Terms of Use

Definitions

1. Introduction

1.1. These Terms of Use define the relationship with you as you interact with our Services, which constitute, each and collectively, the technology platform integrated into the Website, the associated API and mobile applications, and establish the entire agreement and understanding regarding the use of any of our Services.

1.2. If you do not agree with these Terms of Use, please do not use our Services. By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by these Terms of Use, which constitute a legally binding agreement between you and us.

1.3. You acknowledge and agree that the Services involve significant risks, including but not limited to those outlined in Section 9 (Risk Disclosure). You represent that you have the knowledge, experience, and risk tolerance necessary to engage with Virtual Currencies and the Services.

1.4. You acknowledge that AceChange operates as a non-custodial platform. We do not offer Virtual Currency safekeeping, storage accounts, or withdrawal functionality. The Services act as a technical aggregator, allowing you to initiate Virtual Currency swaps via Third-Party Providers. Any control over your funds is limited to the technical execution of a specific Transaction. We do not maintain user accounts that store or manage your Virtual Currencies.

2. Legal Capacity and User Conduct

2.1. By accessing the Services and continuing to access the Services, you represent as follows:

• You are at least 18 years of age or older (or such higher age of full legal capacity as the laws of your jurisdiction prescribe);
• You have not been previously suspended or removed from the Services;
• You have full power and authority to enter into this legal relationship and by doing so will not violate any other legal relationship;
• You guarantee that your Virtual Currencies rightfully belong to you, are not sold, encumbered, in contention or under seizure, and that no third-party rights exist to your Virtual Currencies;
• You will use the Services with your own e-mail and for your own benefit, and you do not act on behalf of or in the interest of any other person.

2.2. You represent, warrant, and covenant that all information you provide to us, whether during the initial setup of a transaction or in response to any AML/KYC, security or compliance inquiry, is and will remain true, accurate, current and complete. You are solely responsible for the accuracy and integrity of this information.

You agree to promptly and fully cooperate with all requests from us for information and documentation that we, in our sole discretion, deem necessary to comply with our legal, regulatory, security or risk-management obligations. This includes successfully passing any AML/KYC checks. Your failure, refusal or delay in providing such information may, at our sole discretion and without prior notice, result in the immediate suspension or termination of your access to the Services and the freezing, cancellation or reversal of any pending Transactions.

You have a continuing obligation to promptly update your information to ensure it remains accurate at all times. You accept full and sole responsibility for all of your activities conducted through the Services. You agree to indemnify and hold AceChange, its affiliates and its agents harmless from any and all claims, losses, liabilities, damages and expenses (including legal fees) arising out of or related to your breach of this section.

You further acknowledge that any Third-Party Provider may conduct its own AML/KYC procedures at its sole discretion. AceChange cannot influence, control or interfere with such procedures and shall not be held liable for any aspect of a Third-Party Provider’s AML/KYC process.

2.3. You guarantee that you are able to bear any and all expenses that might occur while accessing and using the Services.

2.4. We may contact you using the details you provide to us. This may include contacting you by email or other electronic means. It is important that you ensure your contact details are correct and up to date. If your contact details change, you must let us know immediately. If you do not, we will not be responsible if you do not receive information, notices or other important information from us.

2.5. If you are using the Services on behalf of an entity, you represent and warrant that (a) such legal entity is duly organised and validly existing under the applicable laws of the jurisdiction of its organisation, and (b) you are authorised to accept these Terms of Use on such entity’s behalf, and that such entity agrees to be responsible to us if you violate these Terms of Use.

2.6. You guarantee that you are not a Politically Exposed Person or a family member or close associate of such, not on any trade or economic sanctions lists, nor restricted or prohibited from engaging in any type of trading by law-enforcement agencies.

2.7. We may prevent or suspend your access to the Services if you do not comply with any part of these Terms of Use, any terms or policies to which they refer, or any applicable law.

2.8. You are required to notify us immediately of any unauthorised use of the Website or Services that you may become aware of, by way of an email addressed to [email protected]. Any User who violates these Terms of Use may be restricted from accessing the Services and may further be held liable for losses incurred by AceChange or any other User of the Services.

3a. Reverse Solicitation Declaration

3a.1. No solicitation. Nothing on the Website, in any social-media post, newsletter, affiliate link, advertisement, sponsored placement, search-engine result, paid review, podcast appearance, conference presentation or other communication originating from AceChange is intended as, or constitutes, an offer or invitation to use the Services if you are resident or located in a Restricted Jurisdiction.

3a.2. “At your own initiative”. If you are located in a Restricted Jurisdiction and nevertheless choose to access or use the Services, you acknowledge that you do so entirely on your own initiative; that AceChange has not approached you, profiled you, targeted you or otherwise reached out to you to induce such access; and that you cannot subsequently invoke any consumer-protection regime predicated on the assumption of solicitation by AceChange.

3a.3. No new categories of crypto-asset. AceChange does not present, market or recommend any new category of crypto-asset, new product, new feature or service to any User located in a Restricted Jurisdiction. Any rate, pair or routing surfaced through the Services is informational only and reflects offerings of independent Third-Party Providers.

3. Restricted Jurisdictions & Sanctions Screening

3.1. You will not use the Services if you are associated, by reason of your nationality, domicile, citizenship, residence or otherwise, with any Restricted Jurisdiction.

