TERMS OF SERVICE EMCD СOINHOLD WALLET

By registering a new User Account and(or) using any of the Services and(or) visiting any section of the website located at https://coinhold.io/ (the “Platform”), the User agrees to be legally bound by these Terms of Service (the “ToS” or “General Terms”), together with the Privacy Policy, KYC/AML Policy, applicable Risk Disclosures, applicable Product Terms and the terms of any promotions, bonuses or special offers accepted by the User or otherwise expressly incorporated into the contractual relationship.

Please read the ToS carefully before accepting them. You agree that you are free to choose whether to use the Services made available through the Platform and do so at your sole option, discretion and risk. If you have any doubts about your rights or obligations, you should obtain independent legal or other professional advice. If you do not agree to be bound by the applicable terms, you must not open an Account or use the relevant Services. Your continued use of the Platform or relevant Services constitutes acceptance of the terms applicable to such use.

These ToS constitute a legally binding agreement between the User and EMCD FINTECH CORP., a corporation organized and existing under the laws of the Republic of Panama, registered under company No. 155769566, with registered office at PH The Century Tower, Office 317, Vía Ricardo J. Alfaro, Betania, Panama City, Republic of Panama (“CHW”).

CHW provides and operates the Platform and provides the Wallet Services and such other Services as are identified in these ToS or the applicable Product Terms as being provided by CHW.

Certain functionality accessible through the Platform may be provided, executed or otherwise performed by independent Third-Party Providers and may be subject to separate terms applicable between the User and the relevant Third-Party Provider. The availability of such functionality through the Platform, including through a common Account, user interface, mobile application, hyperlink, widget or other technical integration, does not, by itself, make CHW the provider, principal, merchant of record, guarantor, agent or contracting counterparty in respect of any service supplied directly by such Third-Party Provider.

Where the Platform mobile application is published or distributed through a mobile application marketplace by a person other than CHW, such publication or distribution does not, by itself, make that person the provider, operator, guarantor or contracting counterparty in respect of the Services.

DISCLAIMERS

CHW calls the Users’ attention to the following:

1. Digital Assets and transactions involving Digital Assets involve substantial risks. Their market value, liquidity and availability may change rapidly and materially, and the User may lose some or all of the economic value associated with a Digital Asset or transaction.

2. Digital Assets and related services are subject to different and evolving legal and regulatory regimes across jurisdictions. Laws, regulatory requirements, regulatory interpretations or enforcement practices may change and may affect the availability, scope or manner in which any Service, Digital Asset or Supported Network may be offered or used.

3. The operation and use of Digital Assets may be affected by circumstances outside CHW’s control, including blockchain or protocol events, network congestion or failure, forks, cyber incidents, technological defects, market disruption, liquidity constraints, acts or omissions of third parties and changes affecting stablecoins or their underlying arrangements.

4. The Services are not bank deposits, and the protections ordinarily applicable to bank deposits, investment accounts or traditional financial products may not apply.

5. CHW does not provide investment, financial, legal, tax or other professional advice and does not recommend that the User acquire, hold, sell, exchange or otherwise transact in any Digital Asset. The User is solely responsible for evaluating the legality and appropriateness of using the Services and for understanding and accepting the risks associated with the relevant Digital Assets and transactions.

These disclaimers are not exhaustive. The User must review and accept the applicable Risk Disclosures made available in connection with the Services.

DEFINITIONS

1. “Account” means the User account registered on the Platform through which the User accesses the Platform and the Services, including the Wallet Services, and through which the User may view balances, submit Instructions, manage security settings and access such other functionality as CHW makes available from time to time.

2. “App Store Publisher” means EMCD Tech Limited, registration number 70988161, addressed at Room 607, 12/F., Block C, Hong Kong Industrial Centre, 489-491 Castle Peak Road, Lai Chi Kok, Hong Kong, to the extent it is identified as the developer, seller, publisher, distributor or similar app-store-facing entity for the Platform mobile application in Apple App Store, Google Play or any other mobile application marketplace. The App Store Publisher publishes or makes available the mobile application solely for technical, administrative, distribution and app-store compliance purposes. Unless expressly identified as the provider of a particular Service in the applicable Product Terms, the App Store Publisher is not the provider, operator, guarantor, agent or contracting counterparty in respect of that Service.

3. “Account Balance” means the balance of a Digital Asset recorded in CHW’s reconciled internal records as credited to the User’s Account under the Wallet Services, excluding any amount that has been transferred or allocated to a Grow or otherwise debited from the Wallet Services.

4. “Available Balance” means the portion of an Account Balance recorded by CHW as available for withdrawal, transfer or use in connection with a Service after taking account of pending transactions, reservations, holds, applicable limits, Fees and other restrictions permitted under these ToS, applicable Product Terms or Applicable Law.

5. “Applicable Law” means any law, regulation, binding regulatory requirement, sanctions measure, court or administrative order or other legally binding requirement applicable to CHW, the User, a Service or a relevant transaction.

6. “Bulletin Board Operator” means the person identified in the P2P Services ToU as the provider of the P2P Bulletin Board Services.

7. “Borrow Services” means the Digital Asset borrowing functionality provided by CHW under the applicable Borrow Product Terms.

8. “CHW”, “Company”, “we”, “us” or “our” means EMCD FINTECH CORP., a corporation organized and existing under the laws of the Republic of Panama, registered under company No. 155769566, with registered office at PH The Century Tower, Office 317, Vía Ricardo J. Alfaro, Betania, Panama City, Republic of Panama. For the avoidance of doubt, CHW provides and operates the Platform and is the provider of the Wallet Services and such other Services as are expressly identified in these ToS or the applicable Product Terms as being provided by CHW.

9. “Digital Asset” means a cryptographically secured digital representation of value or rights that may be transferred or stored using blockchain, distributed-ledger or comparable technology, including cryptocurrencies, tokens and stablecoins, to the extent supported by the relevant Service.

References in these ToS to “cryptocurrency” or “cryptocurrencies” shall, unless the context requires otherwise, be construed as references to Digital Assets.

10. “Eligible User Location” means the User’s jurisdiction, residency, citizenship, place of incorporation or establishment, current location, KYC/KYB country, IP-based location, device location, tax residence and any other location-related information reasonably determined by CHW for the purposes of assessing eligibility to access the Platform or any Service.

Where relevant location indicators are inconsistent, incomplete or create legal, regulatory, sanctions, AML/CFT or other material risk, CHW may apply the most restrictive treatment, request additional information or verification, restrict access to any Service or refuse or discontinue onboarding or service provision.

11. “External Wallet” means a blockchain address outside the Wallet Services to or from which Digital Assets may be transferred.

12. “Fees” means any fees, spreads, charges, Network Fees or other amounts applicable to a Service or transaction and disclosed or otherwise determined in accordance with these ToS, applicable Product Terms or the relevant transaction flow.

13. “Instruction” means any request, direction, confirmation, authorization or other instruction submitted through the Account or another authenticated method accepted by CHW.

14. “Order” means an Instruction submitted by the User requesting the purchase, sale, exchange or other transaction in Digital Assets through a Service.

15. “Product Terms” means any additional terms, product conditions or transaction-specific terms applicable to a particular Service and made available to or accepted by the User in connection with that Service.

16. “Platform” means the EMCD Coinhold Wallet technology platform operated and made available by CHW, including the website accessible at https://coinhold.io/ and its relevant subdomains, mobile and web applications, interfaces, software, databases, authenticated account functionality and other related technology through which the User may access the Services.

The Platform mobile application may be published or distributed through mobile application marketplaces by the App Store Publisher without thereby making the App Store Publisher the provider of the Services.

17. “P2P Bulletin Board Services” means the online bulletin-board functionality provided by the Bulletin Board Operator, consisting of publication, display, browsing, sorting, filtering and User interaction with advertisements. P2P Bulletin Board Services do not include custody, escrow, release, exchange, brokerage, dealing, payment processing, money transmission, settlement, execution, matching or financial intermediation.

18. “P2P Transaction Support Services” means the custodial wallet, Digital Asset escrow, release, return, compliance, payment-evidence review, dispute-support and related transaction-support services provided by EMCD FINTECH CORP. in connection with P2P transactions, to the extent described in the EMCD P2P Services Terms of Use.

19. “Ramps” means functionality made available through the Platform through which the User may access fiat-to-Digital Asset or Digital Asset-to-fiat conversion services provided by one or more Third-Party Providers, as further described in Section 5.2.

20. “Restricted Jurisdiction” means any jurisdiction in or from which CHW restricts or does not make some or all Services available under these ToS, the KYC/AML Policy or CHW’s applicable legal, regulatory, sanctions, compliance or risk controls.

21. “Sanctions” means any economic, financial, trade or other restrictive measure applicable to CHW, the User or a relevant transaction and administered, enacted or enforced by the United Nations, the United States, the European Union, the United Kingdom or any other competent sanctions authority.

22. “Supported Digital Asset” means a Digital Asset designated by CHW as supported for the relevant Service from time to time.

23. “Supported Network” means a blockchain or distributed-ledger network designated by CHW as supported for the relevant Digital Asset or Service from time to time.

24. “Converter” means the crypto-to-crypto exchange functionality provided through the Platform under Section 5.1.

25. “Portfolio” means the functionality provided by CHW under Section 5.4 through which the User may submit an Order to acquire, increase, partially dispose of or fully dispose of a pre-defined basket of Supported Digital Assets in the proportions displayed through the Platform. A Portfolio is not a separate Digital Asset and does not represent a unit, share or other interest in a separately constituted pool of assets. References through the Platform to a “portfolio”, “index”, “pack”, “basket” or similar designation describe the relevant grouping and composition of underlying Digital Assets only.

26. “Third-Party Provider” means an independent third party that provides services or functionality used in connection with, or accessible through, the Platform, including payment, fiat on-ramp or off-ramp, card, execution, liquidity, banking, acquiring, verification or other service providers, but only to the extent of the services actually provided by that third party.

27. “Wallet Services” means the custodial Digital Asset wallet services provided by CHW through the Platform, including the custody and safekeeping of supported Digital Assets, maintenance of Account balances and internal ledger records, deposits, withdrawals, internal transfers and such related wallet functionality as CHW makes available from time to time.

In providing the Wallet Services, CHW controls the private keys used to control Digital Assets held within the Wallet Services on behalf of Users.

28. “Grow Services” means the Digital Asset placement and rewards functionality provided by CHW under Section 5.3, subject to the applicable Product Terms and transaction-specific parameters accepted by the User. For the avoidance of doubt, the legal treatment of Digital Assets allocated to a Grow is governed by Section 5.3 and differs from the custody treatment applicable to Digital Assets forming part of the User’s Wallet balance.

29. “P2P Services” means the P2P Bulletin Board Services and the P2P Transaction Support Services, as applicable.

30. “P2P Services ToU” means the EMCD P2P Services Terms of Use available within the Platform, as amended from time to time, which govern the use of P2P Bulletin Board Services and P2P Transaction Support Services.

31. “Services” means the Platform functionality and services made available to the User under these ToS or applicable Product Terms, including the Wallet Services, P2P Services, Converter, Ramps, Grow Services, Portfolio, Borrow Services and Card-related functionality, to the extent available to the User.

Certain functionality accessible through the Platform may be provided directly by a Third-Party Provider. Access to such functionality through the Platform does not, by itself, make CHW the provider or contracting counterparty in respect of the service supplied directly by that Third-Party Provider.

32. “ToS” or “General Terms” means these general Terms of Service, as amended from time to time in accordance with Section 1.

33. “Network Fees” means fees or charges payable in connection with the processing or validation of a Digital Asset transaction on a Supported Network, including gas, miner or validator fees, whether charged to the User directly or reflected in the amount of a transaction.

34. “User”, “you” or “your” means the individual or legal entity in whose name an Account is registered and which has accepted these ToS.

1. Amendment of the ToS and Incorporated Agreements

1.1. CHW reserves the right to amend, modify, update, and change the General Terms for several reasons, including commercial, legal (to comply with new laws or regulations), or customer service without prior notice. The most up-to-date ToS and their effective date are available within the Platform.

1.2. CHW will notify the User of any such amendment, modification, or change by publishing the new version of the ToS on the Platform.

1.3. It is the User’s responsibility to make sure that he/she/it is aware of the current terms and conditions of the ToS, and CHW advises the User to check for updates regularly.

