E-Certification Service Agreement

This agreement governs the rights and obligations of Hongshen (Beijing) Legal Consulting Co., Ltd. in providing electronic evidence preservation, Trusted Timestamp, e-signature (subject to compliance activation), and related e-certification services through the Acosmi / Xiezhua group platform to international users.

Applicable region: International (users outside mainland China). Users in mainland China please switch to the Chinese (China region) version.

Effective: June 3, 2026 | Last updated: June 3, 2026

1. Service Provider and Group Structure

The electronic evidence preservation, Trusted Timestamp (e-certification), e-signature (available subject to compliance activation), and related legal certification services you access through Acosmi are operated and delivered by Hongshen (Beijing) Legal Consulting Co., Ltd. ("Hongshen Legal" or "we" / "us"). Hongshen Legal and Xiezhua (Beijing) Intelligent Technology Co., Ltd. ("Xiezhua Technology") belong to the same enterprise group (collectively the "Xiezhua group" or "Acosmi") and together provide all Acosmi products and services under a single brand, a single account system, and unified privacy and security standards.

Agreement status. This Agreement is a specific/supplemental agreement to the Terms of Service and together with the Terms of Service constitutes your entire agreement with Acosmi regarding the services described herein. Where this Agreement conflicts with the Terms of Service on a matter covered by this Agreement, this Agreement prevails; matters not addressed here are governed by the Terms of Service. By using any service described in this Agreement, you confirm that you have read, understood, and accepted all of its terms.

2. Definitions

2.1 Key Terms

3. Scope of Services

Service availability notice: Availability of the services listed below depends on the activation status of your account. Some capabilities require completion of identity verification (KYC) or are in a staged roll-out. For the current status of each capability, see E-Certification Compliance Notes.

3.1 Electronic Evidence Preservation and Trusted Timestamp (currently available)

The following services are currently available to users:

• Electronic evidence preservation: computation of a cryptographic hash of your designated electronic file and archival of the hash together with metadata, forming an electronic evidence record suitable for use in legal or administrative proceedings;
• Trusted Timestamp (RFC 3161 / CFCA): submission to an accredited TSA to obtain and bind a trusted timestamp token; retention of the hash value, timestamp token, and metadata;
• Public verification: provision of a verification channel for self-inspection or presentation to third parties; retention of evidence records for statutory periods (see Section 10).

3.2 E-Signature Service (available subject to compliance activation)

The e-signature signing gate is closed by default. The service becomes available only after compliance activation has been completed. Once activated, the service provides:

• Procurement and management of digital certificates bound to your verified identity;
• Application of digital-certificate-based electronic signatures to data messages;
• Multi-party signing workflow management (initiate, notify signatories, consolidate signed documents);
• Signature verification and signing-record retention.

3.3 Bench Legal Workbench (planning / rolling out)

The Bench legal workbench is currently in the planning and staged roll-out phase and has not been deployed as a live, operating service. The following features are planned; actual availability will be announced on the product page:

• Contract management and review: upload, store, and version-control contract files; AI-assisted clause analysis and risk flagging;
• AI legal consulting: knowledge Q&A and reference opinions powered by large language models (see Section 8.2 for AI disclaimers);
• Lawyer collaboration: connection with registered lawyers on the platform for professional legal advice;
• Document drafting and archiving: assisted drafting of common legal documents; unified archive and search.

3.4 Capability Status Summary

4. Identity Verification (Know Your Customer / KYC)

4.1 Why Identity Verification Is Required

The legal validity of an electronic signature depends on the ability to reliably link the signature to an identifiable natural person or legal entity. Applicable law (including eIDAS for EU users, US ESIGN Act / UETA for US users, and local equivalents elsewhere) and CA business rules require verified identity before a certificate-backed electronic signature can be issued. You must complete identity verification before using any signing or certification feature. The step-up identity verification (KYC) provider is currently being connected; the full KYC flow for high-risk operations will be available once integration is complete.

4.2 Individual Users

Individual users are required to provide and verify the following (specific steps per the product interface):

• Full legal name and valid government-issued photo identity document (passport, national ID card, driving licence, or equivalent);
• Mobile phone number for one-time verification codes;
• Depending on the applicable CA rules, liveness detection or authoritative-data-source comparison may be required.