3.2 Country & Region Block List

3.3 Sanctions-List Screening — Continuous, Daily, Automated

3.3.1. Authoritative sources we ingest daily:

• U.S. Treasury Office of Foreign Assets Control (OFAC) — Specially Designated Nationals and Blocked Persons (SDN) List, Consolidated Sanctions List, Sectoral Sanctions Identifications (SSI) List, Foreign Sanctions Evaders (FSE) List, Non-SDN Menu-Based Sanctions (NS-MBS) List. Source: treasury.gov/ofac/downloads/sdn.xml and related feeds.
• United Nations Security Council — UN Consolidated Sanctions List.
• European Union — EU Consolidated Financial Sanctions List (CFSL).
• United Kingdom HM Treasury — UK Consolidated List of Financial Sanctions Targets.
• FATF — High-Risk Jurisdictions (“Black List”) and Jurisdictions under Increased Monitoring (“Grey List”), as published in the most recent FATF plenary update.

3.3.2. How the screening works. Our seven-layer Anti-Money-Laundering Screening Engine (“AML Engine”) screens (a) every customer-provided deposit and recipient wallet address, and (b) every name or identifier associated with a Transaction, in real time on initiation. The screening layers are:

3.3.3. Name-matching methodology. Sanctioned-person screening uses a combination of (i) exact string comparison, (ii) Soundex and Metaphone phonetic fuzzy matching (so that Putin / Putyn / Путин, Khaled / Khalid, Mohammad / Muhammad all match against the underlying record), (iii) transliteration-aware Cyrillic / Arabic / CJK normalisation, and (iv) Levenshtein edit-distance matching with a similarity threshold of 0.80 or higher. Soft phonetic boosts are applied to Levenshtein scores between 0.50 and 0.84 to catch additional transliteration variants.

3.3.4. OFAC 50 % Rule. In accordance with the OFAC 50 % Rule (revised 13 August 2014, “Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked”), any entity that is owned, directly or indirectly, 50 % or more in the aggregate by one or more persons on the OFAC SDN List, UN, EU or UK consolidated lists is itself treated as a sanctioned person, regardless of whether such entity itself appears on a sanctions list. Our beneficial-ownership screening lookup applies this rule automatically.

3.3.5. Action on positive match. Where a Transaction triggers a positive sanctions match at any of layers L1–L7, the Transaction is automatically blocked at the application layer, an internal Blocked Property record is created, the event is written to the immutable audit log, and (where applicable under the law of the jurisdiction with regulatory authority over us) the matter is reported to the competent authority within ten (10) business days. You forfeit any right to refunds or recovery in such cases.

3.3.6. Continuous, not point-in-time. Screening is repeated on every interaction — not only at the time of initial onboarding — so that designations made after a User’s first contact with the Services are also captured on the next Transaction.

3.4 Additional Sanctions Coverage

3.4.1. In addition to the list in Section 3.2, the Services are not available to any person located in, or a resident or citizen of, any jurisdiction subject to comprehensive sanctions imposed by the United Nations Security Council, the European Union, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury, the Office of Financial Sanctions Implementation (OFSI) of HM Treasury (United Kingdom), or any equivalent regime — even where such jurisdiction is not explicitly listed in Section 3.2.

3.4.2. Secondary sanctions. You acknowledge that “facilitation” prohibitions under 31 CFR Parts 510 (DPRK), 560 (Iran), 542 (Syria), 587 (Russia) and equivalent provisions extend extraterritorially to non-U.S. persons. You shall not use the Services to facilitate, in whole or in part, any transaction prohibited to a U.S. person.

3.5 Anti-Circumvention

3.5.1. You agree not to use any technology (including VPN, proxy, Tor, residency spoofing, false documents or any other technical or contractual circumvention method) to bypass the restrictions in this Section 3.

3.5.2. If we determine, in our sole discretion, that you are accessing the Services from a Restricted Jurisdiction or have breached this Section 3, we reserve the right to immediately and without notice suspend or terminate your access and report your activity to relevant authorities. You forfeit any right to refunds or recovery in such cases. It is your sole responsibility to ensure that your use of the Services is compliant with your local laws and regulations.

3b. Enhanced Due Diligence Jurisdictions (FATF Grey List)

3b.1 Current EDD Trigger Jurisdictions (FATF Feb 2025 update)

The list above is the FATF “Jurisdictions under Increased Monitoring” status as of the most recent FATF plenary report (February 2025). It is updated automatically by our AML Engine on a daily basis. Bulgaria, Croatia, Syria, the Democratic Republic of the Congo and South Sudan also appear on this FATF list but are additionally fully geo-blocked under Section 3.2 and so are not repeated here.

