Terms of Service

These Terms of Service (these “Terms”) constitute a legally binding agreement between Univerra, S.A. de C.V. (hereinafter “VitaPay”, “we”, “us”, or “the Company”) and you (hereinafter “User”, “you”, or “your”) governing your access to and use of our platform, website, mobile applications, and any products and services offered through them (collectively, the “Services”).

By registering an account, accessing our platform, or using any of our Services, you confirm that:

• You have read, understood, and agreed to be bound by these Terms;
• You have read and understood our Privacy Notice, which is incorporated herein by reference;
• You have the legal capacity and authority to enter into this agreement; and
• If you are acting on behalf of a legal entity, you have the authority to bind that entity to these Terms.

If you do not agree to any provision of these Terms, you must not register an account or use our Services. If at any time you no longer agree to these Terms, you must immediately stop using our Services and close your account in accordance with Section 14.

These Terms, together with our Privacy Notice and any other policies or notices we may publish from time to time, constitute the entire agreement between you and VitaPay regarding your use of our Services.

In these Terms, the following capitalized terms shall have the meanings set forth below:

Univerra, S.A. de C.V. is a non-financial institution entity that, through its own or third-party operated electronic, digital, and similar platforms — managed and operated by the Company — provides, on a regular and specialized basis, virtual asset trading services. These services are aimed at facilitating, executing, and processing the Virtual Assets under our customers’ names, and include the provision of technical support services necessary for the custody, storage, and transfer of Virtual Assets.

Our business includes, in accordance with Applicable Law, transactions conducted abroad for Mexican citizens. For the purposes of our business scope, Virtual Assets refer to value carriers recorded in electronic form that are used among the public as legal trading and payment instruments, and that can only be transferred by electronic means. Legal tender, foreign currency, and any other assets denominated in legal tender or foreign currency do not constitute Virtual Assets.

We may enter into all lawful legal instruments and agreements, and conduct all types of supporting and ancillary business necessary or convenient for the achievement of our corporate purposes; provided that such business must be lawful and must not constitute business exclusively reserved for financial institutions or other licensed entities, unless the Company has obtained the corresponding operating license.

VitaPay is not a bank, financial institution, or money services business as defined under Mexican law, and the Services we provide are not banking services, deposit services, or financial intermediation services. We do not hold, manage, or control customer funds in legal tender on a banking or deposit-taking basis. Our Services are limited to Virtual Asset trading and related technical support.

4.1 Services We Provide

Through our Platform, we provide the following Services:

• Custody and Storage Technical Support: Providing the technical infrastructure and support services necessary for the custody and storage of your Virtual Assets, including wallet management, key management, and transaction monitoring.
• Transfer Technical Support: Providing the technical support necessary for the transfer of Virtual Assets to and from designated wallet addresses.
• Identity Verification: Conducting KYC verification for the purpose of complying with AML/CFT/AF regulations and providing our Services.

4.2 Services We Do Not Provide

We do not provide:

• Banking, deposit-taking, or financial intermediation services;
• Services involving legal tender or foreign currency that are exclusively reserved for financial institutions or other licensed entities;
• Investment advice, financial advice, or portfolio management;
• Guarantees regarding the value, liquidity, or marketability of any Virtual Asset;
• Services that are exclusively reserved for financial institutions or other licensed entities, unless we have obtained the corresponding operating license.

4.3 Availability and Modifications

We reserve the right to modify, suspend, or discontinue, temporarily or permanently, any of the Services (or any part thereof) at any time, with or without notice. We may also impose limits on certain features of the Services or restrict access to parts or all of the Services without notice or liability.

We may update the list of Virtual Assets available for trading on our Platform at any time, including adding, suspending, or delisting Virtual Assets. Such changes may be driven by regulatory requirements, risk assessments, liquidity considerations, or other business reasons.

4.4 Geographic Restrictions

The Services are primarily offered to users in Mexico and, in accordance with Applicable Law, to Mexican citizens conducting transactions abroad. The Services may not be available in all jurisdictions. You are responsible for ensuring that your access to and use of the Services complies with all Applicable Laws of your jurisdiction. If you access the Services from a jurisdiction where they are not authorized or permitted, you do so at your own risk and are solely responsible for compliance with local laws.

5.1 Eligibility

To create an Account, you must:

• Be at least 18 years of age;
• Have the legal capacity to enter into binding contracts under Applicable Law;
• Not be prohibited from using the Services under any Applicable Law or regulatory order;
• Not be listed on any Sanctions Lists;
• Not be a person or entity identified as a PEP without prior disclosure and approval;
• Not have been previously suspended or removed from the Platform by us.