4.3 Business / Organisation Users

Business users must provide and verify:

4.4 Accuracy Obligation

You warrant that all identity information and supporting materials you provide are true, accurate, complete, and not falsified. You must not impersonate another person or entity. You are solely responsible for any legal consequences arising from false or inaccurate information. We reserve the right to suspend your account, terminate services, and report to competent authorities if we detect or are notified of identity fraud.

4.5 Certificate Procurement from CA Partners

We act as your agent in procuring digital certificates from our accredited CA partners. By completing KYC, you authorise us to submit the required information to our CA partner(s) on your behalf. Certificates are issued by the CA pursuant to its own certification practice statement (CPS); we do not control the CA's independent adjudication of applications and are not liable for CA decisions.

5. Legal Effect of Electronic Signatures

5.1 Legal Basis

The legal effect of electronic signatures varies by jurisdiction. We provide the following summary for general informational purposes; you should seek local legal advice regarding enforceability in your specific jurisdiction.

5.2 Conditions for a Reliable / Advanced E-Signature

5.3 Matters Where E-Signatures May Not Be Legally Sufficient

Certain categories of legal act may require a wet-ink signature, notarisation, or other specific formality under local law. Common examples include (this list is illustrative, not exhaustive):

• Wills, testaments, and succession documents — many jurisdictions require physical signatures and witnesses;
• Family law acts (marriage, adoption, divorce decrees) — generally require in-person formalities;
• Transfers of title to real property — often require notarised instruments and registration;
• Negotiable instruments (bills of exchange, promissory notes in some jurisdictions);
• Court filings — while many courts now accept e-signatures, specific requirements vary;
• Transactions requiring notarisation under applicable law.

If you are uncertain whether e-signatures are legally sufficient for your specific transaction, you should seek independent legal advice.

5.4 Cross-Border Recognition

Cross-border recognition of electronic signatures depends on the laws of both jurisdictions and any applicable bilateral or multilateral agreements. eIDAS-qualified signatures are mutually recognised within the EU/EEA but may not automatically be recognised as equivalent to wet-ink signatures in non-EU countries. We do not warrant the recognition of signatures created through our service in any particular jurisdiction outside the user's home country. Consult local counsel for cross-border transactions.

6. Trusted Timestamps and Electronic Evidence Preservation

6.1 Evidentiary Value of Trusted Timestamps

A trusted timestamp issued by an accredited TSA in accordance with RFC 3161 provides a reliable, independently verifiable record that a specific set of data existed in a specific form no later than the stated time. Courts in many jurisdictions treat properly issued timestamps as reliable evidence of:

• The existence of the document or data at the stated time;
• The integrity of the document (i.e., it has not been altered since the timestamp was applied).

In the EU, timestamps issued by qualified TSPs are qualified electronic time stamps under eIDAS and carry a legal presumption of accuracy of the date and time indicated and integrity of the data (eIDAS Art. 41).

6.2 How Hash-Based Preservation Works

When you request evidence preservation for an electronic file, the system will:

1. Compute a SHA-256 (or stronger) cryptographic hash of the file content;
2. Submit the hash value together with metadata (operator, time, description) to an accredited TSA, obtaining a signed timestamp token;
3. Record the hash value, timestamp token, and metadata in the platform's evidence database and archive;
4. Issue you an evidence certificate containing the evidence record number, hash value, and timestamp information.

To verify later, you (or any third party) need only recompute the hash of the original file and compare it to the hash recorded in the certificate. An identical hash confirms the file is unchanged since the moment of preservation.

6.3 Verification Channel

We provide an online verification tool within the platform (Evidence Management → Verify). Technical details and step-by-step verification instructions are available at /docs/e-cert/compliance. You may also verify independently by submitting the timestamp token to the TSA's public verification service.

6.4 PAdES Signature Verification

PAdES electronic signature verification is not yet provided. Any future availability will be announced separately.

6.5 Blockchain / Judicial-Chain Anchoring

Blockchain and judicial-chain anchoring are planning-stage capabilities only and are not current production features. If this technology is incorporated into a specific evidence preservation product in the future, it will be clearly stated on the product page or in the evidence certificate. The legal effect of an evidence record derives from the cryptographic integrity of the hash and the RFC 3161 timestamp token; blockchain anchoring would serve as a supplementary tamper-evidence layer and does not independently establish legal evidentiary value. We make no warranty regarding the continued operation of any blockchain network or the availability of any specific distributed ledger.

