Term of service

Terms of service

1. ELIGIBILITY

To be eligible for any ONFA Services, you must be at least 18 years old and reside in the country where the relevant ONFA Services are accessible. Please note that not all ONFA Services are available in every country.

2. SERVICES

2.1 Digital Asset Services

The following services ("Digital Asset Services") may be provided to you by ONFA:

A Digital Asset Wallet ("Digital Asset Wallet") enables you to store, monitor, transfer, and manage balances of various supported Digital Assets such as Bitcoin or Ethereum, etc. (collectively, "Digital Assets");

The Digital Assets redemption service allows you to select prices for the conversion (purchase and sale) of various types of Digital Assets and (subject to certain restrictions) to perform such redemptions on the ONFA App ("Digital Asset Exchange Service").

2.2 Additional Services.

In addition to core services (i.e., Digital Asset Services), ONFA may provide the following services ("Additional Services"), such as P2P, daily staking, Credit Line, Secured Trading Guarantee, Farming, Launchpad, etc.

2.3 Service fees ("Fees").

You agree to be responsible for and to pay all fees associated with use of the service.

3. SET UP AN ACCOUNT

3.1 Register for an ONFA account

To use the ONFA Services, you must register for an ONFA account ("ONFA Account") by providing your details, including your name, email address, and password, and by accepting the terms of this Agreement.

By using an ONFA Account, you agree and represent that you will use the ONFA Services only for yourself. Each customer is permitted to register only one ONFA account. You are solely responsible for all activity that occurs in your ONFA Account.

We may, at our sole discretion, refuse to open an ONFA Account for you, or suspend or terminate any ONFA Account (including, but not limited to, duplicate accounts), or suspend or terminate transactions of specific Digital Assets in your account.

3.2 Identity verification

You agree to provide us with the information we request (which we may request from time to time as we deem necessary) for identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime, including as described in Schedule 2 (Verification Procedures and Limits), and to permit us to retain such information.

You will need to complete specific verification procedures before you can begin using the ONFA Services and access certain ONFA Services, including specific redemptions of Digital Assets. The limits applicable to your use of the ONFA Services may change as information is continuously collected.

The information we request may include (but is not limited to) personal data such as name, residential address, phone number, email address, date of birth, taxpayer identification number, national identification number, information related to your bank account (such as bank name, account type, routing number and account number), network status, customer type, customer role, payment type, mobile device identifiers (e.g., International Mobile Subscriber Identity and International Mobile Equipment Identity) and other subscriber status details, and any such information that ONFA is required to collect from time to time under applicable law.

You may also be required to undergo an "Advanced Due Diligence" process, whereby ONFA may request additional information about you or your business, require relevant documentation, and arrange meetings with staff so that ONFA may obtain information about the source of your Assets and the source of Assets for any transactions undertaken during your use of the ONFA Services.

By providing us with this information or any other information that may be requested, you acknowledge that such information is true, accurate, and complete and that you will not withhold any information that may affect ONFA's assessment of an application for an ONFA Account or the provision of ONFA Services to you. You undertake to promptly notify ONFA in writing and provide ONFA with information regarding any changes that may render any previously provided information false, inaccurate, or incomplete. You agree to provide any documents, records, and other additional information as may be required by ONFA and/or applicable law. You authorize us to retain records of such information. We will process this information in accordance with the Data Protection Section.

You authorize us to make requests, directly or through third parties, that we deem necessary to verify your identity or to protect you and/or us against fraud or other financial crime, and to take such actions as we reasonably consider necessary to make inquiries. When we make these requests, you acknowledge and agree that your personal information may be disclosed to fraud or financial crime law enforcement agencies to the extent required to satisfy our requests. Additionally, we may require you to wait for a period following the completion of a transaction before permitting further use of the ONFA Services and/or before permitting you to carry out transactions exceeding certain volume limits.

4. DIGITAL ASSET SERVICES

4.1 General

Your Digital Asset Wallet allows you to send Digital Assets to, request, receive, and store Digital Assets from other users or third parties outside of the ONFA Platform by submitting orders through the ONFA App (each such transaction is a "Digital Asset Transaction").

The Digital Assets Exchange Service allows you to trade and exchange Digital Assets on the ONFA Platform; ONFA facilitates and enables the trading and exchange of Digital Assets among its customers on the ONFA Platform.

4.2 Execution of Transactions

We will use reasonable efforts to execute all transactions (buy/sell) and exchanges of Digital Assets, but in some cases we may not be able to do so. If that occurs, we will notify you and obtain your consent to attempt redemption at the current Exchange Rate (as defined below).

4.3 Exchange rate

Each conversion (purchase or sale) of a Digital Asset is subject to the Exchange Rate applicable to that transaction. "Exchange Rate" means the price of a supported Digital Asset expressed in units of Fiat as quoted on the ONFA App. The Exchange Rate is EXPRESSED as a "Buy Price" or an "Ask Price", which is the price at which you can purchase or sell the respective Digital Asset.

You acknowledge that the Exchange Rate for the Purchase Price may differ from the Exchange Rate for the Sale Price at any time and that we may add an Asset Differential to the quoted Exchange Rate. By agreeing to execute a transaction, you accept the Exchange Rate applicable to that transaction. We do not guarantee the availability of any particular Exchange Rates. We do not guarantee that you will be able to trade (buy and/or sell) your Digital Assets on the open market at any price or at any specific time.

4.4 Approval of transactions; Reverse the transaction; Cancel the transaction

By clicking the 'Buy' or 'Sell' button on the ONFA App, you authorize ONFA to initiate a transaction at the Quoted Bid or Ask Price and agree to any associated fees and other charges.

You may not cancel, reverse, or modify transactions marked as complete or pending. If your payment fails or your payment method lacks sufficient Digital Assets, you authorize us, at our sole discretion, to cancel the transaction or to deduct Assets from your other payment methods to complete the transaction. It is your responsibility to maintain an adequate balance and/or sufficient Digital Assets or fee allowances. ONFA reserves the right to suspend access to the ONFA Services until any outstanding Digital Assets are settled.

