Effective Date: [01/01/2021]

These Terms and Conditions (“Terms” or “Agreement”) govern the use of the electronic trading platform, including any website or mobile application (“App”, collectively with the website, referred to as “Website”) to access the platform, and any services provided through the platform (collectively, “Platform”) provided by ALIXPAY (“Company”, “we”, “our”). These Terms constitute a binding agreement between the Company and you, as an individual user (“you”, “your” or “User”) for personal use of the App and Platform. By registering and downloading the App and using the Platform, you acknowledge and accept this Agreement and our related Privacy Policy. If you do not agree to these Terms, you must uninstall the App immediately and stop using the App and Platform.

Securities Disclaimer: No material or any other information provided on the Website or Platform shall be considered or construed as a recommendation, endorsement, offer, invitation, or solicitation to engage in any transaction or to purchase any products, or to trade securities, cryptocurrencies, or other products. You understand that no information provider, including any third-party providers (as defined below), is providing personal advice to you regarding the nature, potential value, or suitability of any specific securities or cryptocurrencies, securities or cryptocurrency portfolios, trades, investment strategies, or other matters, and any information provided is not tailored to the investment needs of any specific individual. You understand that an investment in any securities or cryptocurrencies involves certain risks, and discussions about any securities or cryptocurrencies posted on the Website or Platform may not include a list or description of the relevant risk factors. Please note that the market is constantly changing, so any information, content, Third-Party Content (as defined below), or other materials provided on or through the Website or Platform may not be complete or up-to-date, and may be superseded by more recent information. You rely on such information at your own risk.

No Professional or Investment Advice: Our Website and Platform are not intended to provide tax, legal, insurance, or investment advice, and no content on the Website or Platform should be construed as an offer to sell, solicitation to buy, or recommendation for any securities or cryptocurrencies by the Company. Only you are responsible for determining whether any investment, security, or strategy, or any other product or service, is suitable or appropriate for you based on your investment objectives and your financial and personal situation. You should consult with a lawyer or tax advisor regarding your specific legal or tax situation.

Definitions

a) “Account” means the account established by a User who has downloaded the Application or accessed the Website and registered with the Company to use the Website and Platform.

b) “Application” means the mobile application provided by the Company for accessing the Platform.

c) “Authorized Person” means any person authorized to access and use the Website (including the Application) and the Platform on behalf of the User.

d) “Biometric Authentication” means the identity verification feature using biometric information including fingerprints, facial recognition, or any other biometric data as we may permit from time to time.

e) “Digital Asset” means Bitcoin, Ether, or other cryptocurrency or digital assets or currencies.

f) “Digital Platform” refers to third-party distribution platforms where mobile applications or other software programs may be accessed or downloaded, including but not limited to Apple App Store and Google Play.

g) “Government Agency” means any nation or government or any province or state or any other political subdivision thereof, or any entity, agency, or authority performing executive, legislative, judicial, administrative, or regulatory functions of or related to government, including any government agency, department, council, committee or instrumentality or any political subdivision thereof, any court, tribunal, or arbitration, and any self-regulatory organization.

h) “Document” means any offering documents, term sheets, market data, research reports, product or service documents, or any other information provided through the Platform.

i) “Personal Information” refers to information provided by the User that can directly or indirectly identify that User.

j) “Privacy Policy” means the additional terms and conditions governing the collection, use, and disclosure of Personal Information of each User, as stated here [link]. Each User must read and agree to the Privacy Policy in order to use the Application or Website.

d) “Biometric Authentication” means the identity verification feature using biometric information including fingerprints, facial recognition, or any other biometric data as we may permit from time to time.

k) “Service Notice” means one-way notices from the Company (which may include security-related notices) via text message or email and, where possible, push notifications through the Website. These notices are sent to Users regarding certain information or events related to the account that Users have access to through the Platform.

l) “Third-Party Financial Service Provider” means any third party providing trading accounts, fiat-crypto exchanges, or other financial services that may be registered and accessed through the Platform.

m) “Third-Party Account” means a separate financial services account that a User establishes with a third-party service provider to carry out transactions.

n) “User” means any person who has registered with the Company to use the Website and access the Platform and any Authorized Person acting on their behalf.

o) “User Verification Policy” means the policy and procedures for customer identification that the Company applies from time to time related to User access to the Platform.
p) “User Login Information” means the set of user identification information, password, personal identification number, token, and any other information or device provided to the User for accessing the Platform.

Changes

2.1 We reserve the right at any time to: (a) modify, update, or change the terms and conditions of this Agreement or our Privacy Policy; (b) modify, update, or change the Website and Platform, including removing or discontinuing any content or features of the Website or Platform; or (c) impose fees, charges, or other conditions for the use of the Platform or any part thereof (with reasonable notice) (all of the above referred to as “Changes”).

2.2 We may make such Changes at any time without prior notice (except as stated in subsection (c) above). Any Changes to this Agreement may be posted on our website or notified to you via push notification through the Website or email to the email address in your Account. For this reason, you should check our website regularly, allow the Website to receive such push notifications, and keep your email address and other contact information updated in your Account. You accept any Changes if you continue to use the Website and Platform after such Changes have taken effect.

Digital Platform Terms

3.1 The Application may be downloaded from one or more Digital Platforms. Your download, installation, access, or use of the Application is also subject to the terms and conditions and privacy policies of the applicable Digital Platforms (“Digital Platform Terms”). In case of any conflict between these Terms and the Digital Platform Terms, these Terms will take precedence.

