> For the complete documentation index, see [llms.txt](https://docs.holdstation.com/holdstation/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.holdstation.com/holdstation/holdstation-pay/term-of-use.md). # Term of Use ## Introduction Welcome to **Holdstation Pay**. These Terms of Use ("**Terms**") constitute a legally binding agreement between **you** ("User") and **Fundara**, operating as **Holdstation Pay** ("Holdstation Pay", "Fundara", "we", "our", or "us"). Fundara is a company incorporated in the Republic of Poland: | Item | Information | | ----------------- | ----------- | | Company | Fundara | | Country | Poland | | KRS Number | 0001122160 | | NIP | 5214087337 | | VASP Registration | RDWW-1544 | These Terms govern your access to and use of: * Holdstation Pay website * Holdstation Pay platform * All products * All services * Widgets * Related content provided by Holdstation Pay By accessing or using Holdstation Pay, you agree to be bound by: * These Terms of Use * Our Privacy Policy * Any additional policies published on the Platform If you do not agree with these Terms, you must not access or use the Services. *** ### GDPR Notice As a controller established within the European Union, Holdstation Pay processes personal data in accordance with: * General Data Protection Regulation (GDPR) * Applicable Polish data protection laws Please review our Privacy Policy to understand how your personal information is collected, processed, stored, and protected. *** ### Scope of These Terms These Terms apply **globally**, except for users located in: * European Union (EU) * European Economic Area (EEA) * United States These users are **not eligible** to access or use Holdstation Pay under these Terms. Holdstation Pay: * Does **not** onboard EU/EEA customers; * Does **not** market or provide Services to EU/EEA customers; * Does **not** hold, custody, process, or manage fiat or digital assets belonging to EU/EEA customers. > **Important:** Eligibility requirements and restricted jurisdictions are further described in **Section 2** and **Section 3**. *** ### Regulatory Disclosure Fundara is registered in Poland as a **Virtual Asset Service Provider (VASP)**. | Item | Information | | ---------------------- | ------------------------------------------------------ | | Registration Authority | Director of the Tax Administration Chamber in Katowice | | Registration Number | RDWW-1544 | For Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) purposes, Fundara is an obliged institution supervised by: **General Inspector of Financial Information (GIIF)** A complete list of applicable regulations is available in **Section 23**. *** ## 1. Definitions Unless otherwise specified, the following definitions apply throughout these Terms. ### 1.1 Account A verified user profile created through Holdstation Pay containing: * Personal information * Identification information * Transaction history * Verification records *** ### 1.2 AML/CTF Laws Applicable Anti-Money Laundering and Counter-Terrorist Financing laws and regulations, including: * Polish AML Act (1 March 2018) * Applicable EU AML Directives * Applicable local AML/CTF regulations * Other laws intended to prevent: * Money laundering * Terrorist financing * Financial crime *** ### 1.3 Buyer A User purchasing Digital Assets using Fiat Currency through Holdstation Pay. *** ### 1.4 Fiat Currency Government-issued currency recognized as legal tender. *** ### 1.5 Funds Fiat currency or Digital Assets used in connection with Holdstation Pay Services. *** ### 1.6 Digital Asset / Virtual Currency A digitally represented value that: * Exists on blockchain networks; * Is transferable electronically; * Is not issued by any government; * Is accepted as a medium of exchange. Examples include: * Bitcoin (BTC) * Ethereum (ETH) * USDT *** ### 1.7 Network Fee The blockchain fee required to process and confirm transactions on the relevant blockchain network. *** ### 1.8 On-Ramp A service allowing Users to purchase Digital Assets using fiat currency. Before completing an order, Holdstation Pay may perform: * AML screening * Sanctions screening * Fraud detection * Compliance review Once payment has been received and approved, Holdstation Pay transfers the purchased Digital Assets directly to the User's designated wallet using Holdstation Pay's own inventory. *** ### 1.9 Off-Ramp A service allowing Users to sell Digital Assets in exchange for: * Fiat Currency; or * Other supported Digital Assets. Upon receiving the Digital Assets, Holdstation Pay completes the transaction by: * Sending fiat currency to the User's payout account; or * Delivering the agreed Digital Asset in the case of a swap. Compliance reviews may be performed before settlement. *** ### 1.10 Services All products and services provided by Holdstation Pay, including purchasing and selling Digital Assets. *** ### 1.11 Payout Account The account designated by the User to receive fiat proceeds from Off-Ramp transactions. Examples include: * Personal bank accounts * Approved payment accounts * Other supported payout methods *** ### 1.12 Platform The Holdstation Pay environment enabling: * Fiat-to-Crypto exchange * Crypto-to-Fiat exchange *** ### 1.13 Purchase A User instruction to buy Digital Assets using Fiat Currency. Purchased assets will be delivered directly to the wallet address designated by the User. *** ### 1.14 Site The official Holdstation Pay website: [**https://pay.holdstation.com**](https://pay.holdstation.com) *** ### 1.15 Sell A User instruction to sell Digital Assets for Fiat Currency. After successful completion, fiat proceeds will be transferred to the User's designated payout account. *** ### 1.16 Transaction Price The total amount paid by the Buyer for a transaction. *** ### 1.17 Transaction The completed transfer of Digital Assets or Fiat Currency through Holdstation Pay. *** ### 1.18 Transaction Fee The fee charged by Holdstation Pay for completing a transaction. *** ### 1.19 User Any individual or legal entity using Holdstation Pay Services. *** ### 1.20 Wallet A blockchain wallet address designated by the User to receive purchased Digital Assets. *** ### 1.21 Widget A standalone integration allowing third-party platforms to access Holdstation Pay Services. *** ### 1.22 Excluded and Not Supported Jurisdictions Holdstation Pay does **not** provide Services to Users located in: #### European Union (EU) #### European Economic Area (EEA) #### United States Additionally, Services are unavailable in jurisdictions subject to sanctions or internal restrictions, including but not limited to: * Afghanistan * Belarus * Central African Republic * China * Cuba * Ethiopia * Iran * Iraq * Lebanon * Libya * Myanmar * North Korea * Russia * Somalia * Sudan * Syria * Venezuela * Yemen * Zimbabwe This list may be updated from time to time. *** ### 1.23 Interpretation Words expressed in the singular include the plural, and vice versa, where the context requires. *** ## 2. Entity and Service Scope ### 2.1 Service Availability These Terms apply globally except to Users located in the European Union or the EEA. *** ### 2.2 Operating Entity All Services are provided exclusively by: **Fundara (Poland)** There are no affiliated entities providing Services under these Terms. *** ### 2.3 Company Information Legal and contact information for Fundara is available within these Terms and on the Holdstation Pay website. *** ### 2.4 EU/EEA Restriction Users located within the EU or EEA: * Cannot create accounts; * Cannot complete onboarding; * Cannot access Holdstation Pay Services. Where Holdstation Pay reasonably determines that a User is located within the EU or EEA, it may: * Refuse onboarding; * Reject transactions; * Reverse transactions where legally permitted; * Suspend or terminate access. *** ### 2.5 Availability by Jurisdiction Service availability depends on local laws and regulations. Users are solely responsible for ensuring that their use of Holdstation Pay complies with all applicable laws in their jurisdiction. *** ### 2.6 Blockchain Finality Because blockchain transactions are irreversible: * Wallet addresses cannot be modified after submission. * Transactions generally cannot be cancelled. * Users are responsible for verifying all transaction details before confirmation. *** ## 3. Eligibility and Compliance To use Holdstation Pay, you must satisfy **all** of the following conditions. ### 3.1 Eligibility Requirements You must: * Be at least the legal age required to use financial services (generally 18 years or older); * Not be located, resident, or established in the EU or EEA; * Not be located in the United States; * Reside in a jurisdiction where Holdstation Pay is authorized to provide Services; * Have full legal capacity to enter into binding agreements; * Not be subject to sanctions or legal restrictions. *** ### 3.2 Compliance Representation By using Holdstation Pay, you represent and warrant that all eligibility requirements above remain true and accurate. Holdstation Pay may suspend or terminate your access to the Services if it reasonably believes that: * You no longer satisfy the eligibility requirements; * You violate applicable laws; * You violate these Terms of Use; * You