# XREX User Legal Agreements Last Update: 12 Mar 2026 Welcome to XREX! Please read the XREX User Legal Agreements carefully before creating your account. By using any of our Services, you agree to be bound by the applicable XREX User Legal Agreements. # XREX General Terms and Conditions Last Update: 12 Mar 2026 The General Terms and Conditions and any terms expressly incorporated herein (“**Terms**”) apply to any access to or use of the services offered by XREX Pte. Ltd. and its Affiliates (collectively referred to as “**XREX**” or “**we**”). These Terms apply when you use any of XREX's websites (“**Site**”), the XREX application (“**XREX Pay**”), any application programming interface (“**API**”) provided by XREX that relates to the Site, and any other related services provided by XREX, including but not limited to crypto-fiat conversion, BitCheck and Paylynk (collectively referred to as the “**Services**” as further defined below). These Terms are a legal contract between you and XREX Pte. Ltd. so it is important that you review them carefully before using the Services. By clicking on the “I agree” button or check-box presented with these Terms or by continuously accessing any of the Services that manifest your consent, you agree to be bound by these Terms. These Terms, the hyper-linked documents herein and all Annexes comprise the agreement (the “**Agreement**”) between you and XREX Pte. Ltd. The information provided in the Terms are for information purposes only and is not to be construed as a recommendation or advice to you in relation to any legal, tax, financial investment or any other matters. You should consult with an attorney or other professional advisor to determine what may be best for your needs. This Agreement contains the entire agreement and supersedes all prior and contemporaneous understandings between you and XREX Pte. Ltd. regarding the Services. In the event of any conflict between this Agreement and any other agreement you may have with XREX Pte. Ltd., this Agreement will prevail unless the other agreement specifically identifies this Agreement and declares that the other agreement supersedes this Agreement. Save for the Indemnified Parties, no provision of this Agreement is enforceable by virtue of the Contracts (Rights of Third Parties) Act 2001 by any person who is not a Party to this Agreement.
# Interpretation and Definitions In addition to terms defined elsewhere in these Terms, the following definitions shall apply throughout these Terms, unless the contrary intention appears: “**Affiliates**”: with respect to a person, a person that controls, is controlled by or under common control with such person; and “**control**” means the right to exercise, directly or indirectly, more than 50% of the voting securities of such person or the power to direct the management or policies of such person (and the terms “**controlled by**” and “**under common control with**” shall be construed accordingly). “**Annex**”: annexures to these Terms, which may be in the form of hyperlinked documents, setting out provisions applicable for the relevant jurisdictions in which XREX provides its Services, XREX’s product and fee schedules. “**Applicable Laws**”: any applicable constitution, treaty, statute, rule, regulation, ordinance, order, directive, code, judgment, decree, injunction, or any interpretation, determination, award, permit, license, authorisation, directive requirement, ruling or decision of, or agreement with, or by, a government authority, including Singapore Sanctions Laws. “**Business Day**”: a day other than a Saturday, Sunday or public holiday in Singapore. “**B2B**”: business to business. “**AML/CFT**”: anti-money laundering / combating the financing of terrorism. “**Communications**”: includes announcements, agreements, disclosures, documents, mail (electronic) messages, notices and receipts. “**Conversion**” and “**convert**”: an exchange between one type of DPTs to another type of DPTs, or between DPTs and Fiat Money. “**Digital Payment Tokens**” and “**DPTs**”: only blockchain-based fungible coins or tokens supported by XREX Pay and available on the Site. “**Dynamic**”: Dynamic Labs, Inc. “**FATF Travel Rule**”: a set of recommendations issued by the Financial Action Task Force, applicable to VASPs (including XREX) to prevent money laundering and terrorist financing, as further explained in paragraph 2.11 of [Privacy Policy](/doc/xrex-user-legal-agreements/xrex-privacy-and-cookies-policy). “**Fee Schedule**”: the schedule of fees for our Services as outlined in [XREX Pay Help Center](https://intercom.help/xrex-sg/en/articles/12739983-xrex-pay-fees-overview). “**Feedback**”: has the meaning ascribed to it in [Paragraph 4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/4.-proprietary-rights). “**Fiat Money**”: government-issued currency excluding central bank digital currencies. “**Force Majeure Event**”: means any act of God, labour action or dispute, war declared or undeclared, invasion, act of terrorism or sabotage, cyber-terrorism, disruption to the security, integrity, and availability of the internet or blockchain networks, blockade, civil unrest, man-made disaster, government restraint or action, perils of the sea, embargo, disease epidemic, pandemic, public health crisis, radioactive, chemical or biological contamination, accident, nationalization, expropriation, currency restrictions, acts of state, interruptions, IT Malfunction, market data error or other power failure, regulatory changes and for the avoidance of doubt includes any Communications Failure, or any other cause, event or circumstance, whether of the kind specifically enumerated above or otherwise, the occurrence and the effect of which is beyond the reasonable control of, and could not have been reasonably prevented by, the Party whose obligation it affects, notwithstanding the exercise of reasonable foresight, at reasonable cost and by the exercise of reasonable diligence on the part of that Party and which renders due performance of an obligation under this Agreement illegal or impracticable. “**Formal Complaint**” and “**Formal Complaint Process**”: these terms are defined in [Paragraph 10](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/10.-governing-law-and-dispute-resolution) relating to the resolution of any disputes with XREX. “**Funds**”: the deposit of DPTs and/or Fiat Money from an e-wallet and/or bank account under the user’s name (and only their name) into his/her XREX E-Wallet and the Safeguarding Account (as the case may be) on the Site. “**Indemnified Parties**”: XREX Pte. Ltd. and its Affiliates and their respective shareholders, directors, officers, employees, attorneys, agents, representatives, suppliers, and contractors. “**Insolvency Event**”: means an event where: 1. in relation to an entity: 1. an order is made or an effective resolution is passed for the winding up, liquidation or dissolution without winding up (otherwise than for the purposes of a solvent reconstruction or amalgamation) of the entity; 2. a receiver, receiver and manager, judicial manager, liquidator, administrator or like official is appointed over the whole or substantially the whole of the undertaking or property of the entity; 3. the holder of an encumbrance takes possession of the whole or substantially the whole of the undertaking or property of the entity; 4. the entity proposes or takes any steps to implement a scheme, arrangement or other compromise with its creditors or any class of them; 5. the entity is declared or taken under the Applicable Laws to be insolvent or the entity’s board of directors resolves that it is insolvent; 6. the entity has stopped or suspended, or threatened to stop or suspend, payment of all or a class of its debts which are due; or 7. anything analogous with any of the above; 2. in relation to a trust, all or substantially all of the assets of the trust becomes vested in the beneficiaries; or 3. in relation to a natural person: 1. such natural person authorises a registered trustee or solicitor to call for a meeting of his creditors or proposes or enters into a deed of assignment or composition with any of his creditors; 2. any third party holding a security interest in any of such natural person’s assets enters into possession of or takes control of any of such assets; or 3. such natural person commits an act of bankruptcy, including having a bankruptcy order made against him, acts of applying or obtaining an order for voluntary arrangement, or being placed under a debt repayment scheme. “**KYC**”: know your client. “**Losses**”: means all costs, damages, losses, liabilities (including tax liabilities), charges, actions, claims, demands and expenses in connection with any action, suit or proceeding, investigations, judgments, orders whether involving a third party claim or a claim solely between the Parties and includes any incidental, indirect or consequential damages (including any ordinary, direct, indirect, consequential, incidental, special, punitive or exemplary damages), losses (direct or consequential), liabilities or expenses, and any lost profits or diminution in value. “**OTC**”: over-the-counter. “**Owed Amount**”: has the meaning ascribed to it in [Paragraph 6](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/6.-safeguarding-measures). “**Parties**”: you and XREX Pte. Ltd. “**Paylynk**”: the XREX domestic and cross-border trade payment function which allows the transfer of Funds from the Third Party Payor’s bank account or Payor Dynamic Wallet to the XREX Account. “**Paylynk Transaction**”: the transaction initiated by the Paylynk User via Paylynk to receive Funds from the Third Party Payor to the XREX Account. “**Paylynk User**” means the XREX user who initiates a Paylynk Transaction. “**Payor**”: the third-party payor that is required to make payment to the Paylynk User pursuant to the Paylynk Transaction. “**Payor Dynamic Wallet**”: the unhosted non-custodial e-wallet that Dynamic provides to the Third Party Payor. “**Relevant Money**”: any money that is received by XREX from, or on account of, you in respect of the provision of our payment services and which we continue to hold at the end of each Business Day, but does not include the following (1) any money paid to us to reduce the amount owed to us by you, (2) any money that is repaid by us to you, (3) any money which is paid to us, or which we have informed you, will be used to defray any fee or charge imposed by us for providing our payment services to you, (4) any money that is paid to a recipient in accordance with your instructions to us, (5) any money that is paid to any other person that is entitled to the money. “**Safeguarding Account**”: designated trust bank account that XREX maintains with a bank in Singapore in accordance with Applicable Laws. “**Safeguarding Institution**”: has the meaning ascribed to it in [Paragraph 6](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/6.-safeguarding-measures). “**Services**”: all the features, functions, and services provided by XREX on the Site, XREX Pay and any APIs. “**SIAC**” and “**SIAC Rules**”: these terms refer to the Singapore International Arbitration Centre and the rules which it publishes to regulate arbitration proceedings, respectively, and apply to the resolution of any disputes with XREX, as set out in [Paragraph 10](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/10.-governing-law-and-dispute-resolution). “**Singapore Sanctions Laws**”: the Terrorism (Suppression of Financing) Act 2002 and the respective regulations promulgated under the Monetary Authority of Singapore Act 1970, as amended, supplemented or replaced from time to time. “**Tax**” or “**Taxation**”: all forms of taxation (including goods and services tax and other than deferred tax) and statutory, governmental, state, provincial, local governmental or municipal impositions, duties, contributions and levies and whether levied by reference to income, profits, gains, net wealth, asset values, turnover, added value or otherwise and shall further include payments in respect of or on account of tax, in each case, whenever and wherever imposed on any party and whether chargeable directly or primarily against or attributable directly or primarily to a party and all penalties, charges, costs and interest relating thereto. “**Third-Party Content**”: this term is defined in [Paragraph 4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/4.-proprietary-rights) relating to our proprietary rights. “**Trust Account**”: a trust account maintained by us with a Safeguarding Person to hold DPTs. “**VASP**”: Virtual Asset Service Provider, being any natural or legal person who as a business conducts one or more of the following activities or operations for or on behalf of another natural or legal person, namely, the exchange between DPTs and Fiat Money, the exchange between one or more types of DPTs, the transfers of DPTs, the safekeeping and/or administration of DPTs. “**User Content**”: has the meaning ascribed to it in [Paragraph 4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/4.-proprietary-rights). “**XREX Account**”: any user account provided by XREX for the purpose of using the Services, including but not limited to the XREX E-Wallet, Corporate Accounts, and Advanced Accounts (all as set out in [Paragraph 1.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/1.-account) herein). “**XREX E-Wallet**”: the hosted e-wallet that XREX provides to you as part of the Services and in which you may store, track, transfer and manage your DPT balances. “**XREX Material**”: has the meaning ascribed to it in [Paragraph 4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/4.-proprietary-rights). # 1. Account 1. **Eligibility for XREX Account application:** 1. Any applicants located in, or of citizenship of, any countries or regions listed on this [page](https://intercom.help/xrex-sg/en/articles/9232927-what-countries-are-on-the-prohibited-list-and-who-is-affected-by-these-restrictions) will be denied for AML/CFT or other regulatory purposes. This list of the restricted and prohibited jurisdictions will be updated and revised from time to time at the sole discretion of XREX. If you change your residence or nationality, or both, to any jurisdiction on the [list](https://intercom.help/xrex-sg/en/articles/9232927-what-countries-are-on-the-prohibited-list-and-who-is-affected-by-these-restrictions), you must notify XREX immediately and cease your use of our Services unless you receive written permission from XREX. 2. In order to use the Services, you must be at least 18 years of age, and you must have the authority to enter into and execute an agreement to these Terms. In order to leverage any part of the Services, you are required to provide personal information. You hereby warrant that any information provided by you is accurate, complete, and current and you accept that any inaccuracies may lead to XREX, in its sole discretion, ceasing its Services, freezing your XREX Account, assets, and access at any time and without prior notification. 3. You are not a designated individual or entity as defined or set out in the Singapore Sanctions Laws. 2. **Relationship of the Parties:** XREX is an independent contractor for all purposes. Nothing in this Agreement is intended to or shall operate to create a partnership, joint venture, or employment relationship between you and XREX, or authorise you to act as agent of XREX. 3. **XREX Account** 1. In order to access some of the Services, you must complete our identity verification questionnaire and provide accurate and truthful details and documentation as required by our policies and procedures. You agree that XREX may share the relevant data with certain third parties contracted by XREX to perform verification of the data and documentation provided by you and to ascertain your status as required by the Applicable Laws of the jurisdiction(s). 2. Corporate Account: Individuals with the intent to use the Services on behalf of an enterprise or legal entity must request a Corporate Account when such accounts are made available on our platform. If you use the Services on behalf of an enterprise or legal entity without registering for a Corporate Account, you do so at your own risk and you agree and accept that your XREX Account may be restricted, access to your XREX Account may be prevented, and access to your Funds may be withheld pending a full investigation of your background and the enterprise or legal entity on whose behalf you are accessing the Services. You also agree that your details and the results of such an investigation will be shared with the relevant regulatory authorities. 3. Advanced Account: At its sole discretion, XREX may grant additional benefits, rewards, or features for qualified users as Advanced Account holders (such as premium accounts). Notwithstanding the foregoing, Advanced Account holders are still users under these Terms, not contractors, representatives, or agents of XREX, and you shall contact XREX directly to confirm the information regarding any benefits or rewards when using the Services for an Advanced Account. 4. Access to your Account: You must not sell or otherwise make your XREX Account accessible to any unauthorised person. You are fully responsible for maintaining the security and confidentiality of your username, password and any other access credentials to use and/or access your Account, and all activities that occur in connection with your Account. 4. **Responsibility for Actions** 1. Authorised Actions: Any instruction or Communication sent from or is otherwise referable to your XREX Account (e.g., an email sent from the email address that you have registered with us in setting up your Account), or any of your contact information, shall be deemed to be authorised and is binding on you. XREX is not obliged to verify the identity or authority of any persons using your XREX Account and we shall be entitled to accept and place full reliance on any instruction or Communication sent from or is otherwise referable to your Account. 2. Unauthorised Actions: Any unauthorised use of your XREX Account will constitute a breach of this Agreement and in case of such breach, XREX has the right, without prejudice to any of our rights or remedies under Applicable Laws, to terminate, suspend or restrict your access to your Account, terminate the provision of all or part of the Services to you, as well as take any other action as we deem fit, whether for a specified period of time or indefinitely. \ If you notice any unauthorised or suspicious log in or activity in your XREX Account or in the event of any breach of security, loss, theft or unauthorised use of your username, password, security information or any other access credentials to access or use our Services, you must notify us in writing immediately through your designated relationship manager and provide us with a police report and any other information and documents as we may require. You shall also immediately take steps to restrict access to your Account, which can be done via the Services or other means. 3. No Liability: You acknowledge and agree that none of the Indemnified Parties shall not be liable to you or any other person or entity for any direct, indirect, special or consequential losses (including loss of profits, business or opportunities), damages or costs by reason of, or arising from, or as a consequence of, your XREX Account being used by a third-party, whether authorised or unauthorised by you. 5. **Account Funding** 1. Deposits: 1. Only users who have passed the KYC checks (including identity verification) can deposit DPTs and Fiat Money from their e-wallet and/or bank account under their name (and their name only) into its XREX E-Wallet and its/their Safeguarding Account. You can view your balance of DPTs and Fiat Money from your XREX Account. If you send DPTs to the incorrect e-wallet address or if you send unsupported DPTs, these may be lost forever, and XREX will not accept responsibility for such lost Funds or digital assets. Any funds you send to the XREX E-Wallet addresses or Safeguarding Account will not receive any interest unless specifically stated otherwise on the Site or the XREX Pay. 2. Deposit amounts may be subject to limits depending on the level to which you have verified your identity and/or provided additional information requested by us. 2. Withdrawal 1. Only users who have passed the KYC checks can withdraw DPTs and Fiat Money from the XREX Account. You will be required to maintain enough Funds in your XREX E-Wallet or Safeguarding Account to cover any pending transactions and fees to be incurred. Any Funds in excess of those committed to your transactions may be withdrawn to an external e-wallet, in the case of DPTs, or to an external bank account under your name (and your name only), in the case of Fiat Money. 2. XREX may require you to verify your ownership of any external wallets or bank accounts prior to approving your withdrawal requests. Please note that XREX is unable to reverse any withdrawal transactions and therefore accepts no responsibility for amounts sent to incorrect, improperly formatted, or erroneous addresses, or addresses of a different type of DPT than the one stipulated in the withdrawal request. 3. XREX has the right to impose such conditions and limits to the amounts that you can transfer in or out of your XREX E-Wallet and Safeguarding Account at any time, depending on third-party requirements such as those of financial institutions, or in accordance with our internal policies. 4. You hereby authorise XREX to deduct from the Funds in your XREX Account the fees charged by XREX before XREX sends the amounts to any approved external wallet address and/or bank account specified by you when using the Service. 3. Other Account Funding Terms 1. You hereby accept to bear any fees charged by third parties when making transfers to external wallet addresses or bank accounts, in addition to the fees charged by XREX when executing transfers on your behalf. 2. You also accept responsibility for ensuring that any transfer request, whether inbound or outbound, complies with XREX’s requirements under these Terms, with the requirements of any third-party service providers or DPT requirements for processing such a request. For transfers of DPTs, you accept all responsibility for ensuring e-wallet addresses are properly formatted, correct, and suitable for the type of DPT being transferred. 3. You further accept responsibility for ensuring that there are no errors in your transfer instructions when using the Services. You hereby agree and accept that if you do not comply with any of the above requirements, your DPTs may be permanently lost and you agree to hold XREX harmless and waive any and all claims against XREX under such circumstances. 4. The timing of completion of transactions is contingent on the availability of third-party networks and XREX provides no guarantees as to how long it takes for a transaction to be completed. 5. XREX may suspend or even terminate your ability to make transfers into or from either your XREX E-Wallet or Safeguarding Account or both, in order to comply with Applicable Laws or at XREXʼs own discretion if XREX has reasonable grounds to suspect any wrong-doing on your part. 6. You may receive transfers of supported DPTs from supported blockchain addresses into your XREX E-Wallet. We may require you to assist with the verification of the identity of the owner of the supported blockchain address and you agree to provide us with any and all information, documents and/or materials that we may from time to time request for such purposes, and you permit us to keep a record of all such information, documents and materials for so long as we are required or permitted to do so under Applicable Laws, including beyond the termination of your Accounts. In providing us with such information, documents and/or materials that we request, you confirm (a) the accuracy, completeness, and authenticity of all such information, documents, and materials, and (b) you have not withheld any information, document or material that may influence our verification of the identity of the owner of the relevant blockchain address. 6. **Prohibited Use and Activities**\ You will not violate any law, regulation, contract, intellectual property, or another third-party right, or commit a tort while using the Services; use the Services in any manner that could interfere with, disrupt, negatively affect, or inhibit other users from fully enjoying the Services, or that could damage, disable, overburden, or impair the functioning of the Services in any manner; engage in any type of market manipulation. Market manipulation activities include, but are not limited to, pump and dump schemes, wash trading, self-trading, front running, quote stuffing, and spoofing and layering, regardless of whether it is prohibited by law; use the Services to pay for, support, or otherwise engage in any illegal gambling activities, fraud, money-laundering, or terrorist activities, or other illegal activities; use any robot, spider, crawler, scraper, or other automated means or interface not provided by us to access the Services or to extract data; use or attempt to use another userʼs account without authorisation; attempt to circumvent any content filtering techniques we employ, or attempt to access any service or area of the Services that you are not authorised to access, or attempt to access the Services from any location or jurisdiction in which you are prohibited from accessing the Services; introduce to the Services any malware, virus, trojan worms, logic bombs, or other harmful material; develop any third-party applications that interact with our Services without our prior written consent, or unless otherwise agreed; provide false, discriminatory, bigoted, abusive, inflammatory, fraudulent, deceptive or otherwise objectionable; post content containing unsolicited promotions, political campaigning, or commercial messages (SPAM) or any chain messages or user content designed to deceive or trick the user of the Service; post content containing private information of any third-party including, but not limited to, addresses, phone numbers, email addresses, Social Security numbers, and credit card numbers; promote, offer, use or otherwise exploit the Services or use or otherwise exploit any data related thereto in connection with the formation, operation or offering of any index fund or similar product or any data package or similar product or any other derivative product utilizing the Site or the Services; or encourage or induce any third-party to engage in any of the activities prohibited under this Paragraph 1. 1. Copyright Violations: XREX has a policy of limiting access to our Services and terminating the accounts of users who infringe our or others’ intellectual property rights. If you believe that anything on the Services infringes any copyright that you own or control, you may notify us via email at . In addition, please note that if you knowingly misrepresent that any activity or material on our Services is infringing, we shall hold you liable for all of our costs and damages caused by your misrepresentation. 2. Remedies: If you violate any of these Terms, XREX may, as it determines reasonably necessary to remedy or mitigate your violation, delete all or part of such information transmitted by you, suspend or cancel your account, or confiscate DPTs owned by you without any prior notice to you. XREX shall in no event be responsible or liable for any damage incurred by the user as a result of an action taken by us pursuant to this paragraph. Any right or remedy of XREX set forth in these Terms is in addition to, and not in lieu of, any other right or remedy whether described in these Terms, under the statute, at law, or in equity. 7. **Representations, Warranties and Undertakings**\ When you use the Services, you hereby represent, warrant and undertake to XREX at all times that: 1. you have full power, authority and capacity to (i) access and use the Site and/or the Services; and (ii) enter into and deliver, and perform your obligations under, this Agreement and any other agreements entered into pursuant to, or in connection with this Agreement; 2. this Agreement and any other agreements entered into pursuant to, or in connection with, this Agreement constitute valid and legally binding obligations, enforceable against you in accordance with their respective terms; 3. (in the case of an entity) you are duly incorporated, organized and validly existing under the laws of your jurisdiction and have full power to conduct your business; 4. (in the case of an individual) you are at least 18 years old or of legal age to form a binding contract under all Applicable Laws, and have full mental capacity to enter into this Agreement and any other agreements entered into pursuant to, or in connection with, this Agreement, and to make decisions regarding your investments or transactions; 5. all consents, permissions, authorisations, approvals and agreements of third parties, and all authorisations, approvals, permissions, consents, registrations, declarations, filings with any regulatory authority, governmental agency, commission or other organization having jurisdiction over you which are necessary or desirable for you to obtain in order to (i) access and use the Site and/or the Services and (ii) enter into and deliver, and perform the transactions contemplated under this Agreement and any other agreements entered into pursuant to, or in connection with, this Agreement, have been unconditionally obtaining in writing and have been disclosed in writing to us and have not been withdrawn or amended; 6. all the activities that you undertake during the use of the Services will be in compliance with all Applicable Laws; 7. your access and use of the Site and/or the Services, your execution and delivery of, and the performance of your obligations under this Agreement and any other agreements entered into pursuant to, or in connection with, this Agreement, will not (i) result in a breach of or conflict with any provision of your constitution, (ii) result in a breach of, or constitute a default under, any instrument, agreement document or undertaking to which you are a party or by which you or any of your property is bound or subject and (iii) result in a breach of any Applicable Laws; 8. all documents, materials and information you have provided to XREX are true, accurate, complete and updated in all respects, and may be relied upon by us in determining your eligibility to access the Site and use the Services; 9. you have sufficient knowledge, sophistication and experience as to be able to evaluate the merits and risks of each transaction and are acting on your own account and have made your own independent decision to enter into each transaction and assessed whether the transaction is appropriate or suitable for you based on your own judgment or upon professional advice obtained independently of us; 10. there is no pending claim, action, suit or proceedings at law or in equity (in any jurisdiction) before any court, tribunal, governmental body, agency, official or any arbitrator that is likely to affect the legality, validity or enforceability against you and/or the legal entity you act on behalf of, or your ability to perform the obligations under this Agreement; and 11. you have not suffered any Insolvency Event. 8. **Suspension, Termination and Cancellation** 1. You agree that XREX shall have the right, in its sole and absolute discretion, without prior notice to you or any other users, to refuse to act upon any instruction, refuse to complete or block, reverse, cancel, modify and/or disregard any request or transaction you have authorised or instructed, immediately suspend, restrict your access to, and/or terminate your Account or the Services, and/or freeze or liquidate your Funds in your Account, whether for a specified period of time or indefinitely, and/or refuse to transmit information or instructions to third parties, for any reason including but not limited to where: 1. we are of the opinion that we are required to do so by any Applicable Laws; 2. we reasonably believe that doing so will protect our reputation or goodwill; 3. you have not complied with, or we reasonably suspect you to be acting in breach of, any terms of this Agreement; 4. we detect any unusual activity in relation to your Accounts; 5. we detect any unauthorised access to your Accounts; 6. we have determined or reasonably suspect that any transaction is erroneous, unauthorised, fraudulent or unlawful or we suspect your Accounts and/or the Services are being used in a fraudulent, unauthorised or unlawful manner; 7. we have concerns about the security of your Accounts; 8. we have determined or suspect that there is an occurrence of money laundering, terrorism financing, fraud or any other financial crime; 9. we have determined or suspect that your Funds have been stolen or otherwise are not lawfully possessed by you; 10. we have determined or suspect that you have directly or indirectly registered an Account in another person’s name; 11. any information that you have provided to us is untruthful, inaccurate, outdated or incomplete in any respect; 12. you have conveyed your unwillingness to accept any of the revised or updated terms, conditions or provisions of the amended Agreement; 13. we have determined in our sole and absolute discretion that we no longer want to continue to have any business relations with you; and 14. you have requested in writing that we terminate or suspend the provision of any Services to you. 2. In the event of discontinuation of any or all Services or other termination of your right to access all Services: (a) all amounts payable by you to us will immediately become due; (b) we may delete or deactivate your XREX Account and all related information and files in such account without liability to you; (c) we may cancel any transaction requests that are pending at the time of discontinuation or termination. 3. In the event of discontinuation or termination of any or all Services or discontinuation or termination of transfer or storage Services for all or some DPTs, we will, unless prohibited under Applicable Laws give you a reasonable period to remove the affected DPTs and any Fiat Money from your XREX Account. 9. **Acceptance of Terms** If you do not agree to the Agreement, please do not visit, access, or use the Site or Services, or create an account. The electronic acceptance, acknowledgement of the Agreement or continued use of the Site or Services shall constitute an acceptance of the Agreement, which shall take effect upon your first access of the Site or Services. Any failure to comply with the Agreement may constitute a violation of Applicable Laws. XREX reserves the right to suspend, disable or cancel your account at any time and without notice to you if it deems that you have failed to comply with the Agreement. # 2. Data Protection and Security 1. Personal Data: You acknowledge that we may process personal data in relation to you, and personal data that you have provided (or in the future provide) to us in relation to your employees and other associates, or other individuals, in connection with the Terms, or Services. We will collect, use, disclose, and/or otherwise process your personal data in accordance with the Privacy Policy. You acknowledge that the Privacy Policy shall be incorporated by reference into, and shall form part of, the Terms. You represent and warrant that: 1. your disclosure to us of any personal data relating to individuals other than yourself has been duly authorised by such individuals, is made in accordance with all applicable data protection and data privacy laws, such data is complete, accurate, up-to-date and relevant at the time of disclosure. You shall promptly update us as to any changes in such authorisation and/or necessary changes to such personal data; 2. before providing any personal data to us or otherwise accessing or using the Services, you acknowledge that you have read and agreed to our Privacy Policy, a copy of which is available here: Privacy Policy, and, in the case of personal data relating to an individual other than yourself, have (or will at the time of disclosure have) provided the individual with a copy of, or directed the individual towards a webpage containing that Privacy Policy (as amended from time to time); and 3. if from time to time we provide you with an updated version of the Privacy Policy, you will promptly read that updated Privacy Policy and provide a copy of the same to, or re-direct towards a webpage containing the updated Privacy Policy, any individual whose personal data you have provided to us. 2. Security: 1. While XREX maintains a high standard of cyber hygiene practices and implements advanced security controls, you are required to ensure the security of your account by protecting and maintaining the confidentiality of your account data, passwords, crypto-asset wallet addresses, and other relevant data. You also agree to follow the security practices and rules presented by XREX in order to maintain the security of your account and your personal data. 2. Authentication and Verification: In order to initiate the KYC process to access the Services as required by XREX, you are to provide an email address and create a password. XREX offers two-factor authentication via a supported time-based one time password application. You are responsible for safekeeping electronic devices through which the Services are accessed and maintaining adequate security, confidentiality and control of any and all security details (including but not limited to email address, password, security information or login credentials) that are used to access the Services. This includes taking all reasonable steps to avoid the loss, theft or misuse of said electronic devices and ensuring that said electronic devices are password-protected. You must keep your security details safe at all times. For example, you should not write them down or otherwise make them visible to others. Any loss or compromise of personal electronic devices or security details may result in unauthorised access of your account by third parties, the loss or theft of Funds held in your account and/or the misuse of any associated accounts, including linked bank account(s) and e-wallets(s). You hereby accept full responsibility for any Losses arising from the above scenarios. To the maximum extent permitted under the Applicable Laws, we shall not be liable to you or any third party for any Losses arising out of or in connection with such scenarios. 3. Any breach of security, loss, theft or unauthorised use of your electronic devices and/or security details must be notified to XREX in writing immediately. We reserve the right to suspend or terminate your XREX Account at any time where the security of your account is suspected by us to have been compromised, or where we suspect that your account has been operated in breach of these Terms. 4. Safety and Security of Your Computer and Devices: XREX is not liable for any damage or interruptions caused by any computer viruses, computer worms, Trojan horses, spyware or other harmful, corrupt or malicious code, programme or software that may affect your electronic devices, or any phishing, spoofing or other attacks. We advise the regular use of reputable and readily available virus screening and prevention software to protect your electronic devices. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use all due care in reviewing messages purporting to originate from XREX. # 3. Services and Fees 1. XREX provides the following Services on the Site and XREX Pay: 1. Deposit, withdrawal, custody, conversion and transfer of DPTs; 2. Deposits and withdrawals of Fiat Money, transfer of Fiat Money, B2B payment settlements and Paying Service; 3. On and off-ramp conversions between Fiat Money and DPTs; and 4. Other products, features and services operated by XREX that are incidental to the above. 2. **Compliance with Law.** You represent and warrant to XREX at all times that you have informed yourself of all applicable legal and regulatory requirements, rules, prohibitions and restrictions in respect of your use of the Services, and you would fully comply with all such requirements, rules, prohibitions and restrictions, including any foreign exchange controls or restrictions or tax consequences applicable to your use of the Services. 3. **Availability of Services.** XREX may, in accordance with [Paragraph 11.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/11.-general-provisions), modify, suspend or discontinue, temporarily or permanently, all or any portion of any Services. You acknowledge and accept that (1) if and when Services resume, DPT valuations and conversion rates may differ significantly from the valuations and rates prior to the suspension or discontinuation of the Services and (2) XREX will not be liable for any losses suffered by you resulting from any modification of any Services or from any suspension, discontinuation of the Services, or termination of your access to all or a portion of any Services or for any other reason. XREX reserves the right to correct, reverse, or cancel any of your Service requests or attempt to do so where we have discovered an error, whether such error was by the Services, by you, or by a third party. You hereby authorise us to make or attempt any such correction, reversal or cancellation described. XREX provides no warranty or guarantees that any such attempt will be successful and bears no responsibility or liability for any such error or correction attempt. 4. **No Broker or Fiduciary Relationship.** XREX is not your broker, intermediary, agent, or advisor and has no fiduciary relationship or obligation to you in providing the Services nor in connection with transactions or other decisions or activities effected by you. As such, no information provided to you by XREX is intended or should be considered as advice. You are advised to consult your professional adviser. Please refer to [Paragraph 5 (Risk Warning and Disclosures)](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/5.-risk-warning-and-disclosures-limitation-of-liability-and-no-warranties) when choosing whether to use the Services. 5. **Transactions Final and Irrevocable.** Due to the nature and characteristics of our Services, you understand and agree that all transactions are final and irrevocable upon execution, subject to our right as set out in Paragraph 3.3 above. You shall not have the right to reverse or cancel any transaction. 6. **Cancellation of Transactions.** XREX may, in its sole and absolute discretion without prior notice to you, whether for a specified period of time or indefinitely, reverse, cancel, modify and/or disregard any transaction under any circumstance and for whatever reason or no reason whatsoever. 7. **Deposit, withdrawal and transfer of DPTs** 1. You may deposit any supported DPTs into your XREX E-Wallet from another digital wallet or trading platform or withdraw or transfer any supported DPTs in your XREX E-Wallet to another digital wallet or trading platform. You may also transfer any supported DPTs in your XREX E-Wallet to another XREX user via Bitcheck, or receive Funds from third parties via Paylynk. 2. You are solely responsible for ensuring the recipient wallet address is correct prior to submitting any such withdrawal or transfer request. 3. All instructions for withdrawals and transfers from your XREX E-Wallet are irrevocable once sent and XREX shall not be responsible for verifying recipient wallet addresses for such withdrawals or transfers. XREX will not be able to cancel a withdrawal or transfer once it has been effected. 4. XREX shall not be liable for any Losses resulting from such use of your XREX E-Wallet. 8. **Custody of DPTs** 1. You may store your DPTs in your XREX E-Wallet. 2. XREX will safeguard your DPTs in accordance with the safeguarding arrangements in [Paragraph 6](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/6.-safeguarding-measures). 3. You may track and manage your balances in your XREX E-Wallet by logging into your XREX Account. 9. **Conversion of DPTs** 1. You may convert your DPTs into Fiat Money (off-ramp conversion) or your Fiat Money into DPTs (on-ramp conversion). 2. You will have to choose the type and quantity of supported DPTs to purchase and/or sell (as applicable) and XREX will present you with the applicable conversion rate, and any associated fees before you proceed with the conversion. 3. All conversions are final and irrevocable and XREX shall not be responsible for verifying recipient account details for such transactions. No reconversions shall be made by XREX. 4. If requested by you, XREX will provide a quote setting out the current rate and spread for any conversion required. Each quote provided by XREX shall be valid for the period indicated by XREX with the quotation. By proceeding with an instruction, you are deemed to have accepted the applicable rate and spread. 5. Prior to the completion of any conversion, where such completion will or is likely to lead to an adverse effect on XREX (determined in XREX’s sole and absolute discretion), XREX shall be entitled to cancel or refuse to complete the Service without liability to you. 6. XREX may suspend provision of any conversion services for any duration by providing a written notification 24 hours in advance on its Site, XREX Pay and/or electronic mail transmission, if, in XREX’s opinion, the following categories of changes or occurrences, or any combination thereof, is effecting/are likely to effect a material change in the applicable exchange rates for a supported DPT: 1. political (including changes by reason of military action); 2. financial (including stock market conditions, currency exchange conditions in any relevant financial markets and interest rates); 3. economic conditions in the region or internationally (including changes or developments in stock, bond, money, and interest rate markers); or 4. any Force Majeure Event. 7. You are solely responsible for ensuring your bank account and XREX Account details are correct prior to submitting any instructions for any conversion transactions. 8. XREX shall not be liable for any Losses resulting from such use of the Services. 9. You acknowledge and agree that: 1. you use and rely on the Services at your own risk, and XREX excludes all liability associated with any Loss suffered or incurred by you as a result of the change in value of any supported DPTs or Fiat Money. 2. XREX will not be liable for any Losses arising out of or relating to: (a) any inaccuracy, defect or omission of the DPT’s price data, or any error, delay or interruption in the transmission of such data; (b) viruses or other malicious software obtained by accessing XREX’s websites, software, systems operated by XREX or on XREX’s behalf or any of the XREX’s Services (c) glitches, bugs, errors, or inaccuracies of any kind in XREX’s websites, software, systems operated by XREX or on XREX’s behalf or any of the XREX’s Services; or (d) a suspension or other action taken by XREX with respect to the XREX Account; or 3. XREX reserves the right to refuse to process, or to cancel, correct, reverse, claw back or recover any transaction or transfers in our sole discretion, even after funds have been debited from your XREX Account, if required by the Applicable Laws; or if XREX suspects that the transaction, including the relevant exchange rate or price data, may be erroneous, or involve money laundering, terrorist financing, fraud, or any other type of financial crime. In such instances, XREX will reverse, recover or claw back the transaction, under no obligation to reinstate a purchase or sale order at the same price or on the same terms as the canceled transaction. 10. In the event that your XREX E-Wallet or Safeguarding Account does not have sufficient Funds to execute the conversion, you will not be able to proceed with the conversion. 11. XREX shall be entitled, in its sole and absolute discretion, to determine the types of DPTs and the specific blockchain thereof that will be made available for trading, transferring, and storing on the Services. XREX will make reasonable efforts to notify you in writing of any changes to the supported DPTs. If you do not remove your unsupported DPTs or other assets to an external wallet address or account prior to the cessation of support on the Services, you may lose all or part of your DPTs or other assets. In such cases, XREX will not be liable for any losses, liabilities, costs, or expenses related to its decision to remove support for any DPT or asset. 10. **Deposit and withdrawal of Fiat Money** 1. You may deposit any supported Fiat Money into your XREX Account from your bank account for the purposes of using the Services or withdraw any supported Fiat Money in your XREX Account to your bank account. 2. You are solely responsible for ensuring your bank account details are correct prior to submitting any such withdrawal request. 3. All instructions for withdrawals from your XREX Account are irrevocable once sent and XREX shall not be responsible for verifying recipient account details for such withdrawals. XREX will not be able to cancel a withdrawal once it has been effected. 4. XREX shall not be liable for any Losses resulting from such use of your XREX Account. 11. **Transfer of Fiat Money** 1. You may transfer any supported Fiat Money in your XREX Account to: 1. a third party via the Site or XREX Pay; or 2. XREX user via BitCheck, the Site or XREX Pay. 2. You are solely responsible for ensuring the recipient account details is correct prior to submitting any such transfer request. 3. All instructions for transfers from your XREX Account are irrevocable once sent and XREX shall not be responsible for verifying recipient account details for such transfers. XREX will not be able to cancel a transfer once it has been effected. 4. XREX shall not be liable for any Losses resulting from such use of your XREX Account. 12. **B2B Payment Settlements** 1. You may effect: 1. B2B payment settlements with another user by utilising BitCheck; or 2. B2B payment settlements with a third party by raising a payment request to process payment in Fiat Money to that third party. 2. Please refer to the BitCheck Service Agreement for the terms and conditions on the use of BitCheck. 13. **Paylynk Service** 1. You may effect payment settlements from a third party by raising a payment request to receive payment from a third party in either Fiat Money or DPTs. For the avoidance of doubt, the Paylynk Service does not support any transfer of Funds by you to a third party. Any transfer of Fiat Money to a third party will have to be effected via the B2B payment settlements in Paragraph 3.12 above. 2. In order to initiate a Paylynk Transaction: 1. you must hold a XREX Account and be a customer of XREX; 2. you must provide up-to-date, complete and accurate transactional details on the XREX platform in relation to the Payor, as your customer, and the Paylynk Transaction; 3. you must upload the supporting invoices for the Paylynk Transaction on the XREX platform to the satisfaction of XREX; 4. you must create a customer invitation link (“**Customer Invitation Link**”) and send the Customer Invitation Link to the Payor via email; and 5. the Payor will be required to input its identification information and details of its bank account and/or Payor Dynamic Wallet via the Customer Invitation Link, review the terms and conditions, approve the Paylynk Transaction and authorise the auto-debit function in respect of the Payor Dynamic Wallet. 