# Consent Agreement for Service Transfer and Change of Operator

## Consent Agreement for Service Transfer and Change of Operator

Effective Date: August 31, 2025

#### 1. Purpose

This Agreement is intended to inform existing users of the Neopin service about the changes to the service name and operating entity, and to obtain their consent to continue using the updated service under its new name, Stablez, operated by H Lab Limited.

**2. Changes to the Service**

1. Service Name
   * Previous: Neopin
   * New: Stablez
2. Service Operator:
   * Previous: Neopin Co., Ltd. (Republic of Korea)
   * New: H Lab Limited (United Arab Emirates, Abu Dhabi Global Market)
3. After this transfer, the service will be fully operated and provided by H Lab Limited, and all legal rights and obligations related to the use of the service will be established between H Lab Limited and the user.

**3. Processing of Personal Data**

1. Personal data previously collected and stored by Neopin (particularly for KYC/AML identity verification purposes) will be permanently deleted as part of this transfer process.
2. The Stablez service will not require KYC/AML screening for continued use of the application, and therefore, no identity verification data will be newly collected.
3. Data subject to deletion includes, but is not limited to:
   * Copies of identification documents (ID card, passport, etc.)
   * Proof of address and residential information
   * Customer due diligence (CDD) and enhanced monitoring records
   * Any other information collected solely for KYC/AML verification
4. Any transaction records required to be retained under applicable laws or regulations may be excluded from deletion.

**4. User Rights and Choices**

1. By providing consent, users may continue using the Stablez service with their existing account and wallet addresses without additional registration or verification.
2. If you do not agree to this transfer, your access to the service may be restricted following the update. In such cases, you may contact our support team to request assistance with transferring or withdrawing your assets.
3. Once the transfer is complete, all previously collected personal data will be deleted, and continued service use will not require re-submission of such information.

**5. Change of Contracting Entity and Governing Law**

Following this transfer, H Lab Limited (UAE, ADGM) becomes the sole contracting party responsible for providing the service and ensuring data protection in compliance with applicable laws.

Disputes arising from the use of the service shall primarily be governed by the laws of the United Arab Emirates (ADGM jurisdiction), unless otherwise required by mandatory consumer protection laws of the user’s country of residence.

**6. Consent Process**

1. Users are encouraged to carefully review this Agreement before making a choice.
2. By ticking the "I Agree" checkbox and clicking the confirmation button, you acknowledge and agree to the service transfer and the terms set forth herein.
3. If you do not agree, your access to the application will be limited, and you may stop using the service and withdraw at any time.

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