TERMS OF SERVICE (USER AGREEMENT)

ABCEX Platform (abcex.io)

Brief Summary

These Terms govern access to and use of the ABCEX.io Platform. The Platform is intended for transactions in Virtual Assets and for internal ledger accounting. The Operator applies a risk-based compliance approach, including KYC/AML/KYT and sanctions screening. The internal accounting unit RUB is used solely within the Platform and is not a monetary obligation.

Contacts: legal notices - legal@abcex.io; support - support@abcex.io.

PART I. GENERAL PROVISIONS

1. Parties and Subject Matter

1.1. These Terms of Service (the "Terms", "ToS") govern access to and use of the ABCEX platform available at abcex.io, as well as related services (including web interface, mobile interfaces, mini-applications, API and other interfaces, where applicable) (the "Platform").

1.2. Platform Operator: NUEVA CRYPTOLOGIA, SOCIEDAD POR ACCIONES SIMPLIFICADA DE CAPITAL VARIABLE (abbr.: NUEVA CRYPTOLOGIA, S.A.S. DE C.V.), Republic of El Salvador. Registration details: Inscrito en el Registro de Comercio al número 582 del Libro 4927 del Registro de Sociedades; asiento número 2025074769; gestión No. SF2025008950; registration date: 20.08.2025 (San Salvador). Address: Avenida La Revolución, Plaza Presidente, Level 6, Local 1, Colonia San Benito, San Salvador, San Salvador Centro, Distrito San Salvador, El Salvador. Tel.: 77411981 (the "Operator", the "Company").

1.3. "User" means an individual or a legal entity/sole proprietor who (i) has created an Account on the Platform or (ii) uses the Platform without registration to the extent permitted by its functionality.

1.4. "Partner" means an independent third party (legal entity/sole proprietor) that provides Users with separate services outside the Platform (including transactions with cash/non-cash funds) and uses the Platform under a separate B2B agreement with the Operator. The Partner acts in its own name and bears independent responsibility.

1.5. The Operator is not a party to the User's transactions with Partners and/or other Users (including P2P), unless the Operator expressly states otherwise for a specific feature.

1.6. Nothing in these Terms creates between the Parties any relationship of agency, partnership, joint venture, employment, or trust management.

2. Acceptance of the Terms, Electronic Form and Amendments

2.1. The User accepts these Terms by: (a) registering an Account; (b) confirming consent in the interface; and/or (c) actual use of the Platform (including deposits/withdrawals of assets, transactions, use of RUB/Codes, placing orders, using P2P and/or the API).

2.2. The User agrees that electronic acceptance of the Terms and/or actions performed on the Platform is equivalent to written form to the maximum extent permitted by applicable law.

2.3. The Operator may unilaterally amend the Terms, appendices and policies (including the AML Policy, Privacy Policy, Risk Warning, P2P Rules, Fee Schedule, and AUP). The new version enters into force upon publication on the Platform unless the text specifies otherwise.

2.4. Continued use of the Platform after publication of changes constitutes the User's consent to the new version. If the User disagrees, the User must stop using the Platform and close the Account (subject to compliance requirements and completion of obligations).

2.5. The Operator may publish local terms for certain products/regions. In case of conflict, the special terms apply if they expressly provide so.

3. Terms and Definitions

3.1. Key definitions are set out below. Other definitions may be used in these Terms and have the meaning derived from the context.

3.2. In case of discrepancies between translations, the version designated by the Operator as the primary version for the relevant region/product prevails.

4. Legal Status of the Platform and Nature of Services

4.1. The Platform is a technological venue providing an interface for Virtual Asset transactions and for internal accounting of Users' rights and obligations.

4.2. The Operator is not a bank, does not open bank accounts for Users, does not conduct banking operations and does not guarantee deposit insurance of assets.

4.3. The Operator is not an investment adviser, does not provide personalized investment recommendations, does not guarantee returns, and does not act as a fiduciary of the User.

4.4. No information on the Platform constitutes investment, legal, tax or other professional advice.

4.5. The Operator may engage third parties to provide certain functions (custodians, liquidity providers, KYC/AML/KYT providers, infrastructure providers, etc.). The User agrees that some functions may depend on such third parties.