3b.2 What Enhanced Due Diligence Means in Practice

3b.2.1. For Transactions involving any address, counterparty, originating IP, billing country or User-asserted residency associated with an EDD jurisdiction, our AML Engine applies a deeper-than-default screening profile, including all of the following:

• Full 7-layer chain-of-custody screening (L1–L7 per Section 3.3.2) is run end-to-end on every wallet address, regardless of amount;
• Counterparty 2-hop graph expansion — beyond the standard 1-hop check, the AML Engine traces transaction ancestors and descendants up to two hops away from the customer wallet to detect indirect exposure to sanctioned or high-risk addresses;
• Source-of-Funds (SoF) attestation — the User may be required to declare and, where requested, evidence the origin of the funds being exchanged;
• Mandatory name verification — for any Transaction above a de-minimis threshold (currently the FATF Travel Rule threshold of USD/EUR 1 000 or equivalent), the User must provide a real name that is screened against the sanctions and PEP lists under Section 3.3 with the same phonetic-fuzzy methodology (Soundex / Metaphone / Levenshtein ≥ 0.80);
• Adverse-media screening — automated adverse-media checks across global news indices are run on the supplied name, with explicit category filtering for fraud, money laundering, terrorist financing, corruption, sanctions evasion and human trafficking;
• Entity-resolution cross-reference — multi-attribute matching (surname phonetic similarity + date of birth + nationality + occupation) against the sanctions and PEP datasets, producing an Identity Confidence score that is incorporated into the final risk decision;
• Transaction-pattern anomaly detection — velocity spikes, structuring indicators (amounts deliberately under reporting thresholds), rapid-cycle behaviour and unusual-hour activity are evaluated;
• PEP screening — the supplied name is matched against the OpenSanctions consolidated Politically Exposed Persons dataset (currently 1.1 million-plus records) with phonetic fuzzy matching enabled;
• Mandatory manual review — every EDD Transaction is queued for human compliance review prior to settlement when the automated risk score is medium or above.

3b.2.2. Effect on rates and timing. EDD Transactions may take longer to settle and may attract additional Third-Party Provider fees passed through to the User. We do not guarantee that any EDD Transaction will be approved; approval is at the sole discretion of AceChange and the underlying Third-Party Provider, and we reserve the right to refuse, refund or revert any EDD Transaction without explanation.

3b.2.3. Cooperation obligation. If our AML Engine flags a Transaction for EDD, you agree to cooperate promptly, fully and accurately with any information request from us, including identity documents, proof of residence, proof of source of funds, proof of source of wealth, screenshots of wallet activity, video confirmations, and small verification transactions. Failure or refusal to cooperate may result in the Transaction being cancelled, the funds being held pending compliance investigation under Section 4.5, or, where lawfully required, reported and surrendered to a competent authority.

3b.2.4. Continuous reassessment. The FATF “Increased Monitoring” status of any jurisdiction may change at each FATF plenary (typically February, June and October). Our AML Engine ingests the live FATF lists daily; jurisdictions that have been removed by FATF will automatically exit the EDD regime, and jurisdictions added by FATF will automatically enter it, without any further change to these Terms of Use.

4. Prohibited Activities and Restricted Use

4.1. AceChange is committed to complying with all applicable laws and regulations and has zero tolerance towards the use of its Services for any illegal purpose. Any such abuse by any User shall result in forthwith restriction of access and reporting of such activities to the concerned regulatory and statutory authorities. AceChange shall report all suspicious activities to the concerned authorities to ensure the initiation of investigation and prosecution against you, if required. We are strongly dedicated to upholding a resilient and efficient system to combat financial crimes, including money laundering, terrorist financing, fraud and other unlawful activities.

4.2. You further guarantee that you will not, directly or indirectly:

4.2.1. Use the Website or Services for any purpose that is illegal, fraudulent, harmful, threatening, abusive, defamatory, obscene, hateful, discriminatory, or otherwise objectionable in any jurisdiction. This includes, but is not limited to, money laundering, terrorist financing, financial crimes, dark-net activities, illegal gambling, hacking, using Virtual Currencies from illegitimate sources, or engaging in suspicious activity.

4.2.2. Use unauthorised automated means (robots, spiders, scrapers) to access the Services or extract data; develop interacting third-party applications without our prior written consent; or use or create technologies to mask IP addresses or obfuscate transactions.

4.2.3. Provide false, inaccurate or misleading information, impersonate others, misrepresent affiliations, or mislead AceChange.

4.2.4. Impersonate any person or entity, use false or fictitious names or falsely state or otherwise misrepresent your affiliation with a person or entity.

4.2.5. Have any ties, direct or indirect, to dark-net activities, including participation in or facilitation of illegal marketplaces, drug trafficking, weapons sales, child exploitation, human trafficking, distribution of illegal digital content, ransomware or malware operations, hacking services, identity theft, or any other criminal enterprises or activities.

4.2.6. Be involved in any financial-crime activities, including fraud, scams, embezzlement, insider trading, market manipulation, tax evasion, bribery, corruption, money laundering, terrorist financing, cybercrime, forgery, identity theft, or sanction evasion.

4.2.7. Be subject to sanctions (UN, EU, UK HMT, US OFAC); engage in prohibited financial activities (unlicensed banking or remittance, shell banks); or be involved in restricted industries (arms, atomic power, extractive industries, precious metals or stones, unregulated charities, adult entertainment, marijuana businesses, embassies or consulates).

4.3. In the event of any suspicious or large transactions being undertaken by you, AceChange shall have the right but not the obligation to verify such activity by sharing your IP address with the relevant authority and, if required, suspend the transactions or terminate your access to the Services.

4.4. You are hereby duly informed that we shall share all details with regulatory or legal authorities and you shall be solely responsible for the correctness of the contents provided, and for any legal action arising from false or incorrect information furnished.

4.5. If, in AceChange’s sole discretion, the source, nature, or context of any Virtual Currency is suspected to be illegal or associated with prohibited activities, AceChange reserves the right to suspend or freeze the associated Transaction. Such a freeze may last up to one hundred and eighty (180) calendar days from the date of detection and may be extended where reasonably necessary to complete ongoing compliance investigations or to cooperate with relevant authorities. This technical suspension does not constitute custody of funds. Users do not have access to or control over the frozen funds during the investigation period, and no account-based storage or withdrawal rights are created.

