Terms of Service

1. About Pamgia and This Website

Pamgia LLC is a limited liability company incorporated in the State of Delaware, United States ("Pamgia", "we", "us", "our"). Pamgia is developing a private credit platform backed by Scotch whisky casks. This website at pamgia.com (the "Website") is our public-facing informational presence.

The Website exists to explain who we are, describe our intended services to prospective borrowers and investors, and allow interested parties to get in touch with us.

Nothing on this Website enables any visitor to buy, invest, subscribe, transact, or enter into any agreement of any kind. All of that happens, when and if it happens, entirely offline through direct conversations with our team.

2. Acceptance of Terms

These Terms of Service ("Terms") form a legally binding agreement between Pamgia LLC and any person who accesses or uses the Website ("you", "your", "User"). By visiting the Website, including simply browsing its pages or submitting an enquiry, you confirm that you have read, understood, and agree to be bound by these Terms.

You represent that you are at least 18 years of age. If you are under 18, you may not use this Website.

By using this Website or submitting an enquiry, you consent to receive communications from us electronically in accordance with the U.S. Electronic Signatures in Global and National Commerce Act (E-SIGN Act), 15 U.S.C. Section 7001 et seq. You agree that all notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. To access and retain electronic communications, you will need a device with an internet connection, a current web browser that supports TLS 1.2 or later, and a valid email address. You may withdraw your consent to receive electronic communications by contacting us at paul@pamgia.com, although withdrawal of consent may limit our ability to communicate with you and, if applicable, your ability to use Pamgia's services.

If you do not agree to these Terms, please stop using the Website immediately.

We may update these Terms from time to time. The current version will always be available on the Website with an updated Effective Date. Your continued use of the Website after any update means you accept the revised Terms.

3. Definitions

"Content" means all text, images, data, graphics, logos, and other material published on the Website.

"Enquiry" means a message or contact form submission sent by a visitor through the Website.

"Intellectual Property" means all patents, trademarks, copyrights, trade secrets, proprietary technology, and know-how owned by or licensed to Pamgia.

"User" means any individual or entity that accesses or browses the Website.

"Website" means the website located at pamgia.com, including all pages, subdomains, and associated content.

4. What This Website Offers

This Website currently allows visitors to do two things:

1. Read information about Pamgia, our business model, and our intended services for borrowers and investors.
2. Submit an enquiry form to express interest and request a conversation with our team.

That is the full extent of what this Website does. Submitting an enquiry creates no legal obligation on either side. It simply opens a conversation. We aim to respond within 48 hours but cannot guarantee a specific response time, and we reserve the right not to respond at our discretion.

5. No Financial Advice, Offer, or Solicitation

Nothing on this Website is, or should be construed as, financial advice, investment advice, tax advice, legal advice, or any offer or solicitation to buy or sell any security, investment product, loan, or financial instrument of any kind.

No Reliance. The Content on this Website is provided for general informational purposes only and does not purport to be comprehensive or to include advice on which reliance should be placed. You should obtain professional or specialist advice before taking, or refraining from, any action on the basis of the Content.

This Website does not present specific investment returns, yield projections, or financial forecasts. Any discussion of Pamgia's business model is for general informational purposes only and does not constitute a projection of future results. Past performance of Scotch whisky as an asset class is not indicative of future results.

You should always seek independent professional advice before making any financial decision. Pamgia is not a licensed financial adviser, broker-dealer, investment manager, or regulated financial institution.

Regulatory Status. No regulatory authority, including the U.S. Securities and Exchange Commission, the UK Financial Conduct Authority, or any state securities regulator, has reviewed, approved, or endorsed Pamgia, its business model, or any content on this Website. Any future securities offerings by Pamgia will be conducted solely under applicable exemptions from registration, including but not limited to Rule 506(c) of Regulation D under the U.S. Securities Act of 1933, as amended, and will be available only to investors who meet applicable eligibility requirements, including verification as accredited investors under Rule 501 of Regulation D.

State securities laws (sometimes called "blue sky laws") may impose additional notice filing requirements in connection with any future offering. Pamgia intends to comply with all applicable state securities requirements.

6. Forward-Looking Statements

This Website may contain forward-looking statements regarding Pamgia's plans, objectives, expectations, and intentions. These statements are based on current expectations and are subject to risks and uncertainties that could cause actual results to differ materially. Forward-looking statements include any statements that are not statements of historical fact, including statements containing the words "expects," "intends," "plans," "believes," "anticipates," "will," "may," or similar expressions. Pamgia undertakes no obligation to update any forward-looking statement. You should not place undue reliance on any forward-looking statement.

