Developer License Agreement

Document Version: ALL-DLA-v1.0.0 / Legal Pack Version: ALL-LP-v1.0.0

Effective Date: 26 October 2026 | Last Updated: 26 October 2026

Parties

This ALL Developer & SDK License Agreement (this "Agreement") is entered into between:

(1) All360 Technology S.A., a company incorporated in the Republic of Panama ("ALL", "we", "us", "our"); and

(2) The individual or legal entity that registers as a Builder on the ALL Platform ("Developer", "Builder", "you", "your").

ALL and the Builder are each referred to herein individually as a "Party" and collectively as the "Parties".

By registering as a Builder, accessing the SDK or APIs, or submitting any App to the ALL Marketplace, you agree to be bound by this Agreement. If you are entering into this Agreement on behalf of a legal entity, you represent that you have full authority to bind that entity.

1. Definitions

In this Agreement, the following terms have the meanings set out below. Capitalised terms not defined herein have the meanings given to them in the ALL Platform Terms of Use.

2. Eligibility and Enrollment

2.1 Eligibility Requirements

To register as a Builder and access the SDK, APIs, and ALL Marketplace, you must:

• Be a natural person of at least eighteen (18) years of age with full legal capacity, or a validly incorporated legal entity in good standing;
• Not be located in, incorporated in, or operating from a jurisdiction subject to comprehensive sanctions maintained by OFAC, the European Union, OFSI, or the United Nations Security Council, or listed on any applicable sanctions list;
• Complete ALL's Builder registration process, including any KYC or KYB verification required by ALL or applicable law;
• Agree to and comply with this Agreement, the AUP, the Terms of Use, the Privacy Policy, and all applicable Submission Guidelines;
• Possess the technical capability to develop, test, and support Apps in accordance with ALL's Developer Documentation and Submission Guidelines.

2.2 Builder Account

Access to the SDK, APIs, Developer Portal, and Marketplace submission tools requires a registered Builder Account. The Builder is solely responsible for: (a) maintaining the confidentiality of Builder Account credentials and API keys; (b) all activity occurring through the Builder Account; and (c) ensuring all information provided to ALL is accurate, complete, and current. ALL may suspend or terminate a Builder Account at any time in accordance with Section 15.

2.3 Test Credentials

ALL may issue Test Credentials to Builders for development and testing purposes only. Test Credentials must not be used in production environments, shared with unauthorised third parties, or used to access live Platform data. ALL may revoke Test Credentials at any time without prior notice. The Builder is responsible for securing Test Credentials and for any misuse arising from unauthorised access to or disclosure of Test Credentials.

3. SDK and API License

3.1 Licence Grant

Subject to the Builder's ongoing compliance with this Agreement, ALL grants the Builder a limited, non-exclusive, non-transferable, non-sublicensable, revocable, royalty-free licence to: (a) download, install, and use the SDK solely to develop, test, and operate Apps for or with the ALL Platform; (b) access and use the APIs solely to integrate Apps with the ALL Platform and distribute such Apps through the ALL Marketplace or as otherwise expressly authorised by ALL in writing; and (c) use the Developer Documentation solely for reference in connection with the foregoing.

3.2 Licence Restrictions

The Builder must not:

• Copy, modify, adapt, or create derivative works of the SDK or APIs, except as required for standard integration in accordance with the Developer Documentation;
• Reverse-engineer, decompile, or disassemble the SDK, APIs, ALL Control Tower, ALL360 OS, or any ALL Platform component;
• Sublicense, resell, rent, lease, lend, or otherwise transfer access to the SDK or APIs to any third party;
• Use the SDK or APIs to build a product that competes with the ALL Platform or ALL Marketplace without ALL's prior written consent;
• Remove, alter, or obscure any proprietary notices contained in or on the SDK, APIs, or Developer Documentation;
• Use production API keys for load testing, benchmarking, or scraping without ALL's prior written consent;
• Attempt to access, query, or extract data beyond what is expressly authorised by ALL's API permissions;
• Access or attempt to access private, undocumented, or internal ALL APIs not expressly made available through the Developer Portal.

3.3 SDK Updates and Deprecation

ALL may update, modify, deprecate, or discontinue any SDK or API version at any time. ALL will use commercially reasonable efforts to provide advance notice of material deprecations through the Developer Portal. Where a supported API version is deprecated, ALL will specify a transition period of not less than 90 days unless immediate deprecation is required by security, legal, or operational reasons. The Builder is responsible for updating Apps to remain compatible with current supported versions. ALL is not liable for any App malfunction, incompatibility, or Marketplace removal resulting from a failure to update to a supported version.

3.4 Open Source Components

Certain SDK components may be licensed under open source licences, as identified in the Developer Documentation or SDK release notes. Open source licences take precedence over this Agreement with respect to those components. Nothing in this Agreement limits the Builder's rights under applicable open source licences.

3.5 API Rate Limits and Fair Use

ALL may impose rate limits, throttling, quotas, or access restrictions on API usage at any time to protect the stability, security, and performance of the ALL Platform and to ensure fair access across all Builders. Rate limits are published on the Developer Portal and may be updated from time to time. Builders must not circumvent, bypass, or artificially inflate API usage beyond permitted limits. ALL may immediately suspend API access to any Builder Account that exceeds applicable rate limits or that ALL determines is placing unreasonable load on Platform infrastructure.

