Terms of Use

(last updated on October 20, 2025)

3-102-895421 S.R.L. (hereinafter referred to as the “Developer” or “we”), registration number 3-102-895421, a company duly organized and existing under the laws of the Republic of Costa Rica and having a registered office address at Province of San José, Central Canton, Mata Redonda District, Sabana Sur, Centro Colón Building, Office No. 4-B, has compiled these Terms of Use (hereinafter referred to as the “Terms”) to govern the use of its applications and interfaces (collectively, the “Apps”), including the Telegram Mini App (“MA”) and the Progressive Web Application (“PWA”), which allow users (hereinafter referred to as the “Users” or “you”) to access its services and products (hereinafter referred to as the “Services” and “Products”) through various digital platforms, including but not limited to Telegram Messenger Inc. (hereinafter referred to as “Telegram”) and compatible web browsers.

ACCEPTANCE OF TERMS

By using MA/PWA and our Services and Products through it, you agree that you have read in full, understood and accepted to be legally bound by the terms contained herein.

We may, at our sole and absolute discretion and without liability, at any time and without notice, introduce changes to MA/PWA and modify Terms in any way we deem necessary. We hold no liability for how these changes may affect access to MA/PWA, as well as Services and Products offered in it.

Your continued access to and use of MA/PWA shall constitute your acceptance of these Terms, including any updates or modifications to them.

When you connect to MA, you may be further subject to Telegram’s terms of use, which are to be considered in addition to this document and are subject to periodical revisions on the part of Telegram.

Although MA operates independently of Telegram, it relies on the platform’s proper functioning. Therefore, Developer shall not be held responsible for interruptions in Telegram’s operations, security breaches in resulting from vulnerabilities in Telegram’s code, changes in Telegram’s policies and any of their adverse consequences.

Since your account on Telegram (hereinafter referred to as “TGA”) serves as the identification we use to grant you access to our MA, you fully acknowledge and explicitly assume any and all risks related to the security of your TGA. Developer may offer security guidelines; however, they are not to be viewed as formal advice.

Should you discover that someone else has gained control to a device with access to your TGA (hereinafter referred to as “Trusted Device”), you shall bear the sole responsibility for taking all appropriate measures to prevent unauthorized access of that person to our MA, including, but not limited to resetting the password and logging out of devices over which you do not exercise the sole control. You agree to exempt Developer from any liability for any losses resulting from such incidents.

PROGRESSIVE WEB APPLICATION

When you access our Services via the PWA, you do so through your web browser and internet connection. The PWA operates independently of Telegram and relies on the proper functioning of your browser, operating system, and network connection.

The Developer applies reasonable technical and organizational measures to ensure the security and continuous operation of the PWA, including appropriate encryption, access control, and system monitoring. These measures are designed to protect data integrity and prevent unauthorized access within the scope of our control.

However, you acknowledge that the use of the PWA involves certain risks inherent to internet-based services, such as connection interruptions, browser vulnerabilities, or unauthorized access to your device. The Developer cannot be held responsible for failures, errors, or security breaches caused by factors beyond its reasonable control - including issues related to third-party browsers, devices, internet providers, or malicious software present on your device.

You are solely responsible for maintaining the confidentiality of your credentials and securing the device used to access the PWA. Should you discover that your browser session, password, or device has been compromised, you shall take immediate measures to prevent unauthorized access, such as changing passwords, logging out of active sessions, and ensuring the physical and digital security of your device.

To the extent permitted by applicable law, the Developer’s liability is limited to ensuring the proper functioning and reasonable security of the PWA itself, and it shall not be liable for any indirect losses arising from external factors or your failure to take reasonable precautions.

SERVICES AND PRODUCTS

MA/PWA encompasses a range of services and products, including but not limited to:

custodial wallet (hereinafter referred to as “Wallet”) and tools for its management;
payment cards and their management through a dedicated dashboard (hereinafter referred to as “Card Account”);
referral program.

Wallets and Card Accounts are established and maintained by us for the sole purpose of providing Services and Products. Under no circumstances should the provision of Wallets and Card Accounts be interpreted as offering a banking service, or a stored value facility of any kind. Nor shall any of the information in MA/PWA construed as financial advice.

Developer reserves the right to update, modify, discontinue, suspend, disable, or restrict access to any of those Services and Products, as well as separate features, components or content thereof at any time, for any reason, without notice or liability to the user.

