Terms of Use

Last Updated: February 2, 2026 — Version 1.0

FIN TWIN TECHNOLOGIES INC.
Trading as FINTWIN Pay

IMPORTANT: PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING THE FINTWIN PAY WEB PORTAL OR ANY SERVICES PROVIDED BY FIN TWIN TECHNOLOGIES INC. BY ACCESSING OR USING OUR SERVICES, YOU AGREE TO BE BOUND BY THESE TERMS OF USE. IF YOU DO NOT AGREE TO ALL OF THESE TERMS, DO NOT ACCESS OR USE OUR SERVICES.

Who We Are and How to Contact Us
Scope
Key Definitions
Eligibility
Acceptable Use
Your FINTWIN Account
Scope of Services
Website Disclaimer
Changes to These Terms
Accessing the Website
Account Registration
Fees and Payments
Prohibition of Use
Account Security
Trademarks and Intellectual Property Rights
Privacy Notice
Linking and Third-Party Services
Restricted Locations
Disclaimer of Warranties
Limitation of Liability
Indemnity
Governing Law and Jurisdiction
Waiver and Severability
Entire Agreement
Client Due Diligence and AML Compliance
Dispute Resolution
Contact Information

1. Who We Are and How to Contact Us

1.1 Corporate Identity

FIN TWIN TECHNOLOGIES INC. (hereinafter referred to as “FINTWIN,” “the Company,” “we,” “us,” or “our”) is a corporation incorporated on January 15, 2026, under the laws of the Province of Ontario, Canada, pursuant to the Ontario Business Corporations Act (R.S.O. 1990, c. B.16).

Legal Name: FIN TWIN TECHNOLOGIES INC.
Trading Name: FINTWIN Pay
Ontario Corporation Number: 1001472662
Registered Office: 1025 King Street East, Unit 107-1587, Cambridge, Ontario, N3H 3P5, Canada
Director: Pavel Martynov

1.2 Regulatory Status

FIN TWIN TECHNOLOGIES INC. is registered as a Money Services Business (MSB) with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17) (PCMLTFA).

FINTRAC MSB Registration Number: C10001675

The Company operates as a Payment Service Provider (PSP) subject to the regulatory framework established under the Retail Payment Activities Act (S.C. 2021, c. 23, s. 177) (RPAA) and applicable regulations administered by the Bank of Canada.

1.3 Services Overview

FINTWIN Pay provides the following cross-border payment and financial services through its web portal:

Foreign Exchange Services (currency conversion)
Wire Transfers (cross-border transfers via SWIFT, SEPA, and Faster Payments Network)
FINTWIN Transfers (remittance services to multiple countries in fiat and digital currencies)
Virtual Currency Exchange (exchange services for Bitcoin (BTC), Ethereum (ETH), Tether (USDT), and USD Coin (USDC))

1.4 How to Contact Us

You may contact FINTWIN Pay through the following channels:

Through the support section of your FINTWIN Account or via live chat on our Web Portal — available 24 hours a day, 7 days a week
Live Chat (Messengers): Available in real-time during business hours through the FINTWIN Pay web portal

FINTWIN Pay does not offer telephone support. All inquiries, service requests, and complaints should be submitted through the support section of your FINTWIN Account or via live chat.

1.5 Business Model

FINTWIN Pay operates on a pass-through, same-day (D+0) settlement basis. The Company does not hold, store, or retain end-user funds beyond the time strictly necessary to complete and settle a transaction. Funds received from clients are processed and transmitted to the designated beneficiary or destination within the shortest operationally feasible timeframe. FINTWIN accounts are non-interest-bearing.

2. Scope

2.1 Application of These Terms

These Terms of Use (the “Terms”) constitute a legally binding agreement between you (the “User,” “Client,” “you,” or “your”) and FIN TWIN TECHNOLOGIES INC. governing your access to and use of:

The FINTWIN Pay website located at https://fintwinpay.com (the “Website” or “Web Portal”)
All services, features, content, and functionality offered through the Web Portal (collectively, the “Services”)
Your FINTWIN Account and all transactions conducted through it

2.2 Acceptance of Terms

By accessing the Website, creating a FINTWIN Account, or using any of our Services, you acknowledge that you have read, understood, and agree to be bound by these Terms, together with:

Our Privacy Policy
Our Anti-Money Laundering (AML) Policy
Our Fee Schedule, as published and updated from time to time on the Web Portal
Any supplementary terms, notices, or guidelines published on the Website

2.3 Geographical Scope

FINTWIN Pay provides cross-border payment services only. We do not facilitate domestic payments within Canada. Our Services are primarily designed for and marketed to Canadian residents, though they may be accessed by eligible users in other jurisdictions, subject to applicable laws and these Terms.

2.4 Regulatory Scope

These Terms are drafted in compliance with the following Canadian federal and provincial legislation and regulatory frameworks:

Retail Payment Activities Act (S.C. 2021, c. 23, s. 177) (RPAA)
Proceeds of Crime (Money Laundering) and Terrorist Financing Act (S.C. 2000, c. 17) (PCMLTFA) and its associated Regulations
Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (PIPEDA)
Ontario Business Corporations Act (R.S.O. 1990, c. B.16)
Currency Act (R.S.C., 1985, c. C-52)
Canadian Payments Act (R.S.C., 1985, c. C-21)
Applicable FINTRAC guidance and directives

2.5 Language

These Terms are drafted in the English language. In the event of a translation into any other language, the English language version shall prevail in case of any conflict or inconsistency.

3. Key Definitions

In these Terms, unless the context otherwise requires, the following terms shall have the meanings set out below:

“AML” means Anti-Money Laundering, encompassing all policies, procedures, and controls implemented by the Company to prevent the use of its Services for money laundering, terrorist financing, or other financial crimes.
“Applicable Law” means all federal, provincial, territorial, and municipal laws, regulations, rules, orders, directives, guidelines, policies, and regulatory requirements applicable to the Company, the Services, or the User, including the RPAA, PCMLTFA, PIPEDA, and FINTRAC guidance.
“Authenticator App” means a software-based authentication application used to generate time-based one-time passwords (TOTP) for two-factor authentication purposes.
“Beneficiary” means the individual or entity designated to receive funds or virtual currency transferred through the Services.
“Business Day” means any day other than a Saturday, Sunday, or statutory holiday in the Province of Ontario, Canada.
“Client Due Diligence” or “CDD” means the processes and procedures conducted by the Company to verify the identity of Users and assess the risk associated with their activities, in accordance with Applicable Law.
“Cryptocurrency” or “Virtual Currency” means a digital representation of value that can be used for payment or investment purposes, such as Bitcoin (BTC), Ethereum (ETH), Tether (USDT), and USD Coin (USDC).
“D+0 Settlement” means the Company’s pass-through model whereby funds are processed and transmitted to the designated recipient on the same day they are received, without the Company holding funds beyond the time necessary to complete the transaction.
“EDD” means Enhanced Due Diligence, being additional CDD measures applied to higher-risk clients, transactions, or business relationships.
“Fee Schedule” means the schedule of fees, charges, and commissions applicable to the Services, as published on the Web Portal and updated from time to time.
“FINTRAC” means the Financial Transactions and Reports Analysis Centre of Canada.
“FINTWIN Account” means the online account created by a User on the Web Portal to access and use the Services.
“FINTWIN Transfer” means a remittance service provided by the Company enabling the transfer of fiat or digital currency to beneficiaries in multiple countries.
“Foreign Exchange Services” means the currency conversion services offered by the Company.
“KYC” means Know Your Client, being the process of verifying the identity and assessing the suitability and risks of a Client in accordance with Applicable Law.
“PEP” means a Politically Exposed Person, as defined under the PCMLTFA and its Regulations.
“Personal Information” has the meaning ascribed to it under PIPEDA.
“Prohibited Activity” means any activity that is prohibited under these Terms, Applicable Law, or the Company’s policies.
“RPAA” means the Retail Payment Activities Act (S.C. 2021, c. 23, s. 177).
“Sanctions” means economic or trade sanctions, embargoes, or restrictive measures imposed, administered, or enforced by Canada (under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act, or the United Nations Act), the United Nations Security Council, the United States (including OFAC), the European Union, or the United Kingdom.
“Services” means all payment services, foreign exchange services, wire transfer services, FINTWIN Transfer services, virtual currency exchange services, and related services offered by the Company through the Web Portal.
“STR” means a Suspicious Transaction Report filed with FINTRAC in accordance with the PCMLTFA.
“Transaction” means any payment, transfer, conversion, exchange, or other financial operation conducted through the Services.
“Two-Factor Authentication” or “2FA” means an additional layer of security requiring two forms of identification to access a FINTWIN Account, provided via SMS verification code or authenticator application.
“User,” “Client,” “you,” or “your” means any individual or entity that accesses the Website, creates a FINTWIN Account, or uses any of the Services.
“Web Portal” means the FINTWIN Pay web-based platform accessible at https://fintwinpay.com through which Users access the Services.
“Travel Rule” means the regulatory requirement under FINTRAC guidance for virtual currency transfers, obligating the Company to collect, verify, and transmit originator and beneficiary information when transferring virtual currency on behalf of a User.
“Wire Transfer” means a cross-border electronic transfer of funds facilitated through the SWIFT, SEPA, or Faster Payments Network.

