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Terms and Conditions

Last Updated: 16 September 2025

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 (Via Del Lauro 9, 20121 Milan, Italy, registration number 13774000965), listed in the Italian Register of Virtual Assets Service Providers under the oversight of the Organismo Agenti e Mediatori (OAM).
  • UAB Lunu Europe, Gedimino pr. 44A-201, Vilnius, Lithuania, registered in Lithuania under number 305774629, registered in the Lithuanian Register of Virtual Assets Service Providers. UAB Lunu Europe provides the following services: virtual assets wallet services, fiat to virtual assets and virtual assets to fiat exchange services and other applicable virtual assets services.

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 service that enables fiat-to-crypto and crypto-to-fiat exchanges for clients. In simple terms, you can use Lunu to buy cryptocurrency with fiat currency (“on-ramp”) or sell cryptocurrency for fiat currency(“off-ramp”).

Lunu is not a bank, not an investment advisor, and not a brokerage. We do not provide electronic money or fiat custodial accounts, and we do not give any advice on the merits of cryptocurrency investments. Our service is purely transactional: we help convert one form of asset to another at your direction.

Lunu does not provide fiat payment services, electronic money services, or custodial accounts for clients. We do not accept or hold client fiat funds on deposit.

All fiat transactions conducted through Lunu’s Services (including card payments, bank transfers, or other methods) are processed exclusively by duly authorised third-party payment service providers.

We comply with regulatory standards in the jurisdictions we serve, including anti-money laundering and consumer protection rules. Our service may not be available in certain regions where we are not licensed or where crypto exchanges are restricted. We reserve the right to restrict or refuse services in any jurisdiction as required by law. Lunu Pay does not provide electronic money services, fiat custodial services, or fiat-to-crypto and crypto-to-fiat exchange services to U.S. residents. Such services are offered by third-party providers, and Lunu Pay only facilitates technical support for access.

All Clients’ crypto-assets held with Lunu are maintained in segregated accounts and are not commingled with the Company’s own assets. Client assets shall not be used by Lunu for its own account. Where Lunu temporarily receives crypto funds for settlement purposes, such funds shall be placed in a separate no later than the end of the next business day.

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. This is important for compliance and safety reasons.
  • Identity Verification (KYC): As a regulated company, Lunu is required in certain cases to verify the identity of its clients . This process is often referred to as KYC (Know Your Customer). You must successfully complete KYC verification before you can perform fiat-to-crypto or crypto-to-fiat transactions. Lunu may use third-party services or databases to assist in verifying your identity and compliance status. In accordance with applicable compliance Laws, Lunu must keep certain information relating to you, including your account details and transaction history, for at least ten years or for a longer period 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. All approvals of new accounts are at Lunu’s sole discretion.

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. Lunu may monitor, screen, and analyze transactions for anything that could indicate illegal or prohibited activity. 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. We maintain an internal AML program (including policies and procedures) to ensure compliance. 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. This includes (but is not limited to) money laundering, terrorist financing, fraud, evasion of sanctions, or any other criminal activity. You also must not attempt to use the service to disguise the origin of funds or to evade any financial regulations. If Lunu has reason to believe that your use of the service 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. You also confirm that the cryptocurrency you are purchasing is for legal purposes. Lunu may request proof or documentation of the source of funds or source of crypto at any time, especially if required under AML laws. If you fail to provide requested documentation or information, 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 (for example, lists maintained by the United Nations, EU, OFAC, etc.), and that you are not located in, or a citizen of, any country that is subject to comprehensive sanctions. Lunu does not provide services to individuals or entities that are subject to sanctions or that are in certain high-risk jurisdictions. We may screen users against sanctions lists and refuse service if a match is found.
  • Ongoing Compliance: Lunu complies with all applicable anti-money laundering and counter-terrorism financing regulations. In order to fulfill our AML/CFT obligations, Lunu reserves the right to request any information or documentation necessary to verify user identities and transactions. This may include additional identity documents, proof of address, source-of-funds evidence, or details about your transaction history. You must promptly provide any information or documentation requested by Lunu to satisfy AML/CFT requirements. This is in addition to the standard KYC (Know Your Customer) information you provided at onboarding.

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. By ensuring that both originator (sender) and beneficiary (recipient) details accompany qualifying transactions, Lunu aligns with international AML/CFT standards and enhances transparency in 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 (but is not limited to):

  • 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. These processors handle your payment details; Lunu does not store full payment card numbers. All card details are encrypted and processed off-site by the payment gateway. Your card statement may reflect a charge from Lunu or from our processing partner – details on the descriptor will be provided at payment time. If your payment is declined by the bank or issuer, the transaction will not proceed.

