EEA Terms of Service for Individuals

These Terms of Service (the "Terms") constitute a legally binding agreement between you, acting in your personal capacity and not on behalf of a business or other legal entity unless expressly approved by Moneychurros S.L. ("you" or "User"), and MONEYCHURROS S.L., a limited liability company incorporated under the laws of Spain, with C.I.F. B55377238 and registered office at Calle Espronceda 27, Entreplanta 1, Oficina 1, 28003 Madrid, Spain ("Moneychurros", the "Company", "we", "us" or "our"), concerning your access to and use of the Platform and the technical services made available by Moneychurros through the website, user interface, APIs, integrated digital interfaces and related infrastructure operated under the Mercuryo brand.

1. BACKGROUND

1.1. To govern the provision of services, mutual obligations, and liability of the parties, MONEYCHURROS S.L. has established these Terms of Service (the "Terms") for private individuals.

1.2. Moneychurros S.L. is a limited liability company incorporated and existing under the laws of Spain, with C.I.F. B55377238 and registered office at Calle Espronceda 27, Entreplanta 1, Oficina 1, 28003 Madrid, Spain (the "Company" or "Moneychurros"). Moneychurros is part of the Mercuryo group and uses the Mercuryo trade name in connection with its business activities. Unless the context requires otherwise, references in these Terms to "Mercuryo" mean the Company acting through the Mercuryo brand.

1.3. As of 1 July 2026, and unless expressly stated otherwise for a particular service or jurisdiction, Moneychurros does not hold a MiCA authorisation as a crypto-asset service provider ("CASP") and, for users in the European Economic Area ("EEA"), acts primarily as a platform, interface and technical services provider in connection with services made available through the Platform. Prior to 1 July 2026, certain services may have been provided by Moneychurros under its Spanish VASP registration to the extent permitted by applicable law.

1.4. The Platform enables users to access and submit information and technical requests in connection with certain crypto-asset related services, including fiat-to-crypto transactions, crypto-to-fiat transactions, crypto-to-crypto exchanges, and other related technical functionalities (together, the "Services"). The legal entity responsible for providing a particular Service to a user may differ depending on the user's jurisdiction, the service flow, the product configuration, and applicable law. For the avoidance of doubt, where a Service constitutes a Regulated Service in the EEA, the relevant regulated service is provided by the Third-Party Provider identified to the user in the relevant transaction flow and not by Moneychurros unless expressly stated otherwise.

For users located in the EEA, any regulated crypto-asset service requiring authorisation under MiCA is provided by the third-party CASP or other regulated provider identified to the user before the relevant transaction (the "Third-Party Provider"). In a Third-Party-Provider EEA model, the relevant Third-Party Provider alone performs and controls the regulated crypto-asset service and the regulated parts of the transaction flow through its own systems, accounts, vendors, policies and compliance framework, and acts as the legal entity responsible for the relevant regulated transaction. Moneychurros acts solely as a provider of platform, interface and related technical services in that model and does not, merely by operating the Platform, receive, accept, execute or transmit orders for crypto-assets on behalf of clients as a regulated service.

1.5. For users outside the EEA, or where otherwise expressly stated and legally permitted, Moneychurros may itself provide certain Services. The specific service provider for each transaction will be disclosed to the user in the interface, in the transaction flow, or in supplemental terms. For EEA users, the relevant Third-Party Provider shall be identified to the user before the user confirms the relevant regulated transaction, including in the relevant interface, checkout flow, disclosure screen, confirmation screen or supplemental terms, as applicable.

1.6. For convenience, these Terms are divided into sections. Section titles are for reference only and do not affect interpretation.

1.7. The relationship between the parties is governed by these Terms together with any applicable supplements, service-specific disclosures, pricing information, privacy notices, and applicable laws and regulations.

1.8. Before using the Services, you should carefully read these Terms and assess the risks involved in crypto-asset transactions.

1.9. As part of accessing or using the Services, you may be required to review and accept separate terms, disclosures, privacy notices, or consents of Third-Party Providers, payment service providers, acquirers, settlement agents, identity verification providers, execution venues, blockchain infrastructure providers, or other third parties involved in the relevant service flow. Where the regulated service is provided by a Third-Party Provider, you acknowledge that such provider's terms and privacy notice may apply directly between you and that provider. The user interface may also identify the relevant Third-Party Provider as "Provided by [CASP]" or by substantially similar wording and may display the legal entity processing the relevant transaction. Where such identification is made, you acknowledge and agree that the identified Third-Party Provider, and not Moneychurros, is the provider and contractual counterparty of the relevant regulated service, except to the extent mandatory law provides otherwise.

