Terms & Conditions

These are the Clients Terms and Conditions of Services (“Terms”, “Terms of Services”) as they form an Agreement between you as a Client and Collect & Exchange CY Ltd as a crypto asset services provider. These Terms and Conditions were last updated and published on 6th October 2025 and set out the different services which we may provide to you. We recommend that you print a copy for your records.

Collect & Exchange CY Ltd. (“Collect & Exchange CY”, “we”, “Administrator”) is a limited liability company incorporated under the Laws of the Republic of Cyprus with registered No. HE456884 and has a registered office at Thessalonikis 13, P.C. 3025, Limassol, Cyprus. Collect & Exchange CY is a Licensed Crypto Assets Service Provider with license number CASP003/25. The status of the licence and its validity may be verified at the CySec website cysec.gov.cy and ESMA website esma.europa.eu. Collect & Exchange CY is a subsidiary company of Collect-Group Holdings CY Ltd, a limited liability company incorporated in the Republic of Cyprus, with registered No. HE 418472 and with its registered office at 13 Thessalonikis str., P.C 3025, Limassol, Cyprus.

Collect & Exchange CY provides access to its services to Clients according to the Collect & Exchange CY Terms and Conditions, and these Clients Terms and Conditions are located on the https://collectnexchange.cy/ (the “Website”)

Whereas:

1. The Collect & Exchange CY Ltd. is authorised by Cyprus Securities and Exchange Commission and provides crypto-asset services regulated under the European Union Regulation (EU) on markets in crypto-assets (MiCA), and the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007 (Law 188(I)/2007), as amended up to and including Law 98(I)/2023, and in line with all applicable directives and circulars of the Cyprus Securities and Exchange Commission and the Central Bank of Cyprus (the “AML/CFT Law”);
2. The Client has entered into this Agreement which includes the Terms, all exhibits, appendixes, addenda, schedules, pricing sheets, fee schedules, the Rules, and the like attached hereto or incorporated by reference herein, as amended from time to time by Collect & Exchange CY (the “Agreement”) as follows:

2.1You and Collect & Exchange CY will be collectively called the “Parties”.

2.2You, as Client, agree with these Clients Terms and Conditions as stipulated under the European Union Regulation (EU) on markets in crypto-assets (MiCA), the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007 (Law 188(I)/2007), as amended up to and including Law 98(I)/2023, and in line with all applicable directives and circulars of the Cyprus Securities and Exchange Commission and the Central Bank of Cyprus (the “AML/CFT Law”), in line with EU Directives and Financial Action Task Force (FATF) regulation, the Policy Statement on the registration and operations of crypto-asset services providers (PS-01-2021), and any other relevant legislation of Cyprus and EU, international conventions, and treaties ratified by the Republic of Cyprus, as well as best international standards and practices, including those of the Financial Action Task Force (“the FATF”) (“The Regulations”) and any applicable laws for the provision of crypto-asset services under the name of Collect & Exchange CY (the “Terms”, or “Agreement”), in order to:

1. 2.2.1access or otherwise use the Website and/or the web application or any information contained on them, and all accounts, services, programs, information, and products (collectively the “Accounts”) that you may use, open, or otherwise access from time to time or through the Website and/or the web application. Additional terms and conditions applicable to specific areas of this Website and/or Web application to particular content or transactions are posted in particular areas of the Website and/or the Web application and, together with these Terms, govern your use of those areas, content or transactions;
2. 2.2.2have basic rights and obligations resulting from a contractual relationship established between Collect & Exchange CY and you, as from the date when you express your intention to enter into a contractual relationship with Collect & Exchange CY.

You acknowledge and agree that:

1. the Terms regulate the legal relationships established between you and Collect & Exchange CY in accordance with the Regulations
2. the Terms constitute the basic rights and obligations arising from a contractual relationship between Collect & Exchange CY and its clients interested in using Collect & Exchange CY web application
3. the Terms are formed by electronic means and enforced pursuant to applicable law
4. neither you nor Collect & Exchange CY may challenge the validity of this Agreement
5. the Terms could be updated by Collect & Exchange CY at any time, and such modification shall be effective immediately upon either posting of the modified Agreement on this Website and/or Web application or notifying you
6. it is your obligation to periodically review this Agreement to be aware of Terms modifications, and your continued access or use of this Website and/or Web application shall be deemed your acceptance of the modified Agreement
7. Collect & Exchange CY Ltd is not responsible for the operation, maintenance, or development of the underlying blockchain or distributed-ledger protocols of any Crypto-Asset supported by the Platform. The Company cannot guarantee the continued functionality, security, or availability of such protocols.
8. You acknowledge and accept that changes to the underlying software protocols, such as forks, network upgrades, or consensus changes, may materially affect the value, availability, or functionality of a Crypto-Asset.
9. Collect & Exchange CY Ltd shall determine, acting reasonably and in accordance with its internal governance procedures, the appropriate response to any such protocol change, including whether to support or discontinue support for affected Crypto-Assets. The Company shall not be liable for any loss in value resulting solely from such external protocol changes, provided that the Company has acted with due care, security, and diligence in safeguarding the Client's assets in accordance with MiCA and applicable law. In cases where a protocol or asset becomes unsupported, the Company will notify affected Clients as soon as practicable and provide information regarding withdrawal or transfer options.
10. You acknowledge and understand that the value of Crypto-Assets is highly volatile and that the market for such assets may be illiquid or unstable at times. You are solely responsible for assessing the nature, potential value, and suitability of Crypto-Assets and related services, taking into account your personal circumstances and financial capacity. You should carefully consider whether the acquisition, holding, or exchange of Crypto-Assets is appropriate for you. The value of your holdings may decrease significantly or become worthless. In certain market conditions, it may be difficult or impossible to convert or transfer Crypto-Assets. Collect & Exchange CY Ltd provides no investment, financial, or tax advice, and does not guarantee the future performance, value, or liquidity of any Crypto-Asset.

Please have a careful look at these Terms and the policies and guidelines referenced in these terms to learn more about the way we process and handle your personal information.

1. DEFINITIONS

Unless otherwise provided in this Agreement, the following terms shall have the meanings set forth below:

1.1. Clientmeans any natural or legal person that has entered into, or is deemed to have entered into, a contractual relationship with Collect & Exchange CY Ltd for the purpose of receiving one or more Crypto-Asset Services as defined under Regulation (EU) 2023/1114 (MiCA), including but not limited to custody and administration of crypto-assets, exchange services, or transfer services. For the avoidance of doubt, the term includes any person to whom a crypto-asset account, custody wallet, or similar access credential is provided or authorised for use.

1.2. Client Account(or “Custody Wallet”) means an account or wallet established and maintained by Collect & Exchange CY Ltd on behalf of the Client for the purpose of holding, safeguarding, and transferring Crypto-Assets or fiat funds related to the provision of Crypto-Asset Services in accordance with Regulation (EU) 2023/1114 (MiCA).

1.3. Fundsmeans money in fiat currency (such as euros or other legal tender) held for or on behalf of the Client in connection with the provision of Crypto-Asset Services, including the exchange of crypto-assets for funds, in accordance with Regulation (EU) 2023/1114 (MiCA). For clarity, the term “Funds” does not include Crypto-Assets, which are defined and held separately within the Client's Custody Wallet.

