Refund Policy

REGULATION
_**on the procedure for processing transactions, refunding funds and managing risks on the CityPay platform _Italic**Tashkent 07 August 2026

arabuli

• giorgi

ChatGPT

1.1. This Regulation on the procedure for processing transactions, refunding funds and managing risks on the CityPay platform (hereinafter — the “Regulation”) sets out the procedure for processing certain types of transactions, conducting checks, suspending, rejecting and refunding operations, as well as the procedure for applying fees, limits and other risk management measures when using the CityPay platform.
1.2. This Regulation is an integral part of the CityPay Public Offer, as well as of other Company documents governing the procedure for providing services to Users. 1.3. In the event of acceptance of and consent to the Public Offer by the User, registration on the Platform, use of the Platform, or performance of any operation using the Platform, the User shall be deemed to have fully read this Regulation and to have accepted its terms in full. 1.4. This Regulation applies to all Users of the Platform, as well as to all operations related to the sending, receipt, processing, refund, rejection, suspension or verification of crypto-assets carried out through the Platform. 1.5. The Regulation has been developed in order to ensure the proper functioning of the Platform, compliance with the requirements of the legislation of the Republic of Uzbekistan, requirements in the field of combating the legalization of proceeds derived from criminal activity, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, as well as the Company’s internal policies for managing operational, technical, compliance, sanctions and other risks. 1.6. The Company is entitled to apply the measures provided for in this Regulation, including suspension, rejection, refusal to process, refund, withholding of fees, routing of funds to an intermediate wallet, restriction of access to an operation or funds, as well as other reasonable measures necessary to comply with the law, the Company’s internal rules and to protect the interests of Users, the Company and the Platform. 1.7. The User acknowledges and agrees that certain internal verification procedures, risk-assessment criteria, AML/CFT monitoring algorithms, scoring rules, indicators of suspicious operations, as well as other internal risk management mechanisms constitute internal information of the Company and are not subject to mandatory disclosure to the User. 1.8. This Regulation does not constitute a public promise of an unconditional refund of funds and does not create for the User a right to demand a refund in cases where an operation is subject to restriction, suspension, rejection, verification or other processing in accordance with the law, the Public Offer, this Regulation or the Company’s internal rules. 1.9. The Company is entitled to unilaterally amend, supplement and update this Regulation. The current version of the Regulation is published on the Company’s website and/or in another Platform interface accessible to the User. 1.10. In the event of a conflict between this Regulation and the Public Offer, the terms of the Public Offer shall prevail, unless otherwise expressly provided by the Public Offer or this Regulation.

2.1. For the purposes of this Regulation, the terms below are used with the following meaning, unless otherwise expressly arising from the context:
“AML/CFT” — measures, procedures and mechanisms aimed at combating the legalization of proceeds derived from criminal activity, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, applied by the Company in accordance with the legislation of the Republic of Uzbekistan, the Company’s internal policies and international risk management practices. “Blockchain network” — a distributed information system that ensures the recording, storage and confirmation of operations with crypto-assets. “External wallet” — a wallet, address or other crypto-asset storage instrument that does not belong to the Platform and is not controlled by the Company. “Refund” — an operation to return a crypto-asset, in full or in part, in the cases provided for by this Regulation, the Public Offer, the Company’s internal rules or the requirements of the law. “Incoming transaction” — a transaction involving the receipt of a crypto-asset from an external blockchain network to an address provided by the Platform to the User. “Internal operation” — an operation carried out within the Platform without recording the corresponding operation in the blockchain network. “Fee” — a charge withheld by the Company in connection with the processing of operations, refunds, transfers, checks or the performance of other actions related to the functioning of the Platform. “Company” — JV LLC “City Pay Gate”, which is the operator of the CityPay Platform and operates in accordance with the legislation of the Republic of Uzbekistan. “Limits” — quantitative, value-based, time-based or other restrictions on performing operations, established by the Company in respect of Users, operations, crypto-assets, networks or other parameters of using the Platform. “Rejected transaction” — a transaction whose processing was terminated by the Company before its execution or completion. “Platform” — the CityPay hardware and software complex, including the mobile application, web interfaces, API, software, technical infrastructure and other components that ensure the provision of services to Users. “User” — an individual who has accepted and given consent to the Public Offer and uses the Platform. “Intermediate wallet” — a technical wallet of the Company used for the temporary storage, isolation, verification or processing of funds in respect of which additional verification or the application of risk management measures is required. “Verification” — a set of automated and/or manual procedures applied by the Company in respect of transactions, Users, crypto-assets, addresses or other objects of analysis for the purposes of risk management, compliance with AML/CFT requirements, sanctions control, limits and the Company’s internal policies. “Risk operation” — an operation that has indicators of elevated risk in accordance with internal criteria, monitoring systems, AML/CFT procedures or the Company’s internal rules. “Processing status” — an internal technical status of a transaction meaning that the operation is undergoing additional verification, analysis or processing and is not considered finally confirmed by the Company. “Transaction” — any operation related to the sending, receipt, transfer, refund, processing or other movement of crypto-assets using the Platform.

