• have carefully read, understood and accepted these Terms;
• understand all the risks associated with virtual assets and virtual assets transactions;
• agree to accept any additional terms, rules, and conditions of use that may be issued by Fintopio from time to time; and
• you agree to review and be bound by the terms and conditions of any third-party service providers offering services on or through the Platform.
• agree to the collection, use, disclosure, and other handling of your personal data as outlined in our Privacy Policy and Cookie Policy (https://fintopio.com/privacy-policy and https://fintopio.com/cookie-policy respectively).

“Fintopio Platform” refers to the software provided by Fintopio, which includes any websites, Telegram bot, pages, features, or content owned or operated by Fintopio, any web-application developed or made available by Fintopio, as well as any application programming interfaces (APIs) offered to users or third-party applications dependent on such APIs where users can manage virtual assets wallets and interact with blockchain networks. This also encompasses any other means Fintopio may designate in the future for accessing Fintopio Wallet Services.

“Mini-App” refers to a smaller, lightweight application within the Fintopio ecosystem integrated to, and accessible through and/or within the Telegram messaging app, that provides specific functionalities related to Fintopio Services.

“Telegram integrated Fintopio Bot” refers to a specialized bot within the Telegram messaging app that provides users access to Fintopio Services directly through the Telegram platform.

“User” refers to any individual or entity that uses or accesses the Platform or Fintopio Services or any other services provided by Fintopio or third-parties on the Fintopio Platform.

“Telegram integrated Fintopio Bot” refers to a specialised bot within the Telegram app that provides users access to Fintopio Wallet Services directly through the Telegram platform.

“Fintopio Services” refers to all the features, tools, materials, or services offered on or through the Fintopio Platform, including but not limited to decentralised finance (DeFi) services provided by WALLET LLC, and centralised finance (CeFi) services offered by Fintopio Virtual Assets LLC, a third-party virtual assets services provider (VASP) duly licensed as a Virtual Assets Exchange Operator with registration number: 225012-3301-OOO, and registered address at 9 Razzakov St., Business Center Russia, 9th Floor, Room 900, Perwomaisky district, Bishkek city, Kyrgyz Republic (”CeFi Service Provider” or “Fintopio Kg”). Fintopio Kg is regulated by the Service for Regulation and Supervision of the Financial Market under the Ministry of Economy and Commerce of the Kyrgyz Republic.

“DeFi Services” refers to decentralized financial services provided by Fintopio through the Fintopio Platform, allowing users to create and manage non-custodial wallets; deposit, swap, send, receive, and store virtual assets; and interact with blockchain networks via decentralized application (DApp) websites without intermediaries.

“Non-Custodial Wallet” refers to a type of digital wallet wherein the user retains full control over their private keys and, therefore, full control over their funds.

“СeFi Services” refers to centralised finance services provided by Fintopio Kg on or through the Fintopio Platform, including but not limited to virtual assets transfer, buying, selling, and trading, exchange, conversion, custody, on-ramp, and off-ramp, and other related virtual assets activities as may be provided from time to time by Fintopio Virtual Assets LLC. CeFi services require user identification and are only available to users who have completed the mandatory Know Your Customer (KYC) requirements.

“Custodial Wallet” refers to a wallet provided by Fintopio Kg to a user, through the Fintopio Platform, wherein Fintopio Kg holds and manages the user's private keys on the user's behalf, thereby assuming responsibility for the security and management of the user's funds.

"Know Your Customer (KYC)" refers to the mandatory process undertaken by Fintopio Kg via its affiliates and/or third-party services providers, to verify the identity users of the Fintopio Platform before providing them with access to CeFi Services. It ensures the authenticity of users' identity and assess potential risks of illegal activities with respect to the use of the CeFi Services.

“Third-Party Services” refers to all services provided by third parties, including virtual asset-related services like CeFi Services, that are accessible through or within the Fintopio Platform.

“Third-party Services Providers” refers to entities that offer or provide their services to users on or through the Fintopio Platform to Fintopio Platform users.

“Prohibited Jurisdictions” refers to (i) any jurisdiction in which the entry into these Terms or using of the Fintopio Platform or Services is prohibited by applicable law, and (ii) any jurisdiction that is subject to the sanctions or embargoes introduced or administered by the United States or the United Nations.

Provided that you have complied with, and that you continue to comply with, all of the provisions of this ToU, Fintopio hereby grants you a non-exclusive, non-transferable, non-sub-licensable licence to use the Fintopio Platform in object code form only for the purposes and in the ways established in this ToU. You shall not try to copy, lease, reverse engineer the Fintopio Platform, or obtain its source code, or use it in any way that contradicts this ToU. In such cases, Fintopio is entitled to immediately restrict your access to the Fintopio Platform at its sole discretion.

Any virtual assets and virtual asset services or transactions connected with Decentralized Finance (DeFi) services provided on the Fintopio Wallet are provided and/or facilitated by WALLET LLC, registration number3708 LLC 2024, registered address: Suite 305, Griffith Corporate Centre, Beachmont, Kingstown, St. Vincent and the Grenadines.

Your wallet balances and transaction histories within the Platform are supported by separate blockchain explorers or browsers specific to each cryptocurrency. Fintopio neither collects nor stores any private keys, backup/seed phrases, or passwords. Furthermore, the Fintopio Wallet does not collect, hold, or facilitate the transfer of any virtual assets to or from users' wallets in any capacity.

Any virtual assets and virtual asset services or transactions connected with CeFi Services are provided and/or facilitated by Fintopio Virtual Assets LLC registration number: 225012-3301-OOO, registered address: 9 Razzakov St., Business Center Russia, 9th Floot, Room 900, Perwomaisky district, Bishkek city, Kyrgyz Republicand holding Virtual Assets Exchange Operator (VAEO) License, series BA No. 0097, registration number 84, dated May 11, 2024, issued by Service for Regulation and Supervision of the Financial Market under the Ministry of Economy and Commerce of the Kyrgyz Republic.

By accessing, utilizing, or continuing to utilize the CeFi Services, you hereby acknowledge, agree to, and accept, without limitation or qualification, the Terms of Use of Fintopio Kg available at https://fintopio.kg/terms-of-use-ru. Your continued use of the CeFi Services constitutes a binding agreement between you and Fintopio Kg to adhere to all terms, conditions, policies, and any amendments thereto, as may be implemented and communicated via its web-page from time to time. It is your responsibility to regularly check, review and remain informed of the current Terms of Use of Fintopio Kg, which shall govern your use of the CeFi Services in all respects.