are located in a restricted jurisdiction. *** ## 4. Description of Services Holdstation Pay provides a platform that enables Users to exchange fiat currency and supported Digital Assets through a non-custodial infrastructure. *** ### 4.1 Available Services Holdstation Pay currently provides the following Services: #### 4.1.1 On-Ramp Purchase supported Digital Assets using fiat currency. *** #### 4.1.2 Off-Ramp Sell supported Digital Assets in exchange for fiat currency. *** #### 4.1.3 Direct Transactions Unless otherwise stated, when you buy or sell Digital Assets through Holdstation Pay, you are transacting **directly with Holdstation Pay (Fundara)**. *** ### 4.2 Non-Custodial Services Holdstation Pay operates as a **non-custodial service provider**. We do **not**: * Hold fiat currency on your behalf; * Hold Digital Assets on your behalf; * Provide custodial wallet services. *** ### 4.3 User-Controlled Wallets All purchases and sales are initiated by the User. Digital Assets are delivered directly to, or received directly from, a blockchain wallet address controlled by the User. Holdstation Pay does not provide hosted wallet accounts. *** ### 4.4 Third-Party Payment Processing Holdstation Pay is **not**: * a payment acquirer; * a payment processor; * a card payment network. All fiat payment transactions are processed by authorized third-party payment providers. Holdstation Pay does not directly acquire or process payment card transactions. *** ## 4A. No Right of Withdrawal / All Sales Final ### 4A.1 No Cooling-Off Period Holdstation Pay does **not** provide Services to consumers located within the European Union or the European Economic Area (EEA). Accordingly, the withdrawal rights provided under the **EU Consumer Rights Directive (2011/83/EU)** do not apply to these Terms. *** ### 4A.2 Finality of Transactions Digital Asset transactions are executed immediately after your authorization. Once a transaction has been executed: * it cannot be cancelled; * it cannot be withdrawn; * it cannot be reversed; * it cannot be modified. By confirming a Purchase or Sell Order, you acknowledge that: * Holdstation Pay begins fulfilling your order immediately; * the agreement is fully performed once Digital Assets or fiat funds have been delivered; * no cooling-off period applies except where mandatory consumer protection laws in your jurisdiction provide otherwise. > **Important:** Please carefully review all transaction details before confirming an order, as blockchain transactions are generally irreversible. *** ## 5. Accessing the Services and User Verification (Onboarding & KYC/AML Compliance) ### 5.1 License to Use the Services Subject to your ongoing compliance with these Terms, Holdstation Pay grants you a: * revocable; * limited; * non-exclusive; * non-transferable license to access and use the Services for your personal and lawful purposes. Holdstation Pay may suspend or terminate this license at any time. *** ### 5.2 User Onboarding Certain Services require successful completion of Holdstation Pay's onboarding process. Onboarding is conducted in accordance with: * applicable laws; * Holdstation Pay's Compliance Program; * AML and KYC requirements. *** ### 5.2A EU/EEA Restrictions Identity verification and onboarding are **not available** to Users who are: * located in the EU; * resident in the EU; * established within the EEA. Holdstation Pay applies screening measures intended to prevent access by Users located within restricted jurisdictions. *** ### 5.3 Required Verification Information During onboarding, Holdstation Pay may request information including, but not limited to: * Full legal name; * Date of birth; * Residential address; * Email address; * Phone number; * National identification number; * Government-issued photo identification; * Source of funds; * Bank account information; * Device or network information; * Proof of address; * Selfie or facial verification; * Any additional information reasonably required for compliance or risk management. *** ### 5.4 Identity Verification You authorize Holdstation Pay, directly or through authorized third parties, to verify: * your identity; * documents provided; * information submitted during onboarding. Verification may include additional inquiries where reasonably necessary. *** ### 5.5 Accuracy of Information You represent and warrant that all onboarding information is: * accurate; * complete; * up to date. You agree to notify Holdstation Pay of any material changes within **10 days** after becoming aware of such changes. *** ### 5.6 Additional Information Requests Holdstation Pay may request additional verification documents at any time. You agree to provide any requested information within **14 days** of receiving the request. Failure to do so may result in: * restricted account functionality; * suspension of Services; * termination of your account. *** ### 5.7 AML & Compliance Reviews To comply with applicable AML and Counter-Terrorist Financing (CTF) regulations, Holdstation Pay may request additional documentation: * during onboarding; * after account creation; * during transaction reviews; * whenever required by law. *** ### 5.8 Personal Data Personal information collected during onboarding is processed in accordance with: * Holdstation Pay Privacy Policy; * applicable data protection laws. *** ### 5.9 Suspension for Compliance Reasons Holdstation Pay reserves the right to suspend or terminate access to the Services if: * your identity cannot be verified; * fraudulent activity is suspected; * unauthorized use is detected; * applicable laws or these Terms are violated. *** ## 6. User Rights, Responsibilities, Representations, and Conduct ### 6.1 Right to Access the Services Users may access and use: * the Website; * the Widget; * the Platform; * Holdstation Pay Services, provided they comply with these Terms. *** ### 6.2 Acceptance of the Terms By accessing or using the Services, you confirm that you have: * read these Terms; * understood these Terms; * agreed to comply with these Terms; * agreed to comply with all applicable laws within your jurisdiction. *** ### 6.3 Lawful Use You agree to use Holdstation Pay solely for lawful purposes. You must not use the Services for activities involving: * money laundering; * terrorist financing; * fraud; * or any other unlawful activity. *** ### 6.4 Account Security You are solely responsible for: * protecting your login credentials; * maintaining account security; * all activity performed using your account. Unless expressly approved in writing by Holdstation Pay, you may not maintain more than one account. *** ### 6.4A Account Sharing Prohibited Each Holdstation Pay account may only be used by the individual who registered it. You agree **not** to: * share your account; * allow another person to use your account; * provide account access to third parties. *** ### 6.5 Security Notifications You must immediately notify Holdstation Pay at: **** if you become aware of: * unauthorized account access; * compromised credentials; * suspected security incidents. *** ### 6.6 Responsibility for Transactions Blockchain transactions are irreversible. You are solely responsible for verifying: * wallet addresses; * transaction amounts; * payment details; * destination information before submitting any transaction. *** ### 6.7 Compliance Cooperation You agree to provide any additional information reasonably requested by Holdstation Pay to comply with: * AML requirements; * CTF regulations; * sanctions screening; * applicable legal obligations. You also agree to cooperate with any compliance investigations where required. *** ### 6.8 Transaction Risk You acknowledge that you are solely responsible for evaluating: * the suitability of each transaction; * your own financial circumstances; * your individual risk tolerance. Holdstation Pay does not make investment decisions on your behalf. *** ### 6.9 Payment Methods All payment methods used with Holdstation Pay must belong to you. This includes, but is not limited to: * Bank accounts * Payment cards * Other supported payment instruments Using a payment method owned by another individual may be treated as fraudulent activity. Holdstation Pay strictly prohibits transactions made using: * Another person's bank account; * Another person's payment card; * Any unauthorized payment instrument. Violations may result in account suspension or termination. *** ### 6.9A Third-Party Accounts and Wallets You may **not**: * Send funds from a third-party bank account; or * Receive funds into a third-party bank account or wallet. All payment methods and wallet addresses used in connection with Holdstation Pay must be owned and controlled by you. *** ### 6.10 Indemnification You agree to indemnify and hold Holdstation Pay harmless against any damages, losses, liabilities, or expenses arising from: * Your breach of these Terms; * Your violation of applicable laws; * Your infringement of any third-party rights. *** ### 6.11 User Representations and Warranties By using the Services, you represent and warrant that: #### (a) Sanctions Compliance You are **not**: * located in a sanctioned jurisdiction; * controlled by a sanctioned person; * listed on any applicable