7. Digital Asset and Blockchain Risks

Pamgia's intended platform involves the use of blockchain technology and tokenized securities. While no tokens or digital assets are available through this Website, visitors should be aware of the following risks associated with our intended business model:

• Tokens and tokenized securities are not deposits. They are not insured by the Federal Deposit Insurance Corporation (FDIC), the Securities Investor Protection Corporation (SIPC), or any similar government or private insurance scheme.
• Blockchain technology carries inherent risks, including but not limited to smart contract vulnerabilities, network failures, cybersecurity threats, and the potential for loss of digital assets.
• Smart contracts, even when professionally audited, may contain undiscovered bugs or vulnerabilities. No audit can guarantee that a smart contract is entirely free from defects. A smart contract vulnerability could result in loss of funds, disruption of services, or other adverse consequences.
• Blockchain protocols may undergo upgrades, forks, or governance changes that could affect the functionality, value, or availability of tokenized assets. Pamgia does not control the underlying blockchain infrastructure and cannot guarantee its uninterrupted operation.
• Users of blockchain-based platforms are responsible for the security of their own private keys and wallet credentials. Loss of private keys may result in the permanent, irreversible loss of access to digital assets. Pamgia cannot recover lost private keys or reverse blockchain transactions.
• Regulatory frameworks governing blockchain technology, digital assets, and tokenized securities are evolving and remain uncertain in many jurisdictions. Changes in law or regulation may adversely affect the availability, legality, or economic terms of blockchain-based products. There is a risk that certain jurisdictions may classify tokenized securities in ways that restrict their issuance, transfer, or ownership.
• The value of Scotch whisky casks used as collateral may fluctuate due to market conditions, supply and demand dynamics, maturation timelines, and other factors. Past appreciation in whisky values is not indicative of future performance.

8. Intended Audience and Jurisdiction

The information on this Website relating to investment opportunities, lending structures, and potential returns is intended for sophisticated and institutional readers, specifically persons who would qualify as accredited investors, high-net-worth individuals, or institutional counterparties under applicable law in their jurisdiction. This Website is not directed at retail investors or the general public in any jurisdiction where its content would constitute a regulated financial promotion or require prior regulatory approval.

This Website is not directed at investors in the United Kingdom. Nothing on this Website constitutes a financial promotion approved for the purposes of Section 21 of the UK Financial Services and Markets Act 2000. Pamgia is not authorised or regulated by the UK Financial Conduct Authority.

Pamgia's lending services are directed exclusively at businesses (such as independent bottlers and craft distillers) acting in a commercial capacity. Pamgia does not offer consumer credit and is not required to hold an FCA consumer credit licence.

If you are a retail investor, or if you are unsure whether the information here is appropriate for you, please do not rely on it and seek independent advice.

9. Jurisdiction Restrictions and Sanctions Compliance

This Website is not directed at, and the information herein is not intended for distribution to or use by, any person or entity in any jurisdiction where such distribution or use would be contrary to law or regulation, or that would subject Pamgia to any registration or licensing requirement within such jurisdiction.

Without limitation, this Website is not directed at persons located in jurisdictions subject to comprehensive economic sanctions imposed by the United States, the United Kingdom, or the European Union, including but not limited to Cuba, Iran, North Korea, Syria, Russia, Belarus, and the Crimea, Donetsk, and Luhansk regions of Ukraine.

This Website is also not directed at, and Pamgia's services are not available to, any person or entity that is: (a) named on the Specially Designated Nationals and Blocked Persons List (SDN List) maintained by OFAC, the UK Sanctions List maintained by OFSI, or the EU Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions; (b) owned or controlled by, or acting on behalf of, any such listed person or entity; (c) located in, incorporated in, or organised under the laws of any sanctioned jurisdiction listed above; or (d) otherwise prohibited from accessing the Website or Pamgia's services under applicable sanctions, export control, or anti-terrorism laws (collectively, "Restricted Persons"). If you are a Restricted Person, you must not access or use this Website.

Pamgia complies with all applicable anti-money laundering (AML) laws, sanctions regulations, and counter-terrorism financing (CTF) requirements, including those administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the UK's Office of Financial Sanctions Implementation (OFSI), and equivalent authorities.

When Pamgia's platform becomes operational, all users seeking to participate as borrowers or investors will be required to complete identity verification (Know Your Customer, or KYC) and screening procedures before accessing any services. Pamgia reserves the right to refuse, suspend, or terminate access to any person who fails to provide satisfactory identification, who is identified on any sanctions list, or who Pamgia reasonably suspects of engaging in money laundering, terrorism financing, fraud, or other unlawful activity. These requirements apply regardless of the user's jurisdiction.

10. Intellectual Property

All Content on this Website, including text, graphics, the Pamgia name, logo, brand, and all descriptions of our proprietary technology, is owned by or licensed to Pamgia LLC and is protected by applicable intellectual property and copyright law.

You may browse and print Content for your own personal, non-commercial reference. You may not:

• Copy, reproduce, republish, or distribute any Content for any commercial purpose;
• Use our name, logo, or brand in any way without our prior written permission;
• Use automated tools to scrape, crawl, or extract data from the Website;
• Represent our Content as your own or as endorsed by Pamgia without authorisation.

All rights not expressly stated here are reserved by Pamgia LLC.