1.10. Moneychurros is not responsible for the content, operation or enforcement of legal terms imposed directly by a Third-Party Provider or other third party, except to the extent such responsibility cannot be excluded under applicable law. Without limitation to the foregoing, where a Third-Party Provider is identified as the provider of a regulated crypto-asset service, Moneychurros does not assume responsibility for that provider's regulated execution, pricing, customer acceptance decisions, compliance determinations, wallet operations, custody functions, crypto delivery, or other regulated performance obligations, except to the extent such responsibility cannot lawfully be excluded.

1.11. Not all transactions are executed directly between Moneychurros and the user. Where a Third-Party Provider is identified as the regulated service provider or contractual counterparty, the relevant regulated transaction is executed by or with that provider, and Moneychurros acts solely in its role as provider of the Platform, interface, integrations, support functions and related technical services, unless expressly stated otherwise.

1.12. Moneychurros may cooperate with one or more Third-Party Providers and other entities within the payments and crypto-asset ecosystem, including payment service providers, acquirers, settlement agents, identity verification vendors, fraud prevention vendors, execution venues, liquidity providers and blockchain infrastructure providers, in order to make the Services available.

1.13. Services are provided through the Website and through integrated digital interfaces embedded in third-party environments that are controlled or made available by Moneychurros.

1.14. These Terms apply only to natural persons acting for personal purposes and not on behalf of a business or other legal entity. Legal entities, professional clients and institutional investors are not eligible to use the Services under these Terms unless the Company expressly agrees otherwise in a separate written contract.

1.15. For EEA users, Moneychurros's role after 1 July 2026 is limited to the platform/interface and technical provider model described above unless otherwise disclosed. Nothing in these Terms should be interpreted as a representation that Moneychurros itself is the MiCA-regulated CASP for EEA-facing regulated crypto-asset services after that date. Moneychurros shall not, and nothing in these Terms shall be construed to, hold Moneychurros out as providing MiCA-regulated crypto-asset services in the EEA where such services are provided by a Third-Party Provider.

2. DEFINITIONS

2.1. For the purposes of these Terms, the following terms have the meanings set out below.

"CASP" means a crypto-asset service provider within the meaning of MiCA, being a person duly authorised to provide one or more crypto-asset services under applicable law.

"Compliance Vendors" means third-party providers used in connection with KYC, KYT, Travel Rule, fraud prevention, wallet screening, blockchain analytics, or related compliance functions, including SumSub or any equivalent provider.

"Integrated Digital Interface" or "IDI" means a widget, API, iframe, hosted page, partner integration or similar interface through which Services are made available or initiated.

"Order" means a request, instruction or application submitted by the user through the Platform or an IDI for presentation to the relevant service flow in connection with the possible initiation or provision of a Service. Where a Regulated Service is provided by a Third-Party Provider, any regulated order or transaction instruction shall be deemed to be received, accepted, rejected, processed and executed only by that Third-Party Provider, and not by Moneychurros..

"Platform" means the website, user interface, software environment, APIs, technical integrations, workflows and related systems operated or made available by Moneychurros under the Mercuryo brand.

"Regulated Service" means any service for which authorisation, registration or other regulatory status is required under MiCA or other applicable law.

"Third-Party Provider" means any third party identified to the user as the provider, counterparty, processor, executor, arranger or regulated provider of a relevant Service or transaction flow, including any CASP, payment service provider, electronic money institution, payment institution, acquirer, settlement agent, identity verification provider or other third party participating in the Service. For the avoidance of doubt, a Third-Party Provider may be the sole provider and contractual counterparty of a Regulated Service even where Moneychurros provides the user-facing Platform or related technical services.

"Third-Party Provider Terms" means the terms of service, mandatory risk disclosures and other contractual terms, if any, that are presented to the user by the relevant Third-Party Provider in the relevant transaction flow and accepted by the user at or before the time the relevant Service is initiated. Third-Party Provider Terms do not include these Terms and do not amend these Terms except to the limited extent expressly stated in Section 6. Privacy notices and data protection disclosures of a Third-Party Provider are not incorporated into these Terms as contractual terms solely by being presented together with them, but may apply separately in accordance with applicable law and the relevant privacy notice.

