User Agreement

BitFrog Platform

The BitFrog platform (hereinafter the “Platform” or “we/us/our”) allows its users (hereinafter the “User” or “you”) to trade Digital Assets (as defined in this Agreement) and provides other services related to Digital Assets (collectively, the “Services”). For convenience, you and we are collectively referred to as the “Parties” and individually as a “Party.”

You understand that the Site (as defined in this Agreement) serves only as the platform through which you access and use the Services. You should exercise your own judgment to carefully evaluate the authenticity, legality, and validity of the relevant Digital Assets and/or information, and you shall bear any responsibilities and losses that may arise therefrom.

Any opinions, information, discussions, analyses, prices, and other information displayed on the Platform shall not be construed as investment advice. We are not liable for any losses, whether direct or indirect, including but not limited to loss of profits, arising from reliance on such information.

Unless you maintain an Account (as defined in this Agreement) on the Platform, you may not use the Services intended for users who hold an Account.

1.1 Risks

By using the Services provided on the Platform, you accept the risks associated with such Services. We emphasize that:

(i) Digital Assets available on the Platform may not be issued by us, by financial institutions, or by other legal entities; (ii) The Digital Asset market is new, uncertain, and may not grow; (iii) Digital Assets are inherently highly speculative and are not as mature as other asset classes; (iv) Digital Assets are volatile, trade continuously, and their prices are not subject to limits; (v) Trading Digital Assets may result in partial or total loss of your capital; (vi) Actions by third parties, such as market makers or governments, may materially impact Digital Assets; (vii) Digital Asset trading is not suitable for most people; (viii) Although we endeavor to comply with all applicable laws, rules, and regulations, we may not be regulated in every jurisdiction in which we operate; and (ix) In addition to the above, other unpredictable or derivative risks may exist.

Before using the Services, please consider your own financial situation and, if necessary, seek independent legal, financial, tax, accounting, or other advice.

1.2 Restricted Jurisdictions

Users from the following jurisdictions are prohibited from using any Services: Mainland China, the United States, Canada, Japan, Cuba, Iran, North Korea, Sudan, Syria, Venezuela, Singapore, and Crimea.

Users from the following jurisdictions are prohibited from trading derivatives: Hong Kong (China), Israel, Iraq, Bangladesh, Bolivia, Ecuador, Kyrgyzstan, Sevastopol, and the United Kingdom (retail users only).

The list of Restricted Jurisdictions may change or vary in accordance with our policies and changes to the Services we offer in particular jurisdictions. We may not notify you of such changes. You should check the Platform or this Agreement for the latest information.

1. General Terms

This User Agreement, as updated from time to time (hereinafter this “Agreement” or these “Terms and Conditions”), includes this User Agreement, the Privacy Policy, Fiat Rules, KYC (“Know Your Customer”) and AML policies, the user agreement or terms and conditions for each Service, and any other guidelines, rules, statements, and instructions published on the Platform from time to time.

Before accessing the Services via the Platform, you should read this Agreement carefully and seek independent legal advice if necessary. If you do not agree with or do not understand this Agreement, please immediately close your Account and stop using the Services. By clicking “I Agree,” creating an Account, obtaining your account identification number and creating a password, logging into your Account, or using the Services, you shall be deemed to have understood and fully agreed to this Agreement and to be bound by it (including any modifications made to this Agreement from time to time).

All headings in this Agreement are for convenience only and are not intended to expand or limit the content or scope of the terms and conditions herein. Information on the Platform and all information in this Agreement are provided “as is” and “as available,” and no further undertakings are made. Headings are for convenience only and do not affect the meaning or interpretation of any clause.

1. Definitions

“Account” means the account you create on the Platform.

“Agreement” means the BitFrog Platform User Agreement.

“AML/CTF” means anti-money laundering/combating the financing of terrorism.

“Business Day” means a day on which banks are open for business, other than Saturdays, Sundays, or public holidays published in the gazette.

“Buy Price” has the meaning set out in Clause 7.1.

“Compensation Amount” has the meaning set out in Clause 15.1.

“Processing Your Account” has the meaning set out in Clause 4.4.

“Digital Assets” means values represented in digital form supported by the Platform, which can be transmitted, stored, and traded electronically.

“Dispute” has the meaning set out in Clause 17.11.

“Exchange Rate” has the meaning set out in Clause 7.1.