THIRD-PARTY SERVICE AND PRODUCT PROVIDERS

When providing some of Services and Products to Users Developer relies on third-party providers (hereinafter referred to as “TPPs”). Those include, without limitation, processing providers, banks, exchanges, data storage facilities, as well as software development companies.

TPPs have their own terms of use and policies, whose change may lead to change in these Terms.

Developer shall not be held accountable for any consequences of TPPs’ changes in their terms and policies, which result in respective changes in these Terms.

Nor shall Developer be liable for any interruptions, limitations or deficiencies in Services or Products caused by interruptions, limitations or deficiencies in TPPs’ services and products it relies upon.

ACCESS TO SERVICES AND PRODUCTS

To be able to use Services and Products, User shall run MA/PWA on a Trusted Device.

By accessing MA/PWA, you warrant that:

You understand that the Services are not available in certain jurisdictions due to applicable regulatory limitations. Without limitation, the Services are not intended for, and shall not be accessed or used by, any person who is located in, resident in, or subject to the laws of the United States, the European Union, the United Kingdom, or the United Arab Emirates, or any other jurisdiction where the access to or use of the Services is prohibited or restricted by applicable law.
You are accessing MA/PWA on your own initiative without active promotion and/or solicitation from us, any of its companies, employees and/or any of its affiliated, associated or connected persons.
You have read, understood and agreed to our Privacy Policy as well as these Terms.
You have the full right, power, and authority to agree to our Privacy Policy and these Terms.
You have attained the minimum age required under all relevant applicable laws for using Services and Products.
You are the owner of TGA you are using to run this MA/PWA.
You are not impersonating any other person, operating under an alias or otherwise concealing your identity.

We may adjust the eligibility criteria for use of MA/PWA at any time.

You agree to provide us with all information and/or documents requested by us or TPPs. Such information and/or documents may, without limitation, be necessary for us to verify your identity, update and maintain accurate customer records, enhance security measures, validate your funding sources or transactions and ensure the continued provision of Services and Products in accordance with regulatory and operational requirements.

The information that you provide must be complete, accurate and up-to-date. If at any time we believe that your information is outdated or inaccurate, we may contact you and request further information or request that you go through the verification process again. Failure to complete any step of the registration process may also result in your inability to use MA/PWA.

We may confidentially verify the information you provide us with or obtain information on you ourselves or through TPPs. By agreeing to these Terms, you confirm that you consent to us or TPP carrying out such verifications on our behalf.

Developer has the sole discretion as to the provision of Services and Products, including but not limited to:

suspending an account;
specifying or modifying the scope of Services and Products for each User or all Users;
prescribing the types of supported virtual assets and fiat currencies;
setting limits or imposing restrictions on any type of account activity.

We may refuse to provide Services and Products if, in our opinion:

you have provided any incorrect, incomplete or misleading information or/and documents or made an incorrect or misleading representation or warranty;
you have not provided sufficient evidence that meets our eligibility criteria for relevant Services and Products.

Without limiting our rights under any other provision contained in these Terms, we may also suspend or refuse to provide any Services and Products if, in our opinion, they may:

not comply with applicable laws, including any AML/CTF requirements;
be used to circumvent any applicable law, including any AML/CTF requirements;
result in us providing Services to a person in a jurisdiction that is the target of country-wide or territory-wide sanctions and such other country or territory in which we may not offer services, as determined by us from time to time (the current list includes Belarus, Cuba, DPRK, Congo, the Central African Republic, Myanmar, Haiti, Iran, Libya, Russia, Syria, Somalia, Venezuela, Yemen, Zimbabwe, as well as Donetsk, Luhansk, Zaporizhzhia and Kherson regions and Crimea).

FEES

Your use of Services may be subject to certain fees. The list of main applicable fees is displayed under a payment card before its purchase.

All applicable fees listed in MA/PWA are exclusive of any applicable taxes.

All fees paid shall be non-refundable.

Developer may at its sole discretion introduce additional fees or otherwise adjust or update the fees from time to time without prior written notice or explanation.

You undertake to settle any outstanding fees immediately, failing which we reserve the right to suspend your use of Services and Products until all such outstanding fees have been settled.

Blockchain transaction fees required to deposit virtual assets to Wallet are not charged by Developer and have therefore not been listed here. Users shall pay them separately and exempt Developer from any liability for any expenses or losses occurring when such transactions are executed.