"Travel Rule Information" means originator, beneficiary and other information required to be collected, processed or transmitted in connection with a transaction under applicable Travel Rule requirements.

3. ELIGIBILITY AND REGIONAL APPLICATION

3.1. You may use the Services only if you are at least 18 years old, have full legal capacity, and are not prohibited by applicable law from using the Services.

3.2. You may use the Services only for your own personal purposes and not on behalf of another person, business or other organisation unless expressly approved by Moneychurros in writing.

3.3. Moneychurros may restrict or refuse access to the Services based on jurisdiction, sanctions, AML/CTF risk, tax risk, fraud risk, product availability, or other legal or operational reasons. Without limitation to the foregoing, you may not access or use the Platform or any Service if you are located in, resident in, ordinarily resident in, established in, or a national or citizen of any jurisdiction that Moneychurros, a Third-Party Provider, an acquirer, a payment service provider, a settlement agent, or any other participant in the relevant service flow designates as restricted or prohibited, or if your access or use would cause any person to breach applicable sanctions, AML/CTF laws, or other applicable law.

3.4. You shall not use the Platform or any Service in connection with any unlawful, prohibited or restricted activity, including unlawful gambling or betting, fraud, deception, Ponzi or pyramid schemes, counterfeit goods, illegal substances, sanctioned transactions, restricted goods, weapons, or any activity prohibited by applicable law or by any Third-Party Provider, acquirer, payment service provider, settlement agent, card scheme, or other participant in the relevant service flow.

3.5. The availability of Services may differ by region. For EEA users after 1 July 2026, regulated crypto-asset services available through the Platform are provided by the relevant Third-Party Provider and not by Moneychurros unless expressly stated otherwise. For non-EEA users, the identity of the relevant provider may differ and will be disclosed in the applicable flow or supplemental terms. No statement on the Website, in the Platform, or in any integrated digital interface shall be construed as indicating that Moneychurros is itself the regulated provider of an EEA-facing Regulated Service where the relevant Third-Party Provider has been identified to the user for that service.

4. ACCOUNT REGISTRATION, ONBOARDING AND VERIFICATION

4.1. To use the Services, you may be required to register a profile or otherwise submit information through the Platform.

4.2. Depending on the relevant service flow, onboarding, identity verification, KYC, KYT, Travel Rule, AML/CTF checks, fraud screening, wallet screening, source-of-funds checks and related compliance controls may be conducted by Moneychurros, by a Third-Party Provider, or by both, each within their respective role in the service model. For EEA regulated crypto-asset services after 1 July 2026, the Third-Party Provider remains responsible for those regulated controls that it is required to perform in its capacity as the MiCA-regulated service provider. Moneychurros may support such processes by collecting, transmitting, displaying or technically processing relevant information through the Platform, but shall not thereby be deemed to assume responsibility for regulated compliance functions allocated by law or by the service model to the relevant Third-Party Provider.

4.3. In a Third-Party-Provider EEA flow, customer KYC may be performed by the Third-Party Provider in its own onboarding environment and/or its own account with the relevant identity verification vendor, and the Third-Party Provider may determine whether a particular user is accepted for the regulated service. KYT rules and ongoing transaction monitoring for the regulated service may be managed by the Third-Party Provider. Where the Travel Rule applies, the relevant Travel Rule process may take place within the Third-Party Provider's compliance environment, although Moneychurros may collect certain Travel Rule Information from the user through the interface and transmit that information to the Third-Party Provider or its Compliance Vendors for the purposes of the regulated transaction flow. Any such collection or transmission by Moneychurros is performed solely as part of the Platform and technical service model and does not make Moneychurros the regulated provider of the relevant crypto-asset service or of any regulated payment service.

4.4. Moneychurros may collect onboarding or transaction-related information from you directly or through service providers and may transmit such information to a Third-Party Provider, including through shared or linked Compliance Vendors, where necessary for the relevant service flow, subject to applicable law and the relevant privacy notices. Where a Third-Party Provider uses its own onboarding account, wallet infrastructure, exchange accounts or other vendor accounts, Moneychurros does not control the provider's decisions within those environments. Where a Third-Party Provider is the provider of a Regulated Service, that provider remains solely responsible for customer acceptance decisions, compliance determinations, execution decisions and regulated wallet or custody operations within those environments.

