Version 2026-06-24

ZenFi Platform Terms of Use

Preamble

These Terms of Use (hereinafter — the "Agreement") govern the conditions of access to the ZenFi platform (hereinafter — the "Platform"), the use of its functionality, digital tools, NFT mechanics, internal units of account, the affiliate program, and other services available through the web interface, smart contracts, and related infrastructure.

This Agreement constitutes a legally binding agreement between the user of the Platform (hereinafter — the "User") and the company operating ZenFi (hereinafter — the "Company"), incorporated under the laws of Panama.

By using the Platform, connecting a cryptocurrency wallet, carrying out transactions, purchasing access to products, participating in the affiliate program, or otherwise interacting with the functionality of ZenFi, the User confirms that they have fully read, understood, and accepted this Agreement.

If the User does not agree with this Agreement, they must immediately cease using the Platform.

1. Definitions

Platform — the totality of software, technical, interface, server, blockchain, and smart-contract solutions of ZenFi available to Users through the web interface and related digital tools, including the products comprising the ecosystem.

Company — the legal entity incorporated in Panama that carries out the technical administration of the Platform.

User — any person accessing the Platform or using its functionality.

Wallet — the User's external cryptocurrency wallet used to interact with the blockchain infrastructure.

Ecosystem Products — software services to which access is provided through the Platform, including tools for community management, cross-chain exchange of digital assets, trading tools, copy trading, analytics, an AI assistant, gaming products, and other technological solutions.

NFT Key — a digital token used within the Platform as an element of access to the Ecosystem Products and their functionality according to level.

$ZEN — an external digital token that may be traded on decentralized venues and whose market value is determined solely by external market conditions.

$INT — an internal unit of account of the Platform, used exclusively within the functionality of ZenFi and not intended for independent circulation outside the Platform.

Affiliate Program — a software-based marketing mechanism allowing Users to promote the Ecosystem Products and receive rewards in accordance with the terms of this Agreement.

Reward — a digital, internal, or other conditional accrual that may be reflected in the Platform interface in accordance with its algorithms.

Smart Contract — program code deployed on a blockchain network, used for the automated execution of certain operations.

2. Legal Nature of the Platform

2.1. The ZenFi Platform is a technological software solution intended to provide Users with access to a set of digital products and tools, smart contracts, NFT-based mechanics, internal units of account, and other elements of digital infrastructure.

2.2. The principal subject matter of the User's interaction with the Platform is the acquisition of access to the Ecosystem Products and their functionality. By acquiring an NFT Key of the corresponding level, the User obtains technical access to a defined set of products and capabilities of the Platform.

2.3. The Company provides the User with technical access to the functionality of the Platform. Such access may not be regarded as the provision of financial, investment, brokerage, banking, custodial, payment, trust, advisory, or other regulated financial services.

2.4. The Company is not a bank, broker, investment adviser, asset manager, exchange operator, payment institution, depository, custodian, or operator of a collective investment scheme.

2.5. The Platform is not intended for and may not be regarded as a mechanism for raising investments from Users, collective management of funds, offering of yield, custody of Users' funds, or guaranteeing any increase in the value of digital assets.

2.6. All actions performed by the User on the Platform are carried out independently and at the User's own discretion, voluntarily, at their own risk, and with full understanding of the legal, financial, technical, and tax consequences.

2.7. The Company has the right to modify, supplement, restrict, suspend, or terminate individual functions of the Platform where necessary for security, compliance with the law, technical maintenance, protection of users, prevention of abuse, or adaptation of the Platform or its operating model.

3. Acceptance of the Agreement

3.1. The User is deemed to have accepted this Agreement from the moment of first actual use of the Platform, including, without limitation, connecting a wallet, creating an account, acquiring an NFT Key, using $INT, participating in the Affiliate Program, or carrying out any operation through the Platform interface.

3.2. Acceptance of this Agreement signifies the User's full and unconditional consent to all of its terms, including, without limitation, provisions concerning risks, limitation of liability, taxation, AML/KYC procedures, the Affiliate Program, suspension or restriction of operations, and applicable law.

3.3. If the User acts on behalf of a legal entity, the User represents and warrants that they have the necessary authority to enter into and accept this Agreement on behalf of such legal entity.