4. Eligibility

4.1 General Eligibility Requirements

To be eligible to create a FINTWIN Account and use the Services, you must satisfy all of the following conditions:

You must be at least eighteen (18) years of age or the age of majority in your jurisdiction of residence, whichever is greater.
You must be a natural person acting on your own behalf, or a duly authorized representative of a legal entity with the authority to bind such entity to these Terms.
You must have the legal capacity to enter into a binding agreement under the laws of your jurisdiction.
You must not be located in, a resident of, or a citizen of any jurisdiction subject to comprehensive Sanctions or designated as a Restricted Location under Section 18 of these Terms.
You must not be listed on any applicable Sanctions list, including Canadian sanctions lists, the OFAC Specially Designated Nationals (SDN) List, UN Security Council Consolidated List, or EU Consolidated List.
You must provide accurate, current, and complete information during the registration and KYC process and maintain the accuracy of such information at all times.
You must not have previously been suspended, terminated, or banned from using the Services.

4.2 Corporate and Business Clients

If you are registering on behalf of a business, corporation, partnership, trust, or other legal entity:

You represent and warrant that you are duly authorized to act on behalf of such entity and to bind it to these Terms.
You must provide all requested documentation regarding the entity, such as articles of incorporation, certificate of status, beneficial ownership information, partnership agreements, trust deeds, or other organizational documents as required.
The entity must be duly organized, validly existing, and in good standing under the laws of its jurisdiction of incorporation or formation.
All authorized signatories and beneficial owners must undergo the Company’s KYC and CDD procedures.

4.3 Representations and Warranties

By creating a FINTWIN Account and using the Services, you represent and warrant that:

All information you provide to us is truthful, accurate, and complete.
You are not acting on behalf of any third party in violation of Applicable Law.
Your use of the Services does not violate any Applicable Law in your jurisdiction.
Funds and virtual currency used in connection with the Services are derived from legitimate sources and are not the proceeds of crime.
You are not using the Services for money laundering, terrorist financing, proliferation financing, tax evasion, fraud, or any other illegal purpose.
You will comply with all Applicable Law in connection with your use of the Services.

4.4 Ongoing Eligibility

Your eligibility to use the Services is subject to ongoing verification. The Company reserves the right, at any time and without prior notice, to:

Request additional documentation or information to verify your continued eligibility.
Suspend or terminate your FINTWIN Account if you no longer meet the eligibility requirements.
Restrict access to certain Services or features based on your risk profile, jurisdiction, or regulatory requirements.

5. Acceptable Use

5.1 General Acceptable Use Policy

You agree to use the Services and the Web Portal solely for their intended purposes, in accordance with these Terms, Applicable Law, and applicable industry standards. You must not use the Services in any manner that could damage, disable, overburden, or impair the Web Portal or interfere with any other party’s use of the Services.

5.2 Permitted Uses

The Services may be used for the following lawful purposes:

Sending and receiving cross-border fiat currency payments via wire transfer (SWIFT, SEPA, Faster Payments Network).
Converting currencies through the Foreign Exchange Services.
Sending and receiving FINTWIN Transfers (remittances) in fiat and digital currencies.
Purchasing, selling, and exchanging supported virtual currencies (BTC, ETH, USDT, USDC).
Funding your FINTWIN Account via bank wire transfer or cryptocurrency deposit.
Managing your FINTWIN Account, including updating personal information and security settings.

5.3 Prohibited Uses

You agree not to use the Services or the Web Portal to:

Engage in any Prohibited Activity as described in Section 13 of these Terms.
Violate any Applicable Law, including laws relating to anti-money laundering, counter-terrorist financing, Sanctions, tax, data protection, or consumer protection.
Transmit or receive funds or virtual currency that are the proceeds of crime or are intended to finance illegal activities.
Circumvent, or attempt to circumvent, the Company’s KYC, CDD, AML, or Sanctions screening procedures.
Create multiple FINTWIN Accounts for the purpose of evading limits, controls, or enforcement actions.
Impersonate any person or entity, or misrepresent your affiliation with any person or entity.
Use the Services for speculative trading, market manipulation, or any form of financial abuse.
Interfere with, disrupt, or attempt to gain unauthorized access to the Web Portal, its servers, networks, or any connected systems.
Introduce any viruses, malware, trojans, worms, or other harmful code to the Web Portal.
Use automated systems, scripts, bots, or scraping tools to access or interact with the Web Portal without prior written authorization from the Company.
Use the Services in connection with gambling, gaming, or lottery activities where such activities are illegal in the relevant jurisdiction.
Use the Services in connection with the purchase or sale of illegal goods or services, including controlled substances, weapons, or stolen property.

5.4 Compliance Monitoring

The Company reserves the right to monitor your use of the Services for compliance with these Terms and Applicable Law. Without prior notice, we may:

Flag, delay, or block Transactions that we consider suspicious or potentially non-compliant.
Report suspicious Transactions or activities to FINTRAC or other relevant authorities as required by Applicable Law.
Request additional information or documentation from you to verify the purpose and legitimacy of any Transaction.
Suspend or terminate your FINTWIN Account in the event of a breach of these Terms.

6. Your FINTWIN Account

6.1 Account Nature

A FINTWIN Account is a non-interest-bearing transactional account provided by the Company solely to facilitate access to and use of the Services through the Web Portal. A FINTWIN Account is not a bank account, deposit account, savings account, or investment account.

FINTWIN Pay does not accept deposits in the traditional banking sense.
FINTWIN Pay does not pay interest on any funds or balances associated with your FINTWIN Account.
FINTWIN Pay operates a pass-through (D+0) model and does not hold, store, or retain end-user funds beyond the time strictly necessary to complete and settle a Transaction.
Funds received from you are processed and transmitted to the designated beneficiary or destination as expeditiously as possible.

6.2 Account Ownership

Each FINTWIN Account is personal to the registered User and may not be assigned, transferred, or shared with any third party.
You are solely responsible for all activity conducted through your FINTWIN Account, whether or not authorized by you.
Only one FINTWIN Account per individual or entity is permitted unless the Company expressly authorizes otherwise in writing.

6.3 Account Responsibilities

As a FINTWIN Account holder, you are responsible for:

Maintaining the confidentiality of your login credentials, including your username, password, and 2FA codes.
Ensuring that all information associated with your FINTWIN Account is accurate, current, and complete.
Promptly notifying the Company of any unauthorized access to or use of your FINTWIN Account.
Promptly notifying the Company of any changes to your personal or business information, including your name, address, email address, phone number, citizenship, residency, or beneficial ownership structure.
Complying with all Applicable Law and these Terms in connection with your use of the FINTWIN Account and the Services.

6.4 Account Suspension and Termination

The Company reserves the right, in its sole and absolute discretion, to suspend, restrict, or terminate your FINTWIN Account, with or without prior notice, for any of the following reasons:

Breach of these Terms or any of the Company’s policies.
Failure to provide requested KYC, CDD, or EDD documentation within the specified timeframe.
Suspected involvement in money laundering, terrorist financing, fraud, or other illegal activity.
Suspected involvement in Sanctions evasion or dealings with Sanctioned persons, entities, or jurisdictions.
Receipt of a court order, regulatory directive, or law enforcement request requiring suspension or termination.
Extended account inactivity (see Section 6.5 below).
Any other reason that the Company considers necessary for the protection of the Company, its Users, or the integrity of the Services.

Upon termination of your FINTWIN Account, any pending Transactions may be cancelled, and any funds or virtual currency remaining in transit will be processed in accordance with Applicable Law. You will remain liable for all obligations incurred prior to termination.

6.5 Dormant Account Policy

A FINTWIN Account will be classified as dormant if no Transactions or login activity have been recorded for a continuous period of six (6) months.
The Company will attempt to contact you via email to notify you of the dormant classification and request confirmation of your intention to maintain the account.
If no response is received within thirty (30) days of the dormancy notification, the Company may, at its discretion:
- Restrict or limit the functionality of the FINTWIN Account.
- Require re-verification of your identity (updated KYC/CDD) before reactivating the account.
- Close the FINTWIN Account and, if applicable, return any residual funds to your verified source of funds, less any applicable fees.
Treatment of dormant accounts shall comply with Applicable Law, including any applicable unclaimed property or escheatment legislation.

