Terms and Conditions – Promotional Campaign: "Es Un Millón"

These Terms and Conditions (the "Terms") govern the promotional campaign "Es Un Millón" (the "Campaign") organized by Hapi Securities LLC. Participation in the Campaign implies full acceptance of these Terms.

All time references in these Terms are expressed in UTC-5, unless otherwise explicitly stated.

This Campaign is organized by Hapi Securities LLC, a broker-dealer member of FINRA and SIPC (hereinafter, "Hapi"), with respect to the Campaign's operations, promotional communications, and benefit assignment.

Brokerage services are provided by Hapi Securities LLC. This Campaign does not constitute an investment recommendation or financial advice. Investing involves risks, including the possible loss of capital.

The Campaign will grant promotional benefits, in the form of fractional shares of securities, to Participants who meet the conditions described in these Terms, while stock and promotional budget remain available.

For the avoidance of doubt, and applicable to the Campaign as a whole:

Investing in securities involves risks, including the possible loss of capital. Past performance does not guarantee future results.

For purposes of these Terms:

The Campaign will be active from Monday, June 22, 2026 at 00:00 (UTC-5) until Wednesday, July 22, 2026 at 23:59 (UTC-5) (the "Campaign Period"), unless early termination, modification, or suspension occurs pursuant to these Terms, or unless the benefit limit set forth in Section 10 is reached earlier.

Any participation outside the Campaign Period will not be considered valid.

Promotional benefits will be credited twice (2) per week, on Tuesdays and Thursdays at 5:00 PM (UTC-5), subject to operational and compliance validations.

The final assignment of promotional benefits will take place on Thursday, July 30, 2026 at 5:00 PM (UTC-5), pursuant to the validation criteria in Section 8.

Notwithstanding the above, deposits initiated within the Campaign Period may be confirmed after its close, pursuant to the time criteria established in Section 8.

The Campaign is directed exclusively to users who meet all of the following conditions:

Mandatory identity verification. KYC is an indispensable requirement to qualify for any benefit under this Campaign. No promotional benefit — including the acquisition of fractional shares — may be assigned to accounts that have not completed such verification, pursuant to the requirements of custodian Apex Clearing Corporation and applicable regulations.

Geographic scope. The Campaign is valid only in countries where Hapi Securities LLC legally operates and is void where prohibited by law, subject to applicable local regulations.

Hapi Securities LLC may limit or reject any user's participation based on regulatory, operational, risk, or compliance criteria.

The Campaign consists of three (3) independent promotional phases. In all cases, the promotional benefit is determined randomly pursuant to the assignment mechanics described in Section 6.4. The customer does not select the amount or the security they receive.

Overview. A First Deposit User may participate upon meeting the following requirements.

Requirements:

Applies to any user who makes their first valid net deposit during the Campaign Period, regardless of whether they registered during or before the Campaign Period.

Promotional benefit. Once the user completes their first net deposit ≥ USD $100, Hapi Securities LLC may credit a randomly determined promotional amount between USD $5 and USD $10 (six possible outcomes, with the following fixed probabilities: USD $5 with a probability of 75%; USD $6 with a probability of 10%; USD $7 with a probability of 7%; USD $8 with a probability of 4%; USD $9 with a probability of 2%; and USD $10 with a probability of 2%) to the user's brokerage account, during the established benefit crediting times. This amount will be used to acquire a fractional share of one of the six (6) eligible securities defined in Section 9, randomly assigned by Hapi (each security with a probability of 1/6, approximately 16.67%). The customer does not select the amount or the security.

Limitations:

Requirements. Existing Hapi users may participate as Referrers — meaning they have completed their KYC and have executed at least one (1) investment order on the platform prior to their participation — and who activate at least one valid referral.

A valid referral is one where the invited person:

Promotional benefit. Once a valid referral completes their first net deposit ≥ USD $100, Hapi Securities LLC may credit a randomly determined promotional incentive of USD $5 to the Referrer's account. The incentive will be automatically used to acquire a fractional share of one of the eligible securities defined in Section 9 (each security with a probability of 1/6, approximately 16.67%). The amount and security will be determined randomly pursuant to Section 6.4 and cannot be selected by the user.

Limitations:

Overview. During the Campaign Period, Hapi Securities LLC may activate promotional days called "Hapi Days" on dates selected at its discretion. On those dates, eligible users who meet the established requirements may access an additional promotional benefit, subject to availability and on a first-come, first-served basis.