“Fork” has the meaning set out in Clause 6.2.

“ICC International Court of Arbitration” has the meaning set out in Clause 17.11.

“Identity Information” has the meaning set out in Clause 10.1.

“Intellectual Property Rights” has the meaning set out in Clause 11.

“Internal Resolution” has the meaning set out in Clause 17.11.

“Login Details” has the meaning set out in Clause 4.3.

“Miner Fees” has the meaning set out in Clause 6.1.

“Party” means a party to this Agreement, namely the User and the Platform.

“Platform” means the BitFrog platform.

“Pre-Closure Period” has the meaning set out in Clause 4.4.

“Registration Data” has the meaning set out in Clause 4.1.

“Sanctioned Countries” has the meaning set out in Clause 17.8.

“Sanctioned Person” has the meaning set out in Clause 17.8.

“Sell Price” has the meaning set out in Clause 7.1.

“Services” means the products and services provided to Users through the Platform.

“Trading Fees” has the meaning set out in Clause 8.

“Transaction” has the meaning set out in Clause 4.2.

“User” means a user of the BitFrog Platform.

“Site” means the website or other gateway, such as a mobile application, through which users can access the Platform to use the Services.

4.1 Account Creation

To be eligible to create an Account, you confirm you are a natural person, legal person, or other entity authorized to enter into this Agreement and to use the Services in compliance with all applicable laws, rules, and regulations. You must not create an Account for the purpose of violating any applicable laws, rules, and regulations and/or undermining the Services provided on the Platform.

If you are not eligible to create an Account, we reserve the right to refuse your registration. If you have already created an Account, we may suspend, terminate, and/or close your Account without further notice and may hold you responsible for any adverse consequences arising therefrom. We reserve the right, at our sole discretion, to reject any application to create an Account (including but not limited to accounts related to political and/or public figures) or to comply with AML/CTF laws and regulations.

To create an Account, you should provide, as necessary:

(i) a valid email address; (ii) a mobile phone number; (iii) your real name; (iv) identification documents; and (v) any other information we require to create and maintain your Account,

collectively, the “Registration Data.”

If your mobile phone number requires real-name registration, you should complete such registration before providing the number to us. You are responsible for any direct or indirect losses and adverse consequences arising from failing to complete such registration.

You are responsible for updating the Registration Data to ensure its accuracy at all times. You are responsible for the authenticity, completeness, and accuracy of the Registration Data and shall bear any direct or indirect losses and adverse consequences arising from inaccuracies.

Upon our verification and approval of your Account, you will receive an account identification number and password with which you may use the Services. You agree to receive emails and/or messages from us relating to Platform administration and operations.

4.2 Account Use

You are entitled to use your Account to access the Platform and the Services, including:

(i) viewing real-time quotes and trading information for Digital Asset products on the Site; (ii) submitting Digital Asset trading instructions, whether for trades or other instructions (collectively, “Transactions”); (iii) completing Transactions; (iv) viewing information provided to Users through your Account; (v) participating in activities organized by us in accordance with the relevant rules; and/or (vi) other Services we may provide to you from time to time.

4.3 Account Security

You are solely responsible for your Account’s Login Details, including your username, password, mobile phone number, trading password, and verification codes received on your phone (“Login Details”). If your Login Details are stolen and/or your Account is accessed by an unauthorized third party, you may immediately notify us to request suspension of your Account. Upon receipt of such request, we will act within a reasonable time; however, we are not responsible for any consequences before the suspension takes effect.

Unless approved by us, you shall not transfer your Account to any other person by donation, lending, leasing, assignment, or otherwise.

If any Digital Asset, password, or private key is lost, stolen, becomes defective, is damaged, or otherwise becomes inaccessible, we are under no obligation to issue any replacement Digital Asset.

4.4 Suspension, Termination, or Closure

We are entitled to suspend part or all of the Services to your Account, freeze Digital Assets in your Account, terminate your Account, close your Account, and/or notify relevant authorities (“Processing Your Account”) if:

(i) we reasonably consider this necessary to protect our reputation; (ii) your Account is subject to any pending litigation, investigation, or governmental proceeding and/or we consider your Account activity to present an increased risk of illegal or non-compliant conduct; (iii) you are from a Restricted Jurisdiction as described in Clause 1.2; (iv) you are not eligible to create an Account under Clause 4.1; (v) you create an Account on behalf of a legal entity without proper authorization to act for that entity; (vi) we, in our sole discretion, deem you unsuitable for the Services; (vii) you are not the person described in your Account Registration Data; (viii) you fail to log in to your Account for 1 year; (ix) you use your Account for unlawful or illegal activities, such as money laundering or bribery; (x) you use your Account for market manipulation, improper trading, or other illegal trading activities such as money laundering, smuggling, or commercial bribery; and/or (xi) you violate this Agreement or any other applicable laws, rules, or regulations.

