Terms of Use

1. Introduction

Welcome to Control Money (“Control Money”, “we”, “our”, or “us”).

These Terms of Use (“Terms”) govern your access to and use of the Control Money platform, including our website, mobile applications, APIs, software, and all related services (collectively, the Platform).

The Platform enables eligible users to:

• complete identity verification;
• fund their account through approved payment partners;
• hold supported digital assets;
• earn yield on eligible digital assets where offered;
• invest in supported tokenized financial products;
• redeem virtual assets;
• withdraw eligible balances to verified bank accounts; and
• access other products and services introduced from time to time.

These Terms constitute a legally binding agreement between you and Control Money.

By accessing or using the Platform, you acknowledge that you have read, understood and agree to be bound by these Terms.

If you do not agree, you must not access or use the Platform.

2. Regulatory Status

Control Money is a technology platform that facilitates access to digital asset infrastructure and investment products through regulated and licensed third-party service providers.

Control Money is not:

• a bank;
• a deposit-taking institution;
• an exchange recognised by any securities regulator unless expressly stated;
• an investment adviser;
• a portfolio manager;
• a broker-dealer;
• a mutual fund; or
• a fiduciary.

Certain services are provided through regulated partners, including but not limited to:

• KYC providers;
• payment service providers;
• FIU-registered Virtual Asset Service Providers (VASPs);
• custodians;
• wallet infrastructure providers;
• liquidity providers;
• token issuers;
• market makers; and
• other regulated financial institutions.

Where applicable, additional terms imposed by such partners shall also apply.

3. Eligibility

You may use the Platform only if you satisfy all of the following conditions:

3.1 Individual Users

You must:

• be at least eighteen (18) years old;
• possess full legal capacity;
• complete identity verification;
• maintain an active bank account in your own name where required;
• comply with applicable laws;
• not appear on any sanctions or prohibited persons list.

3.2 Entity Accounts

Business accounts may be permitted subject to separate onboarding requirements.

Control Money may request:

• incorporation documents;
• beneficial ownership information;
• board resolutions;
• tax registrations;
• authorised signatory information; and
• any additional documentation required for compliance purposes.

3.3 Restricted Users

The Platform may not be used by:

• sanctioned individuals;
• politically exposed persons where onboarding is declined following risk assessment;
• residents of prohibited jurisdictions;
• persons involved in money laundering, terrorism financing or other unlawful activity;
• persons acting on behalf of undisclosed third parties; or
• any person whom Control Money determines presents unacceptable legal, regulatory or commercial risk.

Eligibility may change at any time due to changes in applicable law or our risk policies.

4. Definitions

For purposes of these Terms:

Account means your registered user account on the Platform.

Applicable Law means all laws, regulations, governmental notifications, circulars, directives and judicial decisions applicable to the Platform or your use of it.

Digital Asset means any supported blockchain-based asset made available through the Platform.

Stablecoin means a supported digital asset designed to maintain value relative to one or more reference assets.

Digital Dollars refer to USDC/USDT, the supported U.S. dollar-denominated stablecoin accepted by the Platform from time to time.

USDY means the supported yield-bearing digital asset made available through the Platform.

Tokenized Asset means a blockchain-based representation of an underlying financial asset made available through the Platform, including supported tokenized exchange traded funds and tokenized equity securities.

Wallet means the blockchain wallet associated with your verified account through approved custody or wallet infrastructure providers.

Yield means any return generated by eligible digital assets under applicable product terms. Yield is not guaranteed and may vary over time.

Capitalised terms not defined in these Terms shall have the meaning assigned elsewhere in these Terms or in any applicable Product Terms.

5. Acceptance of Terms

By creating an Account, accessing the Platform, or using any Service, you represent and warrant that:

• you have the legal authority to enter into these Terms;
• all information provided by you is accurate and complete;
• you will promptly update any information that changes;
• you will comply with all applicable laws;
• you understand the risks associated with digital assets and tokenized financial products; and
• you accept these Terms and all policies incorporated by reference.

If you are accepting these Terms on behalf of a legal entity, you represent that you have authority to bind that entity.

6. Amendments

Control Money may amend these Terms from time to time to reflect:

• changes in applicable law;
• regulatory guidance;
• product enhancements;
• operational changes;
• risk management requirements; or
• updates to third-party service providers.

Where required by law, we will provide reasonable notice before material changes become effective.

Your continued use of the Platform after the effective date of revised Terms constitutes acceptance of the updated Terms.

If you do not agree to the revised Terms, you must discontinue use of the Platform and close your Account in accordance with these Terms.

7. Order of Precedence

If there is any inconsistency between these Terms and any Product Terms, the following order shall apply:

1. Applicable Law;
2. Product-Specific Terms;
3. These Terms;
4. Policies published by Control Money;
5. Website content and marketing materials.

Marketing content is provided for informational purposes only and does not modify these Terms.

8. User Accounts

8.1 Account Registration

To access the Platform, you must create a Control Money Account.

You agree to provide accurate, complete, and current information during registration and throughout your use of the Platform.

You acknowledge that inaccurate or misleading information may result in suspension or termination of your Account.

8.2 One Account Per User

Unless expressly authorised by Control Money in writing:

• each individual may maintain only one personal Account;
• Accounts may not be transferred, sold, leased, or shared;
• multiple Accounts created to circumvent Platform rules may be suspended or closed.