If you are registering an Account on behalf of a legal entity, you represent and warrant that the entity is validly organized and existing under the laws of its jurisdiction, and that you have the full authority to bind such entity to these Terms.

5.2 Registration Process

To create an Account, you must provide accurate, complete, and current information, including but not limited to your full legal name, date of birth, nationality, residential address, email address, phone number, and tax residency. You must also create access credentials (such as a password) and complete the identity verification process described in Section 6.

5.3 Account Security

You are solely responsible for:

• Maintaining the confidentiality and security of your Account credentials, including passwords, PINs, one-time passcodes, and security questions;
• All activities that occur under your Account, whether authorized or unauthorized;
• Immediately notifying us of any unauthorized use of your Account or any other security breach.

We will never ask you for your password, PIN, or one-time passcode by phone, email, social media, or SMS. You should treat any such request as fraudulent and report it to us immediately.

5.4 Account Types

We may offer different types of Accounts, including individual, merchant, and institutional Accounts. Each Account type may have different features, limits, fees, and requirements, as described on our Platform or in Schedule I.

6.1 KYC Requirements

As part of our regulatory obligations under AML/CFT/AF laws and regulations, we are required to verify the identity of all Users before providing Services. The KYC process includes:

• Customer Due Diligence (CDD): Collection and verification of your identification information, including government-issued IDs (passports, driver’s licenses, or national IDs), proof of address, and other documentation as required.
• Enhanced Due Diligence (EDD): Additional verification for Users identified as PEPs, high-risk customers, or in other circumstances requiring enhanced scrutiny.
• Biometric Verification: Facial recognition and liveness detection to confirm your identity.

6.2 Ongoing Monitoring

We conduct ongoing monitoring of your Account and Transactions to detect and prevent suspicious activities, including money laundering, terrorist financing, fraud, and other illicit activities. This includes:

• Transaction monitoring for unusual patterns or suspicious activity;
• Screening against Sanctions Lists and PEP databases;
• Risk assessment and risk rating of Users and Transactions;
• Periodic re-verification of your identity information.

6.3 Your Cooperation

You agree to:

• Provide accurate, complete, and up-to-date information during the KYC process;
• Update your information promptly if any of it changes;
• Respond to our requests for additional information or documentation in a timely manner;
• Cooperate with any additional verification or risk assessment procedures we may require.

If you fail to complete the KYC process, provide false or misleading information, or refuse to cooperate with our verification procedures, we may suspend or close your Account and refuse to provide Services.

6.4 Reporting Obligations

We may be required by Applicable Law to report suspicious activities or Transactions to relevant authorities. Such reports are typically made on a confidential basis, and we will not notify you of such reports unless required by law.

7.1 General Obligations

You agree to:

• Comply with all Applicable Laws when using the Services;
• Provide accurate and truthful information in all interactions with us;
• Use the Services only for lawful purposes;
• Maintain the security of your Account and credentials;
• Pay all applicable fees and charges in accordance with Section 10;
• Cooperate with our KYC, AML, CFT, and AF procedures;
• Report any errors, bugs, or security vulnerabilities you discover to us promptly.

7.2 Prohibited Conduct

You are strictly prohibited from:

• Illegal Activities: Using the Services for money laundering, terrorist financing, fraud, tax evasion, or any other illegal activity;
• Sanctions Violations: Transacting with individuals or entities on Sanctions Lists, or with persons in embargoed or sanctioned jurisdictions;
• Market Manipulation: Engaging in any activity intended to manipulate the price, volume, or market for any Virtual Asset, including wash trading, spoofing, layering, or front-running;
• Fraud: Providing false or misleading information, using another person’s identity, or engaging in any fraudulent activity;
• Unauthorized Access: Attempting to gain unauthorized access to our Platform, systems, or other Users’ Accounts;
• System Abuse: Using bots, scrapers, automated scripts, or other automated means to access or use the Platform, except as expressly authorized by us;
• Malware: Introducing viruses, malware, or other malicious code to the Platform;
• Reverse Engineering: Attempting to reverse engineer, decompile, disassemble, or otherwise derive the source code of our Platform or any component thereof;
• Multiple Accounts: Creating multiple Accounts without our prior written consent;
• Account Transfer: Selling, leasing, lending, or otherwise transferring your Account or credentials to any third party;
• Violation of Others’ Rights: Infringing on the intellectual property, privacy, or other rights of any third party.