4. The User's Right to Use the Platform

4.1. By using the Platform, the User represents and warrants that:

a) they have reached the age of 18, as well as the age of majority under the laws of their jurisdiction; b) they have full legal capacity; c) they are not subject to any sanctions, restrictions, or prohibitions; d) they are not a resident, citizen, or person located in a jurisdiction where the use of the Platform is prohibited; e) they are not a citizen, resident, or person located in the territory of the United States of America, the People's Republic of China, or the United Kingdom, and are not a Restricted Person as defined in Section 5 of this Agreement; f) their use of the Platform does not violate applicable law; g) they have independently assessed the legality and permissibility of using the Platform in their jurisdiction.

4.2. Access to the Platform and its products, including gaming products, is permitted exclusively to persons who have reached the age of 18. The Company has the right to apply measures to restrict access by minors.

4.3. The Company is not obliged to verify the legality of each User's use of the Platform in their jurisdiction.

4.4. The User is solely responsible for accessing and using the Platform from their country, including compliance with applicable legislation on digital assets, taxation, currency control, advertising, consumer protection, financial services, and sanctions regulation.

4.5. The Company has the right to refuse access to the Platform, restrict its use, or terminate the provision of services to a User if the Company has reasonable grounds to believe that such User is violating this Agreement, applicable law, or is creating legal, regulatory, reputational, or technical risks for the Platform.

5. Restricted Jurisdictions and Compliance with Sanctions Requirements

5.1. The Platform is not intended for use by persons located in jurisdictions subject to international sanctions, embargoes, trade restrictions, or other measures prohibiting or materially restricting the provision of digital, technological, or related services.

5.2. The User is prohibited from accessing or using the Platform if such access or use would violate applicable sanctions laws, export control rules, AML/CFT requirements, or other mandatory legal requirements.

5.3. The Company has the right to apply geographic, technical, compliance-based, or other restrictions on access to the Platform at its discretion.

5.4. Any attempt to circumvent such restrictions, including through the use of a VPN, proxy services, falsified documents, the identity of others, or by any other means, constitutes a material breach of this Agreement.

5.5. Fully Prohibited Jurisdictions. Notwithstanding any other provision of this Agreement, access to and use of the functionality of the Platform are strictly prohibited for the following persons (hereinafter — "Restricted Persons"):

a) citizens of the United States of America, persons with permanent residence in the United States (including green card holders), United States tax residents, as well as any persons physically located within the United States or its territories; b) citizens of the People's Republic of China, as well as any persons physically located within the territory of the People's Republic of China; c) citizens of the United Kingdom of Great Britain and Northern Ireland, as well as any persons physically located within the territory of the United Kingdom.

5.6. Special Provisions Regarding U.S. Persons. The Platform and its functionality, including without limitation NFT Keys, tokens, the Affiliate Program, and any other elements, are under no circumstances offered, sold, or provided to persons connected with the United States of America. The Company does not provide services to U.S. citizens and residents under any scenario whatsoever and does not regard such persons as permissible users. Any interaction by a U.S.-connected person with the Platform is unauthorized and carried out in breach of this Agreement.

5.7. Prohibition on Circumventing Restrictions. Restricted Persons are categorically prohibited from accessing or using the Platform by any means, including through the use of a VPN, proxy servers, anonymizers, falsified or third-party documents, spoofed location data, IP address modification, or any other technical or organizational means of circumventing the established restrictions.

5.8. Absence of Company Liability. If a Restricted Person has accessed or used the Platform by employing a VPN, circumvention tools, false information about citizenship, residence, or location, or other methods of concealing their status, such person acts solely at their own risk and in breach of this Agreement. The Company bears no liability whatsoever for any consequences of such unauthorized access or use, including any losses or legal, tax, or regulatory consequences arising for such person. All responsibility for such access lies entirely with the Restricted Person.

5.9. The Company has the right, at any time and without prior notice, to block, restrict, or terminate access of any person in respect of whom there are grounds to believe that they are a Restricted Person or have circumvented the established restrictions, and to cancel operations, accruals, and rewards associated with such person.

6. User Account and Wallet

6.1. Access to certain functions of the Platform may be provided through the connection of an external cryptocurrency wallet.

