, fine, penalty, loss, or cost arising from your failure to comply with laws applicable to you.

Nothing in this Section 13.5 deprives you of any protection afforded to you by provisions of law that cannot be derogated from by agreement in your country of habitual residence.

13.6 Country Schedules

If you are habitually resident in the United Kingdom, the United States, Australia, France, Portugal, New Zealand, or Argentina, the corresponding Country Schedule at the end of this EULA (Schedule A — United Kingdom; Schedule B — United States; Schedule C — Australia; Schedule D — France; Schedule E — Portugal; Schedule F — New Zealand; Schedule G — Argentina) applies to you and, to the extent of any conflict, prevails over the body of this EULA. The Schedules exist so that the mandatory consumer, privacy, and fairness protections of your own country apply to you automatically — you do not need to invoke them. For South African residents, the body of this EULA (including Section 13.2) already reflects South African mandatory law.

14. Termination & Suspension

14.1 User Termination

You may terminate your account at any time by submitting a written request to [email protected]. Termination takes effect immediately. Upon termination:

• Unused Tuppence is retained on your account record and is not converted to cash. If you register again using the same verified identity within 24 months, your retained balance is restored to you in full. Tuppence is not redeemable for cash or ZAR under any circumstance, and no payment is made to you on closure;

• Your active listings are removed from public display within 48 hours;

• Your account data is deleted or anonymised within 30 days, subject to FICA and other legal retention obligations;

• Buyers with open Introduction requests are notified that the Seller is no longer available. Tuppence spent on closed Introductions is consumed; no reissuance is made.

14.2 Immediate Termination for Breach

The Platform may terminate your account immediately, without notice, if you:

• Violate this EULA, POPIA, CPA, ECT Act, FICA, or any applicable South African law;

• Post fraudulent, illegal, defamatory, or harmful content;

• Fail to complete identity verification (Section 3.5) after acceptance of a first Introduction;

• Attempt to circumvent the Anonymity Gate (Section 3.3);

• Engage in money laundering, terrorism financing, or sanctions evasion (FICA);

• Claim false professional credentials;

• Harass, abuse, or threaten other Users or Platform staff.

Upon termination for breach under cause B5 (payment fraud or chargeback abuse) or cause B6 (identity fraud or deliberate deception), unused Tuppence is forfeited. On termination for breach under any other cause, unused Tuppence is retained on your account record and is restored in full if the account is reinstated. In no case is Tuppence converted to cash. The Platform reserves the right to recover damages arising from the breach.

14.3 Termination for Convenience

The Platform may terminate your account on 30 days' written notice to your registered email address for any reason, provided you have no active Introduction disputes or pending arbitrations. If such termination occurs, your unused Tuppence is retained for 24 months and is restored in full if you register again using the same verified identity. Because the Platform, and not you, ended the agreement, no Tuppence is forfeited. Tuppence is not redeemable for cash or ZAR under any circumstances, including on account termination. You will be notified of the termination and of your retained balance at the email address registered to your account.

14.4 Survival

The following sections survive account termination and continue in full force: Section 1 (Definitions), Section 3.6 (Regulatory Disclosure), Section 8 (User-Uploaded Content), Section 9 (Privacy and POPIA), Section 10.3–10.8 (Disputes and Liability), Section 13 (Governing Law, including Sections 13.5–13.6 and the Country Schedules), and any accrued Tuppence obligations. For clarity, Reference Library continuity under Section 8.10 survives as part of Section 8.

14.5 Enumerated Blocking Causes (B1–B6)

The Platform may BLOCK a listing together with the associated Seller account only upon verified evidence of one of the following enumerated causes. All causes are empirical and objectively verifiable; no subjective or discretionary blocking is permitted. B1 — Fraudulent Trust Score evidence (forged, altered or misrepresented credential documents); reinstatement possible on authenticated original documents and re-verification. B2 — Fraudulent listing (marketing a property, item or service the Seller does not own or is not authorised to represent); reinstatement possible on proof of authority within the appeal window. B3 — Systematic introduction ignoring (three or more introduction requests left without response within any rolling 30-day window, measured empirically by the Platform); reinstatement after a 60-day cooling-off period served in full and written acknowledgement of the introduction model rules. B4 — Buyer harassment (confirmed contact of a Buyer outside the Platform following a declined or withdrawn introduction); reinstatement available on first offence only, requiring the Buyer's written consent and a completed 90-day suspension.