Notwithstanding the foregoing, we may, upon 7 Business Days’ prior notice, close and terminate your Account. Thereafter, you will have 7 Business Days to take necessary actions, including canceling any instructions or closing positions (the “Pre-Closure Period”). After the Pre-Closure Period ends, we may cancel your instructions, close positions, and return the Digital Assets in your Account to you. Notwithstanding anything to the contrary, if your Account is closed under this clause, all remaining Account balances (including fees and liabilities owed to us) become immediately due and payable to us.

We shall not be responsible for any adverse consequences and/or losses related to Processing Your Account.

If an Account is suspended or closed due to fraud investigations, unlawful conduct, or investigations of a breach of this Agreement, we will fully preserve Digital Assets, funds, and user information/data which may be handed over to governmental authorities.

1. Deposits, Custody, Withdrawals, and Transfers

The Services are provided only for Digital Assets supported by us and may change from time to time. Under no circumstances should you use your Account to store, send, request, or receive Digital Assets in any form not supported by us. We assume no responsibility or liability if you attempt to use your Account for unsupported Digital Assets. We do not act as a buyer or seller in any Digital Asset transaction when providing the Services. The Services do not include the deposit, withdrawal, or custody of any fiat currency.

All Digital Assets in your Account are held by us on a custodial basis. This means:

(i) ownership of the Digital Assets remains with you and is not transferred to us. You bear the risk of loss of the Digital Assets in your Account. We will not claim or treat the assets in your Account as belonging to us; (ii) we may not grant any security interest over the Digital Assets held in your Account; (iii) except as required by competent authorities or otherwise provided in this Agreement, we will not sell, transfer, lend, pledge, or otherwise encumber assets in your Account unless instructed by you or ordered by a court of competent jurisdiction; (iv) you control the Digital Assets in your Account. Subject to interruptions, downtime, and other applicable policies, you may withdraw your Digital Assets at any time by sending them to another blockchain address controlled by you or a third party; and (v) for safer custody of your assets, your Digital Assets are accounted for separately from our own assets or funds—that is, user and Platform accounts are maintained under distinct ledger accounts. Notwithstanding the foregoing, we are under no obligation to use separate blockchain addresses to store Digital Assets belonging to you, other customers, or us.

We are entitled to set and adjust daily limits on trading volume and withdrawals at our internal discretion, including considerations of the security and status of the relevant Digital Asset networks.

1. Digital Asset Networks

6.1 Digital Asset Transactions

We will process Transactions based on your instructions. Before submitting instructions, you should verify all Transaction information. We do not guarantee the identity of any user, recipient, requestee, or third party, nor are we obligated to ensure the accuracy or completeness of the information you provide. Once broadcast to the relevant Digital Asset network, a Transaction cannot be reversed.

We may charge network fees (“Miner Fees”) to process your Transactions. We will calculate Miner Fees at our discretion, but will always inform you of the Miner Fees at or before your authorization of a Digital Asset Transaction. When you or a third party sends Digital Assets from an external wallet not hosted by the Platform to your Account, the party initiating the Transaction is responsible for executing it correctly, including paying the Miner Fees to facilitate successful completion. Failure to pay Miner Fees may result in your Transaction remaining pending beyond our control; we are not liable for delays or losses resulting from errors in initiating Transactions and are not obligated to assist in remedying such Transactions.

Once submitted to a Digital Asset network, Transactions remain pending for a period until sufficiently confirmed by the network. Pending Transactions are incomplete. Digital Assets related to pending Transactions will be locked accordingly and will neither be reflected in your Account balance nor be available for trading until network confirmation.

We may refuse to process or cancel any pending Transaction as required by laws, regulations, or any court or competent authority with jurisdiction over us, for example, when money laundering, terrorist financing, fraud, or other financial crimes are suspected.