7.3 Consequences of Prohibited Conduct

If we determine, in our sole discretion, that you have engaged in any prohibited conduct, we may, without notice and without liability:

• Suspend or terminate your Account;
• Cancel, reverse, or freeze pending Transactions;
• Refuse to process future Transactions;
• Report your activities to relevant authorities;
• Take any other action we deem necessary to protect the integrity of our Platform, our Users, or the public.

8.1 Trading Process

When you initiate a Transaction on our Platform, the following process applies:

1. Order Submission: You submit an order specifying the Virtual Asset, quantity, price (for limit orders), and direction (buy, sell, or exchange).
2. Order Matching: Our matching engine processes your order against available counterparties or liquidity providers.
3. Execution: Once matched, the Transaction is executed and recorded on our Platform.
4. Settlement: Virtual Assets are transferred between accounts, and applicable fees are deducted.
5. Confirmation: You receive a confirmation of the completed Transaction.

8.2 Order Types

We may offer the following order types, subject to availability on our Platform:

• Market Order: An order to buy or sell Virtual Assets at the best available price.
• Limit Order: An order to buy or sell Virtual Assets at a specified price or better.
• Stop Order: An order that becomes a market order when a specified price level is reached.
• Other Order Types: Any additional order types we may introduce from time to time.

8.3 Transaction Finality

Once a Transaction is executed on our Platform, it is final and irrevocable. You cannot cancel, modify, or reverse a Transaction after it has been executed. This is particularly important for Transactions involving Blockchain transfers, as Blockchain records are immutable and cannot be changed or deleted.

WARNING: Virtual Asset Transactions, especially those involving Blockchain transfers, are irreversible. If you send Virtual Assets to the wrong wallet address, or if you provide incorrect transaction instructions, you may permanently lose your Virtual Assets. Always double-check wallet addresses and transaction details before confirming.

8.4 Transaction Limits

We may impose minimum and maximum Transaction limits, daily/monthly limits, and other restrictions on Transactions. These limits may vary based on your Account type, verification level, jurisdiction, and risk assessment. We may modify these limits at any time with or without notice.

8.5 Abnormal Market Conditions

During periods of extreme market volatility, system disruption, or other abnormal conditions, we may:

• Suspend or restrict trading in specific Virtual Assets;
• Widen spreads or adjust pricing;
• Cancel or modify pending orders;
• Temporarily halt all trading activities.

We will not be liable for any losses resulting from such actions.

8.6 Error Resolution

If an error occurs in the execution of a Transaction (e.g., incorrect pricing, duplicate execution, or system malfunction), we reserve the right to:

• Correct the error by adjusting your Account balance;
• Cancel or reverse the affected Transaction;
• Take any other action we deem appropriate to rectify the error.

You must report any suspected errors to us immediately upon discovery. Failure to report an error within 48 hours may affect our ability to resolve it.

9.1 Custody Model

We provide technical support services for the custody, storage, and transfer of your Virtual Assets through a combination of hot wallets and cold wallets:

• Hot Wallets: Connected to the internet and used for operational liquidity, enabling fast processing of Transactions. Only a limited portion of Virtual Assets is held in hot wallets at any time.
• Cold Wallets: Offline storage systems used for the majority of Virtual Assets, providing enhanced security against cyberattacks. Cold wallets are not directly connected to the internet and require multi-signature authorization for any transfer.

9.2 Your Wallet

When you create an Account, we assign you a designated Virtual Asset wallet address (or addresses) for each supported Virtual Asset. This wallet is managed by us on your behalf for the purpose of providing custody and transfer technical support services. You may also transfer Virtual Assets to and from external wallet addresses that you control.

9.3 Transfers

You may initiate transfers of Virtual Assets:

• Internal Transfers: Transfers to other VitaPay Accounts, using a VitaPay Wallet address, typically processed instantly.
• External Transfers (Withdrawals): Transfers to external wallet addresses, subject to security checks, network confirmations, and applicable fees.
• Deposits: Transfers from external wallet addresses to your VitaPay Account, subject to network confirmations.

9.4 Security Measures

We implement the following security measures for custody and transfer operations:

• Multi-signature authorization for cold wallet transactions;
• Multi-factor authentication for withdrawal requests;
• Whitelisting of withdrawal addresses (optional, user-configurable);
• Time-lock mechanisms for large withdrawals;
• AES-256 encryption for data at rest and TLS/HTTPS for data in transit;
• Real-time monitoring for suspicious activity;
• Regular security audits and penetration testing.