1.4. Servicesmeans the crypto-asset services provided by Collect & Exchange CY through the Website and/or Web application. The services provided are the following:

• providing custody and administration of crypto-assets on behalf of clients
• exchange of crypto-assets for funds
• exchange of crypto-assets for other crypto-assets
• providing transfer services for crypto-assets on behalf of clients

1.5. Rules means all by laws, rules, programs, and regulations, as they exist from time to time, of the financial institution.

1.6. Fees means any fee or commission mentioned in this Agreement and/or in the Terms and/or in the price list listed on the Website and/or Web application.

1.7. Exchange ratemeans the last known exchange rate as published by a partner bank or exchange Web application plus Collect & Exchange CY fees.

1.8. Cryptocurrencymeans any crypto-asset, as defined under Regulation (EU) 2023/1114 (MiCA), that is supported, listed, or otherwise made available for custody, exchange, or transfer by Collect & Exchange CY Ltd through its Web application.

1.9. Integrated parties means any third party that has integration to the Collect & Exchange CY Web application as crypto exchange partners, processors, gateways, etc.

1.10. Payermeans a third party that initiates a transfer of Crypto-Assets in favour of the Client in connection with the purchase of goods, works and/or services from the Client, and which is not a client of Collect & Exchange CY Ltd.

Any other definitions used and not defined herewith should be understood as described in the Terms.

2. SUBJECT

2.1.Collect & Exchange CY provides to its Client, and its Client receives crypto-asset services under the present Agreement, the Terms and the price list as listed on Website and/or web application.

2.2. Crypto-Assets processed through the Services may be used by third parties as a contractual means of settlement between the Client and such third parties based on Art. 82 of Regulation (EU) 2023/1114 (MiCA). Crypto-Assets do not constitute legal tender and are not guaranteed by any central bank or public authority. Detailed explanation about the Services, please find in Annex 1 of this document.

3. FORMATION OF CONTRACT

3.1.Each crypto-asset activity, including exchange, transfer, or custody-related activity, shall be executed by Collect & Exchange CY Ltd only upon receiving a valid instruction from the Client through the Web application or other approved communication channels. Such instructions must comply with these Terms, applicable MiCAR provisions, and any internal procedures related to transaction authentication, client verification (KYC), and anti-money laundering (AML) obligations.

3.2. Before any activity, you should read the updated version of the Clients Terms and Conditions, as the Company has the right to make changes to these Terms, as necessary, changes may be made due to market changes, legislation (but not limited to).

4. RIGHTS AND OBLIGATIONS

4.1.The Client shall use the Custody Wallet and associated accounts provided by Collect & Exchange CY Ltd solely for the purpose of exchanging fiat currency and/or supported crypto-assets through Integrated Parties, including authorized exchange partners, processors, and gateways. All such transactions shall be subject to these Terms, applicable MiCAR provisions, and the operational policies of Collect & Exchange CY Ltd and its Integrated Parties.

4.2. The Client will provide the Administrator with documents showing his organizational structure, ultimate beneficial owner, and all the relevant KYC information requested by the Administrator from time to time.

4.3.Collect & Exchange CY may, at any time, in its sole discretion, change the risk level of Clients.

4.4.The Client is responsible for any advice from acts of and omissions of Client's employees, consultants, advisors, contractors, agents, officers, and directors. Client is responsible for the use, unauthorized use, or misuse of Client's equipment or software.

4.5. Offsetting Receivables. In relation to the Client, Collect & Exchange CY shall be entitled to offset any of its receivables from the Client against any of the Client's receivables from Collect & Exchange CY of the same type at any time without prior notice, regardless of whether they are due, statute-barred, contingent or noncontingent, regardless of the legal relationship they arise from and the time when they arise, as well as the receivables of Collect & Exchange CY that cannot be claimed before a court. In order to offset the receivables specified in the previous paragraph, Collect & Exchange CY shall also be entitled to use the funds collected on the Client's accounts regardless of whether the receivables arise in connection with the maintenance of the account or otherwise. Collect & Exchange CY shall also be entitled to offset receivables denominated in various currencies, even if these currencies are not freely convertible, at the exchange rate set by Collect & Exchange CY for the date when the receivables are to be offset.

4.6.The Client warrants and represents that neither it nor any of its principals, associates, directors or officers has/have been convicted of or pleaded guilty or nolo contendere to an offense involving fraud, corruption, or moral turpitude, has/have been identified as or affiliated with a person designated as a terrorist or associated with terrorism, bribery or money laundering pursuant to any law or regulation promulgated thereunder (a “Prohibited Person”); or has/have never been identified by any gambling authority as unsuitable to be associated with gaming, denied a gaming license in any jurisdiction or been subject to a suspension or revocation of a gambling license in any jurisdiction (an “Unsuitable Person”).

4.7. The Client/Administrator agrees that during the term of this Agreement, it shall comply with all applicable anticorruption, anti-money laundering, and bribery rules, laws and regulations, including those governing the providing of incentives, inducements, kickbacks, gratuities or bribes and shall not do any business with a Prohibited Person.

4.8. The Client/Administrator shall be entitled to terminate this Agreement: Upon written notice to the Administrator/Client in case of a material breach of this Agreement by the Administrator/Client and the breach is not remedied within thirty (30) days from written notice thereof; Immediately upon written notice to the Administrator/Client and without liability if:

1. 4.9.1. the Client/Administrator should become bankrupt or insolvent, have a receiver, trustee, Administrator or liquidator appointed to it, a petition for an administrative order is presented against it or other actions are taken against it indicating an inability to fully trade or a compound with its.
2. 4.9.2. the Client/Administrator or any of its principals or associates becomes a Prohibited Person;
3. 4.9.3. the Client/Administrator is in breach of clause 4.8.

4.10.Collect & Exchange CY is entitled to refuse to execute any transaction done by the Client. The Client commits and agrees to show upon request any documents related to the transaction.

4.11. The Company may suspend or restrict account activity where required by law, regulation, or to protect the integrity of the system. Where practicable and lawful, the Company shall notify the Client promptly of the reason for such suspension and any steps necessary to remedy the situation. For example, we may suspend or terminate your access to or use of the Service for:

• the actual or suspected violation of these Terms
• the actual or suspected violation any applicable laws or regulations
• the use of the Service(s) in a manner that may cause Collect & Exchange CY to have legal liability or disrupt others use of the Service(s), (each, a "Violation") or if:
• scheduled downtime and recurring downtime, or unplanned technical problems and outages takes place
• we are required to do so by a regulatory authority or court order or by our partner bank
• the account is, or is related to any account that is, subject to any pending litigation, investigation, or governmental proceeding
• we believe someone is attempting to gain unauthorized access to the account or we suspect the Collect & Exchange CY Services are being used in a fraudulent or unauthorized manner
• the account has not been accessed in three months or more
• in case that we believe that there were UBO or structural changes in the management or shareholders

4.11.1.Any refund of Crypto-Assets initiated by the Client shall be subject to prior review and approval by Collect & Exchange CY Ltd in accordance with Regulation (EU) 2023/1114 (MiCA), AML/CFT legislation, and the Company's internal policies.

