* 3.3.5 Register as a member, expressing willingness to participate in the community established by HKD.com through various social media, including but not limited to WhatsApp, Telegram, WeChat and other groups. ### **4. Services** This website only provides online trading platform services for your digital asset trading activities (including but not limited to digital asset trading and other services) through this website. #### 4.1 Service Content * 4.1.1 You have the right to browse the real-time market and transaction information of various digital asset products on this website, and have the right to submit digital asset transaction instructions and complete digital asset transactions through this website. * 4.1.2 You have the right to view the information under your member account on this website, and have the right to operate the functions provided by this website. * 4.1.3 You have the right to participate in website activities organized by this website in accordance with the activity rules published on this website. * 4.1.4 Other services that this website promises to provide you. #### 4.2. Service Rules You undertake to abide by the following service rules of this website: * 4.2.1 You should abide by the requirements of laws, regulations, rules, and policies to ensure the legality of all sources of digital assets in your account, and shall not engage in illegal or other damage to this website or third parties on this website or using its services Rights and interests activities, including but not limited to sending or receiving any information that is illegal, illegal, or infringing on the rights and interests of others, sending or receiving pyramid schemes or other harmful information or remarks, using or forging email header information on this website without the authorization of this website Wait. * 4.2.2 You shall abide by laws and regulations and properly use and keep your account number, login password, fund password, mobile phone number bound to your registration, and mobile verification code received by your mobile phone. You are responsible for any operations and consequences of using your account and login password, fund password, and mobile phone verification codetake full responsibility. When you find that the account number, login password, or fund password or verification code of this website is used by a third party without your authorization, or there are other account security problems, you should immediately and effectively notify this website and request this website to suspend the service of this website account . This website has the right to take action on your request within a reasonable time, but this website does not assume any responsibility for the consequences that have occurred before taking action (including but not limited to any loss to you). You may not give, borrow, lease, transfer or otherwise dispose of your account on this website to others without the consent of this website. * 4.2.3 You agree to conduct all activities under your account and password on this website (including but not limited to information disclosure, posting information, clicking on the Internet to agree to or submitting various rules and agreements, online renewal of agreements or purchases) services, etc.) are liable. * 4.2.4 When you conduct digital asset transactions on this website, you must not maliciously interfere with the normal conduct of digital asset transactions or disrupt the transaction order; you must not interfere with the normal operation of this website or interfere with other users’ services to this website by any technical means or other means. use; shall not maliciously slander the goodwill of this website by fictitious facts and other means. * 4.2.5 If you have disputes with other users due to online transactions, you shall not request this website to provide relevant information through judicial or administrative channels. * 4.2.6 During your use of the services provided by this website, the taxable taxes, as well as all hardware, software, service and other expenses, shall be solely judged and borne by you. * 4.2.7 You should abide by this agreement and other terms of service and operating rules published and updated by this website from time to time, and have the right to terminate the use of the services provided by this website at any time. * 4.2.8 Services Provision and Transaction Management * 4.2.8 (a): Transaction Management and Abnormal Conditions In connection with the services rendered by HKD.com on the HKD.com Platform: We retain the exclusive authority to undertake, annul, rectify, recover, and/or reverse any transaction or transfer involving Digital Assets. This authority extends to nullifying unusual transaction outcomes at our sole discretion, even subsequent to the deduction of funds from your account(s). Such actions may be taken due to abnormal transactions, disruptions in the market, and other irregular circumstances stemming from, linked to, or arising from system malfunctions, platform system glitches, network breakdowns, distributed denial of service (DDoS) assaults, hacking incidents, and other unforeseen factors.\ \ Additionally, we reserve the right to execute these measures in response to legal requests such as subpoenas, court orders, or government directives. Should we suspect that a transaction is connected to money laundering, terrorist financing, fraudulent activities, or any form of financial misconduct, or if the transaction is determined to be erroneous or violates the stipulations outlined in these Terms, we retain the authority to act accordingly. For Futures, Peer-to-Peer (P2P) transactions, and Margin Lending, we maintain the prerogative to retroactively reverse all transactions occurring within a specified time frame, as delineated in the respective user agreement.\ \ In such occurrences, HKD.com will reverse the transaction in question and debit the corresponding Digital Assets from your account(s) in order to recuperate losses arising from said transaction. It is imperative to note that we are under no obligation to reinstate any purchase or sale order at the same terms or price as the annulled transaction. * 4.2.8 (b): Prohibition of Unfair Trading Behaviors
Furthermore, we categorically prohibit unjust trading practices. HKD.com reserves the unchallenged right, as determined at our sole discretion, to assume control of your account should you: (i) Engage in activities such as price manipulation, insider trading, market distortion, or other malevolent actions adversely affecting the market; (ii) Exploit vulnerabilities within the Service, or employ other unreasonable methods, with the intention of causing harm to other users or HKD.com; (iii) Participate in any activities that, in the estimation of HKD.com, pose a threat to the overall health of the market.
Moreover, we retain the authority to implement various actions, including but not limited to account closure, trading restrictions, trading halts, transaction cancellations, transaction rollbacks, and the restitution of pertinent Digital Assets to any aggrieved party, in order to mitigate any adverse impacts on the well-being of the market. Under no circumstances shall we be held liable for any losses incurred due to such actions taken against you. **4.3. Product Rules** * 4.3.1 Browsing transaction information When browsing transaction information on this website, you should carefully read all the contents contained in the transaction information, including but not limited to price, order volume, handling fee, buying or selling direction, you are fully After accepting all the content contained in the transaction information, you can click the button to conduct the transaction. * 4.3.2 Submitting the order After viewing the transaction information and confirming that it is correct, you can submit the order. After you submit the transaction entrustment, you authorize this website to conduct the corresponding transaction matching on your behalf. This website will automatically complete the matching transaction when there is a transaction that meets your entrusted price without notifying you in advance. * 4.3.3 View transaction details You can view the corresponding transaction records through your account. * 4.3.4 Cancellation/modification of the order, you have the right to cancel or modify the order at any time before the order is completed. ### **5. Rights and obligations of this website** 5.1 If you do not have the registration qualifications stipulated in this agreement, this website has the right to refuse your registration. If you have already registered, this website has the right to cancel your membership account. This website reserves the right to you or your The agent's right to be held accountable. At the same time, this website reserves the right to decide whether to accept your registration under any other circumstances. 5.2 According to the judgment of this website, when this website finds that you or your associated account users are not suitable for high-risk investment, it has the right to suspend or terminate your account and the use of all associated accounts. 5.3 This website has the right to suspend or terminate the use of the account when it finds that the account user is not the initial registrant of the account. 5.4 When this website reasonably suspects that the information provided by you is wrong, inaccurate, invalid or incomplete through technical testing, manual sampling and other testing methods, it has the right to notify you to correct or update the information or to suspend or terminate the provision of services on this website. . 5.5 This website reserves the right to correct any information displayed on this website if it finds any obvious error. 5.6 This website reserves the right to modify, suspend or terminate the services of this website at any time, and this website does not need to inform you in advance to exercise the right to modify or suspend services; if this website terminates one or more services of this website, the termination shall be made by this website Effective on the date the termination notice is posted on the website. 5.7 This website will take necessary technical means and management measures to ensure the normal operation of this website, and provide necessary and reliable trading environment and trading services to maintain the order of digital asset trading. 5.8 If you have not used the membership account and password of this website to log in to this website for one year in a row, this website has the right to cancel your account on this website. After the account is cancelled, this website has the right to open the corresponding member name to other users for registration and use. 5.9 This website protects the security of your digital assets by strengthening technical investment and improving security precautions, and will notify you in advance when there are foreseeable security risks in your account. 5.10 This website has the right to delete all kinds of content information on this website that do not comply with laws and regulations or the provisions of this website at any time, and this website does not need to notify you in advance to exercise such rights. 5.11 This website has the right to request you to provide more information or materials in accordance with the requirements of the laws, regulations, rules, orders and other norms of your sovereign country or region, and to take reasonable measures to comply with local norms You are obliged to cooperate; this website has the right to suspend or permanently stop opening some or all of the services of this website to you according to the requirements of the laws, regulations, rules, orders and other norms of your sovereign country or region. ### **6. Compensation** 6.1 In no event will our liability for direct damages to you exceed the total service fee we charge you for your use of this website for a period of three (3) months. 6.2 If you violate this agreement or other laws and regulations, you must compensate us at least USD 2 million and bear all the costs (including attorney fees, etc.) arising therefrom. If it is not enough to cover the actual loss, you must make up Complete. ### **7. The right to seek injunctive relief** We and you both acknowledge that common law remedies for your breach or possible breach may not be sufficient to cover all of our losses, so we have the right to seek injunctive relief and common law or possible breach in the event of your breach or possible breach all other remedies permitted in equity. ### **8. Limitation of Liability and Disclaimer** 8.1 You understand and agree that under no circumstances shall we be liable for: * 8.1.1 Loss of income; * 8.1.2 Trading profits or contract losses; * 8.1.3 Losses due to business interruption; * 8.1.4 Loss of expected monetary savings; * 8.1.5 Losses caused by information problems; * 8.1.6 Loss of opportunity, goodwill or reputation; * 8.1.7 Corruption or loss of data; * 8.1.8 The cost of purchasing substitute products or services; * 8.1.9 any indirect, special or incidental loss or damage arising out of tort (including negligence), breach of contract or any other cause, whether or not such loss or damage could be reasonably foreseen by us; whether or not we be advised in advance of the possibility of such loss or damage. Clauses 8.1.1 to 8.1.9 are independent of each other. 8.2 You understand and agree that we shall not be liable to you for any damages arising from any of the following: * 8.2.1 Your specific transaction may have a material violation of law or breach of contract. * 8.2.2 Your conduct on this website is suspected of being illegal or immoral. * 8.2.3 Expenses and losses arising from the purchase or acquisition of any data, information, or transactions, or alternative behaviors through the services of this website. * 8.2.4 Your misunderstanding of the services of this website. * 8.2.5 Any other loss related to the services provided by this website which is not caused by us. 8.3 We are not responsible for the maintenance of information network equipment, information network connection failure, computer, communication or other system failure, power failure, weather, accidents, strikes, labor disputes, riots, uprisings, riots, productivity or means of production Deficiencies, fires, floods, storms, explosions, wars, bank or other partner causes, digital asset market crashes, government actions, orders of judicial or administrative authorities, other acts or other acts beyond our control or our ability to control. We do not assume any responsibility for the inability or delay of service due to third-party reasons, as well as for your losses. 8.4 We cannot guarantee that all the information, programs, texts, etc. contained in this website are completely safe, and will not be interfered and destroyed by any malicious programs such as viruses and Trojans. Any programs, information, data, etc., are your personal decisions and bear your own risks and possible losses. 8.5 We do not make any guarantees and commitments for any information, products and business of any third-party website linked in this website, or any other content that does not belong to our subject. Services, information and products are all determined by you personally and assume all responsibilities arising therefrom. 8.6 We do not make any express or implied warranties for your use of the services of this website, including but not limited to the applicability of the services provided by this website, the absence of errors or omissions, continuity, accuracy, reliability, suitability for a certain specific use. At the same time, we do not make any promises and guarantees for the validity, accuracy, correctness, reliability, quality, stability, completeness and timeliness of the technology and information involved in the services provided by this website. Whether to log in or use the services provided by this website is your personal decision and is at your own risk and possible losses. We do not make any express or implied guarantee for the market, value and price of digital assets. You understand and understand that the digital asset market is unstable, and prices and values may fluctuate or collapse at any time. Trading digital assets is your personal freedom Choose and decide at your own risk and possible losses. 8.7 Our warranties and undertakings set out in this Agreement are our sole warranties and representations with respect to this Agreement and the services provided by this website, and supersede any warranties and undertakings arising from any other means and means, whether in writing or Oral, express or implied. All such warranties and representations represent only our own promises and warranties and do not guarantee that any third party will comply with the warranties and promises contained in this Agreement. 