6.6 Account Closure by User

You may request closure of your FINTWIN Account at any time by contacting us through the support section of your FINTWIN Account or via live chat on our Web Portal. Upon receipt of your closure request:

All pending Transactions will be completed or cancelled, as applicable.
Any residual funds or virtual currency will be returned to your verified source of funds or a designated wallet address, less any applicable fees.
The Company will retain your records and Personal Information for the periods required by Applicable Law (see Section 25.7).
Account closure does not release you from any obligations or liabilities incurred prior to closure.

7. Scope of Services

7.1 Overview

FINTWIN Pay provides the following cross-border payment, foreign exchange, and virtual currency services through its Web Portal. All Services are subject to these Terms, the applicable Fee Schedule, Applicable Law, and the Company’s internal policies and procedures.

7.2 Foreign Exchange Services

FINTWIN Pay offers currency conversion services enabling Users to convert between supported fiat currencies at competitive exchange rates.
Exchange rates are provided in real-time through the Web Portal and are subject to market fluctuations.
The applicable exchange rate for a Transaction is the rate displayed at the time of Transaction confirmation. Once confirmed, the exchange rate is locked for that Transaction.
The Company may charge a spread or margin on the applicable exchange rate, as disclosed in the Fee Schedule.
The Company does not guarantee any specific exchange rate for future Transactions.

7.3 Wire Transfer Services

FINTWIN Pay facilitates cross-border wire transfers through the following payment networks:
- SWIFT (Society for Worldwide Interbank Financial Telecommunication) for international wire transfers
- SEPA (Single Euro Payments Area) for transfers within the European Economic Area
- Faster Payments Network for transfers within the United Kingdom
Wire transfers are processed on a D+0 (same-day) pass-through basis wherever operationally feasible, subject to the processing times of the applicable payment network, intermediary banks, and the beneficiary’s financial institution.
FINTWIN Pay does not provide domestic (within-Canada) payment or wire transfer services. All wire transfers must involve a cross-border component.
The Company is not responsible for delays, fees, or deductions imposed by intermediary banks, correspondent banks, or the beneficiary’s financial institution.
Users must provide accurate and complete beneficiary information, including name, address, account number (IBAN where applicable), SWIFT/BIC code, and any other information required by the applicable payment network.

7.4 FINTWIN Transfer Services

FINTWIN Transfers are remittance services enabling Users to send fiat currency and digital currency to beneficiaries in multiple countries.
FINTWIN Transfers may be denominated in fiat currency, virtual currency, or a combination thereof, depending on the destination country and the beneficiary’s preferences.
FINTWIN Transfers are processed through the Company’s network of correspondent partners and payment service providers.
Available destination countries, supported currencies, transfer limits, and estimated delivery times are published on the Web Portal and updated from time to time.
The Company reserves the right to add or remove destination countries, currencies, or delivery methods at any time without prior notice.

7.5 Virtual Currency Exchange Services

FINTWIN Pay offers virtual currency exchange services enabling Users to buy, sell, and exchange the following supported virtual currencies:
- Bitcoin (BTC)
- Ethereum (ETH)
- Tether (USDT)
- USD Coin (USDC)
Virtual currency exchange rates are provided in real-time through the Web Portal and are subject to market fluctuations, which may be significant.
The applicable exchange rate for a virtual currency Transaction is the rate displayed at the time of Transaction confirmation. Once confirmed, the rate is locked for that Transaction.
The Company may charge a spread, commission, or network fee on virtual currency Transactions, as disclosed in the Fee Schedule.
Virtual currency is not legal tender in Canada or any other jurisdiction. The value of virtual currencies is highly volatile and may decrease significantly or become worthless. Users acknowledge and accept the risks associated with virtual currency Transactions.
The Company utilizes Fireblocks (incorporated in the United States) for digital asset custody and transfers, and Scorechain (incorporated in Luxembourg) for blockchain analytics and AML compliance.

7.6 Account Funding Methods

Users may fund their FINTWIN Account through the following methods:

Bank Wire Transfer: Funds may be deposited via wire transfer from a bank account held in the User’s verified name. Third-party wire transfers are not accepted.
Cryptocurrency Deposit: Users may deposit supported virtual currencies (BTC, ETH, USDT, USDC) to their FINTWIN Account from an external wallet. The external wallet must be controlled by the User and may be subject to verification.

FINTWIN Pay does not accept funding by credit card, debit card, cash, cheque, money order, prepaid card, or any method not expressly listed above.

7.7 Transaction Limits

Transaction limits (minimum and maximum amounts per Transaction, daily, weekly, and monthly limits) are established by the Company based on the User’s risk profile and Applicable Law.
Transaction limits are disclosed to the User through the Web Portal upon successful account registration and KYC verification.
The Company reserves the right to modify Transaction limits at any time, with or without prior notice, based on regulatory requirements, risk assessments, or operational considerations.

7.8 Service Availability

The Services are available through the Web Portal only. FINTWIN Pay does not currently offer a mobile application.
The Company endeavours to maintain the Web Portal and Services on a continuous 24/7 basis but does not guarantee uninterrupted availability. The Services may be temporarily unavailable due to scheduled maintenance, system upgrades, force majeure events, or circumstances beyond the Company’s reasonable control.
The Company will use commercially reasonable efforts to provide advance notice of scheduled maintenance through the Web Portal or email notification.

8. Website Disclaimer

8.1 General Disclaimer

The FINTWIN Pay Web Portal and all content, information, and materials provided therein are made available on an “as is” and “as available” basis. While the Company endeavours to ensure that the information on the Web Portal is accurate and up to date, we make no representations or warranties, express or implied, regarding:

The accuracy, completeness, reliability, suitability, or timeliness of any content, information, exchange rates, fees, or other data displayed on the Web Portal.
The uninterrupted, error-free, or secure operation of the Web Portal or the Services.
The absence of viruses, malware, or other harmful components in the Web Portal.

8.2 No Financial Advice

The content provided on the Web Portal, including exchange rates, market information, and general informational materials, does not constitute financial, investment, tax, legal, or other professional advice.
FINTWIN Pay does not provide personalized financial recommendations or investment advice.
You should seek independent professional advice before making any financial decisions related to foreign exchange, cross-border payments, or virtual currency transactions.
Past performance of any currency or virtual currency is not indicative of future results.

8.3 Exchange Rate Information

Exchange rates displayed on the Web Portal are indicative and subject to change without notice until a Transaction is confirmed.
The Company does not warrant that exchange rates displayed on the Web Portal will be available at the time of Transaction execution.
Market conditions, liquidity, and other factors may affect the final exchange rate applied to a Transaction.

8.4 Third-Party Content

The Web Portal may contain links to third-party websites, resources, or content. The Company does not endorse, control, or assume responsibility for any third-party content or services.
Any reliance you place on third-party content is at your own risk.

9. Changes to These Terms

9.1 Right to Modify

The Company reserves the right to modify, amend, supplement, or replace these Terms at any time, in its sole discretion, to reflect:

Changes in Applicable Law, regulations, or regulatory guidance.
Changes in the Services, features, or functionality offered by the Company.
Changes in the Company’s business model, operations, or corporate structure.
Changes necessitated by security, fraud prevention, or risk management considerations.
Any other changes the Company considers necessary or appropriate.

9.2 Notice of Changes

Material changes to these Terms will be communicated to Users via email at the address associated with their FINTWIN Account and/or by posting a prominent notice on the Web Portal at least thirty (30) days prior to the effective date of such changes.
Non-material changes, such as corrections of typographical errors, formatting changes, or minor clarifications, may be made without prior notice.
The “Last Updated” date at the top of these Terms will be revised to reflect the date of the most recent amendment.

9.3 Acceptance of Changes

Your continued access to or use of the Services after the effective date of any changes to these Terms constitutes your acceptance of the amended Terms.
If you do not agree to the amended Terms, you must discontinue use of the Services and close your FINTWIN Account in accordance with Section 6.6.
It is your responsibility to review these Terms periodically to stay aware of any changes.

10. Accessing the Website

10.1 Access Requirements

To access and use the FINTWIN Pay Web Portal, you must:

Have a compatible internet-connected device (desktop computer, laptop, or tablet) with a modern, up-to-date web browser.
Maintain a stable and secure internet connection.
Enable JavaScript and cookies in your web browser, as these are required for the proper functioning of the Web Portal.

10.2 Supported Browsers

The Web Portal is designed to be compatible with the latest versions of major web browsers. The Company does not guarantee full functionality or compatibility with outdated or unsupported browser versions.