sanctions list. This includes, but is not limited to: * European Union sanctions * United Nations sanctions * OFAC (United States) * OFSI (United Kingdom) * Other applicable governmental sanctions lists *** #### (b) Restricted Jurisdictions You are **not**: * located in the European Union (EU); * located in the European Economic Area (EEA); * located in the United States. *** #### (c) Ownership of Payment Methods You own and control: * all linked bank accounts; * all payment methods; * all wallet addresses used in connection with Holdstation Pay. You agree to promptly update this information whenever changes occur. *** #### (d) Legal Compliance You agree to comply with all applicable laws and regulations, including those relating to: * Anti-Money Laundering (AML) * Counter-Terrorist Financing (CTF) * Sanctions compliance * Tax reporting * Consumer protection * Financial crime prevention *** #### (e) Unauthorized Automation You will not use unauthorized automated tools such as: * bots; * spiders; * scrapers; * automated scripts; * data extraction tools without Holdstation Pay's prior written consent. *** #### (f) Circumvention You will not attempt to bypass: * geographic restrictions; * technical controls; * regulatory restrictions; * eligibility requirements. *** #### (g) Permitted Automation Reasonable user-initiated automation (such as recurring purchases) is permitted only where expressly supported by Holdstation Pay. *** #### (h) Malicious Software You will not introduce: * malware; * viruses; * ransomware; * hacking tools; * malicious code; * harmful scripts into the Services. *** ### 6.12 Cooperation You agree to cooperate with Holdstation Pay whenever we request: * clarification; * confirmation; * additional documentation; * updated information relating to your account or transactions. *** ### 6.13 Additional User Representations You further represent that: #### (a) Lawful Source of Funds All fiat currency used to purchase Digital Assets: * belongs to you; and * originates from lawful sources. *** #### (b) Lawful Transactions All transactions conducted through Holdstation Pay: * comply with applicable laws; and * do not infringe the rights of any third party. *** #### (c) Compliance Data Sharing You acknowledge that Holdstation Pay may share your personal information with authorized third parties where necessary to comply with: * applicable laws; * AML obligations; * tax reporting requirements; * crime prevention obligations; * regulatory requirements. Such processing is carried out in accordance with the Holdstation Pay Privacy Policy. *** ### 6.13A Third-Party Platform Transactions You may access Holdstation Pay through an integrated third-party platform, website, application, embedded widget, or white-label solution (each, a **Third-Party Platform**). When using Holdstation Pay through a Third-Party Platform, you acknowledge and agree that: #### (a) Third-Party Integration Your transaction is initiated through a Third-Party Platform that has integrated Holdstation Pay's Services. *** #### (b) Data Sharing To complete your transaction and satisfy regulatory obligations, Holdstation Pay may share certain information with the Third-Party Platform, including: * Identity verification information; * KYC information; * Tokenized or securely processed payment credentials; * Other information reasonably necessary to complete the transaction. *** #### (c) Purpose Limitation Information will only be shared to the extent necessary to: * process your transaction; * complete onboarding; * satisfy compliance obligations; * support the third-party integration. *** #### (d) Third-Party Responsibility Holdstation Pay is **not responsible** for how a Third-Party Platform subsequently: * stores; * processes; * shares; or * protects your information. Those activities are governed by the Third-Party Platform's own: * Terms of Service; * Privacy Policy; * applicable legal obligations. *** By proceeding with a transaction through a Third-Party Platform, you expressly consent to the data sharing described above. *** ### 6.14 User Conduct You are solely responsible for your conduct while using Holdstation Pay. You agree to comply with all: * applicable laws; * regulations; * governmental requirements. *** ### 6.15 Prohibited Activities Without limiting the foregoing, you agree **not** to: #### (a) Interfere with the Services Use the Services in any manner that: * disrupts other users; * impairs system performance; * damages Holdstation Pay's infrastructure; * overloads our systems. *** #### (b) Illegal Activities Use Holdstation Pay for activities including, but not limited to: * illegal gambling; * fraud; * money laundering; * terrorist financing; * other unlawful conduct. *** #### (c) Unauthorized Data Collection Use any: * robot; * spider; * crawler; * scraper; * automated interface to access or extract data from Holdstation Pay without authorization. *** #### (d) Unauthorized Account Access You must not: * use another person's account; * impersonate another individual; * provide false or misleading information. *** #### (e) Circumvent Restrictions Attempt to bypass: * content filtering; * access controls; * technical restrictions; * eligibility requirements. *** #### (f) Harmful Software Upload or introduce: * malware; * Trojan horses; * worms; * logic bombs; * malicious software; * other harmful code. *** #### (g) Unauthorized Integrations Develop or operate third-party software that interacts with Holdstation Pay without prior written approval. *** #### (h) Encouraging Violations Encourage, facilitate, or assist another person in violating these Terms. *** ## 7. Holdstation Pay's Rights and Responsibilities ### 7.1 Transaction Review Holdstation Pay reserves the right to suspend, refuse, delay, freeze, or block any transaction where we reasonably suspect: * fraud; * money laundering; * sanctions violations; * illegal activity; * violations of these Terms; * violations of applicable law. Where necessary, Holdstation Pay may freeze fiat currency or Digital Assets before settlement. *** ### 7.2 Standard of Service Holdstation Pay will provide the Services using commercially reasonable care. Our responsibility is limited to: * processing transactions; * submitting Digital Asset transfer instructions to the relevant blockchain network. *** ### 7.3 Blockchain Responsibility Once Holdstation Pay has successfully submitted a blockchain transaction, we are not responsible for: * confirmation times; * blockchain delays; * network congestion; * successful receipt by your wallet. Transaction completion ultimately depends on the relevant blockchain network. *** ### 7.4 Limitation of Operational Liability To the maximum extent permitted by law, Holdstation Pay is not liable for indirect or consequential damages including: * lost profits; * lost revenue; * business interruption; * loss of opportunity; * loss of data, unless directly caused by Holdstation Pay's material breach of these Terms. *** ### 7.5 Third-Party Service Interruptions Holdstation Pay is not responsible for delays or interruptions caused by: * internet outages; * blockchain congestion; * banking systems; * payment processors; * other third-party service providers. *** ### 7.6 Fraud Reporting Where required by law, Holdstation Pay may: * report suspicious activity to competent authorities; * provide transaction information; * provide user identification information; * freeze related accounts or transactions. This may occur in connection with investigations relating to: * fraud; * money laundering; * terrorist financing; * sanctions compliance. *** ### 7.7 Non-Excludable Liability Nothing in these Terms excludes or limits Holdstation Pay's liability for: * fraud committed by Holdstation Pay; * death or personal injury caused by Holdstation Pay's negligence; * any liability that cannot legally be excluded. *** ## 7A. Export Control and Sanctions Compliance ### 7A.1 Compliance The Services are subject to applicable: * export control laws; * economic sanctions; * trade embargoes. These may be administered by authorities including: * European Union; * United Nations; * United States; * United Kingdom; * Poland; * other competent authorities. *** ### 7A.2 Sanctioned Jurisdictions You represent that you are not located in any comprehensively sanctioned jurisdiction, including (without limitation): * Iran * North Korea * Syria * Cuba * Crimea * Donetsk * Luhansk or any other jurisdiction subject to applicable sanctions. *** ### 7A.3 Restricted Activities You may not use Holdstation Pay to engage in any activity that violates applicable: * export control laws; * sanctions regulations; * trade restrictions. *** ### 7A.4 Enforcement Where Holdstation Pay reasonably suspects a violation of export control or sanctions laws, we may: * suspend your account; * terminate access to the Services; * reject transactions; * freeze assets where legally required. *** ## 8. Transaction Terms and Refund Policy ### 8.1 Finality of Transactions All transactions processed through Holdstation Pay are **final**. #### On-Ramp Transactions For On-Ramp transactions, an order becomes final once: * the Digital Asset has been broadcast to the blockchain; and * a blockchain