Flexible provision. Since Hapi Days depend on agreements Hapi maintains with its providers during the Campaign Period, the specific dates, participation conditions, applicable benefit, mechanics, and availability of each Hapi Day will be defined and announced by Hapi through its official channels during the Campaign Period, with at least 24 hours' notice prior to their start, subject to these Terms, the combined limit of Section 10, and first-come, first-served criteria. Hapi may update, modify, or cancel a Hapi Day for regulatory, operational, provider availability, or compliance reasons. The activation of a Hapi Day does not guarantee the activation of subsequent days.

Requirements. Users may participate in Hapi Days if they meet all of the following:

Promotional benefit. On days when this mechanic is activated, and unless Hapi announces specific different conditions for a particular Hapi Day pursuant to the flexible provision above, Hapi Securities LLC may credit a randomly determined promotional amount of USD $5 to the eligible user's brokerage account. This amount will be used to acquire a fractional share of one of the eligible securities defined in Section 9, randomly assigned by Hapi (each security with a probability of 1/6, approximately 16.67%). The customer does not select the amount or the security.

Limitations:

Benefit compatibility. The three mechanics (Sections 6.1, 6.2, and 6.3) are independent of each other. A single user may receive, at most: one (1) benefit under Section 6.1; up to three (3) benefits under Section 6.2 (one per valid referral, maximum three); and the benefits corresponding to Section 6.3 pursuant to its announced conditions. No benefit may be received more than once for the same triggering event.

Once the user meets the eligibility condition for their mechanic, they will receive a randomly determined promotional benefit. The benefit is assigned through two independent random steps:

Step 1 — Amount. Each possible amount has an identical probability; there is no weighting toward any outcome:

*Unless specific conditions are announced by Hapi for a particular Hapi Day.

Step 2 — Delivery. The amount is delivered as a fractional share of a single security randomly selected from the six (6) eligible securities defined by Hapi for this Campaign (NVDA, AAPL, GOOGL, META, AMZN, TSLA), each with a probability of 1/6 (approximately 16.67%). The selection of the security determines which fractional share the user receives; the dollar amount is fixed in Step 1.

Both steps are independent of each other. The customer does not select the amount or the security; both are assigned randomly pursuant to the probabilities described herein.

Only fiat methods enabled in the app are eligible, subject to availability by country, internal validation, and regulatory controls.

Not eligible:

The exclusion of these methods applies only for eligibility purposes in this Campaign. Excluded methods remain available for general account funding.

The deposit must:

Hapi Securities LLC may disqualify deposits that present inconsistencies, indications of fraud, suspicious activity, or non-compliance with these Terms.

Additional methods enabled during the Campaign Period. Hapi may enable additional FIAT methods operated by integrated providers during the Campaign Period. Once enabled in the app, such methods will be eligible for this Campaign from their activation, regardless of the underlying rail used, without the need to modify these Terms, and will be communicated through official channels.

Qualifying timestamp. For purposes of the Campaign Period, the deposit initiation timestamp recorded in Hapi's internal systems will be considered, understanding a deposit as "made" when it has been initiated (deposit request completed in the app) within the Campaign Period and is subsequently confirmed and passes internal validations. A deposit initiated within the Campaign Period that is not confirmed, or that is reversed, cancelled, or subject to chargeback, will not qualify.

Delayed deposits and validation queue. Since some deposits may take time to confirm depending on the provider, all deposits initiated within the Campaign Period will be considered, provided they are subsequently confirmed and pass internal validations. This applies particularly to deposits initiated during the final days of the Campaign Period, which may be confirmed after its close.

Eligibility Cutoff Date. To access a promotional benefit, both the deposit confirmation and the Participant's KYC completion must have occurred no later than July 29, 2026 at 23:59 (UTC-5) (the "Eligibility Cutoff Date"). Benefits corresponding to deposits initiated within the Campaign Period and confirmed, with KYC completed, by said deadline will be credited in the final assignment on Thursday, July 30, 2026.

A deposit initiated within the Campaign Period whose confirmation or KYC is completed after the Eligibility Cutoff Date will not be eligible for any benefit. Once the final assignment of July 30, 2026 is completed, no additional benefits will be granted and no claims will be admitted, without generating any right, claim, or compensation in favor of users.

Promotional incentives will be used to acquire fractional shares of eligible securities within the program. Both the incentive amount and the assigned security are determined randomly pursuant to the mechanics of Section 6.4. The customer does not select the amount or the fraction they receive.

