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Terms of Use

  Last update: June 2023

  These Terms of Use are an agreement between VVWallet Operators and you or the entity you represent (hereinafter referred to as “you” or “your”). These Terms of Use (hereinafter “Terms”) refer to VVWallet and its corresponding services, website, applications, widgets, blogs and social networks (hereinafter “VVWallet Offerings”). By using, downloading, and/or accessing any of VVWallet Offerings, you agree with these Terms. You may be subject to specific additional Terms of Use when using some of VVWallet Offerings. Capitalized terms used herein shall have the meanings set forth in Section 11 of these Terms.

  These Terms contain important provisions including an arbitration provision that requires all claims to be resolved by way of legally binding arbitration. The terms of the arbitration provision are set forth in Section 9 hereunder.

  As with any asset, the values of Digital Currencies (as defined below) may fluctuate significantly and there is a substantial risk of economic losses when purchasing, selling, holding or investing in Digital Currencies and their derivatives. By making use of VVWallet Offerings, you acknowledge and agree that (1) you are aware of the risks associated with transactions of digital currencies and their derivatives, (2) you shall assume all risks related to the use of VVWallet Offerings and transactions of digital currencies and their derivatives; and (3) VVWallet shall not be liable for any such risks or adverse outcomes.

  1. General Provisions

  1.1 About VVWallet: VVWallet mainly serves as a global online platform to transfer and trade Digital Assets, and provide Users with a wallet, financing services, technical services and other Digital Assets-related services. As further detailed in Section 3 below, Users must register and open a VVWallet Account, and deposit into their account. Although VVWallet has been committed to maintaining the accuracy of the information provided through VVWallet Offerings, VVWallet cannot and does not guarantee its accuracy, applicability, reliability, integrity, performance or appropriateness, nor shall VVWallet be liable for any loss or damage that may be caused directly or indirectly by your use of these contents. The information about VVWallet Offerings may change without notice, and the main purpose of providing such information is to help Users make independent decisions. VVWallet does not provide investment or consulting advice of any kind, and is not responsible for the use or interpretation of information on VVWallet or any other communication medium. All Users of VVWallet Offerings must understand the risks involved in Digital Assets trading and transferring.

  1.2 Registration: To access VVWallet Offerings, you first must open a VVWallet Account providing the information requested by VVWallet and accepting the corresponding legal documentation. VVWallet may refuse, in its discretion, to open a VVWallet Account for you.

  1.3 Eligibility: You must be at least eighteen (18) years of age and not be resident, located in or otherwise attempting to access the VVWallet platform or the VVWallet Offerings from, or otherwise acting on behalf of a person or legal entity that is resident or located in a restricted location, including the United States, Malaysia, Canada, and such other locations as designated by VVWallet Operators from time to time as a “Restricted Location”. Access to VVWallet platform may be banned if laws and regulations of certain countries, or states, are being violated. VVWallet Offerings and certain functionality within the VVWallet platform may not be available or may be restricted. You shall be responsible for informing yourself about and observing any restrictions and/or requirements imposed with respect to the access to and use of the VVWallet platform and VVWallet Offerings in each country from which the VVWallet platform and the VVWallet Offerings are accessed by you or on your behalf. VVWallet Operators reserve the right to change, modify or impose additional restrictions with respect to the access to and use of the VVWallet platform and VVWallet Offerings from time to time at their discretion at any time without prior notification.

  1.4 Account Usage Requirements: The VVWallet Account can only be used by the account registrant with the MPC wallet license. VVWallet reserves the right to suspend, freeze or cancel the use of VVWallet Accounts by persons other than account registrant. If you suspect or become aware of any unauthorized use of your username and password, you should notify VVWallet immediately. VVWallet assumes no liability for any loss or damage arising from the use of VVWallet Account by you or any third party with or without your authorization.