3.6 Third-Party Development Assistance

The Builder may engage third-party contractors or service providers ("TSPs") to assist in developing Apps, subject to the following conditions:

• The Builder remains fully responsible for the TSP's compliance with this Agreement, the AUP, the Submission Guidelines, and the confidentiality obligations in Section 13;
• The Builder must bind each TSP to written confidentiality obligations at least as protective as Section 13 before providing the TSP with access to any ALL Confidential Information, SDK components, or Test Credentials;
• TSPs must not be granted access to the Builder Account or Builder Account credentials; all access must be mediated through the Builder;
• The Builder must ensure that any Confidential Information provided to a TSP is destroyed or returned promptly upon the conclusion of the engagement;
• ALL assumes no liability for any act or omission of a TSP, and the Builder indemnifies ALL against any loss arising from a TSP's breach of obligations.

4. App Development Requirements

4.1 Technical and Content Standards

All Apps submitted to the ALL Marketplace must comply with the Submission Guidelines. Without limiting the foregoing, each App must:

• Be functional, stable, and free from critical bugs or crashes at the time of submission;
• Be compatible with the applicable ALL Platform environment and API version specified in the Submission Guidelines;
• Include accurate, complete, and non-misleading metadata, descriptions, screenshots, and categorisation;
• Implement security best practices, including secure authentication, encrypted data transmission, and protection against known vulnerabilities;
• Not include malware, spyware, adware, ransomware, trojans, backdoors, or any other malicious or unauthorised code;
• Clearly disclose to Users all data collected, processed, or transmitted by the App;
• Comply with all applicable privacy and data protection laws, including GDPR, CCPA/CPRA, LGPD, and Panama Law No. 81/2019 on Personal Data Protection, where applicable;
• Include a publicly accessible, accurate, and compliant privacy policy URL at the time of submission, which must remain accessible throughout the listing period.

4.2 Data Handling Requirements

Apps must comply with the following data requirements:

• Apps must not access, collect, process, store, or transmit Traffic Content under any circumstances;
• Apps must not access or process data from Platform users beyond what is strictly necessary for the App's declared functionality;
• Apps must not collect or process Sensitive Data unless ALL has granted express prior written approval and the Builder has implemented appropriate safeguards;
• Apps must provide Users with a clear and accessible privacy notice describing all data collected;
• Apps must not share, sell, or disclose User data to third parties except where required for core functionality and with User consent where required by applicable law;
• Apps must implement data minimisation: only the minimum data necessary for the declared purpose may be collected.

Where an App accesses, collects, uses, shares, or transmits Personal Data, Sensitive Data, device data, usage data, location data, identifiers, authentication data, network data, or similar data in a manner that may not be reasonably expected by the User, the Builder must provide a clear in-App disclosure and obtain any required affirmative consent before such access, collection, use, sharing, or transmission begins. A privacy policy alone is not sufficient where applicable law or ALL's Submission Guidelines require an in-App disclosure, runtime permission, or separate consent. This obligation applies with enhanced force where the App is accessible to minors, in accordance with Section 4.6.

4.3 Security Requirements

The Builder is responsible for the security of each App, including:

• Implementing and maintaining appropriate technical and organisational security measures to protect User data and Platform integrations;
• Promptly patching known security vulnerabilities following discovery or public disclosure;
• Immediately notifying ALL at [email protected] upon discovery of any security vulnerability, data breach, or unauthorised access involving the App or its Platform integration;
• Not storing ALL API keys, secrets, or credentials in publicly accessible repositories or insecure locations.

ALL may require the Builder to provide security scan results, dependency lists, software bill of materials (SBOM), code-signing information, vulnerability remediation evidence, penetration-test summaries, or other security documentation reasonably required for App review, continued listing, incident response, or compliance verification. ALL may also require re-submission of an App following material changes to its security posture, dependencies, or architecture. The Builder must not submit unsigned, tampered, obfuscated, or materially modified App packages except as expressly permitted by the Submission Guidelines.

4.4 Content Rating Classification

The Builder must accurately self-declare a Content Rating for each App at the time of submission, in accordance with ALL's Content Rating Guidelines. The Builder represents that the Content Rating accurately reflects the App's content and intended audience. ALL may verify, amend, or withdraw the Content Rating at any time if ALL determines that the declared rating is inaccurate or misleading. An App whose actual content does not match its declared Content Rating will be removed from the Marketplace pending correction. Systematic misrepresentation of Content Ratings constitutes a material breach of this Agreement.

4.5 Advertising in Apps

Where an App contains advertising, the Builder must:

• Clearly identify all advertising content as advertising and not present it as editorial, system-generated, or Platform-endorsed content;
• Comply with all applicable advertising laws and regulations, including the EU Directive 2005/29/EC on unfair commercial practices and applicable national advertising standards;
• Not implement advertising that targets minors in a manner inconsistent with applicable law or that exploits minors' limited capacity to distinguish advertising from content;
• Not engage in, facilitate, or benefit from fraudulent ad impressions, artificial click generation, or other ad fraud;
• Not serve advertising that promotes illegal products or services, hate speech, CSAM-adjacent content, or content prohibited by the AUP;
• Disclose to Users in the App's privacy policy that advertising is present and identify the categories of data used for ad targeting, where applicable.

4.6 Apps Targeting or Accessible to Minors

Where an App is directed at or accessible to children under the age of 13 (or a higher age where required by applicable law, including 16 under GDPR Article 8), the Builder must:

• Comply with COPPA, GDPR Article 8, the UK Age Appropriate Design Code, and all applicable child protection and privacy laws in every jurisdiction where the App is made available;
• Not engage in behavioural advertising targeting minors;
• Not collect precise geolocation data from minors without explicit, verifiable parental consent where required;
• Implement verifiable parental consent mechanisms where required by applicable law;
• Disclose to ALL in the submission form whether the App is directed at children, partially directed at children, or intended for a general audience;
• Not include features that encourage or facilitate contact between minors and unknown adults.