10.3 Access Restrictions

The Company reserves the right, without liability, to:

Restrict access to the Web Portal or any portion thereof at any time, for any reason, including for maintenance, security, or regulatory compliance purposes.
Implement geographic access restrictions based on the User’s IP address or other location indicators to comply with Sanctions, Restricted Location policies, or Applicable Law.
Require Users to complete additional verification steps before accessing certain features or Services.

10.4 Security Measures

Access to the Web Portal is secured using AES 256-bit encryption to protect data transmitted between your device and our servers.
Users must enable Two-Factor Authentication (2FA) on their FINTWIN Account, using either SMS verification or an authenticator application, as a mandatory security measure.
The Company employs real-time automated transaction monitoring to detect and prevent fraudulent or unauthorized activity.

10.5 Your Responsibilities

You are responsible for:

Making all arrangements necessary to access the Web Portal, including obtaining internet access and appropriate hardware and software.
Ensuring that all persons who access the Web Portal through your internet connection or devices are aware of and comply with these Terms.
Maintaining the security of your devices, internet connection, and login credentials.
Logging out of your FINTWIN Account after each session, particularly when using shared or public devices.

11. Account Registration

11.1 Registration Process

To access and use the Services, you must register for a FINTWIN Account through the Web Portal by completing the following steps:

Provide Personal Information: Submit your full legal name, date of birth, residential address, email address, phone number, nationality, and any other information requested during registration.
Identity Verification (KYC): Complete the Company’s Know Your Client verification process, conducted by our third-party identity verification provider, Sumsub (incorporated in the United Kingdom). This process typically requires:
- A valid, government-issued photo identification document (passport, national identity card, or driver’s licence).
- Proof of residential address (utility bill, bank statement, or government correspondence dated within the last three (3) months).
- A selfie or live video verification to confirm your identity.
Set Up Security: Create a strong, unique password and enable Two-Factor Authentication (2FA) via SMS or authenticator application.
Accept Terms: Review and accept these Terms of Use, the Privacy Policy, and any other applicable agreements.
Account Approval: Your registration will be reviewed by the Company. Account activation is subject to successful completion of KYC verification and internal compliance review.

11.2 Additional Verification

All clients undergo the same standard verification process upon registration. Depending on the outcomes of the Company’s AML risk assessment and internal compliance policies, additional verification may be required. The depth of such verification is determined by the presence of risk factors identified during the business relationship. Additional documentation may include:

Source of funds documentation (bank statements, employment records, tax returns).
Source of wealth documentation (inheritance records, property sale agreements, investment statements).
Enhanced due diligence questionnaire.
Business registration documents (for corporate clients).

11.3 Ongoing Verification

The Company may request updated or additional KYC documentation at any time during the business relationship, in accordance with Applicable Law and the Company’s risk-based approach to CDD.
Failure to provide requested documentation within the specified timeframe may result in the suspension or termination of your FINTWIN Account and the restriction of pending Transactions.

11.4 Accuracy of Information

You represent and warrant that all information provided during registration and throughout your use of the Services is accurate, current, and complete.
You must promptly update your FINTWIN Account information if any of your personal or business details change.
Providing false, misleading, or incomplete information constitutes a material breach of these Terms and may result in immediate account termination and referral to relevant authorities.

11.5 Screening

As part of the registration and ongoing monitoring processes, the Company screens all Users and their Transactions against:

Sanctions lists maintained by Canada, the United Nations, the United States (OFAC), the European Union, and the United Kingdom, using OpenSanctions (incorporated in Germany).
PEP (Politically Exposed Person) databases.
Adverse media sources.
Blockchain analytics data provided by Scorechain (incorporated in Luxembourg) for virtual currency transactions.

12. Fees and Payments

12.1 Fee Schedule

The Company charges fees for the use of its Services as set out in the Fee Schedule published on the Web Portal.
The Fee Schedule discloses all applicable fees, charges, commissions, spreads, and other costs associated with each Service in a clear, transparent, and accessible manner, in compliance with the requirements of the Retail Payment Activities Act (RPAA) and applicable Bank of Canada regulations.
Users are responsible for reviewing the Fee Schedule before initiating any Transaction.

12.2 Types of Fees

Fees may include the following:

Transaction Fees: A fixed or percentage-based fee charged per Transaction.
Foreign Exchange Spread: A margin applied to the mid-market exchange rate for currency conversion services.
Wire Transfer Fees: Fees applicable to outgoing and, where applicable, incoming wire transfers via SWIFT, SEPA, or Faster Payments Network.
FINTWIN Transfer Fees: Fees applicable to remittance transactions, which may vary based on destination country, currency, and delivery method.
Virtual Currency Exchange Fees: Fees, commissions, or spreads applied to the purchase, sale, or exchange of supported virtual currencies.
Network Fees (Gas Fees): Blockchain network fees applicable to virtual currency deposits, withdrawals, and transfers, which are determined by the applicable blockchain network and are not controlled by the Company.
Account Fees: Fees that may be applicable in connection with dormant accounts or account reactivation, as disclosed in the Fee Schedule.

12.3 Fee Transparency

In accordance with the RPAA and applicable regulatory requirements:

All fees applicable to a Transaction will be clearly disclosed to the User before the Transaction is confirmed.
The total cost of a Transaction, including all fees, charges, and the applicable exchange rate, will be displayed on the Transaction confirmation screen.
Users must affirmatively confirm the Transaction, including all disclosed fees, before the Transaction is executed.
No hidden or undisclosed fees will be charged.

12.4 Third-Party Fees

Transactions may be subject to additional fees imposed by third parties, including intermediary banks, correspondent banks, beneficiary financial institutions, or blockchain networks.
The Company does not control third-party fees. Such fees may be deducted from the Transaction amount before delivery to the beneficiary.
Where reasonably possible, the Company will inform Users of potential third-party fees before Transaction confirmation.

12.5 Fee Changes

The Company reserves the right to modify the Fee Schedule at any time.
Material changes to fees will be communicated to Users via email and/or posted on the Web Portal at least thirty (30) days prior to the effective date.
Continued use of the Services after the effective date of a fee change constitutes acceptance of the updated Fee Schedule.

12.6 Taxes

Users are solely responsible for determining and fulfilling any tax obligations arising from their use of the Services, including income tax, capital gains tax, goods and services tax (GST), harmonized sales tax (HST), and any other applicable taxes in their jurisdiction.
The Company does not provide tax advice. Users should consult with a qualified tax professional regarding their tax obligations.
The Company may be required to collect and remit applicable taxes in certain jurisdictions and will do so in accordance with Applicable Law.

12.7 Refunds and Reversals

Transactions initiated through the Services are generally final and irreversible once confirmed.
Refunds or reversals may be available in limited circumstances, such as:
- Transactions that could not be completed due to errors attributable to the Company.
- Transactions involving incorrect beneficiary information that result in non-delivery of funds.
- Transactions that are required to be reversed by Applicable Law or regulatory order.
Virtual currency Transactions are irreversible by their nature once broadcast to the applicable blockchain network. The Company cannot reverse or cancel a virtual currency Transaction once it has been confirmed on the blockchain.
Any approved refund will be processed to the original funding source, less any fees already incurred or network fees charged by third parties or blockchain networks.

13. Prohibition of Use

13.1 Prohibited Activities

You are strictly prohibited from using the Services, the Web Portal, or your FINTWIN Account in connection with any of the following activities (each a “Prohibited Activity”):

Money Laundering: Using the Services to conceal or disguise the nature, origin, location, disposition, movement, or ownership of funds or virtual currency that are the proceeds of crime.
Terrorist Financing: Using the Services to collect, provide, or transmit funds or virtual currency for the purpose of financing terrorism or terrorist activities.
Proliferation Financing: Using the Services to provide financial services in connection with the development, production, acquisition, or delivery of weapons of mass destruction or their means of delivery.
Sanctions Evasion: Using the Services to evade, circumvent, or facilitate the evasion of Sanctions imposed by Canada, the United Nations, the United States, the European Union, the United Kingdom, or any other applicable jurisdiction.
Fraud: Using the Services to perpetrate or facilitate any type of fraud, including identity fraud, investment fraud, advance-fee fraud, romance fraud, or business email compromise.
Tax Evasion: Using the Services to evade or facilitate the evasion of tax obligations in any jurisdiction.
Market Manipulation: Using the Services to manipulate the price or market for any currency or virtual currency.
Illegal Gambling: Using the Services in connection with illegal gambling, gaming, or lottery activities.
Illegal Goods and Services: Using the Services to purchase, sell, or facilitate the trade of illegal goods or services, including controlled substances, narcotics, weapons, explosives, child exploitation material, counterfeit goods, or stolen property.
Human Trafficking and Exploitation: Using the Services in connection with human trafficking, forced labour, or sexual exploitation.
Intellectual Property Infringement: Using the Services to facilitate the infringement of intellectual property rights, including copyright, trademark, or patent infringement.
Unauthorized Financial Services: Using the Services to provide unlicensed or unauthorized financial services to third parties.
Structuring (Smurfing): Deliberately breaking Transactions into smaller amounts to evade reporting thresholds or regulatory requirements.
Shell Company Activity: Using the Services through shell companies, nominees, or other structures designed to obscure the true identity of the beneficial owner or the purpose of the Transaction.
Darknet and Illicit Platforms: Using the Services in connection with transactions originating from or destined for darknet marketplaces, mixing/tumbling services, or other platforms primarily used for illicit purposes.