3.2 The Application is independent and not affiliated, related, sponsored, endorsed, or otherwise connected with any Digital Platform. You and we acknowledge that this Agreement is entered into between you and us, and not with any Digital Platform, and that we, not the Digital Platform, are solely responsible for the Application and its content to the extent specified in this Agreement.

Network Provider Requirements

4.1 You acknowledge that your agreement with your mobile and Internet service provider (“Network Provider”) will apply to your use of the Website. You acknowledge that you may be charged by the Network Provider for data service when using certain features of the Website or any other third-party charges that may arise and you accept full responsibility for such charges. If you are not the person paying for the mobile/Internet device being used to access the Website, you will be assumed to have obtained permission from the person paying for the device to use the Website.

Terms and Registration

5.1 You must be at least 18 years old to access and use the Website and Platform. You further confirm that you are fully capable and competent to participate in the terms, conditions, obligations, affirmations, representations, and warranties set forth in these Terms and to comply with and abide by these Terms. You must register with the Company to use the Website and Platform; you agree to provide complete and accurate information when registering to use the Website and Platform, and to update that information.
5.2 We have the sole discretion to accept or reject your registration with the Platform. Only Users with approved registration are our customers.

Intellectual Property

6.1 All ownership, proprietary rights, and intellectual property rights in or related to the Website and Platform, any information transmitted by, to, or through the Platform, and information related to the use of the Platform will remain with the Company or the Company’s licensors. Nothing on the Platform will be construed as granting any User any license, except as explicitly stated in this document, to any ownership, proprietary, and/or intellectual property rights of the Company or any third party, whether by implication, estoppel, or otherwise.

6.2 The Platform and Application may provide you access to content, information, quotes, videos, images, or other materials (“Third-Party Content”) provided by certain third parties (“Third-Party Content Providers”). The Company does not endorse or recommend, and is not responsible for verifying the accuracy, validity, or completeness of any Third-Party Content provided through the Website or Platform. Your use of or reliance on such Third-Party Content is at your own risk. All ownership, proprietary rights, and intellectual property rights in or related to Third-Party Content will remain with the applicable Third-Party Content Providers.

6.3 Provided that you comply with these Terms, you may download and access the Website on a single mobile device and access the Platform using validly authorized User Login Information. All other rights in the Website are reserved by the Company. In the event of a breach of these Terms, we will have the right to terminate your use and access to the Website and Platform immediately.

6.4 You agree not to: (a) modify, adapt, reproduce, translate, or create derivative works of the Website or Platform, or any data or content (including Third-Party Content) provided through the Website or Platform, or any part thereof, or attempt to reverse engineer, decompile, disassemble, or attempt to discover the source code of the Website or Platform; (b) remove any copyright, trademark, attribution, logo, or product identification notices from the Website or Platform; (c) impersonate other websites as the Company’s Website by copying the “look and feel” of the Company’s Website or infringing on the Company’s intellectual property rights, including but not limited to “scraping” text or images from the Company’s Website or banners and/or text links managed by the Company, search marketing, or any other online or offline campaigns; (d) edit, modify, filter, truncate, or alter the order of information contained in any part of the Company’s Website, or remove, obscure, or diminish any part of the Company’s Website in any manner without the Company’s permission; (e) use the Website or Platform or the Company’s logo, trademark, or brand name for any commercial purpose in any manner.

6.5 Each User authorizes the Company to use any information or content provided or processed by the User in connection with the use of the Website and Platform (e.g., Personal Information, Geographic Information, Device Information) in the context and for the purpose of providing services or products on the Platform and for the safe use of the Website and Platform.

Account

7.1 To use the services on the Platform, you must create an account with the Platform (“Account”). The Account will be used to record various digital assets that you transfer to the Platform and to execute transactions on the Platform. An Account may be registered by any individual over 18 years old or an organization by a legally authorized representative, provided that such individual or organization has read and understood the Risk Disclosure Statement, incorporated by reference and will be part of this Agreement. Each User may only register one trading Account on the Platform. Registering multiple trading Accounts will be a violation of these Terms and may result in the immediate termination of these Terms and related Accounts.

7.2 The Account is not a bank account, and the digital assets held in the Account are not deposits or other financial products. Unless permitted by the Platform, no interest will be paid on any funds or digital assets in your Account, and all digital assets held directly by us for your benefit are not insured by any government agency.

7.3 You may fund the Account by transferring digital assets from your account with a third party to the Account. The Platform does not charge for funding the Account; however, third parties, such as your bank, may charge transaction fees and other fees. Digital assets will be transferred to the Platform’s address for user account aggregation. The Platform will then credit your Account with the amount of digital assets on the Platform’s ledger.

7.4 You may withdraw all or part of the digital assets under your name recorded on the Platform’s ledger. There is no minimum amount of digital assets required to maintain your User status. Digital assets will be transferred from the user account aggregation held by the Platform to the specific digital asset address you provide. Withdrawals may take up to three (3) days to complete, provided that larger withdrawals may take up to thirty (30) days to complete and any withdrawal may be delayed if necessary to comply with applicable laws and/or the Platform’s user verification policies.

Transactions

8.1 The Platform is a marketplace that allows you to place orders and facilitate the matching and settlement of buying or selling digital assets or their derivatives with other Users. The Platform merely matches buy and sell orders placed by Users and assists Users in executing their intentions as expressed through their orders. Unless explicitly stated otherwise in this Agreement, the Company and the Platform do not act as a principal or other parties in such transactions. Both the Company and the Platform are not responsible for any disputes between or among Users regarding any transactions.

