Terms of Use

1. User agreement

The edition is valid from the moment of publication. Last update date: 05/04/2026.

This User Agreement (hereinafter referred to as the “Agreement”) is a public offer and an electronic contract between the person using the sitehttps://saikyo.exchange(hereinafter referred to as the “Client”, “User”), and the operator of the SAIKYO service (hereinafter referred to as the “Service”, “SAIKYO”, “We”). The Agreement defines the conditions for access to the Site and use of the services provided on it.

The Service has the right to unilaterally make changes to this Agreement and other documents of the Service without prior notice to the Client. The new edition comes into force from the moment of publication on the Site. The client is responsible for monitoring changes independently. Continued use of the Site after the publication of a new edition means its unconditional acceptance.

1.1. Terms and definitions

1.1.1.“Service” / “SAIKYO” is an exchange service available athttps://saikyo.exchange, exchanging digital financial assets for non-cash funds in Russian rubles and in the opposite direction.

1.1.2.“Site” is a collection of software, content and services located at https://saikyo.exchange and its subdomains.

1.1.3.“Client” / “User” - an individual or legal entity, individual entrepreneur who uses the Site and has accepted the terms of this Agreement.

1.1.4.“Application” is an offer made by the Client through the Website interface to carry out an exchange operation, indicating the direction, amount, details and other essential conditions.

1.1.5.“Digital financial asset” / “DFA” / “Cryptocurrency” is a virtual asset, the circulation of which is carried out in distributed registries (blockchains).

1.1.6.“KYC” (Know Your Customer) - procedures for identifying the Client in accordance with international FATF standards and internal regulations of the Service.

1.1.7.“AML” (Anti-Money Laundering) and “CTF” (Counter-Terrorism Financing) are a set of measures to combat the legalization (laundering) of proceeds from crime and the financing of terrorism.

1.1.8.“Suspicious traffic / transaction” - actions, assets, operations or behavior of the Client that potentially violate the AML/CTF/KYC policy, including communication with mixers, P2P exchanges without KYC, darknet sites, phishing/fraudulent addresses, sanctioned addresses, high-risk addresses according to the classification of Chainalysis, AMLBot, TRM Labs, Crystal Blockchain, Elliptic.

1.1.9.“Restricted Persons” - individuals and legal entities included in any of the sanctions lists: OFAC SDN List; Consolidated list of EU financial sanctions; UK Sanctions List; Canada Sanctions List; Rosfinmonitoring list of terrorists and extremists; UN Security Council Lists; other internationally recognized sanctions lists.

1.1.10.“High-risk jurisdictions” are countries classified by FATF as jurisdictions with serious AML/CTF deficiencies, or subject to restrictive measures, including (without limitation): DPRK, Iran, Syria, Afghanistan, Yemen, Myanmar, Cuba, Venezuela.

1.1.11.“PEP” (Politically Exposed Person) is a politically exposed person, his close relatives and affiliates within the meaning of FATF recommendations.

1.2. Subject of the agreement

1.2.1.The subject of the Agreement is the provision by the Service to the Client of services for the exchange of digital financial assets for non-cash funds in Russian rubles and in the opposite direction, in the manner and under the conditions specified on the Site.

1.2.2.Services are provided exclusively after completing the KYC procedure. The service is focused primarily on working with legal entities and individual entrepreneurs by bank transfer. Services are provided to individuals after full identification of the Client and in the absence of signs of suspicion.

1.2.3.The service reservesthe unconditional right to refuse services to any person without giving reasons and without prior notice. This right is an essential condition of the Agreement.

1.2.4.Any operation initiated by the Client cannot be canceled unilaterally by the Client after the actual transfer of funds. Refunds are possible only in cases and in the manner established by the Procedure for depositing and returning funds (section 6).

1.2.5.The service is not a bank, credit or microfinance organization, payment agent, professional participant in the securities market, digital financial asset exchange operator, or information system operator. The service operates within the functionality of a peer-to-peer digital currency exchange infrastructure and is not subject to mandatory licensing.

1.2.6.The service is not a depository, does not store the Client’s assets beyond the time required to complete a specific application, and does not provide trust management services.

1.3. Service Rights

1.3.1.The service has the right:

1. Suspend, cancel or refuse executionany Application at any time before the actual dispatch of the counter asset, including if signs of suspicion are identified, at the request of the competent authorities, in the event of a technical failure, error in the course, violation by the Client of any clause of these documents or applicable law.
2. Request additional documents from the Clientand information, including: identification documents; selfie with document; video verification (turning the head, demonstrating a document, pronouncing a text of the Service’s choice); confirmation of the source of origin of funds and DFA; organization documents; confirmation of the authority of the representative; video call with an authorized compliance officer.
3. Block the Client's funds and/or DFAfor up to365 (three hundred sixty-five) calendar daysto conduct AML/KYC verification. Upon expiration of the blocking period, the Client is obliged to independently apply for a final decision within 30 (thirty) calendar days; otherwise, the Service has the right to write off the funds as unclaimed or transfer them at the request of the competent authorities.
4. Transfer any information about the Client, its Applications, transactions, documents, IP addresses, devices and behavioral data to competent authorities and partner AML services.
5. Unilaterally recalculate the Applicationat the actual rate at the time of execution, if: the rate has deviated by more than3 %from the weighted average exchange rate of Bybit, Binance, OKX, Bitget, MEXC, Rapira; The Client paid for the Application with a delay; DFAs did not receive confirmation within the prescribed time limit; a technical failure occurred; network fees have changed significantly; an amount has been received that is different from that specified in the Application.
6. Withhold commissions and actual costsupon refund in accordance with the procedure established by section 6.
7. Involve third parties(paying agents, banks, acquirers, AML providers, legal consultants, telecom operators, accounting companies) to fulfill obligations to the Client and process personal data.
8. Change tariffs, limits, list of available exchange directions and operating conditions of the Servicewithout prior notice to the Client.
9. Close, block or limit the Client's accountwithout the right of recovery upon detection of any violation, repeated suspicions of suspicious activity, detection of multi-accounts, use of anonymizers for sanction purposes, attempts to bypass KYC limits, refusal to undergo KYC.
10. Refuse to perform an operation unilaterally without giving reasonsat any stage.

1.4. Guarantees and obligations of the Client

1.4.1.The Client warrants and represents that:

1. Has reached the age of 18 years, has full legal capacity, acts on its own behalf and in its own interests or has duly executed authority from the person in whose interests it acts, and will disclose such person upon request of the Service;
2. Is not a person under restrictions (clause 1.1.9), is not a tax/currency/civil resident of high-risk jurisdictions (clause 1.1.10), is not a PEP without disclosing this status to the Service;
3. The funds and digital financial assets used in the Application were obtained legally and are not related to criminal activity, money laundering, terrorist financing, drug trafficking, illegal arms trafficking, fraud, cybercrime, illegal gambling, or trade in sanctioned goods;
4. Is the sole owner of the funds used and DFA, has independent access to them and disposes of them freely, without orders and instructions from third parties;
5. Is not under physical, psychological or social pressure, does not act under threats, deception or misrepresentation, does not follow instructions from unknown third parties to buy/sell DFAs or transfer to third-party wallets;
6. Understands the principles of blockchain and DFA operation, the risks of volatility and irreversibility of erroneous transactions, and accepts them in full;
7. Independently complies with the applicable tax regime in the jurisdiction of its residence/registration.

1.4.2.The client undertakes:

1. Provide the Service with complete, truthful, current and non-misleading information. If any information changes, update it yourself and in a timely manner;
2. Complete KYC and AML verification procedures in full and within the time limits established by the Service;
3. Independently check the correctness of the details before paying for the Application: wallet address, network, BIC, current account, TIN, purpose of payment.The risk of errors in the details is borne by the Client in full;
4. Do not use the Site to commit illegal actions, including money laundering, terrorist financing, bypassing sanctions regimes, tax evasion, cashing out, splitting transactions to bypass KYC limits;
5. Do not attempt to gain unauthorized access to the Site, do not introduce malicious code, do not carry out DDoS attacks, do not parse data bypassing the API, do not create multiple accounts in order to bypass limits;
6. Immediately report any suspicion of account compromise to the Service support service;
7. Do not falsify communications with the Service, do not provide false documents, do not use other people’s details.

