Terms and Conditions

1.1 Welcome to the General Terms and Conditions of Use (the "Terms of Use") of our website, www.bepay.com (the "Website"). This Website is owned and collectively managed by DIRECTPAY FINTECH LTD – CANADA MSB (REGISTERED), BEPAY MONEY EUROPE SRL – ROMANIA VASP, BEPAY MONEY INC – USA MSB, BEPAY MONEY HOLDING LTD, BEPAY MONEY PRODUCTS HOLDING LTD. Each company is held by Bepay Money Products Holding and ultimately by the ultimate beneficiary owner, a private limited liability company registered under the laws of the British Virgin Islands (hereinafter: BVI), having company registration number 2185015, and its registered address situated at SR Corporate Services Limited of Wattley Building, 2nd Floor, 160 Main Street, P.O. Box 3410, Road Town, Tortola, British Virgin Islands ("BEPAY", the "Company", "us", "we" or "our").

1.1.1 For clarity, if you use the services of only one BEPAY entity, you agree to these terms and conditions, and they shall be applicable only between you and that specific entity in compliance with the applicable laws of country of registration of that specific legal person.

1.2 BEPAY will seek voluntary authorization from the Romania Financial Supervision Authority (ASF) for the relevant activity according to the national legal framework. No application is received or accepted by the national competent authority for review at the moment, namely ASF. Thus, the activity is out of the regulatory scope now, which is confirmed by local specialized lawyers via Bepay Money's secured legal opinion. All necessary AML/CFT rules are carefully followed and duly implemented in the course of business for the BVI, Romania, Lithuania, Dubai, USA and EU operations as well as at international level. BEPAY MONEY EUROPE owns local operational subsidiaries with VASP registrations in Lithuania (the EU), United States of America, India, and carries out due diligence with its activities in line with the AML/CFT requirements in the Cayman Islands, British Virgin Islands and the United Arab Emirates (Dubai).

1.3 The main purpose of the Cryptoasset is to provide a digital alternative to traditional forms of money that is more efficient, secure, and accessible and to be used as utility cryptoasset, virtual financial asset, or other crypto asset under the definition prescribed in the MiCA Regulation, in a variety of contexts, including online on-chain transactions via blockchain or other DLT, and decentralized finance (DeFi) applications.

1.4 The terms and conditions of participation and other information relative to the details of the Cryptoasset are outlined in the White Paper, available on this Website.

• AML/CTF — refers to Anti-Money Laundering and Countering the Financing of Terrorism.
• AML Regulations — the Prevention of Money Laundering and Funding of Terrorism Regulations, Subsidiary Legislation 373.01, and the 4th and 5th EU Directives on the Prevention of Money Laundering and Terrorism Financing and including the Implementing Procedures Parts 1 and 2 issued by the Financial Intelligence Analysis Unit (FIAU). These AML Regulations also refer to the corresponding national law of the British Virgin Islands (BVI).
• Company or BEPAY or the Issuer — Bepay Money (group) consists of: Bepay Fintech Products Holding LTD, British Virgin Islands (Registration No: 2185015); Bepay Money Europe S.R.L, Romania (Registration No: 52474864); Bepay Money Fintech UAB, Lithuania, European Union (Registration No: 306999867); Bepay Fintech Inc, United States (Registration No: 31000294520372) and Canada (Registration No: 1001340184).
  
  DIRECTPAY FINTECH LTD (Sole UBO's Canadian Money Services Business with incorporation number 1001340184 & registered and regulated entity under Canadian law with MSB registration number C100001109 on the FINTRAC REGISTER to be accessed on https://fintraccanafe.canada.ca/msb-esm/reg-eng) and BEPAY FINTECH INC (Sole UBO's USA Money Services Business registered and regulated entity under USA law with MSB registration number 31000294520372 on the MSB REGISTRANT REGISTER to be accessed on https://www.fincen.gov/resources/msb-state-selector);
  
  BEPAY FINTECH PRODUCTS HOLDING LTD, a limited liability company incorporated under the Laws of the BVI, bearing company incorporation number 2185015, and with the registered office address at SR Corporate Services Limited of Wattley Building, 2nd Floor, 160 Main Street, P.O. Box 3410, Road Town, Tortola, British Virgin Islands, with operational office address at 1st Floor, Ellen Skelton Building, 3076 Sir Francis Drake's Highway, Road Town Tortola, British Virgin Islands. This legal entity owns or will own all other operational corporate entities in different economic areas over the world.
• USER(S) — shall mean a natural or legal person who wants to become an approved user (in line with KYC/KYB and AML/CFT requirements) in order to be onboarded with the purpose to get information from and about the bepay ecosystem, offers from sellers or merchants, buy goods and services from others, including approved and onboarded merchants in line with KYB and AML/CFT requirements, by the means of supported cryptoassets, cryptocurrency, virtual assets, digital assets or fiat (later on and where applicable and permitted by the local law). All transactions are decentralized, peer-to-peer, immutable, irrevocable, irreversible, and without the intervention or intermediation of bepay, BEPAY MONEY EUROPE or any affiliated person.
• Custodian — N/A at this point in time and not required by law.
• Dissolution Event — an event whereby it becomes necessary, recommendable, or advantageous for the Company to dissolve or liquidate.
• DLT — Distributed Ledger Technology.
• Documents — includes these Terms of Use, the White Paper, T&Cs and any other information relating to the Project and the use of Cryptoassets as may be announced by the Company from time to time, including electronic (written or oral) communications.
• EUR, Euro — the currency of the Member States of the European Union, that participate in the European Monetary Union.
• Exchange Rate — means the exchange rate with stablecoins (e.g., USDC), in the following proportion calculated on the basis of the Subscription Rounds as described in the Whitepaper (from the primary issuer only, meaning BEPAY).
• Fiat — a legal tender issued by a government.
• Force Majeure — shall include labour disputes or other industrial disturbances, hacking or any other cybercrime attack, or computer oriented crime, electrical, telecommunications, hardware, software or other utility failures, software or smart contract bugs or weaknesses, earthquakes, storms, or other nature-related events, blockages, embargoes, riots, strikes, acts or orders of government, acts of terrorism or war, technological change, changes in interest rates or other monetary conditions, and, for the avoidance of doubt, changes to any blockchain-related protocol.
• FSC — Financial Services Commission of the British Virgin Islands (BVI).
• Intellectual Property — Means ideas, know-how, concepts, techniques, inventions, formulas, methods, information, computer programs and software, including any preparatory works, code and functions and includes but is not limited to copyrights, trademarks, patents, design rights, trade secrets, and all other rights of a similar or equivalent nature and/or description, across the whole world, and irrespective of whether such rights are registrable or unregistrable in nature which belong to the Company, are conceived and/or created by the Company or over which the Company has any rights.
• KYC/KYB — Know Your Customer/Business – a due diligence procedure carried out by the Company in terms of AML/CFT Regulations.
• MiCA — Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 (or The EU's Regulation on Markets in Crypto Assets; hereinafter: "MiCA").
• Merchant — shall mean a natural or legal person who wants to become an approved user (in line with KYC/KYB and AML/CFT requirements) in order to be onboarded with the purpose to sell online or physical goods or services through the bepay ecosystem, accepts to pay a listing fee based on volume of items paid, sell goods and services from others, by the means of supported cryptoassets, cryptocurrency, virtual assets, digital assets or fiat (later on and where applicable and permitted by the local law). All transactions are decentralized, peer-to-peer, immutable, irrevocable, irreversible, and without the intervention or intermediation of bepay, BEPAY MONEY EUROPE or any affiliated person. All claims form purchaser users are to be the sole responsibility of the Merchant. Bepay or BEPAY MONEY EUROPE are not liable of any (non-)delivery, missing item or service, malicious deliverable or harmful goods or services, or any part of the performance. Bepay is only the software that enables the Merchant to collect cryptoassets in exchange for the occurred sale of goods or services. The Merchant does not pay a commission for each transaction. Bepay only charges merchants for the software license and APIs as a listing fee in the bepay ecosystem and may be based on volume of items sold according to a predetermined schedule, negotiated or automatically accepted by the merchants upon the offer received from bepay via the decentralized application in terms and conditions, email, phone, mail, or other electronic means of communications. All disputes are to be exclusively settled in Amsterdam at NCC. Both parties implicitly, freely, voluntarily and unequivocally accept the competence of the NCC (Dutch Commercial Court of Arbitration).
• Parties — shall refer to the Company and the User(s) jointly, and individually they shall be referred to as a "Party".
• Prohibited Participants — a natural or legal person, being a User(s) and being incorporated, registered or being effectively managed and/or controlled from or in:
  