4.5 Trading Digital Assets

We will process Digital Asset Transactions according to the instructions we receive from you. You must verify all transaction information before providing instructions. We do not guarantee the identity of any user, recipient, authorized person, or other third party, and we have no obligation or responsibility to ensure that the information you provide is accurate or complete.

Digital Asset transactions are irreversible once submitted to the respective Digital Asset network. If you execute a Digital Asset Transaction by entering the recipient's email address and the recipient does not have an ONFA Account, we will invite the recipient to open an ONFA Account. If the recipient does not open an ONFA Account within 30 days, we will return the relevant Digital Asset units to your Digital Asset Wallet.

We may charge a network fee to process Digital Asset Transactions on your behalf. We will charge the network fee at our discretion but will inform you of the network fee when you approve the Digital Asset Transaction or beforehand. The network fee for each transaction will be displayed on the payment page at the time of payment. When you or a third party deposits Digital Assets from an external wallet not part of ONFA into the ONFA Digital Asset Wallet, the person conducting the transaction is responsible for proper execution of the transaction, including payment of network fees, providing sufficient gas for transactions to be completed, and related matters. Failure to pay network fees may result in your transaction being held pending beyond ONFA's control; we are not responsible for delays or losses arising from execution errors, and we are not obligated to assist in the recovery of such erroneous transactions.

Once a Digital Asset Transaction is submitted to the Digital Asset network, the transaction will remain unconfirmed until the Digital Asset network confirms it. A pending Digital Asset transaction means that the transaction has not been completed. The transaction identifier associated with a pending Digital Asset Transaction will be marked as pending and will not be added to your Digital Asset Wallet balance and will not be available to execute Digital Asset Transactions until the network confirms the transaction.

We may also refuse to process or cancel any pending Digital Asset Transactions as required by law, regulation, or any court or authority to which ONFA is subject in any jurisdiction, for example, in cases of suspected money laundering, terrorist financing, fraud, or any other financial offense.

4.6 Types of Digital Assets Supported

Our Digital Asset Service applies only to types of Digital Assets supported by ONFA ("Supported Digital Asset Types"). Supported types may change over time.

Under no circumstances should you use your Digital Asset Wallet to store, send, request, or receive Digital Assets in ways we do not support. We are not responsible or liable for use of your Digital Asset Wallet for types of Digital Assets that we do not support. You acknowledge and agree that ONFA is not responsible or liable for any unsupported assets sent to the wallet associated with your ONFA Account.

4.7 Stop supporting a type of Digital Asset

At ONFA's sole discretion, ONFA may discontinue support for any Digital Asset. ONFA will notify you at least two days in advance (unless applicable law or a regulatory authority requires a shorter notice period) at the email address associated with your ONFA Account or by posting a notice on the ONFA App or Website. If you do not sell or withdraw such Digital Assets from the platform during this period, ONFA reserves the right to remove such Digital Assets from your account and credit your ONFA Account with the market value of a supported Digital Asset (price to be determined at our reasonable discretion).

4.8 Operation of Digital Asset protocols

We do not own or control the underlying software protocols that govern the operation of the types of Digital Assets supported on our platform. Generally, the underlying protocols are "open source," and anyone may use, copy, modify, and distribute them.

We are not responsible for the operation of the underlying protocols and cannot guarantee the functionality or security of network operations. You acknowledge and accept the risk that the underlying software protocols related to any type of Digital Asset held in your Digital Asset Wallet may change.

In particular, the underlying protocols may be subject to sudden changes in operational rules (including "forks"). Any such significant operational change could materially affect the availability, value, functionality, and/or name of the type of Digital Asset contained in your Digital Asset Wallet. ONFA has no control over the timing or nature of these significant operational changes. You should remain aware of upcoming operational changes and carefully review public information that ONFA may provide to determine whether to continue transacting in the affected Digital Asset with your ONFA Account. In the event of any such operational change, ONFA reserves the right to take necessary steps to protect the security and safety of assets held on the ONFA Platform, including temporarily suspending operations for the affected type(s) of Digital Assets and taking other necessary measures; ONFA will use its best efforts to notify you of ONFA's response to material operational changes; however, such changes are beyond ONFA's control and may occur without prior notice to ONFA. ONFA's response to any material operational changes is at ONFA's sole discretion and may include a decision not to support any new Digital Assets, forks, or other divergent actions.

You acknowledge and accept the risk of operational changes to Digital Asset protocols and agree that ONFA is not responsible for such functional changes and is not liable for any loss in value you may experience as a result of those rule changes. You acknowledge and accept that ONFA has sole discretion to respond to any operational changes and that ONFA is not responsible for assisting you with unsupported protocols, assets, or currencies.

4.9 Latency of storing and transferring Digital Assets

ONFA stores Digital Asset private keys securely using a combination of online and offline storage. Our security protocols may delay the execution or crediting of a Digital Asset Transaction.

4.10 Third-party payments

We have no control over and are not responsible for the distribution, quality, safety, legality, or any other aspect of any goods or services you buy, receive, sell, or transfer to any third party (including other users of the Digital Asset Service). We are not responsible for ensuring that a third-party buyer or seller you deal with will complete or is authorized to complete a transaction. If you have a problem with goods or services purchased from or sold to a third party using Digital Assets transferred via the Digital Asset Services, or if you have a dispute with such third party, you must resolve the dispute directly with that third party.

If you believe a third party has acted fraudulently, deceptively, or otherwise inappropriately, or if you cannot satisfactorily resolve a dispute with a third party, you may notify ONFA support at: https://t.me/OnfaSupport so that we can assess how to address the matter.

4.11 Digital Asset Ownership

All types of Digital Assets held in your Digital Asset Wallet are held by ONFA on a custody basis for you. This means:

(A) Ownership of the Digital Assets remains with you at all times. As the owner of the Digital Assets in your Digital Asset Wallet, you bear all risk of loss of such Digital Assets. ONFA accepts no liability for fluctuations in the value of Digital Assets held in your Digital Asset Wallet.

