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PINTOPAY (PTP) SERVICES TERMS & CONDITIONS

Version dated 16 October 2026

IMPORTANT NOTICE

These Terms and Conditions (the “Terms”) contain important information governing your relationship with us in connection with your Account and the Services (each as defined in this document). Additional terms and conditions may apply to certain Services. Any such additional terms and conditions are supplemental to and form an integral part of these Terms.

Nothing in these Terms or any other statements contained herein shall be construed as legal, tax or financial advice. We do not act as your financial adviser and shall not be regarded as acting in such capacity. You should consult your own independent professional advisers before entering into any transaction and should only enter into a transaction if you fully understand its nature, the contractual relationship you are entering into, and all applicable terms and conditions.

PART A. GENERAL TERMS

1. INTRODUCTION

1.1. Your Account and the related Services are provided by the PTP group, including its affiliated entities and third-party partners, depending on the nature of the specific Service (collectively, the “Group” and the “Partners”).

Certain Services may be provided by different entities within the Group or with the involvement of third-party Partners, in accordance with these Terms and any applicable additional terms.

2. SCOPE

2.1. These Terms govern your Account and your use of the Services. Please read these Terms carefully before using the Services in order to understand your legal rights and obligations.

The Services may be made available through various access channels, including, without limitation, a mobile application (App), a website (Website), and embedded mini-applications, including within third-party platform environments (Mini-App).

By using any of the Services and/or completing the registration process, you enter into a legally binding agreement with us and are deemed to have expressly read, understood, and agreed to be bound by these Terms.

2.2. These Terms include:

2.3. Inconsistency

Subject to the application of any mandatory provisions of applicable law, in the event of any inconsistency between:

For the purposes of these Terms, a transaction confirmation (Confirmation) means any document, message or electronic notification provided to you in connection with a specific action performed within the Services (including, without limitation, transfers, exchanges, card issuance or other transactions), which sets out the principal parameters of such transaction, including the amount, fees, exchange rate, limits and other applicable conditions.

The terms set out in the relevant transaction confirmation (Confirmation) shall apply exclusively to the corresponding transaction and shall prevail over the general provisions of these Terms, unless expressly stated otherwise.

In the event that a transaction confirmation (Confirmation) contains an obvious technical or arithmetic error (including, without limitation, an evidently incorrect amount, exchange rate or fee), such information shall be deemed erroneous and shall not create any binding obligations on either party.

2.4. Eligibility, Access and Restrictions

The Services are not intended for use and are not made available to any persons who are located in, resident in, citizens of, or tax residents of Hong Kong, or who access the Services from within the territory of Hong Kong.

The Services do not constitute an offer, invitation, or solicitation to provide any services in Hong Kong.

By using the Services, the User represents and warrants that they do not fall within the above restrictions and do not act on behalf of any persons subject to the jurisdiction of Hong Kong.

The Group reserves the right, at its sole discretion, to restrict, suspend, or terminate access to the Services where it reasonably believes that the User is connected to Hong Kong.

3. SERVICES

3.1. The Services provided to users encompass a broad range of functions related to financial and digital assets, including, without limitation:

Nothing in these Terms creates or shall be deemed to create any fiduciary,trust, agency, partnership or advisory relationship between the User and the Group.

Description of the Services

PTP Card (including card issuance services) — the provision to Users of the ability to apply for and use virtual and/or physical payment cards issued by third-party partners of the Group, in accordance with the applicable rules of payment systems and the additional terms and conditions of such third parties.

Swap Transactions — the provision to Users of a technical capability to exchange digital assets or other supported units of account through the Service interfaces, using third-party liquidity providers or other partners, subject to applicable fees, exchange rates, and limits. We do not provide investment advice and do not guarantee the execution of any transaction at any particular rate.

Use and functional management of the Custodian Wallet — the provision to Users of an interface for access to, viewing, and management of digital assets held in custodial wallets operated by third-party custodial service providers. Granting access to a Custodian Wallet does not constitute the acceptance of deposits, placement of funds, or discretionary asset management on behalf of the User and does not constitute banking activity.

Provision of Virtual Accounts — the provision to Users of virtual details or accounting identifiers intended to reflect transactions within the Services, which do not constitute bank accounts, payment accounts, or electronic money accounts.

Other Third-Party Services — any other services or features provided in whole or in part by third-party partners of the Group, access to which may be made available through the Services and which are governed by the additional terms and conditions of such third parties.

3.2. The Services may be made available through various access channels, including, without limitation, a mobile application (App), a website (Website), and embedded mini-applications, including within third-party platform environments (Mini-App). The availability of specific Services, features or components may depend on the access channel used.

3.3. Certain Services or elements thereof may be provided by third-party partners of the Group. In such cases, additional terms imposed by such third parties may apply to the relevant Services in addition to these Terms.

3.4. We reserve the right, at any time and at our sole discretion, without prior notice and without any liability to the user, to update, modify, suspend, disable, restrict access to, or discontinue the Services or any features, components or content thereof. We do not guarantee that any particular Services, features, components or content will be available at all times.

3.5. Pre-conditions for the Provision of the Services

We may, at our sole discretion, determine from time to time the scope of Services made available to you under these Terms. To access the Services, you must open and maintain an Account with us in accordance with these Terms.

Without limiting our rights, we may refuse to provide any Service if, in our opinion:

Without limiting our rights under any other provisions of these Terms, we may also suspend or refuse to provide any Service if, in our opinion, such Service may:

Any decision to suspend, refuse or terminate the provision of the Services shall be made at our sole discretion, and we shall not be obliged to disclose the reasons for such decision, except as required by applicable law.

4. ONBOARDING

4.1. For the purpose of providing you with the Services, we may open an Account in your name or otherwise in respect of you. Registration and onboarding may be carried out through various access channels, including, without limitation, a mobile application (App), a website (Website) and embedded mini-applications, including within third-party platform environments (Mini-App).

4.2. To open and maintain an Account with us and access the Services, you must:

All information provided by you must be complete, accurate and up to date.

4.3. We have sole discretion with respect to the opening, operation and closure of the Account. Without limiting any other provisions of these Terms, we may, at any time, at our sole discretion and without any liability:

4.4. Any Account is established and maintained by us solely for the purpose of providing the Services. Under no circumstances shall an Account be construed as a bank account, a payment account, a stored value facility, or any other banking or financial service.