  (i) a country, jurisdiction or territory where the VFA Allocation Event (Pre-Sale) (if any) or the holding and use of Cryptoassets and/or other cryptoassets at any moment in time is prohibited by laws, regulations, or other practices and policies in the said country, jurisdiction or territory, which is taken to include but not limited to the United States of America ('USA') (including tax residents of the USA) or any other jurisdiction where the aforementioned is prohibited; or in
  
  (ii) countries deemed to be high risk subject to a call for action by the Financial Action Task Force ("FATF"); or in
  
  (iii) countries which are deemed to be outside the risk appetite of the Company.
  
  This shall also include any person representing or acting on behalf of such Prohibited Participant/s in any manner or capacity.
• Project — the reason behind this protocol creation and development is to introduce the use of Cryptoassets as a fair, fast, readily available and affordable alternative medium of exchange and to encourage the instrumental function and use of the Cryptoassets.
• T&Cs — shall refer to the terms and conditions applicable to the use of the websites provided by Bepay.
• Cryptoassets — a cryptoasset (or VFA/virtual financial asset/digital asset/virtual asset) based on Bitcoin or ERC 20 and EVM compatible standard protocol (or other DLTs) intended primarily to participate and benefit from the Project as outlined in the Whitepaper of BEPAY; such cryptoassets are to be used for decentralized payments, peer-to-peer between sellers and buyers of online or physical goods or services from one another, without any intermediation.
• Unhosted wallet address — shall refer to an unique address accessible exclusively through the safeguarded private key of the counterparty at stake in order to read data, regarding crypto-assets specifically allocated to it, from and/or on the blockchain in question (or any other distributed ledger technology with similar characteristics, features, or outcomes regardless of the unique differences in terms of advantages and disadvantages), which allows the transfer of crypto-assets (i.e., MiCA definitions and categories) between such unhosted wallet addresses.
• User — shall refer to any person entering, accessing, connecting to or using the Website.
• USDC — The digital asset stablecoin issued by Circle, which, in principle and in general, holds a 1:1 parity level with the USD by exchanging 1 USD for 1 USDC; Under EU's MiCA Regulation, USDC is a crypto asset, which represents an electronic money cryptoassets (or e-money cryptoassets, or hereinafter: "EMT").
• USD — the currency of the United States of America.
• VASP Act (BVI) — Virtual Assets Service Providers Act of the British Virgin Islands 2022.
• VFA — a VFA, or virtual financial asset, is any form of digital medium recordation that is used as a digital medium of exchange, unit of account, or store of value and that is not electronic money, a financial instrument or a virtual cryptoasset, as set out in the Law.
• Law(s) — Virtual Assets Services Provider Act (2022), Markets in Crypto Assets (MiCA), MSB and RPAA regulations (Canada), other applicable laws of BVI (amended in line with MiCA), VARA, VASP, and other legal framework of each state where any bepay subsidiary is incorporated.
• Wallet — a private key or a combination of private keys having a unique address and capable of receiving Bitcoin or ERC 20 cryptoassets including the Cryptoassets and which is necessary to acquire, hold and dispose of Cryptoassets.
• Website — the Company's domain, accessible from the following link: https://www.bepay.money.
• White Paper — a marketing document prepared and issued by the Company and in the course of registration with the regulator in question, to explain and give a detailed description of bepay, the team, the terms, and the benefits of participating in the Project.
• Working Days — a day during the week (Monday-Friday) when state authorities and/or the respective merchants work and are able to provide full service for customers or to the public, which does not include days when bank services are only available via the internet.

The terms 'jurisdiction', and 'territory' may be used interchangeably and shall have the same meaning and shall also be taken to include any determinate geographic location to the extent applicable in these Terms of Use.

The term 'wallet' shall be construed to include 'digital vault', or any other storage mechanism and these terms may be used interchangeably throughout these Terms of Use.

Where the context so requires, the use of the masculine gender shall include the feminine and the singular shall include the plural and vice versa.