Card payments may incur currency conversion surcharges for purchases made outside of Hong Kong. Those are charged by the acquiring bank and may vary depending on the exchange rate. Users shall pay them separately and exempt Developer from any liability for any expenses or unrealized gains.

TAXES

You are solely responsible for determining, calculating, reporting, and paying any taxes applicable as a result of your use of Services and Products.

You acknowledge that tax laws and regulations may change from time to time, and Developer shall not be liable for any tax obligations or consequences arising from your use of the Services and Products.

Developer does not provide tax advice, and it is your responsibility to consult with your tax advisor to ensure compliance with all tax obligations.

If requested by Developer, you agree to provide necessary tax-related information or documentation to comply with applicable tax laws and regulations. Failure to provide such information may result in restrictions on use of MA/PWA.

UNDERLYING PROTOCORLS

We do not own, control, operate or maintain the underlying software protocols which govern the operation of virtual currencies supported in MA/PWA.

In general, the underlying protocols are open-source software and anyone can use, copy, modify, and distribute them.

By using our Services and Products, you acknowledge and agree (i) that we are not responsible for the operation of the underlying protocols and that we make no guarantee of their security, functionality or availability; and (ii) that the underlying protocols are subject to sudden changes in operating rules, which may materially affect the value, function, name of the virtual currency and/or our ability to support certain virtual currencies.

All the risks inherent in virtual currency transactions remain with you. Developer shall not be liable for errors, hacks or any other reasons leading to losses.

All of the virtual assets you top up your Wallet with go through our risk-monitoring system. Should any of them prove red-flagged as high-risk or subject to enforcement of a judgment, we reserve the right to freeze them, terminate your use of Services and Products and report the transaction to regulatory authorities.

INTELLECTUAL PROPERTY RIGHTS

You acknowledge and agree that:

The trademarks, service marks, logos, trade names, and any other proprietary indicia used in MA/PWA (collectively referred to as “Trade Marks”) are the exclusive property of Developer, its partners, affiliates and TPPs. You shall not use, copy, imitate, or modify any of Trade Marks without prior written consent of Developer or the relevant rights holder.
The intellectual property rights, including but not limited to copyrights, patents, trade secrets, and proprietary rights in MA/PWA and any associated software, content, design, text, graphics, user interfaces, images, algorithms, and other components, whether registered or unregistered, are either owned by Developer or licensed to Developer by TPPs.
Other than the limited, non-exclusive, non-transferable, revocable license expressly granted to you under these Terms, no other rights, title, or interests are granted to you in respect of either Trade Marks, MA/PWA, or any Services and Products. Any unauthorized use of such intellectual property may result in legal action.

You agree that you shall not, and shall not permit any third party to:

reproduce, distribute, republish, display, broadcast, hyperlink, transmit, adapt, modify, translate, create derivative works, sell, license, or otherwise commercially exploit any part of MA/PWA, Services and Products, or any intellectual property associated with Developer’s business without obtaining prior written permission from Developer or the respective rights holder;
reverse-engineer, decompile, disassemble, or otherwise attempt to derive the source code or underlying algorithms of any part of MA/PWA, Services and Products, except where explicitly permitted by applicable law;
modify or adapt the whole or any part of MA/PWA or combine or incorporate MA/PWA into another other program or application;
remove, alter, or obscure any copyright, trademark, or other proprietary notices displayed on or contained within MA/PWA or any related materials;
use any automated tools, bots, scraping techniques, or similar methods to extract data or content from MA/PWA without express authorization.

If you submit, upload, or provide any content, feedback, or suggestions to Developer regarding Services and Products, you grant Developer a worldwide, non-exclusive, royalty-free, irrevocable, sublicensable, and transferable right to use, reproduce, modify, distribute, and display such content for the purpose of improving or promoting Services and Products. You warrant that you have the necessary rights to grant this license and that such content does not infringe on any third-party rights.

Developer reserves the right to take all necessary legal actions, including seeking damages and injunctive relief, against any unauthorized use, copying, or distribution of its intellectual property. Developer also reserves the right to report any intellectual property violations to relevant authorities or enforcement agencies.