6.2. The User is solely responsible for the security of their wallet, private keys, seed phrases, devices, passwords, email accounts, and any other means of access.

6.3. The Company does not store the User's private keys and has no technical ability to restore access to the User's wallet.

6.4. Loss of access to the wallet may result in the complete and irreversible loss of access to digital assets, NFTs, tokens, accrued balances, and any other elements associated with such wallet.

6.5. The Company bears no liability for any consequences arising from: a) loss of private keys; b) phishing attacks; c) compromise or hacking of the User's devices; d) disclosure of credentials to third parties; e) errors in specifying wallet addresses; f) use of malware; g) compromise of the User's account or wallet.

7. Smart Contracts and Blockchain Infrastructure

7.1. The Platform may use smart contracts deployed on one or more blockchain networks to provide certain functions, including interaction with digital assets, NFTs, internal accounting mechanisms, accruals, fees, and other technical operations.

7.2. The User acknowledges that smart contracts constitute program code executed on a distributed network, and their execution may occur automatically in accordance with the embedded logic, without additional confirmation, intervention, or control by the Company.

7.3. The User agrees that transactions executed by means of smart contracts may be irreversible, final, and not subject to cancellation once confirmed on the relevant blockchain network.

7.4. The Company makes no representations and gives no warranties regarding the absence of errors, vulnerabilities, defects, exploits, delays, failures, or other technical problems in smart contracts, blockchain networks, wallets, bridges, oracles, decentralized protocols, or any related infrastructure.

7.5. The Company bears no liability for any losses, including loss of digital assets, inability to access assets, delays in the execution of transactions, or other consequences arising from: a) errors or vulnerabilities in smart contracts; b) failures or congestion of blockchain networks; c) hacking attacks or actions of third parties; d) User errors in initiating or executing transactions; e) use of unsupported networks or protocols; f) transfer of digital assets to incorrect addresses; g) failures or vulnerabilities of external services, including wallets, bridges, decentralized exchanges (DEX), and other decentralized solutions.

7.6. The User is solely responsible for verifying all parameters of a transaction, including the recipient address, network, amount, fees, and any other conditions, prior to confirmation.

7.7. The Company has the right, at any time, to update, modify, replace, restrict, or disable smart contracts or any of their functions where necessary for security, error correction, functional changes, compliance with the law, or prevention of abuse.

7.8. In the event of a vulnerability, attack, technical error, or other security threat, the Company may, without prior notice to the User: a) suspend the execution of operations; b) restrict access to certain functions; c) block interaction with certain addresses or assets; d) take any other reasonable measures to protect the Platform and its Users.

7.9. The User understands and accepts that certain elements of the blockchain infrastructure may be beyond the Company's control and may depend on third parties, including validators, node operators, protocol developers, and infrastructure providers.

7.10. Neither smart contracts nor automated operations of the Platform may be regarded as a guarantee of profit, liquidity, return of funds, preservation of asset value, or any obligation of the Company to ensure any economic result.

8. Ecosystem Products

8.1. The principal value provided to the User within the Platform is access to a set of technological Ecosystem Products. Depending on the level of the NFT Key acquired, the User may be provided with, among other things:

a) a tool for managing and moderating communities in messengers; b) a cross-chain service for exchanging digital assets between different blockchain networks; c) a trading tool for carrying out transactions with digital assets; d) an automatic copy-trading service; e) an analytics service for the digital asset market; f) an AI assistant; g) gaming products; h) other products available within the ecosystem.

8.2. Access to products is provided on a technical basis. The Company does not guarantee that the use of any product will lead to any financial, economic, or other result for the User.

8.3. Products are provided on an "as is" and "as available" basis. The Company has the right to modify, supplement, restrict, or discontinue individual products, their functions, access parameters, and conditions of provision.

8.4. The use of trading, analytical, and other products related to digital assets does not constitute and may not be regarded as the provision of investment, financial, or trading advice. Any decisions made by the User when using such products are made independently and at their own risk.

8.5. Gaming Products (StarZen and Others)

8.5.1. The gaming products of the ecosystem, including StarZen, are entertainment software products of the "play-to-earn" type, in which the User may receive rewards in the form of ecosystem tokens or other digital prizes depending on their gaming achievements and skill.