Fintopio reserves the unilateral right to update or modify these Terms at any time. In the event of such changes, Fintopio will notify you either by posting the revised Terms on the Fintopio Wallet or through other reasonable methods of communication (i.e. via Telegram Integrated Fintopio Bot). The revised Terms, as posted on the Platform, shall immediately take effect unless otherwise specified. It is your responsibility to regularly check the Platform for any such changes and decide whether to accept the revised version of these Terms. By continuing to use the Platform after any update or modification to these Terms, you are deemed to have accepted the revised Terms. If you do not agree to these Terms or any updates or modifications, you must cease accessing or using the Platform. Please note that we reserve the right to change or discontinue all or any part of the Services at any time and without prior notice, at our sole discretion.

To be eligible to use the Services:

• You must be at least eighteen (18) years old (or of legal age under the applicable law in Your country of residence). If You are entering into these Terms on behalf of an entity, You hereby represent and warrant that: (i) the legal entity is duly incorporated and validly existing under the applicable laws of the jurisdiction of its incorporation; and (ii) you are duly authorised by such legal entity to act on its behalf;
• You must not be a resident of Prohibited Jurisdictions;
• You must not be currently the subject of or subject to economic sanctions such as the United Nations Security Council Sanctions List, the list of specially designated nationals maintained by OFAC, the denied persons or entity list of the U.S. Department of Commerce or any similar list maintained by any other relevant sanctions authority;
• You must not be located in, or be a resident or a national of a country blacklisted by the Financial Action Task Force (FATF);
• You must not use any software to bypass these limitations or to use our Services in any illegal activities, such as money laundering or financing of terrorism;
• You must not be resident in a jurisdiction where virtual assets services are prohibited;
• You must not be resident in a jurisdiction where Telegram is not operational and/or is banned.

To avoid any uncertainty, it is imperative that you refrain from using the Services if you are situated in, or hold citizenship or residency in any state, country, territory, or jurisdiction where such use would contravene applicable laws or regulations. It is your responsibility to ensure that your use of the Services complies with all relevant laws, rules, and regulations. You affirm that any funds used in conjunction with the Services are lawfully acquired and rightfully yours.

By engaging with the Fintopio Wallet, you assert and guarantee that you satisfy all eligibility criteria delineated in these Terms. Nonetheless, we retain the right to deny access to Fintopio Wallet to certain individuals and reserve the discretion to modify our eligibility criteria at our discretion.

Wallet creation or importation To use Fintopio Wallet, you must either import an existing wallet or create a new one. Upon wallet creation, a private key will be assigned to you. It is your responsibility to promptly notify us of any unauthorised usage of your private key or any security breaches about your wallet. However, you acknowledge and agree that you bear all risks associated with utilizing Fintopio Wallet, and you are solely accountable for safeguarding the confidentiality and security of your private key.

You acknowledge and agree that by using CeFi Services, you are solely accountable for protecting the confidentiality and security of your private key and assume full responsibility for any potential issues relating to your investment decisions and virtual assets management available to you through the CeFi Services. The private key storage functionality is provided for your convenience, subject to the limitations stated herein.

Upon wallet creation, it is strongly advised that you take precautions to prevent potential loss of access or control over your wallet. Recommended measures include, but are not limited to:

• generating a robust and unique password exclusive to your wallet (distinct from other passwords such as your phone password or those used for websites and online services), and utilizing biometric authentication if available;
• refraining from storing the private key and secret phrase in plain text online or in an unsecured physical location;
• restricting access to your devices and wallet;
• implementing necessary safeguards against malware on your devices and networks;
• promptly informing us upon discovering or suspecting any security breaches pertaining to your wallet.

Notwithstanding the foregoing, we hereby declare that we shall assume no responsibility or liability whatsoever for any actions or events taking place within your wallet, regardless of whether they were authorised by you or not.

Payment and fees: By utilizing Fintopio Services, you agree to cover all applicable fees, including transaction fees for cryptocurrency swaps/trades and fees associated with card or bank transfers. Any bank fees, or debit card fees incurred during cryptocurrency purchases may be deducted from the settled amount of your cryptocurrency purchases made using Google Pay, Apple Pay or a debit card. You are accountable for any additional fees levied by your payment services provider. Additionally, you will encounter network and/or gas fees, which are charges incurred when purchasing BTC, ETH, and ERC20 tokens, or native gas fees. These fees are paid to the blockchain network for facilitating transactions and are not retained by Fintopio. Any applicable fees for the Services or its components will be detailed on the Platform. Fintopio reserves the right to withhold taxes as required. All applicable fees will be clearly displayed and updated within the platform and may be subject to updates and changes by Fintopio from time to time. Unless otherwise specified, all fees payable by you exclude taxes.

Transaction fees: Certain virtual assets transactions may incur transaction fees (e.g., mining fees) mandated by the virtual assets system or blockchain network involved. It is your responsibility to ensure that your wallet has a sufficient balance and/or "gas" to complete transactions before initiating them. You acknowledge and agree that we bear no liability for failed transactions or losses resulting from incorrectly set transaction fees (i.e., too low or too high) or insufficient funds or gas associated with your wallet address. Additionally, you acknowledge and agree that we do not have access to your transactions or those of others.

Taxes: It is your sole responsibility to assess whether any taxes apply to transactions conducted via the Platform and to properly withhold, collect, report, and remit the appropriate tax amounts to the relevant tax authorities. We are not liable for determining the tax implications of your transactions or for collecting, reporting, withholding, or remitting any taxes arising from virtual assets related transactions. Fintopio reserves the right to withhold taxes as required.

Third-party payment services: The Platform may include links to third-party processors for processing fiat purchases of cryptocurrencies. When you engage in cryptocurrency purchases with fiat currencies through these links, you are directly purchasing cryptocurrencies from the third-party provider. Payment methods may include Google Pay, Apple Pay or a valid bank account using your debit card. It is imperative that your purchases adhere to the relevant instructions provided within the Platform and comply with the terms and conditions stipulated by the third-party provider.

