These Terms govern your access to and use of the centralized financial (“CeFi”) services (the “Services”) provided on or through the Fintopio platform (the “Platform”). By accessing the Platform and using the Services, or by clicking to accept or agree to these Terms where such option is made available, you hereby represent, warrant, and acknowledge that:

• You have carefully reviewed, fully understand, and agree to be legally bound by these Terms;
• You acknowledge and accept all risks associated with virtual assets and virtual asset transactions, as set forth in our Risks Disclosure Statement available at https://fintopio.kg/risk-disclosure-statement;
• You consent to the collection, use, disclosure, and other handling of your personal data in accordance with our Privacy Policy and Cookie Policy, available at https://fintopio.kg/privacy-policy-kg and https://fintopio.kg/cookie-policy-kg respectively; and
• You agree to be bound by any additional terms, rules, and conditions of use that we or any third party may issue from time to time in connection with the Services, including those that are necessary to access the Platform and use the Services.

As with any asset, the value of virtual assets may fluctuate substantially, and engaging in the purchase, sale, holding, or investment of virtual assets involves a significant risk of financial loss. Before you trade or hold virtual Assets, you should carefully assess whether doing so is appropriate considering your individual financial situation. For additional information regarding the risks involved in accessing and using the Services, please refer to our Risks Disclosure Statement at https://fintopio.kg/risk-disclosure-statement. Although this Risk Disclosure document provides important risk-related information, it may not identify every risk or relate each risk to your personal circumstances. We may update this Risks Disclosure Statement from time to time, and you should thoroughly review it on a regular basis.

It is essential that you fully understand all associated risks before deciding to use the Services. We act solely as a Virtual Assets Services Provider and are not your broker, intermediary, agent, or advisor. We owe you no fiduciary duties or obligations in connection with any Transactions or activities carried out through your use of the Services. We do not provide investment or financial advice under any circumstances, and no communication or information we provide to you should be construed as such. You bear sole responsibility for determining whether any investment, investment strategy, or related transaction is suitable for you, given your personal investment goals, financial circumstances, and risk tolerance. You are solely liable for any losses incurred in relation to any virtual asset transaction as we do not recommend the purchase, sale, transfer, or holding of any virtual asset. Before making any decision to buy, sell, earn, or hold virtual assets, we strongly encourage you to do your own research (DYOR), conduct independent due diligence and if possible, consult a professional financial advisor. We assume no responsibility for any decision you make to engage in virtual asset transactions or for any losses you may incur because of such decisions, even if such decisions are based on the information we provide on the Platform with respect to the Services. Any communication or information we provide on the Platform in relation to the Services is provided solely for informational purposes.

1. Right to Amend. We may modify, revise, or update these Terms, including any rules, policies, or documents incorporated by reference (collectively, the “Terms”), at any time.
2. Notification and Acceptance. Changes of these Terms will be posted on the Platform and may also be communicated by email, in-app notification, or by any other means we deem appropriate. Your continued use of the Services constitutes your acceptance of any revised Terms. While we generally endeavour to provide reasonable notice before changes become effective, there may be situations such as to (i) comply with legal or regulatory obligations, (ii) clarify existing provisions, where changes take effect immediately upon publication. In such cases, we will notify you as soon as reasonably practicable after the changes are implemented.
   Except where changes become effective immediately, any update to these Terms will become binding upon you once we have notified you (including by means of posting on the Platform). If you do not agree to the changes, you may terminate your Fintopio Account in accordance with these Terms. Your continued access to or use of the Services after any such notice will be deemed acceptance of the updated Terms.

We provide a range of CeFi services (the “Services”) through the Fintopio Platform. These Services include, without limitation:

• On-Ramp Services: Facilitating the conversion of fiat currencies into virtual assets, including fiat-to-crypto conversions and payment processing through third parties.
• Off-Ramp Services: Facilitating the conversion of virtual assets back into fiat currencies, including crypto-to-fiat conversions, withdrawal processing, and payment gateway integrations.
• Virtual Assets Trading: Enabling the purchase, sale, and trading of virtual assets, as well as managing trade execution, liquidity provision, and access to real-time market data.
• Transfers, Exchanges, and Conversions: Allowing you to send, receive, transfer, exchange, and convert various virtual assets seamlessly.
• Custody Services: Providing secure storage solutions to safeguard your virtual assets.
• Virtual Assets Management: Offering portfolio management tools, analytics, reporting features, and integration with financial tools to help you effectively manage your digital asset holdings.
• Broker-Dealer Services: Acting as an intermediary for the purchase and sale of virtual assets on your behalf, ensuring efficient and accurate transaction settlements.
• Over-The-Counter (OTC) Services: Supporting large-scale, private virtual asset transactions directly between buyers and sellers, independent of our public order books.
• Peer-to-Peer (P2P) Services: Supporting direct transactions between users, including user matching, escrow arrangements, and dispute resolution mechanisms.
• Staking Services: Allowing you to stake your virtual assets on the Fintopio Platform (via third party API integrations) to earn rewards and support underlying network operations.

We may also offer any additional services ancillary or incidental to the provision of these Services. We reserve the right to introduce new Services, modify existing Services, or discontinue certain Services at any time, in our sole discretion. The availability of certain Services may depend on your jurisdiction and applicable regulations.

1. General Requirements. To be eligible to access and use the Services, you must:
   1. be an individual at least eighteen (18) years of age, or of the legal age of majority in your jurisdiction of residence, whichever is greater;
   2. you have the full capacity and authority to agree to the Terms, and to enter into any transactions or use the Service provided on the Platform;
   3. if acting on behalf of a legal entity, represent and warrant that such entity is duly formed, validly existing under applicable laws, and that you are fully authorized to bind the entity to these Terms;
   4. not be located in, or be a resident, citizen, or national of any jurisdiction where the provision, access, or use of the Services would violate applicable laws, regulations, or sanctions, including any jurisdiction that appears on our list of prohibited or restricted countries (as provided on the Platform) or that is designated as high-risk or non-cooperative by the Financial Action Task Force (FATF);
   5. not be identified on, or associated with any individual or entity identified on, any list of prohibited or restricted parties maintained by a relevant governmental authority, including but not limited to the United Nations Security Council Sanctions List, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) list of Specially Designated Nationals, the European Union or HM Treasury's financial sanctions regimes, or similar sanctions lists (each a “Sanctioned Country”);
   6. You are not identified on any economic sanctions lists published by applicable authorities (including, but not limited to, those issued by the Ministry of Interior, the Executive Office for Control and Non-Proliferation, the United Nations Security Council, or any other comparable sanctioning body) (a “Sanctioned Person”), or otherwise restricted from using financial services and/or the virtual assets services provided by us;
   7. not be located in, or be a resident of, any jurisdiction where the use of virtual asset services, and/or communications platforms (such as Telegram), is prohibited or blocked;
   8. not have been previously suspended or removed from using our Services, and not presently have an existing account with us that violates these Terms;
   9. not use any software, tool, technique, or other methods (including without limitation Tor, VPN or remote access software) to misrepresent your location, bypass geographical restrictions, or to engage in activities considered illegal under applicable law (including but not limited to money laundering, terrorist financing, fraud, or any other financial crimes);
   10. Conduct transactions using legally obtained virtual assets and/or Fiat Currency supported on the Platform and rightfully owned by you, free of any liens, claims, or encumbrances. At the time you transfer any such virtual assets or Fiat Currency to us or any third party through the Platform, you hold full legal and beneficial title to them, as well as all rights necessary to authorize their use.
   11. not a citizen, resident, or physically located in the United States (“U.S.”). Individuals residing in, or accessing the Services from, the U.S. are prohibited from registering an account with the Platform and from using the Services; and
   12. agree that each time you access or use the Services, you will do so in a manner that does not violate any applicable laws, rules, or regulations, including those of any sanctioned country or territory.
2. Compliance with Applicable Laws. You are responsible for ensuring that your use of the Services complies with all applicable laws, regulations, and rules. You must not use the Services if such use is unlawful or requires any form of regulatory approval that has not been obtained.
3. Changes to Eligibility Criteria. We reserve the right, at our sole discretion, to amend our eligibility criteria and impose additional requirements or restrictions on your use of the Services at any time, with or without prior notice. If changes are required by law, are made for your protection, or must be implemented promptly for any other valid reason, we may do so without advance notice. If at any time we determine, in our sole discretion, that you no longer meet these criteria, we may immediately suspend or terminate your access to the Services. We will notify you of such changes as soon as reasonably practicable.

We reserve the right to limit the availability of all or part of the Services in certain markets or jurisdictions. Nothing in these Terms should be construed as exempting you from the laws of your country or region of residence. If you do not meet these eligibility requirements, you must not access or use the Services. By accessing or using the Services, you represent and warrant that you meet all of the eligibility criteria set forth in these Terms.

