LINKING TERMS AND CONDITIONS V8

LINKING TERMS AND CONDITIONS

VERSION 8.0 | MARCH 2026

GROOVY COMPANY, INC. DBA OTCM PROTOCOL

Wyoming Corporation | CIK: 1499275 | OTC: GROO

12 Daniel Rd East, Fairfield, NJ 07004

SEC Category 1 Model B | Release No. 33-11412 (March 17, 2026)

PLEASE READ THESE LINKING TERMS AND CONDITIONS BEFORE LINKING TO ANY OTCM PROTOCOL WEBSITE.

Issuer-Sponsored Tokenized Securities pursuant to SEC–CFTC Joint Interpretive Release No. 33-11412 (March 17, 2026) and SEC Joint Staff Statement on Tokenized Securities dated January 28, 2026.

Modification Policy

From time to time, Groovy Company, Inc. dba OTCM Protocol (“OTCM Protocol” or “OTCM”) may modify these Linking Terms and Conditions (“Linking Terms”). Please review the Linking Terms periodically. Your continued establishment of a link after modifications constitutes your acceptance of the Linking Terms as modified. If you do not accept the Linking Terms, you must discontinue linking to all OTCM Protocol websites. Any additional or conflicting terms you propose are expressly rejected.

1. User Assent to Terms and Conditions

By linking to any OTCM Protocol website, you represent that you have read and agree to be bound by these Linking Terms for the following websites:

Website	URL
Primary Platform	https://otcm.io
CEDEX Trading Platform	https://cedex.otcm.io
Issuers Gateway	https://otcm.network
Documentation / Education	https://otcm.info
All Subdomains	.otcm.io, .otcm.network, *.otcm.info

You also represent that you have read and agree to be bound by our Terms and Conditions, Privacy Policy, Risk Disclosure, and all other terms and conditions of service published on our websites.

2. Intellectual Property

2.1 Protected Content

You acknowledge that the website content has been specially designed by Groovy Company, Inc. dba OTCM Protocol, including visual design, user interface, content, branding, logos, trademarks, and functionality (collectively, the “Look and Feel”).

2.2 Legal Protection

The Look and Feel is protected by United States and international copyright laws, registered and common law trademarks, service marks, international intellectual property treaties, and proprietary rights laws of the United States and other countries.

2.3 License Grant

Upon linking pursuant to these Linking Terms, you receive a limited, non-exclusive, revocable license to link to OTCM Protocol websites. No ownership or proprietary rights are transferred. This license may be revoked at any time at OTCM Protocol’s sole discretion and is contingent upon compliance with these Linking Terms.

3. Restrictions on Linking to Home Pages

3.1 Permitted Links

Without limiting the Terms of Service, you may include links to:

Permitted Target	URLs
Home Pages	https://otcm.io, https://cedex.otcm.io, https://otcm.network, https://otcm.info
Related Subdomains	Subdomains of permitted domains
Trading Pages	Pages providing ST22 Digital Securities trading functionality on CEDEX
Market Data	Market data and price information pages
Company Information	Company and issuer information pages
Public Documentation	Public documentation and educational materials

3.2 Prohibited Source Sites

You may NOT link to any OTCM Protocol website from any site containing:

• Inappropriate, profane, defamatory, infringing, obscene, indecent, or unlawful content

• Material violating intellectual property, proprietary, privacy, or publicity rights of any party

• Content promoting illegal activities or securities fraud

• Misleading information about ST22 Digital Securities or the OTCM Utility Token

• Competing blockchain or tokenization platforms without clear disclosure

• Content that violates federal or state securities laws

• Content promising investment returns or guaranteed profits

• Content encouraging non-accredited investors to purchase ST22 Digital Securities

3.3 Category 1 Compliance Requirements for Linking

When linking to OTCM Protocol pages involving ST22 Digital Securities, you must:

• Acknowledge that ST22 Digital Securities are securities under federal securities laws and Release No. 33-11412

• Include notice that ST22 Digital Securities are available only to accredited investors (Reg D, U.S.) or non-U.S. persons (Reg S)

• Not make claims inconsistent with the OTCM Protocol Risk Disclosure or Investment Risk Disclosure

• Not make guarantees about investment performance

• Comply with all applicable securities law communication requirements

4. Restrictions on Other Linking Activities

Groovy Company, Inc. dba OTCM Protocol is concerned about website integrity when accessed or viewed in settings solely determined by third parties. The following activities are restricted:

Restricted Activity	Description
Framing	Displaying OTCM Protocol content within frames on third-party sites. Framing is NOT permitted under any circumstances.
Deep Linking	Linking directly to interior pages without prior written permission from OTCM Protocol.
Content Modification	Altering the appearance or functionality of linked content in any way.
Redirection	Redirecting users through intermediate pages before reaching OTCM Protocol content.
Data Scraping	Automated extraction of content, data, pricing, or trading information from any OTCM Protocol website.
False Attribution	Implying endorsement, partnership, or affiliation with OTCM Protocol without written authorization.

You must make a specific written request and secure written permission from OTCM Protocol prior to engaging in deep linking or similar activities. Maintain records of all permissions granted.