8.5.2. The gaming products are not gambling, betting, or financial wagering. The receipt of rewards is determined by the User's gaming achievements rather than by a random stake of funds at entry.

8.5.3. Access to gaming products is permitted exclusively to persons who have reached the age of 18.

8.5.4. The Company does not guarantee that the User will receive any rewards, nor their amount, value, or liquidity. Any rewards are provided in accordance with the Platform's algorithms, which may be changed by the Company.

9. External Token ($ZEN)

9.1. $ZEN is an external digital token that may have a market value and may circulate and be traded on decentralized venues.

9.2. The Company does not control: a) the price of $ZEN; b) the liquidity of $ZEN; c) the presence of buyers or sellers; d) the existence or availability of trading venues; e) blockchain network fees; f) the operation, rules, or behavior of decentralized protocols; g) the actions or behavior of market participants.

9.3. The Company does not guarantee that the User will be able to acquire, sell, exchange, or withdraw $ZEN at any time or at any particular price.

9.4. Any information regarding $ZEN available on the Platform may not be regarded as investment advice, financial advice, a price forecast, or a promise or guarantee of return.

9.5. The User independently determines and undertakes any actions with $ZEN, acts at their own discretion, and bears full responsibility for all associated risks and consequences.

10. Internal Unit of Account ($INT)

10.1. $INT is an internal unit of account of the Platform, used exclusively to reflect certain actions, statuses, accruals, calculations, or other elements of ZenFi functionality.

10.2. $INT is not: a) legal tender; b) electronic money; c) a security; d) a financial instrument; e) a bank deposit; f) a share in the Company's property; g) a claim against the Company; h) an investment product; i) an independent crypto-asset intended for free circulation outside the Platform.

10.3. $INT does not grant the User any rights of ownership over the Company's property, rights to profit, dividends, management, voting, distribution of revenue, or other participation in the Company's business.

10.4. The Company has the right, at any time, to change: a) the functionality of $INT; b) the procedure for accrual; c) the procedure for use; d) restrictions; e) internal coefficients; f) calculation algorithms; g) the conditions for discontinuing support of $INT.

10.5. The User understands that $INT may lose its functional significance, be restricted, canceled, changed, or withdrawn from use within the Platform.

10.6. The Company does not guarantee the ability to exchange $INT for $ZEN, NFTs, fiat funds, other tokens, or any assets. $INT is not intended for the accumulation of value, investment, or subsequent extraction of economic benefit.

11. NFT Keys and Digital Functionality

11.1. NFT Keys within the Platform are used as digital elements of access, accounting, functional interaction, or participation in certain mechanics of the ecosystem. The principal purpose of an NFT Key is to provide the User with access to the Ecosystem Products in accordance with their level.

11.2. NFT Keys are not: a) securities; b) investment contracts; c) a share in a business; d) a right to dividends; e) a right to participate in the management of the Company; f) a guarantee of income; g) a guarantee of liquidity; h) an obligation of the Company to buy back.

11.3. The acquisition of an NFT Key does not entail the acquisition of rights to the Company's intellectual property, trademarks, program code, design, trade secrets, databases, or other objects of the Company's rights.

11.4. The User understands that the value of NFT Keys may be volatile, subjective, speculative, or equal to zero.

11.5. The Company does not guarantee the existence of a secondary market for NFT Keys, the presence of buyers, demand, a minimum price, or the possibility of resale.

11.6. The Company has the right to temporarily restrict operations with NFT Keys where there are technical, compliance, AML, sanctions, regulatory, or other reasonable grounds.

12. Affiliate Program

12.1. The Affiliate Program is a transparent software-based marketing mechanism, implemented via a smart contract, designed for the promotion and distribution of access to the real Ecosystem Products. Rewards under the Affiliate Program are paid for the promotion and distribution of access to the Platform's products, and not for the mere fact of attracting other persons.

12.2. Participation in the Affiliate Program is voluntary and available only subject to compliance with the terms of this Agreement.

12.3. A participant in the Affiliate Program (hereinafter — the "Partner") acts as an independent party. The Partner is not an employee, agent, representative, franchisee, broker, financial adviser, manager, fiduciary, or authorized representative of the Company.

