TERMS OF USE

1. DEFINITIONS

In these Terms, unless otherwise indicated, the following definitions shall apply:

• "Account" means a User Account previously created on the KUNA platform as a result of User registration, with the help of which User had the ability to perform transactions and keep records of activity on the Website or App.
• "Affiliate" means with respect to any Person, an individual, corporation, partnership, firm, association, unincorporated organization or other entity directly or indirectly controlling, controlled by or under common control with such Person.
• "AML Policy" means the Anti-Money Laundering and Counter-Terrorist Financing Policy of the Company, as amended from time to time.
• "Business Day" means any calendar day other than Saturday, Sunday or any other day on which banks and credit institutions are authorized to be closed in Lithuania.
• "Company" or "KUNA" means UAB "KUNA PRO", a company registered and operating under the laws of Republic of Lithuania, company number 306041195, with the registered address at: Vilnius, Eišiškių Sodų 18-oji g.11, Republic of Lithuania.
• "Fiat Money" means government-issued currency that is designated as a legal tender in its country of issuance on the legislative level.
• "Funds" means the amount of Virtual Assets remaining on a User Account, including balances that have been converted to USDC or other stablecoins.
• "KYC/Verification Procedure" means the obligatory identification procedures prescribed by the AML Policy and applicable law.
• "Law" means all applicable laws, regulations, judgments, decrees, treaties, ordinances, orders and rulings, interpretations and statements of policy of any governmental authority or regulatory or self-regulatory organization, authority, agency or body, in each case which has jurisdiction over KUNA, the User, or their respective operations.
• "Person" means an individual, partnership, limited partnership, corporation, limited liability company, joint stock company, unincorporated organization or association, trust or joint venture, or a governmental authority or political subdivision thereof.
• "Politically Exposed Person" or "PEP" means a natural person who is or has been entrusted with prominent public functions, as well as their immediate family members and close associates, as defined in the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing.
• "Privacy Policy" means rules of personal data collection, storage, and use, developed by the Company in accordance with applicable law.
• "Prohibited Jurisdiction" means any country or territory listed in Section 5 of these Terms where the Company's services are not available.
• "Sanctions" means economic or financial sanctions or trade embargoes imposed by the European Union, the Government of Canada, the United States of America, the United Nations, or any other applicable governmental authority.
• "User" or "You" means a Person who has previously registered an Account with KUNA and may have remaining Funds subject to withdrawal.
• "Virtual Asset" means a decentralized peer-to-peer digital asset or digital currency, that is not legal tender, is not securities, e-money, or money under applicable law, and can be transferred, traded and used for payments and exchange purposes.
• "Withdrawal" means an operation involving a transfer of Funds from the User's Account to an external wallet or bank account.
• "Withdrawal Request" means a formal request submitted by a User to withdraw their remaining Funds from the Company.

2. CESSATION OF SERVICES

2.1. Discontinued Services. The Company has permanently ceased all Virtual Asset Service Provider (VASP) activities in late March, 2025, including virtual asset exchange operator and deposit virtual asset operator services. The following services are no longer available: virtual asset exchange and trading services; deposit of Fiat Money or Virtual Assets; peer-to-peer trading; custodial wallet services for new deposits; account registration for new users; any other services previously offered on the KUNA platform.

2.2. Available Services. The only service currently provided by the Company is the processing of Withdrawal Requests for Users with remaining Funds balances. Users may submit requests to withdraw their Funds by contacting the Company through the designated channels specified in Section 16 of these Terms.

3. CONVERSION OF BALANCES

3.1. Rationale for Conversion. In connection with the cessation of VASP activities and in order to protect User Funds from market volatility during the wind-down period, the majority of User balances held in volatile Virtual Assets have been converted to USDC (USD Coin), a stablecoin pegged to the United States Dollar. This measure was undertaken to: (a) preserve the value of User Funds and prevent potential losses arising from price fluctuations in volatile Virtual Assets; (b) ensure operational simplicity during the fund return process; and (c) comply with regulatory requirements applicable to the wind-down of VASP operations. The respective information regarding the conversion has been provided to Users via email or other means of communication in prior.