6.2 Operation of Digital Asset Protocols

We do not own or control the software protocols governing the operation of the Digital Assets supported by the Platform. Generally, such protocols are “open source,” and anyone may use, copy, modify, and distribute them.

We assume no responsibility for the operation of such protocols and cannot guarantee the functionality or security of network operations. You acknowledge and accept the risk that software protocols for any Digital Asset stored in your Account may change.

In particular, the relevant protocols may be affected by sudden changes in operating rules (a “Fork”). Any such material operational change may significantly impact the availability, value, functionality, and/or name of Digital Assets stored in your Account. We do not control the timing or characteristics of such material changes. You are responsible for staying informed about upcoming operational changes and must carefully consider publicly available information and any information we may provide when deciding whether to continue to use your Account to transact in affected Digital Assets. If any such change occurs, we may take necessary measures to protect assets on the Platform, including suspending operations for the affected Digital Asset and taking other necessary steps.

We will make reasonable efforts to notify you of our response to any material operational change. However, such changes are outside our control and may occur without notice to us. Our response to any material change is at our sole discretion, including deciding not to support any new Digital Asset, Fork, or other action.

You acknowledge and accept the risks of operational changes to Digital Asset protocols and agree that we are not responsible for such changes and are not liable for any loss of value you may suffer due to changes in operating rules. You acknowledge and accept that we may respond to any operational change at our sole discretion and that we have no obligation to assist you in handling unsupported assets or protocols.

6.3 Trading Rules

You shall comply with the following rules when trading Digital Assets on the Platform:

(i) Before executing any Transaction, you should read, understand, and fully accept information on the Platform, including but not limited to prices, fees, and whether to buy or sell the Digital Assets; (ii) When you execute a Transaction and submit your order, you authorize the Platform to act as your broker to match a counterparty, without further notice to you; (iii) You have the right to cancel or modify your order at any time before execution; and (iv) You may view your Transaction details and records in the Platform’s management center.

7.1 Exchange Rate

Each purchase or sale of Digital Assets is subject to the exchange rate applicable to the specific Transaction. “Exchange Rate” means the fiat currency price quoted on the Platform for a specific supported Digital Asset. The Exchange Rate is expressed as a “Buy Price” or a “Sell Price,” which is the price at which you can buy or sell a Digital Asset.

You acknowledge that at any particular time, the Buy Price may differ from the Sell Price, and we may include a margin or “spread” in the quoted Exchange Rate. By authorizing a Transaction, you agree to the Exchange Rate. We do not guarantee the availability of any Exchange Rate. We do not guarantee that you will be able to buy and/or sell your Digital Assets at any specific price or time in the open market.

1. Fees

You agree to be responsible for all fees. Each purchase or sale of Digital Assets is subject to fees (“Trading Fees”). Trading Fees will be shown to you on the Platform before each Transaction and will be stated on the receipt we send to you. We may adjust our Trading Fees at any time.

1. Compliance

Our KYC and AML/CTF policies are designed to comply with international laws and standards concerning KYC and AML/CTF, including those in your local jurisdiction. We will comply with our KYC and AML/CTF policies and will use best efforts to take measures and employ relevant technologies to provide the Services safely and reliably and to prevent losses arising from money laundering.

You authorize us, directly or through third parties, to make inquiries we deem necessary to verify your identity or to protect you and/or us against fraud or other financial crimes, and to take actions we reasonably deem necessary based on the results. In conducting such inquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies, which may respond in full to our inquiries. This is an identity check and should not adversely affect your credit rating. In addition, we may require you to wait a period after completing Transactions before allowing you to access more Services and/or execute Transactions beyond certain volume limits.

If we learn that any Digital Assets or funds in your Account are stolen or not lawfully owned by you, we may (but are not obligated to) administratively freeze the affected funds and your Account. If we impose an administrative freeze on some or all of your funds or Account, we may continue the freeze until the dispute is resolved and we receive acceptable evidence of resolution in a form satisfactory to us. We will not participate in such disputes or their resolution. You agree that we are not liable for any freeze as described above or for your inability to withdraw Digital Assets or funds or to execute Transactions during the freeze.