1. Account Creation: To access and use the Services, you must create and maintain a Fintopio account (“Fintopio Account”). Depending on whether you are an individual or acting on behalf of a legal entity, you represent and warrant that you have the authority, capacity, and all necessary consents to open, maintain, and operate a Fintopio Account. We may, at our sole discretion and without obligation to provide any reasons, refuse to open an account for you, limit your access to the services, suspend or terminate your Fintopio Account.
2. Single Account Use. You may only open and operate one Fintopio Account, unless expressly authorized in writing by us. Attempting to register or operate multiple accounts without our prior written consent may result in immediate account closure and/or other actions we deem appropriate.
3. Identity Verification and Customer Due Diligence (CDD). As a condition to opening and maintaining a Fintopio Account, and to comply with applicable legal and regulatory requirements, you agree to provide all information and documentation we request for the purpose of verifying your identity and conducting mandatory CDD procedures. Such information may include, without limitation, your full legal name, residential or registered business address, valid phone number, email address, date of birth or incorporation, relevant Know Your Customer (KYC) identification documents such as government-issued identification (IDs) or passports, banking details, proof and source of funds, taxpayer identification number, and a real-time liveness selfie as well as any other information or documents we may require from time to time. You represent and warrant that all information you provide to us is accurate, truthful, and complete, and you agree to promptly update us if any of this information changes. You authorize us to perform any necessary inquiries, either directly or through third parties, including verification service providers or agencies, to confirm your identity, assess your ongoing eligibility, and protect against financial crimes such as fraud, money laundering, or terrorist financing. You acknowledge that our identity verification and CDD procedures may result in temporary delays or limitations in accessing the platform and the Services. These measures are essential to ensure compliance and protect against potential risks. Fintopio Kg shall not be liable for any delays, suspensions, or losses incurred because of such procedures. By registering a Fintopio Account, you agree to these terms and to abide by all applicable policies, including our Privacy Policy and Anti-money Laundering/Know Your Customer Policy (AML/KYC Policy).
4. Tiered Access and Ongoing Compliance. Your access to certain features, transaction limits, and services may depend upon the level of CDD and verification we have completed. We may periodically require you to submit updated or additional information or documents to maintain your account’s verification status and/or to enable you to upgrade to another level of CDD and verification. If at any time we determine that information you have provided is insufficient, outdated, or otherwise unsatisfactory, we may, at our sole discretion, impose restrictions on your Fintopio Account, suspend or terminate your access to the Services, or require you to undergo enhanced due diligence procedures.
5. Enhanced Due Diligence (EDD). We may, at our sole discretion, require you to undergo enhanced due diligence procedures (“Enhanced Due Diligence”) to access certain Services, increase your account limits, or otherwise comply with applicable laws. Such procedures may include providing additional or updated information and documentation about yourself or your business, arranging meetings with our representatives, or any other actions we deem necessary. We reserve the right to charge fees or costs associated with Enhanced Due Diligence, and we will inform you in advance if such charges apply. Completion of Enhanced Due Diligence does not guarantee approval for increased limits or continued access to the Services, and we may reduce or refuse to increase your limits at any time.
6. Account Monitoring and Records Retention. We maintain records of your information for the duration of your account's activity and for a minimum of eight (8) years after account closure or as otherwise required by applicable laws and regulations. This includes maintaining updated records for periodic CDD reviews throughout the lifespan of your account. Fintopio may, at its sole discretion, conduct necessary inquiries, directly or through third parties, to monitor your account, verify your identity and to prevent fraud, money laundering, terrorist financing, or any other financial crime. These inquiries may involve sharing your personal information with compliance agencies, fraud prevention bodies, or identity verification service providers. By registering a Fintopio Account, you authorize us to perform these inquiries and take any actions deemed necessary based on the results. You acknowledge and agree that we may collect, store, and use the information and documents you provide during the account registration process, in accordance with our Privacy Policy and applicable laws and regulations, including recordkeeping and retention requirements.
7. No Third-Party Access. You must not permit any unauthorized person to access, use, or control your Fintopio Account or to use the Services on your behalf without our prior written consent. You remain fully responsible for any actions taken under your Fintopio Account, whether by you or by any person acting under your authorization.

1. Access Requirements. To access and use your Fintopio Account, you must possess the necessary equipment (such as a computer or smartphone) and maintain a reliable internet connection. We may specify additional methods or requirements for accessing your Fintopio Account, including the use of application programming interfaces (APIs). You are only permitted to access your account using the unique login credentials, security measures, or other access identifiers (“Access IDs”) we provide, and we may require multi-factor authentication or other enhanced security measures at our discretion.
2. Authorized Use and Third-Party Access. Your Fintopio Account is for your sole, authorized use. If you are opening and maintaining the account on behalf of a legal entity, all individuals authorized to access the account (“Permitted Users”) must do so strictly in accordance with these Terms. Unless we provide our prior written consent, you must not grant, directly or indirectly, any third party the right or ability to access your Fintopio Account. You acknowledge and accept full responsibility for all actions and transactions carried out under your Fintopio Account, whether by you or any Permitted User.
3. Instructions. You agree that all instructions you submit through the Platform (“Instructions”) must be complete, accurate, and properly authorized. We are under no obligation to verify the accuracy, authenticity, or validity of any Instruction, nor are we required to reject duplicate or erroneous Instructions. Once submitted, Instructions are considered final and irrevocable, and you may not rescind or withdraw them without our express written consent. Our records of Instructions are conclusive and binding on you for all purposes. By issuing an Instruction, you authorize us to execute the requested transaction, which may include debiting or crediting your account or providing necessary settlement information to third parties. If your Fintopio Account does not contain sufficient digital assets or fiat currency to cover the transaction and associated fees, we may refuse to process the transaction.
4. Accuracy and Security of Communications. You acknowledge that Instructions and other information transmitted to or from your Fintopio Account may travel over public networks, potentially exposing such communications to unauthorized interception or access. While we employ reasonable security measures, we cannot guarantee absolute protection against unauthorized access. You assume all associated risks and agree that we are not liable for any losses arising from interception or unauthorized access to your Instructions or communications.
5. Withdrawals. Subject to these Terms, the availability of the relevant services, and any applicable limits, you may instruct us to withdraw digital assets from your Fintopio Account to an external address by following the withdrawal procedures we establish. We will make reasonable efforts to process your withdrawal requests promptly. However, we may refuse or delay withdrawals if we believe doing so is necessary to comply with applicable laws, regulations, or these Terms, or to investigate potential security incidents or unauthorized activities. Once any such concerns are resolved, withdrawals may resume.

1. User Responsibility: You are solely responsible for maintaining the security and confidentiality of your Fintopio Account credentials, including passwords, email addresses, and any two-factor authentication (2FA) codes. You agree to: (i) Use strong, unique passwords and update them regularly, (ii) Safeguard your login credentials and refrain from sharing them with third parties, (iii) Monitor your account for any unauthorized or suspicious activity, (v)Keep your registered email and phone number up to date to receive notifications or alerts. Fintopio will never ask you to share your password, 2FA codes, or grant remote access to your device.
2. Unauthorized Access and Security Breach: If you suspect that your Fintopio Account has been compromised or accessed without authorization, you must: (i) Notify us immediately through the official support channels, (ii) Secure your account by changing your password and disabling access, if applicable, (iii) Follow any additional security steps as reasonably required by Fintopio Kg to address the breach. You acknowledge that any delay in reporting a security breach may result in further unauthorized access or loss of digital assets, for which you assume full responsibility.
3. Account Monitoring and Security Measures: You are responsible for regularly reviewing your account activity. Any transactions or activities conducted using your Fintopio Account credentials will be considered authorized by you unless reported otherwise. Fintopio kg implements industry-standard security measures to protect user accounts; however, you remain responsible for: (i) Ensuring your devices are protected against viruses, malware, or unauthorized access, and (ii) Logging out of your account after each session. We reserve the right to suspend or terminate access to your account, without prior notice, if: (i) Unauthorized access or suspicious activity is detected, (ii) Your account is suspected of being involved in fraud, money laundering, or any illegal activities. If you wish to cease using your account, you must ensure all outstanding obligations are settled and withdraw any eligible digital assets. Fintopio Kg may, at its discretion, delete or retain your account data as required by law.

1. Fintopio Kg provides its Services solely for those virtual assets that we designate, from time to time, as “Supported Virtual Assets.” The current list of Supported Virtual Assets is available on our website or through the Platform. You must not attempt to store, send, or receive any virtual assets other than Supported Virtual Assets in your Fintopio Account. We assume no responsibility for any loss, inaccessibility, or other adverse outcome arising from any attempt to use your Fintopio Account for non-supported or incompatible assets.
2. We reserve the right, at our sole discretion, to remove, delist, restrict, or cease support for any Supported Virtual Asset at any time. Where feasible, we will notify you in advance via our Platform or your registered email address. Upon delisting or discontinuation of support, we may permit you to withdraw, convert, or otherwise transfer the affected asset. However, if you fail to act within any specified timeframe, we may, without liability, convert or transfer such assets as we reasonably deem appropriate.
3. Protocol Upgrades, and Forks. We do not control or influence the underlying software protocols of any Supported Virtual Asset. Such protocols are subject to sudden changes in operating rules (“Forks”) or upgrades, which may materially affect the functionality, value, or name of a virtual asset. We may temporarily suspend Services related to an affected asset while assessing the implications of the Fork or upgrade, and we may, at our sole discretion, decide whether to support any resulting asset or protocol branch. You acknowledge and accept all risks associated with protocol changes, including the possibility of loss in asset value.
4. Disclaimer of liability. You understand and agree that Fintopio Kg assumes no responsibility for; (i) Any attempt to use your account for virtual assets not supported by Fintopio Kg; (ii) Any impact on your virtual assets due to Forks, network upgrades, or similar events, whether or not we elect to support the new or modified protocols; and (iii) The conversion or removal of any virtual asset in accordance with this Clause, including any discrepancy between the conversion rate we apply and prevailing market rates where such conversion or removal arises in connection with, or is necessitated by, the circumstances described in (i) or (ii) above.

1. Funding Your Fintopio Account: You may fund your Fintopio Account with fiat currency (“Fiat”) using any of the deposit methods we support. These may include, without limitation: bank transfers, credit/debit card payments, or other payment methods indicated on the Platform. You acknowledge that certain deposit methods may involve third-party service providers, and you agree to comply with their respective terms and conditions. We reserve the right, at our sole discretion, to conduct any checks or verifications deemed reasonably necessary before or after you deposit Fiat into your Fintopio Account, including but not limited to identity verification checks for the purposes of preventing money laundering, terrorist financing, fraud, or other financial crimes.
2. Withdrawals: You may request to withdraw any or all of your available Fiat balance by selecting the relevant option within your Account and following the instructions provided on the Platform. All withdrawal requests are subject to your applicable limits and to any compliance checks we deem necessary. Depending on the withdrawal method used and your financial institution, withdrawals may take an extended period (e.g., few hours or business days) to process. We assume no liability for delays caused by third parties or events beyond our control. We shall only process your withdrawal to the same bank account, card, or payment method from which the original deposit was made or any other bank account designated by you.
3. Deposit and Withdrawal Limits: Your ability to deposit or withdraw Fiat is subject to daily, weekly, and monthly limits, which we may establish and modify in our sole discretion. We will make these limits available to you either directly on the Platform or at the point of initiating a transaction. We reserve the right to amend these limits at any time, without prior notice, to comply with internal risk policies, regulatory obligations, or other lawful requirements. Such amendments shall be effective immediately upon posting on the Platform or otherwise communicating them to you.
4. Transaction Finality and User Responsibility: Once a deposit or withdrawal instruction has been confirmed or completed on the Platform, it cannot be canceled, amended, or reversed. You bear full responsibility for verifying all transaction details (including destination addresses, payment methods, and amounts) prior to confirming any transaction. You must notify us immediately and, in any event, no later than thirty (30) days after the relevant transaction, if you suspect that a transaction in your Fintopio Account was unauthorized or incorrectly executed. We will investigate the matter and take reasonable measures to rectify any errors. However, we assume no liability for unauthorized transactions that result from your failure to maintain the security of your Account credentials or from actions or omissions that violate these Terms.
5. Account Restrictions: We may, in our sole discretion and without prior notice, restrict or suspend your ability to deposit or withdraw Fiat if we suspect any illegal, fraudulent, or unauthorized activities, or if you fail to comply with these Terms or applicable laws. In certain cases, we may not be able to disclose the specific reason for imposing account restrictions if doing so would violate legal or regulatory obligations or compromise our security procedures.

