1.1. This User Agreement (hereinafter referred to as the Agreement) governs the terms of access to and use of WLUX hardware and software (hereinafter referred to as the Platform).
1.2. Any actions by the User to register for, sign in to, access the features of, or actually use the Platform shall constitute full and unconditional acceptance of this Agreement.
1.3. The User represents and warrants that they:
are acting in their own name and interests;
have full legal capacity;
and are independently making decisions when using the Platform.
2.1. The Platform constitutes an independent and neutral information technology service that is not an intermediary and that exclusively provides a software interface for Users to interact with, enabling:
users to post information and offers;
users to communicate with each other;
and a technical interface to display information related to digital assets.
2.2. The Platform does not participate in Users’ operations, does not control their actions, does not determine the terms or outcome of their interactions, and neither does it facilitate the execution of any transactions, settlements, or exchanges of assets.
2.3. The Platform is not a financial institution and does not engage in regulated financial activities, provide financial services, serve as payment infrastructure, or substitute banking or payment services.
2.4. The Platform has no access to, control over, or ability to dispose of cash funds, digital assets, or the means to access them.
2.5. The Platform does not:
provide access to Users’ wallets;
initiate, sign, or confirm transactions;
store private keys, seed phrases, or other access methods;
or provide clearing or settlement operations.
2.6. All operations involving digital assets are conducted by Users exclusively using third-party tools and infrastructure that is not controlled by the Platform.
2.7. The Platform does not provide functionality that enables Users to perform any settlements, transactions, or exchanges of cash funds or digital assets.
2.8. The Platform does not act as a representative, agent, attorney-in-fact, or other party acting in Users’ interests.
2.9. The Platform does not:
transfer cash funds;
accept, store, account for, or distribute cash funds;
act as a Platform for transferring cash funds;
act as a paying agent or bank paying agent;
or act to bring about settlements between Users.
2.10. The Platform is not a party in any monetary obligations between Users.
2.11. Any financial relations between Users, including settlements, the exchange of assets, reciprocal consideration, and the fulfillment of obligations, arise, are performed, and are terminated exclusively outside the Platform and without its involvement.
2.12. All actions performed by Users are done independently, on the Users’ own initiative, and free from any control, participation, or influence by the Platform.
2.13. The Platform reserves the right to modify, restrict, supplement, or discontinue specific functions of the Service at any time and to the extent permitted by applicable law.
2.14. The Platform reserves the right to restrict, suspend, or terminate a User’s access to the Platform or specific features thereof in the cases provided for by this Agreement or applicable law, or if doing so is necessary to protect the rights and legitimate interests of the Platform, other Users, or third parties.
2.15. Nothing within the Platform’s functionality, interface, communications, or user experience shall be construed as the Platform’s participation in any transactions between Users or as the provision of services related to transferring funds, exchanging assets, or other regulated activities.
3.1. The Platform solely provides the technical capability for Users to interact with one another.
3.2. The Platform does not initiate Users’ actions, does not propose specific scenarios for interaction, and does not encourage Users to perform any operations.
3.3. Users have the right to post and transmit information to other Users, including contact details and other data needed to interact, but the Platform does not determine the purpose or manner in which such information is used.
Such information is:
provided at the User’s initiative;
and used independently by Users.
3.4. The Platform does not select or match Users, does not participate in the negotiation of terms between Users, does not influence the content of said negotiations, does not monitor Users’ actions outside the Platform, and does not enforce the fulfillment of any agreements.
3.5. The User independently and at their own risk:
makes decisions regarding the performance of any actions, including actions outside the Platform;
assesses the consequences of such actions;
and bears responsibility for their actions and the results thereof, including the actions of third parties with whom they interact.
3.6. The User independently determines the legal classification of their actions and is obliged to ascertain the necessity of obtaining licenses or permits, or of complying with other legal requirements within their jurisdiction.
3.7. Use of the Platform does not constitute and shall not be construed as constituting the creation of any interconnection, interdependence, or single process or operation involving Users’ actions.
3.8. The User is entitled to use the Platform exclusively in accordance with its intended purpose, this Agreement, and applicable law.