transaction ID (TxID) has been generated. Because blockchain transactions are irreversible, completed transfers cannot be cancelled, modified, or recalled. *** #### Off-Ramp Transactions For Off-Ramp transactions, an order becomes final once the fiat payout has been successfully processed to your designated payout account. *** #### Transaction Reference The blockchain transaction ID or transaction reference may be used to: * resolve disputes; * investigate transaction issues; * verify completed transactions. *** ### 8.2 Refund Eligibility Refunds are only available under limited circumstances. These include: #### 8.2.1 Unsupported Digital Assets You send an unsupported cryptocurrency or use an unsupported blockchain network. *** #### 8.2.2 Amount Below Minimum You send an amount below the minimum transaction threshold. *** #### 8.2.3 Processing Failure Holdstation Pay is unable to complete the transaction due to: * fraud detection; * compliance reviews; * technical processing failures. *** ### 8.3 Refund Deductions Where a refund is approved, Holdstation Pay may deduct: * applicable blockchain network fees; * third-party payment processing fees; * investigation costs; * administrative costs reasonably incurred during the refund process. *** ### 8.4 Sanctions-Related Funds If Holdstation Pay determines that funds originate from, or are connected to: * sanctioned wallet addresses; * sanctioned individuals; * sanctioned entities; * prohibited jurisdictions, we may take one or more of the following actions. #### 8.4.1 Freeze Funds Freeze the affected funds indefinitely where required by applicable law. *** #### 8.4.2 Report to Authorities Notify the appropriate governmental or regulatory authorities, including where applicable: * General Inspector of Financial Information (GIIF) * European Union sanctions authorities * United Nations Security Council * Office of Foreign Assets Control (OFAC) * Office of Financial Sanctions Implementation (OFSI) * Other competent authorities *** ### 8.5 Refund Method Where possible, approved refunds will be returned: * using the same payment method; or * to the same blockchain wallet used for the original transaction. *** #### 8.5.1 Alternative Refund Method Where returning funds using the original payment method is not possible, Holdstation Pay may request: * another compatible wallet address; or * another eligible refund destination. *** #### 8.5.2 Unrecoverable Funds If the refund amount is less than the required: * blockchain network fee; or * processing cost, the funds may be considered **unrecoverable** and no refund may be possible. *** ## 9. Order Rules, Limitations, and User Accountability ### 9.1 Minimum Order Amount The minimum order amount for both On-Ramp and Off-Ramp transactions is: > **10 USDT (or equivalent value).** Orders below this amount may not be processed. Where feasible, Holdstation Pay will attempt to refund the received amount after deducting applicable network fees. *** If: * the amount is too small to cover refund costs; or * the Digital Asset is unsupported or unrecognized, the funds may become permanently unrecoverable. *** ### 9.2 Incorrect or Unsupported Digital Assets #### 9.2.1 Wrong Supported Asset If you send a supported cryptocurrency different from the asset specified in your order, Holdstation Pay may process the transaction using the asset actually received. *** #### 9.2.2 Incorrect Amount If you send a supported asset in an incorrect amount (but above the minimum threshold), Holdstation Pay may: * process the transaction; * request additional verification; * require additional KYC or compliance checks. *** #### 9.2.3 Unsupported Assets Holdstation Pay does not guarantee recovery of unsupported or unknown Digital Assets. Such assets may be permanently unrecoverable. *** ### 9.3 Service Availability Access to Holdstation Pay Services depends on applicable laws and regulations. Holdstation Pay reserves the right to: * restrict access; * suspend Services; * prohibit transactions; * impose transaction limits; at its sole discretion and without prior notice where permitted by law. *** ### 9.4 User Responsibility for Orders You are solely responsible for ensuring that all transaction information is accurate before submitting an order. This includes: * wallet addresses; * payment details; * transaction amounts; * destination accounts. *** #### 9.4.1 Transaction Review Before confirming an order, you should carefully review the transaction summary. *** #### 9.4.2 Mistaken Transactions Holdstation Pay is not responsible for losses resulting from: * incorrect wallet addresses; * unsupported wallets; * accidental transfers; * user input errors. Blockchain transactions are generally irreversible. *** ### 9.5 Account Security You are solely responsible for: * protecting your login credentials; * maintaining account security; * all activity performed through your account. Transactions initiated using your credentials will generally be considered authorized by you. *** ### 9.6 Unauthorized Transactions Except where required by applicable law, Holdstation Pay is not liable for losses resulting from unauthorized access to your account. *** ### 9.7 Security Incident Notifications If Holdstation Pay determines that your personal information or account may have been compromised due to a security incident, we will notify you as required by applicable law. You agree to cooperate with any reasonable measures required to: * secure your account; * prevent further loss; * investigate the incident. *** ## 10. Fees, Payment Processing, and Merchant of Record ### 10.1 Transaction Fees All applicable fees will be displayed before you confirm a transaction. By proceeding with the transaction, you agree to pay all disclosed fees. *** ### 10.1A Regulatory Compliance All payment transactions are processed in accordance with applicable financial regulations and payment laws within the relevant jurisdiction. *** ### 10.2 Currency Display Fees and transaction amounts may be displayed in: * local currency; or * EUR equivalent, depending on your location and payment method. *** ### 10.2 Merchant of Record Fundara, operating as **Holdstation Pay**, acts as the **Merchant of Record** for transactions completed through the Platform. Although Holdstation Pay uses third-party payment processors to facilitate payments, Holdstation Pay remains responsible for providing the Services purchased under these Terms. However, Holdstation Pay is not responsible for delays or technical errors caused by third-party payment providers. *** ### 10.3 Payment Authorization By using your chosen payment method, you authorize Holdstation Pay (directly or through authorized payment processors) to: * debit payments; * credit refunds; * process reversals; * process adjustments; for the full transaction amount, including applicable fees and taxes. *** ### 10.4 Card Network Rules Your payment method remains subject to the rules of: * your financial institution; * Visa; * Mastercard; * other applicable payment networks. You agree to comply with all applicable payment network requirements. *** ### 10.5 Third-Party Processing Fees Payment providers may charge additional fees, including: * currency conversion fees; * cross-border fees; * banking charges; * network assessment fees. These fees are outside Holdstation Pay's control. *** #### 10.5.1 Holdstation Pay Fees Holdstation Pay may charge fees including: * processing fees; * blockchain network fees; * ecosystem partner fees. Applicable fees depend on factors such as: * network congestion; * payment method; * operational costs. All applicable fees will be disclosed before confirming a transaction. *** ### 10.6 Fee Updates Current fee schedules are available on the Holdstation Pay website. Holdstation Pay may update fees from time to time without prior notice. You are responsible for reviewing applicable fees before submitting a transaction. *** ### 10.6A Blockchain Network Fees Blockchain Network Fees: * are determined by the blockchain network; * fluctuate dynamically; * are outside Holdstation Pay's control. These fees are separate from Holdstation Pay's own service fees. *** ### 10.7 Payment Capture For card transactions, Holdstation Pay captures payment only after: * the Digital Asset has been broadcast to the blockchain; and * a blockchain transaction ID has been generated. *** ### 10.8 Sufficient Funds You are responsible for maintaining sufficient: * account balances; * available credit; * payment limits to complete your transactions. Holdstation Pay is not responsible for overdraft charges or other fees imposed by your financial institution. *** ### 10.9 Transaction Rejection Holdstation Pay reserves the right to refuse, suspend, cancel, reverse, or decline any transaction where necessary, including where: * fraud is suspected; * insufficient funds exist; * these Terms are violated; * applicable laws require intervention. *** ### 10.10 Refund Authorization You expressly authorize Holdstation Pay to process refunds and payment reversals where appropriate under these Terms and applicable law. *** ### 10.11 Transaction Receipts After each completed transaction, Holdstation Pay will provide a transaction receipt. The