4.5. By registering to open an Account and use the Services, you represent and warrant that:

4.6. In addition to the foregoing, you agree to provide us, upon request, with any information and/or documents (including information and/or documents required to comply with applicable law, AML/CTF and sanctions requirements) on an ongoing basis or from time to time.

4.7. You agree to cooperate with all requests made by us or by our third-party service providers acting on our behalf in connection with your use of the Services, including requests to identify or authenticate your identity, verify funding sources or review specific transactions. This may include, without limitation, providing additional information and/or documents, confirming ownership of a phone number, device or payment instruments, and verification of your information against third-party databases or other sources.

We are entitled, at our sole discretion, to refuse your application and to suspend, restrict or terminate your use of the Services, and/or to amend the eligibility criteria for registration at any time.

4.8. We may confidentially verify the information you provide to us and may obtain information about you ourselves or through third parties from secure databases. By accepting these Terms, you confirm that you consent to us or third parties carrying out such verifications on our behalf.

4.9. You must ensure that any information provided to us or to any of our third-party service providers remains accurate and up to date at all times. If at any time we believe that your information is outdated or inaccurate, we may contact you to request additional information or require you to undergo the verification process again. Failure to complete any step of the registration or verification process may result in your inability to use the Services.

5. ACCESS INTERFACES TO THE SERVICES (Website, Mini-App)

5.1. General Provisions

Access to the Services may be provided through various interfaces, including, without limitation, a website (Website) and embedded mini-applications, including within third-party platform environments (Mini-App, including Telegram) (collectively, the Access Interfaces).

The functionality of the Access Interfaces, as well as the scope of Services, features and components available through them, may from time to time be modified, updated, restricted or discontinued without prior notice at the sole discretion of the Group.

A Mini-App within third-party platforms, including Telegram, serves solely as an interface for accessing the Services. Such third-party platforms are not providers of the Services and bear no responsibility for the provision, operation, availability or results of the use of the Services.

5.2. Functional Capabilities

Depending on applicability, availability of specific Services and the user’s status, the Access Interfaces may enable the user, including without limitation, to:

All notifications, reports, transaction confirmations and other information are provided exclusively in electronic form through the relevant Access Interfaces.

5.3. Subject to your ongoing compliance with these Terms, the Group grants you a limited, non-transferable and non-exclusive licence to use the Application to the extent owned by or licensed through the Group, solely on your Enabled Device and solely for personal use, in accordance with these Terms.

You acknowledge and agree that your use of the Account and the Services is at all times subject to your compliance with these Terms and any other applicable terms.

5.4. Security features, including PIN codes, biometric authentication (Face ID, fingerprint recognition) and other security mechanisms, are controlled by the user’s device and the relevant operating systems. We do not store, process or control the user’s biometric data and do not bear responsibility for the operation of such security mechanisms.

6. YOUR DEVICE

6.1. General User Obligations

You acknowledge and agree that, in connection with your use of the Access Interfaces to the Services (including the website (Website) and Mini-App, including within third-party platform environments such as Telegram), you shall be responsible, at your own cost, for the following:

6.2. Responsibility for Access and Use

Without prejudice to the foregoing and any other provisions of these Terms, you shall be solely responsible for any access to and use of the Account and the Services through your device, regardless of whether such access or use occurred with or without your knowledge, authorisation or consent.

The Group shall not be liable for any loss or damage arising from such access or use.

6.3. Credentials and Security

You shall also bear full responsibility for the safekeeping and confidentiality of any credentials, access codes, PINs, passwords, authentication means and other security mechanisms used to access the Account and the Services, including credentials of third-party platform accounts (such as Telegram), where such accounts are used to access the Services.

6.4. Irreversibility of Transactions

You acknowledge and agree that transactions carried out through the Services using your device or credentials may be irreversible.

We are not obliged to reverse, suspend or compensate for any such transactions if they were initiated or executed as a result of the loss, compromise or unauthorised use of your device or credentials.

6.5. Loss of Device and Unauthorised Access

If you discover that your device has been lost, stolen, or accessed or used in an unauthorised manner, you must immediately contact the Service support team and notify us of such loss, theft or unauthorised access/use via the communication channels specified in the Access Interfaces, including, without limitation, by contacting [email protected].

In addition, you must promptly take all reasonable measures to protect the Account, including changing passwords, access codes and other authentication means.

7. FEES

7.1. Your use of the Services may be subject to certain fees (Fees) which, where applicable, may be debited from your Wallet, Smart Contract Vault or Virtual Account balance (as applicable), deducted upon settlement of Card Balances, upon completion of Swap Transactions, or otherwise charged to you separately.

You undertake to promptly pay any Fees due upon our request. In the event of non-payment, we reserve the right to suspend your access to the Services until all outstanding Fees have been fully settled.

The list of applicable Fees is set out in the relevant fee schedules and is published through the Access Interfaces, including the website (Website) and Mini-App. The Group may, at its sole discretion, introduce additional Fees or otherwise amend, adjust or update the Fees from time to time by publishing updated information through the Access Interfaces.

7.2. All applicable Fees set out in the fee schedules and through the Access Interfaces are exclusive of any applicable taxes, duties or similar mandatory charges payable under Applicable Law. The actual Fee charged may be increased to account for any such taxes or charges where required by Applicable Law.

7.3. All Fees paid are non-refundable, unless otherwise expressly provided in these Terms or required by Applicable Law.

7.4. Your obligation to pay any amounts under these Terms is independent of, and not contingent upon, any of your other payment obligations.

8. RIGHTS OF NETTING, SET-OFF AND LIEN

8.1. Netting of Obligations

If, on any day, you and we have payment or delivery obligations in the same fiat currency or the same Acceptable Token in respect of two or more transactions, we may elect to settle such obligations on a net basis, in which case such obligations shall be automatically satisfied and discharged.

Where the aggregate amount payable by one party exceeds the aggregate amount payable by the other party, the relevant obligations shall be replaced by an obligation of the party owing the greater amount to pay the excess to the other party.

8.2. Right of Set-Off

In addition to our rights under Clause 8.1, we may, at any time during the term of these Terms or following their termination, without prior notice to you, set off any amount or other obligation owed by you (or, where the client consists of more than one person, by any one or more of such persons jointly or severally) to the Group against any amount owed by the Group to you, whether or not such obligations are matured or contingent, and irrespective of the currency, asset or place of payment, to the extent permitted by Applicable Law.