7.1. DeFi services: The Platform enables a user to create a non-custodial wallet designed for the management of virtual assets, including cryptocurrencies and NFTs. You retain full control and responsibility for your virtual assets and private keys, while authorising transactions from your DeFi wallet address(es). By availing yourself of the Services, you explicitly acknowledge and consent that you bear full responsibility for your actions and assume any and all potential risks of financial loss at all times. The Platformallows you to perform the following:

• Generation of DeFi wallet addresses and associated private keys for sending and receiving virtual assets;
• Self-storage and transfer of supported cryptocurrencies;
• Portfolio tracking and real-time monitoring of your virtual assets holdings;
• Access to and interaction with third-party decentralised applications ("DApps") and decentralised exchanges ("DEX") through the Mini-app.
• Swapping/trading of virtual assets via DApp functionality provided by third-party service providers.
• Where applicable (and through third-parties), staking of certain digital assets in third-party 'proof of stake' networks through staking services ("Staking Services").
• Access to digital asset price information provided by third-party service providers.
• Broadcasting of digital asset transaction data to various blockchains supported by the Platform, eliminating the need for downloading or installing associated blockchain-based software on your device.
• Provision of other services, features, and capabilities that may be introduced from time to time by Fintopio.

Some of the decentralised applications (DApps) accessible through the Platform may also entail accessing specific cryptocurrency markets, platforms, or interfaces facilitating complex financial transactions. Please note that the availability of specific services and features may vary over time, and Fintopio reserves the right to modify or discontinue any aspect of the Services at its discretion.

7.2. CeFi Services: When using Fintopio Wallet, users can access custodial wallet functionality provided by the designated CeFi Service Provider. The CeFi Service Provider securely manages and retains control over the private key required to conduct transactions and other wallet operations on your behalf. As part of security protocols, CeFi Service Provider may access and retrieve private key information to authorize transactions as needed and may process associated data to comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) purposes regulations under applicable law.

For avoidance of doubt, Fintopio merely provides a display interface enabling your interaction with the CeFi Service Provider and undertakes no obligations with regard to CeFi Services.

CeFi Services offered include the following functionalities:

• On-Ramp Services. The CeFi Service provider enables users to convert fiat currencies into virtual assets seamlessly through the Fintopio Platform, including fiat-to-crypto conversion and payment processing.
• Virtual Assets Trading. The users may buy, sell, and trade virtual assets, whereas the CeFi Service Provider ensures trade уxecution, liquidity management and real-time market data.
• Sending, Receiving, Transfer, Exchange, and Conversion of Virtual Assets. The users may send and receive virtual assets seamlessly, as well as transfer, exchange, and convert between different digital currencies.
• Virtual Assets Custody Services. The CeFi Service Provider provides secure custody solutions for users’ virtual assets, ensuring their safety and integrity.
• Peer-to-Peer (P2P) Services. The CeFi Service Provider supports peer-to-peer transactions, allowing users to interact directly for trading and transferring virtual assets, including user matching, escrow services and Dispute Resolution.
• Virtual Assets Management. The CeFi Service Provider provides comprehensive virtual assets management services to assist users in effectively managing their digital portfolios, such as Portfolio Tracking, Analytics and Reporting and Integration with Financial Tools.
• Broker-Dealer Services. The CeFi Service Provider may act as an intermediary in the buying and selling of virtual assets on behalf of users, ensuring efficient and accurate trade settlements.
• Off-Ramp Services. The CeFi Service Provider enables users to convert their virtual assets back into fiat currencies, providing a seamless exit from digital asset holdings, including crypto-to-fiat conversion, withdrawal processing and payment gateway integration.
• Over-The-Counter (OTC) Services. The CeFi Service Provider supports large-scale private transactions of virtual assets directly between buyers and sellers outside its order book.
• Staking Services. The CeFi Service Provider enables users to stake their virtual assets on Fintopio Platform to earn rewards and support network operations

Each of these CeFi Services functionalities supports compliant transactions managed by CeFi Service Provider.

7.3. Purchase of digital assets with supported credit or debit cards: If you would like to use the Platform for purchasing virtual assets with your bank account, credit or debit card, a third party will facilitate the conversion of your designated amount into the relevant virtual asset and credit it to your wallet. You acknowledge and agree that:

• Fintopio is not accountable for your use of such third-party services and bears no liability whatsoever in connection with their usage;
• You will be subject to any terms and conditions stipulated by the respective third-party service provider, including the Terms of Use of the CeFi Services provided by Fintopio Kg through the Platform;
• Fintopio lacks the capability to alter, retract, or annul any conversion requests initiated by you;
• Fintopio bears no responsibility for any exchange rates offered by the relevant third-party service provider(s);
• Fintopio is not responsible for any fees levied by the relevant third-party service provider(s), or by your bank or credit card issuer(s).

7.4. Virtual assets transactions: For all proposed virtual assets transactions to be finalised, confirmation and recording in the associated public blockchain of the virtual assets are requisite. These networks are decentralised, peer-to-peer networks supported by independent third parties, which Fintopio neither owns, controls, nor operates. Consequently, we do not guarantee that any transaction details submitted via our Services will be confirmed and processed. By utilizing the Fintopio Wallet, you acknowledge and agree that:

• We lack the authority to cancel or modify your transaction;
• Transaction details submitted by you may encounter delays or may not be completed by the relevant blockchain networks;
• We do not engage in the storage, transmission, or reception of virtual assets;
• Any transfer related to a Virtual Asset takes place on the relevant blockchain network, and not on a network owned or operated by us. Therefore, we do not warrant the transfer of title or rights in any Virtual Asset.

You affirm and warrant that any information furnished via the Services is accurate and comprehensive. You acknowledge that we bear no responsibility for any errors or omissions made by you in connection with any virtual assets transaction initiated via the Services. It is strongly advised to thoroughly review transaction details before initiating a virtual asset transfer.

7.5. Use of Staking Service: If you access or employ the Staking Services, a third party may engage in staking certain virtual assets on your behalf, hereafter referred to as "Staked Virtual Assets." These assets act as transaction validators on the relevant blockchain network. In the event that a block of transactions is successfully validated utilizing said Staked Virtual Assets, a reward is conferred by the network, commonly known as a "Staking Reward." You acknowledge and agree that:

• Fintopio holds no responsibility for your use of the Staking Services and bears no liability whatsoever in connection therewith;
• Continuous staking cannot be guaranteed by Fintopio;
• Fintopio does not assure the staking or continued staking of any particular Virtual Asset.