5. Services Description

5.1. The Services primarily aggregate and display information related to Virtual Currencies and facilitate your connection to External Services provided by Third-Party Providers for Virtual Currency swaps and other functions. AceChange is a non-custodial information aggregator and technology intermediary only.

5.2. The Services include our API, which is available for use without any charges, subject to compliance with these Terms of Use and the relevant Third-Party Provider services or products. Such Third-Party Provider services are subject to the terms and conditions of the Third-Party Providers. We make no direct or indirect warranties of any kind, express or implied, in relation to our Services, and you are strongly encouraged to conduct your own checks, verifications, consult your advisors and satisfy yourself of the suitability of our Services as well as the acceptability of the terms and conditions of the respective Third-Party Providers whose services or products are made available or referenced on our Website.

5.3. AceChange is neither the creator nor the administrator of any Virtual Currencies. It merely acts as a non-custodial aggregator and intermediary between the User and the various Third-Party Providers across the globe through External Services.

5.4. The Services are provided “as is” and without warranty of any kind, either express or implied. While we strive to provide you with uninterrupted Services, AceChange does not guarantee that access to the Services will not be interrupted, or that there will be no delays, failures, errors, omissions or loss of transmitted information. We may suspend use of the Services for maintenance and will make every reasonable effort to give you reasonable notice.

6. Third-Party Products and Services / External Services

6.1. The Services may provide links, integrations, or other forms of access to Third-Party Providers’ websites, platforms, services, applications and widgets (“External Services”). Please be aware that External Services are not operated by us. You need to read and agree to the Third-Party Providers’ terms of use, privacy policies, AML/KYC terms and other documents (if any) before using them. We are not responsible for External Services. Specifically, we do not handle or control the actual exchange of Virtual Currencies, which is performed by Third-Party Providers.

6.2. You acknowledge and agree that:

• AceChange has no control over, and is not responsible for, the content, accuracy, security, privacy policies or practices of any External Services.
• AceChange does not endorse or make any representation or warranty about any External Services or any information, software, products, services or materials found there.
• Your access to and use of External Services, including any data or content you provide to them, is solely at your own risk and subject to the terms and privacy policies of those External Services.
• It is your responsibility to evaluate the reliability, suitability, and safety of any External Service before using it.
• You are solely responsible for taking all necessary precautions to protect yourself from fraud, scams, malware, or other harmful elements that may be present on or through External Services.

6.3. AceChange does not guarantee that any External Services will be available, uninterrupted, or error-free. We are not responsible for any loss or damage arising from your use of or reliance on any External Services.

6.4. The Services may utilise APIs from Third-Party Providers to facilitate certain functionalities, such as Virtual Currency exchange services. AceChange is not responsible for the performance, security, or availability of these Third-Party Provider APIs.

6.5. To the fullest extent permitted by applicable law, AceChange shall not be liable for any direct, indirect, incidental, special, consequential or punitive damages arising out of or in connection with your use of any External Services.

6.6. If a User navigates away from the Website and initiates or conducts an exchange or any other transaction directly on the website of a Third-Party Provider, such activity is conducted entirely outside of the AceChange Services. AceChange has no involvement in, control over, or liability for any transaction made by avoiding the AceChange Website and API.

7. Service Use

7.1. AceChange operates as a non-custodial platform and does not offer wallet, storage or safekeeping services. We are not liable for losses resulting from your own actions, such as using incorrect wallet addresses, losing your private keys, or making mistakes when setting up an exchange.

7.2. AceChange facilitates the exchange of digital assets through Third-Party Providers. The process generally involves the following steps:

• You select the desired trading pair (e.g. BTC to ETH) and input the amount you wish to exchange.
• You provide the Recipient Address where you want to receive the exchanged asset.
• AceChange analyses and provides you with exchange rates offered by various Third-Party Providers.
• You select a Third-Party Provider, and the exchange is executed through that Third-Party Provider’s platform.
• You send the specified amount of the initial digital asset to the Deposit Address provided by the Third-Party Provider.
• You receive the specified amount of the exchanged digital asset at the Recipient Address.

7.3. The availability of specific trading pairs and providers may vary depending on your jurisdiction and local regulations.

7.4. To initiate an exchange, you must provide and/or select the following information: trading pair, exchange amount, rate type (fixed or floating), Recipient Address. Depending on the selected Third-Party Provider and trading pair, you might also need to supply additional details such as a refund address, email, or memo/tag. It is your responsibility to make sure all the information you provide is accurate and complete.

7.5. It is your responsibility to ensure that the receiving address you enter is correct. We highly recommend providing a valid refund address so that funds can be safely returned if there are any problems with the exchange.

7.6. You confirm that you will have access to, and control over, both the receiving address and any refund address you provide until the exchange is finished. You must not delete, deactivate or restrict access to these addresses before the exchange is complete.

7.7. Once an exchange is initiated, it may not be possible to modify or cancel it.

7.8. You must deposit the funds promptly after creating an exchange with a fixed rate. If the funds are not received within the specified timeframe, the exchange rate may be recalculated or the exchange may be cancelled, and the funds may be returned to you (subject to network fees and provider policies).

