Terms and Conditions

1. Acceptance of Terms

Welcome to Lunu. These Terms and Conditions ("Terms") govern your access to and use of Lunu's services, including our fiat-to-crypto and crypto-to-fiat exchange gateway provided via our website and related applications ("Lunu Services" or "Services"). By accessing or using the Lunu Services (for example, by initiating a cryptocurrency purchase or sale on our site), you acknowledge that you have read, understood, and agree to be bound by these Terms. If you do not agree with any part of these Terms, you must not use the Lunu Services.

2. Company Information

Lunu's Services are provided by the following registered entities (collectively referred to as "Lunu", "we", "us", or "our"):

• WEB3 Solutions S.R.L. – a company incorporated in Italy with its registered office at Largo Richini 6, CAP 20122, Milan, registration number – 13774000965, duly registered in the Italian Register of Virtual Asset Service Providers (VASP Register) under the oversight of the Organismo Agenti e Mediatori (OAM).

All references to "Lunu" or the "Company" in these Terms mean the applicable entity above that provides services to you, or both entities collectively, as context requires.

3. Services Provided by Lunu

Lunu provides an online technological platform that enables users to exchange fiat currency for digital assets and vice versa ("exchange services"). In other words, users may use Lunu to purchase digital assets with fiat currency ("on-ramp") or to sell digital assets for fiat currency ("off-ramp").

Lunu is not a bank, financial institution, investment advisor, or brokerage. We do not provide or maintain any fiat or digital asset accounts, nor do we give investment or trading advice. Our role is limited to facilitating the exchange process through duly authorised third-party service providers.

4. User Registration and Account Security

To use Lunu's exchange services, you must meet the following eligibility criteria and complete the necessary registration steps:

• Legal Age: You must be at least 18 years old (or the age of legal majority in your jurisdiction) to use Lunu. By accepting these Terms, you confirm that you are of legal age and have the capacity to enter into a binding agreement.
• Personal Use and Own Behalf: You may only use Lunu on your own behalf and for your own personal or business purposes. You are not allowed to use Lunu's services on behalf of any third party. By registering, you declare that you are acting for yourself and not for someone else.
• Identity Verification (KYC): As a regulated company, Lunu is required in certain cases to verify the identity of its clients. You must successfully complete KYC verification before you can perform fiat-to-crypto or crypto-to-fiat transactions. Lunu may use third-party services to assist in verifying your identity. Lunu must keep certain information relating to you, including your account details and transaction history, for at least ten years or longer if required by law. Where necessary, Lunu may also be obliged to inform the appropriate authorities about unusual transaction activity or any suspicion of involvement in financial crime or unlawful conduct.
• Denial of Registration: Lunu reserves the right to decline any registration or to close accounts, especially if compliance checks are failed or if we suspect the account may be used in violation of these Terms or any law.

5. Compliance with AML and CFT Regulations

Lunu strictly adheres to Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) laws and regulations. By using our services, you agree to comply with all applicable AML/CFT requirements and you acknowledge the following:

• Transaction Monitoring: All transactions on Lunu's platform are monitored. We also implement the "Travel Rule" and other regulatory measures, which may require us to share certain transaction and identity information with relevant financial institutions or authorities when you transfer cryptocurrency to other platforms, as mandated by law.
• Suspicious Activity Reporting: Lunu will report any suspicious transactions or activities to the relevant authorities as required by law. You consent to such reporting and acknowledge that Lunu may be required to block, freeze, or refuse transactions if suspicious activity is detected or if required by law.
• No Illegal Use: You must not use Lunu's services for any unlawful purpose (including but not limited to money laundering, terrorist financing, fraud, evasion of sanctions). If Lunu has reason to believe that your use is in violation of any law or these Terms, we may suspend or terminate your access and take any necessary legal action.
• Source of Funds: You confirm that the fiat funds and cryptocurrency you use in transactions through Lunu come from lawful sources. Lunu may request proof or documentation of the source of funds or source of crypto at any time. If you fail to provide requested documentation, Lunu may refuse to process your transaction or may terminate the business relationship.
• Sanctions and Restricted Persons: By using Lunu, you confirm that you are not on any government watchlist or sanctions list, and that you are not located in, or a citizen of, any country that is subject to comprehensive sanctions. Lunu may screen users against sanctions lists and refuse service if a match is found.
• Ongoing Compliance: Lunu reserves the right to request any information or documentation necessary to verify user identities and transactions. You must promptly provide any information or documentation requested by Lunu to satisfy AML/CFT requirements.

