Legal & Privacy

Users accessing the ZebPay Platform in or from Singapore will be contracting with Genie Technologies Pte Ltd (UEN: 201919382H), at 18 Cross Street, #02-101, Singapore 048423 (“ZebPay”, “we”, “our”, or “us”). ZebPay owns and operates the ZebPay Platform in Singapore. 

These Terms of Use are the terms on which a User may use the ZebPay Platform. Use of the ZebPay Platform includes accessing, browsing, or registering to use the ZebPay Platform. Please read these Terms of Use carefully before you start using the ZebPay Platform.

1. Definitions and Interpretation

In these Terms of Use the following terms, unless the context otherwise indicates, will have the following meanings:

AML Regulations means the laws, statutes, and regulations of Singapore and any guidelines, notices, circulars, or rules issued or published by any competent authority in Singapore, relating to anti-money laundering, countering the financing of terrorism and sanctions, including the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992, the Terrorism (Suppression of Financing) Act 2002, and MAS Notice No. PSN02 Notice to Holders of Payment Service License (Digital Payment Token Service).

AML Policy means the policies and programs maintained by ZebPay to comply with the AML Regulations.

Business Day means a day that is not a Saturday, Sunday or public holiday in Singapore.

Crypto Assets means any Digital Payment Tokens, or cryptocurrencies, crypto tokens, or virtual currencies that are issued, stored and/or transferred based on the protocol of a computer or blockchain network.

Crypto Asset Wallet means a hosted wallet enabling a User to deposit, store, track, or withdraw supported Crypto Assets.    

Client Asset Account means any account opened by a User on the ZebPay Platform including the Fiat Wallet and Crypto Asset Wallet. 

Client Funds means any and all Crypto Assets held by a User in their Crypto Asset Wallet and fiat in their Fiat Wallet.

Competent Authority means the Monetary Authority of Singapore or such other relevant government authority.

Digital Payment Token has the same meaning as defined in the Payment Services Act 2019.

Digital Payment Token Exchange has the same meaning as defined in Part 3 of the First Schedule to the Payment Services Act 2019. 

Force Majeure shall mean and include any cause arising from or attributable to acts, or events, beyond the reasonable control of ZebPay, including natural calamity, strikes, terrorist action or threat, civil commotion, riot, crowd disorder, invasion, war, threat of or preparation for war, fire, explosion, storm, flood, earthquake, subsidence, structural damage, epidemic or other natural disaster, calamity, attacks including through computer viruses, hacking, denial of service attacks, ransomware or other manmade disruptions or any law, order enactment, statutory direction, legislation, regulation, rule or ruling of any court of law or any  Competent Authority. 

Fiat Wallet means a virtually denoted ledger accessible through the ZebPay Platform and assigned to a User, which ledger denotes the User’s fiat holdings and acts as a closed loop system that can only be used with respect to the User’s activity within the ZebPay Platform.

Fees means such fees payable by a User on transactions executed on the ZebPay Platform as provided at https://zebpay.com/sg/features/pricing, as may be amended from time to time.

KYC means know your customer requirements under the AML Regulations.

Privacy Policy means the privacy policy of ZebPay available at https://zebpay.com/sg/legal-privacy#privacy-policy, incorporated by reference into these Terms of Use.

Registered Bank Account refers to any Singapore bank account of a User that is authenticated or verified as per KYC requirements of ZebPay and from/to which a User can make top-ups/withdrawals to or from the Fiat Wallet.

Risk Disclosure Statement means the non-exhaustive risk disclosures available at https://zebpay.com/sg/legal-privacy#risk-disclosure-statement, incorporated by reference into these Terms of Use. 

User or Client or you or your shall mean a user of the ZebPay Platform or persons availing of the ZebPay Services, directly or indirectly.

ZebPay Platform shall collectively mean and include the ZebPay Android App, ZebPay iOS App (collectively, “ZebPay App”) or Zeb Web app (“Web version”) and ZebPay website “www.zebpay.com” (“ZebPay Website”), and other web assets on the zebpay.com domain, together with the ZebPay Developer Portal, Public APIs and secure authentication for Users (all either existing or available in the future).

ZebPay Services means the services made available from time to time on the ZebPay Platform.

2. Risk Warning

Crypto Assets are subject to frequent fluctuations in value and exchange rates, and the value of Crypto Assets may increase or decrease at any time. Consequently, there can be a risk that you lose money buying, selling, holding, or investing in Crypto Assets. Trading in Crypto Assets may not be appropriate for all investors, and you should seek independent legal advice if necessary. Instances of security breaches, changes in regulations, and government policies are always a possibility that may end up compromising the integrity or anonymity of the systems that produce Crypto Assets. 

Actual or potential regulatory actions or enhanced regulatory scrutiny of Crypto Assets businesses may adversely affect our business, including our ability to offer all or part of the ZebPay Services.  As a result, such regulatory action or scrutiny may also adversely affect your ability to access, use, transfer, withdraw, or exchange your Client Funds. 

Trading in Crypto Assets may result in a total loss of your investment for reasons mentioned in these Terms of Use, the Risk Disclosure Statement, and due to additional risks not listed or foreseen by ZebPay.

By creating an account on the ZebPay Platform you represent and acknowledge that (a) you have read and fully understand the risks outlined in these Terms of Use and the Risk Disclosure Statement; (b) you have carefully assessed your financial standing and risk tolerance and also procured legal advice; (c) you are aware of the risks associated with the transactions/trading of Crypto Assets; (d) you shall assume all risks related to holding and/or trading of Crypto Assets; and (e) you agree that ZebPay shall not be liable for any such risks or adverse outcomes (called by any name whatsoever). 

3. General Information

(a) These Terms of Use, Risk Disclosure Statement, and Privacy Policy form a binding agreement between you and ZebPay as the operator of the ZebPay Platform.

(b) By using any services made available through the ZebPay Platform you agree that you have read, understood, and accepted all the terms and conditions contained in these Terms of Use, Risk Disclosure Statement, and Privacy Policy.

(c) These Terms of Use, Risk Disclosure Statement, and Privacy Policy constitute a legally binding contract.  You are required to carefully read these Terms of Use, Risk Disclosure Statement, Privacy Policy and related notices before using any  ZebPay Services.

(d) By registering, accessing or using the ZebPay Platform, you agree to the terms and conditions set out in these Terms of Use, Risk Disclosure Statement, and Privacy Policy.