Control Money reserves the right to merge, suspend or terminate duplicate Accounts.

8.3 Account Ownership

The registered user is deemed to be the legal owner of the Account.

You may not:

• create an Account on behalf of another individual without lawful authority;
• permit another person to operate your Account;
• lend, rent or transfer your Account credentials.

8.4 Account Information

You must promptly update any change relating to:

• legal name;
• residential address;
• email address;
• mobile number;
• tax residency;
• bank account details;
• citizenship;
• beneficial ownership (where applicable); or
• any information relevant to regulatory compliance.

Failure to maintain accurate information may restrict access to the Platform.

9. Identity Verification (Know Your Customer)

9.1 Mandatory Verification

Access to financial services offered through the Platform is subject to successful completion of identity verification (“KYC”).

Control Money may conduct verification directly or through authorised third-party verification providers.

9.2 Continuing Due Diligence

Identity verification is an ongoing process.

Control Money may periodically require you to:

• re-confirm personal information;
• provide updated documentation;
• complete additional verification;
• answer compliance questionnaires; or
• explain specific transactions.

Failure to cooperate may result in restrictions on your Account.

10. Anti-Money Laundering & Compliance Screening

All users are subject to compliance screening before and during use of the Platform.

Control Money reserves the right to delay, reject, suspend or report transactions where required under Applicable Law.

11. Bank Account Verification

Users may only deposit funds from and withdraw funds to bank accounts held in their own legal name unless otherwise permitted.

Control Money may verify bank ownership through:

• penny-drop verification;
• account validation services;
• payment service providers;
• documentary evidence; or
• other verification methods.

Joint accounts, third-party accounts or business accounts may be accepted only where specifically approved.

12. Account Security

12.1 User Responsibilities

You are responsible for maintaining the confidentiality of:

• passwords;
• PINs;
• one-time passwords (OTPs);
• authentication devices;
• passkeys;
• recovery methods; and
• all credentials associated with your Account.

You must not disclose authentication credentials to any third party.

12.2 Security Notifications

You must immediately notify Control Money if you become aware of:

• unauthorised access;
• loss of a mobile device;
• phishing attempts;
• compromised credentials;
• suspicious transactions; or
• any security incident affecting your Account.

12.3 Multi-Factor Authentication

Control Money may require multi-factor authentication (“MFA”) for:

• login;
• withdrawals;
• device changes;
• password resets;
• security changes; and
• high-risk transactions.

Failure to complete required authentication may prevent access to certain Services.

13. Wallet Services

13.1 Wallet Creation

Following successful verification, an eligible user may be assigned a blockchain wallet through an approved wallet infrastructure or custody provider.

The wallet is linked to your verified identity for regulatory and operational purposes.

Wallet creation does not constitute a bank account or deposit account.

13.2 Custody Infrastructure

Control Money may utilise one or more regulated custody or wallet technology providers.

Such providers may change over time without affecting these Terms.

Control Money may migrate wallet infrastructure where reasonably necessary for:

• security;
• operational efficiency;
• regulatory compliance;
• product enhancements; or
• business continuity.

Where required, users will be notified of material changes.

13.3 Blockchain Transactions

Transactions involving Digital Assets are recorded on public or permissioned blockchain networks.

You acknowledge that:

• blockchain transactions may be irreversible;
• network congestion may delay settlement;
• blockchain confirmation times vary;
• transaction fees may fluctuate; and
• Control Money cannot reverse completed blockchain transfers unless technically and legally possible.

13.4 Wallet Restrictions

Control Money may restrict wallet functionality where necessary to:

• comply with Applicable Law;
• protect customer assets;
• investigate suspicious activity;
• respond to court orders;
• implement sanctions; or
• prevent fraud.

14. User Representations

At all times during your use of the Platform, you represent and warrant that:

• you are acting for your own benefit unless disclosed otherwise;
• funds deposited originate from lawful sources;
• you are not attempting to conceal ownership or control of assets;
• you will comply with all tax obligations applicable to you;
• you understand that blockchain transactions may be irreversible; and
• you will not use the Platform for unlawful, fraudulent or prohibited purposes.

Any breach of these representations constitutes a material breach of these Terms.

15. Right to Request Information

Control Money may request additional information at any time where reasonably necessary for:

• compliance with Applicable Law;
• fraud prevention;
• transaction monitoring;
• security investigations;
• regulatory reporting;
• customer due diligence; or
• risk management.

Failure to provide requested information within the prescribed timeframe may result in suspension, withdrawal restrictions, or closure of your Account.

16. Funding Your Account

16.1 Supported Funding Methods

Eligible users may fund their Control Money Account using payment methods approved by Control Money from time to time.

Depending on jurisdiction, supported funding methods may include:

• UPI
• IMPS
• NEFT
• RTGS
• Bank Transfer
• Other approved payment methods

Control Money reserves the right to modify supported payment methods without prior notice where required for regulatory, operational or security reasons.

16.2 Third-Party Payment Partners

Fiat deposits are processed through regulated payment partners and Virtual Asset Service Providers (“VASPs”).

By initiating a deposit, you acknowledge that:

• the payment partner may conduct its own compliance checks;
• additional verification may be required;
• transactions may be delayed or rejected;
• separate terms of the payment partner may apply.

Control Money is not responsible for delays caused by banking systems, payment networks or third-party service providers.

