TERMS OF SERVICE FOR BILL PAYMENT SERVICE

Last Updated: March 14, 2025

These Terms of Service for the bill payment service (hereinafter referred to as the "Terms") constitute a legally binding agreement between the registered User and Changebox Limited, incorporated in BVI , company number 2171550 (hereinafter referred to as the "Operator" or "we") regarding the use of Virtual Assets on behalf of the User for the purpose of paying bills to third parties (hereinafter referred to as the "Service").

The Service is available exclusively to registered and verified Users of the Platform.

By using the Service, you confirm that you have read and understood these Terms in their entirety and unconditionally accept all provisions thereof.

If you disagree with any provision of this document, you must immediately cease using the Platform in relation to the Service.

We reserve the right to unilaterally amend these Terms at any time. Such amendments and revisions shall take effect upon publication of the revised Terms on the Platform, but shall not apply to payment requests already processed and for which the User's Virtual Assets have been blocked.

Continued use of the Service after any amendments to these Terms shall signify your unconditional acceptance of the revised Terms.

These Terms are an integral part of the General Terms of Service of the ChangeBox Platform (hereinafter referred to as the "General Terms"). In matters not regulated by these Terms, the relationship between Users and the Operator concerning the use of the Service shall be governed by the General Terms.

1. Definitions

1.1. The following terms shall have the following meanings in this document:

• Virtual Asset: A set of data in electronic-digital form that has value and serves as a digital representation of property and/or non-property rights, created, stored, and circulated using distributed ledger technology.

• Monetary Funds: Any funds in the national currency of the British Virgin Islands and/or in a foreign currency permitted for circulation and use in accordance with applicable law.

• Platform: The aggregate of information, web forms, software and hardware, and intellectual property, access to which is provided to the User via a device using web browser software via the domain (or subdomain, if the domain name has a corresponding sign) name: changebox.io (equal to https://changebox.io, with/without the abbreviation "www"), the exclusive rights and/or the right to use which belong to the Operator.

• User: An individual or legal entity that has registered an Account on the Platform.

• Operator/Agent: Changebox Limited, registered in the British Virgin Islands, operating the Platform and providing the Service.

• Service: The organization, on behalf of the User, of payments for bills submitted by the User through the crediting of the corresponding amount of Virtual Assets in the User's Account for the payment of such bills to third parties outside the British Virgin Islands in the prescribed manner.

• Account: A set of data unique to each User containing information about the User and their use of the Platform's functionality, including the Service (if applicable), access to which is provided to the User through the Platform interface upon provision of valid access data specified by them during registration.

• Subagent: A legal entity engaged for the provision of the Service to process payments on behalf of the User.

• Individuals and Entities Subject to Economic Sanctions: Individuals and legal entities, as well as other organizations that are included in the sanctions lists of the governmental bodies of the European Union, member states of the European Union, the United States of America, the United Nations, or other international organizations that restrict their financial activities, access to markets, or other aspects of business operations. Such entities may include, but are not limited to, organizations involved in terrorism, money laundering, illegal arms trade, human rights abuses, or other types of criminal activity that violate international law.

1.2. Terms and definitions not defined in this section shall have the meaning assigned to them in the General Terms and their annexes, links to the current versions of which are provided in this document, unless a different interpretation is provided for by this document, and, as a last resort, by their generally accepted meaning.

2. Service Usage Procedure

2.1. Access to the Service is granted exclusively to registered and successfully verified Users who have met all requirements established by the Operator, including but not limited to the provision of accurate and up-to-date registration data and compliance with all applicable rules and policies of the Platform.

2.2. To submit an application for bill payment under the Service, the User must perform the following actions:

(a) Log into their Account using the access data specified during registration;

(b) Provide the invoice (bill) to be paid and complete and accurate data required for payment processing, including but not limited to:

(i) Payee details (name, address, bank details, or other identifiers);

(ii) Purpose of payment, including a description of goods, services, or other obligations;

(iii) Payment currency and exact amount;

(iv) Other data indicated by the Operator in the Platform interface as mandatory if such data is not present in the invoice provided by the User;

(c) Ensure that there are sufficient Virtual Assets in their Account to execute the requested transaction, including covering all applicable fees and commissions;

(d) Confirm their agreement with the current tariffs, fees, and commissions accessible to the User in the Platform interface.