8.3. Enforcement Against Assets in Case of Shortfall

If, following any set-off, a balance becomes due and payable by you to the Group:

8.4. Lien

To the extent permitted by Applicable Law, the Group may exercise a general lien over any property, funds, balances or other values of the User which, for any reason, are reflected, recorded or otherwise made available within the Services or through the Group’s technical or contractual arrangements with third-party service providers.

For the avoidance of doubt, any reference to possession or control under this Section shall be deemed to arise solely through such technical or contractual arrangements with third-party service providers and shall not imply possession or control of users’ private keys or Digital Assets by the Group.

Where legally and technically permissible, the Group may cause such property to be realised through applicable third-party service providers and apply the proceeds, after deduction of reasonable costs, towards the satisfaction of any amounts owed by the User to the Group.

8.5. For the purposes of this Clause 8, we may carry out any necessary currency or asset conversions at rates that we reasonably consider appropriate under the prevailing market conditions.

8.6. Our rights under this Clause 8 are in addition to, and do not limit, any other rights of set-off, netting, combination of accounts, lien, retention, withholding or similar rights or requirements to which we may be entitled under these Terms or by operation of Applicable Law.

9. INTELLECTUAL PROPERTY RIGHTS

9.1. You acknowledge and agree that:

9.2. Referral links and codes.

10. RULES OF CONDUCT AND RISK MANAGEMENT

10.1. Prohibited Activities

Without prejudice to any other provisions of these Terms, the User shall not, whether directly or indirectly, and shall not knowingly or otherwise authorise, permit or assist any third party to:

10.2. Consequences of Breach

Any breach by the User of Clause 10.1 or any other obligation expressly imposed on the User under this Section 10 may, at the Group’s discretion and to the extent permitted by Applicable Law, result in the suspension, restriction or termination of the User’s access to the Services, blocking of the User’s Account, refusal to provide certain Services and/or the application of any other measures available under these Terms and/or Applicable Law.

For the avoidance of doubt, the mere existence of any circumstance or risk indicator referred to in Clause 10.3 shall not, in itself, constitute a breach of these Terms by the User unless and until such breach is established following the relevant review.

10.3. Transaction Monitoring and Risk Management

10.3.1. General Monitoring

The Group may monitor the use of the Services and any transactions conducted or attempted through the Services, whether on a real-time or retrospective basis, for the purposes of risk management, fraud prevention, compliance with Applicable Law, protection of the Group and its Partners, and detection of unusual, irregular, potentially unlawful or abusive use of the Services.

For these purposes, the Group may apply internal risk indicators, transaction monitoring, behavioural analysis, blockchain transaction screening, risk scoring and other reasonable risk-management procedures, controls and tools.

10.3.2. Large Deposits and Subsequent Disposal of Funds

Where a User makes one or more related deposits of Digital Assets to the Custodian Wallet with an aggregate value equivalent to USD 2,000 (two thousand United States dollars) or more and, within 48 (forty-eight) hours following such deposit or deposits, initiates or attempts to initiate a withdrawal, transfer or other disposal of all or a material part of such funds, the Group may treat such activity as an indicator of increased transactional risk requiring additional review.

For the purposes of this Clause 10.3.2, multiple deposits may be treated as related where, having regard to their timing, source, originating blockchain addresses, counterparties, transaction pattern or other relevant circumstances, the Group reasonably determines that such deposits form part of the same transaction or a series of connected transactions.

The occurrence of such indicator shall not, by itself, constitute a breach of these Terms by the User and shall not constitute an independent basis for the permanent withholding, deduction, appropriation or other permanent deprivation of the User’s funds.

10.3.3. Additional Review

Upon identification of the activity described in Clause 10.3.2, or any other unusual, irregular, potentially unlawful, fraudulent or abusive activity, or any other circumstances giving rise to increased transactional, compliance or financial crime risk, the Group may conduct an additional review of the User and the relevant transactions.

For the purposes of such review, the Group may, without limitation:

The User shall provide the requested information, explanations and documents within a reasonable period and shall provide such cooperation as may reasonably be required for the purposes of the review.

Failure to provide the requested information or documents, provision of incomplete, inaccurate, false or misleading information, or refusal to cooperate may be taken into account by the Group when assessing the relevant activity and determining the outcome of the review.

10.3.4. Temporary Protective Measures

During the period of any review conducted under this Section 10.3, the Group may, where reasonably necessary for risk-management purposes and to the extent permitted by Applicable Law:

Any review under this Section shall be conducted within a reasonable period, having regard to the nature and complexity of the relevant circumstances, the scope and timeliness of the information and documents provided by the User, and any requirements or response times applicable to the Group’s Partners or competent authorities.

Any temporary restrictions imposed under this Clause 10.3.4 shall remain in place only for so long as reasonably necessary for the purposes for which they were imposed, or for such other period as may be required under Applicable Law or pursuant to any binding requirement of a competent authority or the Group’s Partners.

The occurrence of the indicator described in Clause 10.3.2 shall not, by itself, result in the automatic application of any fee, charge, withholding or deduction in respect of the User’s funds or Digital Assets.

10.3.5. Outcome of Review

Following completion of the review, the Group may:

10.3.6. Costs, Losses and Withholding

Where, following the review, the Group reasonably determines that the relevant activity constitutes a breach of these Terms or other improper or abusive use of the Services, and such activity has resulted, or is reasonably expected to result, in additional costs, expenses, fees, penalties, losses or other liabilities being incurred by the Group or its Partners, the Group may, to the extent permitted by Applicable Law, withhold an appropriate amount from the User’s funds towards the coverage of such costs, expenses, fees, penalties, losses or other liabilities.

The amount of any such withholding shall be determined by the Group having regard to the nature and circumstances of the identified breach and shall be reasonably proportionate to the costs, expenses, fees, penalties, losses or other liabilities actually incurred or reasonably expected to be incurred by the Group or its Partners as a result of the relevant breach.

In no circumstances shall the amount withheld under this Clause 10.3.6 exceed 10% (ten per cent) of the amount of funds subject to the relevant review.

The relevant amount may be withheld from the User’s available balance or set off in accordance with Section 8 of these Terms.

Where the review does not establish grounds for such withholding, no withholding shall be applied and any funds temporarily subject to restrictions shall be released from such restrictions, except where the continued application of such restrictions is required under Applicable Law, pursuant to a binding requirement of a competent authority, or under any other applicable provision of these Terms.