4.6. The Operator may, at its discretion, change Platform functionality, suspend certain features, introduce limits and fees, and set access requirements.

PART II. ELIGIBILITY, ACCOUNT AND SECURITY

5. Eligibility, Age and Jurisdictional Restrictions

5.1. The User confirms they have reached the age of majority in their jurisdiction and have full legal capacity to accept these Terms and to transact in Virtual Assets.

5.2. The Operator may establish and change the list of Restricted Jurisdictions and categories of Users for whom access is prohibited or restricted. The list may be published on the Platform and/or communicated to the User by other means.

5.3. The User undertakes to independently assess the legality of using the Platform in their jurisdiction and is responsible for compliance with applicable law, including currency control, tax, sanctions and other regulations.

5.4. The Operator may apply geo-blocking, IP/device restrictions, citizenship/residency restrictions, and other access control measures.

5.5. The User undertakes not to use VPN/proxy or other methods to bypass access restrictions where such restrictions are set by the Operator.

5.6. The Operator may refuse service to persons who, in the Operator's opinion, pose an unacceptable risk (sanctions, reputational, legal, fraud, etc.).

6. Registration, Data Accuracy and Security

6.1. To access the core functionality of the Platform, the User creates an Account and provides accurate, complete and up-to-date information. The User undertakes to keep such information current.

6.2. The User must ensure confidentiality of their login, password, 2FA codes, access to email/phone number/messenger, as well as other authentication means.

6.3. The Operator may require enabling two-factor authentication (2FA), additional confirmations and/or restrict functionality until security requirements are met.

6.4. All actions performed using the User's credentials are deemed performed by the User unless the Operator determines otherwise.

6.5. The User must immediately notify the Operator of suspected compromise of the Account. The Operator may apply emergency blocking and additional checks.

6.6. The User is responsible for security of their own devices, software and communication channels. The Operator is not responsible for damage caused by malware, SIM swap, email compromise or other actions of third parties if the Operator applied reasonable security measures.

6.7. The User agrees that the Operator may implement additional security mechanisms, including device analysis, geolocation, behavioral factors, restrictions on withdrawal addresses and/or whitelists.

7. API Access and Technical Keys

7.1. The Operator may provide API access subject to the User's compliance with additional terms, limits, access keys and security requirements.

7.2. The User undertakes to keep API keys confidential, not to transfer them to third parties, and to implement security measures (key rotation, least privilege, IP whitelist, etc.).

7.3. The Operator may limit request frequency (rate limits), disable the API in case of suspected abuse, and change API specifications without prior notice.

7.4. The Operator is not liable for losses arising from incorrect integration by the User, coding errors, use of third-party libraries and/or compromise of API keys.

7.5. For certain API features, the Operator may require separate acceptance of "API Terms" and/or additional checks (including technical attestation and restriction of automated trading strategies).

PART III. KYC/AML, SANCTIONS AND COMPLIANCE

8. General Compliance Principles

8.1. The Operator applies a risk-based AML/CFT approach and follows international standards and industry best practices to the extent applicable to its business model.

8.2. The Operator may monitor transactions, including KYT checks based on blockchain data, behavioral scoring, device monitoring and other methods of risk detection.

8.3. The Operator may require the User to provide documents and explanations confirming identity, address, source of funds (SoF) and/or source of wealth (SoW), as well as proof of ownership of assets.

8.4. The Operator may temporarily restrict functionality until the requested data is received. Failure to provide documents or provision of inaccurate information is grounds to refuse services, freeze assets and/or close the Account.

8.5. The Operator may apply Travel Rule measures (where applicable) and exchange necessary information with other virtual asset service providers as part of compliance.

8.6. The User acknowledges and agrees that compliance checks may cause delays in processing transactions and withdrawals.

9. Identification (KYC) and Access Tiers

9.1. The Operator may establish verification levels (for example, Basic/Enhanced/Professional) and link them to limits, access to features and transaction processing speed.

9.2. KYC may be required to access P2P, RUB Code operations, operations via Partners and/or upon reaching certain limits.

9.3. The Operator may conduct re-verification at any time, including requesting additional documents, selfie/video verification, proof of address and confirmation of control over contacts/devices.

9.4. For legal entities, the Operator may require documents on beneficial owners, ownership structure, authority of representatives, corporate resolutions and business profile.

