1.1. The User Agreement applies to all legal relationships between the User and the Virtual Currency Service Provider (if applicable according to the terms) and between the User and the Payment Service Provider.

1.2. Each of the following legal entity shall be named hereinafter as the Service Provider and services provided by Service Provider as Services:

Name of the Company: Pay Integration, UAB
Company number: 306115286
Legal form: Private Limitited Company
Registered office address: Eišiškių Sodų 18-oji g. 11, LT-02194 Vilnius, Republic of Lithuania
Address of electronic delivery box: 306115286
Date of registration: 13-07-2022

1.3. The each clause of this User Agreement shall be applied mutatis mutandis for the Payment Service Provider and the Virtual Currency Service Provider considering the circumstances, that each of them offers only part of the Services provided by the Platform and that depending on the User's place of residence or their seat the Services may be offered by different legal entities.

1.4. By the services (hereinafter – the Services) is meant a proposal an environment for the User and considering this, providing ability to use the Virtual Currency Service and the Payment Service:

1.5. The Virtual Currency Service includes the following:

• 1.5.1. virtual currency wallet service, which means a service in the framework of which keys are generated for User and User's encrypted keys are kept, which can be used for the purpose of keeping, storing and transferring virtual currencies;
• 1.5.2. The Platform provides the Virtual Currency Service (crypto e-wallet and crypto exchange services) related to virtual currencies BTC, USDT, USDC, ETH, LTC, TRX. Company can extended list with other currencies in future.

1.6. For EEA country users the Virtual Currency Service is provided by Virtual Currency Service Provider.

1.7. For non-EEA country users the Virtual Currency Service is provided by Payment Service Provider.

1.8. The Payment Service means a service in the framework of which account opened for the User. The User's currency held on the opened account and the User has the opportunity to execute payment transactions, including transfer of their currency to another payment account(s) opened with the Payment Service Provider, to receive currency from another payment account(s) opened with the Payment Service Provider and to withdraw currency to the User's bank account or to withdraw currency using another method provided by the Payment Service Provider (e. g. to the payment account(s) opened with another payment service provider), exchange service, which means a service with the help of which a User exchanges a virtual currency against a fiat currency or a fiat currency against a virtual currency or a virtual currency against another virtual currency.

• 1.8.1. The Payment Service is provided only by the Payment Service Provider.
• 1.8.2. The Platform provides the Payment Services and Money transfers beetwen user accounts, related to the following currencies EUR, USD and available crypto currencies.

1.9. The virtual currency means a value represented in the digital form, which is digitally transferable, preservable or tradable and which natural persons or legal persons accept as a payment instrument, but that is not the legal tender of any country or funds for the purposes of Article 4(25) of Directive (EU) 2015/2366 of the European Parliament and of the Council on payment services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/36/EU and Regulation (EU) No 1093/2010, and repealing Directive 2007/64/EC (OJ L 337, 23.12.2015, pp 35–127) or a payment transaction for the purposes of points (k) and (l) of Article 3 of the same Directive.

1.10. In addition to the User Agreement, relations between the User and the Service Provider are governed by the valid legislation of the Republic of Lithuania, the Service Provider's Privacy Policy, the Service Provider's price list (hereinafter – the Price List) for the use of respective service, detailed terms and conditions of the service, if User informed about them, instructive texts and established good practices.

1.11. If any of the User Agreement's provisions in conflict with the provisions of the law and thus invalid does not generally affect the validity of other provisions of the User Agreement.

1.12. All information exchange and communication between the User and the Service Provider exceeds in English unless another language is in use by agreement between the User and the Service Provider.

The User account

2.1. In order to use the Platform, the User is required to register a user account on their name (hereinafter – the User Account).

2.2. Upon registering the User Account, a person enters their contact information and other data requested by the Service Provider into the respective environment and selects a unique ID and password.

2.3. The Service Provider shall have the right to limit the rights of certain groups of users in terms of specific usage rights, including limiting access and/or usage rights with respect to certain parts of the Platform or the Services.

2.4. In order to enter the Platform, the User is required to enter their ID and password. Payment service providers and other the Service Provider's partners (including virtual currency exchange service providers, payment service providers etc.) may set additional requirements for using the third party’s services provided on the Platform.

