User Agreement This document (hereinafter — the “Agreement” or the “Offer”) defines the rules and conditions for the provision of services by the multi-currency exchange service [website address] (hereinafter — the “Service”) and constitutes an official written public offer addressed to persons using the functionality of the Service (hereinafter — the “User”), for the purpose of concluding, on the terms set out below, an agreement for the provision of services. Before beginning to use the Service, the User is obliged to fully familiarize themselves with the provisions of this Agreement; access to the Service’s services is granted solely on condition that the User accepts all of its terms without exception. The current version of the Agreement is publicly available on the Service’s website [website address]. 1. General Provisions 1.1. This Agreement defines the rules for the provision of services by the Service, as well as the rights, obligations, and liability of the parties. Use of the Service in any form — whether performing a transaction, registration, or any other interaction with its functionality — is regarded as the User’s full and unconditional acceptance of the terms of this Agreement. 1.2. Access to the Service’s functionality is granted solely on condition of the User’s full and unconditional agreement with the provisions of this Agreement. 1.3. [website address] is not a banking institution, a payment system, or an operator of electronic money; it provides services exclusively within the limits established by applicable law. 1.4. If the User disagrees with the terms of this Offer, the User is obliged to immediately stop using the Service. Continued use of the Service after becoming familiar with the terms of the Agreement is deemed to be the User’s full and unconditional agreement with them. 1.5. By means of the functionality located on the website [website address], the Service provides the User with the technical ability to perform exchange, purchase, sale, and transfer transactions involving digital assets, fiat currencies, as well as non-cash and cash funds. Completion of an Application signifies the User’s full and unconditional agreement with the terms of this Offer and the rules of the Service. 1.6. The Service is not a financial institution, a bank, an operator of electronic money, a payment agent, or an issuer of electronic currency: its activity is limited to providing a software and technical complex that ensures the execution of transactions in accordance with the parameters of the User’s Application. 1.7. The provision of services by the Service is conditional upon the correct completion of the Application, the provision of accurate data by the User, and compliance by the User with the provisions of this Agreement and the rules posted on the website. 1.8. All transactions performed through the Service are carried out by the User at their own risk. The Service is not liable for the User’s losses arising from changes in exchange rates, technical failures, or other circumstances related to the use of the Service’s functionality. 1.9. The use of crypto-addresses directly or indirectly connected to high-risk or illegitimate sources is not permitted. 2. Terms and Definitions 2.1. Service — the website [website address], through which online currency exchange services are provided to Users. 2.2. User — any person using the services of the Service. 2.3. Digital Asset — cryptocurrencies, tokens, and (or) other accounting units used in electronic settlement systems, rights to which arise as a result of transactions performed through the Service, including exchange, purchase, sale, and transfer. 2.4. Payment System — a software and hardware product developed by a third party, representing a mechanism for accounting for monetary obligations and organizing mutual settlements between Users. 2.5. Payment (transaction) — the transfer of electronic or other currency from the payer to the recipient. 2.6. Payment System Client — a person who has entered into an agreement with the relevant payment system for the acquisition of proprietary claim rights against it, expressed in the conventional units accepted by that payment system. 2.7. Services of the Service — transactions for depositing and withdrawing electronic currencies from payment systems, as well as other services, information about which is posted on the pages of the website [website address]. 2.8. Application — an official request by the User to the Service, expressing the intention to use one of the Digital Asset exchange services and completed via an electronic form on the website with all necessary data specified; submission of an Application signifies the User’s agreement with the terms of this Agreement and the current rules of the Service. 2.9. Refund — the return to the User of Digital Assets or funds upon cancellation of a transaction, an erroneous payment, or on another basis provided for by the rules of the Service. 3. Access to Use of the Service 3.1. Only natural persons who have reached the age of majority, possess full legal capacity, and are not subject to restrictions established by the laws of their jurisdiction may use the Service. 3.2. Use of the Service from territories subject to international sanctions or restrictions, as well as by persons for whom such use is contrary to local law, is prohibited. List of prohibited countries:

• Russia
• Belarus
• Crimea
• the so-called self-proclaimed “DNR” and “LNR” republics
• Afghanistan
• Burundi
• Vanuatu
• Venezuela
• Guyana
• Democratic Republic of the Congo
• Zimbabwe
• Iraq
• Yemen
• Iran
• North Korea (DPRK)
• Côte d’Ivoire
• Laos
• Liberia
• Lebanon
• Libya
• Burma (Myanmar)
• Papua New Guinea
• Syria
• Somalia
• Sudan
• Sierra Leone
• USA
• Uganda
• Central African Republic
• South Sudan
• Abkhazia
• Nagorno-Karabakh Republic
• Pridnestrovian Moldavian Republic (Transnistria)
• Turkish Republic of Northern Cyprus
• South Ossetia