6. Travel Rule Compliance

To comply with global Travel Rule requirements (FATF Recommendation 16), Lunu may be legally required to collect, verify, retain, and securely transmit specific information for certain virtual asset transfers. When a transfer is subject to the Travel Rule, Lunu will collect and transmit the required originator and beneficiary information, which may include: Sender (Originator): full legal name; unique account or wallet identifier; physical address and/or government-issued ID or customer reference number (as required by law). Recipient (Beneficiary): full legal name; destination wallet address or account reference; and, if applicable, the receiving VASP or financial institution identifier. All collected information is handled confidentially and only shared with other regulated financial institutions or VASPs involved in the transaction, strictly for compliance with the Travel Rule.

7. Payment Methods and Card Processing

Payment Processor: Card payments and other fiat transactions on Lunu are processed securely via third-party payment processors that are compliant with PCI DSS and other regulatory standards. Lunu does not store full payment card numbers. Authorization: When you confirm the transaction, you authorize us (and our payment partners) to charge the full amount displayed, which will include the price of the cryptocurrency and any applicable fees. Fraud Prevention: The payment processor may implement fraud prevention measures such as 3D Secure. We reserve the right to refuse to process a payment if we suspect unauthorized or fraudulent activity.

8. Pricing, Fees, and Exchange Rates

Transparent Pricing: Lunu uses individualized pricing for each transaction. Before you finalize a transaction, you will be shown a clear breakdown of what you will pay or receive. Exchange Rate Determination: The exchange rate is sourced from our liquidity partners or market data feeds at the time of your transaction. The rate is locked in at the moment of your confirmation, for a short validity period. Fees and Commissions: Lunu may charge a service fee; third-party providers may also have fees. All such fees are either included in the exchange rate/spread or listed explicitly. No Additional Costs After Confirmation: Once you confirm a transaction, you will not be asked to pay more than the agreed amount. Individual Transaction Confirmation: Each transaction is handled separately; you cannot "lock in" a rate for future transactions beyond the current checkout session.

9. Transaction Process and User Confirmation

To buy (fiat-to-crypto) or sell crypto (crypto-to-fiat) via Lunu: choose amount, currency, and payment method if required; see amount, rate, fees, and wallet address; transaction proceeds only after explicit confirmation; fiat is charged, or crypto must be sent within the time limit; crypto transfers require network confirmation; transaction finalizes, confirmation and receipt are issued. No transaction occurs without your active confirmation. Once confirmed and executed, it cannot be reversed. You are responsible for correct wallet addresses, payment, and personal details. Quotes are valid only for a limited time. You may cancel before final confirmation. Lunu reserves the right to suspend, block, or cancel any transaction if: there are doubts regarding the lawful origin of funds; the transaction contravenes applicable laws, international sanctions, or internal Lunu policies; or you fail to provide required documents within the prescribed timeframe. You bear full responsibility for the accuracy of all transaction details. All transactions confirmed by you are considered final and irrevocable.

10. Refunds

Payment Exception: If a purchase order/invoice is not paid in full or is overpaid, customers can resolve exceptions in the Lunu Pay Widget or on https://support.lunu.io/contact-us. Lunu charges miner fees and Service Fees for refunding. For a Payment Exception refund, miner fees and 5 EUR (except applicable VAT 21%) will be deducted from the refunded amount. Refunds are made in the original currency of the transaction. Refunds are processed only if the total refundable amount is equal to or exceeds 10 USD (or equivalent); a fixed service fee of 5 USD (or equivalent) and network fees will be deducted. Expired Payment: Payments received outside the 5-minute window in the Widget/terminal are marked as expired. Customers can request refunds; miner fees and 5 EUR (except VAT) will be deducted. Unsupported Payments: See supported wallets. Payments with unsupported wallets/exchanges/cryptocurrencies will be refunded after deducting miner fees. Retailer Refund Policy: Lunu is not responsible for the retailer's refund policy. If refunds are allowed, Lunu can only refund the amount in cryptocurrencies.

11. Receipts, Records, and Cancellations

After a successful transaction, Lunu will provide you with a receipt or confirmation record (on screen and/or by email). The receipt will include: date and time of execution; unique transaction ID; type of transaction; fiat and crypto amounts; exchange rate; fees; wallet address; and identification of the parties. We recommend that you save this information. Contact support if you spot any discrepancy.

12. User Conduct and Prohibited Uses

You shall not: use the Services for any unlawful purpose (including money laundering, terrorism financing, fraud, tax evasion); use the Services if you or the counterparty is subject to economic sanctions; create a false identity or impersonate any person or entity; interfere with the security or integrity of our systems; register or use multiple accounts to bypass limits or use automated scripts/bots without permission; infringe intellectual property rights; manipulate or tamper with transactions; circumvent controls or limits (e.g. using VPNs to evade restrictions); use robots, scrapers, or crawlers to access our Services without permission. Violation may result in immediate termination of access, legal action, and reporting to authorities.