Authorization: When you input your card or payment information and confirm the transaction, you authorize us (and our payment partners) to charge the full amount displayed for the transaction, which will include the price of the cryptocurrency and any applicable fees. No additional fees beyond what is disclosed at checkout will be charged without your consent. If we offer the option to save your payment method for future use, it will be explicitly presented and subject to your agreement.

Fraud Prevention: For your security and ours, the payment processor may implement fraud prevention measures, such as 3D Secure authentication (e.g., Verified by Visa or MasterCard SecureCode), requiring you to complete an additional verification step with your bank. If you fail or decline such authentication, the transaction might not be completed. We also reserve the right to refuse to process a payment if we suspect unauthorized or fraudulent activity. In such cases, you might need to use an alternate payment method or contact your bank.

8. Pricing, Fees, and Exchange Rates

Transparent Pricing: Lunu uses individualized pricing for each transaction. This means that for every purchase or sale request, the exchange rate and fees are calculated in real-time based on market conditions and any applicable charges. Before you finalize a transaction, you will be shown a clear breakdown of what you will pay or receive: this includes the amount of fiat currency (e.g., euros or dollars) you will be charged or will obtain, the amount of cryptocurrency you will receive or sell, the exchange rate applied to convert between the fiat and crypto, and any fees or commissions that apply. We believe in full transparency: all relevant costs and the final price will be displayed to you upfront, in your chosen currency, prior to payment. You will have the opportunity to review these details and cancel if you do not agree. Lunu will not hide any fees – the price you see before confirming is the price you agree to pay.

Exchange Rate Determination: The exchange rate for converting between fiat and crypto is sourced from our liquidity partners or market data feeds at the time of your transaction. This rate may include a small spread or margin which is how Lunu or the liquidity provider earns revenue (this is often already factored into the price you see). Exchange rates for cryptocurrencies can fluctuate rapidly. The rate is locked in at the moment of your confirmation of the transaction, for a short validity period. If you take too long to complete a step (for example, if you delay entering a confirmation code or sending the crypto for an off-ramp), the quote may expire and a new rate could be offered. We will notify you if a quote has expired and present an updated rate for acceptance before proceeding.

Fees and Commissions: Lunu may charge a service fee for facilitating the transaction. Additionally, Third-Party Providers (such as the crypto exchange fulfilling the order, or the payment processor) may have fees. All such fees are either included in the exchange rate/spread or listed explicitly. You will see any Lunu fee or third-party fee as part of the price breakdown before you commit to the transaction.

No Additional Costs After Confirmation: Once you confirm a transaction, you will not be asked to pay more than the agreed amount. The transaction is considered final at that agreed price. Only under exceptional circumstances (such as your failure to complete a required step, or a technical error showing an incorrect price) would a transaction not go through at the confirmed price – in which case it would be canceled rather than unilaterally changed.

Individual Transaction Confirmation: Each transaction is handled separately. Prices and rates may vary from one transaction to the next. You cannot “lock in” a rate for future transactions beyond the current checkout session. There is no subscription or recurring charge (unless explicitly stated for a particular service). Therefore, for every new purchase or sale, you will need to review and accept the rate and fees again. This ensures you have full control and awareness for each transaction you make.

9. Transaction Process and User Confirmation

Transaction Initiation: 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.

Accuracy of Information: You are responsible for correct wallet addresses, payment, and personal details. Mistakes may cause permanent loss of funds.

Timing & Rate Locks: Quotes are valid only for a limited time. If expired or if the market moves sharply, you may need to confirm a new rate.

User Cancellation: You may cancel before final confirmation. If payment is already initiated, contact support. After confirmation or sending crypto, cancellation is not possible.

Transactions suspension: Lunu reserves the right to suspend, block, or cancel any transaction if:

  1. there are doubts regarding the lawful origin of funds,
  2. the transaction contravenes applicable laws, international sanctions, or internal Lunu policies,
  3. You fail to provide required documents within the prescribed timeframe.

In such cases, the Lunu may hold funds until completion of the investigation, or return them net of applicable fees and expenses

Your Responsibility for Transaction Details: You bear full responsibility for the accuracy of all transaction details (including wallet address, amount, currency, and any other required data). Errors or inaccuracies in the information provided by You may result in the irretrievable loss of funds, for which the Lunu shall not be held liable.

Irrevocability of Transactions: All transactions confirmed by the You are considered final and irrevocable. Lunu is under no obligation to amend, cancel, or compensate for such transactions, even if they were made in error by You.