  1.5 Account Security: By signing up for a VVWallet Account, you acknowledge that you are responsible for maintaining the confidentiality of your account and password, and restricting access to the device(s) you use to access VVWallet. To the extent permitted by law, you agree to take full responsibility for all the activities carried out using your account. If you suspect that your account’s security has been breached, you should notify us immediately so that we can take appropriate action. You must not use your VVWallet Account in any way that causes, or is likely to cause, interruption, damage and/or impairment of the VVWallet platform. You must not use your VVWallet account in any way that causes, or is likely to cause, annoyance, inconvenience, and/or anxiety to any other person. You must not decompile, reverse engineer, disassemble, derive the source code of, modify or create derivative works of VVWallet Offerings.

  1.6 Prohibition of Use: By accessing and using VVWallet Offerings, you represent and warrant that you have not been included in any trade embargoes or economic sanctions list (such as the United Nations Security Council sanctions list), the list of specially designated nationals maintained by OFAC (Office Of Foreign Assets Control of the United States Department of the Treasury), or the denied persons or entity list of the U.S. Department Of Commerce. VVWallet reserves the right to choose markets and jurisdictions to conduct business, and may restrict or refuse, in its discretion, the provision of VVWallet Offerings in certain countries or regions.

  1.7 Supplementary Terms: Due to the rapid development of Digital Currencies and VVWallet, these Terms between you and VVWallet Operators do not enumerate or cover all rights and obligations of each party, and do not guarantee full alignment with needs arising from future development. Therefore, the Privacy Notice, VVWallet Platform Rules, and all other agreements entered into separately between you and VVWallet are deemed supplementary terms that are an integral part of these Terms and shall have the same legal effect. Your use of VVWallet Offerings is deemed your acceptance of the above supplementary terms.

  1.8 Changes to these Terms: VVWallet reserves the right to change or modify these Terms in its discretion at any time. VVWallet will notify such changes by updating the terms on its website and modifying the date displayed on this page. Any and all modifications or changes to these Terms will become effective upon publication on the website or release to Users.

  2. VVWallet Offerings

  VVWallet Offerings include, but are not limited to, Digital Currencies transfer, deposit, withdraw, and exchange, Fiat Services, VVWallet savings services, staking, acquiring market-related data, research and other information released by VVWallet, participating in User activities held by VVWallet, etc., in accordance with the provisions of these Terms (including VVWallet Platform Rules and other individual agreements). VVWallet has the right to (a) provide, modify or terminate, in its discretion, any VVWallet Offerings; (b) allow or prohibit some Users’ use of any VVWallet Offerings in accordance with relevant VVWallet Platform Rules; (c) determine which Digital Assets are listed on the platform and may add or remove Digital Assets from the platform at its sole discretion, from time to time. In respect of such additions, removals, conversions or amendments, VVWallet may, but is not obliged to, notify Users in advance and VVWallet shall have no liability to Users in connection with such additions, removals, conversions or amendments.VVWallet is an MPC wallet. Private key fragments are stored in fragments on the user side, VVWallet side, and third-party trusted provider’s side, thereby ensuring the isolation, security, and recoverability of private key fragments.

  3. Service Usage Guidelines

  3.1 License: Provided that you constantly comply with the Terms, VVWallet grants you a revocable, limited, royalty-free, non-exclusive, non-transferable, and non-sublicensable license to access and use VVWallet Offerings through your computer or internet compatible devices for your personal/internal purposes. The content layout, format, function and access rights regarding VVWallet Offerings should be stipulated in the discretion of VVWallet. VVWallet reserves all rights not expressly granted in these Terms. Therefore, you are hereby prohibited from using VVWallet Offerings in any way not expressly authorized by these Terms.

  These Terms only grant a limited license to access and use VVWallet Offerings. Therefore, you hereby agree that when you use VVWallet Offerings, VVWallet does not transfer VVWallet Offerings or the ownership of intellectual property rights of any VVWallet intellectual property to you or anyone else. All the text, graphics, user interfaces, visual interfaces, photos, sounds, process flow diagrams, computer code (including html code), programs, software, products, information and documents, as well as the design, structure, selection, coordination, expression, look and feel, and layout of any content included in the services or provided through VVWallet Offerings, are exclusively owned, controlled and/or licensed by VVWallet Operators or its members, parent companies, licensors or affiliates.

