TERMS OF SERVICE

1.1 About AceChange

These Terms of Service (“Terms”) govern your access to and use of the website AceChange.io and any widgets, tools, or services provided through it (collectively, the “Service”).

The Service is operated by m0ne s.r.o., a limited liability company incorporated in the Slovak Republic, with its registered office at Hlavná 47, 930 35 Michal na Ostrove, Slovakia (“AceChange”, “Exchanger”, “Provider”, “we”, “us”, or “our”).

Contact: info@acechange.io – Please specify the subject of your inquiry in the email subject line (e.g., “Legal”, “Support”, “Compliance”, “Privacy”, “Refund”, etc.) for faster processing.

1.2 Nature of Service – Non-Custodial Routing and Aggregation

AceChange is a non-custodial routing and aggregation service. We display rates and facilitate access to third-party providers such as cryptocurrency exchanges, brokers, liquidity platforms, and fiat on/off-ramp services (collectively, “Partner Services”).

Examples of our integration partners include:

• FixedFloat (ff.io) – for crypto-to-crypto exchanges
• Transak (transak.com) – for fiat-to-crypto and crypto-to-fiat transactions
• Swapped.com – for additional exchange options
• Other Partner Services as integrated from time to time

AceChange does NOT:

• Operate its own custodial wallet
• Hold client funds at any time
• Execute cryptocurrency trades directly
• Store or control your private keys
• Have the ability to cancel, recover, or reverse transactions

1.3 Contracting Parties

This Agreement for the Provision of Digital Asset Exchange Services is entered into between:

Service Provider: m0ne s.r.o., operating AceChange.io, a non-custodial cryptocurrency exchange routing and aggregation platform. The Exchanger facilitates access to the following Partner Services for transaction processing:

• FixedFloat (ff.io) – registered as FFX Group Ltd, Republic of the Marshall Islands
• Transak (transak.com) – regulated fiat-to-crypto service provider with licenses in the USA (FinCEN MSB), UK (FCA FRN: 928910), EU/Poland (VASP RDWW-498), Canada (FINTRAC), Australia (AUSTRAC 100865469)
• Swapped.com – additional exchange partner

and

Customer: a natural or legal person using the Service (hereinafter referred to as the “Customer”, “User”, “you” or “your”).

1.4 Relationship with Partner Services

AceChange enables you to:

• Access exchange rate data from Partner Services
• Initiate swaps or buy/sell crypto via Partner integrations
• Optionally request fiat cash-out where available (currently limited and experimental)

AceChange is NOT a counterparty to your transactions. We do NOT verify or guarantee:

• Availability or outcome of a Partner Service
• Correctness of exchange rates or limits
• Refunds, delivery, or regulatory compliance of Partners

1.5 Definition of Terms

For the purposes of these Terms of Service, the following terms shall have the following meanings:

1.6 Acceptance of Terms

By accessing or using the Service, you confirm that you have read, understood, and agree to be bound by these Terms and our Privacy Policy. If you do not agree, you must not use the Service.

If you use the Service on behalf of a company or entity, you confirm you have authority to bind it, and all references to “you” apply to that entity.

1.7 Hierarchy of Documents

In case of conflict between these Terms of Service and the terms of Partner Services, the stricter terms shall apply. The Customer is obliged to familiarize themselves with the terms of all relevant documents:

• FixedFloat Terms of Service: https://ff.io/terms-of-service
• FixedFloat Privacy Policy: https://ff.io/privacy-policy
• Transak Terms of Service: https://transak.com/terms-of-service
• Transak Privacy Policy: https://transak.com/privacy-policy
• Transak AML Policy: https://transak.com/group-bsl-asl-policy
• Swapped.com Terms: https://swapped.com/terms

2.1 General Order Creation Conditions

An order is considered validly created if all of the following conditions are met:

1. The order is created through the official online form with calculator on the AceChange.io website;
2. The Customer has provided all mandatory information required by the form;
3. The Customer has expressly agreed to these Terms of Service;
4. The system has automatically assigned a unique Order ID;
5. The Customer has received order confirmation at the provided email address.

