TERMS AND CONDITIONS

1.1 In the Terms of Use, the following defined terms shall have the meaning ascribed to them below:

“Account” – an individual account created and maintained by the User with Lunora, which enables the User to access and use the Services in accordance with these Terms. “Applicable Law” means all statutes, laws (including rules of common law), principles of equity, rules, regulations, regulatory principles and requirements, notices, orders, writs, injunctions, judgements, bye-laws, rulings, directives, proclamations, circulars, mandatory codes of conduct, guidelines, practice notes and interpretations (whether of a governmental body, regulatory or other authority, or self-regulatory organization of which Lunora LLC is a member), that are applicable to the provision, receipt or use of the Services, or any other products or deliverables provided, used or received in connection with the Services or the Terms.

“Lunora” means Lunora LLC, a Costa Rica private limited liability company, having its registered office at San José Sfera EBC Centro Corporativo, 8th floor. San José, Escazú, Costa Rica.

“Conversion Rate” means the applicable rate used by Lunora to determine the exchange value between fiat currencies and Digital Assets. This rate is calculated based on various factors, including but not limited to, prevailing market conditions, liquidity providers, asset acquisition costs, and associated operational risks. The User acknowledges that the Conversion Rate is subject to change at any time, including after an Order has been placed, and such changes may affect the final amount received.

“Cryptocurrency” means a digital representation of value or rights that is not issued or guaranteed by any central bank or public authority, is not necessarily attached to a fiat currency, and is accepted by individuals or legal entities as a means of exchange. Cryptocurrencies can be stored, transferred, and exchanged electronically using distributed ledger technology.

“Lunora” means the brand name used by Lunora LLC, a private limited liability company incorporated in the Republic of Costa Rica, for the operation of its online platform and related Services under the domain https://cryptopayments.com. References to “Lunora” in these Terms refer to the commercial brand through which services are provided to Users, while “Lunora LLC” refers to the underlying legal entity, unless expressly stated otherwise.

“Cryptoprocessing” means a payment processing solution provided by Lunora under its official brand, enabling merchants and business clients to accept and settle transactions in Digital Assets. The service includes real-time conversion, settlement in fiat or crypto, fraud prevention, and integration support. Cryptoprocessing is offered subject to applicable compliance requirements, including KYC and KYT obligations, and is governed by these Terms and any applicable Supplementary Terms.

“Digital Assets” means a digital representation of value or rights, which may be transferred and stored electronically, using distributed ledger technology or similar technology, including, but not limited to, cryptocurrencies.

“Exchange Service” means a service provided by Lunora that facilitates the conversion between supported fiat currencies and Digital Assets, or between different Digital Assets, as listed on the Website https://cryptopayments.com. Lunora does not act as an investment advisor or offer asset management or trading advice.

“Fiat Payments” means a feature of the Services that enables Users to purchase Digital Assets using fiat currency through approved payment methods (e.g., credit or debit cards), as listed and subject to applicable fees and limits on the Website.

“Know Your Customer” or “KYC process” means the identity verification and due diligence procedures implemented by Lunora to verify the User’s identity at onboarding and at any subsequent stage, as required by Applicable Law and Lunora LLC’s internal compliance policies. KYC may include the collection and verification of personal identification documents and information.

“Know Your Transaction” or “KYT process” means the ongoing monitoring and screening of transactions by Lunora to detect suspicious activity and ensure compliance with applicable anti-money laundering and counter-terrorism financing regulations.

“Order” means any instruction submitted by the User via the Website or other approved channels to (i) purchase Digital Assets from Lunora; (ii) sell Digital Assets to Lunora; (iii) deposit Digital Assets into the Wallet; (iv) withdraw Digital Assets to an external wallet; or (v) conduct other actions involving the Services.

“Partner” means any third party service provider with which Lunora may partner in connection with the offering of any Services.

“Services” means the facilitation by Lunora of any of the following:

On-Ramp: Lunora facilitates on ramp solutions, we offer a straightforward process to convert fiat currency into various cryptocurrencies.

Off-Ramp: Lunora facilitates Off-ramp solutions, we offer a straightforward process to convert Crypto currencies into various Fiat currencies.

Crypto-to-Crypto Swaps: Lunora enables seamless exchanges between different cryptocurrencies. Whether you’re diversifying your portfolio or need to switch from one digital asset to another, our platform ensures efficient and secure swaps.

“Supplementary Terms” has the meaning given to it in Section 2.2 below.

“Terms” means the Terms of Use and any Supplementary Terms.

“Users” means you and other individuals, companies, entities, institutions or organizations that meet the criteria and conditions stipulated by Lunora and accept the Terms, access or use any Services.

“Wallet’ means a custodial digital wallet service provided or facilitated by Lunora, enabling the User to store, receive, and transfer supported Digital Assets.

“Wallet Services” means the services related to the management, storage, and transaction execution of Digital Assets through a Wallet accessible via the Lunora Website.

1.2 All capitalized terms and references used in the Terms that are defined and construed in the Lunora Terms of Use but are not defined or construed in the Terms shall have the same meaning and construction in the Terms.

2.1 Contractual Relationship

These Terms constitute a legal agreement and create a binding contract between you and Lunora LLC. These Terms are provided in English. By accepting them, you confirm that you understand and agree to the content in this language.

2.2 Supplementary Terms

Due to the rapid development of Digital Assets, these Terms of Use do not enumerate or cover all rights and obligations of each party and may not guarantee full alignment with needs arising from future developments. Therefore, the Privacy Policy and any other agreements entered into separately between you and Lunora are deemed to be supplementary terms (the “Supplementary Terms”) that form an integral part of these Terms and shall have the same legal effect.

2.3 Changes to the Terms

2.3.1 We may make changes to these Terms at any time due to changes in Applicable Law, regulatory guidance, or updates to the scope and/or functionality of the Services. We will provide you with fourteen (14) calendar days' notice before implementing such changes, as published on our Website.

2.3.2 In certain cases, we may need to make urgent changes without prior notice (e.g., in response to regulatory action or for security reasons). If we are unable to notify you in advance, we will inform you as soon as reasonably possible after such changes are implemented.

2.3.3 We may also make changes that do not materially affect your rights or the use of the Services (e.g., updates to our company name, branding, or website layout) without prior notice, as these changes do not impact your contractual relationship with us.

2.3.4 Except where changes take effect immediately (as per Clause 2.3.2), the updated Terms will come into effect fourteen (14) calendar days after you receive notice. If you do not wish to accept these changes, you may terminate these Terms as outlined in Clause 6. Your continued use of the Services after the effective date will be considered as acceptance of the updated Terms.