  VVWallet owns any feedback, suggestions, ideas, or other information or materials (hereinafter collectively referred to as “Feedback”) about VVWallet or VVWallet Offerings that you provide through email, VVWallet Offerings, or other ways. You hereby transfer all rights, ownership and interests of the Feedback and all related intellectual property rights to VVWallet. You have no right and hereby waive any request for acknowledgment or compensation based on any Feedback, or any modifications based on any Feedback.

  3.2 Restriction: When you use VVWallet Offerings, you agree and undertake to comply with the following provisions:

  (a) During the use of VVWallet Offerings, all activities you carry out should comply with the requirements of applicable laws and regulations, these Terms, and various guidelines of VVWallet;

  (b) your use of VVWallet Offerings should not violate public interests, public morals, or the legitimate interests of others, including any actions that would interfere with, disrupt, negatively affect, or prohibit other Users from using VVWallet Offerings;

  (c) without prior written consent from VVWallet, you may not modify, replicate, duplicate, copy, download, store, further transmit, disseminate, transfer, disassemble, broadcast, publish, remove or alter any copyright statement or label, or license; sub-license, sell, mirror, design, rent, lease, private label, grant security interests in the properties or any part of the properties; or create their derivative works or otherwise take advantage of any part of the properties;

  (d) you may not (i) use any deep linking, web crawlers, bots, spiders or other automatic devices, programs, scripts, algorithms or methods, or any similar or equivalent manual processes to access, obtain, copy or monitor any part of the properties, or replicate or bypass the navigational structure or presentation of VVWallet Offerings in any way, in order to obtain or attempt to obtain any materials, documents or information in any manner not purposely provided through VVWallet Offerings; (ii) attempt to access any part or function of the properties without authorization, or connect to VVWallet Offerings or any VVWallet servers or any other systems or networks of any VVWallet Offerings provided through the services by hacking, password mining or any other unlawful or prohibited means; (iii) probe, scan or test the vulnerabilities of VVWallet Offerings or any network connected to the properties, or violate any security or authentication measures on VVWallet Offerings or any network connected to VVWallet Offerings; (iv) reverse look-up, track or seek to track any information of any other Users or visitors of VVWallet Offerings; (v) take any actions that impose an unreasonable or disproportionately large load on the infrastructure of systems or networks of VVWallet Offerings or VVWallet, or the infrastructure of any systems or networks connected to VVWallet Offerings; (vi) use any devices, software or routine programs to interfere with the normal operation of VVWallet Offerings or any transactions on VVWallet Offerings, or any other person’s use of VVWallet Offerings; (vii) forge headers, impersonate, or otherwise manipulate identification, to disguise your identity or the origin of any messages or transmissions you send to VVWallet, or (viii) use VVWallet Offerings in an illegal way.

  By accessing VVWallet Offerings, you agree that VVWallet has the right to investigate any violation of these Terms, unilaterally determine whether you have violated these Terms, and take actions under relevant regulations without your consent or prior notice. Examples of such actions include, but are not limited to, (i) publishing the alleged violations and actions that have been taken; (ii) deleting any information you published that are found to be violations.

  3.3 Fiat Services: By accepting these Terms, you acknowledge and agree that:

  (a) you have read, accepted and will comply with these Terms, the Privacy Notice, and any other VVWallet Platform Rules related to Fiat Services;

  (b) VVWallet may partner with any Fiat Partners and that, if applicable, you will open an account with such Fiat Partners by completing the relevant registration and identity verification for such account, and by accepting any user agreements, terms and conditions, policies and procedures or similar documents of any Fiat Partners;

  (c) any payments expressed in any Fiat currencies and which have been made in connection with any Fiat Services may not be canceled, recalled or refunded, and that any chargeback requests in connection with any Fiat Services that involve a Fiat Partner, are subject to that Fiat Partner's policies and procedures.

  3.4 VVWallet OTC: If agreed with VVWallet, you may be permitted to receive certain over-the-counter (OTC) services with respect to bilateral transactions in Digital Assets, and such services shall be subject to the VVWallet OTC Terms. You agree to be bound by the VVWallet OTC Terms with respect to all OTC services provided to you through Agreed Communication Channels (as each term is defined in the VVWallet OTC Terms).