2.5. After registering the User Account, the User has an opportunity to execute transactions through the Platform by the User or the legal person represented by the User.

2.6. The person to whose name the User Account has been registered (the User) shall be responsible for the rights and obligations related to the User Account. Among other things, the User shall be a party of the transactions made through the User Account.

2.7. The User Account shall reflect:

• 2.7.1. the User's personal data;
• 2.7.2. payment accounts belonging to the User and the amount of funds disposed on these accounts;
• 2.7.3. virtual currency wallets' address(es), which is(are) opened on the name of the User and the amounts of virtual currency disposed on the wallets opened on the name of the User;
• 2.7.4. information about transactions, which were made using the payment accounts and virtual currency wallets opened on the name of the User;
• 2.7.5. information about service fees and other payments made by the User to the Service Provider.

Entry into the User Agreement

2.8. To ensure reliable operation of the financial sector and the transparency of the business environment, the Service Provider limits the circle of persons with whom it enters into the User Agreement.

2.9. The Service Provider shall have the right to decide with whom to enter or not to enter into the User Agreement (Freedom of Contract). The Service Provider shall conclude the User Agreement, if entity which intends to become the User meets the Conditions of the Service Provider and submits the Service Provider the data and documents requested by the Service Provider. Before the Service Provider refuses to enter into the User Agreement, it shall thoroughly consider all the circumstances.

2.10. The Service Provider may refuse to conclude the User Agreement with a good reason, which first and foremost constitutes an agreement where entity which intends to become the User or a Connected person1:

• 2.10.1. has intentionally or due to severe negligence submitted the Service Provider incorrect/insufficient data or documents or refuses to submit requested by the Service Provider data or documents;
• 2.10.2. does not submit sufficient data or documents requested by the Service Provider for entity’s, it’s representative, actual beneficiary or for a partner’s identification or data or documents don’t meet the requirements of the Service Provider;
• 2.10.3. has caused direct or indirect damage to the Service Provider or a threat of actual damage or has caused damage to the reputation of the Service Provider;
• 2.10.4. does not submit sufficient data or documents related to the entity or to the partners, requested by the Service Provider for the certification of the legality of their funds or there are any other grounds for suspecting them of money laundering (incl. using a front person) or terrorism financing;
• 2.10.5. is personally or its partners are connected, or has been connected, to organised crime, money laundering, terrorism financing or evasion of taxes, also to international sanctions or other national transaction limits (e.g. sanctions of the European Union or the USA) according to the information of acknowledged and reliable sources (e.g. state bodies, international organizations, international or national databases, correspondent banks, and mass media);
• 2.10.6. is personally or its partners are connected, or has been connected, to the traditional income sources of organised crime, incl. illicit traffic of excise goods or narcotic substances, illegal trafficking of arms or persons, mediation of prostitution, unlicensed international transmission of money;
• 2.10.7. comes from a country that has insufficient levels for preventing corruption / money laundering / terrorism financing;
• 2.10.8. is, in the opinion of the Service Provider, personally or its Connected person engaged in the field of activity with a high level of risk of money laundering and terrorism financing (incl. but not limited to providers of services of alternative payment instruments, intermediaries of such payment instruments, internet casinos) or they operate without the required registration or authorisation;
• 2.10.9. is according to the Service Provider’s estimates related to the territory, area of activity, transaction or person subject to Sanctions or other national transaction limits (e.g. sanctions of the European Union or the USA);
• 2.10.10. has, according to a decision made by a competent authority or body (e.g. a precept by an agency, a court order) or judging by another event or fact, through its acts or omissions undermined the reputation of persons working in the same area of activity (incl. the Service Provider), or, according to a reasoned opinion of the Service Provider, does not behave in a responsible manner and does not follow the requirement of due diligence and the customs expected of companies working in this area of activity.

2.11. The Service Provider also refuses to enter into the User Agreement with other good reason, especially if the conclusion of the User Agreement is impeded by a legal hindrance such as restricted active legal capacity and contradictions or absence of the right of representation, and the Service Provider has not been provided the necessary data and documents in order to meet its Know Your Customer principles.

Requirements for documents and data, provided by the User

2.12. The User or their representative shall submit the data and documents requested by the Service Provider for identification of the User.