(e) If you disagree with these Terms of Use, Risk Disclosure Statement, or Privacy Policy, you shall not proceed to access, browse or initiate account registration with ZebPay or seek to acquire any of ZebPay Services, it being deemed that on the first instance/event of use of ZebPay Services, you have unconditionally agreed to what is stated thereunder.

4. Anti-Money Laundering & Countering the Financing of Terrorism Statement

ZebPay is committed to improving the global fight against money laundering and terrorist financing. In this regard, ZebPay has endeavoured to carefully ensure all of its internal anti-money laundering and combating the financing of terrorism procedures comply with AML Regulations. ZebPay reserves the right to take any action, at its sole discretion, to comply with AML Regulations and you agree that you shall not oppose such actions. 

5. Amendments and modifications 

(a) ZebPay reserves the right to modify or change these Terms of Use, the Risk Disclosure Statement and/or Privacy Policy, or any part thereof, at any time and at its sole discretion. ZebPay will provide reasonable notice of these modifications or changes to you. ZebPay also reserves the right to limit, change, or completely stop the ZebPay Services, or any part or feature thereof, at any time and at its sole discretion. 

(b) Any and all modifications or changes to these Terms of Use, Risk Disclosure Statement, or Privacy Policy will be effective at a date and time mentioned in the notice provided to you. As such, your continued use of ZebPay Services, including but not limited to any failure to close your Client Asset Account during the requisite notice period, acts as acceptance of the amended terms and conditions. For the avoidance of doubt, if you do not agree with any part of these Terms of Use, Risk Disclosure Statement or Privacy Policy or any such modification or change at any point in time, then you should close your Client Asset Account, withdraw any relevant Client Funds and cease using the ZebPay Platform.

6. Eligibility

(a) To use any ZebPay Services, you are required to create a Client Asset Account by adhering to the KYC requirements of ZebPay. If you fail to satisfy the KYC requirements, ZebPay will be entitled to either reject the creation of or terminate the said Client Asset Account.

(b)  By registering to use a Client Asset Account and ZebPay Services, you represent and warrant (i) in the case of an individual, that you are at least 18 years old and have the mental capacity to enter into these Terms of Use; and (ii) in the case of a legal person or other organization, that you have the full legal capacity and authority to enter into these Terms of Use, to contract with ZebPay, and to perform your obligations under these Terms of Use.

(c) If you are an individual and not at least 18 years old, your legal guardian shall be responsible for all consequences resulting from your actions on the ZebPay Platform and ZebPay shall have the right to cancel or freeze your Client Asset Account in addition to filing claims against you and your legal guardian for compensation/damages.

(d) Each User shall have one Client Asset Account only. Multiple accounts for the same User will not be allowed. ZebPay reserves the right, at its sole discretion, to suspend or terminate such multiple accounts without prior notice to the User. 

7. Prohibited Countries, Customers, Uses and Businesses

(a) Prohibited Countries

Persons and/or residents of certain countries listed at https://zebpay.com/sg/supported-countries, which include those on the Financial Action Task Force’s blacklist (as amended from time to time) (“Prohibited Countries”), are not permitted, either directly or indirectly, to use ZebPay Services in any capacity. Users visiting any Prohibited Country should not attempt to access the ZebPay Services from the Prohibited Country.

(b) Prohibited Customers

By accessing and using the ZebPay Platform and ZebPay Services, you represent and warrant that you are (i) not in breach of applicable laws and regulations including, but not limited to, laws and regulations relating to anti-money laundering, combating the financing of terrorism, anti-corruption, and bribery; and (ii) not on any trade or economic sanctions lists, including, but not limited to, sanctions lists issued by the United Nations Security Council, the Monetary Authority of Singapore, and the U.S. Office of Foreign Assets Control (OFAC).

(c) Prohibited Uses and Businesses

Users are prohibited from accessing or using the ZebPay Platform and ZebPay Services to engage in any of the following non-exhaustive list of activities:

(d) ZebPay reserves the right to, at its sole discretion, disable your access to your Client Asset Account at any time if, in its reasonable opinion, you have failed to comply with any provisions of these Terms of Use. 

(e)  ZebPay reserves the right to choose markets and jurisdictions to provide the ZebPay Services and may restrict or refuse in its sole discretion, the provision of ZebPay Services in certain countries or regions.

8. Description of Services or Business Activity

(a) The Digital Payment Token Exchange Service 

The Digital Payment Token Exchange service is a service accessed through the ZebPay Platform whereby ZebPay provides a trading platform with Crypto Asset/fiat and Crypto Asset/Crypto Asset pairs. The functionalities available under this service fall into two separate classes. 

(b) The OTC Trading Platform 

The OTC Trading Platform Service is a service accessed through the ZebPay Platform whereby ZebPay provides an online Crypto Asset trading platform via a sophisticated mechanism that facilitates over-the-counter trading of Crypto Assets. 

The User acknowledges and agrees that confirmations received from the User via Telegram and/or other forms of communication authorized by the OTC Trading Platform shall be valid proof of the User’s confirmations of trading activity. Further, the order(s) placed by Users on the OTC Trading Platform shall remain active for a time period as may be prescribed by ZebPay from time to time, post which ZebPay shall have the right to invalidate the said order(s). 

When a User enters into the OTC Trading Platform Service on the ZebPay Platform, the User acknowledges and agrees that the User is transacting with ZebPay as a counterparty, meaning that for all intents and purposes, ZebPay is dealing on its own account and the prices are set by ZebPay itself.

(c) Transaction fees are applicable upon the execution of an order and/or transaction. Users are required to maintain sufficient balances of fiat or the relevant Crypto Asset, as the case may be, in their Client Asset Account for the execution of the relevant order and/or transaction. You acknowledge and agree that if you have insufficient balance in your Client Asset Account, your order/transaction may not be executed. 

(d) You acknowledge and agree that ZebPay cannot guarantee that ZebPay will be able to provide an indicative quote for any sale or purchase of Crypto Assets; that any order will be executed based on the indicative quote; and/or any order or transaction you enter into will be completed or settled. You further agree and acknowledge that even if the limit price is hit on your order, the order might not always be filled. In some cases, your limit order might only be partially filled. It all depends on market conditions and overall liquidity.

(e) By undertaking a transaction on the ZebPay Platform, you acknowledge and agree that ZebPay is not liable or responsible for any vagaries of trade on the platform or any losses that may be suffered as a consequence. 

9. Provisions relating to all the ZebPay Services

(a) You must register and open a Client Asset Account.