B5 — Payment fraud or chargeback abuse (disputed Tuppence charges, fraudulent transactions, or a deliberate pattern of chargebacks); no reinstatement — the matter is referred to the payment processor's fraud team and may be escalated to the relevant financial authorities. B6 — Identity fraud or deliberate deception (operating under a false or stolen identity, or any deliberate deception intended to circumvent the anonymity and trust model); no reinstatement — the matter may be referred to the relevant legal authorities. By accepting this EULA you explicitly acknowledge that causes B5 and B6 carry permanent account termination with no right of appeal, and you waive any claim to reinstatement on those grounds.

14.6 Appeals

For causes B1–B4 the Seller has 30 days from the date of the BLOCK notification email to lodge a formal appeal via the Platform's designated appeals channel. The notification email states the cause code, the evidence on which the block was based, and the appeals contact. Appeals are reviewed by a human administrator and the outcome is communicated within 14 days of receipt. If no appeal is received within 30 days, the listing and account are automatically ARCHIVED and the right of appeal is extinguished.

15. Changes, Miscellaneous & Contact

15.1 Changes to These Terms

The Platform may update this EULA at any time. When material changes are made, you will be notified by email to your registered address and by an in-app notification at least 14 days before the changes take effect. The updated version number and effective date are displayed on this page at trustsquare.co/terms.

Continued use of the Platform after the effective date constitutes acceptance of the updated EULA. If you do not accept the updated terms, you must close your account before the effective date.

15.2 Entire Agreement

This EULA, together with the Privacy Policy at trustsquare.co/privacy and any Platform policies or guidelines published at trustsquare.co/legal, constitutes the entire agreement between you and the Platform regarding your use of the Platform, and supersedes all prior agreements, representations, or understandings relating to the same subject matter.

15.3 Severability

If any provision of this EULA is found to be unlawful, void, or unenforceable, that provision shall be severed from the EULA. The remaining provisions shall continue in full force and effect.

15.4 Waiver

The Platform's failure to enforce any provision of this EULA at any time does not constitute a waiver of that provision or of the right to enforce it in the future.

15.5 No Agency

Nothing in this EULA creates a partnership, joint venture, agency, franchise, or employment relationship between you and the Platform.

15.6 Assignment

You may not assign or transfer your rights or obligations under this EULA without the Platform's prior written consent. The Platform may assign its rights and obligations to a successor entity upon written notice to you.

15.7 Force Majeure

The Platform is not liable for any failure or delay in performance caused by circumstances beyond its reasonable control, including natural disasters, load-shedding, telecommunications failures, cyberattacks, or government action, provided the Platform notifies you as soon as reasonably practicable and takes reasonable steps to resume performance.

15.8 Plain Language

This EULA is written in plain English. If you do not understand any provision, please contact [email protected] and we will provide a plain-language explanation within 5 business days. You may request a copy of this EULA and your transaction history at any time.

15.9 Contact

Schedule A — United Kingdom

This Schedule applies if you are habitually resident in the United Kingdom and prevails over the body of this EULA to the extent of any conflict.

A1 Mandatory rights — Nothing in this EULA excludes or limits any right or remedy you have under UK law that cannot be excluded or limited by agreement, including under the Consumer Rights Act 2015.

A2 Service standard — The Introduction service is supplied with reasonable care and skill. If it is not, you are entitled to the statutory remedies of repeat performance or an appropriate reduction in price.

A3 Cancellation (Consumer Contracts Regulations 2013) — You have a 14-day right to cancel a distance service contract. By requesting an Introduction you expressly request immediate performance and acknowledge that once the service is fully performed (contact details exchanged under Section 3.2), the right to cancel is lost. If you cancel before full performance, the held Tuppence is released to your balance.