9.5. The Operator may deny verification and/or reduce the User's access level without explanation if necessary for compliance.

10. Sanctions, Prohibitions and Refusal of Service

10.1. The User represents and warrants that they are not a Prohibited Person and do not act on behalf of Prohibited Persons.

10.2. The Operator may refuse service or restrict services without explanation if necessary to comply with sanctions, AML/CFT, counterparty requirements, risk assessment or other compliance grounds.

10.3. The Operator may apply geo- and sanctions screening, including using third-party databases and providers, and may assess links between transactions and sanctioned/high-risk addresses.

10.4. The User undertakes not to attempt to circumvent sanctions/restrictions, including through transaction splitting, use of intermediaries, mixers, exchange through high-risk services and other schemes.

10.5. The Operator may require disclosure of the ultimate beneficiary, controlling persons and source of funds, and confirmation that transactions are performed in the User's own interests.

10.6. The User agrees that the Operator may apply compliance measures with respect to linked accounts, devices, IP addresses and other identifiers.

11. Freezing, Holds, Reversals and Response Measures

11.1. Where there are signs of violations, sanctions or criminal risks, the Operator may restrict functionality, suspend transactions, freeze assets/funds and hold them until completion of checks.

11.2. The Operator may adjust internal accounting (including RUB) upon detection of errors, technical failures, abuse, fraud, chargeback scenarios, manipulation or other violations.

11.3. The Operator may cancel/review transactions and trades if: (a) the transaction occurred due to a system error; (b) signs of compromise are detected; (c) the transaction violates these Terms; (d) a mandatory authority request is received; (e) the assets are linked to high-risk sources.

11.4. The Operator may cooperate with competent authorities and provide information within the limits of applicable law and the privacy policy.

11.5. The User agrees that compliance decisions may be taken without disclosure of specific reasons where disclosure may harm an investigation, violate legal/counterparty requirements, or create security risks.

11.6. If erroneous crediting of assets/funds is detected, the Operator may take corrective actions, including debiting the erroneously credited amount, to the extent permitted by applicable law.

PART IV. ASSET ACCOUNTING, CUSTODY AND TECHNICAL OPERATIONS

12. Internal Accounting and Evidence (off-chain/on-chain)

12.1. The Operator maintains internal accounting of Users' balances. Internal ledger records are primary for determining the User's rights on the Platform unless mandatory provisions of applicable law provide otherwise.

12.2. On-chain data (transaction hashes, addresses, signatures) and off-chain confirmations (cabinet statements, electronic notifications, logs) may be used by the Parties as evidence in disputes.

12.3. In case of discrepancies between the display of a transaction in the interface and confirmation on the blockchain network, the final state is determined based on the Operator's reconciliation, taking into account network rules, compliance restrictions and internal logs.

12.4. In case of discrepancies between the display of a transaction in the interface and confirmation on the blockchain network, the final state is determined based on the Operator's reconciliation, taking into account network rules, compliance restrictions and internal logs.

12.5. The User acknowledges that transactions may be aggregated (batching) and routed through technical paths that do not match the addresses displayed in the interface.

13. Omnibus Custody and Custodial Providers

13.1. Virtual Assets may be stored under an omnibus model, including hot and cold storage, and/or through custodial providers.

13.2. The User understands and accepts that they do not have title to specific coins/UTXOs at a specific address; their right is determined by a claim against the Operator for delivery of an equivalent amount of assets, subject to fees and compliance checks.

13.3. The Operator may perform batching, use shared addresses, change transfer routing, and perform internal transfers of assets for security and operational efficiency.

13.4. The Operator may change custodial providers and custody infrastructure, and may use multi-signature, HSM, limits, monitoring and other safeguards.

13.5. The User acknowledges that custody of Virtual Assets involves risks including cyberattacks, protocol errors, forks, insolvency of counterparties and similar risks; see the Risk Warning for more.

13.6. The User agrees that in the event of bankruptcy/insolvency of certain infrastructure providers (including custodians), access to assets may be restricted; the Operator will use reasonable efforts to protect Users' interests but does not guarantee outcome.

14. Deposits and Withdrawals of Virtual Assets

14.1. Deposits are made by the User sending assets to an address/memo/tag specified by the Platform. The User is responsible for correct network, address and transfer parameters.