1.4.3. Consent to the processing of personal data.By accepting the Agreement, the Client gives unconditional consent to the Service processing all personal data provided during registration, passing KYC, creating Applications and contacting support, in the manner specified in the Privacy Policy (Section 3).

1.5. Special conditions for legal entities and individual entrepreneurs

1.5.1.Services to legal entities and individual entrepreneurs are provided exclusively by bank transfer from a current account, the details of which were specified by the Client during registration and confirmed by documents.Payments from bank accounts of third-party organizations, personal bank cards, cash and through fast payment systems are not accepted.

1.5.2.Each operation is formalized by a written contract (framework or one-time) or an invoice-offer and a service acceptance certificate.

1.5.3.The minimum application amount for legal entities and individual entrepreneurs is3,000,000 (three million) rublesor 3,700,000 KGS; maximum - determined individually based on the results of a compliance check.

1.5.4.The application rate is fixed at the time the invoice is issued and is valid until the end of the current business day (until 18:00 Moscow time). When paying on a different date, the rate is recalculated according to the current one.

1.5.5.The client-legal entity/individual entrepreneur is obliged to provide: an extract from the Unified State Register of Legal Entities/Unified State Register of Individual Entrepreneurs no more than 30 days old, a copy of the charter (for legal entities), documents confirming the authority of the person signing the agreement, a bank card with sample signatures, tax returns for the last reporting period (on request), financial statements (on request).

1.5.6.The purpose of payment must strictly comply with the wording specified in the Service invoice. Payments for other purposes may be refunded minus bank fees and actual costs.

1.6. Cost of services and commissions

1.6.1.The cost of services is included in the exchange rate. The marketing margin of the Service is published on the Site and may be changed unilaterally without prior notice.

1.6.2.In addition to the Service markup, the following is withheld from the Client: blockchain network fee (network fee / gas fee) - actual, in full; commissions of banks and payment systems are actual, in full; commissions of AML providers - if extended verification is required.

1.6.3.The service is not responsible for changes in tariffs, the Client’s expectations regarding the profitability of operations and other subjective factors.

1.7. Jurisdictional restrictions

1.7.1.The service does not provide services to: citizens and residents of the United States of America (in accordance with FinCEN rule 31 CFR § 1010.100(ff) and the OFAC sanctions regime); citizens and residents of high-risk jurisdictions (clause 1.1.10); persons included in any sanctions lists (clause 1.1.9); politically exposed persons (PEP) - without conducting an extended KYC check; to other persons at the discretion of the Service’s compliance service.

1.7.2.By accepting the Agreement, the Client guarantees that he does not fall under any of the restrictions in clause 1.7.1. Indication by the Client of false information in this part is an independent basis for blocking funds and the account.

1.8. Disclaimer

1.8.1.The Service guarantees the execution of accepted Applications solely within the limits of funds and DFA received from the Client, in the manner and within the time limits published on the Site at the time of the Application.

1.8.2. The total liability of the Service to the Client for any reason cannot exceed the amount of the Service markup actually paid by the Client for the specific Application that was the basis for the claim.The service under no circumstances compensates for lost profits, moral damages, reputational damage, indirect and indirect damages.

1.8.3.The service is not responsible for: actions of third parties - banks, payment systems, blockchain networks, other counterparties; delays in performance caused by failures in designated third parties or unfavorable network conditions; any actions of the Client, as a result of which funds were transferred to erroneous details; force majeure circumstances;change in risk assessment (AML Risk Score) at the Client’s addresses after execution of the Application— revaluation is not a basis for making claims; theft, loss of private keys, phishing attacks on the Client’s side; tax consequences for the Client in any jurisdiction; duration of the compliance procedure - the Service sets it independently.

1.8.4. Guarantee of compensation for losses (indemnification).The Client undertakes to fully reimburse the Service, its operators, employees, affiliates and partners for any losses, fines, expenses (including reasonable expenses for legal representation) arising in connection with: violation by the Client of any provision of these documents; the Client providing false, incomplete or misleading information; the Client's use of the Service in violation of applicable law; claims of third parties related to the Client’s actions.

1.8.5.The service is provided on an “as is” basis. The Service does not guarantee uninterrupted operation, absence of errors, compatibility with any devices, or compliance with any Client expectations.

1.9. Force majeure

1.9.1.The parties are released from liability for complete or partial failure to fulfill obligations in the event of force majeure circumstances. These include: natural disasters, fires, floods, earthquakes, pandemics, epidemics, military actions, terrorist attacks, civil unrest, changes in legislation, acts of government bodies, Internet restrictions, blocking and regulatory restrictions, DDoS attacks on the Service, hacker attacks on blockchain networks, forks and reorganizations of the blockchain, termination or suspension of payment systems and banks, revocation of licenses from payment providers, interruptions in power supply, equipment failures, actions of telecom operators and Internet providers.

1.9.2.If force majeure occurs, the Service has the right to suspend the execution of all Applications until the force majeure circumstances cease; the duration of such circumstances is not taken into account when calculating the deadlines for execution.

1.10. Applicable law, claim procedure and jurisdiction

1.10.1.Relations between the Parties are governed by international standards in the field of combating money laundering and the financing of terrorism (FATF Recommendations), as well as - subsidiary - by the law of the jurisdiction in which the Service actually operates; the specific jurisdiction is not publicly disclosed and is determined by internal documents of the Service.

1.10.2.All disputes arising from this Agreement or in connection with it are subject to mandatory pre-trial (claim) settlement. The period for consideration of a claim by the Service is up to 15 (fifteen) business days from the date of receipt of the set of documents, unless a longer period is required for AML/KYC verification, response from the bank, payment provider, blockchain service or competent authority.

1.10.3.Claims are sent exclusively through the Service support service via the email indicated on the Site, or through a confirmed Telegram channel. The complaint must indicate: Application number, date and amount of the transaction, direction of exchange, details of the sender and recipient, description of the problem, confirmation of payment or transaction hash, as well as a contact for a response.

1.10.4.If a claim is submitted through monitoring exchangers or another platform, the Client is obliged to simultaneously provide the Service with data sufficient to identify the Application. The service has the right to respond within the framework of such a dispute without disclosing personal data to third parties and in compliance with AML/KYC, banking, commercial secrets and legislation on personal data.

1.10.5.The limitation period for any Client's claims to the Service is1 (one) yearfrom the moment the relevant circumstances occur.

1.10.6.To resolve the dispute, the Parties, before going to court, are required to consider the possibility of mediation or commercial arbitration at the choice of the Service.

1.11. Final provisions

1.11.1.If any provision of this Agreement is held to be invalid or unenforceable, the remaining provisions will remain in full force and effect.

1.11.2.Section and paragraph headings are for convenience and do not affect the interpretation of the Agreement.

1.11.3.Electronic correspondence through the Service support service is considered acceptable written evidence in all disputes.

1.11.4.This Agreement is drawn up in Russian. In case of translation into other languages, the Russian version prevails.

2. AML and KYC policy

This Policy is an integral part of the User Agreement and is subject to application in conjunction with it.

2.1. Goals and principles

2.1.1.The service strives to prevent the use of its infrastructure for legalization (laundering) of proceeds from crime, financing of terrorism, circumvention of sanctions regimes, as well as any other illegal actions. This Policy has been developed taking into account the recommendations of the Financial Action Task Force (FATF), the Fifth Anti-Money Laundering Directive (5AMLD), as well as generally accepted principles of international Compliance practice.

2.1.2.The service uses a risk-based approach (Risk-Based Approach): the scope of KYC and AML checks depends on the risk level of the Client and the operation.

