Restricted Jurisdictions

Phygitals' position on geographic restrictions, regulatory classification of pack openings, user responsibility for local law compliance, and sanctions.

Overview

Phygitals is a collectible card platform where users purchase digital packs containing randomized selections of professionally graded, physically vaulted trading cards. This page explains our regulatory position, your responsibilities regarding local law, and the sanctions-related restrictions that apply to the platform.

Regulatory Position

Phygitals believes that its pack openings and related features are purchases of digital goods rather than gambling or lottery services. However, regulatory definitions vary by jurisdiction and continue to evolve. Phygitals makes no guarantee regarding the classification of its services in any jurisdiction. Our position is based on the following:

• Fair value exchange: Every pack is priced so that the total fair market value of the cards contained within is equal to or greater than the purchase price. Users receive collectible goods of real value, not a chance at nothing.

• Physical backing: Every digital card on the platform is backed by a professionally graded, physically vaulted trading card. Pack openings are analogous to purchasing sealed physical trading card products (e.g., booster packs), which are widely recognized as retail products rather than gambling instruments.

• Collectibles, not cash: Users receive collectible trading cards, not cash or cash equivalents. While cards may be resold on the marketplace, the primary product is a physical collectible.

• Provable fairness: All pack outcomes are determined by a cryptographic provably fair algorithm with no human involvement in the selection process. Users can independently verify the randomness and integrity of their results.

Notwithstanding the above, Phygitals acknowledges that the regulatory treatment of randomized digital rewards varies by jurisdiction and continues to evolve. Some jurisdictions may classify paid randomized reward mechanics differently regardless of the underlying value proposition.

User Responsibility

You are solely responsible for determining whether your use of the Service complies with all laws and regulations applicable in your jurisdiction. This includes, but is not limited to:

• Understanding local laws regarding digital assets, collectibles, and any regulations that may apply to randomized reward mechanics;

• Determining whether pack openings, Pack Parties, or other features are subject to any restrictions in your jurisdiction;

• Complying with local tax obligations related to digital asset transactions and collectible purchases;

• Determining whether participation in pawn/lending services is subject to local consumer lending regulations.

Phygitals does not provide legal, tax, or financial advice. If you are unsure about the legality of using any feature of the Service in your jurisdiction, we strongly recommend consulting a qualified legal professional before proceeding.

By using the Service, you represent and warrant that your use of the platform and its features is lawful in your jurisdiction. You assume all risk and liability arising from your use of the Service in any jurisdiction.

Future Geographic Restrictions

Phygitals reserves the right to implement, expand, modify, or update geographic restrictions at any time as regulatory landscapes evolve. This may include:

• Restricting access to specific features (such as pack openings or Pack Parties) in certain jurisdictions;

• Implementing IP-based geolocation, account-level restrictions, or on-platform access controls;

• Blocking access to the entire platform in jurisdictions where compliance is not feasible.

If geographic restrictions are implemented, they may be applied without prior notice in response to new legislation, regulatory guidance, or enforcement actions. Phygitals will make reasonable efforts to communicate material changes to affected users where practicable.

Sanctions & Comprehensive Restrictions

The entire Phygitals platform is not available to users who are:

• Residents of, or located in, any country or territory subject to comprehensive economic sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the European Union, the United Kingdom, or the United Nations;

• Listed on any sanctions, denied persons, or blocked persons list, including but not limited to: OFAC's Specially Designated Nationals and Blocked Persons List, the U.S. Commerce Department's Denied Persons List, HM Treasury's Consolidated List of Financial Sanctions Targets (UK), and the EU Consolidated List of persons, groups, and entities subject to EU financial sanctions;

• Owned or controlled by, or acting on behalf of, any person or entity described above.

This includes, but is not limited to, residents of: Cuba, Iran, North Korea, Syria, the Crimea region of Ukraine, the Donetsk People's Republic, and the Luhansk People's Republic. This list is subject to change in accordance with applicable sanctions regulations.

By using the Service, you represent and warrant that you are not a person or entity subject to any applicable sanctions, and that you are not accessing the Service from a comprehensively sanctioned jurisdiction.

Contact

If you have questions about geographic restrictions, regulatory compliance, or sanctions, please contact us:

• Email: [email protected]

• General support: [email protected]

This policy is reviewed and updated periodically. Material changes will be communicated through the platform. Continued use of the Service following any updates constitutes acceptance of the revised policy.