For the avoidance of doubt, the mere fact that a User has deposited Digital Assets with an aggregate value equivalent to USD 2,000 (two thousand United States dollars) or more and subsequently disposed of such funds within the period specified in Clause 10.3.2 shall not, in itself, give rise to any obligation on the User to pay any amount or confer upon the Group any automatic right to withhold 10% or any other amount of the User’s funds under this Clause 10.3.6.

10.3.7. Relationship with Other Rights and Remedies

The measures provided for in this Section 10.3 are without prejudice to, and shall not limit or exclude, any other rights, restrictions, protective measures or remedies available to the Group under these Terms or Applicable Law, including the rights of set-off, enforcement and lien provided for under Section 8 and the rights of suspension, restriction and termination provided for under Section 13.

11. DATA PROTECTION

11.1. By using the Services, you confirm that you have read and understood our Privacy Policy and consent to the collection, use, processing, storage, transfer and sharing of your Personal Data by us, as well as the disclosure of such Personal Data to the Group, our authorised service providers and relevant third parties, to the extent and for the purposes necessary to provide, administer and operate the Services.

11.2. The purposes of processing, categories of Personal Data, legal bases for processing, retention periods and other information relating to the processing of Personal Data are set out in more detail in our Privacy Policy available at pintopay.me, which forms an integral part of these Terms.

11.3. You acknowledge and agree that your Personal Data may be processed and transferred to countries and jurisdictions other than your country of residence, including transfers within the Group and to its partners, subject to compliance with applicable data protection laws and the implementation of appropriate safeguards.

11.4. You further acknowledge and agree that your Personal Data may be processed for the purposes of compliance with Applicable Law, including, without limitation, anti-money laundering and counter-terrorist financing (AML/CTF) requirements, sanctions laws, and the requirements of regulators, payment systems, issuing banks and other competent authorities.

11.5. Where you access the Services through Mini-Apps on third-party platforms (including, without limitation, Telegram), you acknowledge that such third-party platforms are not providers of the Services and bear no responsibility for the provision thereof. The processing of Personal Data by such platforms is governed by their own privacy policies, and we do not control or assume responsibility for such processing outside the scope of the Services.

11.6. The processing of Personal Data in connection with the Services is carried out solely to the extent and in the manner permitted by Applicable Law and in compliance with the rights of data subjects provided under such laws.

12. ELECTRONIC COMMUNICATIONS

12.1. You accept full responsibility for the security and authenticity of all instructions, orders and requests (the “Instructions”) sent through the Access Interfaces to the Services and agree to be bound by all such Instructions. We are entitled to assume that all Instructions received from you through your Enabled Devices via the Access Interfaces originate from you. We shall have no obligation to verify whether such communications were in fact sent by you.

12.2. You acknowledge that Instructions and information transmitted through the Access Interfaces to the Services are generally transmitted via the Internet and may be routed through public and transnational networks and infrastructures which are not specifically protected. We do not guarantee that such Instructions and information will be fully protected against unauthorised access, and you accept all risks associated therewith.

12.3. Your use of the Access Interfaces to the Services through third-party platforms and communication channels (including, without limitation, Telegram or other third-party platforms) is at your own risk and subject to the terms of use and policies of such third-party platforms. We do not control and shall not be responsible for the operation, security or availability of such third-party platforms outside the scope of the Services.

12.4. Any Instructions sent by you to us shall be deemed received by us only when such Instructions have been successfully retrieved by the relevant system and we have duly notified you of such receipt. Any Instructions sent by you to third parties (including, without limitation, merchants, payment systems, processing centres or other counterparties) shall be deemed received by such third parties solely in accordance with their respective terms and conditions.

12.5. Without prejudice to any other provisions of these Terms, you shall be liable for any loss or damage that may arise in connection with the use of the Internet, including, without limitation, loss of data, delays, misunderstandings, corruption of information, unauthorised interception by third parties or duplication of messages.

12.6. You acknowledge and agree that, in the event of any dispute arising in connection with your use of the Services, our records (including electronic, computer and other records, including Transaction History) relating to your use of the Services and/or to you at any specified date shall constitute conclusive and binding evidence of their accuracy and authenticity, except in cases of proven technical error or fraud.

You further agree to the admissibility of such records as evidence in any court or arbitration proceedings without the need for further proof of their authenticity or accuracy under applicable rules of evidence.

13. LIMITATION OF ACCOUNT AND SERVICES / TERMINATION

13.1. Suspension, Restriction and Termination by the Group

To the extent permitted by Applicable Law and at its reasonable discretion, the Group may suspend, restrict or terminate your use of the Account and/or the Services, in whole or in part, where this is objectively necessary in order to:

Such measures may include, without limitation:

13.2. Events of Default

For the purposes of these Terms, an Event of Default shall be deemed to have occurred upon the occurrence of one or more of the following objective circumstances, including but not limited to:

13.3. Incentive and Referral Programs

The Group may cancel, revoke, refuse to grant or exclude you from participation in any incentive programs, including reward, cashback or referral programs, if a breach of these Terms is identified, whether directly or indirectly.

13.4. Survival of Obligations and Set-Off

Your obligations under these Terms shall survive any suspension or termination of the Services.

The Group may debit amounts from the Wallet Balance, Smart Contract Vault Balance and/or Virtual Account Balance (as applicable) in respect of any amounts and fees payable under the section “Fees”, both before and after termination of the Services.

You shall remain liable for such amounts until they are paid in full.

13.5. No Compensation

You shall have no right to claim any payments, compensation or damages from the Group in connection with the suspension or termination of your use of the Services, except as expressly required by Applicable Law or as provided under the section “Limitation of Liability” of these Terms.

13.6. Termination by the User

You may request termination of the Services at any time (“User-Initiated Termination”) through the relevant Access Interfaces.

For the purposes of processing such request, the Group may request identification documents and other information necessary to comply with Applicable Law.

13.7. Return and Release of Funds

Upon termination of the Services, you shall be entitled to the return of any remaining Wallet Balance, the release of Smart Contract Vault Balance and/or the withdrawal of funds from the Virtual Account Balance (as applicable), subject to compliance with these Terms and Applicable Law.

13.8. Limitations on Returns

To the extent permitted by Applicable Law, the Group may delay, refuse or reduce the amount of funds to be returned where this is necessary to prevent a negative balance or to cover amounts payable by you.

13.9. Method of Return

The method of return or release of funds (including on-chain transfer, bank transfer or other means) shall be determined by the Group at its reasonable discretion.

Any return shall be made solely to the holder of the relevant Account and shall not be made to third parties.