A4 Liability — Nothing in this EULA excludes or limits liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot be excluded under UK law. Section 10.6 applies subject to this Schedule.

A5 Data protection — Processing of your personal data is subject to the UK GDPR and the Data Protection Act 2018, as described in the Privacy Policy. You may lodge a complaint with the Information Commissioner’s Office (ico.org.uk).

A6 Unfair terms — No provision of this EULA is intended to create a significant imbalance in the parties’ rights to your detriment. Any term found unfair under Part 2 of the Consumer Rights Act 2015 does not bind you.

Schedule B — United States

This Schedule applies if you are habitually resident in the United States and prevails over the body of this EULA to the extent of any conflict.

B1 Mandatory rights — Nothing in this EULA limits any non-waivable right you have under applicable federal or state law. Where a state consumer-protection statute grants you mandatory rights or remedies, those prevail over any conflicting provision of this EULA.

B2 Electronic contracting — You consent to contracting electronically (E-SIGN Act / UETA); your acceptance under Section 2.4 constitutes your electronic signature.

B3 Subscriptions & auto-renewal — Where a subscription renews automatically, the renewal terms are disclosed clearly and conspicuously before purchase, renewal reminders are sent where required by state law, and you may cancel online at least as easily as you subscribed.

B4 California privacy — If you are a California resident, the CCPA/CPRA notices in the Privacy Policy apply. The Platform does not sell or share personal information as those terms are defined in the CCPA/CPRA. You have the rights to know, correct, and delete, and to be free from discrimination for exercising them.

B5 Dispute resolution & opt-out — Section 10.4 (arbitration) applies, except that: (i) you may bring an individual claim in small-claims court; and (ii) you may opt out of arbitration entirely by emailing [email protected] within 30 days of first accepting this EULA. Disputes are resolved on an individual basis; you and the Platform each waive any right to class or representative proceedings to the extent permitted by law.

Schedule C — Australia

This Schedule applies if you are habitually resident in Australia and prevails over the body of this EULA to the extent of any conflict.

C1 Consumer guarantees — Our services come with guarantees that cannot be excluded under the Australian Consumer Law, including that services will be provided with due care and skill, be fit for their purpose, and be supplied within a reasonable time. Nothing in this EULA excludes, restricts, or modifies those guarantees.

C2 Permitted limitation — To the extent permitted by section 64A of the Australian Consumer Law, the Platform’s liability for failure to comply with a consumer guarantee in relation to services is limited, at the Platform’s option, to supplying the service again or paying the cost of having the service supplied again. Section 10.6 applies subject to this Schedule.

C3 Misleading conduct & unfair terms — Nothing in this EULA limits your rights in respect of misleading or deceptive conduct (ACL s18), and no provision is intended to be an unfair contract term within the meaning of the ACL; any such term is void and does not bind you.

C4 Privacy — Handling of your personal information is subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles, as described in the Privacy Policy. Complaints may be made to the Office of the Australian Information Commissioner (oaic.gov.au).

Schedule D — France

This Schedule applies if you are habitually resident in France and prevails over the body of this EULA to the extent of any conflict.

D1 Mandatory rights — Nothing in this EULA excludes or limits any right or remedy you have under French law that cannot be excluded or limited by agreement, including under the Code de la consommation and the Code civil.

D2 Service standard — The Introduction service is supplied in conformity with the contract. Where it is not, you have the remedies for lack of conformity provided by articles L.224-25-12 and following of the Code de la consommation, and the guarantee against hidden defects under article 1641 of the Code civil.

D3 Right of withdrawal — As a consumer you have a 14-day right of withdrawal for a distance service contract (article L.221-18). By requesting an Introduction you expressly request that performance begin before the withdrawal period expires and acknowledge that, once the service is fully performed (contact details exchanged under Section 3.2), the right of withdrawal is lost (article L.221-28, 1°). If you withdraw before full performance, the held Tuppence is released to your balance.