1. KYC and AML/CTF

With respect to KYC and AML/CTF, we:

(i) shall promulgate and update our KYC and AML/CTF policies to meet standards prescribed by applicable laws, rules, and regulations; (ii) shall promulgate and update guidelines and rules related to the operation of the Platform, and our staff shall provide the Services to you in accordance therewith; (iii) shall design and implement Transaction monitoring procedures, including but not limited to strict identity verification procedures, and maintain a dedicated team to address anti-money laundering issues; (iv) shall adopt a risk-based approach to conduct due diligence and supervision of our users; (v) are entitled to review and inspect Transactions conducted on our Platform; (vi) are entitled to report Transactions we, in our sole judgment, deem suspicious to relevant authorities; and (vii) shall retain Registration Data and Identity Information (as defined herein) for at least 6 years.

10.1 Identity Information

If you are an individual, we will collect certain information including but not limited to your:

(i) name; (ii) address (and your residential address if different). Your address (or residential address) shall be verified in the manner we prescribe; (iii) valid email address; (iv) date of birth; (v) nationality; (vi) photograph of you holding your identification document; (vii) official identification documents, including passport, national ID card (front and back), and other government-issued IDs; and (viii) any other information we may require from time to time,

collectively, “Personal Identity Information.”

If you are a legal entity other than an individual, we will collect certain information including but not limited to your:

(i) registration and incorporation documents; (ii) articles of association or memorandum; (iii) ownership structure and a description thereof; (iv) board resolution designating authorized persons responsible for your Account; (v) identification documents of directors, principal shareholders, and authorized persons. Generally, shareholders who hold 10% or more of voting rights must be identified; (vi) your address; and (vii) any other information we may require from time to time,

collectively, “Corporate Identity Information,” together with Personal Identity Information, “Identity Information.”

The Identity Information we require may vary depending on your jurisdiction, and we may require notarization of copies of documents you provide to us. If your Identity Information is not provided in English or Chinese, we may require translation into English and notarization.

10.2 Transaction Reporting

We will monitor the activity in your Account to detect suspicious Transactions. If we determine that a Transaction related to your Account is suspicious, we may suspend, stop, or terminate the Transaction, reverse it, and/or report it to relevant authorities without further notice. Any action we take concerning suspicious Transactions will not constitute a breach of this Agreement.

1. Intellectual Property Rights

All Intellectual Property Rights related to the Platform—including but not limited to the site name, goodwill, trademarks, logos, databases, website design, text and graphics, software, photos, videos, music, sounds, any combination of the foregoing, as well as software compilations, related source code, and software (including applets and scripts)—(“Intellectual Property Rights”) belong to us. You shall not copy, modify, reproduce, transmit, or use any Intellectual Property Rights for commercial purposes. Your use of the Services does not grant you any rights in the Intellectual Property Rights.

By accepting this Agreement, you are deemed to have transferred to us, free of charge, all copyrights in any form of information you publish on the Site, including but not limited to the rights of reproduction, distribution, rental, exhibition, performance, screening, broadcasting, information network dissemination, filming, adaptation, translation, compilation, and other transferable rights enjoyed by the copyright owner. We are entitled to bring claims and recover full compensation for any infringement of such copyrights. This Agreement applies to any content protected by copyright law that you publish on the Site, whether generated before or after the execution of this Agreement.

You shall not unlawfully use or dispose of our or any other person’s Intellectual Property Rights when using the Services. You shall not publish or authorize other websites or media to use the Intellectual Property Rights in any manner.

1. Rights and Obligations

Notwithstanding anything to the contrary, we reserve the right, at our sole discretion, to:

(i) modify information displayed on the Site in the event of errors or updates; (ii) modify, suspend, or terminate any or all of the Services at any time without notice. Such termination shall take effect from the date of announcement on the Site; (iii) suspend or permanently terminate your access to your Account, the Platform, or any or all Services; (iv) notify you to correct or update information you provided to us if we suspect or determine it to be incorrect, untrue, invalid, and/or incomplete, and suspend or terminate the Services if you fail to correct or update such information; (v) remove from the Platform any content or information that does not comply with applicable laws, rules, or regulations without notice; (vi) request information from you in accordance with applicable laws, rules, and regulations, and you are obligated to assist us in such requests; and (vii) under special circumstances that impede the Services—such as system failure, network failure, or extreme market conditions—modify the Services to protect users’ interests. Such modifications will be announced on the Site.