CONDUCT

Without prejudice to the foregoing, you shall not (and shall not, knowingly or otherwise, authorize, allow or assist any other party to):

use MA/PWA to conduct electronic spamming;
use MA/PWA to perform unlawful or immoral activities (including but not limited to money laundering, terrorism financing and fraudulent activities);
use MA/PWA in any manner that would lead to the infringement of our intellectual property rights or those of any third-party;
use MA/PWA in a way that could damage, disable, impair or compromise it or the provision of Services and Products (or the systems or security of MA/PWA or any other computer systems or devices used in connection therewith) or interfere with other Users or affect the reputation of Developer or its affiliates;
shall not engage in any activities that we, at our sole discretion, deem inappropriate or that contravene any applicable laws;
demonstrate or use any abusive, threatening and/or violent behavior or language towards our personnel.

ELECTRONIC COMMUNICATIONS

You shall accept full responsibility for the security of your account and actions you perform in MA/PWA.

We shall be entitled to assume that all actions performed with your account are taken by you or at your behest. We shall be under no obligation whatsoever to verify if it is the case.

You are aware that information you receive in MA/PWA is generally transmitted via the internet and may be routed via public, transnational installations which are not specifically protected. We cannot guarantee that the information so transmitted will in fact be completely protected against such unauthorized access, and you accept these associated risks.

Without prejudice to any of these Terms, you shall be liable for any damage arising from the use of the internet, including but not limited to loss, delay, misunderstandings, corrupted texts, unauthorized interceptions by third parties, or duplication. Furthermore, if it is proven that you have directly or indirectly contributed to or caused such damage through any act, omission, or deliberate misconduct, your liability shall be extended accordingly.

You acknowledge and agree that in the event of any dispute arising in connection with your use of Services and Products, our records (including electronic, computer and microfilm stored records) of all matters relating to your use of Services and Products (including transaction history) at any specified date shall be conclusive of their accuracy and authenticity and shall be binding on you for all purposes whatsoever.

TERMINATION OR LIMITATION OF SERVICES

Developer may at any time, without notice and in its sole and absolute discretion, terminate, suspend or limit your use of Services (including freezing or closing your custodial wallet, virtual account, refusing to process any card transactions, reversing any card transaction that you have effected, refusing or suspending any transfers, deposits or withdrawals, or refusing or suspending any swap transactions) for any reason, including, without limitation:

in the event of any breach by you of these Terms, or all other applicable terms;
for the purposes of complying with applicable laws;
where Developer suspects that a transaction effected by you is potentially connected to any unlawful activities (including but not limited to money laundering, terrorism financing and fraudulent activities);
as may be informed by its internal risk monitoring policy and the profile of spending reasonably anticipated for the type of consumer group you belong to;
in the event you become insolvent or any of your assets are subject to insolvency proceedings (including where there is any assignment, arrangement or composition with or for the benefit of creditors);
you act fraudulently or dishonestly;
you breach any applicable laws;
you are convicted of a tax or other crime in any jurisdiction;
we, in our discretion, consider that Services and Products are being used in an irregular or improper manner;
anything occurs which, in our opinion, is likely to have a material adverse effect on your ability or willingness to comply with your obligations under these Terms;
you fail to make on its due date any payment (including principal, interest or other sum) or any other event of default (however described) under any other agreement between you and Developer occurs.

Developer reserves the right to reverse, cancel, refuse to honor or exclude you from participating in any incentive programs if you are found in breach of any of these Terms, whether directly or indirectly, voluntarily or involuntarily.

Your obligations under these Terms will continue and Developer shall remain to be entitled to debit your Wallet balance and/or Card Account (as applicable) for any amount and charges incurred in or related to Services and payment card transactions that are carried out before or after the termination of your account and you shall continue to remain liable to Developer for such amounts and charges until they are paid in full.

You shall not be entitled to any payment, compensation or damages from us in relation to any suspension or termination of your use of Services and Products for any reason whatsoever. Any suspension or termination of your use of Services and Products for any reason whatsoever shall not release you from any liability or responsibility on your part, which at the time of such suspension or termination, has already accrued.

Developer’s rights of suspension and termination under these Terms shall be without prejudice to any other rights or remedies which Developer may have (whether under these Terms, at law, in equity or otherwise).

Likewise, you may at any time discontinue the use of Services and Products and withdraw the entire Wallet balance less blockchain gas fees required to carry out the transaction. Withdrawal from Card Account cannot be executed.

Developer may, subject to applicable laws, delay, deny, or reduce the amount returned or released to you if necessary to ensure that the requested reduction or release does not result in a negative Wallet balance.