D4 Liability — Nothing in this EULA excludes or limits liability for death or personal injury, for fraud or gross negligence (faute lourde ou dolosive), or for any other liability that cannot be excluded under French law. Section 10.6 applies subject to this Schedule.

D5 Data protection — Processing of your personal data is subject to the GDPR and the Loi Informatique et Libertés, as described in the Privacy Policy. Where the Platform has obtained your business contact details from a publicly accessible source and contacts you at a professional address for reasons connected with your professional activity, it relies on legitimate interests (GDPR article 6(1)(f)) and identifies that source to you. You may object at any time, without giving reasons. You may lodge a complaint with the CNIL (cnil.fr).

D6 Unfair terms — No provision of this EULA is intended to create a significant imbalance between the parties’ rights and obligations to your detriment. Any term found abusive within the meaning of article L.212-1 of the Code de la consommation is deemed unwritten and does not bind you.

D7 Language — This EULA is concluded in English, and the English version governs. Where a French translation is provided, it is provided for information. Where French law requires that a contract concluded with a consumer in France be supplied in French, the Platform will supply this EULA in French, and in that case the French version prevails for that consumer to the extent French law so requires.

D8 Dispute resolution — Before commencing proceedings you may refer a consumer dispute free of charge to a mediator of consumption (médiateur de la consommation) and to the European Online Dispute Resolution platform. Section 10.4 (arbitration) does not deprive you of the right to bring proceedings before the courts of your place of residence.

Schedule E — Portugal

This Schedule applies if you are habitually resident in Portugal and prevails over the body of this EULA to the extent of any conflict.

E1 Mandatory rights — Nothing in this EULA excludes or limits any right or remedy you have under Portuguese law that cannot be excluded or limited by agreement, including under Decreto-Lei n.º 84/2021 and the Lei de Defesa do Consumidor (Lei n.º 24/96).

E2 Service standard — The Introduction service is supplied in conformity with the contract. Where it is not, you are entitled to the remedies for lack of conformity provided by Decreto-Lei n.º 84/2021.

E3 Right of free resolution — As a consumer you have a 14-day right of free resolution for a distance service contract (Decreto-Lei n.º 24/2014). By requesting an Introduction you expressly request that performance begin within that period and acknowledge that, once the service is fully performed (contact details exchanged under Section 3.2), the right lapses. If you resolve the contract before full performance, the held Tuppence is released to your balance.

E4 Liability — Nothing in this EULA excludes or limits liability for death or personal injury, for fraud (dolo) or gross negligence (culpa grave), or for any other liability that cannot be excluded under Portuguese law. Section 10.6 applies subject to this Schedule.

E5 Data protection — Processing of your personal data is subject to the GDPR and Lei n.º 58/2019, as described in the Privacy Policy. Where the Platform has obtained your business contact details from a publicly accessible source, it identifies that source to you and relies on legitimate interests (GDPR article 6(1)(f)). You may lodge a complaint with the CNPD (cnpd.pt).

E6 Electronic communications — Where you are a legal person, unsolicited direct-marketing communications are permitted until you object, in accordance with article 13.º-A(2) of Lei n.º 41/2004. You may object at any time using the mechanism provided in any such communication, and you may register on the list maintained under article 13.º-B(2) by the Direção-Geral do Consumidor.

E7 Unfair terms — No provision of this EULA is intended to be an abusive clause within the meaning of Decreto-Lei n.º 446/85; any such clause is void and does not bind you.

E8 Language — This EULA is concluded in English, and the English version governs. Where a Portuguese translation is provided, it is provided for information. Where Portuguese law requires that a contract concluded with a consumer in Portugal be supplied in Portuguese, the Platform will supply this EULA in Portuguese, and in that case the Portuguese version prevails for that consumer to the extent Portuguese law so requires.

E9 Dispute resolution — You may refer a consumer dispute to an authorised alternative dispute resolution entity (RAL) and to the European Online Dispute Resolution platform. Section 10.4 does not deprive you of the right to bring proceedings before the courts of your place of residence.