Unless otherwise provided herein, we shall:

(i) employ necessary technical and administrative measures to ensure normal operation of the Platform and provide a necessary and reliable environment for your use of the Services; (ii) maintain provision of the Services to you; (iii) enhance our technical capabilities and security measures to ensure the safety of your Digital Assets; and (iv) provide advance notice to you of foreseeable security risks related to your Account.

1. Representations and Warranties

By agreeing to this Agreement, you represent, warrant, and/or undertake that:

(i) you have not previously been suspended or barred from using the Services; (ii) you are of legal age, have the capacity, and are authorized to enter into this Agreement and use the Services in compliance with all applicable laws, rules, and regulations; (iii) your use of the Services and your Account activities comply with all applicable laws and regulations; (iv) all your Digital Assets are lawfully obtained and owned by you; (v) you are fully responsible for actions taken through your Account; (vi) you are responsible for all profits, losses, or liabilities arising from your Transactions and use of your Account; (vii) all information you provide to us is true, accurate, and complete; (viii) you will file reports with competent authorities for tax purposes; (ix) you will avoid engaging in any illegal activity through use of the Services; (x) you will always refrain from conduct that damages the Platform’s interests, whether or not related to the Services; (xi) you will not act contrary to the intended use of the Platform, such as facilitating illegal transmission of information, spreading false information about the Platform, infringing our or other users’ rights, inviting others to join pyramid schemes, or forging and forwarding such false information to us or other users; (xii) you will not, by technical means or otherwise, maliciously interfere with the normal operation of the Platform or other users’ use of the Services; (xiii) you will not make or disseminate false defamatory information about us; (xiv) if any dispute arises between you and other users, you shall resort only to judicial means or other government-related processes to request information from us; (xv) you are responsible for all costs and taxes related to any hardware, software, and other third-party services arising from your use of the Services; and (xvi) you shall comply with this Agreement and other guidelines and rules we publish concerning the Platform.

1. Liability and Indemnity

You understand and agree that, in any of the following circumstances, we assume no liability and you shall bear full responsibility:

(i) loss of income; (ii) loss of trading profits; (iii) loss under contract; (iv) business interruption; (v) currency-related losses; (vi) loss or damage to information or data; (vii) loss of opportunity; (viii) loss in the price or value of Digital Assets; (ix) costs of goods and services purchased outside the scope of the Services; (x) any failure of software, hardware, or internet connection and any resulting distortion or delay; (xi) any indirect, special, or incidental loss or damage arising from any tort (including negligence) and/or breach of contract or otherwise, whether or not reasonably foreseeable or whether or not we were advised of the possibility of such loss or damage in advance; (xii) any malicious programs you may encounter while using the Services, such as viruses or trojans; (xiii) information, products, or business on third-party websites linked to the Site; (xiv) losses caused by the effectiveness, accuracy, correctness, reliability, quality, stability, completeness, timeliness, suitability (including fitness for a particular purpose), or freedom from errors or omissions, or consistency of any information or technology on the Platform; (xv) our calculation errors on the Platform; (xvi) damage to: (a) your goodwill or reputation; (b) losses suffered when we reasonably believe your Transactions and/or conduct on the Platform may involve illegal activity or breach of this Agreement; (c) any fees or losses arising from data, information, or Digital Currencies purchased or obtained through the Services; (d) losses arising from your misunderstanding of the Services; and/or (e) any other losses related to the Services not attributable to us.

14.1 Limitation of Liability

Notwithstanding anything to the contrary, our liability to you shall not exceed your total costs during the three (3) months preceding the date on which the event giving rise to liability occurred.

We do not waive any rights not mentioned in this Agreement and, to the maximum extent permitted by applicable law, limit, disclaim, or offset our liability for damages.

If you have a dispute with one or more users of the Services (excluding us), you agree that neither we, our affiliates, service providers, nor our or their officers, directors, agents, joint ventures, employees, or representatives shall be liable for any claims, demands, and damages (actual and consequential, direct or indirect) arising out of or in any way connected with such disputes.

14.2 Indemnity

You agree to indemnify us, our affiliates, and service providers, and our and their officers, directors, agents, employees, and representatives for any costs reasonably incurred (including attorneys’ fees and any penalties, fees, or fines imposed by any regulatory authority) arising from any claim, demand, or damages due to your breach of this Agreement and/or our enforcement of this Agreement, or your violation of any law, rule, regulation, or any third party’s rights.