1.4. CHW reserves the right to modify the Platform, its interface, technical infrastructure, functionality and system specification requirements, and to introduce, modify, restrict, suspend or discontinue any Service, Supported Digital Asset, Supported Network, feature, transaction type, eligibility requirement or applicable limit, at any time and without prior notice where CHW considers this appropriate for commercial, legal, regulatory, compliance, security, technical, operational, market, liquidity or risk-management reasons. Except where expressly provided otherwise in the applicable Product Terms, the availability of any Service, feature, Supported Digital Asset or Supported Network at any particular time does not create an obligation on CHW to continue making it available. Any modification under this Section is without prejudice to transaction-specific rights and obligations that have already become binding under applicable Product Terms, except where modification, suspension or other action is required or reasonably considered necessary by CHW as a result of Applicable Law, sanctions, an order or requirement of a competent authority, security considerations or circumstances expressly permitted under these ToS or the applicable Product Terms.

1.5. If any amendment to these ToS is unacceptable to you, you may cease using the Platform and the Services and(or) close your Account in accordance with these ToS. Your continued use of any part of the Platform or any Service after the effective date of revised ToS constitutes your binding acceptance of the revised ToS. For the avoidance of doubt, amendments may include additions, removals or changes to the Services, Product Terms, Supported Digital Assets, Supported Networks, eligibility requirements, limits, Third-Party Providers or the manner in which a Service or any part of it is made available, subject to any rights applicable to transactions already accepted under the relevant Product Terms.

1.6. In addition to these ToS, the User shall review and comply with the Privacy Policy, KYC/AML Policy, applicable Risk Disclosures, applicable Product Terms, the P2P Services ToU where applicable, and any other terms or policies expressly identified through the Platform as applicable to the relevant Service or transaction. Such documents, as amended from time to time in accordance with their terms, form part of the contractual framework governing the User’s use of the Platform and the Services. Product Terms may supplement or modify these ToS in relation to a particular Service or transaction. In the event of an inconsistency concerning such Service or transaction, the following order of precedence applies to the extent of that inconsistency: (a) transaction-specific parameters expressly confirmed by the User through the authenticated Platform flow; (b) the applicable Product Terms, including the P2P Services ToU where applicable; (c) these ToS; (d) the applicable Risk Disclosures; (e) the KYC/AML Policy; and (f) any other Platform content. The Privacy Policy governs matters specifically relating to the processing of personal data.

2. Representations and Warranties. Legal Requirements

2.1. The Users hereby warrant that they are individuals whose legal capacity has not been limited to the extent that would prevent them from undertaking the obligations assumed by the ToS.

2.2. If the User is a legal entity, it warrants that it is duly established and existing under the law that governs their establishment and existence, respectively, and the person acting on behalf of the legal entity hereby further represents that it is authorized to act on behalf of the legal entity and to undertake obligations according to the ToS.

2.3. The Users warrant that they have not previously had Accounts that were deleted unless it was due to their request of the User or due to the inactivity of the User.

2.4. The User warrants that all information and documents provided to CHW in connection with the Account or the Services are true, accurate, complete and not misleading and shall keep such information up to date. CHW shall not be responsible for any loss, damage or other consequence arising from inaccurate, incomplete, outdated or misleading information provided by the User. CHW may request additional or updated information at any time and may reject, restrict, suspend or close the Account or any Service where the User fails to provide information requested by CHW or where information provided by the User is or appears to be inaccurate, incomplete, outdated or misleading.

2.5. The User is solely responsible for determining and complying with any tax, reporting, filing, withholding or similar obligations applicable to the User in connection with the Account, the Services, any Digital Assets and any transactions conducted through the Platform. Unless required by Applicable Law, CHW does not act as the User’s tax agent and is not responsible for determining, calculating, reporting or paying taxes on behalf of the User. CHW may deduct or withhold any amount where required to do so by Applicable Law.

2.6. The availability and legal or regulatory treatment of Digital Assets and related services may differ between jurisdictions. CHW does not provide legal, regulatory or tax advice and makes no representation that the Platform, any Service, Digital Asset or transaction is appropriate or lawfully available to every User or in every jurisdiction. The User is solely responsible for determining whether the User is permitted to access and use the relevant Services under Applicable Law. Users from Restricted Jurisdictions are not permitted to access or use the Services to the extent restricted by CHW. Restricted Jurisdictions include jurisdictions identified as restricted under the KYC/AML Policy and any additional jurisdiction in respect of which CHW restricts some or all Services from time to time for legal, regulatory, sanctions, compliance, commercial or risk-management reasons. CHW may apply different eligibility requirements or restrictions to different Services, Users or jurisdictions and may refuse, restrict, suspend or discontinue access where CHW determines that the User is or has become ineligible to use the relevant Service. The technical availability of the Platform or any functionality, including the ability to register, log in, view a Service or submit an Instruction, does not constitute confirmation that the User is eligible to use that Service.

2.7. CHW does not intend to enable the User to contravene Applicable Law. The User represents, warrants and undertakes that the User’s access to and use of the Platform and the Services, and each Instruction or transaction submitted through the Account, shall comply with Applicable Law and these ToS. The User shall not use the Platform or any Service for any unlawful, fraudulent, abusive or unauthorized purpose, or in any manner intended to circumvent any legal, regulatory, sanctions, eligibility, verification, security, transaction or other control implemented by CHW. CHW shall not be responsible for any unlawful or unauthorized use of the Platform or the Services by the User.

2.8. Personal Data processed by CHW in connection with the Platform and the Services is processed in accordance with the Privacy Policy, as amended from time to time in accordance with its terms.

2.9. The User represents, warrants and undertakes that, in respect of every Digital Asset transferred to, held through or used in connection with the Account or any Service, the User is the legal and beneficial owner of that Digital Asset or is otherwise lawfully authorized to possess, transfer and dispose of it in the manner contemplated by these ToS and the applicable Product Terms. Unless expressly permitted by CHW, the User shall not use the Account or the Services to hold, transfer, manage or transact in Digital Assets for or on behalf of another person. The User further represents and warrants that no Digital Asset used in connection with the Services is subject to any lien, pledge, security interest or other third-party right that would prevent the User from transferring or otherwise dealing with it as contemplated by these ToS.

2.10. The representations, warranties and undertakings in this Section 2 are deemed repeated each time the User accesses or uses a Service or submits an Instruction, by reference to the facts and circumstances existing at that time. The User shall promptly cease using the affected Service and notify CHW where any such representation or warranty ceases to be true in any material respect.

3. User Account

3.1. The User shall create an Account on the Platform in order to access the functionality and Services made available to that User. The Account may provide access to the Wallet Services and to such other Services as CHW makes available to the User from time to time, subject to eligibility, verification, applicable limits and these ToS and Product Terms. The Platform may distinguish between Unverified and Verified Accounts. The functionality and limits applicable to each Account status may differ and may be further restricted or adjusted by CHW in accordance with these ToS, the KYC/AML Policy and CHW’s risk-based controls.

3.2. CHW reserves the right to reject any application for an Account, decline or defer activation of an Account, or condition access to any Service, without liability to the User. Where Account registration details or other information provided by the User are inaccurate, misleading, incomplete or outdated, or where the User does not satisfy or ceases to satisfy applicable eligibility, verification, compliance or risk requirements, CHW may require additional information or verification and may restrict, suspend or close the Account or any Service in accordance with these ToS. A single Account may provide access through a common interface, login or mobile application to Services provided by CHW and to functionality supplied directly by Third-Party Providers. Such technical integration does not merge the legal roles or obligations of CHW and any Third-Party Provider.

3.3. Where functionality accessible through the Account is provided directly by a Third-Party Provider, the relevant Third-Party Provider is responsible only for the service component expressly provided by it under the applicable Product Terms or its own terms. Neither a common interface, shared login, single sign-on, in-app flow, hyperlink, widget, API, common branding, technical integration nor distribution of the Platform mobile application through an app store shall, by itself, make CHW responsible for obligations independently owed by a Third-Party Provider, or make such Third-Party Provider responsible for the Wallet Services or any other Service provided by CHW.

3.4. After opening an Account, you must not disclose, whether deliberately or accidentally, your login credentials, authentication factors or other security credentials to anyone else or permit any unauthorized person to access or use your Account.

3.5. You are responsible for maintaining the confidentiality and security of your Account credentials, authentication factors, devices and other means used to access or authorize activity through your Account. Subject to Applicable Law, you are responsible for Instructions and activities carried out through your Account using valid authentication credentials or authentication methods until CHW has received and had a reasonable opportunity to act upon notice from you that your Account or security credentials have been compromised. You shall not permit another person to use your Account except where expressly permitted by CHW.

3.6. You must notify CHW immediately if you know or suspect that:

(a) your Account, login credentials, authentication factors, device or recovery information has been lost, stolen, compromised or used without authorization;

(b) an Instruction or transaction appearing in your Account was not authorized by you; or

If requested, you shall promptly provide CHW with such information and evidence as CHW considers necessary to investigate or respond to the relevant event. CHW may, without prior notice, restrict access to the Account, suspend withdrawals or other functionality, revoke or reset authentication methods or apply other protective measures while a security review is pending. Changes to authentication credentials, recovery information, devices or other security-sensitive Account settings may be subject to temporary withdrawal or transaction restrictions determined by CHW for security and fraud-prevention purposes. Account access or recovery remains subject to CHW’s applicable verification and security procedures.

3.7. The User shall not misuse or abuse the Platform, the Services, any process or control implemented by CHW, any Third-Party Provider or Supported Network, or any error, vulnerability, bug, defect or unintended functionality. Without limitation, prohibited conduct includes:

(a) unauthorized access, hacking, malware, denial-of-service, botnet or other attacks against the Platform, any Service, another User or any third party;

(b) exploiting or attempting to exploit an error, vulnerability, pricing error, processing error, technical defect or unintended functionality for the User’s or another person’s benefit;

(c) manipulating or attempting to manipulate any transaction, quote, reward, promotion, limit, eligibility rule, verification process or other Platform functionality;

(d) circumventing or attempting to circumvent geographic, KYC/KYB, AML/CFT, sanctions, security, transaction, Account or other controls;

(e) creating or using multiple Accounts without CHW’s permission where intended to avoid controls, limits or restrictions;

(f) using the Platform or Services in a manner that interferes with, damages, disrupts or places an unreasonable burden on the Platform, the Services, CHW, another User or a Third-Party Provider; or

(g) any other activity that CHW, acting reasonably and in its sole discretion, suspects or determines to be fraudulent, abusive, manipulative, unauthorized, irregular or harmful to the Platform, the Services, CHW, other Users or any third party.

CHW may take any action permitted under Section 3.8 in response to actual or suspected conduct described in this Section 3.7 and may correct, reverse or otherwise address the effects of such conduct to the extent permitted by these ToS, applicable Product Terms and Applicable Law.

3.8. CHW reserves the right, at any time and in its sole discretion, to modify, restrict, suspend or discontinue temporarily or permanently any part or feature of the Platform or Services in accordance with these ToS. Without limiting any other right under these ToS or applicable Product Terms, CHW may:

3.8.1. Decline, block, cancel, reverse or, where permitted by Applicable law and applicable Product Terms, reverse or correct any transaction or Instruction;

3.8.2. Terminate, suspend, or restrict your access to any or all of the Services.

3.8.3. Terminate, suspend, close, place on hold, or restrict your access to any or all of your Account.

3.8.4. Decline, defer or cease transmitting any information, Instruction, Order, payment request or other communication to a Third-Party Provider.

3.8.5. Take any action deemed necessary with immediate effect, for any reason, including:

a. You are or become ineligible to use one or more of the Services.

b. We have reasonable grounds to suspect that:

• The person accessing your Account is not you, or the account is or will be used for unauthorized, illegal, or fraudulent purposes.

• More than one person is using the same account, or such use suggests unauthorized or unlawful activity.

• The information you provided is false, outdated, incomplete, or misleading.

c. We have legitimate concerns regarding your creditworthiness or financial condition, including:

• If you are an individual: bankruptcy, unsound mind, act of bankruptcy, or legal proceedings started against you.

• If acting on behalf of a partnership: death, bankruptcy, unsoundness of mind of any partner; steps to dissolve or alter partners or partnership structure.

• If acting on behalf of a corporation: inability to pay debts when due; initiation of insolvency, receivership, judicial administration, or similar proceedings.

• Any proposal, compromise, or assignment for the benefit of creditors, or calling creditors’ meetings.

d. Pending submission of requested information or documentation.

e. Pending submission of enhanced due diligence documentation.

f. A legal or regulatory obligation exists, or we are required to comply with a court order or regulatory authority.

g. We determine or reasonably suspect:

• You have violated these Terms or any Product Terms.

• You have breached any warranties or made false representations.

• Any transaction is unauthorized, erroneous, fraudulent, or unlawful, or the account or service is being used in a fraudulent or unauthorized manner.