7.9. The speed of processing transactions depends on the blockchain network and its congestion. AceChange is not responsible for delays caused by blockchain network conditions. Transaction fees may be applied — these may include network fees, provider fees, and/or service fees. It is your responsibility to ensure you understand the fees you will be charged.

7.10. Each transaction progresses through a series of statuses. Understanding these statuses helps you track your exchange and know when to contact support:

• Creating Exchange — the exchange has been created in the system; you need to deposit the appropriate assets to continue the transaction.
• Awaiting Payment — the system is waiting for your deposit.
• Processing — the exchange is in progress with the Third-Party Provider.
• Finished — the exchange has been successfully completed and the assets have been sent to the Recipient Address.
• Failed — the exchange failed for some reason (e.g. technical issue, rate discrepancy).
• Verifying — the transaction is under review by AceChange or the Third-Party Provider, typically for security or compliance reasons.
• Expired — the time window for depositing funds has elapsed and the exchange has been automatically cancelled.
• Refunded — the deposited funds have been returned to the Original Deposit Address.

If a transaction remains in “Awaiting Payment” status longer than expected, or if the status is “Failed”, “Verifying”, or any other unclear state, or if you experience any other unexpected issues, contact [email protected] for assistance, including a transaction ID for a quicker response.

7.11. AceChange reserves the right to:

• Cancel an exchange and return funds to the Original Deposit Address in the event of sudden market fluctuations, technical issues, inaccurate pricing data, or any unforeseen circumstance that makes the exchange infeasible or potentially harmful;
• Offer a re-exchange at a new exchange rate that reflects current market conditions;
• Refuse to execute any order for any reason, at its sole discretion, without explanation.

7.12. You acknowledge that any estimated time of arrival (ETA) displayed for a Transaction is provided by the respective Third-Party Provider and is an estimate only. AceChange does not make any representations or warranties about the accuracy of this time.

8. Service Modification and Discontinuation

8.1. AceChange reserves the right to modify, suspend or discontinue the Services (or any part thereof), temporarily or permanently, at any time, for any reason, with or without prior notice to you. Such reasons may include, but are not limited to:

• Technical issues or maintenance;
• Changes in market conditions or regulatory requirements;
• Security concerns;
• Business decisions to alter or discontinue the Services;
• Force Majeure Events.

8.2. To the fullest extent permitted by applicable law, AceChange shall not be liable to you or any third party for any losses, damages, costs or expenses arising out of or in connection with any modification, suspension or discontinuance of the Services.

8.3. While AceChange is not obligated to provide notice of modifications or discontinuations, it will make commercially reasonable efforts to provide advance notice when practicable.

9. Risk Disclosure

9.1. The content of the Services is meant to provide information regarding AceChange, the Services, our APIs, our applications, prices or market value of cryptocurrencies, tokens, coins, rankings, trade-volume data, and other information related to Virtual Currencies. This information constitutes general knowledge only and is not meant to be relied upon for any purpose. You are strongly advised to procure your own checks and professional advice before you decide to make any trade, investment or swap. No content constitutes any trading or investment advice or guarantee of any kind.

9.2. Virtual Currencies are highly volatile, largely unregulated, and subject to significant price fluctuations, potentially leading to substantial or total loss of value. Transactions are irreversible once initiated on the network. Execution prices may differ from indicated rates during market volatility. We are not liable for losses due to Virtual Currency volatility or price fluctuations.

9.3. You are solely responsible for assessing your financial situation, risk tolerance and the suitability of Virtual Currency transactions. Our Services are “execution-only”; we do not provide advice or manage risk. You must obtain independent professional financial, legal, tax and other relevant advice before transacting.

9.4. The rates made available via the Services shall not be considered investment or financial advice and cannot be used as the basis for an investment strategy, a legal position in court, or otherwise.

9.5. No information, write-ups, listings, prices, events, photographs, graphs, charts, articles, news updates, forecasts, project information, testimonials, advertisements, analyses, reports, media files, APIs or other content on the Website constitutes advice of any kind.

9.6. You acknowledge that, in addition to the risks outlined in these Terms of Use, there may be other risks associated with using our Services and transacting with Virtual Currencies that we have not foreseen or identified. You accept full responsibility for all such risks.

10. Refund Policy

10.1. You acknowledge that Virtual Currency transactions are complex and often irreversible. Consequently, refunds or transaction reversals are not guaranteed and are subject to technical feasibility, Third-Party Provider policies, network conditions and our sole discretion. Refunds are generally unavailable once an order’s status progresses to “Confirming,” “Exchanging,” “Sending” or “Finished.” While we may review unique circumstances on a case-by-case basis, we cannot facilitate returns for orders involving assets identified as fraudulent or imitative.

10.2. Each transaction relies on the User providing correct information and following the instructions given during the order process. Refunds are not possible if:

• The wrong Virtual Currency was submitted for exchange;
• An incompatible or incorrect network was used;
• The transaction was initiated after the contract expired;
• A deposit was made without the required identifier (MEMO, Destination Tag, etc.);
• An amount was sent below the specified minimum.

It is your sole responsibility to carefully review and confirm all transaction details before proceeding.

10.3. If you have an issue with a transaction, you must contact us through the following official channel: email [email protected]. For security reasons, and due to platform limitations, we cannot process requests made through social media or other unofficial channels.

10.4. The investigation and potential resolution of such requests can take up to thirty-one (31) calendar days.

10.5. We are not liable for losses incurred if you share sensitive transaction information with unauthorised parties or seek help through unofficial channels. Always verify that any message claiming to be from us is genuine by contacting our official email directly.