2.3. Upon receipt of the User's payment request, the Operator shall take the following steps:

(a) Verify the completeness and accuracy of the data provided by the User, and compliance with all conditions for transaction execution;

(b) At its discretion, the Operator may request additional documents, data, or clarifications from the User necessary to ensure the legality and security of transaction execution;

(c) Notify the User of any additional transaction terms, including, but not limited to, information about the Subagent, applicable fees and commissions, and the estimated amount of bank fees that are non-refundable.

2.4. After performing the actions described above and receiving the User's consent to the applicable additional terms for providing the Service in relation to a specific invoice, the Operator shall accept the Service request and block the amount of Virtual Assets in the User's Account necessary to execute the transaction, including the amount of Monetary Funds specified in the invoice, the applicable fees of the Operator, Subagent, banks, and payment systems.

2.5. When calculating the blocked amount of Virtual Assets required for Service execution, the Operator uses the exchange rate between Virtual Assets and Monetary Funds (hereinafter the "Rate"), which is determined based on data provided by authorized market sources (e.g., cryptocurrency exchanges or other official providers). The Rate applied to calculate the blocked amount is fixed at the time the User submits their application for the Service or at the time the Operator confirms the application, if required under these Terms.

2.6. If the Rate fluctuates by more than 1% between the time of application submission and confirmation by the Operator, the Operator may notify the User of the need to update the blocked amount and suspend processing of the application until the User agrees to the new terms.

2.7. After the Operator has accepted the Service request and blocked the required amount of Virtual Assets in the User's Account, the Operator transmits instructions to the Subagent to transfer Monetary Funds according to the details provided by the User through the Platform.

2.8. Upon receipt of confirmation of funds transfer from the Subagent's bank in accordance with the User's provided details, the Operator transfers the blocked Virtual Assets, less the part corresponding to the Operator's commission for providing the Service, from the User's Account to the Subagent and updates the payment request status on the Platform, completing the request.

2.9. By confirming the payment request, the User provides the Operator with an irrevocable instruction to transfer and/or sell Virtual Assets from their Account for the purposes of making the payment specified in the Service application.

2.10. The User confirms that they bear full responsibility for the accuracy and reliability of the provided data. If the Operator identifies inaccurate or incomplete information, the User must provide clarifications and accurate data, and compensate the Operator for all losses incurred, including but not limited to fines, penalties, and direct or indirect damages.

2.11. Transaction completion is confirmed by a corresponding notification displayed in the Platform interface. The Operator’s obligations are considered fully fulfilled upon receipt by the Operator from the Subagent of documentation confirming the Subagent's instruction to its bank to execute the transfer according to the details provided by the User via the Platform.

2.12. The Operator shall not be liable for transaction delays caused by the rules for processing transactions by the banks and payment systems involved in processing the payment under the Service.

3. Grounds for Service Denial

3.1. The Operator reserves the right to refuse to provide the Service or suspend its provision in the following cases:

(a) Absence of a Subagent capable of processing the payment;

(b) The User has not passed or completed the Account verification procedure in accordance with the Operator's requirements;

(c) The data, documents, or information provided by the User are inaccurate, incomplete, contradictory, or misleading;

(d) The User has violated these Terms, the General Terms, or their annexes;

(e) The User's Account does not contain sufficient Virtual Assets to execute the requested transaction, including covering all applicable fees and commissions of banks, payment systems, and blockchain networks (if applicable due to the need to sell the User's Virtual Assets to provide the Service);

(f) The User's application contains technical or other errors that prevent its processing, or the data provided by the User does not meet the Operator's requirements;

(g) The User's actions may violate applicable law, regulations, or provisions applicable to transactions with Virtual Assets;

(h) The Operator has received requests, instructions, or other notifications from government bodies, banks, payment systems, or other authorized organizations ordering the refusal to process the transaction;

(i) The transaction application shows signs of suspicious or fraudulent activity, including attempts to circumvent procedures prescribed by anti-money laundering legislation and the financing of terrorism, as well as counter-terrorism financing and the proliferation of weapons of mass destruction or other compliance requirements;

(j) Suspicion of unauthorized access by third parties to the User's Account;

(k) The User has been previously blocked, access to the Service has been restricted, or the User is included in denial-of-service lists.

3.2. The Operator may suspend or refuse to provide the Service in the event of the following technical or organizational circumstances:

(a) Technical malfunction, failure, or other disruption of the Platform that prevents processing of User applications;

(b) Problems on the part of third parties involved in transaction processing, including banks, payment systems, or other service providers;

(c) Force majeure circumstances that prevent the provision of the Service, including but not limited to natural disasters, war, epidemics, actions of governmental bodies, or other emergencies.