ALL reserves the right to require additional compliance documentation or to remove any App that ALL reasonably believes poses a risk to minors, regardless of the Builder's declared audience classification.

5. App Submission and Review

5.1 Submission Process

To submit an App to the ALL Marketplace, the Builder must: (a) provide complete and accurate App metadata, pricing model, Content Rating, privacy policy URL, and data collection disclosures; (b) upload the App package in the format specified in the Submission Guidelines; (c) confirm compliance with this Agreement, the AUP, and the Submission Guidelines; and (d) pay any applicable submission fee as disclosed on the Developer Portal. Each submission constitutes a representation by the Builder that the App complies with all applicable requirements as of the date of submission.

5.2 Review and Approval

ALL reserves the right, in its sole and absolute discretion, to approve, reject, or request modifications to any App submission for any reason, including non-compliance with technical standards, content policies, security requirements, legal requirements, content rating accuracy, or ALL's business policies. ALL may conduct automated and manual review of App code, metadata, data handling, advertising practices, and runtime behaviour. Approval of an App does not constitute ALL's endorsement of the App or the Builder, does not represent a warranty of legal compliance, and does not create any obligation on ALL to maintain the App in the Marketplace.

By submitting an App, the Builder authorises ALL to retain, reproduce, test, scan, analyse, sandbox, decompile to the extent necessary for security review and as permitted by applicable law, monitor runtime behaviour, and store copies of the App package, metadata, logs, security reports, and related submission materials for App review, malware detection, compatibility testing, compliance verification, dispute resolution, audit, and Platform security purposes. This authorisation survives removal of the App from the Marketplace for as long as ALL has a legitimate security, audit, compliance, or legal basis for retaining such copies.

5.3 Post-Publication Monitoring and Removal

ALL may monitor published Apps on an ongoing basis. ALL may remove, delist, suspend, restrict, disable, reclassify, downgrade visibility, block updates, require changes to, or prevent installation or execution of any App at any time where ALL determines that such action is necessary or appropriate for legal, security, privacy, compliance, User safety, Platform integrity, Business Customer, Node Operator, reputational, operational, or commercial reasons. ALL will notify the Builder where legally permitted and practicable, but is not obligated to provide advance notice where immediate action is required. To the maximum extent permitted by applicable law, ALL is not liable for any loss of downloads, usage, ranking, visibility, revenue, data, goodwill, or business opportunity resulting from any such action.

5.4 Builder Responsibility for Published Apps

The Builder is solely responsible for the App and its content, functionality, accuracy, legality, and performance following publication. The Builder must: (a) maintain and update published Apps to ensure continued compliance; (b) respond to User complaints and support requests in a timely manner; (c) notify ALL immediately upon becoming aware of any material defect, security vulnerability, legal concern, or change in Content Rating accuracy affecting a published App.

5.5 Single App Removal by Builder

The Builder may request removal of a specific published App from the ALL Marketplace at any time by submitting a removal request through the Developer Portal. ALL will process the removal within a reasonable period after receiving the request. Removal of a specific App does not terminate this Agreement or affect the Builder's other published Apps. Builder Revenue earned prior to the effective date of removal will be processed in the next applicable payout cycle, subject to applicable deductions, holds, and fees. ALL may retain the App's metadata in Marketplace archives for a reasonable period following removal for operational and compliance purposes.

5.6 Compatibility and Platform Updates

The Builder must update published Apps to maintain compatibility with ALL Platform API versions within 90 days of ALL publishing a supported version transition notice on the Developer Portal, unless ALL specifies a different transition period. ALL will provide advance notice of not less than 30 days before removing an incompatible App from the Marketplace, except where immediate removal is required by security or legal reasons. ALL is not liable for any loss of revenue or access resulting from an App's removal due to the Builder's failure to maintain compatibility.

6. Prohibited Content and Uses

6.1 Prohibited Apps

The following types of Apps are prohibited from the ALL Marketplace and must not be developed using the SDK or APIs:

• Malware, spyware, adware, ransomware, trojans, rootkits, keyloggers, or any other malicious software;
• Apps designed to intercept, inspect, decrypt, capture, or analyse Traffic Content;
• Apps designed to manipulate, falsify, or suppress Node telemetry, earnings data, usage metrics, or Session records;
• Apps that harvest, scrape, or aggregate personal data from Platform users without explicit authorisation from ALL and the relevant users;
• Apps that facilitate illegal activity, including fraud, money laundering, sanctions evasion, CSAM, forced labour, human trafficking, or cybercrime;
• Apps containing illegal, defamatory, obscene, hateful, discriminatory, or objectionable content;
• Apps that impersonate ALL, its products, other Builders, or third parties;
• Apps designed to circumvent ALL's security controls, Platform access restrictions, content rating requirements, or App review process;
• Cryptocurrency mining applications that utilise Node resources without explicit authorisation from ALL and the relevant Node Operators;
• Apps that manipulate, fake, or incentivise user reviews, ratings, or download metrics in the ALL Marketplace;
• Apps that create, distribute, or promote AI-generated content sexualising minors (AI-CSAM);
• Apps targeting or designed to harm specific individuals, organisations, or infrastructure.