14.3 Our Warranties

The warranties and undertakings set forth in this Agreement are the sole warranties and representations we make in relation to Services provided under this Agreement and through the Site, and supersede any and all other warranties and undertakings, whether written or oral, express or implied. All such warranties and undertakings represent only our own warranties and undertakings and do not guarantee compliance by any third party with the warranties and undertakings contained herein.

1. Termination for Breach and Remedies

We may terminate all Services provided to you under this Agreement at any time, and this Agreement shall terminate on the date all Services are terminated. You may terminate your use of the Services at any time, and this Agreement shall terminate on the date you cease using the Services. Upon termination of this Agreement, you agree that you are not entitled to require us to continue providing the Services or to perform any other obligations, including but not limited to requiring us to retain or disclose your Account information, or to disclose to you or any third party any unread or unsent information.

15.1 Breach

If you breach this Agreement or any applicable law, rule, or regulation, you shall pay us compensation of not less than USD 2,000,000 and bear all costs incurred by us as a result, including legal fees (the “Compensation Amount”). If the Compensation Amount does not cover our losses, you shall be responsible for any amount in excess thereof.

For the avoidance of doubt, termination of this Agreement does not prejudice the non-breaching Party’s right to hold the breaching Party liable for obligations arising outside this Agreement.

1. Notices and Communications

Users undertake to regularly and promptly review announcements, data, and information on the Platform. We assume no responsibility and will not provide any form of compensation for losses arising from your failure to review such announcements, data, and information.

1. Miscellaneous

17.1 Assignment

The rights and obligations under this Agreement are equally binding on the Parties’ permitted assignees, successors, executors, and administrators. You may not assign any of your rights or obligations under this Agreement to any third party without our consent. We may assign our rights and obligations under this Agreement to any third party at any time upon thirty (30) days’ prior notice to you.

17.2 Force Majeure

We shall not be liable for failure or delay in providing the Services due to maintenance of information network equipment, information network connection failures, computer errors, communication or other systems, power failures, weather, accidents, labor actions, labor disputes, uprisings, riots, lack of productivity or production materials, fire, floods, storms, explosions, war, issues with banks or other partners, collapse of Digital Asset markets, governmental actions, actions of judicial or administrative authorities, or other acts beyond or outside our control or due to third parties, nor for any losses you may thereby suffer.

17.3 Relationship of the Parties

This Agreement binds only the rights and obligations between you and us and does not concern the legal relationships or disputes arising from or related to Transactions between Site users or between other parties and you.

Unless otherwise provided herein, nothing in this Agreement shall be deemed to create, imply, or otherwise make us your agent, trustee, or other representative.

17.4 Entire Agreement

If any provision of this Agreement is held unenforceable, invalid, or illegal by a court of competent jurisdiction, the validity of the remaining provisions shall not be affected.

17.5 Amendments

We reserve the right, in our sole discretion, to revise or modify any content of this Agreement at any time. The date and time displayed in the “Last Updated” section of this Agreement indicate when any changes to the terms or content occurred. The amended Agreement becomes effective immediately upon publication on the Platform. Although we have taken reasonable measures to ensure the accuracy of information on the Platform, we do not guarantee its accuracy and assume no liability for any losses arising directly or indirectly from information on the Platform or from any delays or failures in connecting to the network or in the transmission or receipt of any notices or information.

You are responsible for staying informed of the latest revisions to this Agreement. If you do not agree to such revisions, please stop using the Services immediately. Your continued use of the Services constitutes your acceptance of the terms of this Agreement.

17.6 Survival

All provisions of this Agreement that by their nature should survive expiration or termination shall remain binding and in effect after termination or expiration.

17.7 Data Protection

Your personal data will be properly protected and kept confidential, but we may collect, process, use, or disclose your personal data in accordance with this Agreement or applicable law. Depending on the products or services involved, your personal data may be disclosed to the following third parties:

(i) your counterparties; (ii) our shareholders, partners, investors, directors, supervisors, senior management, and employees; (iii) our joint venture partners, alliance partners, and business partners; (iv) our agents, contractors, suppliers, third-party service providers, and professional advisors, including contracted providers of administrative, financial, research, operations, IT, and other services in telecommunications, information technology, payroll management, information processing, training, market research, and storage; (v) third-party business partners that provide goods and services or sponsor competitions or other promotional activities, whether or not in cooperation with us; (vi) insurers or insurance investigators and credit providers; (vii) credit reference agencies or any debt collection agency or dispute resolution center (in the event of a dispute); (viii) professional advisors such as auditors and lawyers; (ix) relevant government regulatory bodies or law enforcement agencies (for purposes of compliance with laws or regulations implemented by government authorities); (x) assignees of our rights and obligations; (xi) banks, credit card companies, and their respective service providers; and (xii) persons identified by you or relevant contracts and consented to by you.