3.3. In case of refusal to provide the Service, the Operator shall notify the User thereof via the Platform, and by any other method considered acceptable by the General Terms. The Operator shall indicate the reason for refusal to process the application to the extent that it does not conflict with applicable law or internal compliance procedures, and, if possible, provide the User with a reasonable time to remedy the reasons for refusal.

3.4. The Operator reserves the right to reconsider its decision to refuse to provide the Service if the User remedies the identified grounds for refusal and provides additional documents, information, or explanations requested by the Operator.

3.5. If the User does not respond within the period specified by the Operator, refuses to provide the requested explanations or information, the Operator shall close the application, unblock the Virtual Assets in the User's Account less any bank and payment system fees, and blockchain network fees (if applicable in connection with the need to sell the User's Virtual Assets to provide the Service), if such commissions have already been incurred at the time the application is cancelled.

3.6. Users acknowledge and agree that the Operator shall not be liable for damages caused by the refusal to provide the Service if such refusal is based on the provisions of these Terms, applicable law, or is caused by the actions of third parties.

4. Terms of Service Use

4.1. To use the Service, the User must be registered on the Platform and have their Account verified in accordance with the procedures established by the Operator.

4.2. The User undertakes to provide accurate data for the use of the Service. If the provided data changes, the User must promptly notify the Operator through the Platform interface.

4.3. The Operator reserves the right to refuse to provide the Service to the User if their actions or the data provided contradict the requirements of the law or these Terms, as well as the General Terms governing the use of the Platform.

4.4. The User is responsible for the legality of the purpose of payment transactions using the Service.

5. Withdrawal of Service Application

5.1. The User has the right to withdraw their application for the Service until the moment it is processed by the Operator. The application is considered processed if the User has received notification from the Operator that the application has been accepted for execution.

5.2. The Operator may, at its discretion, agree to the requested withdrawal submitted by the User after the processing of the application has begun, with the deduction of its commission and applicable commissions of the Subagent, banks, payment systems, and blockchain networks. The application cannot be withdrawn after the Service has been provided.

5.3. The User further acknowledges that in cases where it is necessary to sell Virtual Assets as part of the Service, the withdrawal of the application after processing has begun may be impossible due to the irreversibility of transactions in blockchain networks.

5.4. To withdraw an application, the User must send a withdrawal notification via the Platform interface and ensure that the notification is received by the Operator before processing of the application begins.

5.5. In case of successful application withdrawal, the Operator shall unblock the Virtual Assets in the User's Account intended for Service provision, less the commissions of banks, payment systems, and/or blockchain networks (if such expenses have already been incurred).

5.6. If, at the time the withdrawal request is submitted, the Operator has already begun processing the application, the User agrees that a refund may be impossible or may involve additional costs borne by the User. In any case, the Operator acknowledges that all commissions of the Subagent, bank, payment systems, and blockchain networks already paid in connection with the execution of the application are non-refundable.

6. Applicable Fees and Commissions

6.1. The following types of fees and commissions may apply when the Service is provided:

(a) Operator's commissions - a fee for using the Platform's functionality and organizing the process of providing the Service;

(b) Subagent's commissions - remuneration for actions performed on behalf of the User in the framework of providing the Service;

(c) Bank and payment system commissions - fees charged by financial institutions and payment service providers involved in the transaction processing;

(d) Blockchain network commissions - fees for executing transactions in blockchain networks, if applicable due to the need to sell the User's Virtual Assets for Service provision.

6.2. By confirming the terms of application execution for the Service provided by the Operator through the Platform interface, the User agrees to the established commissions and fees, recognizing them as fair and reasonable.

6.3. The User acknowledges and agrees that the indicated commissions may be withheld at the Operator's discretion by debiting the corresponding amount of Virtual Assets from their Account, from the Monetary Funds received as a result of the conversion of Virtual Assets for transaction execution, or by issuing a separate invoice from the Operator.

6.4. Before executing the transaction, the Operator provides the User with information on the approximate amount of applicable commissions and fees through the Platform interface. The User must familiarize themselves with this information and confirm their consent before the transaction is processed. The User understands that the commissions of banks, payment systems, and blockchain networks are outside the Operator's control.

6.5. Refunds of commissions paid by banks, payment systems, blockchain networks, and Subagents are not possible. The User acknowledges that they are obliged to take into account and accept possible expenses associated with the payment of commissions to third parties, and bears responsibility for their payment. The Operator reserves the right to deduct all expenses for the specified commissions associated with the provision of the Service from the Virtual Assets/Monetary Funds returned to the User's disposal.