8.2 Orders are automatically matched by the Platform through its proprietary software and model, and the Platform will notify the respective Users that the order has been executed. When an order is matched, it is executed and settled immediately. YOU SHOULD ONLY PLACE AN ORDER IF YOU FULLY INTEND TO COMPLETE THE TRANSACTION. You have the right to cancel an authorized order by initiating a procedure through your Account to close the open order.

8.3 Unless otherwise permitted by the Platform, you may only sell an amount of digital assets not exceeding the total amount of digital assets held in your Account and recorded on the Platform’s ledger, plus applicable transaction fees (as defined below). Any attempt to sell more digital assets than the amount recorded in your Account after deducting applicable transaction fees will result in a failed transaction and may be grounds for termination of the Account.

8.4 You acknowledge that it may not be possible to cancel or modify an order in all cases, even before the order is matched or executed. We are not responsible for ensuring that an order is modified or canceled and you understand and agree that, if an order cannot be canceled or modified, you are bound by any execution of the original order. You also acknowledge that attempts to modify or cancel and replace an order may result in over-execution or execution of duplicate orders, and you will be responsible for all such executions.

8.5 You will be deemed to have placed an order through the Platform when we confirm such orders through the Platform or by other means that we may determine (whether or not you actually receive or are aware of such confirmation). You understand that the Platform provides real-time visibility into the status of all your open and pending instructions. You also understand that you are responsible for monitoring your open and pending instructions in real-time until the Platform confirms the execution, cancellation, or full rejection of such orders or instructions and we are not responsible or liable if you do not do so. In the event that you do not immediately notify us of any errors in real-time confirmation regarding the status of any open or pending instructions, including the Platform not timely confirming the receipt of an order after you have transmitted such order, we reserve the right to act in good faith requiring you to accept the transaction or remove the transaction from your Account with only your gain or loss. In some cases, and at our sole discretion, we may require secondary confirmation by electronic, verbal, written, or other forms before acting if your Account activity is outside its normal scope.

8.6 Your orders will be subject to trading limits that we may establish, modify, and notify you of from time to time.

8.7 Pursuant to Section 8.10, once an order has been executed, the transaction may be irreversible.

8.8 You acknowledge that due to technical and other limitations, the price of digital assets displayed on the Website may be delayed and thus not reflect the direct, current market value of those digital assets. However, you agree that the prices displayed on the Website control the value of your Account and your use of the Platform and Website.

8.9 You acknowledge and agree that the Platform cannot and does not guarantee that any Orders placed through the Platform will be executed at the best available price.

8.10 In the absence of consent from the relevant parties, we reserve the right to cancel or void transactions in the following cases: (a) transactions resulting from a detectable disruption or malfunction of the execution, settlement, or communication systems. (b) transactions that the Company, at its sole discretion, believes to be fraudulent, manipulative, or disruptive to other Users or the Platform. (c) transactions made by any Account that has been hacked by unauthorized users and we determine in good faith that canceling such transactions would be in the best interest of the Users or the Platform. (d) the Company believes, at its sole discretion, that your Account or trading activities within it violate these Terms.

Third-Party Accounts

9.1 You may be provided with the ability to register and set up a third-party account with a third-party service provider. Such third-party account will be subject to the terms and conditions and policies set forth by the third-party service provider for such third-party account (“Third-Party Service Provider Terms”).

9.2 You should carefully read the Third-Party Service Provider Terms before opening a third-party account with such third-party service provider. If you do not agree with the Third-Party Service Provider Terms, you should not register and open a third-party account with them. All transactions and other dealings conducted through a third-party account will be governed by the Third-Party Service Provider Terms. Additionally, you understand and agree that: (a) The Company will only act as a platform administrator and service provider to the third-party service provider regarding third-party accounts. Therefore, the Company may collect your personal information and other information on behalf of the third-party service provider in the process of opening a third-party account and providing the Platform for transactions conducted through the third-party account. Such personal information will be processed by the Company according to its Privacy Policy and will be shared with the third-party service provider, who will handle such personal information according to their own privacy policies. (b) The Company does not provide the third-party account to you and is not responsible or liable for the third-party account or any transactions conducted through the third-party account, or for any actions or omissions by the third-party service provider in relation to the third-party accounts, Third-Party Service Provider Terms, or the handling of your personal information. The Company will not be liable for any transactions conducted by you or your authorized individuals related to your third-party account. All questions and inquiries regarding third-party account transaction activities or other services that you send to us will be forwarded to the third-party service provider by the Company.

Fees

10.1 There is no fee to download the Application and register as a User, but we may charge fees for certain in-app purchases and other features that we may designate from time to time.

10.2 In exchange for access to the Platform and Services, you agree to pay a fee for each transaction initiated by you (the fee being referred to as “Transaction Fee”). The current Transaction Fees can be found on the Website after you log into your Account. We reserve the right to change, modify, or increase the Transaction Fees at any time and from time to time. Any such changes, modifications, or increases will be effective when such changes, modifications, or increases are posted on the Website. If you do not agree with the posted changes, modifications, or increases, you should stop using your Account as provided herein. Your continued use of the Account after the posting of modified Transaction Fees as posted on the Website will constitute your acceptance of all such changes or modifications.