  4. Liabilities

  4.1 Disclaimer of Warranties: To the maximum extent permitted under applicable law, VVWallet Offerings, and any product, service or other item provided by or on behalf of VVWallet, are offered on an “as is” and “as available” basis, and VVWallet expressly disclaims, and you waive, any and all other warranties of any kind, whether express or implied, including, without limitation, warranties of merchantability, fitness for a particular purpose, title or non-infringement or warranties arising from course of performance, course of dealing or usage in trade. Without limiting the foregoing, VVWallet does not represent or warrant that the sites or VVWallet Offerings are accurate, complete, reliable, current, error-free, or free of viruses or other harmful components. VVWallet does not guarantee that any order will be executed, accepted, recorded or remain open. Except for the express statements, agreements and rules set forth in these Terms, you hereby acknowledge and agree that you have not relied upon any other statement or agreement, whether written or oral, with respect to your use and access of VVWallet Offerings. Without limiting the foregoing, you hereby understand and agree that VVWallet will not be liable for any losses or damages arising out of or relating to (a) any inaccuracy, defect or omission of Digital Assets price data; (b) any error or delay in the transmission of such data; (c) interruption in any such data; (d) regular or unscheduled maintenance carried out by VVWallet and service interruption and change resulting from such maintenance; (e) any damages incurred by other Users’ actions, omissions or violation of these Terms; (f) any damage caused by illegal actions of other third parties or actions without authorized by VVWallet; and (g) other exemptions mentioned in disclaimers and platform rules issued by VVWallet.

  4.2 Disclaimer of Damages and Limitation of Liability: To the maximum extent permitted by applicable law, in no event shall VVWallet, its affiliates and their respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers or contractors be liable for any incidental, indirect, special, punitive, consequential or similar damages or liabilities whatsoever (including, without limitation, damages for loss of data, information, revenue, profits or other businesses or financial benefits) arising out of VVWallet Offerings, any performance or non-performance of VVWallet Offerings, or any other product, service or other item provided by or on behalf of VVWallet and its affiliates, whether under contract, statute, strict liability or other theory even if VVWallet has been advised of the possibility of such damages except to the extent of a final judicial determination that such damages were a result of VVWallet’s gross negligence, fraud, willful misconduct or intentional violation of law. Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, so the above limitation may not apply to you.

  Notwithstanding the foregoing, in no event will the liability of VVWallet, its affiliates and their respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers or contractors arising out of services offered by or on behalf of VVWallet and its affiliates, any performance or non-performance of VVWallet Offerings, or any other product, service or other item, whether under contract, statute, strict liability or other theory, exceed the amount of the fees paid by you to VVWallet under these terms in the twelve-month period immediately preceding the event giving rise to the claim for liability.

  5. Indemnification

  You agree to indemnify and hold harmless VVWallet Operators, their affiliates, contractors, licensors, and their respective directors, officers, employees and agents from and against any claims, actions, proceedings, investigations, demands, suits, costs, expenses and damages (including attorneys’ fees, fines or penalties imposed by any regulatory authority) arising out of or related to (i) your use of, or conduct in connection with, VVWallet Offerings; (ii) your breach or our enforcement of these Terms; or (iii) your violation of any applicable law, regulation, or rights of any third party during your use of VVWallet Offerings. If you are obligated to indemnify VVWallet Operators, their affiliates, contractors, licensors, and their respective directors, officers, employees or agents pursuant to these Terms, VVWallet will have the right, in its sole discretion, to control any action or proceeding and to determine whether VVWallet wishes to settle, and if so, on what terms.

  6. Announcements

  All official announcements, news, promotions, competitions and airdrops will be listed on www.VVWallet.io. Users undertake to refer to these materials regularly and promptly. VVWallet will not be held liable or responsible in any manner of compensation should Users incur personal losses arising from ignorance or negligence of the announcements.