8.8 We do not waive any rights not mentioned in this Agreement to limit, exclude or set off our liability for damages to the fullest extent applicable by law. 8.9 By registering, you agree to any operation we perform in accordance with the rules set forth in this agreement, and any risk arising therefrom shall be borne by you. ### **9. Termination of the agreement** 9.1 This website has the right to terminate all services of this website in accordance with this agreement. This agreement shall be terminated on the day when all services of this website are terminated. 9.2 After the termination of this agreement, you have no right to require this website to continue to provide it with any services or perform any other obligations, including but not limited to requiring this website to retain or disclose to you any information in its original website account, Forward any information, etc., to you or a third party that they have not read or sent. 9.3 The termination of this agreement does not affect the non-compliance party's requirement to undertake other responsibilities. ### **10. Intellectual Property** 10.1 All intellectual achievements contained in this website include but are not limited to website logos, databases, website designs, text and graphics, software, photos, videos, music, sounds and combinations thereof, software compilation, related source code and software The intellectual property rights (including applets and scripts) are owned by this website. You may not reproduce, alter, copy, transmit or use any of the foregoing materials or content for commercial purposes. 10.2 All rights (including but not limited to goodwill and trademarks, logos) contained in the name of this website are owned by the company. 10.3 Your acceptance of this agreement shall be deemed that you voluntarily own the copyright of any form of information you publish on this website, including but not limited to: reproduction rights, distribution rights, rental rights, exhibition rights, performance rights, exhibition rights, Broadcasting rights, information network dissemination rights, filming rights, adaptation rights, translation rights, compilation rights and other transferable rights that should be enjoyed by the copyright owner are exclusively assigned to this website for free. Get full compensation. The validity of this agreement applies to any content of works protected by copyright law that you publish on this website, whether the content is formed before or after the signing of this agreement. 10.4 You shall not illegally use or dispose of the intellectual property rights of this website or others in the process of using the services of this website. You may not publish or authorize other websites (and media) to use the information published on this website in any form. 10.5 Your access to this website or use of any services provided by this website shall not be deemed as an assignment of any intellectual property rights by us to you. ### **11. Information Protection** Subject to the stipulations of the "Privacy Policy" separately published on this website. ### **12. Calculation** All transaction calculation results have been verified by us, and all calculation methods have been published on the website. The use of the website is guaranteed to be uninterrupted or error-free. ### **13. export control** You understand and acknowledge that in accordance with the relevant laws of Seychelles, you may not export, re-export, import or transfer any material (including software) on this website, so you warrant that you will not actively commit or assist or participate in any of the above violations Exports or related transfers or other violations of applicable laws and regulations; if such situations are found, they should promptly report to us and assist us in handling them. ### **14. Transfer** The rights and obligations stipulated in this Agreement also govern the assignees, heirs, executors and administrators of the parties who derive benefits from such rights and obligations. You may not assign to any third party without our consent, but we may assign our rights and obligations under this Agreement to any third party at any time with notice to you. ### **15. Divisibility** If any provision of this Agreement is found to be unenforceable, invalid or illegal by any court of competent jurisdiction, this does not affect the validity of the remaining provisions of this Agreement. ### **16. non-agency relationship** Nothing in this Agreement shall be deemed to create, imply or otherwise treat us as your agent, trustee or other representative, except as otherwise provided in this Agreement. ### **17. Abstaining** A waiver by us or either of you of any breach of contract or other liability under this Agreement shall not be deemed or construed as a waiver of other breach of contract; the failure to exercise any right or remedy shall not be construed in any way as a Waiver of Rights or Remedies. ### **18. Title** All headings are provided for convenience only and are not intended to expand or limit the content or scope of the terms of this agreement. ### **19. Applicable Law** The entire contents of this agreement are concluded in accordance with the laws of Seychelles, and its establishment, interpretation, content and implementation shall be governed by the relevant laws of Seychelles; any claims or lawsuits arising from the services agreed in this agreement shall be governed by Seychelles laws the laws governing, interpreting and enforcing. For the avoidance of doubt, this clause expressly applies to any claim of infringement against us. The competent court or forum for any claim or action against or in connection with us shall be in Seychelles. You unconditionally acquire exclusive jurisdiction to litigate and appeal in the courts of Seychelles. You also unconditionally agree that disputes or issues related to this agreement or any claims and lawsuits arising from this agreement shall be exclusively located in Seychelles, and if other businesses of this website have a special agreement on jurisdiction, such agreement shall prevail. The principle of forum non-convenience does not apply to the court chosen under these Terms of Service. ### **20. Effectiveness and Interpretation of the Agreement** 20.1 This agreement takes effect when you click on the registration page of this website to agree to register, complete the registration process, and obtain the account and password of this website, and are binding on this website and you. 20.2 The final interpretation right of this agreement belongs to this website. ## **Know Your Customer and Anti-Money Laundering Policy** ### **I. Introduction** 1.1 We pledge to prudently comply with "Know Your Customer" and Anti-Money Laundering related laws and regulations and shall not knowingly violate this "Know Your Customer and Anti-Money Laundering Policy". Within the scope of our reasonable control, we will take necessary measures and technologies to provide you with safe services, so as to protect you from the losses caused by the money laundering of criminal suspects as much as possible. 1.2 Our know-your-customer and anti-money laundering policy is a comprehensive international policy system, including the know-your-customer and anti-money laundering policies of the different legal jurisdictions to which you belong. ### **2. Know your customer and anti-money laundering policies are as follows:** 2.1 Promulgate know-your-customer and anti-money laundering policies and update them from time to time to meet the standards set by the corresponding laws and regulations; 2.2 Promulgate and update some guidelines and rules for the operation of this website, and our staff will provide services in accordance with the guidelines and rules; 2.3 Design and complete procedures for internal monitoring and control of transactions, such as verifying identity by strict means, and arranging the formation of a professional team dedicated to anti-money laundering; 2.4 Conduct due diligence and ongoing monitoring of customers using a risk-prevention approach; 2.5 Review and regularly review transactions that have occurred; 2.6 Report suspicious transactions to competent authorities; 2.7 Proof of identity, address and transaction records will be maintained for a minimum of six years if submitted to regulatory authorities without prior notice to you. ### **3. Identity information and verification** 3.1 Identity Information * 3.1.1 According to different regulations in different jurisdictions and different types of entities, the content of your information collected by us may be inconsistent. In principle, the following information will be collected from registered individuals: Basic personal information: your name, Residential address (and permanent address, if different), date of birth and nationality, etc., as other information may be available. Authentication should be based on documents issued by official or other similar authorities, such as passports, ID cards or other identification documents required and triggered by different jurisdictions. The address you provide will be verified using appropriate methods, such as checking passenger transport bills or rate bills or checking the voter register. Valid photo: Before you register, you must provide a photo of you holding your ID on your chest; Contact: Phone/mobile number and/or valid email address. * 3.1.2 If you are a company or other legal entity, we will collect the following information to identify you or the ultimate beneficiary of the trust account. Company registration and registration certificate; a copy of the company's articles of association and memorandum; detailed certification materials of the company's shareholding structure and ownership statement, proving the decision to open an account on this website and the implementation of the board resolution of the authorized client; company directors as required , the identity document of the major shareholder and the authorized signatory of the account on this website; the main business address of the company, if it is different from the company's mailing address, provide the mailing address. If a company's local address is inconsistent with its principal business address, it is considered a higher risk client and needs to submit additional additional documents. Documents issued by other certifications and authorities required by us and documents we deem necessary according to different regulations in different jurisdictions and different types of entities. * 3.1.3 We only accept identity information in English or Chinese. If not, please translate your identity information into English and notarize it. 3.2 Confirmation and verification * 3.2.1 We ask you to provide the full page content of your identification document. * 3.2.2 We ask that you provide a photo of you holding your identification document on your chest. * 3.2.3 Copies of supporting documents should generally be checked against the original documents. However, a copy is acceptable if a reliable and appropriate certifier can certify that the copy is an accurate and complete reproduction of the original. Such certifiers include ambassadors, judicial commissioners, magistrates, etc. * 3.2.4 The requirement to identify ultimate beneficiaries and account control is to identify which individuals ultimately own or control the direct customer, and/or identify that ongoing transactions are performed on behalf of others. In the case of a business, the identity of major shareholders (such as those holding 10% or more voting interest) should be verified. Generally, holding 25% of the shares will be considered as normal risk, and its shareholder identity must be verified; if holding 10% of the shares or having more voting rights or shares, it is considered high risk, and the shareholder identity must be verified. ### **4. Monitoring transactions** 4.1 We set and adjust the daily transaction and withdrawal maximum limit from time to time according to security and actual transaction conditions; 4.2 If the transactions are frequently concentrated on a registered user or there is an unreasonable situation, our professional team will evaluate and decide whether they are suspicious; 4.3 We may take restrictive measures such as suspending the transaction, rejecting the transaction, and even reversing the transaction as soon as possible, and reporting to the competent authority at the same time, and reporting to the competent authority at the same time. inform you; 4.4 We reserve the right to refuse registration applications from persons in jurisdictions that do not meet international anti-money laundering standards or who could be considered politically exposed persons Doing so does not violate any obligations and responsibilities towards you. ## Withdrawal Limitation and Processing Time Policy ### 1. Withdrawal Limitation using the Even Distribution Method In certain unforeseen circumstances, which may include but are not limited to increased withdrawal requests or market volatility, HKD.com Limited ("HKD.com") may, at its sole discretion, implement a withdrawal limitation using the Even Distribution Method. This mechanism aims to ensure fairness and equal access to available cryptocurrency assets for all our valued users without compromising the overall stability and security of our platform. ### 2. Withdrawal Processing Time Adjustment During the implementation of the withdrawal limitation using the Even Distribution Method, the standard withdrawal processing time may be subject to adjustments. Under such circumstances, HKD.com reserves the right to extend the withdrawal processing time to a maximum of 30 days. This extension allows us to effectively manage and process withdrawal requests while maintaining the security and integrity of our platform. ### 3. Special Case: Uniformity Principle HKD.com adheres to the Uniformity Principle to ensure that all users are treated fairly and equitably during periods of increased withdrawal demand or exceptional market conditions. This principle underscores our commitment to providing a level playing field for all users, regardless of the specific situation. ### 4. Evenly Distributed Understanding Principle Our Evenly Distributed Understanding Principle reflects our dedication to transparency and clear communication with our users. We strive to provide you with comprehensive information and updates regarding any changes to our withdrawal processes, ensuring that you are well-informed and understand the measures we may implement to protect the interests of all users.\ \ By using our platform and services, you agree to abide by the terms outlined in this section and acknowledge that HKD.com may employ the Even Distribution Method and adjust withdrawal processing times as deemed necessary to safeguard the interests of our client community. We remain committed to maintaining the security, stability, and fairness of our cryptocurrency exchange platform, and we appreciate your understanding and cooperation in these matters.
# Privacy Policy ### 1. Both parties 1.1 HKD.com (hereinafter referred to as the "Company") operates the website
### **Canada MSB License**
.png?alt=media&token=f1f1c214-e09a-46e9-9028-451869c3cfb9)
.png?alt=media&token=7e40e310-c297-4c0f-96ea-cd3559ac89c4)
#### 1.2 Read and Accept terms of Agreements Unless you have read and accepted all the terms of this Agreement, you are not authorized to use The Fixed Staking Service and its corresponding Services. Your acceptance of this Agreement and your use of the Service represents that you have read and agreed to this Agreement and that this Agreement is legally binding on you. ### 2. Definitions * T Day: A natural day based on Singapore time (UTC+8). * Fixed Staking: The User will stake and freeze a certain amount of an agreed digital asset in HKD.com. During the staking period, the User will not be able to trade the staked and frozen digital asset in the User’s Account. * Redemption: The redemption of the staked and frozen digital asset takes T+N days to deliver to transfer to the User’s Account. * Transfer-in: The User transfers a certain amount of digital asset in the User’s Account to the User’s relevant sub-account for Staking. * Transfer-out: The User transfers a certain amount of digital asset from the User’s Account to the User’s relevant sub-account. * Staking Period: The time period for the User to stake the digital asset. If you stake your digital asset on T day (HKT) and redeem it between 0:00 to 24:00 on T+N day, your staking period is n-1 days. If you choose a fixed staking period, it is agreed that after the staking period expires, the User can redeem the staked digital asset into the User’s Account. In the case where the staking period is flexible, the User can redeem the staked digital asset at any time to the User’s Account.