(b) You must always treat your Client Asset Account information (including your password and PIN) as confidential and must not disclose it to any third party. Any access to the ZebPay Platform or ZebPay Services through your Client Asset Account shall be considered as access by you, and you shall be solely responsible for any activity carried out in, by or through your Client Asset Account on the ZebPay Platform.

(c) After registration of your Client Asset Account, as per the required process you will be eligible to buy, sell, send, receive or store Crypto Assets supported by the ZebPay Platform. You may be required to maintain a minimum balance of Client Funds in your Client Asset Account before you initiate certain orders and/or transactions. We reserve the right to refuse to execute any order and/or transaction initiated by you, if you have insufficient balance in your Client Asset Account, or if the same is in contravention to the AML Policy, or to comply with directions of appropriate enforcement authorities.

(d) Trading on the ZebPay Platform is subject to payment of transaction fees and such other fees as prescribed by ZebPay from time to time. You may request the withdrawal of Crypto Assets and fiat currency subject to the limitations available at https://zebpay.com/sg/features/pricing, as amended from time to time.   

(e) You agree and acknowledge that ZebPay may, at its sole discretion, without prior notice to you, impose minimum and/or maximum transaction limits (including on orders, deposits and/or withdrawals) on your Client Asset Account. 

(f) ZebPay strives to maintain the accuracy of information posted on the ZebPay Platform however it cannot guarantee the accuracy, suitability, reliability, completeness, performance or fitness for purpose of the content through the ZebPay Platform and will not accept liability for any loss or damage that may arise directly or indirectly from the content.

(g) Information on the ZebPay Platform can be subjected to change without notice and is provided for the primary purpose of facilitating Users to arrive at independent decisions.

(h) Users of the ZebPay Platform must understand that there are risks involved in the usage of the ZebPay Platform. ZebPay encourages all Users to exercise prudence and trade responsibly within their own means.

(i) While ZebPay emphasises online interface security to ensure the continuity and security of its services (announcements will be made in the event of downtime/maintenance), it will be non-accountable to Users for an act of God, Force Majeure, malicious targeted hacking, terrorist attacks and other unforeseen circumstances.

(j) ZebPay reserves the right, at its sole discretion, to cancel, rollback or block orders and transactions of any and all types on the ZebPay Platform in the event of abnormal transactions, market volatility, or based on its AML Policy.

(k) ZebPay reserves the right, at its sole discretion and at any time, to cease support for any Crypto Asset and/or blockchain network or protocol.  

(l) ZebPay will not ask for any password or PIN from Users except when the User attempts to login into the ZebPay Platform and use ZebPay services. ZebPay will also not ask Users to transfer funds that are not listed on its ZebPay Platform.

(m) By using the ZebPay Platform and ZebPay services, you declare that all information provided by you to ZebPay is true, accurate and complete.

(n) You acknowledge and agree that the underlying protocols of different crypto networks are subject to changes (each a “Fork“) which may result in more than one version of such network (each a “Forked Network“) and that these changes are beyond ZebPay’s control. You further acknowledge and agree that Forks may materially affect the value, function, and/or name of the Crypto Assets held by you with ZebPay. In the event of a Fork, ZebPay may temporarily suspend any services in respect of the relevant Crypto Assets (with or without advance notice to you) and may determine, in its sole discretion, whether or not to support the Forked Networks. Details of ZebPay’s position on such Forks are available at https://help.ZebPay.com/support/solutions/articles/44001895103/, which may be subject to change from time to time.

10. User Identity Verification

(a) With the registration of a Client Asset Account on the ZebPay Platform, you agree to share personal information requested for the purposes of identity verification and other purposes permitted by applicable laws. This information is used specifically to identify you and for the detection of money laundering, terrorist financing, fraud, and other financial crimes on the ZebPay Platform and to ensure that you and your trades are fully compliant with the AML Regulations. ZebPay will retain your personal information in accordance with the Privacy Policy and applicable law.

(b) In addition to providing this information, to facilitate compliance with global industry and government standards for data retention, you agree to permit ZebPay to keep a record of such information and all transaction information relating to your Client Asset Account for the lifetime of your Client Asset Account plus a minimum of five (5) years after closing that account or the minimum period required by applicable law, whichever is later.

(c) You also authorise ZebPay to make inquiries, either directly or through third parties, that are deemed necessary to verify your identity or to protect you and/or ZebPay against financial crimes such as fraud, etc.

11. Client Funds

(a) Deposits and Withdrawals

(b) Custody and Segregation of Client Funds

12. Know Your Customer (KYC) and on-boarding

(a) ZebPay is required to adhere to KYC requirements. ZebPay may undertake remote KYC procedures and video onboarding, among other modes of performing KYC procedures.

(b) The KYC procedures may be created or undertaken by any authorised representative of ZebPay (such as a third-party KYC service provider) possessing all the relevant and necessary credentials to conduct the KYC and due diligence in accordance with the AML Regulations and the AML Policy.

(c) You are required to follow all on-screen instructions and adhere to all requirements for on-boarding onto the ZebPay Platform.

13. Authenticity and self-responsibility of identity information

(a) You must register for a Client Asset Account before using the ZebPay Platform via our standard application procedure.

(b) Depending on certain conditions and in our sole discretion, ZebPay may refuse to open an account for you.

(c) Where ZebPay is required under applicable law and regulations to report transactions with you to a Competent Authority or otherwise, you must obtain and provide ZebPay with any information as ZebPay may require. You shall not be permitted to place orders or execute transactions unless and until you have provided the information required, and subject to clearance of the Competent Authority or other authority, as the case may be.

(d) ZebPay shall carry out all the searches and enquiries that ZebPay deems appropriate to assess your identity and/or to carry out any anti-money laundering controls which may be required under the AML Regulations or its AML Policy. This information may be also used for the prevention of money laundering or terrorism financing as well as for the management of your Client Asset Account. You authorise ZebPay to use the information to perform the above checks in relation to these Terms of Use.

(e) The identity verification information which may be requested can generally include but not limited to full name, email address, nationality, telephone number, Government issued ID/passport, date of birth, proof of address, bank account details, photographs and images. Such other documents, as may be notified from time to time by ZebPay in accordance with applicable laws.

(f) In providing this required information, you confirm that it is accurate and authentic. Post-registration, you guarantee that at all times the information is truthful, complete and updated in a timely manner with any changes. You must ensure that any identity verification or personal information and/or documents submitted by you belong to you. You are not permitted to create a Client Asset Account on someone else’s behalf.

