Terms of Service

  1. Preambule

    1. This document (hereinafter, the “Terms and Conditions”) contains the principal provisions pertaining to the operation of the Relopay System and using this System.

    2. The Terms and Conditions define the principles and conditions on which the Relopay - provides the Customers with an access to the System Services, charging Fees as per the agreed Rates, and a Customer shall use the System and its Services in accordance with these Terms and Conditions and Internal Policies.

    3. The Terms and Conditions define the principles and conditions on which the Relopay – provides the Customers with an access to the System Services, charging Fees as per the agreed Rates, and a Customer shall use the System and its Services in accordance with these Terms and Conditions and Internal Policies.

    4. The Terms and Conditions define the principles and conditions on which the Relopay – provides the Customers with an access to the System Services, charging Fees as per the agreed Rates, and a Customer shall use the System and its Services in accordance with these Terms and Conditions and Internal Policies.

    5. The Terms and Conditions define the principles and conditions on which the Relopay – provides the Customers with an access to the System Services, charging Fees as per the agreed Rates, and a Customer shall use the System and its Services in accordance with these Terms and Conditions and Internal Policies.

    6. The Terms and Conditions define the principles and conditions on which the Relopay – provides the Customers with an access to the System Services, charging Fees as per the agreed Rates, and a Customer shall use the System and its Services in accordance with these Terms and Conditions and Internal Policies.

  2. Role of Relopay and Fund Management

    1. Relopay acts as a facilitator between Customers and Issuer (as defined herein). Relopay does not hold responsibility for effectuating the transactions with use of the issued virtual cards.

    2. We advise Customers against retaining funds on their Relopay virtual cards longer than necessary. Instead, these cards should only be used as a temporary method for executing transactions.

    3. Relopay ensures the security of USDT and other assets transferred to Relopay until they are converted or transferred to the Issuer. However, this guarantee does not extend to the funds held by the Issuer and shown as the balance available on the virtual cards. Customers should be aware that such funds may be subject to restrictions imposed by the banking institutions used by the Issuer.

    4. Relopay, in its capacity as a service facilitator, shall bear no liability for any actions taken by Issuer or banking institutions with respect to Customers’ funds, including but not limited to account freezes, delays, or other restrictions.

  3. Terms and Definitions

    1. “Account” shall mean the virtual profile of a Customer in the System registered in accordance with these Terms and Conditions and Internal Policies.

    2. “Relopay’s Contact Details” shall mean the following addresses from the Relopay's side:
      for communication via email: support@relopay.io

    3. “Applicant” shall mean an individual willing to create an Account and submitting the registration application via the System.

    4. “Authorization Details” shall mean a combination of the Login and Password.

    5. “Authorization” shall mean the process of authenticating a person by the Login and Password.

    6. “Chargeback” shall mean the procedure of cancelling a bank card payment initiated by the cardholder through their bank.

    7. “Contact Details” shall mean email address and mobile number entered by a Customer into the System.

    8. “Customer” shall mean an individual being an Account holder, who has completed the Registration and has a right to use the System in accordance with the Terms and Conditions and Internal Policies.

    9. “Dormant Account” shall mean an account in which the Customer has not logged in for one year or more.

    10. “Fees” shall mean remuneration charged by the Relopay for the System Services provided to a Customer.

    11. “Funds” shall mean electronic money and digital assets that are owned by a Customer and accounted for as funds in this Customer’s Wallet.

    12. “Internal Policies” shall mean the Relopay’s internal documents that govern operation of the System, including the AML Policy and Personal Data Protection Policy published on the Website.

    13. “Login” shall mean a Customer’s email address or an alphanumeric combination specified by a Customer.

    14. “Parties” shall mean the Relopay and a Customer.

    15. “Password” shall mean an alphanumeric combination specified by a Customer during the Registration used together with Login to access the Account.

    16. “Payment Order” shall mean an instruction requesting the execution of a Transaction given by a Customer in an electronic form through the System.

    17. “Payment” shall mean Funds accounted for as funds in a Wallet and transferred from a Customer to a third party or from a third party to a Customer.

    18. “Prohibited Activities” shall mean activities characterized by one or more of the following qualities: constitute criminal offense in a Customer’s country of residence; are connected with sales of goods, works or services distribution (GWS) prohibited for sale in a Customer’s country of residence; are prohibited under the applicable laws; are connected with sales of any GWS (any and all transactions) referred to in Exhibit 1 to the Terms and Conditions; contradict the accepted universal standards of ethics and morality.

    19. “Application” shall mean the application operated within the Telegram ecosystem called Relopay, which, together with the Website and other components, forms part of the System.