13.10. Claim Period

Any funds subject to return or release must be claimed by you within three (3) years from the date on which the Group initiates such return or release. Upon expiry of this period, the Group may appropriate such funds without further notice.

13.11. Fees on Return

A fee may be charged for the return, withdrawal or release of funds in order to cover costs incurred by the Group, in accordance with the section “Fees”.

13.12. Maintenance Fees on Remaining Balances

Where an Account is suspended or terminated, the Group may charge an account maintenance fee in respect of any remaining balances held in the Wallet Balance, Smart Contract Vault Balance and/or Virtual Account Balance.

13.13. Reservation of Rights

The rights of the Group under this Section 13 are without prejudice to any other rights or remedies available to the Group under these Terms or Applicable Law.

14. LIMITATION OF LIABILITY

14.1. Disclaimer of Warranties

Except as expressly provided in these Terms and to the fullest extent permitted by Applicable Law, we disclaim all other representations and warranties, whether express or implied, made to you, your affiliates or any other person, including without limitation any warranties as to quality, suitability, merchantability, fitness for a particular purpose or otherwise (regardless of any course of dealing, custom or usage of trade), in respect of any Services or any goods provided in connection with the Services under these Terms.

To the extent that any representations or warranties cannot be excluded by law, our liability in respect of such representations or warranties shall, at our option, be limited to one of the following remedies:

14.2. Exclusion of Liability

Notwithstanding anything to the contrary in these Terms and to the fullest extent permitted by Applicable Law, in no event shall the Group or any of its representatives be liable to you:

14.3. Aggregate Liability Cap

In any event, the total aggregate liability of the Group arising out of or in connection with the provision of any Services under these Terms shall be limited to the amount of your Wallet Balance, Smart Contract Vault Balance and/or Virtual Account Balance (as applicable) as at the date on which the relevant claim arises.

14.4. Third-Party Service Providers

The Group shall not be liable for any act or omission of any third-party service providers engaged by us. In such cases, the Group’s liability shall be limited to exercising reasonable care in the selection, appointment and instruction of such third-party service providers (but not any subcontractors or other third parties engaged by such providers).

14.5. Non-Excludable Liability

Nothing in these Terms shall operate to limit or exclude any liability for fraud or for death or personal injury resulting from negligence, to the extent that such liability cannot be limited or excluded under Applicable Law.

15. INDEMNIFICATION

You agree to indemnify, defend and hold harmless the Group, each of its affiliates and third-party service providers, and each of their respective officers, directors, agents, joint venturers, employees and representatives (collectively, the “Indemnified Parties”), from and against any and all claims, demands, losses, liabilities, costs or expenses (including reasonable attorneys’ fees and any fines, fees or penalties imposed by any regulatory authority) arising directly out of or in connection with:

16. AMENDMENT AND VARIATION

16.1. These Terms may be updated or amended from time to time. The Group shall publish any such updates or amendments through the relevant Interfaces of Access to the Services.

16.2. The updated version of the Terms shall take effect immediately upon publication through the Interfaces of Access, unless otherwise expressly stated by us.

16.3. You undertake to independently and regularly review the current version of the Terms through the Interfaces of Access in order to familiarise yourself with any changes.

16.4. We reserve the right, at any time, at our sole discretion and without prior notice, to modify, add or remove any features or functionalities of the Interfaces of Access or the Services.

16.5. By continuing to use the Interfaces of Access and/or the Services after any amendments or updates have taken effect, you confirm your acceptance of the updated version of these Terms, as well as the modified functionalities of the Interfaces of Access.

16.6. If you do not agree with any amendments or additions to these Terms, you must immediately cease using the Interfaces of Access and the Services.

17. ASSIGNMENT AND SUBCONTRACTING

17.1. These Terms, and any rights and licences granted to you hereunder, are personal to you and may not be transferred, assigned or otherwise disposed of by you without our prior written consent.

17.2. The Group may, without restriction, assign, transfer or otherwise dispose of these Terms, and any of its rights and obligations hereunder, including without limitation to any affiliate or subsidiary of the Group, or to any successor in interest in connection with any merger, reorganisation, acquisition or transfer of any business or assets related to the Services.

17.3. Any such assignment, transfer or disposition shall not adversely affect your rights or obligations under these Terms.

17.4. Any attempted transfer or assignment in breach of this Section shall be null and void.

18. SEVERABILITY

18.1. If any provision of these Terms is held by any court or administrative body of competent jurisdiction to be invalid, unlawful or unenforceable, such invalidity, unlawfulness or unenforceability shall not affect the validity or enforceability of the remaining provisions of these Terms, which shall remain in full force and effect.

18.2. The relevant provision shall be modified and interpreted so as to give effect to the intent and objectives of such provision to the maximum extent permitted by Applicable Law.

19. ENTIRE AGREEMENT AND LANGUAGE

19.1. These Terms constitute the entire agreement between you, on the one hand, and the Group, on the other hand, with respect to their subject matter, and supersede and replace all prior or contemporaneous representations, arrangements, understandings and agreements relating to the same subject matter, whether oral or written, express or implied.

19.2. Each party acknowledges that, in entering into these Terms, it does not rely on any statement, representation, warranty or understanding other than those expressly set out in these Terms.

19.3. Notwithstanding the foregoing, in the event of any conflict or inconsistency between these Terms and any Service Content, including without limitation informational materials, interface texts, notices or help sections displayed through the Interfaces of Access, these Terms shall prevail.

20. WAIVER

20.1. Any waiver of these Terms, whether in whole or in part, shall be effective only if made with the prior written consent of the Group.

20.2. Any delay or failure by the Group to exercise or enforce any right under these Terms shall not be construed as a waiver of such right, nor shall it affect the Group’s rights in respect of any breach or any subsequent breach of these Terms.

20.3. No right, power or remedy conferred upon or reserved to the Group under these Terms shall be deemed exclusive, and each such right, power or remedy shall be cumulative and in addition to any other rights, powers or remedies available to the Group under these Terms or Applicable Law.

21. NOTICES AND COMMUNICATIONS

21.1. By using the Services (as applicable), you agree that the Group, its affiliates and related entities, as well as third-party service providers, contractors or sub-contractors, may provide you with any notices or other communications relating to your use of the Services in electronic form, including:

21.2. The primary and preferred channel of communication between you and the Group in connection with the use of the Services shall be the Service’s support system, accessible through the relevant Interfaces of Access. Any other communication channels shall be considered supplementary or auxiliary.