(g) If there is any reasonable doubt that any information provided by you is wrong, untruthful, outdated or incomplete, ZebPay shall have the right to send you a notice to demand corrections, remove relevant information directly, suspend use of your Client Asset Account and, as the case may be, terminate all or part of ZebPay Services to you.

(h) You shall be solely and fully responsible for any loss or expenses incurred by the you in the course of the use of any ZebPay Services if you cannot be reached through the contact information provided by you.

(i) You hereby acknowledge and agree that you have the obligation to keep all information provided to ZebPay up to date if there are any changes.

(j) ZebPay may or may not accept an application to become a User in its absolute discretion, including, but not limited to, if you fail to pass the relevant appropriateness checks. If your application is accepted by ZebPay, you shall be notified of the same.

(k) You shall be solely responsible for the safekeeping of your Client Asset Account and password/ PIN and you will be responsible for all activities relating to your logins and password/PIN.

(l) You hereby covenant that you:

(m) ZebPay will not be responsible for any loss or consequences caused by your failure to comply with the above terms and conditions.

14. Representations and warranties of the User

(a) You represent, warrant, and covenant to ZebPay that:

(b) You will not use any data or information displayed on the ZebPay Platform for commercial purposes without the prior consent of ZebPay.

(c) You will use the ZebPay Platform in accordance with these Terms of Use and the Privacy Policy, without taking acts of unfair competition nor attempting to intervene with the normal operation of ZebPay. Examples of such malicious acts include, but are not limited to:

(d) By accessing any of the ZebPay Services, you agree that ZebPay shall have the right to unilaterally determine whether you have violated any of the provisions of these Terms of Use and take action without receiving your consent or giving prior notice to you. Examples of such actions include, but are not limited to:

(e) You consent to the ZebPay Platform’s AML and KYC checks and procedures and ZebPay reserves the right to (i) withhold the refund of any monies and Crypto Assets; and/or (ii) deny access to the ZebPay Platform, before all necessary procedures have been vetted and consent is formally authorised for you to access the ZebPay Platform.

(f) Without prejudice to the aforesaid, any Client Funds will be ‘frozen’ until the relevant procedures are completed, and under no circumstance may they be ‘exchanged’ or ‘withdrawn’.

(g) If your alleged violation causes any losses to a third-party, you shall solely undertake all the legal liabilities in your own name and hold ZebPay harmless from any loss, fine or extra expenses. If, due to any alleged violation ZebPay incurs any losses, is claimed by any third party for compensation or suffers any punishment imposed by any administrative authorities, you will indemnify ZebPay against any losses and expenses caused thereby, including legal fees on a full indemnity basis.

(h) You acknowledge and agree that the above representations, warranties and covenants have been a material inducement to the decision of ZebPay to permit you to open an account with ZebPay and trade on the ZebPay Platform.

(i) In case of any abnormal behaviour, fluctuation or delay in transactions beyond ZebPay’s control, ZebPay shall not be liable to you.

15. Intellectual Property Rights

(a) Unless otherwise specified, all logos, information, text, graphics, or other materials uploaded by ZebPay, which appear on the ZebPay Platform for other Users to access (“Content”) are the property of ZebPay and are protected under copyright, trademark and other applicable laws.

(b) All logos, trademarks, service marks and logos of ZebPay and others used or displayed on the ZebPay Platform, (“Trademarks”) are the property of ZebPay or its group companies. You may not copy, imitate or use them without our prior written consent.

(c) You shall not reverse engineer or disassemble any part of the ZebPay Platform for any reason whatsoever. Any such action shall amount to a material breach of these Terms of Use and may result in ZebPay terminating the defaulting Client Asset Account.

(d) The ZebPay Platform may in places include third party intellectual property including the software used for creating or distributing crypto assets. ZebPay does not own any rights to such third-party IP and is bound by the license terms for such IP and by virtue of these Terms of Use you shall also be bound by the said license terms.

16. Disclaimer of Warranties

(a) ZebPay will provide access to the ZebPay Platform and ZebPay Services on an “as is” and “commercially available” condition and to the maximum extent permitted by law, ZebPay does not offer any form of warranty (whether express, statutory or implied, oral or in writing) with regards to the ZebPay Platform and ZebPay Services, including, but not limited to, accessibility, adequacy, fitness for a particular purpose, reliability, stability, accuracy and completeness of the technology involved. The ZebPay Platform serves merely as a venue of transactions where Crypto Assets information can be acquired, and Crypto Assets transactions can be conducted. The contents of the ZebPay Services or the ZebPay Platform may contain bugs, errors, problems or other limitations. ZebPay assumes no liability or responsibility whatsoever for any errors or omissions in the ZebPay Services or the ZebPay Platform.

(b) You expressly acknowledge and agree that the use of the ZebPay Services and the ZebPay Platform is at your sole risk. ZebPay cannot control the quality, security or legality of the Crypto Assets in any transaction, truthfulness of the transaction information, or capacity of the parties to any transaction to perform their obligations. You must carefully consider the associated investment risks, legal status and validity of the transaction information and investment decisions prior to your use of the ZebPay Platform.

(c) ZebPay makes no warranty that the ZebPay Services or the ZebPay Platform (or any part or functionality thereof) will be uninterrupted, timely, accurate or reliable; nor do we make any warranty as to the permanent availability of any information and/or that may be stored or transferred through the ZebPay Services or the ZebPay Platform. You understand and agree that any material and/or data downloaded or otherwise obtained through use of the ZebPay Services or the ZebPay Platform is done at your own discretion and risk and you will be solely responsible for any damage to your computer system or phone or any other device or loss of data that results from the download of such material or data.

(d) ZebPay is not responsible for any content uploaded by you on the ZebPay Platform. We are not responsible for any direct or indirect damages or losses caused to you, including without limitation, lost profits, business interruption or other loss resulting from use of or reliance in any way on anything available on the ZebPay Platform. It is solely your responsibility to evaluate the accuracy, reliability, completeness and usefulness of Content available on the ZebPay Platform that is used by you.

(e) ZebPay does not provide investment and financial advice to Users. The Content on the ZebPay Platform is provided for general information only and is not intended to, and does not amount to, investment advice. By giving its approval, consent, advice or information about any matter dealt with by these Terms of Use or in respect of ZebPay Services, ZebPay does not create, make or give any warranty, representation or undertaking about any circumstances relating to the subject matter of the consent or approval.

(f) ZebPay will not be liable for any loss or damage caused to your computer equipment, computer programs, data or other device caused by a virus, denial-of-service attack, distributed denial of-service attack, or other technologically harmful material. You must use your own virus protection software. ZebPay does not guarantee that the ZebPay Platform will be free of viruses, trojan horses or other code that manifests contaminating or destructive properties.