11. Acceptable Use

By using this Website, you agree not to:

• Use it for any unlawful, fraudulent, or harmful purpose;
• Submit false or misleading information through the enquiry form;
• Attempt to gain unauthorised access to our systems or infrastructure;
• Introduce viruses, malware, or any harmful code;
• Do anything that could damage, disrupt, or impair the Website's operation;
• Violate any applicable law or regulation.

We reserve the right to block access to the Website from any user we reasonably believe is in breach of this section.

12. Data Protection and Privacy

When you submit an enquiry or otherwise interact with this Website, we may collect personal data such as your name, email address, and the content of your message. We use this information solely to respond to your enquiry and, where you have opted in, to send you updates about Pamgia's services.

We handle all personal data in accordance with our Privacy Policy, which forms part of these Terms. You can ask us to stop contacting you at any time by emailing paul@pamgia.com.

Pamgia LLC is a US entity (Delaware). Where personal data is transferred from the UK or EEA, we rely on appropriate legal mechanisms to ensure lawful transfer, including Standard Contractual Clauses where required.

For information about our use of cookies, see our Cookie Policy. As of the Effective Date, the Website uses only strictly necessary cookies.

13. Third-Party Links

The Website may include links to third-party websites for reference purposes. We have no control over those websites and accept no responsibility for their content, privacy practices, or availability. A link does not imply our endorsement of any third-party site or service.

14. Disclaimers and Limitation of Liability

14.1 No Warranties

This Website and all Content are provided "as is" and "as available" without any warranty, express or implied. To the fullest extent permitted by law, Pamgia disclaims all warranties, including as to accuracy, completeness, fitness for purpose, and non-infringement. We do not warrant that the Website will be uninterrupted, error-free, or free from harmful components.

14.2 Limitation of Liability

To the maximum extent permitted by applicable law, Pamgia LLC, its members, managers, officers, employees, and agents shall not be liable for any direct, indirect, incidental, consequential, or punitive damages arising from your use of or inability to use this Website or its Content, including any reliance on information published here.

You use this Website and rely on its Content entirely at your own risk.

14.3 Indemnification

You agree to indemnify and hold harmless Pamgia LLC and its members, managers, employees, and agents from any claims, losses, liabilities, costs, or expenses (including reasonable legal fees) arising from your breach of these Terms or your misuse of the Website.

15. Modification, Suspension, or Discontinuation of the Website

Pamgia reserves the right to modify, suspend, or discontinue the Website (or any part of it) at any time, with or without notice, for any reason. We shall not be liable to you or any third party for any modification, suspension, or discontinuation of the Website.

16. Governing Law and Disputes

These Terms are governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict-of-law rules.

Any dispute arising out of or relating to these Terms or your use of the Website that cannot be resolved informally shall be submitted to binding arbitration in accordance with the rules of the American Arbitration Association (AAA), with the arbitration seated in Delaware. The arbitration shall be conducted by a single arbitrator. Each party shall bear its own costs and expenses, with filing and arbitration fees allocated in accordance with the applicable AAA rules. Where required by applicable law or AAA rules, Pamgia will bear all arbitration costs beyond the initial filing fee. Nothing in this clause prevents either party from seeking emergency injunctive relief from a competent court.

To the maximum extent permitted by applicable law, you agree that any dispute resolution proceedings will be conducted only on an individual basis and not in a class, consolidated, or representative action. You waive any right to participate in a class action lawsuit or class-wide arbitration. Either party may elect to resolve a dispute in small claims court (if the claim qualifies) instead of through arbitration.

If you are located in the United Kingdom or the European Economic Area, nothing in this section limits your right to bring proceedings in the courts of your country of residence. The mandatory arbitration and class action waiver provisions in this section apply only to users located in the United States.

If you are accessing the Website from outside the United States, you do so voluntarily and are responsible for compliance with applicable local laws.

17. General

17.1 Entire Agreement. These Terms, together with our Privacy Policy and Cookie Policy, constitute the entire agreement between you and Pamgia in relation to your use of this Website.

17.2 Severability. If any provision of these Terms is found to be invalid or unenforceable, it will be severed and the remaining provisions will continue in full force.

17.3 Waiver. Our failure to enforce any provision of these Terms does not constitute a waiver of that right.

17.4 No Relationship; No Fiduciary Duty. Nothing in these Terms creates any partnership, agency, employment, joint venture, or fiduciary relationship between you and Pamgia. Without limiting the foregoing, Pamgia does not owe any fiduciary duties to you and expressly disclaims any such duties. Your use of this Website or any future interaction with Pamgia does not create a relationship of trust or confidence, and you should not rely on Pamgia to act in your interest except as expressly set out in any separate written agreement.

17.5 Force Majeure. We are not liable for any failure or delay caused by circumstances beyond our reasonable control, including internet outages, natural disasters, or government action.

17.6 Accessibility. Pamgia is committed to making this Website accessible to all visitors. If you experience difficulty accessing any part of this Website, please contact us at paul@pamgia.com so we can assist you.

By using this Website you confirm you have read and agreed to these Terms of Service.

Copyright 2026 Pamgia LLC. All rights reserved.