6.2 AUP Compliance

All Apps and all Builder activity on the Platform must comply with the AUP at all times. In the event of conflict between this Agreement and the AUP regarding acceptable use, prohibited content, or enforcement, the stricter restriction applicable to protect the Platform, Users, or third parties applies.

7. Intellectual Property

7.1 ALL's Intellectual Property

ALL and its licensors retain all right, title, and interest in and to the ALL Platform, SDK, APIs, ALL Control Tower, ALL360 OS, Developer Documentation, ALL Marketplace infrastructure, trademarks, branding, and all associated intellectual property rights. This Agreement does not grant the Builder any ownership interest in any of the foregoing.

7.2 Builder's Intellectual Property

As between ALL and the Builder, the Builder retains ownership of the Builder's original App code and proprietary components, subject to: (a) the licence granted to ALL in Section 7.3; (b) ALL's right to enforce this Agreement, the AUP, and the Submission Guidelines; and (c) third-party intellectual property rights incorporated into the App, which remain subject to applicable third-party licences.

7.3 Licence to ALL

By submitting an App to the ALL Marketplace, the Builder grants ALL a worldwide, non-exclusive, royalty-free, sublicensable licence to: (a) host, store, reproduce, distribute, transmit, and display the App and its metadata through the ALL Marketplace; (b) use the App's name, logo, screenshots, and descriptions to market and operate the Marketplace; (c) review, test, analyse, monitor, and collect Analytics Data regarding the App for compliance and Platform improvement purposes. This licence terminates upon permanent removal of the App from the Marketplace, subject to ALL's right to retain cached copies for a reasonable period for technical and compliance purposes.

7.4 Trademark Licence

ALL grants the Builder a limited, non-exclusive, non-transferable, revocable licence to use ALL's "Built for ALL" badge and "ALL Marketplace" designation solely to identify the App as compatible with or distributed through the ALL Platform, in compliance with ALL's Brand Guidelines as published on the Developer Portal. ALL may revoke this licence at any time. The Builder must not use any ALL trademark in a manner that suggests ALL endorses, certifies, or is affiliated with the Builder beyond what this Agreement provides.

7.5 Feedback

If the Builder provides ALL with suggestions, ideas, or feedback regarding the SDK, APIs, Platform, or Marketplace ("Feedback"), ALL may use such Feedback for any purpose without restriction, compensation, or attribution. The Builder irrevocably assigns to ALL all intellectual property rights in and to such Feedback to the extent required for ALL to use it.

7.6 Third-Party Components

The Builder is solely responsible for ensuring that all third-party libraries, components, and content incorporated into an App are properly licensed for use and distribution through the ALL Marketplace. The Builder must not incorporate third-party components in a manner that: (a) creates obligations on ALL; (b) is incompatible with this Agreement; or (c) violates the third-party licensor's terms. The Builder must disclose all material third-party components in the App's submission metadata.

8. Revenue Share and Payments

8.1 Paid Apps and Revenue Model

Builders may offer paid Apps, subscription-based Apps, in-App purchases, or usage-based monetisation through the ALL Marketplace, subject to ALL's prior approval and the pricing models permitted by ALL from time to time. ALL processes all payments from Users for paid Apps through the PSP/VASP. The Builder must not collect payments directly from Users for Apps distributed through the ALL Marketplace.

8.2 Builder Revenue Share

ALL will credit the Builder's account with Builder Revenue attributable to their published Apps in accordance with the Developer Revenue Schedule. The Developer Revenue Schedule sets out: (a) ALL's Platform Fee; (b) the Builder's net revenue share after applicable deductions; (c) minimum payout thresholds and withdrawal fees; and (d) payout timelines and methods (fiat and/or cryptocurrency via PSP/VASP).

8.3 Changes to Developer Revenue Schedule

ALL may modify the Developer Revenue Schedule at any time, subject to providing at least 30 days' advance notice via the Developer Portal or registered email, except where immediate changes are required to address fraud, abuse, legal or regulatory requirements, PSP/VASP changes, or material operational risks. The Builder's continued publication of an App following the effective date constitutes acceptance of the updated Schedule. If the Builder does not accept a change, the Builder may remove their App(s) from the Marketplace before the effective date without penalty.

8.4 Payout Holds and Withholding

ALL may freeze, withhold, offset, delay, reduce, or — where Builder Revenue has been earned through confirmed fraud, manipulation, or material breach as determined by ALL — forfeit Builder Revenue payments, to the extent permitted by applicable law and the applicable Developer Revenue Schedule, where: (a) ALL has reasonable grounds to suspect fraud, manipulation of usage metrics, ratings, downloads, installs, attribution, or chargeback abuse; (b) a chargeback, refund, reversal, payment dispute, tax issue, PSP/VASP issue, or User complaint is in progress; (c) KYC/KYB, tax, DAC7, sanctions, or payout verification has not been completed; (d) a law enforcement request, regulatory instruction, court order, sanctions alert, or legal hold applies; (e) ALL is investigating a breach of this Agreement, the AUP, Submission Guidelines, privacy obligations, security obligations, or third-party IP rights; (f) the App has been removed, suspended, restricted, or is subject to an unresolved compliance review; or (g) withholding is necessary to protect ALL, Users, Business Customers, Node Operators, payment providers, or the Platform from legal, financial, security, fraud, abuse, or reputational risk.

8.5 Taxes

The Builder is solely responsible for all tax obligations arising from Builder Revenue in all applicable jurisdictions. ALL may withhold taxes where required by law and will provide relevant documentation as required. ALL may be required to report Builder earnings under applicable reporting regimes (including the EU DAC7 Directive) and the Builder must provide ALL with accurate information required for such reporting.