### 3. Eligibility to Use the Service #### 3.1 You understand and confirm: * You have agreed to abide by the “Staking Service Terms and Conditions” and you are eligible and not to be prohibited from using the Services defined therein; * If you are registering the Service in your personal capacity, in order to accept this Agreement effectively, you must be at least 18 years old, with full civil rights and civil capacity, and have all the necessary authorities and abilities to sign this Agreement. Once signed, it is binding on you; * If you are registering to use the Service on behalf of a legal entity, in order to accept this Agreement effectively, you declare and guarantee that (i) such legal entity is legally established and valid in accordance with applicable laws; (ii) you are duly authorized by the legal entity to have the right to act on their behalf. * You have the experience and risk tolerance of using the service and have the experience and knowledge to invest in non-guaranteed digital currency products; * In order to use the Service, you have the ability to perform operations on the Internet; * This Agreement does not conflict with the laws of your country or region, and you promise that you will comply with the laws of your country or region; * You are the legal owner of the digital assets in your HKD.com Account and guarantee that the sources of these digital assets are legal. #### 3.2 You agree and promise: * You will not use the Service for any illegal purposes, including but not limited to illegal gambling, money laundering, fraud, extortion, extortion, data breaches, terrorist financing, and any other violent activities or any businesses prohibited by the law. * You will not conduct, initiate or promote any forms of market manipulation or other forms of illegal conduct, including but not limited to illegal gambling, money laundering, fraud, extortion, extortion, data breach, terrorist financing, and any other violent activities or businesses prohibited by the law. #### 3.3 You understand and accept the risks that may arise to you and the related losses you may suffer from using the Service, including but not limited to: * The risks you may suffer from the risks associated with the inability to trade the staked digital assets. You are willing to bear the funding risks and potential financial losses caused by staking; * The expected yield displayed on the HKD.com website is the theoretical estimation of yield instead of the actual yield guaranteed or promised by HKD.com. The actual yield may vary from the expected yield. Your final yield will be based on the actual yield you receive. HKD.com will deduct the cost, fees, and expenses related to the operation of Staking (including but not limited to the server fees, electricity fees, etc.) as well as the handling fees for Staking from your actual yield of Staking to determine your final yield. HKD.com does not make any guarantee or promise to the actual yield that you may receive; * High price fluctuations of digital assets and their derivatives may cause significant or total losses in a short period of time; * Technical anomalies may occur, which may delay or prevent you from using the Service or performing related transactions and result in losses of your digital assets; * Market anomalies may occur, which may result in losses of your digital assets; * In order to maintain the overall health of the market, HKD.com is required to add, remove, or change the policies, the terms of this Agreement, or other relevant service agreements or terms from time to time. Such behavior may benefit or harm individual customers like you. ### 4. Use of this Service 4.1 You can make commands, such as Staking, through the HKD.com staking page. Once the command is set, you will not be able to cancel or edit it. 4.2. When your assets are successfully locked up, you agree to entrust and authorize HKD.com to perform certain actions to a certain amount of digital assets in your account, including but not limited to node voting and digital asset gain. 4.3 Staking rules: If a User stakes an asset before 24:00 on T-1 day (HKT, UTC+8), the User’s yield will be calculated starting from the T day. From the T+1 day, the yield will be settled and distributed on a periodic basis. All profits will be distributed to your Account. HKD.com reserves the right of the final and only interpretation of the Staking Rules, yield calculation method, profits distribution, yield calculation period, and other relevant contributions to the staking rules. 4.4 Redemption rules: If a User selects “flexible access” for the staking period, the User can redeem after entering the redemption command. The redeemed digital asset might take T+N days to arrive at the User’s account, depending on the token type. If the staking period is fixed, the User should redeem after it expires. The redeemed digital assets may arrive at the User’s account after T+N days, depending on the token type. You understand and agree that between the redemption date and the actual arrival date, you will not be able to make any profits, transfer, or other commands to the redeemed digital assets. You understand and accept that the actual date for the redeemed digital assets to arrive in your account may vary. The arrival time shown on the website is final. There is currently no ‘flexible access’ offered on HKD.com; all staking products available are fixed staking. 4.5 Default Settlement: If a User request to redeem the digital assets frozen for Staking before the expiration of the Fixed Staking Period, HKD.com, at our discretion, will pay you the applicable amount based on the principal balance in the lock-up profit account. Additional interest and administrative fees will be charged by HKD.com to User. The administrative fees will be the lock-up income between the fixed staking expiration date and the withdrawal date. “Principal Balance” means a certain amount of digital assets being frozen in the User’s Account for the purpose of using the Staking service. ### 5. Liabilities 5.1 You agree and accept that the User’s estimated yield displayed on the HKD.com website is an estimation but not a guaranteed or promised actual yield. The actual yield may not meet or may be lower than the estimated yield. Your final yield will be based on your actual yield. HKD.com does not promise or guarantee your estimated yield or actual yield you will receive. 5.2 You agree and accept that when you redeem your assets, the time it takes for the digital assets to arrive at your account may vary, and the arrival displayed on the website is final. HKD.com shall not be liable for any losses caused by the digital asset arrival time difference. 5.3 You agree and accept that HKD.com reserves the right to amend the content of this Agreement anytime in its sole discretion. HKD.com shall not be liable for any losses due to your misunderstanding of this Agreement, or your delay in reading the amendments to this Agreement. 5.4 You agree and accept that if the HKD.com platform cannot function properly or the Service is interrupted due to the following conditions, such that you are unable to use the Services or cannot make commands or perform related trading operations, including but not limited to failure, delay, interruption, no system response, delayed system response or any other abnormal circumstances, HKD.com shall not be liable to any losses. These circumstances include but are limited to the following: * Service suspension for maintenance as announced by HKD.com; * System failure to transmit data; * Force majeure or accidents, such as typhoon, earthquakes, tsunamis, flooding, plague, power outage, war, turmoil, government actions, terrorist attacks, etc. that lead to the suspension of the HKD.com platform; * Service interruption or delay due to hacking, computer virus, technical adjustment or failure, website upgrade, banking issues, temporary closure due to government regulations, etc.; * Service interruption or delay caused by the computer system being damaged, defective, or unable to perform normally; * Losses due to technical problems that cannot be predicted or solved by existing technical forces in the industry; * Losses to you or other third parties due to the fault or delay of the third party; * Losses to you or other third parties due to changes in laws and regulations or government orders; * Losses to you or other third parties due to force majeure or accidents caused by other unforeseeable, unavoidable and unsolvable objective circumstances. You agree and accept that the above reasons may lead to abnormal transactions, market interruptions, and other possible abnormal circumstances; HKD.com reserves the right to refuse to execute your commands based on the actual circumstance. You understand and agree that HKD.com shall not be liable for any of your losses (including but not limited to direct or indirect losses, actual losses, or loss of possible yield, etc.). 5.5 You agree and accept that HKD.com shall not be liable for any losses caused by the risks described in Section 3.2 of this Agreement (including but not limited to any direct or indirect losses, actual losses, or possible loss of profits). ### 6. Mandatory Measures You agree and accept that HKD.com strictly prohibits unfair trading practices. HKD.com reserves the right to exercise control over your account or shut down your account if you perform the following actions: * Price manipulation or any other malicious market behaviors; * Harming other Users or HKD.com using the loopholes of the Service or other unreasonable means; * Participation in any activities that HKD.com regards as harmful to the market; * Violation of law and regulations. In order to eliminate any adverse effects on the overall market, HKD.com reserves the right to take the following measures at its sole discretion, including but not limited to the closing down of your account, and restricting or canceling your commands. You understand and agree that HKD.com shall not be liable for any losses (including but not limited to any direct or indirect losses, actual losses, or losses of possible profits) incurred by you in connection with the above measures. ### 7. Indemnification 7.1 You shall take every possible measure to protect HKD.com from any damages arising out of your use of the Service or other actions related to your HKD.com account; otherwise, you should be liable to HKD.com. 7.2 You hereby agree to defend, indemnify and hold HKD.com harmless from any claim or demand (including reasonable legal fees) made or incurred by any third party against HKD.com due to or arising out of your breach of this Agreement, your improper use of the Service, your violation of any law or the rights of a third party and/or the actions or inactions of any third party to whom you grant permissions to use your HKD.com account or access our website, software, system (including any network and servers used to provide any of the Service) operated by us or on our behalf, or any of the Services on your behalf. ### 8. Miscellaneous 8.1 The contents of this Agreement also include HKD.com's various system specifications, other agreements or rules in the annex to this Agreement, and other relevant agreements and rules regarding the Service that HKD.com may issue from time to time. Once the above content is officially released, it is an integral part of this Agreement, and you should also abide by it. In the event of any conflict between the above content and this Agreement, this Agreement shall prevail. 8.2 HKD.com reserves the right to unilaterally modify this Agreement (including the above contents) if necessary. Such modification could happen at any time without prior notice. If any changes are made, the revised content shall be posted on HKD.com's website immediately. Please check the latest information posted therein to inform yourself of any changes. Your continued use of or access to the Service following the posting of any changes constitutes acceptance of those changes. If you do not accept the revised content, you should stop using the Services. 8.3 You should carefully read the Agreement, and any document referred to in Sections 8.1 and 8.2 of this Agreement that constitute the contents of this Agreement. If there is anything that you do not understand in the Agreement and any document referred to herein, you should contact HKD.com and seek clarification. Unless otherwise instructed by HKD.com, any formal communication and document transfer between you and HKD.com should be undertaken through email. You are also able to contact HKD.com telephonically as informal communication. Any formal communication between you and HKD.com should unless otherwise agreed, be made in the English language. In the event of any discrepancy between the communication in English and that in a foreign language, the English version shall prevail. In the event of any discrepancy between any formal and/or informal communications and the Agreement, the Agreement shall prevail. To HKD.com: Email:
# Regulatory Agency Query For Government and Law Enforcement Agencies only ### 1. Introduction As disclosed in our Terms of Service, the services of HKD.com are being provided by the following entities: HKD.com Limited (“HKD.com”) HKD.com are collectively referred to herein as “we” or “us”. Where appropriate, we will respond to requests from authorized law enforcement officers with proof of authority. We will review each case and cooperate on a case-by-case basis, in accordance with the relevant Terms of Service, our Privacy Policy Statement, and any applicable laws and regulations. This Law Enforcement Request Guide explains how authorized law enforcement officers can engage and contact us to request customer information and/or freeze a customer’s HKD.com account. Please note that we will only respond to requests from authorized law enforcement officers, addressed to us. If applicable, please also reference the appropriate applicable Mutual Legal Assistance Treaty-related documents if cross-border law enforcement is involved. ### 2. Law Enforcement We are responsible for processing law enforcement requests from all jurisdictions, in accordance with our User Agreement, our Privacy Policy Statement, and any applicable laws and regulations. If you are an authorized law enforcement office, please contact the following email address for all law enforcement-related requests:
# Whistleblower Notice Each of the Group Companies is committed to conducting its business with integrity and based upon ethical best practices and principles, including anti-bribery and anti-corruption compliance standards. The Group Companies have zero tolerance for bribery and corruption.
If you know or suspects that any employee(s), consultant(s) or associated persons of Group Company or their Related Persons or any persons claimed to be the employee(s), consultant(s) of Group Company have taken bribes from you, you shall promptly notify the Group Companies by sending an email with all relevant details to the following email address
The Group Companies will keep all information providers and all information provided thereof strictly confidential, and take certain measures to support you as follows: \ Regardless of whether you provide or is being forced to provide to any employee or associated persons of the Group Companies or their Related Persons with improper benefits or advantages, if you proactively provide effective information and explains the situation to a Group Company before the Group Company is aware of such information from other sources, the Group Company will in its sole discretion consider the actual situation and continue with the business dealings with you. The Group Companies may not take action against your violation of any of the above provisions.\ \ Once the information in relation to bribery conducts provided to a Group Company is verified, the Group Company shall offer monetary reward to whistleblower based on the degree of influence by such bribery conducts. # Perpetual Contract User Agreement The perpetual contract offering available on the HKD.com website, iOS app, and android app, is provided by HKD.com Limited ("HKD.com"), an International Business Company incorporated in the Republic of Seychelles, and of company number 235204. The perpetual contract offering is a service HKD.com provides.\ \ By engaging HKD.com's perpetual contract offering, you agree and accept that HKD.com strictly prohibits unfair trading practices. HKD.com reserves the right to exercise control over your account or shut down your account if you perform the following actions: * Price manipulation or any other malicious market behaviors; * Harming other Users or HKD.com using the loopholes of the Service or other unreasonable means; * Participation in any activities that HKD.com regards as harmful to the market; * Violation of law and regulations. In order to eliminate any adverse effects on the overall market, HKD.com reserves the right to take the following measures at its sole discretion, including but not limited to the closing down of your account, restricting or canceling your commands. You understand and agree that HKD.com shall not be liable for any losses (including but not limited to any direct or indirect losses, actual losses or losses of possible profits) incurred by you in connection with the above measures.
# OTC Advertising Agreement Welcome, and thank you for using HKD.com OTC Advertiser Service. This agreement is entered into between HKD.com Limited, an International Business Company incorporated in the Republic of Seychelles, and of company number 235204, (hereinafter referred to as “the Platform” or “HKD.com” or “we”) and the “Advertiser” on the Platform (hereinafter referred to as “You” or “the Advertiser”). By signing up as an advertiser or placing an advertisement on our website, API, mobile application, or related applications, you agree that you have read, understood, and unconditionally accepted all of the terms and conditions stipulated in this Advertiser Service Agreement and related announcements (hereinafter referred to as "this Agreement" or “these Terms”). HKD.com reserves the right to change, modify or update this Agreement at any time with or without prior notice of any kind, and any modifications or changes to this Agreement will become effective at any time we deem fit; therefore, your continued usage of our services is deemed your acceptance of the modified agreement and rules. If you do not agree to this Agreement or the revised terms and rules, you must immediately stop using HKD.com OTC Advertiser Service and must terminate your advertiser account on the Platform. **Disclaimer:** 1. Once your right to OTC Advertiser Service is approved, or your advertisement is placed, you acknowledge that you have accepted and agreed to be bound by this Agreement and its related rules and announcements. 2. These Terms will be effective upon publication and will be revised or modified from time to time. Any changes will take effect immediately upon publication, and your continued use of HKD.com OTC Advertiser Service constitutes acceptance. In case of any discrepancy between the contents of this Agreement and the updated terms published on the platform, the updated terms shall prevail. 3. The Advertiser is an independent trader on the Platform and is granted the right to place advertisements after it is verified and certified by the Platform, but this does not mean that the Advertiser is 100% credible, nor that there is any guarantee between the Platform and the Advertiser. The Platform is not responsible or liable for any losses due to the Advertiser’s violation of this Agreement or any damages caused by the Advertiser. 4. The Advertiser must abide by local laws in relation to the legal usage of HKD.com OTC Advertiser Service. You are prohibited from using the Platform to perform any illegal activities or transactions, including but not limited to money laundering, smuggling, commercial bribery, market manipulation, or interference with the trading system. If You are identified as having committed any of the aforementioned illegal activities, the Platform has the right to take necessary actions, including but not limited to suspending, freezing, or canceling the use of your HKD.com OTC Advertiser Account, confiscating your security deposit, referring your case to a judicial institution and more; and the Platform is not liable for any losses or damages arising directly or indirectly from the action taken.