13.2 Consequences of Prohibited Activity

If the Company determines that you have engaged in, attempted to engage in, or facilitated any Prohibited Activity:

Your FINTWIN Account will be immediately suspended and may be permanently terminated.
Pending Transactions may be frozen, cancelled, or reversed.
The Company will file all required reports with FINTRAC and other relevant authorities, including Suspicious Transaction Reports (STRs), Terrorist Property Reports (TPRs), and any other reports required by Applicable Law.
The Company may disclose your Personal Information and Transaction records to law enforcement agencies, regulatory authorities, and other competent authorities as required or permitted by Applicable Law.
You may be subject to civil and/or criminal liability under Applicable Law.
The Company shall have no liability to you for any losses, damages, or costs arising from the suspension, termination, or freezing of your FINTWIN Account or Transactions in connection with a suspected Prohibited Activity.

14. Account Security

14.1 Security Measures

FINTWIN Pay implements the following security measures to protect your FINTWIN Account and personal information:

AES 256-bit Encryption: All data transmitted between your device and the Web Portal is encrypted using industry-standard AES 256-bit encryption.
Two-Factor Authentication (2FA): All Users are required to enable 2FA on their FINTWIN Account. 2FA is available via:
- SMS Verification: A one-time verification code sent to your registered mobile phone number.
- Authenticator Application: A time-based one-time password (TOTP) generated by a compatible authenticator application on your mobile device.
Real-Time Automated Transaction Monitoring: The Company employs automated systems to monitor Transactions in real-time for suspicious, fraudulent, or unauthorized activity.
Session Management: Automatic session timeout and account lockout mechanisms are in place to prevent unauthorized access.
Secure Password Requirements: Users must create passwords that meet the Company’s minimum complexity requirements.

14.2 Your Security Obligations

You are responsible for maintaining the security of your FINTWIN Account. You agree to:

Create a strong, unique password that is not used for any other online account or service.
Keep your login credentials (username, password, and 2FA codes) confidential and not share them with any third party.
Enable and maintain 2FA at all times.
Avoid writing down or storing your password in an unsecured location.
Log out of your FINTWIN Account after each session, especially when using shared, public, or unsecured devices or networks.
Immediately notify the Company through the support section of your FINTWIN Account or via live chat on our Web Portal if you suspect or become aware of any unauthorized access to or use of your FINTWIN Account.
Regularly monitor your FINTWIN Account activity and Transaction history for any unauthorized or suspicious activity.
Keep your device, operating system, and web browser up to date with the latest security patches and updates.
Use reputable antivirus and anti-malware software on your devices.

14.3 Unauthorized Access

In the event of suspected or confirmed unauthorized access to your FINTWIN Account, the Company will take immediate steps to secure your account, which may include suspending access, requiring a password reset, and initiating an investigation.
The Company is not liable for any losses or damages resulting from unauthorized access to your FINTWIN Account where such access was caused by your failure to maintain the security of your login credentials or comply with the security measures described in these Terms.
You agree to cooperate fully with the Company in any investigation relating to unauthorized access to your FINTWIN Account.

14.4 Phishing and Social Engineering

The Company will never ask you for your password, 2FA codes, or private cryptocurrency wallet keys via email, live chat, or any other communication channel.
If you receive any communication purporting to be from FINTWIN Pay that requests your password, 2FA codes, or private keys, do not respond and immediately report it through the support section of your FINTWIN Account or via live chat on our Web Portal.
The Company is not responsible for losses resulting from phishing attacks, social engineering, or other schemes where you voluntarily disclose your credentials to a third party.

15. Trademarks and Intellectual Property Rights

15.1 Ownership

All intellectual property rights in and to the Web Portal, the Services, and all associated content, materials, software, logos, trademarks, service marks, trade names, designs, graphics, text, data, and other proprietary elements (collectively, “Company IP”) are owned by or licensed to FIN TWIN TECHNOLOGIES INC. and are protected by Canadian and international intellectual property laws, including the Copyright Act (R.S.C., 1985, c. C-42), the Trademarks Act (R.S.C., 1985, c. T-13), and applicable international treaties.

15.2 Trademarks

The following trademarks and trade names are owned by FIN TWIN TECHNOLOGIES INC.:

FINTWIN
FINTWIN Pay
FIN TWIN TECHNOLOGIES
The FINTWIN Pay logo and design marks

These trademarks may not be used, reproduced, or displayed without the prior written consent of the Company.

15.3 Limited Licence

Subject to your compliance with these Terms, the Company grants you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to access and use the Web Portal and the Services solely for your personal or internal business purposes, as applicable. This licence does not include the right to:

Copy, modify, distribute, sell, lease, sublicense, or create derivative works of any Company IP.
Reverse engineer, decompile, disassemble, or otherwise attempt to derive the source code of any software used in the Web Portal or the Services.
Use the Company’s trademarks, logos, or other proprietary designations without prior written authorization.
Frame, mirror, or otherwise incorporate the Web Portal or any portion thereof into any other website or application.
Use any data mining, robots, scraping, or similar automated data gathering or extraction tools on the Web Portal.

15.4 User Content

If you submit, upload, or transmit any content to the Web Portal (including Transaction instructions, messages, or feedback), you grant the Company a non-exclusive, royalty-free, worldwide, perpetual licence to use, process, store, and transmit such content for the purpose of providing the Services and complying with Applicable Law.
You represent and warrant that any content you submit does not infringe the intellectual property rights or other rights of any third party.

15.5 Copyright Infringement

If you believe that any content on the Web Portal infringes your copyright or intellectual property rights, please contact us through the support section of your FINTWIN Account or via live chat on our Web Portal with the following information:

A description of the copyrighted work or intellectual property you claim is infringed.
A description of the location of the allegedly infringing material on the Web Portal.
Your contact information (name, address, phone number).
A statement that you have a good-faith belief that the use is not authorized by the intellectual property owner, its agent, or the law.
A statement that the information in the notification is accurate and that you are authorized to act on behalf of the intellectual property owner.

16. Privacy Notice

16.1 Commitment to Privacy

FIN TWIN TECHNOLOGIES INC. is committed to protecting the privacy and security of your Personal Information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and all other Applicable Law relating to data protection and privacy.

16.2 Privacy Policy

Our collection, use, disclosure, and protection of your Personal Information is governed by our Privacy Policy, available at https://fintwinpay.com/privacy. The Privacy Policy forms an integral part of these Terms and is incorporated herein by reference.

16.3 Collection of Personal Information

We collect Personal Information from you for the following purposes:

To verify your identity and comply with KYC, CDD, and AML requirements under the PCMLTFA and applicable FINTRAC guidance.
To provide, maintain, and improve the Services.
To process Transactions and communicate with you regarding your FINTWIN Account and Transactions.
To detect, prevent, and investigate fraud, money laundering, terrorist financing, and other illegal activities.
To comply with Applicable Law, including regulatory reporting obligations.
To enforce these Terms and protect the rights, property, and safety of the Company, its Users, and others.

16.4 Third-Party Data Processors

We share your Personal Information with the following third-party service providers for the purposes described in our Privacy Policy:

Sumsub (United Kingdom) — KYC, identity verification, and Travel Rule compliance services.
OpenSanctions (Germany) — Sanctions and PEP screening.
Scorechain (Luxembourg) — Blockchain analytics and AML compliance.
Fireblocks (United States) — Digital asset custody and transfers.
Reload dev s.r.o. (Beekeeper) (Czech Republic) — Core payment platform infrastructure.

All third-party data processors are contractually bound to process your Personal Information in accordance with Applicable Law and our Privacy Policy.

16.5 Cross-Border Data Transfers

Your Personal Information may be transferred to, stored, and processed in jurisdictions outside of Canada, including the United Kingdom, the European Union, the United States, the Czech Republic, Luxembourg, and Germany. Such transfers are conducted in compliance with PIPEDA and are subject to appropriate contractual and technical safeguards.