4.5. You must provide accurate, complete and up-to-date information and must promptly notify Moneychurros of changes to previously submitted information where the Platform permits or requires such updates.

4.6. Moneychurros may refuse registration, suspend access, require additional documents, or decline to process an Order where information is incomplete, inconsistent, unverifiable, out of date, or where required by law or risk policy.

4.7. Nothing in these Terms creates or shall be construed as creating any agency, fiduciary, trustee, custody, safeguarding, deposit-taking, payment-institution, electronic-money-institution or similar relationship between Moneychurros and the user in respect of any funds or crypto-assets, except to the extent expressly stated otherwise in supplemental terms and permitted by applicable law.

5. DATA SHARING AND PRIVACY

5.1. Your personal data will be processed in accordance with the applicable privacy notice(s) presented to you when you use the Services.

5.2. Where a Service involves a Third-Party Provider, you may be required to accept both Moneychurros's Privacy Notice and the Third-Party Provider's privacy notice before the transaction proceeds. The applicable notices will explain which entity acts as controller, the categories of personal data processed, the lawful bases for processing, the purposes of processing, and the recipients of the data.

5.3. Depending on the service flow, Moneychurros and the relevant Third-Party Provider may each act as independent controllers of personal data. Moneychurros may process personal data for its own legitimate and independent purposes, including operation of the Platform, transaction administration, fraud prevention, customer support, account management, collection and transmission of Travel Rule Information, security, continuity of service, compliance monitoring, and future service development, as further described in the applicable Privacy Notice.

5.4. Where necessary for a Service, Moneychurros may share personal data, including identity verification, onboarding and transaction-related data, with a Third-Party Provider or receive such data from a Third-Party Provider, including through shared or linked Compliance Vendors such as SumSub or similar systems, subject to applicable law and contractual data-sharing arrangements. Such sharing may include data required for customer onboarding, fraud prevention, transaction administration, customer support, service continuity, Travel Rule compliance, or related compliance and operational purposes described in the applicable privacy notice(s).

5.5. The parties do not rely on consent as the primary lawful basis for mandatory identity verification required for regulated crypto-asset services where another lawful basis applies under Article 6 GDPR, as described in the applicable privacy notice(s).

6. THIRD-PARTY PROVIDER TERMS AND ORDER OF PRECEDENCE

6.1. Where a Third-Party Provider is identified to you as the provider or counterparty of a Regulated Service, the Third-Party Provider Terms presented to you in the relevant transaction flow govern the Regulated Service and your direct relationship with that Third-Party Provider in respect of that Regulated Service. To the maximum extent permitted by applicable law, the identified Third-Party Provider shall be treated as the sole provider and principal obligor in respect of that Regulated Service.

6.2. These Terms continue to govern your relationship with Moneychurros in respect of the Platform, interface, transaction orchestration, integrations, support functions and related technical services that Moneychurros provides. These Terms do not make Moneychurros the provider of a Regulated Service merely because the Regulated Service is displayed, initiated, supported or technically enabled through the Platform.

6.3. Third-Party Provider Terms are incorporated into the overall contractual framework only for the limited purpose of governing the Regulated Service provided by the relevant Third-Party Provider and only to the extent such terms are presented to and accepted by you at or before the time of the relevant transaction. Third-Party Provider Terms do not, by virtue of such incorporation, amend, replace or supersede these Terms except with respect to the specific Regulated Service to which they relate.

6.4. If there is any conflict between these Terms and the Third-Party Provider Terms, the Third-Party Provider Terms prevail only with respect to the Regulated Service provided by the relevant Third-Party Provider, and these Terms prevail with respect to Moneychurros's own services, including the Platform and technical services.

6.5. For the avoidance of doubt, a hyperlink, reference or mention of a Third-Party Provider on the Website or in the Platform does not by itself incorporate all current or future terms, notices or policies of that provider into these Terms. Only the version of the Third-Party Provider Terms presented to and accepted by you in connection with the relevant transaction shall apply to that transaction, unless applicable law requires otherwise.