12.4. The Partner is not authorized to: a) act on behalf of the Company; b) sign contracts on behalf of the Company; c) guarantee returns; d) promise profit; e) represent themselves as a manager or official representative of the Company; f) create the impression that they are authorized by the Company; g) use misleading statements; h) provide investment, financial, tax, or legal advice.

12.5. The Affiliate Program is a software-based marketing mechanism associated with Users' product-promotion activity and the internal algorithms of the Platform. Participation in the Affiliate Program does not guarantee the receipt of income, payouts, the activity of attracted users, the growth of a structure, the filling of levels, the stability of accruals, or the preservation of prior conditions. The amount of any reward depends on the volume of distributed product access and the efforts of the Partner themselves and is not fixed or guaranteed.

12.6. Any reward under the Affiliate Program does not constitute investment income, interest, a dividend, or a return on invested funds and must not be regarded as such.

12.7. The Company has the right to modify, restrict, suspend, or terminate the Affiliate Program in whole or in part.

12.8. The Partner is solely responsible for all of their advertising materials, publications, presentations, landing pages, posts, mailings, webinars, videos, offline events, and other promotional activity.

12.9. All statements made by the Partner must be accurate, truthful, not misleading, and compliant with applicable law.

12.10. The Partner is prohibited from using wording or materials that create the impression of: a) guaranteed income; b) an investment program; c) risk-free passive income; d) an official financial service; e) a banking product; f) a collective investment scheme; g) a mandatory buyback; h) guaranteed liquidity.

12.11. The Partner must comply with applicable law regarding advertising, consumer protection, personal data, financial promotion, taxes, digital assets, and sanctions.

12.12. The Company is not obliged to pre-screen or approve the Partner's marketing materials.

12.13. In the event of a breach of the terms of the Affiliate Program, the Company has the right to: a) restrict the account; b) suspend accruals; c) cancel disputed commissions; d) exclude the Partner from the program; e) block access to certain functions; f) transfer data to competent authorities; g) demand compensation for losses.

12.14. The Partner undertakes to compensate the Company for any losses, expenses, fines, claims, court costs, legal fees, and reputational damage arising from the Partner's actions, statements, advertising, breaches, or bad-faith conduct.

13. Repeat Operations and Internal Mechanics

13.1. Any references to "reactivations," "repeat purchases," "activity," "accruals," or similar terms shall be understood as elements of software-based, internal mechanics of the Platform associated with the acquisition and renewal of access to the Ecosystem Products, unless otherwise expressly provided by this Agreement.

13.2. The acquisition or repeat acquisition of access is not an investment, contribution, deposit, financial product, or guarantee of income.

13.3. Payments for access to products are non-refundable, except in cases expressly provided by applicable mandatory law or a separate policy of the Company.

13.4. The User acknowledges that the acquisition of access does not guarantee the receipt of income, rewards, digital assets, NFTs, $ZEN, liquidity, or any other economic results.

14. Algorithmic Distribution System

14.1. The Platform may use software algorithms to calculate, distribute, display, or modify internal accruals, statuses, rewards, and other elements of functionality.

14.2. Such algorithms are part of the Platform's software and do not create for the User any guaranteed right to income, profit, fixed payouts, or the preservation of any particular level of accruals.

14.3. The Company does not guarantee: a) the activity of other users; b) the filling of any levels, structures, or positions; c) the receipt of rewards; d) the growth of the user base; e) the stability of the algorithms; f) the immutability of the Platform's economic model.

14.4. Any examples of calculations, income, potential accruals, or development scenarios are provided solely for illustrative purposes and must not be regarded as a promise, guarantee, or forecast.

14.5. The Company has the right to change the algorithmic model of the Platform where necessary for security, stability, compliance with the law, prevention of abuse, or product development.

15. Fees

15.1. The Company has the right to charge fees for the use of certain functions of the Platform.

15.2. Fees may include: a) a service fee; b) a network fee; c) a processing fee; d) a conversion fee; e) a marketplace fee; f) other applicable fees.

15.3. The Company may unilaterally change the amount and method of calculating fees, taking into account market conditions, technical costs, network fees, risks, and other factors.