21.3. For notices delivered in electronic form, including notices transmitted through the Service’s support system, the date of receipt shall be deemed to be the date on which such notice is sent or posted through the relevant Interface of Access, unless otherwise required by Applicable Law.

21.4. We prefer to receive notices, requests and communications from you through the Service’s support system, accessible via the Interfaces of Access. Where expressly permitted or indicated by us, you may also contact us by email at [email protected] or through other communication channels specified in the Interfaces of Access.

22. THIRD PARTY RIGHTS

22.1. Certain provisions of these Terms confer rights and protections on specific third parties identified in these Terms (in particular, the Indemnified Persons, including the Group’s affiliates, partners and service providers). Such third parties shall be entitled to enforce the relevant provisions of these Terms in their own right, to the extent permitted by Applicable Law.

22.2. Except for the third parties expressly referred to above, no other person shall have any right to enforce any provision of these Terms or to rely on them for any purpose.

22.3. You and the Group agree that these Terms may be amended or terminated at any time without the consent of any third party, including any Indemnified Persons, unless otherwise expressly required by Applicable Law.

23. GOVERNING LAW AND DISPUTE RESOLUTION

23.1. Governing Law

These Terms shall be governed by and construed in accordance with the laws of Hong Kong, without regard to its conflict of laws principles.

23.2. Arbitration (Primary Dispute Resolution Mechanism)

Except as expressly provided below, any dispute, controversy, difference or claim arising out of or in connection with these Terms, including without limitation any question regarding their existence, validity, interpretation, performance, breach or termination, or any dispute relating to non-contractual obligations arising out of or in connection with these Terms, shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) in accordance with the HKIAC Administered Arbitration Rules in force at the time the Notice of Arbitration is submitted.

23.3. Arbitration Parameters

You and the Group agree that:

23.4. Consumer Rights Safeguard

Nothing in this Section 23 shall limit or exclude the right of a User who is a consumer to bring proceedings before a competent court, where such right cannot be excluded or restricted under applicable consumer protection laws, including the laws of the country of the User’s habitual residence.

In such cases, the arbitration provisions of this Section 23 shall apply only to the extent permitted by Applicable Law.

23.5. Injunctive and Interim Relief

Notwithstanding anything contained in this Section 23, the Group shall be entitled to seek injunctive relief, interim measures or any other urgent legal remedies in any jurisdiction, where such relief is necessary to protect its rights or legitimate interests.

PART B. TERMS APPLICABLE TO THE PTP CARD

B.1. Scope of Application

B.1.1. This Part B applies to the use of PTP Card payment cards, including virtual and physical cards (the “Cards”), as well as to services related to their issuance, activation, use, and servicing (the “Card Services”).

B.1.2. Your use of the Card Services constitutes your acceptance of this Part B, as well as any additional terms, notices, Confirmations, fees, limits, and rules published or made available through the Access Interfaces.

B.2. Card Issuers and Nature of the Service

B.2.1. PTP Cards are issued exclusively by third parties — card issuers that are licensed financial institutions or payment organizations holding all necessary authorizations and licenses in accordance with applicable law and the rules of the relevant payment systems.

B.2.2. The Group is not a bank and is not a card issuer. The Group provides the Card Services solely as a technological, informational, and interface-based service granting access to card products issued by such licensed issuers.

B.2.3. The use of a Card is governed by:

B.3. Card Issuance and Activation

B.3.1. The issuance of a virtual and/or physical Card is carried out upon your request through the Access Interfaces and subject to the successful completion of onboarding and verification procedures.

B.3.2. Prior to using the Card, you must complete its activation in accordance with the procedure made available through the Access Interfaces.

B.3.3. The Card is issued personally in your name.

Use of the Card by third parties, including nominee, proxy, or shared usage, is prohibited unless expressly permitted by these Terms or applicable issuer rules.

B.4. Card Use and Transactions

B.4.1. Cards may be used to pay for goods and services at merchant locations and in online environments that accept cards of the relevant payment system, as well as for other transactions permitted by the issuer.

B.4.2. All card transactions must comply with:

B.4.3. The Group does not guarantee acceptance of the Card by all merchants and bears no liability for refusal by third parties to accept the Card.

B.5. Card Balances and Settlements

B.5.1. Use of the Card is possible only within the available balance reflected through the relevant Services (including a Virtual Account or Custodian Wallet).

B.5.2. All fees, conversion rates, limits, and other transaction parameters are communicated to you through the Access Interfaces or in a Confirmation and are binding for the relevant transaction.

B.6. Fees and Limits

B.6.1. Fees for issuance, maintenance, and use of the Card, as well as applicable limits, are published through the Access Interfaces and form an integral part of these Terms.

B.6.2. The Group reserves the right to amend fees and limits in accordance with Part A of these Terms.

B.7. Security and User Responsibility

B.7.1. You are obliged to ensure the safekeeping of the Card, card details, PIN codes, authentication credentials, and other security data.

B.7.2. All transactions performed using a properly activated Card and applicable authentication means are deemed to have been carried out by you, unless otherwise determined under applicable law.

B.7.3. The Group bears no liability for losses arising from:

B.8. Disputes, Claims, and Refunds

B.8.1. If you believe that a card transaction was executed erroneously, unauthorized, or incorrectly, you may submit a dispute through the Access Interfaces or by contacting the Service’s support team.

B.8.2. A dispute must be submitted within the time limits established by the rules of the relevant payment system and/or the card issuer. Failure to meet such deadlines may result in the inability to process the dispute.

B.8.3. Disputes are reviewed in accordance with:

The final decision on a dispute is made by the card issuer and/or the payment system.

Chargebacks and disputes in relation to Card transactions are governed by the rules and procedures of the relevant card issuer and payment scheme. The initiation of a chargeback does not guarantee a refund, and the outcome of any chargeback is determined solely by the card issuer and/or the payment scheme.

The Group does not guarantee the success of any chargeback and shall not be liable for any losses resulting from the rejection or unsuccessful resolution of a chargeback.

Any provisional or temporary credit granted in connection with a chargeback is conditional and may be reversed in accordance with the applicable issuer or payment scheme rules. The Group does not control or influence the chargeback process, timelines, evidentiary assessment or outcome.

B.8.4. The dispute review period may be up to ninety (90) calendar days, unless a different period is specifically established by the issuer or the payment system.

B.8.5. The Group may request additional information or documents from you. Failure to provide such information may result in refusal to consider the dispute.