7. SERVICE MODEL AND THIRD-PARTY PROVIDERS

7.1. Moneychurros operates the Platform and provides the user interface, technical infrastructure, transaction orchestration, system integrations, support functions and related technical services associated with the Services. Except where expressly stated otherwise, Moneychurros does not thereby assume any obligation to provide a regulated crypto-asset service, regulated payment service, electronic money service, or custody service.

7.2. For EEA regulated crypto-asset services after 1 July 2026, the relevant Third-Party Provider is responsible for providing the regulated crypto-asset service to the user and for the regulated activities allocated to it under applicable law and the service model, including, where applicable, customer acceptance decisions, KYC, KYT, Travel Rule compliance, AML/CTF controls, anti-fraud controls, transaction execution, liquidity sourcing, exchange-side purchase or sale activity, crypto-wallet management and crypto delivery. The relevant Third-Party Provider shall also remain solely responsible for any best-execution obligations, client-order handling obligations, safeguarding obligations applicable to it, and other regulatory obligations arising in connection with the regulated crypto-asset service.

7.3. In a Third-Party-Provider EEA flow, the Third-Party Provider may perform KYC in its own SumSub account or equivalent onboarding environment, carry out exchange-side purchase or sale activity through its own exchange account, and send crypto-assets to the user through its own wallet or custody infrastructure. Moneychurros may collect user inputs through the interface, orchestrate system interactions, and connect payment, compliance, exchange and delivery components, but does not thereby assume control over the regulated parts of the flow. For the avoidance of doubt, the mere collection of user inputs or technical orchestration of system interactions by Moneychurros shall not be construed as Moneychurros independently receiving, accepting or transmitting client orders for crypto-assets on a professional basis.

7.4. Moneychurros does not, solely by operating the Platform, assume responsibility for regulated functions that are allocated to the relevant Third-Party Provider. Moneychurros shall not be deemed the merchant of record, payee, settlement beneficiary, acquirer, payment service provider, or settlement intermediary vis-à-vis the user solely because the relevant transaction is displayed, initiated or technically supported through the Platform, except where expressly disclosed and required by the applicable contractual structure or by mandatory law.

7.5. The identity of the relevant Third-Party Provider may be displayed in the interface, in the transaction flow, in a payment screen, in a disclosure, in a transaction confirmation, or in supplemental terms, including by identifying that the regulated service is "Provided by [CASP]" and by showing the legal entity processing the transaction. Where such identification is displayed, it shall prevail for the purpose of identifying the provider of the relevant Regulated Service.

8. ORDERS, EXECUTION AND SETTLEMENT

8.1. By submitting an Order, you request possible processing of the relevant Service in accordance with the terms presented to you in the relevant flow. Where the relevant Service is a Regulated Service provided by a Third-Party Provider, your submission of information through the Platform constitutes a request for the relevant Third-Party Provider to consider and, if applicable, process the transaction in accordance with its own terms, policies and controls. Moneychurros does not, by receiving information through the Platform, undertake to receive, accept, transmit or execute any regulated order for crypto-assets on behalf of clients.

8.2. Moneychurros will use reasonable efforts to operate the Platform in a manner that enables fair, orderly and technically reliable processing of Orders. However, the execution, acceptance, pricing, refusal, settlement or completion of a transaction may depend on the relevant Third-Party Provider, payment chain participants, blockchain conditions, liquidity availability, fraud controls, sanctions screening, technical outages, network congestion, market conditions, and other factors outside Moneychurros's direct control. Moneychurros does not warrant that any Order will be accepted, executed, settled or completed.

8.3. Where the relevant regulated service is provided by a Third-Party Provider, that provider may act as the contractual counterparty for the transaction, determine whether to accept or reject a transaction, and apply its own execution, compliance and risk policies.

8.4. Certain fiat settlement, acquiring, payment processing and related payment-chain functions may be performed through acquirers, payment service providers, electronic money institutions, settlement agents, affiliated entities or other third parties participating in the relevant transaction chain. The use of such participants and the existence of one or more settlement steps do not by themselves make Moneychurros the provider of the relevant regulated crypto-asset service. Unless expressly disclosed to the user and permitted by applicable law, Moneychurros does not itself receive, hold, safeguard, process or transfer user funds for the purpose of providing a regulated payment service, electronic money service or regulated crypto-asset service.