(B) None of the Digital Assets in your Digital Asset Wallet are the property of ONFA or may be used by ONFA for lending; ONFA does not represent the assets in a user's Digital Asset Wallet as ONFA's property. ONFA will not grant security over Digital Assets held in your Digital Asset Wallet. Except where required by a legally enforceable court order, a valid request by a law enforcement agency, or as otherwise provided herein, ONFA will not sell, transfer, lend, mortgage, or otherwise dispose of Digital Assets in your Digital Asset Wallet unless requested by you or required to do so by a court or law enforcement agency.

(C) You control the Digital Assets in your Digital Asset Wallet. You may withdraw your Digital Assets at any time by sending them to another blockchain address controlled by you or by a third party, subject to any platform downtime and other applicable policies.

(D) To hold customers' Digital Assets more securely, ONFA may use shared blockchain addresses to hold Digital Assets on behalf of customers and/or on behalf of ONFA. Customers' Digital Assets are segregated from ONFA's own Digital Assets by maintaining separate ledgers for customer and ONFA accounts. Notwithstanding this, ONFA is not obligated to use separate blockchain addresses to hold Digital Assets owned by you and Digital Assets owned by other customers or by ONFA.

ONFA is under no obligation to issue any replacement Digital Asset in the event that any Digital Asset, password, or private key is lost, stolen, malfunctions, destroyed, or becomes inaccessible.

5. TRADE LIMITS AND ENHANCED ASSESSMENTS

5.1 Transaction limit

Use of all ONFA Services is subject to limits on the volume you may trade or transfer within a specified period (e.g., daily). See Appendix 2 (Verification and Limitation Process) for more details. To view your limits, log in to your ONFA Account. Your transaction limits may vary depending on the verification steps you have completed and other factors. We reserve the right to change applicable limits as we deem necessary. If you wish to increase your limit beyond what is displayed, you may submit a request at https://t.me/OnfaSupport

5.2 Advanced due diligence

We may request that you provide additional information about yourself or your business, supply documentation, and arrange a meeting with ONFA personnel if you wish to increase your limit ("Advanced Due Diligence"). We reserve the right to charge you for costs and fees associated with such Advanced Due Diligence. If we intend to charge you, we will notify you in advance so you can decide whether to proceed with the request to increase your limit. At our discretion, we may refuse to increase your limit or may reduce your limit at a later time, even if you have completed Advanced Due Diligence.

6. SUSPENSION, TERMINATION, AND CANCELLATION

6.1 Suspension, Termination, and Cancellation

We may: (a) refuse to complete, hold, block, cancel, or reverse a transaction you authorized (even after the Assets have been credited to your ONFA Account); (b) suspend, restrict, or terminate your right to use any or all of the ONFA Services; and/or (c) deactivate or cancel your ONFA Account, and such actions may be effective immediately for any reason, including but not limited to the following:

(A) we reasonably believe such action is necessary to protect ONFA's reputation;

(B) we are required to do so by applicable law, regulation, or order of any court or competent authority to which we are subject in any jurisdiction;

(C) we have reasonable grounds to suspect that you have breached this Agreement;

(D) we suspect you have violated our 'Prohibited Use, Prohibited Business and Conditional Use Policy' (as set forth in Exhibit 1);

(E) we have concerns that a transaction was executed in error, have concerns regarding the security of your ONFA Account, or suspect that the ONFA Service is being used fraudulently or for illegal purposes;

(F) we suspect money laundering, terrorist financing, fraud, or any other financial offense;

(G) your use of the ONFA Account is subject to pending litigation, investigation, or governmental action and/or we perceive a high risk of non-compliance with law or regulation in connection with the operation of your ONFA Account; and/or

(H) you take any action that may affect our control, such as opening multiple ONFA Accounts or abusing our incentive or support programs.

We may also refuse to complete, block, cancel, or reverse a transaction you authorized where there are insufficient Digital Assets in your Digital Asset Wallet and/or an insufficient number of Digital Assets in your Digital Asset Wallet to pay for the transaction and associated fees (if any).

6.2 If we refuse to complete a transaction and/or suspend, restrict, or close your ONFA Account and/or terminate your use of the ONFA Service, we reserve the right to terminate your account without prior notice if you have violated company policies. Additionally, where appropriate, we will inform you of the error-correction procedure that led to the refusal, suspension, or closure of your ONFA Account. In the event we refuse to complete a suspension and/or closure, we will lift the suspension or complete the transaction as soon as practicable once the reasons for the refusal and/or suspension no longer exist. However, we are under no obligation to restore a transaction at the same price or under the same terms as a transaction that has been suspended, reversed, or aborted.

We may suspend, limit, or terminate your right to use any or all of the ONFA Services and/or deactivate or cancel your ONFA Account without cause. You acknowledge that our actions, including restricting access, suspending, or closing your ONFA Account, may be based on security criteria necessary for our security and risk management protocols. You agree that ONFA is under no obligation to disclose the details of its security and risk management processes to you.

6.3 Consequences of Termination or Suspension

Upon termination of this Agreement for any reason, except where prohibited by applicable law or by any court order to which ONFA is subject in any jurisdiction, you will have access to your ONFA Account:

(A) for ninety (90) days thereafter to transfer Digital Assets out of your Digital Asset Wallet and/or out of the ONFA Platform; and/or

(B) at any time within a period of ninety (90) days from the date of termination of this Agreement to move Digital Assets out of your Digital Asset Wallet and/or out of the ONFA Platform.

You are not permitted to use the ONFA Services or your ONFA Account for any other purpose during this period, and we may, at our sole discretion, limit the functionality of the ONFA Platform or your access to the ONFA Platform.

If we suspend or close your ONFA Account or terminate your use of the ONFA Services for any reason, we reserve the right to require you to undergo the procedures set forth in Section 3.2 (Identity verification) again before permitting you to transfer or withdraw Digital Assets.