3.2. Scope of Conversion. Users acknowledge and understand that the majority of balances have been converted to USDC. However, not all balances have been converted - certain User Accounts may retain balances in other currencies or Virtual Assets where conversion was not practicable or where the original asset was already a stablecoin or in some other liquid assets. Users will be informed of the composition of their current balance upon submitting a Withdrawal Request.

3.3. Conversion Terms. Conversions were executed at prevailing market rates available at the time of conversion. Due to the variety of Virtual Assets and currencies previously supported by the platform, multiple conversions may have occurred at different times and rates. The Company does not guarantee any specific exchange rate and is not liable for any difference between the original asset value and the converted equivalent, whether at the time of conversion or withdrawal.

4. USER ELIGIBILITY AND RESTRICTIONS

4.1. Eligibility for Withdrawal. Withdrawal Requests may only be submitted by Users who: (a) are at least 18 years old or are of legal age to form a binding contract under applicable laws; (b) have a previously registered and verified Account with KUNA; (c) are not residents or citizens of a Prohibited Jurisdiction; (d) are not subject to Sanctions; and (e) are not on any sanctions list maintained by the European Union, the Government of Canada, the United States of America (including OFAC), or the United Nations.

4.2. Sanctions Compliance. Users represent and warrant that they will not receive or attempt to receive Funds if they are, or if the beneficial owner of the Funds is, an individual, entity, or country upon which Sanctions have been imposed. This includes, but is not limited to, persons listed under the legislation and related regulations referenced at: https://www.sanctionsmap.eu and https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/current-actuelles.aspx.

4.3. Prohibited Activities. The Company reserves the right to refuse, delay, or reverse any Withdrawal Request if the User or the source of Funds is associated with any of the following: unlawful businesses or activities, including but not limited to sale of narcotics, weapons, stolen goods, or other prohibited items; money laundering, terrorist financing, fraud, or other financial crimes; circumvention of Sanctions; provision of false, inaccurate, or misleading information; any activity that would cause the Company to violate applicable Law. A detailed list of prohibited activities is set forth in Annex 1 to these Terms.

5. PROHIBITED JURISDICTIONS

5.1. Restricted Countries and Territories. The Company's services, including fund withdrawals, are not available to residents or citizens of the following countries and territories: Afghanistan, Algeria, Belarus (except persons who have a valid EU entry visa or EU residence permit), Benin, Burkina Faso, Cabo Verde, Cambodia, Central African Republic, China, Cuba, Côte d'Ivoire, Congo, Democratic People's Republic of Korea (North Korea), Democratic Republic of Ethiopia, Dominican Republic, Eritrea, Federal Republic of Ambazonia, Ghana, Guatemala, Guinea, Guinea-Bissau, Guyana, Haiti, Honduras, Iran, Iraq, Jamaica, Jordan, Kenya, Kosovo, Laos, Lebanon, Liberia, Libya, Mali, Morocco, Mozambique, Myanmar (Burma), Nicaragua, Nigeria, Northern Cyprus, Pakistan, Philippines, Russia, Senegal, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Uganda, Vanuatu, Venezuela, Yemen, Zimbabwe.

5.2. Restricted Regions. The following regions are also restricted regardless of the User's citizenship: Crimea (region of Ukraine), Donetsk (region of Ukraine), Luhansk (region of Ukraine), Nagorno-Karabakh (temporarily occupied by Russia), Transnistria (temporarily occupied by Russia), territories of Georgia temporarily occupied by Russia (Abkhazia and South Ossetia).

5.3. Regulatory Restrictions. In addition, due to regulatory requirements, the Company does not serve customers in Japan, the United States, or the United Kingdom.

5.4. Updates to Restricted List. The Company reserves the right to update this list at any time in accordance with changes in applicable Sanctions regimes, regulatory requirements, or other legal considerations. Users from Prohibited Jurisdictions are not entitled to submit Withdrawal Requests, and any such requests will be denied.

6. FUND WITHDRAWAL PROCEDURE

6.1. Submission of Withdrawal Request. To initiate a Withdrawal of remaining Funds, Users must contact the Company via email at support@kuna.io. The request must be sent from the email address associated with the User's Account. The email must include: (a) the User's full name as registered on the Account; (b) a clear statement of intent to withdraw remaining Funds; and (c) the preferred withdrawal method (Virtual Asset transfer to an external wallet).