LIMITATION OF LIABILITY

Except as expressly provided in these terms, to the fullest extent permitted by law, we disclaim all other representations or warranties, express or implied, made to you, your affiliates or any other person, including without limitation, any warranties regarding quality, suitability, merchantability, fitness for a particular purpose or otherwise (regardless of any course of dealing, custom or usage of trade) of any Services and Products under these Terms. Our liability in respect of representations and warranties that cannot be excluded is limited, at our option, to any one of:

re-supplying, replacing or repairing Services and Products in respect of which the breach occurred;
paying the cost of the re-supplying, replacement or repairing of the Services and Products in respect of which the breach occurred.

Notwithstanding anything in these terms, to the extent permitted by law, in no event shall Developer or any of its representatives be liable to you for any losses or damage or claims

arising from or in connection with:
1. any delay, suspension, discontinuance or failure of MA/PWA, Services and Products;
2. any rejection of the card or transaction failure;
3. your inability to effect or complete any transaction due to system maintenance or breakdown/non-availability of MA/PWA, network, our hardware or software or that of any TPPs;
4. use of your enabled device and the services by third parties, whether authorized or unauthorized by you;
5. any theft or loss of your Trusted Device;
caused by us due to compliance with applicable laws, court orders, and/or card network rules;
arising out of or in connection with these terms for lost profits, lost revenues, lost business opportunities, exemplary, punitive, special, incidental, indirect or consequential damages, each of which is hereby excluded by these Terms, regardless of whether such damages were direct or indirect, foreseeable or unforeseeable, or whether we have been advised of the possibility of such damages.

In any case, the total liability of Developer arising out of or in connection with the provision of any service under these Terms shall be limited to your wallet balance as of the date your claim arises.

Developer shall not be liable for fault on the part of any third-party service providers employed by us. In such cases, Developer’s liability shall be limited to using reasonable care in the selection, appointment and use of services of such third-party service providers (but not of any sub-contractor or other third-party such third-party service provider may use).

Nothing in these Terms shall operate to limit or exclude any liability for fraud or for death or personal injury resulting from negligence.

FORCE-MAJEURE

Developer shall not be held liable for any delay, failure, or inability to perform its obligations under these Terms due to any event beyond its reasonable control (“Force Majeure Event”). A Force Majeure Event includes, but is not limited to:

Acts of God, natural disasters (such as earthquakes, floods, hurricanes, and fires), pandemics, epidemics, or other public health crises;
war, hostilities (whether war is declared or not), military conflicts, civil disturbances, riots, terrorism, or sabotage;
government actions, sanctions, embargoes, or regulatory restrictions;
strikes, labor disputes, or industrial actions (whether involving Developer’s workforce or any third party);
cyberattacks, hacking incidents, failures or disruptions in telecommunications, networks, data centers, or Internet service providers;
failures or disruptions of payment systems, banking networks, blockchain networks, or other essential third-party services required for the operation of MA/PWA;
power failures, system failures, software errors, or any other technical malfunctions beyond Developer’s reasonable control.

In the event of a Force Majeure Event:

Developer shall make reasonable efforts to mitigate the impact of such an event and resume operations as soon as reasonably practicable.
Developer shall not be liable for any losses, damages, or claims arising directly or indirectly from its inability to perform its obligations due to a Force Majeure Event.
If the Force Majeure Event continues for more than thirty (30) calendar days, either party may terminate affected Services by providing written notice to the other party without liability, except for obligations incurred before the occurrence of the Force Majeure Event.

INDEMNIFICATION

You agree to indemnify and hold Developer, each of its affiliates and TPPs, and each of their respective officers, directors, agents, joint venturers, employees and representatives (“Indemnified Parties”), harmless from any claim or demand (including attorneys’ fees and any fines, fees or penalties imposed by any regulatory authority) arising out of or related to any action, omission, or misconduct on your part, provided that it is proven that such claim, demand, or liability has arisen as a direct result of your fault:

your breach of these Terms;
your use of MA/PWA, Services and Products;
your violation of any rule or regulation, or the rights of any third-party;
any transactions resulting from your willful default, fraud, gross negligence or breach of these Terms.

ASSIGNMENT AND SUBCONTRACTING

These Terms, and any rights and licenses granted hereunder, are personal to you and may not be transferred or assigned by you, but may be assigned by Developer without restriction, including without limitation to any of Developer’s affiliates or subsidiaries, or to any successor in interest of any business associated with Services and Products.