2.13. A natural person shall be identified on the basis of personal identification documents that comply with legislation and accepted by the Service Provider.

2.14. A legal person shall be identified on the basis of a valid extract from the register and/or the documents accepted by the Service Provider.

2.15. The User or their representative may be identified through a means of communication accepted by the Service Provider.

2.16. The User shall present to the Service Provider the original documents or their copies if they are notarized or equally certified.

2.17. The Service Provider shall assume that the document presented by the User is authentic, valid, and correct.

2.18. The Service Provider may require that documents issued abroad be legalized or certified with an apostille.

2.19. If documents are in a foreign language, the Service Provider may require that the documents be translated into the language understandable for the Service Provider. The Service Provider may require that the translation must be notarized or certified by a sworn translator.

2.20. The User shall bear the costs concerning the formalization, translation, certification of the documents and other related costs and they don’t subject to reimbursement by the Service Provider.

2.21. The Service Provider may make a copy of the document submitted by the User or retain the original document, if possible.

2.22. If the submitted document does not meet the requirements of the Service Provider or the Service Provider has doubts concerning its correctness, the Service Provider shall have the right not to execute the User’s order or require the submission of additional documents.

Following the Know Your Customer principles

2.23. The Service Provider shall apply measures for the prevention of money laundering, terrorism financing, and tax evasion, as well as the measures of the application of international financial sanctions. Therefore, the Service Provider must have an overview of the User, the persons considered as Connected persons, and also the User’s activities (incl. economic activities) and the origin of the assets of the User (Know Your Customer principle).

2.24. Based on the abovementioned considerations, the Service Provider shall have the right and obligation to:

• 2.24.1. check the identification information of the User or the representative of the User on a regular basis and receive additional documents and data (incl. citizenship, tax residence, place of residence, owners of the legal person, actual beneficiaries, founders and members of the management board) from the User;
• 2.24.2. regularly ask for documents and data regarding the activities of the User, incl. data regarding the Connected persons, turnover, international payments, as well as data regarding the purpose and essence of transactions and the legal origin of the assets or of the assets used in transactions;
• 2.24.3. ask the documents constituting the basis for the transactions from the User (e.g. sales, lease and supply agreements, documents related to the goods etc.), and also data or documents regarding the counterparty, actual beneficiary of the transaction or any other person involved in or related to the transaction;
• 2.24.4. monitor how the User uses the Services;
• 2.24.5. establish temporary or permanent restrictions on the use of the Services.

2.25. The Service Provider shall have the right not to execute the User’s order if the User does not submit data or documents specified in clauses 2.24.1– 2.24.3 of the User Agreement to the Service Provider.

2.26. While applying the measures for the prevention of money laundering and terrorism financing the Service Provider shall use risk-based methods and select the suitable and appropriate extent of the measures, proceeding from the nature of the transactions, as well as the assessment regarding the amount of risk that the User or any other person related to the transaction is engaged or may commence money laundering or terrorism financing.

3.1. The Service Provider shall forward information to the User through its place of business, its website, through the Platform or by any other agreed manner. The Service Provider shall send personal notices to the User by a means of communication (e.g. by post, email, mobile phone including text messages) or through an electronic channel of the Service Provider (e.g. notifications on the Platform)

3.2. Upon submitting to the Service Provider the User’s contact details (e.g. postal address, email, phone number) the User agrees to receive any information from the Service Provider via abovementioned contact including details about the amendment of the User Agreement which regulate relations with the User and the User’s private data.

3.3. Communication between the User and the Service Provider, the Service Provider’s explanations regarding the User Agreement, and/or news, articles, information letters, etc. forwarded by the Service Provider shall not constitute investment consultations, or advice, an offer or recommendation to conduct a transaction.

3.4. Personal notices sent to the User by the Service Provider shall be considered as received by the User when the period usually necessary for sending a notice through the corresponding means of communication has passed as of sending the notice to the User’s contact details. A personal notice sent through an electronic channel shall be considered as received on the day it was sent. A notice given by email or SMS shall be considered as received on the day it was sent.

3.5. The User receives information about the Services from the User Agreement, the Service Provider’s employee or the Platform's website.

3.6. The User shall forward information to the Service Provider on paper, electronically (e.g. through the Platform functional, by email) or in another agreed manner.