3.3. If violations of this Agreement are detected or there are signs of suspicious activity, the Service has the right to refuse service, suspend the execution of the Application, or block access to the Service. 3.4. This Agreement does not override the effect of the laws of the countries of registration and location of the Service and the User, nor the contractual relations existing between the User and the Payment System(s). If, by virtue of the requirements of applicable law or other agreements, the User is deprived of the right to use the Service’s services, the User’s use of such services is prohibited by this Agreement and deemed unlawful. 3.5. The Service guarantees the confidentiality of information about the User and the transactions performed by them. Disclosure of such information is permitted exclusively at the request of authorized state bodies, officials, or representatives of Payment Systems, and only where there are lawful grounds for doing so. 4. Terms of Use of the Service 4.1. The Service’s services are available to all Users; the Service does not verify the legality and lawfulness of the User’s ownership of Digital Assets or financial funds and does not monitor the User’s transactions within the framework of any of the Payment Systems. 4.2. Responsibility for funds entrusted by the User to a Payment System or a financial institution rests exclusively with that Payment System or institution. The Service is not a party to such an agreement and under no circumstances bears liability for improper or unlawful use by the User of the capabilities of the Payment System, nor for abuse of its functionality. The mutual rights and obligations of the User and the Payment System (financial institution) are governed by agreements concluded directly between them, without the involvement of the Service. 4.3. Any completed transaction for depositing or withdrawing a Digital Asset, as well as any other transaction offered by the Service to the User, is irrevocable: once it is completed — that is, once the User has received the funds due to them under the terms of a previously accepted Application — cancellation of such a transaction by the User is not permitted. 4.4. Upon receipt from authorized bodies of information about the unlawfulness of the User’s ownership of Digital Assets or financial funds, as well as other information that precludes the Service from being able to provide services to the User, the Service has the right to suspend or cancel the transaction being executed. 4.5. If the User violates the exchange conditions or the provisions of this Agreement, the Service has the right to suspend execution of the Application for 48 (forty-eight) working hours pending completion of full identification of the User, or to cancel execution of the Application. In such a case, the refund is made with a deduction of the Service’s fee of up to 5% (five percent), and the amount of such fee may not exceed the equivalent of 100 (one hundred) US dollars. If the User refuses to undergo AML/KYC verification, the funds are to be refunded within 10 (ten) days, provided there are no violations of this Agreement or applicable law on the User’s part. 4.6. The Service has the right, without explanation of reasons, to cancel the transaction being executed and return the electronic currency and (or) financial funds deposited by the User. 5. Rights and Obligations of the User 5.1. Rights and Obligations of the User 5.1.1. When completing an Application, the User is obliged to provide accurate, current, and complete information, and, in the event of any changes thereto, to promptly update the relevant data. 5.1.2. The User undertakes to use the Service solely for lawful purposes and bears full responsibility for actions performed using their data and details, including transactions involving digital assets. 5.1.3. Before confirming a transaction, the User is obliged to independently verify the correctness of the details, the amount, and the direction of the exchange; the Service bears no liability for errors made by the User. 5.1.4. The User has the right to contact support for clarification regarding the exchange conditions or the status of a transaction. 5.1.5. The User is obliged to comply with the Service’s instructions communicated to them on the website, in correspondence, or in notifications relating to the performance of a specific transaction. 5.1.6. The User confirms that they have all the rights and authority necessary to dispose of the digital assets or funds involved in the exchange transaction. 6. Rights and Obligations of the Service 6.1. Provided the User properly performs all necessary actions, the Service undertakes to carry out exchange transactions in accordance with the terms posted on the website. 6.2. For the purposes of complying with security requirements and AML/KYC rules, or upon detecting signs of suspicious activity (for example, deposit splitting, as established by the liquidity provider), the Service has the right to request additional information or documents from the User. To identify the User, the Service may request the following documents: Contact data:

• messenger nickname (Telegram);
• phone number;
• email address.

Identity documents:

• domestic and (or) international passport;
• identity card (ID card);
• driver’s license.