3.1. General provisions
3.1.1. All transactions carried out using the Platform are subject to automated and/or manual verification by the Company for the purposes of: • ensuring the security of the Platform; • complying with the requirements of the legislation of the Republic of Uzbekistan; • complying with AML/CFT requirements; • preventing fraud; • minimizing operational, sanctions, technical, compliance and other risks. 3.1.2. The Company independently determines the scope, procedure, sequence, duration and methods of conducting checks. 3.1.3. Checks may be carried out both before the execution of a transaction and after its initiation, reflection in the User’s interface, processing or preliminary confirmation. 3.2. Transaction checks 3.2.1. In respect of transactions, the Company is entitled to carry out, including but not limited to: • checking limits; • AML/CFT checks; • sanctions checks; • analysis of the source of origin of funds; • analysis of addresses, wallets and counterparties; • checking for indicators of suspicious activity; • analysis of the User’s transactional behavior; • other checks provided for by the Company’s internal procedures. 3.2.2. The Company is entitled to use: • automated analysis systems; • internal monitoring algorithms; • third-party blockchain operation monitoring systems; • external databases; • other risk management tools. 3.2.3. The Company is not obliged to disclose to the User: • risk assessment criteria; • internal monitoring rules; • the grounds for assigning a risk status; • the parameters of automated checks; • internal AML/CFT procedures. 3.3. Powers of the Company 3.3.1. The Company is entitled, at its own discretion, to: • suspend the processing of a transaction; • reject a transaction; • restrict access to funds; • move a transaction to additional verification status; • request information and documents from the User; • refuse to carry out an operation; • carry out a refund of funds; • withhold fees and expenses; • apply other risk management measures. 3.3.2. The said measures may be applied: • automatically; • manually; • without prior notice to the User; • in cases where the Company deems it necessary. 3.3.3. The Company is entitled to refuse to process a transaction without disclosing the specific reasons for such refusal, if disclosure: • may violate the requirements of the law; • may affect the effectiveness of AML/CFT procedures; • may create a risk of circumventing internal security procedures; • or contradicts the Company’s internal policies. 3.4. Specifics of processing and displaying transactions 3.4.1. The User agrees that the display of transaction information in the Platform interface: • may be of a preliminary, technical or informational nature; • does not always reflect the final status of the operation’s processing; • may be updated with a delay. 3.4.2. The display of a transaction as: • “successful”, • “completed”, • “confirmed”, • or another similar status does not in itself mean the final confirmation of the operation by the Company and does not exclude the possibility of conducting additional verification, suspension, restriction or rejection of the operation, and the transaction status may be changed. 3.5. Verification of Users and request for information 3.5.1. The Company is entitled at any time to request from the User: • information on the origin of funds; • documents confirming the source of origin of funds; • information on the purposes of the operation; • documents and information necessary for an AML/CFT check; • other information that the Company deems necessary. 3.5.2. Until the requested information is provided, the Company is entitled to: • restrict access to operations; • suspend the processing of funds; • restrict the account functionality; • refuse to carry out an operation. 3.5.3. The User’s failure to provide information or the provision of incomplete, inaccurate or misleading information may serve as grounds for: • refusal to process a transaction; • restriction of operations; • application of other measures provided for by the Public Offer and the Company’s internal rules. 3.6. Limitations of the Company’s liability 3.6.1. The Company does not guarantee: • the continuity of operation of blockchain networks; • the speed of transaction processing; • the possibility of executing any initiated operation; • the absence of delays, technical restrictions or errors of third parties. 3.6.2. The Company is not liable for: • the actions and decisions of third parties; • the operation of blockchain networks; • User errors; • the consequences of the User providing incorrect data; • restrictions caused by the requirements of the law, AML/CFT or internal risk management procedures. 3.7. Discretionary powers of the Company 3.7.1. The Company assesses risks and makes the decisions provided for in this Regulation independently and in good faith, on the basis of: • the law; • regulatory requirements; • internal policies; • the interests of ensuring the security of the Platform; • the protection of the Company and Users. 3.7.2. The User agrees that the Company’s decisions made within the framework of risk management and AML/CFT procedures may provide for restrictions, delays, checks and other measures necessary to comply with the law and ensure the security of the Platform.

4.1. General provisions
4.1.1. Cancellation of sending is a procedure for terminating the processing of a transaction initiated by the User before its final execution in the blockchain network or within the Platform. 4.1.2. The cancellation of sending procedure applies in cases where a transaction has not passed one or more of the checks provided for by the Company before its actual execution. 4.1.3. Cancellation of sending is not an executed transaction and is not considered a completed transfer of a crypto-asset. 4.2. Grounds for cancellation of sending 4.2.1. The Company is entitled to apply the cancellation of sending procedure in cases, including but not limited to: • exceeding limits; • identification of indicators of a risk operation; • the results of an AML/CFT check; • identification of restrictions related to an address, wallet, network or counterparty; • technical errors; • the impossibility of correctly processing the operation; • the User’s violation of the requirements of the Public Offer or the Company’s internal rules; • other circumstances that the Company deems to create a risk for the Platform, the Company or Users. 4.2.2. The Company independently determines the existence of grounds for applying the cancellation of sending procedure. 4.2.3. The Company is not obliged to disclose to the User the specific reasons for the cancellation of sending, if disclosure of such information: • may violate the requirements of the law; • may negatively affect AML/CFT procedures; • may create a risk of circumventing internal security mechanisms; • or contradicts the Company’s internal rules. 4.3. Procedure for processing a cancelled transaction 4.3.1. In the event of applying the cancellation of sending procedure: • the transaction receives the status “rejected”; • the record of the transaction is kept in the Platform system; • the operation is considered not executed. 4.3.2. The Company is entitled to retain information on the transaction, its parameters, the results of checks and other related data for the purposes of: • complying with the requirements of the law; • internal record-keeping; • AML/CFT monitoring; • risk management; • dispute resolution; • fulfilling the requirements of state authorities. 4.4. Refund of funds upon cancellation of sending 4.4.1. In the event of cancellation of sending, the operation amount is subject to restoration to the User’s balance. 4.4.2. Such restoration: • is carried out automatically or manually; • is not considered a separate refund; • constitutes a restoration of the available balance for an unexecuted operation. 4.5. Fees and limits 4.5.1. In the event of cancellation of sending, the fee for executing the transaction is not charged, since the operation is considered not executed. 4.5.2. The Company is entitled to: • not take such a transaction into account when calculating limits; • adjust the User’s limits; • restore previously reserved limits. 4.5.3. The procedure for calculating and restoring limits is determined by the Company independently and may not be disclosed to the User. 4.6. Specifics of displaying cancelled operations 4.6.1. The User agrees that: • the transaction status may change during processing; • the operation may be displayed as being in processing until the moment of final rejection. 4.6.2. The display of an intermediate transaction status does not create for the User a right to demand execution of the operation. 4.7. Limitation of liability 4.7.1. The Company is not liable for: • the impossibility of executing a cancelled transaction; • the consequences of applying risk management procedures; • restrictions caused by AML/CFT checks; • technical restrictions or specifics of blockchain networks. 4.7.2. The User agrees that cancellation of sending is one of the measures for ensuring the security of the Platform and managing risks.