4.11.2. Approved refunds of Crypto-Assets shall be executed exclusively to the originating blockchain address from which the original transfer was initiated, unless otherwise required by applicable law.

4.11.3. Where a refund is refused, suspended or delayed, the Client shall be informed without undue delay, unless such notification is prohibited by law or would compromise AML/CFT obligations.

4.12.You acknowledge that our decision to take certain actions, including limiting access to, suspending, or closing your Collect & Exchange CY Account, may be based on confidential criteria that are essential for the purposes of our risk management and security protocols. You agree that we are under no obligation to disclose the details of its risk management and security procedures to you.

4.13.Client will remain liable for all amounts due up to and including the date of termination; and/or accordingly may deny the Client access to the Service(s) (or any part thereof). You are responsible for any fees, costs, expenses, charges, or obligations associated with the closing of your Collect & Exchange CY Account. If the costs of closing of your Collect & Exchange CY Account exceed the value in your account, you agree to reimburse us.

4.14.You agree that if we determine, in our sole discretion, that you have committed a Violation, we have the right to debit from your Collect & Exchange CY Account any damages suffered by us as a result of the Violation.

4.15. You agree to be obligated to respond to any requests in writing that you receive from us in relation to investigating your account or transactions or any other information request initiated pursuant to these Terms and Conditions of services within the time frame defined in the request.

4.16.If we refused to complete your transaction or suspended your Collect & Exchange CY Account, we will lift the suspension or complete the transaction as soon as reasonably possible once the reasons for refusal or suspension cease to exist. However, we are not obligated to allow you to reinstate a transaction at the same price or on the same terms as the suspended, reversed or cancelled transaction.

4.17.If we suspend or close your Collect & Exchange CY Account or terminate your use of Collect & Exchange CY Services for any reason, we reserve the right to require you to re-complete account verification before permitting you to transfer or withdraw your assets.

4.18. We may terminate the business relationship with the Client by unilateral refusal to perform the Agreement in cases including, but not limited to:

1. 4.18.1. in the process of studying transactions there appears a suspicion that the business relationship is used by the Client for the purpose of legalizing (laundering) criminal proceeds or financing of terrorism;
2. 4.18.2. sanctions have been imposed on the Client and/or its affiliates, in accordance with the jurisdiction of any country (for example, by the OFAC, US) or an international organization (including but not limited to the FATF and the UN);
3. 4.18.3. we have grounds to believe that the transactions of the Client fall under the effect of international economic sanctions or are aimed at evading international economic sanctions;
4. 4.18.4.on other grounds stipulated by the Collect & Exchange CY internal regulatory documents and procedures aimed at anti-money laundering and combating the financing of terrorism;
5. 4.18.5.for other grounds stipulated by the Law of the Republic of Cyprus on “The prevention and suppression of money laundering and terrorist financing laws of 2007 – 2021 (AML/CFT LAW)” as amended.

4.19.In any case, Collect & Exchange CY shall not be responsible for any loss or damages incurred by Collect & Exchange CY refusal to accept or execute any transaction or wire.

4.20. Title to any Crypto-Asset held in your Custody Wallet shall at all times remain with you. As the legal owner, you retain full control over the Crypto-Assets and bear all associated risks, including but not limited to market volatility, loss of value, and liquidity constraints.

4.21.Collect & Exchange CY Ltd provides custody and administration of Crypto-Assets strictly in accordance with Art.75 of Regulation (EU) 2023/1114 (MiCA). Such custody services do not create any trust, fiduciary, or ownership interest in favour of Collect & Exchange CY Ltd.

4.22.Collect & Exchange CY is under no obligation and bears no responsibility to issue any replacement Crypto-Asset in the event that any Crypto-Asset, password or private key is lost, stolen, malfunctioning, destroyed, or otherwise inaccessible.

4.23. The client confirms that any deposit or withdrawal involving their wallet originated from or has been transferred to a wallet under their ownership, or that they will provide necessary supporting documents if a third party is involved. The client accepts full responsibility for the accuracy of these declarations.

4.24. The client acknowledges and accepts full responsibility for any incorrect information provided in their declarations. The client agrees to bear any consequences or liabilities arising from the provision of inaccurate or misleading information.

5. ADMINISTRATOR'S REMUNERATION

5.1.The Administrator's remuneration shall be provided to Clients prior account opening and be available on the Web application.

5.2.Collect & Exchange CY may require you to provide additional information about yourself or your business, provide records and we may, among other, establish the source of your wealth and source of funds for any transactions carried out in the course of your use of Collect & Exchange CY Services.

5.3.The Client agrees and understands that his/her acceptance of these Client's Terms and Conditions is considered to be his/her acceptance of Collect & Exchange CY's remunerations and/or fees. Collect & Exchange CY reserve the right to change, modify, or increase our remunerations and/or fees at any time.

6. LIMITATION OF LIABILITY

6.1.Neither the Administrator nor any of its officers, directors, managers, principals, shareholders, partners, members, employees, agents, representatives and affiliates (each a “Related Party” and, collectively, the “Related Parties”) shall be liable to the Client or any of its affiliates for any loss or damage arising directly or indirectly (including special, incidental or consequential loss or damage) from the Client's use of the Website and/or Web application including any loss, damage or expense arising from, but not limited to, any defect, error, fault, mistake or inaccuracy with the Website, its contents or the Administrator's web application, or due to any unavailability of the website or any part thereof or any contents or the Web application unless such loss, liability, damage or expense shall be proven to result directly from the willful misconduct of such person. These exclusions for direct, indirect, special, incidental, consequential or exemplary damages include, without limitation, damages for lost profits, lost data, loss of goodwill, work stoppage, computer failure or malfunction, or any other commercial damages or losses.

6.2. In no event will the Administrator or any of its Related Parties be liable to the Client for special, indirect, punitive, or consequential damages, including, without limitation, loss of profits or lost business, even if Administrator has been advised of the possibility of such damages. Under no circumstances will the liability of Administrator and Related Parties exceed, in the aggregate, the fees paid to providers, referred to in clause 6.3., hereunder.

6.3.Collect & Exchange CY shall not be liable to any damage and/or losses incurred by a Client integrated or not to Collect & Exchange CY Web application and/or the Crypto-Asset exchange. The Client agrees and understands that Collect & Exchange CY is a crypto asset service Provider that brings the client a solution based on the Crypto-Asset provider services.

6.4.If the contractual conditions are violated by one of the parties, the aggrieved party shall be entitled to compensation for damage based on the applicable law, unless the other party proves that the obligations have been violated in circumstances excluding liability, legal facts referring to extraordinary, unpredictable and independent event that has caused damage (unless the Agreement or these Terms stipulate expressly otherwise). Circumstances excluding liability on Collect & Exchange CY's side comprise the following events: civil unrest in various forms, fire, flood, terrorist attack, or hacker attack; power supply outage (full or partial); interruption, outage or disruption in computer system operation (hardware or software) or in communication services (including an unexpected EMC outage) on the side of the Client by a provider of the Client; any technical breakdown on the side of the Client/Authorised Person in communication with Collect & Exchange CY; any other extraordinary event, catastrophe, or extraordinary restrictions or instructions making it impossible to obtain the necessary permits in time, which directly or indirectly relate to the individual performances under the Agreement; or any other obstacle occurring independently of Collect & Exchange CY's will and preventing Collect & Exchange CY from discharging its obligations. The Client shall indemnify and keep Collect & Exchange CY indemnified against all damages, costs, expenses, taxes, liabilities or losses of any nature suffered by Collect & Exchange CY through the Client's failure to observe any terms in respect of any instruction agreed with Collect & Exchange CY.