Documents confirming the address of residence (registration):

• copy of a utility bill;
• copy of a phone bill;
• copy of an electricity bill;
• bank statement.

If necessary, the Service has the right to request other information. 6.3. A transaction may be suspended, rejected, or canceled by the Service on any of the following grounds:

• signs of fraudulent or suspicious activity have been identified;
• the data provided is inaccurate or contains errors;
• the transaction requires additional verification carried out by the Service within the framework of applicable law;
• a violation of the Service’s internal policy or the requirements of applicable law has occurred.

6.4. The Service is obliged to ensure the confidentiality of the User’s data, except in cases provided for by law or by AML/KYC rules. 6.5. The Service has the right to change exchange rates, fees, limits, terms of use, and other parameters of its operation by publishing the corresponding updates on the website; all such changes take effect from the moment of their publication without prior notice to the User. 6.6. The Service is not liable for delays caused by the functioning of third-party systems — banks, blockchain networks, payment gateways, payment processors — as well as network congestion or technical failures on the part of third parties. 6.7. For the purposes of carrying out technical work, modernization, or enhancing the level of security, the Service has the right to temporarily restrict access to individual functions or to the website as a whole; Users are notified of planned works in an accessible form on the website. 6.8. Regardless of the direction of the exchange and the method of dispatch, the Service undertakes to ensure the quality and legitimacy of the assets transferred to clients. 6.9. Provided the client properly performs the exchange conditions, the Service is obliged to compensate the client for documented direct losses arising directly from the properties or parameters of a banking, cryptocurrency, or other transaction performed by the Service in the course of executing the client’s application, including, in particular, cases of AML flagging, the sender being deemed untrustworthy, or insufficient network fees. Losses caused by changes in asset exchange rates, the client’s investment decisions, the client’s actions after receiving the funds, or other circumstances unrelated to the properties of the transaction itself are not subject to compensation. 6.10. If the User does not approach the Service with a request for the return of funds blocked as a result of AML checks by third parties (for example, centralized exchanges whose wallets are used in the execution of the Application) for a period of more than 6 (six) months, the Service has the right, at its own discretion, to determine the form of return of such funds — in USDT or in the corresponding token, at the exchange rate on the date the Application was made or at the exchange rate on the date of the return. 7. Liability of the Parties 7.1. Liability of the Service 7.1.1. Provided the User has supplied accurate data and complied with all of the Service’s requirements, the Service bears responsibility for the correct execution of transactions in accordance with the parameters of the Application and the terms of this Agreement. 7.1.2. The Service is not liable for the User’s losses arising as a result of:

• the provision of incorrect details;
• errors in the transfer amount;
• untimely or improper performance by the User of its obligations;
• the use of outdated data;
• actions of third parties, including payment systems, banks, cryptocurrency networks, and other third-party services.

7.1.3. The Service is not liable for delays or the impossibility of executing transactions caused by:

• technical failures in blockchain networks, settlement systems, banks, or third-party services;
• the need to undergo verification due to legal requirements or to carry out a transaction review for security purposes;
• actions of intermediaries involved in the execution of the Application, including payment systems, banks, and exchanges;
• blocking of a transaction or wallet by a centralized cryptocurrency exchange whose wallets are used in the execution of the Application.