2.4 Prohibition of Use

While using the Services, and without prejudice to any other restrictions set out in these Terms, you agree that you will not, directly or indirectly:

• breach these Terms or any agreement entered into pursuant to, or in connection with, the Services;
• use the Services in any manner that violates public order, public morals, or the legitimate interests of others, including actions that may disrupt or negatively affect other users;
• use the Services for resale or on behalf of third parties, unless explicitly approved in writing by Lunora;
• engage in any form of market manipulation or activity intended to distort the natural pricing or transaction flow of any Digital Asset, including, without limitation: pump and dump schemes, wash trading, self-trading, spoofing, layering, or quote stuffing;
• engage in fraud or be reasonably suspected of doing so;
• use the Services to conduct lotteries; bidding fee auctions; sports forecasting or odds making; fantasy sports leagues with cash prizes; internet gaming; contests; sweepstakes; or games of chance;
• attempt to receive funds for the same transaction from both Lunora and another user;
• use the Services in a way that causes or is likely to cause complaints, chargebacks, disputes, fines, penalties, or other liabilities to Lunora or third parties;
• provide false, inaccurate or misleading information in connection with your use of the Services, in communications with us;
• (1) replicate or bypass the navigational structure or presentation of the Services in any way, in order to obtain or attempt to obtain any materials, documents or information in any manner not purposely provided through the Services; (2) connect to the Services or any of our servers or any other systems or networks of any Services by hacking, password mining/breaching/stealing or any other unlawful or prohibited means; (3) robe, scan or test the vulnerabilities of the Services, or violate any security or authentication measures on the Services or any network connected to the Services; (4) reverse look-up, track or seek to track any information of any other users or visitors of the Services; (5) take any actions that impose an unreasonable or disproportionately large load on the infrastructure of systems or networks of the Services, or the infrastructure of any systems or networks connected to the Services; (6) use any devices, software or routine programs to interfere with the normal operation of the Services or any transactions on the Services, or any other person’s use of the Services; or (7) forge headers, impersonate, or otherwise manipulate identification, to disguise your identity or the origin of any messages or transmissions you send to us;
• facilitate any viruses, Trojan horses, worms or other computer programming routines that may damage, detrimentally interfere with, surreptitiously intercept, or expropriate any system, data or information in connection with the Services;
• (1) use an anonymizing proxy; (2) use any temporary, disposable, self-destructive, or similar email address when using the Services; (3) use any device, software, or routine to bypass our robot exclusion headers, or interfere or attempt to interfere with the Services;
• create, or purport to create, any security over your fiat currency held in your Account without our prior written consent;
• Violate, or attempt to violate: (1) any applicable law, regulation, directive, or governmental requirement in any relevant jurisdiction; or (2) any rights of Lunora or third parties, including but not limited to copyrights, patents, trademarks, trade secrets, database rights, design rights, or any other intellectual property rights, as well as rights of privacy, publicity, data protection, or contractual rights;
• use Lunora’s data, content, or systems in any commercial manner without prior written consent from Lunora, including but not limited to: i. Operating any services or applications that replicate, mirror, or simulate pricing, quotes, or other informational content published by Lunora; ii. Using data feeds, APIs, or streaming tools that extract or rely on information from Lunora without express written authorization from Lunora; iii. Running any website, platform, or application that monetizes, charges users, or earns revenue (via subscriptions, advertisements, referral links, or other means) through the use, redistribution, or derivative use of Lunora’s data.
• modify, replicate, duplicate, copy, download, store, further transmit, disseminate, transfer, disassemble, broadcast, publish, remove or alter any copyright statement or label, or license, sub-license, sell, mirror, design, rent, lease, private label, grant security interests in the properties or any part of the properties, or create their derivative works or otherwise take advantage of any part of the properties without prior written consent from Lunora;
• (1) use any deep linking, web crawlers, bots, spiders or other automatic devices, programs, scripts, algorithms or methods, or any similar or equivalent manual processes to access, obtain, copy or monitor any part of the Lunora platform, or replicate or bypass the navigational structure or presentation of the Services in any way, in order to obtain or attempt to obtain any materials, documents or information that are intended to be provided by Lunora to enable access to the Services; (2) attempt to access any part or function of the Lunora platform without authorization, or connect to the Services or any Lunora servers, or any other systems or networks related to the Services, by hacking, password mining, or any other unlawful or prohibited means; (3) probe, scan, or test the vulnerabilities of the Services or any network connected to the Lunora platform, or violate any security or authentication measures on the Services or any network connected to them; (4) reverse look-up, track or seek to track any information of any other Users or visitors of Services; (5) take any actions that imposes an unreasonable or disproportionately large load on the infrastructure of systems or networks of the Services or Lunora, or the infrastructure of any systems or networks connected to the Services; (6) use any devices, software or routine programs to interfere with the normal operation of the Services or any transactions on the Services, or any other person’s use of the Services; (7) forge headers, impersonate, or otherwise manipulate identification, to disguise your identity or the origin of any messages or transmissions you send to Lunora, and/or (8) use Services in an illegal way.
• you may not access, use, or attempt to access or use, the Services directly or indirectly in connection with (1) any jurisdictions that Lunora, at its sole discretion, has classified as restricted, including but not limited to: Iran, North Korea, Myanmar (See Section 8.1 for the full list); or (2) any individuals or entities that Lunora has identified as high-risk or restricted, including, but not limited to, those designated on sanctions or restriction lists maintained by: the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC), or the U.S. Department of Commerce Denied Persons List and Entity List. Lunora reserves the right to update and enforce such restrictions without prior notice, and to take any necessary action, including account suspension, funds freezing, or termination of Services

3.1 Activation

Activation of the Services may require Lunora and/or Partners to be provided with information including your real name, and phone number or email address, as well as any other information that may reasonably be required by Lunora for the purpose of activation, and accept the Terms and the Privacy Policy. For using certain Services you may also be required to agree to separate terms and/or conditions of the relevant Partners. Lunora may refuse, in its sole discretion, to activate the Services for you. You warrant that all information provided by you for activation of Services is true, complete, accurate and not misleading, and you agree to timely update any information you provided to Lunora to maintain the integrity and accuracy of the information. As a User you can only activate the Services once.

3.2 Eligibility

By using the Services, you represent and warrant, that:

• a ) as an individual, you are at least 18 or are of legal age to form a binding contract under Applicable Laws at the date of registration;
• b ) as an individual, legal person, or other organisation, you have full legal capacity and sufficient authorisations to enter into the Terms;
• c ) you have not been previously suspended or removed from using any Services;
• d ) you have not previously activated Services as a different User;
• e ) you are not based, located or residing in, nor acting on behalf of any person or entity based, located or residing in sanctioned countries and any other country on Lunora restricted or prohibited countries list and such other locations as designated by Lunora;
• f ) you are not a citizen or resident of the United States of America, nor are you accessing the Services from any location within the United States;
• g ) you are not a Politically Exposed Person (PEP), a family member of a PEP, or a known close associate of a PEP, as defined under relevant anti-money laundering laws and regulations, unless explicitly approved through enhanced due diligence by Lunora;
• h ) if you act as an employee or agent of a legal entity, and enter into the Terms on their behalf, you represent and warrant that you have all the necessary rights and authorizations to bind such legal entity;
• i ) your use of any Services will not violate any Applicable Law;
• j ) you confirm that you are not subject to any international sanctions and have not been listed on any economic sanctions or restricted persons lists, including but not limited to: i. the Specially Designated Nationals (SDN) List maintained by the U.S. Office of Foreign Assets Control (OFAC);

You further confirm that you are not directly or indirectly associated with, employed by, or receiving funding or income from any person, entity, or jurisdiction that is subject to such sanctions.