6.5.Nothing in this Agreement shall limit or exclude either party's liability for death or personal injury arising from its negligence.

7. WEB APPLICATION

7.1.Considering that the Client's e-mail address and / or phone number provided to Collect & Exchange CY are used for communication with the Client, accessing of the Custody Wallet of the Client, as well as for the authorization and confirmation purposes, login details to these instruments, including their passwords, shall be protected by the Client.

7.2.The Client is responsible for the login details to Client's e-mail address and phone and must keep them safe, secure, private and confidential at all times and not disclose them to any third parties including friends and family members.

7.3.Collect & Exchange CY recommends memorizing passwords to these instruments and not recording them on any carrier where they can be watched by third parties, the Client's contact information and designated authorities as mentioned in application. The Client is solely responsible for maintaining the security of its keys and/or passwords.

7.4.Client acknowledges and agrees that in case the Web application Services hereunder has any error or delay or has been temporarily suspended, arising from service connection system or computer system or any relevant system or virus attack or electronic equipment problems and / or force majeure or any causes beyond the Collect & Exchange CY control, the Applicant/Client shall not definitely raise such error to claim any damages against the Collect & Exchange CY and shall notify the Collect & Exchange CY immediately of such error. However, Collect & Exchange CY will use its best efforts to solve the issue hastily, and the Applicant/Client agrees to fully assist and cooperate with the Collect & Exchange CY to solve such issues.

8. CLIENT'S REPRESENTATIONS AND WARRANTIES

Upon signing the Agreement, and each time Client submits a crypto-asset service instruction Client represents and warrants that:

8.1. Client has abided by this Agreement and all applicable law with regard to the crypto-asset service instruction.

8.2. Each statement made herewith was true as of the date Client signed this Agreement.

8.3.The Client is obliged to provide updated organizational structure, ultimate beneficial owner, and other relevant KYC information to Collect & Exchange CY as soon as these documents become effective or upon Collect & Exchange CY request in 24 hours.

8.4.Collect & Exchange CY reserves the right to cancel business relations with the Client if the business nature, organizational structure or any other documents of the Client were significantly changed or if such changes make the continuation of the business relationship impossible for Collect & Exchange CY.

8.5.There have been no materially adverse changes in the information provided herewith or in Client's financial condition or management.

8.6. The person who executes the Application on behalf of the Client has the full power and authority to execute the Application and to enter into this Agreement.

8.7.Client will pay all and any fees as stated by Collect & Exchange CY or by integrated parties, including exchange fees and rates. Client will hereby waive any claim in these matters against Collect & Exchange CY and, the Client will perform the action only after understanding and requesting all data and fees and cost for the action, including conversion rates, etc.

8.8. The Client will undertake to establish and maintain effective systems and controls to ensure that, on an ongoing basis, it is properly informed as to, and takes reasonable measures to comply with relevant resolutions or sanctions issued by the United Nations Security Council or by the applied Law and regulations under the Republic of Cyprus. In addition, the Client must confirm that neither the Client nor any of its affiliates or any of its relevant directors, officers, employees, agents or representatives directly or indirectly owned or controlled by an individual or legal entity, is subject to any sanctions currently imposed by government (or any authority) of Canada, USA, EU (or any of its member countries), the United Nations Security Council or any other relevant authorities.

8.9.If, at any time, when the Client or its affiliates, or any of their respective directors, officers, employees, agents or representatives, or other persons or companies owned or managed by the Client is imposed sanctions, the Client shall immediately inform the administrator. Collect & Exchange CY and shall have the right to terminate the Agreement immediately without further liabilities.

8.10.Any violation of provisions of points 8.8-8.9 shall entitle the Collect & Exchange CY to terminate this Agreement immediately without further liabilities.

9. RISK DISCLOSURE

You have requested that Collect & Exchange CY Ltd. facilitate an exchange of your funds into USDT.

Regulatory Status

USDT is not currently authorised as an Electronic Money Token (EMT) under Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA). It is not issued by a credit institution or electronic money institution authorised in the European Union under MiCA and does not benefit from the regulatory safeguards applicable to MiCA-authorised EMTs. I understand that USDT does not benefit from the regulatory safeguards applicable to MiCA-authorised EMTs, including prudential supervision, reserve requirements, redemption rights under MiCA, or EU regulatory oversight of the issuer.

Execution-Only Basis

Collect & Exchange CY Ltd. will execute this transaction strictly on an execution-only basis and solely upon your initiative. Collect & Exchange CY Ltd. does not recommend, endorse, promote, or provide investment advice in relation to USDT.

Risk Disclosure

9.1 USDT Risk

If you have requested that Collect & Exchange CY Ltd. facilitate an exchange of your funds into USDT.

Regulatory Status

USDT is not currently authorised as an Electronic Money Token (EMT) under Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA). It is not issued by a credit institution or electronic money institution authorised in the European Union under MiCA and does not benefit from the regulatory safeguards applicable to MiCA-authorised EMTs.

Execution-Only Basis

Collect & Exchange CY Ltd. will execute this transaction strictly on an execution-only basis and solely upon your initiative. Collect & Exchange CY Ltd. does not recommend, endorse, promote, or provide investment advice in relation to USDT.

Risk Disclosure

Holding or transacting in USDT involves risks, including but not limited to:

• Issuer and counterparty risk
• Reserve asset and backing risk
• De-pegging risk
• Regulatory or enforcement risk within the EU or other jurisdictions
• Liquidity restrictions, suspension, or delisting risk
• Operational and technological risks

No Redemption Guarantee

Collect & Exchange CY Ltd. is not the issuer of USDT and does not guarantee redemption of USDT at par value or at any value. Collect & Exchange CY Ltd. has no control over the issuer's reserves, governance, or redemption mechanisms.

Delisting & Regulatory Action

USDT may in the future become subject to trading restrictions, suspension, delisting, or regulatory prohibition within the European Union or other jurisdictions. Collect & Exchange CY Ltd. shall not be responsible for any losses, inability to trade, suspension events, regulatory measures, or other actions affecting USDT or its issuer.

Client Acknowledgement

I confirm that:

• I have read and understood this disclosure in full;
• I understand that USDT does not benefit from the regulatory safeguards applicable to MiCA-authorised EMTs, including prudential supervision, reserve requirements, redemption rights under MiCA, or EU regulatory oversight of the issuer.
• I acknowledge that USDT is not a MiCA-authorised EMT;
• I understand the associated risks, including potential delisting and lack of redemption guarantees;
• I am requesting this transaction on my own initiative;
• I accept full responsibility for the risks associated with this exchange;
• I confirm that I have conducted my own assessment of USDT and its risks and that I am not relying on Collect & Exchange CY Ltd. for any representation regarding its regulatory status, stability, or suitability.
• I expressly instruct Collect & Exchange CY Ltd. to execute this exchange on an execution-only basis despite USDT not being a MiCA-authorised EMT.