8.6 Revenue Statements and Dispute Window

ALL will issue Builder Revenue statements through the Developer Portal on a monthly basis. The Builder must review each statement and notify ALL of any disputed amount within 30 days of the statement being issued. Disputes raised after the 30-day window will not be accepted, and the relevant statement will be deemed accurate and accepted by the Builder. Disputes must be raised in writing to [email protected] with sufficient detail to identify the disputed transaction(s) and the basis for the dispute.

9. Data and Privacy

9.1 Builder as Independent Controller

The Builder acts as an independent controller where it determines the purposes and means of processing personal data. Where it processes personal data on behalf of another controller, its role and obligations are determined by applicable law and the required data processing agreement. The Builder remains responsible for compliance with the data protection obligations applicable to its actual role.

9.2 ALL as Controller for Platform Data

ALL processes personal data relating to the Builder (including Builder Account data, KYC/KYB data, payment information, and Builder Revenue records) as controller in accordance with the ALL Privacy Policy, which is incorporated by reference into this Agreement.

9.3 Data Processing Agreement

Where an App processes personal data of ALL Platform users on ALL's behalf or through ALL's infrastructure, the Parties may be required to enter into a separate Data Processing Agreement (DPA). The Builder must notify ALL prior to submission of any App that processes personal data of ALL Platform users, so that ALL can determine whether a DPA is required. Where either Party processes personal data on behalf of the other, the required data processing agreement must be concluded before that processing begins.

9.4 Prohibited Data Practices

The Builder must not, through any App or otherwise:

• Access, collect, process, store, or transmit Traffic Content under any circumstances;
• Access or process Node Operator data, Business Customer data, or other Platform user data beyond what ALL expressly authorises through granted API permissions;
• Use personal data collected through an App for any purpose other than the declared purpose disclosed to Users at collection;
• Sell, rent, broker, or otherwise transfer personal data of Platform users to third parties;
• Collect or process Sensitive Data without ALL's express prior written consent and implementation of appropriate safeguards;
• Retain personal data beyond the period necessary for the App's declared purpose or as required by applicable law.

9.5 Security Incident Notification

The Builder must notify ALL at [email protected] without undue delay, and in any event within 48 hours of becoming aware, of any security incident, data breach, or unauthorised access affecting an App, its Users, or data processed through the App's Platform integration. The notification must include the nature of the incident, data affected, estimated number of Users affected, and remediation steps taken or planned.

9.6 ALL Analytics Rights

ALL may collect and use Analytics Data in connection with published Apps. ALL uses Analytics Data to: (a) monitor App performance and stability; (b) detect and remediate security or compliance issues; (c) improve the SDK, APIs, and ALL Marketplace; and (d) generate aggregated Platform performance reports. Analytics Data collected by ALL does not include personal data of individual Users or Traffic Content. The Builder's licence grant in Section 7.3 encompasses ALL's right to collect Analytics Data from published Apps. ALL's use of Analytics Data is governed by the Privacy Policy.

10. User Relationships

10.1 Builder as Contracting Party

The Builder is solely responsible for the contractual relationship with Users of the Builder's App(s). ALL is not a party to any agreement between the Builder and its Users. The Builder must provide Users with a compliant Builder EULA and a compliant privacy policy governing the use of each App before Users access the App.

10.2 User Support

The Builder is solely responsible for providing reasonable technical support to Users of the Builder's App(s). ALL does not provide support to Users on behalf of Builders. User complaints directed to ALL regarding a Builder's App will be forwarded to the Builder where practicable and may result in a compliance review under Section 5.3.

10.3 ALL's Role

ALL's role is limited to operating the Marketplace infrastructure and facilitating distribution of approved Apps. ALL does not endorse, warrant, or guarantee any App, its content, functionality, fitness for purpose, or legality. ALL is not responsible for any dispute between a Builder and a User.

10.4 Prohibited Representations

The Builder must not: (a) represent to Users or third parties that ALL endorses or certifies the Builder's App beyond what Marketplace approval entails; (b) make any representations regarding expected or guaranteed earnings from the ALL Platform or Marketplace to any third party; or (c) misrepresent the functionality, performance, security, Content Rating, or compliance of the App.

10.5 Minimum Builder EULA Requirements

The Builder must make a Builder EULA available to Users before each App is installed or accessed. The Builder EULA must, at a minimum:

• State that the App is licensed by the Builder (not by ALL), and identify the Builder as the sole licensor;
• Disclaim ALL's liability to the User with respect to the App, its content, and its performance;
• Notify the User that ALL is a third-party beneficiary of the Builder EULA and has the right to enforce it against the User to the extent necessary to protect the ALL Platform;
• Prohibit the User from reverse-engineering, decompiling, or disassembling the App;
• Comply with applicable consumer protection and distance selling laws in the User's jurisdiction;
• Include a compliant privacy notice describing all data the App collects, processes, and shares.

ALL's standard Minimum EULA Terms, which Builders may adopt by reference, are published on the Developer Portal. Adoption of the standard Minimum EULA Terms does not relieve the Builder of their obligation to ensure the Builder EULA complies with applicable law.