Please note that the Services may not be available in certain jurisdictions or regions or to certain users. Lunora reserves the right to change, modify or impose additional restrictions at its discretion at any time. Lunora reserves the right to refuse, in its discretion, the provision of Services to certain companies and/or individuals.

3.3 User Identity Verification

(a) In order to use the Services you may be required to provide all the required personal information for identity verification purposes. Scope of required information may change from time to time and Lunora or Partners may require additional information, if required by Applicable Law or in order to ensure accurate identity verification. Such information will be used to verify the Users’ identity, identify traces of money laundering, terrorist financing, fraud and other financial crimes through Lunora, or for other lawful purposes stated by Lunora. We will collect, use and share such information in accordance with our Privacy Policy. (b) In addition to providing such personal data, you agree to allow Lunora to keep a record of that personal data during the period for which you use the Services and/or remain an active User and within eight (8) years after the Terms or any part thereof are terminated, or for any other period required by Applicable Law, in compliance with global industry standards on data storage. You also authorize Lunora to conduct necessary investigations directly or through a third party to verify your identity or protect you and/or us from financial crimes, such as fraud. The information Lunora requires to verify your identity may include, but is not limited to, your name, surname, government-issued personal code,and/or date of birth, citizenship, email address, contact information, phone number, username, government-issued ID, and other information collected during account registration. When providing the required information for the purpose of user identity verification, you confirm and warrant that all information provided by you is true, complete, accurate and not misleading. For more information on how we process and store personal data please refer to our Privacy Policy. (c) After registration, you must ensure that the information is true, complete, and timely updated when changed. If there are any grounds for believing that any of the information you provided is incorrect, false, outdated, misleading or incomplete, Lunora reserves the right to send you a notice to demand correction, directly delete the relevant information, and/or, as the case may be, terminate all or part of any Services provided for you. If any of the information provided by you is untrue or incomplete, or if we are unable to reach you with the contact information you provided in a reasonable time, you shall be fully liable for any loss or expense caused to Lunora due to your action or lack thereof during your use of any Services. You hereby acknowledge and agree that you have the obligation to update all the information if there is any change. By using the Services, you hereby authorize Lunora to conduct investigations that Lunora considers necessary, either directly or through a third party, to verify your identity or protect you, other users and/or Lunora from fraud or other financial crimes, and to take necessary actions based on the results of such investigations. You also acknowledge and agree that your personal data may be disclosed to credit bureaus and agencies for fraud prevention or financial crime prevention as well as any other governmental, administrative or judicial authorities. (d) Lunora performs identity verification and transaction monitoring in accordance with the Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania and its implementing regulations.

3.4 Services Usage Requirements

Lunora reserves the right to suspend, freeze or cancel the use of the Services by persons other than the eligible User. If you suspect or become aware of any unauthorized use of your username and password, you should notify Lunora immediately. Lunora assumes no liability for any loss or damage arising from the use of Services by you or any third party with or without your authorization. Further details regarding suspension, termination, and account restrictions can be found in Section 6 Termination.

3.5 Account Security

You shall agree to treat your access credentials (such as username and password) as confidential information, and not to disclose such information to any third party. You also agree to be solely responsible for taking the necessary security measures to protect your credentials and personal data. Lunora will not be liable for any loss resulting from your failure to adhere to these rules. In addition, Lunora requires the use of two-factor authentication (2FA) to access Services. You are solely responsible for securely storing your 2FA credentials, including backup codes and any authentication devices, and must not share them with anyone. Failure to maintain the confidentiality of your 2FA credentials may result in unauthorized access to your account. Lunora disclaims any liability for losses resulting from your failure to adequately secure your 2FA authentication tools. You should be solely responsible for keeping your credentials safe, and be responsible for all your transactions. Lunora assumes no liability for any loss or consequences caused by authorized or unauthorized use of your credentials, including but not limited to information disclosure, information release, consent or submission of various rules and agreements by clicking on the website, online agreement renewal, etc. By activating the Services, you hereby agree that:

i) you will notify Lunora immediately if you are aware of any unauthorized use of your credentials or any other violation of security rules; ii) you will strictly abide by all mechanisms or procedures of Lunora regarding security, authentication, charging, and withdrawal; iii) Lunora has the right to investigate any violation of the Terms in order to, unilaterally determine whether you have violated any Terms, and may take relevant actions under relevant regulations without your consent or prior notice. Examples of such actions including, but are not limited to:

locking and closing order requests; limiting or freezing your access to the Services; reporting the incident to the authorities; publishing the alleged violations and actions that have been taken; deleting any information you published that are found to be violations.

3.6 Personal Data and Privacy Policy

Access to the Services will require the submission of certain personally identifiable information. Please review the Privacy Policy as available from time to time for a summary of Lunora’s guidelines regarding the collection and use of personally identifiable information. All personal data is processed by Lunora in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation - GDPR) and the Law on Legal Protection of Personal Data of the Republic of Lithuania. You have the right to access, rectify, or erase your data, restrict or object to processing, and file a complaint with the State Data Protection Inspectorate (VDAI) at www.vdai.lrv.lt.

3.7 Complaints Handling

Lunora is committed to maintaining a transparent and accessible complaints management process. If you wish to file a complaint concerning the Services, you are required to follow the procedure outlined below.

3.7.1 Submission of Complaints All complaints must be submitted using the official Lunora Complaint Form. Informal messages or free-form letters (whether via email or other channels) will not be accepted as valid complaints. The Complaint Form is available in English and Lithuanian and can be easily accessed in the “Complaints” section of our official website at cryptopayments.com. The form must be completed in full and signed using a qualified electronic signature. You may submit the completed form in either of the following ways: Via Lunora Account: Log in to your Lunora account and submit the form directly from the “Complaints” section. This method will be considered equivalent to a qualified electronic signature, provided that your KYC verification is valid and not expired.

3.7.2 Acknowledgment and Review Upon receiving a valid complaint, Lunora will confirm receipt without undue delay using the contact details provided. All complaints will be registered in our internal complaint log. In addition to formal complaints, Lunora monitors general service feedback and technical issues reported via Customer Support. These reports are tracked and reviewed on a periodic basis (at least once every six months) to identify systemic issues or service improvement opportunities.

3.7.3 Handling and Response All complaints will be reviewed and handled by the Compliance team or other appropriately designated personnel. A formal response will be provided as soon as reasonably practicable and in accordance with regulatory time limits. If you remain dissatisfied with our response, you may escalate the complaint following the steps set out in Section 9 (Governing Law & Dispute Resolution).