14.2. The Platform may require a minimum number of network confirmations. Until the threshold is reached, assets may be shown as pending and unavailable for transactions.

14.3. Withdrawals are made to the User's address provided that: (i) there is sufficient balance; (ii) fees are paid; (iii) compliance checks are passed; (iv) no restrictions/freezes exist.

14.4. The User must verify compatibility of the address with the network and token standard. Sending to the wrong network/address may result in irreversible loss.

14.5. The Operator may suspend deposits/withdrawals in case of force majeure, network failures, hard forks, increased security risks, investigations, regulator demands or provider demands.

14.6. The Operator may set minimum amounts, limits, delays, whitelist requirements and other security conditions.

14.7. The Operator may refuse to process a withdrawal if the destination address or related transaction is, in the Operator's opinion, associated with high risk (sanctions, fraud, stolen funds, etc.).

15. Network Fees, Forks, Airdrops and Network Support

15.1. Network fees are set by the blockchain network and/or infrastructure providers and may change. The Operator may charge an additional fee for processing withdrawals.

15.2. The Operator does not guarantee support for all forks, airdrops, token migrations or protocol upgrades. Support is at the Operator's discretion taking into account security and compliance.

15.3. In case of a fork/airdrop, the Operator may: (a) not support the new asset; (b) credit the asset partially/fully; (c) set conditions for receipt; (d) determine processing timeframes. The User acknowledges forks and airdrops may involve fraud and technical risks.

15.4. The Operator may suspend operations for an asset in case of suspected protocol vulnerability, attacks, chain reorganizations, lack of liquidity or sanctions risks.

PART V. TRADING FEATURES, LISTING AND P2P

16. Trading Features and Types of Transactions

16.1. The Platform may provide functionality for: (a) exchange of Virtual Assets; (b) spot trading; (c) conversion; (d) P2P; (e) other products if enabled (for example, Earn/staking/referral programs).

16.2. Availability of specific features depends on region, verification level, limits, technical condition and compliance assessment.

16.3. The Operator may introduce trading restrictions (minimum order sizes, tick sizes, limits on cancellation frequency, measures to ensure market integrity).

17. Orders, Execution and Obvious Errors

17.1. The Platform may support various order types (limit, market, stop orders, etc.). Specific order types and parameters are described in the interface/documentation.

17.2. The User is responsible for correctness of order parameters. Placing an order does not guarantee execution.

17.3. The Operator does not guarantee best price, absence of slippage, continuity of quotes or availability of a specific trading pair.

17.4. In case of an obvious quote error, technical failure, manipulation or other anomalies, the Operator may cancel/adjust trades and restore correct account state.

17.5. In case of partial execution of an order, the User agrees that the remainder may stay in the order book or be canceled depending on order type/settings.

17.6. The Operator may cancel orders and/or restrict trading in emergencies (matching engine issues, suspected attack, incorrect data).

18. Listing and Delisting

18.1. Listing/delisting decisions are at the Operator's discretion based on technological, market and compliance factors.

18.2. The Operator may suspend trading, deposits/withdrawals and other operations for an asset at any time if necessary to protect Users, comply with law, remediate vulnerabilities, sanctions control or other reasons.

18.3. Upon delisting, the Operator may set a withdrawal period. After the period, the Operator may disable withdrawals or apply other measures in accordance with internal rules and compliance.

19. Market Integrity and Prohibition of Manipulation

19.1. The User is prohibited from market manipulation, including wash trading, spoofing, layering, pump-and-dump, use of insider information and other abuses.

19.2. The Operator may use market surveillance systems, investigate suspicious activity, restrict trading and void trades upon detection of violations.

19.4. The Operator may impose penalty measures (for example, higher fees, API restrictions, cancellation restrictions) to protect market integrity.

20. P2P Section (Core Principles)

20.1. In the P2P section, transactions are concluded directly between Users. The Operator provides an interface, rules, and, where necessary, tools to freeze disputed assets and mediation, but is not a buyer/seller.

20.2. The User must comply with P2P rules, including requirements for payment descriptions, prohibition on sensitive words, anti-fraud policy and rules for confirming payment.