### 1. Scope of Application The services stated in this Agreement are applicable to users under the following conditions, hereinafter referred to as "the Advertiser": I. Users who are certified by the Platform are users who have officially obtained the "Advertisement Publication Qualification"; II. Users who are not certified as advertisers but have locked up a certain amount of their assets on the Platform as a security deposit; III. Users who are in the process of terminating their qualification voluntarily as Advertisers but still have their security deposits locked in their accounts in the Platform. ### 2. Service You will be qualified as an HKD.com OTC Advertiser and have the right to publish advertisements on the Platform once you have completed your application and verification. You are entitled to the following services in addition to the rights of a regular user of the Platform: Publishing Advertisement: You will enjoy relevant publishing rights after becoming an Advertiser in order to carry out a smoother and more flexible transaction.\ \ (Please note: After You are qualified as an HKD.com OTC Advertiser and have obtained the publishing rights, You are obliged to report all Your payment methods to the Platform. If Your bank account is frozen, You or the authorized person must immediately fill in and submit the “Registration Form for Frozen Account” in order for the Platform to take necessary actions.)\ \ One-to-one Service: We will offer one-to-one service in order to improve the transaction flow and provide effective action to resolve any complaints. Exclusive Verification Icon: We will provide an exclusive verification icon to qualified Advertisers, which will be displayed next to their username, to distinguish them from regular users. Others: The Platform may launch other new products and services for Advertisers from time to time and may change or upgrade existing products and services anytime. For specific updates about the services, please refer to those announcements published on the website and related interfaces. ### 3. Application for Verification In order to enhance the security of the transaction and the credibility of the Advertiser, the Platform will provide the confirmation of the Advertiser’s application and verification. #### Materials Required for Verification You need to provide the following materials to apply for verification and publishing rights: * Your mobile phone number * Email address * National Identity Card * Passport * and other materials required by this Platform for compliance purposes. Please Note: While we are not liable for the accuracy and authenticity of the user identification materials submitted, we will cooperate with the applicable law enforcement should there be illegal activities involved with the user identification information collected. #### Application Process 1. You submit the materials required for the application. 2. Once the Platform receives your materials, the Platform will assess them in accordance with the requirements of the KYC and anti-money laundering principles. 3. Once the verification is completed, the Platform will provide You with an exclusive "V" icon to distinguish You from regular users. At the same time, as a verified Advertiser, You must lock the agreed amount of assets in the security deposit account, which will not be non-transferable until You terminate your\ Advertiser account. #### Application Update Required Materials: The application is an identification service provided by the Platform. Once You have completed your application on the Platform, the submitted information for identity verification and the application result will not be modified unless otherwise agreed and stated in this Agreement unless there is a legal change to your identity information after the verification. If your identity information has been legally changed after completing the verification, You are responsible for informing and providing the Platform with the updated information issued by the competent authorities, and the Platform will assist You with changing the related information in your account. Management of the Application Materials: Your application and submission of material for verification mean that you consent to authorize the Platform to retain the verified materials. The Platform will not disclose, edit or reveal your verified materials except for lawful or agreed purposes and will not be used for non-public content on the Platform for commercial purposes. However, You authorize the Platform to disclose your information under the following conditions: 1. When the Platform is asked to provide such materials to relevant government authorities or law enforcement agencies; 2. When the Platform is asked to provide such materials by any of our affiliated companies and partners; 3. When a third party is working with the Platform and needs such materials to provide You with the Service (excluding your bank information); 4. When You and a third party are involved in a civil dispute where the Platform has the right to disclose your identity and related materials to the third party. Please refer to the Privacy Policy on the Platform for more information about data protection. ### 4. Security Deposit The Advertiser shall comply with the terms and conditions in this Advertiser Service Agreement, as well as have read, understood, and accepted the following Security Deposit clause: #### 4.1 Description of Security Deposit The Platform will require the Advertiser to deposit and lock a certain amount of assets in its security deposit account after verifying and passing the Platform's KYC and anti-money laundering review. The required amount and asset type vary in accordance with your nationality and your type of publishing rights on this Platform. Please refer to the verified personal information in your Advertiser Account for the specific requirement. #### 4.2 Confiscate Security Deposit The Platform has the right to confiscate some or all of the Advertiser's security deposit in the following cases: 1. The Advertiser fails or refuses to cooperate or perform the corresponding obligations and causes damages to other users after being deemed to be at fault by the Platform in a transaction dispute and is held liable for the dispute; 2. The Advertiser repeatedly violates "The Advertiser Credit Points Rules" and is punished in accordance with the relevant terms and rules; 3. The Advertiser uses the Platform to perform illegal activities, including but not limited to money laundering, illegal arbitrage trading, market manipulation, or interference with the trading system; 4. The Advertiser causes damages to the Platform and its reputation by using the brand, HKD, to engage in any false or misleading publicity or promotion; 5. The Advertiser uses other people's identities, credit cards, or bank cards to perform unlawful activities such as money laundering and causes damages to related users or parties; 6. The Advertiser has unusual orders and is being complained about but fails to be contacted due to any objective reason (e.g., the Advertiser is detained by the police); 7. The Advertiser violates any terms and conditions of this Agreement, any legal documents, or transaction rules on the Platform; 8. The Advertiser fails to report to the Platform as required after its payment method is suspended; 9. The Advertiser engages in unauthorized cross-platform transactions and uses its HKD account to collect and make payments in such unauthorized cross-platform transactions and fails to perform the effective separation of risky funds, which results in freezing other users' accounts on the Platform; 10. Other circumstances where the Platform evaluates the situation and determines that a deduction should be made from the Security Deposit. The confiscated amount is determined by the severity of the actual consequences after the Platform conducts the risk control assessment. Examples include but are not limited to the following: * The deducted amount is generally used as compensation for the actual losses caused by the user. However, if the security deposit is insufficient to cover the losses caused by the user, We have the right to require You to provide an additional security deposit. The amount of the additional security deposit is confirmed by the Platform. * The Platform has the right to confiscate all of your security deposit under the following circumstances: * When the Advertiser is found and identified by the Platform as having directly participated in or assisting in money laundering or other illegal activities * When the Advertiser is found and identified as having been involved in money laundering by conducting cross-platform OTC transactions on high-risk platforms (platforms with low-risk control capabilities such as lack of KYC review) * When the Advertiser forms any authorized trading groups or participates in any authorized community trading and fails to perform KYC and verify basic information from the trading party, which results in bringing illegal funds and assets to HKD. * When the payment of the Advertiser leads to freezing the bank cards of three or more users, and the Advertiser refuses or does not actively cooperate to resolve the issue. When the bank card the Advertiser uses is suspended, and the Advertiser fails to report the issue to the Platform as required, or when the Advertiser fails to inform the Platform after its bank card is frozen, which causes losses or damages to other users on the Platform. ### 5. Advertiser Account Termination The Advertiser shall comply with the terms and conditions in this Advertiser Service Agreement, as well as have read, understood, and accepted the following Advertiser Account Termination clause: #### 5.1 When the Advertiser terminates its own account and publishing rights: The Advertiser must submit a formal application to the Platform to terminate its Advertiser Qualification should the Advertiser wants to cancel its verification due to personal reason. If the Platform confirms the Advertiser is not involved in any unresolved dispute or any illegal activities, the Platform will complete the termination within seven (7) working days and transfer the remaining Security Deposit to Your Fiat Currency Account. #### 5.2 When the Platform unilaterally terminates the Advertiser Account The Platform has the right to terminate your Advertiser account if one of the following conditions exists: 1. The Advertiser has received many complaints during trading on this Platform; 2. The Advertiser provides false or misleading information during the application; 3. The Advertiser appears to use the Platform in a fraudulent manner or maliciously spreads bad information that affects the Platform and its reputation; 4. The Advertiser does not cooperate with the Platform's customer support to process the order or delay the process intentionally; 5. The Advertiser maliciously uses the rules of the Platform to gain profit; 6. The Advertiser is identified by the Platform to use other people’s bank cards to trade or engage in money laundering; 7. The Advertiser is found and identified as having been involved in money laundering or other illegal activities by performing trading on platforms with low KYC/ risk control capabilities or in high-risk OTC communities. If other user accounts are frozen due to the actions of the Advertiser, the Advertiser is required to cooperate with the Platform for account unfreezing in addition to being disqualified as an Advertiser and having the Security Deposit confiscated; 8. The Advertiser must carry out proper risk control and identification measures such as KYC and AML to prevent illegal funds from flowing into the Platform if the Advertiser engages in unauthorized cross-platform OTC transactions. The Advertiser must separate its funds and avoid using its HKD Account to collect or make payments in unauthorized cross-platform OTC transactions. If any user account is frozen because the Advertiser fails to effectively separate its funds or account in such unauthorized cross-platform transactions, the Platform has the right to terminate your Advertiser Account immediately; 9. The Advertiser’s bank account or payment account is frozen but fails to report to the Platform as required; 10. The Advertiser violates this Agreement or “The Advertiser Credit Points Rules”; 11. The Advertiser violates the rules, purpose, or spirit of the Platform and their actions are not in conformity with public order, good customs, and fair transactions as determined by the Platform. ### 6. Limitation of Liability The Advertiser shall comply with the terms and conditions in this Advertiser Service Agreement, as well as have read, understood, and accepted the following exemption and limitation of liability: 6.1 Over-the-counter Trading is extremely complicated, and You have to pay extra attention to the risk of involving in any money laundering or illegal activities. You must trade in accordance with the procedures and rules of the Platform and verify the identity of the trading party in accordance with the requirements of the KYC and anti-money laundering principles; otherwise, your bank account can be frozen due to your trading party’s criminal actions. The Platform is not liable for any loss that may be caused arising out of this situation. 6.2 The Platform only provides matching services for C2C transactions and is not a party to a C2C transaction. All transactions are carried out solely by the users. You agree to independently bear all the risks arising from the engagement in C2C transactions should you violate any of the terms and rules of this Agreement. The Platform is not responsible or liable for any losses due to the Advertiser’s violation of this Agreement or any damages caused by the Advertiser. 6.3 The Advertiser must avoid illegal funds or assets flowing into the Platform (especially when the Advertiser withdraws coins in authorized cross-platform OTC transactions, the Advertiser must identify the trading party and separate the funds properly) to prevent from using the Platform to engage in illegal activities including but not limited to money laundering or illegal arbitrage trading. If the Advertiser is identified and verified as having participated in unlawful activities on this Platform (e.g., using, buying, or renting other people’s bank cards to wash trades or illegally bulk trade in US dollars), the Platform has the right to take necessary actions including but not limited to suspending, freezing or canceling the use of your HKD.com OTC Advertiser Account, confiscating your security deposit, referring your case to a judicial institution and more. The Platform is not liable for any losses or damages arising directly or indirectly from the action taken. 6.4 The platform discourages You from renting or buying other people’s bank cards to trade: 1. If you rent or buy other people’s bank cards to wash trades, resulting in the loss of the real owner of the card, the Platform has the right to refer You to the judicial institution or government authorities and is not liable for any losses caused by the action taken. 