3.7.4 Additional Information For a complete overview of how Lunora manages customer complaints, including internal tracking, responsibilities, escalation procedures, and regulatory compliance, you may consult our Complaints Policy, available at: cryptopayments.com.

4.1 General

Upon completion of your activation and identity verification, you may use the various Services in accordance with the provisions of the Terms. Lunora has the right to:

• a) partner with third party service providers, including Partners, in order to offer any of the Services or facilitate their provision;
• b) provide, modify or terminate any Services in accordance with rules set out in Terms; and/or
• c) allow or prohibit, restrict, suspend, freeze, or block some Users’ use of any Services in accordance with the Terms.

4.2 License

• a) Provided that you comply with the Terms at all times during your usage, Lunora grants you a revocable, limited, royalty-free, non-exclusive, non-transferable, and non-sublicensable license to access and use the Lunora Services through your computer, mobile device or other Internet compatible devices for your personal/internal purposes. You are prohibited to use any Services for resale or commercial purposes, including transactions on behalf of other persons or entities. All the above actions are expressly prohibited and constitute a material violation of the Terms. The content layout, format, function and access rights regarding any Services should be stipulated in the discretion of Lunora. Lunora reserves all rights not expressly granted in the Terms. Therefore, you are hereby prohibited from using any Services in any way not expressly authorized by the Terms.
• b) The Terms only grant a limited license to access and use the Services. Therefore, you hereby agree that when you use any Services, Lunora does not transfer any Services or the ownership of intellectual property rights of any Lunora intellectual property to you or anyone else. All the text, graphics, user interfaces, visual interface, photos, sounds, process flow diagrams, computer code (including html code), programs, software, products, information and documents, as well as the design, structure, selection, coordination, expression, look and feel, and layout of any content included in the services or provided through the Services, are exclusively owned, controlled and/or licensed by Lunora or its members, parent companies, licensors or affiliates.
• c) Lunora owns any feedback, suggestions, ideas, or other information or materials (hereinafter collectively referred to as “Feedback”) about Lunora or the Services that you provide through email, or other channels. You hereby transfer all rights, ownership and interests of the Feedback and all related intellectual property rights to Lunora.

By accepting the Terms, you acknowledge and agree that:

Lunora may partner with any Partners in connection with any Services and that, if applicable, you will open an account with such Partners by completing the relevant registration and identity verification process for such account, and by accepting any user agreements, terms and conditions, policies and procedures or similar documents of any Partners; you also acknowledge that Lunora does not assume any responsibility over actions, documents or services provided directly by any Partner or any other third party provider; any payments expressed in any fiat currencies and which have been made in connection with any Services may not be canceled, recalled or refunded, and that any chargeback requests in connection with any Lunora Services that involve a Partner, are subject to that Partner's policies and procedures.

4.3.1 Wallet Services Lunora provides the Users with digital wallet services (“Wallet Services”) that enable the Users to deposit, receive, store, and withdraw supported Digital Assets via the Website. Wallet Services are a core part of the Services offered by Lunora and are governed by these Terms. Wallets provided by Lunora are custodial. This means that Lunora manages and safeguards the private keys associated with the Wallets and retains operational and security control over wallet infrastructure. While Users retain beneficial ownership of the Digital Assets held in their Wallets, they acknowledge and agree that Lunora administers custody on their behalf. Wallet Services include the following core functionalities:

4.3.1.1 Deposits: Users may deposit supported Digital Assets into their Wallet by transferring assets from an external wallet. It is the User’s sole responsibility to ensure that only supported assets and blockchain networks are used, and that any necessary tag, memo, or reference information is correctly included. Lunora shall not be held liable for any loss resulting from deposit errors, including the use of unsupported networks or incorrect transaction data.

4.3.1.2. Withdrawals: The Users may request to withdraw supported Digital Assets from their Wallet to an external address. The User is solely responsible for the accuracy of the destination address and for covering all applicable network and transaction fees. Lunora may reject or delay withdrawals if risk indicators or compliance concerns arise during transaction review.

4.3.1.3 Storage and Security: Lunora implements strict technical and organizational security measures, including multi-signature cold storage and encrypted infrastructure. However, the Users remain responsible for securing their access credentials and enabling additional protection features such as two-factor authentication (2FA).

4.3.1.4 Monitoring and Compliance: All Wallet activity is subject to KYT (Know Your Transaction) monitoring. Lunora reserves the right to freeze or block Wallet balances or individual transactions that are considered suspicious, non-compliant, or connected to high-risk wallets or jurisdictions.

4.3.1.5 Service Limitations: Lunora does not guarantee uninterrupted access to Wallet Services and may, without prior notice, restrict or suspend Wallet functionality in cases involving legal obligations, technical issues, security threats, or suspected policy violations.

4.3.1.6 No Interest or Yield: Unless otherwise expressly agreed in writing, Wallet balances do not generate interest, rewards, or returns of any kind. Lunora does not engage in rehypothecation, lending, or staking of User funds without the User’s prior informed consent.

4.3.1.7 Liability: Lunora shall not be liable for losses resulting from the User’s error, third-party attacks, blockchain congestion, service downtime, or events beyond Lunora’s reasonable control. Digital Assets held in your Wallet are not protected by the Republic of Costa Rica’s deposit guarantee scheme or any investor protection mechanism. Lunora does not offer any guarantee of asset preservation or return. Use of the Wallet Services is conditioned upon ongoing compliance with these Terms, Applicable Law, and any additional internal policies determined by Lunora.

4.3.2 Know Your Transaction (KYT) Process Lunora will conduct the Know Your Transaction (“KYT”) process on all transactions carried out through the Services. This includes, but is not limited to, monitoring and screening of transaction participants, associated Cryptocurrency wallets, wallet history, geographic origin of funds, and any unusual or high-risk behavioral patterns identified in the User’s transaction activity. During the KYT process, Lunora may request additional information or documentation from the User regarding the specific transaction, the source or destination of funds, and any other involved parties, in order to assess the nature, purpose, and legitimacy of the activity. Transaction monitoring is performed in real-time and may include: (i)Identification of abnormal transaction behavior (e.g., rapid transfers, structuring, volume spikes); (ii) IP address and geolocation checks; (iii) Screening against international sanctions and watchlists; (iv) Risk scoring based on cumulative transaction history. Lunora uses automated tools and the services of specialized third-party providers to perform transaction analysis, wallet risk classification, and blockchain intelligence gathering. These tools support real-time alerts and internal compliance decision-making. All personal and transactional data processed during the KYT procedure is strictly limited to what is necessary to comply with legal and regulatory requirements. Such data is protected by adequate technical and organizational security measures in accordance with applicable data protection laws. Failure by the User to provide requested information may result in transaction delays, suspension of Services, account freezing, or reporting to competent supervisory or law enforcement authorities, where legally required. Lunora reserves the right to block, delay, or decline any transaction deemed high-risk, potentially suspicious, or in violation of Applicable Law or internal compliance policies.