The eligible securities for this Campaign are:

NVDA, AAPL, GOOGL, META, AMZN, TSLA (each with a selection probability of 1/6, approximately 16.67%)

The securities were defined using internal criteria related to market capitalization and market liquidity at the time of the Campaign's design.

The inclusion of any security in this Campaign:

Hapi Securities LLC does not conduct suitability analyses or personalized recommendations in connection with this Campaign.

Nature of the benefit. For the avoidance of doubt:

The Campaign has a limited number of promotional benefits and a maximum promotional budget defined at Hapi Securities LLC's discretion.

Promotion limits. This promotion is limited to the first 3,200 eligible benefit assignments for First Deposit Users (Section 6.1) and the first 2,100 assignments combined for Referrers (Section 6.2) and Hapi Days (Section 6.3). Once the applicable limit is reached, the promotion will end automatically for that benefit and no additional benefits will be assigned under the same, even if the promotional period has not yet concluded.

Hapi Securities LLC will communicate through its official channels when the limits established in this Section have been reached.

Benefits will be granted exclusively to Participants who correctly fulfill the conditions described and while stock and budget remain available. Priority order and determination of limit fulfillment will be based on Hapi Securities LLC's internal records, which will be conclusive and binding to the extent permitted by applicable law.

Once the available stock is exhausted or the maximum promotional budget is reached — whichever occurs first — the Campaign may remain active without granting additional benefits, without generating any right, claim, or compensation in favor of users.

Investments in securities involve risks, including the possible total or partial loss of invested capital. Eligible securities may experience significant volatility and price fluctuations. Past performance does not guarantee future results.

Fractional shares:

Nothing in this Campaign constitutes financial, legal, tax, or investment advice.

Promotional benefits will be assigned when the Participant fulfills all conditions corresponding to each Campaign phase. Both the amount and the security of the benefit are determined randomly pursuant to the two-step mechanics described in Section 6.4.

The crediting of the promotional benefit:

Assets acquired through the promotional benefit may not be sold or liquidated for a minimum period of one (1) business day from their effective assignment.

Hapi Securities LLC reserves the right to cancel, limit, reverse, or withdraw promotional benefits in cases of:

Only deposits with a net amount equal to or greater than USD $100 qualify. Cancelled, reversed, or chargebacked deposits do not qualify. Fraudulent or automated accounts will be disqualified.

The following may not participate:

The Campaign may be limited, suspended, or modified pursuant to Section 18 for regulatory, operational, or compliance reasons.

Hapi Securities LLC reserves the right to review, validate, reject, revoke, or cancel participation or rewards if it detects, at its sole reasonable discretion and to the extent permitted by applicable law:

If one or more referrals initially considered valid cease to meet the requirements due to a subsequent reversal, chargeback, or fraud finding, Hapi Securities LLC may recalculate the Participant's eligibility and revoke the reward if applicable.

By participating in the Campaign, the Participant authorizes Hapi Securities LLC to use their username and participation status exclusively for promotional or informational purposes related to the Campaign.

No financial information or sensitive data will be disclosed. The authorization may be revoked pursuant to applicable law.

This Campaign:

Promotional benefits may have tax consequences depending on the user's jurisdiction. Tax obligations will be the exclusive responsibility of the user. Hapi Securities LLC does not provide tax advice.

Participation is subject to KYC, AML, and anti-fraud control processes.

Hapi Securities LLC may, at its sole discretion, modify, suspend, cancel, or terminate this Campaign — in whole or in part — as well as modify these Terms and Conditions, at any time during the Campaign Period, for operational, regulatory, legal, technical, commercial, security, provider availability, or force majeure reasons.

Any modification will be communicated through Hapi's official channels and will apply prospectively, without affecting promotional benefits already validly accrued and confirmed prior to the modification. Continued participation after publication of changes constitutes acceptance thereof.

The foregoing is without prejudice to the automatic termination of the promotion upon reaching the limits established in Section 10.

Hapi Securities LLC will not be liable for:

Brokerage accounts are custodied by Apex Clearing Corporation.

Hapi Securities LLC is a member of SIPC. SIPC protects customers up to USD $500,000 (including USD $250,000 for cash) against broker-dealer insolvency. SIPC does not protect against market losses. More information at www.sipc.org.

These Terms shall be governed by the laws applicable in the jurisdictions where Hapi Securities LLC legally operates. For any dispute, the user agrees to submit to the competent courts in the corresponding jurisdiction.

Participation implies full and unconditional acceptance of these Terms and Conditions and Hapi Securities LLC's general policies.

Hapi Securities LLC — Member of FINRA and SIPC