17. Limitation of Liability

(a) Release of ZebPay Liability

(i) If you have a dispute with one or more Users of the ZebPay Platform, you agree that neither we nor our affiliates or service providers, nor any of our respective officers, directors, agents, joint venturers, employees and representatives will be liable for any claims, demands and damages (actual and consequential) of any kind or nature arising out of or in any way connected with such disputes.

(ii) ZebPay will not be liable for any loss caused to you due to the discontinuation of any Crypto Asset that is offered through the ZebPay Platform.

(iii) ZebPay shall not be liable for any disruption of service, whereby you are denied access to your Client Funds.

(iv) ZebPay shall not be liable for any loss caused to you through loss of any Crypto Assets stored in your Client Asset Account for any reason whatsoever, save and except due to a wilful and malicious commission or omission by ZebPay directly resulting in such loss.

(v) ZebPay shall not be liable for any discontinuation, alteration, suspension or termination of any part of the services offered on the ZebPay Platform caused or occasioned by any Force Majeure event or any change in applicable law with respect to Crypto Assets.

(vi) ZebPay shall not be liable for any loss caused to you due to fluctuations in the price of Crypto Assets. ZebPay does not guarantee profits from the sale or purchase or transfer of Crypto Assets. ZebPay shall not be liable for any loss caused to you for suspension, cancellation or termination of your Client Asset Account, including on account of a violation by you of any provision of these Terms of Use, the Privacy Policy or any applicable law. You agree that ZebPay will not be liable to you or to any third party for termination of your Client Asset Account r for restricting access to the ZebPay Platform, which shall be at the sole discretion of ZebPay.

(vii) You shall not be entitled to any damages from ZebPay for any reason whatsoever including, but not limited to, consequential or compensatory damages against ZebPay for any reasons including suspension, cancellation or termination of your Client Asset Account or for cessation of any or all services on the ZebPay Platform. You shall only be entitled to refund / recovery of the Client Funds credited to your Client Asset Account, subject to deductions of amounts owed to ZebPay and other legal, regulatory or statutory dues or those stipulated under applicable law, and to the permissibility of such refund or recovery under applicable law.

(viii) In the event that any Crypto Assets credited to your Client Access Account are seized, or ZebPay is unable to access or return the same to you, ZebPay shall not be held liable or responsible for the same. You are cautioned to avail yourself of the ZebPay Platform subject to the above risk. At no point in time will ZebPay, its directors, shareholders, employees, representatives, officers, affiliates or assigns be held liable for any claims whatsoever for cessation of services or termination of any part of the ZebPay Platform or ZebPay Services or any disruption with respect to access to any Client Asset Account.

(ix) All claims by you shall be limited to the Crypto Assets and fiat standing to your credit in the relevant client account, subject to the above mentioned conditions.

(x) To the maximum extent permitted by law, THE MAXIMUM CUMULATIVE LIABILITY OF ZEBPAY IN ANY EVENT, FOR ANY CLAIM, DAMAGES, TORT SHALL BE LIMITED TO THE MONIES ACTUALLY RECEIVED FROM THE USER, AS CONSIDERATION OR FEES FOR THE SERVICES RENDERED BY ZEBPAY IN RELATION TO THE APPLICABLE TRANSACTION TO WHICH THE CLAIM RELATES. IF THE CLAIM DOES NOT RELATE TO ANY TRANSACTION IN PARTICULAR, THEN ZEBPAYS MAXIMUM CUMULATIVE LIABILITY SHALL BE LIMITED TO THE CRYPTO ASSETS ACTUALLY RECEIVED FROM THE USER, AS CONSIDERATION OR FEES FOR THE SERVICES RENDERED BY ZEBPAY IN RELATION TO THE TWO TRANSACTIONS IMMEDIATELY PRECEDING THE DATE ON WHICH THE CLAIM IS MADE BY THE USER.

(b) No Liability for Breach

ZebPay will not be liable for any breach of these Terms of Use, where the breach is due to abnormal and unforeseeable circumstances beyond ZebPay’s control, the consequences of which would have been unavoidable despite all effects to the contrary, nor is ZebPay liable where the breach is due to the application of mandatory legal requirements.

(c) Limitation of loss

Without prejudice to the generality of the foregoing, in no event shall ZebPay, our affiliates or our service providers, or any of our or their respective officers, directors, agents, employees or representatives, be liable for any of the following types of loss or damage arising under or in connection with these Terms of Use or otherwise:

(i) any loss of profits or loss of expected revenue or gains, including any loss of anticipated trading profits and / or any actual or hypothetical trading losses, even if we are advised of or knew or should have known of the possibility of the same;

(ii) any loss of or damage to reputation or goodwill; any loss of business or opportunity, customers or contracts; any loss or waste of overheads, management or other staff time; or any other loss of revenue or actual or anticipated savings, even if we are advised of or knew or should have known of the possibility of the same;

(iii) any loss of use of hardware, software or data and / or any corruption of data; including but not limited to any losses or damages arising out of or relating to any inaccuracy, defect or omission of Crypto Assets price data; any error or delay in the transmission of such data; and / or any interruption in any such data;

(iv) any loss or damage whatsoever which does not occur directly from our breach of these Terms of Use; and/or

(v) any loss or damage whatsoever which is in excess of that which was caused as a direct result of our breach of these Terms of Use (whether or not you are able to prove such loss or damage).

(d) To the maximum extent permitted by applicable law, you hereby release and waive all claims against ZebPay, our affiliates, our service providers, and any of our or their respective officers, directors, agents, employees or representatives, from any and all liability for claims, damages (actual and/or consequential), costs and expenses (including litigation costs and attorneys’ fees) of every kind and nature, arising from or in any way related to your use of the ZebPay Platform or ZebPay Services. You hereby expressly waive and relinquish any and all rights and benefits that you may have under any other national, state or federal statute or common law principle of similar effect, to the fullest extent permitted by law.

18. Indemnification

You agree to indemnify and hold harmless ZebPay, its affiliates, contractors, licensors, and our and their respective directors, officers, employees, representatives and agents, from and against any action, claims, damages and liabilities (including legal fees, fines or penalties imposed by any regulatory authority, on a full indemnity basis) arising out of or in connection with (a) your breach or our enforcement of these Terms of Use (including with limitation your breach of the Privacy Policy, AML Policy or any other restrictions on the use of ZebPay services); (b) your violation of any law, rule or regulation, or the rights of any third party and/or (c) your use of ZebPay Services. The aforesaid indemnity shall also apply to your violation of any applicable law, regulation, or rights of any third party during your use of the ZebPay Services.