9.5 Risk Allocation

While we implement robust security measures, you acknowledge that:

• Virtual Asset custody involves inherent risks, including but not limited to cyberattacks, technical failures, and human error;
• Blockchain Transactions are immutable and cannot be reversed;
• We are not responsible for losses resulting from your failure to maintain the security of your Account credentials;
• We are not responsible for losses resulting from Transactions you authorize, even if such Transactions were based on incorrect information;
• We are not responsible for losses resulting from events beyond our reasonable control, including Blockchain network failures, forks, or congestion.

10.1 Fees

We charge fees for the use of certain Services. The applicable fees are described in Schedule I (Fee Schedule) and may include:

• Trading Fees: Fees for executing purchase, sale, and exchange Transactions, typically calculated as a percentage of the Transaction value.
• Transfer/Withdrawal Fees: Fees for processing external transfers (withdrawals), typically calculated based on the Virtual Asset and network conditions.
• Network Fees: Blockchain network fees (gas fees) for on-chain Transactions, which may be passed through to you.
• Other Fees: Any additional fees for specific services or features, as described on our Platform.

10.2 Fee Modifications

We may modify our fee schedule at any time. Changes will be effective on the date specified in the notice, which we will provide through our Platform or by email. Fee changes will apply only to Transactions executed after the effective date.

10.3 Taxes

You are solely responsible for determining and paying any taxes applicable to your use of the Services and your Transactions, including income tax, capital gains tax, value-added tax, and any other taxes. We are not responsible for determining, collecting, or remitting taxes on your behalf, except where required by Applicable Law. We may issue tax reports to you and/or to tax authorities as required by Applicable Law.

10.4 Fee Deduction

Unless otherwise specified, fees are automatically deducted from the relevant Transaction or your Account balance at the time of execution. You authorize us to deduct all applicable fees in this manner.

11.1 Our Rights

The Platform, including all software, code, interfaces, designs, logos, trademarks, service marks, text, graphics, and other content (collectively, “VitaPay IP”), is owned by VitaPay or its licensors and is protected by intellectual property laws. You may not use, copy, reproduce, modify, distribute, or exploit any VitaPay IP without our prior written consent, except as necessary to use the Services as contemplated by these Terms.

11.2 Trademarks

“VitaPay” and all associated names, logos, and marks are trademarks of VitaPay. You may not use any of our trademarks without our prior written consent.

11.3 Your Content

You retain ownership of any content you submit, upload, or provide to us through the Platform (your “User Content”). By providing User Content, you grant us a non-exclusive, worldwide, royalty-free license to use, process, and store your User Content for the purpose of providing the Services and complying with our legal obligations.

11.4 Feedback

If you provide any feedback, suggestions, or ideas regarding the Platform or Services, you grant us a perpetual, irrevocable, royalty-free license to use and incorporate such feedback into our products and services without any obligation to you.

RISK WARNING: TRADING IN VIRTUAL ASSETS CARRIES A HIGH LEVEL OF RISK AND MAY NOT BE SUITABLE FOR ALL USERS. YOU SHOULD CAREFULLY CONSIDER YOUR FINANCIAL SITUATION AND RISK TOLERANCE BEFORE USING OUR SERVICES.

You acknowledge and accept the following risks:

12.1 Price Volatility

Virtual Assets are subject to extreme price volatility. The value of Virtual Assets can fluctuate significantly in short periods and may lose all or a substantial portion of their value. We do not guarantee the value, liquidity, or marketability of any Virtual Asset.

12.2 Regulatory Risk

The regulatory environment for Virtual Assets is evolving and uncertain. Changes in laws or regulations in Mexico or other jurisdictions may affect the legality, availability, or value of Virtual Assets and our Services.

12.3 Technology Risk

The Services rely on complex technology, including Blockchain networks, cryptographic systems, and internet infrastructure. Technical failures, software bugs, cyberattacks, or other technology-related issues may result in service disruptions, Transaction errors, or loss of Virtual Assets.

12.4 Blockchain Risk

Blockchain Transactions are immutable and irreversible. If you send Virtual Assets to an incorrect address, or if a Blockchain network experiences a fork, attack, or other disruption, you may permanently lose your Virtual Assets. We cannot reverse Blockchain Transactions.