  7. No Financial Advice

  VVWallet is not your broker, intermediary, agent, or advisor and has no fiduciary relationship or obligation to you in connection with any trades or other decisions or activities affected by you using VVWallet Offerings. No communication or information provided to you by VVWallet is intended as, or shall be considered or construed as, investment advice, financial advice, trading advice, or any other sort of advice. Unless otherwise specified in these Terms, all trades are executed automatically, based on the parameters of your order instructions and in accordance with posted trade execution procedures, and you are solely responsible for determining whether any investment, investment strategy or related transaction is appropriate for you according to your personal investment objectives, financial circumstances and risk tolerance, and you shall be solely responsible for any loss or liability therefrom. You should consult legal or tax professionals regarding your specific situation. VVWallet does not recommend that any Digital Asset should be bought, earned, sold, or held by you. Before making the decision to buy, sell or hold any Digital Asset, you should conduct your own due diligence and consult your financial advisors prior to making any investment decision. VVWallet will not be held responsible for the decisions you make to buy, sell, or hold Digital Asset based on the information provided by VVWallet.

  8. Compliance with local laws

  It is your responsibility to abide by local laws in relation to the legal usage of VVWallet Offerings in their local jurisdiction as well as other laws and regulations applicable. You must also factor, to the extent of their local laws, all aspects of taxation, the withholding, collection, reporting and remittance to their appropriate tax authorities.

  9. Resolving Disputes

  9.1 Dispute and Claim: Any dispute or claim relating in any way to your use of VVWallet Offerings, or to any products or services sold or distributed by VVWallet shall be attempted to resolve internally and negotiate in good faith between both parties. In the event the dispute cannot be resolved satisfactorily, and you wish to assert a legal claim against VVWallet, then you agree to the exclusive jurisdiction in Hong Kong at the Council of the Hong Kong International Arbitration Centre (HKIAC). You agree to set forth the basis of your claim in writing in a “Notice of Claim” as prior notice to VVWallet. The Notice of Claim must (1) describe the nature and basis of the claim or dispute; (2) set forth the specific relief sought; (3) provide the original ticket number; and (4) include your VVWallet Account email. The Notice of Claim should be submitted to an email address or hyperlink provided in your correspondence with VVWallet. After you have provided the Notice of Claim to VVWallet, either VVWallet or you may submit the dispute referenced in the Notice of Claim to arbitration in accordance with what was aforementioned. For the avoidance of doubt, the submission of a dispute to VVWallet for resolution internally and the delivery of a Notice of Claim to VVWallet are prerequisites to commencement of an arbitration proceeding (or any other legal proceeding). During the arbitration, the amount of any settlement offer made by you or VVWallet shall not be disclosed to the arbitrator.

  9.2 Agreement to Arbitrate: You and VVWallet Operator agree that any dispute, claim, or controversy between you and VVWallet (and/or VVWallet Operators) arising in connection with or relating in any way to these Terms or to your relationship with VVWallet (and/or VVWallet Operators) must be determined by an Agreement to Arbitrate. All arbitrations are conducted in the English language. The arbitration shall be subject to the Council of the Hong Kong International Arbitration Centre (HKIAC) once the Agreement to Arbitrate is submitted. Unless the parties agree otherwise, there shall be only one arbitrator appointed in accordance with the HKIAC Rules. You and VVWallet Operators agree that the arbitrator shall have the exclusive power to rule on their own jurisdiction, including without limitation any objections with respect to the existence, scope or validity of the Agreement to Arbitrate, or to the arbitrability of any claim or counterclaim. In arbitration, there is no judge or jury, and court review of an arbitration award is limited. The arbitrator must follow this agreement and can award the same damages and relief as a court (including, if applicable, attorney fees), except that the arbitrator may not award declaratory or injunctive relief in favor of anyone but the parties to the arbitration. Regardless of the manner in which the arbitration is conducted, the arbitrator shall issue a reasoned written decision sufficient to explain the essential findings and conclusions on which the decision and award, if any, are based. The arbitration provisions set forth in this Section will survive termination of these Terms.

  9.2.1 Time: Any arbitration against VVWallet Operators must be commenced by filing a request for arbitration within one (1) year, after the date the party asserting the claim first knows or reasonably should know of the act, omission or default giving rise to the claim; and there shall be no right to any remedy for any claim not asserted within that time period. This one-year limitation period is inclusive of the internal dispute resolution procedure. There shall be no right to any remedy for any claim not asserted within that time period.