3.9. The User is prohibited from:
using the Platform for purposes contrary to applicable law;
circumventing established technical, contractual, or legal restrictions;
using the Platform to conduct activities that require a license, registration, authorization, or other special status, without obtaining the necessary permits;
using the Platform for the benefit of third parties, if such use entails licensing or regulatory requirements or is subject to any other special legal regime;
coordinating actions aimed at performing operations with the characteristics of regulated activity;
providing false, misleading, or another person’s information;
impersonating another person or otherwise misrepresenting information about themselves;
violating the rights and legitimate interests of the Platform, other Users, or third parties;
gaining unauthorized access to the Platform, its parts, data, source code, infrastructure, other Users’ accounts, or related systems;
interfering with the operation of the Platform, disrupting its normal functioning, or engaging in automated data collection, scraping, parsing, reverse engineering, decompilation, or attempts to bypass security mechanisms, unless expressly permitted by binding provisions of law;
distributing malicious software, spam, false information, or materials that infringe upon the rights of third parties;
using the Platform to create a competing product or to extract data and materials for purposes unrelated to the regular use of the service;
using the Platform in a manner that could create the impression among third parties that the Platform acts as a participant, guarantor, operator, intermediary, or organizer of the User’s activities beyond its intended functions;
using the Platform in a manner whereby the interface, functionality, or User behavior creates the impression among third parties that settlements, the exchange of assets, the fulfillment of obligations, or the confirmation of results are taking place with the Platform’s participation;
or using the Platform in a manner aimed at organizing or facilitating settlements, the exchange of assets, or other regulated activities, including by creating the impression among third parties that it is possible to perform such actions via the Platform.
3.10. In the event of a violation of this section, the Platform reserves the right to take measures provided for by this Agreement and applicable law, including restricting or terminating access to the service.
3.11. The Platform reserves the right to conduct limited monitoring of the use of the Service solely to the extent necessary to ensure compliance with this Agreement, prevent abuse, and protect the Platform, without monitoring the content of Users’ interactions or participating in their actions.
3.12. Actions that create a risk of the Platform being used beyond its intended functions include, but are not limited to:
coordinating settlements between Users via the Platform’s interface;
posting instructions on transferring cash funds or digital assets that create the impression that such actions are part of the Platform’s functionality;
using the Platform to record, structure, or confirm the terms of interactions involving the exchange of assets;
and attempting to circumvent restrictions established by the Platform for the purpose of facilitating transactional interactions.
3.12.1. Actions that create a risk of the Platform being used beyond its intended functions also include scenarios in which one User fulfills another User’s obligation, provides reciprocal consideration on behalf of another User, or otherwise participates in structuring an exchange between Users via the Platform’s interface.
3.13. The Platform reserves the right to evaluate such actions based on their actual content and the user scenario, regardless of the terminology used or the manner in which it is presented.
3.14. In the event of the detection of User actions that:
create or may create the impression that the Platform participates in transactions between Users, including instances involving the exchange of assets, reciprocal consideration, or the fulfillment of an obligation by a third party,
are aimed at using the Platform as a tool for organizing settlements, exchanging assets, or other regulated activities,
or violate the restrictions established by this Agreement,
the Platform reserves the right, at its sole discretion, to take the following measures (including without prior notice):
Limiting functionality
Deleting content or information
Suspending access
Deleting the account
Blocking repeat registration
Other measures aimed at preventing violations
In cases provided for by applicable law, transferring information to authorized agencies
3.15. The application of the specified measures is aimed at maintaining the Platform’s status as a neutral technical service.
4.1. To use certain Platform features, the User may be required to create an account.
4.2. When creating an account, the User undertakes to provide accurate, complete, and current information and to keep it up to date to the extent that the corresponding functionality is available on the Platform.
4.3. Unless otherwise permitted by the Platform in writing, a single User is permitted to create only one account.
4.4. The User is solely responsible for the security of their login credentials, the confidentiality of their account access methods, and for any actions performed using their account, unless circumstances involving unauthorized access that arose beyond the User’s reasonable control are proven.
4.5. The User must immediately notify the Platform of any instance of unauthorized access to their account, loss of means of access, or any other security breach.
4.6. The Platform reserves the right to establish additional requirements for registration, access, account security, verification of contact details, or the use of specific service features.
4.7. The Platform reserves the right, at its sole discretion, to temporarily restrict, suspend, or terminate the User’s access to their account or to specific functions of the Platform if:
the User violates this Agreement;
there are indications of dishonest, unlawful, or unsafe use of the Platform;
the User’s actions create a risk to the Platform, other Users, infrastructure, or third parties;
or if the Platform must do so pursuant to legislative requirements, an act of an authorized agency, or to protect its rights and legitimate interests.