5.1. General provisions
5.1.1. A refund on internal operations is an internal operation of the Company to restore to the User crypto-assets previously debited within the framework of an internal operation on the Platform. 5.1.2. A refund on internal operations may be carried out: • on the Company’s initiative; • within the framework of risk management procedures; • upon identification of technical errors; • in other cases determined by the Company. 5.1.3. A refund on internal operations is not an obligation of the Company to carry out a refund upon any request of the User and is carried out solely in the cases provided for by the Public Offer, this Regulation, the Company’s internal rules or the requirements of the law. 5.2. Grounds for carrying out a refund 5.2.1. The Company is entitled to carry out a refund on an internal operation, including but not limited to, in the following cases: • a technical error; • a failure in processing the operation; • an erroneous debit; • cancellation of an internal operation; • identification of violations or restrictions after processing the operation; • application of risk management procedures; • other circumstances determined by the Company. 5.2.2. The Company independently determines: • the possibility of a refund; • the scope of the refund; • the procedure for processing the refund; • the applicable fees and restrictions. 5.3. Scope of the refund 5.3.1. A refund may include: • the full amount of the operation; • part of the amount of the operation; • the fee withheld when performing the operation; • other amounts determined by the Company. 5.3.2. The Company is entitled to: • withhold the fee in full or in part; • withhold expenses related to processing the operation; • refuse to refund the fee. 5.3.3. The decision on refunding the fee is made by the Company taking into account: • the nature of the operation; • the reasons for the refund; • technical expenses; • the results of checks; • the Company’s internal rules. 5.4. Specifics of processing a refund 5.4.1. A refund on internal operations is reflected in the Platform system as a separate operation. 5.4.2. In the User’s operation history: • the original operation; • and the refund operation may be displayed separately. 5.4.3. The Company is entitled to carry out a refund: • automatically; • manually; • without re-passing the standard sending process; • without re-verification by the User. 5.4.4. A refund may be carried out using special internal processing procedures that differ from the standard transaction sending mechanism. 5.5. Limits and recalculation 5.5.1. In the event of carrying out a refund, the Company is entitled to: • adjust the User’s limits; • restore previously used limits; • exclude the operation from the limit calculation; • recalculate operation volumes. 5.5.2. The procedure for calculating limits is determined by the Company independently and may be changed without prior notice to the User. 5.5.3. The Company is not obliged to disclose to the User the internal logic for calculating and recalculating limits. 5.6. Restrictions and checks 5.6.1. The Company is entitled to: • suspend a refund; • refuse a refund; • restrict access to refunded funds; • route funds for additional verification. 5.6.2. A refund may be restricted or rejected in cases of: • identification of indicators of a risk operation; • AML/CFT restrictions; • the presence of indicators of fraud; • the User providing inaccurate information; • violation of the Public Offer or the Company’s internal rules. 5.7. Processing time 5.7.1. A refund is carried out within a reasonable period determined by the Company taking into account: • the nature of the operation; • technical specifics; • the results of checks; • the load on the infrastructure; • other circumstances. 5.7.2. The said periods are indicative and are not guaranteed periods for the fulfillment of obligations. 5.8. Limitation of liability 5.8.1. The Company is not liable for: • delays in the refund; • the impossibility of a refund; • the consequences of applying risk management procedures; • restrictions caused by AML/CFT checks; • the actions of third parties and external services. 5.8.2. The User agrees that a refund on internal operations is a right and not an unconditional obligation of the Company, except in cases expressly provided for by the legislation of the Republic of Uzbekistan.

