Acceptable Use Policy

1. Introduction

This Acceptable Use Policy ("Policy") governs your access to and use of the website, mobile application, APIs, and all products and services (collectively, the "Services") provided by Zabira Digital Services Limited ("Zabira", “Company” "we", "our", or "us").

By creating an account or using our Services, you acknowledge that you have read, understood, and agree to comply with this Policy, our Terms of Service, Privacy Policy, and all applicable laws and regulations. This Policy is intended to protect our users, preserve the integrity of the Platform, and ensure compliance with applicable legal and regulatory obligations.

2. Scope of the Policy

This Policy applies to every user, customer, merchant, business partner, and any individual or entity accessing or using the Platform. It governs all activities conducted through the Platform, including current and future services we may offer.

3. User Responsibilities

As a user of the Platform or Services, you are solely responsible for all activities conducted through your account and you agree to the following responsibilities:

• a. To provide complete, accurate, and up-to-date information at all times.
• b. To use the Services only for lawful purposes.
• c. To maintain the security and confidentiality of your account credentials.
• d. To act honestly and in good faith when interacting with the Platform and other users.
• e. To promptly notify us of any unauthorized access, suspected fraud, or security incident affecting your account.
• f. To cooperate with reasonable compliance requests, including identity verification and requests for supporting documentation.

Users must comply with all applicable local, national, and international laws and regulations governing their use of the Platform, including laws relating to financial crimes, taxation, consumer protection, sanctions, anti-money laundering, counter-terrorist financing, data protection, and digital assets.

4. Prohibited Activities

You shall not use the Platform to engage in, facilitate, or attempt to engage in any activity that:

• a. Violates any law, regulation, court order, or regulatory requirement.
• b. Involves fraud, deception, impersonation, identity theft, forgery, phishing, social engineering, or other dishonest conduct.
• c. Provides false, inaccurate, misleading, or incomplete information during registration, verification, or transactions.
• d. Attempts to gain unauthorized access to the Platform, user accounts, systems, networks, databases, or APIs.
• e. Distributes malware, ransomware, viruses, spyware, bots, or other malicious software.
• f. Interferes with the operation, availability, or security of the Platform.
• g. Harasses, threatens, extorts, defames, discriminates against, or otherwise infringes the rights of another person.
• h. Collects or uses another person's personal information without lawful authority.
• i. Circumvents Platform controls, security measures, transaction limits, or compliance procedures.
• j. Engages in market manipulation, abuse of promotional offers, or any conduct that unfairly exploits the Platform.

5. Prohibited Transactions

The Platform shall not be used for transactions involving:

• a. Illegal goods or services.
• b. Narcotics, controlled substances, or drug paraphernalia.
• c. Firearms, ammunition, explosives, or prohibited weapons.
• d. Counterfeit, stolen, pirated, or unauthorized goods.
• e. Child exploitation, human trafficking, kidnapping, or any form of abuse.
• f. Pornographic or unlawful adult content.
• g. Hate speech, terrorism, violent extremism, or organizations promoting violence or discrimination.
• h. Illegal gambling, lotteries, betting, or games of chance not authorized by applicable law.
• i. Pyramid schemes, Ponzi schemes, deceptive investment opportunities, or fraudulent financial arrangements.
• j. Bribery, corruption, sanctions evasion, tax evasion, or the concealment of criminal proceeds.
• k. Any activity reasonably believed to expose the Platform, its users, or financial partners to legal, regulatory, reputational, or financial risk.

6. Prohibited Businesses

The Platform reserves the right to refuse or terminate services to businesses engaged in activities which it may determine from time to time as prohibited by law or prohibited by reason of no authorization. Businesses prohibited by reason of no authorization are such businesses which the Platform may only provide where the user applies through established processes to obtain approval from the Platform to conduct such business on the Platform. For the avoidance of doubt, the Platform will never consent to or approve the doing of an unlawful and illegal business. Prohibited businesses including, but are not limited to:

• a. Unlicensed financial or money transmission services.
• b. Illegal investment or securities schemes.
• c. Counterfeit or unauthorized products.
• d. Drug-related businesses.
• e. Adult entertainment prohibited by law.
• f. Illegal gambling operations.
• g. Businesses primarily engaged in fraud or deceptive practices.
• h. Businesses that repeatedly generate fraudulent or disputed transactions.
• i. Any business determined by the Platform to present unacceptable legal, regulatory, financial, or reputational risk.