2.2. Client Identification (KYC)

2.2.1.Identification is mandatory for all Clients, regardless of the amount and category of the transaction.

2.2.2.Scope of identification of individuals (KYC):

• last name, first name, patronymic (in full);
• date of birth;
• series and number of passport (or other identification document);
• by whom and when the document was issued;
• registration address;
• TIN (on request);
• photo of the photo spread and registration page;
• selfie with an open document in hand;
• video with head rotation (liveness check) - with extended testing;
• contact details: e-mail, mobile phone, Telegram;
• bank card/account details that will be used;
• addresses of crypto wallets used in operations.

2.2.3.Scope of identification of legal entities and individual entrepreneurs:

• full and abbreviated name, OGRN/OGRNIP, INN, KPP;
• legal and actual address;
• extract from the Unified State Register of Legal Entities/Unified State Register of Individual Entrepreneurs not older than 30 days;
• a copy of the charter (for legal entities);
• documents confirming the powers of the sole executive body and authorized representatives;
• passport details of the manager and representatives signing the documents;
• information about beneficial owners (share more than 25%);
• bank card with sample signatures;
• tax returns and financial statements (on request);
• information about types of activities (OKVED), turnover, tax regime.

2.2.4.The service has the right to conduct an enhanced due diligence (EDD) check if: the operation is classified as high-risk; The Client or its counterparty is a PEP; the crypto wallet address is associated with suspicious sources; there are reasons to suspect an attempt to bypass KYC limits; the source of funds is not obvious.

2.3. Verification of digital financial assets (KYT/AML)

2.3.1.Each crypto wallet address participating in the operation undergoes automated AML verification through specialized providers (Chainalysis, AMLBot, TRM Labs, Crystal Blockchain, Elliptic).

2.3.2.The following are subject to verification: address of the sender of the DFA (when the Client purchases the DFA from the Service); address of the recipient of the DFA (if the Client sells the DFA to the Service); history of transactions at the specified addresses for a period of at least 12 months; connection of addresses with known illegal sources - darknet marketplaces, mixers (Tornado Cash, Wasabi, ChipMixer, etc.), sanctioned addresses, P2P exchanges without KYC, phishing/fraudulent wallets, sanctioned exchanges; direct and indirect connection (1st and 2nd level) with the specified sources.

2.3.3.Risk scale:

• 0–30% – low risk: the operation is carried out as usual;
• 30–70% – average risk: The service has the right to request additional documents about the origin of funds;
• 70–100% – high/critical risk: The operation is blocked and funds are held for investigation. The service has the right to refuse execution and not return funds until AML/KYC procedures are completed, including with the involvement of competent authorities.

2.3.4.If the results of the KYT/AML check reveal a violation of this Policy, the Service has the right to: block funds for a period of up to 365 (three hundred sixty-five) calendar days; request an extended package of documents (KYC + Source of Funds + Source of Wealth); refuse to execute a transaction and return funds in cases expressly provided for by applicable law, including cases where the return of such funds is illegal; transfer information and funds to the competent authorities.

2.4. Confirmation of the source of funds (Source of Funds, SoF)

2.4.1.The Service has the right at any time to request from the Client a documented explanation of the origin of funds and/or DFA. Such documents include (without limitation): 2-NDFL certificates or equivalent in another jurisdiction; tax returns, including income from transactions with digital financial services; statements from bank and brokerage/trading accounts; employment contracts, contract agreements, provision of services, dividends; contracts for the purchase and sale of property, inheritance, donation; extracts and confirmations from trading crypto exchanges; mining agreements and documents confirming the legality of mining activities; other documents as required by the Service.

2.4.2.The deadline for providing documents is up to 14 (fourteen) calendar days from the date of request. For valid reasons, the period may be extended by agreement with the Service.

2.4.3.Refusal or failure to submit documents within the prescribed period is an independent basis for suspending the operation, blocking funds and/or refusing to execute the Application.

2.5. Categories of Invalid Operations

2.5.1.The service unconditionally refuses and does not return funds for transactions related to: financing of terrorism and the proliferation of weapons of mass destruction; drug trafficking and illicit trafficking in psychotropic substances; arms trade in circumvention of sanctions regimes; human trafficking, exploitation and illegal pornography; cybercrime (ransomware, phishing, carding, sale of stolen credentials); illegal gambling and illegal bookmaking operations; bypassing sanctions regimes; laundering proceeds from fraud (including investment fraud, romance scams, Ponzi schemes); theft of funds from crypto exchanges and DeFi protocols.

2.6. Data storage and cooperation with authorities

2.6.1.All KYC data, documents, transaction history, IP addresses, device fingerprints, correspondence with support and other information are stored by the Service for at least 5 (five) years from the date of the Client’s last transaction, and in cases of investigation - until the completion of the relevant procedures.

2.6.2.The service cooperates with competent authorities in the manner prescribed by applicable law and provides information about the Client, his transactions and funds upon lawful requests.

2.7. Client's responsibility

2.7.1.The client bears full responsibility for the accuracy of the KYC data provided. Indicating knowingly false information or providing forged documents is an independent basis for the unconditional and irrevocable blocking of funds and account, as well as the transfer of materials to law enforcement agencies.

2.7.2.The client guarantees that the person actually sending the funds matches the person who has completed the KYC. A discrepancy is grounds for blocking the operation.

3. Privacy Policy

This Policy governs the processing of personal data of Service Clients.

3.1. Composition of processed data

The service collects and processes the following categories of data:

• Identification data: full name, date and place of birth, citizenship, series and number of passport (or other document), issued by whom and when, registration address, TIN;
• Biometric data: photo/video materials depicting the Client’s appearance and provided for the purposes of KYC and fraud prevention (including a selfie with a document, video with a head turn);
• Contact details: e-mail, telephone, Telegram, instant messengers, other communication channels;
• Payment and financial data: details of bank cards and accounts, BIC, current account, data on payment systems, transaction history;
• DFA data: crypto wallet addresses, transaction history, AML metrics, tokens and networks;
• Information about the legal entity / individual entrepreneur(if available);
• Technical data: IP address, device and browser identifiers, OS and browser version, language, time zone, screen resolution, fingerprint, event logs, cookie identifiers;
• Behavioral data: history of visits, actions on the Site, history of requests for support, correspondence.
• Authentication data: password hash (irreversible bcrypt hash), 6-digit email confirmation codes (stored hashed SHA-256 for 15 minutes), with two-factor authentication enabled - TOTP secret (used to generate one-time codes; not transmitted to third parties), authentication status flags (email confirmed, 2FA enabled), logs of login attempts (to protect against brute force).
• KYC documents uploaded by the Client independently through his personal account: photo/scan of the front and back sides of the identity document, selfie of the Client with the document. The files are stored on the Service infrastructure with access control and are accessible only to Service verifiers as part of the performance of the obligation to identify the Client.

3.2. Purposes of processing

• execution of this Agreement and provision of Service services;
• Customer identification (KYC) and abuse prevention (AML/CTF);
• conducting checks against sanctions lists and PEP lists;
• ensuring the security of the Site, protection against fraud, cyber threats, fraud;
• fulfillment of duties established by applicable law;
• interaction with competent authorities on their legitimate requests;
• analytics, service quality assessment, technical monitoring;
• informing the Client about the status of his Applications, promotions and services (with the possibility of refusal);
• protection of the rights and legitimate interests of the Service in disputes.

3.3. Legal grounds

Processing is carried out on the following grounds: consent of the subject (for situations that directly require consent); execution of a contract to which the subject is a party; fulfillment of the obligation assigned to the Service under applicable law; justified (legitimate) interest of the Service in the field of anti-fraud and security.

3.4. Shelf life

• identification and KYC data - at least 5 (five) years from the date of the Client’s last transaction, and in cases of investigation - until the completion of the procedures;
• history of transactions and correspondence - at least 5 (five) years;
• biometric materials - for the period necessary to conduct verification and subsequent protection of the rights of the Service in disputes, but not less than 3 (three) years;
• technical and security logs - from 6 to 24 months, unless a different period is required to investigate the incident;
• cookie - during the lifetime of a specific cookie or until it is deleted by the Client.

