Service Provision Rules of SRL INVEST-STRATEGY

1. Terms and Definitions

1.1. This is a service providing digital currency transaction services.

1.2. User — any individual who agrees to all the terms provided by the Service and adheres to this agreement. The User and the Service are collectively referred to as "Parties."

1.3. Application — information submitted by the User electronically using the Service's resources, indicating their intention to use the Service's services under the terms provided by the Service and specified in the application parameters.

1.4. Exchange — operations that involve the transfer of digital currency from one holder to another using monetary funds.

1.5. Exchange Rate — the value ratio of the two exchanged currencies.

1.6. Agreement — the contract between the Parties for digital currency transactions based on the terms and conditions of the Service’s provisions.

2. Subject of the Agreement and Its Effective Date

2.1. The subject of this agreement is the digital currency transaction services carried out at the request of the User, as well as other services described on the Service's website.

2.2. The agreement is considered accepted when the User submits an Application, which is an integral part of this agreement. Each User’s application constitutes a new Agreement under the new terms at the time of application submission.

2.3. This agreement becomes effective upon completion of the Application by the User and the assignment of a unique application number.

2.4. The date, time, and parameters of the Application terms are automatically recorded by the Service at the time of completion and assignment of a unique application number.

2.5. This agreement terminates upon the receipt of funds or digital currency by the User as specified in the parameters of the User’s Application, or upon cancellation of the application.

2.6. The Service reserves the right to unilaterally amend this Agreement without notifying the User, but with the mandatory publication of the current version of the agreement on this page.

3. Terms of Service Provision

3.1. Only Users who have fully read and agreed to the Service's rules and terms may use its services.

3.2. The Service automatically sets the exchange rate and publishes it on the Service's website.

3.3. The Service reserves the right to change the exchange rates unilaterally at any time, notifying Users by posting updated information on the Service's website.

3.4. Fixing of the exchange rate and order of rate change in the application:

• The rate is fixed for 10 minutes from the moment the exchange direction is selected; after this period, a new rate will automatically be offered.
• If the User has managed to create an application within 10 minutes, this rate is extended for another 15 minutes for payment. If the User does not complete the payment and change the application status to "paid" by pressing the “I paid” button, a new exchange rate will automatically be offered.
• The Service reserves the right to unilaterally change the exchange rate if more than 8 hours have passed since the transaction appeared in the digital currency network and if there are fewer than 2 confirmations of the transaction from the digital currency network.
• The Service reserves the right to unilaterally change the exchange rate if the application contains an error due to the User's fault, and the User has not provided the correct information to the Service’s email within 8 hours.
• The Service reserves the right to unilaterally change the exchange rate if the initial rate has changed by more than 1% before the application payment is completed and the application status is changed to "paid" by pressing the “I paid” button.

3.5. Management of the exchange process or obtaining information about the service progress is conducted via the User interface on the Service’s website.

3.6. The Service executes exchanges according to User applications in strict accordance with its privacy policy and anti-money laundering policy.

3.7. Any completed operation by the Service per the User's application cannot be canceled by the User after its completion — once the Service has sent funds or digital currency owed to the User under the previously accepted exchange terms.

3.8. If the User does not transfer funds or digital currency within one hour of application creation, the Agreement is considered terminated unilaterally by the Service, as it has not taken effect.

3.9. If the agreement is terminated, funds or digital currency received after the specified period shall be returned to the User’s account upon request, with all commission fees for the return deducted from the received funds at the User's expense. The Service is not responsible for delays in refunds if they are not caused by the Service.

3.10. If the amount of funds or digital currency received differs from the amount stated by the User, the Service may unilaterally terminate the agreement by rejecting the application and returning the received funds to the User's account, or by recalculating the amount at the fixed rate in the application. All commission fees for the return shall be deducted from the received funds at the User's expense. The Service is not responsible for delays in refunds if they are not caused by the Service.

3.11. If the Service has not transferred funds or digital currency to the User’s specified account within 72 hours of payment receipt, the User may request termination of the agreement and a full refund if there is no reason for the Service to block the funds or digital currency received under the User’s Application.

3.12. In the event of application cancellation, a refund will be made by the Service to the sender's account within 48 hours of the cancellation request. The Service is not responsible for delays in refunds if they are not caused by the Service.

3.13. If the exchange rate increases by more than 1%, all funds unclaimed for more than one day will be exchanged or returned at the rate fixed at the time of application creation.

3.14. The Service reserves the right to involve third-party contractors to fulfill its obligations.

3.15. The Service reserves the right to cancel the application and return the funds or digital currency deposited by the User, with commission fees reimbursed to the User, without explanation.