3.1 The provisions of these Terms of Use will govern the entry, access, connection to or use of our Website by general user(s) (the "User(s)", "you", "your" or "yours"). For the avoidance of doubt, any reference in these Terms of Use to 'use' shall refer to any sort of use of the Website, inclusive of simple entry, access or connection to the same Website. These Terms of Use form a legally binding agreement between the User and BEPAY and you should therefore take the time to read them carefully. By entering, accessing, connecting to or using this Website in any manner, you are deemed to have read, understood and agreed to these Terms of Use. If you do not agree with these Terms of Use, please refrain from using our Website.

3.2 The use of this Website does not imply that you can acquire BEPAY or any other cryptoassets. Should you wish to acquire Cryptoassets, you will be required to pass our client acceptance and onboarding procedures in line with BEPAY's KYC/KYB and AML procedures, as well as confirm your agreement to the specific T&Cs for the purpose of self-issuance and auto-distribution of cryptoassets via the use of the smart contract of BEPAY.

3.3 Any accepted contribution is made by the respective USER(S) or Participant for an Initial Coin Offering or the so-called Pre-Sale of Bepay, which also represents the Cryptoasset Allocation in the BVI and is exempted by the FSC under the VASP Act of 2022 in the BVI.

3.4 The Participant or USER(S) understands and freely the following statements in an unequivocal manner by way of a positive click action in the checkboxes of the Pre-Sale:

• I understand this is a request to participate in the BEPAY Pre-Sale. All requests require identification, approval, and full payment to be finalized.
• I certify that I have adequately informed myself regarding BEPAY, including its mission as outlined in its website and whitepaper, as well as the restrictions, conditions, and dangers associated with participating in the pre-sale. I am also cognizant of the fact that I may forfeit my entire contribution, as such allocations are subject to irreparable harm and inherent risks.
• I confirm that I am well-informed regarding the anticipated digital assets and the nature of my contribution, in addition to the risks and limitations associated with utilising blockchain technology. It is understood that BEPAY functions via smart contracts and that neither my country of residence nor the country where BEPAY as a protocol is headquartered have direct legal regulation over DeFi (Decentralised Finance). At the time of subscription, Bepay is therefore not subject to regulation, supervision, or monitoring by a financial regulator, as is not yet mandated by law.
• I hereby declare that I will not engage in any financial crime and will not use Bepay, digital assets obtained via this contribution, or services for engaging in illicit activities on-chain, off-chain, online, or offline.
• I agree to the terms and conditions of the BEPAY Pre-Sale as set out in the Terms and Conditions of the BEPAY Pre-Sale 2024.

4.1 To use most of our services, you need to create an account with us. Your account may hold Digital Assets. To use any of our services, or to create an account, you must meet at least the following conditions:

• if you are an individual, be old enough to legally form a binding contract in your jurisdiction (18 years old or above, but it may be different where you live),
• if you are an entity, be duly organized and validly existing under the applicable laws of the jurisdiction of your organization,
• have a current and valid email address, mobile phone number, and street address,
• have full power and authority to enter into these Terms without violating any other agreement you have made,
• not have been restricted from using our services,
• if you are an individual, not be located in, under the control of, or resident in—or, if you are an entity, not be directly or indirectly owned or controlled by any person located in, under the control of, or organized or resident in—any sanctioned or embargoed jurisdiction (including Crimea, Cuba, Donetsk, Iran, Luhansk, North Korea, Russia, and Syria), or any jurisdiction where we may have restricted use of any services, and
• if you are an individual, not be listed on—or, if you are an entity, not listed on or be directly or indirectly owned or controlled by any person listed on—the Office of Foreign Assets Control of the U.S. Department of Treasury's Specially Designated Nationals and Blocked Persons List ("SDN"), the U.S. Department of Commerce's Denied Persons List, Consolidated Non-SDN Lists available here, the United Nations (UN) Security Council Consolidated List available here, or regional or foreign government watchlists

4.2 You understand that we are providing you with access to our Website on an "as is" and "as available" basis and BEPAY expressly disclaims any and all warranties, express or implied, in relation to the Website.

4.3 You agree that any use of the Website shall be for the legitimate purposes expressly permitted and contemplated by these Terms of Use and, where applicable, by the T&Cs. You may not use the Website for any other purpose without our express written consent.

4.4 Content and materials available in this Website that are accessible without the acquisition of the Cryptoassets are made available for general information purposes only.

4.5 You agree to, and represent and warrant that you will:

• not use your account for the benefit of any person other than you,
• not share your account or password with anyone else,
• maintain the security of your account, including by using a strong password for your account that you don't use anywhere else,
• notify us immediately if you discover or suspect any security breaches related to your account,
• take responsibility for all activities that occur under your account, and accept all risks of any authorized or unauthorized access to your account, to the maximum extent permitted under applicable law, and
• provide accurate, complete, truthful, and updated information (including email address, mobile phone number, and street address) at all times when using any account or service.

4.6 We may, in our discretion, determine that it's necessary or appropriate to temporarily suspend or even terminate your account. In the event of breach of any provision in these Terms and Conditions, other policies, or applicable laws, regulations or guidelines in the state of residence, operation, nationality or other civil status, Bepay is fully and duly entitled to take immediate proportionate action as deemed appropriate, including any account restrictions, suspension for indefinite period of time, or termination in line with the applicable laws, including AML/KYC, GDPR, and other privacy laws that may apply.

4.7 You are solely responsible for all acts and omissions that occur under your account, and you will be deemed to have made all actions taken using your account. You will abide by all applicable laws. You will not engage in any money laundering or terrorist financing activity by the use of any Bepay Money product, service, persons or associated parties to the corporate group. You will not be allowed to copy any Bepay Money software, IP, or use know-how obtained from interaction with Bepay Money's staff.

4.8 Registration and Verification: As part of the registration process, you must provide BEPAY with the information requested to identify and verify your identity and for the detection of anti-money laundering, terrorist financing, fraud, or any other financial crime, and permit us to keep a record of such information. You will need to complete certain verification procedures before you are permitted to start using the BEPAY Services.

4.9 Requested Information: The information we request may include certain personal information including, but not limited to, your name, address, telephone number, email address, date of birth, taxpayer identification number, government identification number, information regarding your bank account (such as the name of the bank, the account type, routing number, and account number), network status, customer type, customer role, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status details. We will treat this information in strict accordance with the Privacy Policy and Data Protection provisions of this Agreement, as set out at Sections 16 and 27.