receipt may include: * purchased or sold Digital Assets; * applicable fees; * payment amounts; * credited or debited totals. *** ## 10A. Transactions ### 10A.1 Buying and Selling Digital Assets Holdstation Pay enables Users to purchase and sell supported Digital Assets using fiat currency through: * the Holdstation Pay Website; or * supported Widgets and partner integrations. *** ### 10A.2 Crypto Delivery #### Card Payments For card payments, Holdstation Pay will only capture payment after: * the cryptocurrency transaction has been broadcast to the relevant blockchain; and * the transaction ID (TxID) has been generated and made available to the User. Authorization and payment capture are typically completed within a few seconds while Holdstation Pay performs: * Anti-Fraud screening; * AML checks; * KYC verification; * Counter-Terrorist Financing (CTF) controls. *** #### Bank Transfers and Alternative Payment Methods Where payment is made using: * bank transfer; or * another supported payment method, Digital Assets are generally delivered shortly after Holdstation Pay confirms receipt of payment and completes all required compliance checks. *** #### Failed Compliance Checks If a transaction fails Anti-Fraud, AML, KYC, or CTF reviews, Holdstation Pay may reject the transaction and initiate a refund, provided the funds are not associated with: * money laundering; * terrorist financing; * sanctions violations; or * other unlawful activity. *** ### 10A.3 Final and Irreversible Transactions Before submitting a payment order, you should carefully review all transaction details. By confirming a transaction, you acknowledge and agree that: * execution begins immediately; * completed transactions are final; * blockchain transactions are irreversible; * transactions cannot be cancelled after execution. *** ### 10A.4 Processing Delays Transactions may be delayed due to circumstances outside Holdstation Pay's control, including: * identity verification; * AML or compliance reviews; * blockchain congestion; * blockchain confirmation times; * network disruptions. Delivery of Digital Assets may require additional time depending on the blockchain network. *** ### 10A.5 Unauthorized Activity If you become aware of any unauthorized transaction or suspicious activity involving your account, you must immediately contact: **** Holdstation Pay may temporarily freeze related transactions while conducting an investigation. *** ### 10A.6 Transaction Recall Where permitted or required by: * applicable law; * payment network rules; or * financial institutions, Holdstation Pay may cancel or recall an executed transaction. *** ### 10A.7 Processing Errors If, due to a system error or processing issue, you receive more Digital Assets or fiat currency than intended, you agree to: * notify Holdstation Pay immediately; and * return the excess funds as instructed. Where necessary, Holdstation Pay may: * freeze your account; * recover excess funds; * take other reasonable measures permitted by law. You agree to cooperate in resolving any such discrepancies. *** ## 10B. Transaction Fees and Transmission Delay ### 10B.1 Transaction Fees Holdstation Pay determines applicable Transaction Fees at its discretion. All applicable fees will be disclosed before you confirm a transaction. *** ### 10B.2 Third-Party Fees Holdstation Pay is not responsible for: * exchange rates; * payment processing fees; * banking charges; * card issuer fees; * other charges imposed by third-party financial institutions. Such fees remain your responsibility. *** ### 10B.3 Fee Payment By completing a transaction, you agree to pay all applicable Transaction Fees disclosed before execution. *** ### 10B.4 Blockchain Transmission Delays Blockchain transactions may experience delays due to: * network congestion; * validator availability; * blockchain confirmation times; * protocol-level processing. Such delays may affect the timing of transaction execution and settlement. *** ### 10B.5 Price Changes and Re-Quotes Because blockchain fees and Digital Asset prices may change rapidly during processing, Holdstation Pay may provide an updated transaction quote ("**Pre-Completion Re-Quote**") before finalizing the transaction. The updated quote may reflect: * current market prices; * updated exchange rates; * revised blockchain network fees. *** ### 10B.6 Acceptance of Delays By proceeding with a transaction, you acknowledge and accept that: * transmission delays may occur; * blockchain congestion may affect settlement times; * pricing may change before execution. Holdstation Pay is not liable for losses arising from: * network congestion; * blockchain delays; * updated quotations; * transmission latency. *** ## 10C. Rounding Policy To ensure consistency across transactions, Holdstation Pay applies standardized rounding rules. #### Fiat Currency Fiat amounts are generally rounded to: > **Two (2) decimal places** *** #### Digital Assets Digital Asset amounts may be rounded differently depending on: * blockchain precision; * token divisibility; * supported decimal places for the relevant asset. *** ## 11. Risk Disclosure and Assumption of Liability > **Important:** Before using Holdstation Pay, you should carefully consider the risks associated with Digital Assets and blockchain technology. By accessing or using the Services, you acknowledge and accept the risks described below. *** ### 11.1 Digital Asset Risks You acknowledge and agree that: #### 11.1.1 Market Volatility Digital Assets are highly volatile and may lose part or all of their value over a short period of time. *** #### 11.1.2 No Legal Tender Status Most Digital Assets: * are not legal tender; * are not issued by any government; * are not backed by any central bank; * are not protected by deposit insurance schemes. *** #### 11.1.3 No Investment Advice Holdstation Pay does not guarantee: * market prices; * liquidity; * future value; * usability of any Digital Asset. Nothing provided through the Services constitutes: * investment advice; * financial advice; * performance guarantees. *** #### 11.1.4 Blockchain Finality Blockchain transactions are generally: * irreversible; * final; * subject to network delays; * subject to protocol-level technical issues. *** #### 11.1.5 Third-Party Networks Holdstation Pay is not responsible for losses resulting from: * blockchain congestion; * network fees; * wallet failures; * third-party wallet providers. *** #### 11.1.6 Regulatory Changes Government actions or regulatory changes may affect: * legality; * availability; * transferability; * taxation; * value of Digital Assets in your jurisdiction. *** #### 11.1.7 No Insurance Digital Assets are generally **not insured** by: * governments; * deposit insurance programs; * investor protection schemes. Holdstation Pay does not provide private insurance covering Digital Assets. You acknowledge that total loss of value is possible. *** #### 11.1.8 Limited Acceptance Digital Assets are not universally accepted as a means of payment and may not be recognized by merchants, financial institutions, or governments. *** #### 11.1.9 Irrecoverable Transactions Transactions involving Digital Assets are irreversible. If assets are sent to: * an incorrect address; * an unsupported wallet; * an incompatible blockchain, they may be permanently lost. *** #### 11.1.10 Blockchain Timing Transactions may appear on a public blockchain at a different time than when they were initiated. Confirmation times depend on: * blockchain congestion; * validator performance; * network protocols. *** #### 11.1.11 Technical Risks Digital Assets and blockchain networks may be affected by: * cyberattacks; * hacking; * fraud; * theft; * software bugs; * protocol upgrades; * blockchain forks; * chain reorganizations; * technical failures. These events may result in partial or total loss of your Digital Assets. *** #### 11.1.12 Market Collapse The value of Digital Assets depends on market demand. If market demand declines significantly, Digital Assets may lose all value. *** #### 11.1.13 Legislative Risk Future legislative or regulatory developments may adversely affect: * Digital Assets; * blockchain technology; * Holdstation Pay Services; * your ability to transact. *** #### 11.1.14 Independent Decision Making Holdstation Pay does not recommend buying or selling any Digital Asset. Any educational or informational content is provided solely for general information and should not be interpreted as: * investment advice; * legal advice; * tax advice. You are solely responsible for conducting your own due diligence and seeking professional advice where appropriate. *** #### 11.1.15 Technology Failure Hardware failures, software bugs, connectivity issues, or blockchain network disruptions may prevent access to your Digital Assets. Holdstation Pay is not liable for losses arising from such events. *** ### 11.2 Assumption of Risk You acknowledge that you use Holdstation Pay entirely at your own risk. You accept full responsibility for any losses arising from: * market conditions; * blockchain operations; * technical failures; * compliance actions; * regulatory developments. *** ### 11.3 No Professional Advice Holdstation Pay does not provide: * financial