9.2. You acknowledge and agree that you shall access and use the Services at your own risk. The risk of loss when holding and exchanging Crypto-Assets can be significant. Therefore, you should carefully consider whether such services are right for you, given your circumstances and financial resources.

9.3. You should be aware of the following points:

1. 9.3.1. The Client acknowledges and accepts that the value of Crypto-Assets held in their Custody Wallet may be subject to extreme volatility, technological risks, and market disruptions. As a result, the Client may sustain a total loss of the value of the Crypto-Assets held in their Account.
2. 9.3.2. Under certain market conditions, you may find it difficult or impossible to liquidate a position. This can occur, for example, when the market reaches a daily price fluctuation limit or there is insufficient liquidity in the market or in case the bank refuses to accept Fiat that was converted from Crypto or was sent by Crypto exchange.
3. 9.3.4. The value of Crypto-Assets may be derived from the continued willingness of market participants to exchange Crypto-Assets for Crypto-Assets, which may result in a permanent and/or complete loss of value for specific Crypto-Assets in the event that the market for those Crypto-Assets disappears.
4. 9.3.5. That there are risks associated with utilizing an Internet-based system including, but not limited to, the failure of hardware, software, and Internet connections.
5. 9.3.6.That Collect & Exchange CY shall not be responsible for any communication failures, disruptions, errors, distortions or delays you may experience when trading via the Services, however caused.
6. 9.3.7. The volatility and unpredictability of the price of the Crypto-Asset in relation to the Fiat Currency may lead to partial and/or complete losses within a short period of time.
7. 9.3.8. The nature of the Crypto-Assets may lead to an increased risk of financial crime or cyber attacks, and may also mean that technological difficulties may arise that will limit access, including to the complete loss of access to or use of your Crypto-Assets.
8. 9.3.9. Recovery of lost and/or stolen Crypto-Assets may be limited, and in some cases impossible at all.
9. 9.3.10. Transactions with Crypto-Assets may be irreversible and, accordingly, losses due to fraudulent and / or accidental transactions are not recoverable.
10. 9.3.11. The price and liquidity of Crypto-Assets has been subject to large fluctuations in the past and may be subject to large fluctuations in the future.
11. 9.3.12. All the points noted above apply to all Crypto-Assets. This brief statement cannot, of course, disclose all the risks and other aspects associated with these trades.

Risk acknowledgement

9.4.1.By using the Website and/or Web application of Collect & Exchange CY and by entering into this Terms of Services, the Client fully understand and was made aware of the inherent and potential risks associated with a Services in any products or services provided by Collect & Exchange CY, including, but not limited to the risk of a complete loss of value of Crypto-Assets.

9.4.2.I acknowledge the potential risks involved foreseen or otherwise, AND HEREBY UNEQUIVOCALLY AND IRREVOCABLY RELEASE, DISCHARGE, WAIVE AND COVENANT NOT TO SUE AND AGREE TO HOLD HARMLESS Collect & Exchange CY AND ITS OFFICERS, EMPLOYEES, THEIR RESPECTIVE SUCCESSORS, ASSOCIATES or any of its relevant directors, officers, agents or representatives directly or indirectly owned or controlled by an individual or legal entity related to Collect & Exchange CY Ltd and assigns of all of the foregoing from any and all claims, liabilities, legal action for damages, losses, costs directly or indirectly arising out of or otherwise relating in any respect whatsoever to activities, services or products provided by the Collect & Exchange CY.

9.4.3.For the avoidance of doubt, Crypto-Assets may be used as a contractual means of settlement between Clients and payers; however, in accordance with the EU Regulations the General Crypto-Assets do not constitute fiat currency, electronic money. In accordance with the EU Regulations the EMTs are considered as Electronic Money and pegged to the associated fiat currency. Collect & Exchange operates in relation and in accordance with all EU and CY regulations and requirements in relation to this matter. No interest, yield or similar consideration shall accrue in respect of Crypto-Assets held in a Custody Wallet.

10. PROHIBITED USE

10.1. By registering You as a client in our Web application, you warrant that you will not use, any Services and/or the Web application to do any of the following businesses, activities, practices, or items:

1. 10.1.1. Illegal activity that would violate or contribute to the violation of any law, statute, regulation, ordinance or sanctions program or that would involve the proceeds of any illegal activity, also post, distribute or disseminate any illegal material or information.
2. 10.1.2. Abuse of actions that place an unreasonable or disproportionately large load on our infrastructure or damage, intercept or expropriate any system, data or information; also transmit or upload to the Site any material that contains viruses, Trojan horses, worms or any other malicious or harmful software; attempt to gain unauthorized access to the Website/Web application.
3. 10.1.3.Fraudulent activities that are intended to deceive Collect & Exchange CY, Collect & Exchange CY users or any other person; also provide any false, inaccurate or misleading information.
4. 10.1.4. Any activities related to Gambling games such as lotteries, auctions, sports betting or betting, fantasy sports leagues with cash prizes, internet games, contests, lotteries, gambling.
5. 10.1.5. Any activities related to drugs and drug paraphernalia, including the sale of drugs, controlled substances, and any equipment designed to manufacture or use drugs, and pharmaceuticals and other products.
6. 10.1.6. Adult Content and Services: pornography and other obscene material (including literature, images and other media); sites that offer any service of a sexual nature, such as prostitution, escorts, pay-per-view, adult chat features and others.

11. CONFLICTS OF INTEREST

11.1.Collect & Exchange CY will always endeavor to act in your best interests as our Client. However, circumstances can arise where Collect & Exchange CY or one of our other Clients may have some form of interest in business being transacted for you. If this happens or Collect & Exchange CY becomes aware that our interests or those of one of our other Clients appear to conflict with your interests, Collect & Exchange CY will take appropriate steps to manage the conflict of interests fairly wherever possible. So long as Collect & Exchange CY use reasonable commercial endeavors to manage potential conflicts, Collect & Exchange CY will have no liability to you for any conflicts of interest that may arise as a result of our Services, including but not limited to processing transactions for and on behalf of other Clients.

12. CRYPTO-ASSET TERMS OF SALE

12.1. Prices and Availability. All prices reflect the exchange rates applicable to the purchase or sale of Crypto-Assets using the Legal Tender or alternative form of Crypto-Assets identified in your purchase order. All Crypto-Asset sales and purchases are subject to availability, and we reserve the right to discontinue the sale and purchase of Crypto-Assets without notice.

12.2. Errors. In the event of an error, whether via our Services, in a purchase order confirmation, in processing your purchase, or otherwise, we reserve the right to correct such error and revise your purchase transaction accordingly (including charging the correct price) or to cancel the purchase and refund any amount received. Your sole remedy in the event of an error is to cancel your purchase order and obtain a refund of any amount charged.

12.3. No Returns or Refunds. All sales and purchases of Crypto-Assets by Collect & Exchange CY via the Services are final. We do not accept any returns or provide refunds for your purchase of Crypto-Assets from Collect & Exchange CY, except as otherwise provided in these Terms.

13. COMPLAINTS, AND DISPUTE RESOLUTION AND APPLICABLE LAW

13.1.Parties' relations under this Agreement shall be governed by the Laws of the Republic of Cyprus.

13.2. The Parties shall take measures to settle any disputes and differences arising from this General Terms of Services or in relation to its execution by means of negotiations.