11. Representations and Warranties

11.1 Builder Representations

The Builder represents and warrants to ALL, on an ongoing basis throughout the term of this Agreement, that:

• The Builder has full legal capacity and authority to enter into and perform this Agreement;
• The Builder is not subject to the sanctions regimes described in Section 2.1;
• Each App is the Builder's original work or the Builder has all necessary rights to develop, submit, and distribute it through the ALL Marketplace;
• Each App does not and will not infringe any third-party intellectual property rights, including patents, trademarks, copyrights, trade secrets, or rights of personality or privacy;
• Each App complies and will continue to comply with this Agreement, the AUP, the Submission Guidelines, and all applicable laws;
• All information provided to ALL, including App metadata, Content Ratings, privacy policy URLs, and data collection disclosures, is accurate, complete, and not misleading;
• The Builder has implemented and will maintain appropriate security measures for each published App;
• The Builder's use of the SDK and APIs complies with all applicable export control and sanctions laws.

11.2 ALL's Representations

ALL represents and warrants only that: (a) ALL has the right and authority to enter into this Agreement and grant the licences expressly granted herein; and (b) ALL will process personal data relating to the Builder in accordance with the Privacy Policy and applicable data protection law.

12. Warranty Disclaimer

— READ CAREFULLY —

12.1 THE SDK, APIS, DEVELOPER PORTAL, ALL MARKETPLACE, ALL PLATFORM, ALL CONTROL TOWER, ALL360 OS, AND ALL RELATED SERVICES AND MATERIALS ARE PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE.

12.2 TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ALL EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO: (A) ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, QUIET ENJOYMENT, OR NON-INFRINGEMENT; (B) ANY WARRANTY THAT THE SDK, APIS, OR PLATFORM WILL BE ERROR-FREE, UNINTERRUPTED, TIMELY, SECURE, OR FREE FROM DEFECTS; (C) ANY WARRANTY REGARDING THE ACCURACY, COMPLETENESS, OR RELIABILITY OF ANY CONTENT, DATA, OR OUTPUT GENERATED THROUGH THE SDK OR APIS; AND (D) ANY WARRANTY THAT THE PLATFORM OR MARKETPLACE WILL REMAIN AVAILABLE OR THAT ANY PARTICULAR FEATURE WILL CONTINUE TO BE PROVIDED.

12.3 ALL DOES NOT WARRANT THAT: (A) THE SDK OR APIS WILL MEET THE BUILDER'S REQUIREMENTS OR EXPECTATIONS; (B) ANY ERRORS OR DEFECTS IN THE SDK, APIS, OR PLATFORM WILL BE CORRECTED; (C) THE RESULTS OBTAINED FROM THE USE OF THE SDK OR APIS WILL BE ACCURATE OR RELIABLE; OR (D) THE MARKETPLACE WILL GENERATE ANY PARTICULAR LEVEL OF USER TRAFFIC, DOWNLOADS, OR REVENUE FOR THE BUILDER'S APP.

12.4 THE BUILDER ACKNOWLEDGES THAT ALL RESERVES THE RIGHT TO MODIFY, DEPRECATE, SUSPEND, OR DISCONTINUE THE SDK, APIS, DEVELOPER PORTAL, OR MARKETPLACE (OR ANY PART THEREOF) AT ANY TIME WITHOUT LIABILITY TO THE BUILDER, EXCEPT AS EXPRESSLY PROVIDED IN THIS AGREEMENT.

12.5 SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES. TO THE EXTENT THAT IMPLIED WARRANTIES CANNOT BE EXCLUDED UNDER APPLICABLE MANDATORY LAW, SUCH WARRANTIES ARE LIMITED IN DURATION TO THE MINIMUM PERIOD PERMITTED BY LAW.

13. Confidentiality

13.1 Confidential Information

"Confidential Information" means any non-public information disclosed by ALL to the Builder in connection with this Agreement, including SDK source code, API specifications, pre-release features, technical architecture, pricing information, business strategies, User data, Node Operator data, Platform telemetry, Analytics Data relating to other Builders, and any information marked as confidential or that a reasonable person would understand to be confidential.

13.2 Confidentiality Obligations

The Builder must: (a) hold all Confidential Information in strict confidence; (b) not disclose Confidential Information to any third party without ALL's prior written consent, except to TSPs in accordance with Section 3.6; (c) use Confidential Information solely for developing and operating Apps in accordance with this Agreement; (d) protect Confidential Information with at least the same degree of care as the Builder's own confidential information, and in no event less than reasonable care; and (e) promptly notify ALL upon becoming aware of any actual or suspected unauthorised disclosure. Confidentiality obligations survive termination of this Agreement for three (3) years.

13.3 Exclusions

Confidentiality obligations do not apply to information that: (a) is or becomes publicly available through no breach by the Builder; (b) was known to the Builder prior to disclosure without restriction; (c) is independently developed by the Builder without use of Confidential Information; or (d) is required to be disclosed by law or court order, provided the Builder gives ALL prompt advance notice where legally permitted and cooperates with ALL to seek a protective order.

13.4 Press Releases and Publicity

The Builder must not issue any press release, public announcement, marketing material, case study, or social media post that references ALL, the ALL Platform, the ALL Marketplace, this Agreement, or the existence of any business relationship with ALL without ALL's prior written consent. Nothing in this Section prevents the Builder from accurately identifying their App as "available on the ALL Marketplace" in compliance with Section 7.4 and ALL's Brand Guidelines.