  If we request arbitration against you, we will give you notice at the email address or mailing address you have provided. You agree that any notice sent to this email or mailing address shall be deemed effective for all purposes, including without limitation to determinations of adequacy of service. It is your obligation to ensure that the email address and/or mailing address on file with VVWallet is up-to-date and accurate.

  9.2.2 Seat of Arbitration: The seat of the arbitration shall be Hong Kong.

  9.2.3 Place of Hearing: The location of any in-person arbitration hearing shall be Hong Kong, unless otherwise agreed to by the parties.

  9.2.4 Confidentiality: The parties agree that the arbitration shall be kept confidential. The existence of the arbitration, any nonpublic information provided in the arbitration, and any submissions, orders or awards made in the arbitration (together, the “Confidential Information”) shall not be disclosed to any non-party except the tribunal, the HKIAC, the parties, their counsel, experts, witnesses, accountants and auditors, insurers and reinsurers, and any other person necessary to the conduct of the arbitration. Notwithstanding the foregoing, a party may disclose Confidential Information to the extent that disclosure may be required to fulfill a legal duty, protect or pursue a legal right, or enforce or challenge an award in bona fide legal proceedings. This confidentiality provision shall survive termination of these Terms and of any arbitration brought pursuant to these Terms.

  9.3 Class Action Waiver: You and VVWallet agree that any claims relating to these Terms or to your relationship with VVWallet as a User of VVWallet Offerings (whether based in contract, tort, statute, fraud, misrepresentation, or any other legal theory, and whether the claims arise during or after the termination of these Terms) shall be brought against the other party in an arbitration on an individual basis only and not as a plaintiff or class member in a purported class or representative action. You and VVWallet further agree to waive any right for such claims to be brought, heard, or arbitrated as a class, collective, representative, or private attorney general action, to the extent permissible by applicable law. Combining or consolidating individual arbitrations into a single arbitration is not permitted without the consent of all parties, including VVWallet.

  9.4 Modifications: VVWallet reserves the right to update, modify, revise, suspend, or make any future changes to the parties’ Agreement to Arbitrate, subject to applicable law. You hereby consent and agree that it is your responsibility to ensure that your understanding of this Section is up to date. Subject to the applicable law, your continued use of your VVWallet account shall be deemed to be your acceptance of any modifications to the parties’ Agreement to Arbitrate. You agree that if you object to the modifications to Section 9, VVWallet may block access to your account pending closure of your account. In such circumstances, the Terms of Use prior to modification shall remain in full force and effect pending closure of your account.

  10. Miscellaneous

  10.1 Independent Parties: VVWallet is an independent contractor but not an agent of you in the performance of these Terms. These Terms shall not be interpreted as facts or evidence of an association, joint venture, partnership, or franchise between the parties.

  10.2 Entire Agreement: These Terms constitute the entire agreement between the parties regarding use of VVWallet Offerings and will supersede all prior written or oral agreements between the parties. No usage of trade or other regular practice or method of dealing between the parties will be used to modify, interpret, supplement, or alter the terms herein.

  10.3 Interpretation and Revision: VVWallet reserves the right to alter, revise, modify, and/or change these Terms at any time. All changes will take effect immediately upon being published on VVWallet websites. It is your responsibility to regularly check relevant pages on our websites/applications to confirm the latest version of these Terms. If you do not agree to any such modifications, your only remedy is to terminate your usage of VVWallet Offerings and cancel your account. You agree that, unless otherwise expressly provided in these Terms, VVWallet will not be responsible for any modification or termination of VVWallet Offerings by you or any third party, or suspension or termination of your access to VVWallet Offerings.

  10.4 Language: All communications and notices made or given pursuant to these Terms of Use must be in the English language. If we provide a translation of the English language version of these Terms of Use, the English language version of the Terms of Use shall control if there is any conflict.