7. LEGAL RESPONSIBILITIES

7.1 Exemption for ONFA

If you have a dispute with one or more users of the ONFA Services (other than ONFA), you agree that neither we nor our affiliates, service providers, officers, directors, agents, joint ventures, employees, nor representatives will be liable for any claims, demands, or damages (actual or consequential, direct or indirect) of any kind arising from such dispute.

7.2 Compensation

You agree to indemnify us, our affiliates and service providers, and each of our respective officers, directors, agents, employees, and representatives, and any of our service providers, for any costs (including attorneys' fees and any fines, fees, or penalties imposed by any regulatory authority) reasonably incurred in connection with any claim, demand or damage arising from your breach and/or our entry into this Agreement (including but not limited to your breach of the 'Prohibited Use Policy', Prohibited Business, and 'Conditional Use' (as set forth in Exhibit 1)) or your violation of any law, rule, or regulation, or the rights of any third party.

7.3 Limitation of Liability

ONFA's aggregate liability to you for any single claim or series of related claims for loss, expense, liability, or cost you may incur as a result of or in connection with any breach of this Agreement by ONFA shall be limited to the total value of the Digital Assets in your Digital Asset Wallet at the time of the breach attributable to ONFA. In the case of processing a specific request in relation to a particular transaction, that liability shall be limited to the corresponding amount of the Transactional Assets (buy/sell) involved in that transaction.

7.4 Loss limit

In addition to the limitation of liability in Section 7.3 above, in no event shall we, our affiliates, service providers, or any officers, directors, agents, managers, employees, or representatives of our affiliates or service providers, or of us, be liable for any of the following losses or damages arising out of or in connection with this Agreement or otherwise:

(A) any loss of profit or loss of anticipated revenue or profit, including any loss of expected trading profit and/or any actual or hypothetical trading loss, whether direct or indirect, even if we were notified or made aware in advance of the possibility of such loss. This means that if you claim we failed to properly process a Digital Asset Transaction, your damages will be limited to no more than the total value of the Digital Assets involved in the transaction, and you may not recover expected trading profit or actual trading losses resulting from failure to buy or sell Digital Assets (this example is not limited to the foregoing).

(B) any loss of reputation; any loss of business or loss of opportunities, customers, or contracts; any overhead, administrative costs or time of other employees; or any other actual or expected loss of revenue or savings, direct or indirect, even if we had been advised of or were aware of the possibility of such loss; any loss of use of hardware, software or data and/or any data corruption; including but not limited to any loss or damage arising out of or in connection with inaccuracies, errors or omissions in Digital Asset price data; any errors or delays in transmission of such data; and/or any interruption to such data; and

(C) any loss or damage not directly arising from our breach of this Agreement (whether or not you can prove such loss or damage).

7.5 Applicable Law

The limitation of liability in this Section 7 is subject to any obligations we may have under applicable laws and regulations, including the duty to exercise due care and reasonable skill when providing the ONFA Service. Nothing in this Agreement shall limit our liability in cases of fraud or misrepresentation, gross negligence, willful misconduct, death, or personal injury caused by the negligence of us or our subcontractors.

7.6 No warranties are given

ONFA Services, the ONFA Platform, and the ONFA App are provided on an "as is" and "as available" basis. We make no further guarantees regarding the availability of ONFA Services. In particular, we make no implied warranties of title, merchantability, fitness for a particular purpose, or non-infringement. We do not warrant that access to the ONFA Platform, any ONFA Services, or any materials on the ONFA platform will be continuous, uninterrupted, timely, or error-free.

We make no representations regarding the accuracy, timeliness, or completeness of Digital Asset pricing data available on the ONFA App or Website. Any materials, information, views, opinions, projections, or estimates presented on the ONFA App or Website are provided by ONFA for informational purposes only and are subject to change without notice. You must assess for yourself the relevance, timeliness, accuracy, completeness, commercial value, and reliability of the materials, information, opinions, projections, or estimates on the ONFA App or Website. Accordingly, ONFA makes no warranties and accepts no liability for any loss arising directly or indirectly from your reliance on any documents, information, opinions, projections, or estimates provided or made available through the ONFA App or Website.

ONFA Services, the ONFA Platform, and the ONFA App and Website are not intended to provide specific investment, tax, or legal advice, nor to recommend the suitability of any investment or product for any particular investor. You should seek independent financial, legal, regulatory, tax, or other professional advice before making any investment. If you choose not to seek advice from an appropriate advisor, you should consider whether the investment or product is suitable for you.

We will use reasonable efforts to ensure that Digital Asset Transactions and requests related to Digital Asset Wallets are processed promptly, but ONFA makes no representations or warranties regarding the time required for processing. Completion depends on many factors beyond our control. We will use reasonable efforts to ensure timely processing of requests on the ONFA platform, but we do not guarantee specific processing times; such times depend on many factors beyond our control.

Except for the express statements set forth in this Agreement, you acknowledge and agree that you do not rely on any other statement or understanding, whether written or oral, regarding the use of the ONFA Services, App, or Website when using or accessing them.

7.7 No liability for disruptions

We are not liable for any breach of this Agreement, including delays, non-performance, or service interruptions, arising directly or indirectly from unusual circumstances and unforeseeable events beyond our control, the consequences of which are unavoidable, nor shall we be liable if application of mandatory legal rules causes such breach.

8. APPLICABILITY AND ACCURACY OF THE ONFA APP, SITE

8.1 Accessibility & Availability

Access to the ONFA Service may be reduced or unavailable during periods of high trading volume or significant volatility. This may result in restrictions on access to your ONFA Account or ONFA Services, including inability to execute or complete transactions, and may cause delays in customer support responses.

(A) although we strive to provide optimal service, we do not guarantee that the ONFA App, Website, or other ONFA Services will be available without interruption, and we do not guarantee that any of your ONFA Accounts will be accepted, credited, remain open, or be accessible at all times; and

(B) please be aware that our customer support response times may be slow, particularly during periods of high volume or significant volatility, especially with respect to reliability and security inquiries. Under no circumstances will ONFA be liable for any alleged damages arising from service interruptions, transaction processing delays, or lack of timely response from ONFA customer support.