Furthermore, the Platform reserves the right to apply the specified measures, including to prevent the use of the Service for organizing settlements, the exchange of assets, or other regulated activities.
4.8. The User has the right to discontinue their use of the Platform and delete their account using the Platform’s functionality, if such functionality is provided, or by submitting a request to Support.
4.9. Deleting an account or terminating access to it does not automatically terminate User obligations arising prior to the date of account deletion or termination of access.
4.10. The Platform reserves the right to retain certain information following account deletion to the extent and for the duration necessary to comply with applicable laws, address claims, prevent abuse, ensure security, and protect the Platform’s rights.
5.1. The Platform reserves the right to process information about the User to the extent necessary to provide access to the Platform, ensure its functioning and security, address inquiries, and comply with applicable law.
5.2. By posting information on the Platform or transmitting it through the Platform’s functionality, the User understands and agrees that such information may become accessible to other Users to the extent determined by the User’s own actions and the service’s functionality.
5.3. The User independently determines the volume of information to be disclosed to other Users and bears the risk of the consequences of such disclosure.
5.4. The Platform bears no responsibility for the use of information by other Users after it is posted or transmitted via the Platform, if such use occurred beyond the Platform’s reasonable control.
5.5. The Platform does not identify, verify, or screen Users for the purposes of complying with financial, banking, or AML law, nor does it create User profiles for the purpose of assessing their trustworthiness or financial conduct, unless expressly required to do so by binding provisions of applicable law.
5.6. More detailed terms and conditions regarding the processing of User information — including data categories, purposes, legal bases for processing, retention periods, deletion procedures, the use of cookies, cross-border data transfers, and procedures for data subject inquiries — are set forth in the separate Privacy Policy, which constitutes an integral part of this Agreement.
5.7. The Platform reserves the right to remove, restrict, or otherwise process information posted by Users if such information could create the impression among third parties that the Platform is involved in settlements, the exchange of assets, or other regulated activities.
6.1. The Platform’s fee is solely associated with the provision of access to the Platform’s functionality and is independent of the fact, content, volume, value, occurrence, or outcome of any interaction between Users.
7.1. The Platform bears no responsibility for the actions of Users, the content and results of their interactions, or for any consequences arising from such actions.
7.2. The Platform bears no liability for the use of the Platform by Users in violation of applicable laws, including instances where such use may be classified as a regulated activity.
7.2.1. The Platform is entitled to take measures aimed at preventing the use of the service for purposes extending beyond its intended functionality and bears no liability for the consequences of applying such measures.
7.3. The User uses the Platform at their own risk.
7.4. The User undertakes to indemnify the Platform for any damages, expenses, fines, and other losses arising from the User’s breach of this Agreement or applicable law, to the extent permitted by applicable law.
7.5. The Platform does not:
warrant the fulfillment of Users’ obligations;
warrant uninterrupted operation;
ensure or warrant the possibility that Users may enter into or perform transactions;
participate in dispute resolution;
verify the accuracy of information posted by Users;
provide warranties or representations regarding Users or their actions;
provide consultations (including financial, legal, or tax advice), and the User must not rely on the Platform when making decisions;
warrant the good faith, legal capacity, or intentions of Users. The User interacts with other Users exclusively at their own risk.
7.6. There is no agency, fiduciary, or other similar relationship between the Platform and the User.
8.1. The User shall independently fulfill their tax obligations.
8.2. The Platform does not act as a tax agent and does not calculate, withhold, or remit taxes on Users’ behalf.
9.1. All exclusive rights to the Platform — including its software, databases, interfaces, design, texts, graphic elements, trademarks, logos, trade designations, domain names, as well as other products of intellectual activity and means of individualization — belong to the Platform and/or the respective rightholders.
9.2. The User is granted a limited, non-exclusive, non-transferable, and revocable right to use the Platform exclusively within the scope of its regular functionality and solely for the duration of the User’s use of the Platform in accordance with this Agreement.
9.3. Use of the Platform does not constitute the transfer to the User of any rights to the products of intellectual activity except for those specified in this Agreement.