13. Intellectual Property and Site Use

All content on Lunu's website belongs to Lunu or its licensors and is protected by law. Lunu™ and its logos are trademarks of Lunu. You are granted a limited, revocable, non-exclusive license to use the site and Services only for their intended purpose (buying/selling crypto). You may not copy, modify, distribute, reverse-engineer, or extract source code, except as permitted by law or open-source licenses.

14. Customer Support and Contact Information

Email: [email protected]. You may also use our online Help Center or FAQ pages. We strive to respond within 1-2 business days. When contacting support, provide your transaction ID, email or phone associated with the transaction, and a clear description of your issue. For complaints or disputes, we encourage you to reach out to us first to attempt resolution.

15. Disclaimers and Limitation of Liability

Lunu relies on third-party providers and cannot guarantee their performance. Services are provided "as is" and "as available," without warranties of accuracy, uninterrupted access, or error-free operation. To the fullest extent permitted by law, Lunu and its affiliates are not liable for indirect damages, lost profits, data, or funds caused by factors beyond our control. These limitations do not exclude liability that cannot be waived by law (e.g., death, personal injury, or fraud). Lunu's liability shall be strictly limited to direct losses arising solely from Lunu's proven negligence or willful misconduct and shall in no event exceed the greater of: the total amount of fees actually paid by you to Lunu for the specific transaction concerned; or one hundred (100) euros.

16. Privacy and Data Protection

Our collection, use, and sharing of your personal information is governed by our Privacy Policy. By using the Services, you acknowledge that you have read the Privacy Policy. We collect data to provide the service (e.g. KYC info, transaction details, cookies); we use it to fulfill transactions, comply with legal obligations (e.g. AML/CFT), and improve our services; we share data with third parties only as needed (payment processor, exchange partner, verification providers, and government authorities if legally required). We secure your data with industry-standard practices. You may have rights under applicable data protection laws (e.g. access or delete your data). Contact us as described in the Privacy Policy for privacy questions.

17. Changes to These Terms

Lunu may update or modify these Terms from time to time. If we make material changes, we will notify users by posting the updated Terms on our website and updating the "Last Updated" date. In some cases, we may provide additional notice (e.g. via email or platform notification). Changes are effective when posted, unless a later effective date is specified. By continuing to use the Services after the Terms have been updated, you are agreeing to the revised Terms. If you do not agree to the changes, you must stop using the Services.

18. Governing Law and Dispute Resolution

These Terms are governed by the laws of Italy. You agree that any dispute or claim arising from your use of Lunu's services or these Terms will be subject to the exclusive jurisdiction of the courts of Milan, Italy. You expressly consent to venue there and waive any objections to inconvenient forum. If any provision is held to be invalid or unenforceable, the remaining provisions will remain in full force and effect. Your rights under these Terms are personal to you and may not be assigned without Lunu's prior written consent.

19. Crypto Asset Risk Disclosure

In line with European regulations (including MiCA), Lunu provides the following risk disclosures. Volatility Risk: Digital assets are subject to extreme price volatility; you may lose a substantial part or all of your investment. Security and Operational Risks: Digital platforms remain vulnerable to hacking, theft, unauthorized access, and data breaches. You are responsible for safeguarding your access credentials. Costs, Charges & Fees: Using Lunu's services may involve fees; all applicable charges are disclosed transparently. Regulatory Risk: The regulatory framework for crypto-assets is developing and may change. Fair, Clear, and Non-Misleading Information: All information provided by Lunu is designed to be fair, clear, and not misleading. Competence of Staff: Lunu ensures that personnel possess appropriate knowledge and competence in crypto-assets and related risks. No Investment Advice: Lunu acts solely as a service provider and does not offer investment or financial advice. You remain fully responsible for your investment decisions. If you are uncertain about trading or investing in digital assets, seek advice from a qualified financial professional.

20. Miscellaneous Provisions

If any provision of these Terms is held to be invalid, illegal, or unenforceable, that provision shall be enforced to the maximum extent permissible, and the remaining provisions shall remain in full force and effect. You may not assign or transfer any of your rights or obligations under these Terms without our prior written consent. We may freely assign or transfer these Terms (in whole or in part) as part of a corporate reorganization, acquisition, or for any other reason. Lunu shall not be liable for any delays, failure in performance, or interruption of service which result directly or indirectly from any cause or condition beyond our reasonable control, including but not limited to: acts of God, pandemic, earthquake, fire, flood, wars, civil unrest, terrorism, internet or power outages, equipment or telecommunication failure, acts of government or regulators, or the failure of any third-party service provider.