4.10 Third-Party Inquiries: You authorise us to make enquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries. When we carry out these enquiries, you acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime agencies and that these agencies may respond to our enquiries in full. This is an identity check only and should have no adverse effect on your credit rating. Additionally, we may require you to wait some amount of time after completion of a transaction before permitting you to use further BEPAY Services and/or before permitting you to engage in transactions beyond certain volume limits.

4.11 Partner Referrals: Where you are referred to us by our Partners via Partner Sites, you will still be required to register for an Account with BEPAY, and this Agreement will apply in full irrespective of any other terms you sign up to with our Partners.

5.1 Where a User qualified as a User(s), it hereby agrees to abide by the following principles and information readily available and easily accessible in the whitepaper of Bepay:

5.1.1 The User(s) is not eligible to acquire any Cryptoassets if the User(s) is a Prohibited Participant;

5.1.2 The Cryptoassets or any ability to buy or sell goods or services are not available to any Prohibited Participant, User or Merchant, who is prohibited from complying with the terms set out in the Documents and acquiring, holding, using and benefiting from the Cryptoassets or any other VFA generally or to a User(s) in a country where any special or particular approval or licence is required or similar event without obtaining such approval or licence and consequently would be excluded from bepay by termination of the relationship without any outstanding claims or any option to claim damages in any court (if any such event);

5.1.3 The Company retains the right to deny transferring the Cryptoassets to any User(s) or Prohibited Participant; this outcome shall be justified only to previously onboarded Participants, Merchant or USER(S)s whereas the User(s)s must request the reasoning withing 48 hours.

5.1.4 The terms of the Documents may only be used, and are only made available, in such country where the Documents and the acquisition and holding of Cryptoassets as described in the Documents is not prohibited by law or regulation;

5.1.5 The User(s) is required to inform themselves about the content of the Documents, as may be applicable, carefully read and analyse the White Paper and consult legal counsel in its country of registration and/or residence whether it can participate in this bepay eocsystem or whether there are any restrictions imposed upon it by any jurisdiction other than the laws of BVI;

5.1.6 If the User(s) is resident or registered in a country or territory that has declared the trade with cryptoassets or the participation in or subscription towards any VFA Allocation Event or Service to be illegal, the User(s) may face administrative or criminal charges when participating. In such a case, any losses suffered by the User(s) shall be borne solely by him and the Company shall not be held liable for such losses, reputational damages, or any other claims;

5.1.7 Subject to section 5.1.8 below, all Cryptoassets allocated by the Issuer to the User(s) in line with the Subscription Amount are final, and there are no refunds or cancellations except as may be required by applicable law, decree, regulation, treaty, or administrative act;

5.1.9 The acquisition of Cryptoassets by the User(s) in no way creates any exclusive relationship between the User(s) and the Company, nor any partnership, joint venture, or agency.

5.2 The User(s) represents and warrants that to the extent that it is not a Prohibited Participant, it is to ensure that no prior or subsequent approval, notification, registration or licence is needed or if such is needed it is up to the User(s) to obtain such prior approval, notification, registration or licence.

5.3 The User(s) also confirms its understanding that:

5.3.1 the Cryptoassets are not securities and do not carry with them any right as may be commonly associated with securities. The Cryptoassets do not grant any rights with respect to the corporate decision making, any rights relative to receipt of dividends, any rights to vote or receive proceeds upon liquidation or any other right to receive payments from the Company. Cryptoassets are intended to be solely used as further set out in the White Paper. The rights of the User(s) in the VFA Allocation Event are limited to statutory and contractual rights according to the laws of the BVI;

5.3.2 the Company retains all rights, title and interest in all of its Intellectual Property and data pertaining to the Website, the Project and the Cryptoassets, whether or not patentable. The User(s) may not use any of the Company's Intellectual Property for any reason, except prior to obtaining the Company's express consent;

5.3.3 the Company shall issue the Cryptoassets only if the documents requested by the Company when conducting its KYC or any other verifications have been passed and approved by the Company and not later than 7 working days from when verifications are passed and approved;

5.3.4 the Company is not in a position to guarantee a stable value of the cryptoassets at any point in time, especially since it does not aim to have an objective to or control its price, especially when the price is made by participants on the secondary market.

5.3.5 the Company does not hold cryptoassets in custody for the User at any point in time, nor does the Company have the power to reverse, alter, modify, or change in any other way cryptocurrency transactions made on the blockchain on which a cryptoasset can be transferred. Each User has complete self-custody and control over his funds at any give moment. Bepay Money's dApp only reads that from the blockchain and provides a user friendly interface. All services on the dApp are provided by regulated third parties. Bepay Money operates under a MiCA Regulation exemption while it does not directly provide any regulated service.

Each User only allocates self-custodial funds on his own wallet address on Bepay Money dApp.

7.1 In case of a Dissolution Event at any moment during the VFA Allocation Event, the Company will only refund an amount equal to the Subscription Amount, subject to section 7.2, and payable to the User(s) immediately before, or in tandem with the consummation of the Dissolution Event, subject to the rights and ranking of creditors under the Laws of the BVI.

7.2 If immediately prior to the consummation of the Dissolution Event, the assets of the Company that remain legally available for distribution to the participants, as determined in good faith by the Company's board of directors, are insufficient to allow distribution to all the participants of their respective Subscription Amounts, then the remaining assets of the Company that are legally available for distribution, following all distributions to the shareholders and creditors, will be distributed with equal priority and pro rata among the participants in proportion to their Subscription Amount.

7.3 Any distributed amount may be made in Fiat or any other VFA as the Company may at its discretion decide to distribute and on the basis of its reserves at that time, especially in context of eventual debts by taking into account hierarchy of creditors and security rights of such counterparties BEPAY entered in a commercial relationship with for adequately and properly justified reasons, or stemming from certain allocations into financial instruments of short- or long-term vesting or lock-up period on the basis of its own discretion aligned with its internal financial risk control models and/or on the basis of regulatory requirements (e.g., liquidity, subscribed capital and available reserves).

7.4 These financial instruments consist of, but are not limited to, traditional financial instruments for the purpose of liquidity available, especially as required by applicable law but also based on the discretion and financial risk control parameters of BEPAY, other crypto-assets, certain governmental bonds, other debt instruments, cash, liquid equity shares of companies established in the EU/EEA, and other potential instruments in limited sizes and amounts.