20.3. The User acknowledges that responsibility for choosing counterparties, payment methods and performance lies with Users. The Operator does not guarantee payment performance by the counterparty and is not liable for Users' actions in P2P.

20.4. The User acknowledges that responsibility for choosing counterparties, payment methods and performance lies with Users. The Operator does not guarantee payment performance by the counterparty and is not liable for Users' actions in P2P.

20.5. The Operator may set requirements for payment methods, restrictions on bank transfers, prohibition of third parties in settlements and other anti-fraud rules.

PART VI. RUB, CODES AND PARTNER MODEL

21. Legal Nature of RUB

21.1. RUB is the Platform's internal accounting unit. The display of "RUB" is conditional and used for Users' convenience.

21.2. RUB is not: (a) legal tender; (b) currency of any state; (c) electronic money; (d) a bank deposit/account; (e) a security; (f) an investment instrument; (g) a payment token; (h) an unconditional monetary obligation of the Operator to pay the User fiat funds.

21.3. The Operator does not guarantee equivalence of RUB to fiat money, a fixed conversion rate, or mandatory redeemability of RUB for cash or non-cash money.

21.4. RUB is intended solely for use within the Platform. Any attempts to use RUB as a means of payment outside the Platform are prohibited.

21.5. The Operator does not accept fiat funds from the User and does not provide the User with a monetary obligation to redeem RUB. Any fiat transactions are carried out outside the Platform between the User and independent Partners/third parties.

21.6. The Operator may establish RUB limits, suspend operations, cancel/adjust accruals in case of errors, fraud, AML risks or violation of these Terms.

21.7. The User undertakes not to disseminate information about acceptance of RUB outside the Platform and not to use wording that may mislead third parties as to the status of RUB.

22. RUB Codes

22.1. A RUB Code is a technical method of transferring/crediting RUB within the Platform's internal accounting.

22.2. Codes may have an expiration date, limits, restrictions on eligible recipients, KYC requirements and other parameters indicated in the interface/rules.

22.3. The Operator may revoke/cancel Codes and Code transactions in case of erroneous issuance, dispute, AML suspicions, fraud, compromise or other violations.

22.4. Any sale/transfer of Codes outside the Platform is at the User's risk and does not create obligations for the Operator.

22.5. Transfer of Codes and/or RUB between Users is permitted only within Platform functionality and subject to compliance requirements.

22.6. The Operator may set additional restrictions on Codes (for example, only for verified Users, prohibition of transfers between linked accounts, limit on number of redemptions, etc.).

23. Operations via Partners

23.1. The User may purchase RUB (or receive a RUB Code) from a Partner under a separate B2C transaction concluded outside the Platform. The legal nature of such transaction is determined by the Partner and the law applicable to the Partner.

23.2. The Operator is not a party to the User's B2C transaction with the Partner, does not accept cash/non-cash money from the User, and is not responsible for settlements between the User and the Partner.

23.3. The Platform may provide an application interface, selection of an office/cash desk and technical crediting/transfer of RUB. Such interface does not mean that money is transferred to the Operator.

23.4. The Partner may refuse to conclude a B2C transaction (including due to AML risks, lack of documents, exceeding limits, suspicious banknotes, technical failures).

23.5. The Operator does not guarantee conversion of RUB into fiat funds and does not dispense cash. Cash receipt is possible only via the User's own transactions with Partners or other methods available to the User.

23.6. The User acknowledges that the Partner's rates/fees/limits are determined by the Partner, may change and depend on region/channel. Any disputes related to the B2C transaction are resolved between the User and the Partner.

23.7. In case of a dispute related to a Partner operation, the Operator may provide informational support but is not an arbitrator for monetary settlements between the User and the Partner.

PART VII. FEES, PROHIBITIONS, DATA AND LIABILITY

24. Fees, Tariffs, Limits and Taxes

24.1. Trading fees, limits, network fees, Partner fees and other tariffs are published on the Platform and/or in help materials and may vary by region, verification level and product.

24.2. The Operator may change fees and limits at any time, including without prior notice, if required for security, compliance or market conditions.

24.3. The User is responsible for payment of taxes and duties applicable to their transactions and independently obtains professional advice.

24.4. Where tax withholding/reporting obligations arise in any jurisdiction, the Operator may act in accordance with applicable law (including withholding/disclosure of information) if required.