7.6. Use of DApps and DEX: If you access or use DApps or DEX, inclusive of DApp functionality integrated within the Services, you acknowledge and consent to the following:

• Fintopio holds no responsibility for your access or usage of DApps or DEX, and assumes no liability whatsoever in connection therewith, including any transactions subject to dispute;
• Limits on the amounts you may exchange via DEX per day are contingent upon the requirements stipulated by third-party developed smart contracts;
• Blockchain operations are irreversible, meaning that when you conduct transactions via DApps or DEX, you bear sole responsibility for any associated issues, including transfers to incorrect addresses or problems with node servers selected by you;
• Third-party developed smart contracts utilized in DApps or DEX may impose handling fees and/or service fees. Any fee information displayed on the Platform is provided for reference only, and Fintopio does not guarantee its accuracy, applicability, reliability, integrity, or appropriateness, nor shall Fintopio be liable for any resulting loss or damage arising directly or indirectly from your reliance on such information;
• Fintopio currently does not impose any service fees or handling fees for the use of DApps or DEX. However, Fintopio reserves the right, at its discretion, to introduce such fees at any time in the future. Any updated fees will apply to transactions occurring following the effective date of the fee update.

7.7. DeFi Wallet address, private key, and backup procedures: An encrypted backup of select information linked to your wallet can be stored on compatible devices. The private key, in conjunction with the wallet address, authorises the transfer of virtual assets to and from the respective wallet address. You bear sole responsibility for safeguarding and securing your private key and any mnemonic phrase ("Secret Phrase") associated with your wallet. It is imperative to maintain the security of your wallet address, secret phrase, and private key access information. Failure to do so may lead to the loss of control over digital assets linked to your wallet.

You acknowledge and agree that we will neither receive nor store your wallet password, encrypted private key, unencrypted private key, or secret phrase connected to your wallet. We are unable to generate a new password for your wallet if you fail to recall the original password. In the event you have not securely stored a backup of any wallet address and private key pairs preserved within your wallet, you accept and recognize that any virtual assets linked to such wallet addresses will become inaccessible. Consequently, we bear no responsibility or liability should you encounter difficulty accessing your wallet for any reason, including, but not limited to, your failure to maintain the security of your wallet address, secret phrase, and private key information.

As for the CeFi Services, you acknowledge and agree that Fintopio Kg securely manages and retains control over your CeFi wallet to facilitate digital asset transactions and other wallet operations on your behalf. As part of security protocols, Fintopio Kg shall authorize digital asset transfers. If you lose your wallet login details, Fintopo Kg may be able to help you retrieve your wallet and set a new password. Additionally, Fintopio Kg shall process your personal identification information and verify your identity to comply with KYC, and AML requirements mandated by applicable laws.

By utilizing the Platform, you may access information related to third-party cryptocurrencies, cryptocurrency wallets, staking pools, and liquidity pools. However, the presentation of such information does not imply any affiliation with or endorsement of third parties, even if certain functionalities provided within the Platform necessitate the use of such third-party products. It is important to note that the majority of the Services available on the Platform are provided by third-party service providers. ThePlatform solely furnishes software services enabling users to generate wallet addresses and associated private keys for the purpose of sending, receiving, storing, and transferring virtual assets, as well as viewing and monitoring their virtual asset holdings in real time. In addition, the Platform also enables users to use third-party services provided through the platform by third-party services providers.

The content pertaining to third-party services and products as presented on, or within the Platform is derived from publicly available information or provided to us by such third parties. As such, we do not make any representations or warranties regarding the accuracy of such third-party service or product-related information. In no circumstance shall any description or mention of a third party's product or service, including hyperlinks, be construed as an endorsement or promotion by us of such third-party products or services. We maintain the exclusive right to supplement, modify, or terminate the availability of any third-party service.

You may opt to receive push notifications from third party content providers; however, you must explicitly opt in to this service. Push notifications for third party content will not be automatically activated on your device. We do not exercise control over, endorse, or adopt any third-party content disseminated through push notifications and disclaim any responsibility for third party content, including token availability and/or sales.

To the extent permitted by Fintopio, you may grant explicit consent to a third party to access or link to your Fintopio Wallet, whether through the third party's product or service or through the Platform itself. You acknowledge that granting such permission to a third party to act on your behalf does not absolve you of any obligations under these Terms. You are fully liable for all actions or oversights of any third party granted access to your wallet.

Choose a Custodial or Non-Custodial wallet for your operations. The Platformprovides both custodial (CeFi) and non-custodial (DeFi) wallet options for managing supported cryptocurrencies. Users who select the non-custodial wallet retain complete control over their cryptocurrencies and the associated private keys, which are stored directly on their device. Fintopio does not have access to or control over non-custodial wallets, private keys, or seed phrases, and cannot assist with recovering lost credentials.

For users opting for custodial wallet services, Fintopio Kg securely manages wallets on behalf of users. While users maintain control over their assets, Fintopio Kg provides custody for the assets and facilitates transactions, and may require authentication and/or verification information as necessary to authorize activities, in compliance with applicable regulations. Regardless of the option selected, users are responsible for safeguarding their credentials and securing account access.

Fintopio bears no responsibility regarding CeFi Services and custodial wallet features provided by Fintopio Kg

Recovery phrase. Upon creating a new DeFi wallet within the Platform, users receive a 12-word recovery phrase, also known as a "seed phrase" or "secret phrase," which only they possess. Loss of the recovery phrase results in the loss of access to the user’s DeFi wallet and any virtual assets therein. Fintopio does not have access to the recovery phrase and cannot assist in fund recovery or wallet access in the event of a lost recovery phrase. Platform offers an encrypted iCloud or Google Drive feature for users to back up their recovery phrase. Users are encouraged to utilise this feature, along with writing down and securely storing their recovery phrase. To access the backup feature, users can navigate to Settings and select Recovery Phrase within the Platform.

Supported cryptocurrencies The Platform currently supports BTC, USDT (ERC20 / TRC20), ETH, TRX, and TON. Users can view all supported cryptocurrencies for storing and transferring within the Platform by tapping either the DeFi or the CeFi "Wallet'' feature on the Platform. A search bar is available for users to check if a specific cryptocurrency is supported. While certain ERC-20 tokens may be unsupported at times, this may limit users' ability to purchase or sell such tokens.