13.3.If the Client is not satisfied with the services or activities of the Collect & Exchange CY, the client can submit a complaint to the Collect & Exchange CY in a free form. The complaint must be filed no later than 30 days from the date on which the Client became aware or ought to have become aware of the violation of his rights or legitimate interests. Complaints to the Collect & Exchange CY can be submitted by e-mail at [email protected]. Collect & Exchange CY's Complaints handling procedures are available free of charge to any Client on request.

13.5. Any dispute, whether contractual or non-contractual, arising out of or in connection to this Agreement, including any question regarding its existence, validity, or termination, shall be subject to the exclusive jurisdiction of the Republic of Cyprus Courts. The language to be used in the proceedings shall be Greek. This Terms of Services is governed by the European Union Regulation (EU) on markets in crypto-assets (MiCA) and the prevention and suppression of money laundering and terrorist financing laws of 2007 – 2021 (AML/CFT LAW).

14. CRYPTO-ASSET TRANSFER SERVICES

Crypto-Assets held in Custody Wallets are safeguarded in accordance with Art. 75 of Regulation (EU) 2023/1114 (MiCA) and the Company's internal safeguarding arrangements, including segregation of client assets, reconciliation and record-keeping requirements.

14.1. Regulatory Basis. The Company provides crypto-asset transfer services in accordance with Article 82(1) and Article 82(2) of Regulation (EU) 2023/1114 (MiCAR). This section governs the execution, rejection, liability, and disclosure obligations related to such transfers.

14.2. Execution of Transfers

1. Transfer instructions must be submitted via the Platform
2. Execution times may vary due to blockchain congestion, network latency, or compliance verification procedures

14.3. Rejection, Suspension, and Return of Transfers

14.3.1. The Company reserves the right to reject or suspend in the following circumstances: (a) Non-compliance with AML/CFT obligations; (b) Invalid or blacklisted recipient address; (c) Insufficient Account balance; (d) Technical or regulatory impediments.

14.3.2. In the event of rejection or suspension, the Client shall be notified promptly, including the reason and any applicable remedies.

14.4. Information Disclosure

For each executed transfer, the Client shall receive confirmation including: (a) Transaction identifier; (b) Transferred amount and crypto-asset type; (c) Recipient address; (d) Timestamp of execution; (e) Applicable fees.

14.5. Liability

14.5.1. The Company shall be liable for losses arising from failed or erroneous transfers only where such failure is attributable to proven negligence or willful misconduct.

14.5.2. The Client is solely responsible for ensuring the accuracy of transfer instructions, including the correctness of recipient addresses.

14.6. Internal Controls

14.6.1. The Company maintains documented procedures and internal controls to ensure the secure and compliant execution of crypto-asset transfers.

14.6.2. These controls include transaction monitoring, fraud detection mechanisms, and escalation protocols.

14.7. Compliance with the Travel Rule

The Company ensures that all transfers of crypto-assets include the originator and beneficiary information required under Regulation (EU) 2015/847, as amended by Regulation (EU) 2023/1113.

15. MISCELLANEOUS

15.1.This Agreement shall be deemed concluded and shall enter into force on the date the Client electronically accepts the Terms by ticking the acceptance box and clicking “Continue” or any equivalent confirmation mechanism provided on the Collect & Exchange CY Ltd Web application or Website. Such electronic acceptance shall constitute full and binding execution of the Agreement by the Client, with the same legal effect as a signed written contract, in accordance with applicable law and Regulation (EU) 2023/1114 (MiCA).

15.2.Collect & Exchange CY reserves the right to change, correct, supplement, expand, improve, make any other amendments to the Terms of Services (or any part thereof) without prior notice at any time with such changes effective immediately. In case of disagreement with such changes, the Client may terminate the Terms of Services by sending a notice in free written form.

15.3. The European Union Regulation (EU) on markets in crypto-assets (MiCA) and the prevention and suppression of money laundering and terrorist financing laws of 2007 – 2021 (AML/CFT LAW) shall apply to this Agreement.

15.4.Collect & Exchange CY Ltd reserves the right to deduct any amount from the Client's fiat account to cover fees, charges, or liabilities incurred by the Client, including those arising from transactions, account maintenance, or interactions with partner banks and financial institutions. Such deductions may be made without prior notice, provided they are in accordance with these Terms, applicable law, and the Company's internal policies.

15.5. The Company operates solely within the scope of activities authorised by the Cyprus Securities and Exchange Commission under MiCA.

15.6.If any of the Agreement provision become void for any reason, including adoption of new statutory act, the other provisions of the Agreement remain in full force and effect and shall be binding on its Parties, and the Collect & Exchange CY shall take all necessary measures to review such provision or to bring the Agreement in line with the requirements of new statutory act.

16. STABLECOINS DISCLOSURE

Please note that based on the European Banking Authority (“EBA”) No Action Letter on the interplay between Directive (EU) 2015/2366 on payment services in the internal market (“PSD2”) and Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCAR”), which was published on 10 June 2025 and (ii) to the EBA's follow up opinion published on 12 February 2026 from 2nd of March 2026 you are not allowed to:

1. make a transfer of crypto assets where they entail electronic money tokens (“EMTs”) and in the web application of Collect & Exchange CY — https://collectnexchange.cy, as well as
2. have a custody and administration services of EMTs within Collect & Exchange Web application — https://collectnexchange.cy. Custodial wallets are also regarded as a payment account under the PSD2 whereas the held in the name of one or more clients and allows to send and receive EMTs to and from third parties.

17. PAYMENT PROCESSING IN DIGITAL ASSETS

Clientmeans a legal entity or other commercial organization that is a client of Collect & Exchange and that, acting in a commercial capacity, accepts payments in Digital Assets from payers for goods, works and/or services.

Payers means third parties who initiate payments in Digital Assets in favour of the Client.

1. Collect & Exchange shall provide, and the Client shall accept, Digital Assets payment services, as well as information and technology services, aimed at enabling the acceptance of Payments in Digital Assets from Payers in favour of the Client for goods, works and/or services sold by the Client through the Collect & Exchange System.
2. Within the framework of providing crypto-payment services, Collect & Exchange shall provide the Client with technical infrastructure, software solutions and services enabling: (a) generation of crypto addresses and/or QR codes for the acceptance of payments in Digital Assets; (b) processing and accounting of payments in Digital Assets; (c) transaction monitoring for the purposes of AML/CFT compliance and internal risk management procedures; (d) enabling the Client, following completion of applicable compliance checks, to dispose of Digital Assets exclusively through the services and functionality of the Collect & Exchange Web Application.
3. Collect & Exchange acts as a Crypto Assets Service Provider under the EU and CY Legal framework and provides the Services within the scope of its CASP license and in accordance with applicable EU and CY laws and regulations:
   
   The Client shall be solely responsible for ensuring that all traffic, merchants, Distribution Partners, End Users, marketing activities, websites, applications, payment flows, and business practices connected to the Company are lawful, legitimate, and fully compliant with all requirements set forth herein:
   
   Scope of Compliance: The Affiliate shall ensure compliance with:
   • all applicable laws and regulations of the European Union and any relevant jurisdiction, as interpreted by the Company for risk management purposes
   • Regulation (EU) 2023/1114 (MiCA)
   • Regulation (EU) 2023/1113 (Travel Rule)
   • applicable AML/CFT legislation
   • GDPR and applicable data protection laws, as they relate to Company-approved processing activities
   • card scheme rules and requirements issued by Visa, Mastercard, or any other payment network
   • acquiring bank requirements
   • payment service provider requirements
   • API integration requirements, technical standards, security requirements, operating procedures, and compliance instructions issued by the Company from time to time
   • any other regulatory, legal, compliance, operational, risk management, fraud prevention, or security requirements communicated by the Company
   Prohibition on Improper Traffic: The Affiliate shall not generate, facilitate, permit, or introduce any fraudulent, deceptive, misleading, unlawful, sanctioned, prohibited, high-risk, incentivised, artificial, manipulated, or non-compliant traffic.
   
