Terms of Service

1. Acceptance of Terms

These Terms of Service (the "Terms", "Agreement") are a binding agreement between you (the "User", "you") and Crypocto (the website available at https://crypocto.com, together with all related subdomains, pages and services offered through it, the "Service"). References to "we", "our" or "us" mean the legal entity responsible for the Crypocto brand (the "Company"). The Company's full legal name, registration details and registered office are set out in the Contact section or available on written request.

This Agreement is a public offer addressed to individuals and legal entities who wish to use the Service. By visiting the website, submitting an enquiry, creating an Order or otherwise using any part of the Service, you confirm that you have read, understood and accepted these Terms and our Privacy Policy in full. If you do not agree with any part of these Terms, you must not use the Service.

The current version of the Terms is published at crypocto.com/terms and may be updated from time to time as described in the "Changes to these Terms" section.

2. Definitions

In these Terms, capitalised words have the following meaning:

• User — any individual or legal entity that uses, or intends to use, any part of the Service and accepts these Terms.
• Service — the Crypocto online platform that supports (i) crypto-to-fiat and fiat-to-crypto exchange (crypto on-ramp and off-ramp), (ii) crypto-to-crypto exchange, and (iii) crypto-settled escrow for real-asset deals (real estate, cars, yachts, watches, jewelry, art and similar high-value assets).
• Virtual asset — a digital representation of value that can be traded or transferred digitally and used for payment or investment purposes, including but not limited to cryptocurrencies and stablecoins.
• Cryptocurrency — a virtual asset built on distributed-ledger technology (for example BTC, ETH, USDT/USDC, LTC, TRX).
• Fiat money — a state-regulated means of payment (for example EUR, USD, UAH, PLN, CHF).
• Payment system — any third-party infrastructure used to transfer fiat or virtual assets (for example SEPA, SWIFT, card networks, stablecoin networks, major blockchains).
• Source currency — the virtual asset or fiat money that the User wishes to send to the Service in a given Order.
• Resulting currency — the virtual asset or fiat money that the User receives as a result of the exchange.
• Source account — the wallet or payment-system account from which the Source currency is sent.
• Resulting account — the wallet or payment-system account to which the Resulting currency will be sent.
• Order — the exchange or escrow request created by the User through the Service (on the website or with the assistance of a Crypocto manager), which constitutes acceptance of these Terms.
• Rate — the exchange ratio between two assets applied to an Order.
• Escrow deal — a real-asset purchase in which funds and/or crypto are held by the Service as an independent escrow agent and released only on satisfaction of pre-agreed conditions.
• KYC (Know Your Customer) — procedures used to verify the identity of the User and, where applicable, their ultimate beneficial owner.
• AML (Anti-Money Laundering), CTF (Counter-Terrorist Financing), Sanctions — policies and procedures used to prevent money laundering, terrorist financing and breaches of applicable sanctions programmes.
• Fraud — any deception carried out for the purpose of obtaining personal benefit and harming the interests of the Service, its partners or other Users.

3. Description of the Service

The Service provides virtual-asset and fiat exchange operations and crypto-settled escrow for real-asset transactions. In particular, the Service offers:

• Crypto on-ramp: the conversion of fiat money (via SEPA, SWIFT or card) into a virtual asset chosen by the User;
• Crypto off-ramp: the conversion of a virtual asset into fiat money settled on the User's bank account;
• Crypto-to-crypto exchange between supported tokens and networks;
• Escrow for real assets (real estate, cars, yachts, watches, jewelry, art), where the Service acts as an independent escrow agent responsible for holding, converting and releasing funds in line with the deal's pre-agreed conditions;
• Transaction coordination and documentation, including invoicing, proof-of-funds letters and liaison with notaries, banks, dealers or legal counsel when required for the underlying deal.

The Service is offered on a settlement-only basis. The Company does not act as a broker, advisor or dealer for any real asset and does not accept custody of physical goods, title documents or vehicles, unless a separate agreement is signed with a specific User and counterparty.