6.6. The Operator has the right to change tariffs for its services and publish updated tariffs on the Platform. New tariffs shall take effect from the moment of their publication, unless otherwise indicated by the Operator. The User agrees that transactions initiated after the publication of changes shall be carried out by the Operator with the collection of commissions calculated according to the updated tariffs.

6.7. The Operator charges commissions and fees for providing the Service, the amount of which is determined based on the current tariffs published on the Platform. The User agrees that the use of the Service implies an obligation to pay such commissions, which are calculated and charged in accordance with these Terms and the published tariffs.

7. Limitations on Service Use

7.1. The Operator sets minimum and maximum transaction amounts applicable within the framework of Service provision and places the corresponding information on the Platform. Users confirm that these limits may change based on the requirements of banks and payment systems involved in the transaction processing. The Operator reserves the right to change the limits at any time by updating the information on the Platform. New limits shall apply to applications submitted by Users after their publication.

7.2. If the provision of the Service under previously established limits becomes impossible due to the requirements of the Subagent or payment systems, the Operator shall notify the User and offer new terms, including, but not limited to, changes to the Subagent, currency, or transaction amount. If the User refuses the new terms, the transaction shall be closed, and the Virtual Assets shall be unblocked less the actually paid commissions of the banks and payment systems, as well as blockchain networks (if applicable due to the need to sell the User's Virtual Assets for Service execution).

7.3. The Operator expressly prohibits the use of the Service for transactions related to payments in favor of countries included in the black or grey lists of the Financial Action Task Force (FATF), as well as in the sanctions lists of the United Nations (UN), the European Union (EU), or the United States of America (USA).

7.4. If, after the application is accepted, the country of destination of the payment or the servicing bank falls under the aforementioned lists, the Operator shall have the right to cancel the corresponding application and notify the User accordingly. In this case, the Virtual Assets associated with this application shall be unblocked less the actually incurred expenses, including bank and payment system commissions.

7.5. If the transaction was initiated by the Subagent's bank, but the transaction amount was blocked by the bank or another financial institution involved in processing the payment, execution of the application shall be suspended until the moment the funds are unblocked or returned to the Subagent's account. If the funds are returned, the application is subject to closure, and the Virtual Assets are unblocked for withdrawal by the User, less the commissions deducted by the banks and payment systems, and blockchain networks (if applicable due to the need to sell the User's Virtual Assets to provide the Service). If the funds have been credited to the recipient's account, the Operator shall complete the execution of the application by transferring to the Subagent either Virtual Assets or an equivalent amount in Monetary Funds.

7.6. By confirming the terms of application execution under the Service, Users understand and agree to the risk associated with the possible blocking of payments due to sanctions imposed on the recipient country or bank. The Operator is not liable for losses resulting from such blockages if they occurred due to the reasons specified above.

7.7. The Operator prohibits the use of the Service for payments associated with Individuals and Entities Subject to Economic Sanctions. The Operator reserves the right to suspend or reject an application for the use of the Service at any time if it becomes clear that the payment recipient is an Individual and Entity Subject to Economic Sanctions, regardless of when and where this information was obtained. In the event of such suspension or rejection of the application, the Operator undertakes to notify the User within a reasonable time and unblock the Virtual Assets in the User's Account less the commissions of banks and payment systems, as well as blockchain networks (if applicable due to the need to sell the User's Virtual Assets to provide the Service), already incurred during the stages of execution that have already been performed. By submitting an application for the use of the Service, the User confirms that they understand all the risks associated with the risk of applying economic sanctions to the payment recipient, and agrees that the Operator is not liable for losses that may arise if the transaction is rejected or delayed due to the application of economic sanctions.

7.8. The Service is provided exclusively for the purpose of paying bills to third parties outside the British Virgin Islands. This restriction is introduced in order to comply with legal requirements, including international rules governing financial and payment transactions. The Operator has the right to update or change this restriction at any time in the event of changes in the relevant international or local legal norms, as well as in the event of the emergence of other factors affecting the security and legality of transactions. Updates to these conditions will be reflected on the Platform, and they will unconditionally apply to all applications for the use of the Service submitted after their publication, and if necessary, even before the publication of the update on the Platform. If an application for the use of the Service was submitted for the payment of an invoice in favor of a recipient located in the British Virgin Islands, the Operator may reject such an application. If the application was accepted, but it later became clear that the payment is made in favor of a recipient within the British Virgin Islands, the Operator shall have the right to suspend or cancel the execution of the transaction and unblock the Virtual Assets less the incurred expenses and commissions of banks and payment systems, and blockchain networks (if applicable due to the need to sell the User's Virtual Assets for Service provision).