16.3 Accepted Funding Sources

You may only fund your Account using:

• bank accounts held in your own legal name;
• payment instruments approved by Control Money; and
• funds originating from lawful sources.

Control Money may reject deposits originating from:

• anonymous payment methods;
• sanctioned entities;
• third-party accounts;
• high-risk jurisdictions;
• or any source considered unacceptable under Applicable Law or our internal risk policies.

17. Conversion into Digital Assets

17.1 Fiat Conversion

Following successful receipt of your fiat funds and completion of applicable compliance checks, your funds may be converted into supported digital assets through authorised liquidity providers.

For users in India, this generally involves conversion of INR into USDC through regulated on-ramp infrastructure.

The applicable exchange rate, spreads and fees shall be displayed before confirmation wherever reasonably practicable.

17.2 Conversion Finality

Digital asset conversions are generally irreversible once executed.

Once conversion has occurred:

• exchange rates cannot be reversed;
• market movements may affect value;
• blockchain settlement cannot ordinarily be cancelled.

17.3 Exchange Rates

Exchange rates displayed on the Platform may include:

• market prices;
• liquidity provider pricing;
• spreads;
• execution costs;
• blockchain costs; and
• applicable taxes.

Quoted prices remain valid only for the period displayed at the time of execution.

18. Yield

18.1 Eligible Assets

Where available, Control Money may automatically convert eligible USDC balances into USDY or another supported yield-bearing digital asset.

The purpose of this conversion is to enable eligible users to earn yield while maintaining exposure to supported digital assets.

Participation in any yield programme is governed by these Terms and any Product-Specific Terms.

18.2 Yield Accrual

Subject to operational processing times and product availability:

• yield begins accruing after successful conversion into the applicable yield-bearing asset;
• accrual frequency may vary depending on the underlying protocol or issuer;
• displayed balances may be updated periodically rather than continuously.

Yield is not guaranteed.

18.3 Variable Yield

Yield rates may change at any time due to:

• market conditions;
• protocol performance;
• issuer decisions;
• liquidity;
• regulatory developments;
• operational considerations.

Historical yield does not indicate future performance.

18.4 Suspension of Yield

Control Money may suspend, reduce or discontinue yield where reasonably necessary due to:

• regulatory requirements;
• issuer decisions;
• protocol upgrades;
• smart contract vulnerabilities;
• security incidents;
• liquidity constraints;
• extraordinary market events; or
• business continuity measures.

Suspension of yield shall not automatically constitute a breach of these Terms.

19. Internal Ledger

19.1 Ledger Records

Control Money maintains an internal ledger recording, among other things:

• deposits;
• withdrawals;
• conversions;
• purchases;
• sales;
• transfers;
• accrued yield;
• fees;
• taxes;
• corporate actions; and
• adjustments.

The internal ledger is maintained for operational and accounting purposes.

19.2 Authoritative Record

In the event of discrepancies between:

• user interface balances;
• cached information;
• notifications;
• emails; and
• temporary display errors,

the internal ledger together with applicable blockchain records shall constitute the authoritative record unless demonstrably incorrect.

19.3 Corrections

Control Money reserves the right to correct:

• computational errors;
• duplicate credits;
• pricing mistakes;
• blockchain reconciliation differences;
• accounting errors; and
• operational inaccuracies.

Reasonable notice shall be provided where practicable.

20. Ownership of Assets

Subject to Applicable Law, assets credited to your Account remain beneficially attributable to you.

However, Control Money may:

• hold assets through omnibus wallets;
• use pooled custody arrangements;
• utilise regulated custodians;
• maintain internal accounting records reflecting beneficial ownership.

You acknowledge that blockchain addresses may not correspond one-to-one with individual customer Accounts.

21. Safeguarding of Customer Assets

Control Money will implement commercially reasonable measures to safeguard customer assets.

Such measures may include:

• segregation of customer records;
• multi-signature controls;
• institutional custody providers;
• operational risk controls;
• access management;
• security monitoring;
• reconciliation procedures; and
• disaster recovery processes.

Nothing in these Terms guarantees absolute protection against loss arising from cyberattacks, blockchain failures or extraordinary events.

22. Failed or Delayed Deposits

Deposits may fail or be delayed due to:

• banking failures;
• payment network interruptions;
• compliance reviews;
• blockchain congestion;
• incorrect payment information;
• technical outages;
• regulatory intervention.

Where possible, Control Money will make commercially reasonable efforts to assist users in resolving failed deposits.

23. Stablecoin Risks

You acknowledge that supported stablecoins may be subject to risks including:

• de-pegging from their reference asset;
• issuer insolvency;
• redemption restrictions;
• liquidity shortages;
• smart contract vulnerabilities;
• regulatory intervention;
• sanctions;
• blockchain network disruptions.

Stablecoins are not equivalent to bank deposits.

Stablecoins are generally not protected by deposit insurance schemes.

24. No Guaranteed Returns

Except where expressly required by Applicable Law, Control Money makes no representation or warranty that:

• any yield will be generated;
• any particular yield rate will continue;
• digital assets will maintain value;
• principal will be preserved;
• investments will be profitable.

All investment decisions remain solely the responsibility of the user.