• There is suspected involvement in money laundering, terrorist financing, fraud, or any other criminal activity.

h. Your account usage is subject to pending or threatened litigation, investigation, or regulatory proceedings, or we perceive an increased risk of legal or regulatory non-compliance in your activities.

i. Account is inactive. User Account is considered inactive if the User has not logged into the User Account via Platform for more than one (1) year (twelve consecutive months). CHW may delete Inactive User Accounts after three previous email warnings made thirty (30), ten (10), and one (1) day before the deletion.

j. You owe amounts to us that remain unpaid.

k. Emails sent to your registered email address return as undeliverable.

l. An issue arises regarding the verification of your identity.

m. You take actions that circumvent our controls — such as creating multiple accounts without consent or abusing promotional offers.

n. Any other legitimate reason exists necessitating such action.

3.8.6. CHW is not required to disclose the reason for an action under this Section where disclosure is prohibited by Applicable Law, could compromise security or fraud-prevention measures, could prejudice an investigation or compliance review, or would otherwise be inappropriate having regard to applicable legal or regulatory requirements.

3.9. Closure, suspension or termination of an Account does not extinguish any rights, obligations, liabilities, pending transactions, holds or restrictions arising before such action. Subject to Applicable Law, the KYC/AML Policy, applicable Product Terms and any lawful hold or restriction, a User whose Account is being closed may be required to complete verification, provide additional information and submit valid withdrawal instructions for any Available Balance remaining in the Wallet Services. CHW may defer or restrict withdrawal or transfer of any Account Balance for so long as a restriction permitted under these ToS, the applicable Product Terms or Applicable Law remains applicable. Amounts allocated to Grow, amounts committed to or affected by another Service, pending transactions and any amounts subject to a hold, reservation, set-off or other restriction shall be dealt with in accordance with the terms applicable to the relevant Service. If the User does not provide information or Instructions reasonably required to return or otherwise deal with an Account Balance, CHW may continue to hold the relevant Digital Assets or take such other action as is required or permitted by Applicable Law. Closure of the Account does not by itself transfer ownership of a Wallet Account Balance to CHW.

3.10. The User may request closure of the Account through functionality made available on the Platform or by contacting CHW support through the in-app support channel or at [email protected]. Account closure is subject to completion, cancellation or other treatment of pending transactions and Services, settlement of amounts owed to CHW, resolution of applicable holds or restrictions and such identity, security or compliance verification as CHW may require. A request to close the Account does not require CHW to process a transaction, withdrawal, redemption or other Instruction that would otherwise be prohibited, restricted, suspended or subject to review under these ToS, applicable Product Terms, the KYC/AML Policy or Applicable Law. CHW may retain records relating to a closed Account to the extent provided in the Privacy Policy or required or permitted by Applicable Law.

4. WALLET SERVICES

4.1. CHW provides the User with custodial Wallet Services through the Account. Subject to these ToS, the KYC/AML Policy, applicable limits and availability, the Wallet Services may enable the User to hold supported Digital Assets, receive deposits, make withdrawals and internal transfers, view transaction history, manage withdrawal addresses and use the Account Balance in connection with other Services made available through the Platform. CHW may determine from time to time which Wallet functionality, Supported Digital Assets and Supported Networks are available to a particular User or Account.

4.2. Custody and ownership. The Wallet Services are custodial. CHW safeguards and controls the private keys or other cryptographic credentials through which Digital Assets held within the Wallet Services are controlled. The User does not control, possess or have any right to obtain or export the relevant private keys, seed phrases or other cryptographic credentials. Except where Digital Assets are transferred, allocated or otherwise dealt with pursuant to an Instruction or the terms of another Service, Digital Assets credited to the User’s Account Balance remain beneficially owned by the User as between the User and CHW. CHW does not acquire beneficial ownership of such Digital Assets merely by holding them in custody.

The custody relationship under this Section is contractual and does not create a trust, fiduciary, escrow, agency, partnership, investment-management or advisory relationship between CHW and the User. CHW does not undertake any fiduciary duty or duty to manage, invest or act in the best interests of the User in respect of the Account Balance.

4.3. CHW may maintain Digital Assets attributable to Users through pooled or omnibus wallet arrangements and may consolidate, transfer or otherwise reorganize Digital Assets between blockchain addresses, wallets or accounts controlled or used by CHW for custody, security, execution, liquidity or operational purposes. The User has no right to any particular blockchain address, private key, UTXO, token unit or other specifically identifiable on-chain asset merely because a deposit address or Account Balance is associated with the User.

CHW shall maintain internal ledger records identifying the Digital Assets credited to the User’s Account Balance. Internal movements by CHW that do not constitute a User transaction do not, by themselves, alter the User’s Account Balance or beneficial entitlement recorded by CHW.

4.4. The User may deposit a Supported Digital Asset to a deposit address made available through the Account for the applicable Supported Network.The User is solely responsible for ensuring that the correct Digital Asset, Supported Network, deposit address and, where applicable, destination tag, MEMO or other required transaction information are used. A blockchain transaction, blockchain confirmation or receipt of Digital Assets at an address associated with CHW does not, by itself, constitute a final credit to the User’s Account Balance. A deposit will be reflected in the Account Balance only after CHW has completed such blockchain confirmation, reconciliation, security, AML/CFT, sanctions, fraud-prevention and other applicable controls as CHW considers necessary. CHW does not guarantee the time required to credit a deposit. Deposits involving unsupported Digital Assets, unsupported networks, incorrect addresses, missing or incorrect destination tags or MEMOs, or other erroneous transfer details are subject to Section 8. CHW has no obligation to recover, credit or return such Digital Assets except as expressly provided in Section 8.

4.5. The User may request a withdrawal of an Available Balance to an External Wallet by submitting an authenticated Instruction through the Account. A withdrawal is subject to:

(a) sufficient Available Balance;

(b) applicable transaction, Account and risk-based limits;

(c) completion of any authentication, address-whitelisting, security or verification requirements applicable to the Account;

(d) applicable Network Fees and other charges;

(e) the availability and proper functioning of the relevant Supported Network; and

(f) the controls and rights of CHW under these ToS and the KYC/AML Policy.

CHW may decline, defer, restrict or cancel a withdrawal Instruction before the relevant blockchain transaction is transmitted where permitted under these ToS. Once a withdrawal transaction has been transmitted to the relevant Supported Network, it may be irreversible and CHW may be unable to cancel, recover or modify it. The User is solely responsible for verifying the destination address, Supported Network and all other transaction details before confirming a withdrawal. CHW is not required to verify that an External Wallet is owned or controlled by the intended recipient. CHW does not guarantee any particular withdrawal or blockchain settlement time.

4.6. Where made available, the User may transfer supported Digital Assets to another eligible Account through an internal transfer functionality. An internal transfer may be effected by entries in CHW’s internal ledger without an on-chain transaction and shall be treated as completed when the corresponding debit and credit are recorded in CHW’s reconciled records. The User is responsible for confirming the intended recipient and transaction details before submitting an internal transfer. CHW is not obliged to reverse a correctly processed internal transfer solely because the User selected or identified an unintended recipient. Nothing in this Section limits CHW’s right to correct an erroneous entry or to take action under Section 3.8 in cases of actual or suspected fraud, unauthorized activity, error, abuse or other circumstances permitted under these ToS.

4.7. CHW may rely on an Instruction submitted through the Account using the applicable authentication methods as having been authorized by the User, subject to Sections 3.5 and 3.6. The User is responsible for reviewing the transaction details presented through the Platform before confirming an Instruction. An Instruction may cease to be revocable once CHW has begun executing it, made the relevant internal ledger entry, transmitted a blockchain transaction or otherwise committed to the transaction in a manner that cannot reasonably be reversed. CHW’s final reconciled records of Account Balances, Instructions, credits, debits and transactions shall constitute evidence of the matters recorded in them, absent manifest error or fraud. Blockchain records may be used by CHW as evidence of an on-chain transaction but do not, by themselves, determine the User’s Account Balance. CHW may correct any erroneous or duplicate entry in the Account, including by debiting an amount credited in error. If an amount credited in error has already been transferred, withdrawn or otherwise used by the User, the User shall remain liable to CHW for the corresponding amount, and CHW may exercise its rights under these ToS to recover it.

4.8. CHW may make available address-book, withdrawal-whitelisting or similar security functionality and may require the use of such functionality for certain transactions or Accounts. The User remains responsible for the accuracy of any address or other information saved or selected using such functionality. Inclusion of an address in an address book or whitelist does not constitute a representation or verification by CHW as to the ownership, identity, legality, security or suitability of that address. CHW may impose temporary restrictions on withdrawals or other transactions following changes to authentication credentials, recovery information, whitelisted addresses or other security-sensitive Account settings.

4.9. Where the User instructs CHW to use all or part of an Account Balance in connection with another Service, CHW is authorized to debit, reserve, transfer or otherwise apply the relevant Digital Assets to the extent necessary to process that Instruction. The legal treatment of Digital Assets following such debit, transfer or allocation is governed by the provisions applicable to the relevant Service. In particular, Digital Assets accepted for allocation to Grow cease to be held under the custody arrangement described in this Section and are thereafter subject to Section 5.3. Digital Assets transferred or allocated as Collateral under the Borrow Services cease to be held under the custody arrangement described in this Section upon the transfer of title provided for in the applicable Borrow Product Terms. Digital Assets acquired through Portfolio remain subject to the custodial treatment described in this Section 4 and do not cease to form part of the User’s beneficial entitlement under the Wallet Services merely because they are displayed or accounted for through the Portfolio interface. This is without prejudice to any subsequent transfer, disposal or allocation of such Digital Assets pursuant to another Instruction or Service.

4.10. Unless expressly stated otherwise in applicable Product Terms, the mere holding of Digital Assets as part of an Account Balance does not entitle the User to interest, Rewards, yield, staking proceeds or any other return in respect of those Digital Assets.

4.11. CHW may add, remove, restrict or suspend Wallet functionality, Supported Digital Assets or Supported Networks in accordance with Sections 1, 3.8, 8 and 13. Where CHW discontinues support for a Digital Asset, Supported Network or the Wallet Services generally, CHW may require the User to withdraw or otherwise deal with the affected Account Balance within a period specified by CHW, subject to Applicable Law and any applicable compliance, security or other restriction under these ToS.CHW may take such other measures as it reasonably considers necessary to facilitate an orderly restriction or discontinuation of the affected functionality, including restricting new deposits, transactions or use of the affected Digital Asset in other Services.

4.12. The Users may be offered certain other options to convert the cryptocurrency to fiat currency. The Users should remember that such services are provided by other companies and not CHW. CHW should bear no liability for the quality and timeliness of such services.

4.12.1. The P2P Services relating to the sale of cryptocurrency for fiat currency are governed by the EMCD P2P Services Terms of Use (P2P Services ToU) available within the Platform. For the avoidance of doubt, the P2P Services comprise separate functional components: (i) P2P Bulletin Board Services, provided by the Bulletin Board Operator, which are limited to online bulletin-board functionality for user-generated advertisements; and (ii) P2P Transaction Support Services, provided by EMCD FINTECH CORP., including custodial wallet functionality, Digital Asset escrow, release, return, compliance and dispute-support functions, where applicable and as further described in the P2P Services ToU. Users must review the P2P Services ToU before using any P2P Services. By using any P2P Services, Users accept and agree to comply with the P2P Services ToU. EMCD FINTECH CORP. may amend the P2P Services ToU from time to time in accordance with the amendment mechanics set out therein or within the Platform.

4.12.2. Buyer/ seller is obliged to provide payment receipts to the counterparty upon request. If you refuse to provide a payment receipt, the other party has the right to withhold the cryptocurrency until such receipt is provided. Facilitation of any holding, continued holding, release or return of Digital Assets in connection with P2P Services shall be performed by EMCD FINTECH CORP. under the P2P Services ToU, and not by the Bulletin Board Operator.

4.13. The User undertakes to minimize the risk themselves by keeping in secret their User Account access information and(or) performing reasonable actions for improving the information security of the User’s personal device.

5. ADDITIONAL SERVICES

5.1. Converter.

5.1.1. CHW may make available functionality enabling the User to exchange one Supported Digital Asset for another Supported Digital Asset through the Account (the “Swap”). Swap is available only for the Digital Asset pairs, amounts and Users supported by CHW from time to time and is subject to applicable limits, availability, these ToS and the KYC/AML Policy. Swap does not include the purchase or sale of Digital Assets for fiat currency.