25. Prohibited Activities and Acceptable Use Policy

25.1. The User is prohibited from using the Platform for illegal activity, sanctions violations, AML violations, fraud, market manipulation or to harm the Operator/third parties.

25.2. Prohibited activities include (non-exhaustive):

• Money laundering, terrorism financing, sanctions evasion, facilitation of criminal activity;
• Use of mixers, tumblers, darknet services and other high-risk sources of funds where prohibited by compliance policies;
• Providing false information, using nominees, concealing beneficial owners;
• Phishing, hacking, malware, attempts to bypass security measures, social engineering;
• API abuse, exceeding rate limits, automation that violates rules;
• Price manipulation, wash trading, spoofing, exploitation of obvious quote/order errors and other technical anomalies;
• Infringement of intellectual property rights;
• Use of RUB outside the Platform or presenting RUB as money/payment instrument;
• Transferring an Account to third parties, selling Accounts, granting access without the Operator's consent;
• Using the Platform to distribute prohibited content, spam, threats or other abuse.

25.3. Upon violation, the Operator may take measures including blocking, freezing assets, canceling transactions, notifying authorities and recovering damages.

26. Intellectual Property

26.1. The Platform, its software, design, databases, trademarks and other elements belong to the Operator or its licensors and are protected by applicable law.

26.2. The User is granted a limited, non-exclusive, revocable license to use the Platform for its intended purpose. Any other use requires the Operator's written consent.

26.3. The User may not decompile, reverse engineer, extract source code, circumvent technical limitations or create derivative products based on the Platform, except as expressly permitted by law.

27. Personal Data and Confidentiality

27.1. Processing of personal data is carried out in accordance with the Privacy Policy published on the Platform and applicable law.

27.2. The User understands that data may be transferred to KYC/AML providers, hosting providers, analytics providers and competent authorities in cases provided by law/policies.

28. Risks and Disclaimer of Warranties

28.1. The User acknowledges the high risks of Virtual Asset transactions (volatility, technological and legal risks). A detailed Risk Warning is an integral appendix to these Terms.

28.2. The Platform is provided "as is" and "as available". The Operator gives no warranties of uninterrupted operation, accuracy of information, fitness for a particular purpose or absence of errors.

29. Limitation of Liability

29.1. The Operator is not liable for actions of Partners and terms of the User's B2C transactions with Partners, actions of P2P counterparties, or losses from volatility, erroneous transfers and Account compromise due to the User's fault.

29.2. To the maximum extent permitted by applicable law, the Operator is not liable for indirect damages, lost profits, loss of data, reputational harm or other consequential losses.

29.3. The Operator's aggregate liability for any claims is limited to the lesser of: (i) fees paid by the User to the Operator for the last 3 (three) months, or (ii) USD 100 (one hundred), unless prohibited by applicable law.

29.4. Nothing in these Terms limits liability to the extent it cannot be limited under applicable law.

30. Force Majeure

30.1. The Operator is not liable for non-performance due to force majeure, including actions of authorities, sanctions, wars, emergencies, provider outages, infrastructure shutdowns, forks, attacks and other events beyond the Operator's reasonable control.

30.2. During force majeure, the Operator may temporarily restrict or disable Platform features without liability to the User.

31. Indemnity

31.1. The User undertakes to indemnify the Operator for losses, fines, expenses and third-party claims arising from: (i) breach of these Terms, (ii) violation of law/sanctions, (iii) use of the Platform for illegal purposes, (iv) infringement of third-party rights.

32. Termination and Account Closure

32.1. The User may close their Account subject to completion of obligations, completion of necessary checks and withdrawal of available assets.

32.2. The Operator may restrict/close the Account in case of breaches of these Terms, AML risks, legal requirements, security threats or other compliance grounds.

32.3. Upon Account closure, the Operator establishes the procedure for withdrawal of available assets and/or completion of RUB operations, if permissible and not prohibited by a compliance decision.

32.4. The User agrees that certain assets/funds may remain frozen until completion of an investigation or fulfillment of mandatory authority requirements.

33. Governing Law and Dispute Resolution

33.1. These Terms are governed by the law of the Republic of El Salvador, unless the Operator expressly states otherwise for a specific product/region.