16.6 Data Retention

We retain your Personal Information for as long as necessary to fulfil the purposes for which it was collected, to comply with Applicable Law, and to protect our legal interests. Specific retention periods are set out in Section 25.7 of these Terms and in our Privacy Policy.

16.7 Your Privacy Rights

Under PIPEDA, you have the right to:

Access the Personal Information we hold about you.
Request the correction of inaccurate or incomplete Personal Information.
Withdraw your consent to the collection, use, or disclosure of your Personal Information, subject to legal and contractual limitations.
File a complaint with the Office of the Privacy Commissioner of Canada if you believe your privacy rights have been violated.

To exercise any of these rights, please contact us through the support section of your FINTWIN Account or via live chat on our Web Portal.

17. Linking and Third-Party Services

17.1 Third-Party Links

The Web Portal may contain hyperlinks to third-party websites, services, or resources that are not owned, operated, or controlled by the Company. These links are provided for informational or convenience purposes only.

17.2 No Endorsement

The inclusion of any link to a third-party website or service on the Web Portal does not constitute an endorsement, recommendation, or approval by the Company of such website, service, or its content.

17.3 Third-Party Terms

Your use of any third-party website or service is subject to the terms and conditions and privacy policies of that third party. The Company is not a party to and assumes no responsibility for any agreement between you and any third party.

17.4 No Liability

The Company is not responsible or liable for:

The content, accuracy, opinions, reliability, or policies of any third-party website or service.
Any loss or damage arising from your use of or reliance on any third-party website, service, or content.
The privacy practices, data collection, or security measures of any third party.

17.5 Third-Party Service Providers

The Company utilizes the following third-party service providers in connection with the delivery of the Services:

Provider	Service	Jurisdiction
Reload dev s.r.o. (Beekeeper)	Core payment platform	Czech Republic
Sumsub	KYC/Identity verification, Travel Rule	United Kingdom
OpenSanctions	Sanctions/PEP screening	Germany
Scorechain	Blockchain analytics/AML	Luxembourg
Fireblocks	Digital asset custody/transfers	United States

The Company exercises due diligence in selecting and monitoring its third-party service providers but does not guarantee the performance, availability, or security of their services. The Company is not liable for any loss or damage arising from the acts or omissions of its third-party service providers, except where such loss or damage results directly from the Company’s own negligence or breach of these Terms.

18. Restricted Locations

18.1 Sanctions and Restricted Jurisdictions

FINTWIN Pay does not provide Services to, or facilitate Transactions involving, individuals, entities, or jurisdictions that are subject to comprehensive Sanctions or that are designated as high-risk by the Company. This includes the following jurisdictions (the “Restricted Locations”):

Countries subject to comprehensive Canadian sanctions: As designated under the Special Economic Measures Act (S.C. 1992, c. 17), the Justice for Victims of Corrupt Foreign Officials Act (S.C. 2017, c. 21), and the United Nations Act (R.S.C., 1985, c. U-2), including:
- Belarus
- Central African Republic
- Cuba
- Democratic People’s Republic of Korea (North Korea)
- Democratic Republic of the Congo
- Eritrea
- Haiti
- Iran
- Iraq
- Lebanon
- Libya
- Mali
- Myanmar (Burma)
- Nicaragua
- Russia
- Somalia
- South Sudan
- Sudan
- Syria
- Venezuela
- Yemen
- Zimbabwe
Countries subject to OFAC comprehensive sanctions programs: Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions of Ukraine.
Jurisdictions identified as high-risk by FATF: As listed in the FATF’s “High-Risk Jurisdictions subject to a Call for Action” and “Jurisdictions under Increased Monitoring” lists, as updated from time to time.

18.2 Updates to Restricted Locations

The list of Restricted Locations is subject to change based on updates to Sanctions programs, FATF designations, and the Company’s internal risk assessments. The Company will update the list of Restricted Locations on the Web Portal as changes occur.

18.3 User Responsibility

You are responsible for ensuring that your use of the Services complies with all applicable Sanctions and that you do not use the Services to send funds or virtual currency to or from any Restricted Location. If your jurisdiction of residence becomes a Restricted Location, you must immediately cease using the Services and contact the Company.

18.4 VPN and Location Masking

The use of virtual private networks (VPNs), proxy servers, or other tools to mask your true location or IP address in order to access the Services from a Restricted Location is strictly prohibited and constitutes a material breach of these Terms.

19. Disclaimer of Warranties

19.1 General Disclaimer

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE WEB PORTAL, THE SERVICES, AND ALL CONTENT, MATERIALS, INFORMATION, AND FUNCTIONALITY PROVIDED THEREIN ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE.

19.2 Specific Disclaimers

THE COMPANY EXPRESSLY DISCLAIMS ALL WARRANTIES, INCLUDING:

IMPLIED WARRANTIES OF MERCHANTABILITY — No warranty that the Services are of merchantable quality or fit for any particular purpose.
IMPLIED WARRANTIES OF FITNESS FOR A PARTICULAR PURPOSE — No warranty that the Services will meet your specific requirements or expectations.
WARRANTIES OF NON-INFRINGEMENT — No warranty that the Web Portal or the Services do not infringe the intellectual property rights of any third party.
WARRANTIES OF ACCURACY — No warranty that the information, data, exchange rates, or other content on the Web Portal is accurate, complete, reliable, or current.
WARRANTIES OF AVAILABILITY — No warranty that the Web Portal or the Services will be available uninterrupted, timely, secure, or error-free.
WARRANTIES AGAINST HARMFUL COMPONENTS — No warranty that the Web Portal is free from viruses, malware, or other harmful components.

19.3 Virtual Currency Risk Disclaimer

WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, THE COMPANY MAKES NO WARRANTIES REGARDING:

The value, stability, or future performance of any virtual currency, including BTC, ETH, USDT, and USDC.
The regulatory treatment of virtual currencies in any jurisdiction.
The security, reliability, or availability of any blockchain network.
The irreversibility or finality of virtual currency Transactions.
The risk of loss, theft, or unauthorized access to virtual currency.

YOU ACKNOWLEDGE THAT VIRTUAL CURRENCIES ARE HIGHLY VOLATILE AND SPECULATIVE, AND THAT YOU MAY LOSE SOME OR ALL OF THE VALUE OF YOUR VIRTUAL CURRENCY. THE COMPANY IS NOT RESPONSIBLE FOR ANY SUCH LOSSES.

19.4 No Guarantee of Transaction Completion

THE COMPANY DOES NOT GUARANTEE THAT ANY TRANSACTION WILL BE COMPLETED WITHIN A SPECIFIC TIMEFRAME OR AT ALL. TRANSACTIONS MAY BE DELAYED, SUSPENDED, OR CANCELLED DUE TO COMPLIANCE REQUIREMENTS, NETWORK CONGESTION, THIRD-PARTY PROCESSING DELAYS, OR OTHER FACTORS BEYOND THE COMPANY'S REASONABLE CONTROL.

20. Limitation of Liability

20.1 General Limitation

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL FIN TWIN TECHNOLOGIES INC., ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, AFFILIATES, SUCCESSORS, OR ASSIGNS (COLLECTIVELY, THE "FINTWIN PARTIES") BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY:

INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, including damages for loss of profits, loss of revenue, loss of business, loss of goodwill, loss of data, loss of virtual currency, or loss of opportunity, however caused and regardless of the theory of liability (whether in contract, tort, negligence, strict liability, or otherwise), even if the FINTWIN Parties have been advised of the possibility of such damages.
LOSSES ARISING FROM OR IN CONNECTION WITH:
- Your use of or inability to use the Web Portal or the Services.
- Unauthorized access to or alteration of your data, Transactions, or FINTWIN Account.
- Any failure, delay, or error in the processing, transmission, or settlement of any Transaction.
- Fluctuations in exchange rates (fiat or virtual currency) between the time of Transaction initiation and settlement.
- Actions taken by intermediary banks, correspondent banks, beneficiary financial institutions, or blockchain networks.
- Actions taken by the Company to comply with Applicable Law, including the freezing, suspension, or termination of accounts or Transactions.
- Any force majeure event (see Section 20.4).
- The acts or omissions of third-party service providers.

20.2 Maximum Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE TOTAL AGGREGATE LIABILITY OF THE FINTWIN PARTIES TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THESE TERMS, THE SERVICES, OR THE WEB PORTAL SHALL NOT EXCEED THE LESSER OF:

The total fees paid by you to the Company in the twelve (12) months immediately preceding the event giving rise to the claim; or
One Thousand Canadian Dollars (CAD $1,000).