  10.5 Force Majeure: We and our affiliates shall not be liable for any delay or failure to perform any obligation under these Terms of Use where the delay or failure results from any cause beyond our reasonable control, including acts of God, labor disputes or other industrial disturbances, electrical or power outages, utilities or other telecommunications failures, earthquake, storms or other elements of nature, blockages, embargoes, riots, acts or orders of government, acts of terrorism, or war.

  10.6 Severability: If any portion of these Terms of Use is held to be invalid or unenforceable, the remaining portions of these Terms of Use shall remain in full force and effect. Any invalid or unenforceable portions shall be interpreted to effect and intent of the original portion. If such construction is not possible, the invalid or unenforceable portion shall be severed from these Terms of Use, but the rest of these Terms of Use shall remain in full force and effect.

  10.7 Assignment: You shall not assign or otherwise transfer these Terms of Use or any of your rights and obligations under these Terms of Use, without our prior written consent. We may assign these Terms of Use without your consent (a) in connection with a merger, acquisition or sale of all or substantially all of our assets, or (b) to any affiliate or as part of a corporate reorganization; and effective upon such assignment, the assignee is deemed substituted for VVWallet as a party to these Terms of Use and VVWallet is fully released from all of its obligations and duties to perform under tthese Terms of Use. Subject to the foregoing, these Terms of Use shall be binding upon, and inure to the benefit of the parties and their respective permitted successors and assigns.

  10.8 No Waivers: The failure by us to enforce any provision of these Terms of Use shall not constitute a present or future waiver of such provision nor limit our right to enforce such provision at a later time. All waivers by us must be in writing to be effective.

  10.9 Third-Party Website Disclaimer: Any links to third-party websites from VVWallet Offerings does not imply endorsement by VVWallet of any product, service, information or disclaimer presented therein, nor does VVWallet guarantee the accuracy of the information contained on them. If you suffer loss from using such third-party product and service, VVWallet will not be liable for such loss. In addition, since VVWallet has no control over the terms of use or privacy notices of third-party websites, you should read and understand those policies carefully.

  10.10 Matters Related to Apple Inc.: If you use any device manufactured by Apple Inc. to participate in any commercial activities or reward programs through VVWallet Offerings, such activities and programs are provided by VVWallet and are not associated with Apple Inc. in any manner.

11.1 These are the Anti-Money Laundering (AML) Policy and Procedures adopted by VVWallet’s internal policies and regulatory obligations and the business will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities. We use your personal information as we believe necessary or appropriate to comply with applicable laws (including anti-money laundering (AML) laws and know-your-customer (KYC) requirements), lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

To these ends:

The identities of all new and existing customers will be verified to a reasonable level of certainty;

  • A risk-based approach will be taken to the monitoring of client tax and accounting affairs;

  • Any suspicious activity will be reported, and all AML activities recorded;

  • Any suspicious, large and frequent transactions will be manually reviewed by risk control and audit department;

  • Separate duties and independent audits will be established internally to ensure that there will be no corruption within the company;

  • All staff that meet or contact customers and potential customers of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting customers;

11.2 CUSTOMER DUE DILIGENCE

The business has established know-your-customer (KYC) policies for system pre-test and customer follow-up reviews to ensure that the identities of all new and existing users are verified to a reasonable level of certainty. This will include that all user identities will be verified through an online system or face-to-face or a combination of both. Any government issued document that provides the date of birth, NI or Tax number or other such government identifier.

Note* This part of the KYC review may be completed by a cooperative payment company with equivalent capabilities.

Any government-issued proof of income document that requires a date of birth or tax ID number or proof of income or other such government identifier for any suspicious, frequent, large-value transactions, not limited to other forms of identification, such as the source of funds for certain users; User's historical consumption records; Bank Account Proof of User Entity, etc.

If VVWallet fails to verify a user's identity with reasonable certainty, it will not enter a business relationship or conduct a transaction. If a potential or existing customer refuse to provide the above information, or appears to have knowingly provided misleading information, the business should refuse to enter a business relationship or proceed with the requested transaction. Other forms of identity confirmation, such as evidence of a long-standing relationship with the customer, or a letter of assurance from independent and reliable persons or organizations, who have dealt with the client for some time, may also provide a reasonable level of certainty.