10. Refunds

Payment Exception: In certain situations, if a purchase order/invoice is not paid in full or is overpaid, this will result in a payment exception and an incomplete purchase order. Customers can resolve these exceptions either in the Lunu Pay Widget or on the Lunu contact page https://support.lunu.io/contact-us.

Customers can also contact the Retailer and request a refund. Lunu charges miner fees and Service Fees for refunding a payment. If the customer requests a refund for a Payment Exception, the miner fees and an amount equal to 5 EUR (except for the applicable VAT (21%)) will be deducted from the refunded amount. This 5 EUR fee is levied on Customers. Refunds will only be made in the original format currency of the transaction (e.g. if the invoice was paid in BTC, the refund will be in BTC only). The refund shall be processed within 30 days after the transaction.

Expired Payment: Expired Payments occurs when a transaction is received outside the time window of specified 5 minutes in the Lunu Pay Widget and terminal. All payments sent to the expired address will show up in Lunu's system as an expired payment. Customers can request refunds for the expired payments either in the Lunu Pay Widget or on the Lunu contact page https://support.lunu.io/contact-us. The miner fees and an amount equal to 5 EUR (except for the applicable VAT (21%)) will be deducted from the refund amount. This 5 EUR fee is levied on Customers.

Unsupported Payments: For an overview of currently supported wallets and cryptocurrencies, please visit https://lunu.io/supported-wallets. Currently, Lunu does not support any other cryptocurrencies or wallets unless specifically stated on our website. Any payment made with unsupported wallets, exchanges, cryptocurrencies will be marked as "Unsupported Payments" and the transaction amount will be refunded to the customer after deducting the miner fees.

Disclosure of the Retailer Refund Policy: Lunu is not responsible for the retailer's refund policy. However, we recommend that Retailers have a clear refund policy for their customers (including, if applicable, "no refunds are allowed as all sales are final"). For certain industries, a refund policy may not be applicable (e.g., when a service is provided). 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 for your transaction. Typically, this will be shown on the final screen and also sent to you via email (if you provided an email address during the process). The receipt will include:

  • The date and time of the transaction execution.
  • A unique transaction ID or reference number.
  • The type of transaction (buying which cryptocurrency or selling which, in exchange for which fiat currency).
  • The fiat amount that was charged or paid out
  • The cryptocurrency amount that was delivered or received
  • The exchange rate that was applied
  • Any fees or commissions that were applied
  • The wallet address involved in the crypto part of the transaction: for on-ramp this will be the destination address you provided where the crypto was sent, for off-ramp it will be the address you sent crypto to. In some cases, a transaction hash for the blockchain transfer may also be provided for your reference.
  • Identification of the parties: the receipt will note Lunu as the facilitating platform (with our brand/logo and name), and may also include the name of the third-party provider that fulfilled the crypto liquidity or processed the payment.

This receipt is your proof of purchase/sale. We recommend that you save this information. If you spot any discrepancy on the receipt (for instance, an incorrect amount or a typo in your details), contact support immediately.

12. User Conduct and Prohibited Uses

By accessing Lunu Services, you agree that you will not engage in any activities that violate these Terms, any applicable law, or the rights of any third party. Specifically, you shall not:

  • Illegal Activities: Use the Lunu Services for any unlawful purpose, including but not limited to money laundering, terrorism financing, fraud, tax evasion, the purchase or sale of illegal goods or services, or other criminal activities. Any attempt to use our platform to transact in relation to illicit activities is strictly forbidden and will be reported to law enforcement as required.
  • Sanctions Violations: Use the Services if you or the counterparty of your transaction is subject to any economic sanctions or embargo. For example, you may not use Lunu to send or receive funds on behalf of persons or entities on sanctions lists such as OFAC’s SDN list, the EU’s sanctioned persons list, UK HMT sanctions, UN sanctions, etc. We also do not allow usage from certain high-risk countries or regions as determined by us in line with Section 4.3.
  • Impersonation and Misrepresentation: Create a false identity or impersonate any person or entity, misstate your affiliation with a person or entity, or attempt to use Lunu on behalf of someone else without full disclosure and our consent. You must use your own identity and information.
  • Security Violations: Interfere with or disrupt the security or integrity of our systems. This includes not attempting to circumvent any security measures, not introducing malware or viruses, not performing any penetration testing or vulnerability scanning on our site, and not accessing data that is not intended for you. Unauthorized access or use of our platform is a breach of these Terms and may be illegal.
  • Multiple Accounts / Abuse: Register or use multiple accounts to bypass limits or restrictions, or use any automated scripts or bots in relation to the Service without our permission. You should not abuse referral programs or promotions, if any, by cheating or taking advantage in a way not intended by Lunu.
  • Intellectual Property Infringement: Use Lunu’s Services or content in a manner that infringes on intellectual property rights of others. This might include uploading or sharing any content through our platform that you don’t have rights to. (Note: Generally, our platform is for transactions, and you don’t upload content in the same way as a social platform, so this is more about using our site content appropriately – see Section 11).
  • Transaction Tampering: Try to manipulate, interfere with, or unfairly influence the normal processing of transactions. For example, deliberately sending the wrong amount of crypto to exploit rounding, or attempting to double-spend crypto, or using any technique to confuse the on-chain tracking. All blockchain transactions are monitored for consistency; any tampering will result in transaction failure and possibly account termination.
  • Bypassing Controls: Attempt to circumvent any controls or limits we put in place (such as transaction limits, geolocation blocks, verification requirements). Using VPNs or other technical measures to hide your location for the purpose of evading restrictions is not allowed.
  • Data Mining: Use any robot, scraper, crawler or other automated means to access our Services for any purpose without our express permission, especially to extract data or perform analysis that we have not authorized. Violation of any of the above, or any other aspect of these Terms, may result in immediate termination of your access to Lunu Services, potential legal action, and reporting to relevant authorities if applicable. We reserve the right to refuse to process, or to cancel or reverse, any transaction we suspect is in violation of these Terms or applicable law.