Peer-to-Peer transactions: The Platform facilitates sending, receiving, and storing (including trading/swapping, and depositing) supported cryptocurrencies from third parties by providing instructions within the Platform. Transfers of supported cryptocurrencies between users' wallets and third parties are considered transfers. The initiation of cryptocurrency transfers, including payment of network or miner's fees, is the sole responsibility of the person initiating the transaction. Insufficient network fees may result in delays or loss, and Fintopio is not obligated to assist in remediation. Users are responsible for verifying all transaction information before submission. Fintopio holds no liability in the event of an incorrect blockchain destination address entry. Cryptocurrency transfers are irreversible once broadcast to the relevant cryptocurrency network, and Fintopio makes no guarantees regarding confirmation by the network.

Absence of insurance coverage: Cryptocurrency does not hold legal tender status and is not backed by governmental entities. Accounts and value balances associated with the Platform are not protected or covered by any insurance policy. Fintopio does not operate as a bank and does not provide fiduciary services. There are no guarantees that a transfer initiated through Fintopio Services will successfully convey title or ownership rights to any cryptocurrency.

Emergence of new technology. While extensive testing has been conducted, Platform remains a novel software. Despite ongoing development efforts, the software may contain bugs or security vulnerabilities. Moreover, the software is subject to potential significant alterations over time that may not align with user expectations.

Risks relating to information security. The use of cryptocurrency and engagement with Fintopio Services may expose users to the risk of expropriation or theft. Malicious entities, including hackers, may attempt to disrupt Fintopio Services through various means, such as malware attacks or denial of service attacks. Furthermore, as the Ethereum protocol relies on open-source software, the software underpinning Fintopio Services may contain intentional or unintentional bugs or weaknesses, potentially resulting in the loss of user cryptocurrency or the inability to access or control your wallet on the Platform. In the event of such occurrences, users may not be guaranteed any remedy, refund, or compensation.

While we endeavour to maintain uninterrupted access to the Platform and the Services, we cannot guarantee uninterrupted availability. Although we strive to provide accurate and up-to-date information via the Services, including content, it may occasionally contain technical inaccuracies or typographical errors. We reserve the right, to the extent permitted by applicable law, to modify or update information provided through the Platform and/or the Services without prior notice, including information pertaining to our policies, products, and services or platform. Therefore, it is your responsibility to verify all information before making any decisions based on it. We shall not be liable for any decisions made based on information obtained through the Services or the Platform. Links to third-party materials, including websites, are provided for convenience only and are not under our control. You acknowledge and agree that we are not responsible for the accuracy or content of any such third-party materials accessible through or linked to the Platform.

Once a purchase is completed, whether through fiat or cryptocurrency, it cannot be cancelled or reversed. All purchases are considered final once the cryptocurrency is transferred to the designated wallet address. Once an order has been fulfilled and the cryptocurrency transferred to the designated wallet address, it cannot be retrieved or reversed under any circumstances. By completing the purchase, you agree that upon delivery, you are not entitled to any credit or refund, and all transactions are deemed final. Fintopio's obligations are fulfilled upon delivery of the purchased cryptocurrency to the designated wallet address, and you waive any claim or right against Fintopio thereafter.

To the maximum extent permitted by applicable law, neither Fintopio nor its directors, employees, or agents shall be liable to you or any third party for any indirect, consequential, exemplary, incidental, special, or punitive damages, including lost profits or lost data, arising from your use of the Platform or the Services, or any content or materials accessed through the Platform, even if Fintopio is aware of the possibility of such damages.

Notwithstanding any provision herein to the contrary, to the extent permitted by applicable law, Fintopio's liability to you for any cause whatsoever, and regardless of the form of the action, shall be limited to the amount paid, if any, by you to Fintopio for the Services. In no event shall Fintopio's liability to you exceed the lesser of (i) $100 or (ii) the amounts paid by you to Fintopio for the Services in the twelve (12) month period preceding the applicable claim respectfully. You acknowledge that if no fees are paid to Fintopio for the Services, you shall be limited to injunctive relief only, unless otherwise permitted by law, and shall not be entitled to damages of any kind from Fintopio, regardless of the cause of action.

Some jurisdictions do not allow the exclusion or limitation of certain damages or the limitation of implied warranties. If these laws apply to you, some or all of the above disclaimers, exclusions, or limitations may not apply to you, and you may have additional rights.

Fintopio provides the Platform and the Services on "AS IS” and "AS AVAILABLE” basis without warranty of any kind, express or implied. To the maximum extent permitted by law, we hereby disclaim all representations and warranties relating to the Platform and the underlying software, or any aspect of the information, content, or services, whether provided or owned by us, or by any third party, or contained in any third-party materials or on any third-party websites accessible or linked to the Platform or the Services.

This disclaimer includes, without limitation, warranties of merchantability, fitness for a particular purpose, title, non-infringement, freedom from computer virus, and any implied warranties arising from course of dealing, course of performance, or usage in trade. Furthermore, we do not represent or warrant that the content accessible via the Fintopio Platform is accurate, complete, available, current, free of viruses or other harmful components, or that the results of using the service will meet your requirements. We do not make any representations or warranties that the access to Platform or use of the Services or Platform, and the functionality thereof will be continuous, uninterrupted, timely, or error-free. Some jurisdictions do not allow the disclaimer of implied warranties, so the foregoing disclaimers may not apply to you.

Subject to the extent permitted by applicable law, you hereby agree to defend, indemnify, and hold harmless Fintopio and affiliates, and respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers, and contractors from and against any and all claims, damages, obligations, losses, liabilities, torts, costs, or debts, and expenses (including, but not limited to, attorney’s fees) arising from: (i) your use of and access to the Platform and the Services; (ii) any feedback or submissions you provide to Fintopio concerning the Fintopio Platform or the Services; (iii) violation of any third party services and/or content; (iv) your violation of these Terms; or (v) your violation of any law, rule, or regulation, or the rights of any third party.