8.1 BEPAY may (a) refuse to complete, or block or cancel what you have authorised, (b) suspend, restrict, or terminate your access to any or all of the BEPAY Services, and/or (c) deactivate or cancel your BEPAY Account with immediate effect for any reason, including but not limited to where:

• The Issuer is required to do so by valid court order, or binding order of a governmental authority; or
• The refund of the Subscription Amount to the User(s) in certain instances as outlined in these Terms of Use; or
• The payment to the User(s) of the Subscription Amount due in terms of these Terms of Use; or
• The Issuer takes the unilateral decision or is required to terminate in line with AML Regulations and its internal KYC procedures; or
• The User(s) wishes to redeem the Cryptoassets in line with what is set out in the Documents; or
• We reasonably believe that we need to do so in order to protect our reputation; or
• We reasonably suspect you of acting in breach of these Terms of Use or the Documents
• We have concerns that a transaction is erroneous, we have concerns about the security of your Account, or we suspect the Services are being used in a fraudulent or unauthorized manner
• We suspect money laundering, terrorist financing, fraud, or any other financial crime
• The use of your Account is subject to any pending litigation, investigation, or government proceeding, and/or we perceive a heightened risk of legal or regulatory non-compliance associated with your Account activity
• You take any action that may circumvent our controls, such as opening multiple Accounts or abusing promotional offers which we may offer from time to time
• You fail to provide on request such documentation as the Company reasonably requires in order to comply with its obligations under applicable money laundering laws and regulations, or otherwise to ensure the verification of your identity and/or funding sources
• Any Cryptoasset or Digital Asset order is significantly larger in size than usual
• We reasonably believe that it is necessary or desirable to do so in order to protect the security of the Account, including circumstances where any Account details may have been lost or stolen

In the case of User(s), these Terms of Use shall remain applicable unless amended by BEPAY.

8.2 All provisions of the Documents which by their nature should survive termination, shall survive termination, including but not limited to, disclaimers or limitations of obligations or liability and indemnity.

9.1 The acquisition of Cryptoassets through the VFA Allocation Event carries with it substantial risks. The User(s) should carefully weigh all the risks and possible costs, including the risks set out in the Whitepaper and the non-exhaustive list of risks described hereunder:

• The Company maintains sole discretion in the conduct of its business including as related to the VFA Allocation Event, maintenance, and use of the Cryptoassets;
• The User(s) understands and accepts the inherent risks associated with the Cryptoassets, including but not limited to, risks associated with: (i) decentralisation of the blockchain technology; (ii) money laundering; (iii) fraud; (iv) anonymity of transactions; (v) use of Cryptoassets for illicit purposes; (vi) theft; (vii) loss of Wallet key.
• The User(s) understands and accepts that the software and hardware, technology and technical theories associated with DLT and used by issuers of cryptoassets is still in early development stages and still is unproven and might be unreliable and risky. There is no warranty that the technology will be uninterrupted or error-free and there is an inherent risk that the technology could contain weaknesses, vulnerabilities or bugs causing, inter alia, in rare instances, the complete loss of the Cryptoassets and the Issuer's entire Subscription Amount.
• The User(s) understands and accepts that the distribution of Cryptoassets by means of the VFA Allocation Event, may be abandoned for a number of reasons including but not limited to lack of interest from the industry and/or the public, lack of uptake by third parties, lack of funding and lack of commercial success. The User(s) therefore understands that there is no assurance that, even if such project is partially or fully developed and launched, the User(s) may receive any functionality through the Cryptoassets it holds;
• The User(s) understands and accepts that the underlying software application and software platform of the Cryptoasset, the internet, the blockchain network, the Issuer itself and all other involved software, technology components concerned with the Cryptoasset may be exposed to attacks by hackers or other individuals that could result in theft or loss of the Cryptoassets and the User(s)'s entire Subscription Amount;
• The User(s) understands and accepts that public-based blockchain systems depend on independent validators, and therefore may be vulnerable to consensus attacks. Any successful attacks present a risk to such systems, expected proper execution and sequencing of Cryptoasset-related transactions and expected proper execution and sequencing of software computations, including loss of the User(s)'s entire Subscription Amount;
• The User(s) understands and accepts the inherent risks outlined under the Law named 'Regulatory and Investigatory powers' whereby the Minister is given regulatory and investigatory powers including but not limited to the power to regulate the activities of issuers, regulate the promotion or sale by and on behalf of any issuer, the power to transpose and issue directives and regulations, the power to appoint inspectors, the power to protect public interest and consumers, the right of entry, and the power to impose administrative fines and penalties. The User(s) understands and accepts that these risks can have severe adverse effects on the Issuer. The User(s) understands and accepts that, subject to the Law, it has no right to recourse as a result of any loss due to circumstances under these sections. The same power are given to the Minister in the BVI for the Pre-Sale.

10.1 User(s)s shall be responsible to pay all applicable taxes and duties, if any, that may arise in connection with the acquisition of the Cryptoassets.

10.2 The Issuer bears no liability or responsibility with respect to any tax consequences to a User(s) arising from the subsequent sale of the Cryptoassets.

11.1 Upon using the Website you warrant that:

• you are over eighteen (18) years of age and are not classified as a 'minor' in your country of residence;
• you will not use the Website in any illegal, fraudulent, improper or immoral ways, or for any illegal, fraudulent, improper or immoral purposes;
• you will not use the Website in any manner prohibited under section 14 entitled 'Acceptable Use' below;
• you have the legal capacity to enter into these Terms of Use with BEPAY; and
• you shall not do or omit to do any such thing that shall be in breach of these Terms of Use.