1. Transactions. You may engage in Fiat or Virtual Asset transactions (“Transactions”) directly with us or with other users (facilitated by us, where applicable). We do not guarantee that any Transaction will be completed successfully or within a specified time. You are solely responsible for verifying all Transaction details, including beneficiary information, wallet addresses, amounts, networks, and other relevant parameters.
2. Transaction Finality. Once a Transaction is broadcast or confirmed on the relevant network or otherwise marked as completed on the Platform, it cannot be canceled, amended, reversed, or withdrawn. You must carefully review all information prior to submitting your Transaction. Transactions will remain pending until fully confirmed by the relevant network.
3. Unauthorized or Incorrect Transactions. You bear full responsibility for maintaining the confidentiality of your Account credentials and monitoring your Transaction history. We will assume that you have authorized any instructions issued from your Account unless you promptly notify us of suspicious or unauthorized activity. We are not liable for losses resulting from any Transaction unless our internal investigation conclusively shows it was executed solely due to a technical issue attributable to our gross negligence or willful misconduct.
4. Transaction Limits: Your Account may be subject to daily, weekly, or monthly limits on Transaction value or volume. These limits will be disclosed on the Platform or at the time you initiate a Transaction. We reserve the right, in our sole discretion, to modify your Transaction limits at any time and without prior notice and may impose additional conditions or requirements before approving a change in your limits.
5. Rejection and Cancellation of Transactions: We may, at our sole discretion and without liability, reject or cancel any Transaction if we suspect unauthorized or unlawful activity, are instructed to do so by a competent authority, or if the Transaction violates these Terms or any Applicable Law. We will endeavor to notify you as soon as reasonably practicable under such circumstances.
6. Transaction information: We may keep records and information related to your Transactions in accordance with our legal and regulatory obligations and our Privacy Policy. By using the Platform, you consent to our retention of such data for the duration and purposes permitted by Applicable Law.

1. Payment of Fees: By using our Services, you agree to pay any and all applicable fees, charges, or commissions incurred in connection with your transactions or activities on the Platform. Such fees may include, without limitation:
   
   1. Transaction Fees: Costs associated with trading, buying, selling, converting, or transferring virtual assets and/or fiat currencies.
   2. Network or Gas Fees: Charges imposed by a blockchain network (e.g., BTC, ETH) for processing transactions, which are neither set nor collected by Fintopio Kg.
   3. Payment Services Fees: Bank transfer or card processing fees, including charges incurred by payment service providers, which may be deducted from your settled transaction amount.
2. Fee Schedule and Display: We will display current fees on the Platform or at the time you initiate a transaction. It is your responsibility to review these fees prior to engaging in any transaction. Continuation of the transaction signifies your acceptance of the applicable fees.
3. Calculation and Deduction: You authorize us to deduct fees directly from your Fintopio Account balances (including from any virtual asset balances, if necessary). If you owe amounts in a currency or virtual asset not supported by your current balance, we may convert your holdings into the required currency or virtual asset at a rate determined by us or the Platform. If you have insufficient balance to cover fees, you acknowledge that any outstanding fee is a debt immediately owed to us in the equivalent form or amount we reasonably determine.
4. Revisions and Updates: We reserve the right, at our sole discretion, to modify, introduce, or revise any fees or methods of fee calculation without prior notice. Any updated fees will be binding once published on the Platform or otherwise communicated to you. If you do not agree to any revised fees, you may discontinue using the Services, but you will remain liable for fees already incurred.
5. Taxes: You are solely responsible for determining and fulfilling any tax obligations arising from your transactions, including withholding, collection, reporting, and remitting the appropriate taxes to the relevant authorities. We do not provide tax advice, nor are we responsible for determining any tax implications of your activities or transactions on the Platform. Where required by law, Fintopio Kg may withhold taxes from amounts payable to you and remit them to the appropriate authorities.

1. Access to Account Information: You will have access to your Account information, including your transaction history, balances, and other relevant details (“Transaction Records”), through the Platform. Although we employ reasonable measures to ensure the accuracy and reliability of the information presented in your Transaction Records, occasional errors or omissions may occur. Any discrepancies in your Transaction Records do not alter the actual substance or outcome of a transaction.
2. Review and Confirmation: You are solely responsible for regularly reviewing your Transaction Records and promptly notifying us in writing of any inaccuracies, inconsistencies, or unusual activities. Unless you notify us otherwise within fourteen (14) calendar days (or within any shorter period prescribed by Applicable Law) after the information becomes available to you, your Transaction Records will be deemed correct, approved, and confirmed. You acknowledge that any communication we send to the email address on record for your Account is deemed received by you and shall be treated as having been reviewed and accepted.
3. Rectification of Errors: We reserve the right to correct any error, inaccuracy, or omission in your Transaction Records. In the event we rectify a mistake, we will make the necessary adjustments to reflect the correct transaction details. Any such amendment does not entitle you to gains or benefits resulting from the erroneous entry, nor does it excuse you from any liabilities or obligations incurred before the rectification.
4. Information-Sharing and Regulatory Compliance: We may be legally required to share information about your Account or Transaction Records with third parties (including regulators, Affiliates, or service providers) to comply with Applicable Law, facilitate service operations, or address fraud and security concerns. By accessing the Platform, and using the Services, you acknowledge and consent to such disclosures as set forth in our Privacy Policy and in accordance with the law.

1. Custody of Fiat and Virtual Assets:
   1. Omnibus Wallet and Client Money Account. We maintain your fiat deposits (“Client Money”) and your virtual assets (“Assets”) in pooled or omnibus accounts (“Client Money Account” for fiat, and “Custody Wallets” for virtual assets), collectively holding balances belonging to multiple users. While our internal ledger entries distinguish your funds and Assets from those of other users and from our own, Fintopio Kg or its Affiliates is under no obligation to maintain segregated bank accounts or standalone wallet addresses solely for your benefit.
   2. Beneficial Title. Notwithstanding the use of omnibus accounts, beneficial title to any fiat currency or Assets held on your behalf always remains with you and shall not transfer to Fintopio Kg or its Affiliates. You acknowledge that you bear all market and exchange rate risk associated with such holdings.
2. Security and Storage:
   1. Offline/Online Custody. We employ a combination of secure online and offline storage (“cold storage”) to safeguard your virtual assets. This security protocol, while intended to reduce unauthorized access and theft, may result in processing delays when you initiate or receive certain transactions involving offline-stored Assets.
   2. Transmission Delays. You accept that retrieving Assets from offline storage requires additional security checks, which can extend transaction times. We shall not be liable for any delay or resultant losses arising from these necessary security procedures.
3. Risks and Insurance:
   1. No Deposit Protection. Neither fiat balances nor virtual assets held by Fintopio Kg on your behalf are protected by any form of deposit insurance, deposit protection scheme, or equivalent regulatory guarantee, whether established under the laws of the Kyrgyz Republic or any other jurisdiction.
   2. Bank or Custodian Failure. If a financial institution or custodian responsible for holding your fiat or Assets becomes insolvent or is unable to meet its obligations, you acknowledge that Fintopio Kg bears no liability for any resulting losses, except to the extent Fintopio Kg is found by a court of competent jurisdiction to have engaged in fraud or criminal misconduct directly causing the loss.
4. Access and Control:
   1. Withdrawal Rights. Subject to outages, downtime, compliance checks, and other policies, you may withdraw your fiat and/or virtual assets from our omnibus accounts at any time by submitting a withdrawal request through the Platform.
   2. User Responsibility for Credentials. You are solely responsible for safeguarding your account credentials, wallet keys, and passwords. Any instruction executed via your account or wallet shall be conclusively presumed authorized by you. You agree to promptly notify us if you suspect or become aware of any unauthorized access.
5. Re-Hypothecation: Unless we receive your explicit, prior written consent, we will not lend, pledge, or otherwise re-hypothecate your Assets. You acknowledge that consenting to re-hypothecation may introduce additional risk to your Assets.
6. No Liability for Value Fluctuations: You expressly agree that Fintopio Kg shall bear no liability for any reduction in the value of your fiat or virtual assets due to market fluctuations, network fees, or changes in the broader economic environment. All proceeds or losses associated with your holdings accrue solely to you.
7. Unclaimed Fiat and/or Assets:
   1. Dormancy Period. If we cannot contact you and detect no activity in your Account for a period defined by Applicable Law (but not less than six years), we may, in accordance with relevant legal requirements, treat your Account as dormant or unclaimed property. We will use reasonable efforts to locate you based on the contact information you have provided.
   2. Disposition of Unclaimed Property. If we are unable to reach you after exhausting reasonable efforts, we reserve the right, subject to Applicable Law, to close your Account and transfer any remaining Fiat or Virtual Assets to a designated authority or handle them as unclaimed property pursuant to instructions from a competent authority or court of law.
   3. Deceased Users and Fiduciary Designation. If we receive official documentation suggesting your death, we may freeze your Account until either: (i) the designated fiduciary opens a new Account to which the assets may be transferred, or (ii) the fiduciary, having provided sufficient legal and KYC/AML documentation, directs us to release the assets to a verified external account or wallet without opening a Fintopio Account. We may require proof of a valid will or estate documentation before recognizing a designated fiduciary or estate representative, and if there is any uncertainty about the fiduciary’s legitimacy, we may request further documentation or a court order clarifying the rightful heir or beneficiary.