In accordance with MiFID II requirements, all applicable charges, commissions, and other potential costs are clearly disclosed prior to your use of our Services. Detailed information about all fees is provided in our publicly available Fee Schedule, which you can access here: cryptopayments.com. This document includes: A full list of all applicable service fees, including the inactivity fee for dormant accounts (up to 100 EUR per month), as stated in Section 4.5. All applicable transaction fees for deposits, withdrawals, conversions, and other operations, as well as any third-party fees that may apply. Clear information on when and how fees will be deducted from your account. The Fee Schedule is updated regularly, and we will inform you of any material changes as required by applicable law.

By using our Services, you confirm that you have read, understood, and agreed to the current Fee Schedule. Should you have any questions about applicable fees, you may contact our Customer Support team at any time.

By activating an account, you explicitly consent to the application of the dormant account fee as described below, in accordance with Costa Rica’s consumer protection law. Lunora applies a service fee to maintain user accounts and platform operations. If a User account holds a positive balance but remains inactive for a period of six (6) consecutive months, Lunora reserves the right to initiate a gradual deduction of service fees from the remaining balance. Prior to initiating such deductions, Lunora will make reasonable efforts to contact the User through all available communication channels associated with the account, including but not limited to email, phone, and in-platform notifications. If the User does not respond or take action to reactivate the account within thirty (30) calendar days from the last attempted contact, Lunora may begin applying the service fee periodically until the account balance reaches zero (0). The dormant account fee shall apply on a monthly basis, up to a maximum of 100 EUR per month, or the equivalent in another supported currency, until the account balance is fully depleted. Once the account balance has been fully depleted, the User’s account will be considered dormant and may be closed permanently. Any attempts to access a closed account will require a new registration, subject to applicable KYC and onboarding procedures. The applicable service fee amount, frequency, and conditions shall be made available on the Lunora Website and may be updated from time to time. It is the User’s responsibility to remain informed of applicable fees.

4.6.1 Refunds The User may request a refund by submitting a written request through the ticketing system available on the Lunora Website or by contacting support@cryptopayments.com via the email address previously registered with Lunora. All refund requests must include the relevant transaction reference and may require the User to provide additional Know Your Customer (KYC) documentation and transaction details, as deemed necessary by Lunora for compliance and verification purposes. Refunds are not guaranteed and may only be granted at the sole and absolute discretion of Lunora. Refunds are considered only in the event of a technical or operational error directly attributable to Lunora. Orders successfully completed through the Services, including but not limited to cryptocurrency sent to the wallet address specified by the User, are final and non-refundable. Refunds will not be processed in the event of: (i) Incorrect wallet addresses provided by the User; (ii) Data mismatch or incomplete order details; (iii) Suspicious behavior, including possible fraud or attempted abuse of the refund process. In cases involving high-risk transactions (e.g. suspected fraud, stolen funds, money laundering, terrorist financing), Lunora reserves the right to freeze the funds or suspend the User’s Account for further investigation, and may report the incident to competent authorities. If a refund is approved, (i) It will be issued based on the prevailing Conversion Rate at the time of processing. (ii) the User acknowledges that market fluctuations may result in value differences compared to the original transaction amount. (iii) Refunds may be subject to administrative or processing fees, which may vary depending on the payment method used. (iv) Refunds will be made only to the original payment source from which the funds were received. Under no circumstances will Lunora process refunds to third-party accounts or unrelated payment instruments. Approved refunds may be processed using one of the following methods: SEPA bank transfer: Subject to a €200 processing fee (plus bank fees); SWIFT bank transfer: Subject to a €200 processing fee (plus bank fees); Virtual currency (to original sending wallet): Subject to a €10 processing fee (plus applicable miner fees);

Refund timelines: The enrollment of the refund to the User’s bank account or wallet may take up to 10 business days, depending on the policies and procedures of the receiving financial institution or blockchain network. Lunora shall not be held responsible for delays caused by such external parties. All refund requests are reviewed on a case-by-case basis. Lunora reserves the right to reject any refund request if the original transaction was completed in accordance with the User’s instructions and the Terms.

4.6.2. Refund Conditions and Non-Refundable Transactions Refunds may only be issued to the same source account, card, or digital wallet from which the original payment was received. Under no circumstances will refunds be made to third-party accounts, wallets, or unidentified recipients. This measure is implemented in full compliance with applicable AML and KYC regulations. Users are hereby informed and acknowledge that cryptocurrency transactions are inherently final and non-refundable once confirmed on the blockchain. Lunora does not have the technical ability to reverse or cancel completed transactions. Accordingly, refunds for cryptocurrency transactions are generally not permitted unless a clear and verifiable technical or operational error on Lunora’s part is demonstrated. Lunora reserves the right to request additional documentation and verification before processing any refund, and any approved refund shall be issued based on the prevailing Conversion Rate at the time of refund execution. Administrative or processing fees may also apply.

4.6.3 Chargebacks The User agrees to make every reasonable effort to resolve any payment-related issue directly with Lunora prior to initiating any chargeback request with the User’s financial institution or payment provider. All such communications must be initiated via the official support ticket system or by email to support@Lunora.io using the User’s registered contact email. Lunora will investigate any chargeback initiated by the User and reserves the right to provide relevant evidence to the issuing bank or card network, including proof of Order completion, delivery of Services, or any other relevant documentation. During the course of the chargeback investigation, Lunora reserves the right to temporarily suspend the User’s account and restrict access to any associated Digital Assets held in the User’s Wallet until the matter is resolved. This section does not limit or exclude any statutory rights the User may have under applicable law, including rights to seek recourse from their financial institution or payment provider.

4.6.4 Order Amendments

4.6.4.1 Order Execution and Completion The User acknowledges that the execution and completion of any Order submitted via the Lunora platform is subject to the operational capabilities, system availability, and applicable compliance checks of Lunora. Upon confirmation of the Order by the User, Lunora will initiate processing without undue delay. However, the actual execution time may vary due to factors including, but not limited to: (i) Blockchain network congestion; (ii) Third-party payment processor delays; (iii) Internal compliance or risk assessment procedures; (iv) Market conditions and liquidity availability; (v) Force majeure or system maintenance events.

Lunora does not guarantee real-time execution of Orders and shall not be held liable for any delays or losses resulting from factors beyond its reasonable control. The User is solely responsible for monitoring the status of their Orders and for providing accurate information during submission. An Order shall be deemed completed once: (i) The purchased Cryptocurrency has been successfully delivered to the User’s designated wallet; (ii) The fiat equivalent has been transferred to the User’s verified payment account; or (iii) The Order status is marked as “Completed” within the User’s Account interface. Blockchain based transactions are irreversible once confirmed. Network delays, forks, or protocol changes may affect execution time or transaction outcome. Lunora is not responsible for losses caused by such underlying blockchain mechanics.

