User Agreement

ALFABIT FINTECH LLC
Date: 01/01/2026

1. GENERAL PROVISIONS

This User Agreement (hereinafter referred to as the "Agreement") governs the procedure for accessing and using the services provided by AlfaBit Fintech LLC (hereinafter referred to as the "Company" or "AlfaBit").
By using the Company's website, mobile applications, software interfaces, virtual asset exchange services, or any other services provided by the Company, the User confirms that they have read the terms of this Agreement, understand its contents, and accept it in full.
If the User does not agree with this Agreement, the User must immediately cease using the Services.

2. DEFINITIONS

"Account" means a User account created for the use of the Company's Services.
"User" or "Client" means an individual or legal entity using the Company's Services.
"Virtual Asset" means a digital representation of value or rights that can be transferred and stored using distributed ledger technology or similar technologies.
"KYC" means customer identification and verification procedures.
"KYB" means legal entity identification and verification procedures.
"EDD" means enhanced due diligence procedures.
"Applicable Law" means the laws of the Kyrgyz Republic, international sanctions requirements, and other mandatory regulatory requirements applicable to the Company and its Users.

3. DESCRIPTION OF SERVICES

AlfaBit is a fintech platform providing services related to virtual assets and digital financial technologies.
The Company's Services may include:
• exchange of virtual assets;
• purchase and sale of virtual assets;
• conversion of cryptocurrency into fiat currency and vice versa;
• transfer of virtual assets;
• storage of virtual assets within the provided services;
• payment solutions;
• services for corporate clients;
• services for institutional clients;
• compliance checks and transaction support;
• other services published on the Company's official website.
The current list of services, supported assets, fees, limits, and service conditions is published on the Company's official website.
The Company has the right to modify, restrict, supplement, or discontinue certain Services at any time without prior notice unless otherwise required by law.
When providing services related to fiat currency, the Company may use banks, payment systems, payment institutions, payment infrastructure providers, and other third parties.
For certain transactions, the Company may request additional information and documents, including documents confirming identity, source of funds, purpose of payment, ownership of a bank account or payment instrument, as well as other information necessary to comply with legal requirements, payment partner requirements, and the Company's internal procedures.
The User agrees that the processing, crediting, return, or rejection of fiat payments may depend on the internal procedures, requirements, and restrictions of banks, payment systems, and other payment service providers.
The Company shall not be liable for delays, additional reviews, restrictions, payment rejections, or other actions taken by banks, payment systems, payment institutions, or government authorities within the scope of their powers and internal procedures.

4. USER ELIGIBILITY

By using the Company's Services, the User represents and warrants that:
• has full legal capacity;
• is at least 18 years old;
• acts on their own behalf or has the necessary authority to represent a legal entity;
• is not subject to sanctions;
• is not a person subject to restrictions under the law or the Company's internal policies;
• does not use the Services for the benefit of prohibited persons or organizations.

5. USER OBLIGATIONS

The User agrees to:
• provide accurate, complete, and up-to-date information;
• promptly update the information provided;
• comply with Applicable Law;
• ensure the security of their account credentials;
• immediately notify the Company of unauthorized access to the Account;
• provide documents and information upon the Company's request;
• cooperate during compliance reviews.
The User bears full responsibility for the accuracy of the information provided.

6. COMPLIANCE WITH AML/CFT, KYC AND KYB REQUIREMENTS

The Company applies a risk-based approach to managing risks related to money laundering, terrorist financing, fraud, and other financial crimes.
The Company may at any time require:
• KYC;
• KYB;
• EDD;
• Source of Funds verification;
• Source of Wealth verification;
• video identification;
• re-verification;
• other checks provided for by the Company's internal procedures.
The User must provide all information and documents reasonably requested by the Company.
Such documents may include:
• identification documents;
• proof of residential address;
• bank statements;
• tax declarations;
• documents confirming the source of funds;
• agreements, bills, and invoices;
• corporate documents;
• information on beneficial owners;
• other documents required for compliance purposes.
The Company has the right to request additional documents and information both within the framework of its own compliance procedures and for the purpose of complying with the requirements of banks, payment institutions, payment systems, payment infrastructure providers, counterparties of the Company, and other persons involved in transaction processing.
Failure to provide the requested information may result in refusal to process a transaction, restriction of access to the Services, suspension of service, or termination of the business relationship with the User.

7. TRANSACTION MONITORING

The Company carries out ongoing transaction monitoring for the purpose of preventing financial crimes and complying with legal requirements.
For these purposes, the Company may use specialized blockchain transaction analysis solutions.
The Company does not provide users with wallet risk scoring services and does not disclose information contained in the Company's internal AML policies.
All transactions may be subject to automated and manual review in relation to:
• sanctions risks;
• fraud;
• terrorist financing;
• use of stolen assets;
• connections with high-risk services;
• other risk factors.

8. RIGHT TO REQUEST ADDITIONAL INFORMATION

The Company has the right at any time to request additional information or documents regarding:
• the User's identity;
• origin of assets;
• economic purpose of transactions;
• counterparties;
• sources of wealth;
• other circumstances relevant to compliance with legal requirements and the Company's internal policies.
Failure to provide such information may result in service restrictions.

9. RIGHT TO RESTRICT AND FREEZE ASSETS

The Company has the right to restrict access to an Account, temporarily block transactions, or freeze assets where:
• there are suspicions of violation of the law;
• there are signs of fraud;
• sanctions risks have been identified;
• additional review is required;
• the User has not provided the requested information;
• a request has been received from a government authority;
• there is a risk of violating AML/CFT requirements;
• there are other reasonable grounds for conducting a review.
Restrictions may remain in place until completion of the review, investigation, or fulfillment of legal requirements.