After the deadline, the data is deleted, anonymized or isolated from active processing.

3.5. Transfer and disclosure of data

The service has the right to transfer data to: involved processors - AML/KYC providers, banks, payment agents, cloud service operators, companies providing infrastructure and support, subject to the conclusion of data protection agreements with them; to competent authorities and regulators for lawful requests; professional consultants (lawyers, auditors) within the scope of their activities; to the legal successors of the Service during reorganization, sale of business or assets; visual identification and recognition services (in an impersonal or limited scope).

3.6. Cross-border transfer

Due to the fact that the Service infrastructure and its processors may be located in different jurisdictions, data may be transferred outside the Client’s jurisdiction. In such cases, the Service applies reasonable protection measures, including contractual obligations of processors and technical measures (encryption, access control).

3.7. Security measures

The service applies technical and organizational data protection measures, including: encryption during transmission (TLS/HTTPS, minimum version TLS 1.2); encryption of sensitive fields at rest (bcrypt hashing of passwords, SHA-256 hashing of one-time codes); restriction and delimitation of access by role with mandatory two-factor authentication for administrative access; logging operations (audit log) with storage of administrator actions and significant security events; daily automatic database backups with rotation and encryption; security monitoring; employee training; minimum required access policy; protection against automated attacks (rate-limiting on sensitive endpoints: login, registration, password recovery, sending codes); centralized security header (HSTS, CSP, X-Frame-Options, Referrer-Policy, Permissions-Policy).

3.7.1. Compliance with SOC 2 Trust Services Criteria

The technical and organizational controls of the Service are designed in accordance with the SOC 2 criteria (Trust Services Criteria - Security, Availability, Confidentiality) developed by the AICPA. Internal SOC 2 readiness documentation is maintained and available upon request for the purposes of due-diligence of corporate clients and partners; independent audit of a CPA firm (Type I → Type II) is currently in the planning process. The service does not confirm the existence of a valid SOC 2 report until it is issued by an external auditor.

3.7.2. Two-factor authentication (2FA)

The client has the right to independently enable two-factor authentication (TOTP, RFC 6238) through authenticator applications (Google Authenticator, Yandex Key, Authy, etc.). The TOTP secret is generated on the Service side, transmitted to the Client once for registration in his application and then stored solely for checking one-time codes upon login. The service does not transfer TOTP secrets to third parties and does not use them for other purposes. The client can disable 2FA at any time in his personal account by confirming the action with the current code.

3.7.3. Email confirmation

To enter your personal account, the Service may require confirmation of the Client’s email address with a 6-digit numeric code. The code has a limited validity period (15 minutes) and a limited number of entry attempts. Only the hash of the code (SHA-256) and metadata of the attempts are stored; the code itself is not saved. Clients registered before the introduction of this requirement are exempt from the mandatory retroactive email confirmation.

3.8. Client Rights

Within the framework of applicable law, the Client has the right to: receive information about the processing of his data; demand correction of inaccurate data; demand the deletion of data in cases that do not contradict the Service’s storage obligations (in particular, AML/KYC); restrict processing where permitted by applicable law; revoke previously given consent to processing not based on other legal grounds; refuse marketing communications; file a complaint with the competent supervisory authority.

Requests to exercise rights are sent through the Service support service. The service has the right to request additional information to confirm the applicant’s identity.

3.9. Minors

The Service is not intended for persons under 18 years of age. If the Service becomes aware of the collection of data from a minor without proper justification, such data will be deleted within a reasonable time.

3.10. Policy Changes

The Service has the right to update this Policy taking into account changes in legislation, business processes and the infrastructure used. The new edition comes into force from the moment of publication on the Site.

4. Declaration of confirmation of the legality of the origin of funds and cryptocurrency assets

This declaration is accepted by the Client at the time of creation of each Application.

I, an individual or legal entity creating an application on the sitehttps://saikyo.exchange(hereinafter referred to as the “Declarant”), being a legally capable person and/or a duly authorized representative of a legal entity, without being in a state of delusion, deception, threat and/or coercion, I consciously and fully confirm and certify the following:

1. The funds and/or cryptocurrency assets used in the Application were mined, received, acquired through legal, non-criminal means.
2. Cash and/or cryptocurrency assets are my property or the property of a person in whose interests I am duly acting and which is disclosed to the Service.
3. Transactions made by me with funds and/or cryptocurrency assets are carried out consciously and in my own (and/or the person I represent) interests, without pursuing the interests of unknown or unauthorized third parties.
4. I do not act on behalf of or receive instructions from known or unknown third parties to buy or sell cryptocurrency, and I do not receive instructions or information about crypto-wallets to which cryptocurrency must be transferred, and/or from whose accounts cryptocurrency must be debited to complete the transaction.
5. I have a complete and unambiguous understanding of the functionality, use, storage, distribution mechanisms and other characteristics of cryptocurrency, I understand and accept the risks of exchange rate volatility, non-refundability of erroneous transactions and other associated risks.
6. I received a full amount of information about the chosen cryptocurrency to make an informed decision about buying or selling it.
7. I comply with any applicable tax regimes in the jurisdiction of my residence and/or registration, including with regard to the declaration of transactions with digital financial assets.
8. The crypto-wallet to which the cryptocurrency must be transferred or from which it will be debited belongs to me (or a person I represent), and I own, manage and have access to it solely.
9. The funds in the amount specified in the Application are mine (or the person represented)’s own. I dispose, own, use and/or benefit from them for my own purposes and needs, and not acting on behalf of or for the benefit of unauthorized third parties.
10. Cryptocurrency in the amount specified in the Application belongs to me (or the person represented) solely, is used for personal purposes, and was obtained in a legal, non-criminal way.
11. I am not under the influence of third parties. I do not receive and have not received threats from unknown persons, I am not subject to warnings, promises of theft of funds from my bank account or fraudulent activities with my bank account.
12. I understand that if I provide false information, I bear the risk of civil, administrative and/or criminal liability under applicable law, and I undertake to compensate the Service for any losses caused by such actions.

4.1. Confirmation of transmission and receipt. No complaints

The Declarant hereby confirms that the funds and/or cryptocurrency assets used in the Application were sent and/or received by him to the crypto-wallet, bank account or bank card specified in the Application in the proper amount.

The declarant confirmsno complaintsin relation to the transferred or received volumes of funds and/or cryptocurrency assets, the timing of the transfer of cryptocurrency or funds and other material or intangible claims to the Service, and also confirms a clear desire to conclude a transaction for the purchase and sale of cryptocurrency.

5. Cookies Policy

5.1. What are cookies

Cookies are small text files that the Site stores in the Client’s browser when visiting. They allow the Service to save the Client’s preferences, correctly display the interface and analyze the use of the Site.

5.2. Types of cookies used

• Session cookies— are valid only during the working session and are deleted after closing the browser;
• Persistent cookies— saved between sessions to save the Client from repeated authorizations and save preferences;
• Technical cookies— necessary for the operation of the Site (CSRF tokens, authorization tokens, sessions);
• Analytical cookies— collect aggregated usage statistics;
• Cookie IDs— may allow identification of the Client in combination with other information; the processing of such cookies requires consent.

5.3. Client Consent

Technical cookies are used on the basis of the legitimate interest of the Service in ensuring the functionality of the Site and do not require separate consent. Analytical cookies and Cookie Identifiers are used based on the Client’s consent, expressed by clicking the appropriate button in the cookies banner, or by continuing to use the Site after notification.

The Client has the right to withdraw consent at any time by clearing cookies in the browser settings or by clicking the “Refuse Cookies” button in the settings section on the Site (if available).

5.4. Partners

Some cookies may be installed by Service partners (analytical, anti-fraud, infrastructure). Partners may combine the information received with other information collected from other resources for purposes beyond the purposes of the Service. The client consents to such processing unless otherwise expressly stated.

