Restrictions for using the Services

7.1. Freezing is an action in a result of which the User’s right to make all transactions or some operations on the Platform, has been suspended.

7.2. The Service Provider shall freeze the right to manage assets or to use the Service, if:

7.2.1. the amount of funds delivered by the User to the Service Provider is not sufficient to settle the Service Provider’s claims against the User;

7.2.2. the Service Provider suspects the User of connection to the money laundering, terrorism financing or other crime (e.g. fraud);

7.2.3. the Service Provider suspects that corresponding transaction, the User or connected person is related to the territory, area of activity, the Service or a person subject to sanctions or other national transaction limits (e.g. sanctions of the European Union or the USA);

7.2.4. a company mediating the Service (e.g. international card organisation or other settlement system operator) has established restrictions on the corresponding country, territory, currency, area of activity, Service, person or transaction (e.g. restrictions on international payments that are related to gambling or a territory linked to sanctions);

7.2.5. the Service Provider has been presented with controversial information about the persons having the right of representation or documents regarding the authenticity of which the Service Provider has doubts;

7.2.6. the User did not submit to the Service Provider documents and all the data which in the meaning of the Service Provider required to establish that submitted to the Service Provider information is correct (e.g., information about the User, about actual beneficiary of the User who is legal person or information about origin of User’s assets);

7.2.7. upon the estimation of the Service Provider, freezing is necessary in order to prevent damages to the Service Provider or a third person;

7.2.8. the User’s assets have been attached or there is another ground for the freezing related to the decision of the state body.

7.3. The Service Provider shall cancel the freezing as soon as the reason for freezing has been eliminated.

7.4. The Service Provider shall not bear liability for the damage arising from freezing.

7.5. The Service Provider shall only attach the assets of the User at the request of a third person in the cases and pursuant to the procedure prescribed by law (e.g., on the initiative of a tax authority or a bailiff).

7.6. The Service Provider shall release the User’s assets from the attachment on the basis of a resolution of the body that issued the attachment decision, regulation or precept or on the basis of the enforced judicial decision.

7.7. The Service Provider may carry out planned maintenance and development work of the information system. If possible, the Service Provider shall carry out the planned maintenance and development work at night.

7.8. Upon the occurrence of extraordinary circumstances, the Service Provider shall carry out extraordinary maintenance or development work at the time chosen by the same in order to prevent greater damage.

7.9. During the maintenance or development work the performance of the Service Provider’s contractual obligations before the User arising from the User Agreement shall be suspended and the Service Provider shall not compensate the User for the potential damage resulting from the failure to perform the obligations under the User Agreement due to the abovementioned grounds.

7.10. The Service Provider may immediately unilaterally cancel the User Agreement for a good reason (extraordinary cancellation). The good reason should be considered as follows:

7.10.1. The User or a legal person connected to them has violated an obligation, the precise following of which is a prerequisite for the continuing interest of the Service Provider upon continuing the performance of the User Agreement. Such obligations include but not limited to:

a) presentation of correct, complete and truthful information to the Service Provider upon identification of the person;

b) notification about all changes to the information set forth in the agreements or the documents presented to the Service Provider;

c) submission of all information and documents that are considered necessary by the Service Provider for determining the truthfulness of the information related to the User or the actual beneficiary of the User which is a legal person;

d) presentation of their sufficient information and documents verifying the legality of one’s economic activities (incl. connected persons, ownership relations), money or other assets of the User at the Service Provider’s request;

e) presentation of accurate information about User’s economic situation provided that such information is of significant importance to the Service Provider upon making decisions or performing other operations;

f) notification of the Service Provider about the deterioration of one’s economic situation or other circumstances that can hinder the performance of the User’s obligations before the Service Provider in the required manner.

7.10.2. the Service Provider suspects the User or a connected person of money laundering or terrorism financing;

7.10.3. the Service Provider suspects that the User or a connected person is a front person;

7.10.4. Sanctions or other national transaction limits (e. g. sanctions of the European Union or the USA) have been imposed on the User or connected person;

7.10.5. the Service Provider suspects that the User’s transaction violates the sanctions or other national transaction limits (e. g. sanctions of the European Union or the USA);

7.10.6. The User or the connected person:

a) is personally or its partners are connected, or has been connected, to organised crime, money laundering, terrorism financing or evasion of taxes, also to international sanctions or other national transaction limits (e. g. sanctions of the European Union or the USA) according to the information of acknowledged and reliable sources (e.g. state bodies, international organizations, international or national databases, correspondent banks, and mass media);

b) is personally or its partners are connected, or has been connected, to the traditional income sources of organised crime, incl. illicit traffic of excise goods or narcotic substances, illegal trafficking of arms or persons, mediation of prostitution, unlicensed international transmission of money;

c) comes from a country that has insufficient levels for preventing corruption / money laundering / terrorism financing;

d) is, in the opinion of the Service Provider, personally or its connected person engaged in the field of activity with a high level of risk of money laundering and terrorism financing (incl. but not limited to providers of services of alternative payment instruments, intermediaries of such payment instruments, internet casinos) or they operate without the required registration or authorisation;

e) is according to the Service Provider’s estimates related to the territory, area of activity, transaction or person subject to Sanctions or other national transaction limits (e.g. sanctions of the European Union or the USA);

f) has, according to a decision made by a competent authority or body (e.g. a precept by an agency, a court order) or judging by another event or fact, through its acts or omissions undermined the reputation of persons working in the same area of activity (incl. the Service Provider), or, according to a reasoned opinion of the Service Provider, does not behave in a responsible manner and does not follow the requirement of due diligence and the customs expected of companies working in this area of activity.

7.10.7. the User has intentionally or due to severe negligence failed to perform their obligation which arises from the User Agreement;

7.10.8. the User has intentionally or due to severe negligence caused damage or a threat of actual damage to the Service Provider by their actions or failure to act;

7.10.9. the User has failed to perform their obligation which arises from any agreement concluded with the Service Provider and this fact constitutes a good reason for the Service Provider to assume that the User will not perform their contractual obligations in the future;

7.10.10. an event which, according to the reasoned opinion of the Service Provider, may hinder due performance of the User’s obligations arising from the User Agreement or which has a considerable adverse effect on the User’s solvency, has occurred;

7.10.11. the User has made incorrect transactions (including fraudulent transactions) on the Platform.

7.11. The Service Provider shall notify the User about the cancellation of the User Agreement as soon as possible and within 14 (fourteen) days upon cancellation the User shall have the right to challenge the decision of the Service Provider by submitting an explanation or other documents (if any). The Service Provider shall examine the received explanation or documents and shall inform the User about its decision in writing.