12.1 When accessing or using the Website, you agree that you will not violate any law, contract, Intellectual Property or other rights. Without limiting the generality of the foregoing, you agree that you will not:

• use the Website in any manner which could interfere with, disrupt, negatively affect or inhibit other user(s) from fully enjoying the Website, or that could damage, disable, overburden or impair the functioning of said Website, in any manner;
• use the Website to fund, support or otherwise engage in any fraud, money laundering or terrorist activities, or any other illegal activities;
• use any robot, spider, crawler, scraper or other automated means or interface not provided by us to access the Website or to extract data;
• transmit, or attempt to transmit, any malware, virus, trojan, worm, timebot, cancelbot, corrupted file or other kind of malicious software or code to the Website;
• breach, or attempt to breach, any of the security measures imposed by BEPAY on this Website;
• attempt to access any service or area of our Website that you are not authorised to access;
• develop any third-party applications that interact with our Website, without our prior written consent;
• provide false, inaccurate, or misleading information;
• annoy, harass, threaten, intimidate or molest any BEPAY employee assisting you;
• copy, modify, reverse engineer, create derivative works or in any other way make any unauthorised use of the Intellectual Property;
• use the Website to cause damage or disrepute to BEPAY; and
• encourage or induce any third party to engage in any of the activities prohibited under this section 14.

13.1 To the extent allowed by law, BEPAY shall not be liable, in any event, for any direct, indirect or consequential damages, losses or liabilities whatsoever incurred or suffered by the User, or any third party, including, without limitation, damages for loss of profit, loss of information, business interruption, or loss of revenue or goodwill, as a result of or in connection with any of the following:

• any downtime or reduced service availability attributable to any third party;
• any instructions from the User received by BEPAY that contain incorrect, missing or improperly formatted information;
• any unforeseen circumstances or other circumstances outside of BEPAY's control preventing the proper performance of the Website despite any reasonable security precautions taken by BEPAY, including any event of Force Majeure; and/or
• any delay, failure or inability to perform any obligation under the Documents where the delay or failure results from any cause beyond the Issuer's reasonable control including any instance of Force Majeure.

13.2 Without prejudice to the provisions of section 15.1 directly above, to the extent allowed by law, in no event of a breach by BEPAY of these Terms of Use shall BEPAY's liability exceed €5,000.

13.3 To the maximum permitted by law, you agree to defend, indemnify and hold harmless the Company and each of its officers, directors, shareholders, members, partners, employees, attorneys, representatives and agents (collectively, the "Indemnified Parties") from and against any claims, actions, damages, losses, liabilities, expenses, penalties, fines, costs or demands, including legal fees (collectively, the "Losses"):

• arising as a direct or indirect result of your breach of these Terms of Use or the Documents; and
• arising out of or relating to a third-party claim concerning the Documents, including and without limitation to any claims related to taxes and duties mentioned.

13.4 This release and indemnity shall also cover any loss, damage, calls on capital, levies, taxes, fees, damages, costs, expenses or any other payments whatsoever which a User(s) may suffer or incur either directly or indirectly in connection with or arising out of:

• any delays, losses, misunderstandings, duplications, disclosures or other unintended results arising from electronic and human errors and risks associated with the use of electronic or other modern means of communication, on the understanding that both Parties shall endeavour to ensure the security and confidentiality of such communications;
• any such act or omission done or omitted thereby directly or indirectly upon instruction, advice or recommendation whether oral or written and howsoever received from the User(s) or from any agent, employee of, advisor to or representative of the User(s) provided always that the covenant for indemnity herein shall not extend to any act or omission in bad faith or gross negligence;
• generally, any act or omission whatsoever done or omitted thereby as an officer/employee of the User(s) except to the extent of these resulting from bad faith or gross negligence.

13.5 In the event that an arbitrator, court or tribunal, notwithstanding the provisions herein, finds against the Company and/or its employees, officers and subcontractors and awards damages against them in relation to a claim raised by a User(s), their total liability in damages, and/or extent of indemnification as the case may be, shall be limited to the Subscription Amount, if any, paid in the last calendar year.

13.6 Statutory Exceptions: Nothing in this Agreement shall exclude or restrict any liability of BEPAY resulting from: (i) death or personal injury; (ii) fraud, fraudulent misrepresentation, or fraudulent misstatement; and/or (iii) any statutory liability not capable of limitation.

13.7 Program Disclaimers: BEPAY shall not be liable for any loss arising from the operation, suspension, or termination of any Cashback Program, including fluctuations in the value of rewards issued in Digital Assets. Furthermore, BEPAY shall not be liable for any failed, delayed, or undelivered Email Payouts, including where the recipient fails to complete registration, verification, or comply with sanctions and AML requirements.

13.8 Malware and Phishing: BEPAY shall not bear any liability for any damage or interruptions caused by any computer viruses, spyware, scareware, Trojan horses, worms or other malware that may affect your computer or other equipment, or any phishing, spoofing, or other attack. It is your responsibility to use a 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 BEPAY.

13.9 Non-Reliance: Except for the express statements set forth in this Agreement, you hereby acknowledge and agree that you have not relied upon any other statement or understanding, whether written or oral, with respect to your use and access of the Services and Website.

14.1 Any and all Intellectual Property related in any manner whatsoever to the Website or BEPAY is the sole and exclusive property or controlled by BEPAY and is subject to protection under the applicable law.

14.2 The User is prohibited from copying, editing, amending, transmitting, distributing, displaying, modifying, adapting, sub-licencing, emulating, reverse-engineering, decompiling, disassembling, combining, processing, encoding, deriving source code, decrypting, translating, selling, or in any other way using any of the Intellectual Property, or the Website or any of its content or to create any derivative works of the Website or any of its content or functionality.

15.1 The acquisition of the Cryptoasset(s), and/or the use of the Cryptoassets are provided as outlined in the Documents, Policies, Whitepaper and/or this Website. The Company makes no representations of any kind, express, implied, statutory, or otherwise, regarding the acquisition of the Cryptoassets. The Company, its directors, officers, employees, agents, attorneys, representatives and associates do not accept any liability for any damage or loss, including loss of business, revenue, or profits, or loss of or damage to data, equipment or software resulting from any use of or inability to use the Cryptoassets, as well as from the acquiring of Cryptoassets, regardless of the basis, upon which the liability is claimed. User(s)s assume all risk of loss resulting from, concerning or associated with risks set forth in the Documents.

15.2 BEPAY does not provide investment advice of any kind. Any investment in or purchase of crypto assets is a risky action due to the volatility of the market, which may result in you losing a part or all of your investment, and other regulatory and technological risks and uncertainty. Thus, Bepay does not encourage, recommends or pursues any user, lead, customer, or investor to use its services or cryptoassets given the associated identified, declared and publicly announced potential risks, deficiencies and weaknesses of its products and services.