8.2 Accuracy of ONFA App, Website

While we aim to provide accurate and timely information on the ONFA App and Website, the ONFA App and Website (including but not limited to ONFA App content) are not always completely accurate, complete, or up to date and may contain technical or typographical errors.

To provide you with the most complete and accurate information possible, to the extent permitted by applicable law, information may be changed or updated from time to time without notice, including but not limited to information about our policies, products, and services. Accordingly, you should verify all information before relying on it, and any decisions based on information contained on the ONFA App or Website are solely your responsibility. We shall not be liable for decisions made on that basis.

Links to third-party materials (including but not limited to third-party apps or websites) may be provided for convenience only and are not controlled by us. You acknowledge and agree that we are not responsible for any aspect of the information, content, or services contained in third-party materials accessible from or linked to the ONFA App or Website.

9. CUSTOMER FEEDBACK, INQUIRIES, COMPLAINTS, AND DISPUTE RESOLUTION

9.1 Contacting ONFA

If you have any feedback, questions, or complaints, contact us via our Customer Support page at https://t.me/OnfaSupport.

When contacting us, please provide your name, email address, and any other information we may need to identify you, your ONFA Account, and the transaction to which your feedback, question, or complaint relates.

9.2 Complaints

If you have a dispute with ONFA, you agree to contact our support team first to attempt to resolve the dispute. If we are unable to resolve the dispute through the support team, you and we agree to use the complaints process set out in this Section 9.2. You agree to use this process before pursuing any of the actions set out in Section 9.4. If you do not follow the procedures in this Section 9.2 before taking actions under Section 9.4, we reserve the right to request a court or authority to dismiss your action or application unless and until you complete the following steps:

If the complaint has not been resolved through contact with ONFA Support, please use our complaint form to specify the cause of the complaint, how you would like us to resolve it, and any other relevant information. You can find the complaint form on ONFA support pages, https://t.me/OnfaSupport, or you can request it from ONFA Customer Support. We will acknowledge receipt of your complaint form upon submission. A customer complaints officer ("Officer") will review your complaint. This Officer will evaluate your complaint based on the information you provided and any information provided by ONFA.

Within 15 business days of our receipt of your complaint, the Officer will address all issues raised in your complaint by emailing you a "Notice of Resolution", in which the Officer will: (i) offer to resolve your complaint in the manner you requested; (ii) decide to deny your claim and state the reasons for the denial; or (iii) offer to resolve your claim by alternative means. Under certain circumstances, if the Officer is unable to respond within 15 business days, the Officer will (unless prohibited by applicable law) send you a provisional response explaining the reason for the delay and specifying a timeframe for a full response (no later than 35 business days from our receipt of your complaint).

Any settlement offer we make to you will become binding on us only if you accept it. Our settlement offer shall not constitute an admission of wrongdoing or liability on our part in connection with the claim.

9.3 If we are unable to resolve your complaint through the complaints process set out in Section 9.2 above, you may bring your complaint through the dispute processes set out in Section 9.4 below, as applicable to you.

9.4 Both you and we agree not to commence any dispute process described in Section 9.4 below in relation to all or part of your claim until the procedures in Section 9.2 have been completed. However, Sections 9.2 and 9.4 do not prevent either party from seeking interim relief from a court of competent jurisdiction. For claims or disputes arising out of or in connection with this Agreement or the provision of the ONFA Services, the ONFA Platform, or the ONFA App and Website that cannot be resolved through the complaints process in Section 9.2 above, you may bring proceedings against ONFA in the courts of Singapore that have consumer jurisdiction.

10. DATA PROTECTION

You acknowledge that we may process personal data relating to you (if you are an individual) and personal data you provide (or provide in the future) to us concerning your personnel and other associates, or other individuals (if you are not an individual) in connection with this Agreement or the ONFA Services. We will process this personal data in accordance with our Privacy Policy, which forms part of this Agreement. Accordingly, you represent and warrant that:

(A) your disclosure to us of any personal data relating to individuals other than you complies with all applicable data protection and privacy laws, and such data is accurate, current, and appropriate when disclosed;

(B) before providing any such personal data to us, you confirm that you have read and understood our Privacy Policy, which you can view here: privacy policy, and in the case of personal data relating to an individual other than you, you acknowledge that you have provided that individual with a copy (or will provide the individual at a later date) or shown the individual the web page containing that Privacy Policy (being the most recent revision of the policy); and

(C) when we provide you with an updated version of the Privacy Policy, you will promptly read the notice and provide updated copies of the Privacy Policy to anyone whose personal data you have provided to us, or show them a website containing the updated Privacy Policy.

11. SECURITY

11.1 Password security

To access the ONFA Services, you will be asked to create or will be provided with security credentials, including a username and password. You are responsible for safeguarding the electronic device from which you access the ONFA Services and for maintaining confidentiality and exclusive control over any and all security information used to access the ONFA Service. This includes taking all reasonable steps to prevent loss, theft, or misuse of such electronic devices and ensuring that such devices are encrypted and password-protected.

Any loss or compromise of your electronic device or security credentials may result in unauthorized third-party access to your ONFA Account and the potential loss or theft of Digital Assets or other assets held in your ONFA Account. You must keep your security credentials safe at all times. For example, do not write them down or allow others to view them.

Under no circumstances will ONFA ask you for your ID, password, two-factor authentication code, request that you share your screen, or attempt to gain remote access to your computer or account. You should not provide your credentials to any third party for the purpose of remote access to your account. Always log in to your ONFA Account through the ONFA App to review transactions or take action if you are uncertain about the authenticity of any communication or announcement.

We are not responsible for any loss you may suffer resulting from compromise of your account login information through no fault of ONFA and/or your failure to comply with the requirements set out in this Section 11.1 or to follow any notice or warning we may send you.