10.3 Transaction Fees are paid by the parties to each specific transaction. Each party will be charged a fee in USDT/USDC or other currencies as approved by us from time to time. You are responsible for any fees imposed by third parties related to transferring digital assets into your Account on the Platform. The Platform charges a fee to transfer digital assets from your Account.

10.4 If you believe you have been incorrectly charged a Transaction Fee, you must promptly notify the Platform of the error, along with any additional information related to the transaction. If you do not raise any questions or objections within thirty (30) days after the Transaction Fee is first appeared on any Account statement, the fee will be deemed acceptable by you for all purposes.

10.5 You may incur Transaction Fees and other fees related to your third-party account. Any such fees are specified in the Third-Party Service Provider Terms. We are not responsible or liable for any fees, costs, or other charges you may incur related to that third-party account.

User Access Obligations

11.1 The Company will provide a unique set of user login information to each registered User of the Website and Platform. This user login information only allows Users to access their Account. Each User must promptly confirm receipt of this user login information to the Company.

11.2 You understand and agree that the information and services provided by the Platform are not to be provided to, and shall not be used by or for the benefit of, any individual or entity in any jurisdiction where such provision or use would be in violation of any applicable laws, or where we are not authorized to provide the Platform or such information and services. We also do not provide services or products to Users in certain excluded jurisdictions including the United States, Mainland China, Hong Kong, Singapore, Canada, the United Kingdom, North Korea, Cuba, Iran, Russian-controlled areas in Ukraine (currently including Crimea, Donetsk, and Luhansk), Syria, or any other jurisdiction that we may identify from time to time to discontinue services at our sole discretion (“Excluded Jurisdictions”). You should immediately notify us if you become a resident in any Excluded Jurisdiction or know of any User located in any Excluded Jurisdiction. You understand and acknowledge that if it is determined that you have provided false information about your location or residence, the Company reserves the right to take any appropriate action to comply with these restrictions or to comply with the laws of the relevant jurisdiction, including immediately terminating any Account and liquidating any open positions. We also do not provide services to individuals or entities on the U.S. Department of the Treasury’s Specially Designated Nationals or Blocked Persons List, the EU Consolidated List of Financial Sanctions, or the UK’s Sanctions List, or to any entity owned or controlled (50 percent or more) by an individual or entity on these lists (collectively referred to as “Prohibited Parties”), or provide services related to or beneficial to Prohibited Parties. You understand that the Company reserves the right to take any appropriate action to comply with these restrictions or to comply with the laws of the relevant jurisdiction, including immediately terminating any Account and liquidating any open positions.

11.3 Each User must: (a) Keep their user login information completely confidential and not share it with anyone else for any purpose, including but not limited to initiating or conducting any payment transactions related to their Account. Furthermore, Users must not disclose their user login information in a way that could be recognizable to third parties on any device (e.g., by writing down or recording the user login information without concealing it).
(b) Make reasonable efforts to secure all records related to their user login information, including but not limited to keeping such records in a safe or physical location accessible or known only to the User and ensuring such records are kept where they are not likely to be accessed by a third party.
(c) Take all reasonable measures to follow the security instructions provided by the Company and protect the security, preventing interference or use by anyone else of the user login information, the Website, or the Platform, including the security measures outlined in our Privacy Policy.
(d) Notify the Company immediately through any channel specified by the Company in the event of: (i) Loss of your user login information, (ii) Your user login information being disclosed to a third party or compromised, (iii) You suspect any unauthorized use of your user login information.
(e) Create a strong password (e.g., using a combination of letters, numbers, and special characters, and not using easily accessible personal information) and a strong PIN (e.g., by not using consecutive numbers or based on User ID, birth date, phone number, identification number, or any other easily accessible personal information).

11.4 When the Platform is accessed by entering the correct user login information or through the Application, the relevant User will be considered to have accessed the Platform. You will be responsible and liable for all actions conducted through such access by an authorized individual permitted to access the Platform on your behalf. The Company will not be obligated to investigate or take any other steps to verify the identity of any User or authorized individual. The Company will not be liable for any losses you may incur due to someone else using your user login information or Account, whether with or without your knowledge. Upon receiving notice under Section 11.3(d), the Company will disable the relevant user login information and block access to the Platform or Website as soon as reasonably possible.

11.5 Each User must secure all devices or systems used to access the Platform (e.g., Application), including but not limited to regularly updating browser settings, security patches, anti-virus software, anti-malware, and firewalls on those devices or systems. Each User must also comply with all instructions, procedures, and guidelines related to the Platform, Website, and user login information as communicated by the Company from time to time, including but not limited to risk management measures and other measures communicated on the Platform login page.


12.1 You may only use the Website or Platform in accordance with these Terms, solely for your own Account or for your internal business purposes. You may not sell, rent, or provide access to the Website or Platform to any third party, nor may you act as a service bureau or use the Website or Platform on behalf of any third party.