2. You are obliged to cooperate with the investigation and unfreeze the account if you have rented or bought other people’s bank cards to trade which then has led the police to freeze the other user accounts or cards due to the payment received from You. If you refuse to cooperate, the Platform has the right to confiscate your security deposit to compensate for the loss of the other users and is not liable for any losses or damages arising directly or indirectly from the action taken. # Merchant Service Agreement Please confirm that you have read this agreement's contents in detail before starting the "Verified Merchant" process. Once you start the verification process, it means that you fully understand and agree to accept the entire contents of this agreement. In order to improve the security of transactions and the credibility of the identity of registered users of this platform, HKD.com Limited, an International Business Company incorporated in the Republic of Seychelles, and of company number 235204, (hereinafter referred to as "this website" or "HKD.com") provides you with authentication services. If you apply for authentication, this website has the right to take various measures that it deems necessary to identify the user's identity. However, as an ordinary network service provider, this website's methods are limited, and there are certain difficulties in identifying users on the network. No guarantees can/will be made by HKD.com. Documents and Information Required for Application: * Full Legal Name (as shown on the national ID card or passport) * Identification Number (as shown on the national ID card or passport) * A declaration that your source of funds is legal and reliable * A declaration that you consent to trade your digital assets voluntarily * A declaration that you fully understand the potential risks involved with the trading of digital assets * A declaration that you will bear all potential risks involved with the trading of digital assets as a merchant * A declaration that you take full responsibility for this merchant account’s operations and will personally bear all legal responsibilities arising from the usage of this account * Other materials as required by this platform for compliance and related purposes #### Security Deposit Upon passing the platform KYC and AML review process, the platform will require the merchants to deposit a security deposit in their platform accounts to ensure the safety of their transactions on the platform. The specific amount of the deposit will be displayed in the personal information of the certified merchant on this platform. In the following circumstances, the platform has the right to deduct the merchant's deposit and other disposals: * The merchant is involved in a dispute during the transaction process, and the merchant is judged to be responsible, but the merchant does not cooperate by fulfilling the corresponding obligations; * Merchant conducted transactions with an account(s) that are not real-named on this platform; * Merchants utilize this platform to engage in illegal activities; * Merchant violates this agreement and/or any related legal document or transaction rules on this website; * When paying other merchants or users, the receiving party(ies)’s bank account is identified as frozen; #### Authentication Process Below are the steps involved with the authentication process: 1. Submit merchant account application materials; 2. Pay the corresponding security deposit; 3. This website will conduct compliance reviews such as KYC and anti-money laundering based on these materials; 4. After passing this website's KYC and anti-money laundering compliance review, the platform will provide an exclusive merchant plus V logo to distinguish it from ordinary users. #### Application to Cancel Merchant Verification If a Merchant wishes to cancel their Merchant Verification status, it can be done by submitting an application for cancellation in the merchant's dashboard. Once the application to cancel Merchant Verification is activated, the Merchant Verification will immediately be voided. The Merchant will no longer enjoy the rights and privileges available only to verified Merchants.\ \ The security deposit will be transferred to the related HKD.com fiat currency account within seven (7) working days when the platform confirms that the merchant is not involved in any pending disputes and has no bad records. \ If the following circumstances occur, the platform will have the right to cancel the Merchant Verification unilaterally: * Multiple transaction-related complaints received from other platform users; * The account was found to involve false information being submitted during the application process; * Not cooperating with the platform's customer service to process the order or deliberately delaying the customer service to process the order; * Malicious use of the rules of this platform; * Violating laws and regulations, this agreement, or related legal documents or trading rules of this website; * Behaviors that do not conform to public order and good customs and fair trade as determined by this platform; * When making payments to other merchants or users, the bank account of the counterparty is frozen, and they do not actively cooperate with the processing; * Merchant is found to be intentionally causing transactional halting for small and sizeable trades; The merchant is found to be sending malicious funds to the counterparty's bank account, resulting in the freezing of the counterparty’s bank account. ### 1. Understanding of Merchant Authentication Services 1.1. Merchant Authentication Service is an identification service provided by this website. Once you have completed the authentication of your account on this website, the corresponding identity information and authentication results will not be modified or canceled for any reason; if your identity information has changed after completing the authentication, you should provide this website with the corresponding information within 48 hours. This website will assist you in changing the corresponding authentication information of your account with the certificate issued by the competent government or regulatory body(ies); otherwise, you will be solely responsible for all the legal consequences arising therefrom. \ 1.2. This website has the right to unilaterally modify or change the content of this agreement at any time, with or without notification. It is your responsibility to check back periodically for updates made to this agreement. If/when modifications or changes are made to this agreement, and you continue to use the services provided by this website, it means that you have read, understood, and agreed to accept the content of the changed agreement; if you do not agree with the content of the changed agreement, you should stop using it immediately Services on this website. ### 2. Use of Verification Materials and Security Deposits #### 2.1. Management of Verification Materials: The authentication materials you submit to this website during the verification process are irrevocably authorized to be retained by this website. This website will not disclose, edit or disclose your information except for statutory or agreed reasons and will not use the non-public content saved on this website for commercial purposes, except in the following cases: * You authorize this website to disclose the relevant information; * This website receives an official request from regulators and/or enforcement departments; * When a third party and this website provide joint-effort services to users (excluding your bank account information) and your information is required for the services; * Based on the need to resolve civil disputes between you and a third party, this website has the right to provide your identity information to the third party(ies). Based on the need to resolve civil disputes between you and a third party, this website has the right to provide your identity information to the third party. #### 2.2. Security Deposits: Security Deposits will be used to ensure transaction security. If the verified merchant has a dispute in the transaction process, is judged to be responsible, and the verified merchant fails to cooperate, this website has the full right to dispose of the deposit and deduct your deposit to compensate for the loss of the relevant counterparty. ### 3. Links to Third-Party Websites 3.1. During the process of identity verification, this website may contain links to third-party websites (such as online banking websites) (hereinafter referred to as "linked websites"). The "Linked Sites" are not under the control of the Site, and the Site is not responsible for the content of any "Linked Sites", including but not limited to any links contained in the "Linked Sites", or any changes or updates to the "Linked Sites". This website is not responsible for network transmissions or other forms of transmission received from "Linked Sites". ### 4. Prohibited Use 4.1. Acceptance of this agreement's instructions, terms, and conditions is a prerequisite for your application for verification. You represent and warrant that you will not engage in any illegal and/or agreement-violating activities. You will not in any way damage, paralyze, overload, or impair other websites or the services of other websites, use the merchant verification service on this website, or interfere with the use of the verified merchant service by other users. You may not obtain or attempt to obtain any material or information by any means not permitted by this website.\ \ 4.2. You understand that the Merchant Service provided by HKD.com is only applicable to HKD.com users and only to approved currencies transactions and other unprohibited currencies and unprohibited transactions where the definition of "unprohibited currencies" and "unprohibited transactions" may vary depending on your country of residence, nationality, and geographic location at the time of using the Merchant Service provided by HKD.com. Violation of this term is not permitted by this website, and you will bear all legal, financial, and related consequences related to the violation. In case of loss, damage, and/or legal consequences which may arise as a result of your use (or inability to use) the Merchant Service provided by HKD.com, you shall not hold HKD.com or any of HKD.com's legal representative, employee, staff, affiliated agencies, affiliated companies, subsidiaries, and ultimate beneficiary owner legally liable, to the extent applicable laws allow, for any: (1) loss of profit, revenue, debt, or any other forms of monetary damages; (2) loss of income, sales, capital loss, liability and other losses incurred during business transactions, business activities, and profit-related activities; (3) data loss or corruption; (4) incidental or special damages; (5) wasted or lost administrative time; (6) pure economic loss in whatever form. (1) - (6) apply in all circumstances, whether direct, indirect, consequential, punitive, or arising in contract, tort, or otherwise. \ \ 4.3. You understand that the Merchant Service (or "P2P Merchant Service") provided by HKD.com is only applicable to HKD.com users, and the action of fund transferral through non-registered payment methods or to third-party accounts is strictly prohibited. Violation of this term is not permitted by this website and may be a violation of law and regulations in the jurisdiction of Seychelles. In case of violation, the website has the right to freeze your assets, report you to the governing authority, and you shall bear all legal, financial, and related consequences related to the violation. ### 5. Disclaimer This website is not responsible for the following situations: 5.1. Your personal information is leaked due to you informing others of your account password, failing to keep your password safe, sharing your account with others, or any other faults that are not stated on our website. 5.2. Any impact due to hacker attack, computer virus intrusion or outbreak, technical adjustment of the telecommunications sector, temporary shutdown due to government control, due to third-party reasons, force majeure that results in the authentication information being leaked, lost, stolen, and/or tampered with. 5.3. The disclosure of bank account information caused by other websites linked to this website (such as online banking, etc.) and any legal disputes and consequences arising therefrom. 5.4. Any failure to pass the verification process or suffering any other losses due to the wrong, incomplete, or false information provided by the user to this website is not part of this website’s responsibilities. ### 6. Special Statement 6.1. The basic information review and deposit requirements of the verified merchants on this website do not mean that the verified merchants are 100% credible, nor does it mean that there is any guarantee of a relationship between this website and the verified merchants. Users of this website are requested to conduct transactions in strict accordance with the process, do a good job reviewing the transaction parties' data, communicate in detail, and ensure the safety of their own transactions and assets! At the same time, based on the particularity of digital asset transactions, you need to pay special attention to the risks of Anti-Money Laundering and understand the identity of your counterparty in accordance with the requirements of the KYC principle; otherwise, you may face risks such as asset freezing due to the suspected crime received from your trade’s counterparty.
# Risk and Compliance Disclosure The Risk and Compliance Disclosure should be read in conjunction with the User Agreement of HKD.com (“HKD.com”). In plain English, we want you to understand the important risks and compliance matters while you trade on our platform. ### 1. Purpose of Our Program We have established and implemented an Anti-Money Laundering, Anti-Terrorist Financing, and Trade & Economic Sanctions Program (“AML/ATF/Sanctions Program” or “Program”) to ensure a robust and compliant digital asset trading platform. We want to promote legal, transparent business activities and maintain a strong reputation among our customers, regulators, and the digital asset industry. ### 2. Our Roles and Activities We are a global digital asset trading platform or marketplace, where traders come as buyers and sellers (commonly referred as market-makers and market-takers). For clarity, buyers and sellers trade with each other and not with HKD.com. We are not a counterparty to any trade. Our Services are available through HKD.com, associated application program interfaces and/or mobile applications and through HKD.com. Disclosure: Trading is risky. The risk of loss in trading or holding digital assets can be substantial. You should therefore carefully consider whether trading is suitable for you in light of your financial condition. ### 3. Regulatory Landscape We understand that regulatory bodies have taken a diverse approach to the laws and regulations regarding digital assets, including some characterizing or defining digital assets as , convertible virtual currency (by USA FinCEN) or virtual commodity (by Hong Kong). As a trading platform, we believe that all digital assets available on HKD.com are an innovative alternative asset class; and therefore, digital assets should not be called currency or money Disclosure: Digital assets are not fiat money nor fiat currency. Digital assets are NOT backed by any government or central bank. We may at times have opinions of the different regulatory approaches taken by various government bodies; however, at all times, we will fully abide by rules and regulations of the respective countries we operate in. We regularly communicate with regulators and industry on the best approach to regulating digital asset businesses. Furthermore, HKD.com does not accept certain customers. To maintain our strong reputation in the market and ensure a robust compliant marketplace, we have decided to not seek nor accept customers from certain jurisdictions including OFAC sanctioned countries. We cooperate with governments and respect regulations and comply with applicable regulations. As good corporate citizens, we may be asked for information from law enforcement authorities and will assist if permissible by law as law enforcement conduct investigations to pursue and thwart illicit activity. What this also means is that our platform is intended for law abiding customers. We welcome the opportunity to earn your business, and in return we require that you act legally and properly on our platform. ### 4. Our AML/ATF Program We have designed our Program to reasonably prevent money laundering and terrorist financing through a risk-based, multi-layer control system. The first layer includes a stringent customer identification program, including verifying the identity of our customers, whether individuals or entities. In addition to obtaining identification documents, we obtain for non-natural persons their entities’ beneficial owners/natural persons consistent to international standards such as the Financial Action Task Force (FATF). The second layer includes a risk-based system to warrant additional customer due diligence. To accomplish this, we screen our customers (including beneficial owners) against the entities/persons on The Government of the Hong Kong SAR Gazette, United States Office of Foreign Assets Control (OFAC) Sanctions Lists, and the United Nation Security Council Sanctions List, among other government-provided lists of sanctioned individuals and entities. We also may screen against other lists on a discretionary basis to protect our reputation and customers. The third layer includes ongoing monitoring for suspicious activity. If our Program suspects or has reason to suspect suspicious activities have occurred, we will file suspicious activities reports with local regulators. A suspicious transaction is often inconsistent with a customer’s known and legitimate business, or personal activities. These are the primary components of our compliance program; however, the most important glue or connection to these layers are our leadership team and staff, including AML/Risk personnel that execute training, oversight and a sound compliance culture. ### 5. Risks Trading in digital assets is considered high risk. Digital assets are NOT backed by any government or central bank. The risk of loss in trading or holding digital assets can be substantial. You should carefully consider whether interacting, holding, or trading digital assets is suitable for you in light of your financial condition. ### 6. Communication If you have questions or require assistance with our customer due diligence controls, please reach out to our 24/7 customer service representatives by phone, chat or email. For any law enforcement requests, please email us at
# Safeguarding Client Assets Proper security is crucial to the diligent management of digital assets. At HKD.com/global ("HKD.com"), we protect client’s digital assets through the utilization multiple defensive layers, and a hot and cold wallet systems with multi-signature protection. HKD.com protects against a range of attacks, while maintaining easy access for authorized parties. ### Hot Wallet HKD.com only allocate 1% of all funds to online storage (also known as hot wallet) for client deposit and withdrawal purposes. Since hot wallet are connected to the internet, HKD.com operations team operate our hot wallet using semi-offline multi-signature mechanism, MPC/threshold signature, cloud data risk control for enhanced convenience and maximum security. ### Cold Wallet 1. Cold wallets are the safest vaults for digital asset storage because they are not connected to the internet. At HKD.com, 99% of all funds are kept offline in our cold wallet system.\
2. HKD.com cold wallet private key follows the principles of remote backup, bank custody, media storage, multi-signatures, and completely offline to ensure the absolute security of digital assets.\