1. Third-Party Ownership and Control: You acknowledge that Fintopio Kg provides its CeFi Services on or through a Platform owned and operated by a third party (“Platform Owner”), pursuant to a licensing agreement. Fintopio Kg does not own, manage, or control the Platform and, therefore, makes no representations or warranties regarding the Platform’s continued availability, uninterrupted functionality, or error-free performance.
2. No Guarantee of Access or Performance: Access to the Platform and Fintopio Kg’s Services may be interrupted, delayed, or restricted due to system maintenance, unforeseen technical difficulties, network congestion, or other factors beyond Fintopio Kg’s reasonable control. Consequently, you may be unable to conduct transactions, submit instructions, or retrieve data during these periods. Fintopio Kg disclaims any liability for losses resulting from or in connection with the unavailability or degraded performance of the Platform, or any delay in transactions or customer support responses caused by Platform issues.
3. Information and Content Accuracy: While the Platform or associated materials may display information about Fintopio Kg’s Services, we do not warrant the completeness, accuracy, or timeliness of any data or content made available through the Platform. You should independently verify any information before relying on it. Links to third-party websites, references to third-party services, or the posting of third-party opinions on the Platform do not constitute endorsements by Fintopio Kg. We do not control the content of such third-party materials and disclaim all liability arising from reliance on, or interaction with, these materials.
4. Network Access and Device Requirements: You are responsible for securing the hardware, software, internet connection, and other resources necessary to access the Platform. Fintopio Kg does not guarantee compatibility with any specific device or configuration. Network, hardware, or device issues outside Fintopio Kg’s control may result in service malfunctions, delays, or errors.
5. Suspension or Maintenance: The Platform Owner may periodically suspend operations or restrict access for routine maintenance, system upgrades, or other necessary activities. Such suspensions may affect your ability to use Fintopio Kg’s Services. The Platform Owner or Fintopio Kg may suspend, restrict, or modify features promptly in response to emergencies, legal obligations, security incidents, or other events requiring immediate action. We will endeavour to provide notice where reasonably practicable but are under no obligation to do so.
6. Disclaimer of Warranties: To the fullest extent permitted by applicable law, Fintopio Kg disclaims all warranties, whether express or implied, regarding the availability, accuracy, reliability, or performance of the Platform, including any implied warranties of merchantability, fitness for a particular purpose, or non-infringement. Fintopio Kg does not represent or warrant that the Platform, or access to its Services through the Platform, will be continuous, uninterrupted, timely, or error-free.

1. Third-Party Providers:
   1. Use of Service Providers. To offer certain features, functionalities, or information, we may rely on one or more third-party service providers. Such services include, but are not limited to, identity verification (KYC), transaction analysis (KYT), payment facilitation, and Travel Rule compliance. We reserve the right to replace, add, or discontinue any service provider at our sole discretion, without prior notice.
   2. Third-Party Terms.Your access to and use of the Platform and Services shall be subject to additional terms and conditions imposed by these third-party providers. By continuing to use our Services, you agree to be bound by any such third-party terms, where applicable.
   3. No Liability for Third-Party Acts.While we strive to engage reputable service providers, we do not control their operations and disclaim any liability arising out of or relating to their performance, actions, omissions, or terms of service. Any issues, disputes, or liabilities you may have in connection with third-party services should be directed solely to the relevant third-party provider.
2. Hyperlinks and External Websites:
   1. Informational Purpose Only. The Platform may contain hyperlinks or references to third-party websites, content, or services (“Linked Materials”) solely for your convenience. Such Linked Materials are neither created, reviewed, nor endorsed by us, and your access to or use of them is entirely at your own risk.
   2. No Endorsement or Control. We make no representations or warranties regarding the accuracy, security, legality, or appropriateness of any Linked Materials and disclaim all liability for any direct or indirect losses or damages arising from or related to their content or use. The inclusion of any hyperlink on the Platform does not imply an endorsement, recommendation, or approval of the Linked Materials or any association with the operator thereof.
   3. Independent Terms and Policies. You acknowledge that each third-party website or service you access through hyperlinks on the Platform is governed by separate terms and conditions and privacy policies. It is your responsibility to review and comply with those independent terms before providing any personal or confidential information or engaging in any transactions.
   4. User-Provided Hyperlinks. You may only create a hyperlink to our Platform with our prior written approval, and must immediately remove such hyperlink at our request, even if initial approval was granted. Linking to our Platform in a way that suggests endorsement, association, or approval by us, or in any manner that damages our reputation, is strictly prohibited.

1. You agree that your use of the Fintopio Platform and the Services, as well as any transactions you initiate, will comply with these Terms and all Applicable Laws, regulations, and other legal requirements relevant to your use of the Services. You will not use the Services in any manner that could cause Fintopio Kg (or its Affiliates) to contravene any Applicable Law.
2. Without prejudice to other restrictions set out in these Terms, you agree not to, and shall not permit or assist any third party to:
   1. Breach or circumvent these Terms, or any other policies, rules, or agreements you enter into with us, or attempt to do so;
   2. Use the Fintopio Platform or Services for any illegal, unlawful, fraudulent, deceptive, or harmful purpose, including but not limited to money laundering, terrorist financing, gambling, or other prohibited conduct;
   3. Engage or attempt to engage in any form of market manipulation, including but not limited to pump-and-dump schemes, wash trading, self-trading, front running, spoofing, layering, or quote stuffing, regardless of its legality under any specific jurisdiction;
   4. Open or operate multiple Fintopio Accounts without prior written consent, impersonate another person, or attempt to use another user’s account without authorization;
   5. Use the Services for commercial or resale purposes on behalf of another individual or entity without our express prior written consent;
   6. Provide false, misleading, or inaccurate information in connection with your use of the Services, including during account creation, KYC verification, or any other communications with us;
   7. Modify, reverse-engineer, decompile, disassemble, copy, or create derivative works of any part of the Fintopio Platform (including its source code or proprietary materials), or infringe upon any intellectual property rights owned or licensed by Fintopio Kg;
   8. Probe, scan, or test the vulnerabilities of the Fintopio Platform or any associated systems; attempt to gain unauthorized access to our servers or networks by hacking, password mining, or other unlawful means; distribute viruses, Trojan horses, or other malicious software; or otherwise interfere with the functionality or security of the Platform;
   9. Employ scraping, crawling, data mining, robots, spiders, or any other automated means to access the Platform or Services for purposes not expressly authorized in these Terms, or otherwise impose an unreasonable or disproportionately large load on our systems or networks;
   10. Create or purport to create any security interest over your Digital Assets held in your Fintopio Account without our prior written consent;
   11. Bypassing Geographic or Legal Restrictions: Use anonymity tools (e.g., proxies, Tor, VPNs) or other methods to circumvent geographic blocks, sanctions, or other technical or legal restrictions on the Services;
   12. Access or use, or attempt to access or use, the Services from any jurisdiction or location that is designated as prohibited, restricted, or high risk by Fintopio in accordance with our policies and Applicable Laws; and
   13. Engage in any activity that we reasonably deem to be in violation of the letter or spirit of these Terms, or that poses a risk to the Platform’s stability, security, or lawful operation.
3. You shall (i) maintain adequate security over your Access IDs, devices, and networks used to access the Services; (ii) promptly notify Fintopio Kg if you suspect unauthorized use of, or access to, your account; and (iii) bear all risks arising from your failure to maintain such security, including any loss of Digital Assets resulting from the compromise of your account credentials or devices.
4. You are solely responsible for all actions and omissions arising from or relating to your use of the Services. You agree to defend, indemnify, and hold harmless Fintopio Kg and its officers, directors, employees, agents, and Affiliates from and against any and all losses, liabilities, claims, damages, costs, and expenses (including reasonable legal fees) arising out of or in connection with: (i) your violation of these Terms or any Applicable Law; (ii) your use or misuse of the Services; (iii) your breach of any representation, warranty, or covenant in these Terms; or (iv) any act or omission by you or your Permitted User that results in loss or damage to Fintopio Kg or any third party.
5. If you violate or we reasonably suspect you have violated any of the obligations in these Terms, we reserve the right, in our sole discretion and without notice, to: (i) suspend or restrict your access to the Services; (ii) freeze your Fintopio Account or any Digital Assets held therein; (iii) cancel, void, or reverse any Transactions, to the extent possible; (iv) impose limits on your Fintopio Account; (v) terminate or close your Fintopio Account; and/or (vi) take any other action we deem necessary to protect our interests or comply with Applicable Law.

1. Reservation of Right. We reserve the right, at our sole discretion and with or without prior notice, to modify or discontinue any aspect of the Services, including by terminating, suspending, restricting, or otherwise placing holds (“freezing”) on your Fintopio Account or any transactions therein. These actions may be taken immediately and may be temporary or permanent. Where feasible, and unless prohibited by Applicable Law or internal policies, we will provide you with notice of the measures taken and the reasons for them.
2. Grounds for Termination, Suspension, Holds, or Restrictions. Without limiting other circumstances under these Terms, your Fintopio Account may be terminated, suspended, restricted, or frozen (“hold”) for reasons including, but not limited to, where:
   1. Legal or Regulatory Requirements: We believe, in our reasonable judgment, that such action is required under Applicable Law, regulation, court order, or at the direction of a competent authority.
   2. Breach of Terms or Policies: We reasonably suspect that you are in breach of these Terms, any other agreements you have with us, or our internal policies, including those concerning AML/KYC, fraud, or other compliance matters.
   3. Suspected Illegal or Unauthorized Activities: We reasonably suspect that your Account is being used for illicit purposes, including but not limited to money laundering, terrorist financing, fraud, or other financial crimes.
   4. Security Concerns: We identify unusual, unauthorized, or suspicious activity on your Account, or suspect that your Account credentials have been compromised, or your Account may be subject to external attacks or hacking attempts.
   5. Insufficient or Erroneous Information: You fail to provide accurate, current, and complete information or fail to satisfy our ongoing requests for identification, verification, or Enhanced Due Diligence.
   6. Outstanding Obligations: You owe any outstanding fees or amounts to us or have insufficient funds (whether fiat or virtual assets) to cover a pending transaction or associated fees.
   7. Unauthorized Multiple Accounts or Abusive Behaviour: You open multiple Accounts without our prior written consent, attempt to circumvent our controls or platform restrictions, or engage in activities that we consider manipulative, fraudulent, or harmful to the Platform.
   8. Pending Investigations or Disputes: Your Account becomes subject to litigation, investigation, or governmental or regulatory proceedings, or if we perceive heightened legal or regulatory risks associated with your Account activities.
   9. Other Valid Reason: We determine that there is any other valid reason, consistent with our risk management, security protocols, or business interests, necessitating the termination, suspension, restriction, or hold of your Account.
3. Effects of Termination, Suspension, or Hold: (i) If your Account is terminated, suspended, or subject to a hold, you may lose access to the Services and may be unable to initiate, authorize, or complete transactions. We reserve the right to reverse, cancel, or refuse any pending or future transaction, (ii) Where permitted by Applicable Law and our internal policies, you may withdraw your available Digital Assets or Fiat Currency within the timeframe we specify. However, we reserve the right to require you to complete additional KYC or other procedures before permitting withdrawals or transfers, (iii) If you have open or pending transactions, they may be closed or canceled, depending on the circumstances, including whether there is an ongoing investigation into the transaction(s) or your Account, (iv) You remain liable for any fees, charges, or other obligations incurred prior to the termination, suspension, or hold. We may offset or deduct such amounts from any balance in your Account, (v) We are under no obligation to reinstate transactions that were canceled, nor to reactivate your Account on the same terms, if the underlying cause for suspension or termination is not fully resolved to our satisfaction.
4. Notice and Confidentiality. (i) Unless prohibited by Applicable Law or internal policies, or where it would compromise security protocols, we will take reasonable steps to notify you of any termination, suspension, restriction, or hold imposed on your Account, (ii) You acknowledge and agree that our decision to take certain actions under this Clause may be based on confidential criteria and risk assessments essential to our compliance and security measures. We are not obligated to disclose the details of such internal policies or procedures to you.
5. Effect of Termination on These Terms. If we or you terminate or suspend your access to the Services, these Terms will cease to apply except to the extent necessary to settle your rights and obligations that accrued prior to such termination or suspension (including, but not limited to, indemnification obligations, intellectual property rights, and limitations on liability).