12.2 You may not use the Website or Platform in any way, provide any information or content, or engage in any conduct in using the Website or Platform that: (a) is illegal, unlawful, or unauthorized

12.1 You may only use the Website or Platform in accordance with these Terms, solely for your own Account or for your internal business purposes. You may not sell, rent, or provide access to the Website or Platform to any third party, nor may you act as a service bureau or use the Website or Platform on behalf of any third party.
12.2 You may not use the Website or Platform in any way, provide any information or content, or engage in any conduct in using the Website or Platform that:

（a) is illegal, unlawful, or unauthorized

（b）defames any other person

（c）is pornographic, sexually suggestive, or offensive

（d）advertises or promotes any other products or businesses

（e）harasses, annoys, embarrasses, alarms, or inconveniences any other person

（f）disrupts the Platform in any way; or promotes discrimination based on race, gender, religion, nationality, disability, sexual orientation, or age

（g）violates any copyright, trademark, trade secret, or other proprietary rights of any other person

（h）restricts or inhibits any other person from using the Platform, including but not limited to by ‘hacking’ or defacing any part of the Platform

（i）disables, damages, or alters the functionality or appearance of the Platform

（j）’frames’ or ‘mirrors’ any part of the Platform without our prior written consent

（k）uses any robot, spider, website search/retrieval application, or other manual or automated device or process to download, retrieve, index, ‘data mine’, ‘scrape’, ‘harvest’, or otherwise reproduce or circumvent the navigational structure or presentation of the Platform or its content

（l）collects or gathers information about other users without their clear consent

（m）sends unsolicited or unauthorized advertising, spam, or chain letters to other users of the Platform

（n）unless expressly permitted by the Company in writing, creates multiple accounts unless clearly allowed by the Platform

（o）engages in frequent, intensive trading with or without trading software or tools not authorized by the Platform

（p）transmits any content that contains software viruses, or other harmful computer code, files, or programs

（q）advocates, promotes, or supports any violent or illegal conduct

13.1 We may use technologies, services, or authentication or verification measures that we deem desirable or appropriate. Such measures may include multi-factor authentication or the use of Biometric Information to access the Application and Platform. We cannot guarantee that such authentication technologies, services, or measures will be completely secure, adequate, or successful in preventing unauthorized access to or use of the Platform or your ALIXPAY Account, or hacking or identity theft.

13.2 We may provide access to the Application and Platform using mobile devices through Biometric Authentication. Users acknowledge that by enabling Biometric Authentication for the Platform, unauthorized third parties may gain access to the Platform without entering User Login Information and querying banking information. Users acknowledge and accept the risks and responsibilities associated with using the Platform in conjunction with Biometric Authentication, particularly the risk of third parties accessing their Transaction Account information. By choosing to use Biometric Authentication on the User’s mobile device, Users consent to the collection and use of such Biometric Information to provide access to the Application and Platform in accordance with these Terms and the Privacy Policy. Users are also relying on functionality provided by the hardware and operating system on their mobile device. We will not be liable for any malfunctions, errors, inaccuracies, or unauthorized access to Users’ Biometric Information.

13.3 Although we use reasonable security measures to protect the security and privacy of the Platform and your personal information according to applicable laws, we cannot guarantee the security of all transmissions or any networks or systems on which your personal information or account or transaction information is stored or processed. To the extent required by law, we will notify you of any unauthorized access, use, or disclosure of your personal information that we become aware of. In the event you receive such a notice, you are responsible for following the instructions contained in the notice, including immediately changing your User Login Information and taking other steps to prevent unauthorized access to your account or personal information.

14.1 Each User and Authorized Individual acknowledges that they have received and accepted these Terms. When registering any Authorized Individual to receive access to the Platform and Account on their behalf, the User acknowledges and represents that the Authorized Individual is legally authorized to (i) access and use the Platform on behalf of the User and, if possible, exercise similar powers as granted by the User to the Authorized Individual under any applicable power of attorney to the extent technically feasible and services provided by the Platform are similar to those services that the User can access through other channels; (ii) accept any Changes to these Terms on behalf of the User; and (iii) subscribe to or register for any services of the Platform requiring separate registration or subscription.

14.2 Each User must ensure that each Authorized Individual acting on their behalf is informed of and agrees to comply with these Terms and, if applicable, the terms of any third-party service providers. You will be fully responsible for all actions or omissions or non-compliance of your designated Authorized Individual in accessing and using the Platform and any transactions conducted through your Account.

14.3 Each User shall fully indemnify the Company, and its subsidiaries and affiliates, officers, directors, employees, agents, and representatives against any liability, costs, claims, losses, expenses (including but not limited to legal fees), and damages arising from or related to (i) the breach of these Terms by their Authorized Individual; and (ii) any claims or actions by their Authorized Individual against the Company.

14.4 You represent, warrant, and confirm that you have obtained the consent of your Authorized Individual for the collection, use, transfer, disclosure, and processing of that Authorized Individual’s personal information in accordance with these Terms and the Privacy Policy.


By choosing to use the Platform, each User acknowledges that:

(a) The Company has NO obligation to agree to the User’s request to provide Documentation on any product and/or service

(b) Any Documentation provided, when provided, is only for that User and may not be further distributed without the Company’s written consent.
You acknowledge that neither the Company nor the Platform is your investment advisor or fiduciary. You also acknowledge that no Documentation we provide or provide on the Platform constitutes our recommendation that you should engage in any specific transaction or that any specific transaction is suitable or appropriate for you.
You acknowledge that we have no obligation or responsibility to verify, correct, complete, or update any Documentation displayed on the Platform. Documentation, including but not limited to, market data, quotes, news, and research, may be prepared by information providers independent of us. We do not guarantee that the Documentation will be accurate, complete, or timely updated. You should conduct further research and analysis or consult investment advisors before making investment decisions. Any use or reliance on the Documentation is at your own risk. We are not obligated to notify you of any technical difficulties we encounter related to accessing the Platform.
Information about your Digital Asset balance and Account status is available to you in electronic format for viewing at any time (subject to downtime) on the Website. You may review online all transactions, including pending orders, positions, deposits, and withdrawals, that occurred within the past year or other time period the Company may determine from time to time. You also have the right to receive receipts, transaction tickets, or other proof of transactions. Nothing in the transaction history should be considered as an evaluation. You acknowledge that errors may occur from time to time and such errors do not affect the means and actual results of any specific transaction. Any transaction listed on a statement or other communication with you will be considered and treated as authorized and accurate, approved, and confirmed by you unless we receive written notice from you to the contrary within three calendar days from the date the communication was sent or posted on the Website.
Content and information displayed through the Platform related to products and services may not be eligible for sale or may not be available to residents of certain countries or certain categories of investors due to regulatory restrictions.