10.6. An exchange may be paused while we investigate, or for other reasons. If this occurs, we or Third-Party Providers have the right to complete the exchange and send the converted funds to the Recipient Address. It is your responsibility to ensure the Recipient Address remains accessible and under your control until the funds are received. Where an exchange is suspended, we reserve the right to return Virtual Currencies to the refund address provided by you during exchange creation, without prior notification.

10.7. While we will try to return funds to User preferences, the availability of returns is subject to certain constraints. To ensure the security and legitimacy of all transactions, we reserve the right to request additional verification of deposit ownership.

10.8. Kindly note that the return of any funds may incur associated fees, including a network transaction fee and a recovery fee to cover costs associated with assisting with the return of funds.

11. Monitoring, Investigation, and Potential Limitations

11.1. To ensure the safety of our Services and to comply with legal requirements, we may occasionally review transactions. This usually happens when our security system identifies potentially risky activity. Flags could include:

• Significant or unusual changes in the amount or frequency of your transactions;
• Transactions involving countries known to have a higher risk of illegal activity;
• Connections between your transactions and publicly known illicit activities;
• Gaps or inconsistencies in the information you have provided;
• Signs of attempts to bypass our security measures.

11.2. When such signals are detected, a transaction may be put under review for up to 180 days from the date the concern was identified.

11.3. If your transaction is flagged for review, we may ask you to provide information to help us understand the situation. This might include proof of identity, proof of address, proof of source of funds, or any other information necessary to confirm the transaction is legitimate.

11.4. If, after our review, we determine that there is no unacceptable risk, we will lift any limitations.

11.5. We are fully committed to cooperating with regulatory bodies and law-enforcement agencies. Inquiries or assessments related to potential illegal activity may require the sharing of user information, transaction details and other relevant data with these entities. Such disclosures may be made without prior notice to the User where reasonably believed necessary to comply with applicable law.

11.6. We will not be responsible for any losses, damages or delays that result from freezing funds or sharing information with law-enforcement agencies as described in this section, except as required by law.

11.7. Blocked Property & OFAC reporting. Where a Transaction is blocked by the AML Engine due to a positive match against the OFAC SDN List, the UN, EU or UK consolidated sanctions lists, or pursuant to the OFAC 50 % Rule, an internal Blocked Property record is created and (where applicable under the law of the jurisdiction with regulatory authority over us) reported to the competent authority within ten (10) business days, in the form required (e.g. OFAC Form TD F 90-22.50 for U.S.-nexus matters). Annual reports of blocked property are filed where applicable. Records relating to sanctions matters are retained for a minimum of ten (10) years in accordance with 31 CFR § 501.601.

12. Asset Recovery

12.1. AceChange maintains a voluntary crypto asset recovery mechanism designed to support victims of fraud or error in recovering frozen funds. This process is strictly out-of-court and is not intended to replace legal remedies available through competent courts or authorities.

12.2. A party initiating the process (the “Requestor”) is an individual or legal entity claiming ownership of the frozen assets and asserting that such assets were lost or misappropriated due to fraud, error, or criminal conduct. The Requestor must provide sufficient evidence to establish a legitimate claim to the funds.

12.3. AceChange will conduct an independent assessment of each case. This may include enhanced due-diligence and identity verification, source-of-funds checks, confirmation that the submitted documentation supports a clear and lawful trace from the Requestor to the wallet address from which the funds originated, and an assessment of whether the source of funds can be linked to a fiat-to-crypto onramp or other legitimate origin.

12.4. The asset-recovery process may be lengthy and complex, and is subject to delays outside of AceChange’s control, particularly where third parties or law-enforcement authorities are involved.

12.5. AceChange reserves full discretion to determine whether a Requestor has met the evidentiary threshold to justify recovery and release of the funds. Recovery is not guaranteed, and all decisions are final.

12.6. By submitting an asset-recovery request, the Requestor acknowledges and accepts that they may be required to provide detailed personal and financial information, that they are solely responsible for the accuracy and completeness of the documentation submitted, and that they agree to the fee structure and assessment procedures outlined herein.

12.7. A processing fee covering AceChange’s administrative expenses of 1% of the recovered amount will be charged for all successful asset-recovery claims, subject to a minimum charge of USD 100 (or equivalent). This fee will be deducted prior to disbursement.

12.8. If you are a potential Requestor or a law-enforcement agency and have any questions regarding the asset-recovery process, please contact us at [email protected] (subject line: Asset Recovery).

13. Taxes

You irrevocably accept full responsibility for your actions according to current tax legislation valid at the place of your residence regarding any performed transactions, including but not limited to revenue/income tax. You acknowledge that it is your sole liability to determine, report and remit all applicable taxes to the appropriate tax authority. In no way shall we bear any responsibility for determining whether taxes apply to your transfers or for collecting, reporting, withholding or remitting any taxes arising from any trades or transfers, and we do not act as your tax agent.

14. Intellectual Property

14.1. Any and all content reflected on the Services is protected by copyright, design rights, trademark rights, and/or other intellectual-property rights, whether owned by AceChange or licensed to AceChange, or permitted under the law for use by AceChange, whether registered, registrable or otherwise.