5.1.2. Before submitting a Swap Order, the User is shown the material transaction terms applicable to the proposed Swap, including the Digital Assets to be exchanged, the relevant amount and the quoted exchange rate or resulting amount. A quote may be available only for the period displayed through the Platform and may expire if not confirmed within that period. The quoted rate may be determined by reference to executable pricing and liquidity available through external trading or liquidity venues and may include an CHW spread, mark-up or other pricing component. Unless expressly stated otherwise in the transaction flow, CHW is not required to separately itemize the components from which the quoted rate is derived. By confirming the quote, the User submits an Order and authorizes CHW to reserve or debit the relevant amount of the source Digital Asset from the User’s Available Balance for purposes of executing the Swap.

5.1.3. CHW will seek to execute an accepted Swap Order at the price confirmed by the User. Swap Orders are intended to be executed on a fill-or-kill basis. If the Order cannot be executed in full at the confirmed price and on the applicable transaction terms, CHW may use commercially reasonable efforts to complete the execution on those terms, but is not obliged to do so and may reject or cancel the Order. CHW will not intentionally execute the Order at a less favorable price than the price confirmed by the User without obtaining a new confirmation from the User.No quote, confirmation or submission of an Order constitutes an unconditional guarantee that the Swap will be executed.

5.1.4. CHW may use one or more external exchanges, liquidity providers or other execution sources in providing Swap and may select, change or discontinue such execution sources in its discretion. CHW is not required to disclose its execution venue, routing methodology, liquidity sources or pricing methodology except where required by Applicable Law. The User has no direct contractual relationship with an execution venue solely because CHW uses that venue in connection with a Swap. CHW does not operate a user-to-user order book or match the User’s Swap Order against orders of other Users under the Converter Service.CHW does not undertake to survey all available markets or venues or to obtain the best price available in any market. The transaction price applicable to the User is the price confirmed through the Platform in accordance with Section 5.1.2.

5.1.5. Without limiting Section 3.8, CHW may reject, cancel, defer or decline to execute a Swap Order where, among other things:

(a) the quote has expired;

(b) sufficient liquidity is unavailable at the confirmed price;

(d) an applicable limit, eligibility requirement or risk control is not satisfied;

(e) an external execution or liquidity venue rejects, cancels or is unable to execute the transaction;

(f) a technical, pricing, market, security or operational issue affects the transaction; or

(g) execution is restricted under these ToS, the KYC/AML Policy or Applicable Law.

Where a Swap Order is rejected or cancelled without execution, any amount reserved solely for that Order shall be released or restored to the User’s Account Balance, subject to any independent hold, restriction, set-off or other right applicable under these ToS.

5.1.6. If, notwithstanding the intended fill-or-kill execution of a Swap Order, an external venue, technical failure, reconciliation issue or other exceptional event results in an incomplete, duplicate, erroneous or otherwise irregular execution, CHW may take such reasonable corrective action as it considers appropriate, including completing, cancelling, unwinding, correcting or reflecting the actually executed portion of the transaction in the Account. Nothing in this Section requires CHW to execute any unexecuted portion at a price less favorable to the User than the confirmed price without the User’s further confirmation.

5.1.7. Upon successful execution of a Swap, CHW shall debit the applicable source Digital Asset and credit the resulting Digital Asset to the User’s Account Balance in accordance with its reconciled records. A completed Swap is final and may not be cancelled or reversed by the User solely because the market price of either Digital Asset subsequently changes. CHW retains its rights to correct manifest, duplicate or erroneous entries and to take any action otherwise permitted under Sections 3.8, 4.7 or these ToS.

5.1.8. User is solely responsible for reviewing the Digital Asset pair, amount, quoted rate, resulting amount and other transaction terms displayed before confirming a Swap Order. Any external market price, chart, reference rate, historical price or other market information displayed through the Platform is informational only and does not replace the transaction-specific quote confirmed by the User.

5.2. Ramps

5.2.1. CHW may make available through the Platform functionality enabling the User to access fiat-to-Digital Asset and Digital Asset-to-fiat conversion services provided by independent Third-Party Providers (the “Ramps”). The availability of Ramps through the Platform is a technical integration and does not mean that CHW provides the underlying fiat payment, acquiring, banking or conversion service. CHW may determine which Third-Party Providers, fiat currencies, Digital Assets, payment methods, jurisdictions and transaction types are available through Ramps from time to time.

5.2.2. The fiat payment and conversion component of each Ramp transaction is provided directly by the applicable Third-Party Provider and is subject to that Third-Party Provider’s terms, eligibility requirements, fees, compliance procedures and other conditions.

5.2.3. Unless expressly stated otherwise, CHW:

(a) is not the merchant of record in respect of a fiat payment made through a Ramp;

(b) does not receive or hold fiat funds on behalf of the User;

(d) does not itself acquire or sell Digital Assets for fiat currency as principal through the Ramps; and

(e) does not act as guarantor of the obligations of the Third-Party Provider.

The User is responsible for reviewing and accepting the terms of the applicable Third-Party Provider before using a Ramp. In a fiat-to-Digital Asset transaction, the User makes the relevant fiat payment directly through the applicable Third-Party Provider. If the Third-Party Provider accepts the transaction, converts the relevant fiat amount and transfers the resulting Digital Assets to an address designated by CHW for the transaction, CHW shall, subject to these ToS and its applicable controls, credit the corresponding Digital Assets to the User’s Account Balance. Receipt of a payment instruction, payment authorization or other confirmation from a Third-Party Provider does not require CHW to credit Digital Assets before CHW has received and reconciled the relevant Digital Asset transfer and completed any security, compliance or other controls applicable under these ToS.

5.2.4. In a Digital Asset-to-fiat transaction, the User authorizes CHW to debit the relevant Digital Assets from the User’s Available Balance and to transfer them to the blockchain address or other destination designated by the applicable Third-Party Provider for purposes of completing the requested conversion. Following the relevant transfer, responsibility for conversion of the Digital Assets and payment of fiat currency to the User rests with the Third-Party Provider under its applicable terms. CHW does not guarantee that the Third-Party Provider will complete, approve or settle the fiat payment after CHW has transferred the relevant Digital Assets.

5.2.5. The exchange rate, payment charges, conversion fees, spreads or other economic terms applicable to the fiat component of a Ramp transaction are determined by or through the applicable Third-Party Provider and are displayed through the relevant transaction flow. CHW does not currently charge a separate fee for providing access to the Ramps unless expressly disclosed through the Platform before the relevant transaction. A Third-Party Provider’s fees or spread may be incorporated into the exchange rate or resulting transaction amount and need not be separately charged by CHW. Network Fees associated with a blockchain transfer may be borne by CHW, the Third-Party Provider or reflected in the transaction economics, depending on the relevant Ramp and transaction flow.

5.2.6. A Third-Party Provider may reject, delay, suspend or cancel a Ramp transaction, request additional information or documentation, impose transaction limits or otherwise restrict its services under its own terms and compliance procedures.Without limiting Section 3.8, CHW may also reject, defer, suspend or restrict the Wallet-side component of a Ramp transaction where permitted under these ToS, including where:

(a) CHW has not received the relevant Digital Assets;

(b) the relevant transaction cannot be reconciled;

(d) a security, fraud, AML/CFT, sanctions or other compliance review is pending;

(e) the applicable Third-Party Provider requests or requires that action;

(f) a blockchain or Supported Network issue affects the transaction; or

(g) CHW otherwise has grounds to act under these ToS or Applicable Law.

The timing of a Ramp transaction may therefore depend on the Third-Party Provider, payment networks, banks, Supported Networks and compliance or security reviews. CHW does not guarantee any particular processing or settlement time for a Ramp transaction.

5.2.7. If, after Digital Assets have been credited to the User’s Account in connection with a fiat-to-Digital Asset transaction, the underlying fiat payment is subsequently charged back, reversed, cancelled, determined to be unauthorized or fraudulent, or otherwise invalidated by the applicable Third-Party Provider, payment network, acquiring bank or other relevant participant, CHW may, to the extent permitted by Applicable Law and without assuming responsibility for the underlying fiat payment dispute:

(a) place a hold or restriction on the relevant Digital Assets or an equivalent amount;

(b) reverse or correct the corresponding credit to the User’s Account Balance where the relevant Digital Assets remain available;

(c) set off or recover an equivalent amount from any balance or amount otherwise due to the User under these ToS or applicable Product Terms;

(d) restrict withdrawals or other Services pending resolution of the matter; and/or

(e) require the User to reimburse CHW for any corresponding Digital Assets, amounts, losses or charges properly attributable to the invalidated transaction.

The exercise of these rights does not make CHW a party to, or responsible for resolving, the underlying card, bank or payment dispute.

5.2.8. Any refund, cancellation or return relating to the fiat component of a Ramp transaction is subject to the rules and approval of the applicable Third-Party Provider and other payment participants. CHW does not guarantee that a Ramp transaction may be refunded, cancelled or reversed after it has been initiated or completed. Where a refund or corrective transaction is available, CHW and the applicable Third-Party Provider may determine the method by which it is processed, including whether any corresponding adjustment is made in fiat currency, Digital Assets or by reversal or correction of an Account entry, subject to Applicable Law and the applicable Third-Party Provider terms. The User shall have no right to require CHW to provide a fiat refund where CHW did not receive the relevant fiat funds.

5.2.9. CHW is not responsible for the independent acts or omissions of a Third-Party Provider, bank, card issuer, acquirer, payment network or other third party involved in the fiat component of a Ramp transaction, including any refusal, delay, chargeback, refund decision, payment hold, account restriction or compliance decision made by such person.

Nothing in this Section excludes responsibility of CHW for the Wallet-side component of a Ramp transaction to the extent such responsibility cannot be excluded under these ToS or Applicable Law.

5.2.10. Ramps are separate from any payment-card services governed by Section 6. The use or availability of a Ramp does not amend the terms applicable to the CHW Card or any card-related service.

5.3. Grow

5.3.1. CHW may make available functionality through which the User may allocate Supported Digital Assets from the User’s Available Balance to a Grow and become eligible to receive contractual reward amounts (the “Rewards”) in accordance with this Section 5.3 and the applicable Product Terms (the “Grow Services”). The User may request a Grow through the authenticated Platform flow by selecting the applicable Digital Asset, amount, plan type and such other parameters as are made available for selection. CHW has no obligation to accept any Grow, top-up, renewal, withdrawal or other instruction. A Grow becomes effective only when CHW accepts the User’s request and completes the corresponding internal debit from the User’s Account Balance and allocation to the Grow. The authenticated electronic record maintained through the Account in respect of each accepted Grow (the “Grow Record”) records the transaction-specific parameters applicable to that Grow. Absent manifest error or fraud, the Grow Record and CHW’s final reconciled records constitute evidence of those parameters and of the relevant allocations, withdrawals, Rewards and other entries.

5.3.2. CHW may offer one or more of the following Grow plans:

(a) Fixed, under which the User selects a fixed period (the “Term”) and, except as expressly permitted by CHW under Section 5.3.7, has no contractual right to withdraw or close the Grow before expiry of that Term;

(b) Flex, under which the User selects a fixed Term but may request a full or partial withdrawal or closure before expiry of that Term, subject to this Section 5.3 and the applicable Product Terms; and

(c) Full Flex, which has no fixed Term and under which the User may request a full or partial withdrawal or closure at any time, subject to this Section 5.3 and the applicable Product Terms.

Available Terms may include 30, 90, 180 and 360 days and such other Terms as CHW may make available from time to time. For the avoidance of doubt, the designation “Fixed” describes the applicable Term and withdrawal conditions and does not, by itself, mean that the rate applicable to that Grow is fixed for the entire Term. A rate is fixed only where this is expressly stated in the applicable Grow Record.

5.3.3. Upon completion of the internal debit and allocation of Digital Assets to a Grow, full legal and beneficial title to, and ownership of, the Digital Assets so allocated (the “Placed Assets”) passes to CHW absolutely and unconditionally. From that moment, the Placed Assets are the property of CHW and are no longer held for the User under the custodial arrangement described in Section 4. The User retains no proprietary, equitable, trust or custody interest in any particular Placed Asset, wallet, blockchain address or asset derived from CHW’s use of the Placed Assets. In consideration of that transfer, the User acquires an unsecured contractual claim against CHW for the credit to the User’s Account Balance of Digital Assets of the same type and quantity as the Placed Assets, as adjusted in accordance with this Section 5.3 and the applicable Product Terms, together with any Rewards properly payable to the User. That claim is not secured, guaranteed or insured by any person.