3.7. If the User has not received a notice from the Service Provider, the receipt of which they could anticipate, the User shall notify the Service Provider immediately if the deadline during which one could expect receipt of the notification has passed.

3.8. The User shall immediately verify the correctness of the information included in the notice received from the Service Provider and lodge his or her objections to the Service Provider immediately after receipt of the notice.

3.9. The User shall immediately notify the Service Provider of any and all data and circumstances that have changed compared to the data submitted to the Service Provider earlier (e.g. changes in personal or contact details, residence, or the right of representation; or reorganization proceedings), as well as of any and all circumstances that may affect the performance of the User’s obligations before the Service Provider (e.g. merger, division, bankruptcy, execution or liquidation proceedings). The User shall provide a document certifying the amendment upon the Service Provider’s demand.

3.10. The User shall immediately notify the Service Provider of the loss, theft of their personal identification document or another means of identification or security element or loss of possession thereof against their will in any other manner (e.g. loss of user ID, password or any other methods of authentication)

3.11. The Service Provider shall assume the correctness of the User’s data at the Service Provider’s disposal, even if the User has failed to fulfil the information submission obligation.

4.1. When registering the User Account, the Payment Service Provider creates accounts on the name of the User (hereinafter – the User Payment Account).

4.2. The User Payment Account shall be created only for the currencies, which are applicable in accordance with clause 1.8.2 of the User Agreement.

4.3. The User Payment account for each currency has unique number, which shall be used to perform transaction regarding this User Payment Account.

4.4. The User has a right to execute the following transactions through the User Payment Account:

• 4.4.1. top up the currency balance (deposit a currency) of the User Payment Account by sending relevant amount of currency to the Payment Service Provider;
• 4.4.2. send currency from the User Payment Account to another payment account (specified by the User), which is opened on the Payment Service Provider;
• 4.4.3. receive currency to the User Payment Account from another payment account, which is opened on the Payment Service Provider;
• 4.4.4. exchange currencies deposited on the User Payment Account to another currencies, for which the User Payment Account is created (e. g. exchange EUR to USD etc.);
• 4.4.5. withdraw the currency from the User Payment Account by the method chosen by the User and accepted by the Payment Service Provider (e. g. to another payment service provider or to the card like VISA, MasterCard, Maestro/Cirrus, etc.).

4.5. The User has a right to make transactions with the User Payment Account in accordance with terms and conditions specified in the User Agreement.

4.6. Transactions performed and service fees paid are reflected in the User Account's statement, which is available to the User in an electronic form in the User Account or in another way previously agreed upon.

4.7. To perform the transaction specified in clause 4.4.1 the User shall send the application to the Payment Service Provider, where the top up method, the amount of top up and other necessary data is specified. The Payment Service Provider allows the following methods for top up the User Payment Account:

4.7.1. Bank cards (Visa, MasterCard);
4.7.2. Payment systems.

4.8. To perform the transaction specified in clause 4.4.2 the User shall send the application shall contain at least the following:

• 4.8.1. the payment account number, which is opened on the Payment Service Provider, where currency shall be transferred from the User Payment Account;
• 4.8.2. amount of currency, which shall be transferred from the User Payment Account.

4.9. To perform the transaction specified in clause 4.4.4 the User shall send the application shall contain at least the amount of currency shall be exchanged. The User's currency shall be exchanged with the rate specified by the Payment Service Provider and the result of exchange shall be deposited to the User Payment Account.

4.10. To perform the transaction specified in clause 4.4.2 and 4.4.5 the User shall send the application shall contain at least the amount of currency which shall be withdrawn from the User Payment Account and the withdrawal method. Depending on withdrawal method, the other necessary data required for the withdrawal process may be requested.

4.11. The User is fully responsible for transactions, specified in clause 4.4. None of the losses resulted from the mistakes made by the User when executing the transaction with the User Payment Account shall be covered by the Payment Service Provider and the transaction itself shall not be the subject to the changes or cancel after its complete performance.

4.12. The User Payment Account cannot be closed upon the User's request. The User Wallet may be closed only if there is no currency, which may be sent or withdrawn from the User Payment Account.

