Sanctions & Restricted Regions Policy

1. Regulatory Framework

Sol Clock complies with sanctions programmes administered by the following authorities:

Although Sol Clock does not facilitate financial transactions, custody digital assets, or provide financial services, we recognise that displaying cryptocurrency market data may be subject to restrictions in certain jurisdictions under applicable sanctions regimes. We implement geographic restrictions as a precautionary compliance measure.

2. Restricted Jurisdictions

Sol Clock is not available in the following jurisdictions. This list enumerates exactly the countries screened by the App's built-in region check (20 countries), based on comprehensive and targeted sanctions programmes as of the last-updated date of this policy:

Occupied Ukrainian territories: The Crimea region of Ukraine is subject to comprehensive sanctions (OFAC, EU, UK, AU); devices there typically use the Russian timezone Europe/Simferopol, which the App's screening treats as Russia (RU) and blocks. The so-called Donetsk and Luhansk People's Republics are likewise comprehensively sanctioned, but devices there generally report Ukrainian carrier and timezone signals that on-device screening cannot reliably distinguish from the rest of Ukraine. Use of Sol Clock from any of these territories remains prohibited under the user representations in Section 4, even where the automated screening cannot detect it.

3. How Geographic Screening Works

Sol Clock uses a multi-layered approach to determine the user's geographic location. This screening occurs at app startup and uses the following detection methods in priority order:

Sol Clock does not request an Android location permission and does not use location services or the Geocoder for this check. The device locale is deliberately not used as a blocking signal, because it reflects a chosen UI language rather than physical presence.

3.1 Privacy-preserving design

• All screening is performed entirely on-device — nothing is transmitted to any server
• No location permission is requested, and Android location services and the Geocoder are never used
• The country code obtained is evaluated immediately and discarded; no location or region history is stored, logged, or recorded
• See our Privacy Policy for full details

3.2 What happens when a restricted region is detected

If any detection layer indicates the device is associated with a restricted jurisdiction:

1. The App displays an informational screen explaining that Sol Clock is not available in the detected region
2. The screen identifies the detected region code for transparency
3. Access to the App's features (price display, wallet connection, clock) is restricted
4. Beyond the initial region check, the only transmission is a single anonymous "region-block screen shown" counter event containing no location, region code, or identifiers (see the Privacy Policy, Section 3)

3.3 Limitations of geographic screening

We acknowledge that on-device geographic screening has inherent limitations:

• SIM-based detection may not reflect the user's current physical location (e.g., travelling with a foreign SIM)
• Carrier and timezone signals are device-reported and may be inaccurate or user-altered
• VPNs or location spoofing tools may circumvent geographic restrictions
• Dual-SIM devices may report ambiguous country information

These limitations do not relieve users of their obligation to comply with applicable laws in their actual jurisdiction (see Section 4).

4. User Representations and Warranties

By using Sol Clock, you represent and warrant that:

• You are not currently located in, a resident of, or a national of any jurisdiction listed in Section 2 (Restricted Jurisdictions)
• You are not listed on, or owned or controlled by any person or entity listed on:
  • The US OFAC Specially Designated Nationals and Blocked Persons (SDN) List
  • The EU Consolidated List of Persons, Groups and Entities Subject to Financial Sanctions
  • The UK OFSI Consolidated List of Financial Sanctions Targets
  • The Australian DFAT Consolidated List
  • Any other applicable government sanctions list
• You are not acting on behalf of, or for the benefit of, any sanctioned person, entity, or jurisdiction
• You will not use VPNs, proxy services, location spoofing tools, or any other technology to circumvent the geographic restrictions implemented by the App
• You will immediately cease use of the App if your jurisdiction becomes subject to sanctions
• If you are travelling to a sanctioned jurisdiction, you will not access the App while physically present in that jurisdiction

5. Consequences of Violation

If we determine or reasonably suspect that you are using the App in violation of this Policy or applicable sanctions laws:

• Your access to the App may be immediately terminated
• We reserve the right to cooperate with relevant authorities if required by law
• We may disclose information as required by legal process, subpoena, or government request
• You may be subject to civil or criminal penalties under applicable sanctions laws

6. Updates to Restricted Jurisdictions

International sanctions are dynamic and subject to change. We monitor sanctions designations from OFAC, EU, UK OFSI, and Australian DFAT and will update the restricted jurisdictions list as necessary. Updates may be made:

• Via App updates (changes to the built-in country list)
• Via updates to this policy document
• Without individual prior notice to users

It is your responsibility to be aware of applicable sanctions in your jurisdiction. The list in Section 2 is provided for informational convenience and may not be exhaustive at any given time.

7. No Legal Advice

This Sanctions and Restricted Regions Policy is provided for informational purposes only and does not constitute legal advice regarding sanctions compliance. The sanctions landscape is complex and varies by jurisdiction. If you have questions about whether your use of Sol Clock may be subject to sanctions restrictions, you should consult qualified legal counsel in your jurisdiction.

8. Contact

For questions about this policy or to report a potential sanctions compliance issue, please contact:

• Email: aardappvark@proton.me
• Subject line: "Sanctions Inquiry — Sol Clock"