5.3.4. CHW may hold, use, commingle, rehypothecate, deploy, sell, lend, stake, pledge, invest or otherwise deal with Placed Assets for its own account, in its own name and at its own risk and benefit, without accounting to the User for any profit generated from such activity, subject to CHW’s obligations under this Section 5.3. The User irrevocably authorizes CHW to deal with the Placed Assets in such manner as CHW considers appropriate in connection with the Grow Services. No public statement, description, article, FAQ, marketing material or other general information concerning the manner in which CHW may generate Rewards, deploy assets or manage its treasury or liquidity restricts the rights granted to CHW under this Section unless expressly incorporated into the applicable Product Terms or Grow Record.

5.3.5. Rewards are calculated by reference to the annualized rate applicable to the relevant Grow from time to time (the “Applicable Rate”) and the other parameters applicable to that Grow. Unless otherwise stated in the applicable Product Terms or Grow Record:

(a) Rewards are calculated on a daily basis; and

(b) accrued Rewards are credited or capitalized every thirty (30) calendar days.

Rewards may be capitalized into the relevant Grow or, where CHW makes such functionality available, credited to the User’s Account Balance. The Applicable Rate may differ by Digital Asset, Grow plan, Term, amount, eligibility or other criteria determined by CHW.

CHW may change the Applicable Rate prospectively at any time, including in respect of an existing Grow, unless the applicable Grow Record expressly states that the Applicable Rate is fixed for a specified period. Any change applies only to subsequent accrual periods and does not retrospectively alter Rewards already finally credited, except in the case of manifest error, fraud or another adjustment expressly permitted under these ToS.

Any rate displayed outside the authenticated Grow flow, including any public, promotional, historical, “up to” or illustrative rate, is informational only and does not create a right to that rate. Special or enhanced rates may be subject to additional eligibility requirements, minimum amounts, availability, approval by CHW or other conditions and do not become binding until reflected in an accepted Grow Record.

No Applicable Rate or historical Reward constitutes a representation that the same or any other rate will continue or be available in the future. The actual amount and economic value of Rewards may vary and no fiat-denominated return is guaranteed.

5.3.6. To the maximum extent permitted by Applicable Law, CHW may determine and modify from time to time, in relation to the Grow Services:

(a) Supported Digital Assets;

(b) available plan types and Terms;

(d) aggregate or individual Grow limits and available capacity;

(e) subscription and top-up limits;

(f) Applicable Rates and rate tiers;

(g) withdrawal, closure and redemption conditions or limits;

(h) renewal functionality and conditions;

(i) eligibility requirements;

(j) Fees or other charges; and

(k) any other operational or product parameter applicable to the Grow Services.

Unless expressly stated otherwise in the applicable Grow Record, such parameters may be changed prospectively and may apply to existing Grows to the extent specified by CHW through the Platform or otherwise permitted under this Section 5.3.

5.3.7. Withdrawals and Closure.

(a) Fixed. A Fixed Grow is intended to remain outstanding until expiry of its Term. The User has no contractual right to an early withdrawal or closure. CHW may, in its sole discretion, permit early closure of a Fixed Grow following a request submitted through CHW support. CHW may refuse such request without giving reasons. Where CHW permits early closure of a Fixed Grow, all Rewards accrued, credited or capitalized in respect of that Grow from its commencement may be forfeited, reversed or deducted before the remaining Placed Assets are credited to the User’s Account Balance. Any such early closure is also subject to the security hold described below and to any other applicable restriction under these ToS.

(b) Flex. The User may request a partial withdrawal or full closure of a Flex Grow before expiry of its Term, subject to applicable Product Terms, limits and controls. Unless otherwise stated in the applicable Product Terms or Grow Record, a Flex Grow may be renewed automatically upon expiry at the then-current Applicable Rate and other parameters available at the time of renewal. A renewed Grow is treated as a new Grow for purposes of the applicable rate and product parameters.

(c) Full Flex. The User may request a partial withdrawal or full closure of a Full Flex Grow at any time, subject to applicable Product Terms, limits and controls.

(d) Security hold. An unscheduled withdrawal or early closure of a Grow is subject to a twenty-four (24) hour security hold. Expiry of that security hold does not require CHW to complete the withdrawal or closure while any independent compliance, security, legal, technical or other restriction permitted under these ToS remains applicable.

The treatment of Rewards relating to an amount withdrawn or closed before a scheduled maturity shall be determined in accordance with the applicable Grow plan, Product Terms and Grow Record.

5.3.8. Upon scheduled maturity or effective processing of a permitted withdrawal or closure, CHW shall discharge the corresponding Grow obligation by making an internal credit of the relevant Digital Assets to the User’s Account Balance, subject to this Section 5.3, Section 3.8 and any amount properly deductible or subject to set-off under these ToS. An internal credit to the Account Balance is not an on-chain withdrawal. Any subsequent withdrawal from the Wallet Services is a separate transaction governed by Section 4. CHW does not guarantee any particular processing time for maturity, closure, withdrawal or credit to the User’s Account Balance

5.3.9. Without limiting Section 3.8, CHW may defer, restrict, suspend or decline any new Grow, top-up, renewal, withdrawal, closure, Reward credit or credit to the User’s Account Balance, in whole or in part, where CHW considers this necessary or appropriate due to:

(a) Applicable Law, Sanctions or an order, request or requirement of a competent authority;

(b) an AML/CFT, fraud, security or other compliance review;

(d) an event described in Section 5.3.10, Supported Network disruption or material technical or operational issue;

(e) an actual or suspected error, unauthorized activity or abuse;

(f) circumstances affecting CHW’s ability to safely or orderly operate the Grow Services; or

(g) any other circumstance in which CHW is entitled to act under these ToS.

A right to request withdrawal under a Flex or Full Flex Grow does not limit CHW’s rights under this Section. A suspension or deferral does not, by itself, extinguish amounts otherwise properly due to the User, but the accrual or treatment of Rewards during the relevant period may be adjusted where required by Applicable Law or the applicable Product Terms.

5.3.10. In the event of a fork, chain split, migration, token swap, redenomination, rebase, airdrop, protocol upgrade, exploit, network halt, delisting, cessation of support or other material technical or structural event affecting a Placed Asset or Supported Network (an “Asset Event”), CHW may determine the treatment of the affected Grow in a commercially reasonable manner. Because title to Placed Assets belongs to CHW, the User has no entitlement to any forked asset, airdrop, voting right or other asset, distribution or benefit derived from a Placed Asset unless CHW expressly determines otherwise. CHW may, where appropriate:

(a) adjust the denomination or quantity recorded in respect of the affected Grow following a migration, redenomination, rebase or comparable event;

(b) suspend new Grows, top-ups, withdrawals, renewals or other activity involving the affected Digital Asset;

(d) where continued settlement in the affected Digital Asset is impossible, unlawful or no longer reasonably practicable, settle the corresponding obligation in another reasonably equivalent Digital Asset at a rate determined by CHW by reference to available market information.

5.3.11. Section 4.7 applies to Grow Records, Rewards and credits to the User’s Account Balance. CHW may correct any manifest, calculation, system, processing or other error affecting a Grow or Reward, including by correcting the Grow Record, reversing or adjusting an erroneous Reward or credit to the User’s Account Balance or debiting an amount credited in error. Where an amount credited in error has already been withdrawn, transferred or otherwise used, the User shall remain liable to CHW for the equivalent amount.

5.3.12. Grow is not a bank deposit, savings account or other bank account. Placed Assets are not held in custody, on trust, in escrow or on a segregated basis for the User. Neither the Grow Services nor CHW’s use of Placed Assets creates a fiduciary, trustee, investment-management or advisory relationship between CHW and the User. The User has no right to participate in, receive information regarding, or receive any particular return from CHW’s use of Placed Assets other than the contractual rights expressly provided under this Section 5.3 and the applicable Product Terms. The User must review the applicable Risk Disclosures before using the Grow Services.

5.3.13. CHW may restrict, suspend, modify or discontinue some or all of the Grow Services in accordance with Sections 1, 3.8 and 13, including where continued provision of the Grow Services becomes or may become subject to additional legal or regulatory requirements or otherwise creates legal, regulatory, compliance, liquidity, security, operational or other material risk. Where practicable and lawful, CHW may establish such wind-down, withdrawal, conversion or settlement arrangements as it considers appropriate for affected Grows.

5.4. Portfolio

5.4.1. CHW may make available functionality enabling the User to acquire, increase, partially dispose of or fully dispose of a pre-defined basket of Supported Digital Assets through a single authenticated transaction flow (the “Portfolio”). Each Portfolio displays the underlying Digital Assets and the proportions applicable to the relevant basket. The User independently determines whether, when and in what amount to submit a Portfolio Order. A Portfolio does not constitute a separate Digital Asset. The User acquires an entitlement to the underlying Digital Assets actually acquired and recorded for the User in accordance with this Section and Section 4.

5.4.2. CHW does not provide discretionary portfolio management, investment management, asset management, investment advice or rebalancing through Portfolio. CHW does not make decisions on behalf of the User as to whether, when or in what amount the User should acquire, hold or dispose of any Digital Asset. The composition and proportions displayed for a Portfolio constitute pre-defined transaction parameters applicable to the relevant Portfolio Order and do not create an obligation on CHW to monitor, maintain or restore those proportions after execution. Changes in the market value of the underlying Digital Assets may cause the relative proportions of the Digital Assets held by the User to differ from the proportions originally displayed. CHW does not automatically or discretionarily rebalance the User’s holdings as a result.

5.4.3. The Platform may display information concerning a Portfolio, including: (a) its underlying Digital Assets and proportions; (b) an indicative or current aggregate value; (c) the User’s entry price or acquisition cost; (d) the current estimated value of the relevant holdings; (e) historical or current performance information; and (f) estimated Fees or slippage. Such information may be calculated using market data obtained from an external execution venue or other market-data source and is provided for informational and transaction-interface purposes only. A displayed Portfolio value, entry price, performance figure or other reference value is not a guaranteed execution, redemption or settlement price and does not constitute investment advice, a recommendation or a representation regarding future performance.

5.4.4. By confirming a Portfolio purchase or increase, the User authorizes CHW to debit or reserve the relevant amount of the settlement Digital Asset from the User’s Available Balance and to execute the transactions necessary to acquire the underlying Digital Assets in the proportions applicable to the relevant Portfolio Order. By confirming a partial or full disposal, the User authorizes CHW to dispose of the corresponding underlying Digital Assets and credit the resulting settlement Digital Asset to the User’s Account Balance following completion and reconciliation of the relevant transactions. A Portfolio Order may therefore comprise multiple underlying Orders in different Digital Assets. Unless otherwise displayed through the applicable transaction flow, a partial disposal may be implemented by disposing of corresponding proportions of the underlying Digital Assets held in connection with the Portfolio.

5.4.5. The aggregate value displayed for a Portfolio before execution may be based on current market data and the displayed composition of the basket. Actual acquisition or disposal occurs through execution of the underlying component Orders and may therefore be affected by executable market prices, liquidity, Fees, slippage, minimum order sizes, price increments and other execution conditions applicable at the relevant time. CHW may execute Portfolio Orders through one or more external execution venues selected by CHW. CHW may use a single execution venue for all or part of a Portfolio Order and is not required to route Orders between multiple venues, survey all available markets or obtain the best price available in any market. Underlying Orders are intended to be transmitted for execution on a fill-or-kill basis where supported by the relevant execution venue. No displayed Portfolio value, submission of a Portfolio Order or confirmation by the User constitutes an unconditional guarantee that all underlying component Orders will be executed.

5.4.6. Without limiting Sections 3.8 and 5.1, CHW may reject, cancel, defer or decline to execute a Portfolio Order where:

(a) sufficient liquidity is unavailable; (b) the User has insufficient Available Balance or relevant underlying Digital Assets; (c) a component Order cannot be executed on the applicable terms; (d) the applicable execution venue rejects, cancels or is unable to execute a component Order; (e) a relevant Digital Asset, trading pair or execution venue is unavailable; (f) an applicable limit, eligibility requirement, compliance or risk control is not satisfied; (g) sufficient operational liquidity or funding is unavailable to process the relevant transaction; or (h) a technical, pricing, market, security or operational issue affects execution. Where an external execution venue, technical failure, reconciliation issue or other exceptional circumstance results in an incomplete, duplicate, erroneous or otherwise irregular execution, CHW may take such reasonable corrective action as it considers appropriate, including cancelling, completing, unwinding, correcting or recording the actually executed component transactions. Nothing in this Section requires CHW to execute an unexecuted component Order at a price or on terms that were not accepted by the User.