33.2. Pre-trial procedure: a claim is sent to support@abcex.io and/or legal@abcex.io. Response time: 30 calendar days unless otherwise provided by law.

33.3. All disputes are subject to international arbitration; seat of arbitration: San Salvador (or other place specified by the Operator), language: English. To the maximum extent permitted by law, the User waives class actions and agrees to individual proceedings.

34. Miscellaneous

34.1. Severability: if any provision is found invalid, the remaining provisions remain in force.

34.2. Assignment: the Operator may assign rights and obligations under these Terms to an affiliate or successor without the User's consent; the User may not assign without the Operator's consent.

34.3. Entire agreement: these Terms together with appendices and policies constitute the entire agreement between the Parties.

34.4. Survival: provisions on compliance, liability, arbitration, data and other provisions that by nature should survive will remain in effect after termination of use of the Platform.

35. Notices and Communications

35.1. The Operator may send notices through the Platform interface, email, SMS, messengers, push notifications and other channels specified by the User.

35.2. The User undertakes to keep contact details up to date. A notice is deemed delivered when sent to the last known contact.

35.3. The Operator may record and store communications with the User (including chats and calls) for security, service quality and dispute resolution purposes, unless prohibited by applicable law.

APPENDICES

• Appendix A: Fee Schedule (Fees and Limits) - published on the Platform
• Appendix B: Acceptable Use Policy (AUP)
• Appendix C: P2P Terms
• Appendix D: API Terms
• Appendix E: Complaints Policy (procedure for handling requests)
• Appendix F: List of Restricted Jurisdictions (sample)

Appendix A. Fee Schedule

Actual fees and limits are published in the Platform interface and may vary by region, verification level and product.

Appendix B. Acceptable Use Policy (AUP)

This AUP sets out acceptable use rules for the Platform. Violation of the AUP is a material breach of the ToS.

B1. Prohibited activities

• Any activity violating applicable law (including financial, sanctions, tax, consumer).
• Money laundering, terrorism financing, sanctions evasion, facilitation of criminal activity.
• Fraud, theft, misappropriation, extortion, sale of stolen data or assets.
• Trafficking in illegal goods/services, prohibited content, exploitation of minors.

B2. Prohibited technical actions

• Attempts of unauthorized access, hacking, exploitation of vulnerabilities, DDoS, interference with infrastructure.
• Use of malware, phishing, page spoofing, social engineering.
• Circumvention of restrictions (geo-blocking, limits, KYC) using VPN/proxy, nominees or other schemes.
• API abuse: exceeding rate limits, scraping data in circumvention of rules, automation causing service degradation.

B3. Prohibited market practices

• Market manipulation: wash trading, spoofing, layering, pump-and-dump, mark-the-close and similar practices.
• Use of insider information, collusion to distort price/volume.
• Exploitation of obvious quote/order errors and other technical anomalies.

B4. P2P and payment prohibitions

• Use of third-party payment details, involvement of third parties in settlements without disclosure and permission under P2P rules.
• Use in payment reference of words that may lead to blocking/sanctions (for example, "crypto", "bitcoin", "exchange") - if prohibited by P2P rules.
• Chargeback scenarios, triangulation schemes ("triangles"), forged receipts, fictitious payment confirmations.

B5. Measures upon breach

The Operator may apply response measures: warning, restriction of features, suspension of transactions, freezing of assets, request for documents, cancellation of transactions (where grounds exist), account closure and/or notification of competent authorities.

Appendix C. P2P Terms (extended version)

These P2P Terms apply to all P2P transactions. In case of conflict between the P2P Terms and the ToS, the P2P Terms prevail to the extent relating to P2P.

C1. Roles and responsibility

A P2P transaction is concluded between Users. The Operator is not a party to the transaction and does not conduct fiat settlements. Users bear full responsibility for legality of payments, choice of methods and compliance with rules.

C2. Timers, confirmations and cancellations

• The Buyer must make payment and press "Paid" before the timer expires.
• The Seller must confirm receipt of payment before the timer expires or open a dispute.
• It is prohibited to confirm "Paid" without actual payment.
• The Operator may restrict frequent cancellations and apply sanctions for abusing timers.