The Service is provided via the website and with the assistance of a dedicated personal manager. Users accept that some Orders may require off-platform communication (for example email, Telegram or signed paper documents) to complete KYC, contract and settlement steps.

4. Eligibility

To use the Service you must:

• Be at least eighteen (18) years of age;
• Have full legal capacity to enter into binding agreements in your jurisdiction;
• Not be a resident or citizen of a country or territory subject to comprehensive sanctions programmes (see Restricted jurisdictions);
• Successfully complete the KYC and AML procedures requested by the Service;
• Provide accurate, complete and truthful information in every communication with the Service;
• Use only your own wallets, bank accounts and payment instruments — transactions involving third-party accounts are prohibited.

The Service may refuse to open a deal, or terminate an existing relationship, if any of the above conditions is not met.

5. Restricted jurisdictions

The Service is primarily offered across the twenty-seven (27) Member States of the European Union and in Ukraine. The Service is not available to, and may not be used by:

• Persons residing in, or operating from, jurisdictions or territories subject to comprehensive EU, UN or U.S. (OFAC) sanctions programmes;
• Persons, entities or vessels listed on applicable international or national sanctions lists;
• Persons whose residence or citizenship, or whose source of funds, is linked to disputed, annexed or non-recognised territories;
• Persons located in jurisdictions where the Service, or specific cryptocurrency or escrow activities, are prohibited or restricted by local law.

The Service reserves the right to refuse fiat-settled services to Users whose citizenship or residency triggers additional regulatory, banking or payment-partner requirements, including where the Company's own correspondent banks or EU-licensed counterparties restrict a given nationality. The list of permitted jurisdictions may change; the Service will make its best effort to inform affected Users before an existing Order is closed.

6. KYC, AML, CTF & sanctions compliance

The Service operates a risk-based KYC/AML/CTF and sanctions framework, described in full in the AML Policy, that is designed to prevent its infrastructure from being used for money laundering, terrorist financing, fraud, trafficking, proliferation financing, corruption, bribery or evasion of sanctions. By using the Service, the User agrees to cooperate with these procedures.

As part of the compliance process, the Service may:

• Request a valid government-issued identity document (passport, national ID, residence permit) and clear proof of address;
• Verify cards, bank accounts or wallets used by the User (for example through a photo or video confirmation that the card or account belongs to them);
• Request information and documents evidencing the User's source of funds and, for larger deals, source of wealth;
• Screen the User, counterparties and wallet addresses against sanctions, politically-exposed-persons (PEP) and adverse-media lists;
• Apply on-chain analytics tools to the wallets involved in an Order and to the transaction history linked to them;
• Request additional documents or clarifications at any stage of a deal, and place an Order on hold until they are provided.

The Service operates an internal risk-scoring system that may flag specific Orders, wallet addresses or Users as high-risk. Where this happens, the Service may require enhanced due diligence or reject the Order. For security reasons, the detailed scoring criteria are confidential and will not be disclosed.

The Service may engage third-party compliance, KYC or analytics providers to perform parts of these procedures on its behalf. Any such provider is bound by written confidentiality and data-processing obligations. The Service may disclose the information collected through KYC/AML/CTF procedures to competent authorities when required by law, court order or a legitimate regulatory request.

Where a deposit is identified as high-risk (for example linked to mixing services, darknet markets, hacks, sanctioned addresses or other illicit activity), the Service may refuse to complete the exchange. In such case the relevant assets may be frozen, reported to the competent authority or returned minus the refund commission specified in clause 10, and the related wallet address may be added to the Service's internal block-list.

7. Orders & exchange lifecycle

7.1 Creating an Order

An Order is created when the User submits the relevant exchange or escrow request through the Service, including through a Crypocto manager, and confirms the amount, the Source currency, the Resulting currency, the Resulting account and the disclosed fee. By confirming an Order, the User accepts these Terms and authorises the Service to execute the exchange or escrow on the User's behalf and at the User's expense.

7.2 Rate lock (30 minutes)

Unless expressly stated otherwise in the Order, the Rate is fixed for a period of thirty (30) minutes from the time the Order is created. If the User's deposit is not received within this period, the Service may recalculate the Rate based on market conditions at the time the deposit actually arrives.