3.16. The Service reserves the right to refuse further service to the User without explanation.

3.17. The Service reserves the right to suspend exchanges for the purpose of sender verification. If verification fails, the application is canceled. All commission fees for the return will be deducted from the received funds at the User’s expense. The Service is not responsible for delays in refunds if they are not caused by the Service.

3.18. By using the Service, the User confirms they legally own and control the funds and digital currency they are using and guarantees they are not involved in:

• money laundering activities;
• income from illegal drug trafficking;
• income from criminal and/or terrorist activities;
• income from trade with countries banned by international organizations;
• income from any other illegal activities.

3.19. When the User sends digital currency, the Service will begin fulfilling its exchange obligations only after two confirmations from the digital currency network.

3.20. If the transfer of funds to the details provided by the client cannot be completed due to reasons beyond the service’s control, or if the client has made an error in the payment details, the service reserves the right to request the client to send the correct payment information, card verification, or alternative refund details to the service’s email. In the case of a refund, all commission fees and associated costs for the transfer of funds or digital currencies will be deducted from the amount received and covered by the User.

3.21. If funds cannot be sent to the account provided by the client due to reasons beyond the Service’s control, or if the client has provided incorrect details, the Service may request that the client send correct details to the Service’s email, submit card verification, or provide details for fund return. All commission fees for the return will be deducted from the received funds at the User’s expense.

For exchanges exceeding 2000 USD, verification may be required in certain cases—especially if the transaction is flagged as suspicious.

To complete the verification process, our support team may request the following:

• A copy of your passport or other valid ID;
• A confirmation transaction amounting to 40% of the total exchange value.

Once the verification and confirmation transaction are successfully completed, you will receive the full payment, including the verified amount.

4. Privacy Policy

4.1. To conduct transactions, the Service collects personal data from the User, which it is obligated to store in encrypted form, keep confidential, and not disclose to third parties, except in cases described in paragraphs 4.4 and 5.5 of this agreement.

4.2. All operations with Applications and the transfer of personal data from the User to the Service are carried out over an encrypted SSL channel with a 256-bit key length.

4.3. The Service reserves the right to independently collect additional data about the User if necessary, using any available means. All information collected is kept confidential and is not disclosed to third parties, except as described in paragraphs 4.4, 4.5, and 5.5 of this agreement.

4.4. The Service has the right to disclose the User’s personal data and details of transactions conducted by them at the official request of law enforcement agencies, courts, and on its own initiative to protect its rights.

4.5. The Service may disclose the User’s personal data and details of transactions conducted by them at the official request of payment systems and banks if necessary to fulfill financial obligations.

4.6. All collected data about the User and details of transactions conducted by them are stored in the Service’s database for five years.

5. Limitation of Liability

5.1. The User guarantees that they are not a citizen or tax resident of the United States, North Korea, Iran, or any country under international sanctions.

5.2. Only persons of legal age may use the Service.

5.3. The User agrees that the Service’s liability is limited to the funds received from the User to fulfill the subject of this agreement, that the Service provides no additional guarantees, and bears no additional liability to the User, just as the User bears no additional liability to the Service.

5.4. The Service will make every effort but does not guarantee that its services will be available 24/7. The Service is not liable for losses, lost profits, or other expenses incurred by the User due to the inability to access the site and Service.

5.5. The Service is not liable for losses, lost profits, or other expenses incurred by the User as a result of delays, errors, or failures in bank payments or electronic transfers.

5.6. The Service is not liable for losses, lost profits, or other expenses incurred by the User due to incorrect expectations of the exchange rate, transaction profitability, or other subjective factors.

5.7. If the User provides incorrect recipient details, the Service is not liable for any adverse consequences or losses resulting from this error.

5.8. The User agrees not to falsify communication streams related to the Service’s operations, interfere with its software or hardware, or influence its normal operation in any way, understanding that such actions are subject to strict legal prosecution.

5.9. Neither the User nor the Service shall be held responsible for delays or failure to fulfill obligations resulting from force majeure, including natural disasters, fire, flooding, terrorist acts, governmental changes, civil unrest, and failures in electronic payment systems, power supplies, communications networks, or internet service providers.

5.10. Electronic payment systems or financial institutions are solely responsible for funds entrusted to them by the User. The Service cannot be a party to any agreement between the Payment System or financial institution and the User.

5.11. The Service is not liable for the actions of other payment services or for losses caused by these payment services.