6.6 Scope of What Timestamps and Evidence Preservation Prove

A trusted timestamp and evidence certificate establish only the existence and integrity of specific data at a specific point in time. They do not prove:

• The truth or accuracy of the content of the underlying document;
• The genuine intent or authority of any party to the document;
• The validity or enforceability of any underlying transaction;
• Any attribution of authorship beyond the hash match.

The ultimate weight of evidence is determined by the competent court or arbitral tribunal.

7. Your Obligations and Warranties

7.1 Identity and Material Accuracy

You warrant that:

• All identity information and supporting materials you provide are genuine, accurate, and complete;
• You will promptly notify us of any material change to your identity information (e.g., change of legal representative, name change, corporate restructuring);
• You have the legal capacity and authority to enter into the documents you sign using our service.

7.2 Lawful Purpose

You warrant that you will use the service only for lawful purposes and will not:

• Use e-signatures or evidence preservation to forge, fabricate, or tamper with documents;
• Use the service in furtherance of fraud, money laundering, contract fraud, or any other illegal act;
• Sign documents that violate applicable mandatory law or public policy;
• Infringe the rights of any third party named in or affected by the signed documents.

7.3 Signing Authority

Where you sign on behalf of a legal entity, you warrant that you hold valid and sufficient signing authority (e.g., board resolution, power of attorney). We verify your personal or corporate identity through the KYC process but do not review your internal authority within the signing entity. You are solely responsible for any claims arising from signing without adequate authority.

7.4 Credential Security

• You are responsible for safeguarding your account credentials, digital certificate private key (if held directly), one-time passcodes, and any other authentication factors; you must not share them with others;
• If you become aware of any compromise of your credentials or any unauthorised use of your account, you must immediately contact us (email fuwu@acosmi.com; phone 4000269678 / 400-026-9678) so we can suspend the relevant services;
• Until you notify us, you bear responsibility for signing actions carried out with your credentials, except where caused by our technical fault.

7.5 Document and Transaction Compliance

You are solely responsible for the truthfulness, legality, and completeness of all files you upload, sign, or submit for evidence preservation, and for the underlying transactions those files reflect. We do not conduct substantive review of document content, and we make no representation or warranty regarding the lawfulness or enforceability of any underlying transaction.

8. Our Role, Limitations, and Disclaimers

8.1 Technology and Platform Provider

We provide technology and platform services for e-certification, e-signature, timestamping, and evidence preservation, together with (within Hongshen Legal's legal consulting licence) ancillary legal consulting services. We:

• Are not a party to any contract signed through our service;
• Do not conduct substantive review of the content of documents processed through our service;
• Do not warrant the truth of document contents, the creditworthiness of parties, or the enforceability of any underlying transaction;
• Do not assume a lawyer-client relationship or legal representation obligations unless a specific formal retainer agreement is separately executed with one of our licensed lawyers through the Bench lawyer-collaboration feature.

8.2 AI-Assisted Features — Important Limitations

The AI legal consulting features in Bench (including clause analysis, risk flagging, and document drafting assistance) are reference information generated by large language model technology and are subject to the following limitations:

• AI output does not constitute formal legal advice and should not be treated as professional legal opinion on any specific matter;
• AI outputs may contain errors, hallucinations, or outdated information;
• Do not make significant legal decisions based solely on AI output. For important transactions, litigation, regulatory compliance, or matters with material legal or financial consequences, consult a qualified, licensed lawyer;
• If you need formal legal advice within Bench, please engage our registered lawyers through the "Lawyer Collaboration" feature, which creates a distinct consulting relationship separate from the AI features.

8.3 Certification Is Not Endorsement

Hongshen Legal's completion of an e-signature process or issuance of a trusted timestamp represents only a technical confirmation — at the stated moment — of the signatory's verified identity (per KYC results) and the integrity of the document hash. It does not represent any review, approval, or endorsement of the substantive content of the document or the underlying transaction.

8.4 Third-Party CA Disclaimer

Digital certificates are issued by our CA partner(s) pursuant to their own certification practice statements and business rules, independently of us. We are not responsible for a CA's refusal to issue a certificate, revocation of a certificate, CA system outages, or any other act or omission of the CA as an independent third party. We will use commercially reasonable efforts to assist you in resolving CA-related issues.