5.5. Cookie storage period

The Service stores Cookie Identifiers no longer than required for processing purposes, or until the Client withdraws consent.

5.6. Transfer of cookies to third jurisdictions

Due to the global nature of the Service's infrastructure, cookies may be transferred to countries outside the Client's jurisdiction, where data protection rules may differ. By accepting this Policy, the Client agrees to such transfer.

5.7. Client Rights

The Client has the right to: receive information about the processing of Cookie Identifiers; request correction or deletion; limit processing; receive data in machine-readable format; file a complaint with the competent supervisory authority.

6. Procedure for depositing and returning funds

This Procedure is applied in conjunction with the User Agreement, AML/KYC Policy and Privacy Policy.

6.1. General provisions

6.1.1.This Procedure defines the rules for the crediting and return of funds and digital financial assets, recalculation of Applications, deduction of commissions and actual costs, as well as the actions of the Service when suspicious transactions, technical errors and inconsistencies in details are identified.

6.1.2.Crediting and refunding are carried out exclusively within the framework of a correctly completed Application, unless otherwise expressly provided for by this Procedure and applicable law.

6.1.3.The Client is obliged to check the direction of exchange, amount, details for transfer, receiving address, network and other essential conditions of the transaction before paying for the Application.The risk of errors in the details made by the Client is borne by the Client in full, unless such errors are caused by a direct technical error of the Service.

6.2. Procedure for crediting funds

6.2.1.Funds are subject to crediting only if the Client has submitted an Application through the Service interface and made a transfer within the validity period of the Application using the details specified by the Service, and also completed the applicable AML/KYC procedures.

6.2.2.For applications for the purchase of DFAs, fiat funds are credited after the actual receipt of funds to the details specified by the Service and confirmation of the possibility of completing the operation.

6.2.3.For applications for the sale of DFAs, processing is carried out after the transaction appears in the corresponding blockchain network and receives the minimum number of confirmations established by the Service for a specific asset.

6.2.4.If funds are receivedafter the Application expires, in an amount different from that specified in the Application, using details not specified by the Service, or without mandatory identifiers, such funds may not be credited automatically and are subject to manual verification.

6.2.5.Funds transferred outside the Application may not be credited until the circumstances are clarified, returned at the Client’s request, or credited at the discretion of the Service if it is possible to reliably establish their ownership and purpose of payment. Deduction for processing such payments is up to 5% of the amount.

6.2.6.The service has the right to request supporting documents from the Client if it is necessary to establish the identity of the payment, the legality of the origin of funds, or compliance with KYC requirements.

6.3. Fixing the exchange rate and recalculating

6.3.1.The exchange rate is fixed in the manner specified in the Agreement and the Application interface. If payment is not received within the prescribed period, the Service has the right to recalculate the Application at the current rate at the time of actual receipt of funds or offer a refund minus commissions.

6.3.2.If the amount of receipt differs from the amount specified in the Application, the Service has the right, at its discretion: to execute the Application within the limits of the actual amount received at the current exchange rate; offer the Client an additional payment; return the excess transferred funds minus mandatory fees and actual costs.

6.3.3.If there is a significant change in the market rate (deviation of more than 3% from the rates of the Bybit, Binance, OKX, Bitget, MEXC, Rapira exchanges), network commission, blockchain network rules, or a technical error that affects the parameters of the Application, the Service has the right to suspend execution, offer recalculation or issue a refund.

6.4. Reasons for return

6.4.1.Refunds are allowed in cases where: the operation cannot be completed for technical reasons; the transfer was received outside the Application or using outdated details; The client refused the transaction until the counter asset was actually sent; Based on the results of the inspection, a decision was made to cancel the operation.

6.4.2.Returnnot produced or may be delayed, if: counter execution has already been completed by the Service; the operation is blocked due to AML/KYC verification; a request from the competent authority has been received; The client did not provide sufficient data to identify the payment or the recipient of the return; the return of such funds is illegal.

6.4.3.Refunds are usually made to the same details from which the payment was received, unless a different procedure is additionally agreed upon by the Service and does not contradict the security requirements and KYC policy.

6.5. Procedure for applying for a return

6.5.1.To process a return, the Client sends a request to the Service support service from the email specified in the Application or through a confirmed communication channel.

6.5.2.The request must indicate: the Application number, the date and amount of the transfer, the sender’s details, the return details, the reason for the request, and, if necessary, documents confirming the ownership of the funds and the identity of the Client.

6.5.3.The service has the right to request additional documents and information if necessary to comply with security requirements, identify the Client, establish the origin of funds, fulfill obligations under AML/CTF and comply with laws on personal data.

6.6. Terms for consideration and execution of returns

6.6.1.The period for consideration of the request begins to be calculated from the moment the Service receives all necessary information and documents.

6.6.2.The standard review period is up to 30 (thirty) calendar days, unless other periods are required for additional verification, interaction with payment systems, banks, blockchain networks or competent authorities.

6.6.3.The actual return period depends on the payment system used, bank, blockchain network and other external payment participants. The Service is not responsible for delays caused by the actions of such persons if the Service itself promptly initiated the return.

6.7. Commissions and deductions

6.7.1.Upon return, the Service has the right to withhold the obligatory commission of the payment system or blockchain network, the actual costs incurred for processing and returning the payment, as well as other commissions expressly provided for in the Agreement.

6.7.2.If a return is made due to a Service error, no additional internal return fee will be charged, with the exception of external mandatory costs.

6.7.3.If the return is carried out at the initiative of the Client after payment of the Application, the Service has the right to retain reasonable and pre-disclosed costs associated with revising the Application, changing the rate, manual processing and reverse transfer.

6.7.4. Approximate deduction amounts:

• for bank transfers - from 0.7% to 2% of the refund amount, plus possible fixed bank fees;
• for transactions with bank cards and acquiring - from 2% to 5%;
• for transactions with electronic wallets and other payment services - from 1% to 5%;
• for transactions with virtual assets - the actual network fee (network fee / gas fee) and, if available, the commission of the transfer provider.

Dimensions are indicative and may be changed by relevant third parties without prior notice to the Service. The final amount is determined based on the actual rates on the return date.

6.8. Suspicious transactions and AML/KYC

6.8.1.If a transaction or assets are suspicious from the point of view of AML/KYC procedures, the Service has the right to temporarily suspend crediting or returning until the verification is completed for up to365 (three hundred sixty-five) calendar days.

6.8.2.To complete the verification, the Service may request an identification document; confirmation of ownership of the payment instrument or wallet; documents on the origin of funds and other materials.

6.8.3.Funds may be temporarily blocked until the verification is completed. Refunds for such transactions are carried out after completion of the verification, unless there are legal grounds for further retention, blocking or transfer of information to the competent authorities.

6.8.4.If there is a mandatory request from a competent authority or there are indications that funds are associated with fraud, theft, sanctions restrictions or other severe risk categories, refunds may be limited or not possible to the extent permitted by applicable law.

6.9. Details and identification of the recipient

6.9.1.The client is obliged to indicate correct and belonging to him details to receive funds. The Service is not responsible for the consequences caused by errors in the details if such errors are not related to the actions of the Service.

6.9.2.Changing the recipient's details after completing the Application is permitted only upon the Client's request through a confirmed communication channel and after passing additional verification.

6.9.3.The service has the right to refuse to change the details if there are reasonable doubts as to whether the new details belong to the Client or if the change violates security and AML/KYC requirements.

6.10. Final provisions

6.10.1.This Procedure is an integral part of the User Agreement and is subject to application in conjunction with other documents of the Service.

6.10.2.On issues not regulated by this Procedure, the Service and the Client are guided by the User Agreement, AML/KYC Policy, Privacy Policy and applicable laws.

7. Regulations on the procedure for carrying out activities related to transactions with virtual assets

These Regulations determine the procedure for interaction between the Client and the Service when making transactions with virtual assets. Using the Site means unconditional adherence to the Regulations in full.