advice; * investment advice; * legal advice; * tax advice. All decisions made through the Services are your sole responsibility. *** #### 11.3.1 Tax Responsibilities You are solely responsible for: * determining applicable taxes; * reporting taxable transactions; * paying all taxes and governmental charges arising from your use of Holdstation Pay. Holdstation Pay does not calculate, report, or pay taxes on your behalf. *** ## 12. Disclaimer of Warranties > **Important:** Holdstation Pay provides the Services on an **"AS IS"** and **"AS AVAILABLE"** basis. By using the Services, you acknowledge and accept that Holdstation Pay makes no guarantees regarding the continuous availability, performance, or suitability of the Services. *** ### 12.1 No Warranties The Services are provided without warranties of any kind, whether: * express; * implied; * statutory; or * otherwise. *** ### 12.2 Disclaimer of Implied Warranties To the maximum extent permitted by applicable law, Holdstation Pay expressly disclaims all implied warranties, including but not limited to: * Merchantability; * Fitness for a particular purpose; * Title; * Non-infringement; * System integration; * Data accuracy; * Quiet enjoyment. *** ### 12.3 Service Availability Holdstation Pay does not guarantee that the Services will be: * uninterrupted; * continuously available; * secure; * error-free; * accurate; * reliable; * up to date. *** #### 12.3.1 No Guarantee of Specific Features Without limiting the foregoing, Holdstation Pay makes no warranty regarding: * Continuous availability of the Services; * Compatibility with your devices, wallets, or software; * Accuracy of exchange rates, pricing, or other market information; * Continued availability of any supported: * Digital Asset; * Fiat Currency; * Payment method. *** ### 12.4 Independent Verification You are solely responsible for independently verifying any information obtained through Holdstation Pay before relying upon it. This includes, but is not limited to: * exchange rates; * transaction information; * blockchain data; * Digital Asset information. *** ### 12.5 No Third-Party Beneficiaries Except where expressly stated otherwise, these Terms create rights and obligations solely between: * you; and * Holdstation Pay. No third party acquires any rights under these Terms. *** ### 12.6 Maintenance and Downtime Holdstation Pay may temporarily suspend access to the Services for: * scheduled maintenance; * software upgrades; * security improvements; * emergency situations. Where reasonably practicable, we will seek to minimize service interruptions. *** ## 13. No Custody Disclaimer ### 13.1 Non-Custodial Service Holdstation Pay operates as a **non-custodial** service provider. At no time does Holdstation Pay: * store User funds; * safeguard User funds; * custody Digital Assets; * operate as a bank or deposit-taking institution. *** ### 13.2 On-Ramp Transactions For On-Ramp transactions: Fiat funds are held only for the limited period necessary to complete transaction processing. Digital Assets are delivered only after: * payment has been received; * compliance checks have been completed; * operational controls have been satisfied. Fiat funds are **not treated as customer deposits**. *** ### 13.2A Off-Ramp Transactions For Off-Ramp transactions: Holdstation Pay receives Digital Assets solely for the purpose of purchasing them from the User. Upon successful completion of: * compliance reviews; * transaction verification; and * operational processing, Holdstation Pay pays fiat currency (or another agreed Digital Asset) directly to the User using Holdstation Pay's own inventory. Holdstation Pay does **not** custody the User's Digital Assets during this process. *** ### 13.3 User Wallet Control All purchased Digital Assets are delivered directly to a blockchain wallet designated and controlled by the User. Holdstation Pay does not maintain hosted wallet accounts. *** ### 13.4 Wallet Responsibility You are solely responsible for ensuring that your wallet address is: * correct; * accessible; * compatible with the Digital Asset being transferred. *** ### 13.5 Limitation of Responsibility Holdstation Pay is not responsible for losses arising from: #### 13.5.1 Incorrect Wallet Addresses Sending Digital Assets to an incorrect wallet. *** #### 13.5.2 Lost Wallet Access Loss of access to: * wallets; * seed phrases; * private keys. *** #### 13.5.3 Unsupported Wallets Using wallet software or blockchain networks that are incompatible with the selected Digital Asset. *** ## 13A. User Security Obligations ### 13A.1 Account Security You are solely responsible for protecting the security of your: * Holdstation Pay account; * devices; * blockchain wallets; * email account; * login credentials. *** ### 13A.2 Reporting Security Incidents You must immediately notify Holdstation Pay by contacting: **** if you suspect: * unauthorized account access; * credential compromise; * unauthorized transactions; * any security breach affecting your account. *** ### 13A.3 Sensitive Information Holdstation Pay will **never** ask you to provide: * your password; * your private keys; * your recovery phrase (seed phrase); * your full payment card details via email, SMS, or other unsolicited communications. If you receive such a request, you should treat it as a phishing attempt. *** ### 13A.4 Delay in Reporting Failure to promptly report a suspected security incident may result in increased losses for which you may be responsible. *** ## 13B. Electronic Communications and Consent ### 13B.1 Electronic Communications By using Holdstation Pay, you consent to receive all legally required communications electronically. These communications may include: * Terms of Use; * Privacy Policy updates; * transaction confirmations; * receipts; * compliance notices; * security notifications; * fee updates; * legal disclosures; * other account-related communications. Communications may be delivered through: * email; * the Holdstation Pay platform; * the Holdstation Pay website. Electronic communications are considered equivalent to written communications. You are encouraged to save or print copies for your records. *** ### 13B.2 Maintaining Contact Information To receive electronic communications, you must: * maintain a valid email address; * maintain internet access; * promptly update your contact information whenever it changes. You may withdraw your consent to receive electronic communications by contacting: **** Please note that withdrawing consent may result in termination of your access to the Services, except for marketing communications where withdrawal will not affect your ability to use Holdstation Pay. *** ### 13B.3 Electronic Signatures Your consent to electronic communications and electronic signatures is governed by applicable laws, including: * the EU eIDAS Regulation (as implemented in Poland); and * other applicable electronic communications laws. Holdstation Pay reserves the right to modify or discontinue electronic communication methods where permitted by law. ## 14. Prohibited Use Obligations You agree not to use your Holdstation Pay Account or the Services for any unlawful, abusive, or prohibited activities. Violation of this section may result in: * Suspension of your account; * Rejection of transactions; * Termination of access to the Services; * Reporting to competent authorities where required by law. *** ### 14.1 Prohibited Activities The following activities are strictly prohibited. #### (a) Unlawful Activities You may not use the Services to: * violate applicable laws or regulations; * circumvent sanctions or trade restrictions; * facilitate financial crime; * process proceeds of unlawful activities; * support illegal businesses or organizations. This includes laws and sanctions administered by: * Poland; * the European Union; * the United Nations; * the United States; * or any other competent authority. *** #### (b) Abusive Activities You may not: * interfere with the operation of the Services; * overload Holdstation Pay's infrastructure; * gain unauthorized access to systems; * transmit malicious software; * scrape, mine, or extract platform data without authorization. Examples include: * malware; * viruses; * ransomware; * bots; * automated attacks. *** #### (c) Abuse of Others You may not use Holdstation Pay to: * harass or threaten others; * stalk individuals; * commit extortion; * defame others; * violate privacy rights; * infringe intellectual property rights; * collect personal information without authorization. *** #### (d) Fraud You may not: * provide false information; * submit misleading documents; * impersonate another person; * deceive Holdstation Pay; * deceive merchants or other users; * participate in fraudulent schemes. *** #### (e) Illegal Gambling The Services may not be used in connection with: * illegal lotteries; * unlicensed gambling; * betting; * fantasy sports; * games of chance prohibited by applicable law. *** #### (f) Intellectual Property Infringement You may not: * sell counterfeit goods; * infringe copyrights; * infringe trademarks; * misuse Holdstation Pay branding; * violate proprietary rights of third parties. *** #### (g) Prohibited Goods and Services You may