6. Claims and Dispute Resolution

6.1. Disputes and differences arising in the provision of services to the User by the Service shall be resolved through negotiations between the User and the Service administration based on the provisions of this agreement.

6.2. Any claims under this agreement should be sent by the User electronically to the Service email specified on the Service website.

7. Final Provisions

7.1. The Service has the right to send information to the User’s specified email about the exchange process status and other information concerning the exchange.

7.2. Information on the website, including graphics, text, program code, etc., is the property of the Service and is protected by copyright law.

7.3. The User confirms that they have read all the provisions of this Agreement and unconditionally accepts them; otherwise, the User cannot use the Service.

Cookie Usage Agreement

Our website uses cookies and similar technologies to ensure maximum user convenience by providing personalized information, remembering preferences when navigating the website and during subsequent visits, and helping to deliver the information users need. The information we obtain through cookies helps us to provide our services in the most suitable way for you.

This agreement pertains to the use of information obtained from users of the website through cookies. It also provides details on cookies, the use of cookies on the website, and how you can opt out of such files.

A cookie is a small text file placed by a website on a user’s computer, phone, or other device, containing information about their navigation on the website. Cookies store information about your preferences on the internet.

Cookies are used for various purposes, including:

• Analyzing information about user visits to pages to improve the website.
• Providing messages and content created by us and third parties, both on this website and on others, in line with the user’s interests.
• Assisting the user in obtaining the required information.
• Identifying the number of visitors and understanding how they use our site to enhance the site’s efficiency and better understand the interests of its audience.

Before the website installs cookies on your computer, a pop-up window will appear, asking you to consent to the installation of these cookies. By agreeing to our cookies, you allow us to provide you with the best possible experience and service through our website. If you choose to decline cookie placement, some features of the website may not work fully or as intended.

None of the cookies set by the website in any way compromise your privacy. In the cookies we use, we do not store personal or confidential information that identifies the user, such as address, password, debit or credit card details, etc.

If you wish to prevent the use of cookies on this website, you can disable cookie storage in your browser at any time and then delete the cookies stored in your browser that are associated with our website.

Please note that in this case, page display and website navigation guidance will be limited.

We are not responsible for the content, data collection, or processing methods of third-party websites, including websites linked to from our site. Please review the privacy policies of any resources you visit before providing your data.

Personal Data Processing Policy for Website Users

1. General Provisions

1.1. This document defines the website policy (hereinafter referred to as the Operator) regarding the processing of personal data of website users and sets out the system of fundamental principles applied to the processing of personal data.

1.2. The Personal Data Processing Policy for website users (hereinafter referred to as the Policy) has been developed to comply with the General Data Protection Regulation (GDPR) of the European Union, which covers personal data and the identification of users on the website. The Policy applies to all personal data processed by the Operator.

1.3. The Policy establishes the procedure for processing personal data of website users: actions for collecting, organizing, accumulating, storing, updating (amending, modifying), and destroying personal data.

1.4. The Policy establishes mandatory general requirements and rules for the Operator’s staff involved in website management regarding handling all types of information media containing personal data of website users.

1.5. Terms and Definitions

• Personal Data — any information related directly or indirectly to a specific or identifiable individual (personal data subject).
• Operator — a government body, municipal body, legal or natural person who independently or jointly with other persons organizes and/or carries out the processing of personal data, and who determines the purposes of processing, the scope of personal data to be processed, and actions (operations) carried out with the data.
• Personal Data Processing — any action (operation) or set of actions (operations) carried out with or without the use of automated tools for processing personal data, including collection, recording, organization, accumulation, storage, updating (modifying), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
• User — an internet user and, specifically, a user of the website.
• Automated Personal Data Processing — processing of personal data using computer technology.
• Provision of Personal Data — actions aimed at disclosing personal data to a specific person or group of people.
• Personal Data Blocking — temporary suspension of personal data processing (except where processing is necessary to clarify personal data).
• Personal Data Destruction — actions that make it impossible to restore personal data content in the personal data information system and/or destroy the physical media containing personal data.
• Personal Data Anonymization — actions that make it impossible to determine the data subject’s identity without additional information.

1.6. The Operator ensures the confidentiality and security of personal data during processing in accordance with legal requirements and does not disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by the General Regulation.

According to the list of personal data processed on the website, the personal data of website users is confidential information.