5.4.7. Digital Assets acquired pursuant to a Portfolio Order shall be recorded in CHW’s internal records as attributable to the User and remain subject to the custodial treatment set out in Section 4. CHW may hold corresponding Digital Assets through wallets, accounts or sub-accounts maintained or used by CHW with an external execution venue or other Third-Party Provider for custody, execution, settlement or operational purposes. The User does not acquire a direct contractual relationship with, or a direct right against, an external execution venue solely because CHW uses that venue in connection with Portfolio. Any operational segregation, separate accounting or use of a dedicated account or sub-account by CHW does not, by itself, create a trust, fiduciary relationship or other legal arrangement different from that expressly provided under these ToS.

5.4.8. Fees applicable to a Portfolio transaction shall be displayed or otherwise disclosed through the relevant transaction flow before the User confirms the Portfolio Order. Fees may be deducted from the amount submitted for acquisition, from the underlying Digital Assets, from disposal proceeds or otherwise reflected in the transaction economics as displayed through the Platform.

5.4.9. CHW may add, modify, suspend or discontinue any Portfolio, its displayed composition, proportions, Supported Digital Assets, limits or other product parameters from time to time in accordance with Section 1. Unless the User expressly submits a new Portfolio Order, a subsequent change to the composition or proportions displayed for a Portfolio does not itself cause CHW to purchase, sell or rebalance Digital Assets already recorded for that User. Notwithstanding the foregoing, CHW may take action otherwise permitted under these ToS where a Digital Asset or Supported Network is suspended or discontinued, an Asset Event or material technical event occurs, or action is required or reasonably considered necessary under Applicable Law, the KYC/AML Policy or Section 3.8.

5.4.10. Upon completion and reconciliation of a Portfolio Order, the resulting debits and credits shall be reflected in CHW’s internal records. A completed Portfolio acquisition or disposal may not be cancelled or reversed by the User solely because the market value of the relevant Digital Assets subsequently changes. Any profit, loss, percentage return or other performance information displayed through Portfolio is calculated by reference to available Account and market data and is informational only. Actual disposal proceeds may differ as a result of market movements, Fees, slippage and execution conditions.

6. CHW Card

6.1. CHW Card (the “Card”) is Mastercard (the “Payment Processors”) debit card that can be used worldwide wherever Payment Processors are accepted by merchant. CHW card is issued by METABANK INC, a company registered in the United States with Document # 20231581273, operating under the KazePay brand (the “KazePay”). To use the Card, you must agree to the General terms and to the KazePay terms and conditions located at https://kazepay.io/terms-and-conditions/ (the “KazePay Terms”).

6.2. The user has the right to apply for a Card after accepting the terms and conditions and completing the KYC procedure in their personal Account. CHW has the right not to disclose the reasons for refusing to issue a Card. If at any point you fail to comply with KYC requirements, CHW reserves the right to suspend your access to the Card until the circumstances are clarified.

6.3. You must be at least 18 years old to apply for CHW Card. If CHW finds out that the User is under 18 years of age, access to the Card will be suspended and the funds frozen.

6.4. You agree to familiarize yourself with the information about the supported cryptocurrency in your Account. You hereby authorise CHW to facilitate the transfer of your cryptocurrency, the proceeds of which you authorise CHW to use to fund card transactions in USD.

6.5. The Card can be used to purchase goods and services from merchants at point-of-sale terminals, over the telephone, online, or on payment platforms, that accept Payment Processors cards (“Card Transactions”). The Card is denominated in USD. Any other currency of Card Transactions will convert the sum using the exchange rate of KazePay. Operator may charge commission for conversion of Card Transactions.

6.6. The Card may only be used by the Cardholder and must not be transferred, assigned, or otherwise made available to any third party.

6.7. You shall take all reasonable measures to safeguard the Card, Personal Identification Number (PIN), and any authentication credentials. You shall not disclose the PIN or other access codes to any unauthorized person. You are solely responsible for any transactions resulting from the loss, theft, or misuse of the Card or credentials.

6.8. You agree not to use the Card for any unlawful purpose, including but not limited to online gambling or the purchase of prohibited goods or services. KazePay reserves the right to decline transactions that it deems suspicious, unauthorized, or non-compliant with applicable laws or internal risk policies.

6.9. Transaction and withdrawal limits may apply to the use of the Card, and such limits may be modified from time to time. Card limits are displayed in your Account.

6.10. You must promptly notify CHW of any suspected unauthorized transaction or security breach.

6.11. The maximum execution time of the Card Transaction itself is dependent on actions being taken by the merchant, card scheme and/or other service providers. Operator will use commercially reasonable endeavors to comply with and adhere to the card scheme’s settlement timing requirements. However, in any case, CHW cannot be held liable for any losses or damages caused by the timing of the transaction.

6.12. Restriction, Suspension, and Termination of Card

6.12.1. CHW reserves the right, at its sole discretion and without prior notice, to restrict or suspend the ability to use the Card, in whole or in part, where:

a) there is a reasonable suspicion of fraudulent, unauthorized, or illegal use of the Card;

b) the User is in material breach of this ToS or any applicable laws or regulations;

c) the User account is overdrawn, frozen, closed, or subject to a legal or regulatory hold;

d) there are operational, technical, or security-related issues that, in CHW’s reasonable opinion, necessitate such restriction or suspension to protect the integrity of the Platform.

6.12.2. The User may refuse to use the Card at any time by blocking the Card in the Account on the Platform.

6.12.3. Upon restriction, suspension, or termination of the Card:

a) the Card shall immediately be rendered inactive and may no longer be used for any transactions;

b) the User remains liable for all transactions and obligations incurred prior to such action;

c) the KazePay may cancel any pending or pre-authorized transactions that have not yet been settled.

6.12.4. Reinstatement of Card privileges, if applicable, shall be at the sole discretion of the KazePay and may be subject to verification procedures, resolution of the underlying issue, or satisfaction of any outstanding obligations.

6.13. In the event of a conflict between this ToS, and the KazePay Terms, the provisions of the KazePay Terms shall prevail.

6.14. Operator will not be liable to you for any loss arising from

6.14.1. A merchant refusing to accept a Card;

6.14.2. KazePay restricting, suspending, or terminating a Card or refusing to issue or replace a Card in accordance with these ToS;

6.14.3. KazePay declining a Card Transaction that you make or attempt to make using a Card;

6.14.4. Operator restricting, suspending, or terminating your any related Services; or

6.14.5. Operator compliance with any applicable laws and regulations.

7. Limitation of Operator Liability. ToS Breach.

7.1. CHW shall provide the Platform and the Services for which it is expressly responsible under these ToS and applicable Product Terms with commercially reasonable skill and care. Except as expressly provided in these ToS or applicable Product Terms, the Platform and the Services are made available on an “as available” basis. To the maximum extent permitted by Applicable Law, CHW makes no other express or implied representation, warranty or guarantee regarding the Platform or the Services, including as to uninterrupted availability, continuous operation, fitness for a particular purpose, availability of any particular functionality, Digital Asset or Supported Network, or the completion, timing or outcome of any transaction. Nothing in these ToS constitutes a guarantee that any withdrawal, deposit, Converter transaction, Portfolio Order, Ramp transaction, Grow transaction or other operation will be accepted, processed or completed.

7.2. To the maximum extent permitted by Applicable Law, CHW shall not be liable for any indirect, incidental, special, consequential or punitive loss or damage, or for any loss of profit, revenue, business, opportunity, anticipated savings, goodwill or data, whether or not foreseeable and however arising. CHW shall not be liable for any loss or damage to the extent arising from or attributable to:

(a) the performance, congestion, delay, failure, fork, reorganization, exploit, defect, suspension or other behaviour of any blockchain, protocol, Supported Network, smart contract, validator, miner or other network participant;

(b) market movements, volatility, liquidity conditions, inability to transact at a particular price or the loss of value or convertibility of any Digital Asset, including a stablecoin ceasing to maintain its intended value or peg;

(c) any incorrect, incomplete or unauthorized Instruction submitted through the User’s Account, or the User’s failure to verify an address, Supported Network, Digital Asset, amount, recipient, MEMO, destination tag or other transaction information;

(d) the loss, compromise or misuse of the User’s credentials, authentication factors, devices or recovery information, except to the extent directly caused by CHW’s breach of its obligations under these ToS;

(e) the acts or omissions of a Third-Party Provider, external execution venue, liquidity provider, bank, card issuer, acquirer, payment network or other independent third party, except to the extent CHW has expressly assumed responsibility for the relevant act or obligation under these ToS or applicable Product Terms;

(f) an action, restriction, suspension, deferral, rejection, cancellation, correction or other measure expressly permitted under these ToS or applicable Product Terms;

(g) the User’s breach of these ToS, applicable Product Terms or Applicable Law;

(h) any event or circumstance described in Section 13.8; or

(i) any event or circumstance outside CHW’s reasonable control.

Nothing in this Section 7.2 excludes or limits liability for fraud or willful misconduct or any other liability that cannot lawfully be excluded or limited.

7.3. You hereby agree:

7.3.1. to fully indemnify and hold harmless CHW, the App Store Publisher, their respective directors, employees, partners, affiliates and service providers for any cost, expense, loss, damages, claims, liabilities, and expenses, including legal fees and any other charges whatsoever, howsoever caused that may arise in relation to your use of the Platform.

7.3.2. that CHW may recover compensation for damages and losses incurred through your fault from your account on the Platform. The amount will be proportionate and appropriate to the loss incurred.

7.4. Except to the extent expressly provided in the P2P Services ToU with respect to P2P Transaction Support Services provided by EMCD FINTECH CORP., the Bulletin Board Operator is not a party to any P2P transaction between Users. The Bulletin Board Operator provides only P2P Bulletin Board Services and has no right or obligation to hold, release, return, settle, process or otherwise administer any Digital Assets or fiat payments. Any dispute relating to Digital Asset escrow, release, return, payment evidence, suspected fraud, suspected illegality, sanctions exposure, AML/CFT concerns or transaction-support actions shall be handled in accordance with the P2P Services ToU by EMCD FINTECH CORP., where applicable. No service provider shall assume any financial or non-financial obligations or responsibilities of another entity, except as expressly provided in the applicable Product Terms.

7.5. The identification of the App Store Publisher as the developer, seller, publisher, distributor or other app-store-facing entity for the Platform mobile application does not constitute a representation that the App Store Publisher provides, controls, guarantees or assumes liability for the Services. The provider of a Service shall be determined by these ToS and the applicable Product Terms, irrespective of any app-store listing, developer account, distribution arrangement or similar technical or administrative designation.

7.6. If you believe a third party has behaved in a fraudulent, misleading or inappropriate manner, or if you cannot adequately resolve a dispute with a third party, you may notify the relevant support channel identified within the Platform or the applicable Product Terms. Any such notification does not make the Bulletin Board Operator a party to the underlying P2P transaction and does not expand any obligation of CHW beyond the obligations expressly undertaken by CHW under the P2P Services ToU, where applicable. Any dispute or loss caused by a User’s failure to amend or confirm the transaction status, provide relevant information, submit an application or respond in a timely manner shall be borne by that User, except as otherwise expressly provided in the P2P Services ToU.

7.7. Where functionality accessible through the Platform is supplied directly by a Third-Party Provider, that Third-Party Provider remains responsible for the obligations it independently assumes toward the User. CHW does not assume, guarantee or become liable for the independent obligations of a Third-Party Provider merely because CHW:

(a) makes the relevant functionality accessible through the Platform;

(b) technically integrates with that Third-Party Provider;

(d) provides Wallet functionality used in connection with the third-party service; or

(e) provides support or assistance in connection with a transaction involving that Third-Party Provider.

Nothing in this Section limits any obligation expressly assumed by CHW under Sections 4, 5 or 6.

7.8. If the User believes that a Third-Party Provider or another third party has acted fraudulently, incorrectly or otherwise improperly in connection with functionality accessed through the Platform, the User may contact CHW through the support channels made available on the Platform. CHW may, in its sole discretion, review the matter, request information or documentation from the User or communicate with the relevant Third-Party Provider, but provision of such assistance does not make CHW a party to the underlying transaction or create an obligation to resolve the dispute, reimburse the User or procure any particular outcome. This Section does not limit any express obligation of CHW in respect of the Wallet-side component of a transaction under these ToS.

7.9. CHW shall not be responsible for any withdrawal, deposit, Converter Order, Portfolio Order, Ramp transaction, Grow instruction, access request or other action that is rejected, suspended, delayed, restricted or cancelled because it has not passed or remains subject to applicable AML/CFT, sanctions, fraud-prevention, security, platform-integrity, verification or other compliance procedures. The User acknowledges that CHW may be unable or not permitted to disclose the existence, basis, status or expected duration of certain compliance reviews or restrictions. Nothing in this Section limits CHW’s obligations once the relevant restriction has ceased to apply, except as otherwise provided in these ToS, applicable Product Terms or Applicable Law. Where P2P Transaction Support Services are used, any refund, return, deduction of fees, deduction of costs or rejection mechanics shall be governed by the P2P Services ToU and administered by EMCD FINTECH CORP., where applicable.