Any attempted transfer or assignment in violation hereof shall be null and void.

SEVERABILITY

If any provision of these Terms shall be found by any court or administrative body of competent jurisdiction to be invalid or unenforceable, the invalidity or unenforceability of such provision shall not affect the other provisions of these Terms and all provisions not affected by such invalidity or unenforceability shall remain in full force and effect.

Such provision will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under any applicable laws.

ENTIRE AGREEMENT AND LANGUAGE

These Terms constitute the entire agreement between you, on the one hand, and Developer, on the other, with regard to its subject matter and supersedes and invalidates all other prior representations, arrangements, understandings, and agreements relating to the same subject matter, (whether oral or in writing, express or implied). Each party acknowledges that in agreeing to these Terms it does not rely on any statement, representation, warranty, or understanding other than those expressly set out in these Terms.

These Terms are concluded in the English language and all communications including any notices or information being transmitted shall be in English.

If these Terms or any part of it is translated (for any proceedings, for your convenience or otherwise) into any other language, the English language text of these Terms shall prevail.

Notwithstanding the foregoing, if there are conflicts between these Terms and any information provided in MA/PWA, these Terms shall prevail.

WAIVER

These Terms shall be waived in whole or in part only with the written consent of Developer.

The delay of enforcement or the non-enforcement of any of these Terms by Developer shall not be construed as a waiver of any of the other rights of Developer arising out of the breach or any subsequent breach of any of these Terms and no right, power or remedy conferred upon or reserved for Developer in these Terms is exclusive of any other right, power or remedy available to Developer and each such right, power or remedy shall be cumulative.

NOTICES AND COMMUNICATIONS

By using Services and Products, you agree that Developer, its related corporations, TPPs, contractors or sub-contractors may provide you with any notices or other communications relating to your use of Services and Products via notifications in MA/PWA. The date of receipt will be deemed the date on which such notice is transmitted.

We prefer receiving notices electronically through the official support channels specified on the relevant landing page or within the application interface.

THIRD PARTY RIGHTS

These (together with any other agreements subject to or connected with these) Terms and documents confer benefits on Indemnified Parties and are intended to be enforceable by each Indemnified Party by virtue of the Contracts (Rights of Third Parties) Ordinance (Cap. 623 of the Laws of Hong Kong). The parties to this agreement do not intend that any term of this agreement should be enforceable, by virtue of the Contracts (Rights of Third Parties) Ordinance (Cap. 623 of the Laws of Hong Kong), by any person other than an Indemnified Party.

GOVERNING LAW AND SUBMISSION TO ARBITRATION

These Terms shall be governed by and construed in accordance with the laws of Hong Kong.

Unless otherwise specified, any dispute, controversy, difference or claim arising out of or relating to these Terms, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to these Terms, will be referred to and finally resolved by arbitration administered by Hong Kong International Arbitration Centre (“HKIAC”) under the HKIAC Administered Arbitration Rules in force when the notice of arbitration is submitted.

Unless agreed otherwise, the number of arbitrators will be one (1) and that arbitrator must have relevant legal and technological expertise.

If you and we do not agree on the arbitrator to be appointed within fifteen (15) working days of the dispute proceeding to arbitration, the arbitrator is to be appointed by HKIAC.

The arbitration proceedings will be conducted in English.

Notwithstanding any other provision of these Terms, you agree that we have the right to apply for injunctive remedies (or an equivalent type of urgent legal relief) in any jurisdiction.

HANDLING OF DISPUTES

In the event of any dispute arising between you and Developer concerning these Terms both parties agree to seek resolution through good faith negotiations.

If a resolution cannot be reached within a reasonable timeframe, the dispute shall be escalated for mediation or arbitration in accordance with the governing law provisions set forth in these Terms.

Any claims or disagreements regarding transactions must be reported to Developer within a specified period as determined by applicable service rules or regulations. Failure to raise a dispute within the given timeframe may result in forfeiture of claims.

Developer reserves the right to investigate any disputes thoroughly and may require additional documentation from User to support their claim. Until the dispute is resolved, Developer may, at its discretion, suspend or withhold any disputed amount. Users acknowledge that certain disputes, particularly those involving TPPs, may be subject to separate dispute resolution processes imposed by them.