14. Indemnification and Liability

14.1 Builder Indemnity

The Builder shall indemnify, defend, and hold harmless ALL, its affiliates, officers, directors, employees, agents, successors, and assigns from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or relating to:

• Any App developed or distributed by the Builder, including any claim by a User or third party relating to the App's content, functionality, data practices, advertising, Content Rating, or non-compliance with applicable law;
• The Builder's breach of this Agreement, the AUP, the Submission Guidelines, or any applicable law;
• Infringement of any third-party intellectual property rights by an App;
• Any data breach, security incident, or unauthorised access attributable to the Builder's App or infrastructure;
• Any misrepresentation or inaccuracy in information provided by the Builder to ALL or to Users, including inaccurate Content Ratings or privacy policy disclosures;
• Any tax liability arising from Builder Revenue received under this Agreement;
• Any act or omission of a TSP engaged by the Builder under Section 3.6.

14.2 ALL Indemnity

ALL shall indemnify the Builder only against final, non-appealable third-party claims directly arising from ALL's wilful misconduct or material breach of this Agreement, to the extent such claims are not attributable to: (a) the Builder's acts or omissions; (b) the Builder's breach of this Agreement, the AUP, or applicable law; (c) User conduct; (d) the Builder's App content or functionality; or (e) circumstances outside ALL's reasonable control.

14.3 Exclusion of Consequential Loss

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, NEITHER PARTY SHALL BE LIABLE TO THE OTHER FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING LOSS OF PROFITS, LOSS OF REVENUE, LOSS OF DATA, LOSS OF BUSINESS OPPORTUNITY, LOSS OF GOODWILL, OR COSTS OF SUBSTITUTE GOODS OR SERVICES, WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, EVEN IF THE PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

14.4 Cap on Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ALL'S TOTAL AGGREGATE LIABILITY TO THE BUILDER SHALL NOT EXCEED THE GREATER OF: (A) THE TOTAL BUILDER REVENUE PAID BY ALL TO THE BUILDER IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM; OR (B) USD 500.

14.5 Mandatory Rights

Nothing in this Section 14 limits or excludes any liability that cannot be lawfully excluded or limited under applicable mandatory law in the Builder's jurisdiction of residence or incorporation.

15. Term and Termination

15.1 Term

This Agreement commences on the date the Builder completes registration and is approved as a Builder, and continues until terminated in accordance with this Section 15.

15.2 Termination by the Builder

The Builder may terminate this Agreement at any time by closing the Builder Account, removing all published Apps from the ALL Marketplace in accordance with Section 5.5, and notifying ALL in accordance with Section 19.7. Termination does not affect any outstanding payment obligations or accrued liabilities.

15.3 Termination by ALL for Cause

ALL may terminate this Agreement with immediate effect, without prior notice, upon the occurrence of any of the following:

• Material breach of this Agreement, the AUP, or the Submission Guidelines, where not cured within 14 days of notice (or immediately where the breach is incapable of cure or poses a material legal, security, content, or reputational risk);
• Submission of an App containing malware, prohibited content, AI-CSAM, or code designed to harm Users or the Platform;
• Systematic misrepresentation of App metadata, Content Ratings, or data collection disclosures;
• The Builder is found to be subject to applicable sanctions;
• Provision of false, misleading, or fraudulent information to ALL;
• Detection of fraud, manipulation of usage metrics or ratings, chargeback abuse, or other material dishonest conduct;
• A law enforcement demand, regulatory instruction, or court order requires termination;
• Repeated violation of the Submission Guidelines or AUP following prior warnings.

15.4 Termination by ALL for Convenience

ALL may terminate this Agreement for convenience upon 30 days' written notice to the Builder. ALL will process any outstanding Builder Revenue balance (subject to applicable holds and deductions) within a reasonable period following the effective date of termination.

15.5 Suspension

Without prejudice to ALL's termination rights, ALL may immediately suspend the Builder Account, remove any App, or restrict Marketplace access without prior notice where ALL determines that immediate action is necessary to protect Users, the Platform, or third parties. ALL will notify the Builder where legally permitted. Following a suspension, ALL may reinstate access, extend the suspension, or proceed to termination in its sole discretion.

15.6 Effect of Termination

Upon termination of this Agreement:

• All licences granted to the Builder under this Agreement terminate immediately;
• ALL will remove all Builder Apps from the ALL Marketplace;
• The Builder must cease using the SDK, APIs, and all ALL Confidential Information;
• ALL will process any available Builder Revenue balance (after applicable deductions, holds, and fees) within a reasonable period;
• The Builder must promptly delete all Confidential Information and Test Credentials;
• Sections 7.1, 9, 11, 12, 13, 14, 15.6, 16, and 19 survive termination.

16. Governing Law and Dispute Resolution

16.1 Governing Law

This Agreement is governed by and construed in accordance with the laws of the Republic of Panama, without regard to its conflict of law principles.

16.2 Dispute Resolution

Any dispute, controversy, or claim arising out of or relating to this Agreement, including its formation, validity, breach, or termination, shall be resolved as follows:

• The Parties shall first attempt to resolve any dispute through good-faith negotiation within 30 days of written notice of the dispute;
• If the dispute is not resolved through negotiation, either Party may refer the dispute to binding arbitration administered by the Dubai International Arbitration Centre (DIAC) in accordance with the DIAC Arbitration Rules. The seat of arbitration shall be Dubai, United Arab Emirates; the language of proceedings shall be English; and the arbitral tribunal shall consist of one (1) arbitrator, unless either Party requests a three-arbitrator panel for disputes exceeding USD 500,000 or as otherwise required by the DIAC Rules;
• The arbitral award shall be final and binding on the Parties. Nothing in this Section prevents either Party from seeking urgent interim or injunctive relief from a court of competent jurisdiction.

16.3 Consumer Rights

If the Builder is a natural person operating as a consumer in a jurisdiction that affords mandatory consumer dispute resolution rights under applicable law, those rights are not affected by this Section 16.