1. Your Right to Close Your Account. You may terminate your Fintopio Account at any time by following the account closure procedures we specify from time to time. There is no fee for closing your Fintopio Account; however, you are responsible for settling any outstanding obligations owed to us. You authorize us to cancel or suspend any pending transactions at the time of closure, and to deduct any remaining amounts owed to us from your Fintopio Account. You may be unable to close your Fintopio Account in certain circumstances, including where:
   1. you appear to be attempting to evade an investigation by relevant authorities;
   2. you have a pending transaction or an unresolved dispute;
   3. your Fintopio Account has any unpaid fees or other obligations; or
   4. your Fintopio Account is subject to a freeze, hold, limitation, or reserve.
2. Consequences of Closure. When your Fintopio Account is closed, you must withdraw all Digital Assets credited to your Fintopio Account. If you fail to withdraw your Digital Assets or do not access your Fintopio Account for a continuous period of ninety (90) days, we may send you a notice indicating our intention to treat your account as dormant.
3. Dormant Accounts. If you fail to respond to the notice under Clause 18.2 within 30 days, we may:
   1. designate your Fintopio Account as a dormant account;
   2. convert any Digital Assets in your dormant account into another type of Digital Asset. In doing so, we are not liable for any lost profit, tax obligations, or other losses resulting from such conversion;
   3. transfer the dormant account and/or the Digital Assets in it to a third party (which may be an Affiliate, a third-party custodian, or an isolated wallet) if we reasonably consider it necessary. If this occurs, you retain the right to recover your Digital Assets, subject to meeting our (or the relevant third party’s) verification requirements and any applicable terms and conditions;
   4. adjust your dormant account such that you hold a contractual claim on the quantity and type of Digital Assets formerly credited to your Fintopio Account;
   5. charge a dormant account fee to cover the costs of holding such Digital Assets with us or a third party, which may be deducted from the dormant account on a monthly basis; and
   6. close a dormant account at any time.

You acknowledge that we are under no obligation to pay any reward, incentive, or interest that we might otherwise have agreed to pay on Digital Assets in your dormant account.

• This Clause provides a general overview of the risks associated with purchasing, selling, holding, or otherwise transacting virtual assets through Fintopio Kg’s Services. It does not detail every possible risk. You should consult and carefully review our Risk Disclosure Statement, available on our website at www.fintopio.kg/risks-disclosure , for more comprehensive information. The virtual asset market is rapidly evolving, and certain risks may not be fully understood or anticipated. Fintopio Kg may periodically update the Risk Disclosure Statement to address newly identified or changing risks. However, Fintopio Kg does not accept liability for any risk not expressly mentioned therein.
• By creating an account and using our Services, you acknowledge and accept all inherent risks. You bear sole responsibility for determining the suitability of virtual asset transactions considering your financial circumstances, objectives, and risk tolerance. You agree to remain informed of any updates to our Risk Disclosure Statement.

1. By accessing the Fintopio Platform and using the Services, you represent, warrant, and covenant to Fintopio Kg that, always:
   1. Accuracy of Information. All documents and information you provide or make available to us (including those submitted during account registration and any subsequent updates) are true, accurate, complete, and current in all respects. You acknowledge and agree that Fintopio Kg may rely on this information to determine your eligibility to access and use the Platform and Services.
   2. Independent Decision-Making. Any decision you make to use or access the Services is based solely on your own independent judgment. You have carefully evaluated your financial resources, objectives, and risk tolerance before engaging in any activity on the Platform, and you accept full responsibility for the consequences of your decisions.
   3. Authority and Capacity. You have the full power and authority to; (i) access and use the Platform and Services; and (ii) enter into, execute, and perform your obligations under these Terms and any agreement entered into pursuant to, or in connection with, these Terms. If you are acting on behalf of a corporation, partnership, trust, or any other legal entity, you confirm that the entity is duly incorporated or validly organized under applicable laws, and that you are fully authorized to bind the entity to these Terms.
   4. Corporate or Trust Compliance (if applicable). If you are a corporation, partnership, or trustee of a trust, you will: (i) operate the entity or trust in compliance with all applicable laws and relevant governing documents; (ii) promptly notify us in writing of any changes (including resignations, removals, or appointments) of any directors, partners, trustees, settlors, or ultimate beneficial owners; and (iii) immediately inform us if the entity or trust is dissolved, whether voluntarily or involuntarily.
   5. Requisite Consents and Approvals. You have obtained, and will maintain in full force and effect, all necessary consents, approvals, authorizations, licenses, registrations, and filings under Applicable Law that are required for you to; (i) access and use the Platform and the Services; and (ii) enter into, deliver, and perform any Transactions or obligations contemplated by these Terms or by any other agreements entered into pursuant hereto. Such consents and approvals have been disclosed to us in writing where relevant, and none has been withdrawn or amended in a way that would affect your ability to comply with these Terms.
   6. Binding Obligations. These Terms and any agreements entered into pursuant to, or in connection with, the Services constitute legal, valid, and binding obligations enforceable against you in accordance with their respective terms.
   7. No Restricted Status. You are not, and will not become, a “Restricted Person” or otherwise prohibited from using the Services under Applicable Law or the internal policies of Fintopio Kg. You will promptly notify us if your status changes, and you will cease using the Services if you become restricted or prohibited under any applicable sanctions or laws.
   8. Legal Capacity. If you are a legal entity, you are duly incorporated, validly existing, and in good standing under the laws of the jurisdiction of your formation. If you are an individual, you confirm that you are at least eighteen (18) years of age, or of the legal age of majority in your jurisdiction of residence, whichever is greater.
   9. No Breach or Conflict. Your access to and use of the Platform and Services, and your execution, delivery, and performance under these Terms (and any agreement relating to these Terms), will not: (i) if you are a legal entity, conflict with your organizational documents (e.g., articles of incorporation, partnership agreements, trust deeds); (ii) breach or violate the provisions of any agreement or obligation to which you are a party or by which you or your assets are bound; or (iii) result in, or cause us or any third party to be in, violation of any Applicable Law, decree, judgment, or administrative order in any jurisdiction.
2. You acknowledge and agree that Fintopio Kg relies on the above representations and warranties in providing you access to the Platform and the Services. If at any time any of the above representations and warranties become untrue or inaccurate, you will promptly notify Fintopio Kg in writing. Your failure to comply with these representations and warranties may result in the suspension or termination of your Fintopio Account and/or any other remedies available to Fintopio Kg under these Terms or Applicable Law.

1. The use of the Services in connection with any of the following categories of activities, entities, or transactions (collectively, “Prohibited Businesses”) is strictly prohibited. By using the Services, you represent and warrant that you will not engage in, facilitate, or otherwise associate your account with any of the following Prohibited Businesses:
   1. Unlicensed Money Services: Unlicensed money transmitters or payment service providers, including but not limited to the unlicensed sale of money orders, cashier’s checks, or any other money transmission activities.
   2. Non-Compliant Financial Institutions: Any association with “Shell Banks” or other financial institutions that do not maintain a physical presence in any country, or that engage in activities not compliant with applicable laws, regulations, or standards in the jurisdictions in which we operate.
   3. Adult Content and Services: Activities involving pornography, obscene materials, prostitution, escorts, pay-per-view adult content, adult live chat services, or any other sexually related services.
   4. Deceptive Marketing and False Advertising: Activities that employ deceptive marketing practices, false or misleading advertising, or similar unlawful or unethical promotional methods.
   5. Religious or Spiritual Organizations: Associations with religious, spiritual, or faith-based organizations to the extent restricted by applicable laws or regulations.
   6. Unauthorized Weapons Sales: Unlicensed sales or distribution of firearms, ammunition, knives, explosives, or related accessories.
   7. Regulated Goods and Services: Unlicensed sale of regulated products such as marijuana, tobacco, e-cigarettes, pharmaceuticals, prescription drugs, age-restricted goods, or hazardous materials including toxic, flammable, radioactive, or similar substances.
   8. Pseudo-Pharmaceuticals: Manufacturing, marketing, or selling untested, unapproved, or fraudulent pharmaceutical products.
   9. Illegal Drugs and Paraphernalia: Sale of narcotics, controlled substances, or equipment intended for manufacturing or using such substances, including bongs, vaporizers, and hookahs.
   10. Gambling Activities: Sports betting, casinos, horse racing, dog racing, lotteries, games of chance or skill that may be classified as gambling, sweepstakes, or any related activity where the legality is in question.
   11. Illicit Financial Activities: Money laundering, fraud, terrorist financing, or any other illicit financial transactions or activities.
   12. Ponzi or Pyramid Schemes: Engagement in any Ponzi schemes, pyramid schemes, multi-level marketing programs, or similarly structured fraudulent ventures.
   13. Intellectual Property Infringements: Transactions involving goods or services that infringe or violate copyrights, trademarks, patents, or other proprietary rights.
   14. Layaway Systems or Annuities: Offering or utilizing layaway plans, annuities, or similar deferred payment arrangements to the extent prohibited by applicable law.
   15. Counterfeit or Unauthorized Goods: Trading in counterfeit, unauthorized, stolen, illegally imported or exported goods, including the sale of fake or “novelty” identification documents.
   16. Market Manipulation: Wash trading, front-running, insider trading, or any other forms of market manipulation, fraud, or deceit.
   17. Darknet Marketplaces: Purchasing goods or services from hidden or “Darknet” markets, including but not limited to marketplaces that facilitate the sale of illegal goods.
   18. High-Risk or Unacceptable Activities: Any other activities, goods, or services that we, in our sole discretion, determine to be unacceptable or of high risk, or that may be restricted by our banking or payment partners.
   19. Unlawful Activities: Any activity that violates or assists in violating any applicable law, regulation, sanction, or legal requirement in any jurisdiction in which we or you operate.
   20. Shell Banks and Related Entities: Engagement with Shell Banks, financial institutions whose customers are Shell Banks, or any entities characterized by a lack of transparency or legitimate physical presence.
   21. Bearer Share Entities: Entities structured with bearer shares or ownership mechanisms designed to conceal beneficial ownership.
   22. Defense and Munitions: Involvement with the defense industry, including firearms, munitions manufacturing, or related activities to the extent restricted by law.
   23. Nuclear Energy: Transactions related to nuclear energy, materials, or related regulated activities.
   24. Restricted Financial Services: Credit repair, debt settlement, refinancing, bail bonds, collection agencies, or similar activities, where prohibited or regulated.
   25. Protected Species and Ivory: Transactions involving ivory, endangered species, or any product derived from protected wildlife.
2. If we discover, suspect, or have reason to believe, in our sole discretion, that your Fintopio account is associated with any Prohibited Businesses, it shall be deemed a violation of these Terms. In such circumstances, we may immediately suspend or terminate your account, block any related transactions, freeze your funds, and report any suspected or actual violations to the appropriate law enforcement authorities without prior notice.