25. Acknowledgement

By depositing funds into the Platform, you acknowledge that:

• your fiat funds may be converted into supported digital assets;
• eligible balances may be allocated to supported yield-bearing products where applicable;
• digital asset values fluctuate;
• yield rates are variable and not guaranteed;
• blockchain transactions are generally irreversible;
• tax consequences remain your responsibility; and
• you have reviewed the applicable Risk Disclosure Statement before using the Services.

26. Investment Services

Subject to eligibility, regulatory requirements and product availability, the Platform enables Users to invest in supported tokenized financial products.

Supported products may include:

• Tokenized Exchange Traded Funds (“Tokenized ETFs”);
• Tokenized Equity Securities (“Tokenized Stocks”);
• Tokenized Index Products;
• Tokenized Treasury Products;
• Other digital investment products approved by Control Money.

Availability of any investment product does not constitute a recommendation to purchase, hold or sell that product.

27. Nature of Tokenized Assets

Tokenized Assets available on the Platform are blockchain-based representations of underlying financial instruments.

Depending on the issuer and applicable legal structure, ownership of a Tokenized Asset may:

• represent a beneficial interest;
• represent contractual rights;
• provide economic exposure;
• provide synthetic exposure; or
• represent another legally recognised interest.

Users acknowledge that ownership of a Tokenized Asset may not be identical to directly holding the underlying security.

Specific rights applicable to each product will be disclosed in the relevant Product Terms.

28. Investment Instructions

Users may submit instructions to:

• purchase Tokenized Assets;
• sell Tokenized Assets;
• exchange supported Digital Assets;
• rebalance portfolios where such functionality is offered.

An investment instruction becomes effective only after acceptance by the Platform.

Control Money reserves the right to reject any instruction before execution.

29. Order Types

Where supported, the Platform may provide:

• Market Orders;
• Limit Orders;
• Recurring Investment Orders;
• Scheduled Orders;
• Fractional Purchase Orders.

The availability of specific order types may vary depending on the underlying market, issuer, liquidity provider or blockchain network.

30. Fractional Ownership

Users may purchase fractional interests in eligible Tokenized Assets.

Fractional ownership:

• may not provide voting rights;
• may not provide direct shareholder rights;
• may be subject to issuer-specific limitations;
• may have minimum redemption thresholds.

Fractional ownership shall be governed by the applicable Product Terms.

31. Trade Execution

Investment instructions may be executed through one or more approved execution venues, including:

• decentralised exchanges (DEXs);
• regulated liquidity providers;
• authorised market makers;
• token issuers;
• custodians; or
• execution partners.

Control Money does not guarantee execution through any specific venue.

Execution venues may change without prior notice.

32. Best Execution

Control Money will use commercially reasonable efforts to obtain an efficient execution outcome considering factors including:

• available liquidity;
• quoted price;
• transaction costs;
• settlement speed;
• execution reliability;
• blockchain conditions;
• operational risk.

Best execution does not necessarily mean execution at the lowest available price.

33. Pricing

Displayed prices may include:

• issuer pricing;
• market pricing;
• DEX pricing;
• liquidity provider quotes;
• spreads;
• blockchain network fees;
• settlement costs.

Displayed prices are indicative until execution is completed.

Market conditions may change rapidly.

34. Slippage

Users acknowledge that executed prices may differ from displayed prices due to:

• market volatility;
• insufficient liquidity;
• blockchain congestion;
• order size;
• execution latency;
• changing market conditions.

This difference is referred to as “Slippage.”

By submitting an order, the User accepts the possibility of slippage.

35. Partial Execution

Where liquidity is limited, an order may:

• execute in full;
• execute partially;
• remain pending;
• expire;
• be cancelled.

Control Money is not responsible for market movements occurring while an order remains pending.

36. Failed Transactions

Transactions may fail because of:

• blockchain failures;
• smart contract failures;
• insufficient liquidity;
• regulatory intervention;
• market suspension;
• technical outages;
• pricing errors;
• network congestion.

Where reasonably practicable, Control Money will reverse unsuccessful transactions or restore affected balances.

37. Trading Hours

Certain Tokenized Assets may reflect markets operating in different jurisdictions.

Accordingly:

• some products may trade continuously;
• some may trade only during specified hours;
• pricing may differ outside underlying market hours;
• liquidity may reduce during market closures.

Trading availability will depend upon the applicable Product Terms.

38. Corporate Actions

Where applicable, Control Money will make commercially reasonable efforts to reflect corporate actions affecting supported Tokenized Assets.

Corporate actions may include:

• dividends;
• stock splits;
• reverse splits;
• mergers;
• acquisitions;
• spin-offs;
• rights issues;
• delistings.

Processing times may vary depending upon issuers, custodians and execution partners.

Control Money does not guarantee identical treatment to traditional securities markets.

39. Delisting

Control Money may suspend or remove any Tokenized Asset due to:

• issuer action;
• regulatory changes;
• insufficient liquidity;
• security concerns;
• market integrity issues;
• sanctions;
• business decisions.

Where practicable, Users will be provided reasonable notice before permanent delisting.

40. Investment Risks

Investing in Tokenized Assets involves substantial risk.

Risks include:

• loss of capital;
• market volatility;
• foreign exchange fluctuations;
• liquidity risk;
• smart contract vulnerabilities;
• blockchain failures;
• issuer default;
• custody risks;
• regulatory changes;
• taxation changes.

Users should invest only amounts they can afford to lose.

