Article 1 (Purpose)

This Terms of Service is intended to clearly define the rights, obligations, responsibilities, conditions of use, and other necessary matters between Bluegem Co., Ltd. (hereinafter referred to as the “Company”) and the users in relation to the use of the “CoinPickle” website and app-based services (hereinafter referred to as the “Service”) provided by the Company.

Article 2 (Effectiveness and Amendment of the Terms)

1. These Terms shall be notified to users by being posted on the Company’s website, mobile application, or through other designated methods (e.g., announcements, email, notifications, etc.), and shall take effect when the user agrees to the Terms during registration or uses the Service. 2. The Company may amend these Terms to the extent that such amendments do not violate applicable laws (including the Act on Promotion of Information and Communications Network Utilization and Information Protection, the Act on Consumer Protection in Electronic Commerce, etc.). In the event of such an amendment, the Company shall notify users of the details, reasons, and effective date of the amendment at least 7 days prior to the effective date via the Service’s announcements or other appropriate means. 3. However, if the amendment is unfavorable to users or involves significant changes to their rights and obligations, the Company shall provide notice at least 30 days in advance. The Company shall present a comparison of the previous and amended Terms to make the changes easier for users to understand. 4. When notifying users of the amended Terms pursuant to Paragraphs 2 and 3, the Company shall also inform users that failure to explicitly express objection by the effective date will be deemed as acceptance of the amended Terms. If the user continues to use the Service without expressing any objection, the user shall be considered to have agreed to the amended Terms. 5. If a user does not agree to the amended Terms, and there are special circumstances where the existing Terms cannot be applied or continued service provision is significantly hindered, the Company may terminate the service agreement with that user. 6. The procedures and methods of notification under this Article may vary depending on the type and environment of the Service (web/app), and the Company may improve the methods and content of the notice to enhance user understanding.

Article 3 (Governing Rules Outside the Terms)

Matters not stipulated in these Terms shall be governed by applicable laws, individual service notices, and general commercial practices.

Article 4 (Definitions of Terms)

The definitions of the terms used in these Terms are as follows: 1. “Company” refers to Bluegem Co., Ltd., which operates the Service. 2. “Service” refers to all functions and content provided to Members through the “CoinPickle” website and mobile application operated by the Company. 3. “Member” refers to an individual who has registered for the Service, agreed to these Terms, and is authorized to use the services provided by the Company. 4. “Non-member” refers to an individual who has not completed the membership registration process but uses a limited portion of the services provided by the Company. 5. “GEM” refers to a service-specific digital point granted free of charge by the Company through user activities, participation in events, or rewards. It cannot be exchanged for cash or physical goods and is not available for paid purchase. 6. “USDT” refers to a virtual currency issued by the Company for simulated trading purposes. It allows Members to experience trading functions but holds no actual value in fiat currency, cryptocurrency, or assets. It can only be converted one-way from GEM and is not refundable, exchangeable, or withdrawable. 7. “Virtual Trading” refers to a simulation-based feature that enables Members to experience an environment similar to real trading using USDT. It does not result in any actual financial gain or loss, nor does it create any legal rights or obligations. 8. “Account” refers to a unique identifier created by the Member to use the Service, which is linked to login credentials such as an email address and password. 9. “Content” refers to all digital assets, including text, images, videos, and data, created or provided within the Service by either the Company or the Members. 10. “Experience Points” refers to the numerical values granted or deducted based on the Company’s prescribed methods and standards according to the member’s service usage, activities, event participation, and other factors. These points serve as the basis for determining membership tiers and providing benefits. 11. “Membership Tier” refers to the step-based classification assigned by the Company through a comprehensive evaluation of experience points, activity history, service usage records, and other factors. The range of service benefits and the scope of GEM point usage may vary depending on the tier.

Article 5 (Membership Registration)

1. Individuals who wish to use the Service may apply for membership by entering their personal information in the registration form provided by the Company and agreeing to these Terms. 2. The Company may restrict membership registration or revoke membership after registration if any of the following applies: • If the applicant uses another person’s information or provides false information • If the applicant has a history of violating these Terms or applicable laws • If a child under the age of 14 registers without the consent of a legal guardian 3. The Company verifies whether a user is at least 14 years old based on the date of birth entered by the user during registration and does not conduct separate identity verification. If it is found that a user under the age of 14 has registered using false information, the Company may immediately delete the account upon becoming aware of such fact. The Company shall not be held legally liable for any issues arising from its inability to detect such false information in advance.

