Bitso

Terms and Conditions of the “Regalo Millonario” Promotion (the “Promotion”)

1. Territory of Validity.

The Promotion is valid only within the United Mexican States (“Mexico”).

2. Party Responsible for the Promotion.

Bitso, S.A.P.I. de C.V. (“SAPI”) is the entity that owns the application (the “App”), which operates as an access platform for various products and services, each provided by the entity holding the corresponding regulatory authority.

This Promotion is the responsibility of, and is offered and administered by, Nvierto S.A. de C.V. (“Nvierto”), acting in its capacity as an independent investment advisor.

The opening of the brokerage account, the execution of transactions, and the custody of assets are handled by Alpaca Securities, LLC (“Alpaca”).

Each of the entities mentioned acts exclusively within the scope of its own powers and regulatory authorizations, without implying the joint, indistinct, or several provision of services among them. The App is solely the access channel to the services of each entity.

3. Eligibility Requirements.

  • Be 18 years of age or older.
  • Reside in Mexico.
  • Have an active account in the App with identity verified at the verification level (KYC) required under applicable law.
  • Not be an employee or affiliate of SAPI, Nvierto and/or Alpaca.
  • Adhere to these Terms and Conditions and to the applicable contractual documents within the App.

Only one reward will be granted per user.

4. Term.

This Promotion will be in effect from July 20, 2026 through August 10, 2026 (the “Term”), without prejudice to its early termination upon the occurrence of the first of the following events: (i) the total budget internally allocated to the Promotion is exhausted; or (ii) the maximum number of 56,037 rewards granted is reached.

The Promotion may be enabled on a staggered basis during the Term through different phases, in accordance with the operational, commercial, performance, or internal-metrics compliance criteria determined by Nvierto. Accordingly, the Term of the Promotion does not imply that all users may participate simultaneously, that a subsequent phase will necessarily be activated, or that the Promotion will be enabled for all users throughout the entire Term.

Nvierto may modify, enable, pause, adjust, suspend, or terminate early the Promotion, in whole or in part, as well as any of its phases, for operational, security, regulatory, commercial, or performance-related reasons.

5. Modifications.

Nvierto may modify, suspend, extend, or cancel this Promotion at any time, without prior notice, in its sole discretion.

6. How the Promotion Works.

The purpose of the Promotion is to allow eligible users to become acquainted with the services offered by Nvierto, without such benefit constituting investment advice, a personalized recommendation, a public offering of securities, an incentive to acquire, sell, or hold specific securities, or a guarantee of return. Participation in the Promotion does not require the user to carry out securities transactions. If the user decides to receive investment advisory services, Nvierto may provide such services in accordance with the applicable regulatory framework, taking into account, among other elements, the user’s profile, investment objectives, risk tolerance, the information provided by the user, applicable risk disclosures, and, if applicable, any instructions issued by the user.

Any investment decision will be the sole responsibility of the user, in accordance with the type of service contracted and the applicable regulations.

To be eligible, the user must:

  1. Successfully complete the onboarding process required by Nvierto.
  2. Successfully complete the account-opening process with Alpaca.
  3. Opt in to the Promotion during the Term, within the “Recompensas” / “Rewards Hub” section of the App (“Opt-in”). The Opt-in may be completed even after the account-opening process with Alpaca has been completed, provided that it is completed within the Term.

If the user does not complete the Opt-in activation, the user will not be eligible for the Promotion and will have no right to receive any reward.

Likewise, completion of the foregoing steps does not guarantee the reward if the campaign slots or budget have already been exhausted.

7. Reward.

The Promotion provides for a total of 56,037 rewards.

The individual reward assigned to each participating user consists of a fixed amount pursuant to the reward allocation list (the “Reward List”), which contains 56,037 rewards, each with a different amount, ranging from a minimum of USD $5 to USD $1,000.

The reward is paid in Mexican legal tender (Mexican pesos or MXN), calculated on the basis of a fixed reference exchange rate of MXN $17.43 per USD, taken on July 16, 2026 solely for purposes of this Promotion. Payment may be made in one or more partial payments and must be reflected in full no later than September 1, 2026.

Rewards will be allocated according to a predefined sequence, on a first-come, first-served basis, based on the order in which eligible users successfully complete the campaign requirements. Accordingly, the amount corresponding to each user will depend on the user’s place on the Reward List at the time the applicable process is successfully completed in accordance with these terms and conditions.

The campaign does not operate through a random prize allocation, but rather through a defined distribution of rewards according to the order of participation established in the Reward List.