  4. General Provisions

    1. To become a Customer and use the System Services, an Applicant has to create the Account in accordance with the procedures described herein.

    2. The Customer has a right to receive the information about the System Services provided by the Relopay, about these Terms and Conditions and Internal Policies, to obtain access to the System Services in accordance with a Customer’s status and any other restrictions described by the present Terms and Conditions and the Internal Policies.

    3. The Customer may receive technical and informational support in relation to the use of the System Services.

  5. Registration, Verification and Accepting Terms and Conditions

    1. An Applicant who wishes to create an Account shall complete the Registration process, which includes: activating the Account in the Application; undergoing Verification of identity for the Account; and accepting these Terms and Conditions by clicking “Continue” when prompted during the Verification process.

    2. Upon the Applicant’s acceptance of these Terms and Conditions, a bilateral agreement shall be deemed concluded between the Parties.

    3. During Registration, the Applicant shall provide the following details to Relopay:

      1. Name;

      2. Surname;

      3. Email address;

      4. Password.

    4. By accepting these Terms and Conditions, the Applicant represents and warrants that he/she is acting solely on his/her own behalf and not on behalf of, or in the interest of, any third party.

    5. For the purposes of customer identification and compliance with applicable anti-money laundering and counter-terrorist financing (AML/CTF) laws and regulations, the Applicant or Customer (if Verification takes during use of the System) shall provide the following information and documentation to Relopay:

      1. An image of a valid identification document issued by a competent state authority, containing a unique identification number;

      2. Photo;

      3. Mobile phone number;

      4. Liveness check;

      5. Proof of address documents;

      6. Information on the purpose of the Account creation, source of wealth, occupation and name of employer;

      7. Authentication with the use of videoconference, including the use of the third-party services.

    6. To verify the phone number indicated in the System, Relopay will send an automatically generated one-time password to the indicated phone number that should be entered in Application.

    7. If the information required under Clause 5.5. is not provided, or is found to be unreliable, incomplete, or outdated (in whole or in part), the Verification shall be deemed unsuccessful (failed).

    8. Verification shall normally be completed within 24 hours after the Applicant / Customer has provided the requested information. However, this period may be extended where Relopay has reasonable grounds to conduct enhanced due diligence in accordance with applicable AML/CTF requirements.

    9. Verification shall be deemed completed once the Applicant / Customer receives confirmation from Relopay, either by email or at the phone number provided in the System, at the Customer’s choice. Once Verification is completed, the Applicant / Customer may access the System Services.

    10. The Customer shall promptly notify Relopay of any changes to the information provided for Verification and shall provide up-to-date information as soon as reasonably possible.

    11. Relopay may, at any time and at its sole discretion, require the Customer to confirm that the documents and information previously provided remain accurate, complete, and up-to-date and/or to provide additional supporting documents or information within fourteen (14) days.

    12. If the Customer fails to provide the documents and/or information requested under Clause 5.11 within the prescribed period, Relopay may:

      1. Cancel the Verification;

      2. and/or Suspend the Account.

    13. By completing Registration and Verification, the Customer acknowledges and agrees that Relopay processes personal data strictly in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), and solely for the purposes of providing services, fulfilling legal obligations (including AML/CTF compliance), preventing fraud, and maintaining the integrity of the System.

  6. Account

    1. Once the Applicant successfully completes Registration in accordance with Section 5, an Account is created within the Relopay System and the Applicant becomes a Customer.

    2. Through the Account, the Customer may create and maintain custodial crypto Wallets with Relopay. Digital assets transferred to such Wallets are held by Relopay on a custodial basis until further transferred, exchanged, or withdrawn. The Customer may, via the Relopay interface, apply for Relopay Cards issued by the Issuer. All fiat balances displayed on such cards are held and managed exclusively by the Issuer. Relopay does not custody fiat funds and acts only as a technical interface to facilitate communication between the Customer and the Issuer. Any other features and functionalities of Accounts, including any special categories of Accounts, are described on the Website or in the Application. Relopay may update or restrict available features at its discretion.

    3. To create an Account, an individual must be at least eighteen (18) years old and have full legal capacity under the laws of his/her country of residence. By creating an Account, the Customer represents and warrants that these requirements are satisfied. Relopay may request proof of age or capacity at any time.

    4. Accounts may not be created by citizens or residents of jurisdictions that are not listed as Supported Countries on the Website or in the Application. Relopay should be eligible to amend such a list at any time to comply with AML/CTF regulations applicable.

