Educational Disclaimer and Crypto-Asset Risks

Alchimie Capital LLC, Odesio

Effective date: 2026-04-23 Version: 1.0 To be displayed: home page, application onboarding, footer, header of each conversation with the Odesio assistant.

This English version is a translation provided for convenience. In the event of any discrepancy or dispute, the French version prevails.

⚠️ IMPORTANT WARNING, READ ME

Crypto-assets are extremely volatile investments that carry a risk of total loss of capital.

Odesio is an exclusively educational service provided on a subscription basis. It does not in any way constitute investment advice, a personalised recommendation or a trading signal.

1. Strictly educational nature of the service

The Odesio application and its content are designed to convey knowledge, methodologies and analytical frameworks about the world of crypto-assets.

Our purpose is educational: to teach you how to:

• Understand the fundamentals of blockchain and crypto-assets
• Read a white paper
• Analyse tokenomics
• Build a personal investment thesis
• Identify classic cognitive biases in a volatile market
• Understand the macroeconomic cycles of the crypto market

We will never tell you which crypto-asset to buy, at what price, in what proportion of your wealth, or when.

2. What we are not

Alchimie Capital LLC is not:

• ❌ An investment adviser within the meaning of Regulation (EU) 2023/1114 ("MiCA")
• ❌ An authorised crypto-asset service provider (CASP)
• ❌ A financial investment adviser (CIF, conseiller en investissement financier) within the meaning of the French Monetary and Financial Code (Code monétaire et financier)
• ❌ An Investment Advisor within the meaning of the Investment Advisers Act of 1940 (United States)
• ❌ A bank, broker or investment fund
• ❌ An automated or semi-automated trading service
• ❌ A trading signals service
• ❌ A portfolio management service

Neither Alchimie Capital LLC, nor its founders, nor its trainers, nor Odesio are authorised to provide personalised investment advice in any jurisdiction whatsoever.

3. The Odesio assistant, explicit limitations

Odesio is a conversational assistant based on artificial intelligence.

In accordance with Article 50 of Regulation (EU) 2024/1689 ("AI Act"), you are informed that you are interacting with an AI system and not with a human being.

Odesio can:

✅ Explain technical concepts (Proof of Stake, ZK-rollups, AMM…) ✅ Rephrase the educational content of the Application ✅ Recall the methodological principles taught ✅ Put current events in context within the programme's frameworks ✅ Answer public and verifiable factual questions

Odesio cannot:

❌ Recommend a crypto-asset for you to buy ❌ Give you an entry or exit price ❌ Tell you whether the market will go up or down ❌ Assess your financial situation and formulate a personalised strategy ❌ Advise you on your personal taxation ❌ Replace a lawyer, a tax adviser or an authorised investment adviser

Hallucinations

AI models may produce inaccurate, outdated or fabricated responses ("hallucinations"). Despite our efforts (proprietary knowledge base, secure prompting, moderation), we do not guarantee the accuracy of Odesio's responses.

Always verify significant information against primary sources (official project documentation, Coingecko, CoinMarketCap, blockchain explorers) before making any decision.

4. Risks of crypto-assets

Before investing a single euro in crypto-assets, you must be aware of the following risks:

4.1 Risk of total loss

The price of a crypto-asset can fall to zero. Several thousand crypto projects have disappeared with nothing returned to investors. Recent examples include LUNA/UST (2022, >$60 bn wiped out in 3 days), FTX (2022, fraudulent bankruptcy), and many projects from the 2021 cycle.

4.2 Extreme volatility

Crypto-assets can lose or gain 50% in a few hours. Corrections of 80-90% are frequent in bear phases.

4.3 Liquidity risk

Some crypto-assets cannot be sold quickly without a major discount, particularly in periods of market stress.

4.4 Technological risk

Hacked smart contracts, bugs, zero-day vulnerabilities, 51% attacks, loss of private keys, compromised seed phrases, clipper-type malware, phishing, poisoned airdrops.

4.5 Counterparty risk (exchanges)

Centralised exchanges (CEX) can go bankrupt (FTX, Mt. Gox, Celsius, BlockFi, Voyager) and their users become unsecured creditors, with partial and delayed recovery after insolvency proceedings, or even total loss.

4.6 Regulatory risk

The legal framework for crypto-assets is evolving rapidly:

• EU: MiCA entered into force on 30/12/2024, full CASP regime
• United States: fragmented SEC/CFTC approach, Ripple, Binance, Coinbase case law
• France: former PSAN regime, transition to CASP
• Belgium: FSMA competent since 30/12/2024
• Risk of sudden tightening in a given country

4.7 Tax risk

The taxation of crypto-assets is complex and evolving:

• France: 30% flat tax + BNC (non-commercial profits) if professional
• Belgium: exemption for normal management of private assets / 33% speculation / 50% miscellaneous income (unclear case law, FSMA/FPS Finance (SPF Finances))
• Canada: taxation depending on nature
• United States: the IRS treats crypto as property, capital gains
• Consult a qualified tax adviser in your jurisdiction

4.8 Behavioural risk

Fear Of Missing Out (FOMO), panic selling, over-leveraging, revenge trading, sunk cost fallacy. Emotional control is more difficult than technical analysis.