3. At HKD.com, our operations team have formed a complete handling process, systematic solutions, and a complete emergency response mechanism which have been proven secure and flawless. ### Multi-Signature To enhance protection of digital asset storage, HKD.com adopts institutional level, multi-signature, multi-currency wallet facilities. This is an additional layer of security to wallet transactions that’s ensured that multiple key holder remain accountable to on another (maker-checker system). Through our maker-check mechanism, HKD.com can effectively facilitate escrow transactions and decision making while serving as a form of two factor authentication (2FA). ### Withdrawal Protection HKD.com withdrawal process requires a minimum of two or more multiple security authentications including but not limited to SMS, Email, Google Authenticator, and funding password. The withdrawal can only be passed after the identity verification is completed. After adjusting security settings such as password reset, users will not be able to withdraw within 24 hours. This includes SMS or e-mail to verify your intention of operation. This is an additional layer that helps to prevent hackers from withdrawing funds by modifying the security settings. ### Cryptographically Secured HKD.com secures clients’ digital assets using the cryptographic security of blockchain technology. HKD.com users can be confident that their data will stay private even while being processed. #### I. Built with Blockchain Being powered by our private blockchain technology, it allows HKD.com to optimize customer security and data integrity while maintaining high performance requirements. #### II. Encrypted Throughout HKD.com users can be confident that their data will stay private, even while being processed, as it is encrypted at rest and in transit. ### Regulated HKD.com (“HKD.com”) is regulated. That means we comply with applicable Anti-Money Laundering regulations. #### I. Incoming and Outgoing Asset Protection As part of our overall AML process, all incoming deposits and outgoing withdrawals are scanned to detect patterns of high risk activity and unusual or suspicious transactions. We also perform real-time and ongoing forensic analysis of blockchains and wallets to identify the source of funds entering our platform and wallets. #### II. Co-Mingling Protection HKD.com custody is designed to segrtegate customers’ funding from company assets, so that no co-mingling on any account or blockchain addresses can occur. #### Collusion Resistant HKD.com features cutting-edge security verified with cryptographic validation and an architecture which increases collusion resistance. For additional information on how HKD.com protect and secure digital assets, please submit an information request by contacting
# AML and KYC Policies ### HKD.com’S AML/KYC POLICIES AND PROCEDURES This Policy relates to the anti-money laundering and countering the financing of terrorism (“AML/KYC”) policies and procedures of HKD.com/global ("HKD.com"). This Policy is solely for the purpose of providing general information and is not, in any way, legally binding either on HKD.com and/or on any other person(s) (natural or otherwise). ### A. HKD.com's Principles and Approach to AML/KYC Efforts HKD.com is committed to supporting AML/KYC efforts, in principle, we are committed to, amongst other things: 1. exercising due diligence when dealing with our customers, natural persons appointed to act for our customers ‘behalf; 2. conducting our business in conformity with high ethical standards, and to, as far as possible, guard against establishing any business relations that is or may be connected with or may facilitate money-laundering or terrorism-financing; 3. we will, to the fullest extent possible, assist and cooperate with relevant law authorizes to prevent the threat of money-laundering and terrorism-financing. ### B. HKD.com’s Approach to Risk Assessment and Risk Mitigation #### Risk Assessment We envisage that the majority of our customers would be retail customers, We would: a. document and/or collect documentation in relation to: 1. the identities of our customers; 2. the countries or jurisdictions that our customers are from or in; and b. ensure that, to the best of our knowledge, skill and ability, that our customers, connected persons of a customer, natural persons appointed to act on behalf of a customer, beneficial owners of a customer will be assessed and screened with the assistance of List of Designated Individuals and Entities which include categories such as: the Democratic People’s Republic of Korea; the Democratic Republic of the Congo; Iran; Libya; Somalia; South Sudan; Sudan; Yemen; the UN 1267/1989 Al-Qaida List; the UN 1988 Taliban List; persons identified in the First Schedule of the Terrorism(Suppression of Financing) Act (Cap. 325). #### Risk Mitigation If identified, we shall not deal with any persons identified in the List of Designated Individuals and Entities. ### **C. Our Approach to New Products, Practices and Technologies** We shall be properly advised, in relation to, identifying and assessing the money laundering and terrorism financing risks that may arise in relation to: 1. the development of new products and new business practices, including new delivery mechanism; 2. the use of new or developing technologies for both new and pre- existing We shall especially pay special attention to any new products and new business practices, including new delivery mechanism, and new or developing technologies, that favour anonymity such as digital tokens (whether security, payment and/or utility tokens) that favour anonymity. #### **D. Our Approach to Customer Due Diligence (“CDD”)** We do not open, maintain or accept anonymous accounts or accounts in fictitious names. We do not establish business relations with, or undertake a transaction for a customer that we have any reasonable grounds to suspect that the assets or funds of a customer are proceeds of drug dealing or criminal conduct. We shall lodge a Suspicious Transaction Report and extend a copy to the relevant Financial Intelligence Unit for such transactions. We perform Customer Due Diligence: 1. when we establish business relations with any customer; 2. when we undertake any transaction for any customer whom we had not established business relations with; 3. when we effect or receive digital payment tokens by value transfer for any customer whom we had not established business relations with; 4. when we have suspicion of money-laundering or terrorism financing; 5. when we have doubts about the veracity or adequacy of any information When we suspect that there are 2 or more transactions are or may be related, linked or the result of a deliberate restructuring of an otherwise single transaction into smaller transactions in order to evade the Prevention of Money Laundering and Countering the Financing of Terrorism measures, we shall treat the transactions as a single transaction and aggregate their values for the purpose of complying with Prevention of Money Laundering and Countering the Financing of Terrorism principles. #### Identifying our Customers We shall identify each of our customers. To identify our customers, we shall obtain, **at least**: 1. their full names, including aliases; 2. their unique identification numbers (such as an identity card number, birth certificate number, or passport number, or where the customeris not a natural person, their business registration numbers); **AND** 1. their date of births, establishment, incorporation or registration; and 2. their nationality, place of incorporation or registration Where the customer is a legal person or legal arrangement, we shall apart from obtaining the relevant information as aforesaid above, identify its legal form, constitution and powers that regulate and bind the legal person or legal arrangement; we shall also identify connected parties of it (e.g., directors, partners of and/or persons having executive authority of it), by obtaining at least the following information of each connected party: 1. full name, including aliases; and 2. unique identification number such as identify card number, birth certificate number, or passport number of the connected party). **Verifying the Identities of our Customers** We shall verify the identities of our customers using reliable, independent source data, documents or information. Where our customer is a legal person or legal arrangement, we shall verify the legal form, proof of existence, constitution and powers that regulate and bind the customer, using reliable, independent source data, documents or information. ***Identifying and Verifying the Identities of Natural Persons Appointed to Act on a Customer’s behalf*** Where a customer appoints 1 or more natural persons to act on his behalf in establishing business relations with us, or if the customer is not a natural person we shall: 1. identify each natural person who acts or is appointed to act on behalf of the customer by obtaining: 2. their full name; 3. their unique identification number; 4. date of birth; 5. nationality; and' 6. verify the identities of the aforesaid natural persons using reliable, independent source data, documents or We shall also verify due authority of each natural person appointed to act on behalf of our customers by obtaining: 1. appropriate documentary evidence authorizing the appointment of such natural persons by our customers; 2. the specimen signature of each natural person Where the customer is a Government entity, we shall only obtain such information as may be required to confirm that the customer is a Government entity as asserted. ***Identifying and Verifying Beneficial Owners*** We will inquire if there exist any beneficial owners in relation to a customer. Where there is 1 or more beneficial owner in relation to a customer, we shall identify the beneficial owners and take reasonable measures to verify the identities of the beneficial owners using relevant information or data obtained from reliable, independent sources. We shall: if the customer is a legal person – 1. identify the natural persons (whether acting alone or together) who ultimate own the legal person; 2. where there is doubt as to whether as to whether natural persons who ultimately own a legal person are the beneficial owners or where no natural person ultimately own the legal person, identify the natural persons (if applicable) who ultimately control the legal person or have ultimate effective control of the legal person; and 3. where no natural persons are identified, identify natural persons having executive authority in such legal persons; if the customer is a legal arrangement – 1. for trusts, identify the settlor, the trustee, the protector (if applicable), the beneficiaries, any natural person exercising ultimate ownership, ultimate control or ultimate effective control over the trust; and 2. for other types of legal arrangements, identify person in equivalent positions. Where our customer is not natural person, we shall identify the nature of our customers’ business, its ownership and control structure. We shall be required if there exist any beneficial owners for customers who are: 1. an entity listed on the stock Exchange; 2. an entity listed on a stock exchange that is subject to regulatory disclosure requirements; and requirements relating to adequate transparency relating to its beneficial owners; 3. a financial institution; 4. a financial institution that is subject to and supervised for compliance with AML/CFT requirements consistent with standards set by FATF; or 5. an investment vehicle where the managers are financial institutions, or are subject to and supervised for compliance with AML/CFT requirements consistent with standards set by the FATF; unless we have doubts about the veracity of the CDD information, or suspect that our customers, business relations with, or transactions for the customer, may be connected with money laundering or terrorism financing. We shall also document the basis for our determination. Information on the Purpose and Intended Nature of Business Relations and Transaction Undertaken without an Account being Opened\* We shall, when processing the application to establish business relations or undertake transactions without being opened, understand and as appropriate, obtain from the customer information as to the purpose and intended nature of business relations or transaction. Review of Transactions Undertaken without an Account being Opened\* Where we undertake one or more transactions for a customer without an account being opened (“**current transaction**”), we shall review the earlier transactions undertaken by that customer to ensure that the current transaction is consistent with our knowledge of the customer, its business and risk profile and where appropriate, the source of funds. Where we establish business relations with a customer, the payment service provider shall review any transaction undertaken before the business relations are established, to ensure that the business relations are consistent with our knowledge of the customer, its business and risk profile and where appropriate, the source of funds. We shall pay special attention to all complex, unusually large or unusual patterns of transactions undertaken without an account being opened that have no apparent or visible economic or lawful purpose. We shall, to the extent possible, inquire into the background and purpose of the aforesaid transactions and document its findings with a view to making this information available to the relevant authorities should the need arise. For the purposes of reviewing transactions undertaken without an account being opened, we shall put in place and implement adequate systems and processes, commensurate with the size and complexity of the payment service provider to: 1. monitor its transactions undertaken without an account being openedfor customers; and 2. detect and report suspicious, complex, unusually large or unusual patterns of transactions undertaken without an account being Where there are any reasonable grounds for suspicion that a transaction for a customer undertaken without an account being opened is connected with money laundering or terrorism financing, and where we consider it appropriate to undertake the transaction, the payment service provider shall substantiate and document the reasons for undertaking the transaction. #### Ongoing Monitoring We shall monitor business relations with our customers on an ongoing basis. We shall, during the course of business relations with a customer, observe the conduct of the customer’s account and scrutinise transactions undertaken throughout the course of business relations, to ensure that the transactions are consistent with our knowledge of the customer, its business and risk profile and where appropriate, the source of funds. We shall perform our risk mitigation measures where the transaction involves a transfer of digital payment token to or receipt of a digital payment token from an entity other than: 1. a financial institution;or 2. a financial institution that is subject to and supervised for compliance with AML/CFT requirements consistent with standards set by the FATF. We shall pay special attention to all complex, unusually large or unusual patterns of transactions, undertaken throughout the course of business relations, that have no apparent or visible economic or lawful purpose. We shall, to the extent possible, inquire into the background and purpose of the aforesaid transactions and document its findings with a view to making this information available to the relevant authorities should the need arise. For the purposes of ongoing monitoring, we shall put in place and implement adequate systems and processes, commensurate with the size and complexity of the payment service provider to: 1. monitor its business relations with customers; and 2. detect and report suspicious, complex, unusually large or unusual patterns of transactions undertaken throughout the course of business relations. We shall ensure that the CDD data, documents and information obtained in respect of customers, natural persons appointed to act on behalf of the customers, connected parties of the customers and beneficial owners of the customers, are relevant and kept up-to-date by undertaking reviews of existing CDD data, documents and information, particularly