Article 6 (Membership Termination and Disqualification)

1. The Company may, without prior notice, restrict a user’s access to part or all of the Service or suspend or terminate their account if the user commits any of the following acts: ① Using another person’s personal information or registering with false information ② Abnormally using the Service via automated means (such as macros or bots) ③ Infringing on the intellectual property rights, portrait rights, honor, or privacy of the Company or a third party ④ Uploading offensive or illegal content such as pornography, hate speech, discrimination, defamation, or false information ⑤ Fraudulently acquiring or using GEM points or USDT virtual assets provided by the Company ⑥ Attempting to hack, reverse-engineer, or cause excessive load on the Company’s services or servers ⑦ Intentionally interfering with the operation of the Service or repeatedly violating the Company’s policies, guidelines, or announcements ⑧ Committing other acts that clearly violate applicable laws or public order and morals 2. In cases where an account is restricted or suspended due to the reasons listed in Paragraph 1, the Company will notify the user of such action, and the user may provide an explanation through designated procedures. However, in cases of clear illegal acts or when urgent measures are required, notification may be given afterward. 3. If a user repeats the same violation or commits a serious violation, the Company may permanently suspend the account or restrict future use of the Service. 4. Points (GEM), USDT, and activity history associated with restricted or suspended accounts will not be restored, and the Company shall bear no responsibility for such loss.

Article 7 (Provision and Suspension of Service)

1.The Company aims to provide the Service 24/7 throughout the year but may temporarily suspend part or all of the Service in the following cases: ① Inspection, maintenance, replacement, or malfunction of service-related facilities ② Technical failures such as system errors, hacking, data loss, or traffic spikes ③ Suspension of services by telecommunications providers under relevant laws ④ Orders or directives from government or administrative agencies ⑤ Other unavoidable or urgent operational circumstances of the Company 2. In the event of service suspension under Paragraph 1, the Company will provide prior notice in principle. However, in urgent or unforeseeable circumstances, notice may be given afterward without delay. 3. The Company shall not be held liable for any damages caused by the inability or delay in providing the Service due to force majeure events such as natural disasters, power outages, war, legislative changes, government actions, large-scale DDoS attacks, or the intentional or grossly negligent acts of third parties, unless caused by the Company’s willful misconduct or gross negligence. 4. The Company shall not be liable for any direct or indirect damages, including lost profits, suffered by Members or third parties due to service interruptions, delays, errors, or data loss, unless such damages result from the Company’s willful misconduct or gross negligence.

Article 8 (Modification and Termination of the Service)

1. The Company may modify, change, suspend, or terminate all or part of the Service to ensure smooth operations. In such cases, the Company will notify users of the change and its effective date in advance. However, in the following cases, changes or termination may occur immediately without prior notice: ① Technical reasons beyond the Company’s control such as server failures, hacking, system maintenance, or emergency security updates ② Force majeure events such as natural disasters, power outages, theft, strikes, or national emergencies ③ Unavoidable circumstances arising from applicable laws or orders/directives from government or administrative bodies 2. The Company shall not be liable for any damages caused to Members due to changes, suspension, or termination of the Service, unless such damages result from the Company’s willful misconduct or gross negligence. Furthermore, the Company shall not be liable in the following cases: ① Damages caused by a Member’s failure to review the announced changes or termination ② Expiration or loss of points, benefits, or data in accordance with previously announced terms or conditions ③ Inability to use content or assets acquired by non-members or fraudulent users before the Service termination ④ Damages caused by a Member’s failure to take necessary action despite proper notice from the Company 3. In the event that the Service is terminated or certain features are reduced or modified under this Article, the Company shall not be obligated to provide separate compensation, and Members shall have no rights other than to terminate their service agreement.

Article 9 (GEM Points)

1. GEM is a digital point granted free of charge within the platform operated by the Company, based on the Member’s use of the Service, participation in events, or other activities. GEM cannot be refunded or redeemed for cash, cryptocurrency, or any real-world currency. 2. Members may use GEM in the following ways. However, the Company may add, change, or restrict the scope of usage for operational reasons and will notify users in advance: ① Exchange for gift certificates from designated partners ② One-way conversion into USDT (virtual assets) for use within the Company’s virtual trading services 3. GEM is converted into USDT based on the exchange rate specified by the Company, and conversion from USDT back to GEM is not allowed. The exchange rate may be adjusted according to Company policy, and any changes will be announced at least 7 days in advance through the Service’s notice board. 4. GEM may not be transferred, sold, or pledged in any form without the Company’s explicit approval. Any GEM obtained through illegal means (e.g., using bots, account theft, hacking) may be forfeited without prior notice, and the associated account may be suspended or terminated. 5.The validity period of GEM is one year from the date of the last login. If there is no login activity during this period, the GEM will automatically expire without prior notice. Expired GEMs cannot be recovered under any circumstances, and the company bears no responsibility for such expiration. 6. If a Member voluntarily withdraws or is forcibly removed from the Service by the Company, all remaining GEM will be immediately forfeited and cannot be recovered or claimed for monetary compensation.