   Immediate Notification: The Affiliate shall immediately notify the Company upon becoming aware of any activity that may result in fraud losses, excessive chargebacks, card scheme monitoring, regulatory breaches, sanctions exposure, financial crime risk, reputational damage, or any breach of applicable law.
4. The Client shall pay remuneration (fees and commissions) to Collect & Exchange for the crypto-payment and related services rendered, in the amounts, manner, timeframes and on the terms specified in Collect & Exchange's applicable documents (including, but not limited to, tariffs, fee schedules, service terms and regulations) provided or made available to the Client.
5. The documents of Collect & Exchange governing fees, commissions and other financial conditions form an integral part of these General Terms of Services and apply in the version in effect at the time of provision of the relevant services and provided to each Client individually.
6. The Parties acknowledge that the services of Collect & Exchange are provided under the EU and CY regulatory framework.
7. For the purpose of providing services, Collect & Exchange shall generate one or more dedicated crypto addresses or QR code for the Client within the Collect & Exchange system.
8. The Payers of Client's shall transfer payments directly to the crypto address(es) generated for the Clients.
9. The QR and/or crypto address shall be generated using Collect & Exchange's technical infrastructure and/or with the involvement of third-party service providers. The Client acknowledges and agrees that Collect & Exchange may engage third-party providers to facilitate certain technical aspects of the service.
10. Each generated crypto address and or QR code is unique to the Client and shall be used exclusively for the acceptance of payments in the Client's business activities. The Client shall not use the address for purposes outside the scope of the services, including for private transfers unrelated to business activity or for any attempts to circumvent compliance procedures.
11. All payments received at the Client's designated crypto address during a calendar day shall be recorded and aggregated by the Collect & Exchange system. The received payments will remain temporarily at that crypto address pending the completion of an internal transaction review by Collect & Exchange. Collect & Exchange temporarily accumulates Digital Assets received at the Client's address solely for processing, accounting and AML/CFT purposes. Such Digital Assets are not deposits and are not the property of Collect & Exchange.
12. After completion of the relevant checks, the Client may initiate the transfer of the Digital Assets to its own wallet held with a licensed virtual or digital asset service provider exclusively through the Collect & Exchange Web Application.
13. During the transaction review period, the Client: (a) has no access to any private keys related to the crypto address provided; (b) is not entitled to independently transfer, withdraw, or otherwise dispose of the Digital Assets held at the address; and (c) is not entitled to withdraw or transfer Digital Assets from the address directly to any third-party wallets.
14. The transaction review will be conducted by Collect & Exchange for the purposes of ensuring AML/CFT compliance in accordance with applicable law and internal procedures, assessing transactional activity, and implementing internal compliance controls and risk management measures. The Client undertakes to fully cooperate with Collect & Exchange in the course of any AML/CFT reviews, providing all required documentation and clarifications within reasonable timeframes. If no compliance violations or other issues are identified during the review, Collect & Exchange will enable the Client to dispose of or use the received Digital Assets through the services provided on the Collect & Exchange platform.

Indemnity and Financial Responsibilities

Indemnity:The Affiliate shall fully indemnify, defend, and hold harmless the Company, its shareholders, directors, officers, employees, affiliates, service providers, banking partners, payment processors, and licensors against any and all losses, liabilities, claims, damages, penalties, fines, assessments, costs, chargebacks, scheme fees, monitoring programme fees, legal expenses, regulatory sanctions, investigations, settlement amounts, or other expenses arising directly or indirectly from: (i) the Affiliate's traffic; (ii) merchants introduced by the Affiliate; (iii) Distribution Partners introduced by the Affiliate; (iv) any breach of this Agreement by the Affiliate; (v) any breach of applicable law or regulatory requirements by the Affiliate; or (vi) any act, omission, negligence, misconduct, fraud, or wilful misconduct of the Affiliate or its representatives.

Penalties and Fees:The Affiliate shall indemnify and hold harmless the Company against any fines, penalties, assessments, chargebacks, monitoring programme costs, scheme fees, fraud losses, regulatory sanctions, or damages imposed by Visa, Mastercard, payment processors, acquiring banks, regulators, or competent authorities arising directly or indirectly from the Affiliate's traffic, merchants, marketing practices, or introduced users.

Company's Right to Settle and Recover: The Company may immediately deduct such amounts from any sums payable to the Affiliate. The Company may utilise, liquidate, apply, or set-off any guarantee deposit, reserve balance, or other collateral held in connection with this Agreement against any losses, fines, penalties, chargebacks, fraud losses, regulatory liabilities, scheme assessments, or other amounts owed by the Affiliate. If there are no payable sums to the Affiliate, the Company may redirect a claim to the Affiliate. The Company may immediately withhold, deduct, set-off, recover, or retain any such amounts from Affiliate Fees, reserves, guarantee deposits, settlement balances, or any other amounts held by or payable by the Company to the Affiliate. If such amounts exceed funds held by the Company, the Affiliate shall reimburse the Company within five (5) Business Days of written demand. Failure to timely reimburse shall constitute a material breach of this Agreement.

Financial Stability and Termination: The Affiliate shall maintain sufficient financial resources to satisfy its obligations under this Section and shall remain liable for such obligations notwithstanding the termination or expiration of this Agreement.