10. PROHIBITED ACTIVITIES

The User is prohibited from:
• violating the law;
• participating in terrorist financing;
• engaging in money laundering;
• circumventing sanctions restrictions;
• using stolen assets;
• using false documents;
• using VPN, Proxy, Tor, and similar technologies to bypass restrictions;
• taking actions aimed at disrupting the operation of the Services.
Additionally, the User is prohibited from:
• using unfair practices, schemes, or technical means to circumvent anti-fraud systems, transaction monitoring systems, AML/CFT controls, limits, restrictions, or other security mechanisms of the Company;
• intentionally and maliciously creating conditions that provide the User with an unfair advantage when using the Company's Services compared to other users;
• taking actions aimed at manipulating the operation of services, tariffs, exchange rates, bonus programs, loyalty programs, limits, or other mechanisms of the platform;
• using automated tools, software, scripts, or other technical means to gain an unfair advantage or disrupt the normal operation of the Services.

11. RESTRICTED JURISDICTIONS

The Company does not provide Services to individuals and legal entities who are located in, reside in, are registered in, incorporated in, or are otherwise connected with the following jurisdictions and territories:
• Afghanistan;
• Algeria;
• Angola;
• Bosnia and Herzegovina;
• Burkina Faso;
• Cameroon;
• Côte d'Ivoire;
• Cuba;
• Democratic Republic of the Congo;
• Eritrea;
• Ethiopia;
• Guyana;
• Haiti;
• Iran;
• Iraq;
• Kenya;
• Laos;
• Lebanon;
• Libya;
• Mali;
• Mozambique;
• Myanmar;
• Namibia;
• Nigeria;
• Democratic People's Republic of Korea (DPRK);
• Philippines;
• Somalia;
• South Sudan;
• Sri Lanka;
• Sudan;
• Syria;
• Tanzania;
• Trinidad and Tobago;
• Tunisia;
• Uganda;
• Uzbekistan;
• Vanuatu;
• Venezuela;
• Yemen;
• Ukraine;
• Autonomous Republic of Crimea;
• City of Sevastopol;
• Donetsk Region;
• Luhansk Region.
The Company has the right to refuse the provision of Services, restrict access to the Services, block transactions, or terminate business relationships with any User who is a resident, citizen, beneficial owner, representative, or otherwise connected with the above jurisdictions.
The Company has the right to amend the list of restricted jurisdictions at any time based on legal requirements, international sanctions, recommendations of international organizations, internal risk assessments, and requirements of the Company's partners.
The current list of restricted jurisdictions is published in the Company's Restricted Jurisdictions Policy.
The Company may use technical, organizational, and compliance mechanisms to identify users from restricted jurisdictions, including document verification, transaction monitoring, IP address analysis, geolocation data, and other lawful methods of control.
The use of VPN, Proxy, Tor, or other technologies intended to conceal the User's location or circumvent established restrictions is prohibited and may result in restriction of access to the Services, blocking of transactions, additional review, or termination of service.

12. FEES

The amount of fees is determined by the Company and published on the official website.
The Company has the right to change fees at any time.

13. SUSPENSION AND TERMINATION OF SERVICES

The Company has the right to restrict, suspend, or terminate the provision of services to a User at any time if:
• compliance risks have been identified;
• the User has violated this Agreement;
• the User has refused to undergo verification;
• the User has failed to provide the required documents;
• there are legal requirements;
• further cooperation does not correspond to the Company's risk appetite.
The Company is not obliged to disclose the reasons for its decision in cases provided for by law or internal procedures.

14. LIMITATION OF LIABILITY

The Services are provided on an "as is" and "as available" basis.
The Company does not guarantee the absence of technical errors, interruptions in the operation of blockchain networks, third-party services, or other circumstances beyond the Company's control.
The Company shall not be liable for indirect losses, loss of profit, or other consequences arising from the use of the Services.
The Company shall not be liable for losses arising as a result of User errors, including, but not limited to:
• selecting an incorrect blockchain network;
• providing an incorrect wallet address;
• providing incorrect bank details;
• errors in beneficiary identification information;
• entering incorrect payment details;
• sending assets not supported by the Company;
• any other errors, inaccuracies, or incorrect information provided by the User when using the Services.
The User is solely responsible for verifying the accuracy of all details, addresses, networks, and other information before confirming a transaction.

15. PERSONAL DATA

Personal data shall be processed in accordance with the Law and the Company's Privacy Policy.
The User consents to the processing of personal data to the extent necessary for the provision of the Services and compliance with legal requirements.

16. GOVERNING LAW AND DISPUTE RESOLUTION

This Agreement shall be governed by the laws of the Kyrgyz Republic.
All disputes shall be subject to the jurisdiction of the competent courts of the Kyrgyz Republic.

17. AMENDMENTS TO THE AGREEMENT

The Company has the right to amend this Agreement at any time.
Continued use of the Services following publication of amendments shall constitute acceptance of such amendments by the User.

18. CONTACT INFORMATION

AlfaBit Fintech LLC
Registration Number: 226492-3301-LLC

The company is duly registered as a Limited Liability Company with the Ministry of Justice of the Kyrgyz Republic.

Registered Address:
Office No. 15, Grei Business Center
Yunusaliev Street, Oktyabrsky District
Bishkek, Kyrgyz Republic

Website: https://alfabit.org
E-mail: support@alfabit.org