    5. The Customer may only create an Account if such actions do not violate the laws or regulations of his/her country of residence or registration. By creating an Account, the Customer represents and warrants that no such violation occurs. The Customer shall indemnify and hold harmless Relopay from all losses, liabilities, and expenses arising from a breach of this Clause.

    6. Relopay records and maintains information concerning the Customer’s Account and Wallet activity for the duration of these Terms and Conditions and for at least five (5) years after termination of these Terms and closure of the Account, in compliance with applicable law.

    7. Access to the Account, Wallet(s), and any Relopay Card(s) requires Authorization through Authorization Details, including a Login and Password. A Login is generated automatically by the System using the email address provided during Registration (or as later updated upon the Customer’s request to support), while the Password must be created independently by the Customer. The Customer may change the Authorization Details at any time. The Customer is solely responsible for maintaining the confidentiality and security of the Authorization Details, and any actions performed in the System using valid Authorization Details shall be deemed to have been performed by the Customer.

    8. If Authorization Details are entered incorrectly three (3) times, the Account will be suspended. To restore access, the Customer must contact support.

    9. If the Customer loses Authorization Details, he/she must contact support to recover access. Recovery may include:

      1. a recovery link sent to the registered email;

      2. an SMS verification code sent to the verified mobile number, to be entered on the Website; and/or

      3. additional verification steps as determined by Relopay for security.

    10. The Customer may receive technical and informational support in relation to the use of the System Services.

    11. The Customer may receive technical and informational support in relation to the use of the System Services.

  7. Relopay Cards

    1. The Customer may be offered the option to obtain a Relopay Card through the Account. Relopay Cards may be virtual or, where available, physical.

    2. Relopay Cards are issued and managed solely by an independent third-party provider (the “Issuer”). Relopay is not the issuer of cards and does not custody fiat funds. At present, all cards are issued and powered by Xfers Pte. Ltd.

    3. To obtain a Relopay Card, the Customer may be required to provide additional information and undergo verification procedures for the purposes of anti-money laundering, fraud prevention, and risk management. Use of the Relopay Card is subject to a separate agreement between the Customer and the Issuer (the “Cardholder Agreement”). The Customer must comply fully with the Cardholder Agreement. The Customer expressly consents to Relopay transmitting information relating to the Relopay Card between the Customer and the Issuer for the purpose of card issuance and use.

    4. Relopay’s role is limited to providing a technical interface and information conduit between the Customer and the Issuer. Relopay does not process, authorize, or settle fiat transactions

    5. The Customer is fully responsible for all transactions made with the Relopay Card until it is cancelled or blocked. The Relopay Card may not be used for any unlawful, fraudulent, or restricted purpose. If the Customer loses a Relopay Card or suspects unauthorized use, the Customer must immediately request cancellation by contacting support@relopay.io.

    6. Cancellation, suspension, or freezing of a Relopay Card may take time to take effect. The Customer remains liable for all transactions made until such measures are implemented. If a Relopay Card is cancelled, suspended, or frozen, any remaining value will be available in the Account, subject to deduction of any outstanding liabilities owed by the Customer to Relopay or the Issuer. Relopay reserves the right to instruct the Issuer to suspend, cancel, freeze, or otherwise limit a Relopay Card in order to comply with applicable laws, mitigate risk, or prevent misuse.

    7. If Relopay incurs any liability to the Issuer arising from or related to the Customer’s use of a Relopay Card, the Customer shall indemnify and hold harmless Relopay against all such amounts, including associated costs or expenses.

    8. Each Relopay Card has an expiry date printed on it or displayed in the Application. Upon expiry, the Card will cease to function. Renewal or re-issuance of the Card is at the sole discretion of the Issuer. Relopay shall not be liable for any inability to use an expired Card.

    9. If a Relopay Card remains unused for a continuous period that is described specifically for each type of the Relopay Card within the Application or in Cardholder Agreement, the Issuer may, in accordance with its policies, suspend or cancel the Card. Relopay accepts no responsibility for such suspension or cancellation.

    10. The Customer must keep all Relopay Card details and Authorization Details secure at all times. Any use of the Relopay Card with valid credentials shall be deemed authorized by the Customer.

  8. Card Top-Up and Withdrawal

    1. For internal accounting, Relopay creates a custodial Wallet for each Relopay Card. Supported digital assets sent by the Customer for top-up are first credited to this Wallet.

    2. By sending supported digital assets for the purpose of a Relopay Card top-up, the Customer expressly authorizes Relopay to convert such assets into fiat currency at the prevailing System exchange rate and to transfer the converted fiat to the Issuer for crediting to the Relopay Card balance. The list of digital assets supported for Card top-ups is provided and updated in the Application from time to time.