5. Deep Linking Requests

5.1 Application Process

To request deep linking permission, email frank@otcm.io with the following:

• Full URL of your website

• Name and description of your organization

• Purpose and context of the proposed link

• Specific OTCM Protocol pages you wish to link to

• Description of how the link will be used and presented

• Statement of compliance with securities laws (if linking to ST22 Digital Securities content)

5.2 Review Process

Step	Timeline
Submission	Submit complete request to frank@otcm.io
Review	OTCM Protocol will review within 10 business days
Approval or Denial	Written response provided
Conditions	Any approved links subject to specified conditions

6. Special Provisions for Tokenized Companies (Issuers)

Companies whose equity has been tokenized as ST22 Digital Securities on the OTCM Protocol platform may link to their specific token pages subject to the following conditions:

6.1 Issuer Linking Conditions

• Links must be clearly labeled as leading to the OTCM Protocol platform or CEDEX

• No implication that OTCM Protocol endorses or recommends investment in the issuer’s securities

• Compliance with all securities law requirements regarding communications

• No modification or framing of OTCM Protocol content

• Compliance with SEC Category 1 Model B communication requirements under Release No. 33-11412

6.2 Securities Law Communication Requirements

Issuers linking to their ST22 Digital Securities pages must comply with:

Requirement	Description
Reg D Compliance	Reg D general solicitation requirements for U.S. accredited investors
Reg S Compliance	Reg S offshore transaction requirements for non-U.S. investors
Accredited Investor Notice	Clear indication that offerings are limited to accredited investors (U.S.) or non-U.S. persons
Risk Disclosure	Appropriate risk disclosures accompanying any investment-related content
No Guarantees	Prohibition on guarantees of investment performance
Form D Compliance	Compliance with Form D filing requirements

6.3 Prohibited Issuer Activities

• Promising or implying guaranteed returns on ST22 Digital Securities

• Making specific price predictions for any ST22 token

• Making false or misleading statements about the token or the underlying company

• Encouraging non-accredited U.S. investors to purchase ST22 Digital Securities

• Misrepresenting regulatory status, SEC approval, or Category 1 compliance

7. Compliance with Laws

All linking activities must comply with:

• Federal securities laws (Securities Act of 1933, Securities Exchange Act of 1934, SEC regulations)

• SEC–CFTC Release No. 33-11412 (March 17, 2026) — the binding Digital Securities taxonomy

• State securities laws (Blue Sky laws and state-specific requirements)

• Market manipulation prohibitions

• Prohibitions on false or misleading statements

• SEC rules regarding general solicitation under Reg D

• SEC Category 1 Model B (Issuer-Sponsored Tokenized Securities) requirements

Category 1 Specific Compliance

When linking to content involving ST22 Digital Securities, you must acknowledge that ST22 tokens are securities, note accredited investor requirements, include appropriate risk language, not misrepresent custody arrangements with Empire Stock Transfer, and not overstate Category 1 protections.

8. Termination

8.1 Revocation Rights

Groovy Company, Inc. dba OTCM Protocol reserves the right to revoke linking permissions at any time for:

• Violation of these Linking Terms

• Violation of applicable laws, including federal and state securities laws

• Activity that damages OTCM Protocol’s reputation or brand

• Misrepresentation of relationship with OTCM Protocol

• Association with inappropriate or prohibited content

• Any other reason at OTCM Protocol’s sole discretion

8.2 Effect of Termination

Upon termination of linking permission, you must immediately remove all links to OTCM Protocol websites. You may not establish new links without obtaining new written permission. Indemnification and liability provisions survive termination.

9. Disclaimer and Limitation of Liability

OTCM PROTOCOL WEBSITES AND ALL CONTENT ARE PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. GROOVY COMPANY, INC. DBA OTCM PROTOCOL DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. OTCM PROTOCOL SHALL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING FROM OR RELATED TO YOUR LINKING ACTIVITIES OR ANY THIRD PARTY’S ACCESS TO OTCM PROTOCOL THROUGH YOUR LINKS.

10. Modifications

Groovy Company, Inc. dba OTCM Protocol reserves the right to modify these Linking Terms at any time by posting modifications on the website. Continued linking after posting constitutes acceptance of modified terms. OTCM Protocol may, but is not required to, notify linking parties of changes.

11. Contact Information

Contact Type	Information
General / Linking Inquiries	frank@otcm.io
Deep Linking Requests	frank@otcm.io
Issuer Linking	frank@otcm.io
Compliance Questions	compliance@otcm.io
Mailing Address	12 Daniel Rd East, Fairfield, NJ 07004
Phone	1-404-734-3277

Document Information

Field	Value
Document Title	Linking Terms and Conditions
Version	8.0
Effective Date	March 2026
Legal Entity	Groovy Company, Inc. dba OTCM Protocol
Entity Jurisdiction	Wyoming Corporation
Governing Law	New Jersey State Law and Federal Securities Law
Regulatory Framework	SEC Category 1 Model B — Release No. 33-11412 (March 17, 2026)

By establishing a link to any OTCM Protocol website, you confirm you have read, understood, and agree to be bound by these Linking Terms and Conditions and all related terms referenced herein.

Ensure your website content complies with these Linking Terms and applicable securities laws to maintain your linking privileges.

ST22 Digital Securities are Category 5 Digital Securities under SEC–CFTC Release No. 33-11412 (March 17, 2026). Links to ST22-related content must comply with Reg D, Reg S, and SEC Category 1 Model B requirements. Groovy Company, Inc. dba OTCM Protocol is a Wyoming Corporation (CIK: 1499275).