for higher risk categories of customers. Where there are any reasonable grounds for suspicion that existing business relations with a customer are connected with money laundering or terrorism financing, and where we consider it appropriate to retain the customer: 1. we shall substantiate and document the reasons for retaining the customer; and 2. the customer’s business relations with us shall be subject to commensurate risk mitigation measures, including enhanced ongoingmonitoring. Where we assess the customer or the business relations with the customer to be of higher risk, the payment service provider shall perform enhanced CDD measures, which shall include obtaining the approval of our senior management to retain the customer. CDD Measures for Non-Face-to-Face Business Relations or Non-Face-to- Face Transactions Undertaken without an Account Being Opened\* We shall develop policies and procedures to address any specific risks associated with non-face-to-face business relations with a customer or nonface-to-face transactions undertaken without an account being opened for a customer (“non-face-to-face business contact”). We shall implement the policies and procedures when establishing business relations with a customer and when conducting ongoing due diligence. Where there is no face-to-face contact, the payment service provider shall perform CDD measures that are at least as stringent as those that would be required to be performed if there was face-to-face contact. Where a payment service provider conducts its first non-face-to-face business contact, the payment service provider shall, at his or its own expense, appoint an external auditor or an independent qualified consultant to assess the effectiveness of the policies and procedures, including the effectiveness of any technology solutions used to manage impersonation risks. We shall appoint an external auditor or an independent qualified consultant to carry out an assessment of the new policies and procedures, and shall submit the report of the assessment to the Authority no later than one year after the implementation of the change in policies and procedures. Reliance by Acquiring Payment Service Provider on Measures Already Performed When we (“acquiring payment service provider”) acquires, either in whole or in part, the business of another payment service provider, we shall perform the measures on the customers acquired with the business at the time of acquisition except where the acquiring payment service provider has: 1. acquired at the same time all corresponding customer records (including CDD information) and has no doubt or concerns about the veracity or adequacy of the information so acquired; and 2. conducted due diligence enquiries that have not raised any doubt on the part of the acquiring payment service provider as to the adequacy of AML/CFT measures previously adopted in relation to the business or part thereof now acquired by the acquiring payment service provider, and document such process. #### Measures for Non-Account Holder\* If we undertake any transaction for any customer who does not otherwise have business relations with us, we shall: 1. perform CDD measures as if the customer had applied to the payment service provider to establish business relations; and 2. record adequate details of the relevant transaction so as to permit the reconstruction of the transaction, including the nature and date of the transaction, the type and amount of currency involved, the value date, and the details of the payee or beneficiary #### Timing for Verification We shall complete verification of the identity of a customer, natural persons appointed to act on behalf of the customer and beneficial owners of the customer before: 1. the payment service provider establishes business relations with the customer; 2. the payment service provider undertakes any transaction for the customer, where the customer has not otherwise established business relations with the payment service provider; or 3. the payment service provider effects or receives digital payment tokens by value transfer for the customer, where the customer has not otherwise established business relations with the payment service provider. We provider may establish business relations with a customer before completing the verification of the identity of the customer, natural persons appointed to act on behalf of the customer and beneficial owners of the customer if: 1. the deferral of completion of the verification is essential in order not to interrupt the normal conduct of business operations; and 2. the risks of money laundering and terrorism financing can be effectively managed by the payment service Where we establish business relations with a customer before verifying the identity of the customer, natural persons appointed to act on behalf of the customer, and beneficial owners of the customer, we shall: 1. develop and implement internal risk management policies and procedures concerning the conditions under which such business relations may be established prior to verification; and 2. complete such verification as soon as is reasonably #### Where Measures are Not Completed Where we are unable to complete the measures as required, we shall not commence or continue business relations with any customer, or undertake any transaction for any customer. Where we are unable to complete the measures, the payment service provider shall consider if the circumstances are suspicious so as to warrant the filing of an STR. Completion of the measures means the situation where the payment service provider has obtained, screened and verified (including by delayed verification as allowed under paragraphs 6.43 and 6.44) all necessary CDD information under paragraphs 6, 7 and 8, and where the payment service provider has received satisfactory responses to all inquiries in relation to such necessary CDD information. #### Joint Accounts In the case of a joint account, we shall perform CDD measures on all of the joint account holders as if each of them were individually customers of the payment service provider. #### Screening We shall screen a customer, natural persons appointed to act on behalf of the customer, connected parties of the customer and beneficial owners of the customer against relevant money laundering and terrorism financing information sources, as well as lists and information provided by the Authority for the purposes of determining if there are any money laundering or terrorism financing risks in relation to the customer. We shall screen the persons: 1. when, or as soon as reasonably practicable after, we establish business relations with a customer; 2. before we undertake any transaction for any customer who has not otherwise established business relations with the payment service provider; 3. before we effect or receive digital payment tokens by value transfer, for a customer who has not otherwise established business relations with us; 4. on a periodic basis after we establishes business relations with our customers; and 5. when there are any changes or updates to: 6. the lists and information provided by the Authority to the payment service provider; or 7. the natural persons appointed to act on behalf of a customer, connected parties of a customer or beneficial owners We shall screen all value transfer originators and value transfer beneficiaries, against lists and information provided by the Authority for the purposes of determining if there are any money laundering or terrorism financing risks. We shall document the results of all screening. ### **E. Our Approach to Enhanced Customer Due Diligence** #### Politically Exposed Persons We shall use all reasonable means to determine if a customer, any natural person appointed to act on behalf of a customer, any connected party of the customer or any beneficial owner of the customer is a politically exposed person, or a family member or close associate of a politically exposed person. We shall, in addition to performing CDD measures, perform **at least** the following enhanced due diligence measures where a customer or any beneficial owner of the customer is determined by us to be a politically exposed person, or a family member or close associate of a politically exposed person: 1. obtain approval from senior management to establish and continue business relations with the customer; 2. establish by reasonable means, the source of wealth and source of funds of the customer and any beneficial owner of the customer; and 3. conduct, during the course of business relations with the customer, enhanced monitoring of the business relations with the customer. We shall increase the degree and nature of monitoring for any transactions that appear unusual #### Higher Risk Categories We recognize that the following circumstances where a customer presents or may present a higher risk for money laundering or terrorism financing include but are not limited to the following: 1. where a customer or any beneficial owner of the customer is from or in a country or jurisdiction in relation to which the FATF has called for countermeasures, the payment service provider shall treat any business relations with or transactions for any such customer as presenting a higher risk for money laundering or terrorism financing; and 2. where a customer or any beneficial owner of the customer is from or in a country or jurisdiction known to have inadequate AML/CFT measures, as determined by the payment service provider for itself or notified to payment service providers generally by the Authority or other foreign regulatory authorities, the payment service provider shall assess whether any such customer presents a higher risk for money laundering or terrorism We will perform enhanced CDD for customer who presents a higher risk for money laundering or terrorism financing or any customer the Authority notify to us as presenting higher risk for money laundering and terrorism financing. ### **F. Our Approach to Bearer Negotiable Instrument and Restriction of Cash Payout** We will not make any payment for any sum of money in the form of a bearer negotiable instrument. We will not pay any cash in any amount in the course of carrying on our business. ### **G. Our Approach to Value Transfer(to be implemented when required)\*** If we are the ordering institution, before effecting a value transfer, we shall: 1. identify the value transfer originator and take reasonable measures to verify his or its identity (if we have not already done so); and 2. record adequate details of the value transfer including but not limited to, the date of the value transfer, the type and value of digital payment token) transferred and the value date. If we are an ordering institution, we shall include in the message or payment instructions that accompanies or relates to the value transfer: 1. the name of the value transfer originator; 2. the value transfer originator’s account number (or unique transaction reference number if applicable); 3. the name of the value transfer beneficiary, and 4. the value transfer beneficiary’s account number (or unique transaction reference number if applicable). #### Value Transfers Exceeding a particular threshold For value transfer exceeding a particular threshold and if we are an ordering institution, we shall identify the value transfer originator and verify his or its identity, include in the message or payment instructions that accompanies or relates to the value transfer information and any of the following: 1. the value transfer originator’s- 2. residential address, or 3. registered or business address, and if different, principal place of business; 4. the value transfer originator’s unique identification number; or 5. the date and place of birth, incorporation or registration of the value transfer We shall immediately and securely submit to the beneficiary institution all value transfer originator and value transfer beneficiary information, and shall document all such information. Where we in the capacity as an ordering institution are not able to comply with the requirements, we shall not execute the value transfer. If we are the beneficiary institution, we shall take reasonable measures to identify value transfers that lack the required value transfer originator or required value transfer beneficiary institution. For value transfers where we as the beneficiary institution pays out transferred digital payment token(s) in cash or cash equivalent to a value transfer beneficiary, we shall identify and verify the identity of the value transfer beneficiary (if the identity has not been previously verified). We shall always conduct a review prior to executing a value transfer lacking the required value transfer originator or value transfer beneficiary information, and document our follow-up action.\* If we are the intermediary institution, we shall retain all information pertaining to a value transfer. When we as an intermediary institution effect a value transfer to another intermediary institution or beneficiary institution, we shall immediately and securely provide the information accompanying the value transfer, to that other intermediary institution or beneficiary institution. If we are a receiving intermediary institution, we shall keep a record for at least five years for all information received from an ordering institution or another intermediary institution. We shall take reasonable measures to identify value transfers that lack the required value transfer originator or value transfer beneficiary information when straight-through processing. ### **H. Record Keeping** We will keep proper records as required for a time period of at least 5 years. ### **I. Personal Data\*** We will safeguard the personal data of our customers in the manner prescribed. ### **J. Suspicious Transactions Reporting (“STR”)** We will inform the relevant authorities and file STR Reports as required by law. We will also keep all records and transactions relating to all such transactions and STR Reports. ### **K. Our Policies on Compliance, Audit and Training** Amongst other things, we shall appoint an AML/CFT Compliance Officer at the Management Level, maintain an independent audit function, and take proactive measures in regularly training our employees and employees on AML/CFT matters. **Enterprise-wide money-laundering/terrorism financing risk assessment** We will employ and enterprise-wide money-laundering/terrorism financing risk assessment in 3 phases: **Phase 1: Assessing inherent risk** We will assess the inherent risk in relation to our: 1. customer or entity: we will make an assessment in relation to our customers and/or entities we deal with; 2. product or services: we will and are mindful of who we serve in our cryptocurrency OTC services; 3. 