Document 1: Rekashpay User Agreement (Phase 1 Edition)

1. DEFINITIONS AND INTERPRETATION

• In this Agreement, unless the context otherwise requires, the following capitalized terms shall have the meanings set forth below:
• "Agreement" means this Rekashpay User Agreement (Phase 1 Edition), including all referenced policies, schedules, and appendices, as amended from time to time.
• "App" means the mobile application operated by Rekashpay through which the Services are accessed, including all its features, functions, and content.
• "Applicable Law" means any law, statute, regulation, ordinance, rule, judgment, decree, order, or directive applicable to a Party, the Services, or any Transaction.
• "Card Issuer" or "Issuer" means the licensed financial institution partner that issues the Rekashpay Card.
• "Fiat Currency" or "Fiat" means government-issued currency that is designated as legal tender.
• "KYC/AML" means "Know Your Customer" and "Anti-Money Laundering" procedures and regulations.
• "Off-Ramp Services" means the service allowing the User to sell Supported Cryptocurrencies and receive Fiat Currency into a linked bank account, as described in Clause 3.2.
• "On-Ramp Services" means the service allowing the User to purchase Supported Cryptocurrencies using Fiat Currency, as described in Clause 3.1.
• "Party" means either Rekashpay or the User; "Parties" means both collectively.
• "PCI-DSS" means the Payment Card Industry Data Security Standard.
• "Platform" means the digital platform operated by Rekashpay, comprising the App and related systems, through which the Services are provided.
• "Rekashpay", "We", "Us", or "Our" means Rekashpay Ltd.
• "Rekashpay Balance" means the total balance of Fiat Currency and Supported Cryptocurrencies held in your Rekashpay Wallet.
• "Rekashpay Card" or "U-Card" means the prepaid or debit card (virtual or physical) issued by the Card Issuer, powered by international card schemes and managed through the Platform.
• "Rekashpay Wallet" means the hosted digital wallet provided by Rekashpay for storing Supported Cryptocurrencies and Fiat Currency balances in connection with the Services.
• "Services" means the services provided by Rekashpay under this Agreement, as detailed in Clause 3, including On-Ramp Services, Off-Ramp Services, and Rekashpay Card Services.
• "Slippage" means the difference between the expected price of a Supported Cryptocurrency at the time an On-Ramp or Off-Ramp transaction is initiated and the final executed price, due to market volatility.
• "Supported Cryptocurrencies" means the virtual assets or cryptocurrencies that Rekashpay supports for storage in the Rekashpay Wallet and for use in On-Ramp and Off-Ramp Services, as listed within the App.
• "Transaction" means any action initiated by the User on the Platform, including but not limited to purchasing or selling Supported Cryptocurrencies, loading or spending with the Rekashpay Card, or making a withdrawal.
• "User", "You", or "Your" means either: (a) an individual; or (b) an authorized person acting on behalf of a corporate entity, who accepts this Agreement and uses or accesses the Platform or Services. Depending on context, this term may refer to the individual user or the corporate entity they represent.
• "Business User" means a natural person who is duly authorized to act on behalf of a corporate entity (including but not limited to a company, partnership, or organization) in accepting this Agreement and registering for a Business Account. The actions of a Business User are legally binding on the represented corporate entity.
• "Authorized User(s)" means individual(s) designated by the Business User (administrator) who are permitted to use specific Services (e.g., make transactions with a Rekashpay Card) on behalf of the corporate entity, subject to permissions set within the Platform.
• "Business Account" means a Rekashpay account type created for a corporate entity, governed by this Agreement and any supplemental commercial terms.
• "Personal Account" means a Rekashpay account type created for an individual consumer.
• "Virtual Asset" or "Cryptocurrency" means a digital representation of value that can be digitally traded or transferred and can be used for payment or investment purposes.

2. ACCEPTANCE OF TERMS

This User Agreement ("Agreement") is a binding contract between Rekashpay Ltd. ("Rekashpay", "We", "Platform") and you ("User", "Cardholder"). By accessing our App or using our services, you agree to these terms.

NOTE: Rekashpay is a technology services provider. We are not a bank. The Rekashpay Card is issued by our partner financial institutions ("Issuer").

If You are accepting this Agreement on behalf of a corporate entity, You represent and warrant that:

• a) You are a duly authorized representative of such entity with full legal authority to bind it to this Agreement;
• b) The entity is duly organized, validly existing, and in good standing under the laws of its jurisdiction of formation;
• c) Acceptance of this Agreement and use of the Services does not violate any law, regulation, charter, or contractual obligation applicable to the entity.