    3. The Customer may request withdrawals of digital assets from Wallets by submitting an electronic request. Withdrawals may require additional verification. The Wallet balance must be sufficient to cover the withdrawal and applicable fees.

    4. Relopay and/or the Issuer may require the Customer to undergo additional verification, including KYC/AML checks, before processing any top-up or withdrawal. Transactions may be delayed, rejected, or reversed if verification is not satisfied.

    5. Relopay may impose daily, monthly, or per-transaction limits on top-ups or withdrawals based on the Customer’s status, jurisdiction, verification level, or risk profile. The Issuer may also impose limits on fiat balances or Relopay Card transactions. Relopay and/or the Issuer may restrict deposit/withdrawal methods or payees for risk-based reasons.

    6. Exchange rates, fees, and conditions for Card top-ups and withdrawals are published in the Account, Website, or Application. The Customer may also exchange currencies within the System at displayed rates. Once fiat is credited by the Issuer to the Relopay Card, the top-up is final and non-refundable. Relopay is not liable for delays or failures in crediting fiat caused by the Issuer,

    7. The Customer may request withdrawals of digital assets from Wallets by submitting an electronic requeRelopay and the Issuer may decline, suspend, or reverse any top-up or withdrawal where required to comply with applicable laws, regulations, or sanctions regimes. The Customer acknowledges that Relopay and the Issuer are not liable for losses arising from such compliance measures.st. Withdrawals may require additional verification. The Wallet balance must be sufficient to cover the withdrawal and applicable fees.

    8. Fiat funds loaded onto Relopay Cards are held solely by the Issuer. Relopay shall not be liable for any loss, unavailability, or reduction of funds due to the insolvency, suspension, or failure of the Issuer, its banking partners, or other third parties.

  9. Transactions

    1. All transactions made with a Relopay Card are executed exclusively by the Issuer. By presenting or entering Relopay Card details at the point of purchase or withdrawal, the Customer gives a direct payment order to the Issuer. Relopay does not process, authorize, or settle transactions and bears no responsibility for their execution.

    2. Relopay’s role is limited to providing a technical interface that displays information received from the Issuer regarding Relopay Card transactions, balances, and history. Relopay does not verify, modify, or control the data provided by the Issuer.

    3. The transaction not exceeding the applicable limits set shall be performed without undue delay not later than 24 hours after the payment order is received. The timing of a transaction that depends on third-party financial services is determined in accordance with the policies of such third parties. The Relopay shall not be liable for the delay caused by the fault of the third parties.

    4. Transactions performed with the Relopay Card will be displayed in the Customer’s Account for reference purposes, together with balance and transaction history. Relopay does not verify, modify, or guarantee the accuracy, completeness, or timeliness of such data.

    5. All Relopay Card transactions are governed by the Cardholder Agreement between the Customer and the Issuer, the Issuer’s internal policies, and applicable law.

    6. All limits, fees, restrictions, and conditions applicable to Relopay Card transactions are established by the Issuer and disclosed in the Cardholder Agreement and/or in the Application or Website. Relopay has no control over such conditions.

    7. If the Customer uses the Relopay Card in a foreign currency, conversion into USD and any applicable fees are determined by the Issuer and as disclosed in the Cardholder Agreement.

    8. If the Relopay Card does not have a sufficient fiat balance, the transaction will normally be declined. In the rare event that a transaction is approved despite insufficient fiat, the Customer authorizes Relopay to convert and debit an equivalent amount of digital assets from the Wallet at the prevailing System exchange rate. If insufficient assets are available, the Customer must immediately settle the shortfall, including fees and liabilities.

    9. Relopay may send electronic notifications of Relopay Card transactions and the Customer may download reports via the Account. Such data is provided for convenience only and originates from the Issuer.

    10. Relopay shall not be liable for: (a) the execution, delay, rejection, or reversal of any Relopay Card transaction by the Issuer; (b) holds, freezes, chargebacks, or restrictions imposed by the Issuer, banks, or regulators; or (c) any claims, losses, or disputes arising out of or relating to Relopay Card transactions. The Customer’s sole recourse in respect of Relopay Card transactions lies against the Issuer under the Cardholder Agreement.

    11. All Relopay Card transactions are final and may not be disputed, reversed, or cancelled, except where expressly provided by the Issuer under the Cardholder Agreement or applicable law.

    12. The Customer may download the electronic reporting documents on the executed transactions for any period of time at his/her own discretion in his/her Account.

    13. Any disputes regarding goods or services purchased with the Relopay Card are solely between the Customer and the merchant. Relopay shall not be liable for chargebacks, reversals, or refunds. The Customer’s sole recourse shall be against the merchant or the Issuer under the Cardholder Agreement.