7.10. CHW or service provider shall not be responsible for transactions, instructions, releases, returns, access requests or other actions that have not passed applicable AML/CFT, sanctions, fraud-prevention, platform-integrity or compliance procedures and have therefore been rejected, suspended, delayed, restricted or cancelled. Where P2P Transaction Support Services are used, any refund, return, deduction of fees, deduction of costs or rejection mechanics shall be governed by the P2P Services ToU and administered by EMCD FINTECH CORP., where applicable.

7.11. To the extent permitted by Applicable Law, CHW may set off any matured amount due from the User to CHW under these ToS or applicable Product Terms against any amount otherwise payable or creditable by CHW to the User. Where amounts are denominated in different Digital Assets or currencies, CHW may make any conversion reasonably necessary for the set-off at a commercially reasonable rate determined by reference to available market information at the relevant time. Without limiting any specific right under Section 5.2, this Section may apply to amounts properly recoverable from the User as a result of erroneous or duplicate credits, invalidated or reversed transactions, chargebacks, amounts paid or credited by mistake, Fees, indemnified amounts or other amounts due under these ToS or applicable Product Terms. The exercise of a contractual set-off or recovery right does not, by itself, alter CHW’s legal capacity or make CHW a party to any underlying transaction or dispute to which it is not otherwise a party.

7.12. The User must adhere to the following rules when communicating with Support Team and other users of the platform:

a) do not allow aggressive behavior;

b) act politely and with respect;

c) do not insult, do not threaten or blackmail any member of the Support Team and other users of the platform.

In case of violation, CHW may suspend the provision of technical support services. In case of systematic violation (two or more times) CHW can block the User's account.

8. Supported Digital Assets and Networks

The Services are available only in respect of Supported Digital Assets and Supported Networks applicable to the relevant Service. CHW may add, remove, suspend or otherwise change any Supported Digital Asset or Supported Network from time to time. Where practicable, CHW will use commercially reasonable efforts to provide advance notice of a material discontinuation of support. The User is solely responsible for confirming, through the Platform, that the relevant Digital Asset and network are supported for the intended transaction before transferring any Digital Asset. CHW shall not be responsible for the User’s attempt to use an unsupported Digital Asset or unsupported network except as expressly provided in this Section 8.

8.1. CHW may add Supported Digital Assets or Supported Networks to the Wallet Services or any other Service from time to time. Unless expressly stated otherwise, CHW does not own, develop, control, sponsor or endorse any Digital Asset, blockchain protocol or Digital Asset project merely because it is supported or made available through the Platform. The fact that a Digital Asset is supported, displayed or otherwise available through the Platform does not constitute: (a) a recommendation or endorsement of that Digital Asset; (b) a guarantee of its liquidity, market value, security, functionality or continued availability; (c) confirmation that the Digital Asset is lawful or appropriate for the User in any jurisdiction; or (d) an obligation on CHW to support that Digital Asset or any particular network in connection with all or any other Services.

8.2. You acknowledge and agree that:

(a) you have read, understood and accepted all of the terms and conditions and risks associated with each particular cryptocurrency before entering into any transaction relating to that cryptocurrency, and;

(b) Operator does not and will not in any circumstances have any obligation whatsoever to purchase, repurchase or effect or facilitate the redemption of your cryptocurrency. We reserve the right to change, suspend, or discontinue any service in relation to any cryptocurrency or Supported Network at any time at our sole discretion.

8.3. By using a Service in relation to a Supported Digital Asset, you acknowledge and agree that:

8.3.1. The Platform does not warrant or represent that any Supported Digital Asset, blockchain, protocol or smart contract is secure, free from defects, immune from fraud, or free from malicious conduct by developers, issuers, network participants or other third parties (including so-called “rug pulls”). You assume all risk associated with your use of any supported cryptocurrencies.

8.3.2. CHW makes no representation or guarantee regarding the liquidity, sustained market value, convertibility, stability or continued market availability of any Digital Asset, including any stablecoin.

8.3.3. CHW does not guarantee the integrity, solvency, conduct or continued operation of any Digital Asset issuer, developer, foundation, protocol, reserve arrangement or smart contract. The User is responsible for conducting such assessment of a Digital Asset as the User considers appropriate before using the Services in relation to it.

8.4. No advertisement, description, listing, display, educational material or other Platform content relating to a Digital Asset constitutes investment, financial or other advice or a recommendation to acquire, purchase, hold, exchange or otherwise transact in that Digital Asset.

8.5. Erroneous Deposits Not Eligible for Recovery

8.5.1. Erroneously credited deposits in an amount of less than 100 USDT (or the equivalent amount in another cryptocurrency at the time of crediting) shall not be eligible for return.

8.5.2. The User shall bear full responsibility for verifying supported cryptocurrencies and wallet address prior to initiating any transfer of funds.

8.5.3. No return of funds shall be carried out where any AML-related risks, sanctions restrictions, or suspicions of unlawful origin of funds are identified.

8.6. Erroneous Deposits Eligible for Recovery

8.6.1. CHW may require the User to provide comprehensive evidence of ownership, origin and entitlement to the relevant Digital Assets and may decline to credit or return the Digital Assets until such evidence and any required verification have been completed to CHW’s satisfaction. CHW will not process a recovery or return where doing so is prohibited or restricted by Applicable Law, Sanctions or applicable AML/CFT requirements, or where CHW identifies or reasonably suspects financial-crime, fraud, security or other material compliance risk.

8.6.2. An erroneous deposit with a value of 100 USDT or more, or the equivalent amount in another Digital Asset determined by CHW at the relevant time, may be eligible for consideration for recovery where:

a) The cryptocurrency was transferred via a Supported Network, but the transferred token or coin is not supported by CHW for the relevant Wallet address; and

b) The User has submitted a corresponding request to Customer Support within 72 hours of the erroneous transfer.

Eligibility for consideration does not constitute a guarantee that recovery is technically possible or will be successful.

8.6.3. A recovery is not guaranteed, and CHW may decline or be unable to recover Digital Assets, including where:

a) The cryptocurrency was transferred via an unsupported blockchain network.

b) The transaction was sent to an incorrect address, including but not limited to smart contract addresses, system addresses, unsupported addresses within the relevant Supported Network.

c) the required destination tag, MEMO or other identifying information was omitted or incorrect;

d) CHW cannot reliably identify the User or establish the User’s entitlement to the relevant Digital Assets;

e) the Digital Assets have become inaccessible, technically unrecoverable or incapable of being returned safely;

f) recovery would require CHW to support, integrate with or otherwise interact with an unsupported network, asset, protocol, smart contract or technology; or

g) recovery would expose CHW, the Platform, another User or any third party to material legal, regulatory, compliance, security or operational risk.

8.7. Recovery fee

8.7.1. Where CHW agrees to consider an erroneous-deposit recovery request, CHW shall charge a fixed recovery fee of 100 USDT, or the equivalent amount in another Supported Digital Asset determined using the rate applied by CHW at the time the fee is charged. CHW is not responsible for any change in the market value of the relevant Digital Asset during the recovery process.

8.7.2. Payment of the fee shall constitute a mandatory precondition for initiating the recovery process.

8.7.3. Any applicable Network Fees for the return transaction shall be additionally deducted from the amount to be returned.

8.7.4. The recovery fee is charged by CHW for:

a) technical analysis,

b) processing of the request, and

c) the attempt to recover the funds.

d) If, as a result of the analysis, it is determined that:

e) recovery is technically infeasible, or

f) recovery is otherwise impossible,

g) the recovery fee shall be non-refundable once CHW has commenced the relevant analysis or recovery work, including where recovery is subsequently determined to be technically infeasible, unsafe, unlawful or otherwise impossible.

8.7.5. Payment of the recovery fee constitutes the User’s acknowledgement and acceptance that the service is limited to an analysis and recovery attempt, and does not guarantee a successful outcome.

8.7.6. The recovery fee may be paid using such Supported Digital Asset and payment method as CHW makes available for that purpose.

8.8. Recovery Processing

8.8.1. CHW will use commercially reasonable efforts to analyze and, where technically feasible and permitted under these ToS and Applicable Law, attempt to recover the relevant Digital Assets. The complexity and duration of a recovery may vary materially depending on the Digital Asset, network, transaction, technical circumstances, security requirements, third parties and any applicable compliance review. CHW does not guarantee any particular recovery or processing timeframe.

8.8.2. CHW may suspend, defer or discontinue recovery work where additional information, verification, technical work, third-party assistance or compliance review is required, or where circumstances arise that make continued recovery impracticable, unsafe or inappropriate.

8.9. Interaction with Customer Support

8.9.1. To request recovery, the User must contact Customer Support and provide, at minimum:

● Transaction ID (TxID / transaction hash) of the erroneous deposit;

● Relevant Blockchain network name;

● Digital Asset and, where applicable, its contract address;

● Recipient address (which must correspond to the deposit address assigned to the User);

● Any additional information or evidence reasonably requested by CHW to identify the transaction, establish the User’s entitlement to the Digital Assets or complete applicable compliance and security checks.

8.9.2. Where CHW determines that a recovery request is eligible for consideration:

a) The User submits a request to Customer Support, including all required information. Customer Support may request any additional information or verification required by CHW

b) CHW reviews the request and collects Recovery Fee.

c) The User completes payment and provides confirmation to Customer Support.

d) Upon receipt of payment confirmation, Customer Support notifies the User that the case review has been initiated.

e) Where recovery is feasible and approved by CHW, CHW may proceed with the recovery and return of the relevant Digital Assets.

8.9.3. CHW may reject or discontinue a recovery request where the information provided is incomplete, inaccurate, inconsistent or insufficient, the User fails to complete requested verification, or CHW otherwise determines that recovery should not be attempted under this Section.

8.10. Unless CHW determines otherwise following additional verification, any recovered Digital Assets shall be returned only to the blockchain address from which the original erroneous transfer was made. CHW may refuse to return recovered Digital Assets to an alternative address where CHW is unable to verify the ownership or control of that address or where such return would create legal, compliance, fraud, security or other material risk..

9. Trademarks and Copyrights

9.1. CHW owns, or has obtained the necessary rights or permissions to use, the intellectual property made available through the Platform, including, without limitation, the underlying HTML or other source code, software, databases, text, images, graphics, audio, video, interfaces, designs and other content. Nothing in these ToS transfers to the User any ownership right in the Platform or any intellectual property made available through it.

9.2. User is granted a nonexclusive, nontransferable, non-sublicenseable, revocable, limited license to access and use the Platform and content solely for the User’s permitted use of the Services in accordance with these ToS, provided that the User agrees that (a) CHW shall not be liable for any losses that may incur as a result of using this limited license and (b) the User shall not: - modify, adapt, translate, reverse engineer, decompile, disassemble or otherwise attempt to derive the source code or underlying structure of any part of the Platform, except to the extent such restriction is prohibited by Applicable Law

- reproduce, copy, distribute, publish, transmit, sell, license, sublicense, commercially exploit or otherwise make available any Platform content except as expressly permitted by CHW; - remove, obscure or alter any copyright, trademark or other proprietary notice;

- use any automated means to access, scrape, extract or reproduce Platform content except as expressly authorized by CHW;

- use the Platform or its content in any manner that infringes the rights of CHW or any third party, interferes with the operation of the Platform or Services, or is otherwise prohibited under these ToS.

9.3. CHW may modify, restrict, suspend or terminate the licence granted under Section 9.2 at any time where the User breaches these ToS, the User’s access to the Platform or Services is restricted, suspended or terminated, or CHW otherwise discontinues the relevant Platform functionality. The licence automatically terminates upon closure of the User’s Account, except to the extent any continuing access is expressly permitted by CHW.

9.4. No use of the Platform, its content or any intellectual property belonging to CHW or a third party is permitted except as expressly authorized by these ToS or by the relevant rights holder in writing. Nothing in these ToS grants the User any right, title or interest in any copyright, trademark, service mark, patent, trade name, logo, domain name, software or other intellectual property of CHW or any third party, except for the limited licence expressly granted under Section 9.2.

9.5. Except as expressly provided in these ToS, nothing contained herein shall be construed as conferring on User or any third party any license or right to intellectual property rights. The Platform and the content are protected by copyrights, trademarks, service marks, patents, or other proprietary rights and laws. Any proprietary notice should not be removed when using or downloading any content from the Platform. The User is not granted the right to use any branding or logos provided within the Platform.