3. In the event that XREX fails to successfully whitelist and approve the Payor Dynamic Wallet or the Payor’s bank account for any reason whatsoever, the Payor will not be able to pay you in DPTs or in Fiat Money respectively. XREX will inform you in writing of the rejection of the Payor Dynamic Wallet or the Payor’s bank account, as the case may be. 4. If you choose to receive the payment from the Payor in Fiat Money, any DPTs that have been paid by the Payor based on the exchange rate as at the date of payment of pursuant to the Paylynk Transaction shall be automatically converted to Fiat Money at the prevailing exchange rate as at the date of payment of DPTs by the Payor, and you hereby agree and acknowledge that XREX shall not be liable for any Losses that you may incur arising from the said conversion. 5. In the event of a dispute between the Payor and you regarding the Paylynk Transaction, both parties shall be solely responsible for resolving such dispute independently. Upon a written request by you, XREX may, at its sole and absolute discretion, facilitate communication between the parties to support amicable resolution of such dispute. However, XREX shall have no obligation to do so and makes no representation, warranty or guarantee regarding the outcome or effectiveness of such facilitation. 6. Where such a dispute arises between Paylynk User and the Payor, XREX may, in its sole and absolute discretion, prohibit or restrict any transfer of Funds from the Third Party Payor to the XREX Account of the Paylynk User under the Paylynk Transaction. You acknowledge and agree that XREX shall bear no liability or responsibility for prohibiting or delaying the withdrawal of the relevant Funds during the period of such dispute. 7. **Payment Allocation**\ If there are multiple Paylynk Transactions, any Funds received by XREX will be applied to settle such Paylynk Transactions in chronological order based on the time the Payor confirms the payment method for each respective request through the PayLynk interface, unless otherwise specified in the technical interface. You acknowledge and agree that the actual settlement sequence may vary due to differences in payment methods, processing times, or other technical factors. 8. **Limitation of Liability** 1. To the fullest extent permitted by Applicable Laws, the maximum total liability of XREX in the provision of the Paylynk service shall not exceed the amount of service fees you pay for the relevant Paylynk Transaction. 2. By utilising the Paylynk services provided by XREX, you are bound by and subject to the terms and conditions of our platform and XREX is not liable for any Losses suffered by you arising from or incurred in connection with the use of Paylynk services provided by XREX, including but not limited to transaction delays, suspensions, failures in transaction processing that arise from XREX’s performance of compliance reviews, automated screenings, or fulfillment of regulatory requirements, or errors resulting from incorrect or incomplete information provided by you. You agree that you shall seek and obtain independent advice, if required and that XREX does not provide any advice, whether legal or financial or otherwise to you. 3. To the fullest extent permitted by Applicable Laws, you irrevocably and unconditionally agree to hold harmless and indemnify (and keep indemnified) XREX on demand against any and all Losses which XREX may sustain, incur, suffer or pay arising out of, in connection with or pursuant to the access to and/or the use of Paylynk or the Paylynk service by you, whether or not such access or use was authorised or whether it was due to any act or omission on its part, the breach of these Terms by you, the violation by you of any rights of another person or entity, the breach by you of any Applicable Laws or any claims brought by any third parties, including a Payor, against XREX in respect of the use of Paylynk or pursuant to the Paylynk Transaction. 9. **Disclaimers on Paylynk Service** 1. The Paylynk service is provided strictly on a “AS IS” and “AS AVAILABLE” basis. To the fullest extent permitted by Applicable Laws, XREX makes no representations and warranties of any kind, whether express, implied, or statutory, including but not limited to, the warranties of merchantability and fitness for a particular purpose or that the services will be uninterrupted or error-free. 2. XREX does not verify, validate or endorse the content or terms of any Paylynk Transaction. Under no circumstances shall XREX be liable for any Losses related to or arising from the use of Paylynk. 3. You acknowledge and agree to take full responsibility for the accuracy and completeness of any details provided by you. Although XREX may review the Paylynk Transaction you created, XREX does not provide legal advice and may request from you supporting documents to ensure compliance with the Applicable Laws or independent verification where required. 4. By initiating a Paylynk Transaction and creating a Customer Invitation Link, you are deemed to consent to: 1. the right for XREX to share your personal data with the Payor; and 2. the receipt of such personal data from the Payor. You shall treat personal data contained in the Paylynk Transaction as confidential and shall not disclose such information to any third party unless expressly authorised in writing by the Payor. 5. You are fully responsible for ensuring that all information you provide in connection with your use of the Services, remains accurate, complete and up to date. You consent to sharing your personal information with the Payor, unless you notify XREX in writing to the contrary. XREX shall not be liable for any Losses arising from your failure to update such information or from the use of outdated, inaccurate, or incomplete information stored in the system and/or provided by you. 6. In the event of multiple Paylynk Transactions, you shall be responsible for determining how the Funds that have been paid by the Payor to your XREX Account should be treated in satisfying the multiple Paylynk Transactions, and you agree and acknowledge that XREX does not assist you in, and shall not be responsible for, to account for the Funds vis-à-vis the Paylynk Transactions. XREX’s sole responsibility is to provide the service of collecting payments on your behalf, based on the Paylynk Transactions you have created, and allocating the Funds received on your behalf in accordance with Paragraph 3.13.f. 7. You agree and acknowledge that XREX does not have any control over, or liability for, the delivery, quality, safety, legality or any other aspect of the goods or services that you may sell or transfer to, any third parties. XREX shall not be responsible for ensuring that the Payor will complete the Paylynk Transaction or is authorised to do so. 14. **Fork and Airdrops.** You remain the lawful and beneficial owner of any assets and DPTs in your account and the beneficial owner of additional assets resulting from any applicable (i) network fork that is supported by XREX and (ii) airdrop or similar distribution of DPTs. You acknowledge and agree that XREX retains sole and absolute discretion and has no obligation to support any particular forks, airdrops or similar distribution and such support remain in all instances subject to the Terms. 15. **Fees** 1. Fees and charges on using the Services shall be set out in the [XREX Pay Help Center](https://intercom.help/xrex-sg/en/articles/12739983-xrex-pay-fees-overview) and may be periodically updated by us at our sole and absolute discretion. 2. You agree to pay XREX the fees and charges by authorising us to deduct and/or debit your Funds or from the Conversion amount for any applicable fees payable by you under these Terms. 3. You agree and understand that your acceptance of these Terms include your acceptance of our Fee Schedule. We reserve the right to change or modify our Fee Schedule, including increasing our fees in the Fee Schedule, in accordance with [Paragraph 11.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions/11.-general-provisions). The updated Fee Schedule will apply prospectively to the relevant Services that take place following the effective date of such updated Fee Schedule. # 4. Proprietary Rights 1. **Ownership.** The Services, Site, and all technology, content, data, service names, logos, marks and other materials used, displayed or provided to you in connection with the Services or Site (“**XREX Materials**”) together with all intellectual property rights in any of the foregoing are solely owned by XREX. 2. **Licence.** Subject to the user’s compliance with the Terms, we grant you a limited, revocable, non-exclusive, non-transferable licence to access the Site, XREX Materials and Services for your own personal, informational, non-commercial use as expressly permitted under these Terms. Any other use of the Site or XREX Materials is expressly prohibited and all other rights, title, and interest in the Site or XREX Materials is exclusively the property of XREX and its licensors. XREX reserves all rights, title and interest not expressly granted under this licence to the fullest extent possible under Applicable Laws. 3. **Restrictions.** Without limiting the foregoing, you shall not: 1. re-sell, lease, license, lend, share, distribute, or otherwise permit any third party to use the Site, Services, or XREX Materials or use the Site, Services or XREX Materials; 2. modify, develop or create derivative works of the Site, Services, or XREX Materials, or any portion thereof or any data or information received by you in connection therewith; 3. frame, display, or incorporate the Site, Services, or XREX Materials in any website or any other work of authorship; 4. decompile, disassemble, reverse engineer or attempt to discover the source code of the Site, Services, or XREX Materials; 5. use, or permit the use of, the Site, Services or XREX Materials to design, develop or create any competing product or service; 6. copy, imitate, transmit, distribute, sell, license, reverse engineer, modify, publish, use or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the XREX Materials, in whole or in part copy, without our prior written consent; or 7. otherwise use the Site, Services, or XREX Materials for any commercial or noncommercial purpose other than their intended purposes determined at our discretion. 4. **Feedback.** Any feedback, suggestions, ideas, or other information or materials regarding XREX or the Services that you provide, whether by email, posting through the Services, or otherwise (“**Feedback**”) shall vest in XREX. You hereby assign to XREX Inc. all rights, title, and interest to Feedback together with all associated intellectual property rights. You will not be entitled to, and hereby waive any claim for, acknowledgement or compensation based on any Feedback or any modifications made based on any Feedback. 5. **User Content.** You hereby grant to us a royalty-free, fully paid-up, sublicensable, transferable, perpetual, irrevocable, non-exclusive, worldwide licence to use, copy, modify, create derivative works of, display, perform, publish and distribute, in any form, medium or manner, any text, information, data, materials, images, or other content you provide to us using the Services or submit or post to the Site and that is not Feedback owned by us (the “**User Content**”). You represent and warrant that: 1. you own the User Content or have the right to grant the rights and licences in these Terms, and 2. the User Content and use by XREX of the User Content as licensed herein does not and will not violate, misappropriate or infringe on the rights of any third party or any Applicable Laws. We may remove any User Content from the Site for any reason at our discretion. 6. **Third-Party Content.** The Site may contain information concerning third parties, third party products and services or links to third party websites or applications (“**Third-Party Content**”). In using the Services, you may view the Third-Party Content. XREX does not monitor, control, endorse, or adopt any Third-Party Content and shall have no responsibility for Third-Party Content, including without limitation material that may be misleading, incomplete, erroneous, offensive, indecent, or otherwise objectionable. Any links to other websites are provided as a convenience to you and does not imply XREX’s endorsement, whether express or implicit, of the linked website. In addition, your business dealings or correspondence with such third parties are solely between you and the third parties. To the maximum extent permitted by law, XREX is not responsible or liable for any loss or damage of any sort incurred as the result of any such dealings between you and these third parties, whether or not such dealings have been performed or facilitated through the Site, arising out of or in relation to anything done or omitted to be done in relation to the Third-Party Content, or any delay, inaccuracies or omissions in the Third-Party Content or any interruption to the supply of the Third-Party Content, or the act or omission of these third parties, and you understand that your use of Third-Party Content, and your interactions with third parties, is at your own risk. # 5. Risk Warning and Disclosures, Limitation of Liability, and No Warranties You should read the following statements in detail before using any of the Services. #### 1. **RISK WARNING ON DIGITAL PAYMENT TOKEN SERVICES:** The Monetary Authority of Singapore (“**MAS**”) requires us, **XREX Pte. Ltd.**, to provide this risk warning to you as a customer of a digital payment token (“**DPT**”) service provider. **Before you:** (a) pay your DPT service provider any money or DPT; or (b) pay a third party any money or DPT under an arrangement by your DPT service provider, **you should be aware of the following:** a. XREX Pte. Ltd., being your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider or any other third party referred to above, if your DPT service provider’s or the third party’s business fails. b. You should be aware that MAS does not supervise or regulate your DPT service provider for the provision of unregulated services. This includes any service of trading digital payment token derivatives such as futures. Please refer to Section 2.3.1 of the Guide to the Payment Services Act 2019 (“**Guide**”) (which can be found on the MAS website) for the types of payment services which are regulated under the Payment Services Act. Services which do not fall within the list of services in Section 2.3.1 of the Guide are unregulated services. c. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact if transferred or held by your DPT service provider. d. You should be aware that the value of DPT’s may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens. e. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “**stablecoin**”. #### **2. RISK DISCLOSURES:** **(1) INDUSTRY RISKS** The DPT industry represents a relatively new and rapidly changing industry, and its success is subject to a variety of factors that are difficult to evaluate. The slowing of the development or acceptance of DPTs may adversely affect the DPTs. The growth of the Virtual Asset Service Providers (“**VASPs**”) is also subject to a high degree of uncertainty. \ \ The factors affecting the sustainability of the DPT industry include: * continued worldwide growth in the adoption and use of DPTs; * government regulation of DPTs and their use, or restrictions on or regulation of access to and operation of VASPs; * the maintenance and development of the open-source software protocol; * changes in consumer demographics and public tastes and preferences; * the availability and popularity of other forms or methods of buying and selling goods and services, including new means of using fiat currencies and DPTs; and * general economic conditions and the regulatory environment relating to DPTs. A decline in the popularity or acceptance of DPTs may harm the market price of the DPTs. There is no assurance that any VASPs (including XREX) necessary to accommodate the sale and transfer of the DPTs will continue in existence or grow. Furthermore, there is no assurance that the availability of and access to VASPs will not be negatively affected by government regulation or supply and demand of DPTs and/or other digital assets.\ \ DPTs are not considered legal tender and may not be backed by governments or other legal entities, or by commodities such as gold or silver, and are a unique kind of currency, backed by technology and trust. There is no central bank that are able to undertake corrective measures to protect the value of DPTs in a crisis, manage the demand or supply of DPTs or smoothen any fluctuations in the price or value of DPTs. Instead, DPTs are an autonomous and largely unregulated worldwide system of currency.\ \ **XREX makes no representations, warranties or undertakings on whether any DPT will always be available to trade on the Site, and/or be supported by XREX. XREX may, in its sole and absolute discretion, delist any DPT.** **(2) MARKET RISKS** The prices of DPTs have historically been subject to dramatic fluctuations and are highly volatile. Due to such price fluctuations, you may increase or lose value in the DPTs at any given moment. DPTs may even become worthless. You should not commit funds to trading in DPTs that you are not prepared to lose entirely.\ \ Several factors may influence the market price of the DPTs, including, but not limited to: * global DPTs supply and demand, which can be influenced by the growth of merchants’ and commercial businesses’ acceptance of DPTs as payment for goods and services, the security of DPTs and digital asset exchanges and digital wallets, and the regulatory restrictions on the use and trading of DPTs; * currency exchange rates, including the rates at which DPTs may be exchanged for fiat currencies; * interruptions in service from or failures of major blockchain exchanges on which the DPTs may be traded; * investment and trading activities of large purchasers, including private and registered funds, that may directly or indirectly invest in the DPTs; * monetary policies of governments, trade restrictions, currency devaluations and revaluations; * regulatory measures, if any, that affect the use of digital assets such as the DPTs; and * global or regional political, economic or financial events and situations. Markets for DPTs have varying degrees of liquidity. Some DPTs are liquid while others may be illiquid. XREX does not guarantee that the markets for any DPT will be active and liquid, or that you would be able to buy or sell any DPT whenever you desire or at a favourable price. XREX does not guarantee any profit from trading in DPTs or any other activities associated with the Services. **(3) LEGAL AND REGULATORY RISKS** *Government regulation and Applicable Laws.* DPTs are a relatively new asset type and the continued popularity of and risks involving DPTs has attracted and will continue to attract regulatory scrutiny. Regulation of DPTs and VASPs is unsettled and rapidly evolving, and may severely impact the development and growth of this market and the secondary market for the DPTs. The application and interpretation of existing laws and regulations are largely untested and there is a lack of certainty as to how they will be applied. New laws and regulations may be promulgated in the future that apply to blockchain technology and DPTs, and related service providers, and no assurance can be given that any such changes will not adversely affect DPTs generally (including the use, transfer, exchange and value of DPTs) or the Services. \ \ Changes in Applicable Laws may affect the price, liquidity and/or tradability of DPTs, or the use of any Services. DPTs may decrease in value or lose all of its value due to such changes.\ \ Regulatory actions by governmental authorities could negatively impact DPTs in various ways, including a determination, whether retrospectively or prospectively, that DPTs are financial instruments requiring licensing or registration in certain jurisdictions.\ \ XREX may have to suspend, restrict or limit the trading of certain DPTs or the use of certain Services or disallow users to trade DPTs or use any of the Services based on their citizenship, residence or location if doing so is commercially unsustainable or is prohibited by any Applicable Laws. Changes to Applicable Laws could materially and adversely affect the price, liquidity and/or tradability of DPTs, or the use or availability of any Services.\ \ **XREX has sole and absolute discretion to suspend or reject the execution of any of your instructions, suspend or cease support for any DPTs, or suspend or terminate your access to any accounts or Services, where any such action or inaction is, in XREX’s sole opinion, necessary to facilitate XREX's compliance with Applicable Laws.** **(4) TECHNOLOGY AND RELATED RISKS** *Technology risks.* DPTs rely on various types of distributed ledger technology. Some of this technology is open-source software that is built upon experimental technology, namely blockchain. XREX does not own or control such technology. Risks arising from relying on such technology include the existence of technical flaws in the technology, targeting by malicious persons, changes in the consensus protocol or algorithms, decreased community or miner support, the existence or development of competing networks, platforms and assets, flaws in the scripting language, disputes between developers, miners and/or users and regulatory action. Such changes may materially affect the value, availability and functionality of the DPTs you store in your XREX Account. XREX does not control the timing and features of these changes and it is your duty to keep yourself updated of any potential or implemented changes to any DPTs or the technology and you must carefully consider publicly available information and information that may be provided by XREX in determining whether or not to continue to trade in the affected DPT.\ \ **XREX reserves the right, in its sole discretion, to suspend or cease to support the transfer, storage or trading of any DPT in response to any technology changes. XREX may, but is not obligated to, make changes to your XREX Account in response to such changes. You may be unable to withdraw DPTs if XREX ceases to support transfer of any such DPTs as a result of these technology changes, which may result in the total loss of any such DPTs remaining in your account. XREX will not be liable for any Losses you may experience as a result.** \ \ \&#xNAN;*Network and other risks.* The underlying protocols supporting the Services, and the smart contracts that underlie the DPTs may be subject to certain risks that are beyond our control, and which may result in events, such as (a) loss of control or ownership of your DPTs and (b) transaction records on the blockchain being altered, reversed or otherwise invalidated, whether by way of fraudulent acts or consensus.\ \ \&#xNAN;*Transactions irreversible.* Transactions involving DPTs on blockchain networks are generally irrevocable and irreversible. This means accidental or fraudulent transactions in respect of, or loss or theft of your DPTs may not be reversible. XREX will not be liable for any losses that you may experience in such a scenario.\ \ \&#xNAN;*Loss of private key(s) is permanent and irreversible.* A digital private key is required to access and trade your DPTs. The loss or theft of your private keys will permanently and irreversibly deny you access to your DPTs and hence, you may lose all value of your DPTs. XREX will not be liable for any losses that you may experience in such a scenario. **(5) CYBER-SECURITY, INTERNET AND RELATED RISKS** *Cyber-attacks and other criminal activities.* Cyber-attacks may take different forms, including (but is not limited to) distributed denial of service, computer viruses, spyware, scareware, Trojan horses, worms, malware, double-spending, majority-mining, consensus-based or other mining attacks, misinformation campaigns and spoofing, communication failures and disruptions, which may affect the features, functions, operation, use, access or other properties of the Services and your XREX Account(s). The Services and your accounts may also be exploited for vulnerabilities in smart contracts and other code, as well as to human error. Any such cybersecurity failures or breaches, whether involving the Site or third-party service providers, could have a negative impact on the price, liquidity and/or tradability of DPTs, or the use of any Services. \ \ \&#xNAN;*Cryptographic advancements.* Developments in cryptographic technologies and techniques, including (but not limited to) the advancement of artificial intelligence and/or quantum computing, pose security risks to all cryptography-based systems including the Services, the network infrastructure and your DPTs. These ill-intended use of these advancements may result in theft, loss, disappearance, destruction, devaluation or other compromises of your XREX Account(s) and Funds. \ \ \&#xNAN;*Reliance on the internet.* Transactions rely heavily on the internet and other technologies. However, the public nature of the internet means that either parts of the internet or the entire internet may be unreliable or unavailable at any given time. Further, interruption, delay, corruption or loss of data, the loss of confidentiality in the transmission of data, or the transmission of malware may occur when transmitting data via the internet and/or other technologies. \ \ \&#xNAN;*Unauthorised access.* Any information (including any document) transmitted, or communication or transactions made, over the internet or through other electronic media (including electronic devices, services of third party telecommunication service providers such as mobile phones or other handheld trading devices or interactive voice response systems) may be subject to interruption, transmission blackout, delayed transmission due to data volume, internet traffic, market volatility or incorrect data transmission (including incorrect price quotation) or stoppage of price data feed due to the public nature of the internet or other electronic media. Any DPT may be lost forever if it is sent to the wrong address, such as improper address format and erroneous wallet address.\ \ \&#xNAN;*Operational issues.* Any technological difficulties could prevent your access to your XREX Account or use of the DPTs stored in your XREX Account. For instance, you may be prevented from sending an instruction or initiating a transaction and you may not be able to deposit, withdraw or transfer your DPTs instantaneously. XREX shall not be liable for any losses suffered from any price movements of the DPTs during this period of time.\ \ **XREX makes no representation, warranty or undertaking of any kind, express or implied, statutory or otherwise, regarding any of its technology or blockchain functionalities. XREX does not guarantee the functionality or security of any DPTs or their underlying technology. You acknowledge and accept the risk of any changes or breach of security to the Services, its underlying technology and to the Funds in your XREX Wallet and/or XREX Account(s).**\ \ **You further acknowledge and accept that XREX does not control Internet signal power, its reception or routing, configuration of your equipment or its reliability, and that XREX shall not be responsible for any communication failures, disruptions, errors, distortions or delays you may experience when using the Services, however caused.** **(6) THIRD-PARTY RISKS** There is no guarantee that any person or business who currently accepts DPTs as payment will continue to do so in the future. XREX has no control over, and assumes no liability, for the delivery, quality, safety, legality or any aspect of any DPT that you may receive from or transfer to, any third party. **(7) COMMUNICATION RISKS** There is a risk that you may suffer Losses arising from or in connection with XREX accepting and acting on any instructions over the Site, XREX Pay and/or any other channel, platform or communication service which appears to XREX to be from you and which turns out to have been forged, fraudulent or unauthorised and/or any miscommunication, communication breakdown, forgery, delay, mutilation or duplication in connection with the transmission of any instructions to XREX. **(8) CONFLICTS OF INTEREST RISKS** Actual, potential and/or perceived conflicts of interest may arise while providing the Services to you.\ \ For instance, conflicts of interest may arise between our personnel responsible and accountable for safeguarding your DPTs, and those personnel who make investment, trading or other discretionary decisions on your behalf. If such risks are not mitigated, there may be a risk of misuse of your DPTs. To mitigate such risks, XREX has implemented the following measures: 1. XREX will ensure the segregation of duties to guard against the risk of unauthorised transactions; 2. XREX will implement controls and clear reporting lines for such personnel responsible for safeguarding your DPTs to a senior manager who is resident in Singapore and is independent from trading and commercial decisions; and 3. XREX will provide for different personnel to hold the digital keys and no single employee would be able to solely authorise and effect the disposition, transfer or withdrawal of your DPTs. In determining prospective DPTs which we intend to support on our Site, conflicts of interest may arise if we support DPTs that are issued by us or our related corporations or if we receive incentives to support certain DPTs. Please refer to our Statement on Listing of DPTs for more details on the potential conflicts of interest and the mitigating measures.\ \ WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, YOU ACKNOWLEDGE THAT, BY ACCESSING AND USING THE SERVICES YOU ARE ENGAGING IN FUNDAMENTALLY RISKY TRANSACTIONS INVOLVING SOPHISTICATED INSTRUMENTS. DPTS ARE HIGHLY VOLATILE INSTRUMENTS AND CAN RAPIDLY AND UNEXPECTEDLY DECREASE IN VALUE. TRANSACTING IN DPTS ALSO REQUIRES A CERTAIN LEVEL OF TECHNICAL KNOWLEDGE AND UNDERSTANDING WITHOUT WHICH USERS MAY LOSE THE VALUE OF, OR ACCESS TO, SOME OR ALL OF THEIR DPTS. BY ACCESSING THE SERVICES YOU AGREE THAT YOU ARE VOLUNTARILY ENGAGING IN INHERENTLY RISKY TRANSACTIONS AND THAT YOU ARE AWARE OF THE RISKS INVOLVED INCLUDING BUT NOT LIMITED TO, RISKS OF FINANCIAL LOSS, LOSS OF ACCESS TO DPTS AND FIAT CURRENCIES DUE TO TECHNICAL ERRORS, SYSTEM DOWNTIME, SOFTWARE FLAWS AND CYBER-HACKS WHICH COMPROMISE THE SECURITY OF OUR SERVICES AND/OR YOUR OWN PERSONAL SYSTEMS. #### **3. LIMITATION OF LIABILITY** IN NO EVENT WILL THE LIABILITY OF XREX, THEIR RESPECTIVE AFFILIATES, AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS, OR CONTRACTORS ARISING OUT OF OR IN CONNECTION WITH THE SITE, THE SERVICES, THE XREX MATERIALS, ANY PERFORMANCE OR NON-PERFORMANCE OF THE SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM PROVIDED BY OR ON BEHALF OF XREX, WHETHER UNDER CONTRACT, STATUTE, STRICT LIABILITY OR OTHER THEORY (INCLUDING, FOR AVOIDANCE OF DOUBT, ANY NEGLIGENCE OF XREX) EXCEED THE RELEVANT AMOUNT OF THE FEES PAID BY YOU TO XREX UNDER THIS AGREEMENT IN THE TWELVE-MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM FOR LIABILITY, OR THE PERIOD OF DURATION OF THIS AGREEMENT BETWEEN YOU AND XREX, WHICHEVER IS SHORTER. This Limitation of Liability shall apply to the fullest extent permitted by the Applicable Laws. The Limitation of Liability in this Section is subject to any obligations that we have under Applicable Laws, including our obligation to exercise reasonable care and skill in our provision of the Services. Nothing in this Agreement shall limit our liability resulting from our fraud or fraudulent misrepresentation, gross negligence, deliberate misconduct, nor for death or personal injury resulting from our negligence. #### **4. No Warranties:** All services and products are provided on an “**AS IS**” and “**AS AVAILABLE**” basis. To the fullest extent permitted by the Applicable Laws, XREX disclaims any representations and warranties of any kind, whether express, implied, or statutory, including, but not limited to, the warranties of merchantability and fitness for any particular purpose. # 6. Safeguarding Measures 1. **Safeguarding Arrangements** 1. Upon receipt of your Relevant Money by XREX, your Relevant Money shall be deposited and held by XREX in separate designated Safeguarding Account maintained by XREX with banks or other duly licensed financial institutions (each a “**Safeguarding Institution**”) by no later than the next Business Day following such receipt. 2. Upon receipt of your DPTs by XREX, your DPTs shall be deposited and held by XREX in separate designated Trust Account maintained with XREX and/or such other person that is appointed by XREX to safeguard your DPTs in accordance with Applicable Laws (“**Safeguarding Person**”). 2. Your Funds deposited in the Safeguarding Account and Trust Account will be held on trust by XREX on behalf of you and are segregated and maintained separately from XREX’s own corporate funds. Subject to the Applicable Laws, all assets deposited in the Safeguarding Account and the Trust Account cannot be used for the payment of the debts of XREX and are not liable to be taken under or pursuant to an enforcement order or a process of any court. However, you should be aware that XREX may exercise its right of set off against your Funds held on your behalf. If the Safeguarding Institution or the Safeguarding Person becomes insolvent, you may not be able to recover any of your Funds if the assets are insufficient to satisfy the claims of its creditors or it may take a long time for you to recover your Funds as the process of liquidation and the distribution of proceeds could take a long time. 3. Your Funds in the Safeguarding Account and the Trust Account are commingled and pooled with the Funds received from other users and are exposed to losses or shortfalls in the pooled funds. Any interest earned from your Funds maintained in the Safeguarding Account and the Trust Account are payable to XREX and will not accrue to you. In the event of any misappropriation of Funds in the Safeguarding Account and the Trust Account, you may suffer loss of your Funds. XREX shall not be responsible or liable to you or any other person or entity for any losses incurred by you in connection with any insolvency and/or default by any Safeguarding Institution and its representatives, except that the foregoing shall not exclude any liability in respect of any losses that are caused directly by fraud or negligence by XREX (as adjudged in a final, non-appealable decision of a court of competent jurisdiction or binding arbitration proceeding). You acknowledge that in the event that there are any outstanding amounts owed by you to XREX as designated by XREX (if any) (“**Owed Amounts**”), your Funds held in the Safeguarding Account and the Trust Account may be used to top up or cover for the Owed Amounts. In the event that the Safeguarding Account or the Trust Account is maintained with a Safeguarding Institution outside Singapore, you acknowledge that the laws and practices relating to Safeguarding Account and the Trust Account in the jurisdiction under which the Safeguarding Institution and the Trust Account is licensed, registered or authorised in may be different from the laws and practices in Singapore relating to the Safeguarding Account and the Trust Account (as the case may be). These differences may include, but are not limited to, varying requirements for segregation of assets, custodial arrangements, and any such differences may affect your ability to recover the Funds deposited in the Safeguarding Account and the Trust Account. The level of protection and recourse available to you may not be equivalent to that provided under Singapore’s laws and regulations governing the Safeguarding Account and the Trust Account. 4. In the event where your Funds are commingled with other users of XREX’s services, there is a risk that your interest may not be identifiable by separate physical documents or electronic records kept by XREX and it may be difficult to identify or earmark your Funds from those of other users. Nevertheless, XREX shall maintain records of your interest in the assets that have been commingled. 5. In order to provide sufficient safeguarding measures to your Funds, XREX shall not permit any withdrawal of your Funds from the Safeguarding Account and the Trust Account from any third parties that is not registered under your account, unless a validly executed authorisation letter has been provided to XREX. XREX shall ensure that each Safeguarding Institution and Safeguarding Person complies with the same. 6. In the event that you are of the view that it has incurred losses due to XREX’s fraud or negligence, you shall provide a written report containing full details of such losses. You should also comply with mitigation measures set out in [Paragraph 1.4.b](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/1.-account). Upon receiving the written report, XREX shall conduct an investigation into your claims. You agree to provide all information and/or documentation which XREX may request for in order for XREX to conduct its investigation. Such information could include a comprehensive account of the incidents, the documentations and records reflecting losses suffered, personal identification number and your bank account information for the purposes of identity verification, and such other information that XREX may reasonably require. XREX shall compensate you for any loss of Funds arising from any fraud or negligence on the part of XREX, as XREX may determine in its sole and absolute discretion or as may be adjudged in a final, non-appealable decision of a court of competent jurisdiction or binding arbitration proceeding, in accordance with the Safeguarding Institution’s policies or insurance schemes. 7. XREX shall comply with all recordkeeping obligations under any written law as applicable and ensure each Safeguarding Institution complies with the same. XREX shall also notify you should there be any fees and costs for the safeguarding of your Funds. 8. XREX maintains and stores a minority portion of customer assets in the settlement wallet, which are used as ready liquidity for daily trading, withdrawal and other transactional activity. This minority proportion of customer assets will be maintained by rebalancing to a specific target percentage that complies with Applicable Laws. Assets are managed between the settlement wallet and vault storage systems to ensure that we have the minimum amount of funds in the settlement wallet required to facilitate the immediate liquidity needs of our customers. 9. To mitigate the risk of loss of customer assets due to cyber attacks, XREX takes extensive security measures to protect your assets, including strategically storing a vast majority of assets offline in secure, guarded vault storage facilities that are not connected to the internet so that they are more resistant to threats. In addition, all settlement wallet private keys are stored in an isolated, dedicated service, in an encrypted format. 10. XREX shall inform you of any rights or entitlements (if any) arising from your Funds held within the Safeguarding Institution, or any information relating your Funds. The information in this Section shall be detailed to you via electronic messaging or email. 11. XREX shall provide you with your monthly statement of account with the following particulars: 1. transactions to purchase or sell assets entered into by you and the price at which the transactions are entered into; 2. the status of every asset in XREX’s custody held on behalf of you, including any asset deposited with the Safeguarding Institution; 3. the movement of each of your asset, the date of and reasons for such movement, and the amount of the asset involved; 4. the movement and balance of relevant money received from, or on account of, you in respect of the provision of XREX’s services; and 5. a detailed account of all financial charges and credits to your account during the monthly statement period, unless the detailed account of financial charges and credits has been included in any contract note or tax invoice issued by XREX to you. 12. XREX shall also provide you with your statement of account as soon as practicable upon your written request. However, Section 6.11 shall not apply if: 1. there is no change to any of those particulars since the date on which the last statement of account was made up to; 2. XREX has made available to you, on a real-time basis, those particulars in the form of electronic records stored on an electronic facility and you have consented to those particulars being made available to you in this manner; or 3. you requested, in writing, not to receive the statement of account on a monthly basis from XREX. 13. You confirm and agree, in including for the benefit of the Safeguarding Institution(s) that: 1. the Safeguarding Account arrangements do not result in you being a party to any agreement with the Safeguarding Institution(s), and you will have no right to enjoy or enforce any benefit under such agreement; 2. the Safeguarding Institution(s) does not owe any obligation to you and you have no right to claim against the Safeguarding Institution(s) in relation to any services provided by the Safeguarding Institution(s) to XREX, and your rights and obligations (if any) in relation to any services provided by XREX to you are exclusively against or to XREX only, and not against or to the Safeguarding Institution(s). 14. XREX reserves the right to impose and/or modify any fees or costs associated with the safeguarding of your Funds. Such fees or costs shall be set out in the Fee Schedule, which can be found in the [XREX Pay Help Center](https://intercom.help/xrex-sg/en/) and may be periodically updated by us at our sole and absolute discretion. You agree to pay XREX the fees and costs by authorising us to deduct and/or debit your Funds for any such fees or costs. We reserve the right to change or modify our Fee Schedule, including increasing our fees in the Fee Schedule, in accordance with [Paragraph 11.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/11.-general-provisions). The updated Fee Schedule will apply prospectively to the relevant Services that take place following the effective date of such updated Fee Schedule. # 7. Taxes 1. You are solely responsible for determining, reporting and paying any Taxes under the Applicable Laws that may arise from the transactions made and/or your use of the Services, in accordance with the Applicable Laws. XREX does not provide investment, legal, financial, business or tax advice in connection with your transactions and is not responsible for determining whether any Taxes apply to your transactions, or for collecting, reporting or remitting any Taxes arising from any transaction. It is your responsibility to check with your local tax advisor to determine which Taxes apply to you (if any), and it is your responsibility to pay such Taxes to the appropriate tax authority. You agree that XREX may report information relating to your transactions, payments, transfers, or distributions to the relevant tax or governmental authority, to the extent such reporting is required by Applicable Laws. 2. All liabilities of you to us (including payment for any fees relating to the Services) are to be made free and clear of, and without any deduction or withholding for and on account of, any Taxes, duties or other deductions. Any such deduction or withholding, if required by the laws of any country or taxation authority shall be your sole responsibility. If any such deduction or withholding is required, you agree to increase the sum payable to XREX to ensure that XREX receives the full amount which would have been due to XREX, had no such deduction or withholding been required. 3. XREX may withhold any applicable Taxes from your transactions, payments, distributions made or deemed made to you, where such withholding is required by Applicable Laws. From time to time, XREX may request tax documentation or certification of your taxpayer status. Failure to comply with this request within the timeframe notified may result in withholding and/or remission of Taxes to the tax authority as required by the Applicable Laws. # 8. AML/CFT and Know-Your-Client (KYC) Policy 1. **Know Your Client (KYC) Policy:** XREX conducts ongoing verification of individuals and organizations using the Services. You agree to provide complete and accurate personal information (including but not limited to your name, email address, registered address, gender, phone number, nationality, date of birth, tax identification number or ID card number or passport number, a bank account registered in your name, and other registration and transaction-related information) that XREX and any appointed third-party service providers including financial institutions and KYC/AML compliance vendors may from time to time request. 2. These third parties may collect, process, or use your personal information for the purposes of performing their designated tasks, which may include verifying the authenticity of your bank account, ensuring compliance with Applicable Laws, and fulfilling AML/CFT obligations. Based on the outcomes of such verifications, XREX and its appointed third parties reserve the right to take any measures they deem appropriate. In providing us with your information, you confirm that (a) the accuracy, authenticity and completeness of all such information, documents and materials and (b) you have not withheld any information, document or material that may influence our evaluation of you for the purposes of registering or maintain your XREX Account or providing Services to you. 3. You represent that you are not, directly or indirectly involved in any activity that may contravene the Applicable Laws, in particular the AML/CFT laws and regulations. 4. You further represent and warrant that, to the best of your knowledge: 1. you; 2. any person controlling or controlled by you; 3. if you are a privately held entity, any person having a beneficial interest in you; and 4. any person for whom you act as agent or nominee in connection with this trading, are not listed on any sanctions of restricted party list issued by the relevant regulatory authority in Singapore or any other applicable jurisdiction.\ \ Please be advised that XREX may not accept any trading activities from a prospective user if it cannot make the representations set forth in Paragraphs 8.3 and 8.4 above. In addition, if you cannot make these representations, XREX, at its sole and absolute discretion, may prohibit, terminate or suspend your trading activities and account. 5. You agree to promptly notify XREX if you become aware of any change in the information provided in Paragraphs 8.3 and 8.4 above. Under the Applicable Laws, XREX may be required to “freeze” your account, including suspending trading activities in order to comply with the regulatory obligations. XREX and/or its representatives may also be required to report such action and to disclose your identity to the relevant authorities. In particular, you agree that XREX shall be entitled to (i) exercise its rights under Paragraphs 1 and 3 of the Terms; and (ii) report instances of fraudulent, criminal, suspicious activity or transactions to the relevant authorities. 6. You agree to promptly provide any additional documentation XREX and/or its representatives may request, as deemed necessary by XREX to comply with Applicable Laws. You acknowledge and consent to the disclosure of such information by XREX and/or its representatives to the regulatory authorities in Singapore or other jurisdictions, particularly in connection with AML/CFT requirements. You further agree to have face-to-face meetings with representatives of XREX or take any other action as XREX may require for purposes of performing enhanced due diligence on you so that XREX may establish your source of wealth and source of funds for any transactions carried out in the course of your use of the Services. 7. You agree that XREX and/or its representatives may disclose your information to one another, to any service provider engaged by XREX, or to any regulatory body in any applicable jurisdiction. Such disclosure shall not be deemed a breach of any legal or contractual restriction on the disclosure of information. 8. **AML/CFT Policy:** XREX constantly monitors transactions conducted on the Site and through its Services. We may suspend or block any transaction without prior notice to you if we have reasonable grounds to suspect that you are a designated individual or entity as defined or set out in the Singapore Sanctions Laws, or that the transaction presents risks related to money-laundering, terrorism financing, or similar unlawful activities. In compliance with Applicable Laws, XREX will report any suspicious activity or transaction to the relevant authorities.\ \ XREX reserves the right to deny or suspend access to the Services to anyone: 1. refusing or unable to provide sufficient evidence of their identity and/or their source of funds to the satisfaction of XREX; 2. providing information which XREX determines to be false, misleading, or otherwise unacceptable in any respect; or 3. is identified as a designated individual or entity as defined or set out in the Singapore Sanctions Laws. 9. **Disputes:** If XREX has reasonable grounds to suspect that you are a designated individual or entity as defined or set out in the Singapore Sanctions Laws or any Applicable Laws, or that any DPTs in your XREX E-Wallet are stolen, unlawfully possessed, or represent the proceeds of any illegal activity, we may, in our sole discretion, place an administrative hold on the affected DPTs. This hold will remain in place until the dispute is resolved and you provide evidence acceptable to XREX. XREX will not participate in or mediate the resolution of such disputes. You acknowledge and agree that XREX shall not be liable for any Losses arising from such a hold, or from your inability to withdraw DPTs or Fiat Money, or to execute transactions during the hold period. 10. You are responsible for ensuring that your email address and mobile phone number on file with us remain current and valid to receive electronic Communications. If we send you an electronic Communication and you do not receive due to outdated or incorrect contact information, the blocking by your service provider, or other delivery issues, the Communication shall nonetheless be deemed to have been provided to you. \ \ You can update your contact details at any time by filing a support request at or informing your designated relationship manager in writing. If your contact details become invalid and the Communications sent to you are returned, we may deem your account inactive, and you may be unable to complete any transaction via our Services until valid and accurate contact information is provided.