6.1. General provisions
6.1.1. All incoming transactions received at addresses provided by the Platform to Users are subject to mandatory verification by the Company. 6.1.2. The processing of incoming transactions is carried out in accordance with: • the requirements of the legislation of the Republic of Uzbekistan; • AML/CFT procedures; • internal risk management rules; • the technical and operational requirements of the Platform. 6.1.3. The Company is entitled to process incoming transactions: • automatically; • manually; • with the application of additional verification procedures; • with the involvement of third-party monitoring and analysis systems. 6.2. Verification of incoming transactions 6.2.1. Incoming transactions may undergo, including but not limited to: • a check against internal and international restriction lists; • an AML/CFT check; • analysis of the risk level of an address, wallet or counterparty; • a check of limits; • analysis of transactional behavior; • other risk assessment procedures. 6.2.2. The Company independently determines: • the scope of checks; • risk assessment criteria; • the need for additional verification; • the grounds for restricting or refusing to process a transaction. 6.2.3. The Company is not obliged to disclose to the User: • risk assessment criteria; • internal monitoring mechanisms; • the parameters of automated checks; • the grounds for assigning a risk status; • internal AML/CFT procedures. 6.3. Processing status 6.3.1. If additional verification is necessary, an incoming transaction may be moved to the internal processing status. 6.3.2. The processing status means that: • the transaction is undergoing additional verification; • the operation is not considered finally confirmed by the Company; • the User’s access to the corresponding funds may be restricted in full or in part. 6.3.3. The grounds for moving a transaction to the processing status may include, including but not limited to: • the results of an AML/CFT check; • identification of indicators of a risk operation; • exceeding limits; • the presence of restrictions in respect of an address, wallet, counterparty or source of funds; • indicators of suspicious activity; • the need for additional verification; • other circumstances determined by the Company. 6.4. Specifics of displaying statuses 6.4.1. The User agrees that: • the display of transaction information in the Platform interface may be of a preliminary, technical or informational nature; • the displayed status does not always reflect the final status of the operation’s processing. 6.4.2. In certain cases, a transaction may be displayed as: • “successful”, • “completed”, • “confirmed”, • or a similar status, while the operation is actually undergoing additional verification. 6.4.3. The display of the operation status in the user interface: • does not create for the User an unconditional right to demand crediting of funds; • does not mean the final confirmation of the operation by the Company; • does not exclude the possibility of applying the measures provided for in this Regulation. 6.5. Suspension and restriction of operations 6.5.1. The Company is entitled to: • suspend the processing of a transaction; • restrict access to funds; • refuse to credit funds; • initiate additional checks; • request documents and information from the User; • apply other risk management measures. 6.5.2. The said measures may be applied: • automatically; • manually; • without prior notice to the User; • for the period necessary for the Company to conduct the verification. 6.6. Additional verification and request for information 6.6.1. The Company is entitled to request from the User: • information on the origin of funds; • supporting documents; • information on the purposes of the operation; • information on the sender or counterparty; • other documents and information necessary to the Company. 6.6.2. Until the verification is completed, the Company is entitled to: • restrict access to funds; • not carry out crediting; • hold funds on intermediate wallets; • restrict the account functionality. 6.6.3. The User’s failure to provide the requested information may serve as grounds for: • refusal to process the operation; • restriction of access to funds; • application of other measures provided for by the Company’s internal rules. 6.7. Verification time 6.7.1. The period for conducting the verification is determined by the Company independently, taking into account: • the nature of the operation; • the level of risk; • the volume of information required; • technical and operational factors. 6.7.2. The Company does not guarantee the completion of the verification within a specific period. 6.8. Limitation of liability 6.8.1. The Company is not liable for: • delays in transaction processing; • the consequences of applying AML/CFT procedures; • restrictions caused by internal checks; • the impossibility of executing an operation as a result of applying risk management measures. 6.8.2. The User agrees that the application of the processing status and other verification measures is a necessary element of ensuring the security of the Platform and complying with the requirements of the law.

7.1. General provisions
7.1.1. For the purposes of ensuring the security of the Platform, complying with AML/CFT requirements, managing risks and conducting additional checks, the Company is entitled to use intermediate wallets. 7.1.2. Intermediate wallets are technical wallets of the Company and are used solely within the framework of internal procedures for processing, verifying, isolating, storing or refunding funds. 7.1.3. The use of intermediate wallets does not mean that the Company assumes an obligation for the final crediting, refund or unblocking of funds. 7.2. Grounds for routing funds to an intermediate wallet 7.2.1. The Company is entitled to route funds to an intermediate wallet in cases, including but not limited to: • identification of indicators of a risk operation; • the results of an AML/CFT check; • the need for additional verification of an operation; • identification of restrictions in respect of an address, wallet, counterparty or source of funds; • identification of indicators of suspicious activity; • exceeding limits; • technical restrictions; • other circumstances determined by the Company. 7.2.2. The decision to route funds to an intermediate wallet is made by the Company independently. 7.3. Legal status of funds on an intermediate wallet 7.3.1. Funds placed on an intermediate wallet: • are considered to be undergoing verification and processing; • may be temporarily restricted in use; • are not considered finally credited to the User until the verification is completed. 7.3.2. Until the verification is completed, the Company is entitled to: • restrict access to funds; • refuse crediting; • carry out a refund; • hold funds for the period necessary to conduct the verification; • apply other risk management measures. 7.3.3. The User agrees that the placement of funds on an intermediate wallet may be carried out: • automatically; • without prior notice; • within the framework of the Company’s internal procedures. 7.4. Verification of risk operations 7.4.1. In respect of funds placed on an intermediate wallet, the Company is entitled to conduct: • additional AML/CFT checks; • analysis of the source of origin of funds; • verification of transactional activity; • verification of counterparties; • other risk assessment procedures. 7.4.2. The Company is entitled to request from the User: • information on the origin of funds; • documents confirming the source of origin of funds; • information on the purposes of the operation; • other information necessary to the Company. 7.4.3. The Company is not obliged to disclose to the User: • internal risk assessment criteria; • the grounds for assigning a risk status; • internal verification procedures; • the analysis mechanisms used. 7.5. Refund of funds and threshold values 7.5.1. General provisions. The decision to refund funds placed on an intermediate wallet is made by the Company taking into account: • the results of the verification; • the level of risk; • the nature of the operation; • the applicable restrictions; • the Company’s internal policies. 7.5.2. Minimum refund threshold. The Company is entitled to establish minimum threshold values for processing refunds. As of the date of publication of this Regulation, the minimum refund threshold is the equivalent of 10 (ten) USDT. 7.5.3. Funds below the threshold value. In the event that the operation amount is below the established threshold value: • the Company is entitled to refuse to carry out the refund due to the technical, operational or economic infeasibility of processing such a refund; • such crypto-assets are not considered credited to the User and are not reflected as an available balance on the User’s account; • the placement of such crypto-assets on the Company’s technical or intermediate wallets is carried out solely for the purposes of internal processing, storage and compliance with risk management procedures; • the said crypto-assets do not become the property of the Company solely by virtue of their placement on technical or intermediate wallets; • the Company is entitled to restrict any operations with such crypto-assets until the relevant internal decision is made within the framework of risk management and AML/CFT procedures. 7.5.4. Funds above the threshold value. In the event that the operation amount is equal to or exceeds the established threshold: • the Company is entitled to carry out a refund of funds to the sender or make another decision within the framework of risk management procedures; • the refund may be carried out net of fees, network expenses and other expenses related to processing the operation. 7.6. Period for storing and processing funds 7.6.1. The period for storing funds on an intermediate wallet is determined by the Company independently, taking into account: • the nature of the verification; • the requirements of the law; • internal procedures; • technical factors. 7.6.2. The Company does not guarantee the completion of the verification or the making of a decision within a specific period. 7.7. Limitation of liability 7.7.1. The Company is not liable for: • the consequences of placing funds on intermediate wallets; • restrictions on access to funds; • delays caused by conducting checks; • the impossibility of refunding funds; • restrictions caused by AML/CFT requirements and the Company’s internal procedures. 7.7.2. The User agrees that the use of intermediate wallets is a necessary measure for: • ensuring the security of the Platform; • managing risks; • complying with the requirements of the law and AML/CFT.