    14. Relopay and the Issuer may decline, suspend, or reverse any transaction where required to comply with applicable laws, regulations, or sanctions regimes. The Customer acknowledges that Relopay and the Issuer are not liable for losses arising from such compliance measures.

  10. Rates and Procedures for Charging Fees

    1. The Relopay shall charge the Fees for the Services provided to the Customer.

    2. The amount and procedures for charging the Fees are available on the Website or in Application.

    3. The Relopay may unilaterally change the Fees rates. Such changes and amendments shall come into effect from the day that such changes and amendments are published on the Website/Application.

    4. All Fees are calculated in the currency of Transaction and rounded off to the nearest whole cents.

    5. The System Services provided to the Customer by the Relopay are not subject to VAT or any other turnover taxes.

    6. All the applicable Fees are charged from the Customer’s Wallet by the Relopay upon the completion of a Transaction subject to the Fees, or at the moment when the Relopay has substantiated grounds to charge the applicable Fees.

    7. If the current balance on the Wallet is not sufficient to charge the applicable Fees, the Relopay may reject the Transaction and request the Customer to pay the applicable Fees.

  11. Personal Data

    1. Privacy Policy applicable for the Applicants and the Customers is available on the Website as a separate document.

  12. Liability

    1. In the event of failure to comply and/or improper fulfilment of the obligations under these Terms and Conditions, the Parties shall be responsible in accordance with the provisions of these Terms and Conditions, the Internal Policies, and the applicable laws.

    2. If the Customer delays the fulfilment of any obligation in the monetary form as set forth in these Terms and Conditions, the Customer shall pay to the Relopay a penalty fine in the amount of 0.1% (one tenth of a percentage point) of the amount of such delayed funds to be transferred to the Relopay for every day of such delay. The Customer shall pay to the Relopay the penalty fine as specified in this Clause of the Terms and Conditions within 3 (three) business days after the date the Customer receives a relevant request from the Relopay in writing or electronically. The Relopay has the right, but not the obligation to send a penalty fine payment request.

    3. The Customer shall repay to the Relopay the damages incurred as a result of any damages charged from the Relopay due to the Customer’s violations of the applicable laws when using the System on condition that the Relopay can provide the relevant documents that confirm the amount of the damages incurred by the Relopay.

    4. The Customer shall be responsible for all Transactions accounted for in the Wallet, including any Transactions with the use of bank payment cards. These Transactions shall also include the Transactions executed by the third parties that have access to the Customer’s Wallet.

    5. The Customer shall take full responsibility to get acknowledged with the current legislation of the Customer’s residence, regulating the Account opening and money transfer Transactions via the System. The Relopay shall not be liable for any breach of the national laws by the Customer resulting from the use of the System. If a Customer’s use of the System and Services contradicts the laws of this Customer’s jurisdiction, such Customer should immediately stop using the Services.

    6. The Customer shall take full responsibility for all the risks related to the use of the Internet during a Customer’s interaction with the Relopay, other Customers and third parties.

    7. The Customer shall not undertake any activity that misleads other parties about services offered by the Relopay, which can directly or indirectly damage the Relopay’s reputation, including but not limited to impersonating themselves as representatives of the Relopay in any way or context, providing false data related to the System including but not limited to falsifying transaction IDs, wallet IDs and any other data. as text, screenshots, or any other media, creating clones of the Relopay’s website, and other similar activities. In case of violation the Relopay reserves the right to suspend the Customer’s Accounts, freeze funds for the period of investigation, and limit the usage of the System in other ways. The Relopay also reserves the right to pursue legal action in courts of applicable jurisdiction, including cases when this rule is violated by other parties that are not the Customers of the Relopay.

    8. The Customer shall protect the Relopay’s interests, reimburse the Relopay’s losses and pay compensations to the Relopay as well as indemnify the Relopay and his affiliates against any claims or damages, costs or expenses (including expenses for legal support, penalties or forfeits) resulting from violation by the Customer of these Terms and Conditions or any applicable laws or regulations and (or) use of the System. This provision shall survive termination of relations between the Parties.

    9. If, through the Customer’s fault, a completed Payment serves as a ground for a payer to file a claim to the Relopay for protection of his violated right, the Relopay may demand that the recipient of the Funds reimburses losses resulting from collection of funds or other property from the Relopay to the benefit of the payer.

  13. Disclaimer

    1. To become a CustThe Relopay shall have no responsibility to the Customer in the event of:omer and use the System Services, an Applicant has to create the Account in accordance with the procedures described herein.