# 9. Indemnification 1. None of the Indemnified Parties shall not be liable to you for any Losses, arising out of or in any way connected with: 1. the use or performance of the Site or the Services thereon; 2. trading activities conducted on the XREX platform; 3. the withdrawal or settlement process; 4. the delay or inability to use the Site or the Services thereon; 5. any Force Majeure Event; 6. the provision of or failure to provide the Site or the Services thereon; 7. any third-party operator or open-source software on which the Services provided by XREX may be reliant on; 8. any changes to the operation of the underlying protocols of a blockchain or other circumstances that XREX has no control over, which may result in one or more blockchains emanating from the original blockchain (as applicable); 9. any distributions made by third parties of new DPTs to eligible persons (including distributions whereby the new DPTs are intended to replace existing DPTs) (as applicable); 10. any information, data, software, products, services and related graphics obtained through the Site or the Services thereon; 11. any reliance on any statement, opinion, representation or information on the Site or the Services thereon; or 12. otherwise arising out of the use of the Site or the Services thereon, whether based on contract, tort, strict liability or otherwise, except where such Losses arise from fraud by XREX. 2. You shall irrevocably and unconditionally defend, indemnify, and hold harmless the Indemnified Parties from and against any and all Losses arising out of or relating to: (a) your use of, or conduct in connection with, the Services, whether or not such access or use was authorised or whether it was due to any act or omission on its part; (b) any Feedback or User Content you provide; (c) your violation of these Terms including any representation, warranty, agreement or undertaking by you under this Agreement or our enforcement of this Agreement; (d) your violation of any Applicable Laws or the rights of any other person or entity; and/or (e) any sum or obligation expressed to be payable or liable to be performed under this Agreement not being paid or performed by you by the time, on the date and otherwise in the manner specified in this Agreement. 3. If you are obligated to indemnify any Indemnified Party, XREX (or, at our discretion, the applicable Indemnified Party) will have the right, in its sole discretion, to assume control of any action or proceeding and to determine whether to settle such matter and on the terms of such settlement. 4. **Limitation of Liability.** In the event that XREX is liable to you for damages, you agree that XREX’s aggregate liability to you for any and all Losses shall not exceed the total amount of fees and charges paid by you to XREX in the 12-month period immediately preceding the time such liability arose. # 10. Governing Law and Dispute Resolution PLEASE READ THIS SECTION CAREFULLY. 1. **Governing Law.** Any dispute arising from this Agreement will be governed by and construed in accordance with the laws of Singapore, without regard to any conflict of laws principles that would result in the application of the laws of another jurisdiction. Regardless of whether a Dispute (as defined below) is heard in arbitration or in court, you and XREX agree not to initiate or participate in any class action, class arbitration or representative action or proceeding against the other party. 2. **Dispute Resolution.** Subject to compliance with Paragraph 10.3 below, you agree that all disputes, controversies or differences arising out of or in connection with the Agreement, including any question regarding its existence, validity or termination (“**Dispute**”), shall be referred to and finally resolved by arbitration conducted in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (the “**SIAC**”) (“**SIAC Rules**”), which rules are deemed to be incorporated by reference to this Paragraph 10.2. The seat of the arbitration shall be Singapore. The language of the arbitration shall be English. The tribunal shall consist of one arbitrator, to be appointed by the President of the SIAC. PLEASE NOTE THAT ARBITRATION PREVENTS YOU FROM SUING IN COURT OR FROM HAVING A JURY TRIAL. Notwithstanding Paragraph 10.3.a, you and XREX agree to notify each other in writing (including via electronic Communication) of any Dispute within thirty (30) days from the date the Dispute arises. 3. Procedures Prior to Arbitration: 1. If you have any Dispute with XREX regarding the Services, you agree to file a Formal Complaint before pursuing any other legal actions. This allows us to attempt resolution of the Dispute effectively and efficiently. A Formal Complaint must be submitted via email to as soon as possible with the subject line “**Formal Complaint Process**” and must include: 1. Your full contact information; 2. A detailed description of the issue or Dispute (including relevant dates, times, and parties involved); 3. Supporting documentation; 4. The impact of the issue or Dispute on you; 5. The resolution you are seeking; 6. All prior communications with XREX personnel; and 7. A confirmation that the information provided is accurate and all material information have been provided. 2. Failure to submit a Formal Complaint within thirty (30) days of the Dispute or to provide complete information prior to initiating legal actions or seeking equitable relief may result in XREX requesting the arbitrator or court to issue an injunction, stay proceedings or dismiss the claim until the Formal Complaint Process is completed. 3. If any such Dispute is not settled amicably within ninety (90) days from the date of your Formal Complaint, the Parties agree to refer the matter to arbitration in accordance with Paragraph 10.2 above. In the event of any conflict between the SIAC Rules and these Terms, these Terms shall prevail. # 11. General Provisions 1. **Inconsistency.** Please take the time to read and understand these Terms before using the Services so that you are aware of your legal rights and obligations. In the event of any inconsistency between these Terms and any Annex, the relevant Annex shall prevail. 2. **No Other Relationship or Advice.** XREX is not your broker, intermediary, agent, trustee or advisor and has no fiduciary relationship or obligation to you. XREX also does not provide any advice or participate in any aspect of the user’s investment on the XREX platform. Your decision to invest in any DPT shall solely be yours and you are solely responsible for determining whether any transaction is appropriate for you based on your personal objective, financial circumstances and risk tolerance. You should consult your legal, financial or tax professional regarding your specific situation. 3. **Compliance with Applicable Laws.** You must comply with all Applicable Laws and third-party rights (including, without limitation, data privacy laws and AML/CFT laws) in your use of the Services and the Site. You should seek professional advice if in doubt to ensure compliance with all Applicable Laws. 4. **Amendment**\ XREX may, in its sole and absolute discretion, supplement, vary or amend the Terms from time to time immediately upon written notification to the user. XREX will provide written notification of the modification of these Terms either by sending you an email, by updating the “**Last Updated**” presented at the top of these Terms or by a pop-up window on XREX’s platform. By either (1) clicking the button or a check box presented with the modified Terms to record your consent; or (2) providing your written consent via email to [support@xrex.sg](about:blank), indicating your acceptance of the modified Terms, you agree to be bound by the updated or modified Terms. It is your responsibility to review the Terms regularly upon each access or use to ensure that you are aware of any changes made by XREX. If you do not agree to any modification of the Terms, you must immediately cease using the Services. You are responsible for periodically reviewing the Terms. Your continued access or use of the Site and/or Services after such changes are posted, regardless of whether you have reviewed them, constitutes your acceptance of the modified Terms and your agreement that the revised Terms apply to all current and prior use of the Site. Any questions related to these Terms can be directed to our support team via [support@xrex.sg](about:blank). 5. **Hardware and Software Requirements**\ It is your responsibility to ensure that you have and will maintain the requisite hardware and software, including cybersecurity software and stable and secured internet, to access the Services and communicate with XREX. 6. **Security Interests.** You represent and undertake not to create any security over your Funds held in your Accounts without our prior written consent. 7. **Unclaimed Balances.** If we are unable to contact you after making reasonable attempts or your Account is inactive, suspended and/or terminated, and there are balances in the XREX Account that we are not prohibited from transferring to you under Applicable Laws (“**Unclaimed Balances**”), you expressly acknowledge and agree that we may charge an inactivity or other administrative fee to you, which may be deducted from your Unclaimed Balances, and that we may concert any Unclaimed Balances into any other fiat currency and/or DPTs as we deem appropriate, at such time and rate as we deem appropriate in our sole and absolute discretion. It is your responsibility to contact us to arrange for the transfer of your Unclaimed Balances to you and you must provide us with a bank account or e-wallet address that meets our requirements for you to receive the Unclaimed Balances. Notwithstanding that your Unclaimed Balances may be in one or more fiat currencies and/or DPTs, we shall have no obligation to process a return of all Unclaimed Balances in the same asset and we may require you to convert all Unclaimed Balances into a single fiat currency and/or DPT before returning the Unclaimed Balances to you. 8. **Communications** 1. Should you have any issues, questions, feedback, or comments on the Services or these Terms, you can contact XREX through your designated relationship manager in writing, or send an email to [support@xrex.sg.](about:blank) 2. Consent to Electronic Delivery: You consent to receive electronically all Communications that we provide in connection with this Terms, your account, or any Services. 3. You may withdraw your consent to receive electronic Communications by sending a withdrawal notice to our Support Team by filing a support request at [support@xrex.sg,](about:blank) or informing your designated relationship manager in writing. If you decline or withdraw consent to receive electronic Communications, we may suspend or terminate your use of the Services. 4. Requesting Paper Copies 1. If you have consented to receive Communications electronically and wish to obtain a paper copy of any Communication previously provided to you, you may submit a request within 30 days from the date the Communication was made available, by contacting us at [support@xrex.sg](about:blank). 1. To receive paper copies of the Communications, you must maintain a current street address on file with us. Please note that our Services operate exclusively online, and the production of paper copies imposes a significant administrative burden. Accordingly, by requesting paper copies, you acknowledge and agree that we may charge a processing fee along with any applicable costs in fulfilling your request. 9. **XREX’s Affiliates and Contractors.** The Site and any Services may be operated or provided by XREX, its Affiliates, or their respective contractors. Where an Affiliate or contractor of XREX is operating or providing any Services, such Affiliate or contractor shall be subject to the same Terms to the extent applicable. 10. **Entire Agreement.** This Agreement sets forth the entire understanding between XREX and you with respect to the Services. 11. **Non-waiver.** XREXʼs failure, delay or forbearance in exercising any right, power, or privilege under these Terms shall not operate as a waiver thereof, nor will any single or partial exercise of any right under this Agreement preclude any other further exercise of it or any other right of remedy. 12. **Severability.** If at any time any provision of the Terms is or becomes illegal, invalid or unenforceable under the laws of any jurisdiction, that shall not affect: (a) the legality, validity or enforceability in that jurisdiction of any other provision of the Terms; or (b) the legality, validity or enforceability under the laws of any other jurisdiction of that or another provision of the Terms. 13. **Force Majeure.** XREX has no responsibility or liability for any failure or delays in the performance of any Services, or any Losses that you may incur, due to any Force Majeure Event. 14. **Assignment.** You may not assign or transfer any right to use the Services or any of your rights or obligations under these Terms without prior written consent from us. Where it is in the XREX’s interest to do so, XREX may, from time to time immediately upon written notification to you, assign or transfer to any third party (including, without limitation, to any of its Affiliates) any of the XREX’s rights and obligations under the Terms without your consent and you irrevocably consent to any such assignment or transfer by XREX. 15. **Third Party Contracts Act.** Unless expressly provided to the contrary in this Agreement, a person who is not a party to this Agreement (whether or not such person shall be named, referred to, or otherwise identified, or shall form part of a class of persons so named, referred to, or identified, in this Agreement) has no rights under the Contracts (Rights of Third Parties) Act 2001 of Singapore to enforce this Agreement or any of its terms. 16. **Separately Negotiated Arrangements** 1. From time to time, and subject to the Applicable Laws, XREX may at its sole discretion, enter into separately negotiated arrangements with certain users through confidential agreements that supplement specific economic or other terms of this Terms. Such arrangements shall apply to the relevant user’s relationship with XREX and their use of the Services. These arrangements may include, without limitation: (i) different incentives such as modified economic, funding, fee terms, or other payments; and (ii) access to additional or customized market information not generally available to other users. 2. Any such separately negotiated arrangements will be determined based on factors or considerations determined relevant by XREX in its sole discretion, and may be exclusive to that user. You acknowledge and agree that any separately negotiated arrangement with another user shall not affect the validity or enforceability of these Terms as between you and XREX. 17. **Third Party Websites** 1. The Site may contain information concerning third parties, third party products and services or links to third-party websites or applications. XREX does not monitor, control or endorse these third parties, their products, services, websites or applications. Any links to other websites are provided as a convenience to the user, and does not imply XREX’s endorsement of the linked website or association with their operators. 2. XREX makes no representation as to the quality, suitability, functionality, accuracy or legality of the materials on third party websites that are linked to, or to any goods and services available for such websites. 3. To the maximum extent permitted under the Applicable Laws, XREX is not responsible and disclaim all liability for (a) such third party products, services, websites or applications; (b) for any act or omission of these third parties, or (c) any dealings between you and these third parties, whether or not such dealings have been performed or facilitated through the Site, arising out of or in relation to anything done or omitted to be done in relation to these materials, or any delay, inaccuracies or omissions in the materials or any interruption to the supply of materials. 18. **Language.** XREX may, in its sole and absolute discretion, translate this Agreement into a language other than the English language. Where XREX has provided a translation of the English language version of these Terms (the “**English Version**”) for your convenience, the English Version governs the relationship between you and XREX. In the event of any conflict between the English Version and a translation thereof, the provisions in the English Version shall take precedence over any other translation. 19. **Headings.** Headings of sections are for convenience only and shall not be used to limit or construe such sections. # ANNEX 1 - STATEMENT ON CRYPTOCURRENCY LISTING AND GOVERNANCE POLICIES This Statement on Cryptocurrency Listing and Governance Policies (this “**Statement**") is made available to provide greater clarity and transparency regarding the policies and procedures that are established by us to evaluate the cryptocurrencies that are supported by us. You should evaluate this Statement to make an informed assessment as to such policies and procedures before engaging in any of the digital payment token services that we provide. Unless otherwise defined in this Statement, all capitalised terms used in this Statement shall have the meanings ascribed to them in the XREX General Terms and Conditions. 1. **EVALUATING PROSPECTIVE CRYPTOCURRENCIES** (1) **Cryptocurrencies Listing Committee.** To evaluate prospective cryptocurrencies that we intend to support, we have established a committee comprising certain members of senior management (“**Committee**”), which would oversee the process of evaluating such cryptocurrencies. This is conducted through a rigorous review process that evaluates assets against legal, compliance, risk, and technical security standards. (2) **Cryptocurrencies Listing Assessment.** We have established a cryptocurrency listing assessment (“**Listing Assessment**”) to evaluate a cryptocurrency’s suitability for inclusion on our platform. The Committee is responsible for administering the cryptocurrency assessment framework in accordance with our policies and procedures. This Listing Assessment covers various criteria (such as an evaluation of commercial, governance, technical, and legal criteria), including but not limited to: (a) the founding team and developers of the cryptocurrency; (b) the governance model and token allocation plan (if any) of the cryptocurrency; (c) the supported token protocol for the cryptocurrency; (d) the business use case of the cryptocurrency; (e) the track record, history and reputation of the cryptocurrency; (f) the legal characterisation of the cryptocurrency; (g) the cybersecurity certifications and measures implemented in connection with the cryptocurrency; (h) assessment of the cryptocurrency's features that could heighten money laundering or terrorism financing risks; (i) the supported blockchains and any monitoring or screening of the cryptocurrency; (j) the market capitalisation of the cryptocurrency; and (k) the liquidity and volatility of the cryptocurrency. 2. **ONGOING MONITORING** (1) We monitor the cryptocurrencies on our platform on an ongoing basis to ensure they continue to comply with our listing standards. When a cryptocurrency no longer complies with the standards, we may conduct a review and suspend trading, delist or cease support on the cryptocurrency. (2) The following factors may be taken into consideration in our review: (a) Cryptocurrency no longer meets our legal, compliance and technical security standards; (b) Responsiveness of the developers to our ongoing due diligence question and request for information; (c) No visible product development or commitment from the project team; (d) Trading volume and liquidity on the markets on the platform; (e) Significant events such as security breach or compromise of DPT’s network; and (f) Sanction and adverse media, including money laundering or terrorism financing risks, on the founders or issuer or parties associated with the cryptocurrency. (3) The decision to suspend or delist will be made by the Committee. We will provide customers with timely and clear communication regarding the suspension or delisting process and the implications for their holdings. **Processes for Suspending, Delisting, and/or Ceasing to Support a Cryptocurrency.** (4) If we decide to cease support for a cryptocurrency, we will take the following steps where appropriate: (a) notifying you and the regulatory authority of the decision and, if appropriate, the reasons for doing so; (b) notifying you of the date and time by which we intend to cease support; (c) notifying you of your rights and options in relation to the cryptocurrency before support is ceased; and/or (d) notifying you of the consequences if you do not take any action in relation to the cryptocurrency (including unilaterally selling and/or converting your cryptocurrency) before support is ceased. (5) Generally, we endeavour to use commercially reasonable efforts to provide you with prior written notice of any decision to cease support for a cryptocurrency. If we provide you with such prior written notice, you may sell, convert, and/or (if supported by us) transfer the cryptocurrency before support is ceased. However, if you do not take any action by the specified time notified to you, we may unilaterally sell and/or convert the cryptocurrency in your account. In addition, you should also be aware that you may not always be given each of the rights to sell, convert, and/or transfer the cryptocurrency, especially cryptocurrency transfers are not supported by us for the cryptocurrency. (6) You should also be aware that it may not always be practicable to provide you with prior written notice of ceasing support for any cryptocurrency (for example, in the case of a significant market dislocation and/or absence of liquidity over a short period), although we endeavour to use commercially reasonable efforts to notify you as soon as practicable. In such circumstances where we cease support of any cryptocurrency without giving you prior written notice, we may unilaterally sell and/or convert the cryptocurrencies at the time we cease support for such cryptocurrency and we shall not be liable for any Losses that you may suffer in respect of such sale and/or conversion. 3. **CONFLICT OF INTERESTS IN SUPPORTING CERTAIN CRYPTOCURRENCIES** (1) Potential or actual conflicts of interests may arise under certain circumstances when we are assessing whether to support any cryptocurrency. We are committed to mitigating such risks by implementing appropriate and effective policies and procedures, which should include but is not limited to: (a) a segregation of compliance and commercial functions to provide a degree of independence in the Listing Assessment; and (b) regarding supporting any cryptocurrency whereby (i) we are given any incentive to do so by the issuer and/or any other person and/or (ii) the issuer is a related or affiliated company of us, to declare such conflicts of interest to the Committee for consideration and thereafter implement appropriate steps to mitigate such risks including disclosure to customers on a case-by-case basis. For more information, please refer to our Terms for further information. 4. **ADDITIONAL DISCLAIMERS** (1) **No Guarantees Regarding Cryptocurrencies Listed on the Site.** You acknowledge and agree that: (a) our decision to support any cryptocurrency on our platform does not indicate our approval or disapproval of the cryptocurrency or the integrity, security or operation of the cryptocurrency or its underlying technology, and the risks associated with cryptocurrencies and trading of cryptocurrencies still apply notwithstanding our decision to support a particular cryptocurrency on our platform; (b) we may be reliant on public information and representations made by third parties that are not controlled by us, and we are unable to warrant or guarantee that such information are accurate, complete, updated, not misleading, and/or authentic; (c) our opinions on the legal characterisation of any cryptocurrency is confined under the financial services law and regulations in Singapore and such cryptocurrencies may be characterised differently under the laws of any other jurisdiction; and (d) under no circumstances shall any of the Indemnified Parties be responsible or liable to you or any other person or entity for any Losses by reason of, or arising from, or as a consequence of any reliance by us on such third party information in our evaluation of cryptocurrencies. (2) **No Guarantees of Full Support for All Cryptocurrency Services.** If we decide to support a cryptocurrency, you acknowledge and agree that we may not support all cryptocurrency services for such cryptocurrency. For example: (a) we may support only trading of a cryptocurrency and not deposits/withdrawals of the cryptocurrencies on any blockchain network; and (b) we may support only limited deposits/withdrawals of a cryptocurrency on a specific blockchain network, and not all blockchain networks that the cryptocurrency may be supported. It is your sole responsibility to review the extent to which any cryptocurrency is supported before using any of the Services. # XREX BitCheck Service Agreement Last Update: 03 Nov 2025 All capitalised terms used herein, unless otherwise defined, have the meanings ascribed to them in the General Terms and Conditions. All provisions of the General Terms and Conditions are hereby incorporated by reference mutatis mutandis. The terms herein (the “**BitCheck Terms**”) govern your use of the BitCheck offered by our platform (the "**Platform**"). Before using the BitCheck, you agree to be bound by the following BitCheck Terms: 1. Definitions 1. “**BitCheck**” is XREXʼs proprietary escrow function which locks users’ Funds for a transaction until the BitCheck Issuer and BitCheck Recipient have each fulfilled their respective obligations for a Funds transfer to take effect. 2. “**BitCheck Contract**” is an optional add-on feature based on a specific BitCheck transaction for the purpose of documenting such a transaction. 3. “**BitCheck Issuer**” means the BitCheck User who initiates a BitCheck transaction with another BitCheck Recipient. “BitCheck Issuer” and “Bitcheck Sender” are used interchangeably, as the context requires. 4. “**BitCheck Recipient**” means the BitCheck User who receives a BitCheck from the BitCheck Issuer. “BitCheck Recipient” and “Bitcheck Receiver” are used interchangeably, as the context requires. 5. “**BitCheck User**” means BitCheck Issuer, BitCheck Recipient, or both, as the context may require. Only users who have completed XREX’s KYC checks to XREX’s satisfaction can be BitCheck Users. 6. “**General Terms and Conditions**” means the general terms and conditions in relation to the access to or use of services by XREX Pte. Ltd. and its Affiliates. 7. “**Losses**” means claims, demands, actions, suits, proceedings, investigations, losses (direct or consequential), damages (including any ordinary, direct, indirect, consequential, incidental, special, punitive or exemplary damages), expenses, disbursements, charges and costs (including legal costs on a full indemnity basis and any other expenses properly incurred) inclusive of all duties and taxes including any goods and services tax and all other liabilities of any kinds or nature or description whatsoever and howsoever arising (whether directly or indirectly). 2. **Escrow Service via BitCheck** 1. BitCheck Users may transfer a specified amount of their Funds to another XREX user via BitCheck. Upon issuance of a Bitcheck, these Funds shall be immediately locked on the Platform until either: (a) both the BitCheck Recipient and the BitCheck Issuer mutually agree to cancel the BitCheck; or (b) the BitCheck Issuer releases the locked Funds and the BitCheck Recipient accepts the relevant Funds. 2. For the avoidance of doubt, the BitCheck Recipient may only withdraw or transfer the relevant Funds, including to external e-wallets outside XREX’s control and/or bank account under the BitCheck Recipient’s name, upon the BitCheck Issuer’s release of the BitCheck. 3. In the event of any dispute between the BitCheck Issuer and BitCheck Recipient regarding the locked Funds, both parties shall be solely responsible for resolving such dispute independently. Upon request in writing by either Bitcheck User, XREX may, at its sole discretion, facilitate communication between the parties to support amicable resolution of such dispute. However, XREX shall have no obligation to do so and makes no representation, warranty or guarantee regarding the outcome or effectiveness of such facilitation. 4. Where such a dispute arises between the BitCheck Users, the BitCheck Issuer shall not be obliged to release the relevant Funds to the BitCheck Recipient until such dispute is resolved. You acknowledge and agree that XREX shall bear no liability or responsibility for any withholding of the relevant DPTs and/or Funds, or for your inability to withdraw DPTs or Funds or to execute trades, during the period of such withholding. 3. **BitCheck Contract** 1. When BitCheck Issuer issues a BitCheck, it has the option to purchase a BitCheck Contract, which provides electronic documentation for the specific BitCheck transaction. 2. To complete the documentation of a BitCheck Contract, 1. both BitCheck Users must consent to share their personal information with each other. Upon receiving such consent, XREX will incorporate the Bitcheck Users’ personal information into the BitCheck Contract; 2. the BitCheck Issuer must select the purpose of the BitCheck transaction and provide accurate transactional details. The BitCheck Recipient must then review the BitCheck Contract, and if the BitCheck Recipient deems the contents of the BitCheck Contract fair, accurate, and complete, they may agree and approve the BitCheck Contract; 3. both BitCheck Users must confirm their approval of the content of the BitCheck Contract by affixing their respective electronic signatures. 3. By using the add-on BitCheck Contract to your BitChecks, you agree to share your personal information with the other BitCheck Contract User for the current and all future BitCheck Contract transactions. If you wish to withdraw this consent, you must immediately cease using the BitCheck Contract and notify your designated relationship manager in writing. 4. **Fee**\ Please note that XREX may charge a fee to BitCheck Users for BitCheck and BitCheck Contracts. Such fees shall be set out in the Fee Schedule, which can be found in the [XREX Pay Help Center](https://intercom.help/xrex-sg/en/) and may be periodically updated by us at our sole and absolute discretion. You agree to pay XREX the fees by authorising us to deduct and/or debit your Funds for any such fees. We reserve the right to change or modify our Fee Schedule, including increasing our fees in the Fee Schedule, in accordance with [Paragraph 11.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/11.-general-provisions) of the General Terms and Conditions. The updated Fee Schedule will apply prospectively to the relevant Services that take place following the effective date of such updated Fee Schedule. 5. **Limitation of Liability** 1. To the fullest extent permitted by law, the maximum total liability of XREX in the provision of the BitCheck service shall not exceed the amount of service or product fees you pay for the relevant BitCheck or BitCheck Contract service. 2. By utilising the BitCheck services provided by XREX, you are bound by and subject to the terms and conditions of the Platform and XREX is not liable for any Losses suffered by you arising from or incurred in connection with the use of BitCheck services provided by XREX. You agree that you shall seek and obtain independent advice, if required and that XREX does not provide any advice, whether legal or financial or otherwise to you. 3. To the fullest extent permitted by Applicable Laws, you irrevocably and unconditionally agree to hold harmless and indemnify (and keep indemnified) the Indemnified Parties on demand against any and all Losses which the Indemnified Parties may sustain, incur, suffer or pay arising out of, in connection with or pursuant to the access to and/or the use of Bitcheck or the Bitcheck Contract service by you, whether or not such access or use was authorised or whether it was due to any act or omission on its part, the breach of these BitCheck Terms by you, the violation by you of any rights of another person or entity or the breach by you of any Applicable Laws. 6. **Disclaimer on BitCheck and BitCheck Contract** 1. BitCheck and BitCheck Contract are provided strictly on a “**AS IS**” and “**AS AVAILABLE**” basis. To the fullest extent permitted by Applicable Laws, XREX makes no representations and warranties of any kind, whether express, implied, or statutory, including but not limited to, the warranties of merchantability and fitness for a particular purpose or that the services will be uninterrupted or error-free. 2. The BitCheck Contract is an electronic documentation initiated, reviewed, and approved by BitCheck Users. XREX does not verify, validate or endorse the content or terms of any Bitcheck Contract. Under no circumstances shall XREX be liable for any Losses related to or arising from the use of BitCheck and/or BitCheck Contract. 3. As BitCheck Contract functions as a documentation tool, you acknowledge and agree to take full responsibility for the accuracy and completeness of any BitCheck Contract created or signed by you. While XREX does not review or endorse the BitCheck Contract you created or signed, and does not provide legal advice, XREX may request from you supporting documents to ensure compliance with the Applicable Laws or independent verification where required. You are strongly encouraged to seek independent legal advice before entering into any BitCheck Contracts. 4. Each BitCheck Contract may contain personal data automatically retrieved from XREX’s KYC database. By creating a BitCheck Contract for your BitCheck transaction, both the Bitcheck Issuer and BitCheck Receiver are deemed to consent to: 1. the right for XREX to share their information with the other party to the Bitcheck Contract; and 2. the receipt of such person information from the other party. BitCheck Users shall treat personal data contained in the Bitcheck Contract as confidential and shall not disclose such information to any third party unless expressly authorised in writing by the other party. 5. You are fully responsible for ensuring that all information you provide in connection with your use of the Services, including BitCheck Contract, remains accurate, complete and up to date. You consent to sharing your personal information with the BitCheck Receiver or the BitCheck Sender for the current and any subsequent BitCheck Contracts, unless you notify XREX in writing to the contrary. XREX shall not be liable for any Losses arising from your failure to update such information or from the use of outdated, inaccurate, or incomplete information stored in the system. # XREX Privacy and Cookies Policy Last Update: 03 Nov 2025 Capitalised terms not defined herein shall have the meanings ascribed to them under the General Terms and Conditions (“**Terms**”). We are committed to protecting your privacy and safeguarding your personal data. The purpose of this XREX privacy policy (the “**Privacy Policy**”) is to inform you about our privacy practices, including how we collect, use, and disclose your personal data. This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose, or process personal data for our purposes of operating, and your use of the Services. Any terms used and not otherwise defined herein in this Privacy Policy shall have the meaning as set forth therein in the Terms. By visiting the Site, interacting with us, submitting information to us, signing up for any products and/or using services made available by us or connecting with us at industry events and conferences, you agree and consent to us collecting, using, disclosing, processing, and sharing your personal data amongst ourselves and our affiliates to the extent necessary for the provision of the Services, or otherwise consented to by you, and disclosing such personal data to our authorised service providers and relevant third parties in the manner set forth in this Privacy Policy. If any policies or practices of this Privacy Policy are not agreed to, please do not visit, access, or use the Services. This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your personal data, and your consents herein are cumulative and additional to any rights which we may have at law to collect, use, disclose and/or process your personal data. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use, disclosure and/or processing of your personal data. #### **1. General information** In this section, we provide you with general information about the entity that is responsible for your personal data, this Privacy Policy, and the Services. **1.1. Important terms** In this Privacy Policy, you will encounter recurrent terms. For your convenience, we would like to explain what such terms mean, as stated in this Privacy Policy: “**consent**” means a freely given, specific, informed, and unambiguous agreement to the processing of personal data, including deemed consent; “**data controller**” means the entity that determines the purposes and means of the processing of personal data; “**data processor**” means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data controller; “**PDPA**” means the Personal Data Protection Act 2012 of Singapore, and all subsidiary legislation, regulations, and guidelines promulgated thereunder, and as time to time amended; “**personal data**” means data, whether true or not, about an individual who can be identified from that data or from that data and other information to which the organisation has or is likely to have access; “**processing**” means the use of personal data in any manner, including, but not limited to, collection, storage, erasure, transfer, and disclosure of personal data; and “**You**” and “**your**” means a natural person or a business entity that accesses and/or uses the Services. **1.2. Owner and data controller** The Services are provided by XREX Pte. Ltd. with its registered address at 12 Marina View, #10-23, Asia Square Tower 2, Singapore 018961. XREX acts as a data controller with regard to all personal data collected through the Services. **1.3. Children** The Services is not intended for children under the age of 18 or equivalent minimum age in the relevant jurisdiction. Therefore, we do not knowingly collect the personal data of persons under the age of 18. We are unable to identify whether a child has provided us personal data without the KYC process. If we become aware that a child has provided us with personal data, we will take steps to delete such information as soon as possible. **1.4. Cookies Policy** **Definition of a Cookie** A cookie is a small data piece sent by a website to your browser, which may then be stored on your device. Cookies enable websites to recognize your device and collect certain user data. They include persistent cookies which are valid until you delete them, expiry cookies which are valid until a set expiration date, session cookies which are valid until you close your browser, first-party cookies which are set by the visiting website and third-party cookies which are set by external websites. In respect of the Services, we employ technical cookies, which are crucial for the proper functioning of the Site and XREX Pay, and unclassified cookies to record your service preferences. These cookies may also be used for the following purposes: (a) Recognize new or past users; (b) Store your profile or authentication credentials if you use the Services; (c) Improve the services and to better understand your use of the Services; and (d) Better understand your interests. **Cookie Consent** Upon your first visit to the Site and/or XREX Pay, we (and the service providers working on our behalf) may seek your consent for cookie usage, especially if accessing from the EU. Without consent, only essential technical cookies will be used. However, this might affect your user experience. **Disabling Cookies** You can decline our cookies anytime via your browser/device settings. However, some platform parts might not work correctly without them. For cookie management, please use the applicable link below: (a) [Apple Safari](https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac) (b) [Google Chrome](https://support.google.com/chrome/answer/95647) (c) [Firefox](https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences) (d) [Microsoft Edge](https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy) **1.5. Applicability of the Privacy Policy** This Privacy Policy applies exclusively to the Services and does not extend to any third-party applications, software, products, services, or businesses that may integrate with the Services. **1.6. Changes to the Privacy Policy** Your privacy matters to us so please familiarise yourself with this Privacy Policy. We may update this Privacy Policy by publishing the latest version on our Site or notifying you of any change to this Privacy Policy. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically to be aware of any changes. Your continued interaction with us or use of our products and/or services shall constitute your acknowledgement and acceptance of such changes. **1.7. How we collect your personal data** Before you submit any personal data through Services, you must read and agree to this Privacy Policy. We generally collect your personal data in the following ways: (a) Voluntary disclosure of your personal data directly or via a third party who has been duly authorised by you to disclose your personal data (your “**Authorised Representative**”) after (i) you (or your Authorised Representative) have been notified of the purposes for which the data is collected, and (ii) you (or your Authorised Representative) have provided consent to the collection and usage of your personal data for those purposes; or (b) Involuntary collection and use of personal data without consent as permitted or required by the PDPA or other Applicable Laws. Where it is necessary to collect, use, disclose or process your personal data for purposes which you have not already consented to and been notified of, we shall seek your additional consent to the expanded purposes unless authorised by the PDPA. It is a continuing condition of your access and/or use of the Services that you agree and consent to the collection, use, disclosure, and/or processing of your personal data in accordance with this Privacy Policy. #### 2. Types and purposes of personal data collected We collect only personal data that is necessary for ensuring your proper use of the Services. We use your personal data for specified and limited purposes. In this section, we explain what personal data we collect from you, for what purposes we use that data, and on what lawful bases we rely when processing personal data. **2.1. Types of personal data** We comply with data minimisation principles and collect only personal data that is necessary for your proper use of the Services. Personal data may be obtained from you either directly (e.g., when you register to use the Services or contact us) or through automated means (e.g., when you browse the Site or make a transaction). Please refer below for the types of personal data we collect. **2.2. Purposes of personal data processing** We process your personal data only for specified and legitimate purposes explicitly mentioned in this Privacy Policy. In short, we will use personal data only to enable your use of the Services, deliver the services you request, comply with our legal obligations (e.g., AML/CFT laws), maintain and enhance the Services, conduct research related to our business activities, and respond to your inquiries. We will not process your personal data for any other purposes which you provide your personal data without obtaining your express consent. **2.3. Overview of types and purposes of collecting and processing your personal data** By using the Services, you consent to our collection, use, processing and disclosure of your personal data outlined in the table below. The personal data is collected for the specific purpose associated with the corresponding event reflected in the table below.
S/NEventPurpose Personal Data Collected

Sign up to receive notifications about the ServicesInform you about the Services
  • Email address; and/or
  • Phone number.

Sign up to use the Services
  • To enable your access to the Services;
  • To register and maintain your user account;
  • To deliver the requested services;
  • To contact you, if necessary;
  • To deliver promotional information about the Services;
  • To analyse and improve our business;
  • To manage your relationship with us;
  • To comply with any Applicable Laws;
  • To fulfil any other purposes for which you have provided your personal data; and/or
  • To fulfil any other incidental business purposes related to or in connection with the above.