2. Main Rights and Obligations of the Operator and the Personal Data Subject

2.1. The Operator has the right to:

• Receive personal data from data subjects and third parties (non-data subjects) while fulfilling the obligations specified in Chapter 3 of the General Data Protection Regulation (GDPR);
• Independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of duties set by the Data Protection Regulation and regulatory acts adopted in accordance with it, unless otherwise stipulated by the Data Protection Regulation or other laws;
• In the event of withdrawal of consent for personal data processing by the data subject, the Operator may continue processing personal data without the data subject’s consent if grounds are specified in the Data Protection Regulation.

2.2. The Operator must:

• Organize personal data processing in accordance with the requirements of the Data Protection Regulation;
• Respond to requests and inquiries from data subjects and their legal representatives in compliance with the Data Protection Regulation.

2.3. The data subject has the right to:

• Receive information regarding the processing of their personal data, except as provided by federal law. The Operator provides the data subject with accessible information that does not contain data about other data subjects, unless there is a legal basis for disclosing such data. The list of information and the procedure for obtaining it are defined by the Data Protection Regulation;
• Require the Operator to update, block, or delete their personal data if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing.

3. Purposes of Personal Data Collection

3.1. Personal data processing is limited to achieving specific, pre-defined, and lawful purposes. Personal data processing incompatible with the purposes of data collection is prohibited.

3.2. Only personal data that meets the purposes of its processing is subject to processing.

3.3. Personal data of website users is processed solely to provide users with the ability to interact with the website.

3.4. Personal data on the website is any information relating to an identified or identifiable natural person (data subject).

4. Scope of Processed Personal Data

4.1. The content and volume of personal data processed on the website correspond to the declared processing purposes provided in Section 3 of this Policy. Processed personal data should not be excessive in relation to the declared purposes of their processing.

4.2. The Operator may process the following personal data of users:

• Source of website visit (sites) and information from search or advertising requests;
• Data about the user’s device (such as resolution, version, and other attributes characterizing the user’s device);
• User clicks, page views, field fills, banner and video views, and clicks;
• Data characterizing audience segments;
• Session parameters;
• Visit time data;
• User identifier stored in cookies;
• Last name;
• First name;
• Patronymic;
• Contact phone number;
• Email address.

4.3. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, or personal life, except as required by EU law.

4.4. The Operator does not process biometric personal data.

4.5. The Operator does not perform cross-border data transfers.

5. Personal Data Processing Procedures and Conditions

5.1. Personal data processing is carried out by the Operator in accordance with EU legislation.

5.2. Personal data processing is carried out with the consent of data subjects for the processing of their personal data, and without such consent in cases provided by EU legislation.

5.3. The Operator carries out both automated and non-automated personal data processing.

5.4. Operator employees whose job duties include personal data processing are authorized to process personal data.

5.5. Disclosure and provision of personal data to third parties and dissemination of personal data without the consent of the data subject is not allowed unless otherwise specified in the Data Protection Regulation.

5.6. The Operator takes the necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, dissemination, and other unauthorized actions, including:

• Determining personal data security threats during processing;
• Adopting internal regulatory acts and other documents regulating personal data processing and protection relationships;
• Creating the necessary conditions for working with personal data;
• Organizing records of documents containing personal data;
• Managing information systems where personal data is processed;
• Storing personal data under conditions that ensure its security and prevent unauthorized access.

5.7. The Operator stores personal data in a form that allows the identification of the data subject no longer than required for the purposes of processing, unless a retention period is set by the Data Protection Regulation or contract.

5.8. When collecting personal data, including via the Internet, the Operator ensures recording, organization, accumulation, storage, updating (modification), and retrieval of personal data using databases located in the EU, except as specified in the Data Protection Regulation.

6. Personal Data Storage Procedures and Periods

6.1. The Operator only stores User personal data on the Website.

6.2. The storage period for users' personal data begins upon receiving consent for data processing through acceptance of an offer, which does not require a bilateral signature and is valid in electronic form, and remains in effect until the user requests deletion of their personal data from the site.

6.3. The Operator does not process User personal data on paper media.

7. Deletion and Destruction of Personal Data

7.1. Personal data shall be destroyed upon achieving the purposes of processing or if the data subject withdraws consent for processing, unless:

• Otherwise provided by a contract to which the data subject is a party, beneficiary, or guarantor;
• The Operator is not authorized to process the data without the data subject's consent based on grounds provided by the Data Protection Regulation or other laws;
• Otherwise provided by another agreement between the Operator and the data subject.

7.2. The data subject has the right to request deletion of their personal data in writing if it is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated processing purpose.

7.3. If deletion is not possible, the Operator blocks such personal data.

7.4. Personal data destruction is performed by erasing information using certified software with guaranteed deletion capabilities.