3\. Geographical level: we will not deal with customers from the List of Designated Individuals and Entities. **Phase 2: Assessing mitigating control** We will assess our mitigating controls in relation the aforesaid, any and/or all customer(s) whom we find suspicious will be first monitored, followed by exercising enhanced due diligence. **Phase 3: Assessing residual risk** We will assess our residual risks after assessing our mitigating controls. # Online Information Terms and Conditions ### Customer Service Disclaimer: The customer service provided through HKD.com Limited's Zendesk platform (hereinafter referred to as "Zendesk") is offered as a courtesy to our users. The information and assistance provided via Zendesk are intended to be helpful, but it is important to note that HKD.com Limited (the "Company") does not guarantee the accuracy, completeness, or timeliness of the information provided through this platform. Users are advised to exercise their discretion when relying on Zendesk for information or assistance. ### Legal Disclaimer: The information and dialogues that occur on Zendesk are not intended to be and should not be construed as legal advice or official statements from HKD.com Limited. Users are encouraged to seek professional advice and verification for any specific legal, financial, or regulatory matters. ### Non-Admissibility in Legal Proceedings: All communications, interactions, and information exchanged on Zendesk, whether in the form of text, documents, or any other media, shall not be admissible as evidence in any court of law, tribunal, or legal proceedings, whether domestic or international. No information or dialogue from Zendesk should be used to support any legal claims, disputes, or actions. Users and visitors to Zendesk expressly acknowledge and agree that the information and interactions on Zendesk are provided for informational and general assistance purposes only, and shall not be used as a basis for legal proceedings or litigation in any jurisdiction worldwide. This clause serves as a disclaimer and a statement of the non-admissibility of Zendesk information in legal proceedings and should be included in the terms and conditions or disclaimers of Zendesk services. ### Social Media and Online Communication Channels Disclaimer: Please be advised that information and content shared on our social media and online communication channels are provided for informational purposes and should not be construed as legal advice or official statements from HKD.com Limited. For legal matters, always seek professional advice. Additionally, all content and interactions on these channels are provided out of courtesy only and shall not be admissible as evidence in any legal proceedings, and you agree to the terms of our legal disclaimer. # Environmental Social Governance ### HKD.com ESG Overview At HKD.com Limited, an International Business Company incorporated in the Republic of Seychelles, and of company number 235204 ("HKD.com"), we believe that sustainable business practices are integral to the creation of long-term value for society. We are committed to being a good corporate citizen and bringing value to our stakeholders through the integration of environmental, social, and governance (ESG) considerations in our business practices. We shepherd the resources and relationships we rely on to create and protect values for our stakeholders. In particular, HKD.com aims to be carbon neutral, and neutrality will initially be achieved by purchasing carbon offsets that are blockchain or distributed ledger technology-based instruments, in line with HKD.com’s industry positioning. As a leading player in a fast-moving space, we are positioned to shape the industry’s future. We recognize our responsibilities to our stakeholders and the importance of leading by example in a space where sustainability practices are relatively nascent. We are also excited at the opportunities for bringing innovation, digitalization, and blockchain technology into the ESG realm. We communicate our approach and strategy on sustainable business practices to our key stakeholders through daily business operations, such as regular meetings, the company website, social media platforms, training, emails, and other activities. Our key stakeholders include shareholders, potential investors, government agencies and regulators, counterparties, liquidity providers, customers, employees, industry groups, and communities. We take an active approach to identifying and creating ESG values and integrating them into HKD.com’s policies and systems, including our daily business behaviors, and operational practices. ### ESG Governance Our Executive Committee is responsible for the development of our long-term corporate strategies and values. In doing so, it considers the needs and requirements of the business, its stakeholders, and the Corporate Governance Code and ESG Reporting Guide. The Executive Committee has overall responsibility for and is engaged in, HKD.com’s ESG strategy and reporting, including evaluating and determining ESG-related risks and ensuring appropriate and effective ESG risk management and internal control systems are in place. The senior management team provides confirmation to the Executive Committee of the effectiveness of these systems. ### Corporate Social Responsibility At HKD.com, we regularly update internal documents to help guide our teams’ actions and improve overall performance in areas of Corporate Social responsibility through company policies and guidelines, including: * A comprehensive, mandatory Employee Code of Conduct detailing the expectations of staff to conduct themselves in a professional, ethical, and socially acceptable manner of the highest standards, including company-specific policies on diversity, whistleblowing, and other procedures. * An in-depth Employee Handbook providing all company employees with information on working conditions at HKD.com, company culture, and clear guidance on the company’s equal opportunity, data protection, and other core company policies. * Flexible Working Arrangements in place to cater to staff needs and in general and also specific to the COVID-19 pandemic “new normal” for working. ### Corporate Governance HKD.com’s operations are subject to the company’s internal rules and policies as well as prevailing laws, rules, and codes imposed or recommended by relevant regulatory bodies from time to time, such as the Companies Registry. HKD.com has also created the following governance documents and procedures to elaborate on our values and our commitment to high standards of Corporate Governance: * Anti-Bribery and Corruption Practices, including Anti-Money Laundering Policies * Mitigation of Conflicts of Interest * Corporate Behaviour, including employee training, and on business ethics and other key areas related to financial services and digital asset industries * A corporate data protection policy For further information regarding HKD.com’s ESG approach and the latest information, please submit your inquiry to
# List of Unsupported Countries, OFAC HKD.com Limited ("HKD.com") believes that cryptocurrency should be for everyone, but we cannot extend our services to some countries that are prohibited due to sanctions. ## As of February 2023 As a cryptocurrency exchange with licenses in multiple jurisdictions, including Australia, Canada, Dubai, Singapore, and the United States of America, we opt-in to comply with Office of Foreign Assets Control (“OFAC”) sanctions. The OFAC is a division of the US Department of Treasury that administers and enforces economic and trade sanctions based on foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy, and economy of the United States. ## Unsupported Countries HKD.com does not offer products and services to the users from the following countries and regions. * Afghanistan * Burundi * Canada * Central African Republic Sanctions * Cuba * Crimea region * Hong Kong * Iran * Iraq * Lebanon * Libya * North Korea * Somalia * South Sudan-related Sanctions * Sudan and Darfur * Syria * Venezuela * United Arab Emirates * United States of America * Yemen Additionally, we will cooperate with all OFAC and Specially Designated Nationals (SDN) and Blocked persons lists, we block individuals who threaten international stabilization efforts as defined by OFAC in the regions of: * Balkans * The Democratic Republic of the Congo-Related * Western Balkans area and Belarus as part of Ukraine-/Russia-Related Sanctions * Venezuela related sanctions * Zimbabwe related sanctions Furthermore, we will use the OFAC Consolidated sanctions list which covers non-SDN sanctions designations under the following programs: * Foreign Sanctions Evaders (FSE) List * Sectoral Sanctions Identifications (SSI) List * Palestinian Legislative Council (NS-PLC) list * The List of Foreign Financial Institutions Subject to Part 561 (the Part 561 List) * Non-SDN Iranian Sanctions Act (NS-ISA) List * List of Persons Identified as Blocked Solely Pursuant to Executive Order 13599 (the 13599 List) Globally, we will also screen the following lists: * UN Consolidated Sanctions list which covers various UN Security Council Resolutions * The EU Consolidated Sanctions list which covers the following programs enforced by the EU Security Council and maintained by the European External Actions Service: * Arms embargoes * Trade restrictions, such as import and export bans * Financial restrictions * Restricting movements, such as visa or travel bans # Referral Program Terms and Conditions This Referral Program offered by HKD.com Limited, an International Business Company incorporated in the Republic of Seychelles, and of company number 235204 (“HKD.com”) has been created to reward you, our loyal users, (“you,” “Referrer,” “Participant”), for doing what you would already do - recommending HKD.com to friends who sign on to be HKD.com users and proceed with opening an account through the HKD.com exchange platform. The following Referral Program Terms and Conditions (“Program Terms and Conditions” or “Terms and Conditions” or “Conditions”) contain important information about our Program, so please read them carefully. These Program Terms and Conditions are a binding agreement between you and HKD.com and will govern your participation in all Program offers. By participating in the Program, you agree to the HKD.com Terms and Conditions and the Privacy Policy. You are not authorized to participate in the Program if you do not agree to these Program Terms and Conditions in their entirety. HKD.com reserves the right to modify these Program Terms and Conditions at any time, at its sole discretion, and without prior notice to you. Participation in the Program is considered acceptance of Program Terms and Conditions and any modifications which might be made. HKD.com may also, in its sole discretion, change, cancel, suspend, or modify any aspect of the Program without notice. HKD.com also reserves the right to disqualify any users or prospective users at any time from participation in the Program. ## Referral Program Terms and Conditions 1. **General**\ \ i. These terms and conditions apply to the HKD.com Referral Program (“Program”). By referring a friend or otherwise participating in the Program, the referring user (“Referrer”) agrees to be bound by these terms and conditions, the HKD.com Terms and Conditions (“Conditions”), and all other related documents which are incorporated and form part of the Conditions, including but not limited to the User Agreement and the Privacy Policy.\ \ ii. All terms not otherwise defined herein shall have the definitions set forth in the Conditions.\
2. **Program Participation**\ \ **i.** To be eligible for participation in the Program, the Referrer must be an existing User and registered account holder on HKD.com. The Referrer may refer friends (each a “Referee”) to HKD.com by sharing his/her unique referral link or referral code, which is provided by HKD.com to the User in such User’s administrative interface, upon their successful registration as a User.\ \ **ii.** The terms governing the eligibility of Users to use the Sevices on the Interface as set out in the Conditions shall apply to any Referee.\
3. **Eligibility for Referral Rewards** 1. The Referrer and Referr shall be eligible for the Referral Rewards (as defined below) if such Referee is deemed a Qualified Referr. For the purposes of these terms and conditions, a “Qualified Referee” refers to a new User who has: * Registered for an account on HKD.com through the referral link or referral code sent to them by the Referrer * Been accepted as a User on HKD.com; and * Successfully completed a trade on HKD.com with a minimum notional value as updated from time to time in the Fee Schedule
4. **Referral Rewards** 1. The Referrer and Qualified Referr shall be entitled to enjoy the following referral rewards (“Referral Rewards”): * The Referrer shall receive a proportion of commissions charged by HKD.com (the “Commission Fees”) for any trades conducted by the Qualified Referee and all such persons whose referral can be ultimately traced to the Referrer (the “Referee Network”). The Referrer shall receive Commission Fees in the amount equivalent to such Referrer’s Effective Commission Base.\ \ The Referrer’s Effective Commission Base shall be calculated as (A) an adjustable percentage of commission charged by HKD.com for any trades conducted by the Qualified Referee; and/or (B) a discretionary amount of HDAO utility token or other alternative utility token given to Referrer by HKD.com campaign management team as a courtesy. * Payment of the Commission Fees shall be made directly to the Referrer’s registered account on HKD.com. There is no set time for Commission Fees distribution, and HKD.com reserves the right to change, suspend, delay, and cancel any Commission Fees the Referrer is entitled to or is not entitled to with and/or without notice or announcement of any sort. The Commission Fees can also be paid in any currency or commodity as HKD.com deem fit. By using the Program, Referrer and Referee both agree and consent to this clause. * The Referrer can earn Commission Fees for an undefined duration of the Qualified Referee on all transactions that the Qualified Referee or the Referee Network undertake on HKD.com, subject to clause 4(i)(d) below. HKD.com has the right to define the above-mentioned duration or leave it undefined as HKD.com deem fit. * If a Qualified Referee or any member of the Referee Network is banned from trading for any reason, HKD.com will not pay the Referrer any outstanding Commission Fees for the revenues generated by such banned Qualified Referee or member of the Referee Network. If a Qualified Referee is being investigated by HKD.com for any reason, HKD.com will withhold payments of any outstanding Commission Fees generated from such Qualified Referr or member of the Referee Network until the relevant investigation has been fully completed.
5. **Conduct** 1. In addition to the restrictions agreed to by the Referrer in the Conditions, the Referrer hereby agrees that the following activities are expressly prohibited, and engaging in any of these will be grounds for immediate termination and disqualification from the Program and may lead to the forfeiture of accrued, but not yet received, Referral rewards: * Direct or indirect self-referrals by the Referrer * Setting up any site redirects from any page on the website or network of websites belonging to the Referrer or any third party so that the page goes directly to HKD.com; * Modifying the Referrer’s referral link in any manner, including modifying the referral link such that the modified referral link leads to a website other than HKD.com; * Spam, bulk distribution of referral links, distribution to strangers, or any other promotion of the Referrer’s referral link that would constitute or appear to constitute unsolicited commercial email or spam under any applicable law or regulation under any jurisdiction; * Fraud, attempted fraud, or abuse of the Program or these terms and conditions; and * Selling, trading, bartering, or providing anything of value to third parties beyond the referral link or otherwise using the referral link or Referral Rewards for promotional purposes.
6. **Termination** 1. HKD.com reserves the right to terminate the Program at any time, at its sole and absolute discretion. HKD.com shall not be liable to provide any Referral Rewards in respect of any Referrals occurring after the termination of the Program in according with this Clause 6(i).
2. HKD.com may, in its sole and absolute discretion, terminate or suspend any Referrer’s participation in the Program for breach of these terms and conditions or taking any actions that are inconsistent with the intent of these terms and conditions. In connection with the above, HKD.com reserves the right to confiscate any historical Commission Fees which have been paid to the relevant Referrer or withhold payment of any outstanding Commission Fees to such Referrer.
7. **Force Majeure** 1. HKD.com shall not be liable to any Referrer or Qualified Referee for failure to distribute any Referral Rewards by reason of any acts of God, any actions, regulations, orders, or requests by any governmental or quasi-governmental entity (whether or not the actions, regulations, orders or requests prove to be invalid), equipment failure, threatened terrorist attacks, terrorist acts, air raid, blackout, earthquake, tornado, hurricane, typhoon, war, unusually severe weather, explosion, labor or material shortage, transportation interruption of any kind, work slow-down, civil disturbance, or any other similar or dissimilar cause beyond the Group’s control.\
8. **Indemnification** 1. The Referrer agrees to indemnify, defend, and hold HKD.com and its representative and agents harmless from and against any and all third-party claims, demands, liabilities, costs, or expenses, including attorney’s fees and costs, arising from or related to any breach by the Referrer of any of these terms and conditionals or any violation by the Referrer of applicable law.
9. **Important Disclaimers** 1. HKD.com makes no express or implied warranties or representations with respect to the Program, the Referral Rewards, or the Commission Fees payment arrangements (including, without limitation, their functionality, warranties of fitness, merchantability, legality, non-infringement, or any implied warranties arising out of a course of performance, dealing or trade usage). 2. This Program is not intended to be and shall not be understood, interpreted, used, marketed, promoted, or utilized as, but not limited to, an affiliate program, member-get-member (MGM) scheme, pyramid scheme, multi-level marketing, or Ponzi scheme. HKD.com recognize these activities as illegal events and will periodically review all accounts to evaluate if any Users are utilizing the Program to conduct such illegal activities for selfish gains. If such activities are identified, HKD.com will immediately report the affected and involved account(s) to the applicable authorities and suspend such accounts if necessary. 10. **Independent Investigation** * The Referrer acknowledges that he/she has read these terms and conditions and agrees to abide by these terms and conditions in their entirety. The Referrer has independently evaluated the desirability of participating in this Program and is not relying on any representation, guarantee, or statement other than that set forth in these terms and conditions.\
11. **Contact Us** * If you have any other questions about the Program, please contact us at