  • Email address;
  • Phone number; and/or
  • Password.



Upgrade your user account for transactions
  • To deliver the requested services;
  • To verify your identity;
  • To comply with our legal obligations (e.g., AML/CFT laws);
  • To contact you, if necessary; and/or
  • To analyse and improve our business.
  • Full name;
  • Date of birth;
  • Residential address;
  • Nationality;
  • Identification number;
  • A copy of your identity document and any information included therein;
  • Employment status or designation;
  • Bank account information (bank name, bank account number, bank address, contact details, name of the beneficiary, wire instructions);
  • Annual income;
  • Asset net worth;
  • Occupation and industry;
  • Source of funds or source of wealth; and/or
  • Tax Identification Number (TIN).

Making a transaction using the Services
  • To facilitate and process your transactions;
  • To comply with our legal obligations (e.g., AML/CFT laws); and/or
  • To administer, analyse, and improve our business.
  • Trading records;
  • Trading logs;
  • Addresses of digital assets; and/or
  • Wallet address.

Contact us by email or via live chat
  • To respond to and processing your enquiries; and/or
  • To provide you with the requested information.
  • Full Name;
  • Email address; and/or
  • Any personal data that you decide to provide us in your message.

Making a deposit or withdrawal
  • To process your deposits or withdrawals;
  • To maintain our accountancy records; and/or
  • To comply with our legal obligations (e.g., AML/CFT laws).
  • Name;
  • Bank account information (i.e., bank account number, bank name, and billing address);
  • Purpose of the transaction;
  • Contact information;
  • Relationship of the recipient; and/or
  • Recipient information.

Making a cryptocurrency deposit or withdrawal
  • To share the data to the originator or beneficiary VASP; and/or
  • To comply with FATF (Financial Action Task Force) Travel Rule.
  • Name;
  • Wallet address;
  • Customer ID, including birth information; and/or
  • Transaction amount.

General Use of the Services
  • To analyse, improve, and evaluate our business activities;
  • To customize the Services for your location; and/or
  • To ensure the security of the Services.
  • IP address;
  • Device ID, OS, model name;
  • XREX App version;
  • Errors encountered;
  • Cookie-related data (please refer to the Cookies Policy at Paragraph 1.4 above for more information); and/or
  • Your approximate location.
Please note that we may transmit your personal data to any third parties including third-party service providers, data processors (including but not limited to those identified in Paragraph 3.2 below), agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for any of the abovementioned purposes in this Paragraph 2.3. **2.4. Failure to provide personal data** Unless specified otherwise, all personal data requested by XREX is mandatory and failure to provide such data may prevent us from delivering the Services to you. Where we specifically state that certain personal data is optional, you may choose not to provide it without affecting the availability or the functionality of the Services. However, by voluntarily providing optional personal data, you consent to its collection, use, disclosure, and processing for the purposes outlined in this Privacy Policy. **2.5. Additional data** From time to time, we may receive certain additional personal data when you request support, interact with our social media accounts, submit feedback, or otherwise communicate with us. The provision of such data is optional and you may choose what personal data to share. Please exercise discretion when making your personal data publicly available. We will use such personal data to reply to you, provide you with the requested services, or pursue our legitimate business interests such as analysing and improve our business, in accordance with our obligations under the PDPA. **2.6. Sensitive data** We do not, under any circumstances, collect special categories of personal data (e.g., sensitive data) from you, such as your health, religious or political beliefs, racial origins, trade or professional association membership, or sexual orientation. If you choose to provide such sensitive data, you are deemed to do so at your own sole discretion. **2.7. Personal data published on the Services** If you decide to publish information about yourself through the Site and/or XREX Pay (e.g., via your public user profile), you may disclose certain personal data to other users. Please be aware that such data becomes publicly available and may be used by third parties for unlawful purposes. Please exercise discretion and avoid sharing personal data that is unnecessary, excessive or sensitive. Additionally, you must not publish personal data of other persons without their prior consent. If we become aware of such unauthorised disclosure of personal information, we will take immediate steps to remove the personal data and may suspend you from the access or use of the Services. **2.8. Privacy of transactions** The Services allow you to conduct transactions with other users of the Services. We make reasonable efforts to ensure that any transaction-related data remains confidential and securely protected. We do not intentionally access, manage, correct, delete, share, or disclose transaction-related data, unless it is strictly necessary to: (a) provide the Services; (b) fulfil any of the specific purposes mentioned in this Privacy Policy or related business purposes; (c) exercise our legal rights; (d) enforce the Terms or this Privacy Policy; or (e) comply with the Applicable Laws. **2.9. Location of processing** Your personal data is processed at XREX’s operating offices in Singapore and in any other locations where our data processors are located. The processing of personal data is carried out using secure IT systems and tools, in accordance with organisational procedures and modes that are strictly aligned with the purposes stated in this Privacy Policy. **2.10. Our compliance with Anti-Money Laundering (AML) regulations** We have established robust internal standards to meet regulatory requirements of the Applicable Laws pertaining to AML/CFT. These standards include internal policies and procedures, such as (a) XREX Financial Crime Compliance Policy; (b) AML Policy; (c) Sanctions Policy; (d) ABC (Anti-Bribery & Corruption) Policy; (e) Customer Due Diligence Policy; (f) FATF Travel Rule; and (g) Operation Procedures. **2.11. FATF Travel Rule** To enhance security and prevent illicit activities involving blockchain and Virtual Asset channels or platforms, the Financial Action Task Force (“**FATF**”) has introduced a rule which requires VASPs, including XREX, to exchange sender and recipient information with the other VASPs during Virtual Asset transactions (“**Travel Rule**”). Accordingly, while you make a cryptocurrency deposit or withdrawal, certain personal information may be shared with other VASPs in compliance with the Travel Rule. #### 3. Disclosure and transfer of personal data To support the delivery and operation of the Services, we may need to share your personal data with external parties. This includes third-party service providers, data processors and the relevant authority. Additionally, your personal data may be transferred outside your country of residence. This section outlines the types of third parties we may disclose your personal data to, the purposes of such disclosure, instances when we make international data transfers, and the safeguards we implement to protect your personal data. **3.1. Disclosure of personal data** Your personal data may be disclosed to internal teams within XREX (e.g., administration, sales, marketing, legal, system administration) or external parties appointed as data processors (e.g., third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies). We do not sell your personal data to third parties. Such disclosure of your personal data is limited to the situations necessary for the following purposes: (a) Ensuring the proper operation of the Services; (b) Ensuring the delivery of the Services requested by you; (c) Providing you with requested information; (d) Pursuing our legitimate business interests; (e) Enforcing our rights, preventing fraud, and security purposes; (f) Carrying out our contractual obligations; (g) Law enforcement purposes; and (h) Other purposes to which you provide your consent. **3.2. List of data processors** We only share your personal data with data processors who have legally enforceable obligations to provide a level of data protection comparable to that under the PDPA and other Applicable Laws. The data processors that will have access to your personal data are included, but not limited to, the following: **(a) Name: Amazon Web Services** * Service: Hosting service provider * Location: The United States & Japan (location of our servers) * More information: [https://aws.amazon.com](https://aws.amazon.com/) **(b) Name: Sum and Substance Inc.** * Service: Identity verification service provider * Location: The United Kingdom & Germany (location of our servers) * More information: [https://sumsub.com](https://sumsub.com/) **(c) Name: Fireblocks** * Service: Digital asset infrastructure service provider * Location: Not publicly disclosed * More information: **(d) Name: Intercom** * Service: Customer support service provider * Location: The United States * More information: [https://intercom.io](https://intercom.io/) **(e) Name: Sentry** * Service: Error monitoring service provider * Location: The United States * More information: [https://sentry.io](https://sentry.io/) **(f) Name: World-Check (by LSEG, formerly Refinitiv)** * Service: Risk monitoring service provider * Location: Not publicly disclosed * More information: **(g) Name: MistTrack (by SlowMist AML)** * Service: Blockchain analysis service provider * Location: Not publicly disclosed * More information: **(h) Name: TRM Labs** * Service: Blockchain analysis service provider * Location: Not publicly disclosed * More information: **(i) Name: VerifyVASP Pte. Ltd.** * Service: Travel rule solution provider * Location: Singapore * More information: **(j) Name: Crypto Defenders Alliance (CDA)** * Service: Non-profit blockchain alliance * Location: Not publicly disclosed * More information: **3.3. International transfers of personal data** Depending on your location, we may need to transfer your personal data to a country other than your country of residence to ensure the proper delivery of the Services. Where such transfer occurs, we will take appropriate steps to ensure compliance with the Applicable Laws, including ensuring that recipients of the transferred personal data have a level of protection comparable to that required under the PDPA or other Applicable Laws. By using the Services, you consent to international transfer of your personal data. **3.4. Disclosure of non-personal data** We may disclose non-personal data to third parties for any lawful purpose. For example, we may share such data with prospects or partners for business or research purposes, improving the Services, responding to lawful requests from public authorities, or developing new products and services. **3.5. Legal requests** If requested by a public authority, we may disclose your personal data to the extent necessary to comply with the Applicable Laws. **3.6. Successors** In the event of a merger, acquisition or sale of all or part of our business, your personal data may be transferred to the purchaser or successor entity. We will request the purchaser or successor entity to handle your personal data in accordance with this Privacy Policy, the PDPA and the Applicable Laws. #### 4. Security of personal data We will use our best efforts to keep your personal data safe and secure. This section outlines the measures taken to protect your personal data. **4.1. Our security measures** XREX implements robust security measures to prevent unauthorised access, collection, disclosure, copying, modification, or unauthorised destruction of your personal data. The security measures taken by us include secured networks, SSL protocol, strong passwords, limited access to your personal data by our staff, and anonymization of personal data (when possible). In order to ensure the security of your personal data, we recommend accessing the Services only through secure networks. **4.2. Handling security breaches** While we ensure best efforts and take reasonable precautions to protect your personal data, we shall not be liable for any unauthorised destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In the event of a serious breach, we will take reasonable measures to mitigate the breach and comply with all necessary disclosure obligations under the Applicable Laws. You agree that our liability will be limited to the maximum extent permitted by the Applicable Laws. #### **5. Non-personal data** When you use the Services, we automatically collect certain technical data about your device and use. In this section, we inform you what non-personal data we collect from you and for what purposes we use that data. **5.1. Types of non-personal data** We automatically collect technical non-personal data and anonymised for analytics purposes, including de-identified personal data which is treated as non-personal data. These data collected by us include: **(a) Transaction data** When you make a transaction, details such as expected transaction volume, frequency, trade activity, deposits, withdrawals, parties to send or receive transactions, relationships, and purpose of the transactions. **(b) Usage data** When you access and use the Services, information about your time of request, method of server request, file size received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by you, the various time details per visit, and the details about the path followed within the Services with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment. When you contact us, we keep records of any questions, complaints, recommendations, or compliments made by you and the response, if any. Where possible, we will de-identify your personal data. **5.2. Purposes of using non-personal data** We will use non-personal data for the following purposes: (a) To analyse what kind of users visit and use the Services; (b) To examine the relevance, popularity, and engagement rate of the Services; (c) To investigate and help prevent security issues and abuse; (d) To develop and provide additional features to the Services; and/or (e) To personalize the Services for your specific needs. **5.3. De-identified data** In the event that your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer identify a natural person (whether by itself or in combination with any other data in our possession or control), it will not be considered personal data and we may use it for any purpose set out in Paragraph 5.2 above. #### 6. Direct marketing From time to time, we may send you promotional messages regarding our services. The section outlines the circumstances under which you may receive such notices and how you can manage your preferences. **6.1. Marketing messages** We may send you direct marketing messages to keep you informed about the Services, including updates on existing Services and information about new or related services. Please note that your voluntary subscription to our updates or newsletters will be deemed as such consent. **6.2. Opting-out** You can opt out from receiving marketing messages at any time free of charge by (a) clicking on the “unsubscribe” link contained in any message sent to you; (b) adjusting your account settings; or (c) contacting us directly in accordance with this Privacy Policy. **6.3. Informational notices and service updates** If necessary, we will send you important informational communications, including service-related, technical, administrative emails, information about the Services, your transactions, user account, privacy and security, and other administrative matters. These communications are necessary for the operation of the Services and do not require your prior consent. #### 7. Retention time We retain your personal data only for a period necessary to fulfil the purposes outlined in this Privacy Policy or to meet our legitimate business purpose. This section details the applicable retention period of your personal and non-personal data in our systems, with examples as set out in the table below.
S/NPurpose of retention of personal data and non-personal data Period of retention

Performance of a contract between XREX and userUntil such contract has been fully executed

Satisfying XREX’s legitimate interestsAs long as required to fulfil such legitimate interests
Where processing your personal data based on your consent, we will retain your personal data until the earlier of (i) the purposes for which you have provided your consent is fulfilled or (ii) you withdraw your consent. Upon expiry of the applicable retention period, your personal data shall be securely deleted from our systems. After deletion, your rights to access, rectify, erase, or port your data can no longer be exercised. **7.1. Retention as required by law** XREX may retain your personal data for a longer period where required to do to comply with the Applicable Laws. For example, we may retain your personal data to comply with record keeping obligations, accountancy records and AML/CFT laws. **7.2. Retention of non-personal data** We may retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This includes retention keeping non-personal data after you have deactivated your user account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements. #### 8. Representations and Warranties You represent, warrant, and undertake to us that: (a) if in connection with your access and/or use of the Services, you provide us with the personal data of any person other than yourself, such persons have consented to the collection, use, disclosure and/or processing of your personal data in accordance with the Privacy Policy; (b) your disclosure to us of any personal data is in accordance with all Applicable Laws governing the collection, use, disclosure, and/or processing of personal data, and such personal data is complete, accurate, updated and relevant at the time of disclosure; (c) before providing any such personal data to us, you acknowledge that you have read and understood this Privacy Policy, and, in the case of personal data relating to an individual other than yourself, have (or will at the time of disclosure have) provided the individual with a copy of, or directed the individual towards a webpage containing that Privacy Policy; and (d) if from time to time we provide you with a replacement version of the Privacy Policy, you will promptly read that notice and provide updated copies of the Privacy Policy to, or re-direct towards a webpage containing the updated Privacy Policy, any individual whose personal data you have provided to us. #### 9. Your rights regarding your personal data You have the right to control how we process your personal data. This section outlines your data protection rights and how you may exercise those rights. Subject to the Applicable Laws, you may exercise your right to: **(a) Withdraw your consent** You may withdraw your consent to the processing of your personal data at any time. Your consent for the collection, use, and disclosure of your personal data remains valid until you notify us of your withdrawal in writing. Upon receipt of your written request to withdraw your consent, we may require a reasonable period, depending on the complexity and the impact on our continued obligations to you in providing the Services. We will notify you of any potential consequences, including any legal or service-related implications. Please note that your withdrawal of consent may affect our ability to continue providing the Services to you. **(b) Object to processing** You have the right to object to the processing of your personal data where such processing is based on grounds other than the performance of a contract or pursuing our legitimate business interests. **(c) Access your personal data** You have the right to request for: * access to your personal data in our possession or under our control through receiving a copy of such personal data; and/or * information on how your personal data has been used or disclosed by us, during the last twelve (12) months immediately preceding your request. If we are unable to provide you with such information, we will inform you of the reasons in writing, subject to the Applicable Laws. **(d) Verify and seek rectification** You have the right to request the updating of any inaccurate or incomplete personal data we hold about you. **(e) Restrict processing** You have the right to request the restriction of the processing of your personal data if you have withdrawn of your consent to such processing. **(f) Have your personal data deleted or otherwise removed.** You have the right, under certain circumstances (namely, where retention of the data no longer serves any legal or business need of ours), to erase your personal data from our systems. **(g) Receive your personal data and transfer it to another controller.** You have the right to receive your personal data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller. **(h) Lodge a complaint.** You have the right to bring a claim before their competent data protection authority. **How to exercise your rights** To exercise any of the rights described above, please contact us using the details provided at the end of this Privacy Policy. Requests are generally processed free of charge for one time every year and will be addressed as soon as reasonably practicable, and in any event within one (1) month of receipt. **Lodging a complaint** If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first in writing and express your concerns. Thereafter, we will investigate your complaint and provide you with our response as soon as possible. If you are unsatisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority. **Contact information** For any questions, comments, or requests about this Privacy Policy or your personal data, please contact our Data Protection Officer by using the contact details below. * **Company name:** XREX Pte. Ltd. * **Address:** 12 Marina View, #10-23, Asia Square Tower 2, Singapore 018961 * **Email address:** * **Phone number:** (+65) 69149851
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# XREX General Terms and Conditions\_03 Nov 2025 Last Update: 03 Nov 2025 The General Terms and Conditions and any terms expressly incorporated herein (“**Terms**”) apply to any access to or use of the services offered by XREX Pte. Ltd. and its Affiliates (collectively referred to as “**XREX**” or “**we**”). These Terms apply when you use any of XREX's websites (“**Site**”), the XREX application (“**XREX Pay**”), any application programming interface (“**API**”) provided by XREX that relates to the Site, and any other related services provided by XREX, including but not limited to crypto-fiat conversion and BitCheck (collectively referred to as the “**Services**” as further defined below). These Terms are a legal contract between you and XREX Pte. Ltd. so it is important that you review them carefully before using the Services. By clicking on the “I agree” button or check-box presented with these Terms or by continuously accessing any of the Services that manifest your consent, you agree to be bound by these Terms. These Terms, the hyper-linked documents herein and all Annexes comprise the agreement (the “**Agreement**”) between you and XREX Pte. Ltd. The information provided in the Terms are for information purposes only and is not to be construed as a recommendation or advice to you in relation to any legal, tax, financial investment or any other matters. You should consult with an attorney or other professional advisor to determine what may be best for your needs. This Agreement contains the entire agreement and supersedes all prior and contemporaneous understandings between you and XREX Pte. Ltd. regarding the Services. In the event of any conflict between this Agreement and any other agreement you may have with XREX Pte. Ltd., this Agreement will prevail unless the other agreement specifically identifies this Agreement and declares that the other agreement supersedes this Agreement. Save for the Indemnified Parties, no provision of this Agreement is enforceable by virtue of the Contracts (Rights of Third Parties) Act 2001 by any person who is not a Party to this Agreement.
# Interpretation and Definitions In addition to terms defined elsewhere in these Terms, the following definitions shall apply throughout these Terms, unless the contrary intention appears: “**Affiliates**”: with respect to a person, a person that controls, is controlled by or under common control with such person; and “**control**” means the right to exercise, directly or indirectly, more than 50% of the voting securities of such person or the power to direct the management or policies of such person (and the terms “**controlled by**” and “**under common control with**” shall be construed accordingly). “**Annex**”: annexures to these Terms, which may be in the form of hyperlinked documents, setting out provisions applicable for the relevant jurisdictions in which XREX provides its Services, XREX’s product and fee schedules. “**Applicable Laws**”: any applicable constitution, treaty, statute, rule, regulation, ordinance, order, directive, code, judgment, decree, injunction, or any interpretation, determination, award, permit, license, authorisation, directive requirement, ruling or decision of, or agreement with, or by, a government authority, including Singapore Sanctions Laws. “**Business Day**”: a day other than a Saturday, Sunday or public holiday in Singapore. “**B2B**”: business to business. “**AML/CFT**”: anti-money laundering / combating the financing of terrorism. “**Communications**”: includes announcements, agreements, disclosures, documents, mail (electronic) messages, notices and receipts. “**Conversion**” and “**convert**”: an exchange between one type of DPTs to another type of DPTs, or between DPTs and Fiat Money. “**Digital Payment Tokens**” and “**DPTs**”: only blockchain-based fungible coins or tokens supported by XREX Pay and available on the Site. “**FATF Travel Rule**”: a set of recommendations issued by the Financial Action Task Force, applicable to VASPs (including XREX) to prevent money laundering and terrorist financing, as further explained in paragraph 2.11 of [Privacy Policy](/doc/xrex-user-legal-agreements/xrex-privacy-and-cookies-policy). “**Fee Schedule**”: the schedule of fees for our Services as outlined in [XREX Pay Help Center](https://intercom.help/xrex-sg/en/). “**Feedback**”: has the meaning ascribed to it in [Paragraph 4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/4.-proprietary-rights). “**Fiat Money**”: government-issued currency excluding central bank digital currencies. “**Force Majeure Event**”: means any act of God, labour action or dispute, war declared or undeclared, invasion, act of terrorism or sabotage, cyber-terrorism, disruption to the security, integrity, and availability of the internet or blockchain networks, blockade, civil unrest, man-made disaster, government restraint or action, perils of the sea, embargo, disease epidemic, pandemic, public health crisis, radioactive, chemical or biological contamination, accident, nationalization, expropriation, currency restrictions, acts of state, interruptions, IT Malfunction, market data error or other power failure, regulatory changes and for the avoidance of doubt includes any Communications Failure, or any other cause, event or circumstance, whether of the kind specifically enumerated above or otherwise, the occurrence and the effect of which is beyond the reasonable control of, and could not have been reasonably prevented by, the Party whose obligation it affects, notwithstanding the exercise of reasonable foresight, at reasonable cost and by the exercise of reasonable diligence on the part of that Party and which renders due performance of an obligation under this Agreement illegal or impracticable. “**Formal Complaint**” and “**Formal Complaint Process**”: these terms are defined in [Paragraph 10](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/10.-governing-law-and-dispute-resolution) relating to the resolution of any disputes with XREX. “**Funds**”: the deposit of DPTs and/or Fiat Money from an e-wallet and/or bank account under the user’s name (and only their name) into his/her XREX E-Wallet and the Safeguarding Account (as the case may be) on the Site. “**Indemnified Parties**”: XREX Pte. Ltd. and its Affiliates and their respective shareholders, directors, officers, employees, attorneys, agents, representatives, suppliers, and contractors. “**Insolvency Event**”: means an event where: 1. in relation to an entity: 1. an order is made or an effective resolution is passed for the winding up, liquidation or dissolution without winding up (otherwise than for the purposes of a solvent reconstruction or amalgamation) of the entity; 2. a receiver, receiver and manager, judicial manager, liquidator, administrator or like official is appointed over the whole or substantially the whole of the undertaking or property of the entity; 3. the holder of an encumbrance takes possession of the whole or substantially the whole of the undertaking or property of the entity; 4. the entity proposes or takes any steps to implement a scheme, arrangement or other compromise with its creditors or any class of them; 5. the entity is declared or taken under the Applicable Laws to be insolvent or the entity’s board of directors resolves that it is insolvent; 6. the entity has stopped or suspended, or threatened to stop or suspend, payment of all or a class of its debts which are due; or 7. anything analogous with any of the above; 2. in relation to a trust, all or substantially all of the assets of the trust becomes vested in the beneficiaries; or 3. in relation to a natural person: 1. such natural person authorises a registered trustee or solicitor to call for a meeting of his creditors or proposes or enters into a deed of assignment or composition with any of his creditors; 2. any third party holding a security interest in any of such natural person’s assets enters into possession of or takes control of any of such assets; or 3. such natural person commits an act of bankruptcy, including having a bankruptcy order made against him, acts of applying or obtaining an order for voluntary arrangement, or being placed under a debt repayment scheme. “**KYC**”: know your client. “**Losses**”: means all costs, damages, losses, liabilities (including tax liabilities), charges, actions, claims, demands and expenses in connection with any action, suit or proceeding, investigations, judgments, orders whether involving a third party claim or a claim solely between the Parties and includes any incidental, indirect or consequential damages (including any ordinary, direct, indirect, consequential, incidental, special, punitive or exemplary damages), losses (direct or consequential), liabilities or expenses, and any lost profits or diminution in value. “**OTC**”: over-the-counter. “**Owed Amount**”: has the meaning ascribed to it in [Paragraph 6](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/6.-safeguarding-measures). “**Parties**”: you and XREX Pte. Ltd. “**Relevant Money**”: any money that is received by XREX from, or on account of, you in respect of the provision of our payment services and which we continue to hold at the end of each Business Day, but does not include the following (1) any money paid to us to reduce the amount owed to us by you, (2) any money that is repaid by us to you, (3) any money which is paid to us, or which we have informed you, will be used to defray any fee or charge imposed by us for providing our payment services to you, (4) any money that is paid to a recipient in accordance with your instructions to us, (5) any money that is paid to any other person that is entitled to the money. “**Safeguarding Account**”: designated trust bank account that XREX maintains with a bank in Singapore in accordance with Applicable Laws. “**Safeguarding Institution**”: has the meaning ascribed to it in [Paragraph 6](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/6.-safeguarding-measures). “**Services**”: all the features, functions, and services provided by XREX on the Site, XREX Pay and any APIs. “**SIAC**” and “**SIAC Rules**”: these terms refer to the Singapore International Arbitration Centre and the rules which it publishes to regulate arbitration proceedings, respectively, and apply to the resolution of any disputes with XREX, as set out in [Paragraph 10](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/10.-governing-law-and-dispute-resolution). “**Singapore Sanctions Laws**”: the Terrorism (Suppression of Financing) Act 2002 and the respective regulations promulgated under the Monetary Authority of Singapore Act 1970, as amended, supplemented or replaced from time to time. “**Tax**” or “**Taxation**”: all forms of taxation (including goods and services tax and other than deferred tax) and statutory, governmental, state, provincial, local governmental or municipal impositions, duties, contributions and levies and whether levied by reference to income, profits, gains, net wealth, asset values, turnover, added value or otherwise and shall further include payments in respect of or on account of tax, in each case, whenever and wherever imposed on any party and whether chargeable directly or primarily against or attributable directly or primarily to a party and all penalties, charges, costs and interest relating thereto. “**Third-Party Content**”: this term is defined in [Paragraph 4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/4.-proprietary-rights) relating to our proprietary rights. “**Trust Account**”: a trust account maintained by us with a Safeguarding Person to hold DPTs. “**VASP**”: Virtual Asset Service Provider, being any natural or legal person who as a business conducts one or more of the following activities or operations for or on behalf of another natural or legal person, namely, the exchange between DPTs and Fiat Money, the exchange between one or more types of DPTs, the transfers of DPTs, the safekeeping and/or administration of DPTs. “**User Content**”: has the meaning ascribed to it in [Paragraph 4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/4.-proprietary-rights). “**XREX Account**”: any user account provided by XREX for the purpose of using the Services, including but not limited to the XREX E-Wallet, Corporate Accounts, and Advanced Accounts (all as set out in [Paragraph 1.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/1.-account) herein). “**XREX E-Wallet**”: the hosted e-wallet that XREX provides to you as part of the Services and in which you may store, track, transfer and manage your DPT balances. “**XREX Material**”: has the meaning ascribed to it in [Paragraph 4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/4.-proprietary-rights). # 1. Account 1. **Eligibility for XREX Account application:** 1. Any applicants located in, or of citizenship of, any countries or regions listed on this [page](https://intercom.help/xrex-sg/en/articles/9232927-what-countries-are-on-the-prohibited-list-and-who-is-affected-by-these-restrictions) will be denied for AML/CFT or other regulatory purposes. This list of the restricted and prohibited jurisdictions will be updated and revised from time to time at the sole discretion of XREX. If you change your residence or nationality, or both, to any jurisdiction on the [list](https://intercom.help/xrex-sg/en/articles/9232927-what-countries-are-on-the-prohibited-list-and-who-is-affected-by-these-restrictions), you must notify XREX immediately and cease your use of our Services unless you receive written permission from XREX. 2. In order to use the Services, you must be at least 18 years of age, and you must have the authority to enter into and execute an agreement to these Terms. In order to leverage any part of the Services, you are required to provide personal information. You hereby warrant that any information provided by you is accurate, complete, and current and you accept that any inaccuracies may lead to XREX, in its sole discretion, ceasing its Services, freezing your XREX Account, assets, and access at any time and without prior notification. 3. You are not a designated individual or entity as defined or set out in the Singapore Sanctions Laws. 2. **Relationship of the Parties:** XREX is an independent contractor for all purposes. Nothing in this Agreement is intended to or shall operate to create a partnership, joint venture, or employment relationship between you and XREX, or authorise you to act as agent of XREX. 3. **XREX Account** 1. In order to access some of the Services, you must complete our identity verification questionnaire and provide accurate and truthful details and documentation as required by our policies and procedures. You agree that XREX may share the relevant data with certain third parties contracted by XREX to perform verification of the data and documentation provided by you and to ascertain your status as required by the Applicable Laws of the jurisdiction(s). 2. Corporate Account: Individuals with the intent to use the Services on behalf of an enterprise or legal entity must request a Corporate Account when such accounts are made available on our platform. If you use the Services on behalf of an enterprise or legal entity without registering for a Corporate Account, you do so at your own risk and you agree and accept that your XREX Account may be restricted, access to your XREX Account may be prevented, and access to your Funds may be withheld pending a full investigation of your background and the enterprise or legal entity on whose behalf you are accessing the Services. You also agree that your details and the results of such an investigation will be shared with the relevant regulatory authorities. 3. Advanced Account: At its sole discretion, XREX may grant additional benefits, rewards, or features for qualified users as Advanced Account holders (such as premium accounts). Notwithstanding the foregoing, Advanced Account holders are still users under these Terms, not contractors, representatives, or agents of XREX, and you shall contact XREX directly to confirm the information regarding any benefits or rewards when using the Services for an Advanced Account. 4. Access to your Account: You must not sell or otherwise make your XREX Account accessible to any unauthorised person. You are fully responsible for maintaining the security and confidentiality of your username, password and any other access credentials to use and/or access your Account, and all activities that occur in connection with your Account. 4. **Responsibility for Actions** 1. Authorised Actions: Any instruction or Communication sent from or is otherwise referable to your XREX Account (e.g., an email sent from the email address that you have registered with us in setting up your Account), or any of your contact information, shall be deemed to be authorised and is binding on you. XREX is not obliged to verify the identity or authority of any persons using your XREX Account and we shall be entitled to accept and place full reliance on any instruction or Communication sent from or is otherwise referable to your Account. 2. Unauthorised Actions: Any unauthorised use of your XREX Account will constitute a breach of this Agreement and in case of such breach, XREX has the right, without prejudice to any of our rights or remedies under Applicable Laws, to terminate, suspend or restrict your access to your Account, terminate the provision of all or part of the Services to you, as well as take any other action as we deem fit, whether for a specified period of time or indefinitely. \ If you notice any unauthorised or suspicious log in or activity in your XREX Account or in the event of any breach of security, loss, theft or unauthorised use of your username, password, security information or any other access credentials to access or use our Services, you must notify us in writing immediately through your designated relationship manager and provide us with a police report and any other information and documents as we may require. You shall also immediately take steps to restrict access to your Account, which can be done via the Services or other means. 3. No Liability: You acknowledge and agree that none of the Indemnified Parties shall not be liable to you or any other person or entity for any direct, indirect, special or consequential losses (including loss of profits, business or opportunities), damages or costs by reason of, or arising from, or as a consequence of, your XREX Account being used by a third-party, whether authorised or unauthorised by you. 5. **Account Funding** 1. Deposits: 1. Only users who have passed the KYC checks (including identity verification) can deposit DPTs and Fiat Money from their e-wallet and/or bank account under their name (and their name only) into its XREX E-Wallet and its/their Safeguarding Account. You can view your balance of DPTs and Fiat Money from your XREX Account. If you send DPTs to the incorrect e-wallet address or if you send unsupported DPTs, these may be lost forever, and XREX will not accept responsibility for such lost Funds or digital assets. Any funds you send to the XREX E-Wallet addresses or Safeguarding Account will not receive any interest unless specifically stated otherwise on the Site or the XREX Pay. 2. Deposit amounts may be subject to limits depending on the level to which you have verified your identity and/or provided additional information requested by us. 2. Withdrawal 1. Only users who have passed the KYC checks can withdraw DPTs and Fiat Money from the XREX Account. You will be required to maintain enough Funds in your XREX E-Wallet or Safeguarding Account to cover any pending transactions and fees to be incurred. Any Funds in excess of those committed to your transactions may be withdrawn to an external e-wallet, in the case of DPTs, or to an external bank account under your name (and your name only), in the case of Fiat Money. 2. XREX may require you to verify your ownership of any external wallets or bank accounts prior to approving your withdrawal requests. Please note that XREX is unable to reverse any withdrawal transactions and therefore accepts no responsibility for amounts sent to incorrect, improperly formatted, or erroneous addresses, or addresses of a different type of DPT than the one stipulated in the withdrawal request. 3. XREX has the right to impose such conditions and limits to the amounts that you can transfer in or out of your XREX E-Wallet and Safeguarding Account at any time, depending on third-party requirements such as those of financial institutions, or in accordance with our internal policies. 4. You hereby authorise XREX to deduct from the Funds in your XREX Account the fees charged by XREX before XREX sends the amounts to any approved external wallet address and/or bank account specified by you when using the Service. 3. Other Account Funding Terms 1. You hereby accept to bear any fees charged by third parties when making transfers to external wallet addresses or bank accounts, in addition to the fees charged by XREX when executing transfers on your behalf. 2. You also accept responsibility for ensuring that any transfer request, whether inbound or outbound, complies with XREX’s requirements under these Terms, with the requirements of any third-party service providers or DPT requirements for processing such a request. For transfers of DPTs, you accept all responsibility for ensuring e-wallet addresses are properly formatted, correct, and suitable for the type of DPT being transferred. 3. You further accept responsibility for ensuring that there are no errors in your transfer instructions when using the Services. You hereby agree and accept that if you do not comply with any of the above requirements, your DPTs may be permanently lost and you agree to hold XREX harmless and waive any and all claims against XREX under such circumstances. 4. The timing of completion of transactions is contingent on the availability of third-party networks and XREX provides no guarantees as to how long it takes for a transaction to be completed. 5. XREX may suspend or even terminate your ability to make transfers into or from either your XREX E-Wallet or Safeguarding Account or both, in order to comply with Applicable Laws or at XREXʼs own discretion if XREX has reasonable grounds to suspect any wrong-doing on your part. 6. You may receive transfers of supported DPTs from supported blockchain addresses into your XREX E-Wallet. We may require you to assist with the verification of the identity of the owner of the supported blockchain address and you agree to provide us with any and all information, documents and/or materials that we may from time to time request for such purposes, and you permit us to keep a record of all such information, documents and materials for so long as we are required or permitted to do so under Applicable Laws, including beyond the termination of your Accounts. In providing us with such information, documents and/or materials that we request, you confirm (a) the accuracy, completeness, and authenticity of all such information, documents, and materials, and (b) you have not withheld any information, document or material that may influence our verification of the identity of the owner of the relevant blockchain address. 6. **Prohibited Use and Activities**\ You will not violate any law, regulation, contract, intellectual property, or another third-party right, or commit a tort while using the Services; use the Services in any manner that could interfere with, disrupt, negatively affect, or inhibit other users from fully enjoying the Services, or that could damage, disable, overburden, or impair the functioning of the Services in any manner; engage in any type of market manipulation. Market manipulation activities include, but are not limited to, pump and dump schemes, wash trading, self-trading, front running, quote stuffing, and spoofing and layering, regardless of whether it is prohibited by law; use the Services to pay for, support, or otherwise engage in any illegal gambling activities, fraud, money-laundering, or terrorist activities, or other illegal activities; use any robot, spider, crawler, scraper, or other automated means or interface not provided by us to access the Services or to extract data; use or attempt to use another userʼs account without authorisation; attempt to circumvent any content filtering techniques we employ, or attempt to access any service or area of the Services that you are not authorised to access, or attempt to access the Services from any location or jurisdiction in which you are prohibited from accessing the Services; introduce to the Services any malware, virus, trojan worms, logic bombs, or other harmful material; develop any third-party applications that interact with our Services without our prior written consent, or unless otherwise agreed; provide false, discriminatory, bigoted, abusive, inflammatory, fraudulent, deceptive or otherwise objectionable; post content containing unsolicited promotions, political campaigning, or commercial messages (SPAM) or any chain messages or user content designed to deceive or trick the user of the Service; post content containing private information of any third-party including, but not limited to, addresses, phone numbers, email addresses, Social Security numbers, and credit card numbers; promote, offer, use or otherwise exploit the Services or use or otherwise exploit any data related thereto in connection with the formation, operation or offering of any index fund or similar product or any data package or similar product or any other derivative product utilizing the Site or the Services; or encourage or induce any third-party to engage in any of the activities prohibited under this Paragraph 1. 1. Copyright Violations: XREX has a policy of limiting access to our Services and terminating the accounts of users who infringe our or others’ intellectual property rights. If you believe that anything on the Services infringes any copyright that you own or control, you may notify us via email at . In addition, please note that if you knowingly misrepresent that any activity or material on our Services is infringing, we shall hold you liable for all of our costs and damages caused by your misrepresentation. 2. Remedies: If you violate any of these Terms, XREX may, as it determines reasonably necessary to remedy or mitigate your violation, delete all or part of such information transmitted by you, suspend or cancel your account, or confiscate DPTs owned by you without any prior notice to you. XREX shall in no event be responsible or liable for any damage incurred by the user as a result of an action taken by us pursuant to this paragraph. Any right or remedy of XREX set forth in these Terms is in addition to, and not in lieu of, any other right or remedy whether described in these Terms, under the statute, at law, or in equity. 