14.2. You agree and acknowledge that without our prior written consent you are not permitted to reproduce, copy, download, decompile, disassemble, extract, store, distribute, lease, time-share, publish, sell, translate, modify, or create derivative works from any part of the content, products or services displayed on the Website. You are not permitted to copy, reproduce, duplicate, download, derive, modify, translate, hack, distribute, lease, rent, or otherwise deal with any part of our content or Services except to view or use strictly pursuant to the purpose for which it was made available.

14.3. Any and all names, logos, trademarks, service marks and brands, whether registered or otherwise, represented on the Website and the Services belong to AceChange or to third parties who have agreed to display their names on the Website and the Services. You are not permitted to copy, replicate, modify, extract, download or otherwise use any such names for any purpose whatsoever without the prior written consent of AceChange.

14.4. We reserve the right to take legal action against you for any unauthorised use of our content.

15. Third Party Content

15.1. The Services may host or co-host certain Third-Party content operated by and belonging to such third parties (“Third-Party Content”). Third-Party Content is subject to copyright, trademark and other intellectual-property rights under applicable laws and regulations. We expressly disclaim any and all liability in connection with your use of Third-Party Content. Any such use is at your own risk and may subject you to additional or different terms and restrictions by the third party running the service.

15.2. The Services may include advertisements or other promotional materials from third parties. Such advertisements and promotional materials have not been verified or approved by us, do not constitute advice from us, and are not an endorsement by us of the advertiser or their products or services.

16. Limitation of Liability

16.1. THE SERVICES ARE PROVIDED “AS IS” AND “AS AVAILABLE.” WE DISCLAIM ALL REPRESENTATIONS AND WARRANTIES, EXPRESS, IMPLIED OR STATUTORY, NOT EXPRESSLY SET OUT IN THESE TERMS OF USE, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. WE MAKE NO REPRESENTATION, WARRANTY OR GUARANTEE REGARDING THE RELIABILITY, TIMELINESS, QUALITY, SUITABILITY OR AVAILABILITY OF THE SERVICES, OR THAT THE SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE.

16.2. IN NO EVENT SHALL WE, OUR DIRECTORS, OFFICERS, MEMBERS, EMPLOYEES OR AGENTS BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE OR CONSEQUENTIAL DAMAGES, INCLUDING LOST PROFITS, LOST DATA, PERSONAL INJURY OR PROPERTY DAMAGE RELATED TO, IN CONNECTION WITH, OR OTHERWISE RESULTING FROM ANY USE OF THE SERVICES, REGARDLESS OF OUR NEGLIGENCE.

16.3. IN NO EVENT SHALL WE BE LIABLE FOR ANY DAMAGES, LIABILITY OR LOSSES ARISING OUT OF: (i) YOUR USE OF OR RELIANCE ON THE SERVICES OR YOUR INABILITY TO ACCESS OR USE THE SERVICES; OR (ii) ANY TRANSACTION OR RELATIONSHIP BETWEEN YOU AND ANY THIRD-PARTY PROVIDER; OR FOR ANY DELAY OR FAILURE IN PERFORMANCE RESULTING FROM CAUSES BEYOND OUR REASONABLE CONTROL.

16.4. IN NO EVENT SHALL OUR AGGREGATE LIABILITY, WHETHER IN CONTRACT, WARRANTY, TORT (INCLUDING NEGLIGENCE), PRODUCT LIABILITY, STRICT LIABILITY OR OTHER THEORY, ARISING OUT OF OR RELATING TO THE USE OF, OR INABILITY TO USE, THE SERVICES OR THESE TERMS EXCEED FIVE THOUSAND US DOLLARS (USD 5,000).

16.5. AS FAR AS THE LAW ALLOWS, WE ARE NOT RESPONSIBLE FOR LOSSES, DAMAGES OR PROBLEMS THAT RESULT FROM YOUR ACTIONS OR FAILURES TO ACT. THIS INCLUDES SITUATIONS WHERE YOU ENTER THE WRONG WALLET ADDRESS, MAKE MISTAKES IN TRANSACTION INFORMATION, MAKE POOR INVESTMENT CHOICES, OR LOSE ACCESS TO YOUR OWN WALLETS OR PRIVATE KEYS.

17. Indemnification

You will indemnify and keep indemnified AceChange and its directors, officers, employees and representatives against all direct or indirect liabilities (including without limitation all losses, damages, claims, costs or expenses) incurred by AceChange or any other third party in respect of any act or omission by you in the performance of your obligations under these Terms of Use, unless such liabilities result from gross negligence, wilful default or fraud by AceChange.

18. Force Majeure

18.1. AceChange shall not be liable for any delay or failure in the performance of its obligations under these Terms of Use arising out of or caused by, directly or indirectly, forces beyond its control (each a “Force Majeure Event”). Force Majeure Events may include, but are not limited to: acts of God, natural disasters, war, acts of terrorism, riots, civil unrest, labour disputes, fires, explosions, epidemics, pandemics, government regulations or orders, legal prohibitions, changes in applicable laws or regulations, embargoes, disruptions to the internet or telecommunications infrastructure, power outages, equipment failures, blockchain network congestion or forks, exchange or custodian failures, denial-of-service attacks, hacking or other malicious cyberattacks.

18.2. In the event of a Force Majeure Event, AceChange’s obligations under these Terms of Use shall be suspended for the duration of the Force Majeure Event.

18.3. During a Force Majeure Event, AceChange may, at its sole discretion, take any action it deems necessary or advisable to protect the integrity and security of the Services and the interests of its users.