9.4. Without the prior written consent of the Platform, unless otherwise permitted by binding provisions of law, the User is prohibited from:
copying, reproducing, adapting, distributing, publishing, or otherwise using elements of the Platform;
modifying, adapting, decompiling, disassembling, or otherwise investigating the Platform’s source code;
using proprietary designations, logos, trademarks, or other Platform objects;
or creating derivative products or services using the Platform or its elements outside of standard User functionality.
9.5. If a User posts information, materials, or content on the Platform, the User warrants that they possess the necessary rights and permissions to post such content and bear sole responsibility for it.
9.6. The User grants the Platform a royalty-free, non-exclusive, worldwide right to use materials posted by the User solely to the extent necessary for the Platform’s functioning, the display of such materials, technical processing, storage, transmission, and the protection of the Platform’s rights, unless the nature of the respective material indicates otherwise.
10.1. This Agreement shall be governed by and construed in accordance with the laws of the jurisdiction of the Platform’s registration, without regard for choice of law rules.
10.2. Notwithstanding Clause 10.1, the User is subject to the binding provisions of the laws of the jurisdiction where the User resides or conducts business.
10.3. The User undertakes, on their own initiative, to ensure compliance with all applicable legal requirements, including requirements related to licensing, taxation, the circulation of digital assets, and other regulated areas.
10.4. Nothing in this Agreement shall be construed as directing the Platform’s activities toward a specific jurisdiction, as offering services in the territory of a specific jurisdiction, or as the Platform engaging in regulated activities in any jurisdiction.
10.5. Prior to filing a claim with a court or other competent authority, the User undertakes to submit a written claim to the Platform using the contact details specified on the Platform, unless such a mandatory pre-trial dispute resolution procedure is excluded by applicable law.
10.6. The claim must contain:
information about the applicant;
a description of the details of the dispute;
specification of the right or legitimate interest that the applicant believes was violated;
the applicant’s demands;
and, if available, documents and other materials substantiating the circumstances asserted by the applicant.
10.7. The Platform reserves the right to request additional information and documents necessary to review the claim.
10.8. The timeframe for reviewing a claim is 30 calendar days from the date of its receipt, unless a different timeframe is stipulated by applicable law or is required by the nature of the inquiry.
10.9. If a dispute is not settled through the pre-litigation claims procedure, it shall be resolved by a competent court or other authorized agency in line with the procedures laid out by applicable law.
11.1. The User agrees to interact with the Platform electronically.
11.2. Any notifications, messages, documents, requests, responses, warnings, and other legally significant or informational communications may be sent to the User:
via the Platform’s interface;
by email;
by phone;
via push notification;
or by any other electronic means used by the User to interact with the Platform.
11.3. The User undertakes to ensure that their contact information remains up-to-date and that they can receive messages via such channels.
11.4. A communication shall be deemed to be received by the User from the moment it is dispatched by the Platform to the most recent contact information provided by the User or from the moment the communication is posted in the Platform’s interface, whichever occurs sooner, unless otherwise required by applicable law.
11.5. The User agrees that electronic messages and documents may be used as evidence during dispute resolution and that they shall have legal force to the extent permitted by applicable law.
12.1. In the event that any provision of this Agreement is found to be invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect.
12.2. The Platform reserves the right to amend this Agreement, as well as to modify, supplement, restrict, or discontinue specific functions, sections, or features of the Platform, to the extent permitted by applicable law.
12.3. An updated version of the Agreement shall enter into force when it is posted on the Platform, unless a different effective date is specified.
12.4. Continued use of the Platform after the changes enter into force constitutes the User’s consent to such changes, unless otherwise provided for by applicable law.
12.5. If the User does not agree to the new Terms, they must immediately stop using the Platform.
12.6. This Agreement, together with other documents expressly referred to herein, constitutes the entire agreement between the Platform and the User regarding use of the Platform.
12.7. The failure of the Platform to act in the event of a violation of this Agreement by the User shall not be construed as a waiver of such a violation in the future.
12.8. The User may not reassign their rights and obligations under this Agreement to third parties without the prior written consent of the Platform.
12.9. The Platform reserves the right to reassign its rights and obligations under this Agreement due to a reorganization, business restructuring, transfer of the relevant service, or other legal succession, unless otherwise prohibited by applicable law.
12.10. Section headings are provided solely for convenience and do not affect the interpretation of this Agreement.
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