7. **Representations, Warranties and Undertakings**\ When you use the Services, you hereby represent, warrant and undertake to XREX at all times that: 1. you have full power, authority and capacity to (i) access and use the Site and/or the Services; and (ii) enter into and deliver, and perform your obligations under, this Agreement and any other agreements entered into pursuant to, or in connection with this Agreement; 2. this Agreement and any other agreements entered into pursuant to, or in connection with, this Agreement constitute valid and legally binding obligations, enforceable against you in accordance with their respective terms; 3. (in the case of an entity) you are duly incorporated, organized and validly existing under the laws of your jurisdiction and have full power to conduct your business; 4. (in the case of an individual) you are at least 18 years old or of legal age to form a binding contract under all Applicable Laws, and have full mental capacity to enter into this Agreement and any other agreements entered into pursuant to, or in connection with, this Agreement, and to make decisions regarding your investments or transactions; 5. all consents, permissions, authorisations, approvals and agreements of third parties, and all authorisations, approvals, permissions, consents, registrations, declarations, filings with any regulatory authority, governmental agency, commission or other organization having jurisdiction over you which are necessary or desirable for you to obtain in order to (i) access and use the Site and/or the Services and (ii) enter into and deliver, and perform the transactions contemplated under this Agreement and any other agreements entered into pursuant to, or in connection with, this Agreement, have been unconditionally obtaining in writing and have been disclosed in writing to us and have not been withdrawn or amended; 6. all the activities that you undertake during the use of the Services will be in compliance with all Applicable Laws; 7. your access and use of the Site and/or the Services, your execution and delivery of, and the performance of your obligations under this Agreement and any other agreements entered into pursuant to, or in connection with, this Agreement, will not (i) result in a breach of or conflict with any provision of your constitution, (ii) result in a breach of, or constitute a default under, any instrument, agreement document or undertaking to which you are a party or by which you or any of your property is bound or subject and (iii) result in a breach of any Applicable Laws; 8. all documents, materials and information you have provided to XREX are true, accurate, complete and updated in all respects, and may be relied upon by us in determining your eligibility to access the Site and use the Services; 9. you have sufficient knowledge, sophistication and experience as to be able to evaluate the merits and risks of each transaction and are acting on your own account and have made your own independent decision to enter into each transaction and assessed whether the transaction is appropriate or suitable for you based on your own judgment or upon professional advice obtained independently of us; 10. there is no pending claim, action, suit or proceedings at law or in equity (in any jurisdiction) before any court, tribunal, governmental body, agency, official or any arbitrator that is likely to affect the legality, validity or enforceability against you and/or the legal entity you act on behalf of, or your ability to perform the obligations under this Agreement; and 11. you have not suffered any Insolvency Event. 8. **Suspension, Termination and Cancellation** 1. You agree that XREX shall have the right, in its sole and absolute discretion, without prior notice to you or any other users, to refuse to act upon any instruction, refuse to complete or block, reverse, cancel, modify and/or disregard any request or transaction you have authorised or instructed, immediately suspend, restrict your access to, and/or terminate your Account or the Services, and/or freeze or liquidate your Funds in your Account, whether for a specified period of time or indefinitely, and/or refuse to transmit information or instructions to third parties, for any reason including but not limited to where: 1. we are of the opinion that we are required to do so by any Applicable Laws; 2. we reasonably believe that doing so will protect our reputation or goodwill; 3. you have not complied with, or we reasonably suspect you to be acting in breach of, any terms of this Agreement; 4. we detect any unusual activity in relation to your Accounts; 5. we detect any unauthorised access to your Accounts; 6. we have determined or reasonably suspect that any transaction is erroneous, unauthorised, fraudulent or unlawful or we suspect your Accounts and/or the Services are being used in a fraudulent, unauthorised or unlawful manner; 7. we have concerns about the security of your Accounts; 8. we have determined or suspect that there is an occurrence of money laundering, terrorism financing, fraud or any other financial crime; 9. we have determined or suspect that your Funds have been stolen or otherwise are not lawfully possessed by you; 10. we have determined or suspect that you have directly or indirectly registered an Account in another person’s name; 11. any information that you have provided to us is untruthful, inaccurate, outdated or incomplete in any respect; 12. you have conveyed your unwillingness to accept any of the revised or updated terms, conditions or provisions of the amended Agreement; 13. we have determined in our sole and absolute discretion that we no longer want to continue to have any business relations with you; and 14. you have requested in writing that we terminate or suspend the provision of any Services to you. 2. In the event of discontinuation of any or all Services or other termination of your right to access all Services: (a) all amounts payable by you to us will immediately become due; (b) we may delete or deactivate your XREX Account and all related information and files in such account without liability to you; (c) we may cancel any transaction requests that are pending at the time of discontinuation or termination. 3. In the event of discontinuation or termination of any or all Services or discontinuation or termination of transfer or storage Services for all or some DPTs, we will, unless prohibited under Applicable Laws give you a reasonable period to remove the affected DPTs and any Fiat Money from your XREX Account. 9. **Acceptance of Terms** If you do not agree to the Agreement, please do not visit, access, or use the Site or Services, or create an account. The electronic acceptance, acknowledgement of the Agreement or continued use of the Site or Services shall constitute an acceptance of the Agreement, which shall take effect upon your first access of the Site or Services. Any failure to comply with the Agreement may constitute a violation of Applicable Laws. XREX reserves the right to suspend, disable or cancel your account at any time and without notice to you if it deems that you have failed to comply with the Agreement. # 2. Data Protection and Security 1. Personal Data: You acknowledge that we may process personal data in relation to you, and personal data that you have provided (or in the future provide) to us in relation to your employees and other associates, or other individuals, in connection with the Terms, or Services. We will collect, use, disclose, and/or otherwise process your personal data in accordance with the Privacy Policy. You acknowledge that the Privacy Policy shall be incorporated by reference into, and shall form part of, the Terms. You represent and warrant that: 1. your disclosure to us of any personal data relating to individuals other than yourself has been duly authorised by such individuals, is made in accordance with all applicable data protection and data privacy laws, such data is complete, accurate, up-to-date and relevant at the time of disclosure. You shall promptly update us as to any changes in such authorisation and/or necessary changes to such personal data; 2. before providing any personal data to us or otherwise accessing or using the Services, you acknowledge that you have read and agreed to our Privacy Policy, a copy of which is available here: Privacy Policy, and, in the case of personal data relating to an individual other than yourself, have (or will at the time of disclosure have) provided the individual with a copy of, or directed the individual towards a webpage containing that Privacy Policy (as amended from time to time); and 3. if from time to time we provide you with an updated version of the Privacy Policy, you will promptly read that updated Privacy Policy and provide a copy of the same to, or re-direct towards a webpage containing the updated Privacy Policy, any individual whose personal data you have provided to us. 2. Security: 1. While XREX maintains a high standard of cyber hygiene practices and implements advanced security controls, you are required to ensure the security of your account by protecting and maintaining the confidentiality of your account data, passwords, crypto-asset wallet addresses, and other relevant data. You also agree to follow the security practices and rules presented by XREX in order to maintain the security of your account and your personal data. 2. Authentication and Verification: In order to initiate the KYC process to access the Services as required by XREX, you are to provide an email address and create a password. XREX offers two-factor authentication via a supported time-based one time password application. You are responsible for safekeeping electronic devices through which the Services are accessed and maintaining adequate security, confidentiality and control of any and all security details (including but not limited to email address, password, security information or login credentials) that are used to access the Services. This includes taking all reasonable steps to avoid the loss, theft or misuse of said electronic devices and ensuring that said electronic devices are password-protected. You must keep your security details safe at all times. For example, you should not write them down or otherwise make them visible to others. Any loss or compromise of personal electronic devices or security details may result in unauthorised access of your account by third parties, the loss or theft of Funds held in your account and/or the misuse of any associated accounts, including linked bank account(s) and e-wallets(s). You hereby accept full responsibility for any Losses arising from the above scenarios. To the maximum extent permitted under the Applicable Laws, we shall not be liable to you or any third party for any Losses arising out of or in connection with such scenarios. 3. Any breach of security, loss, theft or unauthorised use of your electronic devices and/or security details must be notified to XREX in writing immediately. We reserve the right to suspend or terminate your XREX Account at any time where the security of your account is suspected by us to have been compromised, or where we suspect that your account has been operated in breach of these Terms. 4. Safety and Security of Your Computer and Devices: XREX is not liable for any damage or interruptions caused by any computer viruses, computer worms, Trojan horses, spyware or other harmful, corrupt or malicious code, programme or software that may affect your electronic devices, or any phishing, spoofing or other attacks. We advise the regular use of reputable and readily available virus screening and prevention software to protect your electronic devices. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use all due care in reviewing messages purporting to originate from XREX. # 3. Services and Fees 1. XREX provides the following Services on the Site and XREX Pay: 1. Deposit, withdrawal, custody, conversion and transfer of DPTs; 2. Deposits and withdrawals of Fiat Money, transfer of Fiat Money and B2B payment settlements; 3. On and off-ramp conversions between Fiat Money and DPTs; and 4. Other products, features and services operated by XREX that are incidental to the above. 2. **Compliance with Law.** You represent and warrant to XREX at all times that you have informed yourself of all applicable legal and regulatory requirements, rules, prohibitions and restrictions in respect of your use of the Services, and you would fully comply with all such requirements, rules, prohibitions and restrictions, including any foreign exchange controls or restrictions or tax consequences applicable to your use of the Services. 3. **Availability of Services.** XREX may, in accordance with [Paragraph 11.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/11.-general-provisions), modify, suspend or discontinue, temporarily or permanently, all or any portion of any Services. You acknowledge and accept that (1) if and when Services resume, DPT valuations and conversion rates may differ significantly from the valuations and rates prior to the suspension or discontinuation of the Services and (2) XREX will not be liable for any losses suffered by you resulting from any modification of any Services or from any suspension, discontinuation of the Services, or termination of your access to all or a portion of any Services or for any other reason. XREX reserves the right to correct, reverse, or cancel any of your Service requests or attempt to do so where we have discovered an error, whether such error was by the Services, by you, or by a third party. You hereby authorise us to make or attempt any such correction, reversal or cancellation described. XREX provides no warranty or guarantees that any such attempt will be successful and bears no responsibility or liability for any such error or correction attempt. 4. **No Broker or Fiduciary Relationship.** XREX is not your broker, intermediary, agent, or advisor and has no fiduciary relationship or obligation to you in providing the Services nor in connection with transactions or other decisions or activities effected by you. As such, no information provided to you by XREX is intended or should be considered as advice. You are advised to consult your professional adviser. Please refer to [Paragraph 5 (Risk Warning and Disclosures)](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/5.-risk-warning-and-disclosures-limitation-of-liability-and-no-warranties) when choosing whether to use the Services. 5. **Transactions Final and Irrevocable.** Due to the nature and characteristics of our Services, you understand and agree that all transactions are final and irrevocable upon execution, subject to our right as set out in Paragraph 3.3 above. You shall not have the right to reverse or cancel any transaction. 6. **Cancellation of Transactions.** XREX may, in its sole and absolute discretion without prior notice to you, whether for a specified period of time or indefinitely, reverse, cancel, modify and/or disregard any transaction under any circumstance and for whatever reason or no reason whatsoever. 7. **Deposit, withdrawal and transfer of DPTs** 1. You may deposit any supported DPTs into your XREX E-Wallet from another digital wallet or trading platform or withdraw or transfer any supported DPTs in your XREX E-Wallet to another digital wallet or trading platform. You may also transfer any supported DPTs in your XREX E-Wallet to another XREX user via Bitcheck. Please note that only verifiable first party transfers are permitted. 2. You are solely responsible for ensuring the recipient wallet address is correct prior to submitting any such withdrawal or transfer request. 3. All instructions for withdrawals and transfers from your XREX E-Wallet are irrevocable once sent and XREX shall not be responsible for verifying recipient wallet addresses for such withdrawals or transfers. XREX will not be able to cancel a withdrawal or transfer once it has been effected. 4. XREX shall not be liable for any Losses resulting from such use of your XREX E-Wallet. 8. **Custody of DPTs** 1. You may store your DPTs in your XREX E-Wallet. 2. XREX will safeguard your DPTs in accordance with the safeguarding arrangements in [Paragraph 6](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/6.-safeguarding-measures). 3. You may track and manage your balances in your XREX E-Wallet by logging into your XREX Account. 9. **Conversion of DPTs** 1. You may convert your DPTs into Fiat Money (off-ramp conversion) or your Fiat Money into DPTs (on-ramp conversion). 2. You will have to choose the type and quantity of supported DPTs to purchase and/or sell (as applicable) and XREX will present you with the applicable conversion rate, and any associated fees before you proceed with the conversion. 3. All conversions are final and irrevocable and XREX shall not be responsible for verifying recipient account details for such transactions. No reconversions shall be made by XREX. 4. If requested by you, XREX will provide a quote setting out the current rate and spread for any conversion required. Each quote provided by XREX shall be valid for the period indicated by XREX with the quotation. By proceeding with an instruction, you are deemed to have accepted the applicable rate and spread. 5. Prior to the completion of any conversion, where such completion will or is likely to lead to an adverse effect on XREX (determined in XREX’s sole and absolute discretion), XREX shall be entitled to cancel or refuse to complete the Service without liability to you. 6. XREX may suspend provision of any conversion services for any duration by providing a written notification 24 hours in advance on its Site, XREX Pay and/or electronic mail transmission, if, in XREX’s opinion, the following categories of changes or occurrences, or any combination thereof, is effecting/are likely to effect a material change in the applicable exchange rates for a supported DPT: 1. political (including changes by reason of military action); 2. financial (including stock market conditions, currency exchange conditions in any relevant financial markets and interest rates); 3. economic conditions in the region or internationally (including changes or developments in stock, bond, money, and interest rate markets); or 4. any Force Majeure Event. 7. You are solely responsible for ensuring your bank account and XREX Account details are correct prior to submitting any instructions for any conversion transactions. 8. XREX shall not be liable for any Losses resulting from such use of the Services. 9. You acknowledge and agree that: 1. you use and rely on the Services at your own risk, and XREX excludes all liability associated with any Loss suffered or incurred by you as a result of the change in value of any supported DPTs or Fiat Money. 2. XREX will not be liable for any Losses arising out of or relating to: (a) any inaccuracy, defect or omission of the DPT’s price data, or any error, delay or interruption in the transmission of such data; (b) viruses or other malicious software obtained by accessing XREX’s websites, software, systems operated by XREX or on XREX’s behalf or any of the XREX’s Services (c) glitches, bugs, errors, or inaccuracies of any kind in XREX’s websites, software, systems operated by XREX or on XREX’s behalf or any of the XREX’s Services; or (d) a suspension or other action taken by XREX with respect to the XREX Account; or 3. XREX reserves the right to refuse to process, or to cancel, correct, reverse, claw back or recover any transaction or transfers in our sole discretion, even after funds have been debited from your XREX Account, if required by the Applicable Laws; or if XREX suspects that the transaction, including the relevant exchange rate or price data, may be erroneous, or involve money laundering, terrorist financing, fraud, or any other type of financial crime. In such instances, XREX will reverse, recover or claw back the transaction, under no obligation to reinstate a purchase or sale order at the same price or on the same terms as the canceled transaction. 10. In the event that your XREX E-Wallet or Safeguarding Account does not have sufficient Funds to execute the conversion, you will not be able to proceed with the conversion. 11. XREX shall be entitled, in its sole and absolute discretion, to determine the types of DPTs and the specific blockchain thereof that will be made available for trading, transferring, and storing on the Services. XREX will make reasonable efforts to notify you in writing of any changes to the supported DPTs. If you do not remove your unsupported DPTs or other assets to an external wallet address or account prior to the cessation of support on the Services, you may lose all or part of your DPTs or other assets. In such cases, XREX will not be liable for any losses, liabilities, costs, or expenses related to its decision to remove support for any DPT or asset. 10. **Deposit and withdrawal of Fiat Money** 1. You may deposit any supported Fiat Money into your XREX Account from your bank account for the purposes of using the Services or withdraw any supported Fiat Money in your XREX Account to your bank account. 2. You are solely responsible for ensuring your bank account details are correct prior to submitting any such withdrawal request. 3. All instructions for withdrawals from your XREX Account are irrevocable once sent and XREX shall not be responsible for verifying recipient account details for such withdrawals. XREX will not be able to cancel a withdrawal once it has been effected. 4. XREX shall not be liable for any Losses resulting from such use of your XREX Account. 11. **Transfer of Fiat Money** 1. You may transfer any supported Fiat Money in your XREX Account to: 1. a third party via the Site or XREX Pay; or 2. XREX user via BitCheck, the Site or XREX Pay. 2. You are solely responsible for ensuring the recipient account details is correct prior to submitting any such transfer request. 3. All instructions for transfers from your XREX Account are irrevocable once sent and XREX shall not be responsible for verifying recipient account details for such transfers. XREX will not be able to cancel a transfer once it has been effected. 4. XREX shall not be liable for any Losses resulting from such use of your XREX Account. 12. **B2B Payment Settlements** 1. You may effect: 1. B2B payment settlements with another user by utilising BitCheck; or 2. B2B payment settlements with a third party by raising a payment request to process payment to that third party. 2. Please refer to the BitCheck Service Agreement for the terms and conditions on the use of BitCheck. 13. **Fork and Airdrops.** You remain the lawful and beneficial owner of any assets and DPTs in your account and the beneficial owner of additional assets resulting from any applicable (i) network fork that is supported by XREX and (ii) airdrop or similar distribution of DPTs. You acknowledge and agree that XREX retains sole and absolute discretion and has no obligation to support any particular forks, airdrops or similar distribution and such support remain in all instances subject to the Terms. 14. **Fees** 1. Fees and charges on using the Services shall be set out in the [XREX Pay Help Center](https://intercom.help/xrex-sg/en/) and may be periodically updated by us at our sole and absolute discretion. 2. You agree to pay XREX the fees and charges by authorising us to deduct and/or debit your Funds or from the Conversion amount for any applicable fees payable by you under these Terms. 3. You agree and understand that your acceptance of these Terms include your acceptance of our Fee Schedule. We reserve the right to change or modify our Fee Schedule, including increasing our fees in the Fee Schedule, in accordance with [Paragraph 11.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/11.-general-provisions). The updated Fee Schedule will apply prospectively to the relevant Services that take place following the effective date of such updated Fee Schedule. # 4. Proprietary Rights 1. **Ownership.** The Services, Site, and all technology, content, data, service names, logos, marks and other materials used, displayed or provided to you in connection with the Services or Site (“**XREX Materials**”) together with all intellectual property rights in any of the foregoing are solely owned by XREX. 2. **Licence.** Subject to the user’s compliance with the Terms, we grant you a limited, revocable, non-exclusive, non-transferable licence to access the Site, XREX Materials and Services for your own personal, informational, non-commercial use as expressly permitted under these Terms. Any other use of the Site or XREX Materials is expressly prohibited and all other rights, title, and interest in the Site or XREX Materials is exclusively the property of XREX and its licensors. XREX reserves all rights, title and interest not expressly granted under this licence to the fullest extent possible under Applicable Laws. 3. **Restrictions.** Without limiting the foregoing, you shall not: 1. re-sell, lease, license, lend, share, distribute, or otherwise permit any third party to use the Site, Services, or XREX Materials or use the Site, Services or XREX Materials; 2. modify, develop or create derivative works of the Site, Services, or XREX Materials, or any portion thereof or any data or information received by you in connection therewith; 3. frame, display, or incorporate the Site, Services, or XREX Materials in any website or any other work of authorship; 4. decompile, disassemble, reverse engineer or attempt to discover the source code of the Site, Services, or XREX Materials; 5. use, or permit the use of, the Site, Services or XREX Materials to design, develop or create any competing product or service; 6. copy, imitate, transmit, distribute, sell, license, reverse engineer, modify, publish, use or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the XREX Materials, in whole or in part copy, without our prior written consent; or 7. otherwise use the Site, Services, or XREX Materials for any commercial or noncommercial purpose other than their intended purposes determined at our discretion. 4. **Feedback.** Any feedback, suggestions, ideas, or other information or materials regarding XREX or the Services that you provide, whether by email, posting through the Services, or otherwise (“**Feedback**”) shall vest in XREX. You hereby assign to XREX Inc. all rights, title, and interest to Feedback together with all associated intellectual property rights. You will not be entitled to, and hereby waive any claim for, acknowledgement or compensation based on any Feedback or any modifications made based on any Feedback. 5. **User Content.** You hereby grant to us a royalty-free, fully paid-up, sublicensable, transferable, perpetual, irrevocable, non-exclusive, worldwide licence to use, copy, modify, create derivative works of, display, perform, publish and distribute, in any form, medium or manner, any text, information, data, materials, images, or other content you provide to us using the Services or submit or post to the Site and that is not Feedback owned by us (the “**User Content**”). You represent and warrant that: 1. you own the User Content or have the right to grant the rights and licences in these Terms, and 2. the User Content and use by XREX of the User Content as licensed herein does not and will not violate, misappropriate or infringe on the rights of any third party or any Applicable Laws. We may remove any User Content from the Site for any reason at our discretion. 6. **Third-Party Content.** The Site may contain information concerning third parties, third party products and services or links to third party websites or applications (“**Third-Party Content**”). In using the Services, you may view the Third-Party Content. XREX does not monitor, control, endorse, or adopt any Third-Party Content and shall have no responsibility for Third-Party Content, including without limitation material that may be misleading, incomplete, erroneous, offensive, indecent, or otherwise objectionable. Any links to other websites are provided as a convenience to you and does not imply XREX’s endorsement, whether express or implicit, of the linked website. In addition, your business dealings or correspondence with such third parties are solely between you and the third parties. To the maximum extent permitted by law, XREX is not responsible or liable for any loss or damage of any sort incurred as the result of any such dealings between you and these third parties, whether or not such dealings have been performed or facilitated through the Site, arising out of or in relation to anything done or omitted to be done in relation to the Third-Party Content, or any delay, inaccuracies or omissions in the Third-Party Content or any interruption to the supply of the Third-Party Content, or the act or omission of these third parties, and you understand that your use of Third-Party Content, and your interactions with third parties, is at your own risk. # 5. Risk Warning and Disclosures, Limitation of Liability, and No Warranties You should read the following statements in detail before using any of the Services. #### 1. **RISK WARNING ON DIGITAL PAYMENT TOKEN SERVICES:** The Monetary Authority of Singapore (“**MAS**”) requires us, **XREX Pte. Ltd.**, to provide this risk warning to you as a customer of a digital payment token (“**DPT**”) service provider. **Before you:** (a) pay your DPT service provider any money or DPT; or (b) pay a third party any money or DPT under an arrangement by your DPT service provider, **you should be aware of the following:** a. XREX Pte. Ltd., being your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider or any other third party referred to above, if your DPT service provider’s or the third party’s business fails. b. You should be aware that MAS does not supervise or regulate your DPT service provider for the provision of unregulated services. This includes any service of trading digital payment token derivatives such as futures. Please refer to Section 2.3.1 of the Guide to the Payment Services Act 2019 (“**Guide**”) (which can be found on the MAS website) for the types of payment services which are regulated under the Payment Services Act. Services which do not fall within the list of services in Section 2.3.1 of the Guide are unregulated services. c. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact if transferred or held by your DPT service provider. d. You should be aware that the value of DPT’s may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens. e. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “**stablecoin**”. #### **2. RISK DISCLOSURES:** **(1) INDUSTRY RISKS** The DPT industry represents a relatively new and rapidly changing industry, and its success is subject to a variety of factors that are difficult to evaluate. The slowing of the development or acceptance of DPTs may adversely affect the DPTs. The growth of the Virtual Asset Service Providers (“**VASPs**”) is also subject to a high degree of uncertainty. \ \ The factors affecting the sustainability of the DPT industry include: * continued worldwide growth in the adoption and use of DPTs; * government regulation of DPTs and their use, or restrictions on or regulation of access to and operation of VASPs; * the maintenance and development of the open-source software protocol; * changes in consumer demographics and public tastes and preferences; * the availability and popularity of other forms or methods of buying and selling goods and services, including new means of using fiat currencies and DPTs; and * general economic conditions and the regulatory environment relating to DPTs. A decline in the popularity or acceptance of DPTs may harm the market price of the DPTs. There is no assurance that any VASPs (including XREX) necessary to accommodate the sale and transfer of the DPTs will continue in existence or grow. Furthermore, there is no assurance that the availability of and access to VASPs will not be negatively affected by government regulation or supply and demand of DPTs and/or other digital assets.\ \ DPTs are not considered legal tender and may not be backed by governments or other legal entities, or by commodities such as gold or silver, and are a unique kind of currency, backed by technology and trust. There is no central bank that are able to undertake corrective measures to protect the value of DPTs in a crisis, manage the demand or supply of DPTs or smoothen any fluctuations in the price or value of DPTs. Instead, DPTs are an autonomous and largely unregulated worldwide system of currency.\ \ **XREX makes no representations, warranties or undertakings on whether any DPT will always be available to trade on the Site, and/or be supported by XREX. XREX may, in its sole and absolute discretion, delist any DPT.** **(2) MARKET RISKS** The prices of DPTs have historically been subject to dramatic fluctuations and are highly volatile. Due to such price fluctuations, you may increase or lose value in the DPTs at any given moment. DPTs may even become worthless. You should not commit funds to trading in DPTs that you are not prepared to lose entirely.\ \ Several factors may influence the market price of the DPTs, including, but not limited to: * global DPTs supply and demand, which can be influenced by the growth of merchants’ and commercial businesses’ acceptance of DPTs as payment for goods and services, the security of DPTs and digital asset exchanges and digital wallets, and the regulatory restrictions on the use and trading of DPTs; * currency exchange rates, including the rates at which DPTs may be exchanged for fiat currencies; * interruptions in service from or failures of major blockchain exchanges on which the DPTs may be traded; * investment and trading activities of large purchasers, including private and registered funds, that may directly or indirectly invest in the DPTs; * monetary policies of governments, trade restrictions, currency devaluations and revaluations; * regulatory measures, if any, that affect the use of digital assets such as the DPTs; and * global or regional political, economic or financial events and situations. Markets for DPTs have varying degrees of liquidity. Some DPTs are liquid while others may be illiquid. XREX does not guarantee that the markets for any DPT will be active and liquid, or that you would be able to buy or sell any DPT whenever you desire or at a favourable price. XREX does not guarantee any profit from trading in DPTs or any other activities associated with the Services. **(3) LEGAL AND REGULATORY RISKS** *Government regulation and Applicable Laws.* DPTs are a relatively new asset type and the continued popularity of and risks involving DPTs has attracted and will continue to attract regulatory scrutiny. Regulation of DPTs and VASPs is unsettled and rapidly evolving, and may severely impact the development and growth of this market and the secondary market for the DPTs. The application and interpretation of existing laws and regulations are largely untested and there is a lack of certainty as to how they will be applied. New laws and regulations may be promulgated in the future that apply to blockchain technology and DPTs, and related service providers, and no assurance can be given that any such changes will not adversely affect DPTs generally (including the use, transfer, exchange and value of DPTs) or the Services. \ \ Changes in Applicable Laws may affect the price, liquidity and/or tradability of DPTs, or the use of any Services. DPTs may decrease in value or lose all of its value due to such changes.\ \ Regulatory actions by governmental authorities could negatively impact DPTs in various ways, including a determination, whether retrospectively or prospectively, that DPTs are financial instruments requiring licensing or registration in certain jurisdictions.\ \ XREX may have to suspend, restrict or limit the trading of certain DPTs or the use of certain Services or disallow users to trade DPTs or use any of the Services based on their citizenship, residence or location if doing so is commercially unsustainable or is prohibited by any Applicable Laws. Changes to Applicable Laws could materially and adversely affect the price, liquidity and/or tradability of DPTs, or the use or availability of any Services.\ \ **XREX has sole and absolute discretion to suspend or reject the execution of any of your instructions, suspend or cease support for any DPTs, or suspend or terminate your access to any accounts or Services, where any such action or inaction is, in XREX’s sole opinion, necessary to facilitate XREX's compliance with Applicable Laws.** **(4) TECHNOLOGY AND RELATED RISKS** *Technology risks.* DPTs rely on various types of distributed ledger technology. Some of this technology is open-source software that is built upon experimental technology, namely blockchain. XREX does not own or control such technology. Risks arising from relying on such technology include the existence of technical flaws in the technology, targeting by malicious persons, changes in the consensus protocol or algorithms, decreased community or miner support, the existence or development of competing networks, platforms and assets, flaws in the scripting language, disputes between developers, miners and/or users and regulatory action. Such changes may materially affect the value, availability and functionality of the DPTs you store in your XREX Account. XREX does not control the timing and features of these changes and it is your duty to keep yourself updated of any potential or implemented changes to any DPTs or the technology and you must carefully consider publicly available information and information that may be provided by XREX in determining whether or not to continue to trade in the affected DPT.\ \ **XREX reserves the right, in its sole discretion, to suspend or cease to support the transfer, storage or trading of any DPT in response to any technology changes. XREX may, but is not obligated to, make changes to your XREX Account in response to such changes. You may be unable to withdraw DPTs if XREX ceases to support transfer of any such DPTs as a result of these technology changes, which may result in the total loss of any such DPTs remaining in your account. XREX will not be liable for any Losses you may experience as a result.** \ \ \&#xNAN;*Network and other risks.* The underlying protocols supporting the Services, and the smart contracts that underlie the DPTs may be subject to certain risks that are beyond our control, and which may result in events, such as (a) loss of control or ownership of your DPTs and (b) transaction records on the blockchain being altered, reversed or otherwise invalidated, whether by way of fraudulent acts or consensus.\ \ \&#xNAN;*Transactions irreversible.* Transactions involving DPTs on blockchain networks are generally irrevocable and irreversible. This means accidental or fraudulent transactions in respect of, or loss or theft of your DPTs may not be reversible. XREX will not be liable for any losses that you may experience in such a scenario.\ \ \&#xNAN;*Loss of private key(s) is permanent and irreversible.* A digital private key is required to access and trade your DPTs. The loss or theft of your private keys will permanently and irreversibly deny you access to your DPTs and hence, you may lose all value of your DPTs. XREX will not be liable for any losses that you may experience in such a scenario. **(5) CYBER-SECURITY, INTERNET AND RELATED RISKS** *Cyber-attacks and other criminal activities.* Cyber-attacks may take different forms, including (but is not limited to) distributed denial of service, computer viruses, spyware, scareware, Trojan horses, worms, malware, double-spending, majority-mining, consensus-based or other mining attacks, misinformation campaigns and spoofing, communication failures and disruptions, which may affect the features, functions, operation, use, access or other properties of the Services and your XREX Account(s). The Services and your accounts may also be exploited for vulnerabilities in smart contracts and other code, as well as to human error. Any such cybersecurity failures or breaches, whether involving the Site or third-party service providers, could have a negative impact on the price, liquidity and/or tradability of DPTs, or the use of any Services. \ \ \&#xNAN;*Cryptographic advancements.* Developments in cryptographic technologies and techniques, including (but not limited to) the advancement of artificial intelligence and/or quantum computing, pose security risks to all cryptography-based systems including the Services, the network infrastructure and your DPTs. These ill-intended use of these advancements may result in theft, loss, disappearance, destruction, devaluation or other compromises of your XREX Account(s) and Funds. \ \ \&#xNAN;*Reliance on the internet.* Transactions rely heavily on the internet and other technologies. However, the public nature of the internet means that either parts of the internet or the entire internet may be unreliable or unavailable at any given time. Further, interruption, delay, corruption or loss of data, the loss of confidentiality in the transmission of data, or the transmission of malware may occur when transmitting data via the internet and/or other technologies. \ \ \&#xNAN;*Unauthorised access.* Any information (including any document) transmitted, or communication or transactions made, over the internet or through other electronic media (including electronic devices, services of third party telecommunication service providers such as mobile phones or other handheld trading devices or interactive voice response systems) may be subject to interruption, transmission blackout, delayed transmission due to data volume, internet traffic, market volatility or incorrect data transmission (including incorrect price quotation) or stoppage of price data feed due to the public nature of the internet or other electronic media. Any DPT may be lost forever if it is sent to the wrong address, such as improper address format and erroneous wallet address.\ \ \&#xNAN;*Operational issues.* Any technological difficulties could prevent your access to your XREX Account or use of the DPTs stored in your XREX Account. For instance, you may be prevented from sending an instruction or initiating a transaction and you may not be able to deposit, withdraw or transfer your DPTs instantaneously. XREX shall not be liable for any losses suffered from any price movements of the DPTs during this period of time.\ \ **XREX makes no representation, warranty or undertaking of any kind, express or implied, statutory or otherwise, regarding any of its technology or blockchain functionalities. XREX does not guarantee the functionality or security of any DPTs or their underlying technology. You acknowledge and accept the risk of any changes or breach of security to the Services, its underlying technology and to the Funds in your XREX Wallet and/or XREX Account(s).**\ \ **You further acknowledge and accept that XREX does not control Internet signal power, its reception or routing, configuration of your equipment or its reliability, and that XREX shall not be responsible for any communication failures, disruptions, errors, distortions or delays you may experience when using the Services, however caused.** **(6) THIRD-PARTY RISKS** There is no guarantee that any person or business who currently accepts DPTs as payment will continue to do so in the future. XREX has no control over, and assumes no liability, for the delivery, quality, safety, legality or any aspect of any DPT that you may receive from or transfer to, any third party. **(7) COMMUNICATION RISKS** There is a risk that you may suffer Losses arising from or in connection with XREX accepting and acting on any instructions over the Site, XREX Pay and/or any other channel, platform or communication service which appears to XREX to be from you and which turns out to have been forged, fraudulent or unauthorised and/or any miscommunication, communication breakdown, forgery, delay, mutilation or duplication in connection with the transmission of any instructions to XREX. **(8) CONFLICTS OF INTEREST RISKS** Actual, potential and/or perceived conflicts of interest may arise while providing the Services to you.\ \ For instance, conflicts of interest may arise between our personnel responsible and accountable for safeguarding your DPTs, and those personnel who make investment, trading or other discretionary decisions on your behalf. If such risks are not mitigated, there may be a risk of misuse of your DPTs. To mitigate such risks, XREX has implemented the following measures: 1. XREX will ensure the segregation of duties to guard against the risk of unauthorised transactions; 2. XREX will implement controls and clear reporting lines for such personnel responsible for safeguarding your DPTs to a senior manager who is resident in Singapore and is independent from trading and commercial decisions; and 3. XREX will provide for different personnel to hold the digital keys and no single employee would be able to solely authorise and effect the disposition, transfer or withdrawal of your DPTs. In determining prospective DPTs which we intend to support on our Site, conflicts of interest may arise if we support DPTs that are issued by us or our related corporations or if we receive incentives to support certain DPTs. Please refer to our Statement on Listing of DPTs for more details on the potential conflicts of interest and the mitigating measures.\ \ WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, YOU ACKNOWLEDGE THAT, BY ACCESSING AND USING THE SERVICES YOU ARE ENGAGING IN FUNDAMENTALLY RISKY TRANSACTIONS INVOLVING SOPHISTICATED INSTRUMENTS. DPTS ARE HIGHLY VOLATILE INSTRUMENTS AND CAN RAPIDLY AND UNEXPECTEDLY DECREASE IN VALUE. TRANSACTING IN DPTS ALSO REQUIRES A CERTAIN LEVEL OF TECHNICAL KNOWLEDGE AND UNDERSTANDING WITHOUT WHICH USERS MAY LOSE THE VALUE OF, OR ACCESS TO, SOME OR ALL OF THEIR DPTS. BY ACCESSING THE SERVICES YOU AGREE THAT YOU ARE VOLUNTARILY ENGAGING IN INHERENTLY RISKY TRANSACTIONS AND THAT YOU ARE AWARE OF THE RISKS INVOLVED INCLUDING BUT NOT LIMITED TO, RISKS OF FINANCIAL LOSS, LOSS OF ACCESS TO DPTS AND FIAT CURRENCIES DUE TO TECHNICAL ERRORS, SYSTEM DOWNTIME, SOFTWARE FLAWS AND CYBER-HACKS WHICH COMPROMISE THE SECURITY OF OUR SERVICES AND/OR YOUR OWN PERSONAL SYSTEMS. #### **3. LIMITATION OF LIABILITY** IN NO EVENT WILL THE LIABILITY OF XREX, THEIR RESPECTIVE AFFILIATES, AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS, OR CONTRACTORS ARISING OUT OF OR IN CONNECTION WITH THE SITE, THE SERVICES, THE XREX MATERIALS, ANY PERFORMANCE OR NON-PERFORMANCE OF THE SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM PROVIDED BY OR ON BEHALF OF XREX, WHETHER UNDER CONTRACT, STATUTE, STRICT LIABILITY OR OTHER THEORY (INCLUDING, FOR AVOIDANCE OF DOUBT, ANY NEGLIGENCE OF XREX) EXCEED THE RELEVANT AMOUNT OF THE FEES PAID BY YOU TO XREX UNDER THIS AGREEMENT IN THE TWELVE-MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM FOR LIABILITY, OR THE PERIOD OF DURATION OF THIS AGREEMENT BETWEEN YOU AND XREX, WHICHEVER IS SHORTER. This Limitation of Liability shall apply to the fullest extent permitted by the Applicable Laws. The Limitation of Liability in this Section is subject to any obligations that we have under Applicable Laws, including our obligation to exercise reasonable care and skill in our provision of the Services. Nothing in this Agreement shall limit our liability resulting from our fraud or fraudulent misrepresentation, gross negligence, deliberate misconduct, nor for death or personal injury resulting from our negligence. #### **4. No Warranties:** All services and products are provided on an “**AS IS**” and “**AS AVAILABLE**” basis. To the fullest extent permitted by the Applicable Laws, XREX disclaims any representations and warranties of any kind, whether express, implied, or statutory, including, but not limited to, the warranties of merchantability and fitness for any particular purpose. # 6. Safeguarding Measures 1. **Safeguarding Arrangements** 1. Upon receipt of your Relevant Money by XREX, your Relevant Money shall be deposited and held by XREX in separate designated Safeguarding Account maintained by XREX with banks or other duly licensed financial institutions (each a “**Safeguarding Institution**”) by no later than the next Business Day following such receipt. 2. Upon receipt of your DPTs by XREX, your DPTs shall be deposited and held by XREX in separate designated Trust Account maintained with XREX and/or such other person that is appointed by XREX to safeguard your DPTs in accordance with Applicable Laws (“**Safeguarding Person**”). 