By default, all content and materials related to the Platform or the Services are the intellectual property of Fintopio and are protected by copyright, trademark, and other applicable laws. You may view, print, and/or download a copy of such content, materials on any single computer solely for Your personal, informational, non-commercial use, provided You keep intact all copyright and other proprietary notices. The trademarks, service marks, and logos of the Service and others used in the Services whether registered or not (“Trademarks”) are the property of Fintopio and their respective owners. The software, text, images, graphics, data, prices, trades, charts, graphs, video, and audio used in the Services belong to Fintopio. The Trademarks, content, and materials should not be copied, reproduced, modified, republished, uploaded, posted, transmitted, scraped, collected, or distributed in any form or by any means, whether manual or automated. It is strictly prohibited to use any of such contents or materials in any other web-application, the Telegram software bot, on any other website or networked computer environment for any other purpose. Any unauthorised use may violate copyright, trademark laws, or other applicable laws and could lead to criminal, administrative or (and) civil legal action. We reserve the right to prosecute infringers of intellectual property rights.

From time to time, we may introduce promotions or rewards programs ("Incentive Programs"). We reserve the right to modify, alter, or terminate any Incentive Program at our discretion, with or without prior notice to you. Such actions may include the cancellation of unredeemed rewards, points, or other benefits. Additionally, we reserve the right to disqualify participants from an Incentive Program if they are found to have violated these Terms or misused the Incentives Program, as determined by us. Participants acknowledge and agree that participation in the Incentives Program is at their own risk. The Incentives Program and all associated services are provided on an "AS IS" and "AS AVAILABLE" basis. Fintopio makes no warranties regarding any rewards or points obtained through the Incentives Program, the value of the Incentive Program or any points obtained therein, the uninterrupted or error-free operation of the Incentive Program, or the accuracy or reliability of any information obtained through the Incentive Program. Fintopio disclaims all express and implied warranties, including but not limited to merchantability, fitness for a particular purpose, and non-infringement.

Specific information about such Incentive Programs may be published in annexes to these Terms from time to time.

The Parties agree to endeavour to resolve any disputes arising under these Terms through good-faith negotiation. In the event of a dispute, You shall contact the support service via the Telegram bot @FintopioHelpRobot or by any other means specified within the Fintopio Platform, and the parties shall endeavour to resolve the dispute within thirty (30) days from the date of receiving your email regarding the issue.

The parties further agree that: (i) Any arbitration proceedings will take place in Saint Vincent and the Grenadines; (ii) The arbitration will be conducted confidentially by a sole arbitrator in accordance with the rules of Saint Vincent and the Grenadines Arbitration Act, conducted in English, and with limited discovery.

Except for class procedures and remedies as discussed below, the arbitrator retains the authority to grant any remedy available to a court or other tribunal. The prevailing party in any action or proceeding to enforce these Terms is entitled to costs and attorneys' fees. The arbitral decision may be enforced in any court. Regardless of whether the dispute is resolved through arbitration or litigation in court, both you and Fintopio agree not to initiate a class action, class arbitration, or representative action or proceeding against each other.

Your use of the Platform signifies your agreement to abide by all applicable laws. This encompasses local, provincial, state, federal, national, and international laws that may pertain to your use of the Platform and the Services. You acknowledge and agree that it is your responsibility to adhere to all applicable laws, statutes, ordinances, and regulations of any jurisdiction while utilizing the Services. It is hereby agreed that you shall refrain from contravening said terms in any manner, as well as the subsequent provisions:

• It is incumbent upon you to ensure that the digital assets you use originate from legitimate sources, as Fintopio cannot ascertain the source of the digital assets. Should you become aware of any unlawful use of the Services or violations of these Terms, you must promptly notify us via the Fintopio Telegram bot @FintopioHelpRobot. Users found violating these Terms may be reported to relevant authorities, barred from accessing the Platform or using the Services, and held accountable for any resulting losses incurred by Fintopio or other users.
• You affirm that you will refrain from employing the Services for the facilitation, support, or engagement in any illicit activities, including but not limited to illegal trade, gambling, fraud, money laundering, terrorist activities, or malicious hacking across any jurisdiction. In the event that We detect or suspect any violation of these Terms or applicable laws, We reserve the right to pursue all available rights and remedies under these Terms and the law, including reporting such violations to the appropriate regulatory and statutory bodies.
• The use of digital assets obtained through illegal means or for illicit purposes within the Platform is strictly prohibited.
• We retain the right to scrutinise suspicious transactions conducted by you by sharing your IP address with relevant authorities and, if deemed necessary, contacting the pertinent entity or individual regarding such matters.
• The masking of IP addresses or the obfuscation of transaction details using circumvention technologies is prohibited.
• Providing false, misleading, or inaccurate information to Fintopio, including during your access to the Platform or use of the Services, is strictly prohibited. Users are solely responsible for furnishing accurate and genuine information and may face legal repercussions for providing false or misleading information.
• Impersonating others, attempting unauthorised access to another user's wallet, or using our Services or the Platform in any manner related to such actions is prohibited.
• Attempts to bypass or circumvent any measures implemented by us to restrict access to the Platform and the Services, including the use of alternative accounts, computer systems, or networks connected to the Platform or the Services, are strictly prohibited.
• Any usage of the Platform or the Service beyond the scope explicitly authorised in these Terms, without prior written consent from Us, is strictly prohibited. In the event of any infringement, we reserve the right to immediately terminate your access to the Platform or the Services without prior notice.

Prior express written consent and approval from Fintopio must be obtained before utilizing Fintopio Services for the following categories of business and/or use ("Conditional Uses''). To request consent, please contact us at @FintopioHelpRobot. Fintopio may impose additional conditions, require supplemental representations and warranties, mandate enhanced onboarding procedures, and impose operational restrictions if you engage in any of the following businesses, activities, or practices when using the Platform or the Fintopio Services:

• Money services: Includes money transmitters, cryptocurrency transmitters, currency or cryptocurrency exchanges or dealers, gift cards, prepaid cards, and sale of in-game currency unless the merchant is the operator of the virtual world. Also encompasses acting as a payment intermediary or aggregator or otherwise reselling any of the Services.
• Games of skill: Refers to games that are not categorised as gambling under these Terms or by law yet involve an entry fee and offer a prize.
• Charities:Involves accepting donations for nonprofit enterprises.
• Religious/spiritual organisations: Covers the operation of a for-profit religious or spiritual organisation.