10. Applicable Law and Jurisdiction

10.1. These ToS, the contractual relationship between the User and CHW arising under them, and any contractual or non-contractual obligation, dispute or claim arising out of or in connection with the Platform or any Service provided by CHW shall be governed by and construed in accordance with the laws of the Republic of Panama, without regard to conflict-of-laws principles that would require the application of the laws of another jurisdiction.

10.2. Subject to any mandatory provision of Applicable Law that cannot lawfully be excluded by agreement, the courts of the First Judicial District of Panama, sitting in Panama City, Republic of Panama, shall have exclusive jurisdiction to settle any dispute, claim or controversy arising out of or in connection with these ToS, the Platform or any Service provided by CHW, including any dispute concerning their existence, validity, interpretation, performance, breach, suspension or termination. For these purposes, the User irrevocably submits to the jurisdiction of such courts and selects the District of Panama as the User’s special contractual domicile in relation to these ToS.

10.3. Where functionality accessible through the Platform is provided directly to the User by a Third-Party Provider under separate terms, the governing law and dispute-resolution provisions contained in those separate terms may govern the legal relationship between the User and that Third-Party Provider solely in respect of the service provided directly by it. No such provision shall alter the governing law or jurisdiction applicable under Sections 10.1 and 10.2 to CHW, these ToS, the Wallet Services, the Platform or any obligation expressly undertaken by CHW.

10.4. Nothing in this Section prevents CHW from seeking interim, conservatory, injunctive or other protective relief in any court of competent jurisdiction where CHW reasonably considers such relief necessary to protect the Platform, Digital Assets, confidential information, intellectual property or any other right or interest pending determination of a dispute on the merits. The User’s submission to the jurisdiction specified in Section 10.2 does not limit any right of CHW to recognize, enforce or execute a judgment or order in any jurisdiction in which the User or the User’s assets may be located.

10.5. Notwithstanding the foregoing, separate terms governing a service provided directly by a Third-Party Provider, and the P2P Services ToU to the extent expressly provided therein, may contain separate governing-law or dispute-resolution provisions applicable solely to the relevant separate legal relationship or P2P Service. Except to that extent, Sections 10.1 and 10.2 apply to the contractual relationship between the User and CHW

10.6. Any dispute relating solely to the publication or distribution of the mobile application by the App Store Publisher in a mobile application marketplace shall be governed by the law and forum applicable to EMCD Tech Limited, unless mandatory applicable law or the relevant mobile application marketplace terms require otherwise.For the avoidance of doubt, the publication or distribution of the mobile application by EMCD Tech Limited shall not alter the governing law or dispute-resolution provisions applicable to the underlying Services under these ToS, the P2P Services ToU or the terms of the relevant Third-Party Provider, as applicable.

11. Transfer of Rights and Obligations

11.1. The User may not assign, transfer, novate, charge or otherwise dispose of any right or obligation under these ToS or applicable Product Terms without CHW’s prior written consent.

11.2. To the maximum extent permitted by Applicable Law, CHW may, without the User’s consent, assign, transfer, novate, delegate, subcontract, charge or otherwise dispose of all or any part of its rights or obligations under these ToS or applicable Product Terms: (a) to an affiliate; (b) to a successor or any person acquiring all or a material part of the business, assets or operations to which the relevant Services relate; (c) in connection with any merger, consolidation, corporate reorganization, financing, restructuring or similar transaction; or (d) where CHW reasonably considers the transfer necessary or appropriate in connection with any legal, regulatory, licensing, compliance, operational or risk-management requirement.

11.3. Where CHW transfers a contractual obligation owed to the User, the transferee may assume and perform that obligation in place of CHW to the extent provided in the relevant transfer arrangement. Following the effective transfer or novation, CHW shall be released from the transferred obligation to the extent assumed by the transferee, except in respect of any liability that cannot lawfully be transferred or excluded. The User authorizes CHW to take such steps and transfer such contractual records, Account information and related rights as are reasonably necessary to implement a transfer permitted under this Section, subject to the Privacy Policy and Applicable Law.

12. 2FA (PassKey)

12.1. CHW may provide or support PassKey authentication, a cryptographic authentication method that uses a key pair consisting of a private authentication key stored on or accessible through the User’s device and a corresponding public authentication key registered with the Platform. Authentication is performed by verification of the relevant cryptographic authentication response. A PassKey and any private key associated with it are used solely for authentication to the User’s Account and are separate from, and shall not be construed as, any private key or other cryptographic credential used by CHW to control Digital Assets under the Wallet Services. Where supported by the User’s device or operating system, PassKey credentials may be stored or synchronized using third-party credential-management services such as Google Password Manager, iCloud Keychain or another supported service.

12.2. The User is responsible for safeguarding and maintaining access to the devices, accounts and credentials used for PassKey authentication and for maintaining such alternative authentication or recovery methods as CHW may make available. If the User loses access to all available authentication methods, access to the Account may be restricted until the User successfully completes CHW’s applicable Account recovery, identity-verification and security procedures.

12.3. CHW does not receive or require access to the private authentication key used by the User’s PassKey merely by supporting PassKey authentication. Information processed in connection with authentication and Account security is handled in accordance with the Privacy Policy. For the avoidance of doubt, this Section relates solely to PassKey authentication and does not affect CHW’s control of the private keys or other cryptographic credentials used to provide the custodial Wallet Services under Section 4.

12.4. CHW is not responsible for the availability, operation or security of any independent third-party credential-management, device, operating-system or cloud-synchronization service used by the User in connection with PassKey authentication, including Google Password Manager or iCloud Keychain, except to the extent liability cannot lawfully be excluded.

12.5. CHW may impose temporary security restrictions on withdrawals, transfers or other Account functionality following:

a) the addition, removal, replacement or reset of a PassKey or other authentication method;

b) a change to Account recovery information or other security-sensitive Account settings;

c) recovery of access to an Account;

d) detection of a new or unusual device, location or authentication pattern; or

e) any other event that CHW reasonably considers to create an increased risk of unauthorized Account access or transactions.

The duration and scope of any such restriction may be determined by CHW having regard to the relevant security and fraud risk. Expiry of any ordinary security restriction does not require CHW to process a transaction while another restriction or review permitted under these ToS remains applicable.

13. Final Provisions

13.1. The headings in these ToS are provided for reference only and shall not affect the interpretation or construction of any provision.

13.2. If any of the ToS specified herein are determined to be invalid, unlawful, or unenforceable to any extent, such term, condition, or provision will to that extent be severed from the remaining terms, conditions, and provisions, which will continue to be valid to the fullest extent permitted by law. In such cases, the part deemed invalid or unenforceable shall be amended in a manner consistent with the applicable law to reflect our original intent as closely as possible.

13.3. Unless otherwise specified in the Account or applicable Product Terms, notices, requests and other communications from the User relating to the Platform or the Services may be submitted through the relevant support channel made available within the Platform or by email to [email protected]. CHW may require that a communication relating to Account ownership, security, withdrawal of Digital Assets, termination, a dispute or another material matter be submitted or confirmed through an authenticated channel or accompanied by such information or verification as CHW reasonably requires. Where a matter relates to functionality provided directly by a Third-Party Provider, CHW may direct the User to communicate with that Third-Party Provider..

13.4. A communication sent by the User to CHW shall not be treated as received merely because it has been transmitted. CHW may treat it as received when it is received through the designated channel in a form that enables CHW reasonably to identify the User and the subject matter of the communication. Nothing in this Section requires CHW to act upon an unauthenticated, incomplete, suspicious or otherwise insufficient communication until such verification or further information as CHW reasonably requires has been provided.

13.5. Any notices and announcements made hereunder, or any other messages addressed to the User, shall be sent by CHW to the email address of the User specified in the User Account or made available to the User upon login into the User Account. A communication made available through the Account or Platform shall be deemed received when made available. An email or other electronic communication shall be deemed received when transmitted to the contact details registered with the Account, unless CHW receives an automated notice that delivery has failed. The User is responsible for maintaining accurate and accessible contact details and for reviewing communications made available through the Account.

13.6. CHW may permanently or temporarily discontinue the Platform or any Service, in whole or in part, in accordance with these ToS without notice. Where CHW discontinues the Wallet Services or closes an Account, any remaining Account Balance shall be dealt with in accordance with Section 3.9, Section 4 and any applicable hold, restriction, set-off or requirement under Applicable Law. Where CHW discontinues the Grow Services, outstanding Grows shall be dealt with in accordance with Section 5.3 and any wind-down, settlement, conversion or other arrangements implemented by CHW pursuant to these ToS. Discontinuation of the Platform or a Service does not require CHW to execute a transaction or release an amount while a lawful or contractual restriction applicable under these ToS remains in effect.

13.7. CHW shall not be liable for any failure, delay, interruption, restriction or modification in the operation of the Platform or performance of the Services to the extent caused by or resulting from circumstances outside CHW’s reasonable control, including: failure, disruption, congestion or compromise of telecommunications, internet, hosting, cloud, power, banking, payment, settlement or other infrastructure; cyberattack, malicious software, denial-of-service attack, security incident or material compromise of systems; failure, halt, fork, reorganization, exploit, defect or other material event affecting a Supported Network, blockchain, protocol, smart contract, Digital Asset or related infrastructure; acts of war, terrorism, civil disorder, natural disaster, epidemic, governmental action, embargo or other comparable event; the material failure or unavailability of a Third-Party Provider or other infrastructure on which a Service depends; or any other event beyond CHW’s reasonable control. In addition, CHW may take any action it reasonably considers necessary or appropriate where there is or may be: a change in Applicable Law, Sanctions or regulatory interpretation or enforcement practice; a new or modified licensing, registration, authorization, capital, safeguarding, reporting, local-presence or other regulatory requirement; an order, direction, request or expectation of a competent authority; a material change in the legal or regulatory treatment of a Digital Asset, Supported Network or Service; or any other legal, regulatory or compliance development that affects or may affect CHW’s ability to provide a Service in its existing form. Without limiting Sections 1, 3.8 and 11, CHW may in such circumstances, with immediate effect where CHW considers this necessary: modify, restrict or suspend a Service or functionality; restrict particular Users, jurisdictions, Digital Assets, Supported Networks or transaction types; impose or modify eligibility, verification, limits or other conditions; suspend new transactions and place a Service into withdrawal-only, redemption-only or other wind-down mode; terminate or discontinue a Service;transfer or migrate some or all relevant rights, obligations, Accounts or Services in accordance with Section 11; and/or implement such settlement, withdrawal, conversion or other transitional arrangements as CHW reasonably considers appropriate and lawful. CHW is not obliged to obtain, apply for or maintain any licence, registration, authorization or regulatory status solely for the purpose of continuing to provide a Service in its existing form where CHW elects instead to modify, restrict, transfer, suspend or discontinue that Service. To the extent reasonably practicable and lawful, CHW will take commercially reasonable steps to address amounts properly due to Users following such an event in accordance with the provisions applicable to the relevant Service. Nothing in this Section requires CHW to process, release, transfer, redeem or settle any amount while doing so is prohibited by Applicable Law or while another restriction permitted under these ToS remains applicable.

13.8. These ToS, together with the Privacy Policy, KYC/AML Policy, applicable Risk Disclosures, applicable Product Terms and any transaction-specific terms expressly incorporated or accepted in accordance with these ToS, constitute the contractual framework governing the User’s access to the Platform and use of the Services. In relation to matters specifically governed by Product Terms or transaction-specific parameters, the order of precedence set out in Section 1.6 applies. Except in the case of fraud, the User acknowledges that no statement, representation, advertisement, FAQ, article, educational material, public rate display, marketing communication or other information that is not expressly incorporated into the contractual framework creates a separate contractual representation, warranty or obligation of CHW.

13.9. CHW acts in its own name and on its own account in providing the Platform, the Wallet Services and each other Service expressly identified in these ToS or applicable Product Terms as being provided by CHW. CHW may engage affiliates, contractors, technology providers, execution venues, liquidity providers and other Third-Party Providers in connection with the operation of the Platform or performance of the Services without thereby creating a contractual relationship between the User and any such person, except where that person separately provides a service directly to the User under its own applicable terms. Nothing in these ToS creates a partnership, joint venture, employment, fiduciary or general agency relationship between CHW and the User. The publication or distribution of the Platform mobile application by the App Store Publisher does not, by itself, make the App Store Publisher the provider or contracting counterparty in respect of any Service.

13.10. These General Terms come into effect upon their publication on the Platform.

Last amended on 14/08/2026