12.5 Liquidity Risk

There may not always be sufficient liquidity for you to buy, sell, or exchange Virtual Assets at your desired price. We do not guarantee the availability of counterparties or liquidity providers at any time.

12.6 Custody Risk

While we implement robust security measures, no system is 100% secure. Your Virtual Assets may be at risk in the event of a security breach, insider threat, or other unforeseen event. Our liability for losses is limited as described in Section 13.

12.7 No Investment Advice

We do not provide investment, financial, legal, or tax advice. Any information provided on our Platform is for general informational purposes only and should not be construed as advice. You should consult independent professional advisors before making any investment decisions.

12.8 Acknowledgment

By using the Services, you confirm that you have read, understood, and accepted all risks described in this Section and elsewhere in these Terms. You are using the Services voluntarily and at your own risk.

13.1 No Warranties

The Services are provided on an “as is” and “as available” basis, without warranties of any kind, whether express, implied, or statutory, including but not limited to warranties of merchantability, fitness for a particular purpose, title, and non-infringement. We do not warrant that the Platform will be uninterrupted, error-free, secure, or that defects will be corrected.

13.2 Limitation of Liability

To the maximum extent permitted by Applicable Law, in no event shall VitaPay, its directors, officers, employees, affiliates, agents, or licensors be liable for:

• Any indirect, incidental, special, consequential, or punitive damages;
• Loss of profits, revenue, Virtual Assets, or data;
• Business interruption or opportunity loss;
• Any damages resulting from your use of or inability to use the Services.

To the maximum extent permitted by Applicable Law, our total aggregate liability for all claims arising out of or relating to these Terms or the Services shall not exceed the total fees paid by you to us in the three (3) months preceding the event giving rise to the claim.

13.3 Excluded Limitations

The limitations in this Section 13 do not apply to liability that cannot be limited under Applicable Law, including liability for death or personal injury caused by negligence, fraud, or willful misconduct.

13.4 Indemnification

You agree to indemnify and hold harmless Vera to any third-party rights, your use of the Services; your breach of these Terms; your violation of any Applicable Law or third-party rights; your fraudulent, negligent, or wrongful conduct.

14.1 Breach

A breach of these Terms occurs when you violate any provision of these Terms, our Privacy Notice, or any other applicable policies. Examples of breach include but are not limited to:

• Providing false or misleading information;
• Engaging in prohibited conduct as described in Section 7.2;
• Failing to complete or cooperate with KYC procedures;
• Failing to pay applicable fees;
• Using the Services for illegal purposes.

14.2 Suspension

If we determine that you have breached these Terms or that your Account poses a risk to our Platform, other Users, or the public, we may, without prior notice:

• Suspend your Account, in whole or in part;
• Freeze pending or completed Transactions;
• Restrict certain features or functions;
• Require additional verification or information.

We will notify you of any suspension as soon as reasonably practicable, unless providing such notice would interfere with an investigation or would be prohibited by Applicable Law.

14.3 Termination by You

You may terminate your Account at any time by following the account closure procedure available on our Platform. Upon termination:

• You must withdraw all Virtual Assets from your Account to an external wallet address you control;
• We will close your Account after confirming a zero balance;
• We will retain certain personal data as required by Applicable Law, as described in our Privacy Notice.

14.4 Termination by Us

We may terminate your Account and these Terms at any time, with or without cause, by providing notice. Upon termination by us:

• You must immediately cease using the Services;
• You must withdraw all Virtual Assets within the period specified in the termination notice (not less than 30 days, unless termination is for cause);
• If you fail to withdraw within the specified period, we may transfer your Virtual Assets to a secure cold wallet and hold them for a specified period before treating them as abandoned.

14.5 Survival

The following provisions shall survive termination of these Terms: Sections 2 (Definitions), 7.3 (Consequences of Prohibited Conduct), 10 (Fees), 12 (Risk Disclosure), 13 (Liability), 14.5 (Survival), 15 (Data Protection), 18 (Dispute Resolution), and 19 (Miscellaneous).

Your personal data is processed in accordance with our Privacy Notice, which is incorporated herein by reference. By using the Services, you consent to the collection, use, disclosure, transfer, and processing of your personal data as described in the Privacy Notice.

Key aspects of our data practices include:

• Collection of personal data for KYC, AML/CFT/AF compliance, Transaction processing, and Service provision;
• Sharing of personal data with authorities, service providers, and other third parties as described in the Privacy Notice;
• Cross-border transfers of personal data, subject to appropriate safeguards;
• Retention of personal data in accordance with legal and regulatory requirements;
• Your rights regarding your personal data, as described in the Privacy Notice.