7.1.4. Services are provided by the Service on an “as is” basis, without the provision of any additional guarantees, including as regards the stability of exchange rates, the speed of processing applications, and the availability of particular exchange directions. 7.2. Liability of the User 7.2.1. The User is responsible for the accuracy of the information provided, the correctness of the details, the amount and purpose of the payment, as well as for compliance with the requirements of this Agreement and applicable law. 7.2.2. Responsibility for actions containing signs of fraud, the use of forged documents, the laundering of funds, or circumvention of the Service’s rules rests entirely with the User; the Service has the right to transfer the relevant information to the competent authorities. 7.2.3. If the actions of the User — including violation of the terms of the Offer, the provision of inaccurate data, or attempts to interfere with the operation of the platform — cause losses to the Service, the User undertakes to compensate them in full. 8. Cost of Services 8.1. The cost of the Service’s services is posted on the website [website address]. 8.2. The Service has the right, unilaterally and at any time, to change the exchange rates for digital assets and the amount of fees charged, giving prior notice to Users by posting the relevant information on the Service’s website. 8.3. The Application submitted by the User on the website [website address] contains an indication of the exchange rate, the amount of the fee of the relevant Payment System for carrying out the transaction, the amount of the Service’s remuneration, as well as the total amount of the funds or electronic currency to be transferred. 8.4. The Service’s remuneration is withheld at the time the corresponding Transaction is carried out; its amount is reflected in the Application and confirmed by the User on one of the pages of the user interface when completing it. 9. Form of the Agreement This Agreement on the rules of use of the Service is recognized by the Service and the User as a document of equal legal force to a written contract. 9.1. This Agreement is deemed concluded on the terms of a public offer, acceptance of which is made by the User by submitting the Application. 9.2. A public offer is deemed to be the information on the parameters and conditions of the Application displayed by the Service. 9.3. Acceptance of the public offer is deemed to be the performance by the User of the actions to complete the formation of the Application, confirming their intention to use the services of the Service on the terms of this Agreement, the AML policy, as well as the terms specified in the Application itself. 9.4. The date, time of acceptance, and the parameters of the terms of the Application are automatically recorded by the Service at the moment the formation thereof is completed. 9.5. The Agreement takes effect from the moment the User completes the formation of the Application; the User has the right to withdraw from performing the transaction before it is paid for. 10. Claims and Disputes Claims under this Agreement are to be sent to the Executor in the form of an electronic letter setting out the substance of the claim to the Executor’s details specified on the website. 10.1. The Service has the right, unilaterally, to make changes to the Agreement by publishing them on the website; such changes take effect from the moment of publication, unless a different period is separately established. 10.2. If there are suspicious actions on the part of the User when completing an Application, the Service has the right to suspend execution of the corresponding transaction until the circumstances are clarified. 10.3. If the transfer of the source currency was made without completing an Application through the website’s user interface, the Service has the right to refuse to carry out the exchange, purchase, or sale transaction; in this case, the funds may be returned less a fee. 10.4. As part of ensuring the successful completion of the transaction, the Service has the right to send the User, at the email address specified by them, information on the progress of the exchange. 10.5. All disputes and disagreements arising out of this Agreement shall be resolved through negotiations on the basis of a written statement from the User. The Service is obliged, within 10 (ten) days, either to satisfy the stated demands or to provide a reasoned refusal. If the dispute is not settled within 60 (sixty) days, either party has the right to apply to the court at the User’s place of residence. 11. Procedure for Completing and Executing Applications 11.1. To gain access to the Service’s services, the User must complete the electronic Application form on the website [website address], specifying all necessary information, including payment details, the chosen exchange direction, and the volume of Digital Assets. 11.2. By forming an Application, the User confirms that they have familiarized themselves with the exchange rate, the amount of the fee, the limits, the timeframes for execution, and other parameters of the transaction displayed on the website. 11.3. The Application is deemed accepted by the Service for processing after it has been correctly completed by the User and payment has been made, after which the system automatically assigns it the status “Paid by client” or a similar status in the Service’s interface, confirming the fact of payment. 11.4. The transfer of funds or digital assets is carried out by the User strictly in accordance with the details provided by the Service and specified in the Application. 11.5. The Service begins execution of the Application after the actual receipt of funds at the specified details and confirmation of the transaction by the relevant payment system or blockchain network. 11.6. The Service is not liable for delays caused, in particular, by:

• overload or slowdown of the blockchain network;
• delays by payment systems or banks;
• errors made by the User when specifying details;
• technical failures on the part of third parties.