Schedule F — New Zealand

This Schedule applies if you are habitually resident in New Zealand and prevails over the body of this EULA to the extent of any conflict.

F1 Consumer guarantees — Where you acquire the Introduction service as a consumer, the guarantees in the Consumer Guarantees Act 1993 apply, including that services be supplied with reasonable care and skill, be fit for purpose, and be completed within a reasonable time. Nothing in this EULA excludes, restricts or modifies those guarantees.

F2 Business acquisition — Where you acquire the service for the purposes of a business, the parties agree that the Consumer Guarantees Act does not apply, to the extent permitted by section 43 of that Act. This does not affect your rights where you acquire the service as a consumer.

F3 Fair dealing — Nothing in this EULA limits your rights in respect of misleading or deceptive conduct, or unsubstantiated representations, under the Fair Trading Act 1986. Any term found to be an unfair contract term in a standard-form consumer contract does not bind you.

F4 Liability — Nothing in this EULA excludes or limits liability that cannot be excluded under New Zealand law. Section 10.6 applies subject to this Schedule.

F5 Privacy — Handling of your personal information is subject to the Privacy Act 2020 and the Information Privacy Principles. Where the Platform has collected your information from a source other than you, it will tell you so and identify that source, in accordance with Information Privacy Principle 3A. Complaints may be made to the Office of the Privacy Commissioner (privacy.org.nz).

F6 Electronic messages — Commercial electronic messages sent to you are sent on the basis of consent, including deemed consent under the Unsolicited Electronic Messages Act 2007. Every such message identifies the sender, and the unsubscribe facility and contact address remain functional for at least 30 days. Opt-out requests are actioned immediately and in any event within 5 working days.

Schedule G — Argentina

This Schedule applies if you are habitually resident in Argentina and prevails over the body of this EULA to the extent of any conflict.

G1 Mandatory rights — Nothing in this EULA excludes or limits any right or remedy you have under Argentine law that cannot be excluded by agreement, including under Ley 24.240 (Defensa del Consumidor) and the Código Civil y Comercial de la Nación.

G2 Service standard and revocation — Where you acquire the Introduction service as a consumer, you have the 10-day right of revocation for distance contracts under article 34 of Ley 24.240. By requesting an Introduction you expressly request immediate performance and acknowledge that, once contact details are exchanged under Section 3.2, the service is fully performed. If you revoke before full performance, the held Tuppence is released to your balance.

G3 Liability — Nothing in this EULA excludes or limits liability that cannot be excluded under Argentine law, including the liability of the supplier under article 40 of Ley 24.240. Section 10.6 applies subject to this Schedule.

G4 Data protection — Processing of your personal data is subject to Ley 25.326. Where the Platform obtained your data from a source of unrestricted public access, it relies on article 27 of that Law and identifies that source to you. You may at any time request the withdrawal or blocking (retiro o bloqueo), total or partial, of your name from the Platform’s databases, in accordance with article 27, subsection 3. Complaints may be made to the Agencia de Acceso a la Información Pública (argentina.gob.ar/aaip).

G5 Abusive clauses — No provision of this EULA is intended to be an abusive clause within the meaning of article 37 of Ley 24.240 or articles 1117 to 1122 of the Código Civil y Comercial; any such clause is deemed not written.

G6 Jurisdiction — Section 10.4 does not deprive a consumer of the right to bring proceedings before the courts of their domicile, as provided by article 36 of Ley 24.240.

G7 Language — This EULA is concluded in English, and the English version governs. Where a Spanish translation is provided, it is provided for information. Where Argentine law requires that a contract concluded with a consumer in Argentina be supplied in Spanish, the Platform will supply this EULA in Spanish, and in that case the Spanish version prevails for that consumer to the extent Argentine law so requires.

— End of TrustSquare Terms of Use / EULA v1.15 —

v1.15 · Republic of South Africa · Country Schedules: United Kingdom · United States · Australia · France · Portugal · New Zealand · Argentina