7.3 Fulfilment (24 hours)

After the User's deposit is received and confirmed, the Service will use reasonable efforts to dispatch the Resulting currency to the Resulting account within twenty-four (24) hours. The obligation of the Service is considered fulfilled at the moment the Resulting currency is debited from the relevant account of the Service and sent to the network or payment system, as recorded in the transaction history of the relevant Payment system.

7.4 Minimum amounts & limits

The Service may set minimum and maximum amounts per Order and daily, monthly or cumulative volume limits for individual Users. Deposits received below the minimum amount may not be credited and, given the disproportionate cost of processing micro-refunds, are not refundable. Current limits are published on the website or communicated by the User's personal manager.

7.5 Incorrect or delayed deposits

If the User sends an amount different from the amount specified in the Order, the Order is recalculated at the Rate valid at the moment the deposit is received, following a written request from the User. If a deposit arrives after the expiry of the Order or after cancellation, it will be treated as a deposit for a new Order at the then-current Rate, subject to any additional KYC/AML steps.

7.6 Irrevocability

Once the Resulting currency has been dispatched by the Service in accordance with the Order, the exchange is considered final and cannot be cancelled by the User. Blockchain transactions are by their nature irreversible; the User is responsible for the accuracy of wallet addresses, networks (chain), memo/tag fields and any other payment-system details provided.

7.7 Network and payment-system delays

The Service is not responsible for delays, errors or failures of third-party Payment systems, blockchain congestion, insufficient gas/network fees set by the User, missing or wrong memo/tag fields, bank compliance reviews or similar events. Where possible, the Service will assist the User in liaising with the relevant provider, to the best extent permitted by law.

8. Escrow service for real assets

In addition to exchange, the Service offers crypto-settled escrow for high-value real-asset transactions. In an Escrow deal:

• The buyer deposits crypto (or fiat) with the Service on the basis of a pre-signed escrow instruction that defines the asset, price, parties, release conditions and, where applicable, the conversion into fiat;
• The Service holds the funds until the agreed release conditions are met (for example notarial signing of a real-estate deed, vehicle title transfer, authentication of a watch, jewelry or art piece, or handover at a trusted hub);
• Upon satisfaction of the release conditions, the Service converts and transfers the fiat amount to the seller's bank account — or the crypto amount to the seller's wallet — in accordance with the escrow instruction;
• If the deal collapses through no fault of the Service, the funds are returned to the buyer subject to the refund rules in clause 10.

The Service acts strictly as a neutral settlement and escrow agent. It does not warrant the quality, condition, authenticity, legal title or fitness for purpose of any real asset, and it is not a real-estate agency, dealer, broker or advisor. Users are responsible for carrying out independent due diligence on the asset, on the counterparty and on the local legal framework (including taxes, registrations, notarial steps and import duties). The Service strongly recommends engaging independent legal and tax counsel before signing an Escrow deal.

Any specific Escrow deal may be subject to a separate written escrow addendum between the User, the counterparty and the Company; in case of conflict, the addendum prevails over these Terms for matters covered by it.

9. Fees & cost of services

The Service's fees and commissions are set by the Company and disclosed to the User prior to Order confirmation. The User's confirmation of the Order constitutes acceptance of the applicable fees. Unless expressly stated otherwise, fees are deducted from the Resulting currency.

In addition to the Service's fee, third-party costs may apply, including but not limited to: blockchain network fees, bank/SWIFT/SEPA fees, card-processing fees, notary and registration costs, escrow-related legal fees and courier or logistics charges. These are borne by the User and are communicated as accurately as possible before the Order is confirmed.

The Service reserves the right to change its fee schedule and Rates at any time by updating the information published on the website. Changes do not apply retroactively to Orders that have already been confirmed and are in the rate-lock window.

The Service is not a tax agent for the User. The User is solely responsible for declaring and paying any tax due on exchange or escrow operations under the laws of their tax residency.