      1. The Customer transfers his/her data to any third parties, deliberate provision of access to his/her Account in the System, or any other violation of the confidentiality of a Customer’s information caused by the Customer’s fault;

      2. Illegal activities of any third parties, including those related to the use of the Customer’s registration data and a Customer’s email or the Authorization Details;

      3. Presence of any viruses or any other malicious software in the hardware and software used by the Customer to access the System;

      4. Any disputes pertaining to any transactions between the Customers made via the System;

      5. For violation of the current legislation by the Customer in relation to the use of the System as well as for the complaints pertaining to the Customer from tax, regulation, and law enforcement authorities regarding any reporting documentation or taxation in relation to the Customer’s transactions involving the System;

      6. If the Customer does not have access to software or hardware that ensure the use of the System;

      7. If the Customer cannot be reached by using the Contact Details filed thereby, particularly, due to the reason that the Customer filed unreliable data or fails to update such data in a timely manner;

      8. For any payment services provided to the Customer by third parties;

      9. For any actions taken by third parties whose websites the Customer visited following a link or information provided on the Website or in Application;

      10. For temporary inoperability of the System, malfunctioning and errors in the operation of hardware or software (including disconnection or damage of electricity supply and communication networks, software malfunctioning, interruption of mail services, Internet provider’s, payment system operations, disruption in other lines, channels and(or) networks that are provided, offered or serviced by third parties, etc.), occurred not through the Relopay’s fault; in this case, the Relopay shall not bear responsibility for Customer’s possible losses.

    2. The Relopay shall not be liable if the Customer cannot recover access to their Account due to lack of access to their registered email, mobile number, or two-factor authentication (2FA) devices.

    3. The Relopay shall not be responsible for any damages and losses incurred by a Customer or by any third party as a result of:

      1. Suspension of Account in accordance with these Terms and Conditions or the requirements of the law;

      2. Failure to pass the Verification;

      3. Incorrect completion of Payment Orders to carry out the Transactions or completion by mistake;

      4. Violation by the Customer of the established procedure for making Payments;

      5. Relopay’s or third parties’ compliance with the legislative or regulative requirements;

      6. Failure to read the up-to-date version of the Terms and Conditions or the Internal Policies and other information published at the Website;

      7. Impossibility to use a desired payment method at the Customer’s location;

      8. Violation by the Customer of these Terms and Conditions or Internal Policies, as well as the Relopay’s instructions and guidelines.

    4. In any event, the Relopay’s responsibility to a Customer shall always be limited to the amount that does not exceed the amount of the Fees charged to such Customer for a period of the previous 3 months.

    5. The Relopay shall not be responsible for any indirect or consequential damages incurred by the Customer or any third parties, including any loss of profit, loss (forfeit, non-receipt, unsubstantiated spending) of revenue, income, contracts, customers, time, data, enterprise, or reputation.

    6. The Relopay shall provide to the Customer Services “as is” as at the moment, without any express, implied or statutory representations or guarantees.

  14. Communication Between The Parties

    1. The Relopay shall use the Contact Details as a means of communication with the Customer.

    2. Communication between the Customer and the Relopay is carried out in English.

    3. The Customer may contact the Relopay at any time using the support team chat available on the Website, or by the email support@relopay.io.

    4. The Relopay may inform the Customer on the changes in the Services provided either by sending the email notifications or by posting the updates on the Website/Application.

    5. The document flow between the Customer and Relopay shall be in electronic form via the System with use of the Customer’s Account. Moreover, the use of the Authorization Details by the Customer shall be deemed by the Parties due and sufficient method of the Customer Authentication for the purposes of the document flow as well as for confirmation of authenticity and integrity of the provided electronic document, except for the cases provided for by the Terms and Conditions or the Internal Policies. Entering the Customer’s Authenticated Data shall be deemed by the Parties equal to the Customer’s handwritten signature.

  15. Suspension of Account

    1. The Relopay, at its discretion, has a right to unilaterally and without a prior notification of the Customer apply Suspension of Account in the following events:

      1. Objectively justified reasons relating to the security of the Account;

      2. Suspicion of unauthorized or fraudulent use of the Account;

      3. The activities of the Customer are deemed suspicious or controversial to the Terms and Conditions, other agreements concluded between the Customer and the Relopay, Internal Policies or the requirements of current legislation;

      4. The Account is subject to a governmental proceeding, criminal investigation or other pending litigation;

      5. the Customer fails to confirm that his documents and data are accurate, complete and up-to-date and/or provide additional documents or data upon request of the Relopay ;

      6. the Customer created multiple Accounts;

      7. the Customer’s Account is Dormant Account;

      8. Actions of the Customer can harm reputation of the Relopay or might cause losses or other negative consequences to the Relopay.