41. No Investment Advice

Control Money does not provide:

• investment advice;
• financial planning;
• portfolio management;
• tax advice;
• legal advice;
• fiduciary services.

Information displayed on the Platform is provided solely for informational purposes.

Any educational material, market commentary or research made available through the Platform should not be interpreted as a recommendation to buy or sell any investment.

Users remain solely responsible for their investment decisions.

42. User Acknowledgements

Before placing an investment order, each User acknowledges that:

• Tokenized Assets may fluctuate significantly in value;
• historical performance does not guarantee future returns;
• investments are not bank deposits;
• investments are generally not insured by any deposit insurance scheme;
• execution prices may differ from quoted prices;
• investments may become illiquid;
• corporate actions may differ from traditional securities markets;
• blockchain technology involves operational and technological risks;
• tax consequences remain the sole responsibility of the User; and
• the User has read and understood the applicable Product Terms and Risk Disclosure Statement before investing.

43. Fees

Your use of the Services may be subject to fees, charges and other costs as described in the Control Money Fees & Charges Policy, which is incorporated into these Terms by reference.

By using the Services, you agree to pay all applicable fees disclosed in accordance with the Fees & Charges Policy.

44. Taxes

You are solely responsible for determining, reporting and paying any taxes arising from your use of the Services, except where Control Money or its regulated partners are required by Applicable Law to collect, deduct or remit taxes on your behalf.

Additional information regarding fees and certain tax-related charges may be provided in the Fees & Charges Policy or other product-specific disclosures.

45. Lawful Use of the Platform

The Platform may only be used for lawful purposes and in accordance with these Terms and Applicable Law.

You agree to use the Platform honestly, responsibly and in a manner that does not adversely affect:

• other Users;
• Control Money;
• our partners;
• financial institutions;
• blockchain networks; or
• market integrity.

46. Prohibited Activities

You must not use the Platform to engage in, facilitate or attempt any activity involving:

Financial Crime

• money laundering;
• terrorist financing;
• sanctions evasion;
• tax evasion;
• fraud;
• corruption;
• bribery;
• identity theft;
• forgery; or
• market manipulation.

Illegal Assets

You may not use the Platform in connection with proceeds derived from:

• narcotics;
• human trafficking;
• child exploitation;
• ransomware;
• cybercrime;
• organised crime;
• illegal gambling;
• environmental crimes;
• intellectual property infringement; or
• any unlawful activity.

Fraudulent Behaviour

You must not:

• submit false information;
• impersonate another person;
• use forged identity documents;
• misrepresent ownership of funds;
• conceal beneficial ownership;
• attempt to deceive compliance personnel; or
• deliberately avoid regulatory requirements.

Platform Abuse

You must not:

• interfere with Platform operations;
• overload infrastructure;
• introduce malware;
• scrape data without permission;
• reverse engineer software;
• probe security vulnerabilities;
• automate access without approval;
• circumvent technical controls;
• attempt unauthorised access.

Market Abuse

You must not engage in:

• wash trading;
• spoofing;
• layering;
• price manipulation;
• front-running;
• insider trading where applicable;
• artificial volume creation;
• coordinated market manipulation.

Wallet Misuse

You must not use the Platform to interact with wallets reasonably believed to be associated with:

• sanctioned persons;
• darknet marketplaces;
• mixers intended to conceal ownership;
• ransomware payments;
• stolen digital assets;
• fraud schemes; or
• other prohibited activities.

47. Intellectual Property Misuse

Users must not upload, distribute or transmit material that infringes:

• copyrights;
• trademarks;
• patents;
• trade secrets;
• confidential information; or
• other intellectual property rights.

48. Fair Use Policy

Users shall not engage in conduct that:

• disrupts Platform operations;
• negatively impacts other Users;
• creates excessive operational costs;
• abuses promotional programmes;
• exploits pricing errors;
• repeatedly initiates failed transactions;
• attempts to manipulate Platform incentives.

Control Money reserves the right to implement reasonable usage limits to protect Platform stability.

49. Remedies

Where Control Money reasonably believes that a User has violated these Terms or Applicable Law, it may, without prejudice to any other rights:

• refuse transactions;
• suspend Services;
• freeze or restrict Accounts where legally permitted;
• cancel pending instructions;
• recover amounts improperly credited;
• terminate the Account;
• report relevant information to authorities;
• pursue legal remedies available under Applicable Law.

The exercise of one remedy shall not limit Control Money’s right to exercise any other remedy available under these Terms or Applicable Law.

50. Right to Suspend Services

Control Money may, at its sole discretion and to the extent permitted by Applicable Law, temporarily suspend all or part of the Services where reasonably necessary to:

• protect customer assets;
• prevent fraud;
• comply with Applicable Law;
• respond to regulatory directions;
• investigate suspicious activity;
• maintain Platform security;
• preserve market integrity;
• perform maintenance;
• address operational incidents; or
• protect the rights of Control Money, its Users or its service providers.

Where reasonably practicable, Control Money will notify affected Users before or promptly after a suspension.

51. Account Restrictions

Without terminating an Account, Control Money may impose one or more temporary restrictions, including:

• preventing new deposits;
• preventing withdrawals;
• restricting trading;
• limiting access to specific products;
• requiring additional verification;
• reducing transaction limits;
• restricting access from certain jurisdictions; or
• requiring completion of compliance reviews.

Restrictions may remain in effect until the underlying issue has been resolved.