3. CORE SERVICES (SCOPE OF BUSINESS)

We currently provide three specific services under this Agreement:

4. ACCOUNT & REGISTRATION

• 4.1. Eligibility: For a Personal Account you must be 18+ and resident in a supported jurisdiction. For a Business Account, the applicant must be a legally incorporated entity under the laws of its jurisdiction.
• 4.2. KYC/AML Compliance: To use On/Off-Ramp or Card services, All Users must complete applicable identity verification. For Personal Accounts, this is Level 1 Identity Verification. For Business Accounts, the Business User must submit, and the entity must provide, documentation which may include:
  • Certificate of Incorporation/Registration and proof of good standing;
  • Constitutional documents (e.g., Memorandum & Articles of Association);
  • Identification documents for Beneficial Owners (UBOs) and controlling persons;
  • Proof of authority for the Business User (e.g., Board Resolution, Power of Attorney).
• We reserve the right to request additional documentation based on risk assessment.
• 4.3. Business Account Management
  • 4.3.1. The Business User (administrator) has the sole responsibility and ability to add, remove, or modify Authorized Users and their specific permissions (e.g., transaction limits, access to services) via the Platform.
  • 4.3.2. The Business User and the corporate entity are jointly and severally liable for all actions, transactions, fees, and compliance with this Agreement performed by their Authorized Users.
  • 4.3.3. The Business User must ensure Authorized User information is accurate and updated promptly upon any change in status. Rekashpay is not liable for any loss arising from the Business User's failure to update such information.

5. FEES AND CHARGES

6. WALLET & CUSTODY

• 6.1. Custodial Nature: Rekashpay provides a hosted wallet. We store your private keys securely. You do not have direct access to private keys.
• 6.2. No Interest: Your wallet balance does not accrue interest. Rekashpay is not a savings account.
• 6.3. Supported Assets: Do not attempt to send unsupported tokens (e.g., NFTs or unsupported chains) to your Rekashpay address. Such assets may be permanently lost.

7. CARD USAGE RULES

• 7.1. Prohibited Transactions: You must not use the Rekashpay Card for:
  • Unlawful gambling or betting.
  • Purchase of illegal drugs or controlled substances.
  • Dating/Escort services (High-risk merchant categories).
  • Transactions designated as "Quasi-Cash" (e.g., buying traveler's checks).
• 7.2. Card Freezing: We may suspend or restrict your card immediately if we reasonably suspect fraudulent, unauthorized, or illegal activity if requested by the Card Issuer/Network.

8. DIGITAL WALLET INTEGRATION (Apple/Google Pay)

• 8.1. Authorization: By adding your Rekashpay Card to a third-party digital wallet, you authorize us to share card data with the wallet provider to facilitate tokenized payments.
• 8.2. Liability: Rekashpay is not responsible for the security of your mobile device or the third-party wallet provider's service availability.

9. DISCLAIMERS & RISK

• 9.1. Volatility: The purchasing power of your crypto balance can decrease rapidly. You bear the sole risk of exchange rate fluctuations.
• 9.2. Regulatory Risk: The legal status of crypto cards may change. We may suspend services in specific countries with short notice to comply with local laws.
• 9.3. Liability Limitation: To the fullest extent permitted by Applicable Law, our total liability arising out of or in connection with this Agreement shall be limited as follows:
  • (a) For Users holding a Personal Account, liability shall be limited to the amount of Fees you have paid to us in the 12 months preceding the event giving rise to liability.
  • (b) For corporate entities holding a Business Account, liability shall be limited to two times (2x) the total Fees paid by the entity to us in the 12 months preceding the event, provided that in no event shall such liability exceed [e.g., USD 50,000].
• Notwithstanding the above, nothing in this Agreement shall limit or exclude our liability for: (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; or (c) any liability that cannot be lawfully limited or excluded.

10. TERMINATION

10.1. You may close your Account at any time.

We may suspend your Account or restrict its functionality, or terminate this Agreement with immediate effect, if we reasonably believe that:

• You materially breach this Agreement and fail to cure such breach within 14 days after our written notice (where cure is possible)
• Your account is flagged for money laundering or fraud based on our reasonable assessment or regulatory requirement
• You abuse the "Chargeback" process as determined in good faith by us or the Card Network (e.g., falsely claiming a transaction was unauthorized).
• It is required by Applicable Law, a regulatory body, or our Card Issuer/network partners.

10.2. Where feasible and not involving immediate risk, we will provide you with notice and an opportunity to remedy a breach before termination.

11. Governing Law and Dispute Resolution

• 11.1. This Agreement shall be governed by and construed in accordance with the laws of Seychelles.
• 11.2. Any dispute arising out of or in connection with this Agreement shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (SIAC) in accordance with its rules. The seat of arbitration shall be Singapore. The language of the arbitration shall be English. The number of arbitrators shall be one.