1. Data Collection and Processing. By using the Services, you acknowledge and consent to the collection, use, disclosure, and storage of your personal data (and, if applicable, the personal data of third parties you represent) as set out in our Privacy Policy, which is incorporated by reference into these Terms. Where you provide personal data of others, you confirm that those individuals have been informed of, and agree to, our Privacy Policy.
2. Privacy Policy Updates. You agree to review any updated or amended versions of our Privacy Policy. Continued access or use of the Services after any such update will constitute your acceptance of the revised Privacy Policy.
3. Security and Retention. We employ reasonable security measures to protect personal data from unauthorized access or misuse and retain such data only as long as necessary for the purposes stated in our Privacy Policy or as required by applicable law.

1. Services Provided “As Is” and “As Available”. The Fintopio Platform and the Services are provided on an “as is” and “as available” basis, without warranty of any kind, whether express, implied, or statutory. To the fullest extent permitted by Applicable Law, we disclaim all implied warranties of merchantability, fitness for a particular purpose, non-infringement, and any other warranties arising out of course of dealing, usage, or trade practice. We do not warrant that the Platform, the Services, or any materials provided through the Platform will be uninterrupted, error-free, secure, or free of viruses or other harmful components.
2. No Guarantee. We make no guarantees regarding the reliability, timeliness, completeness, accuracy, or availability of the Platform, the Services, or any related information. Access to the Platform and/or Services may be suspended or restricted at our discretion, including for maintenance, upgrades, or unforeseen disruptions, and we will not be liable for any resulting delays, losses, or inability to transact.
3. Network Access and Equipment. You are solely responsible for obtaining and maintaining the data network access, hardware, software, and other equipment necessary to use the Platform. Fintopio Kg does not warrant or guarantee that the Services will function on, or be compatible with, your device or network configuration. We disclaim all liability for any malfunctions or delays inherent in the use of the internet and electronic communications.
4. Third-Party Content and Links. The Platform and/or the Services may contain links to, or references of, third-party content, websites, or services. We assume no responsibility for the availability, accuracy, or reliability of such third-party resources. Any access to or use of third-party content or services is at your own risk, and we disclaim all liability in connection therewith.
5. No Responsibility for User Decisions. You acknowledge that you alone bear all risk for your activities on the Platform, including decisions to buy, sell, stake, or hold virtual assets through the Services. We provide no investment, legal, tax, or other professional advice. Any statements, information, or other content made available on or through the Platform are for informational purposes only and do not constitute a recommendation, endorsement, or solicitation of any kind. To the fullest extent permitted by Applicable Law, we will not be liable for any indirect, incidental, special, punitive, or consequential damages (including lost profits, lost revenue, loss of data, trading losses, or loss of goodwill) arising out of or related to your use or inability to use the Platform or the CeFi Services, whether based on warranty, contract, tort (including negligence), or any other legal theory.
6. No Compensation Scheme. You understand and agree that virtual asset transactions facilitated by Fintopio Kg are not subject to any governmental or private compensation or deposit protection scheme. You assume the entire risk of loss associated with holding, transferring, or transacting virtual assets.
7. Assumption of Risk. You assume and accept all risks arising from your access to and use of the Platform and the Services, including but not limited to fluctuations in virtual asset values, potential unauthorized access to your Account, loss of connectivity, and any other operational or technical failures.

1. Aggregate Liability Cap. To the fullest extent permitted by Applicable Law, the total aggregate liability of Fintopio Kg (including its officers, directors, employees, agents, Affiliates, and service providers) arising out of or related to these Terms, the Services, or any Transactions, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, shall not exceed the lower of: (i) the combined value of the relevant virtual assets held in your Fintopio Account at the time of the event giving rise to the claim; or (ii) the total amount of fees (if any) you have paid to Fintopio Kg in the twelve (12) months immediately preceding the event giving rise to the claim.
2. Exclusion of Certain Losses. In addition to the liability cap in Clause 22.1, Fintopio Kg shall not be liable for any indirect, incidental, special, punitive, exemplary, or consequential damages (including but not limited to lost profits, lost revenues, loss of goodwill, trading losses, or loss of data), even if we have been advised of or knew or should have known of the possibility of such damages. In particular, and without limitation, if any claim arises concerning a specific Transaction, any damages or losses shall be limited to the purchase, sale, or swap amount at issue in that Transaction.
3. No Liability for Force Majeure or Compliance with Law. Fintopio Kg is not liable for any failure, delay, interruption, or breach of these Terms that results from abnormal or unforeseeable circumstances beyond our reasonable control, the consequences of which could not have been avoided by reasonable diligence. We shall not be liable where the breach or failure is attributable to compliance with mandatory legal or regulatory requirements or any order of a court or relevant authority.
4. No Additional Remedies. You acknowledge that neither Fintopio Kg nor any of its Affiliates has knowledge of any special circumstances relating to you, and that damages shall be an adequate remedy for any claim you may bring. You shall not be entitled to seek injunctive relief, specific performance, or any other equitable remedy against Fintopio Kg or its Affiliates in connection with these Terms or the Services.
5. User Responsibilities. You agree and acknowledge that it is your responsibility to: (i) understand and assess the risks inherent in virtual asset transactions; and (ii) comply with all security measures necessary to protect your Fintopio Account, including guarding against fraud, phishing, hacking, or any form of unauthorized access. Fintopio Kg shall bear no liability for losses resulting from your failure to implement appropriate security measures or for any third-party fraud or misconduct.
6. Timeliness of Claims. Any claim arising out of or relating to these Terms or the Services must be commenced within one (1) year of the date of the event giving rise to the claim. If Applicable Law prohibits this contractual limitation period, the claim shall be brought within the enforceable timeframe allowed by the applicable law.

1. Indemnification Obligations. You agree to indemnify, defend, and hold harmless Fintopio Kg, its officers, directors, employees, agents, Affiliates, and any of their respective successors or assigns (collectively, the “Indemnified Parties”) from and against any and all claims, demands, actions, suits, proceedings, investigations, liabilities, damages, losses, costs, and expenses (including reasonable attorneys’ fees, court costs, and other professional fees) (collectively, “Losses”) arising out of, or in any way connected with: (a) Your access to or use of the Platform and the Services, including any actions or omissions by persons authorized under your Account; (b) Your breach or alleged breach of these Terms or any supplementary agreement, rule, or policy referenced herein; (c) Your violation of any Applicable Law, or infringement upon the rights of any third party (including but not limited to intellectual property, privacy, or other proprietary rights); (d) Any false, misleading, or inaccurate information provided by you to Fintopio Kg at any time in connection with the Services; or (e) Any claim brought by a governmental authority, regulatory agency, industry body, or other third party, where such claim arises out of your acts or omissions in connection with the use of the Platform and/or the Services.
2. Release of Claims. In addition, you irrevocably release and waive any claims or demands you may have against the Indemnified Parties arising from or connected with any dispute or loss you experience in relation to the use of the Platform, the Services, or any transactions with other users or third parties. You agree that the Indemnified Parties are not liable for any claims, demands, damages, or disputes between you and any other user, counterparty, or third-party involving transactions, information, or services rendered through or in connection with the Platform.
3. Right of Defense and Settlement. We reserve the right, but not the obligation, to control the defense of any claim subject to indemnification under these Terms, including the right to select legal counsel and to settle any such claim on such terms as we, in our sole discretion, deem appropriate. You agree to provide full cooperation and assistance as we may reasonably request in defending any claim. You shall not settle any claim subject to indemnification under these Terms without our prior written consent.
4. No Limitation to Other Rights. The foregoing indemnification obligations are in addition to, and not in lieu of, any other rights or remedies available at law or in equity. Nothing in these Terms shall be construed to limit your liability to the Indemnified Parties in the event of fraud, willful misconduct, or any other wrongdoing.

1. Ownership of IP. All intellectual property rights, including copyrights, trademarks, service marks, trade names, designs, patents, logos, and any other proprietary rights (collectively, “IP Rights”) in and to the Fintopio Platform and all related materials, content, software, tools, or documentation (collectively, the “Materials”) are licensed to Fintopio Kg, and owned by its licensor. Except as expressly stated in these Terms, nothing herein grants you any license or right to use any IP Rights of Fintopio Kg or its licensors.
2. Limited License to Use the Platform. Subject to your continued compliance with these Terms, Fintopio Kg grants you a revocable, non-exclusive, non-transferable, non-sublicensable, and limited license to access the Platform and use the Services, and the Materials solely for your personal or internal business purposes. You may not copy, reproduce, distribute, modify, create derivative works, publicly display, publish, transmit, sell, license, decompile, disassemble, reverse-engineer, or otherwise exploit any part of the Platform or the Materials, except with Fintopio Kg’s prior written consent or as expressly permitted under Applicable Law. Any unauthorized use of the Platform or the Materials is strictly prohibited.
3. Trademarks. All trademarks, service marks, trade names, logos, and brand identifiers (“Trademarks”) used or displayed on the Platform are the registered or unregistered Trademarks of Fintopio Kg’s licensor. Nothing on the Platform should be construed as granting, by implication or otherwise, any license or right to use any Trademark without the prior written permission of the owner of such Trademark. You shall not use any Trademark in connection with any product or service without the owner’s prior written approval, nor use the Trademarks in any manner that may cause confusion or disparagement.
4. User Materials. “User Materials” means any data, text, images, content, or other materials that you or other users upload, post, transmit, or otherwise make available through the Fintopio Platform or Services.
   1. Restricted User Materials. You must not upload, post, transmit, or otherwise provide User Materials that are harmful, insulting, abusive, discriminatory, unlawful, infringing, or otherwise inappropriate, including content that violates applicable laws, third-party rights, or the provisions of these Terms.
   2. Responsibility for User Materials. You acknowledge that you are solely responsible for the accuracy, legality, reliability, and appropriateness of any User Materials you submit. Fintopio Kg does not endorse or guarantee the completeness, reliability, or security of any User Materials.
   3. Right to Remove or Modify. Fintopio Kg reserves the right, in its sole discretion and without prior notice, to remove, block, edit, or otherwise modify any User Materials that it deems objectionable, infringes any IP Rights, violates these Terms, or is otherwise unlawful or inappropriate, including in response to third-party claims or requests from governmental authorities. Fintopio Kg assumes no responsibility or liability for any loss or damage arising from the removal, editing, or blocking of User Materials.
   4. Suspension or Termination. We may suspend or terminate your Fintopio Account if you submit User Materials that violate the provisions of this Clause 26.4.
5. Prohibited Uses. You shall not, and shall not permit any third party to: (i) use the Platform or Materials for any unauthorized commercial purpose or in violation of these Terms; (ii) remove, obscure, or alter any notices of copyright, trademark, or other proprietary rights appearing on or contained within the Platform or Materials; or (iii) engage in or facilitate any act that infringes or violates any IP Rights belonging to Fintopio Kg or any third party.
6. Reservation of Rights and Termination of License. (i) All IP Rights not expressly granted to you under these Terms are hereby reserved by Fintopio Kg and its licensor. No implied rights or licenses are granted hereunder. (ii) Your limited right to access and use the Platform and the Materials automatically terminates upon the suspension or termination of your Fintopio Account. Termination or suspension of your license does not limit any other rights or remedies Fintopio Kg may have under these Terms, at law, or in equity.