15.3 Such crypto assets are classified as Other Crypto Assets under MiCA, Cryptoassets under Maltese law, Virtual Assets in the UAE (Dubai) and the British Birgin Islands, and, as such, are not regulated under investment services legislation in the sense of traditional transferable equities, securities, or other financial instruments. In the BVI, virtual assets are seen as utility cryptoassets and the Pre-Sale operation is exempted as per the Guidelines of the FSC in and from the BVI.

15.4 Unless you are an Experienced Investor (as defined in the VFA Rulebook), you should consult with a professional advisor before investing in crypto assets.

15.5 Be aware that it is your full responsibility to use the correct details (e.g., wallet address, name, crypto-assets, blockchain or other DLT network) due to the irreversible and immutable nature of such transactions. In the unfortunate event of a transaction to the wrong wallet address, no refund will be possible as per the refund policy of BEPAY. Thus, BEPAY shall not be held liable under such circumstances and the user(s) to this cryptoasset allocation ("Pre-Sale") is solely responsible of his behaviour and conduct in this context, which (s)he confirms by accepting the Terms and Conditions of Use of this event or acting as (s)he understood the consequences of his decision by way of acting in such a manner.

15.6 BEPAY will use good faith efforts to facilitate Orders at the time that you place such Order, including the applicable fee and costs. However, from time to time, it may be necessary for BEPAY to delay facilitation of an Order until such time as we are able to execute the Order. In such cases, we will notify you prior to the completion of your Order of: (a) the amount of Digital Assets you will receive; and (b) the price at the time (including associated fees and costs).

15.7 BEPAY does not have any control over transaction times for the Digital Assets Network, and there may be instances where transaction times may take longer than usual. As such, you accept the risk that an Order facilitated by BEPAY may be delayed and you confirm that you will not hold BEPAY responsible for any losses, damages, or injury arising out of or related to such delay.

16.1 In line with its Privacy Policy, the Company values the User(s)'s privacy by not requesting any information that is unnecessary for the holding and use of the Cryptoassets. The Company may request information in order to abide with obligations under the applicable law. The Company is committed to preserving the privacy of the User(s) and is compliant with the General Data Protection Regulation (EU) 2016/679.

16.2 The Company commits itself to do its utmost to ensure that, its directors, officers, secretaries, employees, agents, attorneys, representatives, affiliates, and associates shall not disclose to any person, any non-public proprietary, documents or confidential information which may have been obtained as a result of the relationship between the Parties except to the extent necessary further to any law, regulations, rules or agreement.

16.3 Nevertheless, the Company shall be entitled, at any time, to request from the User(s) information and/or documentation that the Company, in its sole discretion, deems fit and necessary in order to comply with any applicable law or regulation in connection with the holding and using of the Cryptoassets. The User(s) agrees to provide the Company with such information promptly upon request and it acknowledges that the Company may not provide any assistance and/or services to the User(s) until it provides such requested information, and the Company has determined that it is permissible under applicable law or regulation. The Company reserves the right to require more KYC documentation in order to be compliant with the AML Regulations and/or any other laws and regulations that may come in force in the future.

16.4 Furthermore, the duty of confidentiality does not extend to communications in furtherance of an illegal purpose nor to documents or facts showing the commission of a crime or fraud. Moreover, the Company, in accordance with Maltese law, is subject to the duty (without informing the User(s)) to notify the competent authority in certain instances and the User(s) acknowledges that the Company is not bound by confidentiality obligations when the disclosure is necessary in the Company's opinion in order to protect its own interest.

16.5 The User(s)s further understands that pursuant to section 9.1(ix) of this Agreement, and any AML/CTF laws and rules that may bind the Custodian and its service providers, the Company is authorised to disclose KYC information and documentation on the User(s) to the Custodian's unhosted wallet address or bank (if and when applicable or required) as may be requested from time to time.

17.1 Nothing in these Terms of Use shall be deemed to constitute, create, imply, give effect to, or otherwise recognize a partnership, collaboration, agency, employment, joint venture or formal business entity of any kind, or any other similar relationship between yourself and BEPAY.

18.1 BEPAY reserves the right to charge fees for the products and services it offers. BEPAY may also earn rebate commissions from its onboarded third party agents, which provide their services via the decentralized marketplace of Bepay Money. These fees shall be communicated to the User via the dApp interface, email, or other electronic means.

18.2 BEPAY establishes that it shall charge a EUR 20 fee for opening a bank account through its services.

18.3 Exchange Orders and Visibility: The base fee for exchange Orders (acquire/sell/swap of Digital Assets) is 0.015% of the Order amount plus transactional expenses that may vary depending on the corresponding banking/network fees. All fees payable under this Agreement are displayed prior to the purchase or sale of Digital Assets by using the Services, and shall be paid in the applicable fiat currency. Please note, our fees are made clear to you at the point of sale, and at this point, you will be asked to confirm that you are clear about the fee and that, in proceeding, you agree to the fee before BEPAY facilitates the Order.

18.4 Chargebacks: BEPAY reserves the right to pursue any financial losses suffered due to your filing a chargeback procedure with your bank. These can include administration fees levied by the card acquirer and card schemes, as well as the monetary value of the Digital Assets.

18.5 Program Fees: BEPAY may introduce, modify, or waive fees for Cashback Program or Email Payout Services at its discretion. Any applicable fees will be communicated through the Site or Program Terms before they take effect.

18.6 BEPAY reserves the right to charge fees for the products and services it offers. BEPAY may also earn rebate commissions from all its onboarded third-party agents or partners, as mutually agreed upon under a single mutual NDA, which provide their services via the marketplace of Bepay. These fees shall be communicated to the User via the interface, email, or other electronic means.

19.1 You have 14 (thirty) calendar days to exercise your right of withdrawal from this Agreement, without having to justify any reason or pay any penalty. This withdrawal period begins on the day after the date that your application is accepted by us.

19.2 We will not usually provide the Services during the withdrawal period. Any Services or Orders that are fully performed before a withdrawal cannot be reversed.

19.3 You must notify us of your withdrawal request.

19.4 If you exercise your right of withdrawal, this Agreement will be terminated at no cost to you.

19.5 BEPAY reserves the right to modify, suspend, or terminate any Cashback Program or promotional campaign at any time without prior notice. Such termination shall not affect rewards already credited to a user's account, except where required by law or regulatory authority.