11.2 Authentication and Verification

To access the ONFA Service, users must provide an email address and create a password. ONFA provides two-factor authentication via the user's mobile device (Short Message Service or a time-based One-Time Password (OTP) application). A verified phone number is required to enable two-factor authentication via SMS. Users are responsible for securing the electronic devices used to access the ONFA Service and for maintaining exclusive control and security over all security credentials used to access the ONFA Service. This includes taking all reasonable steps to prevent loss, theft, or misuse of such devices and ensuring those devices are password-protected. Any loss or compromise of personal electronic devices or security credentials may result in unauthorized third-party access to your ONFA Account and the loss or theft of digital assets and/or other assets in your ONFA Account, as well as misuse of associated accounts.

11.3 Security Breach

If you suspect that your ONFA Account or any of your security credentials have been compromised, or if you discover any fraudulent or attempted fraudulent activity or any other security incidents (including a cybersecurity attack) affecting you and/or ONFA (collectively, a "Security Breach"), you must:

(A) promptly notify ONFA Support via the designated email address; [email protected];

(B) continue to provide accurate and up-to-date information throughout the duration of the Security Breach;

(C) comply with steps we reasonably request and provide assistance as reasonably required to mitigate, manage, or report any Security Breach.

Failure to promptly notify us of any Security Breach may be considered when we determine the appropriate resolution for the issue.

11.4 Safety and Security for Your Computer and Devices

ONFA is not responsible for any damage or interruption caused by computer viruses or other malicious code that may affect your computer or other devices, nor for any fraudulent, impersonation, or other attacking behaviors. We recommend that you regularly use reputable software to detect and prevent viruses. You should also be aware that SMS messages and emails are susceptible to spoofing and phishing attacks, so exercise caution when reviewing messages purporting to be from us.

12. TERM OF USING API

ONFA APIs are intended for use only on the ONFA Platform, including the ONFA app, the onfa.io website, and by our affiliates, agents, representatives, trusted service providers, and contractors for limited purposes. Use of ONFA APIs outside the ONFA Platform requires ONFA's permission. We reserve the right to block accounts that attempt unauthorized use of APIs for profiteering or disruptive activities, such as system DDoS, Launchpad participation, redemptions, P2P trading, and similar activities.

13. GENERAL TERMS

13.1 Your Compliance with Applicable Laws.

You must comply with all applicable laws, regulations, licensing requirements, and third-party rights (including, without limitation, data privacy, anti-money laundering, and anti-terrorist financing laws) when using ONFA Services, the ONFA Platform, and the ONFA App and Website.

13.2 Prohibited and Conditional Uses

In connection with your use of the ONFA Services and your interactions with other users and third parties, you agree to comply with the 'Prohibited Uses, Prohibited Industries, and Conditional Use Policy' (as set out in Appendix 1). Nothing in this document shall be construed as granting any license or right to use Digital Assets for illegal, fraudulent, unethical, or unauthorized purposes or to promote or facilitate any illegal, fraudulent, unethical, or unauthorized conduct or activity. We reserve the right at all times to monitor, review, retain, and/or disclose any information necessary to comply with applicable laws, regulations, sanctions, legal processes, or the requirements of law enforcement agencies.

13.3 Modifications

We will notify you of any changes to the Agreement regarding the ONFA Services. In such cases, you will be deemed to have accepted such changes if you do not notify us by the effective date of the change and you continue to use the ONFA Services. If you do not accept the change, you must notify us and the Agreement will terminate at the end of the notice period. You may also terminate the Agreement immediately at no cost. Termination takes effect at any time prior to the expiration of the notice period.

We may make other amendments to the Agreement (including in relation to any other ONFA Services) by posting the revised Agreement on the ONFA App or Website, or by sending it via email and informing you when the revised Agreement becomes effective. While we will endeavor to notify you in advance where possible, we may make the revised Agreement effective immediately where permitted by law. If you do not agree to any such modification, you should close your ONFA Account and cease using the ONFA Services. You agree that notice of modifications in the foregoing manner shall constitute sufficient notice and that your continued access to and/or use of the ONFA Services and/or the Website will constitute your acknowledgment of the modifications and your acceptance of the revised Agreement.

Copies of the latest version of the Agreement will always be available on the ONFA App and Website.

13.4 Relationship of the Parties

Nothing in this Agreement shall be construed to create a partnership, joint venture, or agency relationship between you and ONFA.

13.5 The Privacy of Others

If you receive information about other users through the ONFA Services, you must keep that information confidential and use it only in connection with the ONFA Services. You may not disclose or provide user information to third parties or use it except where reasonably necessary to carry out a transaction and other incidental functions such as support, reconciliation, and accounting, unless the user consents. You may not send unsolicited communications to other users through the ONFA Service.

13.6 Contact Information

It is your responsibility to update your contact details (including email address and phone number) in your ONFA Account to receive any notices or alerts we may send you (including notices or warnings about actual or suspected Security Breaches). See Appendix 3 for more details regarding how we will contact you.

13.7 Taxes

You are solely responsible for determining whether transactions conducted through ONFA are taxable and for calculating, collecting, reporting, and paying the correct amount of tax to the appropriate tax authority. Your transaction history is available in your ONFA Account.

13.8 Unclaimed property

If we hold Digital Assets on your behalf and are unable to contact you, and there is no record of your use of the ONFA Services for several years, applicable law may require us to report the digital assets as unclaimed property to authorities in certain jurisdictions. We will attempt to locate you at the address shown in our records; if you cannot be located, we may be required to deliver such Digital Assets to authorities in some jurisdictions as unclaimed property. We reserve the right to deduct account freezing fees or other administrative fees from such unclaimed assets where permitted by applicable law.