8.1. General provisions
8.1.1. For the processing of transactions, refunds, the conducting of checks, the use of the Platform infrastructure, as well as the performance of other operations, the Company is entitled to withhold fees. 8.1.2. Fees are established by the Company independently and may vary depending on: • the type of operation; • the crypto-asset used; • the blockchain network; • technical and operational expenses; • the risk level of the operation; • other factors determined by the Company. 8.1.3. The amounts of fees are determined by the Company at its own discretion and may be changed unilaterally without prior notice to the User, unless otherwise expressly provided by the legislation of the Republic of Uzbekistan. 8.2. Fees upon refund of funds 8.2.1. When carrying out a refund of funds, the Company is entitled to withhold: • the Company’s fees; • blockchain network fees; • expenses related to processing the operation; • other applicable expenses. 8.2.2. Fees are withheld from the refund amount, unless otherwise determined by the Company. 8.2.3. The User agrees that: • the amount of funds actually refunded may be less than the amount of the original operation; • the amount of withholdings may depend on the nature of the operation and the applicable expenses. 8.3. Calculation of fees 8.3.1. Fees may be established: • in a fixed amount; • in an amount depending on the crypto-asset or network; • in another procedure determined by the Company. 8.3.2. For the purposes of calculating fees, the Company is entitled to use: • internal rates; • market quotations; • data from third-party information providers; • other sources of information. 8.3.3. The base calculation unit for determining the amount of fees may be the USDT equivalent or another calculation unit determined by the Company. 8.4. Fee table 8.4.1. The current amounts of certain fees may be published by the Company in the form of tables, tariffs, reference materials or other informational documents. 8.4.2. Fee tables: • are of an informational nature; • may be updated, changed or supplemented by the Company; • are applied in the version in effect at the time of processing the operation. 8.5. Refund fee table !Refund table.png

The USDT equivalents:
• are indicative; • are calculated as of the date of formation of the relevant table; • may change depending on market conditions, network expenses and the Company’s internal calculations. 8.6. Specifics of withholding fees 8.6.1. A fee may be withheld: • automatically; • at the time of processing the operation; • at the time of the refund; • at the time of recalculating the operation; • or in another manner determined by the Company. 8.6.2. The Company is entitled to: • round fee amounts; • apply minimum fee amounts; • withhold additional expenses related to processing operations. 8.6.3. In the event that the operation amount is insufficient to withhold the fee, the Company is entitled to: • refuse to process the refund; • deem the refund technically or economically infeasible; • apply other measures provided for by the Company’s internal rules. 8.7. Change of fees 8.7.1. The Company is entitled at any time to: • change the amounts of fees; • introduce new fees; • change the procedure for calculating and withholding fees; • cancel certain fees. 8.7.2. The current fees are applied at the time of: • processing the operation; • the refund; • the recalculation; • or another action of the Company. 8.8. Limitation of liability 8.8.1. The Company is not liable for: • changes in network expenses; • changes in the market value of crypto-assets; • changes in third-party fees; • the consequences of applying the fees provided for in this Regulation. 8.8.2. The User agrees that: • fees are an integral part of the functioning of the Platform; • the withholding of fees may be a mandatory condition for processing an operation or a refund.