Collection, use, and storage of your personal information are governed by the Privacy Policy published on the Site.

17.8 Export Controls

Your use of the Services is subject to international export control and economic sanctions requirements. By sending, receiving, buying, selling, trading, or storing Digital Assets using the Services, you agree to comply with such requirements. You may not access Digital Assets or use any Services if:

(i) you are located in, under the control of, or a national or resident of the following countries: Cuba, the Democratic Republic of the Congo, the Democratic People’s Republic of Korea, Iran, Libya, Somalia, South Sudan, Sudan, Yemen, or Syria, or any other country subject to U.S. embargo, United Nations sanctions, or sanctions imposed by the European Union, MAS, or the UK Treasury’s financial sanctions regime (collectively, “Sanctioned Countries”), or if you are listed on sanctions lists published by relevant authorities from time to time (including but not limited to the MAS lists of designated individuals and entities, the U.S. Department of Commerce Denied Persons List, Unverified List, Entity List, or EU financial sanctions regimes) (a “Sanctioned Person”); or (ii) you intend to provide any held or stored Digital Assets or Services to Sanctioned Countries (or nationals or residents thereof) or to any Sanctioned Person.

17.9 No Waiver

A waiver by us or you of the other Party’s breach of this Agreement or of any other liability stated herein shall not be construed or deemed to be a waiver of any other breach of this Agreement. Failure to exercise any right or remedy shall not be construed as a waiver of such right or remedy.

17.10 Governing Law

This Agreement and the relationship between the Parties shall be governed by and construed in accordance with the laws of Singapore.

17.11 Dispute Resolution

You acknowledge and agree that, prior to bringing any Dispute or claim, you will contact us and we will endeavor to resolve the Dispute internally as soon as possible (“Internal Resolution”). The Parties agree to negotiate in good faith to resolve any Dispute (such negotiations shall be confidential, protected by applicable laws, rules, and regulations, and shall not be used as evidence in any litigation).

You acknowledge and agree that if any dispute, controversy, difference, or claim is not resolved by Internal Resolution—including any Dispute regarding the existence, validity, interpretation, performance, breach, or termination of these Terms, or any Dispute related to or arising from these Terms (collectively, a “Dispute”)—the Parties shall submit the Dispute to the ICC International Court of Arbitration under the ICC Rules then in effect. Arbitration shall be conducted in Singapore and governed by the applicable law determined under the ICC Rules. Unless otherwise agreed by the Parties, a sole arbitrator shall be appointed in accordance with the ICC Rules. The arbitrator shall have authority to rule on jurisdiction, including but not limited to objections concerning the existence, scope, or validity of the arbitration agreement or the arbitrability of any claim or counterclaim. The arbitration shall be conducted in English. Regardless of the form of arbitration, the arbitrator shall issue a reasoned written decision explaining the arbitral award and its essential findings and conclusions (if any). The arbitral award shall be final and binding on the Parties and may be enforced by any court of competent jurisdiction.

17.12 Unclaimed Property

If we hold Digital Assets for you but are unable to contact you and there is no record of your use of the Services for several years, applicable law in certain jurisdictions may require us to report the Digital Assets to authorities as unclaimed property. We will attempt to contact you at the address on record; if we cannot locate you, we may be required to deliver such Digital Assets to the authorities in certain jurisdictions as unclaimed property. Where permitted by law, we may deduct dormancy or other administrative fees from such unclaimed funds.

17.13 Class Action Waiver

You agree that any claim related to this Agreement (whether based on contract, tort, statute, fraud, misrepresentation, or any other legal theory, and whether arising during or after the term of this Agreement) shall be brought against the other Party in arbitration on an individual basis and not as a plaintiff or class member in any purported class or representative action. To the extent permitted by applicable law, you further waive any right to bring, have heard, or arbitrate such claims as a class, collective, representative, or private attorney general action. Individual arbitrations may not be consolidated or combined into a single arbitration without the consent of all parties, including us.