The use of Service Notifications involves communication through unsecured communication networks.
You must provide us with a complete and accurate email address or phone number to allow us to send Service Notifications to you.
To ensure you receive all communications, you agree to keep your email address updated and notify us immediately of any changes.
Sending any communication to the email address on record is considered valid.

If any email communication is returned as undeliverable, we reserve the right to block your access to the Platform until you provide and confirm a new and valid email address.
When you have provided multiple email addresses and phone numbers to us, you must designate your preferred contact information for receiving Service Notifications.
When your account is a joint account, you must inform us whether Service Notifications should be sent to a specific account holder or all of them.
You agree to receive notifications about the Application, Platform, your Account, and Terms through Service Notifications. You agree that these Service Notifications will constitute effective notice in place of written notice, sent by mail or other forms of notice as required by applicable law.
You are solely responsible for monitoring the applicable email account or phone number without further reminders or repeat notifications from the Company. You must report any unauthorized use or access to the Platform immediately.
You release the Company from any legal liability for losses or damages arising from the use of Service Notifications, to the extent permitted by law. The Company makes no warranties or accepts any legal responsibility that the information provided through Service Notifications is up-to-date, accurate, or complete.
As part of the Platform, your Personal Information may be collected, used, transferred, disclosed, or otherwise processed by the Company in accordance with the Privacy Policy. You should carefully read the Privacy Policy before registering and using the Website and Platform. You agree to the collection, use, and disclosure of your Personal Information as outlined in these Terms and the Privacy Policy, including but not limited to, disclosure to third-party service providers for the purpose of providing services and conducting transactions related to the Account.
You agree to provide accurate, correct, current, and complete Personal Information. You also agree to maintain and promptly update Personal Information to keep it accurate, correct, current, and complete at all times during the term of this Agreement.
You must promptly notify us of all changes, including, but not limited to, changes in Personal Information related to the Platform. If you provide any information that is false, inaccurate, not current, or incomplete, or if we or any of our authorized agents have reasonable grounds to believe that the information is false, inaccurate, not current, or incomplete, we have the right to suspend or terminate the Account and deny any and all current or future use of the Platform and Website by you, as well as hold you liable for civil damages or refer you to the appropriate law enforcement agency for criminal prosecution. We will not be liable for compensation, monetary or otherwise, after suspension, termination, or inability to use your Platform or Website.
You must comply with any reasonable requests we make for information, documentation, and agreements related to any transaction or your use of the Website or Platform. You understand that we may report that information to regulatory authorities as we deem necessary according to the Privacy Policy.
Please note that we may collect information using tracking technologies related to your device, such as IP address, network provider, mobile carrier, mobile browser type, timestamp, timezone, information about speed, direction, orientation, and altitude of the device, or other device identification information. Users agree to the use of such tracking technologies and acknowledge that the information collected may be matched with public or private information that the Company or any third-party service providers may have access to. Users also agree that such information may be shared with the Company’s service providers and third-party service providers for the purpose of providing and maintaining tracking technologies and related services. We may also collect precise location data from or about your device, which may be represented by latitude-longitude coordinates obtained through GPS, WiFi data, cell tower triangulation, or other techniques. Our use of that information is described in our Privacy Policy.
The Platform and Website, including all content (including third-party content), features, and any related services are provided on an ‘as-is’ and ‘as-available’ basis at the User’s sole risk and without any representations or warranties. We do not guarantee that all or any part of the Platform or Application will always be available or accessible by the User at all times.
Risks Associated with Using the Platform

(a) Disclosure of your Personal Information or other information and the existence of your relationship with the third-party service provider to third parties

(b) System failures, security-related limitations, and unauthorized removal of usage restrictions on end devices, and other disturbances that may render usage impractical

(c) Abuse due to manipulation by malicious software or unauthorized use, including in the case where the User’s device used to access the Website or Platform is lost or stolen.
Additionally, you have received, read, and understood any Risk Disclosure Statements and are fully aware of the potential risks associated with accessing or using the Platform and conducting transactions using the Account.
We reserve the right to block or disable the use of the Website on end devices if the security features designed by the operating system or device manufacturer on which the Website is installed have been modified at any time (e.g., if the device has been ‘jailbroken’). Therefore, we do not guarantee the functionality and operation of the Application on end devices that have been modified in this way or on older end devices that no longer meet the technical requirements for using the Website or accessing the Platform.