The virtual currency wallet service
5.1. When registering the User Account, the Service Provider creates virtual currency wallets on the name of the User (hereinafter – the User Wallet).

5.2. The User Wallet shall be created only for a virtual currency, which is available in accordance with clause 1.5.3 of the User Agreement.

5.3. The User Wallet for each virtual currency has unique virtual currency wallet number, which shall be used to perform transactions regarding to this User Wallet.

5.4. The User has a right to make transactions using the User Wallet, including:

• 5.4.1. send virtual currency from the User Wallet to another virtual currency wallet, specified by the User;
• 5.4.2. receive virtual currency to the User Wallet from another virtual currency wallet.

5.5. The User has a right to make transactions using the User Wallet in accordance with terms and conditions specified in the User Agreement.

5.6. Transactions performed and service fees paid are reflected in the User Account's statement, which is available to the User in an electronic form in the User Account or in another way previously agreed upon.

5.7. The User's order for sending virtual currency from the User Wallet shall contain at least following:

• 5.7.1. virtual currency wallet address, where virtual currency shall be transferred from the User Wallet;
• 5.7.2. amount of virtual currency, which shall be transferred from the User Wallet.

5.8. The User is fully responsible for transactions, specified in clause 5.4. None of the losses resulted from the from the mistakes made by the User when executing transaction with the User Wallet shall be covered by the Service Provider and the transaction itself shall not be the subject to the changes or cancel after its complete performance.

5.9. The User Wallet cannot be closed by the User's request. The User Wallet may be closed only if there is no virtual currency, which may be sent or withdrawn from the User Wallet.

The virtual currency exchange service

5.10. At the User's request the Service Provider shall perform one of the following transactions (hereinafter – the Exchange Services):

• 5.10.1. exchange virtual currency disposed on the User Wallet to fiat currency, which shall be disposed on the User Payment Account;
• 5.10.2. exchange one virtual currency against another between the User's Wallets on the Platform;
• 5.10.3. exchange the User's fiat currency disposed on the User Payment Account to virtual currency, which shall be disposed on the User Wallet;
• 5.10.4. exchange virtual currency between the users that have sent the applications for virtual currency exchange to their user wallets with the rate, specified by them (peer to peer exchange).

5.11. To receive the Exchange Services, the User shall submit relevant application to the Service Provider.

5.12. The Exchange Services shall be performed at the exchange rate established by the Service Provider.

5.13. The Service Provider shall perform the Exchange Services in the reasonable time after User's request in accordance with clause 5.11. The User agrees, that due to virtual currency price fluctuations, the exchange rate may vary, and the Service Provider is not obliged to perform the Exchange Services at the exchange rate proposed by the User in application, specified in clause 5.11.

5.14. When performing the Exchange Service specified in clause 5.10.1, the Service Provider shall debit the relevant User Wallet in the virtual currency's amount specified in the User's application and send the relevant amount of currency (as result of exchange) to the relevant User Payment Account.

5.15. When performing the Exchange Service specified in clause 5.10.2 the Service Provider shall debit the relevant User Wallet in the virtual currency's amount specified in the User's application and deposit relevant amount of virtual currency to another User Wallet.

5.16. When performing the Exchange Service specified in clause 5.10.3 the Service Provider shall receive currency from the User Payment Account in amount specified in the User's application and deposit relevant amount of virtual currency to the User Wallet.

5.17. When performing the Exchange Service specified in clause 5.10.4 the Service Provider shall process 2 users´ applications for exchange their virtual currencies and debit the corresponding User Wallets with the virtual currency in the amount specified in users´ applications and deposit relevant amount of virtual currency to the corresponding User Wallets.

5.18. The User is fully responsible for transactions, specified in clause 5.10. None of the losses resulted from the mistake made by the User when executing transaction shall be covered by the Service Provider and the transaction itself shall not be the subject to the changes or cancel after its complete performance.

6.1. The User shall certify their right to use the Service in a manner acceptable to the Service Provider.

6.2. The Service Provider shall refuse to provide the Service if there is a doubt that the person wishing to use the Service is entitled thereto. In such an event, the Service Provider shall not bear any liability for the damage caused by refusal to provide the Service.