15.4. The User must independently verify the amount of applicable fees prior to carrying out a transaction.

16. AML/KYC and Compliance

16.1. The Company has the right to implement AML/KYC, CFT, sanctions screening, source-of-funds verification, transaction monitoring, and User risk assessment procedures.

16.2. Such procedures may be carried out: a) upon registration; b) upon connecting a wallet; c) prior to the withdrawal of assets; d) upon reaching certain limits; e) in the event of suspicious activity; f) upon participation in the Affiliate Program; g) at the request of regulators, law enforcement, tax, or other competent authorities; h) in other cases where the Company deems verification necessary on a risk-based approach.

16.3. The Company has the right to request from the User: a) an identity document; b) proof of address; c) a selfie or video verification; d) information about the source of funds; e) information about the source of wealth; f) tax information; g) data on the User's activity; h) information about associated wallets; i) other documents reasonably necessary for compliance purposes.

16.4. The Company has the right to use third-party KYC/AML providers, blockchain analytics services, sanctions databases, fraud monitoring tools, and other technical solutions.

16.5. The Company has the right to restrict access, freeze transactions, suspend withdrawals, reject a transaction, or terminate service to a User if: a) the User has not passed verification; b) the User has provided false or incomplete information; c) the User has refused to provide documents; d) the User's wallet is associated with high-risk activity; e) there are sanctions, AML/CFT, fraud, regulatory, or other risks; f) the Company has received a corresponding request from a competent authority.

16.6. The Company has the right not to disclose to the User the details of an internal compliance check if such disclosure may violate the law, regulatory requirements, internal security procedures, or anti-money-laundering rules.

17. Disclosure of Data to Competent Authorities

17.1. The Company has the right to disclose information about the User, their account, wallets, transactions, IP addresses, devices, documents, and actions on the Platform to competent authorities where such disclosure is required or permitted by law, a court act, or a request from a regulator, law enforcement authority, tax authority, or other authorized body.

17.2. The Company also has the right to disclose data to protect its rights, prevent fraud, investigate breaches, comply with AML/CFT requirements, protect users, and ensure the security of the Platform.

17.3. The User understands that in certain cases the Company may be limited in its ability to notify the User of such disclosure.

18. Prohibited Use of the Platform

18.1. The User is prohibited from using the Platform for: a) money laundering; b) terrorist financing; c) circumvention of sanctions; d) fraud; e) phishing; f) the use of stolen funds; g) market manipulation; h) violation of the rights of third parties; i) distribution of malware; j) exploitation of vulnerabilities; k) spamming; l) misleading other users; m) illegal advertising; n) illegal raising of investments; o) any activity that violates applicable law.

18.2. The Company has the right to investigate any alleged breaches of this section and to take technical, legal, and compliance measures.

19. Risks

19.1. The User acknowledges that use of the Platform involves a high level of risk.

19.2. The User may lose: a) the value of acquired digital assets; b) the value of NFT Keys; c) internal accruals; d) access to the wallet; e) the ability to withdraw funds; f) expected rewards; g) the value of $ZEN or other tokens.

19.3. The principal risks include: a) market volatility; b) lack of liquidity; c) a fall in asset value to zero; d) technical errors; e) smart contract vulnerabilities; f) hacking attacks; g) user errors; h) loss of private keys; i) phishing; j) actions of third parties; k) changes in legislation; l) sanctions restrictions; m) tax consequences; n) cessation of the Platform's operation.

19.4. The Company does not guarantee: a) the return of funds; b) income; c) profit; d) liquidity; e) price stability; f) preservation of functionality; g) availability of the Platform; h) the ability to exit the project; i) successful participation in the Affiliate Program.

19.5. The User accepts all risks voluntarily and confirms that they do not rely on the Company's statements as financial, investment, tax, or legal advice.

19.6. Absence of Investment Nature and Expectations of Profit

19.6.1. The Platform is intended to provide access to the technological Ecosystem Products and is not intended for investing, extracting profit, or obtaining economic benefit from contributions.

19.6.2. The use of $INT, NFT Keys, access to products, algorithmic accruals, the Affiliate Program, and other elements of the Platform: a) is not intended to generate investment income; b) must not be regarded as investment activity; c) does not create expectations of profit from contributions or the return of funds as an investment; d) is not a financial instrument or investment product.