6.2. Verification Requirements. The Company reserves the right to request additional verification documents or information to confirm the User's identity and ownership of the Account. This may include: government-issued identification documents (passport, national identity card); proof of address; confirmation of ownership of the destination wallet; source of funds documentation; and any other information reasonably required for AML/KYC compliance purposes. Failure to provide requested verification within a reasonable timeframe may result in delays or inability to process the Withdrawal Request.

6.3. Processing Timeline. Due to the manual nature of the wind-down process, Withdrawal Requests are processed on a case-by-case basis. Users should expect extended processing times. The Company will make reasonable efforts to process requests in the order received, but does not guarantee specific processing timeframes. Users will be contacted by a support agent to discuss the specifics of their Withdrawal.

6.4. Minimum Withdrawal Amount. The Minimum Withdrawal Amount is currently not set, but the Company retains the rights to introduce it subject to prior notice.

6.5. Withdrawal Methods. Subject to availability, the User's jurisdiction, and Sanctions compliance, Withdrawals may be processed via only transfer of Virtual Assets (USDC or other available assets) to an external wallet address provided by the User unless other has been agreed with the Company's representative. The Company reserves the right to determine the available withdrawal methods on a case-by-case basis and may refuse certain withdrawal methods if they would cause the Company to violate applicable Law or Sanctions. To prevent possible illegal transactions, the Company requires that the recipient of the Withdrawal be the same person as the Account holder. Any payments to third parties are strictly prohibited.

6.6. Responsibility for Accuracy. The User is solely responsible for the accuracy of all information provided in connection with a Withdrawal Request, including wallet addresses, bank account details, and personal information. The Company shall not be liable for any loss of Funds resulting from incorrect information provided by the User. Virtual Asset transactions are irreversible, and the Company cannot assist in recovering Funds sent to an incorrect address.

7. FEES AND CHARGES

7.1. Withdrawal Fees. Withdrawals may be subject to applicable network fees (for Virtual Asset transfers). Such fees will be deducted from the withdrawal amount or communicated to the User prior to processing.

8. UNCLAIMED FUNDS

8.1. Deadline for Claims. Currently, there is no deadline for submitting Withdrawal Requests. However, the Company reserves the right to introduce a deadline for fund claims upon providing Users with advance notice of at least thirty (30) days. Such notice will be sent to the email address associated with the User's Account and/or published on the Company's website.

8.2. Treatment of Unclaimed Funds. Funds that remain unclaimed after the expiration of any deadline introduced pursuant to Section 8.1, or that remain unclaimed for an extended period as determined by the Company in accordance with applicable Law, may be forfeited and become the property of the Company. The Company will make reasonable efforts to contact Users prior to any forfeiture of unclaimed Funds.

9. LIMITATION OF LIABILITY

9.1. Exclusion of Liability. To the maximum extent permitted by applicable Law, the Company, its officers, directors, employees, agents, and Affiliates shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages whatsoever arising from or related to: delays in processing Withdrawal Requests; fluctuations in the value of Virtual Assets, including any difference between the value at conversion and at withdrawal; technical difficulties, system failures, or interruptions; actions or omissions of third parties, including banks, payment processors, or blockchain networks; any Withdrawal Request that cannot be processed due to Sanctions, Prohibited Jurisdiction restrictions, or AML/KYC concerns; blockchain malfunctions, breakdowns, or protocol changes; any other circumstances beyond the reasonable control of the Company.

9.2. Maximum Liability. The Company's total aggregate liability in connection with these Terms shall not exceed the value of the User's remaining Funds at the time of the Withdrawal Request.

9.3. No Investment Advice. The Company does not provide investment, financial, legal, or tax advice. All Users must understand the risks involved in Virtual Assets. Users are solely responsible for their decisions regarding their Funds and should consult appropriate professional advisors.

10. AML/KYC COMPLIANCE AND INVESTIGATIONS

10.1. Compliance Obligations. The Company engages reliable partners for blockchain analytics and risk assessment to evaluate transactions.