6.3. The User can only give the Service Provider such orders that are allowed for by the conditions of the Services provided. The orders shall be unambiguous and executable. The Service Provider shall not bear any liability for forwarding errors, ambiguities or mistakes in the orders. In the case of ambiguities the Service Provider shall have the right to demand additional information or documents from the User and, until the receipt thereof and information contained therein is checked, to postpone the execution of the order.

6.4. The User or their representative shall give the order by hand, electronically signed/confirmed or through another means of identification or security element accepted by the Service Provider.

6.5. The Service Provider may demand signature of the document in the Service Provider’s office or, if it proves impossible, notarization of the signature.

6.6. The User shall ensure a sufficient amount of funds to the Service Provider for the execution of the order given to the Service Provider. In the event that there is not a sufficient amount of funds on the Service Provider disposal and unless agreed otherwise the Service Provider have a right to not perform the execution of orders.

6.7. An order that the Service Provider has taken to execute shall not be cancelled, amended and/or changed unless otherwise stated in the Service Conditions.

6.8. If the Service Provider has doubts regarding the legality of the order, it may demand additional confirmation at the expense of the User in the form and/or the manner accepted by the Service Provider prior to the execution of the order.

6.9. Upon the execution of an incorrect or insufficient order, the Service Provider may execute the order proceeding from the practice and principles of sound management or refuse to execute the order. The Service Provider shall not bear liability for the execution or non-execution of the order in the aforementioned case.

6.10. The Service Provider may refuse to execute or apply restrictions to the order if this is necessary due to the requirements (e.g., measures for combatting money laundering and the financing of terrorism) set by the payments service provider, the agency of the country, or if the payment is directly or indirectly connected with a person sanctioned or restricted by a foreign country or the transaction is contrary to the restriction imposed by the financial sanctions.

6.11. The Service Provider may refuse to execute the order if the User is intoxicated by alcohol or drugs or the Service Provider has doubts for any other reason that the User is not able to understand the meaning and consequences of their actions.

6.12. The Service Provider shall execute the User’s orders within the reasonable period.

6.13. The Service Provider shall not bear any liability for the deadlines or rules established by the User or a third person or the damage caused by the User or the Third Person.

6.14. The Service Provider may partially or fully transfer the performance of its obligation to third persons provided that it arises from the essence of the obligation or is more expedient for the purpose of performance of the obligation in consideration of the User’s interests.

6.15. For the purposes of ensuring security, the Service Provider may give orders to the User (e.g. to change the account’s password or another security feature) and the User shall comply with the orders immediately. The User shall be liable for all damage resulting from the noncompliance of such orders.

Payments for the Services

6.16. The User shall pay the Service Provider a fee for the rendered Service established in the Price List.

6.17. In addition to the costs specified in the Price list the User shall cover the Service Provider’s expenses which result from the operations performance in the interest of the User (e.g. communication or postal costs, notary fees, etc.) and the costs related to the User Agreement performance (e.g. legal expenses, etc.).

6.18. The User shall pay for the Services not specified in the Price List according to the actual expenses of the Service Provider. The Service Provider shall issue an invoice at the request of the User.

6.19. If the User fails to perform their obligation before the Service Provider, the User shall pay the Service Provider the default interest and/or the penalty established in the Price List. The Service Provider shall start calculating the default interest as of the date of creation of the arrears and terminate the calculation of the default interest as of the date of settlement of the arrears.

6.20. The User shall keep a sufficient amount of funds on the User Payment Account or on the User Wallet so that the Service Provider can debit all service fees and other sums and arrears payable from the User Payment Account or the User Wallet.

6.21. The Service Provider shall debit the User’s assets which are on the User Payment Account or on the User Wallet with the service fees and other sums and arrears payable. This also applies after the sums have become collectible, including in the case that the User has submitted other orders with respect to these sums before their actual withholding by the Service Provider.

6.22. The Service Provider shall withhold the service fees and other sums payable in euros or in the other currency (including virtual currency) in which the User keeps their assets on the User Payment Account or on the User Wallet.

6.23. If the User does not keep the sufficient amount of funds on the User Payment Account or on the User Wallet for the deduction of all the service fees and other sums and arrears payable, the Service Provider shall establish the order of performance of the User's obligations.

6.24. The User shall receive information about the deduction of the service fees and other paid sums and arrears stipulated in the Price List in the User Account.