C3. Payment rules and evidence

• Payment must be made from an account/card belonging to the party to the transaction, unless otherwise permitted by the rules.
• It is prohibited to use third-party accounts, corporate accounts without disclosure, as well as accounts with elevated chargeback risk.
• Upon request in a dispute, the parties provide evidence: receipt, statement, screenshots, video recording, correspondence, proof of identity.

C4. Disputes and mediation

In a dispute, the Operator may request documents and decide on technical release of an asset. The Operator's decision is technical and does not replace court proceedings between Users.

If a compliance event (sanctions/AML) exists, assets in dispute may be held for an indefinite period until completion of checks.

C5. Anti-fraud and sanctions

The Operator applies anti-fraud and AML procedures. If fraud, chargeback, triangulation schemes or use of stolen funds is suspected, the Operator may freeze assets, restrict the account and provide information to competent authorities (within applicable law).

Appendix D. API Terms (extended version)

The API is provided on an as-is basis. The Operator may change or discontinue the API without notice if necessary for security, compliance or system stability.

D1. License and restrictions

• The API is provided for integration with the Platform and automation of User actions within the ToS.
• It is prohibited to use the API to bypass limits, scrape data in circumvention of rules, manipulate markets or engage in other prohibited activity.
• It is prohibited to provide the API to third parties as a service without the Operator's written consent.

D2. Key security

• Store keys in secure vaults (HSM/secret manager).
• Use least privilege, IP restrictions, key rotation.
• Immediately revoke keys upon suspected compromise.

D3. Rate limits and stability

The Operator sets rate limits and other technical restrictions. If limits are exceeded, requests may be rejected. The Operator does not guarantee continuous availability of the API and is not liable for consequences of downtime.

D4. Liability

The User is responsible for the results of algorithmic trading and correct integration. The Operator is not responsible for errors in the User's code, third-party libraries or the User's infrastructure.

Appendix E. Complaints Policy

• The User may submit a request/complaint to support at support@abcex.io, or a legal notice to legal@abcex.io.
• Describe the issue, specify account ID, date/time, transaction hash (if applicable), screenshots and other evidence.
• The Operator acknowledges receipt of the request and may request additional information.
• The review period is usually up to 30 calendar days unless otherwise required by law or the complexity of the investigation.
• In AML/sanctions cases, the Operator may not disclose details of the review (tipping-off prohibition).
• If the User disagrees with the response, they may submit a follow-up request with additional data or use the dispute resolution procedure.

Appendix F. Restricted Jurisdictions; Prohibited Persons and Prohibited Funds.

The services, products, and features made available through ABCEX.io and its related applications, APIs, and websites (collectively, the "Platform" and "Services") are not offered to, and must not be used by, any person who is: (i) a citizen or resident of, or located in, any jurisdiction subject to comprehensive sanctions, embargoes, or similar restrictions; or (ii) a Prohibited Person, including any individual or entity that ABCEX.io knows or reasonably suspects is involved in criminal and/or terrorist activity, acts on behalf of or at the direction of such persons, or is owned or controlled by such persons. Without limiting the foregoing, ABCEX.io may, in its sole discretion, restrict, suspend, terminate, or otherwise limit access to all or part of the Services, or refuse to process any transaction, for citizens or residents of, or persons located in Afghanistan, Bosnia and Herzegovina, the United States, the Democratic People's Republic of Korea, the Democratic Republic of the Congo, Eritrea, Ethiopia, Guyana, Iran, Iraq, the Lao People's Democratic Republic, Libya, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Tunisia, Uganda, Vanuatu, and Ukraine, and may update this list at any time. ABCEX.io does not establish or maintain business relationships with persons known or reasonably suspected to be criminals and/or terrorists, does not process transactions that are known to be the proceeds of, or otherwise derived from, criminal and/or terrorist activity, and does not facilitate any dealings connected to such activity. In addition, ABCEX.io may reject, block, delay, reverse where feasible, or subject to enhanced due diligence any funds or transactions associated with certain high-risk sources, services, typologies, or counterparties, including (without limitation) BeriBit, HODLHODL, SkyBtc Banker, Black Sprut, Wasabi Wallet, Bitzlato, Hydra, Tornado Cash, OMG!OMG!, MEGA DARKNET MARKET, FreeBitcoin, casinos or other gambling services, and 1xBet.