19.6.3. The User confirms that they: a) do not rely on the Platform as a guaranteed source of investment income; b) understand that any potential value of digital elements is uncertain and depends on external factors; c) acquire access to the Ecosystem Products with an understanding of their technological rather than investment nature.

19.6.4. The Company does not guarantee and does not create conditions for Users to extract investment profit.

20. Taxes

20.1. The User is solely responsible for determining, declaring, and paying any taxes, levies, duties, and other mandatory payments associated with the use of the Platform.

20.2. The Company is not the User's tax agent, does not calculate the User's tax obligations, does not withhold taxes, and does not provide tax advice.

20.3. Potentially taxable events may include: a) the receipt of rewards; b) the sale of NFT Keys; c) the exchange of digital assets; d) the receipt of $ZEN; e) affiliate commissions; f) marketplace operations; g) an increase in the value of digital assets; h) other operations depending on the User's jurisdiction.

20.4. The User must independently keep records of their operations and consult professional tax advisers.

20.5. If claims are brought against the Company as a result of the User's breach of tax law, the User agrees to compensate the Company for all associated losses, expenses, fines, penalties, and court and legal costs.

21. Intellectual Property

21.1. All rights to the Platform, source code, design, interface, databases, algorithms, texts, trademarks, trade names, domains, logos, graphics, documentation, and other elements belong to the Company or its rights holders.

21.2. The User is granted a limited, revocable, non-transferable, non-exclusive right to use the Platform only within the limits provided by this Agreement.

21.3. The User is prohibited from: a) copying the Platform; b) modifying the source code; c) reverse engineering; d) extracting databases; e) using the Company's trademarks without permission; f) creating derivative works; g) circumventing technical restrictions.

22. Data and Confidentiality

22.1. The Company may process the User's data for the purposes of: a) providing access to the Platform; b) security; c) AML/KYC; d) fraud prevention; e) technical support; f) analytics; g) compliance with the law; h) protection of the rights of the Company and users.

22.2. The processing of personal data is governed by the Company's separate Privacy Policy.

22.3. The User agrees that data may be transferred to service providers, KYC/AML providers, hosting providers, analytics services, legal advisers, payment and technical partners, as well as competent authorities where there are legal grounds.

22.4. The Company takes reasonable security measures but does not guarantee absolute protection of data from unauthorized access, cyberattacks, failures, or actions of third parties.

23. Availability of the Platform

23.1. The Platform is provided on an "as is" and "as available" basis.

23.2. The Company does not guarantee that the Platform will operate continuously, without errors, securely, without delays, or without technical failures.

23.3. The Company has the right to carry out technical maintenance, updates, migrations, error correction, changes to smart contracts, disabling of functions, or other technical work.

23.4. The Company bears no liability for inability to access the Platform if such inability is caused by technical failures, actions of third parties, blockchain networks, providers, regulatory restrictions, cyberattacks, or circumstances beyond the Company's reasonable control.

24. Disclaimer of Warranties

24.1. The Company provides no express or implied warranties regarding the Platform, including warranties of fitness for a particular purpose, merchantability, uninterrupted operation, security, accuracy of data, liquidity, or conformity to the User's expectations.

24.2. The Company does not guarantee that the use of the Platform will be lawful in every User's jurisdiction.

24.3. The User is solely responsible for determining whether they are entitled to use the Platform in their country.

25. Limitation of Liability

25.1. To the maximum extent permitted by applicable law, the Company bears no liability for: a) indirect losses; b) lost profit; c) loss of data; d) loss of digital assets; e) loss of access to a wallet; f) a decrease in the value of tokens; g) lack of liquidity; h) actions of third parties; i) smart contract errors; j) actions of blockchain networks; k) tax consequences; l) regulatory restrictions; m) cessation of certain functions.

25.2. If the Company's liability cannot be fully excluded by law, the Company's aggregate liability to the User is limited to the amount actually paid by the User to the Company for the use of the relevant function of the Platform during the three months preceding the claim.

25.3. The limitation of liability does not apply in cases where such limitation is expressly prohibited by mandatory applicable law.