13.9 Account holder passed away

For security reasons, if we receive legal documents confirming your death or other information reasonably indicating that you have died, we will freeze your ONFA Account and no transactions may be completed until (i) your executor/designee has opened a new ONFA Account and your ONFA Account assets have been transferred to that new account as further described below, or (ii) we have received satisfactory evidence indicating you have not died. If we have reason to believe you are deceased but have not received satisfactory proof of death, you authorize us to make inquiries, directly or through third parties, that we consider necessary to determine whether you have died. Once we have received satisfactory proof of death, the executor/trustee you designated in a valid will or similar document will be required to open a new ONFA Account. If you have not appointed an executor/trustee, we reserve the right (i) to treat any person entitled to inherit your ONFA Account as determined by us after receipt and review of documents we consider necessary or appropriate (including, but not limited to, a will or similar document), or (ii) to request a court order to appoint an administrator/trustee with jurisdiction over your estate. If we determine there is uncertainty regarding appointment of an executor/trustee, we reserve the right to seek a court order to resolve the matter before taking any action in relation to your ONFA Account. Subject to the foregoing, opening a new ONFA Account by a designated executor/trustee is required upon the death of the ONFA Account holder, and you agree that the executor/trustee will be required to open a new ONFA Account and provide the necessary information pursuant to Section 3 of this Agreement to gain access to the contents of your ONFA Account.

13.10 Entire Agreement

This Agreement (including documents incorporated by reference herein) constitutes the entire understanding and agreement between you and ONFA with respect to the subject matter hereof and supersedes all prior discussions, agreements, and understandings of any kind (including, without limitation, prior versions of this Agreement) between you and ONFA.

13.11 Interpretation

The section headings of this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement.

13.12 Transfers

This Agreement is personal to you and you may not assign or transfer your rights, licenses, interests, or obligations to any other person. We may assign or sublicense our rights, interests, or obligations at any time, including as part of a merger, acquisition, or other corporate reorganization related to ONFA, provided that such assignment or transfer does not materially affect the quality of ONFA Services you receive. Subject to the foregoing, this Agreement shall be binding and enforceable for the benefit of the parties and their respective successors and assigns.

13.13 Invalidity

If any provision of this Agreement is found to be invalid or unenforceable under applicable law, such finding shall not affect the validity of any other provision. If any provision is found to be unenforceable, that provision will be severed and the remaining provisions will continue in full force and effect.

13.14 Exercising Our Rights

We may not always strictly enforce our rights under this Agreement. If at any time we choose not to exercise our rights, that shall be a temporary measure only, and we may choose to enforce our rights strictly at any time.

13.15 Change of control

If ONFA is acquired by or merged with a third-party legal entity, we reserve the right to transfer or assign the information we have collected from you and our relationship with you (including this Agreement) as part of a merger, acquisition, sale, or other change of control.

13.16 Survival

All provisions of this Agreement that by their nature should survive termination or expiration of this Agreement, including but not limited to sections relating to suspension or termination, cancellation of ONFA Accounts, liabilities to ONFA, joint use of the ONFA Platform or App, disputes with ONFA, and general terms, shall continue to be binding and in effect after termination or expiration of this Agreement.

13.17 Governing Law

This Agreement and the relationship between you and us will be governed by the laws of Lithuania, subject to any mandatory local laws or user rights.

APPENDIX

Appendix 1: PROHIBITED TYPES OF USE, PROHIBITED INDUSTRIES, AND CONDITIONAL USE FORMS

1. Prohibited Uses

You may not use your ONFA Account to engage in the following categories of activity ("Prohibited Use"). The specific usage patterns listed below are illustrative but not exhaustive. If you are unsure whether your use of the ONFA Services or the ONFA Platform constitutes a Prohibited Use or have questions about how these requirements apply to you, please submit a support request at: https://t.me/OnfaSupport or email: [email protected]

By opening an ONFA Account, you represent and warrant that you will not use your ONFA Account, any ONFA Services, and/or the ONFA Platform to do any of the following:

(A) Illegal Activity: Activities that may violate or facilitate violation of any law, regulation, ordinance, or enforcement regime applicable in countries where ONFA conducts business, including but not limited to regulatory regimes enforced by the United States Department of the Treasury’s Office of Foreign Assets Control ("OFAC"), or activities intended to derive revenue from illegal conduct; publishing, distributing, or disseminating unlawful material or information.

(B) Abuse Actions: Actions that impose an unreasonable or disproportionately large burden on our infrastructure or interfere with, intercept, or hijack any systems, data, or information in a harmful manner; transmit or upload any material to the Website that contains a virus, Trojan, worm, or any other malicious or harmful program; attempt to gain unauthorized access to the Website, other ONFA accounts, computer systems, or networks connected to the Website through password mining or any other means; use another party's ONFA account information to access or use the ONFA App or Website, except where merchants and/or specific applications are expressly authorized by the user to access that user's information and ONFA account; or transfer your account access or the rights to your account to a third party, except as required by law or with the express permission of ONFA.

(C) Abuse of Other Users: Obstructing another person or entity from accessing or using any ONFA Services; defaming, insulting, blackmailing, harassing, stalking, threatening, or otherwise violating the legal rights (including, without limitation, privacy, publicity, and intellectual property rights) of others; instigating, threatening, facilitating, promoting, or encouraging hostile, racist, or violent behavior against others; collecting information about others from the ONFA App or Website, including but not limited to email addresses, without appropriate consent.

(D) Fraud: Acting to defraud ONFA, ONFA users, or any other person; providing any false, inaccurate, or misleading information to ONFA.

(E) Gambling: Lotteries; charged auctions; sports betting or offering odds; virtual sports prizes with cash awards; internet competitions; sweepstakes; games of chance.

(F) Infringement of Intellectual Property Rights: Engaging in transactions involving items that infringe or violate any copyright, trademark, right of publicity or privacy, or any other proprietary right under law, including but not limited to the sale, distribution, or access to music, movies, counterfeit software, or other licensed materials without prior authorization from the owner; using ONFA intellectual property, name, or logo, including use of ONFA trademarks or service marks without the express consent of ONFA, or otherwise harming ONFA or the ONFA brand; any action that implies an untrue claim about or relating to ONFA.

2. Prohibited Industries

In addition to the Prohibited Uses described above, the following categories of businesses, business methods, and items for sale are prohibited from being conducted using the ONFA Services or the ONFA Platform ("Prohibited Industries"). The specific uses listed below are representative and not exhaustive. If you are unsure whether the use of the ONFA Services or the ONFA Platform relates to a Prohibited Industry or have questions about whether the above requirements apply to you, please contact us at https://t.me/OnfaSupport or email: [email protected].