19. Termination of this Agreement

(a) You agree that we have the right to immediately suspend the Client Asset Account (and any accounts beneficially owned by related entities or affiliates), freeze or lock the fiat and Crypto Assets in all such Client Asset Accounts, and suspend access to ZebPay if we suspect any such Client Asset Accounts to be in violation of these Terms of Use, Privacy Policy, AML Regulations, or any applicable laws and regulations.

(b) Pursuant to certain AML regulations and other applicable laws, ZebPay reserves the right to keep and use the transaction data or other information related to such Client Asset Accounts for up to the longer of five (5) years or the time period required by applicable law following the termination of these Terms of Use, and for the following non-exhaustive list of purposes/events:

(c) In case of any of the following events, ZebPay shall have the right to directly terminate these Terms of Use and cancel the Client Asset Account, and shall have the right to temporarily or permanently freeze and/or liquidate all funds (or any portion thereof) in the Client Asset Account, and cancel the authorisations of the Client Asset Account:

(d) Subject to subparagraph (e) below, once the Client Asset Account is closed/withdrawn, all remaining balances (which include charges and liabilities owed to ZebPay) on the account will be due and payable to ZebPay. Upon payment of all outstanding charges to ZebPay (if any), you will have to immediately withdraw all balance funds from the account.

(e) ZebPay maintains full custody of the funds and user data/information which may be turned over to the authorities in the event of account suspension/closure arising from fraud investigations, AML investigations or violation of the law or these Terms of Use (e.g. trading on ZebPay from a sanctioned country).

(f) Notwithstanding anything to the contrary contained elsewhere in these Terms of Use, ZebPay shall at all times have the right to, without any reason or cause, terminate ZebPay Services to you at any time, including but not limited to closing the relevant Client Asset Account.

20. Compliance with Local Law

(a) It is the responsibility of the User to abide by applicable laws in relation to the usage of ZebPay Services in their local jurisdiction. 

(b) All Users of the ZebPay Platform and any of its services acknowledge and declare that the source of their Client Funds come from a legitimate manner and are not derived from illegal activities. ZebPay maintain a stance of cooperation with law enforcement authorities globally and will not hesitate to seize, freeze, terminate the Client Asset Account and Client Funds which are flagged or investigated by legal mandate.

(c) It is the sole responsibility of Users to determine, collect, report, and submit any all taxes applicable to the payments they make or receive in connection with the use of the ZebPay Services to the appropriate tax authority or under any other applicable laws. ZebPay is not responsible for determining whether any taxes apply to the transactions carried out by Users on the ZebPay Platform or the ZebPay Services availed by Users, or for collecting, reporting or remitting any taxes arising from any transaction undertaken by Users via the ZebPay Platform or ZebPay Services, except to the extent required by law.

21. Force Majeure

(a) ZebPay Services are offered only on the digital domain, which is subject to risks including offensive attacks. ZebPay shall not be liable for any loss caused to your Client Asset Account or the monies or Crypto Assets accrued therein if the same arises due to any Force Majeure event, including commissions or omissions by third parties, forces of nature, offensive attacks on ZebPay servers or on your personal devices, changes in applicable law, or any loss caused by conditions or events beyond the reasonable control of ZebPay.

(b) The above limitation on liability includes any Force Majeure event set out hereunder including acts of god; fire, act of terrorists, act of civil or military authorities, civil disturbance, war, strike or other labour dispute, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe or any other occurrence which is beyond reasonable control of ZebPay; offensive attacks including virus attack, hacking, denial of service attack or theft of your personal devices resulting in loss to the account.

(c) To the maximum extent permitted by law ZebPay shall not be liable for any loss whatsoever caused to or incurred by you due to a data breach of your confidential information, including your account details or password, including when such breach has occurred due to you sharing such details with third parties or due to your failure to follow reasonable due diligence. ZebPay shall also not be liable or responsible for any disclosure by you of any of your account details, including on account of a phishing attack or other third-party disruption.

22. Privacy and Confidentiality

(a) ZebPay processes all personal information in accordance with applicable law and regulations relating to the processing, privacy, and use of personal information.

(b) ZebPay may collect, hold and process personal information about you from the way in which you engage with ZebPay (such as by filling in the application, placing orders, or if you contact ZebPay by post, email, telephone, in person or by any other means), through your interactions with ZebPay and/or the ZebPay Platform.

(c) Details of the types of personal information which ZebPay collects, holds or processes are set out in the Privacy Policy.

(d) ZebPay relies on the following legal basis to process and use your personal information:

(e) Your personal information may be disclosed to service providers and other suppliers (including those outside of Singapore) provided that any such transfer or access is compliant with the Personal Data Protection Act 2012 and is subject to appropriate contractual provisions relating to data protection and confidentiality. Further details as to where your personal information may be transferred or accessed and the basis for such transfers are set out in the Privacy Policy.

(f) ZebPay has security procedures covering the storage and disclosure of your personal information to prevent unauthorised access of any personal information and to comply with the Personal Data Protection Act 2012.

(g) You consent to receive communications from us electronically. ZebPay may communicate with you by e-mail or by posting notices on the ZebPay Platform. You shall be solely responsible for updating your e-mail address and other contact details regularly. If we send any communication by e-mail, it shall be sent to your e-mail address available on the records created by you on the ZebPay Platform.

(h) you shall not disclose to any person any information relating to the business, investments, finances or other matters of a confidential nature of ZebPay which may come into your possession in connection with these Terms of Use, and you shall use all reasonable endeavours to prevent such disclosure, except as may be required by any applicable law, rule or regulatory, law enforcement or tax authority.

(i) For the avoidance of doubt, ZebPay may be required to disclose personal information to third parties in order to carry out fraud-checks and for KYC procedures, and you expressly consent to such disclosure.

23. Complaints

If you have any complaints, feedback or questions, you may contact ZebPay at https://help.zebpay.com and we will make our best efforts to try to resolve your issues. ZebPay does not provide any support services to walk-in users. 

24. Method of payment

Any payment to be made under these Terms of Use must be made by one of the following methods:

(a) a bank draft or a bank cheque;

(b) by credit of cleared funds to the bank account specified by the payee at least 3 Business Days before the anticipated date of the payment; or

(c) any other lawful form of payment that the parties agree in writing.