19.6 Order Finality: Once you have placed an Order and it has been sent to the Digital Assets Wallet, it cannot be canceled, recalled, or retrieved under any circumstances. All Orders are final and cannot be refunded.

19.7 Discharge of Obligations: You hereby agree that upon delivery, you will not be entitled to any credit or refund, and all purchases, sales, and swaps of Digital Assets are final. BEPAY's obligation towards you will be absolutely discharged upon the delivery of the Digital Assets to your Wallet or fiat funds to your bank account (where applicable), and you shall have no claim or right against BEPAY upon such delivery.

19.8 Loss and Fraud: As outlined in Section 15.5, Digital Assets transactions are irreversible and immutable. It is your sole responsibility to be vigilant of any fraud or mistake and to keep your private key safe. BEPAY will not take responsibility for issuing refunds, regardless of whether you were the victim of fraud, mistake, or loss of private key.

19.9 Swaps: If an order for a swap fails for any reason, including if we have to requote a swap quote to you because of price volatility and you reject the requote, then there will be an automatic refund to you, minus any applicable network fees.

19.10 Email Payouts: For Email Payouts, BEPAY may automatically refund the sender if the payout cannot be delivered or claimed within the designated period, if the recipient fails to complete verification, or if BEPAY determines the payout cannot be processed due to regulatory or technical reasons. Refunds will be made in the same Digital Asset originally sent, unless otherwise required by applicable law or operational constraints. If the recipient expressly declines to accept an Email Payout, the payout shall be automatically cancelled, and the funds returned to the sender in accordance with the same refund procedure.

20.1 You will be provided with security details from us, which will be needed in order for you to access your Account with us. You must keep all such security details (including usernames and passwords) private and not share such details with any third party.

20.2 You must monitor your Account and read all messages that have been sent to you. If you suspect that any feature of your Account (for example, login details, password, or other security feature) has been lost, stolen, misappropriated, used without authorisation, or otherwise compromised, you must contact us immediately notifying us of such action, and you agree to change your password immediately if necessary.

20.3 We will never ask you to share your password with us or with any third party, and you must never disclose this to anybody or allow someone to watch you when you are accessing your Account. It is advised that in order to keep your Account safe, you change your password regularly, as this will minimise the risk of your Account being compromised.

20.4 You must also ensure that your registered email account(s) are secure and can only be accessed by you, as your email address may be used in the process of resetting passwords, or we may send communications to your email account regarding the security of your Account with us. In case any of the email addresses registered with your Account are compromised, you should immediately contact us and also contact your email service provider once you have been made aware of this.

21.1 Should you encounter any problem when utilizing the Website, or wish to raise a complaint in relation to the same, kindly make use of and follow our Complaints Handling Process. For any other questions or remarks, please contact us. BEPAY is directly involved in actively listening to its user(s) for feedback implementation to provide the best, most suitable, and potentially desired features, products, services, and about the Website.

22.1 BEPAY reserves the right to make any changes to these Terms of Use at any given time without incurring any liability towards you or any third party. Any such updated Terms of Use shall become immediately applicable and enforceable upon publication on the Website and shall supersede any previously published Terms of Use. Should we be required by law, as set out in section 22 below, to obtain your consent or provide you with prior notice in respect of any such changes, we shall do so.

23.1 These Terms of Use shall be governed by the laws of BVI. Any disputes which may arise between yourself and BEPAY in relation to these Terms of Use shall be subject to the exclusive jurisdiction of the Netherlands Court of Arbitration as a last resort.

23.2 All disputes arising in connection with the present agreement, or further agreements resulting therefrom, shall be settled, first by mediation, or in accordance with the arbitration rules of Netherlands Commercial Court. The place of arbitration shall be Amsterdam (the Netherlands). The proceedings shall be conducted in English. Any court proceedings in the Netherlands before, during or after the arbitration will - to the extent allowed by law - exclusively be dealt with by the Amsterdam District Court or the Amsterdam Court of Appeal, whichever has jurisdiction, following proceedings in English before the Chambers for International Commercial Matters (Netherlands Commercial Court, which consists of the NCC District Court, the NCC Court in Summary Proceedings and the NCC Court of Appeal). The NCC Rules of Procedure (see www.ncc.gov.nl) apply to these proceedings. This clause is not intended to exclude Supreme Court appeal.

23.3 By the use of the website of bepay.com, acceptance of the specific T&C for the issuance and distribution of the cryptoassets, or general enjoyment of access to the protocol, the user freely, unequivocally, and voluntarily gives his or her valid consent for the general use of terms and conditions of the website, acknowledges the risk associated and accepts them and these terms and conditions of use. The user also acknowledged that these terms and conditions are easily and readily accessible for consultation. By raising no further question to BEPAY, the user declares and virtually indicates that (s)he deems himself/herself sufficiently, adequately and appropriately informed of his/her legal rights and obligations without consultation of the legal counsel of BEPAY or his/her own third-party counsel.

24.1 No exercise or failure to exercise or delay in exercising any right or remedy available to BEPAY under these Terms of Use will constitute a waiver by BEPAY of that or any other right or remedy available to it.

25.1 In the event that any provision, or part thereof, of these Terms of Use is found by a competent adjudicatory body or court of law to be invalid, unlawful or unenforceable to any extent, then such provision, or part thereof, shall be severed from the remainder of these Terms of Use, which shall continue to be valid and enforceable to the fullest extent permitted by law.

26.1 No assignment, novation, or transfer of any of the User's rights or obligations forming part of these Terms of Use, whether in whole or in part, is permitted, unless with BEPAY's express and prior consent.

27.1 Should a conflict of interpretation or application arise between these Terms of Use and the T&Cs, the terms contained in the latter shall prevail over these Terms of Use.

28.1 You acknowledge that we may process personal data in relation to you (if you are an individual) and personal data that you may provide to us in relation to your employees or associates or other individuals (if you are a legal person, such as a company) in connection with these Terms of Use and your use of the Website. We shall process this personal data in strict compliance with all data protection and data privacy laws, particularly Regulation (EU) 2016/679 (the General Data Protection Regulation or hereinafter: "GDPR"), and in accordance with our Privacy Policy. The aforementioned statements are to be amended in line with the GDPR review and continuous observance of guidelines and case law development, the EU's Data Governance Act, and other regulations and national laws dealing with data protection and privacy of user(s).