4.9 Scam risk

Scams such as rug pulls, pig butchering, fake influencers, fake trading bots, Ponzi-type pyramid schemes. Losses reported to European authorities exceed 2 billion euros per year.

5. Investment decisions, your sole responsibility

You alone are responsible for your investment decisions.

Before any decision:

1. Assess your personal situation (income, wealth, objectives, horizon, risk tolerance, family responsibilities)
2. Only invest what you can afford to lose entirely
3. Diversify your wealth; the commonly accepted rule is not to exceed 5 to 10% of one's wealth in crypto-assets for a non-professional investor
4. Never take out a loan to invest in crypto-assets
5. Consult an authorised investment adviser in your jurisdiction for a personalised recommendation (EU CASP list on the ESMA website, French CIF list on ORIAS)
6. Consult a tax adviser to anticipate the applicable taxation
7. Consult a lawyer for inheritance and estate matters

6. Past performance

Past performance is not indicative of future performance.

Any figure, chart, curve or testimonial presented in the Application is presented for exclusively educational purposes to illustrate a historical concept. It does not constitute a promise of returns.

User testimonials, if any, reflect their personal experience and in no way guarantee a similar result for you.

7. No guarantee of returns

Alchimie Capital LLC does not guarantee:

• ❌ Any financial return as a result of your subscription
• ❌ Any measurable growth in your wealth
• ❌ The accuracy of any market forecasts mentioned (which are merely educational hypotheses)

8. Regulatory compliance and educational safe harbour

8.1 Position with regard to MiCA

Alchimie Capital LLC considers that its Services fall outside the scope of MiCA in that they do not meet the 4 cumulative criteria of regulated advice (Art. 3(1)(17) MiCA, interpreted in accordance with AMF Position DOC-2008-23 by analogy):

1. ❌ Recommendation: we distribute general educational content, not purchase instructions
2. ❌ Transaction: the Application does not execute any transaction
3. ❌ Specific crypto-asset: our analyses cover methodological frameworks and macro dynamics, not named tokens of the "buy X" kind
4. ❌ Personalised: the educational segmentation does not take into account your individual financial situation in order to formulate an individualised recommendation

8.2 Position with regard to MiFID II

For security tokens that may qualify as financial instruments, the same analysis applies: absence of the 4 cumulative criteria of investment advice within the meaning of Article 4.1.4 MiFID II.

8.3 Substance over form rule

In accordance with the settled case law of ESMA, the AMF and the FSMA, a warning or a disclaimer is not sufficient to requalify an activity which, in practice, would constitute personalised advice. This is why Alchimie Capital LLC explicitly prohibits itself from providing personalised recommendations via Odesio, the trainers or the community.

Any user or collaborator of Alchimie Capital LLC who solicits or formulates a personalised recommendation outside this framework is exposed to contractual sanctions and an exclusion procedure.

9. Prohibited jurisdictions

The Services are not intended for and are not offered to residents of the following countries:

• Countries under international embargo (Cuba, Iran, North Korea, Syria, Russia/Belarus within the OFAC scope, Crimea and occupied regions)
• Countries where the marketing of educational content on crypto-assets would be unlawful (mainland China, to be verified according to developments)
• Countries where the offer would be reserved for locally authorised operators, which we are not

10. User obligations

By using the Services, you undertake:

• Not to interpret the content as personalised investment advice
• To make your decisions independently
• Not to blindly reproduce the educational analyses presented for illustrative purposes
• To consult authorised professionals before any significant decision
• To comply with the legislation applicable in your country of residence

11. Acknowledgement clause

By clicking "I accept", using the Services or paying for a Subscription, you acknowledge that you have read, understood and accepted this Disclaimer.

In particular, you acknowledge:

• That the Services have an exclusively educational purpose
• That no content constitutes personalised advice
• That crypto-assets may result in the total loss of your capital
• That you are solely responsible for your investment decisions
• That Alchimie Capital LLC cannot be held liable for any financial losses you may incur

12. Updates

This Disclaimer may be updated to reflect regulatory developments. The version in force is always the one published in the "Legal" section of the Application.

Last updated: 2026-04-23

Contact: contact@alchimiecapital.com

Alchimie Capital LLC, 4405 Jager Dr NE, Ste C4, Box 2043, Rio Rancho, NM 87144, New Mexico, United States