10. Refunds

A refund is only available while the exchange has not been fully executed — that is, while the Resulting currency has not yet been dispatched by the Service to the Resulting account.

Refunds are processed to the same account from which the deposit was received. If technically or legally impossible, the refund can be processed to an alternative account indicated by the User through an official request sent from the email associated with the Order.

Unless otherwise stated, the Service applies a refund commission of 5% of the refunded amount, in addition to any Payment-system fees incurred to send the funds back. Refunds of amounts below 20 USD equivalent are not made, as the processing cost exceeds the refund itself. The refund commission does not apply where the inability to complete the exchange is due to the fault of the Service (for example, documented technical failure on our side).

The Service may apply the refund commission in situations including, but not limited to:

• The User's account or card is limited or blocked by the Payment system or partner bank;
• The Order cannot be completed due to a violation of these Terms;
• The User paid the Order with incorrect payment details;
• The User overpaid the Order and requested a refund of the overpaid portion;
• The wallet from which the User paid, or which the User indicated for receipt, is blacklisted by the Service or its partners;
• The User paid less than the minimum Order amount (where a refund is technically possible);
• The User created two or more Orders and paid twice to the details of a single Order (the second payment is treated as an overpayment);
• The User's deposit has been identified as high-risk and does not comply with the Service's AML policies;
• The refund is triggered by the User cancelling the Order after payment.

Deposits received after the Order expiry or after cancellation are treated as deposits for a new Order at the then-current Rate; they are not automatically refunded. Blockchain transfers sent in error to wallets of the Service that do not correspond to any active Order are generally non-refundable; the Service will however consider such cases on a case-by-case basis after a written request sent to support@crypocto.com.

11. Cryptocurrency & blockchain risks

Cryptocurrency is a volatile asset. Its value can fluctuate significantly in short periods of time, and the Rate applied to an Order reflects market conditions at the time of conversion. By using the Service, the User confirms that they understand and accept the following risks:

• Market volatility and sudden changes in exchange rates;
• Irreversibility of blockchain transactions — a transfer sent to an incorrect address, network or chain may be lost permanently;
• Network congestion, hard forks, replay attacks and similar events affecting blockchain networks;
• Risks inherent to third-party payment systems, banks, stablecoin issuers or custodians used during the Order;
• Evolving regulatory treatment of crypto assets and real-asset deals, which may lead to changes in fees, limits or available corridors;
• Cybersecurity risks, including phishing, SIM-swap and social-engineering attacks targeting the User directly — the Service will never ask for private keys, seed phrases or two-factor codes.

The Service does not offer, and must not be construed as offering, investment, tax or legal advice.

12. User obligations & prohibited activities

By using the Service, the User undertakes to:

• Use the Service only for lawful purposes and in line with applicable law in their country of residence and in any country involved in a deal;
• Exclude any actions that could directly or indirectly contribute to money laundering, terrorist financing, trafficking, fraud, bribery, corruption or sanctions evasion;
• Not use the Service, nor any bonus, referral or affiliate programme, in a fraudulent or abusive way, including creating multiple accounts, manipulating Rates, or exploiting bugs;
• Not create or distribute pyramid, Ponzi or similar schemes through the Service;
• Not use wallets, bank accounts or cards belonging to third parties, and not provide access to the Service to third parties on their behalf;
• Calculate and pay all taxes due under the law of their tax residency on exchange and escrow operations;
• Communicate truthful and up-to-date information in every step of KYC, Order creation and escrow execution.

Any breach of this clause may result in the immediate suspension of the User's access to the Service, freezing of the relevant Order, disclosure to competent authorities and civil or criminal liability where applicable.

13. Suspension, blocking & termination

The Service may, at its sole discretion and where permitted by law, refuse to open an Order, suspend an Order already in progress, freeze assets or terminate its relationship with the User if:

• The User breaches these Terms or the Privacy Policy;
• A KYC/AML/CTF or sanctions concern arises in connection with the User, a counterparty or a specific address;
• The Order is subject to a legal, regulatory or law-enforcement request (including freeze or seizure orders);
• The Service has reasonable grounds to suspect fraud, phishing or a compromised account;
• Technical or security incidents make the safe execution of the Order impossible.