2.2 Mandatory Information for Order Creation

• Valid email address – mandatory for order creation and communication
• Destination wallet address – the Customer is fully responsible for correctness
• Exchange direction – selection of source and destination cryptocurrency
• Exchange amount – within minimum and maximum limits
• Exchange rate type – choice between fixed rate and float rate
• MEMO/Destination Tag – for cryptocurrencies requiring this (XRP, XLM, EOS, BNB)

2.3 Registration and Identification

2.3.1 Crypto-to-crypto Exchanges (via FixedFloat)

2.3.2 Fiat-to-crypto and Crypto-to-fiat Exchanges (via Transak)

2.4 Customer Eligibility Requirements

By creating an order, the Customer confirms and warrants that:

1. They are at least 18 YEARS old or of legal age in their jurisdiction;
2. They have the right to enter into legally binding contracts;
3. They are not located in a prohibited jurisdiction (see Article 10);
4. They are not a sanctioned person;
5. The funds used for exchange come from legal sources;
6. All information provided is true, accurate, and complete;
7. They comply with all laws applicable to crypto services.

2.5 Limits for Fiat Transactions (Transak)

3.1 Types of Exchange Rates

AceChange.io offers two types of exchange rates for crypto-to-crypto exchanges:

3.1.1 Fixed Rate

With a fixed rate, the Partner Service undertakes to execute the exchange at the displayed rate, provided that ALL THREE conditions are met:

1. Time Condition: Transaction must appear in mempool/block WITHIN 10 MINUTES
2. Amount Condition: The EXACT AMOUNT specified must be sent
3. Volatility Condition: Market rate change must not exceed 1.2%

Fixed rate fee: 1% + blockchain network fee (included in displayed rate)

3.1.2 Float Rate

The rate is NOT fixed. The exchange rate is determined at the moment the Customer’s transaction reaches the required number of network confirmations. The final rate may differ (higher or lower) depending on market movements.

Float rate fee: 0.5% + blockchain network fee (included in displayed rate)

3.2 Rate Type Comparison

3.3 Fixed Rate Invalidation

A fixed rate is considered INVALIDATED if:

1. Transaction did not appear in mempool/block within 10 minutes
2. Amount sent differs from amount specified
3. Market rate change exceeded 1.2%
4. Funds sent to incorrect address or network
5. Third-party smart contract used to send funds

Upon invalidation, the Customer will be offered:

• Option A: Continue at current market rate
• Option B: Request refund (minus network fee)

4.1 Payment Time Limits

4.2 Non-Custodial Nature – Customer Responsibilities

You are fully responsible for:

• Wallet address accuracy – double-check all addresses before sending
• Device and key security – protect your private keys
• Understanding network risks and fees
• Sending the correct amount to the correct address on the correct network

4.3 Network Confirmations Required

4.4 Fiat Payment Processing Times (Transak)

4.5 Processing Times for Rule Violations

5.1 When Cryptocurrency is Sent

Cryptocurrency is sent to the Customer AUTOMATICALLY by the Partner Service after:

1. Transaction has reached required network confirmations
2. Amount corresponds to order specification
3. Transaction passed AML/KYT check
4. No suspicious circumstances identified

5.2 Standard Processing Times

5.3 Warranty Period

6.1 Subject Line Guide

6.2 Response Times

• During business hours: WITHIN 1 HOUR
• Outside business hours: within 24 hours
• Public complaints: within 24-48 hours

6.3 Partner Service Support

• FixedFloat support: support@fixedfloat.com
• FixedFloat AML/compliance: compliance@fixedfloat.com
• Transak support: available through their Help Center at transak.com

7.1 Definition of Force Majeure Events

Force majeure events include circumstances beyond control, which could not be foreseen or prevented:

• Strike, lockout, labor shortage
• Regulatory measures, changes in laws
• War events, armed conflicts, terrorist attacks
• Pandemics, epidemics, quarantine measures
• Natural disasters (fire, flood, earthquake)
• Cyber attacks, hacks, DDoS attacks
• Blockchain network outages
• Bank account blocking
• Significant market volatility (flash crash)

7.2 Erroneous Transfer by Customer

8.1 Data Controller

The data controller is m0ne s.r.o., Hlavná 47, 930 35 Michal na Ostrove, Slovakia. For data protection inquiries, contact: info@acechange.io (Subject: Privacy).

8.2 Legal Basis for Processing

• Regulation (EU) 2016/679 (GDPR)
• UK Data Protection Act 2018
• California Consumer Privacy Act (CCPA)
• Other applicable data protection regulations

8.3 Categories of Collected Data

Voluntarily Provided Data:

• Email address, name, residential address
• Phone number, date of birth
• Identity document numbers, SSN (US users via Transak)
• Bank account information (fiat transactions)

Automatically Collected Data:

• IP address, browser type, device information
• Geolocation data (country, region)
• Transaction data, wallet addresses, timestamps