8. Final Provisions

8.1. Compliance with this Policy is monitored by the authorized person responsible for organizing personal data processing with the Operator.

8.2. Liability for violating EU personal data processing and protection legislation and regulations is defined by EU law.

8.3. In case of amendments to EU law or personal data protection regulations, this Policy remains valid to the extent it does not conflict with current legislation until it is updated accordingly.

8.4. The Operator unilaterally establishes, modifies, and cancels the Policy without prior notice to the User. Once a new Policy version is posted on the site, the previous version is considered void. If there are significant changes to the Policy terms, the Operator notifies users by posting a corresponding message on the website.

8.5. In accordance with the Data Protection Regulation, this document is considered an offer. The act of submitting an application on the website is considered unconditional acceptance of the terms of this Policy and consent to the processing of personal data.

Consent for personal data processing obtained by accepting this offer does not require a bilateral signature and is valid in electronic form.

8.6. If the User does not agree to the terms of this Policy, they must immediately delete their profile from the website or notify the Operator of their disagreement; otherwise, continued use of the website by the User indicates acceptance of this Policy's terms.

Anti-Money Laundering and Counter-Illegal Operations Policy (AML and KYC)

1. In accordance with international law, the Service adheres to a set of rules and implements procedures aimed at preventing the use of the Service for money laundering or other illegal operations.

2. To prevent illegal activities, the Service imposes certain requirements on all Applications created by the User:

• Transfers in favor of third parties are strictly prohibited.
• All contact details and other personal information provided by the User in the Application must be accurate and fully up-to-date.
• It is strictly prohibited for the User to create Applications using anonymous proxy servers or any other anonymous internet connections.

3. The Service reserves the right to request a photo or video with a user identity document as part of the KYC (Know Your Customer) policy. Client identification information will be collected, stored, transferred, and protected strictly in accordance with the company's Personal Data Processing Policy.

4. The User will be refused the exchange if the Service is unsatisfied with the provided information or doubts that the User is who they claim to be.

5. The Service reserves the right to suspend all current Applications of the User until the User provides identity documents and other information necessary to verify the transaction in the following cases:

• If any of the requirements set forth in Section 2 of this Agreement are violated.
• If the User’s Application is halted by the anti-illegal operations system.
• If the Service has reasonable suspicion that the User intends to use the Service for illegal activities.
• If high-risk transactions are detected involving the User’s details.

The User agrees to provide the requested document within 7 business days from the request date or to request Application cancellation.

6. To identify high-risk transactions and addresses, the Service uses an internal verification and analysis system. The Service reserves the right not to disclose information on the methods or results of User transaction checks.

7. In the event that high-risk transactions are detected in connection with the User’s details (if the wallet risk level exceeds 15%), the Service will initiate an AML (Anti-Money Laundering) verification procedure. Based on the results of this verification, the Service reserves the right to cancel the order without refunding any funds or digital assets provided by the User.

As an alternative to cancellation, the Service may offer the User the option to change their wallet address. If the wallet is changed, the Service will request a confirmation transaction from the new wallet in the amount of one-third (1/3) of the total exchange volume to verify ownership of the new address. Only after successful completion of this procedure will the order be processed and the funds released to the updated wallet.

8. If the User refuses to provide requested documents, the Service reserves the right to deny further service to the User.

9. The Service reserves the right to refuse further service to the User and to transfer all available User data, as well as all available information on the User’s transactions, to law enforcement agencies in cases of:

• Detection of transactions intended for money laundering, financing terrorist organizations, any form of fraud, or transactions aimed at any other illegal and unlawful activity.
• Reasonable suspicion that the User-provided identification document is fake or invalid.
• Receipt of information from authorized bodies about the illegitimacy of the User’s possession of funds or digital currency, or other information that renders the provision of services by the Service impossible.
• Detection of any actions or attempts by the User to negatively affect the Service’s hardware and software system.
• Detection of any actions or attempts by the User to steal databases or other material and intangible property of the Service.
• Detection of any actions or attempts by the User that could cause any physical, material, or intangible harm to the Service.

10. If funds are received from a card different from the one verified, the Service will suspend the exchange. Funds from this Application will be returned to the sender within 24 hours of the request, provided that the card from which the funds were received has been verified. Any fees associated with the return of funds or digital currency will be deducted from the returned amount at the User’s expense.

11. Some exchange directions may be unavailable to Users using IP addresses from countries under international sanctions.

12. The Service reserves the right to suspend all current Applications of the User until the User provides copies of documents or other information confirming payment for the Application.