52. Suspension for Compliance Reasons

Control Money may immediately suspend an Account where it reasonably believes:

• Applicable Law requires suspension;
• regulatory reporting obligations have arisen;
• sanctions screening identifies a potential match;
• identity fraud is suspected;
• false information has been provided;
• suspicious transactions require investigation;
• a court or regulator has issued a lawful direction;
• customer assets may be at risk.

Nothing in this section obligates Control Money to disclose confidential regulatory investigations or legally restricted information.

53. Immediate Termination

Control Money may immediately terminate an Account if:

• the User materially breaches these Terms;
• fraudulent or unlawful activity is identified;
• repeated compliance failures occur;
• the User attempts to circumvent Platform controls;
• continued provision of Services would expose Control Money or its partners to unacceptable legal, financial or reputational risk;
• required licences, approvals or partnerships necessary to provide the Services are suspended or revoked.

Termination under this clause shall take effect immediately unless Applicable Law requires otherwise.

54. Termination by the User

A User may request closure of their Account at any time, provided:

• all pending transactions have settled;
• all fees due have been paid;
• no legal or regulatory restrictions prevent closure;
• any remaining supported assets have been withdrawn or otherwise dealt with in accordance with these Terms.

Closure requests may require identity verification.

55. Effect of Termination

Upon termination or closure of an Account:

• access to the Platform will cease;
• open orders may be cancelled;
• recurring investment instructions may be discontinued;
• promotional benefits may expire;
• unused rewards may be forfeited where permitted by Applicable Law;
• transaction history may remain available for the period required by law.

Termination does not affect obligations accrued before termination.

56. Treatment of Customer Assets

Where an Account is terminated:

• Control Money will use commercially reasonable efforts to return eligible assets to the User, subject to Applicable Law;
• assets subject to regulatory restrictions, court orders or sanctions may remain unavailable until legally permitted;
• unsupported or delisted Digital Assets may be dealt with in accordance with the applicable Product Terms.

Control Money may require additional verification before releasing assets.

57. Abandoned Accounts

If an Account remains inactive for an extended period and Control Money is unable to contact the User despite reasonable efforts, assets may be handled in accordance with:

• Applicable Law;
• unclaimed property requirements;
• court orders; or
• regulatory directions.

58. Platform Availability

Control Money aims to provide reliable and continuous access to the Platform.

However, uninterrupted availability cannot be guaranteed.

The Platform may become temporarily unavailable due to:

• scheduled maintenance;
• emergency maintenance;
• cybersecurity incidents;
• internet outages;
• cloud infrastructure failures;
• blockchain network disruptions;
• failures of third-party providers;
• regulatory intervention; or
• force majeure events.

59. Planned Maintenance

Control Money may suspend access to all or part of the Platform for scheduled maintenance.

Where reasonably practicable, advance notice will be provided through the Platform, email or other appropriate communication channels.

Emergency maintenance may be performed without prior notice.

60. Changes to Services

Control Money may:

• introduce new products;
• discontinue existing products;
• modify Platform functionality;
• replace service providers;
• update supported blockchain networks;
• add or remove supported Digital Assets;
• modify trading hours;
• revise operational processes.

Material changes affecting Users’ rights will be communicated in accordance with Applicable Law.

61. Third-Party Service Providers

The Platform relies upon third-party providers, including:

• banking partners;
• payment processors;
• wallet infrastructure providers;
• custodians;
• blockchain networks;
• liquidity providers;
• token issuers;
• cloud infrastructure providers;
• analytics providers.

Control Money is not responsible for failures, delays or interruptions caused solely by such third parties, except to the extent liability cannot be excluded under Applicable Law.

62. Force Majeure

Control Money shall not be liable for any delay, interruption or failure to perform its obligations resulting from events beyond its reasonable control, including:

• natural disasters;
• pandemics;
• war;
• civil unrest;
• terrorism;
• governmental action;
• sanctions;
• labour disputes;
• internet failures;
• telecommunications outages;
• cloud service failures;
• blockchain network failures;
• validator failures;
• protocol exploits;
• cyberattacks;
• power outages; or
• any other force majeure event.

Performance shall resume as soon as reasonably practicable after the relevant event has ended.

63. Preservation of Rights

Failure by Control Money to exercise any right or remedy under these Terms shall not constitute a waiver of that right.

Any waiver shall be effective only if made expressly in writing by an authorised representative of Control Money.

64. Enforcement

Control Money reserves the right to pursue any remedy available under:

• these Terms;
• Applicable Law;
• contractual rights;
• equitable principles; or
• court orders.

Available remedies may be exercised individually or cumulatively.

65. Continued Compliance

Users remain responsible for complying with these Terms even during periods of:

• restricted access;
• suspended trading;
• compliance review;
• temporary Platform interruption; or
• pending investigations.

Control Money’s investigation or suspension of an Account shall not prevent it from taking further action where additional information becomes available.

66. Risk Disclosure

Investing in Digital Assets, Stablecoins, Yield Products and Tokenized Assets involves significant financial, technological, operational and regulatory risks.

Before using the Services or investing through the Platform, you must carefully review the Control Money Risk Disclosure Statement, which forms part of these Terms and is incorporated by reference.