The Service may also block funds where previous transactions of the same User or of the counterparty were challenged by a Payment system, law-enforcement body or court. Where such a measure is taken, the Service will communicate the grounds to the User to the extent permitted by applicable law and regulatory confidentiality requirements.

14. Limitation of liability & disclaimers

To the maximum extent permitted by applicable law:

• The Service is provided on an "as is" and "as available" basis, without warranties of any kind — express or implied — regarding uninterrupted availability, error-free operation or absolute security;
• The Company will not be liable for indirect, incidental, consequential, punitive or special damages, including loss of profit, loss of data or loss of business opportunity;
• The Company's aggregate liability to a given User for any claim arising out of, or in connection with, these Terms or a given Order shall not exceed the Service's fee charged for the Order giving rise to the claim, or the equivalent of one hundred (100) EUR — whichever is higher;
• The Company is not liable for losses arising from the illegal actions of third parties, the User's own errors (for example, wrong wallet addresses, wrong networks, wrong memo/tag), blockchain network events, malfunctions of Payment systems, banks, dealers or notaries;
• The Company is not liable for delays or failures caused by Users not completing KYC/AML procedures on time.

Information stored in the Service's databases (including Order logs, KYC files and communication records) is considered the primary source of truth in the event of a dispute.

15. Intellectual property & indemnification

All content published on the Crypocto website — including texts, graphics, logos, icons, designs, software and page layouts — is owned by the Company or its licensors and is protected by intellectual-property laws. The User is granted a limited, non-exclusive, non-transferable right to access and use the Service for their own personal or internal business use. Copying, scraping, redistribution, creation of derivative works or commercial use without the Company's prior written consent is prohibited.

The User agrees to indemnify and hold harmless the Company, its affiliates, employees, contractors and partners from any claim, damage, loss, cost or expense (including reasonable legal fees) arising out of: (i) the User's breach of these Terms; (ii) the User's violation of any law or regulation applicable to a deal; or (iii) the User's infringement of third-party rights through the use of the Service.

16. Force majeure

Neither Party shall be liable for any delay or failure to perform its obligations to the extent it is prevented or significantly hindered by events beyond its reasonable control, including: acts of God, natural disasters, epidemics, fires, floods, earthquakes; wars, armed conflicts, civil unrest, terrorist attacks, changes of political regime; strikes, blockades, cyber-attacks, infrastructure outages, power or internet failures, sanctions, embargoes, court or regulatory orders, the failure or unavailability of banks, blockchain networks or Payment systems.

The affected Party will take reasonable steps to mitigate the impact of the force-majeure event and to resume performance as soon as possible.

17. Governing law & dispute resolution

These Terms are governed by the law applicable at the Company's registered seat, without prejudice to the mandatory consumer-protection rules available to Users in their country of habitual residence within the EU.

The Parties shall use reasonable efforts to resolve any dispute amicably through direct negotiation. If a dispute is not resolved within sixty (60) days from the date of a written claim sent to support@crypocto.com, either Party may submit the dispute to the competent courts determined in accordance with the applicable law, and, where applicable, to the online EU dispute-resolution platform available at ec.europa.eu/consumers/odr.

18. Changes to these Terms

The Company may amend these Terms from time to time to reflect changes in the Service, applicable law, business practices or risk management. Amendments come into force when the updated version is published on crypocto.com/terms, unless a later effective date is indicated in the publication itself. Where amendments are material, the Service will make its best effort to notify active Users in advance through the Service or by email. The User's continued use of the Service after the effective date constitutes acceptance of the revised Terms.

19. Contact

For any question, complaint or formal notice related to these Terms, please contact us:

• Email: support@crypocto.com
• Contact form: crypocto.com/contact
• Service operator: the legal entity responsible for the Crypocto brand — full legal name, registered office and regulatory details available on request.

These Terms, together with the Privacy Policy, the AML Policy and any specific escrow addendum signed for a given deal, constitute the entire agreement between the User and the Company with regard to the Service.