2. Your Funds deposited in the Safeguarding Account and Trust Account will be held on trust by XREX on behalf of you and are segregated and maintained separately from XREX’s own corporate funds. Subject to the Applicable Laws, all assets deposited in the Safeguarding Account and the Trust Account cannot be used for the payment of the debts of XREX and are not liable to be taken under or pursuant to an enforcement order or a process of any court. However, you should be aware that XREX may exercise its right of set off against your Funds held on your behalf. If the Safeguarding Institution or the Safeguarding Person becomes insolvent, you may not be able to recover any of your Funds if the assets are insufficient to satisfy the claims of its creditors or it may take a long time for you to recover your Funds as the process of liquidation and the distribution of proceeds could take a long time. 3. Your Funds in the Safeguarding Account and the Trust Account are commingled and pooled with the Funds received from other users and are exposed to losses or shortfalls in the pooled funds. Any interest earned from your Funds maintained in the Safeguarding Account and the Trust Account are payable to XREX and will not accrue to you. In the event of any misappropriation of Funds in the Safeguarding Account and the Trust Account, you may suffer loss of your Funds. XREX shall not be responsible or liable to you or any other person or entity for any losses incurred by you in connection with any insolvency and/or default by any Safeguarding Institution and its representatives, except that the foregoing shall not exclude any liability in respect of any losses that are caused directly by fraud or negligence by XREX (as adjudged in a final, non-appealable decision of a court of competent jurisdiction or binding arbitration proceeding). You acknowledge that in the event that there are any outstanding amounts owed by you to XREX as designated by XREX (if any) (“**Owed Amounts**”), your Funds held in the Safeguarding Account and the Trust Account may be used to top up or cover for the Owed Amounts. In the event that the Safeguarding Account or the Trust Account is maintained with a Safeguarding Institution outside Singapore, you acknowledge that the laws and practices relating to Safeguarding Account and the Trust Account in the jurisdiction under which the Safeguarding Institution and the Trust Account is licensed, registered or authorised in may be different from the laws and practices in Singapore relating to the Safeguarding Account and the Trust Account (as the case may be). These differences may include, but are not limited to, varying requirements for segregation of assets, custodial arrangements, and any such differences may affect your ability to recover the Funds deposited in the Safeguarding Account and the Trust Account. The level of protection and recourse available to you may not be equivalent to that provided under Singapore’s laws and regulations governing the Safeguarding Account and the Trust Account. 4. In the event where your Funds are commingled with other users of XREX’s services, there is a risk that your interest may not be identifiable by separate physical documents or electronic records kept by XREX and it may be difficult to identify or earmark your Funds from those of other users. Nevertheless, XREX shall maintain records of your interest in the assets that have been commingled. 5. In order to provide sufficient safeguarding measures to your Funds, XREX shall not permit any withdrawal of your Funds from the Safeguarding Account and the Trust Account from any third parties that is not registered under your account, unless a validly executed authorisation letter has been provided to XREX. XREX shall ensure that each Safeguarding Institution and Safeguarding Person complies with the same. 6. In the event that you are of the view that it has incurred losses due to XREX’s fraud or negligence, you shall provide a written report containing full details of such losses. You should also comply with mitigation measures set out in [Paragraph 1.4.b](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/1.-account). Upon receiving the written report, XREX shall conduct an investigation into your claims. You agree to provide all information and/or documentation which XREX may request for in order for XREX to conduct its investigation. Such information could include a comprehensive account of the incidents, the documentations and records reflecting losses suffered, personal identification number and your bank account information for the purposes of identity verification, and such other information that XREX may reasonably require. XREX shall compensate you for any loss of Funds arising from any fraud or negligence on the part of XREX, as XREX may determine in its sole and absolute discretion or as may be adjudged in a final, non-appealable decision of a court of competent jurisdiction or binding arbitration proceeding, in accordance with the Safeguarding Institution’s policies or insurance schemes. 7. XREX shall comply with all recordkeeping obligations under any written law as applicable and ensure each Safeguarding Institution complies with the same. XREX shall also notify you should there be any fees and costs for the safeguarding of your Funds. 8. XREX maintains and stores a minority portion of customer assets in the settlement wallet, which are used as ready liquidity for daily trading, withdrawal and other transactional activity. This minority proportion of customer assets will be maintained by rebalancing to a specific target percentage that complies with Applicable Laws. Assets are managed between the settlement wallet and vault storage systems to ensure that we have the minimum amount of funds in the settlement wallet required to facilitate the immediate liquidity needs of our customers. 9. To mitigate the risk of loss of customer assets due to cyber attacks, XREX takes extensive security measures to protect your assets, including strategically storing a vast majority of assets offline in secure, guarded vault storage facilities that are not connected to the internet so that they are more resistant to threats. In addition, all settlement wallet private keys are stored in an isolated, dedicated service, in an encrypted format. 10. XREX shall inform you of any rights or entitlements (if any) arising from your Funds held within the Safeguarding Institution, or any information relating your Funds. The information in this Section shall be detailed to you via electronic messaging or email. 11. XREX shall provide you with your monthly statement of account with the following particulars: 1. transactions to purchase or sell assets entered into by you and the price at which the transactions are entered into; 2. the status of every asset in XREX’s custody held on behalf of you, including any asset deposited with the Safeguarding Institution; 3. the movement of each of your asset, the date of and reasons for such movement, and the amount of the asset involved; 4. the movement and balance of relevant money received from, or on account of, you in respect of the provision of XREX’s services; and 5. a detailed account of all financial charges and credits to your account during the monthly statement period, unless the detailed account of financial charges and credits has been included in any contract note or tax invoice issued by XREX to you. 12. XREX shall also provide you with your statement of account as soon as practicable upon your written request. However, Section 6.11 shall not apply if: 1. there is no change to any of those particulars since the date on which the last statement of account was made up to; 2. XREX has made available to you, on a real-time basis, those particulars in the form of electronic records stored on an electronic facility and you have consented to those particulars being made available to you in this manner; or 3. you requested, in writing, not to receive the statement of account on a monthly basis from XREX. 13. You confirm and agree, in including for the benefit of the Safeguarding Institution(s) that: 1. the Safeguarding Account arrangements do not result in you being a party to any agreement with the Safeguarding Institution(s), and you will have no right to enjoy or enforce any benefit under such agreement; 2. the Safeguarding Institution(s) does not owe any obligation to you and you have no right to claim against the Safeguarding Institution(s) in relation to any services provided by the Safeguarding Institution(s) to XREX, and your rights and obligations (if any) in relation to any services provided by XREX to you are exclusively against or to XREX only, and not against or to the Safeguarding Institution(s). 14. XREX reserves the right to impose and/or modify any fees or costs associated with the safeguarding of your Funds. Such fees or costs shall be set out in the Fee Schedule, which can be found in the [XREX Pay Help Center](https://intercom.help/xrex-sg/en/) and may be periodically updated by us at our sole and absolute discretion. You agree to pay XREX the fees and costs by authorising us to deduct and/or debit your Funds for any such fees or costs. We reserve the right to change or modify our Fee Schedule, including increasing our fees in the Fee Schedule, in accordance with [Paragraph 11.4](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_03-nov-2025/11.-general-provisions). The updated Fee Schedule will apply prospectively to the relevant Services that take place following the effective date of such updated Fee Schedule. # 7. Taxes 1. You are solely responsible for determining, reporting and paying any Taxes under the Applicable Laws that may arise from the transactions made and/or your use of the Services, in accordance with the Applicable Laws. XREX does not provide investment, legal, financial, business or tax advice in connection with your transactions and is not responsible for determining whether any Taxes apply to your transactions, or for collecting, reporting or remitting any Taxes arising from any transaction. It is your responsibility to check with your local tax advisor to determine which Taxes apply to you (if any), and it is your responsibility to pay such Taxes to the appropriate tax authority. You agree that XREX may report information relating to your transactions, payments, transfers, or distributions to the relevant tax or governmental authority, to the extent such reporting is required by Applicable Laws. 2. All liabilities of you to us (including payment for any fees relating to the Services) are to be made free and clear of, and without any deduction or withholding for and on account of, any Taxes, duties or other deductions. Any such deduction or withholding, if required by the laws of any country or taxation authority shall be your sole responsibility. If any such deduction or withholding is required, you agree to increase the sum payable to XREX to ensure that XREX receives the full amount which would have been due to XREX, had no such deduction or withholding been required. 3. XREX may withhold any applicable Taxes from your transactions, payments, distributions made or deemed made to you, where such withholding is required by Applicable Laws. From time to time, XREX may request tax documentation or certification of your taxpayer status. Failure to comply with this request within the timeframe notified may result in withholding and/or remission of Taxes to the tax authority as required by the Applicable Laws. # 8. AML/CFT and Know-Your-Client (KYC) Policy 1. **Know Your Client (KYC) Policy:** XREX conducts ongoing verification of individuals and organizations using the Services. You agree to provide complete and accurate personal information (including but not limited to your name, email address, registered address, gender, phone number, nationality, date of birth, tax identification number or ID card number or passport number, a bank account registered in your name, and other registration and transaction-related information) that XREX and any appointed third-party service providers including financial institutions and KYC/AML compliance vendors may from time to time request. 2. These third parties may collect, process, or use your personal information for the purposes of performing their designated tasks, which may include verifying the authenticity of your bank account, ensuring compliance with Applicable Laws, and fulfilling AML/CFT obligations. Based on the outcomes of such verifications, XREX and its appointed third parties reserve the right to take any measures they deem appropriate. In providing us with your information, you confirm that (a) the accuracy, authenticity and completeness of all such information, documents and materials and (b) you have not withheld any information, document or material that may influence our evaluation of you for the purposes of registering or maintain your XREX Account or providing Services to you. 3. You represent that you are not, directly or indirectly involved in any activity that may contravene the Applicable Laws, in particular the AML/CFT laws and regulations. 4. You further represent and warrant that, to the best of your knowledge: 1. you; 2. any person controlling or controlled by you; 3. if you are a privately held entity, any person having a beneficial interest in you; and 4. any person for whom you act as agent or nominee in connection with this trading, are not listed on any sanctions of restricted party list issued by the relevant regulatory authority in Singapore or any other applicable jurisdiction.\ \ Please be advised that XREX may not accept any trading activities from a prospective user if it cannot make the representations set forth in Paragraphs 8.3 and 8.4 above. In addition, if you cannot make these representations, XREX, at its sole and absolute discretion, may prohibit, terminate or suspend your trading activities and account. 5. You agree to promptly notify XREX if you become aware of any change in the information provided in Paragraphs 8.3 and 8.4 above. Under the Applicable Laws, XREX may be required to “freeze” your account, including suspending trading activities in order to comply with the regulatory obligations. XREX and/or its representatives may also be required to report such action and to disclose your identity to the relevant authorities. In particular, you agree that XREX shall be entitled to (i) exercise its rights under Paragraphs 1 and 3 of the Terms; and (ii) report instances of fraudulent, criminal, suspicious activity or transactions to the relevant authorities. 6. You agree to promptly provide any additional documentation XREX and/or its representatives may request, as deemed necessary by XREX to comply with Applicable Laws. You acknowledge and consent to the disclosure of such information by XREX and/or its representatives to the regulatory authorities in Singapore or other jurisdictions, particularly in connection with AML/CFT requirements. You further agree to have face-to-face meetings with representatives of XREX or take any other action as XREX may require for purposes of performing enhanced due diligence on you so that XREX may establish your source of wealth and source of funds for any transactions carried out in the course of your use of the Services. 7. You agree that XREX and/or its representatives may disclose your information to one another, to any service provider engaged by XREX, or to any regulatory body in any applicable jurisdiction. Such disclosure shall not be deemed a breach of any legal or contractual restriction on the disclosure of information. 8. **AML/CFT Policy:** XREX constantly monitors transactions conducted on the Site and through its Services. We may suspend or block any transaction without prior notice to you if we have reasonable grounds to suspect that you are a designated individual or entity as defined or set out in the Singapore Sanctions Laws, or that the transaction presents risks related to money-laundering, terrorism financing, or similar unlawful activities. In compliance with Applicable Laws, XREX will report any suspicious activity or transaction to the relevant authorities.\ \ XREX reserves the right to deny or suspend access to the Services to anyone: 1. refusing or unable to provide sufficient evidence of their identity and/or their source of funds to the satisfaction of XREX; 2. providing information which XREX determines to be false, misleading, or otherwise unacceptable in any respect; or 3. is identified as a designated individual or entity as defined or set out in the Singapore Sanctions Laws. 9. **Disputes:** If XREX has reasonable grounds to suspect that you are a designated individual or entity as defined or set out in the Singapore Sanctions Laws or any Applicable Laws, or that any DPTs in your XREX E-Wallet are stolen, unlawfully possessed, or represent the proceeds of any illegal activity, we may, in our sole discretion, place an administrative hold on the affected DPTs. This hold will remain in place until the dispute is resolved and you provide evidence acceptable to XREX. XREX will not participate in or mediate the resolution of such disputes. You acknowledge and agree that XREX shall not be liable for any Losses arising from such a hold, or from your inability to withdraw DPTs or Fiat Money, or to execute transactions during the hold period. 10. You are responsible for ensuring that your email address and mobile phone number on file with us remain current and valid to receive electronic Communications. If we send you an electronic Communication and you do not receive due to outdated or incorrect contact information, the blocking by your service provider, or other delivery issues, the Communication shall nonetheless be deemed to have been provided to you. \ \ You can update your contact details at any time by filing a support request at or informing your designated relationship manager in writing. If your contact details become invalid and the Communications sent to you are returned, we may deem your account inactive, and you may be unable to complete any transaction via our Services until valid and accurate contact information is provided.
# 9. Indemnification 1. None of the Indemnified Parties shall not be liable to you for any Losses, arising out of or in any way connected with: 1. the use or performance of the Site or the Services thereon; 2. trading activities conducted on the XREX platform; 3. the withdrawal or settlement process; 4. the delay or inability to use the Site or the Services thereon; 5. any Force Majeure Event; 6. the provision of or failure to provide the Site or the Services thereon; 7. any third-party operator or open-source software on which the Services provided by XREX may be reliant on; 8. any changes to the operation of the underlying protocols of a blockchain or other circumstances that XREX has no control over, which may result in one or more blockchains emanating from the original blockchain (as applicable); 9. any distributions made by third parties of new DPTs to eligible persons (including distributions whereby the new DPTs are intended to replace existing DPTs) (as applicable); 10. any information, data, software, products, services and related graphics obtained through the Site or the Services thereon; 11. any reliance on any statement, opinion, representation or information on the Site or the Services thereon; or 12. otherwise arising out of the use of the Site or the Services thereon, whether based on contract, tort, strict liability or otherwise, except where such Losses arise from fraud by XREX. 2. You shall irrevocably and unconditionally defend, indemnify, and hold harmless the Indemnified Parties from and against any and all Losses arising out of or relating to: (a) your use of, or conduct in connection with, the Services, whether or not such access or use was authorised or whether it was due to any act or omission on its part; (b) any Feedback or User Content you provide; (c) your violation of these Terms including any representation, warranty, agreement or undertaking by you under this Agreement or our enforcement of this Agreement; (d) your violation of any Applicable Laws or the rights of any other person or entity; and/or (e) any sum or obligation expressed to be payable or liable to be performed under this Agreement not being paid or performed by you by the time, on the date and otherwise in the manner specified in this Agreement. 3. If you are obligated to indemnify any Indemnified Party, XREX (or, at our discretion, the applicable Indemnified Party) will have the right, in its sole discretion, to assume control of any action or proceeding and to determine whether to settle such matter and on the terms of such settlement. 4. **Limitation of Liability.** In the event that XREX is liable to you for damages, you agree that XREX’s aggregate liability to you for any and all Losses shall not exceed the total amount of fees and charges paid by you to XREX in the 12-month period immediately preceding the time such liability arose. # 10. Governing Law and Dispute Resolution PLEASE READ THIS SECTION CAREFULLY. 1. **Governing Law.** Any dispute arising from this Agreement will be governed by and construed in accordance with the laws of Singapore, without regard to any conflict of laws principles that would result in the application of the laws of another jurisdiction. Regardless of whether a Dispute (as defined below) is heard in arbitration or in court, you and XREX agree not to initiate or participate in any class action, class arbitration or representative action or proceeding against the other party. 2. **Dispute Resolution.** Subject to compliance with Paragraph 10.3 below, you agree that all disputes, controversies or differences arising out of or in connection with the Agreement, including any question regarding its existence, validity or termination (“**Dispute**”), shall be referred to and finally resolved by arbitration conducted in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (the “**SIAC**”) (“**SIAC Rules**”), which rules are deemed to be incorporated by reference to this Paragraph 10.2. The seat of the arbitration shall be Singapore. The language of the arbitration shall be English. The tribunal shall consist of one arbitrator, to be appointed by the President of the SIAC. PLEASE NOTE THAT ARBITRATION PREVENTS YOU FROM SUING IN COURT OR FROM HAVING A JURY TRIAL. Notwithstanding Paragraph 10.3.a, you and XREX agree to notify each other in writing (including via electronic Communication) of any Dispute within thirty (30) days from the date the Dispute arises. 3. Procedures Prior to Arbitration: 1. If you have any Dispute with XREX regarding the Services, you agree to file a Formal Complaint before pursuing any other legal actions. This allows us to attempt resolution of the Dispute effectively and efficiently. A Formal Complaint must be submitted via email to as soon as possible with the subject line “**Formal Complaint Process**” and must include: 1. Your full contact information; 2. A detailed description of the issue or Dispute (including relevant dates, times, and parties involved); 3. Supporting documentation; 4. The impact of the issue or Dispute on you; 5. The resolution you are seeking; 6. All prior communications with XREX personnel; and 7. A confirmation that the information provided is accurate and all material information have been provided. 2. Failure to submit a Formal Complaint within thirty (30) days of the Dispute or to provide complete information prior to initiating legal actions or seeking equitable relief may result in XREX requesting the arbitrator or court to issue an injunction, stay proceedings or dismiss the claim until the Formal Complaint Process is completed. 3. If any such Dispute is not settled amicably within ninety (90) days from the date of your Formal Complaint, the Parties agree to refer the matter to arbitration in accordance with Paragraph 10.2 above. In the event of any conflict between the SIAC Rules and these Terms, these Terms shall prevail. # 11. General Provisions 1. **Inconsistency.** Please take the time to read and understand these Terms before using the Services so that you are aware of your legal rights and obligations. In the event of any inconsistency between these Terms and any Annex, the relevant Annex shall prevail. 2. **No Other Relationship or Advice.** XREX is not your broker, intermediary, agent, trustee or advisor and has no fiduciary relationship or obligation to you. XREX also does not provide any advice or participate in any aspect of the user’s investment on the XREX platform. Your decision to invest in any DPT shall solely be yours and you are solely responsible for determining whether any transaction is appropriate for you based on your personal objective, financial circumstances and risk tolerance. You should consult your legal, financial or tax professional regarding your specific situation. 3. **Compliance with Applicable Laws.** You must comply with all Applicable Laws and third-party rights (including, without limitation, data privacy laws and AML/CFT laws) in your use of the Services and the Site. You should seek professional advice if in doubt to ensure compliance with all Applicable Laws. 4. **Amendment**\ XREX may, in its sole and absolute discretion, supplement, vary or amend the Terms from time to time immediately upon written notification to the user. XREX will provide written notification of the modification of these Terms either by sending you an email, by updating the “**Last Updated**” presented at the top of these Terms or by a pop-up window on XREX’s platform. By either (1) clicking the button or a check box presented with the modified Terms to record your consent; or (2) providing your written consent via email to [support@xrex.sg](about:blank), indicating your acceptance of the modified Terms, you agree to be bound by the updated or modified Terms. It is your responsibility to review the Terms regularly upon each access or use to ensure that you are aware of any changes made by XREX. If you do not agree to any modification of the Terms, you must immediately cease using the Services. You are responsible for periodically reviewing the Terms. Your continued access or use of the Site and/or Services after such changes are posted, regardless of whether you have reviewed them, constitutes your acceptance of the modified Terms and your agreement that the revised Terms apply to all current and prior use of the Site. Any questions related to these Terms can be directed to our support team via [support@xrex.sg](about:blank). 5. **Hardware and Software Requirements**\ It is your responsibility to ensure that you have and will maintain the requisite hardware and software, including cybersecurity software and stable and secured internet, to access the Services and communicate with XREX. 6. **Security Interests.** You represent and undertake not to create any security over your Funds held in your Accounts without our prior written consent. 7. **Unclaimed Balances.** If we are unable to contact you after making reasonable attempts or your Account is inactive, suspended and/or terminated, and there are balances in the XREX Account that we are not prohibited from transferring to you under Applicable Laws (“**Unclaimed Balances**”), you expressly acknowledge and agree that we may charge an inactivity or other administrative fee to you, which may be deducted from your Unclaimed Balances, and that we may concert any Unclaimed Balances into any other fiat currency and/or DPTs as we deem appropriate, at such time and rate as we deem appropriate in our sole and absolute discretion. It is your responsibility to contact us to arrange for the transfer of your Unclaimed Balances to you and you must provide us with a bank account or e-wallet address that meets our requirements for you to receive the Unclaimed Balances. Notwithstanding that your Unclaimed Balances may be in one or more fiat currencies and/or DPTs, we shall have no obligation to process a return of all Unclaimed Balances in the same asset and we may require you to convert all Unclaimed Balances into a single fiat currency and/or DPT before returning the Unclaimed Balances to you. 8. **Communications** 1. Should you have any issues, questions, feedback, or comments on the Services or these Terms, you can contact XREX through your designated relationship manager in writing, or send an email to [support@xrex.sg.](about:blank) 2. Consent to Electronic Delivery: You consent to receive electronically all Communications that we provide in connection with this Terms, your account, or any Services. 3. You may withdraw your consent to receive electronic Communications by sending a withdrawal notice to our Support Team by filing a support request at [support@xrex.sg,](about:blank) or informing your designated relationship manager in writing. If you decline or withdraw consent to receive electronic Communications, we may suspend or terminate your use of the Services. 4. Requesting Paper Copies 1. If you have consented to receive Communications electronically and wish to obtain a paper copy of any Communication previously provided to you, you may submit a request within 30 days from the date the Communication was made available, by contacting us at [support@xrex.sg](about:blank). 1. To receive paper copies of the Communications, you must maintain a current street address on file with us. Please note that our Services operate exclusively online, and the production of paper copies imposes a significant administrative burden. Accordingly, by requesting paper copies, you acknowledge and agree that we may charge a processing fee along with any applicable costs in fulfilling your request. 9. **XREX’s Affiliates and Contractors.** The Site and any Services may be operated or provided by XREX, its Affiliates, or their respective contractors. Where an Affiliate or contractor of XREX is operating or providing any Services, such Affiliate or contractor shall be subject to the same Terms to the extent applicable. 10. **Entire Agreement.** This Agreement sets forth the entire understanding between XREX and you with respect to the Services. 11. **Non-waiver.** XREXʼs failure, delay or forbearance in exercising any right, power, or privilege under these Terms shall not operate as a waiver thereof, nor will any single or partial exercise of any right under this Agreement preclude any other further exercise of it or any other right of remedy. 12. **Severability.** If at any time any provision of the Terms is or becomes illegal, invalid or unenforceable under the laws of any jurisdiction, that shall not affect: (a) the legality, validity or enforceability in that jurisdiction of any other provision of the Terms; or (b) the legality, validity or enforceability under the laws of any other jurisdiction of that or another provision of the Terms. 13. **Force Majeure.** XREX has no responsibility or liability for any failure or delays in the performance of any Services, or any Losses that you may incur, due to any Force Majeure Event. 14. **Assignment.** You may not assign or transfer any right to use the Services or any of your rights or obligations under these Terms without prior written consent from us. Where it is in the XREX’s interest to do so, XREX may, from time to time immediately upon written notification to you, assign or transfer to any third party (including, without limitation, to any of its Affiliates) any of the XREX’s rights and obligations under the Terms without your consent and you irrevocably consent to any such assignment or transfer by XREX. 15. **Third Party Contracts Act.** Unless expressly provided to the contrary in this Agreement, a person who is not a party to this Agreement (whether or not such person shall be named, referred to, or otherwise identified, or shall form part of a class of persons so named, referred to, or identified, in this Agreement) has no rights under the Contracts (Rights of Third Parties) Act 2001 of Singapore to enforce this Agreement or any of its terms. 16. **Separately Negotiated Arrangements** 1. From time to time, and subject to the Applicable Laws, XREX may at its sole discretion, enter into separately negotiated arrangements with certain users through confidential agreements that supplement specific economic or other terms of this Terms. Such arrangements shall apply to the relevant user’s relationship with XREX and their use of the Services. These arrangements may include, without limitation: (i) different incentives such as modified economic, funding, fee terms, or other payments; and (ii) access to additional or customized market information not generally available to other users. 2. Any such separately negotiated arrangements will be determined based on factors or considerations determined relevant by XREX in its sole discretion, and may be exclusive to that user. You acknowledge and agree that any separately negotiated arrangement with another user shall not affect the validity or enforceability of these Terms as between you and XREX. 17. **Third Party Websites** 1. The Site may contain information concerning third parties, third party products and services or links to third-party websites or applications. XREX does not monitor, control or endorse these third parties, their products, services, websites or applications. Any links to other websites are provided as a convenience to the user, and does not imply XREX’s endorsement of the linked website or association with their operators. 2. XREX makes no representation as to the quality, suitability, functionality, accuracy or legality of the materials on third party websites that are linked to, or to any goods and services available for such websites. 3. To the maximum extent permitted under the Applicable Laws, XREX is not responsible and disclaim all liability for (a) such third party products, services, websites or applications; (b) for any act or omission of these third parties, or (c) any dealings between you and these third parties, whether or not such dealings have been performed or facilitated through the Site, arising out of or in relation to anything done or omitted to be done in relation to these materials, or any delay, inaccuracies or omissions in the materials or any interruption to the supply of materials. 18. **Language.** XREX may, in its sole and absolute discretion, translate this Agreement into a language other than the English language. Where XREX has provided a translation of the English language version of these Terms (the “**English Version**”) for your convenience, the English Version governs the relationship between you and XREX. In the event of any conflict between the English Version and a translation thereof, the provisions in the English Version shall take precedence over any other translation. 19. **Headings.** Headings of sections are for convenience only and shall not be used to limit or construe such sections. # ANNEX 1 - STATEMENT ON CRYPTOCURRENCY LISTING AND GOVERNANCE POLICIES This Statement on Cryptocurrency Listing and Governance Policies (this “**Statement**") is made available to provide greater clarity and transparency regarding the policies and procedures that are established by us to evaluate the cryptocurrencies that are supported by us. You should evaluate this Statement to make an informed assessment as to such policies and procedures before engaging in any of the digital payment token services that we provide. Unless otherwise defined in this Statement, all capitalised terms used in this Statement shall have the meanings ascribed to them in the XREX General Terms and Conditions. 1. **EVALUATING PROSPECTIVE CRYPTOCURRENCIES** (1) **Cryptocurrencies Listing Committee.** To evaluate prospective cryptocurrencies that we intend to support, we have established a committee comprising certain members of senior management (“**Committee**”), which would oversee the process of evaluating such cryptocurrencies. This is conducted through a rigorous review process that evaluates assets against legal, compliance, risk, and technical security standards. (2) **Cryptocurrencies Listing Assessment.** We have established a cryptocurrency listing assessment (“**Listing Assessment**”) to evaluate a cryptocurrency’s suitability for inclusion on our platform. The Committee is responsible for administering the cryptocurrency assessment framework in accordance with our policies and procedures. This Listing Assessment covers various criteria (such as an evaluation of commercial, governance, technical, and legal criteria), including but not limited to: (a) the founding team and developers of the cryptocurrency; (b) the governance model and token allocation plan (if any) of the cryptocurrency; (c) the supported token protocol for the cryptocurrency; (d) the business use case of the cryptocurrency; (e) the track record, history and reputation of the cryptocurrency; (f) the legal characterisation of the cryptocurrency; (g) the cybersecurity certifications and measures implemented in connection with the cryptocurrency; (h) assessment of the cryptocurrency's features that could heighten money laundering or terrorism financing risks; (i) the supported blockchains and any monitoring or screening of the cryptocurrency; (j) the market capitalisation of the cryptocurrency; and (k) the liquidity and volatility of the cryptocurrency. 2. **ONGOING MONITORING** (1) We monitor the cryptocurrencies on our platform on an ongoing basis to ensure they continue to comply with our listing standards. When a cryptocurrency no longer complies with the standards, we may conduct a review and suspend trading, delist or cease support on the cryptocurrency. (2) The following factors may be taken into consideration in our review: (a) Cryptocurrency no longer meets our legal, compliance and technical security standards; (b) Responsiveness of the developers to our ongoing due diligence question and request for information; (c) No visible product development or commitment from the project team; (d) Trading volume and liquidity on the markets on the platform; (e) Significant events such as security breach or compromise of DPT’s network; and (f) Sanction and adverse media, including money laundering or terrorism financing risks, on the founders or issuer or parties associated with the cryptocurrency. (3) The decision to suspend or delist will be made by the Committee. We will provide customers with timely and clear communication regarding the suspension or delisting process and the implications for their holdings. **Processes for Suspending, Delisting, and/or Ceasing to Support a Cryptocurrency.** (4) If we decide to cease support for a cryptocurrency, we will take the following steps where appropriate: (a) notifying you and the regulatory authority of the decision and, if appropriate, the reasons for doing so; (b) notifying you of the date and time by which we intend to cease support; (c) notifying you of your rights and options in relation to the cryptocurrency before support is ceased; and/or (d) notifying you of the consequences if you do not take any action in relation to the cryptocurrency (including unilaterally selling and/or converting your cryptocurrency) before support is ceased. (5) Generally, we endeavour to use commercially reasonable efforts to provide you with prior written notice of any decision to cease support for a cryptocurrency. If we provide you with such prior written notice, you may sell, convert, and/or (if supported by us) transfer the cryptocurrency before support is ceased. However, if you do not take any action by the specified time notified to you, we may unilaterally sell and/or convert the cryptocurrency in your account. In addition, you should also be aware that you may not always be given each of the rights to sell, convert, and/or transfer the cryptocurrency, especially cryptocurrency transfers are not supported by us for the cryptocurrency. (6) You should also be aware that it may not always be practicable to provide you with prior written notice of ceasing support for any cryptocurrency (for example, in the case of a significant market dislocation and/or absence of liquidity over a short period), although we endeavour to use commercially reasonable efforts to notify you as soon as practicable. In such circumstances where we cease support of any cryptocurrency without giving you prior written notice, we may unilaterally sell and/or convert the cryptocurrencies at the time we cease support for such cryptocurrency and we shall not be liable for any Losses that you may suffer in respect of such sale and/or conversion. 3. **CONFLICT OF INTERESTS IN SUPPORTING CERTAIN CRYPTOCURRENCIES** (1) Potential or actual conflicts of interests may arise under certain circumstances when we are assessing whether to support any cryptocurrency. We are committed to mitigating such risks by implementing appropriate and effective policies and procedures, which should include but is not limited to: (a) a segregation of compliance and commercial functions to provide a degree of independence in the Listing Assessment; and (b) regarding supporting any cryptocurrency whereby (i) we are given any incentive to do so by the issuer and/or any other person and/or (ii) the issuer is a related or affiliated company of us, to declare such conflicts of interest to the Committee for consideration and thereafter implement appropriate steps to mitigate such risks including disclosure to customers on a case-by-case basis. For more information, please refer to our Terms for further information. 4. **ADDITIONAL DISCLAIMERS** (1) **No Guarantees Regarding Cryptocurrencies Listed on the Site.** You acknowledge and agree that: (a) our decision to support any cryptocurrency on our platform does not indicate our approval or disapproval of the cryptocurrency or the integrity, security or operation of the cryptocurrency or its underlying technology, and the risks associated with cryptocurrencies and trading of cryptocurrencies still apply notwithstanding our decision to support a particular cryptocurrency on our platform; (b) we may be reliant on public information and representations made by third parties that are not controlled by us, and we are unable to warrant or guarantee that such information are accurate, complete, updated, not misleading, and/or authentic; (c) our opinions on the legal characterisation of any cryptocurrency is confined under the financial services law and regulations in Singapore and such cryptocurrencies may be characterised differently under the laws of any other jurisdiction; and (d) under no circumstances shall any of the Indemnified Parties be responsible or liable to you or any other person or entity for any Losses by reason of, or arising from, or as a consequence of any reliance by us on such third party information in our evaluation of cryptocurrencies. (2) **No Guarantees of Full Support for All Cryptocurrency Services.** If we decide to support a cryptocurrency, you acknowledge and agree that we may not support all cryptocurrency services for such cryptocurrency. For example: (a) we may support only trading of a cryptocurrency and not deposits/withdrawals of the cryptocurrencies on any blockchain network; and (b) we may support only limited deposits/withdrawals of a cryptocurrency on a specific blockchain network, and not all blockchain networks that the cryptocurrency may be supported. It is your sole responsibility to review the extent to which any cryptocurrency is supported before using any of the Services. # XREX General Terms and Conditions\_Oct 2024 ### General Terms and Conditions The General Terms and Conditions and any terms expressly incorporated herein (“**Terms**”) apply to any access to or use of the services offered by XREX Pte. Ltd. and its Affiliates (collectively referred to as “**XREX**” or “**we**”). These Terms apply when you use any of XREX's websites (“**Site**”), the XREX application (“**XREX Pay**”), any application programming interface (“**API**”) provided by XREX that relates to the Site, and any other related services provided by XREX, including but not limited to crypto-fiat conversion and BitCheck (collectively referred to as “**XREX Service**” or the “**Services**” as further defined in the following sections). These Terms are a legal contract between you and XREX Pte. Ltd. so it is important that you review them carefully before using the Services. By clicking on the “I agree” button or check-box presented with these Terms or by continuously accessing any of the Services that manifest your consent, you agree to be bound by these Terms. These Terms, the hyper-linked documents herein and all Annexes comprise the agreement (the “**Agreement**”) between you and XREX Pte. Ltd. This Agreement contains the entire agreement and supersedes all prior and contemporaneous understandings between you and XREX Pte. Ltd. regarding the Services. In the event of any conflict between this Agreement and any other agreement you may have with XREX Pte. Ltd., this Agreement will prevail unless the other agreement specifically identifies this Agreement and declares that the other agreement supersedes this Agreement. Save for the Indemnified Parties, no provision of this Agreement is enforceable by virtue of the Contracts (Rights of Third Parties) Act 2001 by any person who is not a Party to this Agreement. # 1. Services and Account #### 1.1. Definitions “**Affiliates**”: with respect to a person, a person that controls, is controlled by or under common control with such person; and “**control**” means the right to exercise, directly or indirectly, more than 50% of the voting securities of such person or the power to direct the management or policies of such person (and the terms “**controlled by**” and “**under common control with**” shall be construed accordingly). “**Annex**”: annexures to these Terms, which may be in the form of hyperlinked documents, setting out provisions applicable for the relevant jurisdictions in which XREX provides its Services, XREX’s product and fee schedules. “**Applicable Law**”: any applicable constitution, treaty, statute, rule, regulation, ordinance, order, directive, code, judgment, decree, injunction, or any interpretation, determination, award, permit, license, authorization, directive requirement, ruling or decision of, or agreement with, or by, a government authority, including Singapore Sanctions Laws. “**Business Day**”: a day other than a Saturday, Sunday or public holiday in Singapore. “**AML/CFT**”: anti-money laundering / combating the financing of terrorism. “**Communications**”: includes announcements, agreements, disclosures, documents, mail (electronic) messages, notices and receipts. “**Conversion**” and “**convert**”: an exchange between one type of Token to another type of Token, or between Token and Fiat Money. “**Cryptocurrencies**” and “**Digital Payment Tokens (DPTs)**”: only blockchain-based fungible coins or tokens supported by XREX Pay and available on the Site. "DPTs" are used interchangeably with "Cryptocurrencies" under these Terms. “**Fee Schedule**”: the schedule of fees for our Services as outlined in [XREX Pay Help Center](https://intercom.help/xrex-sg/en/). “**Fiat Money**”: government-issued currency. “**Feedback**”: this term is defined in [4. Proprietary Rights](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/4.-proprietary-rights) relating to our proprietary rights. “**Formal Complaint**” and “**Formal Complaint Process**”: these terms are defined in [9. Governing Law and Dispute Resolution](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/9.-governing-law-and-dispute-resolution) relating to the resolution of any disputes with XREX. “**Funds**”: the deposit of Tokens and/or Fiat Money from an e-wallet and/or bank account under the user’s name (and only their name) into his/her XREX Wallet and the Safeguarding Account (as the case may be) on the Site. “**Indemnified Parties**”: XREX Pte. Ltd. and its Affiliates and their respective shareholders, directors, officers, employees, attorneys, agents, representatives, suppliers, and contractors. “**KYC**”: know your customer. “**Parties**”: you and XREX Pte. Ltd. “**Relevant Money**”: any money that is received by XREX from, or on account of, you in respect of the provision of our payment services and which we continue to hold at the end of each Business Day, but does not include the following (1) any money paid to us to reduce the amount owed to us by you, (2) any money that is repaid by us to you, (3) any money which is paid to us, or which we have informed you, will be used to defray any fee or charge imposed by us for providing our payment services to you, (4) any money that is paid to a recipient in accordance with your instructions to us, (5) any money that is paid to any other person that is entitled to the money. “**Safeguarding Account**”: designated trust bank account that XREX maintains with a bank in Singapore in accordance with Applicable Laws. “**Services**”: all the features, functions, and services provided by XREX on the Site, XREX Pay and any APIs. “**SIAC**” and “**SIAC Rules**”: these terms refer to the Singapore International Arbitration Centre and the rules which it publishes to regulate arbitration proceedings, respectively, and apply to the resolution of any disputes with XREX, as set out in [9. Governing Law and Dispute Resolution](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/9.-governing-law-and-dispute-resolution)*.* “**Singapore Sanctions Laws**”: the Terrorism (Suppression of Financing) Act 2002 and the respective regulations promulgated under the Monetary Authority of Singapore Act 1970, as amended, supplemented or replaced from time to time. “**Third-Party Content**”: this term is defined in [4. Proprietary Rights](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/4.-proprietary-rights) relating to our proprietary rights. “**User Content**”: this term is defined in [4. Proprietary Rights](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/4.-proprietary-rights) relating to our proprietary rights. “**XREX Account**”: any user account provided by XREX for the purpose of using the Services, including but not limited to the XREX Wallet, Individual Accounts, Corporate Accounts, and Advanced Accounts (all as set out in section [1.4](#id-1.4.