By using the Platform or purchasing any Product, you acknowledge that:

• you have read and understood the Risk Disclosure Statement;
• you understand the risks associated with the Services and Products;
• you accept those risks voluntarily; and
• you are solely responsible for your investment decisions.

67. No Fiduciary Relationship

Your use of the Platform does not create:

• a fiduciary relationship;
• an advisory relationship;
• a trustee relationship;
• an agency relationship,

except where expressly required by Applicable Law.

Control Money acts as a technology platform facilitating eligible transactions through third-party providers.

68. No Warranty

To the maximum extent permitted by Applicable Law, the Platform and Services are provided on an “as is” and “as available” basis.

Control Money does not warrant that:

• the Platform will always be available;
• Services will be uninterrupted;
• transactions will execute immediately;
• errors will never occur;
• information will always be complete or current;
• Digital Assets will retain value;
• any investment will generate returns.

All implied warranties, including warranties of merchantability, fitness for a particular purpose and non-infringement, are excluded to the fullest extent permitted by law.

69. Limitation of Liability

To the fullest extent permitted by Applicable Law, Control Money, its affiliates, directors, officers, employees, shareholders, contractors and service providers shall not be liable for any:

• indirect loss;
• consequential loss;
• incidental loss;
• punitive damages;
• special damages;
• exemplary damages;
• loss of profits;
• loss of business opportunity;
• loss of goodwill;
• loss of anticipated savings;
• loss of data;
• loss arising from blockchain failures;
• losses caused by third-party providers.

70. Liability Cap

Except where liability cannot legally be excluded, the aggregate liability of Control Money arising out of or relating to these Terms shall not exceed the greater of:

• the total fees paid by the User to Control Money during the twelve (12) months immediately preceding the event giving rise to the claim; or
• USD 100 (or the equivalent amount in the User’s local currency).

This limitation shall apply regardless of the legal theory upon which the claim is based.

71. Events Beyond Control

Control Money shall not be responsible for losses resulting from:

• banking failures;
• payment processor failures;
• blockchain congestion;
• validator failures;
• protocol exploits;
• smart contract vulnerabilities;
• government action;
• sanctions;
• cyberattacks beyond reasonable control;
• internet outages;
• force majeure events.

72. User Indemnity

You agree to indemnify, defend and hold harmless Control Money and its affiliates, directors, officers, employees, contractors and partners from and against any claims, losses, damages, liabilities, penalties, costs and expenses (including reasonable legal fees) arising out of or relating to:

• your breach of these Terms;
• your violation of Applicable Law;
• fraudulent or unlawful conduct;
• misuse of the Platform;
• infringement of third-party rights;
• taxes arising from your transactions; or
• negligent or wilful misconduct.

73. Release

To the fullest extent permitted by Applicable Law, you release Control Money from claims arising from:

• investment performance;
• market volatility;
• issuer decisions;
• third-party service failures;
• blockchain network events;
• liquidity shortages;
• changes in Applicable Law; or
• decisions made by you based on information available through the Platform.

Nothing in this section limits rights that cannot be waived under Applicable Law.

74. Consumer Rights

Nothing in these Terms excludes or limits any statutory rights or remedies that cannot lawfully be excluded under Applicable Law.

Where any provision of these Terms conflicts with mandatory consumer protection legislation, the mandatory provisions of such legislation shall prevail to the extent of the conflict.

75. Privacy

Your privacy is important to Control Money.

Our collection, use, storage, processing and disclosure of personal information are governed by the Control Money Privacy Policy, which forms an integral part of these Terms.

By using the Platform, you acknowledge that you have read and accepted the Privacy Policy.

76. Electronic Communications

You consent to receive communications electronically.

Such communications may include:

• account notifications;
• security alerts;
• transaction confirmations;
• statements;
• regulatory notices;
• updates to these Terms;
• marketing communications where permitted by Applicable Law.

Electronic communications satisfy any legal requirement that communications be in writing.

77. Notices

Official notices may be delivered by:

• email;
• in-app notification;
• SMS;
• registered post;
• publication on the Platform.

Notices are deemed received:

• immediately for in-app notifications;
• upon transmission for email, unless delivery failure is notified;
• upon successful transmission for SMS;
• upon delivery according to postal records for physical mail.

Users are responsible for maintaining current contact information.

78. Marketing Communications

Where permitted by Applicable Law, Control Money may send promotional communications relating to:

• new products;
• educational content;
• offers;
• events;
• partnerships.

Users may opt out of promotional communications at any time.

Operational, legal and security communications cannot generally be opted out of.

79. Intellectual Property

The Platform and all associated intellectual property are owned by or licensed to Control Money.

This includes:

• trademarks;
• logos;
• software;
• APIs;
• source code;
• databases;
• designs;
• graphics;
• text;
• videos;
• documentation;
• educational materials.

Nothing in these Terms transfers ownership of intellectual property to Users.

80. Limited Licence

Subject to compliance with these Terms, Control Money grants Users a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform solely for personal or authorised business purposes.

This licence does not permit Users to:

• copy software;
• modify the Platform;
• distribute Platform content;
• create derivative works;
• reverse engineer software;
• sublicense access;
• exploit the Platform commercially without written consent.

81. User Content

Where Users upload or submit content, including feedback, reviews or suggestions, Users grant Control Money a worldwide, non-exclusive, royalty-free licence to use, reproduce, modify, publish and display such content for the purpose of operating and improving the Platform.