Article 9-2 (Membership Tier and Experience Point System)

1. Definition of Membership Tiers ① The Company may assign membership tiers to members based on the extent of their service usage, activity history, and accumulated experience points. ② Membership tiers are determined in accordance with the standards notified by the Company in advance, and such standards and benefits will be announced through a separate information page or notice within the service. 2. Experience Point Calculation Method ① Experience points are granted to members in accordance with the methods and ratios set by the Company, based on their activities (e.g., login, content creation, event participation). ② The criteria for granting and deducting experience points may be changed according to the Company’s operational policies, and any changes will be announced at least seven (7) days in advance. 3. Tier-based Benefits and GEM Usage Restrictions ① Depending on the membership tier, the Company may apply different limitations on the scope of GEM point usage, per-transaction, daily, or monthly usage limits, and the eligibility to exchange for certain services or gift certificates. ② The conditions for tier-based benefits and GEM usage restrictions will be specified on an information page or in a notice within the service, and any changes will be announced at least seven (7) days in advance. ③ Restrictions on GEM usage due to insufficient membership tier or experience points will be deemed reasonable in accordance with the service operation policy, and members may not raise objections thereto. 4. Tier Changes ① Membership tiers may be re-evaluated periodically (monthly, quarterly, or annually) or on a promotional basis, and the Company will notify members of the reason and result of any tier change within the service. ② If a member is inactive for a prolonged period or if there are grounds for deduction of experience points (e.g., violation of rules, point recovery), the membership tier may be downgraded. 5. Policy Changes ① The membership tier system, criteria for granting experience points, tier-based benefits, and GEM usage restriction policies may be changed as necessary for operational reasons, and any such changes will be announced at least seven (7) days in advance within the service. ② However, in the case of significant changes that are disadvantageous to members, the Company will provide notice at least thirty (30) days in advance and obtain the member’s consent.

Article 10 (Virtual Trading Service)

1. The Company provides a simulation-based virtual trading service for educational and experiential purposes only. This service does not involve actual asset transactions and has no relation to real-world financial investment. 2. USDT used in virtual trading is a virtual trading asset that is one-way converted from GEM points. USDT cannot be exchanged for legal currency, cryptocurrency, or any other monetary equivalent. Members shall not assert any property rights, monetary claims, or refund requests regarding USDT. 3. The Company may modify or terminate aspects of the virtual trading service such as features, scope, system specifications, and ranking mechanisms for operational purposes. The Company shall not be held liable for any resulting losses (e.g., expected gains, ranking positions) unless caused by willful misconduct or gross negligence. 4. If a Member abuses the virtual trading feature or exploits the system in any of the following ways, the Company may, without prior notice, take actions including account restriction, data reset, or GEM forfeiture: ① Engaging in abnormal activities using automated tools (macros, bots, etc.) ② Exploiting system vulnerabilities for personal gain ③ Disrupting Company policy with false or misleading information ④ Any other activities deemed as misuse by the Company’s reasonable judgment 5. The results of virtual trading (e.g., profit rates, rankings, transaction records) are for simulation purposes only and do not guarantee actual investment outcomes. They hold no legal effect and must not be interpreted as investment advice or solicitation. 6. Members shall not claim ownership, credit, compensation rights, or any other entitlements over USDT or virtual trading results. The Company assumes no responsibility for recovery, refund, or damages related thereto.

Article 11 (Member Obligations)

Members shall not engage in any of the following activities. Violation may result in usage restrictions, account suspension, or legal action by the Company: 1. Using another person’s personal information or registering with false information 2. Accessing the Service or collecting data using automated tools (e.g., macros, bots, crawlers) 3. Infringing upon the intellectual property rights of the Company or third parties 4. Using offensive expressions via posts, chats, or activity logs, including profanity, sexual harassment, hate speech, discrimination, defamation, or spreading false information 5. Causing harm to other Members through spam, advertisements, monetary requests, fraud, threats, etc. 6. Exploiting structural vulnerabilities in the system or intentionally abusing bugs and errors 7. Intentionally disrupting the Service flow, submitting repeated false reports, impersonating staff, etc. 8. Violating or attempting to violate applicable laws 9. Engaging in other socially inappropriate conduct or behavior inconsistent with the purpose of the Service

Article 12 (Consent to and Withdrawal from Marketing Communications)

1. The Company may send marketing communications via email, SMS, or app push notifications only if the Member has given prior consent. 2. Members may opt out of marketing communications at any time. However, essential notifications related to the service agreement may still be sent even after opting out. 3. Consent to receive marketing communications is separate from participation in events such as GEM point rewards.