20.3 Essential Basis of the Bargain

YOU ACKNOWLEDGE AND AGREE THAT THE LIMITATIONS OF LIABILITY SET FORTH IN THIS SECTION 20 ARE AN ESSENTIAL ELEMENT OF THE BARGAIN BETWEEN YOU AND THE COMPANY, AND THAT THE COMPANY WOULD NOT PROVIDE THE SERVICES WITHOUT THESE LIMITATIONS. THESE LIMITATIONS SHALL APPLY NOTWITHSTANDING ANY FAILURE OF ESSENTIAL PURPOSE OF ANY LIMITED REMEDY.

20.4 Force Majeure

The Company shall not be liable for any failure to perform, delay, or disruption of the Services caused by circumstances beyond its reasonable control, such as:

Acts of God, natural disasters, pandemics, or epidemics.
War, armed conflict, terrorism, sanctions, or government actions.
Cyberattacks, distributed denial-of-service (DDoS) attacks, or other security incidents.
Failure of telecommunications, internet, power supply, or other infrastructure.
Strikes, labour disputes, or industrial action.
Changes in Applicable Law, regulations, or regulatory guidance.
Failures or disruptions of third-party service providers, payment networks, or blockchain networks.

21. Indemnity

21.1 Indemnification Obligation

You agree to indemnify, defend, and hold harmless FIN TWIN TECHNOLOGIES INC. and the FINTWIN Parties from and against any and all claims, actions, suits, proceedings, losses, liabilities, damages, costs, and expenses (including reasonable legal fees and disbursements) arising out of or in connection with:

Your use of or access to the Web Portal or the Services.
Your breach of any provision of these Terms.
Your violation of any Applicable Law.
Your breach of any representation or warranty made under these Terms.
Any Transaction initiated by you or through your FINTWIN Account.
Any allegation that your use of the Services infringes the intellectual property rights or other rights of any third party.
Any claim by a third party arising from or related to your use of the Services.
Your engagement in any Prohibited Activity.
Any inaccurate, misleading, or incomplete information provided by you.

21.2 Defence and Settlement

The Company reserves the right, at your expense, to assume the exclusive defence and control of any matter for which you are required to indemnify the Company.
You agree to cooperate fully with the Company in the defence of any such claim.
You may not settle any claim without the Company’s prior written consent.

21.3 Survival

The indemnification obligations set forth in this Section 21 shall survive the termination or expiration of these Terms and the closure of your FINTWIN Account.

22. Governing Law and Jurisdiction

22.1 Governing Law

These Terms and any dispute, claim, or controversy arising out of or relating to these Terms, the Services, or the Web Portal (whether in contract, tort, or otherwise) shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to conflict of law principles.

22.2 Jurisdiction

You irrevocably submit to the exclusive jurisdiction of the courts of the Province of Ontario, located in the Regional Municipality of Waterloo or the City of Toronto, for the purpose of any suit, action, or proceeding arising out of or relating to these Terms, the Services, or the Web Portal.

22.3 Waiver of Jury Trial

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, EACH PARTY HEREBY IRREVOCABLY WAIVES ANY AND ALL RIGHTS TO A TRIAL BY JURY IN ANY ACTION, SUIT, OR PROCEEDING ARISING OUT OF OR RELATING TO THESE TERMS, THE SERVICES, OR THE WEB PORTAL.

22.4 Class Action Waiver

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, YOU AGREE THAT ANY DISPUTE, CLAIM, OR CONTROVERSY ARISING OUT OF OR RELATING TO THESE TERMS WILL BE RESOLVED ON AN INDIVIDUAL BASIS, AND YOU WAIVE ANY RIGHT TO PARTICIPATE IN A CLASS ACTION, CLASS ARBITRATION, OR OTHER REPRESENTATIVE OR CONSOLIDATED PROCEEDING.

22.5 Limitation Period

Any claim or cause of action arising out of or relating to these Terms, the Services, or the Web Portal must be commenced within one (1) year after the cause of action accrues, unless a longer period is required by Applicable Law. Failure to commence an action within this period constitutes a waiver of such claim.

23. Waiver and Severability

23.1 No Waiver

The failure of the Company to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision.
No waiver of any provision of these Terms shall be effective unless made in writing and signed by an authorized representative of the Company.
A waiver of any right or provision on one occasion shall not be deemed a waiver of such right or provision on any subsequent occasion.
The exercise or enforcement by the Company of any right or remedy under these Terms shall not preclude the enforcement of any other right or remedy.

23.2 Severability

If any provision of these Terms is held to be invalid, illegal, void, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, or if modification is not possible, such provision shall be severed from these Terms.
The invalidity or unenforceability of any provision shall not affect the validity or enforceability of the remaining provisions, which shall continue in full force and effect.
If any provision is held to be excessively broad in scope, duration, or area of applicability, it shall be construed by limiting and reducing it to the minimum extent necessary to be enforceable under Applicable Law.

24. Entire Agreement

24.1 Entire Agreement

These Terms, together with the Privacy Policy, the Fee Schedule, the AML Policy, and any other supplementary terms, policies, or notices published on the Web Portal or otherwise communicated to you in writing, constitute the entire agreement between you and FIN TWIN TECHNOLOGIES INC. with respect to the subject matter hereof. They supersede all prior or contemporaneous oral or written agreements, understandings, representations, and warranties relating to such subject matter.

24.2 Hierarchy of Documents

In the event of any conflict or inconsistency between these Terms and any other document forming part of the agreement between you and the Company, the following hierarchy shall apply (in descending order of priority):

Applicable Law and regulatory requirements.
These Terms of Use.
The Privacy Policy.
The Fee Schedule.
Any other supplementary terms, policies, or notices.

24.3 No Third-Party Beneficiaries

These Terms are entered into solely between you and FIN TWIN TECHNOLOGIES INC. Nothing in these Terms shall create or confer any rights or benefits on any third party, except as expressly provided herein or as required by Applicable Law.

24.4 Assignment

You may not assign, transfer, or delegate your rights or obligations under these Terms to any third party without the prior written consent of the Company.
The Company may assign, transfer, or delegate its rights and obligations under these Terms, in whole or in part, to any affiliate, successor, or acquirer of all or substantially all of the Company’s business or assets, without your prior consent, provided that such assignee agrees to be bound by these Terms.

24.5 Headings

The headings and section titles in these Terms are for convenience of reference only and shall not affect the interpretation or construction of these Terms.

25. Client Due Diligence and AML Compliance

25.1 Regulatory Obligations

FIN TWIN TECHNOLOGIES INC. is a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and is required to establish and maintain a comprehensive compliance program that includes:

The appointment of a Chief Compliance Officer.
Written compliance policies and procedures, including a risk assessment methodology.
An ongoing compliance training program for all employees and agents.
An independent review of the compliance program at least every two (2) years.
Record-keeping in accordance with the PCMLTFA and its Regulations.

25.2 Know Your Client (KYC)

As a registered MSB, the Company is required to verify the identity of all Users before establishing a business relationship or processing Transactions. The Company’s KYC procedures include:

Individual Clients:
- Verification of the client’s full legal name, date of birth, and residential address using reliable, independent source documents (government-issued photo identification, proof of address).
- Verification of the client’s identity through the Company’s third-party identity verification provider, Sumsub.
- Collection of additional information, including occupation, employer, source of funds, and intended use of the Services.
Corporate Clients:
- Verification of the entity’s legal existence, corporate structure, and registered address.
- Identification and verification of all directors, officers, authorized signatories, and beneficial owners (individuals who directly or indirectly own or control 25% or more of the entity).
- Collection of articles of incorporation, certificate of status, partnership agreements, trust deeds, beneficial ownership declarations, and other organizational documents.
Virtual Currency Clients:
- Collection and verification of external wallet addresses used for cryptocurrency deposits.
- Blockchain analytics screening using Scorechain to assess the risk associated with external wallets and virtual currency sources.
- Application of the Travel Rule for virtual currency transfers through Sumsub, in accordance with FINTRAC guidance, requiring the collection and transmission of originator and beneficiary information.

25.3 Enhanced Due Diligence (EDD)

Enhanced Due Diligence measures are applied to higher-risk clients, including:

Politically Exposed Persons (PEPs): Individuals who hold or have held prominent public functions, their family members, and close associates.
Clients from higher-risk jurisdictions: Countries identified as higher risk based on FATF mutual evaluations, Transparency International’s Corruption Perceptions Index, or the Company’s internal risk assessment.
High-value Transactions: Transactions exceeding established thresholds, as determined by the Company’s risk-based approach.
Complex or unusual Transaction patterns: Transactions that do not have an apparent economic or lawful purpose.