18.4. AceChange will make reasonable efforts to notify users of any Force Majeure Event that materially affects their use of the Services. However, AceChange shall not be liable for any failure to provide such notice.

18.5. AceChange will resume performance of its obligations as soon as reasonably practicable after the Force Majeure Event has ceased or abated.

19. Data Privacy and Security

We are committed to protecting your personal information. Our Privacy Policy explains how we collect, use and share your data. By using the Services, you consent to our data practices as described in the Privacy Policy. We will implement reasonable security measures to protect your information, but we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

20. Regulatory and Law-Enforcement Cooperation

20.1. Authorities may contact us directly at [email protected], using one of the following subject lines for accelerated routing:

• Law Enforcement — for police, prosecutors and judicial authorities;
• Regulator — for supervisory authorities, central banks, financial-conduct authorities;
• FIU — for financial-intelligence units;
• Sanctions — for OFAC, UN, EU, UK HMT and equivalent sanctions inquiries;
• MLAT — for Mutual Legal Assistance Treaty / INTERPOL / Europol cooperation requests;
• Compliance — for general compliance correspondence.

20.2. Lawful requests should be transmitted on official letterhead or through verifiable judicial-cooperation channels (e.g. Mutual Legal Assistance Treaty / MLAT, INTERPOL, Europol). For urgent matters involving imminent risk to life or property, contact us at the same email address with the prefix URGENT in the subject line and we will respond on a priority basis.

20.3. We maintain audit-grade logs, geo-block records, sanctions-screening evidence and compliance documentation consistent with the OFAC Sanctions Compliance Program framework (May 2019), the FATF Recommendations, the EU/UK AML regimes and equivalent international standards. Retention periods are calibrated to satisfy these standards (typically up to ten (10) years for sanctions-related records, per 31 CFR § 501.601, March 2025 amendment).

20.4. We do not require any account, contract or pre-arranged channel for an authority to contact us. Every lawful request receives an acknowledgement within five (5) business days, and a substantive response within fifteen (15) business days, unless the complexity of the inquiry requires a longer period (in which case we will communicate the expected timeline).

20.5. We will not contest properly-served subpoenas, court orders, asset-freezing orders, search warrants or equivalent instruments. Where the law permits, we may notify the affected User; where the law prohibits such notification (e.g. tipping-off provisions, gag orders), we will refrain accordingly.

21. Complaints

21.1. If you have a complaint regarding the Services, you may submit it by sending a detailed email to [email protected]. To help us understand and address your issue quickly, please include:

• Your full name and contact information;
• A clear explanation of the issue;
• Any helpful information such as transaction numbers, screenshots or documents that support your concern;
• What you would like us to do to resolve the situation.

21.2. We will confirm that we have received your email within five (5) working days. We will then do our best to look into the matter thoroughly and get back to you with a detailed response within fifteen (15) working days of receiving your message. Some complex issues might take a little longer to fully investigate.

22. Governing Law and Dispute Resolution

22.1. Governing law. These Terms of Use and any dispute or claim arising from or in connection with them (including non-contractual disputes or claims) are governed by and construed in accordance with the laws of the Republic of Costa Rica, without regard to its conflict-of-laws principles.

22.2. Dispute Resolution. The parties shall first attempt to resolve any dispute, controversy or claim arising out of or relating to these Terms (“Dispute”) through good-faith negotiations within thirty (30) calendar days of written notice of the Dispute.

If negotiation fails, the Dispute shall be referred to and finally resolved by arbitration administered by the International Center for Conciliation and Arbitration of the Costa Rican-American Chamber of Commerce (CICA) in accordance with its Rules of Arbitration, which are deemed to be incorporated by reference into this clause. The seat of arbitration shall be San José, Costa Rica. There shall be one (1) arbitrator. The arbitration shall be conducted in English. The arbitral award shall be final and binding. The hearings (if any) shall be held virtually (by means of videoconferencing or otherwise).

23. Miscellaneous

23.1. Modification of Terms. We can change these Terms of Use at any time, so please check them regularly. If you keep using our Services after we change the Terms of Use, it means you accept the new Terms of Use, even if we do not tell you about the changes beforehand.

23.2. Electronic Communication. You agree that all communication between you and us regarding these Terms of Use and your use of the Services will be electronic, primarily via email. You consent to receiving all notifications and documents at your email address and agree to send all notifications and documents to us via email as well.

23.3. Feedback and Contact. If you have any questions relating to these Terms of Use, your rights and obligations arising from these Terms of Use, and/or your use of the Website and the Services, please contact us at [email protected].

23.4. Entire Agreement. These Terms of Use are the only agreement between you and us about using our Services. They replace any previous discussions or agreements. You promise that any information you give us is true, accurate and complete.

23.5. Severability. If any provision of these Terms is or becomes illegal, invalid or unenforceable in any respect under the law of any relevant jurisdiction, such provision shall be deemed severed from these Terms and shall be replaced with one having an effect as close as possible to the deficient provision. The remaining provisions of these Terms will remain in full force.

23.6. Assignment. You may not assign or transfer any of your rights or obligations under these Terms of Use without prior written consent from us, including by operation of law or in connection with any change of control. We may assign or transfer any or all of our rights under these Terms of Use, in whole or in part, without obtaining your consent or approval.

23.7. Headings. Section headings are for convenience only and shall not affect the interpretation of these Terms.