    2. Relopay reserves the right to suspend or terminate user accounts at its sole discretion, without prior notice, if a user is found to be in violation of our Terms of Service or any other guidelines established by Relopay. In such instances, users will forfeit any rights to refunds of fees or payments made to the platform. We strongly encourage users to regularly review our policies to ensure compliance and avoid potential account termination.

    3. The Relopay shall notify the Customer via email address indicated by the Customer in the System of the Suspension of Account unless notifying the Customer would be unlawful or the Relopay is at risk of a security threat.

    4. The Relopay shall lift the Suspension of Account as soon as practicable after the reasons for such suspension have ceased to exist.

    5. Suspension of Account or termination of the Terms and Conditions does not exempt the Customer from the execution of all responsibilities to the Relopay which have arisen till the suspension.

    6. Relopay shall not be liable to the Customer for Suspension of Account.

    7. The Relopay shall reserve the right to keep and use the transaction data or other information related to such suspended Accounts.

  16. Term and Termination

    1. Indefinite Term. These Terms and Conditions are concluded for an indefinite term and shall be in effect until terminated in accordance with the provisions stated below.

    2. The Customer is entitled to terminate relations, including concluded agreements with the Relopay by deleting the Account at his discretion at any time if the Customer does not have any unfulfilled obligations to the Relopay. The Account can be deleted in the relevant section of the Customer’s virtual profile.

    3. After the Customer initiates deletion of the Account, the execution of the Transactions with the use of the Account shall be impossible. Any monetary obligations of the Parties created prior to the date of deletion of the Account shall retain until they are fully executed.

    4. Relopay may unilaterally terminate these Terms and Conditions, sending the written notification to the Customer no later than two months in advance.

    5. The Relopay shall have the right to terminate these Terms and Conditions and delete the Account without prior notification in the following events:

      1. In case the Customer objects to the amendments of the Terms and Conditions by the Customer the Terms and Conditions shall be terminated on the date the amendments enter into force;

      2. At the expiry of the period for three years from the date of the Suspension of Account.

    6. In case any funds remain on the Account of the Customer with whom the Terms and Conditions are terminated, the Customer shall withdraw the remaining funds within a reasonable period of time deducting the applicable fees by indicating the payment details to the Relopay.

    7. Should the Account be terminated (deleted), the account and transactional information that meet data retention standards will be securely stored for 5 years in accordance with the requirements of the law.

  17. Unclaimed Funds

    1. Any unclaimed funds will be held by the Relopay for a period of 3 years from the date of the Suspension of Account and\or termination of the Account, at the expiry of which time, the Customer will be deemed to have waived any claim in respect of such funds. The Customer hereby agrees that upon expiry of such period, the Relopay will be relieved of any further obligation to pay those unclaimed funds to the Customer.

  18. Amendments

    1. The Relopay may unilaterally amend these Terms and Conditions by publishing the updated text on the Website.

    2. The Relopay shall notify the Customer on the upcoming amendments to these Terms and Conditions by posting an informational message inside the Client's Account no later than 2 (two) months before such amendments come into force. The Customer shall either accept or reject the amendments before the date of their proposed date of entry into force. The Customer shall notify the Relopay on objection to the amendments via contacting the support team. In case the Customer objects to the amendments, the Terms and Conditions shall be terminated on the date the amendments enter into force.

    3. The amendments come in force since the amended version of the Terms and Conditions is published on the Website or on the date the corresponding amended version enters into force if it is directly stated on the Website.

    4. The use of the Services by the Customer shall be considered as the unconditional acceptance of the updated Terms and Conditions.

    5. Any Exhibits to the Terms and Conditions shall constitute the integral part of these Terms and Conditions.

    6. Without limitations to the provisions stated in this Section, the period stated in Clause 18.2. does not cover the notification timeframe to any amendments of the Fees applicable to the Services provided by the Company. The Fees changes may be applied immediately and without prior notice.

  19. Force Majeure

    1. The Parties shall not be responsible for any delays in the performance or non-performance of the obligations, any expenses, including losses, and costs related to complaints by any third parties that may result from any due to any acts of God, acts of civil or military authorities, civil disturbances, strikes or other labour disputes, fires, transportation contingencies, interruptions in telecommunications, utility, Internet services or network Provider services, acts or omissions of a third party, infiltration or disruption of the services by a third party by any means, including without limitation, DDoS attacks, software viruses, Trojan horses, worms, time bombs or any other software program or technology designed to disrupt or delay the Services (each a “Force Majeure Event”). The Party experiencing the impact of any Force Majeure Event shall notify the other Party within 10 days after the commencement of such Force Majeure Event.