9.1. General provisions
9.1.1. For the purposes of ensuring the security of the Platform, complying with AML/CFT requirements, managing operational and compliance risks, as well as controlling the volumes of operations, the Company is entitled to establish limits on performing operations. 9.1.2. Limits may be applied: • to all Users; • to certain categories of Users; • to certain operations; • to certain crypto-assets; • to certain blockchain networks; • or in another manner determined by the Company. 9.1.3. The Company independently determines: • the types of limits; • the amounts of limits; • the procedure for their application; • the procedure for calculating operation volumes; • the criteria for changing limits. 9.2. Types of limits 9.2.1. The Company is entitled to establish, including but not limited to: • sending limits; • receiving limits; • daily limits; • monthly limits; • limits on the number of operations; • limits for certain assets or networks; • other restrictions. 9.2.2. Limits may be determined: • in crypto-assets; • in the USDT equivalent; • in another calculation unit determined by the Company. 9.3. Application of limits 9.3.1. Limits are applied by the Company automatically and/or manually. 9.3.2. When calculating limits, the Company is entitled to take into account: • the volume of operations; • the number of operations; • the type of operations; • the networks used; • the risk level of the operation; • the results of an AML/CFT check; • other factors. 9.3.3. For the purposes of calculating limits, the Company is entitled to: • convert the volume of operations into the USDT equivalent; • use internal rates and market quotations; • take operations into account both in full and in part. 9.4. Current limits 9.4.1. The current limits applied by the Company in respect of operations on the Platform are reflected in the CityPay Public Offer. 9.5. Specifics of calculating limits 9.5.1. In the event of performing an operation in a crypto-asset other than USDT, the operation volume may be recalculated by the Company into the USDT equivalent at the rate determined by the Company at the time of processing the operation. 9.5.2. The Company is entitled to: • independently determine the rate used; • use internal and/or market quotations; • change the procedure for calculating the equivalent without prior notice to the User. 9.5.3. For the purposes of applying limits: • a day is calculated by Tashkent city time (UTC+5); • a month is defined as a calendar month, unless otherwise determined by the Company. 9.6. Change and adjustment of limits 9.6.1. The Company is entitled to: • change limits; • apply individual limits; • introduce temporary restrictions; • restrict certain operations; • establish special limits depending on the level of risk. 9.6.2. The Company is entitled to change limits: • automatically; • manually; • without prior notice to the User. 9.6.3. The Company is entitled to: • recalculate used limits; • restore limits; • exclude operations from the limit calculation; • apply internal adjustments. 9.7. Restriction of operations 9.7.1. In the event of exceeding limits, the Company is entitled to: • reject an operation; • suspend its processing; • restrict the User’s functionality; • request additional documents and information; • apply other risk management measures. 9.7.2. Exceeding limits may serve as grounds for: • moving an operation to additional verification status; • applying the processing status; • routing funds to an intermediate wallet; • conducting an additional AML/CFT check. 9.8. Display of limits 9.8.1. Information on limits displayed to the User: • may be of an informational nature; • may be updated with a delay; • does not guarantee the possibility of performing an operation. 9.8.2. The Company is entitled not to disclose: • the internal methodology for calculating limits; • the criteria for changing limits; • internal risk parameters. 9.9. Limitation of liability 9.9.1. The Company is not liable for: • the impossibility of performing an operation as a result of applying limits; • the consequences of changing limits; • restrictions caused by AML/CFT and risk management procedures. 9.9.2. The User agrees that limits are a necessary element of: • ensuring the security of the Platform; • complying with the requirements of the law; • preventing abuse and risk operations.

10.1. General provisions
10.1.1. The processing time for operations on the Platform depends on: • the nature of the operation; • the blockchain network used; • the technical specifics of processing; • the need to conduct checks; • the risk level of the operation; • the actions of third parties; • other factors beyond the Company’s control. 10.1.2. The Company takes reasonable measures for the timely processing of operations; however, it does not guarantee the execution of operations or the completion of checks within a specific period. 10.2. Transaction processing time 10.2.1. The processing of transactions may be carried out: • automatically; • manually; • with the application of additional verification procedures. 10.2.2. The processing time for an operation is determined by the Company independently, taking into account: • the type of operation; • the results of checks; • the load on the infrastructure; • the state of the blockchain network; • technical and operational factors. 10.2.3. The Company is entitled to: • suspend the processing of operations; • extend verification periods; • request additional information; • apply other measures necessary to complete the processing of an operation. 10.3. Refund processing time 10.3.1. Refunds of funds are carried out within a period determined by the Company, taking into account: • the nature of the operation; • the results of the verification; • the applicable restrictions; • the technical specifics of processing; • the load on blockchain networks; • the actions of third parties; • other circumstances. 10.3.2. The indicative period for processing a refund may be up to 48 (forty-eight) business hours. 10.3.3. The said period: • is indicative; • is not a guaranteed period for the fulfillment of an obligation; • may be extended by the Company in the cases provided for in this Regulation. 10.4. Extension of processing time 10.4.1. The Company is entitled to extend the processing time for operations and refunds in cases, including but not limited to: • the need for additional verification; • the conducting of AML/CFT procedures; • the need to obtain documents and information from the User; • identification of indicators of a risk operation; • technical restrictions; • unstable operation of blockchain networks; • increased load on the infrastructure; • the actions or inaction of third parties; • other circumstances affecting the processing of an operation. 10.4.2. The extension of processing time is not considered a violation of the Company’s obligations if such an extension is related to: • ensuring the security of the Platform; • complying with the requirements of the law; • applying risk management procedures; • or other circumstances provided for in this Regulation. 10.5. Dependence on external factors 10.5.1. The User agrees that the processing time for operations may depend on: • the speed of confirmation by blockchain networks; • network load; • technical restrictions of third-party services; • the actions of counterparties; • external infrastructure factors. 10.5.2. The Company is not liable for delays caused by: • the specifics of the operation of blockchain networks; • the actions of third parties; • technical failures beyond the Company’s control; • changes in network conditions. 10.6. Suspension of processing 10.6.1. The Company is entitled to suspend the processing of an operation or a refund: • for the period of conducting the verification; • until the necessary information is received; • until technical restrictions are eliminated; • in other cases provided for in this Regulation. 10.6.2. During the period of suspension of processing: • the operation may remain in verification status; • access to funds may be restricted; • processing periods are considered extended for the period of validity of the relevant circumstances. 10.7. Informing Users 10.7.1. The Company is entitled, but not obliged, to: • notify the User of the progress of the verification; • disclose the details of processing an operation; • report the reasons for the delay. 10.7.2. The scope of information provided to the User is determined by the Company independently, taking into account: • the requirements of the law; • AML/CFT procedures; • internal security rules. 10.8. Limitation of liability 10.8.1. The Company is not liable for: • delays in the processing of operations; • an increase in verification periods; • the impossibility of processing an operation within the period expected by the User; • the consequences of applying AML/CFT and risk management procedures. 10.8.2. The User agrees that the processing time for operations: • may change; • depends on many factors; • cannot always be determined in advance.