Fintopio shall not be held liable for any delays, failure in performance, or interruptions of service which result directly or indirectly from any cause or condition beyond our reasonable control, including but not limited to: any delay or failure due to any acts of God, acts of civil or military authorities, acts of terrorism, civil or industrial disturbances, blockages, embargoes, war, strikes or other labour disputes, fire, earthquakes, storms or other nature-related events, interruption in electrical telecommunications or Internet services or network provider services, failure of hardware equipment and/or software or other utility failures, smart contract bugs or weaknesses, technological changes, changes in interest rates or other monetary conditions, and, for the avoidance of doubt, changes to any blockchain-related protocol, other catastrophe, or any other occurrences which are beyond our reasonable control, and shall not affect the validity and enforceability of any remaining provisions. In the event that the delivery of Services as delineated within these Terms is impeded by circumstances that fall outside of Fintopio’s reasonable control, including but not limited to, instances of force majeure as outlined above, or alterations in the prevailing legal and sanctions frameworks, Fintopio shall be exonerated from any liability pertaining to our failure to provide the Services during the temporal span that aligns with the occurrence of such contingent events.

You acknowledge and agree that the Fintopio reserves the right, at its sole discretion and without cost to you, to restrict your access to the Service, including suspending or terminating the Service, prohibiting access to it and its content or tools, delaying or removing hosted content, and taking technical and legal actions to keep you off the Service. This may occur if any public authority requires us to do so, if we reasonably perceive that you are using the Service inconsistently with its intended purpose or with the Terms, or if you may incur legal liability or infringe upon any intellectual property rights while using the Service.

Fintopio may employ measures in accordance with the preceding paragraph for any reason, including but not limited to:

• Attempts to gain unauthorised access to the Service or provide assistance to others attempting to do so,
• Usage of the Services to perform illegal activities as described in the "Prohibition on illegal activities" section hereunder,
• Exploitation of vulnerabilities in the Platform or the software,
• Any other Violations of these Terms.

You have the right to unilaterally terminate these Terms by ceasing to use the Service at any time without notice to Fintopio, following the settlement of any pending transactions. However, unilateral termination of these Terms does not absolve you of liability for violations committed during the term of validity.

You may also communicate your desire to cease accessing the Platform or using the Services at any time by sending a request to the support team via our Telegram bot @FintopioHelpRobot or our support email at @FintopioHelpRobot

Upon termination of these Terms, Fintopio shall immediately cease the provision of the Services to you, and you shall not be entitled to access or use the Service thereafter.

1. Assignment. You may not assign any rights and/or licences granted under these Terms. Fintopio reserves the right to assign our rights without restriction, including without limitation to any Fintopio affiliates or subsidiaries, or to any successor in interest of any business associated with the Fintopio Wallet Services. Any attempted transfer or assignment in violation hereof shall be null and void. Subject to the foregoing, these Terms will bind and inure to the benefit of the parties, their successors and permitted assigns. In the event that Fintopio is acquired by or merged with a third-party entity or undergoes a change of control, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you as part of such merger, acquisition, sale, or other change of control.
2. Export and sanctions compliance. In connection with these Terms, you must comply with all applicable import, re-import, sanctions, anti-boycott, export, and re-export control laws and regulations, including all such laws and regulations that may apply. For clarity, you are solely responsible for compliance related to the way you choose to use the Services. You may not use any Fintopio Services if you are the subject of U.S. sanctions or of sanctions consistent with U.S. law imposed by the governments of the country where you are using the Service.
3. No waiver.The failure of Fintopio to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision in that or any other instance. If any provision of these Terms is held invalid, the remainder of these Terms shall continue in full force and effect.
4. Notices. To give us notice under these Terms, the user must contact Fintopio @FintopioHelpRobot.
5. Severability. If any provision of these Terms shall be determined to be invalid or unenforceable under any rule, law, or regulation of any local, state, or federal government agency, such provision will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under any applicable law and the validity or enforceability of any other provision of these Terms shall not be affected. If such construction is not possible, the invalid or unenforceable portion will be severed from these Terms, but the rest of these Terms will remain in full force and effect.
6. Survival. The following provisions of these Terms shall survive termination of your use or access to the Site: the sections concerning Indemnification, Disclaimer of Warranties, Limitation of Liability, Waiver, Applicable Law and Dispute Resolution, and General Provisions, and any other provision that by its terms survives termination of your use of the Services or access to the Platform.
7. Entire terms. These Terms and any other documents referred to or incorporated in it constitute the entire agreement between the Parties relating to the subject matter herein, and, supersedes and extinguishes any prior drafts, agreements, undertakings, representations, warranties and arrangements of any nature whatsoever, whether or not in writing, between the Parties in relation to the subject matter thereof.
8. Governing law and jurisdiction. These Terms of Use (these Terms) shall be governed by and construed in accordance with the laws of Saint Vincent and the Grenadines, without regard to its conflict of law principles. Any dispute arising out of or in connection with these Terms, including any questions regarding its existence, validity, or termination, shall be subject to the exclusive jurisdiction of the courts of Saint Vincent and the Grenadines.
9. Contact us: If You have questions relating to these Terms and/or your use of the Fintopio Wallet Services, or any other matter relating to the Fintopio Wallet, please contact us via the following address:

The Hold Points Program ("Program") is designed to promote Fintopio products by rewarding you with Hold Points ("HP") for engaging in specific activities, such as farming and participating in referral programs. The accumulated HP will be considered when the Fintopio Hold Token, a virtual asset, is launched.

For the avoidance of doubts, the HP are solely a feature within the Fintopio Platform and do not represent any form of real currency. They are not linked to any real-world monetary value, nor are they redeemable for cash or any other tangible assets. HP is purely a mechanism for enhancing user engagement within the Platform and should not be considered as having any intrinsic or exchangeable value outside of the Fintopio ecosystem. Furthermore, the accumulation or loss of HP does not imply any financial gain or loss in real terms.

• Joining the Program: To participate, you must accept the Terms and create a DeFi Wallet.
• New Users: Upon joining, you receive 10 invites to share with others for joining the Platform.
• Existing Users: If you have an account created before June 19, 2024, you automatically access the Program but you are not able to join existing referral structures. However, you may start your own referral programs. More info about referral structures may be found in section 4 of this Annex.