10.2. Enhanced Due Diligence. The Company may apply enhanced due diligence measures in cases where the risk is established to be higher than usual, including but not limited to: doubts about the veracity of data provided or authenticity of documents; transactions involving Politically Exposed Persons (PEPs), their family members or close associates; transactions involving high-risk third countries as identified by the European Commission or FATF; any other circumstances warranting additional scrutiny.

10.3. Right to Refuse or Delay. The Company reserves the right to refuse, delay, or any Withdrawal Request if: (a) there are reasonable grounds to suspect that the transaction is connected to money laundering, terrorist financing, fraud, or other illegal activities; (b) the User fails to provide satisfactory verification documentation; (c) the Funds have links to mixers, tumblers, darknet markets, or other high-risk sources; (d) processing the request would cause the Company to violate any applicable Law, regulation, or Sanctions; or (e) required by law enforcement, regulatory authorities, or court order.

10.4. Cooperation with Authorities. The Company reserves the right to monitor, review, retain, and disclose any information as necessary to satisfy applicable Law, regulation, Sanctions programs, legal process, or governmental request. The Company cooperates with supervisory and law enforcement authorities, including the Financial Crime Investigation Service under the Ministry of the Interior of the Republic of Lithuania (FCIS), in preventing money laundering and terrorist financing.

11. DATA RETENTION AND PRIVACY

User data will be retained in accordance with the requirements of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing and other applicable data protection legislation. The Company will keep a record of User information during the period for which the Account was active and for the period required by applicable Law after termination of the business relationship. For more information, please refer to the Company's Privacy Policy.

12. INDEMNIFICATION

To the extent permitted by applicable Law, the User agrees to defend, indemnify, and hold harmless the Company, its Affiliates, contractors, licensors, and their respective directors, officers, employees, and agents from and against any and all claims, damages, obligations, losses, liabilities, costs, or expenses (including but not limited to attorney's fees and fines or penalties imposed by any regulatory authority) arising from: (a) the User's use of and access to the Services; (b) the User's breach of any term of these Terms; (c) the User's violation of any Law, rule, or regulation, or the rights of any third party; or (d) the User's provision of false, inaccurate, or misleading information.

13. GOVERNING LAW AND DISPUTE RESOLUTION

These Terms shall be governed by and construed in accordance with the Laws of the Republic of Lithuania, without regard to conflict of law principles, and shall be construed in all respects as a contract entered into under the laws of Lithuania. Any disputes arising from or in connection with these Terms shall first be attempted to be resolved through negotiation between the parties. Should the parties fail to reach an agreement by means of negotiations within thirty (30) calendar days, any dispute shall be referred to and finally resolved by the competent courts of the Republic of Lithuania.

14. AMENDMENTS

The Company reserves the right to amend these Terms at any time at its sole discretion. Users will be notified of material changes via email to the address associated with their Account and/or through publication on the Company's website. The amended Terms take effect immediately upon publication unless otherwise specified. Continued submission of Withdrawal Requests following such notification constitutes acceptance of the amended Terms.

15. MISCELLANEOUS

15.1. Entire Agreement. These Terms and any annexes, constitute the entire agreement between the User and the Company with respect to fund withdrawals during the wind-down period.

15.2. Severability. If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect.

15.3. Assignment. The Company may assign any of its rights and/or transfer, sub-contract, or delegate any of its obligations under these Terms without the User's consent. The User's agreement to these Terms is personal and may not be transferred or assigned to any third party.

15.4. Language. Should any conflict arise between the English language version of these Terms and any translation thereof, the English language version shall prevail.

15.5. Force Majeure. The Company shall not be held liable for any delays, failure in performance, or interruptions of service which result directly or indirectly from any cause or condition beyond the Company's reasonable control, including but not limited to: any delay or failure due to any act of God, act of civil or military authorities, act of terrorism, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophes, or any other occurrence which is beyond the Company's reasonable control.

16. CONTACT INFORMATION

For all inquiries regarding fund withdrawals, please contact:

UAB "KUNA PRO"

Email: support@kuna.io

Registered Address: Vilnius, Eišiškių Sodų 18-oji g. 11, Republic of Lithuania

Company Number: 306041195

By submitting a Withdrawal Request, you acknowledge that you have read, understood, and agree to be bound by these Terms.