4.6.4.2 Revoking or Amending Orders Once an Order has been submitted and confirmed, it is considered final and binding. Lunora does not guarantee that an Order can be revoked or amended after submission. To request a revocation or amendment, the User must immediately submit a written request via the ticket system available on the Lunora Website or by email to support@Lunora.io, using the email address registered with Lunora. All such requests must include a clear explanation of the amendment or revocation reason and may require the User to provide additional KYC information and transaction documentation. Lunora, at its sole and absolute discretion, may decide whether to approve such requests. If the Order has already been processed, submitted to the blockchain, or otherwise rendered irreversible, the request will be denied. In cases where revocation or amendment is permitted: (i) additional administrative fees may apply; (ii) Lunora may require further verification or information to complete the process.

IMPORTANT: All Orders to sell Cryptocurrency for fiat currency are final and cannot be amended or revoked once confirmed. This includes any Orders that have been submitted but are pending execution on the blockchain.

4.6.5 Minimum Transaction Amount

All Orders submitted via the Lunora platform are subject to a minimum transaction amount of ten (10) Euros (€10) or the equivalent in another supported fiat or digital currency. Orders below this threshold will be automatically rejected and will not be processed. Lunora reserves the right to amend the minimum transaction amount at any time, with or without prior notice. The current minimum threshold will always be displayed on the Website or in the Order interface prior to submission. It is the User’s responsibility to ensure that any submitted Order meets the applicable minimum transaction requirement. Any fees or losses resulting from failed transactions due to insufficient amounts shall be borne solely by the User.

5.1 Disclaimer of Warranties

To the fullest extent permitted by applicable law, the Services, any Lunora materials, and any product, feature, or functionality provided by or on behalf of Lunora are offered strictly on an “as is” and “as available” basis. Lunora expressly disclaims, and you hereby waive, any and all other warranties of any kind - whether express or implied - including, without limitation, implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, or warranties arising from prior course of performance or course of dealing. Without limiting the foregoing, Lunora does not represent or warrant that the site, the Services or Lunora materials are accurate, complete, reliable, current, error-free, or free of viruses or other harmful components. Lunora does not guarantee that any order will be executed, accepted, recorded or remain open. Except for the express statements, agreements and rules set forth in these terms, you hereby acknowledge and agree that you have not relied upon any other statement or agreement, whether written or oral, with respect to your use and access of Services. Without limiting the foregoing, you hereby understand and agree that Lunora will not be liable for any losses or damages arising out of or relating to:

a) any inaccuracy, defect or omission of digital assets price data, b) any error or delay in the transmission of such data, c) interruption in any such data, d) regular or unscheduled maintenance carried out by Lunora and service interruption and change resulting from such maintenance, e) any damages incurred by other users’ actions, omissions or violation of these terms, f) any damage caused by illegal actions of other third parties or actions without authorized by Lunora; and g) other exemptions mentioned in disclaimers and platform rules issued by Lunora.

5.2 Disclaimer of Damages and Limitation of Liability

5.2.1 To the maximum extent permitted by any laws or regulations, in no event will Lunora, its affiliates and their respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers or contractors be liable for any incidental, indirect, special, punitive, consequential or similar damages or liabilities whatsoever (including, without limitation, damages for loss of data, information, revenue, profits or other businesses or financial benefits) arising out of Services, any performance or non-performance of Services, or any other product, service or other item provided by or on behalf of Lunora and its affiliates, whether under contract, statute, strict liability or other theory even if Lunora has been advised of the possibility of such damages except to the extent of a final judicial determination that such damages were a result of Lunora’s gross negligence, fraud, willful misconduct or intentional violation of law. For jurisdictions that do not allow the foregoing exclusion or limitation of incidental or consequential damages, such exclusion or limitation may not apply to you.

5.2.2 Notwithstanding the foregoing, in no event will the liability of Lunora, its affiliates and their respective shareholders, members, directors, officers, employees, attorneys, agents, representatives, suppliers or contractors arising out of the Services offered by or on behalf of Lunora and its affiliates, any performance or non-performance of the Services, or any other product, service or other item, whether under contract, statute, strict liability or other principles of law, exceed the amount of the fees paid by you to Lunora under these terms in the twelve-month period immediately preceding the event giving rise to the claim for liability.

5.3 Indemnification

You agree to indemnify and hold harmless, to the highest extent possible under the Applicable Law, Lunora, their affiliates, contractors, licensors, and their respective directors, officers, employees and agents from and against any claims, actions, proceedings, investigations, demands, suits, costs, expenses and damages (including attorneys’ fees, fines or penalties imposed by any regulatory authority) arising out of or related to:

a) your use of, or conduct in connection with, any Services; b) your breach or our enforcement of the Terms or c) your violation of any law, regulation, or rights of any third party during your use of Services. If you are obligated to indemnify Lunora, their affiliates, contractors, licensors, and their respective directors, officers, employees or agents pursuant to the Terms, Lunora will have the right, in its sole discretion, to control any action or proceeding and to determine whether Lunora wishes to settle, and if so, on what terms.

5.4 Limitation of Liability

To the fullest extent permitted by applicable law, Lunora’s total cumulative liability arising out of or in connection with the provision or use of the Services, whether in contract, tort (including negligence), breach of statutory duty or otherwise, shall in all circumstances be limited to the lesser of: (i) the total amount of fees paid by the User to Lunora in connection with the specific transaction giving rise to the liability; or (ii) 1% of the total transaction amount, in cases where the transaction was rejected by Lunora's compliance department. Lunora shall not be liable for: (i) any indirect, incidental, special, punitive or consequential losses or damages of any kind; (ii) any loss of profits, revenue, business opportunity, goodwill, or data; (iii) any damages resulting from blockchain network delays, third-party service provider failures, market volatility, or force majeure events. Nothing in these Terms shall limit or exclude liability for: (i) death or personal injury resulting from Lunora’s gross negligence or willful misconduct; (ii) fraud or fraudulent misrepresentation; (iii) any other liability that cannot be limited or excluded under applicable law. This limitation applies regardless of whether Lunora has been advised of the possibility of such damages and even if the remedies fail of their essential purpose.

6.1 Suspension of access to Services

You agree that Lunora shall have the right to immediately limit or suspend your access to any Services, freeze or lock the funds in connection with any Services for material reasons, including if Lunora suspects you or your use of the Services to be in violation of the Terms, our Privacy Policy, or any Applicable Laws. You agree that Lunora shall not be liable to you for any permanent or temporary modification of Services provided to you, the freezing or locking of any funds in connection with such Services, or suspension or termination of your access to all or any portion of any Services. Lunora shall reserve the right to keep and use the transaction data or other information related to or derived from such Services. The above account controls may also be applied in the following cases:

i) Provision or use of Services is subject to a governmental proceeding, criminal investigation or other pending litigation; ii) We detect unusual activities; iii) We detect unauthorized access; and/or iiii) We are required to do so by a court order or command by a regulatory/ government authority.