7.1. General provisions

7.1.1.The Service provides the Client with the opportunity to make the following types of transactions with virtual assets through the Website interface:

• purchase of virtual assets for fiat currency, electronic money, including international electronic money;
• sale of virtual assets for fiat currency, electronic money, including international electronic money;
• exchange of virtual assets of one type for virtual assets of another type.

7.1.2.Technological execution of exchange operations is provided by a licensed virtual asset exchange operator -Coin Market LLC(Kyrgyz Republic, Bishkek), operating on the basis of a license issued by the authorized body of the Kyrgyz Republic, through the platformhttps://coinmarket.kg/.

7.1.3.The Service places the exchange operator widget on the Site on the basis of the License Agreement and provides End Users with access to virtual asset exchange services in accordance with applicable law.

7.1.4.By accepting these Regulations, the Client, in accordance with Article 387 of the Civil Code of the Kyrgyz Republic, fully and unconditionally accedes to it and undertakes to comply with its provisions from the moment of making the first Application.

7.2. Terms and definitions

Virtual asset- a set of data in electronic digital form that has a value, which is a digital expression of value and/or a means of certifying property and/or non-property rights, which is created, stored and circulated using distributed registry technology or similar technology and is not a monetary unit (currency), a means of payment and a security (for example, BTC, ETH, USDT, etc.).

Virtual asset wallet— a software application or other mechanism/media for storing and transferring a virtual asset.

Application— the Client’s offer sent to the Service through the Website interface to buy or sell virtual assets for money or exchange virtual assets of one type for virtual assets of another type.

Account- a record registered by the Client on the Site, through which the Client’s identity is associated with his transactions. Access is provided after passing the identification procedure (KYC) based on login and password.

Countercurrency of the transaction— the asset against which the transaction asset is delivered.

Payment details— complete and unambiguous payment instructions sent by the Parties to each other when concluding a transaction.

Transaction— an exchange operation initiated by the Client through a widget on the Site and executed by a licensed exchange operator.

7.3. Procedure for concluding transactions

7.3.1.The conditions of each transaction are determined individually by the Client submitting an Application through the Website interface.

7.3.2.When submitting an Application, the following basic conditions are determined:

• currency, direction of exchange, amount of currency and counter-currency of the transaction;
• exchange rate at the time of creation of the Application;
• the amount of commission of the Service and the operating partner;
• details for non-cash payment (for fiat currency);
• virtual asset wallet details (for a virtual asset);
• special conditions (if applicable).

7.3.3.The rights and obligations of the Parties to the transaction arise from the moment the basic conditions of the Application are confirmed and the Service receives funds from the Client.

7.3.4.The transaction is considered completed from the moment of proper fulfillment by the Parties of all accepted obligations.

7.3.5.The parties do not have the right to refuse, in whole or in part, from the execution of an already concluded transaction unilaterally, unless otherwise expressly provided for in these Regulations.

7.4. Transaction deadline

7.4.1.The transaction period depends on the payment method chosen by the Client and is:

• up to3 (three) working dayswhen paying by bank card (MIR, SBP);
• up to3 (three) working dayswhen paying by bank transfer;
• from a few minutes to 24 hours - when paying with a virtual asset, depending on the number of confirmations in the blockchain network.

7.4.2.The Service undertakes to execute the transaction within the specified time frame from the moment of receipt of the corresponding amount, except in cases where execution within this period is impossible due to external circumstances beyond the control of the Service. In this case, the Service has the right to extend the execution period by notifying the Client.

7.5. Sending virtual assets

7.5.1.The Client undertakes to send the Virtual Asset to carry out transactionsonly after receiving the Wallet address from the Servicewithin the framework of a specific Application.

7.5.2.For violation of this obligation, including for sending a Virtual Asset to an inconsistent Wallet address, the Service has the right to recover from the Clientfine of 20% (twenty percent)from the amount of the Virtual Asset received to an inconsistent address.

7.5.3.The client bears full responsibility for the correctness of the network, address and other transfer parameters. It is technically impossible to return assets sent to the wrong address or network.

7.6. Transaction confirmation

7.6.1.Confirmation of the transaction is recorded in the Client’s personal account and sent to the e-mail specified during registration.

7.6.2.Electronic confirmations transmitted through the Site interface or e-mail are recognized by the Parties as the same legal documents as originals signed by authorized persons, and can be used as evidence in resolving disputes.

7.6.3.All electronic data, including Transaction data and Wallet status, have the same evidentiary value as paper documents.

7.7. Messaging methods

7.7.1.The parties choose the following methods of exchanging messages (reports, notifications and other messages within the framework of the Regulations):

• transmission of messages through the Platform (Site);
• transmission of messages via email specified in the Client’s account, without using an electronic digital signature;
• transmission of messages via the Service support Telegram channel.

7.8. Calculations and exchange rates

7.8.1.Settlements between the Parties are carried out in accordance with the terms of the Application.

7.8.2.The exchange rate is determined based on quotes from leading cryptocurrency exchanges (Bybit, Binance, OKX, Bitget, MEXC, Rapira) and the platform of the operating partnerhttps://coinmarket.kg/, valid at the time of the transaction.

7.8.3.The applicable exchange rate does not include Service fees or other fees charged for completing a transaction. The applicable exchange rate is displayed to the Client prior to the commencement of the transaction.

7.9. Validity period of the Regulations

7.9.1.These Regulations come into force from the moment the Client creates an account and is valid for 1 (one) year. If neither Party notifies the other of its intention to terminate the relationship at least 15 calendar days before the expiration date, the Regulations are considered extended under the same conditions and for the same period.

7.9.2.The Regulations are terminated:

• after the entry into force of a new regulation repealing the current one;
• after changes have been made to the applicable legislation that prevent further implementation of the Regulations;
• by decision of one of the Parties 10 calendar days after receipt by the other Party of written notice, subject to full fulfillment of all obligations under already completed transactions.

7.10. Applicable Law and Dispute Resolution

7.10.1.In terms of virtual asset exchange operations, relations are regulated by the legislation of the Kyrgyz Republic, including the Law of the Kyrgyz Republic “On Virtual Assets” and by-laws of the Cabinet of Ministers of the Kyrgyz Republic.

7.10.2.All disputes arising from these Regulations are subject to pre-trial settlement. If it is impossible to resolve the dispute, the dispute shall be subject to consideration in the International Commercial Arbitration Court at the Chamber of Commerce and Industry of the Kyrgyz Republic or in another competent jurisdiction agreed upon by the Parties.

8. Declaration of risks of working with virtual assets

This Declaration is accepted by the Client at the time of creation of each Application and is an integral part of the User Agreement and Regulations.

8.1. The nature of virtual assets

8.1.1.The Client understands and confirms that virtual assets (including, but not limited to BTC, ETH, USDT, BNB, TON, TRX and others)are not a means of payment, are not backed by the government and are not recognized as legal tender in most jurisdictions.

8.1.2.The object of the transaction planned to be carried out by the Service is both secured and unsecured virtual assets. Secured stablecoins (USDT, USDC and others) may lose their fiat currency peg in the event of issuer default, regulatory action or other force majeure.

8.2. Financial risks

8.2.1.The Client understands and accepts the following financial risks:

1. Volatility risk.The value of virtual assets can change dramatically and significantly over short periods of time. The client may lose part or all of the value of the purchased assets as a result of market fluctuations.
2. Liquidity risk.In certain periods, the Client may be unable to sell a virtual asset at an acceptable price or may not be able to find a counterparty at all.
3. Risk of complete loss of funds.The acquisition of virtual assets may result incomplete loss of fundsand other objects of civil rights (investments) transferred in exchange for virtual assets.
4. Risk of investment losses.Virtual assets are not a guaranteed income instrument. Any profitability expectations are subjective and are not confirmed by the Service.