1. “Confidential Information” includes any information, whether in written, electronic, or any other form, that is disclosed or made available by one party (“Disclosing Party”) to the other (“Receiving Party”) in connection with these Terms, including, without limitation: (i) The existence, content, and subject matter of any dispute, claim, arbitration, or legal proceeding under these Terms; (ii) All documents, data, and materials exchanged in the course of such proceedings; (iii) Any submissions, orders, awards, or other determinations rendered in an arbitration or legal proceeding; and (iv) Any other information that, by its nature or the circumstances of its disclosure, should reasonably be understood to be confidential or proprietary.
2. Obligations of Confidentiality. Each party agrees to treat all Confidential Information as strictly confidential and shall not disclose, transfer, or make available any Confidential Information to any third party, except: (a) To such party’s officers, employees, agents, insurers, reinsurers, auditors, legal counsel, experts, or advisors who have a legitimate need to know such information for the purpose of performing obligations or exercising rights under these Terms, or conducting a bona fide legal or regulatory process, provided that such persons are bound by obligations of confidentiality at least as protective as those contained herein; (b) With the prior written consent of the Disclosing Party; (c) As required by Applicable Law or pursuant to any order of a court, regulatory authority, or other competent tribunal, provided that the Receiving Party, to the extent legally permitted, notifies the Disclosing Party promptly of such requirement and reasonably cooperates in any effort to limit or quash the required disclosure; (d) In connection with the initiation, pursuit, or defense of any bona fide legal or arbitration proceedings relating to these Terms, including to enforce or challenge an arbitration award; or (e) If and to the extent the relevant Confidential Information enters the public domain through no fault or breach of the Receiving Party.
3. Confidentiality of Arbitration Proceedings. In the event of any dispute or claim subject to arbitration under these Terms, the parties agree to maintain the highest level of confidentiality regarding: (i) The existence of the arbitration; (ii) All communications, documents, and information shared in relation to the arbitration; and (iii) Any and all submissions, orders, rulings, or awards made in the arbitration.
4. Breach of Confidentiality. Each party acknowledges and agrees that a breach of this confidentiality obligation could cause irreparable harm to the other party, entitling the non-breaching party to seek injunctive relief or any other equitable remedies available under Applicable Law, in addition to any other legal or contractual remedies.

1. No Liability: Neither Fintopio Kg nor you (“the Parties”) shall be liable for any delay, failure, or interruption in performing any obligation under these Terms, or for any inaccuracy in, or unsuitability of, the Platform’s content or functionality, to the extent such delay or failure results directly or indirectly from events or circumstances beyond the reasonable control of the affected Party (“Force Majeure”). Such events include, without limitation, acts of God, natural disasters, pandemics, war or hostilities, acts of civil or military authority, strikes or labor disputes, shortages of supplies or materials, network or telecommunication failures, power outages, and acts or omissions of third parties not under the affected Party’s reasonable control.
2. Consequences of Force Majeure. For so long as a Force Majeure event continues to prevent, restrict, or delay the performance of the affected Party’s obligations, that Party shall be excused from performing those obligations without liability. The affected Party shall not be deemed to have breached these Terms due to its delay or failure of performance caused by such an event.
3. Mitigation and Notice. The affected Party will use reasonable efforts to mitigate the impact of the Force Majeure event and to resume full performance of its obligations as soon as reasonably practicable. That Party will promptly notify the other Party of the commencement and nature of the Force Majeure event, as well as its efforts to address or mitigate the situation.
4. Exclusions. Notwithstanding the foregoing, this Clause shall not excuse or limit either Party’s obligation to pay any undisputed fees or amounts properly due and owing under these Terms, nor shall it excuse liability arising from the fraud, gross negligence, or willful misconduct of a Party.

1. Initial Resolution. In the event of any controversy, claim, or dispute arising out of or relating to these Terms or the Services (“Dispute”), you agree to first contact Fintopio Kg and attempt to resolve the Dispute informally. Both parties shall negotiate in good faith for at least thirty (30) calendar days (“Resolution Period”). Any communication or settlement offers exchanged during this Resolution Period shall be confidential and not admissible in any subsequent legal or arbitral proceeding unless otherwise required by law.
2. Agreement to Arbitrate Under HKIAC Rules. If the Dispute remains unresolved after the Resolution Period, either party may submit the matter to binding arbitration administered by the Hong Kong International Arbitration Centre (“HKIAC”) in accordance with the HKIAC Administered Arbitration Rules (the “Rules”) in force at the time of the commencement of the arbitration, which are deemed incorporated by reference into this Clause. The seat of the arbitration shall be Bishkek, Kyrgyz Republic, and unless otherwise agreed in writing by the parties, the language of arbitration shall be English. The arbitral tribunal shall consist of a single arbitrator, unless the parties agree otherwise or the Rules require otherwise.
3. Arbitral Tribunal and Award Enforcement. The arbitrator shall have the exclusive authority to determine jurisdictional issues, including questions of arbitrability, the existence, validity, or scope of this arbitration agreement. Any award rendered by the tribunal shall be final and binding on the parties, and judgment upon the award may be entered by any court of competent jurisdiction. The parties may seek recognition and enforcement of any arbitral award under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the “New York Convention”).
4. Time Limitation. Unless a longer period is required by Applicable Law, any claim subject to arbitration under this Clause must be filed within one (1) year from the date on which the party asserting the claim knew or should reasonably have known of the act, omission, or default giving rise to the claim.
5. No Waiver of Mandatory Rights.For the avoidance of doubt, nothing in this Clause shall deprive you of any mandatory legal rights to which you may be entitled under the laws of your place of residence or under any other Applicable Law.
6. Confidentiality of Proceedings. Except as may be required by law or necessary to enforce an arbitral award, the parties shall maintain strict confidentiality regarding the existence and substance of any arbitration proceedings, including all submissions, communications, evidence, and awards issued therein.

1. Governing Law. These Terms, and any non-contractual obligations arising out of or in connection with them, shall be governed by and construed in accordance with the laws of the Kyrgyz Republic. Nothing in this Clause deprives you of any mandatory rights or protections to which you are entitled under Applicable Law in your place of residence.
2. Exclusive Jurisdiction. Subject to the Dispute Resolution and Arbitration provisions set forth in these Terms, any legal proceedings arising out of or in connection with these Terms that are not settled through arbitration shall be brought before the competent courts of the Kyrgyz Republic. By entering into these Terms, you irrevocably submit to the jurisdiction of such courts and agree that any judgment or order of such courts shall be enforceable against you in any jurisdiction.

1. To the fullest extent permitted by Applicable Law, you and Fintopio Kg agree that any dispute or claim arising out of or relating to these Terms, or the Services shall proceed on an individual basis, and not as part of any class, collective, or representative action. You specifically waive any right to initiate or participate in any class, collective, or other representative proceeding against Fintopio Kg. Unless both parties provide written consent, neither party may consolidate or combine individual arbitrations or litigations into a single proceeding.

1. Geographical Limitation. Fintopio Kg offers Services solely in jurisdictions where we hold the requisite licenses and authorizations. It is your responsibility to ascertain whether your access to the Platform and use of the Services complies with all applicable laws and regulations in your place of residence or business.
2. Unsolicited Access. If you are not a resident of a jurisdiction in which we are duly licensed, you hereby represent and warrant that you have approached Fintopio Kg entirely of your own volition, without any direct solicitation, promotion, or marketing initiative on our part. You confirm that your decision to access the Platform and use the Services is undertaken at your sole initiative and request, and that you have specifically requested us to provide information regarding the Services and to facilitate transactions on the Platform.
3. No Offer or Solicitation. Nothing contained on the Platform or in any related communications from us shall be construed as an offer to sell, or a solicitation of an offer to buy, any virtual assets or Services in jurisdictions where such an offer or solicitation is not permitted. Any content, materials, or references made available on the Platform are provided strictly for general informational purposes.