not use Holdstation Pay in connection with transactions involving: * narcotics or controlled substances; * drug paraphernalia; * stolen property; * illegal weapons; * obscene materials; * hate-related content; * pornography or adult content services; * AI-generated explicit sexual content; * prostitution or sexual services; * any products or services promoting illegal activity. *** #### (h) Unacceptable Activities You may not use Holdstation Pay to support or participate in: * pyramid schemes; * Ponzi schemes; * unlicensed financial services; * bribery; * corruption; * any activity prohibited under applicable law. *** ### 14.2 Enforcement Holdstation Pay reserves the right to investigate any suspected prohibited activity. Where we determine, at our sole discretion, that you have violated these Terms or applicable law, we may: * suspend your account; * terminate your account; * refuse or reverse transactions; * freeze related funds where legally permitted; * report the activity to competent authorities. *** ## 14A. Termination of Terms of Use and Account Closure ### 14A.1 Account Closure by User You may close your Holdstation Pay account at any time, provided that: * all pending transactions have been completed; and * all outstanding obligations have been satisfied. *** ### 14A.2 Account Suspension or Termination Holdstation Pay may suspend or terminate your account where: * you violate these Terms; * illegal activity is suspected; * fraud is detected; * required by applicable law; * instructed by a competent authority. *** ### 14A.3 Inactive Accounts Holdstation Pay may close accounts that remain inactive for **six (6) consecutive months**, where permitted by applicable law. *** ### 14A.4 Outstanding Obligations Termination of your account does not affect: * fees already owed; * completed transactions; * legal obligations arising before termination. *** ### 14A.5 Refund Processing Where applicable, refunds relating to fiat payments are processed through Holdstation Pay's authorized payment processors. Refund timelines remain subject to the applicable payment processor's procedures and requirements. *** ## 15. Intellectual Property Rights ### 15.1 Ownership Unless otherwise stated, all intellectual property relating to Holdstation Pay is owned by Holdstation Pay or its licensors. This includes, but is not limited to: * software; * source code; * website content; * graphics; * logos; * icons; * trademarks; * service marks; * trade names; * images; * videos; * audio; * documentation; * databases; * designs. These materials are protected under: * Polish law; * European Union intellectual property laws; * applicable international intellectual property laws. *** ### 15.2 Restrictions on Use Except as expressly permitted by these Terms or applicable law, you may not: * copy; * reproduce; * distribute; * publish; * modify; * create derivative works; * publicly display; * publicly perform; * download; * store; * transmit any Holdstation Pay intellectual property without prior written consent. *** ### 15.3 Trademarks The following are proprietary assets of Holdstation Pay and its affiliates: * trademarks; * service marks; * logos; * brand names; * trade names; * visual branding. You may not: * copy; * imitate; * register; * reproduce; * use any Holdstation Pay trademark without prior written permission. Unauthorized use may constitute trademark infringement. *** ### 15.4 User Content You retain ownership of any content you submit to Holdstation Pay ("**User Content**"). By submitting User Content, you grant Holdstation Pay a: * worldwide; * royalty-free; * transferable; * sublicensable; * irrevocable; * perpetual license to: * use; * reproduce; * modify; * distribute; * publish; * display; * create derivative works; for purposes related to operating, improving, and promoting Holdstation Pay. *** ### 15.5 Feedback If you provide Holdstation Pay with: * suggestions; * comments; * feature requests; * ideas; * feedback, you grant Holdstation Pay a perpetual, worldwide, royalty-free license to use and commercialize such feedback without any obligation to compensate you. *** ### 15.6 Third-Party Intellectual Property The Services may contain content, software, or services owned by third parties. Such third-party intellectual property remains the property of its respective owners and is governed by their own terms and licenses. Holdstation Pay does not claim ownership of third-party intellectual property. *** ### 15.7 Reporting Intellectual Property Infringement If you believe your intellectual property rights have been infringed through Holdstation Pay, please contact: **Email:** Your report should include sufficient information to allow Holdstation Pay to investigate the matter. *** ### 15.8 Enforcement Holdstation Pay reserves the right to investigate alleged intellectual property violations and may take appropriate action, including: * removing infringing content; * suspending accounts; * terminating accounts; * pursuing legal remedies where appropriate. *** ### 15.9 Reservation of Rights All rights not expressly granted under these Terms remain reserved by Holdstation Pay and its licensors. ## 16. Data Protection and Privacy Holdstation Pay is committed to protecting your privacy and processing personal data in accordance with applicable data protection laws. As a data controller established in Poland, Holdstation Pay processes personal data in compliance with applicable privacy regulations, including the General Data Protection Regulation (GDPR) and relevant Polish data protection laws. > **Note:** This section provides a summary of our data protection practices. For detailed information, please refer to our **Privacy Policy**. *** ### 16.1 Our Commitment Holdstation Pay is committed to: * protecting your personal information; * processing data lawfully and fairly; * maintaining appropriate technical and organizational safeguards; * complying with applicable data protection regulations. *** ### 16.2 Legal Basis for Processing Holdstation Pay processes personal data based on one or more of the following legal grounds: * Performance of our contractual obligations; * Compliance with legal and regulatory requirements; * Legitimate business interests; * Your consent, where required by applicable law. Examples of legal obligations include: * AML/KYC verification; * fraud prevention; * sanctions screening; * regulatory reporting. *** ### 16.3 Your Privacy Rights Subject to applicable laws, you may have the right to: * Access your personal data; * Correct inaccurate or incomplete information; * Request deletion of your personal data; * Restrict certain processing activities; * Object to processing in specific circumstances; * Request portability of your personal data; * Withdraw consent where consent is the legal basis for processing. You may also lodge a complaint with the competent data protection authority where permitted by law. *** ### 16.4 Data Retention Holdstation Pay retains personal information only for as long as necessary to: * provide the Services; * comply with legal obligations; * satisfy AML/KYC recordkeeping requirements; * resolve disputes; * enforce these Terms. Unless a longer retention period is required by law, personal data is generally retained for up to **five (5) years** following the end of your relationship with Holdstation Pay. *** ### 16.5 Data Protection Impact Assessments Where required by applicable law, Holdstation Pay conducts **Data Protection Impact Assessments (DPIAs)** to identify, assess, and mitigate risks associated with personal data processing. *** ### 16.6 International Data Transfers Your personal information may be transferred to and processed in jurisdictions outside your country of residence. Where such transfers occur, Holdstation Pay implements appropriate safeguards to protect your personal data, including contractual and organizational measures required under applicable law. *** ### 16.7 Privacy Policy For comprehensive information regarding how Holdstation Pay collects, uses, stores, shares, and protects personal information, please refer to our **Privacy Policy**. *** ### 16.8 Contact If you have any questions regarding data protection or wish to exercise your privacy rights, please contact: **Email:** *** ## 17. Complaints and Dispute Resolution ### 17.1 Filing a Complaint If you are dissatisfied with the Services provided by Holdstation Pay, you may submit a complaint by contacting: **Email:** Please provide sufficient information to allow us to investigate your concern. *** ### 17.2 Complaint Handling Holdstation Pay aims to acknowledge and respond to complaints within **30 Business Days**. We will make reasonable efforts to investigate and resolve complaints fairly and in good faith. *** ### 17.3 Escalation If your complaint cannot be resolved through our internal complaint process, you may, where applicable: * refer the matter to the competent supervisory authority in Poland; * contact an appropriate consumer protection authority; * use an available alternative dispute resolution mechanism in your jurisdiction. Using an alternative dispute resolution process does not affect your right to seek judicial remedies where permitted by