8.5. Where the relevant Third-Party Provider uses its own exchange account, wallet infrastructure, compliance vendors or other third-party accounts to execute or complete the regulated flow, the timing, acceptance, routing and completion of the transaction may depend on those environments and on the Third-Party Provider's rules, controls and operational decisions. Accordingly, the relevant Third-Party Provider may refuse, delay, reverse, cancel, freeze, investigate or condition a transaction in accordance with its own legal and regulatory obligations and risk controls. Without limitation to the foregoing, crypto delivery, fiat settlement, compliance clearance and final transaction completion may occur at different times, and a transaction may be delayed, suspended, reversed, unwound where legally possible, or not completed where required by risk controls, payment-chain actions, chargebacks, fraud concerns, compliance controls or technical failure.

8.6. The availability of any Service may depend on the continued participation, authorisation, onboarding acceptance, operational readiness and legal eligibility of one or more Third-Party Providers and payment-chain participants. Moneychurros may modify, suspend or discontinue access to a particular Service or service flow if a relevant Third-Party Provider or payment-chain participant ceases to support that flow, loses required authorisation, imposes additional restrictions, or if Moneychurros reasonably considers such action necessary to maintain legal or operational compliance.

9. FEES, PRICING AND DISCLOSURES

9.1. All applicable fees, exchange rates, charges, spreads and transaction details will be disclosed to you before you confirm the relevant transaction, to the extent required by applicable law and technically feasible in the relevant flow.

9.2. Where a Third-Party Provider is involved, pricing or fees may include amounts charged by that provider or other third parties involved in the transaction chain.

10. RISK DISCLOSURES

10.1. Crypto-asset transactions are inherently risky and may result in loss, delay, rejection, or adverse pricing outcomes due to market volatility, technical failures, blockchain network conditions, sanctions controls, fraud prevention measures, compliance interventions, or Third-Party Provider decisions. They may also be affected by payment-chain delays, chargebacks, reversals, reserve requirements, transaction investigations, and differences in timing between crypto delivery and fiat settlement.

10.2. Card-funded and other fiat-linked transactions may be subject to rejection, delay, reversal, recall, reserve withholding, investigation or chargeback by acquirers, card schemes, payment service providers, settlement agents or other participants in the payment chain, including after a related crypto-asset transfer has been initiated or completed. In certain service flows, crypto-assets may be delivered before the corresponding fiat leg has been finally settled. You acknowledge and accept that this timing mismatch may create additional risk, including delayed completion, refusal of future transactions, suspension of access, investigation, recovery action, debit, set-off or other protective measures to the extent permitted by applicable law and the applicable contractual framework.

10.3. Unless expressly stated otherwise, Moneychurros does not provide custody or wallet-hosting services, does not safeguard your private keys, and cannot recover access to your external wallet.

10.4. Where permitted by applicable law and the applicable contractual structure, Moneychurros or a relevant Third-Party Provider may suspend processing, delay completion, impose temporary restrictions, request additional information, or decline future use of the Platform or Services where reasonably necessary to manage chargeback exposure, fraud exposure, sanctions risk, AML/CTF risk, or other legal, regulatory or operational risk arising in connection with a transaction.

10.5. Where a Third-Party Provider performs the regulated transaction flow through its own exchange accounts, wallets, compliance systems or vendor environments, Moneychurros is not responsible for the provider's independent onboarding decisions, monitoring rules, execution decisions, wallet operations, or delivery decisions, except to the extent liability cannot be excluded under applicable law. This includes any decision by the relevant Third-Party Provider concerning customer acceptance, execution timing, liquidity sourcing, crypto delivery, reversal handling, Travel Rule processing, or compliance escalation.

10.6. You are solely responsible for ensuring that any wallet address, payment instrument, or account details you provide are accurate and under your lawful control, and for maintaining the security of your own devices, credentials and wallets.

11. LIABILITY ALLOCATION

11.1. Moneychurros will not be liable for losses to the extent they result from: (i) your breach of these Terms or applicable law; (ii) failures, acts or omissions of Third-Party Providers or other third parties outside Moneychurros's reasonable control; (iii) blockchain network failures, congestion or irreversible transfers; (iv) delays or refusals required by law, sanctions controls, AML/CTF controls or fraud prevention measures; or (v) your loss of access to an external wallet or private keys. Nothing in these Terms excludes or limits liability that cannot be excluded under applicable law. Without limitation to the foregoing, and to the extent permitted by applicable law, Moneychurros shall not be liable for any loss arising from payment-chain chargebacks, settlement reversals, reserve withholdings, delayed fiat settlement, refusal or reversal of a transaction by an acquirer, payment service provider or settlement participant, or any timing mismatch between crypto delivery and fiat settlement, except to the extent such loss results directly from Moneychurros's breach of these Terms in relation to its own platform and technical services.