11.3 RISK ASSESSMENT AND ONGOING MONITORING

The business shall take a risk-based approach in monitoring the financial activities of its customers.

The business will actively not accept high-risk customers that are identified as follows:

Customers with businesses that handle large amount of cash exceed the payment provider's limit (i.e. involving more per transaction, or the sterling equivalent) or complex unusually large transactions.

Customers with complex business ownership structures with the potential to conceal underlying beneficiaries.

Customers based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organized crime, or drug production/distribution.

Situations where the source of funds cannot be easily verified.

Unusual patterns of transactions that have no apparent economic or visible lawful purpose.

Money sent to or received from areas known to have high levels of criminality or terrorist activity.

The business will conduct ongoing monitoring of business relationships with customers, to ensure that the documents or information held evidencing the customer’s identity are kept up to date.

Whenever there is cause for suspicion, the customer will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.

11.4 INTERNAL CONTROLS AND COMMUNICATION

When some reviews are unclear, the VVWallet’s inspections will be carried out in turn through operations, risk control, and auditing.

11.5 MONITORING AND MANAGING COMPLIANCE

The business will regularly monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of the business:

Client identity verification;

Reporting suspicious transactions;

Record keeping.

The business will also monitor any developments in the business and the requirements of the business supervisory body. Changes will be made to the AML policies and procedures of the business when appropriate to ensure compliance.

11.6 SUSPICIOUS ACTIVITY REPORTING

A Suspicious Activity Report (SAR) will be made to the relevant authority as soon as the knowledge or suspicion that criminal proceeds exist arises.

The business will be responsible for deciding whether the suspicion of illegal activity is great enough to justify the submission of a SAR.

  12. Definitions

  • “Digital Assets” refer to Digital Currencies, their derivatives or other types of digitalized assets with a certain value.

  • “Digital Currencies” refer to encrypted or digital tokens or cryptocurrencies with a certain value that are based on blockchain and cryptography technologies and are issued and managed in a decentralized form.

  • “Fiat Partner” means any third party service provider, with which VVWallet may partner in connection with any Fiat Services.

  • “Fiat Services” means (a) crediting your VVWallet Fiat Account with one or more Fiat currencies either via a bank transfer, or with your debit card or credit card; (b) purchasing Digital Assets at spot prices with one or more Fiat currencies by using either your VVWallet Fiat Account balance, or your debit card or credit card; (c) selling Digital Assets at spot prices for Fiat currencies and crediting the corresponding proceeds of sale either to your VVWallet Fiat Account, or to your debit card or credit card; (d) withdrawing one or more Fiat currencies from your VVWallet Fiat Account either into your bank account, or to your debit card or credit card.

  • “Users” refer to all individuals, institutions or organizations that access, download or use VVWallet or VVWallet Offerings and who meet the criteria and conditions stipulated by VVWallet. If there exist other agreements for such entities as developers, distributors, market makers, and Digital Currencies exchanges, such agreements shall be followed.

  • “VVWallet” refers to an ecosystem comprising VVWallet websites, mobile applications, clients, applets and other applications that are developed to offer VVWallet Offerings.

  • “VVWallet Accounts” refer to the foundational virtual accounts, including main accounts and subaccounts, which are opened by VVWallet for Users to record on VVWallet their usage of VVWallet Offerings, transactions, asset changes and basic information. VVWallet Accounts serve as the basis for Users to enjoy and exercise their rights on VVWallet.

  • “VVWallet Platform Rules” refer to all rules, interpretations, announcements, statements, letters of consent and other contents that have been and will be subsequently released by VVWallet, as well as all regulations, implementation rules, product process descriptions, and announcements published within products or service processes.

  • “VVWallet Offerings” refer to various services provided to you by VVWallet that are based on Internet and/or blockchain technologies and offered via VVWallet websites, mobile applications, clients and other forms (including new ones enabled by future technological development). VVWallet Offerings include but are not limited to such VVWallet ecosystem components as wallet service, Digital Asset Trading Platforms, the financing sector, VVWallet Fiat Gateway, and novel services to be provided by VVWallet.

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