11.1. General provisions
11.1.1. For the purposes of ensuring the security of the Platform, complying with the requirements of the legislation of the Republic of Uzbekistan, AML/CFT procedures and internal risk management rules, the Company is entitled to interact with Users on matters of processing operations, conducting checks and providing information. 11.1.2. The User undertakes to: • provide accurate, current and complete information; • respond to the Company’s requests in a timely manner; • provide documents and information necessary for the Company to conduct checks. 11.2. The Company’s right to request information 11.2.1. The Company is entitled at any time to request from the User: • information on the origin of funds; • documents confirming the source of origin of funds; • information on the purposes of the operation; • information on the counterparty; • identity documents; • information confirming the right of ownership of the funds; • other information and documents necessary to the Company. 11.2.2. The Company independently determines: • the list of necessary documents and information; • the scope of the verification; • the form of providing information; • the deadlines for providing information. 11.3. Forms of providing information 11.3.1. The User is obliged to provide information: • through the Platform interfaces; • by email; • through the support service; • or in another manner determined by the Company. 11.3.2. The Company is entitled to: • request originals of documents; • request notarized copies; • request a translation of documents; • request additional confirmations. 11.4. Additional checks 11.4.1. The Company is entitled to conduct: • repeated checks; • additional AML/CFT checks; • extended checks of risk operations; • verification of previously provided information. 11.4.2. The conducting of additional checks may be carried out: • regardless of a previously successfully passed check; • at any time of using the Platform; • without prior notice to the User. 11.5. Consequences of failure to provide information 11.5.1. The User’s failure to provide information or documents requested by the Company may serve as grounds for: • refusal to process an operation; • suspension of the processing of an operation; • restriction of access to funds; • application of the processing status; • routing of funds to an intermediate wallet; • restriction of the account functionality; • refusal to refund funds; • application of other measures provided for by the Public Offer and the Company’s internal rules. 11.6. Accuracy of information 11.6.1. The User is responsible for: • the accuracy of the information provided; • the currency of the information provided; • the legality of the origin of funds; • the legality of the operations performed. 11.6.2. The provision of: • inaccurate information; • forged documents; • misleading information; • incomplete information may serve as grounds for: • refusal of service; • restriction of operations; • application of internal risk management measures; • transfer of information to authorized state authorities in the cases provided for by law. 11.7. Communication and support 11.7.1. The User is entitled to contact the Company’s support service to: • clarify the status of an operation; • provide information; • submit requests related to the processing of operations. 11.7.2. The Company is entitled to independently determine: • the scope of information provided; • the procedure for interaction; • the time for considering requests; • the need to provide a response. 11.8. Restriction of information disclosure 11.8.1. The Company is entitled to refuse to disclose information: • on internal AML/CFT procedures; • on risk assessment criteria; • on internal monitoring algorithms; • on the reasons for applying certain measures; • on internal security procedures. 11.8.2. Restriction of information disclosure may be applied in cases where disclosure: • contradicts the law; • may affect the effectiveness of AML/CFT procedures; • may create a risk of circumventing internal security mechanisms; • violates the Company’s internal policies. 11.9. Processing and storage of information 11.9.1. The Company is entitled to: • store the information provided by the User; • use it for the purposes of conducting checks; • transfer information to authorized authorities in the cases provided for by law; • use information for risk management and the prevention of violations. 11.9.2. The period for storing information is determined by the Company, taking into account: • the requirements of the law; • AML/CFT requirements; • internal data storage rules. 11.10. Limitation of liability 11.10.1. The Company is not liable for: • the consequences of the User’s failure to provide information; • delays caused by the need to conduct checks; • restrictions related to AML/CFT procedures; • refusal to process operations as a result of insufficient information. 11.10.2. The User agrees that the provision of information and the passing of checks are mandatory conditions for using the Platform.