6.2 Right to terminate by Lunora

6.2.1 In case of any of the following events, Lunora shall have the right to directly terminate the Terms and restrict your use of Services:

a) you breach any provision of the Terms; b) you allegedly register repeatedly, or register in any other person’s name as a User, directly or indirectly; c) the information that you have provided is untruthful, inaccurate, outdated, misleading or incomplete; d) when the Terms are amended, you state your unwillingness to accept the amended Terms by applying for termination of these Terms or any part thereof or by way of other conduct or means; e) you request that any Services be terminated; and f) any other circumstances where Lunora reasonably deems it should terminate any Services. g) the user may request the deletion of their account at any time by submitting a written request to Lunora through official support channels. Lunora will process such requests within ten (10) business days of receipt, provided that there are no pending obligations, investigations, or legal/regulatory grounds requiring data retention. In cases where regulatory obligations apply, Lunora may retain certain data in accordance with applicable laws, including anti-money laundering and data retention requirements, while restricting access to the account.

6.2.2 Should we terminate the Terms with respect to you, the account and transactional information that meet data retention standards will be securely stored for 8 years, or other period, if provided so by the Applicable Law. In addition, if a transaction is unfinished during the account termination process, Lunora shall have the right to notify your counterparty of the situation at that time. You acknowledge that a user-initiated account exit (right to erasure under GDPR or other equivalent regulations) will also be subjected to the termination protocol stated above.

6.2.3 If Lunora is informed or has reasonable grounds to suspect that any funds held in your Account constitute stolen assets or are otherwise not lawfully owned or controlled by you, Lunora may, at its sole discretion and without obligation, place an administrative hold on the affected funds. If such a hold is applied, Lunora may maintain the restriction until the matter is resolved and sufficient evidence of lawful ownership is provided, in a form acceptable to Lunora. Lunora will not act as a mediator or decision-maker in any such dispute. You acknowledge and agree that Lunora shall not be held liable for any consequences resulting from such a hold, including your inability to access, transfer, or use the affected funds during the hold period.

6.3 Remaining Funds After Termination

Except as set forth in Section 6.4 below, once the Terms or any respective part thereof are terminated with respect to the User, all fees, expenses, charges, liabilities and any other amount owed to Lunora as of the date of termination shall become payable immediately to Lunora, and you hereby authorize Lunora to set off such amount from your accounts without further notice. All termination requests must be submitted exclusively via the User’s officially registered email address. Lunora does not accept termination requests submitted via chat, phone call, or any other informal communication channels. After settlement of all outstanding obligations, the User shall withdraw all remaining funds from their Account within ten (10) Business Days. Prior to such withdrawal, the User must provide verifiable proof of ownership of the destination wallet. Lunora reserves the right to reject withdrawals to third-party wallets or accounts where ownership cannot be clearly established.

6.4 Remaining Funds After Termination Due to Fraud, Violation of Law, or Violation of The Terms

Lunora maintains full custody of the User funds and User data/information, any of which may be turned over to governmental authorities in the event of termination or suspension/closure arising from fraud investigations, investigations of violation of law or violation of the Terms. Lunora does not assume liability for losses that you may have incurred as a result of you voluntarily sending funds to a third party in connection with an investment scam or otherwise, or if you mistakenly sold or purchased Digital Assets or sent them to the wrong addressee. Lunora does not assume any liability for losses that you sustain as the result of your knowingly and voluntarily participating in fraudulent or illegal activity.

Lunora is not your broker, intermediary, agent, or advisor and does not have any fiduciary relationship or obligation to you in connection with your use of the Services or any decisions you make while using them. No communication or information provided to you by Lunora shall be construed as investment advice, financial advice, or any other form of recommendation or guidance. Lunora does not provide trading services or investment advisory services of any kind. Unless otherwise specified in these Terms, all asset exchanges or conversions carried out through the Services are executed automatically based on the parameters you provide. You are solely responsible for determining whether any digital asset-related activity is appropriate for you, taking into account your personal objectives, financial situation, and risk tolerance. Any decision made to interact with Digital Assets is your responsibility, and Lunora shall not be liable for any resulting loss or liability. You should seek independent legal, financial, or tax advice to evaluate the suitability of any activity involving Digital Assets. Lunora does not recommend or suggest that you should buy, sell, hold, or otherwise engage with any specific Digital Asset. Prior to any such decision, you are expected to conduct your own due diligence and consult qualified professionals. Lunora shall not be held responsible for your decisions based on any general information provided via the Services.

It is Users’ responsibility to abide by local laws in relation to the legal usage of the Services in their local jurisdiction as well as other laws and regulations applicable to Users. Users must also consider, to the extent of their local laws, all aspects of taxation, the withholding, collection, reporting and remittance to their appropriate tax authorities. All users of Services acknowledge and declare that their funds come from legitimate sources and do not originate from illegal activities; users agree that Lunora will require them to provide or otherwise collect the necessary information and materials as per relevant laws or government orders to verify the legality of the sources and use of their funds. Lunora maintains a stance of cooperation with law enforcement authorities globally and may be obliged to seize, freeze, terminate Users’ accounts and funds which are flagged out or investigated by legal mandate.

Cleverlee does not offer or provide Services to individuals or entities located, incorporated, or otherwise established in jurisdictions subject to international sanctions or considered high-risk from a compliance, regulatory, or reputational perspective. The following jurisdictions are strictly prohibited from accessing or using Cleverlee’s Services, including account creation, transactional activity, or business engagement:

• Africa: Algeria, Angola, Benin, Burundi, Central African Republic, Chad, Democratic Republic of the Congo (DRC), Djibouti, Equatorial Guinea, Eritrea, Eswatini, Ethiopia, Gabon, Guinea Bissau, Liberia, Libya, Mali, Madagascar, Mauritania, Morocco, Mozambique, Namibia, Niger, Nigeria, Republic of the Congo, Rwanda, Sao Tome and Principe, Sierra Leone, Somalia, South Sudan, Sudan, Tanzania, Togo, Uganda, Zambia, Zimbabwe.
• Asia: Afghanistan, Bahrain, Bangladesh, Cambodia, China, Gaza Strip, India, Iran, Iraq, Jordan, Kuwait, Lao People’s Democratic Republic, Lebanon, Macao SAR, Myanmar, Nepal, North Korea, Oman, Pakistan, Philippines, Vietnam, Syria, Timor-Leste, Turkmenistan, Yemen, West Bank.
• Europe: Belarus, Bosnia and Herzegovina, Hungary, Kosovo, North Macedonia, Russian Federation, Ukraine (Occupied Territories: Crimea, Sevastopol, parts of Donetsk, Luhansk, Kherson, and Zaporizhzhia regions), Transnistria.
• North America and the Caribbean: American Samoa, Barbados, Cayman Islands, Cuba, Guatemala, Haiti, Honduras, Nicaragua, Puerto Rico, Trinidad and Tobago, Turks and Caicos Islands, United States of America, Virgin Islands (British and U.S.).
• South America: Bolivia, Colombia, Ecuador, Guyana, Paraguay, Peru, Suriname, Uruguay, Venezuela.
• Oceania: American Samoa, Guam, Kiribati, Marshall Island, Micronesia, Northern Mariana Islands, Papua New Guinea, Samoa, Solomon Islands, Vanuatu, Wallis and Futuna.