ALL WARRANTIES, CONDITIONS, OR TERMS (WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE), INCLUDING BUT NOT LIMITED TO WARRANTIES RELATED TO QUALITY, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR UNINTERRUPTED ACCESS, ERROR-FREE ARE EXPRESSLY EXCLUDED IN RELATION TO THE WEBSITE AND PLATFORM TO THE MAXIMUM EXTENT PERMITTED BY LAW.
No representation or warranty, whether express or implied, is made regarding the accuracy or completeness of the information provided on the Platform.
Each User acknowledges and accepts the risks that may arise from Internet transactions conducted through open systems that can be accessed by anyone and acknowledges that, despite data encryption, connections from the User’s personal computer or mobile device to the Platform may be observed. We may also use servers and other computer hardware located in any jurisdiction worldwide to provide any part of the Platform.

We exclude any and all liability for losses or damages caused by transmission errors, technical faults, failures, business interruptions, or unlawful interference with transmission networks, IT/computer systems of the User or any third party (including systems in the public domain).

Compensation and Limitation of Liability

To the maximum extent permitted by applicable law, you agree to defend, indemnify, and hold harmless the Indemnified Parties from and against any and all claims (including third-party claims), actions, losses, liabilities, costs, expenses, or demands, including but not limited to legal and accounting fees, whether direct or indirect, arising out of or related to (i) your (or if you are under the control of others, including but not limited to government agencies, such others) use, misuse, or inability to use the Website, Platform, any Account on the Platform, or any content, including Third-Party Content therein or any content or information you have provided to the Platform; or (ii) your violation of these Terms or the Terms of a Third-Party Service Provider, including documents incorporated by reference into these Terms or the Terms of the Third-Party Service Provider.
We will notify you by email, letter, or other appropriate means about any such claims or lawsuits, and reasonably cooperate (at your expense) in the defense of such claims or lawsuits. We reserve the right to participate in the defense of such claims or appoint our own attorneys, but we are not obligated to do so.
IN NO EVENT AND UNDER NO LEGAL THEORY (NEGLIGENCE, CONTRACT, STRICT LIABILITY OR OTHERWISE) SHALL WE OR ANY INDEMNIFIED PARTY BE LIABLE TO YOU OR ANY OTHER PERSON FOR ANY DAMAGES ARISING OUT OF THE USE OR MISUSE, OR INABILITY TO USE, THE PLATFORM, WEBSITE, THIRD-PARTY CONTENT OR ANY ACCOUNTS, WHETHER SUCH DAMAGES ARE DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL OF ANY KIND, INCLUDING DAMAGES FOR LOSS OF BUSINESS PROFITS, LOSS OF DATA, BUSINESS INTERRUPTION, OR LOST SAVINGS, OR ANY LEGAL LIABILITY UNDER ANY CONTRACT, NEGLIGENCE, STRICT LIABILITY, OR OTHER THEORY ARISING OUT OF OR RELATED TO THE WEBSITE, PLATFORM, THIRD-PARTY CONTENT OR ANY ACCOUNTS, OR ANY CLAIM OR DEMAND BY ANY THIRD PARTY, EVEN IF WE HAVE BEEN ADVISED OF OR SHOULD HAVE BEEN AWARE OF THE POSSIBILITY OF SUCH DAMAGES, CLAIMS, OR DEMANDS IF THE ABOVE DISCLAIMER AND LIMITATION OF LIABILITY IS FOUND TO BE INVALID OR UNENFORCEABLE. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OR LIMITATION OF CERTAIN WARRANTIES AND/OR LEGAL LIABILITY, SO SOME OF THE LIMITATIONS OR EXCLUSIONS ABOVE MAY NOT APPLY TO YOU.
IN ANY EVENT, OUR LEGAL LIABILITY, REGARDLESS OF THE FORM OF ACTION AND DAMAGES YOU INCUR, SHALL NOT EXCEED THE TOTAL FEES PAID BY YOU TO US IN CONNECTION WITH THE PLATFORM, OR THE WEBSITE, OR 10,000 USD, WHICHEVER IS GREATER.
We shall not be liable for failure to perform any obligations under these Terms due to events beyond our control, and the time provided to perform such obligations will be extended by a period equal to the duration of such events. Events beyond our control include but are not limited to natural disasters, wars, riots, fires, embargoes, civil disturbances, strikes, labor disputes, equipment failures, banking failures, cryptocurrency market crashes or volatility, failures in processing credit or debit card transactions, strikes, fires, floods, earthquakes, tropical storms or other natural disasters or accidents, labor or material shortages, transportation shortages, facilities, fuel, energy, government regulations or restrictions, actions of civil or military authorities or terrorism, fiber optic cuts, weather conditions, third-party violations or failures, technical issues including hardware and software failures and other glitches, interruptions or failures in phone service, power outages, internet disruptions, viruses, spam or failures of any computer, server, or software, interruptions due to vandalism, theft, phone service outages, power outages, internet disruptions, viruses, and mechanical or electrical or communication failures.

Suspension or Termination in Whole or in Part

20.1 Access to the Platform may be suspended or terminated in whole or in part at any time by the User or by us in accordance with these Terms. Additionally, we reserve the right, at our sole discretion, to suspend or terminate immediately and without notice the access to or use of the Website and Platform by any User if they breach any terms of these Terms.