12.1. General provisions
12.1.1. The Platform is provided to Users on an “as is” and “as available” basis, taking into account the technical, operational, regulatory and other restrictions related to the Company’s activities and the specifics of the functioning of blockchain networks. 12.1.2. The Company takes reasonable measures to ensure the functioning of the Platform; however, it does not guarantee: • the uninterrupted operation of the Platform; • the absence of technical errors; • the absence of delays in processing operations; • the possibility of executing any operation; • the availability of certain Platform functions at any point in time. 12.2. Limitation of liability for blockchain networks and third parties 12.2.1. The Company is not liable for: • the specifics of the functioning of blockchain networks; • delays in transaction confirmations; • changes in the rules of blockchain networks; • network congestion; • failures, errors or restrictions of external networks; • the actions of validators, miners, nodes or other participants in the blockchain infrastructure. 12.2.2. The Company is not liable for the actions or inaction of: • third parties; • counterparties; • infrastructure providers; • service providers; • third-party services; • network operators; • banks; • payment organizations; • other persons not under the Company’s control. 12.3. Limitation of liability for the User’s actions 12.3.1. The User is solely responsible for: • the correctness of the wallet address; • the choice of the blockchain network; • the choice of the crypto-asset; • the accuracy of the information provided; • the legality of the origin of funds; • compliance with the law applicable to the User. 12.3.2. The Company is not liable for: • User errors; • the sending of funds to an incorrect address; • the use of an unsupported network; • the loss of access to external wallets; • the consequences of providing inaccurate information; • the User’s actions performed in violation of this Regulation or the Public Offer. 12.4. Limitation of liability for AML/CFT measures 12.4.1. The Company is not liable for: • delays in processing operations; • restrictions of operations; • refusal to process operations; • withholding of funds; • the conducting of checks; • the application of the processing status; • the use of intermediate wallets; • other measures applied for the purposes of AML/CFT, risk management and compliance with the law. 12.4.2. The User agrees that the Company’s application of AML/CFT and risk management procedures is a mandatory condition for the functioning of the Platform. 12.5. Limitation of liability for the display of information 12.5.1. The Company does not guarantee that: • the information displayed in the Platform interface; • operation statuses; • the amounts of limits; • information on fees; • data on processing times are always final, current or displayed without delays. 12.5.2. The display of an operation as: • “successful”; • “completed”; • “confirmed”; • or another similar status does not exclude the possibility of: • additional verification; • cancellation; • restriction; • suspension; • the application of other measures provided for in this Regulation. 12.6. Limitation of warranties 12.6.1. The Company does not provide the User with: • guarantees of the execution of operations; • guarantees of the refund of funds; • guarantees of the absence of restrictions; • guarantees of the constant availability of the Platform; • guarantees of the absence of technical errors; • guarantees of the absence of changes in fees, limits or other conditions of using the Platform. 12.6.2. No information posted on the Platform or provided to the User shall be regarded as a guarantee or obligation of the Company, unless otherwise expressly provided by the legislation of the Republic of Uzbekistan. 12.7. Force majeure and external circumstances 12.7.1. The Company is not liable for the impossibility of fulfilling obligations as a result of circumstances beyond the Company’s reasonable control, including: • failures of blockchain networks; • communication outages; • the actions of state authorities; • changes in legislation; • sanctions restrictions; • cyberattacks; • technical failures; • accidents; • the actions of third parties; • other circumstances of force majeure. 12.7.2. During the period of validity of the said circumstances, the periods for the fulfillment of the Company’s obligations are considered extended for the period of existence of such circumstances and their consequences. 12.8. Limitation of the amount of liability 12.8.1. To the maximum extent permitted by law, the Company’s liability to the User is limited to the amount of the fee actually received by the Company for the relevant operation, unless otherwise expressly provided by the legislation of the Republic of Uzbekistan. 12.9. Release of the Company from liability 12.9.1. The User agrees that the Company is not liable for: • indirect losses; • lost profits; • reputational losses; • loss of data; • the impossibility of using the Platform; • losses related to the volatility of crypto-assets; • other adverse consequences of using the Platform. 12.10. Acceptance of risks by the User 12.10.1. The User confirms that they: • understand the risks related to the use of crypto-assets; • understand the risks related to the use of blockchain networks; • accept the risks of technical restrictions, volatility, delays and AML/CFT restrictions; • use the Platform voluntarily and at their own risk.

13.1. Application of the Regulation
13.1.1. This Regulation applies jointly with: • the CityPay Public Offer; • the User Agreement; • other rules and documents of the Company governing the use of the Platform. 13.1.2. This Regulation is binding on all Users of the Platform from the moment of: • acceptance of and consent to the Public Offer by the User; • registration on the Platform. 13.2. Amendment of the Regulation 13.2.1. The Company is entitled at any time to: • amend; • supplement; • update; • cancel certain provisions of this Regulation. 13.2.2. Amendments take effect: • from the moment of their publication on the Company’s website; • or from another date determined by the Company. 13.2.3. Continued use of the Platform after the amendments take effect means the User’s full consent to the relevant amendments. 13.3. Publication and availability 13.3.1. The current version of this Regulation is published: • on the Company’s official website; • and/or in the Platform interfaces; • and/or in another manner determined by the Company. 13.3.2. The User undertakes to independently monitor the current version of the Regulation and the amendments made to it. 13.4. Interpretation and validity of provisions 13.4.1. If certain provisions of this Regulation are recognized as invalid, unlawful or unenforceable, this does not affect the validity of the remaining provisions. 13.4.2. An invalid or unenforceable provision is subject to interpretation or replacement to the extent that is as close as possible in meaning and permissible by law. 13.5. Priority and joint application of documents 13.5.1. This Regulation is subject to interpretation and application jointly with the Public Offer and other documents of the Company. 13.5.2. In the event of differing interpretation of the provisions of the Company’s documents, such provisions are subject to interpretation: • taking into account the goals of ensuring the security of the Platform; • compliance with the requirements of the law; • fulfillment of AML/CFT requirements; • risk management; • protection of the legitimate interests of the Company and Users. 13.6. Applicable law 13.6.1. This Regulation is governed by and interpreted in accordance with the legislation of the Republic of Uzbekistan. 13.6.2. The law of the Republic of Uzbekistan applies to all relations related to the use of the Platform. 13.7. Language of the Regulation 13.7.1. This Regulation may be published in the Uzbek, Russian and English languages. 13.7.2. In the event of discrepancies between the language versions, the version in Russian shall prevail, unless otherwise expressly established by the Company. 13.8. Survival of certain provisions 13.8.1. The clauses of this Regulation that by their nature presuppose continued validity after the User ceases to use the Platform shall continue to be in effect after: • the cessation of use of the Platform; • the termination of relations with the User; • the deletion of the account; • the termination of the Public Offer. 13.9. Contact information 13.9.1. The User is entitled to contact the Company on matters related to this Regulation through the official communication channels indicated on the Platform website. 13.9.2. The Company is entitled to independently determine: • the procedure for processing requests; • the time for consideration; • the methods of communication with Users.

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