7. Cryptocurrency-Specific Restrictions

Users must not use the Platform to:

• a. Trade or transfer digital assets connected to criminal activity.
• b. Circumvent sanctions, regulatory restrictions, or compliance obligations.
• c. Conduct wash trading, spoofing, pump-and-dump schemes, or other manipulative trading practices.
• d. Use stolen, hacked, or unauthorized wallets or accounts.
• e. Conceal the source or destination of funds through deceptive transaction structures.

The Platform reserves the right to monitor blockchain transactions, assess wallet risk, and reject or suspend transactions that present elevated compliance risks.

8. Fraud Prevention and Identity Verification

To protect users and comply with regulatory obligations, the Platform may require identity verification, proof of address, proof of source of funds, proof of ownership of assets, business registration documents, or other supporting information.

Failure to provide requested information may result in delayed transactions, restricted account functionality, suspension, or account termination.

9. Sanctions Compliance

The Platform does not provide services to individuals, entities, or jurisdictions subject to certain economic or trade sanctions.

Users must not use the Platform to facilitate transactions involving sanctioned persons, organizations, jurisdictions, or prohibited activities.

10. Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT)

The Platform maintains AML and CFT controls designed to detect and prevent financial crime.

Users agree that the Platform may:

• a. Monitor account activity and transaction patterns.
• b. Conduct risk-based customer due diligence.
• c. Request additional documentation where appropriate.
• d. Delay, reject, or suspend transactions pending compliance review.
• e. Report suspicious activities to competent authorities where required by applicable law.

11. Intellectual Property

Users must respect the intellectual property rights of the Platform and third parties.

You may not copy, reproduce, modify, distribute, reverse engineer, or otherwise misuse our trademarks, logos, software, content, or proprietary materials without prior written authorization.

Likewise, users may not use the Platform to infringe the copyrights, trademarks, patents, trade secrets, or other intellectual property rights of others.

12. High-Risk Accounts and Enhanced Due Diligence

The Platform may classify certain users, transactions, industries, jurisdictions, or business activities as high risk.

Where appropriate, we may apply Enhanced Due Diligence (EDD), including additional identity verification, source of funds verification, transaction monitoring, or other compliance measures before allowing continued use of the Services.

13. Investigations and Reporting

The Platform reserves the right to investigate suspected violations of this Policy.

During an investigation, we may request additional information, temporarily suspend transactions, restrict account access, or preserve relevant records.

Where required or permitted by law, we may cooperate with law enforcement agencies, regulatory authorities, financial institutions, and other competent authorities.

14. Enforcement Actions

Where we reasonably determine that this Policy has been violated, we may take one or more of the following actions without prior notice where permitted by law:

• a. Decline or cancel transactions.
• b. Place transactions under review.
• c. Restrict, suspend, or terminate account access.
• d. Freeze or hold assets where legally required.
• e. Permanently prohibit future use of the Platform.
• f. Report suspected unlawful conduct to competent authorities.
• g. Pursue any other legal or contractual remedies available to us.

Our decision regarding enforcement shall be based on our assessment of the risks presented and our legal and regulatory obligations.

15. Policy Updates

We may amend this Policy from time to time to reflect changes in our Services, legal requirements, industry standards, or operational practices.

Updated versions will become effective upon publication on our website unless otherwise stated. Continued use of the Platform after the effective date of an updated Policy constitutes acceptance of the revised Policy.

16. Contact Information

If you have questions regarding this Policy, require clarification on whether a proposed activity is permitted, or wish to report suspected violations, please contact our Legal and Compliance Departments.

We encourage users to seek clarification before engaging in any activity that may raise compliance concerns.

Contact Emails:

Legal Department: [email protected]

Compliance Department: [email protected]

Support: [email protected]