-xrex-account) herein). “**XREX Wallet**”: the e-wallet address that XREX provides to you as part of the Services. #### 1.2. Eligibility for XREX Account application: 1.2.1. Any applicants located in, or of citizenship of, any countries or regions listed on this [page](https://intercom.help/xrex-sg/en/articles/9232927-what-countries-are-on-the-prohibited-list-and-who-is-affected-by-these-restrictions) will be denied for AML/CFT or other regulatory purposes. This list of the restricted and prohibited jurisdictions will be updated and revised from time to time at the sole discretion of XREX. If you change your residence or nationality, or both, to any jurisdiction on the [list](https://intercom.help/xrex-sg/en/articles/9232927-what-countries-are-on-the-prohibited-list-and-who-is-affected-by-these-restrictions), you must notify XREX immediately and cease your use of our Services unless you receive written permission from XREX. 1.2.2. In order to use the Services, you must be at least 18 years of age, and you must have the authority to enter into and execute an agreement to these Terms. In order to leverage any part of the Services, you are required to provide personal information. You hereby warrant that any information provided by you is accurate, complete, and current and you accept that any inaccuracies may lead to XREX, in its sole discretion, ceasing its Services, freezing your XREX Account, assets, and access at any time and without prior notification. 1.2.3. You are not a designated individual or entity as defined or set out in the Singapore Sanctions Laws. #### 1.3. Relationship of the Parties: 1.3.1. XREX is an independent contractor for all purposes. Nothing in this Agreement is intended to or shall operate to create a partnership, joint venture, or employment relationship between you and XREX, or authorize you to act as agent of XREX. #### 1.4. XREX Account: 1.4.1. In order to access some of the Services, you must complete our identity verification questionnaire and provide accurate and truthful details and documentation as required by our policies and procedures. You agree that XREX may share the relevant data with certain third parties contracted by XREX to perform verification of the data and documentation provided by you and to ascertain your status as required by the Applicable Laws of the jurisdiction(s). 1.4.2. Individual Account: Each individual shall apply and control only one single account. Any requests for additional accounts will not be granted. Using a nominee account may result in the termination of your account. 1.4.3. XREX may, at our discretion and without liability to you, with or without prior notice and at any time, temporarily suspend or permanently terminate your access to all or a portion of any Services. 1.4.4. Corporate Account: Individuals with the intent to use the Services on behalf of an enterprise or legal entity must request a Corporate Account when such accounts are made available on our platform. If you use the Services on behalf of an enterprise or legal entity without registering for a Corporate Account, you do so at your own risk and you agree and accept that your XREX Account may be restricted, access to your XREX Account may be prevented, and access to your Funds may be withheld pending a full investigation of your background and the enterprise or legal entity on whose behalf you are accessing the Services. You also agree that your details and the results of such an investigation will be shared with the relevant regulatory authorities. 1.4.5. Advanced Account: At its sole discretion, XREX may grant additional benefits, rewards, or features for qualified users (either incorporated with their Individual Account or Corporate Account) as Advanced Account holders (such as premium accounts). Notwithstanding the foregoing, Advanced Account holders are still users under these Terms, not contractors, representatives, or agents of XREX, and you shall contact XREX directly to confirm the information regarding any benefits or rewards when using the Services for an Advanced Account. 1.4.6. Access to your Account: You must not sell or otherwise make your Account accessible to any unauthorised person. You are fully responsible for maintaining the security and confidentiality of your username, password and any other access credentials to use and/or access your Account, and all activities that occur in connection with your Account. #### 1.5. Responsibility for Actions 1.5.1. Authorized Actions: Any instruction or Communication sent from or is otherwise referable to your Account (e.g., an email sent from the email address that you have registered with us in setting up your Account), or any of your contact information, shall be deemed to be authorised and is binding on you. XREX is not obliged to verify the identity or authority of any persons using your Account and we shall be entitled to accept and place full reliance on any instruction or Communication sent from or is otherwise referable to your Account. 1.5.2. Unauthorized Actions: 1.5.2.1. Any unauthorised use of your Account will constitute a breach of this Agreement and in case of such breach, XREX has the right, without prejudice to any of our rights or remedies under Applicable Laws, to terminate, suspend or restrict your access to your Account, terminate the provision of all or part of the Services to you, as well as take any other action as we deem fit, whether for a specified period of time or indefinitely. 1.5.2.2. If you notice any unauthorised or suspicious log in or activity in your Account or in the event of any breach of security, loss, theft or unauthorised use of your username, password, security information or any other access credentials to access or use our Services, you must notify us immediately via the Customer Service portal at our Intercom chat and provide us with a police report and any other information and documents as we may require. You shall also immediately take steps to restrict access to your Account, which can be done via the Services or other means. 1.5.3. No Liability: You acknowledge and agree that none of the Indemnified Parties shall not be liable to you or any other person or entity for any direct, indirect, special or consequential losses (including loss of profits, business or opportunities), damages or costs by reason of, or arising from, or as a consequence of, your Account being used by a third-party, whether authorised or unauthorised by you. #### 1.6. Account Funding 1.6.1. Deposits: 1.6.1.1. Only users who have passed the KYC checks (including identity verification) can deposit Cryptocurrencies and Fiat Money from their e-wallet and/or bank account under their name (and their name only) into its XREX Wallet and its/their Safeguarding Account. You can view your balance of Tokens and Fiat Money from your XREX Account. If you send Cryptocurrencies to the incorrect e-wallet address or if you send unsupported token types, these may be lost forever, and XREX will not accept responsibility for such lost Funds or digital assets. Any funds you send to the XREX Wallet addresses or Safeguarding Account will not receive any interest unless specifically stated otherwise on the Site or the XREX Pay. 1.6.1.2. Deposit amounts may be subject to limits depending on the level to which you have verified your identity and/or provided additional information requested by us. 1.6.2. Withdrawal 1.6.2.1. Only users who have passed the KYC checks can withdraw Fiat Money and Tokens from XREX. You will be required to maintain enough Funds in your XREX Wallet or Safeguarding Account to cover any pending transactions and fees to be incurred. Any Funds in excess of those committed to your transactions may be withdrawn to an external e-wallet, in the case of Tokens, or to an external bank account under your name (and your name only), in the case of Fiat Money. 1.6.2.2. XREX may require you to verify your ownership of any external wallets or bank accounts prior to approving your withdrawal requests. Please note that XREX is unable to reverse any withdrawal transactions and therefore accepts no responsibility for amounts sent to incorrect, improperly formatted, or erroneous addresses, or addresses of a different type of Token than the one stipulated in the withdrawal request. 1.6.2.3. XREX has the right to impose such conditions and limits to the amounts that you can transfer in or out of your XREX Wallet and Safeguarding Account at any time, depending on third-party requirements such as those of financial institutions, or in accordance with our internal policies. 1.6.2.4. You hereby authorize XREX to deduct from the Funds in your XREX Account the fees charged by XREX before XREX sends the amounts to any approved external wallet address and/or bank account specified by you when using the Service. 1.6.3. Other Account Funding Terms 1.6.3.1. You hereby accept to bear any fees charged by third parties when making transfers to external wallet addresses or bank accounts, in addition to the fees charged by XREX when executing transfers on your behalf. 1.6.3.2. You also accept responsibility for ensuring that any transfer request, whether inbound or outbound, complies with XREX’s requirements under these Terms, with the requirements of any third-party service providers or Token requirements for processing such a request. For Token transfers, you accept all responsibility for ensuring e-wallet addresses are properly formatted, correct, and suitable for the type of Token being transferred. 1.6.3.3. You further accept responsibility for ensuring that there are no errors in your transfer instructions when using the Services. You hereby agree and accept that if you do not comply with any of the above requirements, your Tokens may be permanently lost and you agree to hold XREX harmless and waive any and all claims against XREX under such circumstances. 1.6.3.4. The timing of completion of transactions is contingent on the availability of third-party networks and XREX provides no guarantees as to how long it takes for a transaction to be completed. 1.6.3.5. XREX may suspend or even terminate your ability to make transfers into or from either your XREX Wallet or Safeguarding Account or both, in order to comply with Applicable Laws or at XREXʼs own discretion if XREX has reasonable grounds to suspect any wrong-doing on your part. 1.6.4. Notice relating to your Safeguarding Account 1.6.4.1. Your Relevant Money will be held by XREX in the Safeguarding Account together with, and commingled with, the relevant monies that we receive from other customers. 1.6.4.2. The risks of the commingling of your Relevant Money with those of other customers include (1) in the event of any loss of records of transactions of the Safeguarding Account, it may be difficult to identify or earmark your Relevant Money from those of other customers and (2) in the event of any misappropriation of funds in the Safeguarding Account, you may suffer loss of your Relevant Money. 1.6.4.3. If the bank at which we maintain the Safeguarding Account becomes insolvent, you may not be able to recover any of your Relevant Money if the bank’s assets are insufficient to satisfy the claims of its creditors or it may take a long time for you to recover your Relevant Money as the process of liquidation and the distribution of proceeds could take a long time. #### 1.7. Prohibited Use and Activities 1.7.1. You will not violate any law, regulation, contract, intellectual property, or another third-party right, or commit a tort while using the Services; use the Services in any manner that could interfere with, disrupt, negatively affect, or inhibit other users from fully enjoying the Services, or that could damage, disable, overburden, or impair the functioning of the Services in any manner; engage in any type of market manipulation. Market manipulation activities include, but are not limited to, pump and dump schemes, wash trading, self-trading, front running, quote stuffing, and spoofing and layering, regardless of whether it is prohibited by law; use the Services to pay for, support, or otherwise engage in any illegal gambling activities, fraud, money-laundering, or terrorist activities, or other illegal activities; use any robot, spider, crawler, scraper, or other automated means or interface not provided by us to access the Services or to extract data; use or attempt to use another userʼs account without authorization; attempt to circumvent any content filtering techniques we employ, or attempt to access any service or area of the Services that you are not authorized to access, or attempt to access the Services from any location or jurisdiction in which you are prohibited from accessing the Services; introduce to the Services any malware, virus, trojan worms, logic bombs, or other harmful material; develop any third-party applications that interact with our Services without our prior written consent, or unless otherwise agreed; provide false, discriminatory, bigoted, abusive, inflammatory, fraudulent, deceptive or otherwise objectionable; post content containing unsolicited promotions, political campaigning, or commercial messages (SPAM) or any chain messages or user content designed to deceive or trick the user of the Service; post content containing private information of any third-party including, but not limited to, addresses, phone numbers, email addresses, Social Security numbers, and credit card numbers; promote, offer, use or otherwise exploit the Services or use or otherwise exploit any data related thereto in connection with the formation, operation or offering of any index fund or similar product or any data package or similar product or any other derivative product utilizing the Site or the Services; or encourage or induce any third-party to engage in any of the activities prohibited under this Section. 1.7.2. Copyright Violations: XREX has a policy of limiting access to our Services and terminating the accounts of users who infringe our or others’ intellectual property rights. If you believe that anything on the Services infringes any copyright that you own or control, you may notify us via email at . In addition, please note that if you knowingly misrepresent that any activity or material on our Services is infringing, we shall hold you liable for all of our costs and damages caused by your misrepresentation. 1.7.3. Remedies: If you violate any of these Terms, XREX may, as it determines reasonably necessary to remedy or mitigate your violation, delete all or part of such information transmitted by you, suspend or cancel your account, or confiscate Tokens owned by you without any prior notice to you. XREX shall in no event be responsible or liable for any damage incurred by the user as a result of an action taken by us pursuant to this paragraph. Any right or remedy of XREX set forth in these Terms is in addition to, and not in lieu of, any other right or remedy whether described in these Terms, under the statute, at law, or in equity. #### 1.8. Termination 1.8.1. In the event of discontinuation of any or all Services or other termination of your right to access all Services: (a) all amounts payable by you to us will immediately become due; (b) we may delete or deactivate your XREX Account and all related information and files in such account without liability to you; (c) we may cancel any transaction requests that are pending at the time of discontinuation or termination. 1.8.2. In the event of discontinuation or termination of any or all Services or discontinuation or termination of transfer or storage Services for all or some Tokens, we will, unless prohibited under Applicable Laws give you a reasonable period to remove the affected Tokens and any Fiat Money from your XREX Account. #### 1.9. Unclaimed Property 1.9.1. If your XREX Account has been inactive for a continuous period of 12 months and you have not responded to reasonable attempts by XREX to contact you using the contact information you provided, XREX may have an obligation to report and/or turn over any Funds in your XREX Wallet or Safeguarding Account (after deducting fees payable to XREX) to the applicable government entity as unclaimed property. # 2. Data Protection and Security #### 2.1. Personal Data: 2.1.1. You acknowledge that we may process personal data in relation to you, and personal data that you have provided (or in the future provide) to us in relation to your employees and other associates, or other individuals, in connection with the Terms, or XREX Service. We will collect, use, disclose, and/or otherwise process this personal data in accordance with the Privacy Policy, which shall form part of the Terms. You represent and warrant that: 2.1.1.1. your disclosure to us of any personal data relating to individuals other than yourself has been duly authorised by such individuals, is made in accordance with all applicable data protection and data privacy laws, such data is complete, accurate, up-to-date and relevant at the time of disclosure. We shall be kept updated as to any changes in such authorisation and/or necessary changes to such data; 2.1.1.2. before providing any personal data to us or otherwise accessing or using the XREX Service, you acknowledge that you have read and agreed to our Privacy Policy, a copy of which is available here: Privacy Policy, and, in the case of personal data relating to an individual other than yourself, have (or will at the time of disclosure have) provided the individual with a copy of, or directed the individual towards a webpage containing that Privacy Policy (as amended from time to time); and 2.1.1.3. if from time to time we provide you with a replacement version of the Privacy Policy, you will promptly read that updated Privacy Policy and provide a copy of the same to, or re-direct towards a webpage containing the updated Privacy Policy, any individual whose personal data you have provided to us. #### 2.2. Security: 2.2.1. While XREX maintains a high standard of cyber hygiene practice and implements advanced security controls, you are required to ensure the security of your account by protecting and maintaining the confidentiality of your account data, passwords, crypto-asset wallet addresses, and other relevant data. You also agree to follow the security practices and rules presented by XREX in order to maintain the security of your account and your personal data. 2.2.2. Authentication and Verification: In order to initiate the KYC (defined below) process to access the Services as required by XREX, you are to provide an email address and create a password. XREX offers two-factor authentication via a supported Time-based One Time Password application. You are responsible for keeping electronic devices through which the Services are accessed safe and maintaining adequate security, confidentiality and control of any and all security details that are used to access the Services. This includes taking all reasonable steps to avoid the loss, theft or misuse of said electronic devices and ensuring that said electronic devices are password-protected. Any loss or compromise of personal electronic devices or security details may result in unauthorized access of your account by third parties, the loss or theft of Tokens and/or funds held in your account and/or the misuse of any associated accounts, including linked bank account(s). You hereby accept all responsibility for any loss or damage arising from the above scenarios. We shall, to the fullest extent permitted under the Applicable Law, in no event be liable to you or any third party for any loss or damage arising out of or in connection with such loss or damage. 2.2.3. Any loss or compromise of your electronic device or your security details may result in unauthorized access to your account by third parties and the loss or theft of any Token or asset held in your account and any associated accounts, including your linked bank account(s) and credit card(s). You must keep your security details safe at all times. For example, you should not write them down or otherwise make them visible to others. We reserve the right to suspend or terminate your XREX account at any time where the security of your account is suspected by us to have been compromised, or where we suspect that your account has been operated in breach of these Terms. 2.2.4. Safety and Security of Your Computer and Devices: XREX is not liable for any damage or interruptions caused by any computer viruses or other malicious code that may affect your computer or other equipment, or any phishing, spoofing or other attacks. We advise the regular use of reputable and readily available virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from XREX. # 3. Services and Fees #### 3.1. General 3.1.1. XREX may, in accordance with [General Provisions 10.5.](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/10.-general-provisions), modify or discontinue, temporarily or permanently, all or any portion of any Services. You acknowledge and accept that (1) if and when Services resume, Token valuations and conversion rates may differ significantly from the valuations and rates prior to such an event and (2) XREX will not be liable for any losses suffered by you resulting from any modification of any Services or from any suspension or termination of your access to all or a portion of any Services or for any other reason. 3.1.2. No Broker or Fiduciary Relationship: XREX is not your broker, intermediary, agent, or advisor and has no fiduciary relationship or obligation to you in providing the Services nor in connection with transactions or other decisions or activities effected by you. As such, no information provided to you by XREX is intended or should be considered as advice. Please refer to [5. Risk Warning and Disclosures](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/5.-risk-warning-and-disclosures-limitation-of-liability-and-no-warranties) when choosing whether or not to use the Services. 3.1.3. XREX reserves the right to correct, reverse, or cancel any of your Service requests or attempt to do so where we have discovered an error, whether such error was by the Services, by you, or by a third party. You hereby authorize us to make or attempt any such correction, reversal or cancellation described. XREX provides no warranty or guarantees that any such attempt will be successful and bears no responsibility or liability for any such error or correction attempt. 3.1.4. Due to the nature and characteristics of our Services, you understand and consent that it is a reasonable matter that all transactions are final and irrevocable upon execution, subject to our right as set out in clause 3.1.3 above. Our service is provided to you contingent upon your understanding and consent to such a reasonable matter. #### 3.2. Conversion 3.2.1. When you opt for Conversion, you will have a time-sensitive price from the Site or the Mobile App. Once you accept the price before the price offer expires, such Conversion is final and cannot be revoked or canceled. 3.2.2. Insufficient Funds: In the event that your XREX Wallet or Safeguarding Account does not have sufficient Funds to execute the Conversion or transaction, XREX may cancel your request for the relevant Services, or only fulfill the part of the request for which you have sufficient Funds. 3.2.3. Token availability: XREX in its sole discretion determines which Tokens and the specific blockchain thereof will be made available for trading, transferring, and storing on the Services. Unless otherwise required by law enforcement or other regulatory bodies, XREX will make reasonable efforts to notify you of any changes to the supported Tokens. If you do not remove your unsupported Tokens or other assets to an external wallet address or account prior to the cessation of support on the Services, you may lose all or part of your Tokens or other assets. In such cases, XREX will not be liable for any losses, liabilities, costs, or expenses related to its decision to remove support for any Token or asset. #### 3.3. Fork and Airdrops: 3.3.1. You remain the lawful and beneficial owner of any assets and Tokens in your account and the beneficial owner of additional assets resulting from any applicable (i) network fork that is supported by XREX and (ii) airdrop or similar distribution of Tokens; provided, that XREX retains sole discretion and has no obligation to support any particular forks, airdrops or similar distribution and such support remain in all instances subject to the Terms. #### 3.4. Fees 3.4.1. You agree to pay XREX the fees described in the Fee schedule, as periodically updated by us at our discretion. The updated Fee Schedule will apply prospectively to the relevant Services that take place following the effective date of such updated Fee Schedule. You authorize us to deduct and/or debit Tokens or Fiat Money from your wallet or from the Conversion amount for any applicable fees payable by you under these Terms. 3.4.2. You agree and understand that your acceptance of these Terms includes your acceptance of our Fee Schedule. We reserve the right to change, modify, or increase our Fee Schedule, in accordance with [General Provisions 10.5.](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/10.-general-provisions) 3.4.3. The Fee Schedule can be found in the [XREX Pay Help Center](https://intercom.help/xrex-sg/en/). #### 3.5. Commission or Rebates: 3.5.1. XREX may grant Commission or Rebates from time to time to its users for promotional activities (such as a referral program). Specific rules for any commission or rebate apply, as set out at [XREX Pay Help Center](https://intercom.help/xrex-sg/en/) unless otherwise agreed between you and XREX in writing. # 4. Proprietary Rights #### 4.1. Ownership: 4.1.1. The Services, Site, and all technology, content, data, and other materials used, displayed or provided or received by you in connection with the Services or Site (“**XREX Materials**”) together with all intellectual property rights in any of the foregoing are, as between you and us, owned by XREX. #### 4.2. Limitation: 4.2.1. You may use the XREX Materials solely as authorized by us in connection with your use of the Services for as long as we permit you to continue to access the Services. Without limiting the foregoing, you will not: 4.2.1.1. resell, lease, lend, share, distribute, or otherwise permit any third party to use the Site, Services, or XREX Materials or use the Site, Services or XREX Materials in any service bureau environment; 4.2.1.2. modify or create derivative works of the Site, Services, or XREX Materials, or any portion thereof or any data or information received by you in connection therewith; 4.2.1.3. frame, display, or incorporate the Site, Services, or XREX Materials in any website or any other work of authorship; 4.2.1.4. decompile, disassemble, reverse engineer or attempt to discover the source code of the Site, Services, or XREX Materials; 4.2.1.5. use the Site, Services or XREX Materials to design, develop or create any competing product or service; or 4.2.1.6. otherwise use the Site, Services, or XREX Materials for any commercial or noncommercial purpose other than their intended purposes determined at our discretion. #### 4.3. Intellectual Property: 4.3.1. Any product or service names, logos, and other marks used on the Site or XREX Materials, or otherwise in connection with the Services, are intellectual property owned by XREX Inc. or its licensors. You may not copy, imitate, or use them without our prior written consent. #### 4.4. Feedback: 4.4.1. XREX will own any feedback, suggestions, ideas, or other information or materials regarding XREX or the Services that you provide, whether by email, posting through the Services, or otherwise (“**Feedback**”). You hereby assign to XREX Inc. all rights, title, and interest to Feedback together with all associated intellectual property rights. You will not be entitled to, and hereby waive any claim for, acknowledgement or compensation based on any Feedback or any modifications made based on any Feedback. #### 4.5. User Content: 4.5.1. You hereby grant to us a royalty-free, fully paid-up, sublicensable, transferable, perpetual, irrevocable, non-exclusive, worldwide license to use, copy, modify, create derivative works of, display, perform, publish and distribute, in any form, medium or manner, any text, information, data, materials, images, or other content you provide to us using the Services or submit or post to the Site and that is not Feedback owned by us (the “**User Content**”). You represent and warrant that: 4.5.1.1. you own the User Content or have the right to grant the rights and licenses in these Terms, and 4.5.1.2. the User Content and use by XREX of the User Content as licensed herein does not and will not violate, misappropriate or infringe on the rights of any third party. We may remove any User Content from the Site for any reason at our discretion. #### 4.6. Third-Party Content: 4.6.1. In using the Services, you may view content provided by third parties (“**Third-Party Content**”). XREX does not control, endorse, or adopt any Third-Party Content and shall have no responsibility for Third-Party Content, including without limitation material that may be misleading, incomplete, erroneous, offensive, indecent, or otherwise objectionable. In addition, your business dealings or correspondence with such third parties are solely between you and the third parties. XREX is not responsible or liable for any loss or damage of any sort incurred as the result of any such dealings, and you understand that your use of Third-Party Content, and your interactions with third parties, is at your own risk. # 5. Risk Warning and Disclosures, Limitation of Liability, and No Warranties You should read the following statements in detail before using any of the Services. #### 5.1. RISK WARNING ON DIGITAL PAYMENT TOKEN SERVICES: The Monetary Authority of Singapore (“**MAS**”) requires us, **XREX Pte. Ltd.**, to provide this risk warning to you as a customer of a digital payment token (“**DPT**”) service provider. **Before you:** (a) pay your DPT service provider any money or DPT; or (b) pay a third party any money or DPT under an arrangement by your DPT service provider, **you should be aware of the following:** 1\. XREX Pte. Ltd., being your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider or any other third party referred to above, if your DPT service provider’s or the third party’s business fails. 1A. You should be aware that MAS does not supervise or regulate your DPT service provider for the provision of unregulated services.\[1] This includes any service of trading digital payment token derivatives such as futures. 2\. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact if transferred or held by your DPT service provider. 3\. You should be aware that the value of DPT’s may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens. 4\. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”. #### 5.2. RISK DISCLOSURES: 5.2.1. INDUSTRY RISKS 5.2.1.1. The cryptocurrency industry represents a relatively new and rapidly changing industry, and its success is subject to a variety of factors that are difficult to evaluate. The slowing of the development or acceptance of cryptocurrencies may adversely affect the Cryptocurrencies. The growth of the Virtual Asset Service Providers (“**VASPs**”) is also subject to a high degree of uncertainty. The factors affecting the sustainability of the cryptocurrency industry include: (a) continued worldwide growth in the adoption and use of cryptocurrencies; (b) government regulation of cryptocurrencies and their use, or restrictions on or regulation of access to and operation of VASPs; (c) the maintenance and development of the open-source software protocol; (d) changes in consumer demographics and public tastes and preferences; (e) the availability and popularity of other forms or methods of buying and selling goods and services, including new means of using fiat currencies and cryptocurrencies; or (f) general economic conditions and the regulatory environment relating to cryptocurrencies. 5.2.1.2. A decline in the popularity or acceptance of cryptocurrencies may harm the market price of the Cryptocurrencies. There is no assurance that any VASPs (including XREX) necessary to accommodate the sale and transfer of the Cryptocurrencies will continue in existence or grow. Furthermore, there is no assurance that the availability of and access to VASPs will not be negatively affected by government regulation or supply and demand of cryptocurrencies and/or other digital assets. 5.2.2. MARKET RISKS 5.2.2.1. The prices of Cryptocurrencies have historically been subject to dramatic fluctuations and are highly volatile. Several factors may influence the market price of the Cryptocurrencies, including, but not limited to: (a) global Cryptocurrencies supply and demand, which can be influenced by the growth of merchants’ and commercial businesses’ acceptance of Cryptocurrencies as payment for goods and services, the security of cryptocurrency and digital asset exchanges and digital wallets, and the regulatory restrictions on the use and trading of Cryptocurrencies; (b) currency exchange rates, including the rates at which Cryptocurrencies may be exchanged for fiat currencies; (c) interruptions in service from or failures of major blockchain exchanges on which the Cryptocurrencies may be traded; (d) investment and trading activities of large purchasers, including private and registered funds, that may directly or indirectly invest in the Cryptocurrencies; (e) monetary policies of governments, trade restrictions, currency devaluations and revaluations; (f) regulatory measures, if any, that affect the use of digital assets such as the Cryptocurrencies; or (g) global or regional political, economic or financial events and situations. 5.2.3. LEGAL AND REGULATORY RISKS 5.2.3.1. *Government regulation and Applicable Laws.* Cryptocurrencies are a relatively new asset type and the continued popularity of and risks involving Cryptocurrencies has attracted and will continue to attract regulatory scrutiny. Regulation of Cryptocurrencies and VASPs is evolving and may severely impact the development and growth of this market and the secondary market for the Cryptocurrencies. The application and interpretation of existing laws and regulations are largely untested and there is a lack of certainty as to how they will be applied. New laws and regulations may be promulgated in the future that apply to blockchain technology and Cryptocurrencies, and related service providers, and no assurance can be given that any such changes will not adversely affect Cryptocurrencies generally (including the use, transfer, exchange and value of Cryptocurrencies) or the Services. 5.2.3.2. Changes in Applicable Laws may affect the price, liquidity and/or tradability of Cryptocurrencies, or the use of any Services. Cryptocurrencies may decrease in value or lose all of its value due to such changes. 5.2.3.3. XREX may have to suspend or limit the trading of certain Cryptocurrencies or the use of certain Services or disallow users to trade Cryptocurrencies or use any of the Services based on their citizenship, residence or location if doing so is commercially unsustainable or is prohibited by any Applicable Laws. Applicable Laws and changes thereto could materially and adversely affect the price, liquidity and/or tradability of Cryptocurrencies, or the use or availability of any Services. 5.2.3.4. **XREX has sole and absolute discretion to suspend or reject the execution of any of your instructions, suspend or cease support for any Cryptocurrencies, or suspend or terminate your access to any Accounts or Services, where any such action or inaction is, in XREX’s sole opinion, necessary to facilitate XREX's compliance with Applicable Laws.** 5.2.4. TECHNOLOGY AND RELATED RISKS 5.2.4.1. *Technology risks.* The Cryptocurrencies rely on various types of distributed ledger technology. Some of this technology is open-source software that is built upon experimental technology, namely blockchain. Risks arising from relying on such technology include the existence of technical flaws in the technology, targeting by malicious persons, changes in the consensus protocol or algorithms, decreased community or miner support, the existence or development of competing networks, platforms and assets, flaws in the scripting language, disputes between developers, miners and/or users and regulatory action. 5.2.4.2. **XREX reserves the right, in its sole discretion, to suspend or cease to support the transfer, storage or trading of any Cryptocurrencies in response to any technology changes. XREX may, but is not obligated to, make changes to your XREX Account in response to such changes. You may be unable to withdraw Cryptocurrencies if XREX ceases to support the transfer of any such Cryptocurrencies as a result of these technology changes, which may result in the total loss of any such Cryptocurrencies remaining in your Account. XREX will not be liable for any losses you may experience as a result.** 5.2.4.3. *Network and other risks*. The underlying protocols supporting the Services, and the smart contracts that underlie the Cryptocurrencies may be subject to certain risks that are beyond our control, and which may result in events, such as (a) loss of control or ownership of your Cryptocurrencies and (b) transaction records on the blockchain being altered, reversed or otherwise invalidated, whether by way of fraudulent acts or consensus. 5.2.4.4. *Transactions irreversible*. Transactions involving Cryptocurrencies on blockchain networks are generally irrevocable and irreversible*.* This means accidental or fraudulent transactions in respect of, or loss or theft of your Cryptocurrencies may not be reversible. XREX will not be liable for any losses that you may experience in such a scenario. 5.2.4.5. *Loss of private key(s) is permanent and irreversible.* A digital private key is required to access and trade your Cryptocurrencies. The loss or theft of your private keys will permanently and irreversibly deny you access to your Cryptocurrencies and hence, you may lose all value of your Cryptocurrencies. XREX will not be liable for any losses that you may experience in such a scenario. 5.2.5. CYBER-SECURITY, INTERNET AND RELATED RISKS 5.2.5.1. *Cyber-attacks and other criminal activities*. Cyber-attacks may take different forms, including (but is not limited to) distributed denial of service, malware, double-spending, majority-mining, consensus-based or other mining attacks, misinformation campaigns and spoofing, which may affect the features, functions, operation, use, access or other properties of the Services and your XREX Account(s). The Services and your Accounts may also be exploited for vulnerabilities in smart contracts and other code, as well as to human error. 5.2.5.2. *Cryptographic advancements*. Developments in cryptographic technologies and techniques, including (but not limited to) the advancement of artificial intelligence and/or quantum computing, pose security risks to all cryptography-based systems including the Services, the network infrastructure and your Cryptocurrencies. These ill-intended use of these advancements may result in theft, loss, disappearance, destruction, devaluation or other compromises of your XREX Account(s) and Funds. 5.2.5.3. *Reliance on the internet.* Transactions rely heavily on the internet and other technologies. However, the public nature of the internet means that either parts of the internet or the entire internet may be unreliable or unavailable at any given time. Further, interruption, delay, corruption or loss of data, the loss of confidentiality in the transmission of data, or the transmission of malware may occur when transmitting data via the internet and/or other technologies. 5.2.5.4. Any information (including any document) transmitted, or communication or transactions made, over the internet or through other electronic media (including electronic devices, services of third party telecommunication service providers such as mobile phones or other handheld trading devices or interactive voice response systems) may be subject to interruption, transmission blackout, delayed transmission due to data volume, internet traffic, market volatility or incorrect data transmission (including incorrect price quotation) or stoppage of price data feed due to the public nature of the internet or other electronic media. 5.2.5.5. **XREX makes no representation, warranty or undertaking of any kind, express or implied, statutory or otherwise, regarding any of its technology or blockchain functionalities. XREX does not guarantee the functionality or security of any Cryptocurrencies or their underlying technology. You acknowledge and accept the risk of any changes or breach of security to the Services, its underlying technology and to the Funds in your XREX Wallet and/or XREX Account(s).** 5.2.5.6. **You further acknowledge and accept that XREX does not control Internet signal power, its reception or routing, configuration of your equipment or its reliability, and that XREX shall not be responsible for any communication failures, disruptions, errors, distortions or delays you may experience when using the Services, however caused.** 5.2.5.7. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, YOU ACKNOWLEDGE THAT, BY ACCESSING AND USING THE SERVICES YOU ARE ENGAGING IN FUNDAMENTALLY RISKY TRANSACTIONS INVOLVING SOPHISTICATED INSTRUMENTS. CRYPTOCURRENCIES ARE HIGHLY VOLATILE INSTRUMENTS AND CAN RAPIDLY AND UNEXPECTEDLY DECREASE IN VALUE. TRANSACTING IN CRYPTOCURRENCIES ALSO REQUIRES A CERTAIN LEVEL OF TECHNICAL KNOWLEDGE AND UNDERSTANDING WITHOUT WHICH USERS MAY LOSE THE VALUE OF, OR ACCESS TO, SOME OR ALL OF THEIR CRYPTOCURRENCIES. BY ACCESSING THE SERVICES YOU AGREE THAT YOU ARE VOLUNTARILY ENGAGING IN INHERENTLY RISKY TRANSACTIONS AND THAT YOU ARE AWARE OF THE RISKS INVOLVED INCLUDING BUT NOT LIMITED TO, RISKS OF FINANCIAL LOSS, LOSS OF ACCESS TO CRYPTOCURRENCIES AND FIAT CURRENCIES DUE TO TECHNICAL ERRORS, SYSTEM DOWNTIME, SOFTWARE FLAWS AND CYBER-HACKS WHICH COMPROMISE THE SECURITY OF OUR SERVICES AND/OR YOUR OWN PERSONAL SYSTEMS. #### 5.3. LIMITATION OF LIABILITY: 5.3.1. IN NO EVENT WILL THE LIABILITY OF XREX, THEIR RESPECTIVE AFFILIATES, AND THEIR RESPECTIVE SHAREHOLDERS, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS, OR CONTRACTORS ARISING OUT OF OR IN CONNECTION WITH THE SITE, THE SERVICES, THE XREX MATERIALS, ANY PERFORMANCE OR NON-PERFORMANCE OF THE SERVICES, OR ANY OTHER PRODUCT, SERVICE OR OTHER ITEM PROVIDED BY OR ON BEHALF OF XREX, WHETHER UNDER CONTRACT, STATUTE, STRICT LIABILITY OR OTHER THEORY (INCLUDING, FOR AVOIDANCE OF DOUBT, ANY NEGLIGENCE OF XREX) EXCEED THE RELEVANT AMOUNT OF THE FEES PAID BY YOU TO XREX UNDER THIS AGREEMENT IN THE TWELVE-MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM FOR LIABILITY, OR THE PERIOD OF DURATION OF THIS AGREEMENT BETWEEN YOU AND XREX, WHICHEVER IS SHORTER. 5.3.2. This Limitation of Liability shall apply to the fullest extent permitted by law. The Limitation of Liability in this Section is subject to any obligations that we have under Applicable Laws, including our obligation to exercise reasonable care and skill in our provision of the Services. Nothing in this Agreement shall limit our liability resulting from our fraud or fraudulent misrepresentation, gross negligence, deliberate misconduct, nor for death or personal injury resulting from our negligence. #### 5.4. No Warranties: 5.4.1. All services and products are provided on an “**AS IS**” and “**AS AVAILABLE**” basis. To the fullest extent permitted by law, XREX disclaims any representations and warranties of any kind, whether express, implied, or statutory, including, but not limited to, the warranties of merchantability and fitness for any particular purpose. *** \[1] Please refer to Section 2.3.1 of the Guide to the Payment Services Act 2019 (which can be found on the MAS website) for the types of payment services which are regulated under the Payment Services Act. Services which do not fall within the list of services in Section 2.3.1 are unregulated services. # 6. Taxes 6.1. The tax treatment of Cryptocurrencies and transactions is uncertain, and it is your responsibility to determine what taxes, if any, arise from transactions using the Services under this Agreement. By using the Services, you are solely responsible for reporting and paying any applicable taxes arising from transactions, and acknowledge that XREX does not provide investment, legal, or tax advice governing these transactions. You understand that XREX may report information with respect to your transactions, payments, transfers, or distributions made by or to you with respect to your activities using the Services to a tax or governmental authority to the extent such reporting is required by Applicable Law. 6.2. XREX may withhold taxes applicable to your transactions or to payments or distributions made or deemed made to you to the extent such withholding is required by Applicable Law. From time to time, XREX shall ask you for tax documentation or certification of your taxpayer status as required by Applicable Law, and any failure by you to comply with this request in the time frame identified may result in withholding and/or remission of taxes to a tax authority as required by Applicable Law. You should conduct your own due diligence and consult your own tax advisors before making any decisions with respect to Cryptocurrencies transactions. # 7. AML/CFT and Know-Your-Customer (KYC) Policy 7.1. Know Your Customer (KYC) Policy: 7.1.1. XREX constantly verifies the individuals and organizations that use the Services. You agree to provide complete and accurate personal information (including your email, name, address, gender, phone number, nationality, date of birth, tax identification number or ID card number or passport number, a bank account in your name, and other registration and transaction information) to XREX and any third party appointed by us (including financial institutions and KYC service providers). These third parties may collect, process, or use this personal information within the specific purposes of their entrusted tasks (including to assisting XREX in verifying the authenticity of your bank account, compliance with laws, and adherence to AML/CFT requirements). Based on the results of these inquiries and reports, XREX and these third parties may take such measures as they deem fit. 7.2. AML/CFT Policy: 7.2.1. XREX constantly monitors transactions on the Site and any transactions via the Services, and XREX may suspend or block any transaction without prior notice to you if we have reasonable grounds to suspect that or you are a designated individual or entity as defined or set out in the Singapore Sanctions Laws, or that the transaction poses money-laundering, terrorism financing, or similar risks. In compliance with Applicable Laws, XREX will report to relevant authorities regarding any suspicious activities and transactions. 7.2.2. XREX will deny or suspend the Services to anyone refusing or unable to provide sufficient evidence of their identity and/or their source of funds, whose evidence XREX determined to be misleading, false, or otherwise unacceptable, or who is a designated individual or entity as defined or set out in the Singapore Sanctions Laws. 7.3. Disputes: 7.3.1. If XREX has reasonable grounds to suspect that you are a designated individual or entity as defined or set out in the Singapore Sanctions Laws, or that any DPTs in your XREX Wallet are stolen or otherwise are not lawfully possessed by you or which represent the proceeds of any illegal activity, we may, in our sole discretion, place an administrative hold on the affected DPTs until such time as the dispute has been resolved and evidence acceptable to XREX has been provided in a form acceptable to XREX. XREX will not involve itself in any such dispute nor in the resolution of such disputes. You agree that XREX has no liability or responsibility for any losses you may suffer arising from such hold, or from your inability to withdraw DPTs or Fiat Money or to execute transactions for the duration of any such hold. 7.4. It is your responsibility to keep your email address and mobile phone number on file with us up-to-date so that you can receive our electronic communications. If we send you an electronic communication but you do not receive it because your email address or mobile phone number on file is incorrect, out of date, blocked by your service provider, or you are otherwise unable to receive electronic communications, we will nevertheless be deemed to have provided the electronic communication to you. 7.5. You can update your email address, mobile phone number, and residential address at any time by filing a support request at our Intercom chat or at . If your email address or mobile phone number becomes invalid such that electronic communications sent to you by us are returned, we may deem your account to be inactive, and you may not be able to complete any transaction via our Services until we receive a valid, working email address or mobile phone number from you. # 8. Indemnification 8.1. You will defend, indemnify, and hold harmless the Indemnified Parties from any claim, demand, lawsuit, action, proceeding, investigation, liability, damage, loss, cost or expense, including without limitation legal fees (on a full indemnity basis), arising out of or relating to: (a) your use of, or conduct in connection with, the Services; (b) any Feedback or User Content you provide; (c) your violation of these Terms; or (d) your violation of any Applicable Law or the rights of any other person or entity. 