SuperStrat Restricted Jurisdictions Policy

Version 1.1.0 Date of last revision: 2026-09-02 Effective from: publication on the Interface

This Policy is an integral part of the SuperStrat Terms of Use (the "Terms") and is incorporated into them by reference (Terms, Section 1.3). Capitalized terms have the meanings given in the Terms.

1. Purpose

This Policy identifies the jurisdictions from which access to the Interface is refused (each a "Restricted Jurisdiction"), and the measures applied to enforce that refusal. It gives the definition of Restricted Jurisdiction used in the Terms and applies to the definition of Restricted Person in Section 1.1 of the Terms. It is reviewed at least quarterly and on the occurrence of any relevant regulatory event.

2. Category A. Absolute Exclusion

Access to and use of the Interface is refused, without exception, by persons who are citizens or residents of, are located in, are incorporated in, or have a registered office in, any of the following:

(a) the United States of America, including its states, territories and possessions, together with US persons wherever located;

(b) any country or territory that is, or whose government is, the target of economic, financial or trade sanctions, embargoes, export controls or other restrictive measures imposed by the United Nations, the European Union or any of its member states, the United Kingdom, the United States, or the British Virgin Islands, currently including Afghanistan, Belarus, Cuba, the Democratic People's Republic of Korea, Iran, Myanmar, Russia, Syria, Venezuela, and the regions of Crimea, Donetsk, Luhansk, Kherson and Zaporizhzhia;

(c) any jurisdiction subject to a Financial Action Task Force call for action.

Access is also refused to any person falling within the definition of Restricted Person in Section 1.1 of the Terms, including any person the Operator reasonably determines presents a high sanctions, money laundering, terrorist financing, proliferation financing or gambling-law risk under its internal policy, regardless of that person's jurisdiction.

3. Category B. Exclusion on Prediction Market Grounds

Access is refused from the following jurisdictions because the competent authority has determined that prediction markets or event contracts constitute unlicensed gambling, has ordered access to the principal Prediction Market Venues to be blocked, or has opened enforcement proceedings on that basis.

The exclusion of the European Union in substance follows from the position taken by its competent authorities. Nine European gambling regulators announced coordinated cross-border supervision of prediction markets in 2026, and enforcement in this field is directed at operators and at persons who promote or collect funds for such offers, not only at individual users. A product whose Vaults gain exposure to prediction markets cannot be offered in those jurisdictions.

4. Category C. Watchlist

The following jurisdictions are under review because the position of the competent authority is unresolved, proceedings are pending, or the principal Prediction Market Venue has itself restricted trading from them: Australia, Brazil, Canada, Japan, Taiwan and Thailand.

Category C jurisdictions are reviewed at each quarterly review and on any relevant regulatory event. Where the position in a Category C jurisdiction becomes adverse, the Operator moves it to Category B, exercises its rights under Section 3.9 of the Terms, and publishes the amended Policy under Section 8. Inclusion in Category C is not a representation that use of the Interface is lawful there (Section 7).

5. Enforcement Measures

The Operator applies the following measures:

(a) Country restriction at the edge. The Operator derives a country from the IP address of each request at the edge of its hosting infrastructure and refuses, from every Category A and Category B jurisdiction, wallet connection, acceptance of the Terms, and every gated action on the Interface, including deposit, redemption, claim and Vault creation. Read-only pages remain visible.

(b) Explicit notice. A person refused under paragraph (a) is shown a notice stating that the Interface is not available in the country determined for that person, naming that country, and linking to this Policy.

(c) Access-control records. The Operator records the derived country, the time of access, the action attempted, whether access was refused and, where a wallet is connected, the wallet address. These records are kept as evidence that access controls were applied, for the period stated in the Privacy Policy (24 months).

(d) No targeting. The Operator conducts no marketing, no paid acquisition, no affiliate or influencer arrangement, and publishes no content targeted at a Category A or Category B jurisdiction, in any language associated primarily with one.

(e) Additional measures. The Operator may introduce wallet screening and further detection measures at any time, without notice. The Privacy Policy is updated and re-versioned before or at the activation of any such measure. The Operator may also request eligibility information from any User at any time and may suspend or terminate access where eligibility cannot be confirmed.

6. Circumvention

Accessing or attempting to access the Interface from a Restricted Jurisdiction, or on behalf of a Restricted Person, by any means, including a virtual private network, a proxy, a relay, a misrepresentation of location or identity, or the use of another person's wallet, is a material breach of the Terms (Terms, Sections 9(d) and 9(m)). Circumvention voids every representation you have given under Sections 4.7, 5 and 10 of the Terms, and any resulting loss or liability is yours alone.

7. No Representation of Lawfulness

The absence of a jurisdiction from this Policy, or its inclusion in Category C only, is not a representation that use of the Interface, or exposure to prediction markets, is lawful there. You remain solely responsible for confirming, before each use of the Interface, that your use of the Interface and any exposure to prediction markets is lawful in your jurisdiction (Terms, Section 5.2).

8. Review and Amendments

This Policy is reviewed at least quarterly and on the occurrence of any relevant regulatory event. Each review is dated and the version number is incremented. Because the Terms incorporate this Policy by reference, an amendment to this Policy is an amendment governed by Section 18 of the Terms and takes effect on publication of the amended version on the Interface.

SuperStrat Restricted Jurisdictions Policy, Version 1.1.0. The authoritative version of this document and its cryptographic hash are published at superstrat.io/restricted-jurisdictions.