EDD measures may include:

Obtaining senior management approval for the business relationship.
Conducting additional source of funds and source of wealth verification.
Implementing ongoing enhanced monitoring of the business relationship and Transactions.
Requiring face-to-face or video verification.

25.4 Sanctions and PEP Screening

All Users and their Transactions are screened against applicable Sanctions lists and PEP databases at the time of account opening, at the time of each Transaction, and on an ongoing basis.
Sanctions and PEP screening is conducted using OpenSanctions and the Company’s internal screening tools.
If a match is identified, the Company will take appropriate action, which may include blocking the Transaction, freezing the account, filing reports with FINTRAC, and notifying relevant authorities.

25.5 Transaction Monitoring

The Company maintains a real-time automated transaction monitoring system designed to detect unusual, suspicious, or potentially non-compliant Transactions.
Transactions are monitored against predefined rules and scenarios based on the Company’s risk assessment, regulatory requirements, and industry practices.
Alerts generated by the monitoring system are reviewed by the Company’s compliance team and escalated as appropriate.
The Company files Suspicious Transaction Reports (STRs) with FINTRAC whenever there are reasonable grounds to suspect that a Transaction is related to money laundering, terrorist financing, or other illegal activity.

25.6 Reporting Obligations

In accordance with the PCMLTFA and its Regulations, the Company is required to file the following reports with FINTRAC:

Suspicious Transaction Reports (STRs): When there are reasonable grounds to suspect that a Transaction is related to money laundering or terrorist financing.
Terrorist Property Reports (TPRs): When the Company is in possession or control of property owned or controlled by or on behalf of a listed person or entity under the Criminal Code or the Regulations Implementing the United Nations Resolutions on the Suppression of Terrorism.
Large Cash Transaction Reports (LCTRs): For cash Transactions of CAD $10,000 or more (or equivalent in any other currency). Note: FINTWIN Pay does not accept cash; however, this obligation is acknowledged for completeness.
Large Virtual Currency Transaction Reports (LVCTRs): For virtual currency Transactions of CAD $10,000 or more (or equivalent).
Electronic Funds Transfer Reports (EFTRs): For international electronic funds transfers of CAD $10,000 or more (or equivalent).
Sanctions-related reports as required under the Special Economic Measures Act, the Justice for Victims of Corrupt Foreign Officials Act, and the United Nations Act.

25.7 Record Retention

The Company maintains records in accordance with the PCMLTFA and its Regulations. The following minimum retention periods apply:

Client identification records: A minimum of five (5) years from the date the business relationship ends.
Transaction records: A minimum of five (5) years from the date of the Transaction.
STRs and other FINTRAC reports: A minimum of five (5) years from the date the report is filed.
Compliance program documentation: A minimum of five (5) years from the date the document was created or last updated.
Complaint records: A minimum of seven (7) years from the date the complaint is resolved (see Section 26).
Financial records: A minimum of five (5) years from the date of the record, or such longer period as required by Applicable Law.

All records are stored securely in compliance with PIPEDA and the Company’s information security policies.

25.8 User Cooperation

You agree to cooperate fully with the Company’s KYC, CDD, EDD, and AML procedures, including:

Providing all requested documentation and information promptly and accurately.
Responding to inquiries from the Company’s compliance team regarding your Transactions or business relationship.
Refraining from any activity intended to circumvent, avoid, or obstruct the Company’s compliance procedures.

Failure to cooperate with the Company’s compliance procedures may result in the suspension or termination of your FINTWIN Account and the blocking or reversal of Transactions.

26. Dispute Resolution

26.1 Internal Complaint Resolution Process

FIN TWIN TECHNOLOGIES INC. is committed to resolving client complaints fairly, promptly, and transparently. If you have a complaint regarding the Services, your FINTWIN Account, or any Transaction, you may initiate the complaint resolution process as follows:

Step 1: Submit a Complaint

All complaints must be submitted in writing through the support section of your FINTWIN Account or via live chat on our Web Portal.
Your complaint should include:
- Your full name and FINTWIN Account identifier.
- A clear and detailed description of the issue or concern.
- The date(s) and amount(s) of any relevant Transaction(s).
- Any supporting documentation or evidence.
- The resolution or remedy you are seeking.

Step 2: Acknowledgment

The Company will acknowledge receipt of your complaint within two (2) Business Days of receipt.
You will be assigned a unique complaint reference number for tracking purposes.
A designated complaint handler will be assigned to manage your complaint.

Step 3: Investigation and Resolution

The Company will conduct a thorough and impartial investigation of your complaint.
The Company will endeavour to resolve your complaint within fifteen (15) Business Days of receipt.
If the complaint cannot be resolved within fifteen (15) Business Days due to the complexity of the matter or the need for additional information, the Company will notify you in writing of the delay and the expected resolution timeframe.
In no event shall the resolution period exceed thirty-five (35) Business Days from the date of receipt of the complaint, unless an extension is agreed upon by both parties in writing.

Step 4: Final Response

Upon completion of the investigation, the Company will provide you with a written final response that includes:
- A summary of the complaint.
- The Company’s decision and the reasons for it.
- Any remedy or corrective action to be taken.
- Information about escalation options if you are not satisfied with the resolution.

26.2 Escalation to External Bodies

If you are not satisfied with the Company’s final response, or if the Company fails to respond within the timelines set out above, you may escalate your complaint to the following external bodies:

Bank of Canada — For complaints relating to the Company’s obligations under the Retail Payment Activities Act (RPAA):
- Website: https://www.bankofcanada.ca
FINTRAC — For complaints relating to the Company’s obligations under the PCMLTFA:
- Website: https://www.fintrac-canafe.gc.ca
Office of the Privacy Commissioner of Canada — For complaints relating to the handling of your Personal Information under PIPEDA:
- Website: https://www.priv.gc.ca
Ontario Ministry of Public and Business Service Delivery — For complaints relating to the Company’s obligations under the Ontario Business Corporations Act or consumer protection legislation:
- Website: https://www.ontario.ca/page/ministry-public-business-service-delivery

26.3 Mediation

Before commencing any formal legal proceedings, the parties agree to attempt to resolve any dispute through mediation administered by a mutually agreed-upon mediator in the Province of Ontario. The costs of mediation shall be shared equally between the parties unless otherwise agreed. If the dispute is not resolved through mediation within sixty (60) days of the appointment of the mediator, either party may proceed with formal legal proceedings.

26.4 Complaint Records

The Company maintains detailed records of all complaints received, including the nature of the complaint, the investigation process, the resolution, and any remedial actions taken.
Complaint records are retained for a minimum of seven (7) years from the date the complaint is resolved, in accordance with Applicable Law and the Company’s record-retention policies.

26.5 No Retaliation

The Company will not retaliate against any User for submitting a complaint in good faith. Filing a complaint will not adversely affect your FINTWIN Account or access to the Services, except where the complaint reveals information that requires the Company to take action under these Terms or Applicable Law.

27. Contact Information

27.1 General Inquiries and Support

For general inquiries, account support, or service-related questions:

Through the support section of your FINTWIN Account or via live chat on our Web Portal (available 24/7)
Live Chat: Available in real-time during business hours through the FINTWIN Pay Web Portal at https://fintwinpay.com

27.2 Complaints

To submit a formal complaint:

Contact us through the support section of your FINTWIN Account or via live chat on our Web Portal.
Please include “COMPLAINT” in the subject line of your message for priority routing.

27.3 Privacy Inquiries

For questions or requests relating to your Personal Information or the Company’s privacy practices:

Contact us through the support section of your FINTWIN Account or via live chat on our Web Portal.
Please include “PRIVACY” in the subject line of your message.

27.4 Registered Office

FIN TWIN TECHNOLOGIES INC.
1025 King Street East, Unit 107-1587
Cambridge, Ontario, N3H 3P5
Canada

27.5 Regulatory Registration

FINTRAC MSB Registration Number: C10001675
Ontario Corporation Number: 1001472662

27.6 Business Hours

Support: 24 hours a day, 7 days a week
Live Chat Support: During business hours (Eastern Time, Monday to Friday, excluding Ontario statutory holidays)

FINTWIN Pay does not offer telephone support. All inquiries must be submitted through the support section of your FINTWIN Account or via live chat.

Acknowledgment and Acceptance

By creating a FINTWIN Account, accessing the Web Portal, or using any of the Services, you acknowledge that you have read, understood, and agree to be bound by these Terms of Use in their entirety.

If you do not agree to these Terms of Use, you must not access the Web Portal or use any of the Services.

Version	Effective Date	Approved By
1.0	February 2, 2026	Pavel Martynov, Director

Signed:

Pavel Martynov
Director
FIN TWIN TECHNOLOGIES INC.
February 2, 2026