This campaign does not constitute a sweepstakes, raffle, lottery, or game of chance under the Federal Law on Games and Sweepstakes and its Regulations, because the granting of the reward does not depend on a random element, but exclusively on the verifiable satisfaction, by each user, of the eligibility requirements and the order of Opt-in activation relative to other users and in accordance with the Reward List.

8. Use of the Reward.

The reward in MXN is intended for the user to use for the acquisition of shares, fractional shares and/or other listed securities available within the App’s stock functionality, through the account opened with Nvierto and Alpaca.

Notwithstanding the foregoing, the user remains free to dispose of the reward in accordance with the functionalities enabled within the App, and neither Nvierto nor Alpaca may condition, penalize, or require the user to use the reward specifically for the purchase of shares.

9. Lock-up and Restrictions.

From the time the reward is credited, it may be subject to operational restrictions within the App for a period of 30 calendar days, solely for fraud or abuse prevention purposes. During such period, shares acquired with the reward may not be freely transferred to another account. Upon expiration of the 30-day period, the user may freely dispose of the user’s assets.

These restrictions do not constitute a penalty for the user’s decision regarding the destination of the reward, but rather an operational and anti-fraud control measure applicable equally to all participants.

10. Cases in Which the Reward May Be Cancelled.

Nvierto may cancel, reject, or recover the reward, including any preliminary tier allocation, if it detects, among other circumstances:

  • false, incomplete, or inconsistent information;
  • use of multiple accounts;
  • identity theft or impersonation;
  • breach of these Terms and Conditions;
  • breach of the applicable terms of Nvierto or Alpaca;
  • fraudulent, abusive, or unlawful activity; or
  • failure to satisfy any eligibility requirement.

11. Liability.

Nvierto will not be liable for onboarding rejections by Nvierto and/or Alpaca, technical failures of third parties, market interruptions, losses arising from the purchase or holding of shares, or investment decisions made by the user.

Nvierto’s maximum liability in connection with this Promotion will be limited, if applicable, to the amount of the reward effectively assigned to the user.

12. Risks.

The purchase of shares and listed securities involves risks. The value of shares may increase or decrease, and the user may lose part or all of the value invested.

The reward: i) does not constitute a personalized investment recommendation; ii) does not guarantee returns; iii) does not eliminate the risks associated with the purchase of shares; and iv) does not imply that Nvierto recommends any specific share or security.

13. Protection.

The reward is granted by Nvierto, which does not provide brokerage or securities custody services. Any shares purchased by the user will be subject to the brokerage account opened with Alpaca and to the applicable terms of such account. Nvierto does not custody securities.

14. Force Majeure.

In the event of force majeure or events beyond Nvierto’s control (including, but not limited to, pandemics, cyberattacks, or technical interruptions), Nvierto may cancel, modify, or postpone the Promotion without prior notice.

15. Intellectual Property.

The trademarks mentioned are the property of their respective owners, and their mention in this Promotion does not imply any commercial relationship.

16. Promotion Dissemination Channels.

The Promotion will be communicated through the following official channels of the Bitso brand: (a) App; (b) email communications; (c) push notifications; (d) social media, including X (formerly Twitter): @Bitso and Instagram.

The Promotion may also mention the Nvierto by Bitso brand.

17. Personal Data.

Participants’ personal data will be processed in accordance with the respective Privacy Notices of the App, available at: https://bitso.com/terms.

18. Contact.

For any questions or clarifications regarding this Promotion, the user may contact Nvierto through:

Nvierto designates the following address for notices: Campos Elíseos #400, Floor 3, INT 302 B, Zip Code 11530, Col. Polanco II Sección, Alcaldía Miguel Hidalgo, Mexico City, Mexico.

19. Tax Obligations.

Users will be responsible for complying with their tax obligations arising from the receipt of the rewards. Neither Nvierto nor Alpaca will be responsible for making withholdings, filings, or tax payments on behalf of users, who must comply with such obligations in accordance with the tax laws applicable to them.

20. General Terms and Conditions.

The general Terms and Conditions of use are available at: https://bitso.com/terms.

21. Governing Law.

These Terms and Conditions will be governed by the applicable laws of Mexico. For their interpretation and performance, participants submit to the jurisdiction of the competent courts of Mexico City, unless otherwise provided by mandatory law.

Securities purchase and sale transactions carried out through Alpaca Securities LLC will be governed by the terms of the corresponding account and by the laws of the United States applicable to such services.

22. Reward List.

The complete Reward List, including the individual amount assigned to each position according to the allocation order, is available for review in the following document: View Reward List