Users represent that they possess all rights necessary to grant this licence.

82. Feedback

Users may voluntarily provide suggestions, comments or ideas relating to the Platform.

Unless otherwise agreed in writing:

• Control Money may use such feedback without restriction;
• no compensation shall be payable;
• Users waive any claim arising solely from Control Money’s use of such feedback.

83. Open Source Software

Certain components of the Platform may incorporate open-source software governed by their respective licences.

Nothing in these Terms overrides rights granted under applicable open-source licences.

84. Public Announcements

Users shall not represent themselves as partners, agents or authorised representatives of Control Money without prior written consent.

Use of Control Money’s name, trademarks or branding in promotional materials requires prior written approval.

85. Survival

The provisions relating to:

• confidentiality;
• intellectual property;
• licences;
• data protection;
• record retention; and
• communications,

shall survive termination of these Terms to the extent necessary to fulfil their intended purpose.

86. Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Republic of India, without regard to conflict of law principles.

Nothing in these Terms limits the application of mandatory laws applicable in the jurisdiction where the User resides where such laws cannot be contractually excluded.

87. Dispute Resolution

87.1 Good Faith Resolution

Before commencing formal legal proceedings, the parties shall make reasonable efforts to resolve disputes through good-faith discussions.

A User should first submit the dispute through Control Money’s Grievance Officer or customer support channels.

Control Money shall endeavour to acknowledge complaints within the timelines prescribed under Applicable Law and communicate updates during the resolution process.

87.2 Arbitration

If a dispute is not resolved within thirty (30) days after receipt of a written notice of dispute, either party may refer the matter to arbitration.

Unless otherwise required by Applicable Law:

• arbitration shall be conducted in accordance with the Arbitration and Conciliation Act, 1996;
• the tribunal shall consist of one arbitrator appointed by mutual agreement, or failing agreement, in accordance with applicable law;
• the seat and venue of arbitration shall be Bengaluru, Karnataka, India;
• proceedings shall be conducted in the English language.

The arbitral award shall be final and binding upon the parties.

87.3 Interim Relief

Nothing in these Terms prevents either party from seeking interim or injunctive relief from a court of competent jurisdiction where necessary to:

• protect confidential information;
• preserve assets;
• enforce intellectual property rights;
• prevent fraud;
• comply with Applicable Law.

88. Jurisdiction

Subject to the arbitration provisions above, courts located in Bengaluru, Karnataka, India shall have exclusive jurisdiction over matters that are not capable of being resolved through arbitration or where judicial intervention is required under Applicable Law.

89. Grievance Redressal

Control Money shall appoint a Grievance Officer in accordance with Applicable Law.

The Platform shall publish the following information:

• name of the Grievance Officer;
• email address;
• business address;
• complaint submission process;
• expected response timelines.

Users should first submit complaints through the prescribed grievance mechanism before initiating formal proceedings, unless Applicable Law provides otherwise.

90. Assignment

Control Money may assign or transfer its rights or obligations under these Terms:

• to an affiliate;
• as part of a merger;
• acquisition;
• corporate restructuring;
• sale of business; or
• other lawful business transaction,

provided such assignment does not materially reduce the protections afforded to Users under these Terms.

Users may not assign or transfer their rights or obligations without the prior written consent of Control Money.

91. Entire Agreement

These Terms, together with the following documents, constitute the entire agreement between the User and Control Money:

• Privacy Policy;
• AML/KYC/CFT Policy;
• Risk Disclosure Statement;
• Fee Schedule;
• Product-Specific Terms;
• Cookie Policy;
• any additional policies expressly incorporated by reference.

These documents supersede all prior discussions, representations or agreements relating to the Services.

92. Severability

If any provision of these Terms is held to be invalid, illegal or unenforceable by a court or competent authority:

• the remaining provisions shall remain in full force and effect; and
• the invalid provision shall be interpreted, modified or replaced to the minimum extent necessary to make it enforceable while preserving its commercial intent.

93. Waiver

Failure by either party to enforce any provision of these Terms shall not constitute a waiver of that provision or any other provision.

Any waiver shall be effective only if made expressly in writing.

94. Relationship of the Parties

Nothing contained in these Terms shall be construed as creating:

• a partnership;
• joint venture;
• employment relationship;
• agency relationship; or
• fiduciary relationship,

between Control Money and any User, except where expressly required by Applicable Law.

95. Third-Party Rights

Except for affiliates and service providers expressly identified in these Terms where applicable, no person who is not a party to these Terms shall have any right to enforce any provision of these Terms.

96. Survival

The following provisions shall survive termination of these Terms to the extent necessary to give them effect:

• Definitions;
• Fees and Taxes;
• Record Retention;
• Intellectual Property;
• Confidentiality;
• Risk Disclosures;
• Disclaimers;
• Limitation of Liability;
• Indemnification;
• Dispute Resolution;
• Governing Law;
• Miscellaneous provisions.

97. Contact Information

Users may contact Control Money using the details published on the Platform.

Official contact information, including customer support and grievance contact details, will be updated from time to time on the Platform.

Electronic Acceptance

By creating an Account, accessing the Platform, or using any Service, you acknowledge that:

• you have read and understood these Terms;
• you agree to be legally bound by them;
• you consent to electronic execution of this agreement;
• electronic records and electronic signatures shall have the same legal effect as physical signatures, to the extent permitted under Applicable Law.