25. Notices

(a) Unless these Terms of Use expressly state otherwise, a notice, consent, approval, waiver or other communication (notice) in connection with these Terms of Use must be in writing. A notice may be given by hand delivery, prepaid post, or by electronic message to the recipient’s physical address or email address as advised from time to time.

(b) A notice given under this clause will be deemed to be received:

unless a notice is received after 5.00 pm on a Business Day in the place of receipt or at any time on a non-Business Day, in which case, that notice is deemed to have been received at 9.00 am on the next Business Day.

26. Assignment

You may not assign or otherwise deal with any of your rights or obligations under these Terms of Use without the prior written consent of ZebPay. However, ZebPay may, without your consent assign its rights under these Terms of Use in the case of the sale of all or part of the ZebPay Platform.

27. Waiver

(a) No failure to exercise or delay in exercising any right given by or under these Terms of Use to a party constitutes a waiver and the party may still exercise that right in the future.

(b) Waiver of any provision of these Terms of Use or a right created under it must be in writing signed by the party giving the waiver and is only effective to the extent set out in that written waiver.

28. Relationship between Parties

(a) Notwithstanding anything contained in these Terms of Use, for all purposes including without limitation the execution of any order and/or transaction initiated by you through the ZebPay Platform, you and ZebPay shall be and act independently, on a principal to principal basis and not as partners, associates, joint venturers, agents, intermediaries, brokers or in any other fiduciary capacity. You shall not have any authority to assume or create any obligation for or on behalf of ZebPay, whether express or implied.

(b)   A person or entity who is not a party to these Terms of Use shall not have any rights under the Contracts (Rights of Third Parties) Act 2001 to enforce any provision of these Terms of Use.

29. Severability

If any provision of these Terms of Use is void, voidable by a party, unenforceable, invalid or illegal and would not be so if a word or words were omitted, then that word or those words are to be severed and if this cannot be done, the entire provision is to be severed from these Terms of Use without affecting the validity or enforceability of the remaining provisions of these Terms of Use.

30. No merger

On completion or termination of the transactions contemplated by these Terms of Use, the rights and obligations of the parties set out in this agreement will not merge and any provision that has not been fulfilled remains in force.

31. Further steps

You agree to promptly do all things reasonably necessary or desirable to give full effect to these Terms of Use, including obtaining consents and signing documents.

32. Time of the Essence

Time is of the essence in respect of your obligations to ZebPay under these Terms of Use.

33. Entire agreement

These Terms of Use contain the entire agreement between the parties about the subject matter hereof and supersede all previous communications, representations or agreements between the parties on the subject matter.

34. Governing law and jurisdiction

(a) These Terms of Use and any dispute or claim arising out of or in connection with it, including the existence, validity, interpretation, performance, breach or termination of these Terms of Use, shall be governed by and construed in accordance with the laws of Singapore, without regard to the principle of conflicts of laws thereof.

(b) You agree that the courts of Singapore shall have the exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms of Use.

Version 1.4

Welcome to ZebPay!

ZebPay is a legal organisation which endeavours to ensure all of its policies and procedures are fully compliant with the Personal Data Protection Act 2012. We also endeavor to treat your privacy concerns very seriously.

ZebPay shall mean and include below –

GENIE TECHNOLOGIES PTE LTD (UEN No. 201919382H), a company registered in Singapore and with registered address at 18 Cross St, #02-101, Singapore 048423

Persons using the ZebPay Platform, directly or indirectly, are referred to herein, as “Users”.

This Privacy Policy describes our information handling practices when you access content we own or operate on the websites or app of ZebPay or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”).

In order to prevent misuse of the ZebPay Platform, Users are required to strictly comply with the terms contained herein, which forms part and parcel of the User Terms of Service . Terms not defined herein shall carry the same interpretation, as in the User Agreement and in the absence thereof to general usage and parlance.

THESE TERMS AND CONDITIONS OF PRIVACY SUPERSEDES AND REPLACES ANY AND ALL PRIOR ORAL OR WRITTEN UNDERSTANDINGS OR AGREEMENTS BETWEEN ZebPay AND THE USER WITH RESPECT TO THE PRIVACY POLICY.

Risk Warning Disclaimer: Trading in Virtual Financial Assets on Crypto-Exchange Platforms involves a high degree of risk to your capital. Virtual Financial Assets may not be appropriate for all investors and you should seek independent advice if necessary. Trading with Virtual Financial Assets may result in total loss of your investment.

AML/CFT Statement

ZebPay is committed to improving the global fight against money laundering and terrorism financing and complying with anti-money laundering, countering the financing of terrorism, sanctions laws, and other applicable regulations.

To this end, ZebPay has implemented various measures and procedures including:

• Conducting risk assessments on customers, jurisdictions customers are from or in, and its products and services;

• Requiring customers to undergo Know-Your-Customer checks to ascertain the identity and to verify the beneficial ownership, source of funds and the purpose of the business relationship, where applicable;

• Requiring customers that present a higher risk to undergo enhanced due diligence; 

• Screening customers and transactions against sanctions lists including those issued by the Monetary Authority of Singapore, the United Nations, and the US Office of Foreign Assets Control;

• Investigating customer alerts or transactions that are flagged by our screening systems and conducting additional due diligence and obtaining information on the parties involved or the nature of the underlying transaction;

• Prohibiting customers from using the services to engage in activities including fraud gambling, intellectual property infringement, defamation, or abuse, and all other unlawful activities; 

• Prohibiting the establishment of business relations or the facilitation of transactions with certain categories of customers (individuals and entities) including those from North Korea, Congo, Iran, Libya, Somalia, South Sudan, Sudan, Yemen and those who are unable to satisfy our due diligence checks;    

• Conducting training on money laundering, terrorism financing and sanctions risks for appropriate employees; 

• Maintaining records for such periods as stipulated in applicable regulations; and

• Escalating suspicious transactions internally and reporting such transactions to the relevant regulatory authorities, where appropriate.

1. Risk Warning on Digital Payment Tokens

Genie Technologies Pte. Ltd. (“ZebPay”) currently operates under an exemption and is exempted, under the Payment Services (Exemption for Specified Period) Regulations 2019, from holding a license under the Payment Services Act 2019 (“PSA”), for the provision of digital payment token services.

The Monetary Authority of Singapore (“MAS”) requires us to provide this risk warning to you as a customer of a digital payment token (“DPT”) service provider.