8. Suspension of Access to the Service

8.1. The Operator reserves the right to temporarily suspend the provision of the Service without prior notice to the User if the Operator has reasonable suspicions that the Service is being used for suspicious or illegal activities. Such activities shall include, but are not limited to, money laundering, terrorist financing, fraud, sanctions evasion, violations of personal data protection legislation, or other actions that violate applicable law.

8.2. In the event of a suspension of the provision of the Service, the Operator shall notify the User of the reasons for such action within a reasonable time, unless this contradicts the requirements of the law or internal compliance procedures. The Operator may request additional documents or explanations from the User to confirm the legality of the use of the Service.

9. Limitation of Liability

9.1. The Operator shall not be liable for any delays, disruptions, or restrictions in the operation of the Service caused by technical malfunctions, including, but not limited to, failures in the operation of servers, equipment, software, network systems, or other infrastructure components. The Operator shall also be relieved of liability for disruptions in the operation of the Service caused by force majeure circumstances, such as natural disasters, military actions, acts of terrorism, mass unrest, acts of government bodies, epidemics, or pandemics, power outages, as well as any other circumstances beyond the reasonable control of the Operator.

9.2. The Operator shall not be liable for any losses, damages, lost profits, or other negative consequences incurred by the User as a result of violation of these Terms. The User assumes all risks associated with the use of the Service in violation of these Terms, applicable law, or instructions posted on the Platform.

9.3. The Operator shall not be liable for the actions or inaction of third parties involved in the provision of the Service, including banks, payment systems, communications service providers, software and equipment suppliers, and any other parties on which the operation of the Service may depend.

9.4. Under no circumstances shall the Operator's aggregate liability for losses associated with the use of the Service exceed the amount of commissions paid by the User for the use of the Service under a specific application that caused the losses.

9.5. The User acknowledges that the use of the Service involves certain risks, including, but not limited to, transaction processing delays, possible blocking of monetary funds or Virtual Assets, changes in legislation, and technical failures. The User undertakes to take reasonable measures to minimize such risks and agrees that the Operator shall not be liable for the consequences caused by these risks.

10. Confidentiality and Data Protection

10.1. The User agrees to the processing of their personal data by the Operator within the framework of providing the Service and interacting with the Platform in accordance with the terms of the Personal Data Processing Policy.

10.2. The Operator undertakes to ensure the confidentiality of User data in accordance with the Personal Data Processing Policy and applicable data protection legislation.

10.3. The User confirms their awareness and consent that all transactions using Virtual Assets are recorded in the distributed ledger system, which may include the disclosure of data within the framework of legal requirements.

11. Governing Law and Dispute Resolution

11.1. These Terms, as well as any relationship between the User and the Operator arising in connection with the provision of Services and the use of the Platform, shall be governed by the laws of the British Virgin Islands.

11.2. Any disputes, disagreements, or claims related to the use of the Platform, provision of Services, or performance of these Terms shall be resolved exclusively in the court at the place of the Operator's registration, unless otherwise provided by law.

11.3. Before filing a lawsuit, Users are obligated to attempt pre-trial settlement of the dispute by sending a written complaint to the Operator. The deadline for considering the complaint is 30 (thirty) calendar days from the date of its receipt.

12. Other Provisions

12.1. If any provision of these Terms is found to be invalid, illegal, or unenforceable under applicable law, the remaining provisions of the Terms remain in full force and effect as if the invalid provision had not been included in the Terms.

12.2. These Terms are drawn up in Russian and, if necessary, other languages. Full versions of the Terms are published on the Platform. In case of any discrepancies or contradictions between the translated versions and the original version in Russian, the latter shall prevail in the resolution of disputes and interpretation of provisions.

12.3. To resolve issues related to the provision of the Service, Users can contact the Operator by using the Platform interface or by sending an email to the following email address: info@changebox.io.

12.4. The Operator reserves the right to make changes to these Terms at any time. Changes shall take effect from the moment of their publication on the Platform, unless otherwise indicated by the Operator. Continued use of the Service by the User after the publication of the updated Terms shall constitute agreement with the changes made.