International Buyer & Jurisdiction Policy

International Buyer & Jurisdiction Policy

BUYENJOY · PLATFORM LEGAL DOCUMENT

International Buyer & Jurisdiction Policy

Geographic eligibility, restrictions, and enhanced due diligence requirements

BuyEnjoy is a global technology platform. Buyers from most countries in the world are welcome to register and, subject to this Policy, to purchase properties in the countries where BuyEnjoy operates. This Policy describes the geographic restrictions and compliance requirements that apply based on your declared country of residence and, for U.S. users, state of residence. Residence — not citizenship or nationality — controls.

I. Who Can Be a Buyer

You may register as a Buyer on BuyEnjoy if you: (a) are at least 18 years old; (b) reside in a country that is not a refused jurisdiction under Section II; and (c) pass identity verification (KYC) through Argos. Residents of U.S. states that are blocked or waitlisted, and residents of markets closed at launch (Section III), may create an account and browse, but cannot currently complete a purchase.

Your country and, where applicable, your state or province of residence are declared at signup or, at the latest, when starting a purchase or an offer, and the Platform checks them against these lists before each transaction. If you reside in a refused jurisdiction, you will be notified at registration and cannot proceed. If you reside in a blocked or waitlisted U.S. state, you may still create an account, but the purchase function is disabled for your state and you will be offered the option to be notified the moment service becomes available.

Biometric verification. Identity verification uses biometric data only with your consent under the Biometric Data Collection Consent (document 22). Residence in Illinois, Texas or Washington is determined from the residence you declare; residents of those states are always shown the biometric notice and asked for the written release before any capture.

II. Refused Jurisdictions

Registration and transactions are not available to persons who reside in, or transact from, the following, following the OFAC and FATF publications, which BuyEnjoy reviews after each FATF plenary and each OFAC action that affects them and updates on the Platform within ten (10) business days of publication — the official publication is always the authoritative source:

OFAC comprehensive sanctions: Cuba (CACR), Iran (ITSR), North Korea (NKSR), and the Crimea, Donetsk, and Luhansk regions of Ukraine.

FATF call-for-action list: Iran, North Korea, and Myanmar (as of the June 2026 plenary).

BuyEnjoy risk policy: Russia, Belarus, and Syria are refused as a matter of BuyEnjoy’s own risk-based policy, given the breadth of targeted sanctions and residual-regime risk affecting those jurisdictions.

In addition, any person on the OFAC SDN or consolidated lists, and any entity owned 50% or more by blocked persons, is refused regardless of location. The authoritative sanctions source is sanctionssearch.ofac.treas.gov; the authoritative FATF source is fatf-gafi.org.

III. U.S. Residents — State Eligibility

U.S. residents are welcome to create an account and browse BuyEnjoy from any state. Every U.S. purchase runs on the fiduciary rail in U.S. dollars described in Section V. A U.S. state opens to purchases only when the licence or exemption, for that state, of the U.S. escrow holder that receives its residents' funds is in BuyEnjoy's compliance file; until then, residents of that state may hold an account and browse, and their purchases are placed on the waiting list. The states that may open on that basis are Texas, Illinois, Virginia, Colorado, Florida, New York, California, Louisiana and Pennsylvania, all on the fiduciary rail; Texas residents always purchase with enhanced review. Residents of all other states are placed on the waiting list. Purchases are not available at launch to residents of Canada, the United Kingdom, the United Arab Emirates or any European Union or European Economic Area country, or of any country refused under Section II of this Policy. Eligibility is determined by the residence the Buyer declares — at registration or, at the latest, when starting a purchase or an offer — as it stands when the transaction is created, and the Platform checks it against these rules before each transaction; it is never determined by IP address. A resident of a blocked or waitlisted state may hold an account and browse. Declaring a false residence is a breach of the Terms of Service: BuyEnjoy may ask for proof of address at any time and, if the declared residence proves false, suspend the account and not continue the transaction, without prejudice to the refund rules of the stage the transaction has reached.

Residents of the European Union and EEA, the United Kingdom, the United Arab Emirates and Canada are held closed at launch by the same residence gate: each of those markets has its own outstanding items — the data-protection assessment and consent flow, the consumer annex and the transfer mechanism for the EU and the UK, and the federal AML and provincial real-estate questions for Canada — and the opening of the fiduciary rail does not open them automatically. Eligibility and the rail assigned to a transaction are decided from the residence declared at the moment the transaction is created, are immutable from that moment, and are never decided from an IP address.

One inventory rule applies on top of the residence gate, for New Jersey and New York. The Platform does not offer subdivided land under a common promotional plan, and it does not offer vacant land on an instalment plan. Those two shapes, and only those, are what the New Jersey Real Estate Sales Full Disclosure Act and Article 9-A of the New York Real Property Law reach. No project, pre-sale or development inventory is offered into New Jersey, and no vacant lot is offered on instalment terms into New York, unless the corresponding registration has been filed first.

Development inventory. Development inventory (lots and condominium units offered by a developer) is sold only on an earnest deposit and payment of the balance at closing; no instalment plan is offered. Whether a project is offered to residents of a given state is decided project by project, and a project not cleared for the Buyer's state is not shown to that Buyer as purchasable; a project not cleared for Virginia or New York is also hidden from residents of those states and left out of marketing directed to them, and public project pages carry the New York safe-harbour disclaimer.