8.5 Force Majeure and Other Exclusions

We are not liable for service interruptions or limitations caused by circumstances beyond our reasonable control, including:

• Acts of God, war, earthquake, epidemic, or other force majeure events;
• Power outages, backbone internet failures, or telecommunications provider failures;
• Government actions, regulatory changes, or changes in applicable law;
• Cyberattacks, malware, or other malicious acts (where we have implemented commercially reasonable security measures);
• TSA system failures, CA system failures, or other third-party infrastructure outages.

We will endeavour to minimise the impact of such events and to notify you promptly.

9. Fees and Payment

Use of Bench, e-signature, and Trusted Timestamp services may be subject to fees. Current pricing (including any free tier, per-use fees, and subscription plans) is displayed on the relevant product page at the time of use. Payment methods, invoicing, refunds, and automatic renewal terms are governed by the Payment, Subscription and Auto-Renewal Agreement.

10. Retention Periods and Data Availability

10.1 Retention Principles

Hongshen Legal retains signed documents, signature records, certificates, timestamps, and evidence records for periods sufficient to support the legal enforceability of the relevant instruments and to enable verification in any proceedings that may arise. Our minimum retention commitments are:

Where applicable law mandates a longer retention period, the statutory requirement prevails.

10.2 Retention After Account Deletion

Account deletion does not affect the retention of completed certification records. See Section 11.3 for a full explanation.

11. Account Deletion

11.1 How to Delete Your Account

To request deletion of your Acosmi account, please contact us through the following channels:

• Support email: fuwu@acosmi.com (please state "account deletion request" and include your account information);
• Support phone: 4000269678 (also written as 400-026-9678).

An in-product self-service deletion path is forthcoming and will be available in account settings when released. After a deletion request is submitted, a cooling-off period (typically 7 calendar days) begins, during which you may withdraw your request. Once the cooling-off period expires without withdrawal, the deletion is finalised. Full details are available in the Account Deletion Guide.

11.2 Steps to Complete Before Requesting Deletion

Before initiating account deletion, please ensure you have:

• Completed or cancelled all pending e-signing workflows (in-progress signing requests will be voided upon account deletion; completed ones are not affected);
• Downloaded and saved any contract files, evidence certificates, or other records you wish to retain, as self-service access to these will no longer be available after deletion;
• Resolved any outstanding membership benefits, unused Credits, and pending billing matters (these are not refunded upon deletion — see the Payment, Subscription and Auto-Renewal Agreement).

11.3 Effect of Account Deletion on Completed Certification Records — Critical Information

Deleting your Acosmi account does NOT invalidate, void, or delete any e-signatures you have previously completed, any contracts you have signed, any trusted timestamps that have been issued, or any evidence records that have been archived.

• Electronic signatures applied before the date of account deletion continue to be legally valid. Their validity derives from the cryptographic integrity of the signature and the underlying digital certificate, not from your account status. Account deletion has no legal effect on signatures already completed.
• Trusted timestamp tokens and hash evidence records are retained in our evidence database for the statutory periods set out in Section 10, irrespective of account status. They are not deleted when your account is deleted.
• After account deletion, if a counterparty, court, arbitral tribunal, or competent authority requires access to or verification of such records, they may request them through the following channels:
  • Email fuwu@acosmi.com with the evidence record number, signing record number, and sufficient identity information to identify the relevant records;
  • Call 4000269678 (also written as 400-026-9678);
  • Where litigation or arbitration is involved, the competent court or arbitral tribunal may obtain records via formal legal process.

We maintain these records as a legal and contractual obligation. Deleting your account will not cause any legally significant evidence in your favour to be lost.

11.4 Assisted Deletion

If you are unable to complete account deletion via the self-service path, or if special circumstances apply (e.g., corporate dissolution, change of legal representative, incapacity), please contact us:

• Email: fuwu@acosmi.com
• Phone: 4000269678 (also written as 400-026-9678)

12. Privacy of Certification Data

Identity verification materials processed in connection with e-certification services (including government ID information, biometric data for liveness checks, and corporate registration data) are personal data / personal information subject to applicable data protection law (including the GDPR for EU/EEA users, the UK GDPR for UK users, and equivalent legislation in other jurisdictions). Our data collection purposes, legal bases, retention periods, third-party disclosures, and your rights (access, correction, erasure, restriction, portability, and objection) are set out in the Privacy Policy.