8.2. If you are obligated to indemnify any Indemnified Party, XREX (or, at our discretion, the applicable Indemnified Party) will have the right, in its sole discretion, to control any action or proceeding and to determine whether we wish to settle, and if so, on what terms. # 9. Governing Law and Dispute Resolution PLEASE READ THIS SECTION CAREFULLY BECAUSE IT REQUIRES YOU TO SUBMIT DISPUTES WITH US TO ARBITRATION. THIS LIMITS THE MANNER IN WHICH YOU CAN SEEK LEGAL RECOURSE. 9.1. You agree to submit to arbitration any dispute arising from these Terms or your use of the Services, except for disputes in which either party seeks equitable and other relief for the alleged unlawful use of copyrights, trademarks, trade names, logos, trade secrets, or patents. ARBITRATION PREVENTS YOU FROM SUING IN COURT OR FROM HAVING A JURY TRIAL. You and XREX agree to notify each other in writing (including via electronic communication) of any dispute within thirty (30) days of when it arises. 9.2. Procedures Prior to Arbitration: 9.2.1. If you have any dispute with XREX regarding the Services, you agree to file a Formal Complaint before pursuing any other legal actions, so that we can attempt to resolve the dispute effectively and efficiently. A Formal Complaint is filed when you send such notice to with the subject “**Formal Complaint Process**” including the details set out below. If you do not file a Formal Complaint or fail to provide complete information in your email before taking any other legal actions or seeking equitable relief in an applicable court, XREX has the right to ask the arbitrator or the court to issue an injunction, put a hold on proceedings or dismiss the filing unless and until you complete the Formal Complaint Process. For the purpose of this section, a “**Formal Complaint**” must include your information, details of the issue or dispute (including dates, times and parties involved, where relevant), supporting documents, the impact of the issue or dispute on you, the desired resolution, any prior communication with XREX personnel, and a confirmation of the accuracy of the information that you provide. 9.2.2. If any such dispute is not settled amicably within ninety (90) days after you file a Formal Complaint, the Parties agree that such dispute shall be referred to and finally resolved by arbitration on a confidential basis at the SIAC in Singapore in accordance with the SIAC Rules. However, to the extent that the SIAC Rules are in conflict with the Terms, the Terms shall prevail. 9.2.3. The tribunal shall consist of one (1) arbitrator, to be appointed by the President of the SIAC. The language of the arbitration shall be English. 9.3. Governing law: Any dispute arising from this Agreement will be governed and construed by these Terms and the laws of Singapore, without giving effect to any conflict of laws principles that may provide for the application of the law of another jurisdiction. Whether the dispute is heard in arbitration or in court, you and XREX will not commence against the other a class action, class arbitration or representative action or proceeding. # 10. General Provisions 10.1. Userʼs General Obligation: You must comply with all Applicable Laws and third-party rights (including, without limitation, data privacy laws and AML/CFT laws) in your use of the Services and the Site. 10.2. XREX does not offer nor purport to offer any legal or financial advice. You should do your own research and consult professional advisors before using our Services. 10.3. Limited Licence: We grant you a limited, revocable, non-exclusive, non-transferable licence, subject to the terms of this Agreement, to access and use the Site and XREX Materials solely for approved purposes as permitted by us from time to time. Any other use of the Site or XREX Materials is expressly prohibited and all other rights, title, and interest in the Site or Content is exclusively the property of XREX and its licensors. You agree not to copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Content, in whole or in part. 10.4. Please take the time to read and understand this Agreement before using the Services so that you are aware of your legal rights and obligations. In the event of any inconsistency between these Terms and any Annex, the relevant Annex shall prevail. 10.5. Modification of Terms: XREX reserves the right to modify these Terms at any time and at XREXʼs discretion. XREX will provide notification of modification of these Terms either by sending you an email, by updating the “**Last Updated**” presented at the top of these Terms or by a pop-up window in the Mobile App. By clicking the button or a check box presented with the modified Terms to record your consent, you agree to be bound by the updated or modified Terms. If you do not agree to any modification of the Terms, you must stop using the Services. It is your responsibility to review these Terms from time to time. Any questions related to these Terms can be directed to our support team via our Intercom chat. 10.6. Hardware and Software Requirements: It is your responsibility to make sure that you have and will maintain the requisite hardware and software, including cybersecurity software and stable and secured internet, to access the Services and communicate with XREX. 10.7. Exercise Your Right 10.7.1. Should you have any issues, questions, feedback, or comments on the Services or these Terms, you can contact XREX via the Intercom chat on the Site or Mobile App, or send an email to 10.7.2. Consent to Electronic Delivery: You consent to receive electronically all Communications that we provide in connection with this Agreement, your account, or any Services. 10.7.3. You may withdraw your consent to receive electronic Communications by sending a withdrawal notice to our Support Team by filing a support request at our Intercom chat or by sending an email to If you decline or withdraw consent to receive electronic Communications, we may suspend or terminate your use of the Services. 10.7.4. Requesting Paper Copies 10.7.4.1. If, after you consent to receive Communications electronically, you would like a paper copy of a Communication that we previously sent you, you may request a copy within 30 days after the date we provided the Communication to you by contacting us at our Intercom chat. 10.7.4.2. In order for us to send paper copies to you, you must have a current street address on file with us. Please note that our Services operate exclusively online and it is burdensome for us to produce paper copies of Communications. Therefore, if you request paper copies, you agree that we may charge you a processing fee and all relevant costs of your request. 10.8. XREX Affiliates and Contractors: The Site and any Services may be operated or provided by XREX, its Affiliates, or their respective contractors. To the extent that an Affiliate or contractor of XREX, is operating or providing any Services, the Affiliate or contractorʼs provision of such Services will be under terms identical to these Terms substituting the Affiliate or contractorʼs name wherever XREX's name occurs in these Terms. 10.9. Non-waiver: XREXʼs failure or delay in exercising any right, power, or privilege under these Terms shall not operate as a waiver thereof. 10.10. Severability: The invalidity or unenforceability of any of these Terms shall not affect the validity or enforceability of any other of these Terms, all of which shall remain in full force and effect. 10.11. Force Majeure: XREX has no responsibility or liability for any failure or delays in the performance of any Services, or any loss or damage that you may incur, due to any circumstance or event beyond the control of XREX, including without limitation any flood, extraordinary weather conditions, earthquake, or other act of God, fire, war, insurrection, riot, labor dispute, accident, the action of government, communications, power failure, or equipment or software malfunction. 10.12. Assignment: You may not assign or transfer any right to use the Services or any of your rights or obligations under these Terms without prior written consent from us, including by operation of law or in connection with any change of control. XREX may assign or transfer any or all of its rights or obligations under these Terms, in whole or in part, without notice or obtaining your consent or approval. 10.13. Separately Negotiated Arrangements 10.13.1. From time to time, XREX may, subject to Applicable Laws and regulations and as determined by us in our sole discretion, enter into separately negotiated arrangements with certain XREX users pursuant to a confidential similar agreement that supplements certain of the economic or other terms of this Agreement, in each case solely as applicable to the userʼs relationship with XREX and use of the Services. Such arrangements may involve, among other matters: (i) different incentives, including, but not limited to, different economic, funding, and/or fee terms, or other payments; and (ii) the ability to receive additional or customized market information not generally available to other users. 10.13.2. Any such separately negotiated arrangements will be entered into based on factors or considerations determined by us to be relevant in our sole discretion, and arrangements or terms offered to one XREX user, generally are not available to all, or even any, other users. You further agree and understand that the validity of or enforceability of these Terms under this Agreement entered into by and between you and XREX, shall not be affected by the existence of or the terms and conditions of any separately negotiated arrangement with any user of XREX. 10.14. Interpretation: 10.14.1. Where XREX has provided a translation of the English language version of these Terms (the “English Version”) for your convenience, the English Version governs the relationship between you and XREX. In the event of any conflict between the English Version and a translation thereof, the provisions in the English Version shall take precedence over any other translation. 10.14.2. Headings: Headings of sections are for convenience only and shall not be used to limit or construe such sections. # XREX BitCheck Service Agreement All capitalised terms used herein, unless otherwise defined, have the meanings ascribed to them in [1. Services and Account](/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/1.-services-and-account) on the General Terms and Conditions governing this Agreement. The terms herein (the “**Terms**”) govern your use of the BitCheck offered by our platform (the "**Platform**"). Before using the BitCheck, you agree to be bound by the following Terms: #### 1. Definitions 1.1. “**BitCheck**” is XREXʼs proprietary escrow function which locks users’ Funds for a transaction until the BitCheck Issuer and BitCheck Recipient have each fulfilled their respective obligations for a DPT transfer to take effect. 1.2. “**BitCheck Contract**” is an optional add-on feature based on a specific BitCheck transaction for the purpose of documenting such a transaction. 1.3. “**BitCheck Issuer**” means the BitCheck User who initiates a BitCheck transaction with another BitCheck Recipient. “**BitCheck Issuer**” and “**Bitcheck Sender**” are used interchangeably, as the context requires. 1.4. “**BitCheck Recipient**” means the BitCheck User who receives a BitCheck from the BitCheck Issuer. “**BitCheck Recipient**” and “**Bitcheck Receiver**” are used interchangeably, as the context requires. 1.5. “**BitCheck User**” means BitCheck Issuer, BitCheck Recipient, or both, as the context may require. Only users who have completed XREX’s KYC checks to XREX’s satisfaction can be BitCheck Users. 1.6. “**Voucher BitCheck**” means a BitCheck service which excludes an escrow service. #### 2. Escrow Service via BitCheck 2.1. BitCheck Users may send a certain amount of their DPTs to another user of XREX. Such an amount of DPTs will be locked on the Platform immediately after a BitCheck is issued until (1) both the BitCheck Recipient and the BitCheck Issuer agree to cancel the BitCheck, or (2) the BitCheck Issuer releases the locked DPTs and the BitCheck Recipient accepts the relevant DPTs, i.e., the BitCheck Recipient may withdraw the relevant DPTs, including transferring them to external e-wallets outside XREXʼs control, only if the BitCheck Issuer releases the BitCheck. (a) If the BitCheck Issuer and the BitCheck Recipient have any dispute regarding the locked DPTs while using BitCheck, the BitCheck Issuer and the BitCheck Recipient must resolve the disputes on their own. Upon the BitCheck Userʼs request, XREX, at its sole discretion, may facilitate amicable communication to resolve such disputes. However, XREX shall not have the obligation to do so and does not guarantee or promise any result or any kind of dispute resolution to BitCheck Users. (b) Should such a dispute occur between the BitCheck Users, the BitCheck Issuer is not obliged to the BitCheck Recipient to release the relevant DPTs until the BitCheck Users resolve such dispute. You agree that XREX has no liability or responsibility for such withholding of the relevant DPTs and/or Funds, or for your inability to withdraw DPTs or Fiat Money or to execute Trades for the duration of any such withholding. #### 3. BitCheck Contract 3.1. When BitCheck Issuer issues a BitCheck or a Voucher BitCheck, it has the option to purchase a BitCheck Contract, a product that provides electronic documentation for the specific BitCheck transaction. 3.2. To complete the documentation of a BitCheck Contract, (i) the BitCheck Users have to consent to share their personal information with the other BitCheck User. Upon such consent from both the BitCheck Users, XREX will incorporate the BitCheck Users' personal information into the BitCheck Contracts; (ii) the BitCheck Issuer must select the genuine purpose of the BitCheck transaction and provide correct transactional information accordingly, and the BitCheck Recipient must review the BitCheck Contract. If the BitCheck Recipient considers these contents of the BitCheck Contract fair, accurate, and complete, they may agree and approve the BitCheck Contract; (iii) both BitCheck Users approve the content of the BitCheck Contract via their electronic signatures respectively. 3.3. To use the add-on BitCheck Contract to your BitChecks, you agree to share your personal information with the other BitCheck Contract User for the current and all subsequent BitCheck Contract transactions. Should you decide to withdraw your permission, you agree to stop using BitCheck Contract and contact our customer service immediately. #### 4. Fee Please note that XREX may charge a fee to BitCheck Users for BitCheck and BitCheck Contracts. XREX reserves the right to adjust the applicable fee schedule. #### 5. Limitation of Liability To the fullest extent permitted by law, XREX’s liability in the provision of the BitCheck service shall be limited up to the amount of service or product fees you pay for the relevant BitCheck or BitCheck Contract service. #### 6. Disclaimer on BitCheck and BitCheck Contract 6.1. BitCheck and BitCheck Contract are provided on a “**AS IS**” and “**AS AVAILABLE**” basis. To the fullest extent permitted by law, XREX disclaims any representations and warranties of any kind, whether express, implied, or statutory, including, but not limited to, the warranties of merchantability and fitness for a particular purpose. 6.2. The nature of the BitCheck Contract is electronic documentation which is initiated, reviewed, and approved by both BitCheck Users. XREX does not verify nor endorse the agreement. Under no circumstances shall XREX be liable for any damages or loss related to or arising from the use of BitCheck, BitCheck Contract, or both. 6.3. Because the BitCheck Contract is a documentation tool, you agree to take full responsibility for the accuracy and completeness of your BitCheck Contract. XREX does not verify or endorse the BitCheck Contract you created or signed, nor does it offer legal advice. Because whether your BitCheck Contract is legally binding on both parties depends on a variety of factors, XREX highly recommends that you seek legal advice before entering into any BitCheck Contracts. 6.4. Every BitCheck Contract contains personal information automatically retrieved from our KYC database. Therefore, if you decide to create the BitCheck Contract for your BitCheck transaction, you and your BitCheck Receiver are each deemed to consent to: (i) the right for XREX to share your information with the other party, AND (ii) the permission for the other BitCheck User to receive your information. BitCheck Contract Users are obligated to keep personal information in confidence unless they explicitly agree otherwise. 6.5. You must keep your information up to date when using all of XREXʼs services and products, including BitCheck Contract. You consent to share your personal information with the BitCheck Receiver or the BitCheck Sender for the current and subsequent BitCheck Contracts, unless you inform XREX otherwise. # XREX Privacy and Cookies Policy Capitalised terms not defined herein shall have the meanings ascribed to them under the General Terms and Conditions. We are committed to protecting your privacy and safeguarding your personal data. The purpose of this XREX privacy policy (the “**Privacy Policy**”) is to inform you about our privacy practices, including how we collect, use, and disclose your personal data. This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose, or process personal data for our purposes of operating, and your use of the XREX Service. If any policies or practices of this Privacy Policy are not agreed to, please do not visit, access, or use the XREX Service. By using the XREX Service, you consent to XREX collecting, using, disclosing and processing your personal data in the manner set forth in this Privacy Policy: ### 1. General information In this section, we provide you with general information about the entity that is responsible for your personal data, this Privacy Policy, and the XREX Service. #### 1.1. Important terms In this Privacy Policy, you will encounter recurrent terms. For your convenience, we would like to explain what such terms mean, as stated in this Privacy Policy: “**Consent**” means a freely given, specific, informed, and unambiguous agreement to the processing of personal data, including deemed consent; “**Data controller**” means the entity that determines the purposes and means of the processing of personal data; “**Data processor**” means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data controller; “**Personal Data Protection Act 2012**” and “**PDPA**” means the Personal Data Protection Act of Singapore, and all subsidiary legislation, regulations, and guidelines promulgated thereunder, and as time to time amended; “**Personal Data**” means any information relating to a natural person who can be identified, (a) from that information; or (b) from that data and other information to which we have or are likely to have access. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, residential address, email address, and IP address; “**Processing**” means the use of personal data in any manner, including, but not limited to, collection, storage, erasure, transfer, and disclosure of personal data; and “**You**” and “**your**” means a natural person or a business entity that accesses and uses the XREX Service. #### 1.2. Owner and data controller The XREX Service is owned and operated by XREX Pte. Ltd. with its operation office at 7 Straits View #05-01 Marina One East Tower Singapore 018936. XREX acts as a data controller with regard to all personal data collected through the XREX Service. #### 1.3. Children The XREX Service is not intended for children under the age of 18 or equivalent minimum age in the relevant jurisdiction. Therefore, we do not knowingly collect the personal data of persons under the age of 18. #### 1.4. Cookies Policy **Definition of a Cookie** A cookie is a small data piece sent by a website to your browser, which may then be stored on your device. Cookies enable websites to recognize your device and collect certain user data. They can be: * Persistent cookies: valid until you delete them. * Expiry cookies: valid until a set expiration date. * Session cookies: valid until you close your browser. * First-party cookies: set by the visiting website. * Third-party cookies: set by external websites. We employ two cookie types on the XREX Service: * Technical cookies: crucial for the platform's proper functioning. * Unclassified cookies: record your service preferences. **Details of Cookies Employed** **ReCAPTCHA v3:** * Type: Third-party * Provider: Google * Expiration: End of session * Purpose: To distinguish humans from bots **token:** * Type: First-party * Provider: XREX * Expiration: 30 minutes * Purpose: User authentication **lan:** * Type: First-party * Provider: XREX * Expiration: Persistent * Purpose: To store language preference **Cookie Consent** Upon your first XREX Service visit, we may seek your consent for cookie usage, especially if accessing from the EU. Without consent, only essential technical cookies will be used. However, this might affect your user experience. **Disabling Cookies** You can decline our cookies anytime via your browser/device settings. However, some platform parts might not work correctly without them. For cookie management, please use the applicable link below: * [Apple Safari](https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac) * [Google Chrome](https://support.google.com/chrome/answer/95647) * [Firefox](https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences) * [Internet Explorer](https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies) * [Microsoft Edge](https://support.microsoft.com/en-us/help/4468242/microsoft-edge-browsing-data-and-privacy-microsoft-privacy) **Do Not Track (DNT)** DNT is a browser feature preventing online monitoring. Although we don't currently support DNT, you can check third-party service provider policies to determine their DNT adherence. #### 1.5. Applicability of the Privacy Policy This Privacy Policy applies to the XREX Service only, it does not apply to any third-party applications or software that integrate with the XREX Service or any other third-party products, services, or businesses. #### 1.6. Changes to the Privacy Policy Your privacy matters to us so whether you are new to the XREX Service or a long-time user, please take the time to get to know and familiarize yourself with our policies and practices. Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time, by posting the changes on the Website. You can always find the latest version of this Privacy Policy with the effective date here on this page. Your continued use of the XREX Service constitutes your acknowledgement and acceptance of such changes. #### 1.7. How we collect your personal data Before you submit any personal data through XREX Service, you must read and agree to this Privacy Policy. We generally collect your personal data in the following ways: (a) Your personal data is provided to us voluntarily by you, directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “**authorised representative**”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes; or (b) Collection and use of personal data without consent is permitted or required by the Personal Data Protection Act 2012 or other laws. Where is it necessary to collect, use, disclose or process your personal data for purposes to which you have not already consented to and been notified of, we shall seek your prior further consent to the same (except where permitted or authorised by law). ### 2. Types and purposes of personal data collected We collect only a minimal amount of personal data that is necessary for ensuring your proper use of the XREX Service. We use your personal data for specified and limited purposes. In this section, we explain what personal data we collect from you, for what purposes we use that data, and on what lawful bases we rely when processing personal data. #### 2.1. Types of personal data We comply with data minimization principles. Thus, we collect only a minimal amount of personal data that is necessary for your use of the XREX Service. Your personal data can be collected directly from you when you provide it to us (e.g., when you sign up to use the XREX Service or contact us) or by automated means (e.g., when you browse the Website or make a transaction). The list of the types of personal data that we collect from you is provided below. #### 2.2. Purposes of personal data processing We process your personal data only for specified and legitimate purposes explicitly mentioned in this Privacy Policy. In short, we will use personal data only for the purposes of enabling you to use the XREX Service, providing you with the requested services, complying with our legal obligations (e.g., AML laws and regulations), maintaining and improving the XREX Service, conducting research about our business activities, and replying to your inquiries. We will not use your personal data for any purposes that are different from the purposes for which your personal data was provided. #### 2.3. Overview of types and purposes of collecting and processing your personal data Below provided is a detailed description of the types of personal data that we collect, use and disclose, the purposes for which we may do so, and the legal bases on which we rely in doing so. **When you sign up to receive notifications about the XREX Service, we may collect your:** * Email address; and/or * Phone number. In order: * To inform you about the XREX Service Legally based on: * Your consent **When you sign up to use the XREX Service, we may collect your:** * Email address; * Phone number; and/or * Password. In order: * To enable your access to the XREX Service; * To register and maintain your user account; * To deliver the requested services; * To contact you, if necessary; * To deliver promotional information about the XREX Service; * To analyze and improve our business; * To manage your relationship with us; * To comply with any Applicable Law, regulations, codes of practice, guidelines, or rules, in order to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; * To fulfil any other purposes for which you have provided your personal data; and/or * To fulfil any other incidental business purposes related to or in connection with the above. Legally based on: * Your consent **When you upgrade your user account for transactions, we may collect your:** * Full name; * Date of birth; * Residential address; * Nationality; * Identification number; * A copy of your identity document and any information included therein; * Employment status; * Bank account information (bank name, bank account number, bank address, contact details, name of the beneficiary, wire instructions); * Annual income; * Asset net worth; * Occupation and industry; * Source of funds; and/or * Tax Identification Number. In order: * To deliver the requested services; * To verify your identity; * To comply with our legal obligations (e.g., AML laws and regulations); * To contact you, if necessary; and/or * To analyze and improve our business. Legally based on: * Your consent **When you make a transaction, we may collect your:** * Trading records; * Trading logs; * Addresses of digital assets; and/or * Wallet address. In order: * To facilitate and process your transactions; * To comply with our legal obligations (e.g., AML laws and regulations); and/or * To administer, analyze, and improve our business. Legally based on: * Your consent **When you contact us by email or via live chat, we may collect your:** * Full Name; * Email address; and/or * Any personal data that you decide to provide us in your message. In order: * To respond to and processing your enquiries; and/or * To provide you with the requested information. Legally based on: * Your consent **When you make a deposit or withdrawal, we may collect your:** * Name; * Bank account information (i.e., bank account number, bank name, and billing address); * Purpose of the transaction; * Contact information; * Relationship of the recipient; and/or * Recipient information. In order: * To process your deposits or withdrawals; * To maintain our accountancy records; and/or * To comply with our legal obligations (e.g., AML laws and regulations). Legally based on: * Your consent. **When you make a cryptocurrency deposit or withdrawal, we may collect your:** * Name; * Deposit wallet address; * Customer ID, including birth information; and/or * Transaction amount. In order: * To share the data to the originator or beneficiary VASP (Virtual Asset Service Provider); and/or * To comply with FATF (Financial Action Task Force) Travel Rule. Legally based on: * Your consent **When you use the XREX Service, we may collect your:** * IP address; * Device ID, OS, model name; * XREX App version; * Errors encountered; * Cookie-related data (please refer to the Cookie Policy for more information); and/or * Your approximate location. In order: * To analyze, improve, and evaluate our business activities; * To customize the XREX Service for your location; and/or * To ensure the security of the XREX Service. Legally based on: * Your consent Please note that we may transmit your personal data to any third parties including our third party service providers, data processors (including but not limited to those identified in [Clause 3.2](https://info.xrex.sg/doc/xrex-user-legal-agreements/xrex-general-terms-and-conditions_oct-2024/pages/YpMbKBUf5HMJE3rOl4C3#id-3.2.-list-of-data-processors) below), agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for any of the abovementioned purposes in this Paragraph 2.3. #### 2.4. Failure to provide personal data Unless specified otherwise, all personal data requested by XREX is mandatory and failure to provide this data may make it impossible for us to provide the XREX Service. In cases where we specifically state that your personal data is not mandatory, you are free to not communicate this data without consequence to the availability or the functioning of the XREX Services. Please note that your provision of non-mandatory personal data constitutes your consent to the collection, use, disclosure and processing of such personal data by us for the abovementioned purposes. #### 2.5. Additional data From time to time, we may receive certain additional data if you request support, interact with our social media accounts, submit your feedback, or otherwise communicate with us. Please note that the provision of such data is optional and you may choose what personal data you would like to share with us. We kindly request you to exercise your due diligence when making your personal data publicly available. We will use such personal data to reply to you, provide you with the requested services, or for pursuing our legitimate business interests (i.e., to analyze and improve our business) in accordance with our obligations under the PDPA. #### 2.6. Sensitive data We do not collect, under any circumstances, special categories of personal data (sensitive data) from you, such as your health information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation, unless you decide to provide such sensitive data, at your own sole discretion. #### 2.7. Personal data published on the XREX Service If you decide to publish information about yourself through the XREX Service (e.g., via your public user profile), you may decide to reveal certain information about yourself. Please keep in mind that such data will become available to other users of the XREX Service. Therefore, we request you to exercise your due diligence and not to disclose your personal data that is not necessary, extensive, or sensitive as such data can be used by third parties for unlawful purposes. Also, please note that you are not allowed to publish personal data pertaining to other persons if they have not provided you with their prior consent to disclose such data. We will take immediate steps to remove any information or user accounts from the XREX Service if we become aware that they contain personal data disclosed unlawfully. #### 2.8. Privacy of transactions The XREX Service allows you to conduct transactions with other users of the XREX Service. We put reasonable efforts to ensure that any transaction-related data remains confidential and properly protected. Moreover, we do not intentionally and directly access, manage, correct, delete, share, or disclose transaction data, unless it is strictly necessary for the provision of the XREX Service or to fulfill any of the specific purposes mentioned in this Privacy Policy (or any other incidental business purposes related to or in connection with those purposes), enforcement of our legal terms, or we are requested by law to do so. #### 2.9. Location of processing The personal data is processed at the operating offices of XREX located in Singapore and in any other places where the data processors appointed by XREX are located (please refer to the section “Disclosure and transfer or personal data” below for more information about the location of our data processors). The processing of personal data is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated in this Privacy Policy. #### 2.10. Our compliance with Anti-Money Laundering (AML) regulations We have established internal standards in meeting regulatory obligations of relevant AML laws, regulations, and guidelines that are applicable to our business. These standards include various internal policies and procedures we are required to adhere to, e.g., XREX Financial Crime Compliance Policy, AML Policy, Sanctions Policy, ABC (Anti-Bribery & Corruption) Policy, Customer Due Diligence Policy, FATF Travel Rule, and Operation Procedures. #### 2.11. FATF Travel Rule To ensure a more secure environment and prevent illicit activities abusing the blockchain and Virtual Asset channels or platforms, FATF has designed and announced the Travel Rule to all Virtual Asset Service Providers (“**VASPs**”), including XREX. According to the Travel Rule, every VASP shall exchange the sender and recipient data with the other VASPs during the process of conducting a Virtual Asset transaction. Therefore, while you make a cryptocurrency deposit or withdrawal, some of your personal information will be exchanged. ### 3. Disclosure and transfer of personal data We may need to cooperate with external service providers and share some personal data with them. Also, to ensure the provision of the XREX Service, your personal data may be transferred outside the country where you reside. In this section, you can find information about the third parties that we may disclose your personal data to, the purposes of disclosure, instances when we make international data transfers, and what safeguards we implement to ensure that your personal data is properly protected. #### 3.1. Disclosure of personal data In addition to XREX, in some cases, your personal data may be disclosed to third parties involved in the operation of the XREX Service (e.g. administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies). Such third parties are appointed by XREX as its data processors. We do not sell your personal data to third parties. The disclosure of your personal data is limited to the situations when such data is required for the following purposes: * Ensuring the proper operation of the XREX Service; * Ensuring the delivery of the services requested by you; * Providing you with requested information; * Pursuing our legitimate business interests; * Enforcing our rights, preventing fraud, and security purposes; * Carrying out our contractual obligations; * Law enforcement purposes; and/or * If you provide your prior consent to such disclosure. #### 3.2. List of data processors We will share your personal data only with the data processors with whom we have entered into legally enforceable obligations to ensure that personal data disclosed is provided a level of protection equivalent to that under the PDPA and other applicable data protection laws. The data processors that will have access to your personal data are included, but not limited to, the following: **Name: Amazon Web Services** * Service: Hosting service provider * Location: The United States & Japan (location of our servers) * More information: [https://aws.amazon.com](https://aws.amazon.com/) **Name: Sum and Substance Inc.** * Service: Identity verification service provider * Location: The United Kingdom & Germany (location of our servers) * More information: [https://sumsub.com](https://sumsub.com/) **Name: HyperVerge Technologies Pvt Ltd.** * Service: Identity verification service provider * Location: India (location of our servers) * More information: [https://HyperVerge.co](https://hyperverge.co/) **Name: Intercom** * Service: Customer support service provider * Location: The United States * More information: [https://intercom.io](https://intercom.io/) **Name: Sentry** * Service: Error monitoring service provider * Location: The United States * More information: [https://sentry.io](https://sentry.io/) #### 3.3. International transfers of personal data Depending on your location, we may need to transfer your personal data to a country other than your own for ensuring the proper provision of the XREX Service and other purposes of your personal data. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that each overseas recipient holds a specified certification (e.g., certification issued under the Asia Pacific Economic Cooperation Cross Border Privacy Rules) or such overseas recipient is bound by legally enforceable obligations to ensure that personal data disclosed is provided a level of protection comparable to that under the PDPA (e.g., a data processing agreement based pre-approved standard contractual clauses). #### 3.4. Disclosure of non-personal data Your non-personal data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving the XREX Service, responding to lawful requests from public authorities, or developing new products and services. #### 3.5. Legal requests If requested by a public authority, we will disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement. #### 3.6. Successors In case our business is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with the PDPA and this Privacy Policy. ### 4. Security of personal data We make our best efforts to keep your personal data safe and secure. In this section, we inform you about our appropriate administrative, physical and technical measures that help us to protect your personal data. #### 4.1. Our security measures XREX takes appropriate security measures to prevent unauthorized access, collection, disclosure, copying, modification, or unauthorized destruction of your personal data, or similar risks. The security measures taken by us include secured networks, SSL protocol, strong passwords, limited access to your personal data by our staff, and anonymization of personal data (when possible). In order to ensure the security of your personal data, we kindly ask you to use the XREX Service through a secure network only. #### 4.2. Handling security breaches Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the Applicable Law. Our liability for any security breach will be limited to the highest extent permitted by the Applicable Law. ### 5. Non-personal data When you use the XREX Service, we automatically collect some technical data about your device and visits. In this section, we inform you what non-personal data we collect from you and for what purposes we use that data. #### 5.1. Types of non-personal data When you use XREX Service, we automatically collect technical non-personal data for analytics purposes. Please note that de-identified personal data is also considered to be non-personal data. Although such non-personal data allows us to analyze your use of the XREX Service, it does not allow us to identify you. The non-personal data collected by us includes the following information: **Transaction data** When you make a transaction, we collect expected transaction volume, expected transaction frequency, details of transactions you make, such as trades, deposits, withdrawals, parties to send or receive transactions, relationships, and purpose of the transactions. **Usage data** When you access and use the XREX Service, we collect information about the time of your request, the method utilized by you to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by you, the various time details per visit (e.g., the time spent on each page) and the details about the path followed within the XREX Service with special reference to the sequence of pages visited, and other parameters about the device operating system and/or your IT environment. When you contact us, we keep records of any questions, complaints, recommendations, or compliments made by you and the response, if any. Where possible, we will de-identify your personal data. #### 5.2. Purposes of using non-personal data We will use non-personal data for the following purposes: * To analyze what kind of users visit and use the XREX Service; * To examine the relevance, popularity, and engagement rate of the XREX Service; * To investigate and help prevent security issues and abuse; * To develop and provide additional features to the XREX Service; and/or * To personalize the XREX Service for your specific needs. #### 5.3. De-identified data In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer identify a natural person (whether by itself or in combination with any other data in our possession or control), it will not be considered personal data and we may use it for any business purpose. ### 6. Direct marketing From time to time, you may receive promotional messages from us. In this section, we explain when you may receive notices from us and what you can do to decline such promotional messages. #### 6.1. Marketing messages To keep you updated about XREX Service, we will send you direct marketing messages. You will receive such communication only if: We receive your express (“**opt-in**”) consent to receive direct marketing messages in relation to both the existing XREX Service provided to you and/or new services closely related to such XREX Service (please note that your voluntary subscription to our updates or newsletters substitutes such consent). #### 6.2. Opting-out You can opt out from receiving marketing messages at any time free of charge by clicking on the “unsubscribe” link contained in any of the messages sent to you, adjusting your account settings, or contacting us directly. #### 6.3. Informational notices and service updates If necessary, we will send you important informational notices, such as service-related, technical, or administrative emails, information about the XREX Service, your transactions, user account, privacy and security, and other administrative matters. Please note that we will send such notices on an “if-needed” basis and they do not fall within the scope of direct marketing communication that requires your prior consent. ### 7. Retention time We retain your personal data only for a period necessary to carry out the purposes mentioned in this Privacy Policy or for our business purposes. In this section, we specify the time period for which we keep your personal and non-personal data in our systems. For example: * Your personal data collected for purposes related to the performance of a contract between you and XREX shall be retained until such contract has been fully performed; * Your personal data collected for the purposes of XREX’s legitimate interests shall be retained as long as needed to fulfill such purposes; and * If you provide your consent to the processing of your personal data, we will retain your personal data (i) for as long as such personal data is necessary for the purposes for which you have provided your consent or (ii) until you withdraw your consent, whichever comes first. Once the retention period specified above expires, your personal data shall be securely deleted from our systems. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period. #### 7.1. Retention as required by law XREX may be obliged to retain your personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. For example, we may retain your personal data for as long as it is necessary to keep our accountancy records or for the time period stipulated by AML laws and regulations. #### 7.2. Retention of non-personal data We may retain non-personal data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping non-personal data after you have deactivated your user account for the period of time needed for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements. ### 8. Your rights regarding your personal data You have the right to control how we process your personal data. Below, we list the rights that you can exercise with regard to your personal data and explain how you can exercise those rights. Subject to any exemptions provided by law, you can exercise the right to do the following: * **Withdraw your consent** You have the right to withdraw your consent at any time where you have previously given your consent to the processing of your personal data. The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes stated in this Privacy Policy. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the request, including any legal consequences which may affect your rights and liabilities to us. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you once such consent has been withdrawn. * **Object to processing** You have the right to object to the processing of your personal data if the processing is carried out on a legal basis other than the performance of a contract with you or pursuing our legitimate business interests. * **Access your personal data** You have the right of access to: (a) personal data about you in our possession or under our control through receipt a copy of such personal data; and/or (b) information about the ways in which that personal data has been used or disclosed by us within a year before the date of your request. If we are unable to provide you with such copy of personal data or such information requested, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA). * **Verify and seek rectification** You have the right to verify the accuracy of your personal data and ask for it to be updated or corrected. * **Restrict processing** You have the right, under certain circumstances, to restrict the processing of your personal data by withdrawing of your consent to such processing. * **Have your personal data deleted or otherwise removed** You have the right, under certain circumstances (namely, where retention of the data no longer serves any legal or business need of ours, to erase your personal data from our systems. * **Receive your personal data and transfer it to another controller** You have the right to receive your personal data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller. * **Lodge a complaint** You have the right to bring a claim before their competent data protection authority. **How to exercise your rights** Any requests to exercise your rights can be directed to XREX by using the contact details specified at the end of this Privacy Policy. The requests can be exercised free of charge to you once per year and they will be addressed by XREX as early as possible and always within one month. **Launching a complaint** If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority. **Contact information** For any questions, comments, or requests about this Privacy Policy or your personal data, please contact our Data Protection Officer by using the contact details below. * Company name: XREX Pte. Ltd. * Address: 7 Straits View #05-01 Marina One East Tower Singapore 018936 * Email address: * Phone number: (+65) 69116677 # Disclosure and Risk Warning\_Oct 2024 **RISK WARNING ON DIGITAL PAYMENT TOKEN SERVICES** The Monetary Authority of Singapore (“MAS”) requires us, XREX Pte. Ltd., to provide this risk warning to you as a customer of a digital payment token (“DPT”) service provider. **Before you:** (a) pay your DPT service provider any money or DPT; or (b) pay a third party any money or DPT under an arrangement by your DPT service provider, **you should be aware of the following:** 1\. Your DPT service provider is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to your DPT service provider or any other third party referred to above, if your DPT service provider’s or the third party’s business fails. 1A. You should be aware that MAS does not supervise or regulate your DPT service provider for the provision of unregulated services.\[1] This includes any service of trading digital payment token derivatives such as futures. 2\. You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact if transferred or held by your DPT service provider. 3\. You should be aware that the value of DPT’s may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens. 4\. You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”. **NOTICE FOR NON-SINGAPORE RESIDENTS** XREX Pte. Ltd. is licensed by the Monetary Authority of Singapore to provide e-money issuance service. Please note that this does not mean that you will be able to recover all the money you paid to XREX Pte. Ltd. if XREX Pte. Ltd.’s business fails. **XREX’S BUSINESS DAYS AND HOURS** Our business days and hours are as follow: Mondays to Fridays (excluding public holidays): From 10:00 a.m. to 6:00 p.m. *** \[1] Please refer to Section 2.3.1 of the Guide to the Payment Services Act 2019 (which can be found on the MAS website) for the types of payment services which are regulated under the Payment Services Act. Services which do note fall within the list of services in Section 2.3.1 are unregulated services.