11.7. Upon detecting errors, suspicious activity, data discrepancies, or a violation of the terms of this Offer, the Service has the right to suspend execution of the Application until the circumstances are clarified and (or) to request from the User additional information, supporting documents, or the completion of verification necessary for the execution of the Application. 11.8. The Application is deemed executed from the moment the Digital Assets or funds are sent to the details specified by the User; the Service bears no responsibility for the further fate of the funds after they have been sent. 11.9. Full responsibility for the correctness of the details and data necessary for the execution of the Application rests with the User; in the event of an error made by them, the return or restoration of funds is not guaranteed. 12. Conducting Exchange Transactions 12.1. Use of the Service’s services for carrying out unlawful transfers or fraudulent actions is categorically prohibited. By entering into this Agreement, the User undertakes to comply with this requirement and, in the event of fraudulent actions, to bear the criminal liability established by applicable law. 12.2. If automatic execution of the Application proves impossible for reasons beyond the Service’s control — such as lack of connection, insufficient funds, or erroneous data provided by the User — the funds are credited to the account within the following 24 (twenty-four) working hours or are returned to the User’s details less the commission expenses. 12.3. For the purposes of counteracting the legalization of proceeds obtained by criminal means and the financing of terrorism, the exchange office carries out an AML check of all transactions received from clients. If a transaction under an Application is deemed high-risk, the exchange office has the right to temporarily suspend it in order to carry out an AML check in accordance with FATF standards; review of such applications may take up to 72 (seventy-two) working hours, and in certain cases — longer. 12.4. Upon first request, the Service is obliged to transfer information on the transfer of Digital Assets to law-enforcement authorities, the administration of settlement systems, as well as to persons who have suffered from fraud, the fact of which has been established by judicial authorities. 12.5. The User undertakes not to interfere with the operation of the Service, not to cause harm to its software and hardware, and to provide accurate information necessary for the Service to fulfill the terms of this Agreement. 13. Risk Warning 13.1. The User is aware of and assumes all risks associated with the exchange of Digital Assets, including possible delays, fluctuations in exchange rates, fees, and the irrevocability of transactions. 13.2. The Service is not liable for losses arising as a result of incorrectly specified details, changes in the exchange rate, or failures in the operation of payment systems. 13.3. All transactions carried out through the Service are final and are not subject to cancellation, except in cases expressly provided for by this Agreement. 13.4. When completing an Application, the User undertakes to verify the accuracy of the data entered and not to use the Service for purposes contrary to law. 14. Taxation 14.1. The Service does not act as the User’s tax agent and does not notify the User of tax obligations; all taxes provided for by the legislation of the User’s jurisdiction of residence are paid by the User independently. 14.2. If state authorities require the Service to pay the User’s taxes or to repay a debt arising from the User’s refusal to pay taxes, the User undertakes to reimburse the Service for all payments incurred in connection therewith. 15. Force Majeure 15.1. The Service is released from liability for partial or complete failure to perform its obligations if this is caused by circumstances of insurmountable force, including:

• disruptions in the operation of blockchain networks;
• mass DDoS attacks;
• power supply disruptions, natural disasters, military actions;
• regulatory prohibitions and interference by government authorities.

16. Disclaimer of Obligations 16.1. The Service has the right, without explanation of reasons, to refuse to conclude this Agreement or to execute an Application; this rule applies to any User. 17. Refusal to Credit or Return Funds 17.1. The Service is not liable for refusing to credit funds or to return them in the following cases:

• errors in details that prevent the crediting of funds;
• verification of the transfer by the recipient’s bank;
• delays in payments by third parties (financial or other institutions);
• blocking of the User’s account at the request of a financial monitoring authority or another state or law-enforcement body;
• restriction or freezing of funds in accordance with the rules of a bank or other financial institution;
• refusal to credit or return funds at the User’s own initiative;
• other regulatory or technical reasons beyond the Service’s control.

18. Suspension of Service in the Presence of Debt 18.1. Upon receipt of confirmed information about the existence of a User’s debt to affiliated or partner services, the Service has the right to suspend the processing of their applications, including payouts. The User acknowledges that such information may come from trustworthy third parties. Upon detecting a debt, the Service has the right to:

• temporarily suspend the Application;
• notify the User of the existence of the debt;
• direct the User to the relevant service to resolve the matter;
• transfer the information necessary for identification strictly within the framework of the law and solely for the purpose of resolving the matter.

The User expresses their consent to such data processing and undertakes to resolve financial disputes independently. 19. Storage and Processing of Personal Data 19.1. The Service receives from the User the personal data necessary for the provision of services and undertakes to store it in encrypted form, without disclosing it to third parties, except in cases provided for in clause 12.4 of this Agreement or by law. 19.2. The Service has the right to collect additional information about the User to the extent necessary for the provision of services and to ensure the security of transactions; all data collected remains confidential and is not transferred to third parties, except in cases provided for by law. 19.3. The Service has the right to transfer personal data and information about transactions performed:

• upon an official written request from an exchange, an electronic settlement system, or a court;
• to law-enforcement authorities in the investigation of fraud or other violations;
• to the User themselves, to whom the data belongs.

19.4. Data about the User and information about the transactions performed by them are stored in the Service’s database for 3 (three) months from the moment of execution of the User’s last Application; the Service has the right to extend this period in order to comply with legal requirements or internal security policies. 19.5. The User has the right to:

• receive information about their personal data held by the Service;
• request the correction or updating of the data;
• if necessary — request the deletion of data to the extent permitted by law and AML/KYC requirements.