1. Compliance with Applicable Law: By accessing or using the Services, you and any authorized individuals acting on your behalf agree to comply with all Applicable Laws, including but not limited to those governing data privacy, anti-money laundering, and counter-terrorist financing.
2. Notices and Communications: (i) Unless otherwise required by Applicable Law, we may deliver notices, announcements, or other communications to you via the email address registered with your Account. You are responsible for ensuring that your contact information remains accurate and up to date. (ii) Any notice sent to your registered email address will be deemed received, even if delivery fails due to an inaccurate or outdated email address. All notices must be in English and signed or otherwise authorized by the issuing party.
3. Official Announcements: We may publish official statements, updates, or promotions on the Platform or our website. These communications may relate to matters that could affect your virtual assets or the security of your Account. You agree to regularly review such announcements and understand that Fintopio Kg is not liable for any outcome arising from your failure to do so.
4. Entire Agreement: These Terms, together with any applicable Product/Service Terms or policies expressly referenced herein, constitute the entire agreement between you and Fintopio Kg with respect to the Services. Each party acknowledges that it has not relied on any representations, statements, or warranties not expressly set out herein.
5. Assignment: You may not assign, delegate, or transfer any of your rights or obligations under these Terms without our prior written consent. We may assign or transfer any of our rights or obligations under these Terms at any time, including in connection with a merger, acquisition, or corporate reorganization.
6. Severability: If any provision of these Terms is held unlawful, invalid, or unenforceable by a competent authority, the validity and enforceability of the remaining provisions shall not be affected. The parties shall replace any invalid provision with a new, valid provision that reflects, to the fullest extent possible, the original intent of the parties.
7. Recording and Monitoring: Subject to Applicable Law, we may record and monitor any communication you have with us, including but not limited to email, chat, and telephone communications. Such recordings may be used for compliance, customer support, dispute resolution, or regulatory purposes, and may be disclosed to competent authorities or otherwise in accordance with these Terms and Applicable Law.
8. Language: These Terms and any related documentation may be translated into other languages for convenience. In the event of any conflict or ambiguity, the English version shall prevail.
9. Third-Party Rights: These Terms confer no rights or benefits upon any person other than the parties hereto and their respective successors and permitted assigns. No third party shall have any right to enforce any provision of these Terms or any agreement referenced herein.
10. Survival: Any provision of these Terms which by its nature is intended to survive termination, including provisions relating to liability, indemnification, dispute resolution, and confidentiality, shall remain in effect after the termination or expiration of these Terms.
11. Relationship of the Parties: Fintopio Kg is not your agent, partner, or joint venture in rendering the Services. Nothing in these Terms shall be construed to establish any form of partnership, agency, or joint venture between the parties.
12. Force Majeure: We are not liable for any failure or delay in performing any obligation under these Terms due to events beyond our reasonable control, including but not limited to natural disasters, labor disputes, strikes, lockouts, war, terrorism, civil unrest, pandemics, or governmental actions.
13. Waiver: No failure or delay by Fintopio Kg in exercising any right or remedy under these Terms shall operate as a waiver thereof, nor shall any single or partial exercise of such right or remedy preclude any other or further exercise thereof.
14. Set-Off: We reserve the right, subject to Applicable Law, to set off any amounts you owe us against any amounts we hold for you. You shall not set off or withhold any amounts you owe to us without our express written consent.
15. Privacy: If you receive information about any other user through the Services, you must keep it confidential and use it only for the purpose of facilitating an authorized transaction. Your use of personal data must be in compliance with our Privacy Policy and Applicable Law. You shall not disclose or distribute such information to any third party except as required by law or regulation.

1. Interpretation:
   • Headings and Numbering. Clause headings and numbering are for convenience only and do not affect the meaning, priority, or interpretation of any clause or sub-clause in these Terms.
   • Include/Including. The words “include” or “including” mean “including, without limitation,” or “including but not limited to,” respectively.
   • Singular and Plural; Gender. Words in the singular include the plural, and vice versa. Words importing any gender include every gender.
   • Undertakings. An undertaking to do or not do a thing includes an undertaking not to permit or suffer the doing of that act or thing.
   • Document References. Any reference to a document shall be to that document as amended, varied, or novated from time to time otherwise than in breach of these Terms.
   • References to “Clause” or “Section.” References to “clauses,” “sections,” or “paragraphs” are to clauses, sections, or paragraphs of these Terms, unless otherwise stated.
   • Cross-References. Any references made to any specific policy (e.g., AML/KYC Policy, Privacy Policy, Cookie Policy) shall mean that policy as amended, restated, or otherwise updated from time to time.
   • Use of Electronic Means. All references to “written,” “in writing,” or similar expressions include electronic communications except where expressly stated otherwise by Applicable Law.
   • Precedence. In the event of any inconsistency between the provisions of these Terms (including any documents referred to in these Terms), that inconsistency shall be resolved according to the following order of precedence: (a) Any relevant Product or Service-Specific Terms; (b) The Privacy Policy or Notice; (c) These Terms.
2. Definitions:

“Fintopio,” “Fintopio Kg,” “CeFi Services Provider,” “we,” “us,” or “our” means Fintopio Virtual Assets LLC, a Virtual Assets Services Provider (VASP) duly licensed in the Kyrgyz Republic, including any of its Affiliates or successors, as applicable under these Terms.
“Affiliate” means, with respect to a specified person or entity, any other person or entity that directly or indirectly controls, is controlled by, or is under common control with the specified person or entity. “Control” means the power to direct or cause the direction of the management and policies of another party, whether through ownership of voting securities, contract, or otherwise.
“Applicable Law” means all statutes, laws (including rules of common law), regulations, regulatory principles, notices, orders, decrees, judgments, rulings, codes of conduct, guidelines, or interpretations issued by any governmental authority or self-regulatory body having jurisdiction over the provision, receipt, or use of the Services, or otherwise applicable under these Terms.
“Fintopio Platform” or “Platform” means the software ecosystem provided by Fintopio, encompassing any websites, Telegram integrated Fintopio Bots, Mini-Apps, web applications, mobile applications, pages, features, application programming interfaces (APIs), or any other channels designated by us for accessing or interacting with the Services.
“Mini-App” means a lightweight application, possibly integrated within a messaging app (e.g., Telegram) or other external platform, that facilitates specialized functionalities of the Fintopio Services in a streamlined manner.
“Telegram integrated Fintopio Bot” refers to a specialized bot residing in the Telegram messaging application, allowing you to manage your Fintopio Account or access Services through the Telegram interface.
“User,” “You,” or “Your” means any individual or legal entity that accesses, attempts to access, or uses the Fintopio Platform or any Services, including individuals or entities acting through Permitted Users on behalf of a corporate account.
“Fintopio Account” or “Account” means an account opened and maintained with Fintopio Kg for the use of the Services, and to record transactions, holdings, and other activities related to your use of the Fintopio Platform.
“Access IDs” means your Fintopio Account login details, usernames, passwords, personal identification numbers, API keys, API secret keys, or any other codes or forms of authentication used to access your Account or the Services, or to send Instructions.
“API” or “Application Programming Interface” means any software interface made available by us or a third-party for interacting programmatically with the Platform or Services.
“Instruction” refers to any request, command, or order submitted by you or a person authorized under your Account to us, relating to your Account or any Transactions. Instructions may include, without limitation, orders to buy, sell, exchange, or transfer Digital Assets, and must be submitted through channels authorized by us.
“User”, “you”, or “your” means any individual or legal entity that accesses, attempts to access, or uses the Fintopio Platform or any Services, including individuals or entities acting through Permitted Users on behalf of a corporate account.
“Permitted User” means any individual designated by a corporate User or otherwise authorized by Fintopio Kg to access and use a Fintopio Account on behalf of such corporate user, subject to any additional KYC or identification requirements.
“Know Your Customer” or “KYC” means a mandatory process carried out by Fintopio Kg (directly or via its Affiliates or third-party providers) to verify the identity of users for regulatory compliance and to mitigate financial crimes such as fraud, money laundering, or terrorist financing.
“Enhanced Due Diligence” or “EDD” means the additional identity verification or due diligence procedures required by Fintopio Kg to comply with Applicable Law, mitigate financial crime risks, or verify your suitability for certain Services or transaction limits. EDD may include, without limitation, requesting additional documentation, proof of source of funds, or any other actions deemed necessary by us.
“CeFi Services” means the centralized financial services (the “Services”) provided by Fintopio Kg through the Fintopio Platform, including (without limitation) on-ramp/off-ramp conversions, trading, custody, staking, P2P services, OTC transactions, brokerage, and other features specified in these Terms.
“Third-Party Services” means any services provided by parties other than Fintopio Kg, accessible via or integrated into the Platform, which may include certain on-ramp/off-ramp solutions, payment gateways, APIs, or blockchain network access.
“Custodial Wallet” refers to a digital wallet provided and managed by a Fintopio Kg (or its authorized third-party custodians), enabling users to store, transfer, and manage digital assets securely.
“Account History” means the written record, including electronic records, of your transactions, deposits, withdrawals, and other activities in your Fintopio Account.
“Digital Assets” or “Virtual Assets” means a digital representation of value or rights that can be transferred, stored, or traded electronically using distributed ledger technology (including blockchain). This may include, but is not limited to, cryptocurrencies, stablecoins, non-fungible tokens (“NFTs”), and tokenized derivatives of any other digital asset, excluding Fiat Currency.
“Supported Virtual Assets” means those Digital Assets that Fintopio Kg designates, from time to time, as eligible for storage, transfer, trading, or other activities on or through the Platform.
“Fiat Currency” means any government-issued currency that is designated as legal tender and is recognized and regulated by a governmental authority (e.g., U.S. Dollar, Euro, Kyrgyz Som) and is not a Digital Asset.
“Force Majeure Even” means any circumstance beyond a party’s reasonable control, including acts of God, natural disasters, pandemics, acts of civil or military authority, war, terrorism, labor disputes, strikes, power failures, internet or telecommunication failures, market disruptions, or any similar events.
“Fork” means any alteration to a Digital Asset’s underlying network protocol that may result in multiple versions or variants of the Digital Asset, planned or unplanned, consensual or controversial. streamlined manner.
“Network Event” means any event or circumstance related to a Digital Asset’s underlying blockchain or protocol that disrupts transaction records, ownership, or functionality of that Digital Asset, and is beyond our reasonable control (e.g., 51% attacks, double spending).
“Prohibited Jurisdictions” means any jurisdiction in which the provision, access, or use of the Services is unlawful or violates Applicable Law or is subject to sanctions or embargoes administered by governments or international organizations.
“Prohibited Person” means any individual or entity listed on any sanctions list maintained by a governmental authority (e.g., the United Nations, OFAC, EU, HM Treasury), or who is located in or a national/resident of a Prohibited Jurisdiction, or otherwise restricted from using the Services under Applicable Law and/or by us. which may be accessible via integrations, APIs, or hyperlinks through the Fintopio Platform.
“Transaction” means any purchase, sale, exchange, deposit, withdrawal, staking, or other action taken in respect of Digital Assets or Fiat Currency carried out through the Services or in connection with your Fintopio Account.
“User IP Rights” means any intellectual property rights owned or licensed to you before or during your use of the Platform, excluding any IP Rights owned or licensed by Fintopio Kg.
“User Materials” means any data, text, images, content, or other materials that you or other users upload, post, transmit, or otherwise make available through the Fintopio Platform or Services.
“Applicable Law” means all statutes, laws, regulations, rules, orders, decrees, directives, codes of practice, judgments, government-issued notices, or any other legal instrument having the force of law in any jurisdiction where you or Fintopio Kg operate or provide the Services.

For inquiries regarding these Terms, you may contact:

Fintopio Virtual Assets LLC
Registered Office: 9 Razzakov St., Business Center Russia,
9th Floor, Room 900,Pervomaisky District,
Bishkek, Kyrgyz Republic.
Telegram Support Bot: @FintopioHelpRobot