13. Intellectual Property and Site Use

All content on Lunu’s website (text, logos, graphics, software, etc.) 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

We value our customers and aim to provide prompt support for any issues or questions. If you need assistance with a transaction, have questions about the Services, or wish to lodge a complaint, you can contact Lunu’s Customer Support:

  • Email: support@lunu.io
  • Support Center: You may also find answers or submit requests through our online Help Center or FAQ pages (accessible via our website’s support section).

We strive to respond to inquiries as quickly as possible, usually within 1-2 business days. Support is provided in English (and potentially other languages where we have capability, though English will be used by default for written communication).

When contacting support, please provide relevant details such as your transaction ID (from your receipt), the email or phone number associated with the transaction, and a clear description of your issue. This will help us assist you more efficiently. For security and privacy, do not include sensitive information like full card numbers or passwords in your support request. Our team may ask for certain identifying information to verify ownership of an account or transaction before discussing details – this is for your protection.

If you have a complaint or dispute with our Services, we encourage you to reach out to us first to attempt resolution. We will do our best to address your concerns and come to a fair solution.

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. We will, however, work to resolve issues and maintain stable operations.

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 (e.g., user mistakes, blockchain issues, fraud).

These limitations do not exclude liability that cannot be waived by law (e.g., death, personal injury, or fraud).

The Lunu’s liability shall be strictly limited to direct losses arising solely from the Lunu’s proven negligence or willful misconduct and shall in no event exceed the greater of:

  • the total amount of fees actually paid by the You to Lunu for the specific transaction concerned; or
  • one hundred (100) euros.

16. Privacy and Data Protection

Your privacy is important to us. Our collection, use, and sharing of your personal information in connection with your use of Lunu Services is governed by our Privacy Policy, which is available on our website. By using the Services, you acknowledge that you have read the Privacy Policy and understand that personal data will be processed in accordance with it. Key points include:

  • We collect certain data to provide the service (e.g. KYC info, transaction details, cookies on the site for functionality).
  • We use this data to fulfill transactions, comply with legal obligations (such as AML/CFT checks), and improve our services.
  • We share data with third parties only as needed – for example, we pass your payment info to the payment processor, your crypto address and amounts to the exchange partner, and your identification info to verification providers. We may also share with government authorities if legally required (as noted in Section 5).
  • We secure your data with industry-standard practices.
  • You may have rights under applicable data protection laws, such as the right to access or delete your data, as outlined in the Privacy Policy.

If you have questions about your privacy or data, you can contact us as described in the Privacy Policy or via the support contacts.

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 at the top. In some cases, we may provide additional notice (such as via email or a notification on our platform) of significant changes. Any changes to the Terms will be 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. We encourage you to review the Terms periodically to ensure you understand the terms and conditions that apply to your use of Lunu.

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 of these Terms is held to be invalid or unenforceable, the remaining provisions will remain in full force and effect. You agree that your rights under these Terms are personal to you and may not be assigned without Lunu’s prior written consent.

19. Miscellaneous Provisions

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, that provision shall be enforced to the maximum extent permissible, and the remaining provisions of the Terms shall remain in full force and effect. For example, if a law limits the enforceability of our liability disclaimer or class action waiver, that portion will be adjusted only to the extent necessary to comply with the law.

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. These Terms will bind and inure to the benefit of the parties, their successors, and permitted assigns.

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, epidemic, 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.

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