ANNEX 1

PROHIBITED ACTIVITIES

The Company may deny processing of Withdrawal Requests at its discretion in case of any suspicion that the activities carried out by the User are aimed at money laundering, terrorist financing, Sanctions evasion, or any other illegal or undesirable activity.

In case suspicious transactions are detected, access to the User Account may be restricted and the User Funds may be blocked for conducting a review for a period of between 24 hours and 180 Business Days. This period may be extended at the discretion of the Company if required by the interests of the Company, investigations, at the request of law enforcement agencies, any third parties, or for any other reason.

1. Unlawful Businesses

Withdrawals are not available for Users associated with activities related to the sale, purchase, exchange, or other transactions involving the transfer of ownership, possession, use, or disposal of the following:

• alcoholic beverages;
• cigarettes and tobacco products;
• narcotic substances and precursors;
• pornographic materials or items, child pornography, escort services or prostitution services;
• drugs, pharmacological products, medicines;
• stolen or illegally obtained goods;
• items posing a danger to life and health;
• non-existent goods;
• human organs and remains, and organs and remains of animals;
• special technical means of secretly obtaining information;
• any electronic, mechanical and computer equipment prohibited or restricted in circulation or use;
• state awards, personal documents, as well as forms of these documents;
• objects of history and art that constitute the cultural values of the country in which the consumer is located;
• firearms, edged weapons, traumatic weapons, stun guns, as well as ammunition and accessories for them;
• special means of active defense used by law enforcement authorities;
• precious metals and precious stones not in the product;
• counterfeit currency and currency values;
• rare and prohibited for sale animals, including animals listed in the CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora);
• any other goods and services prohibited by applicable Law.

Users are also prohibited from activities without a corresponding permit or license, which requires an appropriate permit and/or a license.

2. Abusive Activity

Withdrawals are not available for Users who have engaged in or are suspected of:

• transmitting or uploading any material that contains viruses or any other harmful or deleterious programs;
• actions which impose an unreasonable or disproportionately large load on the Company's infrastructure, or detrimentally interfere with any system, data, or information;
• attempting to gain unauthorized access to other users' accounts, computer systems or networks;
• using account information of another party;
• transferring Account access or rights to a third party without the Company's express permission;
• providing false, inaccurate, or misleading information to the Company;
• impersonating another person or otherwise misrepresenting affiliation with a person or entity, conducting fraud, hiding or attempting to hide identity;
• any activity which creates costs, expenses, losses or liability for the Company;
• activity that operates to defraud the Company, other Users, or any other person;
• modifying, disassembling, decompiling or reverse-engineering the Services;
• transmitting spam, chain letters, or other unsolicited communications;
• attempting to interfere with or compromise system integrity or security;
• bypassing measures used to prevent or restrict access to the Services;
• deleting the Company's copyright or other proprietary rights notices.

3. Intellectual Property Infringement & 4. Sanctions

Withdrawals are not available for Users who have engaged in:

• transactions that violate, infringe or misappropriate any intellectual or industrial property right of any person (such as copyright, trademarks, patents, or trade secrets);
• use of the Company's intellectual property, name, or logo without express consent;
• creating a false identity for the purpose of misleading others or fraudulently misrepresenting affiliation with a person, entity or group.

4. Sanctions and High-Risk Sources

Withdrawals are not available for Users whose Funds:

• originate from or are destined to Prohibited Jurisdictions;
• are associated with individuals or entities subject to Sanctions;
• have connections to cryptocurrency mixers, tumblers, or anonymization services;
• originate from darknet markets or other illicit platforms;
• are the proceeds of any criminal activity;
• are associated with Politically Exposed Persons without satisfactory enhanced due diligence.

The Company reserves the right at all times to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable Law, regulation, Sanctions programs, legal process, or governmental request. The Company reserves the right to cancel and/or suspend the Account and/or block transactions or freeze Funds immediately and without notice if the Company determines, in its sole discretion, that the Account is associated with any Prohibited Activity.