B.9. Suspension and Termination of Card Services

B.9.1. The Group may restrict, suspend, or terminate the issuance, use, or servicing of a Card on objective grounds, including:

B.9.2. In such cases, access to the Card and related transactions may be temporarily or permanently restricted to the extent permitted by applicable law.

B.9.3. If no successful payment transactions have been made using a Card for a continuous period of more than forty-five (45) calendar days from the date of its issuance, activation or the last successful payment transaction, whichever occurs later, the Card may be temporarily or permanently blocked by the relevant Card Issuer in accordance with the rules of the applicable Card Program.

Depending on the rules of the applicable Card Program, such blocking may be irreversible, and reactivation of the Card or restoration of access to it may not be possible.

Any remaining Card Balance shall be governed by the rules of the applicable Card Program, the Card Issuer's terms, these Terms and Applicable Law.

B.10. Final Provisions

B.10.1. All notices, confirmations, and terms provided through the Access Interfaces or in the form of a Confirmation form part of the contractual relationship within the Card Services.

B.10.2. This Part B applies in conjunction with Part A and other applicable parts of these Terms.

PART C. SWAP TRANSACTIONS

C.1. General Provisions

C.1.1. Swap Transactions are transactions involving the exchange of digital assets or other supported units of account, initiated by the User through the Access Interfaces to the Services.

C.1.2. The Group provides solely technical and interface-based access to the Swap Transactions functionality and is not a party to the exchange transactions, does not act as an exchange, broker, dealer, market maker, or liquidity provider.

C.2. Execution of Swap Transactions

C.2.1. Swap Transactions are executed using third-party exchanges, digital asset exchange service providers, brokers, or other third parties — partners of the Group (collectively, the “Swap Service Providers”).

C.2.2. The relevant Swap Service Providers:

C.2.3. The Group does not guarantee:

Swap Transactions are subject to market volatility, liquidity conditions and execution constraints of third-party Swap Service Providers. As a result, Swap Transactions may be executed at a different rate than the rate displayed at the time of confirmation (slippage), may be partially executed, or may be cancelled or rejected in whole or in part due to insufficient liquidity or other execution limitations.

The Group does not guarantee full or immediate execution of any Swap Transaction and shall not be liable for any losses resulting from slippage, partial execution, or cancellation of Swap Transactions.

C.3. Licenses and Regulation

C.3.1. Swap Transactions are carried out exclusively through Swap Service Providers which, based on information provided by them to the Group, hold all licenses, registrations, or authorizations required by applicable law to provide the relevant services.

C.3.2. The Group does not provide investment, brokerage, dealer, or other regulated financial services and does not carry out activities requiring licensing as a crypto exchange or investment services provider.

C.4. Rates, Fees, and Settlements

C.4.1. Exchange rates, fees, and other parameters of Swap Transactions:

C.4.2. Upon confirmation of a Swap Transaction, the User agrees to the applicable exchange rates, fees, and execution terms.

C.5. No Investment Advice

C.5.1. The Group:

C.5.2. The User independently makes all decisions related to Swap Transactions and bears all risks associated therewith.

C.6. Restrictions and Refusal to Execute Transactions

C.6.1. The Group may suspend, restrict, or refuse to process Swap Transactions if, in its reasonable opinion, such transactions:

C.7. Liability

C.7.1. The Group shall not be liable for:

C.7.2. The Group’s liability is limited to providing access to the Services in accordance with these Terms.

PART D. WALLETS AND VIRTUAL ACCOUNTS

D.1. General Provisions

D.1.1. This Part D governs the use by Users of the following components of the Services:

D.1.2. The above components are provided to the User solely as technological and interface-based solutions and do not constitute bank accounts, payment accounts, electronic money, or other regulated financial products, unless expressly stated otherwise in these Terms or required by applicable law.

D.2. Custodian Wallet

D.2.1. The Custodian Wallet provides the User with interface-based access to digital assets that:

D.2.2. The Group:

D.2.3. Custodial services are provided by third parties — partners of the Group which, based on the information provided by them, hold the licenses, registrations, or authorizations required in the applicable jurisdictions.

D.2.4. The availability of digital assets, applicable limits, fees, technical parameters, and transaction conditions via the Custodian Wallet may be determined by the relevant third parties and the applicable rules of such partners.

D.3. Virtual Account

D.3.1. A Virtual Account is a virtual accounting mechanism used solely to reflect transactions and balances within the Services.

D.3.2. A Virtual Account:

D.3.3. Any fiat transactions related to a Virtual Account are carried out through third-party payment partners, on the terms and in accordance with the rules of such third parties.

D.4. Transactions and Irreversibility

D.4.1. The User acknowledges and agrees that:

D.4.2. The Group shall not be obliged to compensate losses arising from:

Digital Assets and Wallet Services may be affected by events outside the Group’s control, including blockchain forks, airdrops, network congestion,suspension or cessation of blockchain networks.

The Group does not guarantee support for any forked assets, airdropped tokens or new blockchain networks and may, at its sole discretion, decide whether to support, credit, list or make available any such assets or events.

The Group shall not be liable for any losses, delays or unavailability of Digital Assets resulting from blockchain forks, airdrops or network outages.

D.5. Restrictions and Suspension of Access

D.5.1. The Group may suspend, restrict, or terminate the User’s access to the Custodian Wallet and/or Virtual Account, in whole or in part, where necessary for:

D.6. Disclaimer of Warranties

D.6.1. The Group does not guarantee:

PART E. OTHER THIRD-PARTY SERVICES

E.1. General Provisions

E.1.1. Within the Services, the User may be granted access to certain services, features, or functionalities that are provided in whole or in part by third parties — partners of the Group (Other Third-Party Services).

E.1.2. Such Other Third-Party Services may be made available to the User through the Access Interfaces to the Services, including, without limitation, the website (Website) and the Mini-App, and are provided in addition to the Group’s core Services.

E.2. Nature of Other Third-Party Services

E.2.1. Other Third-Party Services may include, without limitation:

E.2.2. Unless expressly stated otherwise, the Group is not the provider of Other Third-Party Services and acts solely as:

E.3. Third-Party Terms

E.3.1. The use of Other Third-Party Services may be governed by separate terms, rules, or policies of the relevant third parties.

E.3.2. The User agrees that, prior to using such services, the User is solely responsible for reviewing and accepting the applicable third-party terms, where required.