8.4 Data Retention Period

8.5 Data Subject Rights (GDPR)

• Right of Access – obtain confirmation and copy of data
• Right to Rectification – request correction of inaccurate data
• Right to Erasure – request deletion (subject to legal obligations)
• Right to Portability – obtain data in structured format
• Right to Object – object to processing (including marketing)
• Right to Withdraw Consent – at any time

To exercise any rights, contact: info@acechange.io (Subject: Privacy)

9.1 Regulatory Compliance

AceChange.io and Partner Services comply with:

• FATF Recommendations
• OFAC Requirements and SDN List
• UN, EU, and UK Sanctions Regimes
• Bank Secrecy Act (BSA)
• EU Anti-Money Laundering Directives (AMLD)

9.2 KYC Requirements by Transaction Type

9.3 When Verification May Be Required

Verification may be required for crypto-to-crypto exchanges in these cases:

• Suspicion of connection to criminal activity
• Direct connection to sanctioned addresses
• Connection to high-risk services (mixers, tumblers)
• Third-party information (law enforcement, victim complaints)
• High transaction amounts
• Unusual behavior patterns
• Customers from risky jurisdictions

9.4 Consequences of Non-Cooperation

9.5 Prohibited Sources of Funds

• Unlicensed casinos and gambling
• Mixers and tumbler services
• Darknet marketplaces
• P2P platforms without AML/KYC
• Shell banks without physical presence
• Any suspicious or illegal sources

10.1 Prohibited Jurisdictions

Prohibited jurisdictions include: North Korea, Iran, Syria, Crimea, Cuba, Venezuela, Russia, and other countries subject to comprehensive sanctions.

10.2 Prohibited Uses of Service

The platform may not be used in connection with:

• Adult content and services
• Weapons and ammunition
• Unlicensed gambling
• Illegal substances and drugs
• Mixers and Tumbler services
• Multi-level marketing and pyramid schemes
• Terrorist financing
• Money laundering
• Sanctions evasion

11.1 Key Risks

• Risk of Total Capital Loss – Value may fall to zero without legal remedy
• No Consumer Protection – No access to FSCS, FOS, or EU Deposit Insurance
• Volatility Risk – Prices can fluctuate significantly within minutes
• Liquidity Risk – No guarantee assets can be easily sold
• Irreversibility – Transactions may be irreversible
• Technology Risk – Increased risk of hacks and cyber attacks
• Regulatory Risk – Laws may change adversely

11.2 No Financial Advice

12.1 Non-Custodial Service Disclaimer

12.2 “As Is” Service

THE PLATFORM AND SERVICES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, without any warranties of any kind. You assume all responsibility and risk in connection with using the services.

12.3 Maximum Liability

12.4 Exclusion of Damages

Neither m0ne s.r.o. nor Partner Services shall be liable for:

• Loss of profits, revenue, savings, or data
• Hacking, manipulation, or virus transmission
• Technical failures, outages, or unavailability
• Loss or theft of digital currency
• Wallet or network issues
• Misconfigured addresses
• Any consequential, incidental, or indirect damages

13.1 Dispute Resolution Procedure

1. First attempt: Direct negotiation via info@acechange.io (Subject: Legal)
2. Communication method: Email
3. Negotiation period: 30 days from dispute arising
4. If not resolved: Referral to competent court

13.2 Time Limit for Claims

13.3 Governing Law and Jurisdiction

These Terms are governed by the laws of the Slovak Republic. Disputes shall be resolved in courts of the Slovak Republic, unless otherwise required by law.

14.1 Tax Responsibility

14.2 Service Fees

15.1 Right to Change

AceChange.io, m0ne s.r.o., and Partner Services reserve the right to update these Terms. Changes become effective on the date of publication.

15.2 Consent to Changes

Continued use of services after publication constitutes your consent to the updated terms. It is your responsibility to regularly check for changes.

15.3 Notification

Significant changes will be communicated through the website and/or email (if you have an active order). The updated version will be posted with the revised “Last updated” date.

16.1 Entire Agreement

These Terms together with the Privacy Policy and Partner Services’ terms constitute the entire agreement between the Customer and m0ne s.r.o. operating AceChange.io.

16.2 Severability

If any provision is held invalid or unenforceable, the remaining provisions shall remain in full force and effect.

16.3 Partner Services’ Terms

• FixedFloat Terms: https://ff.io/terms-of-service
• FixedFloat Privacy: https://ff.io/privacy-policy
• Transak Terms: https://transak.com/terms-of-service
• Transak Privacy: https://transak.com/privacy-policy
• Transak AML: https://transak.com/group-bsl-asl-policy
• Swapped.com Terms: https://swapped.com/terms

16.4 Contact Information