15. Any withdrawal or outward transfer of Digital Assets from the Client's balance shall be carried out solely through Collect & Exchange's services and in accordance with the procedures set out in these Terms and the platform. The Client may initiate withdrawals or transfers only via the Collect & Exchange Platform interface or APIs, subject to any further verification steps required by Collect & Exchange.
16. Collect & Exchange is entitled to suspend, delay, or restrict the Client's ability to withdraw or transfer Digital Assets in the event of suspicious transactions, elevated risk indicators, or the need for additional verification or compliance review. Such suspension may remain in effect until the cause of concern has been resolved to Collect & Exchange's satisfaction, and any required regulatory reports or actions are completed.
17. Integration of the Client's systems with Collect & Exchange's crypto-payment system shall be performed via the Application Programming Interface provided by Collect & Exchange. The API will be used for generating payment requests, retrieving transaction statuses, and automating the acceptance and acknowledgment of Payments.
18. The Client is fully responsible for properly integrating with the API, including safeguarding API keys, maintaining the security of its integration, and protecting access to its systems. The Client shall follow Collect & Exchange's technical guidelines and security recommendations for integration. Collect & Exchange shall not be liable for any failures, errors, or losses resulting from incorrect integration by the Client or from actions or omissions on the part of the Client. The Client bears all risks related to its own technical infrastructure and integration processes.
19. All requests by the Client to initiate a refund of Digital Assets via Collect & Exchange's system are subject to mandatory review and prior approval by Collect & Exchange. The Client must provide any information or documentation requested to support the refund review.
20. Collect & Exchange reserves the right to refuse or decline processing a proposed refund if the refund request does not comply with these Terms, Collect & Exchange's internal policies, security requirements, or applicable legal/regulatory requirements.
21. Any approved refund of Digital Assets shall be made exclusively to the originating blockchain address from which the payment was originally sent. Refunds to any address other than the original sender's address are not permitted and will not be processed by Collect & Exchange, regardless of the reasons or circumstances. The Client is not authorized to request or instruct a refund to a different address.
22. The Client is solely responsible for the accuracy of all details provided for any refund transaction. This includes but is not limited to the refund amount, the correct blockchain network, the destination address which must be the original sender's address, and any required memo, tag, or payment identifier. Any error in the provided details may result in irreversible loss of funds, for which the Client bears full responsibility.
23. If the Client issues a refund to payer in Digital Assets without prior confirmation or approval from Collect & Exchange, issuing a refund directly from other sources or before Collect & Exchange has confirmed the original transaction or authorized the refund, such refund is made at the Client's own risk. Collect & Exchange shall not be liable for any consequences or losses arising from any refund action taken by the Client independently of the Collect & Exchange system or without required approval.
24. The Client undertakes not to use the Collect & Exchange services for any transactions or activities that: (a) are prohibited under the Acting Law of the European Union and the Republic of Cyprus, or any other applicable laws or regulations including sanctions regimes and the acts of international organizations such as the United Nations), or that violate decisions of courts or other competent authorities and etc.; (b) involve goods and/or services that are illegal or restricted or sanctioned under applicable law, AML/CFT standards, or Collect & Exchange's internal policies, including but not limited to: (1) virtual asset-related business activities conducted without required licenses or regulatory approval; (2) gambling, betting, or gaming services provided without appropriate authorization or licensing; (3) trafficking or distribution of narcotic or psychotropic substances, weapons, or ammunition; (4) sale of pharmaceutical or medical products that require licensing, without possessing valid permits; (5) involve individuals or entities that are on any international or national sanctions lists, terrorist or extremist watchlists, or other restricted-party lists as applicable under international sanctions regimes, foreign legislation, EU and CY Laws, or Collect & Exchange's internal procedures; (c) and another illegal act.
25. Collect & Exchange may restrict, delay, or refuse to process refunds of Digital Assets in cases of suspected fraud, violation of these Terms, or in order to comply with applicable legal or regulatory requirements. This includes situations where a refund might facilitate money laundering, terrorism financing, or other illicit activity.
26. Any refund processed may be subject to additional fees or specific conditions. Collect & Exchange will communicate any such applicable fees or conditions to the Client prior to completing the refund transaction, and may require the Client's acknowledgment or acceptance of these terms before proceeding.
27. The Client remains solely responsible for refunding payer the full amount of the original payment. Any such commission or fee is not recoverable from Collect & Exchange by either the Client or the payer once the original transaction has been executed.
28. Collect & Exchange is not obliged to reimburse the Client or the payers for any retained commission or fees related to a transaction that is subsequently refunded. Furthermore, Collect & Exchange shall not be liable for handling or settling any disputes between the Client and payers regarding amounts to be refunded or any compensation for fees.
29. When a refund is executed to the original sender's address, the Client accepts all risks associated with the refund. This includes the risk of loss if the original address was associated with a cryptocurrency exchange or third-party service, where the funds might not be credited to the intended user without proper memo/tag, or the exchange's policies might prevent return of funds. The Client acknowledges that Collect & Exchange has no control over, and assumes no responsibility for, the handling of funds by any third-party platform that provided the original address.
30. In cases where Digital Assets need to be extracted or recovered due to technical issues, unsupported Digital Assets types, or mistaken transfers, the process may take up to thirty (30) business days, or longer if necessary, to safely complete the extraction. Collect & Exchange will endeavor to complete any Digital Assets extraction as soon as practicable, but makes no guarantee that it can be done sooner than the stated timeframe.
31. Digital Assets that are not supported by Collect & Exchange's platform or services may not be eligible for return or extraction. If Client or payer sends an unsupported digital asset or token to an address provided by Collect & Exchange, Collect & Exchange is not obliged to recover or return such asset. Any decision to attempt retrieval of unsupported assets is at the sole discretion of Collect & Exchange.
32. All decisions made by Collect & Exchange regarding the extraction or non-recovery of assets including unsupported Digital Assets or Digital Assets sent in error shall be final and binding. Collect & Exchange shall not be liable for any loss of unsupported or irretrievable Digital Assets, except to the extent required by applicable law.
33. Any refund of Digital Assets initiated by the Client to payer without explicit confirmation or instruction from Collect & Exchange such as a direct wallet transfer outside of the Collect & Exchange Platform, or a refund initiated before Collect & Exchange has approved or processed the original transaction is considered a premature refund. Such action is undertaken entirely at the Client's own risk.
34. Collect & Exchange shall not be liable for any losses, errors, or disputes arising from a premature or unauthorized refund made by the Client. The Client bears full responsibility for resolving any consequences of such a refund including, but not limited to, reconciliation issues or financial loss, and Collect & Exchange may be unable to assist in recovering any funds dispensed in this manner.
35. Collect & Exchange reserves the right, acting reasonably and in good faith, and solely for legitimate purposes, to initiate and execute a full or partial refund of a Digital Asset transaction without prior consent of the Client where such refund is required or deemed necessary: (a) to comply with applicable laws or regulations, including AML/CFT and sanctions requirements; (b) to comply with a request, instruction or order of any competent authority, court, regulator or partner financial institution; (c) to mitigate or prevent legal, regulatory, financial or reputational risk to Collect & Exchange; or (d) in accordance with Collect & Exchange's internal compliance, risk management and security policies, as amended from time to time.
36. Collect & Exchange shall not be obliged to provide prior notice of, or disclose detailed reasons for, any refund action were doing so would be prohibited by law, regulatory requirements, or would compromise compliance reviews, investigations, or risk management procedures. Where legally and regulatorily permissible, Collect & Exchange may inform the Client of the refund after its execution.
37. Any refund executed by Collect & Exchange in accordance with this Annex and the General Terms of Services shall not constitute a breach of the Agreement. Collect & Exchange shall not be liable for any loss, damage, loss of profit or business interruption suffered by the Client as a result of such refund, provided that Collect & Exchange acted in good faith and within the scope of its rights under this Agreement and applicable law.
38. Any matters not expressly regulated in this Annex shall be governed by the applicable laws of the Republic of Cyprus and the provisions of the General Terms of Services between the Client and Collect & Exchange.
39. For the avoidance of doubt, Digital Assets processed, recorded or temporarily accumulated under this Annex may be used by Payers as a means of payment for goods, works and/or services provided by the Client. No interest, yield or similar consideration shall accrue in respect of Digital Assets. References to balances or records in relation to Digital Assets are notional and maintained solely for technical, accounting, compliance and operational purposes.