11.2. Where the regulated transaction is provided by a Third-Party Provider, Moneychurros is not responsible for the regulated performance obligations of that provider, except to the extent Moneychurros has separately assumed such responsibility under applicable law or express written agreement. For the avoidance of doubt, the regulated performance obligations of the Third-Party Provider may include execution, pricing, best execution, customer acceptance, AML/CTF decisions, Travel Rule compliance, custody or wallet operations, crypto delivery, and the handling of transaction disputes or regulated complaints relating to the regulated service.

12. SUSPENSION, RESTRICTION AND TERMINATION

12.1. Moneychurros may suspend, restrict, delay or terminate access to the Platform or Services where reasonably necessary for legal, regulatory, AML/CTF, sanctions, fraud, security, operational or reputational reasons, or where required by a Third-Party Provider in connection with the relevant service flow. Such action may also be taken where reasonably necessary to address payment-chain risk, chargeback exposure, settlement uncertainty, prohibited-use concerns, restricted-jurisdiction concerns, or requests or requirements of acquirers, payment service providers, settlement agents, card schemes or competent authorities.

12.2. Where legally permitted, Moneychurros will notify the user of such action. No prior notice is required where notice would be unlawful, would compromise security or fraud prevention measures, or is not reasonably practicable.

12.3. You may stop using the Services at any time, subject to completion of pending transactions and satisfaction of outstanding obligations.

13. COMPLAINTS AND COMMUNICATIONS

13.1. Moneychurros remains responsible for complaints relating to the Platform, technical service, interface and support functions that it provides, while complaints relating to the regulated crypto-asset service provided by a Third-Party Provider should also be directed to that provider in accordance with its own complaints procedure, without prejudice to any obligation of Moneychurros to assist with routing or coordination where appropriate. Complaints relating primarily to customer acceptance or rejection, KYC outcomes, KYT outcomes, Travel Rule determinations, execution, pricing, liquidity sourcing, wallet release, custody, crypto delivery or other regulated-service matters shall, to the maximum extent permitted by applicable law, fall within the responsibility of the relevant Third-Party Provider.

13.2. Where a complaint concerns a Service provided by a Third-Party Provider, Moneychurros may redirect the complaint to that provider or ask the user to contact the provider directly, while still providing reasonable assistance in relation to the Platform-side aspects of the matter. Any such assistance by Moneychurros does not make Moneychurros the provider of the relevant regulated service or responsible for the substantive resolution of matters falling within the Third-Party Provider's regulatory perimeter.

13.3. In particular, complaints relating to customer acceptance or rejection, KYC outcomes, KYT decisions, Travel Rule determinations, exchange execution, wallet release, or crypto delivery by the Third-Party Provider may need to be resolved by that provider, although Moneychurros may assist with routing or interface-level support where appropriate. The same applies to complaints or disputes relating to chargebacks, transaction reversals, settlement timing, reserve withholdings, and decisions made by payment-chain participants or by the relevant Third-Party Provider in response to such events, except to the extent the complaint concerns Moneychurros's own Platform or technical support services.

13.4. Unless otherwise stated in the applicable flow or supplemental terms, support requests and general communications may be submitted through the Platform or through the support contact details made available on the Website.

14. GOVERNING LAW AND CONSUMER RIGHTS

14.1. These Terms should be read subject to any mandatory consumer protection laws applicable in the user's country of residence that cannot be contractually excluded or limited.

14.2. Where a Third-Party Provider is the contractual provider of a regulated service, questions of governing law, dispute resolution, or mandatory regulatory disclosures relating to that regulated service may also be governed by that provider's own terms.

14.3. To the extent permitted by applicable law, the governing law and dispute resolution framework applicable to Moneychurros's own platform and technical services shall be the law and forum identified in the supplemental terms, website disclosures, or other applicable legal notice made available to the user.