17. Sanctions and Export Control

The Builder must comply with all applicable sanctions and export control laws and regulations, including those maintained by OFAC, the European Union, OFSI, and the United Nations Security Council. The Builder must not use the SDK, APIs, or ALL Marketplace in connection with any person, entity, or transaction subject to applicable sanctions. The Builder represents and warrants that the App does not include any technology, software component, or encryption feature that would require an export licence under applicable law without such licence having been obtained. ALL may conduct sanctions screening on any Builder at any time and may immediately suspend or terminate this Agreement if a screening alert is generated. The Builder must promptly notify ALL if their sanctions compliance status changes.

18. Amendments

ALL may amend this Agreement, the Submission Guidelines, or the Developer Revenue Schedule at any time by posting the updated version on the Developer Portal. Unless otherwise required by applicable law, updates take effect upon posting or on the effective date specified by ALL. Where ALL considers a change material and not urgent, ALL will provide advance notice of at least 14 days. Changes required to address legal, regulatory, tax, sanctions, security, fraud, abuse, or operational risks may take effect immediately. The Builder's continued use of the SDK, APIs, or ALL Marketplace after the effective date constitutes acceptance. If the Builder does not accept an amendment, the Builder's sole remedy is to terminate this Agreement in accordance with Section 15.2. Notwithstanding the foregoing, Material Changes are subject to the notice periods and urgent-change exceptions in Section 3 of the Terms of Use. Any longer notice period or additional protection required by applicable mandatory law prevails.

19. General Provisions

19.1 Entire Agreement

This Agreement, together with the Terms of Use, the AUP, the Privacy Policy, the Developer Revenue Schedule, the Submission Guidelines, and ALL's Content Rating Guidelines, constitutes the entire agreement between the Parties with respect to the subject matter hereof and supersedes all prior agreements, understandings, and representations, whether written or oral.

In the event of conflict between the foregoing documents: (a) the Submission Guidelines, Content Rating Guidelines, Developer Revenue Schedule, App-specific approval conditions, and Developer Portal requirements prevail for App submission, review, distribution, monetisation, and technical requirements; (b) the AUP prevails for prohibited content, prohibited use, abuse, security, and enforcement matters; (c) the Privacy Policy and any applicable Data Processing Agreement or data-sharing terms prevail for personal data processing; and (d) this Agreement prevails for Builder-specific SDK, API, Marketplace, revenue, intellectual property, and App-distribution obligations. Where more than one restriction applies, the stricter or more protective restriction in favour of ALL, Users, the Platform, or third parties applies to the maximum extent permitted by law.

19.2 Relationship of Parties

The Builder is an independent contractor. Nothing in this Agreement creates a relationship of employment, agency, partnership, joint venture, or franchise between ALL and the Builder. The Builder has no authority to bind ALL or to incur obligations on ALL's behalf.

19.3 Assignment

The Builder may not assign, transfer, or delegate any rights or obligations under this Agreement without ALL's prior written consent. ALL may assign this Agreement to any affiliate, successor entity, or purchaser of all or substantially all of ALL's business or assets, upon notice to the Builder.

19.4 Severability

If any provision of this Agreement is held invalid, illegal, or unenforceable, that provision shall be modified to the minimum extent necessary to make it enforceable, or severed if modification is not possible, and the remaining provisions shall continue in full force and effect.

19.5 Waiver

No failure or delay by either Party in exercising any right under this Agreement shall operate as a waiver. No single or partial exercise of any right precludes any other or further exercise thereof.

19.6 Force Majeure

Neither Party shall be liable for any failure or delay in performance caused by events beyond their reasonable control, including acts of God, natural disasters, pandemics, governmental actions, war, civil unrest, cyberattacks on third-party infrastructure, or failure of third-party telecommunications providers, provided that the affected Party gives prompt notice and uses reasonable efforts to mitigate the impact.

19.7 Notices

Notices under this Agreement shall be provided in writing. ALL may provide notices via the Developer Portal, email to the registered Builder Account address, or through the Platform's notification system. Notices from the Builder to ALL must be sent to [email protected]. Notices are deemed received: (a) if sent by email, on the day of transmission; (b) if sent through the Developer Portal notification system, upon posting.

19.8 Language

This Agreement is made in the English language. If translated into any other language, the English version shall prevail in the event of any inconsistency.

19.9 Independent Development

Nothing in this Agreement restricts or limits ALL's right to independently develop, acquire, market, promote, or distribute products, services, applications, SDKs, or features that are similar to or competitive with the Builder's App, regardless of any similarity to materials that may have been submitted by the Builder to ALL. Nothing in this Agreement imposes any obligation on ALL to use, promote, or prioritise the Builder's App over any competing or similar product.

19.10 Third-Party Beneficiaries

The Parties agree that: (a) ALL's affiliates are intended third-party beneficiaries of the provisions of this Agreement that protect ALL's intellectual property, confidential information, and Platform integrity; and (b) Users of the Builder's App are intended third-party beneficiaries of Section 10.5 (Minimum Builder EULA Requirements) and ALL's right to enforce the Builder EULA against Users to the extent provided therein. Except as expressly provided in this Section, this Agreement does not create any rights in or obligations to any third party.

20. Contact Information

For questions about this Agreement, please contact:

This Agreement should be read together with the ALL Platform Terms of Use, Privacy Policy, Cookie Policy, Acceptable Use Policy, and all applicable role-specific documents, all of which are available on the Platform website.