law. *** ## 18. Limitation of Liability > **Important:** To the maximum extent permitted by applicable law, Holdstation Pay's liability is limited as described below. *** ### 18.1 Excluded Damages Holdstation Pay, including its affiliates, directors, officers, employees, partners, agents, and service providers, will not be liable for: #### 18.1.1 Indirect Losses Any indirect, incidental, special, exemplary, punitive, or consequential damages, including: * lost profits; * loss of revenue; * business interruption; * loss of business opportunities; * loss of goodwill; * reputational damage. *** #### 18.1.2 Commercial Losses Losses relating to: * business; * revenue; * profits; * commercial opportunities. *** #### 18.1.3 Data Loss Loss, corruption, or destruction of: * personal data; * account information; * user-generated content. *** #### 18.1.4 Third-Party Claims Claims arising from: * actions by regulators; * enforcement proceedings; * claims brought by third parties; * consequences of your use of the Services. *** #### 18.1.5 Blockchain and User Errors Losses arising from: * incorrect wallet addresses; * incorrect transaction details; * blockchain congestion; * network failures; * loss of wallet access; * loss of private keys; * sanctions-related restrictions; * frozen funds. *** ### 18.2 Maximum Liability Per Claim To the extent permitted by law, Holdstation Pay's liability for any individual claim shall not exceed the total fees paid by you to Holdstation Pay in connection with the transaction giving rise to that claim. *** ### 18.3 Aggregate Liability In all circumstances, Holdstation Pay's total cumulative liability arising from the Services shall not exceed the total fees paid by you during the **three (3) months** immediately preceding the event giving rise to the claim. *** ### 18.4 Scope of Limitation These limitations apply regardless of the legal theory on which the claim is based, including: * contract; * negligence; * tort; * strict liability; * warranty; * any other legal theory. This limitation applies even if Holdstation Pay has been advised of the possibility of such damages. *** ### 18.5 Exceptions Some jurisdictions do not permit the exclusion or limitation of certain liabilities. Where applicable law prohibits these limitations, they shall apply only to the maximum extent permitted by law. *** ## 18A. User Indemnification You agree to indemnify, defend, and hold harmless Holdstation Pay and its: * affiliates; * subsidiaries; * directors; * officers; * employees; * agents; * service providers, from and against any claims, damages, liabilities, losses, costs, and expenses (including reasonable legal fees) arising out of or relating to: * your use or misuse of the Services; * your breach of these Terms; * your violation of applicable laws or regulations; * any false, inaccurate, or misleading information you provide; * infringement of any third-party rights, including privacy and intellectual property rights; * use of your account by another person, whether authorized or unauthorized. This indemnification obligation survives the termination of your account and these Terms where permitted by applicable law. *** ## 19. Dispute Resolution Holdstation Pay encourages the resolution of disputes through open communication whenever possible. *** ### 19.1 Informal Resolution If you have any concern, complaint, or dispute relating to the Services, we encourage you to contact Holdstation Pay first. We will make reasonable efforts to resolve disputes: * promptly; * fairly; * amicably. *** ### 19.2 Court Resolution If a dispute cannot be resolved through informal discussions, then, subject to any mandatory consumer protection laws applicable in your jurisdiction, the dispute shall be submitted to the competent courts specified in **Section 20 (Governing Law and Jurisdiction)**. *** ### 19.3 Consumer Rights If mandatory consumer protection laws in your jurisdiction apply, you may have the right to bring legal proceedings before the competent courts of your own jurisdiction. Nothing in these Terms limits or excludes any mandatory rights available to you under applicable law. *** ### 19.4 Collective Proceedings Nothing in these Terms prevents Users from participating in collective or representative proceedings where such rights are granted by applicable law. *** ### 19.5 Injunctive Relief Nothing in this section prevents either party from seeking urgent injunctive or equitable relief from a court of competent jurisdiction where necessary to protect: * intellectual property; * confidential information; * proprietary rights; * other rights requiring immediate legal protection. *** ### 19.6 Severability If any provision of this dispute resolution section is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect to the maximum extent permitted by law. *** ## 20. Governing Law and Jurisdiction ### 20.1 Governing Law These Terms are governed by and construed in accordance with the laws of the **Republic of Poland**, without regard to conflict of law principles, except where mandatory laws of your jurisdiction provide otherwise. *** ### 20.2 Consumer Protection Nothing in these Terms affects any mandatory consumer rights available to you under applicable local law. *** ### 20.3 Jurisdiction Unless otherwise required by mandatory consumer protection laws, any dispute arising out of or relating to these Terms shall be subject to the **exclusive jurisdiction of the competent courts in Warsaw, Poland**, where Fundara has its registered seat. *** ## 21. General Provisions ### 21.1 Entire Agreement These Terms, together with the: * Privacy Policy; and * any other policies referenced within these Terms, constitute the entire agreement between you and Holdstation Pay regarding the Services. *** ### 21.2 Third-Party Content While using the Services, you may encounter content or services provided by third parties ("**Third-Party Content**"), including external websites or linked services. Holdstation Pay: * does not control Third-Party Content; * does not endorse Third-Party Content; * is not responsible for Third-Party Content. Any interaction between you and a third party is solely between you and that third party. You access Third-Party Content entirely at your own risk. *** ### 21.3 Assignment You may not assign or transfer these Terms without Holdstation Pay's prior written consent. Holdstation Pay may assign or transfer these Terms without restriction. *** ### 21.4 No Waiver Failure by Holdstation Pay to enforce any right or provision under these Terms shall not constitute a waiver of that right or provision. *** ### 21.5 Severability If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect. *** ### 21.6 Force Majeure Holdstation Pay shall not be liable for delays or failures in performance resulting from events beyond our reasonable control, including: * natural disasters; * internet outages; * regulatory actions; * cyberattacks; * other force majeure events. *** ### 21.7 Notices You agree that Holdstation Pay may deliver all notices and communications electronically through: * your registered email address; or * the Holdstation Pay platform. *** ### 21.8 Confidentiality During your use of the Services, you may gain access to confidential or proprietary information relating to Holdstation Pay ("**Confidential Information**"). Unless required by law or expressly authorized in writing by Holdstation Pay, you agree not to: * disclose; * copy; * distribute; * use any Confidential Information for purposes unrelated to your use of the Services. *** ## 22. Amendments to the Terms Holdstation Pay may update or modify these Terms from time to time to reflect: * changes in applicable laws or regulations; * operational or technical improvements; * security enhancements; * new products or services. Where required by applicable law, Holdstation Pay will provide notice of material changes through the website, platform, or other electronic communication channels. Your continued use of the Services after updated Terms become effective constitutes your acceptance of the revised Terms. *** ## 23. Applicable Laws and Regulatory Authorities Holdstation Pay operates in accordance with applicable laws and regulatory requirements governing virtual asset services, including laws relating to: * Anti-Money Laundering (AML); * Counter-Terrorist Financing (CTF); * financial crime prevention; * sanctions compliance; * data protection; * consumer protection. Depending on the circumstances, Holdstation Pay may cooperate with competent authorities responsible for supervising or enforcing applicable laws, including but not limited to: * General Inspector of Financial Information (GIIF) – Poland; * Director of the Tax Administration Chamber in Katowice; * European Union competent authorities; * United Nations sanctions authorities; * Office of Foreign Assets Control (OFAC); * Office of Financial Sanctions Implementation (OFSI); * other competent regulatory or law enforcement authorities where required by applicable law. *** ## Contact Information If you have any questions regarding these Terms of Use, please contact: **Holdstation Pay** **Email:** **Effective Date:** January 1, 2026\ **Last Updated:** June 29, 2026