The following business types or activities are strictly prohibited from accessing or using the Services:

• Section 311 designated entities (source)
• Sanctioned individuals/entities (OFAC, EU, UN, UK HMT)
• Terrorist organizations or individuals (terrorism financing)
• Money laundering
• Proliferation of weapons of mass destruction (WMD)
• Shell banks and shell companies
• Bearer share corporations
• Clients whose identity is anonymous, fictitious, unverifiable, or who fail CDD requirements
• Child pornography, pornographic or sexual content involving coercion, minors, trafficking, or non-consensual publication, revenge porn
• Human exploitation activities (including trafficking, smuggling, organ trade, sex exploitation)
• Escort, Prostitution services
• Unlicensed financial institutions (banks, remittance, MSBs, casa de cambio, MVTS, Forex, Binary options platforms)
• Pawnbroking and pledge-based lending institutions
• Ponzi schemes, pyramid structures, Multi-Level Marketing (MLM) scams, Matrix programs
• Identity fraud, document forgery, fake profiles, fake IDs, fake government profiles or deep fakes
• Informal value transfer services (hawala, hundi)
• Escrow services (unlicensed)
• Counterfeit goods, smuggling
• Trade in human body parts or pathogens
• Trade in radioactive or nuclear materials
• Narcotics, synthetic drugs, drug paraphernalia, pharmaceutical production/trade (with unverified supply chain)
• Mixers, tumblers, or crypto anonymization services
• Platforms or services used for ransomware or cybercrime funding
• Cultural/archaeological artefacts (sculptures, statues, antiques, collector items), historical or religious items, ivory, protected species
• Unregistered non-EU/EEA charities, non-profits, or funds
• Political or religious organizations associated with hate speech, extremism, or sanctions
• Unlicensed online gambling, iGaming, betting (casino, poker, lotteries, etc.)
• Prize Draws, Gift Cards, Scratch cards
• Offline gambling forms (horse racing, bingo, sports betting)
• Art dealing, auctions, penny bidding platforms
• Weapons, defense, semi-military software or services
• Trade or storage of hazardous chemicals
• Virtual SIM card or spoofing service providers
• Real estate with no clear source of funds (SoF)
• Cash-intensive businesses (car washes, nightclubs, scrap yards)
• Scrap metal trade
• Smart drugs, nootropics, pseudo-pharmaceuticals, unlicensed supplements
• Virtual asset platforms with no licensing or regulatory clarity (DEXs, mixers)
• NFT marketplaces (unregulated or used for wash trading)
• DAO structures without legal personality or accountability
• Carbon credits (if unverifiable or unregulated)
• Visa or immigration services vulnerable to abuse
• Residency-/citizenship-by-investment programs (high misuse risk)
• Logging, quarrying, extractive industries (solid, liquid, gas)
• Wildlife trade or endangered species (with unclear origin)
• Alcohol or tobacco (if unlicensed or from high-risk countries)
• Precious metals or jewellery trade (especially if from conflict areas)
• Debt-related services: collection, restructuring, factoring, credit repair
• Politically exposed persons (PEPs), Diplomatic entities (embassies, consulates, political associations)
• Payment platforms operating from offshore jurisdictions (unlicensed)
• Crowdfunding platforms (if not registered or transparent)
• Freelancers/influencers receiving anonymous or crypto payments
• Importers of second-hand vehicles (cash-based + SoF uncertainty)
• Services related to mail-order brides or matchmaking abroad
• Dating platforms with anonymity risks
• Circumvention/encryption devices used for regulatory evasion
• Unethical gift/influence practices
• Drift net fishing in the marine environment
• Bribery (giving or receiving gifts that could be interpreted as undue influence)
• Abusing confidential or material, non-public information
• Unregulated Trust Companies
• AI systems with Unacceptable Risk (source)
• Dual-Use goods (source) Cleverlee may restrict, suspend, or terminate access to Services at any time, without notice, if the User is found to be associated with any prohibited jurisdiction or business activity listed above.

9.1 Notice of Claim and Dispute Resolution Period

9.1.1 In case of any potential claim or dispute please contact Lunora first. Lunora wants to address your concerns without resorting to formal legal proceedings, if possible. If you have a dispute with Lunora, then you should contact Lunora and a ticket number will be assigned. Lunora will attempt to resolve your dispute internally as soon as possible. The parties agree to negotiate in good faith to resolve the dispute (which discussions shall remain confidential and be subject to applicable rules protecting settlement discussions from use as evidence in any legal proceeding).

9.1.2 In the event the dispute cannot be resolved satisfactorily, and you wish to assert a legal claim against Lunora, then you agree to set forth the basis of such claim in writing in a “Notice of Claim,” as a form of prior notice to Lunora. The Notice of Claim must:

a) describe the nature and basis of the claim or dispute, b) set forth the specific relief sought, c) provide the original ticket number, and d) include your Lunora account email. The Notice of Claim should be submitted to an email address or hyperlink provided in your correspondence with Lunora.

After you have provided the Notice of Claim to Lunora, either Lunora or you may initiate the dispute resolution procedure in accordance with Section 9.2. You agree that the submission of a dispute to Lunora for resolution internally and the delivery of a Notice of Claim to Lunora are prerequisites to commencement of any legal proceeding in accordance with Section 9.2. During the dispute resolution process, the amount of any settlement offer made by you or Lunora shall not be disclosed to the arbitrator.

9.2 Governing Law

9.2.1 Governing Law and Dispute Resolution. These Terms shall be governed by and construed in accordance with the laws of the Republic of Costa Rica. Any dispute arising from or in connection with these Terms shall be subject to the exclusive jurisdiction of the competent courts in the Republic of Costa Rica. Nothing in this clause shall deprive a User, who qualifies as a consumer under applicable law, of the protections afforded to them by the mandatory provisions of the law of their country of residence, including provisions related to governing law and jurisdiction.

9.2.2 Modifications Lunora reserves the right to amend, revise, or update these Terms, including this Article 9, at its sole discretion. In the event of material changes, Lunora shall notify Users via email or through the User’s account interface at least fourteen (14) calendar days in advance of the effective date of such changes. If you do not agree to the modifications, you have the right to terminate the agreement by closing your Lunora account before the changes take effect. Continued use of the Services following the effective date of the modifications shall be deemed as acceptance of the updated Terms. Nothing in this clause shall limit any statutory rights to withdraw or cancel the agreement under applicable consumer protection laws.

9.3 Severability

If any provision of these Terms is held to be invalid, illegal or unenforceable under any applicable law or by a competent authority, such provision shall be severed, and the remaining provisions shall continue in full force and effect.