    2. The provisions of Clause 19.1. shall not limit or terminate the Customer’s obligations pertaining to making the returning Payments, as well as payment of any fines, penalties, fees, Commissions, returning any goods, or (not) performing any works or services after the Force Majeure is over.

  20. Miscellaneous

    1. These Terms and Conditions and the relations between the Relopay and the Customer arising from them are governed by the laws of Canada.

    2. All the disputes between the Parties arising from these Terms and Conditions shall be settled through negotiations. The basis for negotiations shall be either Party submitting a written complaint to the other Party. All Complaints and claims shall be reviewed within thirty days of their receipt.

    3. In case a dispute cannot be resolved by negotiations within the specified period of time, either Party may apply to a court. The courts of Canada shall have the jurisdiction to settle any dispute arising out of or in connection with these Terms and Conditions.

    4. The choice of law and jurisdiction in Clause 16.3. does not affect the mandatory rights of the Customer under the laws of the country of his residence.

    5. A Customer shall not transfer any rights or obligations under these Terms and Conditions to any third party without the prior written consent given by the Relopay.

    6. If any provision of these Terms and Conditions is held to be invalid or unenforceable, such provision shall be struck out and the remaining provisions shall be enforced.

    7. These Terms and Conditions enter into force once the Applicant successfully completes the Registration process.

    8. The Customer acknowledges and confirms that all the provisions of the Terms and Conditions are clear, and that the Customer agrees with the Internal Policies available on the Website, accepts them unconditionally and shall comply with its provisions and requirements.

EXHIBIT 1

Goods, Works, and Services Prohibited for Sale via the System:

  1. Weapons, arms, ammunition and defence products, guns, replicas of firearms or cold steel weapons.

  2. Drugs, drug-like substances and plants (including marijuana/cannabis), as well as their ingredients, or any substances for their production, as well as descriptions of methods for producing such substances.

  3. Medical drugs and medications dispensed on prescription only, as well as raw materials or instructions for their production.

  4. State awards or distinguishing badges.

  5. Identification documents and government issued documents (including falsified documents), and everything connected with creating or obtaining false identification documents or counterfeit government issued documents. Government agencies’ uniforms.

  6. Specialty items related to the police and law enforcement agencies.

  7. Electronic equipment prohibited for use in this country or region.

  8. Devices used for hacking and tampering with locks.

  9. Information containing personal data or data suitable for undertaking illegal activities (spam emails, etc.).

  10. GWS or information containing state, banking, or trade secrets.

  11. GWS whose sale violates any third parties’ copyright and/or related rights, trademark rights, or patents.

  12. Information that violates a person’s privacy, infringing upon the honour, dignity and business reputation of individuals and legal entities.

  13. Information transmitted exclusively virtually and not recorded on any material carrier (ideas, methods, principles, etc.).

  14. Archaeological heritage items.

  15. Precious metals.

  16. Items or services that violate the norms of public morality (including, but not limited to, child pornography, Nazi memorabilia items, escort services, prostitution, and adult).

  17. Any items with available initially but removed serial numbers

  18. Internet gambling.

  19. Malicious software.

  20. Goods or services directly or indirectly compelling illegal actions (promoting social, racial, religious, or ethnic strife; discrimination, violence, hatred, revenge, harassment; containing propaganda of terror or physical harm).

  21. Perishable goods.

  22. Fake or counterfeit goods.

  23. Items and equipment intended for use (including illegal transfer) of copyright protected items without the permission of the authors (including, but not limited to, components designed to remove copyright protection or regional restrictions, or software elements of electronic devices).

  24. Dangerous goods (including, but not limited to, those that contain explosive, toxic, poisonous, and/or radioactive materials).

  25. Information about the production of explosive, pyrotechnic, incendiary, and other similar substances and devices.

  26. Human organs and human remains.

  27. Goods or services that have no value in use.

  28. Services of auctions or trading systems that allow carrying out activities excluding transfer of GWS that have value in use.

  29. Financial or payment instruments whose accounting systems do not ensure proper identification of the owner for the purpose of combating illegal trade, financial fraud, and money laundering of funds obtained by illegal means.

  30. Asset management and investment services provided by unlicensed businesses, as well as any intermediary activity that facilitates the transfer of funds between the parties entering into a transaction forbidden herein.

  31. Items of artistic and historical value that constitute a country’s cultural values.

  32. Services of organizers and operators of lotteries, betting, casinos and any other types of gambling.

  33. Services of advertising (promoting) goods, works and services specified in items 1-33 of this list.