• Farming HP: You can earn HP through a "farming" process. Farming HP is a process within the Fintopio Wallet where you can earn HP by actively participating in specific time-based activities. In this process, you initiate a "farming" cycle, which lasts for 7 hours. Once the 7-hour cycle is successfully completed, you will be rewarded with 50 HP. This process can be repeated to accumulate more HP, allowing you to increase your total HP by consistently engaging with the Fintopio Wallet.
• Referral Program: You receive 100 invites upon joining the Program. Each successful referral earns you 5 HP. You are able to purchase an additional 100 invites for 100 HP via the Platform.

• You can progress through different referral levels, earning increased rewards for successful invites.
• In the table below you may find the detailed information related to referral levels, bonus multipliers, etc.

• Ranking Calculation: Your rankings are based on total HP earned through farming, referrals, and in-app games.
• Excluded Transactions: HP bonuses from Fintopio and HP spent on purchasing invites are not considered in ranking calculations.

• Weekly Rankings: Calculated from Saturday to Saturday (GMT +0).
• Monthly Rankings: Calculated from the 20th of each month to the 20th of the next month (GMT +0).
• All-Time Rankings: Consider HP earned from June 19, 2024, onward.

Participants may be eligible for the following rewards based on the amount of HP accumulated in the weekly, monthly, and all-time leaderboards:

• Weekly Rewards ( 777 USDT total):
  • 1st Place: 333 USDT
  • 2nd Place: 222 USDT
  • 3rd Place: 111 USDT
  • 4th to 10th Places: A total of 111 USDT will be distributed proportionally based on HP earned.
• Monthly Rewards ( 14,000 USDT total):
  • 1st Place: 3,333 USDT
  • 2nd Place: 2,222 USDT
  • 3rd Place: 1,111 USDT
  • 4th to 50th Places: A total of 7,334 USDT will be shared proportionally based on HP earnings.
• All-Time Rewards ( 16,665 TON total):
  • 1st Place: 7,777 TON
  • 2nd Place: 5,555 TON
  • 3rd Place: 3,333 TON

The rewards will be disbursed by Fintopio within seven (7) business days following the final determination of the leaderboard rankings.

• Account Security: You are responsible for maintaining the security of your account. Sharing account credentials is prohibited.
• Fraud and Abuse: Fintopio reserves the right to disqualify, suspend, or terminate you if Fintopio found you engaging in illegal activities, fraud, or any actions that undermine the integrity of the Program.
• Modification and Termination: Fintopio reserves the right to modify or terminate the Program at any time without prior notice. Any changes will be communicated through official channels.
• Governing Law: The Program is governed by the laws of Saint Vincent and the Grenadines.

• No Guarantee: Participation in the Program does not guarantee any financial gain. HP is non-transferable and holds no cash value until the Hold Token is launched.
• Limitation of Liability: Fintopio is not liable for any damages or losses arising from participation in the Program, including but not limited to system failures, technical errors, or unauthorised access to accounts.

Fintopio may provide an in-app store within the Fintopio Wallet, where users can redeem a combination of HP, Gems, and completed Wallet tasks to acquire items available for purchase. The items displayed in the store are represented as real goods; however, the redemption is fulfilled through the equivalent value in USDT vouchers. These vouchers are subject to a redemption period of 72 hours, after which they expire if not claimed. Upon successful redemption, users’ accounts will be credited with the corresponding voucher.

How it works.

When participating in the Fintopio Store, users do not directly purchase physical items. Instead, users exchange their accumulated HP, Gems, and completed Wallet tasks for an equivalent value in USDT, representing the market value of the chosen item at the time of exchange.

Fintopio determines this equivalent value by referencing prices from official retailers or distributors, ensuring that users are provided with a transparent valuation. However, users should note that these prices may not always align perfectly with current market conditions due to fluctuations or variations across different platforms.

Prior to completing any exchange, users will have full visibility of the item's equivalent price in TON within the app's interface, ensuring transparency and clarity. The exchange rate between HP and TON is set solely by Fintopio and is subject to periodic adjustments.

Upon confirming the exchange, users receive TON tokens in place of the selected item. These tokens can be used or redeemed according to the user’s preferences, but Fintopio does not facilitate or guarantee the acquisition of the actual physical item listed in the Store.

• Users participate in the Store's offerings at their own risk. All financial and non-financial decisions based on the information provided in the Store are the user's responsibility.
• Users are responsible for ensuring they meet the requirements for item exchange, including sufficient HP, Gems, and completed tasks.

• The prices of items listed in the Store are based on average market prices, including but not limited to official retailer or distributor prices, and may vary depending on the reference jurisdiction. These prices are used as a general guide for item valuation and do not represent any actual, binding monetary value.
• Fintopio reserves the right to modify or update the prices and availability of items in the Store at any time without prior notice. Prices displayed at the time of the exchange will apply.
• All vouchers earned through item exchanges are subject to a 72-hour redemption window. If not redeemed within this period, the voucher will expire, and the user will forfeit the corresponding reward.

• No physical items: Users will not receive the physical items displayed in the Store after making a purchase. Instead, users will be rewarded with an amount of TON tokens equal to the item's worth, which is determined by the market price at the time of exchange.
• No Advertising or Endorsement: The inclusion of items in the Store does not imply any endorsement, affiliation, or association between Fintopio and any third-party brands, retailers, or manufacturers.
• No Relationship: Fintopio is not a supplier, manufacturer, reseller, or distributor of any products offered in the store. Fintopio solely facilitates the exchange of HP for TON based on the equivalent value of the selected items.
• Fintopio makes no representations or warranties regarding the availability, condition, or quality of any goods or services offered by third-party retailers or vendors following the exchange of TON.
• Fintopio is not responsible for the fulfilment, warranty, or any other claims associated with products acquired through the exchange of TON..
• Items in the Store may be subject to purchase limits per user, based on availability and user participation. Users are only eligible to purchase items according to their accumulated HP, Gems, and completed wallet tasks as displayed in the Store interface.
• The conversion of Hold Points (HP) to USDT or TON does not constitute a real-time financial exchange or promise of monetary value. It serves solely as a mechanism for item acquisition within the Store.

By accessing and using the Fintopio Store, users acknowledge and agree to these Terms and Conditions. Fintopio reserves the right to amend these Terms at any time. Users will be notified of any significant changes, but continued use of the Store constitutes acceptance of the revised Terms.