Before you:

(a) pay or transfer your DPT service provider any money or DPT;

(b) enter into an agreement with a third party to buy or sell DPTs upon inducement by your DPT service provider;

(c) enter into an agreement with a third party under an arrangement by your DPT service provider for the transmission of DPTs;

(d) pay a third party any money or DPT under an arrangement by your DPT service provider for the transmission of DPTs; or

(e) transfer any digital payment token instrument to your DPT service provider, 

you should be aware of the following.

(i) Your DPT service provider is exempted by MAS from holding a licence to provide DPT services. Please note that you may not be able to recover all the money or DPTs you paid to your DPT service provider, or any other third party referred to above, if your DPT service provider’s or the third party’s business fails.

(ii) You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by your DPT service provider.

(iii) You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.

(iv) You should be aware that your DPT service provider, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”.

2. General Disclosures

Unless otherwise defined herein, all capitalised terms used in this Risk Disclosure Statement shall have the same meanings ascribed to them in the Terms of Use.

There are several risks associated with Crypto Assets and transacting in Crypto Assets. The risks outlined in this Risk Disclosure Statement are not exhaustive. By accessing and using ZebPay Services, you hereby acknowledge and affirm that you have thoroughly reviewed the following risk disclosures and have understood and accepted the risks associated with transacting in Crypto Assets.

All trading decisions are based on your own objectives, experience, and evaluation of your prevailing financial circumstances. ZebPay is merely a facilitator, and ZebPay does not seek to influence or otherwise affect your decision-making process in any way whatsoever.

You will not hold nor seek to hold ZebPay or any of its officers, directors, partners, employees, agents, subsidiaries, affiliates or business associates liable for any trading losses or damages incurred in respect of trading as a consequence of you relying upon any information, opinions, advice or any other material whatsoever.

ZebPay does not give any financial advice, and you shall not seek any such advice from ZebPay or any of its employees or representatives.

3. Unique Features of Crypto Assets

Crypto Assets are not recognized as legal tender in most jurisdictions and are not backed by any government or central bank. The pricing of Crypto Assets is determined by the parties involved in a transaction, which may or may not align with the market value (which itself is determined by demand and supply) of the Crypto Asset at the time of the transaction.

4. Price Volatility; Risk of Partial or Total Loss of the Invested Amount

The price of a Crypto Asset is based on its perceived value and is susceptible to fluctuations based on external factors beyond the control of any individual entity. These products are characterised by high volatility, including on occasion due to market manipulation, with certain Crypto Assets experiencing very high daily price swings. Consequently, holding Crypto Assets entails volatility risk, potentially resulting in substantial losses for holders/traders.

5. Valuation and Liquidity

Crypto Assets can be traded through privately negotiated transactions and numerous Crypto Asset exchanges and intermediaries worldwide, each with its own pricing mechanism and order book. The lack of a centralised pricing source poses challenges for valuation. Additionally, certain Crypto Assets may have concentrated holdings, affecting their prices and liquidity. As a result, buyers and sellers of Crypto Assets may not receive their expected treatment or prices, and liquidity dispersion can create challenges for existing positions, particularly during stressful periods.

6. Cybersecurity

ZebPay follows applicable industry standards and best practices to reasonably secure information collected from you. That said, the use of Crypto Assets and related “wallets” exposes market participants to cybersecurity risks, including vulnerabilities to hacking and the possibility that publicly distributed ledgers may not be immutable. A cybersecurity event could lead to significant and irreversible losses for individuals trading Crypto Assets. Even a minor cybersecurity incident within the Crypto Asset sphere could exert downward price pressure on the affected product and potentially impact other Crypto Assets.

7. Crypto Asset Exchanges, Intermediaries, and Custodians

Crypto Asset exchanges, intermediaries, custodians, and vendors facilitating Crypto Asset transactions are relatively new and largely unregulated in most jurisdictions. The lack of regulatory oversight raises the risk that a Crypto Asset exchange may not hold sufficient Crypto Assets and funds to meet its obligations and identifying such deficiencies may prove challenging. Moreover, these exchanges are susceptible to significant outages, downtime, transaction processing delays, and flash crashes, resulting in higher operational risk compared to regulated securities exchanges. 

8. Regulatory Landscape

Most Crypto Assets and products or services associated with them, remain largely unregulated. Such products and services are subject to legal ambiguity and you should obtain appropriate legal advice. Subsequent laws, regulations, or directives may also impact the price of Crypto Assets.

9. Technology

The relatively new and rapidly evolving technology underlying Crypto Assets introduces unique risks. Accessing, using, or transferring a Crypto Asset on a blockchain or distributed ledger requires a unique private key. The loss, theft, or destruction of this private key may result in an irreversible loss of the associated Crypto Asset. Additionally, the ability to participate in blockchain forks could have implications for users.

10. Blockchain Fees

The amounts of blockchain fees associated with Crypto Assets are subject to market forces, and during periods of stress, they may increase substantially. Crypto Asset exchanges, wallet providers, and other custodians may charge high fees relative to custodians in other markets.

11. Insufficient Information

Publicly available information about specific Crypto Assets may be inaccurate, incomplete, and unclear regarding the project and its risks. Documentation may be highly technical and may require diligence on your part to comprehend the characteristics of the Crypto Asset.

12. Misleading Information

Certain Crypto Assets and related products are aggressively advertised to the public through marketing materials and information that may be unclear, incomplete, inaccurate, or intentionally misleading. For instance, advertisements on social media platforms may focus on potential gains without adequately highlighting the high risks involved. Caution should be exercised concerning social media “influencers” who may have a financial incentive to promote specific Crypto Assets and related products and services, potentially leading to biased communications.

13. Fraud and Malicious Activities

Numerous fake Crypto Assets and scams exist, aiming to deceive individuals and deprive them of their funds using various techniques, including phishing or fake identification.

14. No Personal Advice

ZebPay does not provide personal advice in relation to our products or services. ZebPay may provide factual information, information about transaction procedures, and information about potential risks. However, any decision to use our products or services is made by you. No communication or information provided to you by us is intended as or shall be considered or construed as, investment advice, financial advice, trading advice, or any other sort of advice. You are solely responsible for determining whether any investment, investment strategy, or related transaction is appropriate for you according to your personal investment objectives, financial circumstances, and risk tolerance.

15. No Monitoring

ZebPay does not monitor whether your use of ZebPay Services is consistent with your financial goals and objectives. It is up to you to assess whether your financial resources are adequate for your activity with us, and to your risk appetite in the products and services you use.

16. Liquidity risk

Crypto Assets may have limited liquidity which may make it difficult or impossible for you to sell or exit a position when you wish to do so. This may occur at any time, including at times of rapid price movements.

Version 1.1