8.3. Technical and operational risks

8.3.1.The Client understands and accepts the following technical risks:

1. Technical failures of blockchain networks— confirmation delays, temporary network unavailability, forks, chain reorganizations, protocol changes.
2. Errors in addresses and networks.Virtual assets sent to the wrong address or on the wrong networkcannot be restored. Refunds of such funds are technically impossible.
3. Risk of losing private keys.Losing the private key to the Wallet means permanent loss of access to assets.
4. Risk of asset theftas a result of phishing attacks, hacking of Client devices, compromise of private keys, and the use of malware.
5. Technical failures of the Service and/or partner operator— temporary unavailability of the Site, widget errors, delays in the execution of Applications.

8.4. Regulatory and legal risks

8.4.1.The client accepts the following risks:

1. Changes in Applicable Lawin any jurisdiction, including the introduction of prohibitions or restrictions on the circulation of virtual assets.
2. Introduction of new tax obligations, reporting and identification requirements.
3. Application of sanctions regimes, as a result of which individual addresses, services or assets may become unavailable or subject to freezing.
4. Regulators' decisionson the suspension or termination of the activities of individual platforms, exchanges, and stablecoin issuers.
5. Risk of the transaction being declared invalidas a result of anti-money laundering measures.

8.5. Risks of illegal actions of third parties

8.5.1.The Client understands that virtual assets are an object of interest for cybercriminals. Possible:

• phishing attacks on the Client;
• social engineering, deception, fraud, including attempts to convince the Client to transfer assets under the pretext of investments, helping relatives, etc.;
• theft of private keys and seed phrases;
• compromise of exchanges, wallets, exchange services;
• 51% attacks, double-spending in small blockchain networks.

8.6. Client Confirmation

8.6.1.By creating an Application on the Site, the Client confirms that:

1. he is familiar with this Risk Declaration in full;
2. understands all these risks and accepts them in full;
3. understands that the Service does not compensate for losses associated with the implementation of these risks;
4. independently assessed his financial ability to participate in transactions with virtual assets;
5. is not influenced by third parties and acts consciously in its own interests;
6. has not received and does not follow instructions from unknown persons to buy/sell virtual assets.

8.7. Release of the Service from liability

8.7.1.The service under no circumstances is responsible for jumps, falls or other changes in the market value and/or estimated value of virtual assets. Any risks associated with such volatility are borne solely by the Client.

8.7.2.The service does not provide investment recommendations, does not guarantee profitability and is not responsible for the financial results of the Client’s operations.

9. List of permitted and prohibited jurisdictions

This list defines the list of jurisdictions in which the Service is entitled or not entitled to provide services. The list may be changed unilaterally without prior notice.

9.1. Completely prohibited jurisdictions

9.1.1.The service certainly does not provide services to citizens, residents, or persons physically located in the following jurisdictions:

• United States of America (including all states and territories);
• Democratic People's Republic of Korea (DPRK);
• Islamic Republic of Iran;
• Syrian Arab Republic;
• Republic of Cuba;
• Bolivarian Republic of Venezuela;
• Republic of Yemen;
• Republic of the Union of Myanmar;
• Islamic Emirate of Afghanistan;
• Republic of Somalia;
• Republic of South Sudan;
• Republic of Sudan;
• Republic of Belarus - for certain categories of operations under the EU/UK sanctions regimes;
• The occupied territories of Crimea, DPR, LPR, Zaporozhye and Kherson regions - in accordance with the sanctions regimes of the EU, USA and Great Britain.

9.2. Restricted Jurisdictions

9.2.1.The Services are provided with restrictions (extended KYC, amount limits, additional documents) to citizens and residents of the following jurisdictions:

• states and territories classified by FATF as jurisdictions with serious AML/CTF deficiencies (FATF black/grey list);
• states subject to restrictive measures of the UN Security Council;
• states with a high level of corruption according to Transparency International CPI (below 30 points);
• states that do not have a recognized system for regulating virtual assets.

9.3. Permitted jurisdictions

9.3.1.The Services are available to citizens and residents of all other jurisdictions that are not subject to the restrictions specified in paragraphs. 9.1 and 9.2, subject to successful completion of the KYC/AML procedures.

9.4. Categories of persons who are denied service

9.4.1.Regardless of jurisdiction, the Service does not provide the following services:

• persons included in any sanctions lists (SDN List OFAC, EU, UK, Canada, Japan, Australia, Switzerland, UN, Rosfinmonitoring);
• politically exposed persons (PEP), their close relatives and affiliates - without conducting an extended KYC check and approval of the compliance service;
• persons who previously refused to undergo KYC or provided false information;
• persons against whom there is reasonable suspicion of illegal activity;
• minors (under 18 years of age);
• persons with confirmed signs of social engineering and fraud (including those acting under the influence of third parties).

9.5. Self-declaration of the Client

9.5.1.By accepting the terms of the Service, the Client guarantees that he does not fall into any of the categories specified in paragraphs. 9.1, 9.2 (without approval) and 9.4 of this section. Indication of false information regarding jurisdiction and status is an independent basis for refusal of service, unconditional blocking of funds, account and transfer of materials to the competent authorities.

9.6. Changing the list

9.6.1.The list of permitted and prohibited jurisdictions can be changed by the Service unilaterally in the event of the introduction of new sanctions regimes, changes in FATF recommendations, changes in the internal policy of the Service or the requirements of the exchange operator partner. Changes come into force from the moment of publication on the Site.

10. Tariffs and commissions

This section defines the tariffs, commissions and other charges applied when using the services of the Service.

10.1. Commission composition

10.1.1.When making a transaction, the following is withheld from the Client:

• Service commission— in the form of a marketing margin included in the exchange rate;
• Commission remuneration of the exchange operator partner— for transaction processing through the widget;
• Blockchain Network Commission(network fee / gas fee) - actual, in full;
• Commissions of banks and payment systems- actual, in full;
• AML provider fees— if an extended check is required.

10.2. Commission amount

10.2.1.When paying for a transaction with a MIR bank card or through the Fast Payment System (FPS):

• 2% (two percent) of the transaction amount— commission of the operating partner when paying through the widget;
• 0.5% (zero point five percent) of the amount of each transaction— processing fee.

10.2.2.When paying by bank transfer, rates are determined individually based on the results of a compliance check and are recorded in the application confirmation.

10.2.3.When exchanging virtual assets of one type for another, a marketing margin is applied, the amount of which is published in the Website interface at the time of creating the Application.

10.3. Chargeback limit

10.3.1.The acceptable level of chargebacks shall not exceed a specified percentage of the Client's total monthly transaction volume.

10.3.2.If the volume of chargebacks exceeds the specified level, the amount of the commission increases by1% (one percent)during the current calendar month. The increased rate applies only in the month in which the limit was exceeded.

10.4. Exchange rate

10.4.1.The exchange rate is determined based on quotes from leading cryptocurrency exchanges (Bybit, Binance, OKX, Bitget, MEXC, Rapira) and the platform of the operating partner valid at the time of the transaction.

10.4.2.The applicable exchange rate is displayed to the Client prior to the commencement of the transaction and does not include commissions or other charges.

10.4.3.If there is a significant change in the market rate (deviation of more than 3% from the weighted average exchange rate), the Service has the right to recalculate the Application at the current rate.

10.5. Transaction deadlines

10.5.1.The deadlines for execution of transactions are established in section 7.4 of the Regulations. The service undertakes to make all reasonable efforts to process applications in a timely manner, but does not guarantee the exact execution time, since it depends on external factors (banks, blockchain networks, AML providers).

10.5.2.If the transaction is not executed within the established time frame and the exchange operation has not been started (as confirmed by the absence of a corresponding entry in the Blockchain), the transaction is canceled and the funds are returned to the Client in the manner provided for in Section 6.

10.6. Tariff changes

10.6.1.The service has the right to unilaterally change tariffs, limits, the list of available exchange directions and other conditions without prior notice to the Client. New tariffs come into force from the moment of publication on the Site.