20.2 We may, at any time and at our sole discretion, limit, suspend, or terminate, or issue a warning to you regarding, the Platform or Account, including terminating the Account (or some of its functions such as uploading, receiving, sending, and/or withdrawing Digital Assets), if:

(a) we believe it is necessary or desirable to protect the security of the Account
(b) if any transaction is conducted that we, at our sole discretion, consider (a) being conducted in violation of this Agreement or breaching the Account’s security requirements; or (b) suspicious, unauthorized or fraudulent, including but not limited to issues related to money laundering, terrorist financing, fraud, or other illegal activities

(c) if we know or suspect that any Digital Assets or funds held in your Account may be connected to proceeds of crime or not legally owned by you

(d) in the event of insolvency, liquidation, dissolution, bankruptcy, administration, receivership, or dissolution of the User, or if we reasonably consider there to be a threat of any of the foregoing relating to you

(e) we are unable to verify or validate any information you have provided

(f) we believe, in our sole and absolute discretion, that your actions may result in legal liability to you, the Platform, or other Users of the Platform

(g) we decide to cease operating or discontinue providing any services or options offered by the Platform, or any part thereof

(h) there is a change in your circumstances (including a decline or change in your financial situation) that we consider, in our sole discretion, material to the continued operation of the Account

(i) we are directed to do so by any government agency

(j) we are required to do so under applicable law

(k) there is a market disruption event triggering a trading halt

(l) we decide at our sole discretion that termination or suspension of the Account, Platform, or these Terms is necessary.

20.3 We have no obligation to notify you of the reason or basis for suspending, terminating, or freezing your Account or any Digital Assets in your Account or any other actions we take regarding the Website, Account, or Platform.

20.4 Neither the Company, the Platform, nor any third party acting on their behalf will be liable to you for any suspension, restriction, or termination of your Account or your access to any part of the Platform under this Agreement.

20.5 You may not attempt to regain access to the Platform if your access has been terminated by us, whether using the same or a different username, without our prior written consent.

20.6 If there are any ongoing transactions on the Account that must follow termination procedures, the Company will have the right to notify your trading partner of the proposed termination.

20.7 The Company maintains full oversight of assets, funds, and user data/information that may be transferred to government agencies in the event that your Account is suspended or terminated due to a fraud investigation, legal violation investigation, or breach of these Terms. We will not be liable to you, your authorized person, and/or any third party for any loss or damage incurred due to delay, transmission error, technical error or defect, illegal interference with information provided and services rendered, or any failure or delay in executing any orders or transactions using any Account. Similarly, we will not be liable for any loss or damage incurred due to delay, technical error, or disruption in the availability of the Website, Platform, or any Account (including necessary maintenance work for our systems).

Governing Law and Dispute Resolution

22.1 These Terms shall be governed by and construed in accordance with the laws of the country where the dispute arises, without applying its conflict of laws rules.

22.2 Any dispute arising from or related to these Terms or the Platform, including any questions regarding its existence, validity, or termination, shall be finally resolved in accordance with the Rules of Arbitration of the International Chamber of Commerce (ICC) by one or more arbitrators appointed under the aforementioned Rules.

22.3 The place of arbitration shall be the country where the dispute arises. The language of arbitration shall be English.

22.4 Any arbitral award shall be final and binding on the parties. The parties agree to comply with and execute the arbitral award without delay.

22.5 Notwithstanding any other provisions of these Terms, nothing shall prevent any party from seeking emergency or interim relief from a competent court.

22.6 To the extent permitted by law, the parties waive any right to appeal or seek review of any arbitral award before any court or other tribunal.
Legal Restriction:
Before providing account information, users are informed that: “VASP services and cryptocurrency transactions, as well as their derivative products, involve significant loss risks. Please consider carefully before participating.”
VASP License:
Alixpay operates under VASP license number [License Number], issued by [Licensing Authority] on [Issue Date]. A copy of the license can be viewed at [Link to License].
AML/CFT Policy:
Alixpay strictly complies with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) regulations. The full policy can be found at [Link to AML/CFT Policy].
Refund/Cancellation Policy:
4.1. Completed cryptocurrency transactions cannot be refunded due to the irreversible nature of the blockchain.
4.2. For incomplete services, users may request a cancellation within 24 hours from the time the order is placed.
4.3. Collected transaction fees are non-refundable.
4.4. In the event of a system error leading to a failed transaction, the amount will be refunded within 5-7 business days.
Payment Information:
5.1. When making a payment, users must provide complete information, including: first name, last name, name on the card, phone number, email, full address, postal code, CVV2 code, and credit card expiration date.
5.2. The description on the credit card bill will display as “ALIXPAY-CRYPTO” along with the customer support phone number: [Support Phone Number].
5.3. The registered address of Alixpay UAB will be displayed on the payment page.
5.4. We accept payments via major credit cards, including Visa, MasterCard, and American Express. The logos of these cards will be clearly displayed on the payment page.
5.5. All payment transactions are secured with SSL encryption.
5.6. The amount, currency, and information on recurring payments (if any) will be clearly displayed before confirming the transaction.
Transaction ID:
Each transaction will be assigned a unique ID. This ID will be used for reference in case of disputes or issues.
Information Security:
7.1. All personal and transaction information of users will be secured according to Alixpay’s Privacy Policy.
7.2. Users are responsible for protecting their login information and should not share it with anyone.
Regulatory Compliance:
8.1. Users agree to comply with all current regulations on cryptocurrency transactions in their country.
8.2. Alixpay reserves the right to request additional information to comply with KYC (Know Your Customer) and AML regulations.
By using Alixpay’s services, you confirm that you have read, understood, and agreed to all the terms and conditions stated above.

Contact Us

You can contact the Company regarding these Terms, the Website, or the Platform as follows.