26. Indemnification

26.1. The User undertakes to defend the Company, its directors, employees, contractors, partners, and affiliated persons from any claims, losses, expenses, fines, court costs, and demands arising from: a) the User's breach of this Agreement; b) misuse of the Platform; c) violation of the rights of third parties; d) violation of tax law; e) violation of AML/CFT or sanctions rules; f) bad-faith marketing; g) actions within the Affiliate Program; h) the provision of false information.

27. Suspension and Termination of Access

27.1. The Company has the right to suspend, restrict, or terminate the User's access to the Platform if: a) the User has breached this Agreement; b) the User has not passed AML/KYC; c) there are suspicions of fraud; d) there are sanctions or regulatory risks; e) the User abuses the functionality of the Platform; f) the User violates the rights of third parties; g) the access poses a threat to the security of the Platform.

27.2. Termination of access does not release the User from obligations arising prior to such termination.

27.3. The Company is not obliged to compensate the User for losses associated with the lawful restriction of access in accordance with this Agreement.

28. Changes to the Agreement

28.1. The Company has the right to change this Agreement at any time.

28.2. The new version takes effect from the moment of its publication on the Platform's website, unless a different effective date is specified in the change itself.

28.3. Continued use of the Platform after the publication of changes signifies the User's acceptance of the new version of the Agreement.

28.4. If the User does not agree with the changes, they must cease using the Platform.

29. Applicable Law

29.1. This Agreement is governed by and construed in accordance with the laws of Panama.

29.2. The choice of the law of Panama does not exclude the application of mandatory consumer protection rules that may apply to the User in their country of residence, provided that such rules cannot be excluded by agreement of the parties.

30. Dispute Resolution

30.1. The parties agree to first attempt to resolve any dispute through negotiation.

30.2. The User must send the Company written notice of the dispute describing the claims, circumstances, and supporting documents.

30.3. If the dispute is not resolved within 30 calendar days from the date of receipt of the notice, it shall be resolved by arbitration.

30.4. Any dispute, disagreement, or claim arising out of or in connection with this Agreement shall be finally resolved by arbitration in Panama City, Panama.

30.5. The language of the arbitration shall be English, unless the parties agree otherwise in writing.

30.6. The Company has the right to apply to a competent court for interim measures, an injunction against unauthorized use of intellectual property, protection of confidential information, prevention of fraud, or cessation of the User's unlawful actions.

31. Electronic Communications

31.1. The User agrees to receive legally significant notices in electronic form.

31.2. Notices may be sent through: a) the Platform interface; b) email; c) the User's account; d) publication on the website; e) other electronic means of communication.

31.3. Electronic notices have the same legal force as written notices on paper, unless otherwise required by mandatory law.

32. Force Majeure

32.1. The Company bears no liability for failure to perform or delay in performing its obligations caused by circumstances beyond its reasonable control.

32.2. Such circumstances include: a) wars; b) sanctions; c) actions of governmental authorities; d) cyberattacks; e) failures of blockchain networks; f) internet outages; g) failures of service providers; h) natural disasters; i) epidemics; j) market crises; k) sudden changes in legislation; l) actions of third parties.

33. Severability of Provisions

33.1. If any provision of this Agreement is found to be invalid, unlawful, or unenforceable, the validity of the remaining provisions is not affected.

33.2. Such provision shall be interpreted or replaced in a manner that best preserves the original commercial and legal intent of the parties.

34. Entire Agreement

34.1. This Agreement, the Privacy Policy, the Cookie Policy, the Risk Disclosure, the AML/KYC Policy, and other documents published by the Company constitute the entire agreement between the User and the Company regarding the use of the Platform.

34.2. In the event of a conflict between this Agreement and other documents of the Company, this Agreement prevails, unless a different priority is expressly established by the relevant document.

35. Final Provisions

35.1. The User may not transfer their rights and obligations under this Agreement to third parties without the prior written consent of the Company.

35.2. The Company has the right to transfer its rights and obligations under this Agreement to an affiliated person, successor, purchaser of the business, or other party as part of a restructuring, sale of business, transfer of assets, or corporate reorganization.

35.3. The Company's failure to act in the event of a breach of this Agreement by the User does not constitute a waiver of the Company's right to take appropriate action in the future.

35.4. Section headings are provided solely for convenience and do not affect the interpretation of this Agreement.