11. Prohibited actions of the Client

This section defines the list of actions that the Client is prohibited from performing when using the Services. Violation of any of the provisions of this section is a violation of the essential terms of the User Agreement and Regulations and entails unconditional blocking of funds, account and transfer of materials to the competent authorities.

11.1. Prohibition of violation of the law

11.1.1.The client is prohibited from:

1. violate or assist third parties in violating laws, regulations, decrees, orders, sanctions regimes or rules of self-regulatory organizations of which the Client is already or should become a member;
2. use the Site, Platform or Services in any way that is illegal or fraudulent, pursues illegal or fraudulent purposes or entails such consequences;
3. use the Services to evade taxes locally or internationally or facilitate such evasion;
4. participate in a transaction involving the receipt of illegal income or carried out for the purpose of concealing illegal activities;
5. facilitate, commit, support or participate in illegal or suspicious transactions leading to violation of the legislation of the Kyrgyz Republic, the Russian Federation or other territory where services are provided.

11.2. Prohibition of financial crimes

11.2.1.Operations related to:

1. financing of terrorism, extremism and the proliferation of weapons of mass destruction;
2. laundering of proceeds from crime (legalization) in any form;
3. drug trafficking and illicit trafficking in psychotropic substances;
4. trade in weapons, ammunition, military equipment and dual-use goods bypassing sanctions regimes;
5. human trafficking, labor exploitation, sexual exploitation;
6. cybercrimes (ransomware, phishing, carding, sale of stolen credentials, exploits);
7. illegal gambling, illegal bookmaking operations, illegal lotteries;
8. theft of funds from crypto exchanges, DeFi protocols, third party wallets;
9. fraud, including investment fraud, romance scams, Ponzi schemes, fake ICOs, rug-pull schemes;
10. illegal pornography, including those involving minors.

11.3. Prohibition of actions against the Service

11.3.1.The client is prohibited from:

1. mislead or attempt to mislead the Service, operating partner, End Users or other third parties;
2. provide the Service or End Users with false, inaccurate or misleading information;
3. take actions that create an unreasonable or excessively large load on the Service infrastructure;
4. interfere with the access of another individual or legal entity to the services of the Service;
5. distort information about the activities and services of the Service or otherwise damage the business reputation of the Service;
6. publish, distribute or transmit any illegal materials or information on the Service;
7. transmit or upload any software code or file that contains any malware, viruses, Trojan horses, worms or other harmful or harmful programs;
8. attempt to gain unauthorized access to the Site, its computer systems or networks connected to the Site and the Service servers.

11.4. Prohibition of intellectual property infringement

11.4.1.The Client is prohibited from violating copyrights and related rights, patents, trademarks, as well as other protected intellectual property rights of the Service, operating partner or third parties, including:

1. copy, change, decompile, disassemble, modify any content of the Site without the written consent of the Service;
2. use trademarks, logos, brand names of the Service for your own purposes without consent;
3. create derivative products based on the technology and content of the Service.

11.5. Prohibition of violation of confidentiality

11.5.1.The client is prohibited from:

1. without appropriate consent, transfer or disclose personal data, confidential or other information received from the Service and not publicly available;
2. publicly disclose or disclose personal data of End Users, support operators, partners;
3. use personal data of third parties without legal grounds.

11.6. Prohibition of intermediation and resale

11.6.1.The client is prohibited from:

1. act as a payment intermediary, payment aggregator, cash-out structure;
2. resell, distribute, sublicense the services of the Service to third parties without the express written permission of the Service;
3. transfer or assign any rights granted hereunder without the consent of the Service;
4. use the services of the Service to carry out transactions in the interests of third parties that are not disclosed to the Service in accordance with the KYC procedure.

11.7. Prohibition of discrimination and violence

11.7.1.The client is prohibited from:

1. encourage violence, discrimination on any basis (racial, national, religious, sexual, political);
2. use the Services to finance or support extremist movements and organizations;
3. distribute hateful content.

11.8. Prohibition of destructive financial transactions

11.8.1.The client is prohibited from:

1. deposit, transfer or withdraw funds or assets, including offering financial instruments used for speculative purposes for the purpose of market manipulation;
2. carry out wash-trading and other manipulations in the cryptocurrency markets through the Service infrastructure;
3. use the Services to finance high-risk investment schemes, including HYIPs, promising guaranteed returns.

11.9. Consequences of violation

11.9.1.Violation by the Client of any of the provisions of this section is considered a violation of the essential terms of the User Agreement and the Regulations and entails the following consequences:

• unconditional blocking of all funds and assets of the Client;
• refusal to execute an application and non-refund of funds in cases where the return of such funds is illegal;
• blocking, suspending or freezing the execution of transactions;
• blocking the Client's account without the right to restore;
• transfer of information about the Client, his operations, IP addresses, devices and behavioral data to competent authorities and partner AML services;
• reimbursement by the Client of all losses, fines and expenses incurred by the Service or the operating partner in connection with the violation.

12. Omega Wallet: license and regulation

12.1.Omega Wallet is a payment service (electronic wallet, cards, QR payment) provided to Clients under the Omega Wallet brand based on the Altyn Wallet Service. Participants of the Service: Provider - Limited Liability Company "Wallet Altyn" (LLC "Wallet Altyn"), and servicing credit organization - Settlement Non-Bank Credit Organization "ALTYN" (Limited Liability Company), abbreviated as RNKO "ALTYN" (LLC); previous name - RNKO "Ochamchira" (LLC). The service operates on the basis of the Rules of the Altyn Wallet Service, approved by the Board of the RNKO ALTYN (LLC) (Minutes No. 07-20/2026P dated 07/20/2026) and by order of the General Director of Altyn Wallet LLC No. 7 dated 07/20/2026.

12.2.Service Provider: Altyn Wallet LLC. Legal and postal address: 384820, Republic of Abkhazia, Ochamchira, st. B. Shinkuba, 63. OGRN 124RA001030, INN 11031680, KPP 111003316. E-mail:support@altyn.one, website:altyn.one, support on Telegram: Altyn support at altyn.one. Tariffs and limits of the Service are published in the User’s personal account and in the “Altyn Wallet” mobile application.

12.3.Servicing credit organization: RNKO "ALTYN" (LLC). Location: 384900, Republic of Abkhazia, Sukhum, st. Generala Arshba, 38. Registration number 111RA000651, INN/KPP 11004691/611000107, correspondent account No. 30103810000000000002 in the Bank of Abkhazia, BIC 222400005. Telephone: +7 (840) 222-71-11, email. mail:info@ochamchyra.com. License of the National Bank of the Republic of Abkhazia to carry out banking operations for a settlement non-bank credit organization with funds in rubles and foreign currency No. 005 dated 07/15/2026 (initial issue 05/11/2011); information published by the National Bank of the Republic of Abkhazia:nb-ra.org/rnko-altyn.

12.4.Transfers of funds and other banking operations in Omega Wallet (opening and maintaining accounts, transfers without opening a bank account, issuing MIR cards and international Visa cards, payment via QR, conversion) are performed by RNKO "ALTYN" (LLC); Access to services through a personal account and mobile application is provided by the Provider LLC “Wallet Altyn”, which also acts as a bank payment agent, in accordance with the legislation of the Republic of Abkhazia and regulations of the Bank of Abkhazia. The Omega Wallet service acts as an information partner and agent for attracting Clients, is not a credit institution and does not store Clients’ funds placed in Omega Wallet.

12.5.Replenishment of Omega Wallet is allowed only from the Client’s own bank details (the “one’s own” principle); identification of the Client is carried out using a passport according to the rules of the Altyn Wallet Service. Terms of service, tariffs, limits and procedure for consideration of claims (claims are accepted by the Provider in writing within 30 calendar days from the date of the event and are considered within 30 working days) are determined by the Rules of the Altyn Wallet Service, the Service Use Agreement between the User and the Provider and the agreement with RNKO ALTYN (LLC).