E.3.3. In the event of any conflict between these Terms and the terms of the relevant third parties, the terms of the third parties shall prevail to the extent necessary for the use of the relevant Other Third-Party Service.

E.4. Liability and Limitations

E.4.1. The Group does not control and shall not be liable for:

E.4.2. The Group does not guarantee:

E.4.3. Any claims, demands, or disputes arising in connection with the use of Other Third-Party Services shall be resolved directly between the User and the relevant third party, unless otherwise required by applicable law.

E.5. Modification and Termination of Access

E.5.1. The Group may, at any time, at its sole discretion and without prior notice:

E.5.2. Termination of access to Other Third-Party Services shall not affect the validity of these Terms with respect to the other Services.

PART F. Rewards Program Rules

1. General Provisions

1.1. The Rewards Program (the “Program”) allows the User to allocate digital assets within the Service for a selected period and receive variable rewards in accordance with these Rules.

1.2. The Program does not constitute a bank deposit, savings account, investment product, or asset management service.

1.3. Rewards are variable, not guaranteed, and depend on the Program conditions, the operational activity of the Service, and other factors.

1.4. Participation in the Program is voluntary and is carried out by electronic acceptance of these Rules within the Service interface.

2. Participation Mechanics

2.1. The User may transfer digital assets to a separate program balance (“Program Balance”) and select a participation period.

2.2. Allocated assets are locked for the selected participation period, except in cases of early exit as provided in these Rules.

2.3. Rewards are accrued on a daily basis and displayed in the Service interface.

3. Reward Accrual and Withdrawal

3.1. Rewards are accrued daily in accordance with the selected participation conditions.

3.2. The User may withdraw available accrued rewards to their main balance at any time.

3.3. Withdrawal of rewards does not affect the lock period of the allocated assets.

3.4. Availability of withdrawals may depend on technical and operational conditions of the Service.

4. Early Exit from the Program

4.1. The User may exit the Program at any time without waiting for the end of the selected participation period.

4.2. In the event of early exit by the User:

4.3. Consequences of Early Exit

4.3.1. Allocated assets shall be considered unlocked from the moment they are actually returned to the User’s main balance.

4.3.2. Early exit does not guarantee the preservation of accrued rewards and may result in their full cancellation or retention of previously withdrawn amounts.

5. Participation Periods and Estimated Reward Rates

Estimated reward rates are provided for informational purposes only, may change, and are not guaranteed.

6. Sources of Rewards

6.1. Rewards may be generated from:

6.2. Rewards do not constitute interest on a bank deposit, loan, or investment instrument.

7. Limitations and Disclaimer of Guarantees

7.1. The Service does not guarantee:

7.2. Participation in the Program does not create a relationship of bank deposit, loan, investment advisory, or trust management of assets between the Service and the User.

The Company may provide access to staking services through third-party service providers.

The Company does not directly perform staking activities and does not act as a validator, node operator, asset manager, investment advisor, or fiduciary in relation to any staking services.

All staking activities, including validation, reward generation, and custody (where applicable), may be conducted by independent third-party providers.

The Company does not guarantee any specific rewards, returns, or performance and shall not be liable for any losses arising from the actions, omissions, insolvency, or technical failures of such third-party providers.

By participating in staking, the User acknowledges and accepts that staking involves blockchain protocol risks, smart contract risks, slashing risks, market volatility, and counterparty risks.

8. Changes to Program Conditions

8.1. The Service reserves the right to change reward rates, participation periods, and other Program conditions unilaterally.

8.2. Changes shall take effect from the moment they are published in the Service interface or on the official website.

9. Final Provisions

9.1. The User’s participation in the Program constitutes full and unconditional acceptance of these Rules.

9.2. This Appendix forms an integral part of the Service User Agreement.

ANNEX 1. DEFINITIONS

Unless the context expressly requires otherwise, the following terms used in these Terms shall have the meanings set out below:

Account — a User account created by the Group for the purpose of providing access to and enabling the use of the Services, which may include a Custodian Wallet and/or a Virtual Account, as applicable.

Applicable Law — any laws, statutes, regulations, regulatory requirements, rules, directives, or other binding legal provisions in force in the relevant jurisdiction.

Confirmation — an electronic message, notice, or other document provided to the User in connection with a specific transaction performed within the Services, containing the key parameters of such transaction, including the amount, fees, exchange rate, limits, and other applicable terms.

Custodian — a third party, being a partner of the Group, that provides custodial services in respect of the User’s digital assets.

Custodian Wallet — interface-based access provided to the User to digital assets that are held and serviced by a Custodian, without the transfer of control over such assets to the Group.

Chargeback - a procedure initiated by a cardholder through the card issuer to dispute and seek a reversal of a Card Transaction in accordance with the rules of the applicable card issuer and/or payment scheme (including Visa or Mastercard), whereby the final decision is made by the card issuer and/or the payment scheme and does not constitute a guaranteed refund.

Digital Assets — cryptocurrencies, tokens, or other digital units of account supported within the Services.

Event of Default — any circumstance expressly specified in these Terms upon the occurrence of which the Group is entitled to suspend, restrict, or terminate the provision of the Services.

Fees — any fees, charges, or other payments payable by the User in connection with the use of the Services.

Group / we / us / our — the PTP group, including its affiliated entities involved in the provision of the Services.

Interfaces / Access Interfaces — the website, the Mini-App (including Telegram), and any other interfaces through which access to the Services is provided.

Other Third-Party Services — any services, features, or functionalities provided in whole or in part by third parties — partners of the Group, access to which may be made available through the Access Interfaces.

PTP Card — a virtual and/or physical payment card issued by a third-party issuer — a partner of the Group — and made available to the User within the Services.

Services — the aggregate of services, features, and functionalities provided by the Group to the User, including, without limitation, the PTP Card, Swap Transactions, Custodian Wallet, Virtual Account, and Other Third-Party Services.

Swap Service Providers — third-party exchanges, brokers, or other third parties — partners of the Group — that directly execute Swap Transactions.

Swap Transactions — transactions involving the exchange of digital assets, initiated by the User through the Services and executed by Swap Service Providers.

Virtual Account — a virtual accounting mechanism used to reflect the User’s transactions and balances within the Services, which is not a bank account, payment account, or electronic money account.

Wallet Balance / Virtual Account Balance — the accounting balance of digital assets or funds reflected, respectively, in the Custodian Wallet or the Virtual Account.

You / your — a natural person using the Services in accordance with these Terms.