Specific points:

• Identity information required for CA certificate issuance will be transmitted to our CA partner(s) as a necessary step in certificate procurement; by completing KYC you explicitly authorise this transfer;
• We do not use certification materials (especially biometric data) for commercial analytics or marketing beyond the purpose for which they were collected;
• If you wish to exercise data subject rights, please submit your request through the channels specified in the Privacy Policy; records that we are legally required to retain are not subject to erasure.

13. Limitation of Liability

13.1 Liability Cap

To the fullest extent permitted by applicable law, the total aggregate liability of Hongshen Legal and Xiezhua Technology to you under or in connection with this Agreement, arising from any cause of action (whether in contract, tort, statute, or otherwise), shall not exceed the total fees you have actually paid to us for the relevant services in the 12-month period immediately preceding the event giving rise to the claim.

13.2 Exclusion of Consequential Loss

To the fullest extent permitted by applicable law, neither Hongshen Legal nor Xiezhua Technology shall be liable for:

• Loss of profits, loss of revenue, loss of goodwill, or loss of business opportunity;
• Data loss attributable to the user's own actions or failure to maintain backups;
• Losses arising from decisions made in sole reliance on AI consulting output;
• Losses caused by acts or omissions of third parties, including CA system failures or TSA system failures;
• Any indirect, incidental, special, exemplary, or punitive damages.

13.3 Mandatory Rights

Nothing in this Agreement limits or excludes liability for:

• Death or personal injury caused by our gross negligence or wilful misconduct;
• Fraud or fraudulent misrepresentation by us;
• Any liability that cannot be excluded or limited under applicable mandatory law, including consumer protection rights under EU law or equivalent statutes;
• Our liability under applicable data protection law for unlawful processing of personal data.

14. Amendment and Termination

1. We may revise this Agreement in response to changes in law, regulatory requirements, or our business. Material changes will be notified to you by in-platform notice or email before they take effect. Continued use of the services after a revised Agreement takes effect constitutes your acceptance of the revision.
2. If you materially breach this Agreement, we may suspend or terminate your access to all or part of the services described herein. Such suspension or termination does not affect the retention of, or your right to access, completed certification records.
3. If we discontinue a service, we will provide at least 30 calendar days' notice and will assist you in exporting your data within a reasonable period. Our retention obligations under Section 10 are not shortened by service discontinuation.

15. Governing Law and Dispute Resolution

1. Governing law. This Agreement shall be governed by and construed in accordance with the laws of the jurisdiction specified below based on your country of residence, without regard to conflict-of-law principles:
   • EU/EEA users: the law of the Republic of Ireland;
   • UK users: the law of England and Wales;
   • US users: the law of the State of Delaware, USA;
   • All other users: the law of the Republic of Singapore.
2. Negotiation first. In the event of any dispute, the parties shall first attempt to resolve it through good-faith negotiation. If not resolved within 30 days of written notice, either party may proceed under paragraph 3.
3. Binding arbitration. All disputes arising out of or in connection with this Agreement that are not resolved by negotiation shall be finally settled by arbitration administered by the Singapore International Arbitration Centre (SIAC) in accordance with its rules then in force. The seat of arbitration shall be Singapore. The language of arbitration shall be English. The arbitral award shall be final and binding.
4. Consumer carve-out. If you are a consumer under applicable mandatory law (including EU consumer law or equivalent), this Agreement does not affect your right to bring claims before competent courts in your country of residence or to benefit from mandatory consumer protection provisions.
5. Class action waiver. To the extent permitted by applicable law, you waive any right to bring claims as a plaintiff or class member in any purported class, collective, or representative action.

16. Contact Us

For questions about this Agreement, to exercise data subject rights, to request access to retained certification records, or for account deletion assistance, please contact Hongshen Legal / Acosmi customer support:

Related agreements and policies:

• Terms of Service
• Privacy Policy
• Payment, Subscription and Auto-Renewal Agreement
• Account Deletion Guide
• Third-Party Account Login and Authorisation Agreement