By opening an ONFA Account, you represent and warrant that you will not use the ONFA Services or the ONFA Platform in connection with any of the following businesses, activities, practices, or items:

(A) Limited Financial Services: guarantees; debt collection services;

(B) Infringement of intellectual property or proprietary rights: selling, distributing, or providing access to counterfeit music, movies, software, or other licensed materials without the permission of the owner;

(C) Counterfeit or Unauthorized Goods: the unauthorized sale or resale of branded or designer products or services; selling goods or services that are illegally imported or exported;

(D) Strictly Regulated Products and Services: cannabis clinics and distributors and related businesses; sale of cigarettes, e-cigarettes, and e-cigarette liquids; online prescription or pharmacy services; age-restricted goods or services; weapons and ammunition; gunpowder and other explosives; fireworks and related products; toxic, flammable, and radioactive materials;

(E) Drugs and Drug Paraphernalia: selling drugs, controlled substances, and any device designed to produce or consume drugs, such as bongs, vape pens, and hookahs;

(F) Counterfeit Medicines: pharmaceuticals and other products that make health claims that have not been approved or verified by applicable national and/or local regulatory authorities;

(G) Substances Intended to Mimic Illegal Drugs: selling a legal substance that has the same effect as an illegal drug (e.g., salvia, kratom);

(H) Adult Content and Services: pornography and other obscene materials (including literature, images, and other media); sites that provide any sex-related services such as prostitution, pay-per-view adult content, or adult live chat;

(I) Multi-level Marketing: pyramid schemes, network marketing;

(J) Unfair, Exploitative, or Deceptive Practices: investment opportunities or other services that promise high returns; selling or reselling a service without added benefit to the buyer; reselling government services without authorization or value-added; websites that we determine to be unfair, deceptive, or exploitative;

(K) High-Risk Businesses: any business that we believe poses a high financial risk, liability, or violates card network or banking policies.

3. Conditional Use

Express written consent and approval must be obtained from ONFA before using the ONFA Services for certain business items and/or subsequent use ("Conditional Use"). Written consent may be requested by contacting us at: https://t.me/OnfaSupport or by emailing: [email protected]

ONFA may also require you to agree to additional conditions, make additional representations and warranties, complete advanced account opening processes, and operate within limits if you use the Service in connection with any of the following businesses, activities, or practices:

(A) Charities: Receiving donations for nonprofit organizations;

(B) Games of Skill: games that are not classified as gambling under this Agreement or by law but require entry fees and award prizes;

(C) Religious/Spiritual Organizations: activities of a for-profit religious or spiritual organization.

Appendix 2: VERIFICATION PROCEDURES AND LIMITS

ONFA employs multi-level systems and processes to collect and verify information about you to protect ONFA and the community from fraudulent users and to maintain proper records of ONFA customers. Your access to one or more ONFA Services or the ONFA Platform and the limits imposed on your use of the ONFA Services (including but not limited to daily or weekly conversion limits, the limited level of Digital Assets deposited in the ONFA App, asset withdrawals, and transactions, instant purchase limits, transfer limits in the Digital Asset Wallet, and limits for transactions from a recognized payment method link) as well as any changes to such limits from time to time, may be based on the identification and/or personal information you provide to ONFA.

ONFA may ask you to provide or verify additional information or require a waiting period after completing a transaction before allowing you to use any ONFA Services and/or before allowing you to participate in transactions that exceed a certain volume limit. You can determine the volume limits related to your identity verification level by submitting a request at https://t.me/OnfaSupport or by emailing: [email protected]

You can submit a request at https://t.me/OnfaSupport or email: [email protected] to request a limit increase. ONFA will require you to undergo Advanced Account Verification. Additional fees may apply, and ONFA does not guarantee that we will increase your limit.

Appendix 3: CONTACT INFORMATION

1. Electronic delivery of contact information

You agree to receive all communications, agreements, documents, notices, and publicly available information electronically (collectively, "Communications") that we provide in connection with your ONFA account and your use of the ONFA Service. Contact information includes:

(A) the terms of use and policies to which you agree (e.g., the Agreement and Privacy Policy), including updates to these agreements or policies;

(B) account details, history, transaction receipts, confirmations, and any other account or transaction information;

(C) legal, regulatory, and tax disclosures or statements that we may be required to provide to you;

(D) responses to customer support inquiries or requests submitted in connection with your ONFA Account.

Except as otherwise provided in this Agreement, we will provide these Notices to you by posting them on the ONFA App or Website, emailing them to the primary email address listed in your Account, communicating with you via instant chat, and/or through other electronic communications such as text messages or mobile push notifications, and you agree that such Notice will constitute full notice regarding the subject matter.

2. How to withdraw your consent

You may change your decision regarding consent to receive Electronic Notices by contacting us at: https://t.me/OnfaSupport or by emailing: [email protected]. If you do not provide your consent or you withdraw your consent to receive Notices in the specified manner, ONFA reserves the right to immediately close your ONFA Account or to charge an additional fee for a paper copy of the Notice.

3. Update your information

It is your responsibility to provide us with a valid and complete email address and contact information and to keep such information up to date. You understand and agree that if ONFA sends you an Electronic Notice but you do not receive it because the primary email address you provided is incorrect, not up to date, blocked by your service provider, or for any other reason that prevents you from receiving the Electronic Notice, ONFA will be deemed to have provided the Communication to you.

You can update your information by logging into your ONFA Account and accessing settings or by contacting our support team at: https://t.me/OnfaSupport or email: [email protected].

Appendix 4: ADDITIONAL ELIGIBILITY FOR VIETNAMESE CITIZENS

For Vietnamese citizens under the age of 18, to be eligible to use any ONFA Services, you must be 14 years of age or older and have been issued a citizen identification card (with a chip). Vietnamese citizens are not permitted to use Digital Assets through the ONFA Platform as a means of payment for the purchase or sale of any goods or services that are not provided by ONFA.