Reward programs. Residence restrictions on rewards are separate from purchase eligibility. Rewards under the Community Referral Program (document 20) and the Ambassador Program (document 35) are not available to residents of the States of New York, New Jersey, Texas or Florida, or of any province or territory of Canada, even where the property is located elsewhere; see those documents.

IV. FATF Enhanced Monitoring — Enhanced Due Diligence

Buyers residing in countries on the FATF increased-monitoring list (the "grey list") are permitted to register and transact, subject to Enhanced Due Diligence (EDD), completed before the Settlement Statement for the transaction is committed. BuyEnjoy has no power to authorize or withhold any release of funds held by the escrow holder. This is BuyEnjoy’s own risk-based policy choice, applied proportionately — the FATF itself does not mandate enhanced diligence solely on grey-list residence and discourages indiscriminate de-risking. The grey list is reviewed at FATF plenaries (February, June, October) and BuyEnjoy’s flags update accordingly.

EDD requirements include: (a) additional documentation of the source and nature of funds; (b) documentation of beneficial ownership if funds originate from a legal entity; and (c) manual review by BuyEnjoy’s compliance team with senior approval, typically completed within 5 business days of document submission. Certain heavily sanctioned but non-embargoed jurisdictions (for example, Venezuela) sit at the top of the EDD tier with particular attention to government and state-enterprise connections.

If EDD applies to you, BuyEnjoy notifies you at registration and communicates the requirements when you initiate a transaction.

V. How Buyers Pay

BuyEnjoy never receives, holds or directs the transaction funds. At launch every transaction settles on the fiduciary rail in U.S. dollars. A Buyer resident in the United States funds a U.S. escrow holder that is licensed or exempt for that purpose, which makes a single transfer of the funds, on the Buyer's and the Seller's joint written instruction (Form A of the Disbursement Instruction, document 31, signed with the settlement statement as a standing instruction to transfer each amount on receipt), to the escrow account named in that instruction, held by the escrow agent in the property's country, whether in the United States or in that country; the U.S. holder makes no itemized payment. A Buyer resident in California funds instead an escrow holder licensed in California, which holds the whole escrow and runs the itemized waterfall itself under its own agreement. A Buyer resident outside the United States funds the holder in the property's country directly. The itemized waterfall, committed before funding, runs only at the holder in the property's country or, for a California resident, at the California holder. Each holder holds the funds of each transaction apart from its own funds, under a contract that keeps them outside the holder's estate in an insolvency; the funds are not assets of BuyEnjoy and are not available to its creditors. Every disbursement, including the Seller's proceeds, is made by the holder by domestic or international bank transfer. An on-chain rail has been built but is switched off; no transaction settles on it while it remains off, and it is never used for Texas residents or for property in Costa Rica.

VI. EU and EEA Buyers — GDPR Notice

If you are a resident of the European Union or European Economic Area (EU/EEA), the General Data Protection Regulation (GDPR) applies to your personal data processed by Atacama Technologies LLC d/b/a BuyEnjoy as Controller. At registration we collect your residence country (for jurisdiction compliance) and, through Argos, biometric data (for KYC). Your biometric data is special-category data under GDPR Art. 9, processed solely on your explicit consent (Art. 9(2)(a)); see the Biometric Data Collection Consent (document 22) and Privacy Policy (document 02) for your full GDPR rights, including the transfer safeguards applied to processing in the United States. At launch the Platform does not offer purchases to EU/EEA residents and does not target them (Section III); this notice applies to personal data processed at registration. Because identity verification is open to residents of the EU/EEA and the United Kingdom, BuyEnjoy has appointed Prighter Group, with its local partners, as its privacy representative under Article 27 GDPR and Article 27 UK GDPR, and as your point of contact for the European Union (EU) and the United Kingdom (UK). Prighter gives you an easy way to exercise your privacy-related rights (for example, requests to access or erase personal data). If you want to contact us via our representative, Prighter, or make use of your data-subject rights, please visit https://app.prighter.com/portal/buyenjoy. BuyEnjoy communicates the contact of its Data Protection Officer to the supervisory authority of the member state where the EU representative is established. You may lodge a complaint with the supervisory authority of your member state at any time.

VII. OFAC Screening of All Parties

All parties to every transaction — Buyer, Seller, and Professionals — are screened against the OFAC SDN and consolidated lists regardless of the transaction amount, at onboarding and on an ongoing basis as the lists update. This is a U.S. legal requirement and is performed automatically through BuyEnjoy’s compliance controls, with audit-grade records and human adjudication of potential matches.

VIII. Updates and Contact

This Policy is reviewed quarterly and updated as FATF publishes new plenary decisions, OFAC updates its designations, or state licensing evolves. Material changes are notified in-app.

For jurisdiction questions: support@buyenjoy.io. For privacy questions, including GDPR: Data Protection Officer: Gabriel Morales, reachable at support@buyenjoy.io.

ACCEPTANCE

User / Account Holder (acknowledged at registration)