You may exercise your data protection rights by contacting our Data Protection Officer as specified in the Privacy Notice.

We shall not be liable for any failure or delay in performing our obligations under these Terms if such failure or delay is caused by an event beyond our reasonable control, including but not limited to:

• Natural disasters (earthquakes, floods, hurricanes, fires);
• War, armed conflict, terrorism, or civil unrest;
• Government actions, regulatory changes, or legal restrictions;
• Blockchain network failures, forks, or congestion;
• Internet or telecommunications failures;
• Cyberattacks or security breaches affecting our Platform or third-party systems;
• Pandemics, epidemics, or public health emergencies;
• Labor disputes or strikes.

In the event of a force majeure event, we will use commercially reasonable efforts to resume performance as soon as practicable. We will notify you of significant disruptions through our Platform or by email.

We may modify these Terms at any time by posting the updated version on our Platform. Changes will be effective on the date specified in the updated Terms. We will notify you of significant changes through our Platform, by email, or by in-app notification.

Your continued use of the Services after the effective date of any changes constitutes your acceptance of the updated Terms. If you do not agree to the updated Terms, you must stop using the Services and close your Account in accordance with Section 14.

We encourage you to review these Terms regularly to stay informed of any changes.

18.1 Governing Law

These Terms and any dispute arising out of or relating to them shall be governed by and construed in accordance with the laws of the United Mexican States, without regard to conflict of law principles.

18.2 Informal Resolution

Before initiating formal proceedings, you and we agree to attempt to resolve any dispute informally. You must first contact us with a detailed description of the dispute. We will respond within 30 days. If the dispute cannot be resolved informally within 60 days, either party may initiate formal proceedings.

18.3 Jurisdiction

Subject to Section 18.2, any legal action or proceeding arising out of or relating to these Terms shall be brought exclusively in the competent courts of Mexico City, Mexico. You consent to the personal jurisdiction of such courts and waive any objection based on forum non conveniens.

18.4 Class Action Waiver

You and we agree that each party may bring disputes against the other only on an individual basis and not as a plaintiff or class member in any class action or representative proceeding. You and we expressly waive any right to participate in a class action.

18.5 Equitable Relief

Notwithstanding the foregoing, either party may seek injunctive or other equitable relief in any court of competent jurisdiction to protect its intellectual property, confidential information, or other rights without first exhausting the informal resolution process.

19.1 Entire Agreement

These Terms, together with our Privacy Notice and any other policies incorporated by reference, constitute the entire agreement between you and VitaPay regarding your use of the Services and supersede all prior or contemporaneous agreements, communications, and understandings.

19.2 Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect. The invalid provision shall be replaced with a valid provision that most closely reflects the original intent.

19.3 No Waiver

Our failure to enforce any right or provision of these Terms shall not be deemed a waiver of such right or provision. A waiver must be in writing and signed by an authorized representative of VitaPay to be effective.

19.4 Assignment

You may not assign or transfer these Terms or your rights and obligations hereunder without our prior written consent. We may assign or transfer these Terms, in whole or in part, without your consent, including in connection with a merger, acquisition, or sale of all or a portion of our assets. Any attempted assignment in violation of this Section is void.

19.5 Notices

We will provide notices to you through our Platform, by email, or by in-app notification. You are responsible for keeping your contact information current. Notices to us should be sent to our contact details as specified in our Privacy Notice.

19.6 Language

These Terms are provided in both English and Chinese. In the event of any conflict or inconsistency between the two language versions, the English version shall prevail and control.

19.7 Electronic Acceptance

You acknowledge that your acceptance of these Terms by clicking “I agree” or by using the Services constitutes a valid electronic signature and has the same legal effect as a handwritten signature.

19.8 Relationship of the Parties

You and VitaPay are independent contractors. Nothing in these Terms creates any partnership, joint venture, agency, fiduciary, or employment relationship between you and us. Neither party has the authority to bind the other.

19.9 Third-Party Beneficiaries

Except as expressly stated in these Terms, there are no third-party rights to these Terms.

The following fees are current as of the date of these Terms and are subject to change in accordance with Section 10.2. Please refer to our Platform for the most up-to-date fee schedule.

Fees marked with [X]% are placeholders and should be updated with the actual fee rates before publication.