Article 13 (Intellectual Property Rights)

1. All content provided within the Service (including but not limited to text, images, audio, video, UI, icons, logos, programs, code, databases, and other elements) belongs to the Company or third parties holding legitimate rights. 2. Members shall not, without the prior written consent of the Company, reproduce, store, transmit, distribute, display, post, modify, create derivative works, publish, commercially use, or engage in any similar activity involving all or part of the Service in any form. 3. If a Member infringes on the rights of third parties or causes damage to the Company by violating this clause, the Company may pursue both civil and criminal liability, and the Member shall bear full legal responsibility. 4. Intellectual property rights for content uploaded or registered by the Member remain with the Member; however, the Member grants the Company a worldwide, non-exclusive, royalty-free license to use, transmit, store, display, process, and edit such content within the scope necessary for operating, promoting, and improving the Service. This license is non-revocable, and Members cannot claim compensation for such use.

Article 14 (Disclaimer)

1. The Company shall not be held legally liable for damages caused by the following events, unless such damages result from willful misconduct or gross negligence by the Company: ① Force majeure events such as natural disasters, war, riots, fire, power outages, network failures, hacking, or security threats ② Service restrictions or terminations due to government regulations, legal amendments, or policy changes ③ Scheduled or unscheduled system maintenance, security updates, or server failures ④ Service disruptions, account loss, data loss, or personal data exposure caused by the Member ⑤ The reliability or accuracy of information, materials, or content posted or transmitted by Members through the Service 2. The Company does not guarantee the accuracy, reliability, or completeness of the following types of information or services and shall not be liable for any damage arising from reliance on or use of such: ① Virtual trading results, rankings, profit rates, or simulation-related data ② Transactions, messages, comments, and other community activities among Members ③ Third-party information such as external links, advertisements, or affiliate content 3. If a Member violates these Terms or applicable laws, or causes damage to the Company through misconduct, the Member shall compensate the Company in full and may face both civil and criminal legal actions.

Article 15 (Dispute Resolution and Jurisdiction)

1. The Company and the Member shall make sincere efforts to resolve any disputes arising in connection with the use of the Service through mutual consultation. If such efforts fail, the Member may apply for mediation through public agencies such as the Personal Information Dispute Mediation Committee or the Content Dispute Mediation Committee pursuant to Article 33 of the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc. 2. If the dispute cannot be resolved through the procedure in Paragraph 1, either party may file a lawsuit with a competent court under the Civil Procedure Act and other relevant laws. The exclusive jurisdiction for the first instance shall lie with the district court having jurisdiction over the Company’s principal place of business. 3. Members must interpret these Terms in good faith based on the Company’s notices, operating policies, interpretation guidelines, and related documents. Members shall not arbitrarily expand their interpretation of ambiguous clauses or engage in actions that provoke legal disputes. 4. Members agree not to initiate class actions, collective claims for damages, or other group litigation based on individual complaints or grievances arising during use of the Service. If such actions result in damage to the Company, the Member shall be held civilly and criminally liable. 5. Even if a Member raises objections, requests for mediation, or other dispute-related actions, the Company shall not be liable for any damages if the cause is clearly attributable to the Member or involves misconduct.

Article 16 (No Provision of Virtual Asset Transactions or Wallet Services)

1. The Company does not offer, through the Service, any form of real-world virtual asset (including cryptocurrency) transactions, brokerage, investment advice, purchase/sale, exchange, remittance, custody, or wallet services. 2. Services such as “Virtual Trading,” “USDT,” and “GEM Points” are simulation-based features or reward-based points with no real monetary value. They cannot be exchanged for real-world currency, virtual assets, or fiat money. 3. Members shall not interpret the Service as involving real asset trading, expect profit from its use, or link it to external transactions. The Company shall bear no responsibility for any damages resulting from such misinterpretations. 4. The Company does not provide services related to financial product transactions, brokerage, payment processing, or custody within the Service, nor does it currently hold any related licenses.