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Terms and Conditions

PUBLISHED ON 4 FEBRUARY 2025

This agreement ("Terms") is concluded between You as an individual Client ("Client", "you") and the following entities depending on the services provided:

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.

WEB3 SOLUTIONS S.R.L., Milano Via Del Lauro 9 Cap 20121 LEXIA, registered in Italy under the number 13774000965, listed in the Italian Register of Virtual Assets Service Providers. WEB3 SOLUTIONS S.R.L. 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.

Each of the aforementioned companies, WEB3 SOLUTIONS S.R.L. and UAB Lunu Europe shall hereinafter be referred to collectively as “Lunu, Company or Lunu Pay or We or Us or our” which is the trade name for their consolidated services as specified herein.

These Terms of Service ("Terms") establish the main conditions governing your relationship with Lunu Pay, including registration, account creation, wallet usage, fees, transaction terms, obligations, prohibited activities, confidentiality, data protection, dispute resolution, and termination procedures.

1. PRELIMINARY PROVISIONS

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.

Access to services is granted solely at Lunu Pay’s discretion and is not automatic.

Fund protection: Cryptocurrency holdings in Lunu Pay Wallets are not covered by financial compensation schemes but are safeguarded in segregated accounts as per regulatory requirements.

Sanctions compliance: Lunu Pay does not serve sanctioned individuals or entities.

No investment advice: Lunu Pay makes no representations regarding the advisability of cryptocurrency transactions or investment in securities.

Prepaid services: All transactions must be prepaid; no credit or advance payments are permitted.

Payment Initiation Services: Lunu Pay will process the cryptocurrency purchase only after funds are credited to the designated account. Cryptocurrency rates may fluctuate before execution, potentially causing losses, and the final purchase price may differ from the initial quote.

Irrevocable execution: By accepting these Terms, the Client consents to the immediate execution of cryptocurrency purchase orders upon payment. The order will be executed at the market rate at the time of processing, which may lead to losses, and cannot be revoked or withdrawn.

Acceptance of Terms: The Client must review and agree to these Terms before using Lunu Pay’s services. Continued use implies acceptance of any modifications.

2. REGISTRATION AND COMPLIANCE

To use Lunu Pay’s services, Clients must complete the registration process, including identity verification where required.

Lunu Pay conducts KYC (Know Your Customer) and Travel Rule compliance checks based on regulatory requirements and the nature of transactions.

Clients may be required to provide personal identification documents, proof of address, and additional details to comply with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.

Anonymous transactions are not permitted. Lunu Pay reserves the right to request further information or suspend transactions if verification requirements are not met.

By using Lunu Pay’s services, the Client confirms that they:

(a) Are not a U.S. resident;

(b) Have not been charged with financial crimes;

(c) Are not subject to international financial sanctions;

(d) Are not undergoing bankruptcy or debt collection.

Clients must immediately notify Lunu Pay if any of the above conditions change.

Lunu Pay may refuse to process transactions or require enhanced due diligence if a Client acts on behalf of a third party or if there are inconsistencies in the provided information.

Transaction limits and compliance checks are determined based on risk assessments and regulatory requirements, which may change over time.

Clients must ensure that all submitted information is accurate. Any losses due to incorrect data are the Client’s responsibility.

If verification requirements are not met, Lunu Pay may refuse to process a transaction or terminate service access.

Compliance checks, including Travel Rule procedures, are performed as necessary. Lunu Pay reserves the right to request additional documentation at any time.

3. FEES FOR SERVICES AND SETTLEMENT PROCEDURE

The applicable fees for Lunu Pay services are available on the website. Lunu Pay may update these fees and will notify Clients accordingly.

If Lunu Pay reduces service fees, the new rates apply immediately without prior notice or confirmation.
(i) At the time of the crypto transaction; or
(ii) If not deducted immediately, Lunu Pay reserves the right to charge the fee later.

Clients must review and understand all applicable fees before using Lunu Pay’s services.

Fees are paid in the currency of the transaction.

Clients are responsible for ensuring sufficient funds to cover transaction fees.

All fees reflect exchange rates at the time of the transaction.

Lunu Pay covers network transaction fees (e.g., miner’s fees) for transfers to third-party wallets and may charge Clients a corresponding fee. The final transaction fee may differ from initial estimates, but all applicable fees will be disclosed before transaction execution.

4. CRYPTO TRANSACTIONS

Transaction Execution
Crypto transactions using Lunu Pay’s services can be executed:
(i) To wallets or accounts in compliance with applicable AML and Travel Rule regulations;
(ii) To financial institutions and payment systems where permitted;
(iii) To third-party wallets, subject to regulatory requirements.

Currency Exchange
If a transaction requires currency exchange, Lunu Pay applies its exchange rates at the time of execution. When using third-party services for currency conversion, Lunu Pay is not responsible for exchange rate differences.

Purchasing Cryptocurrency
4.3.1. Cryptocurrency purchases can be made through accepted payment methods.
4.3.2. Placing an order constitutes consent to the transaction execution.
4.3.3. Lunu Pay may refuse any order at its discretion.
4.3.4. Cryptocurrency can be redeemed at its nominal value unless restrictions apply.
4.3.5. Transactions are processed only after receipt of funds, less applicable fees.

Transaction Processing
4.4.1. Cryptocurrency balances remain available unless otherwise restricted.
4.4.2. Purchased cryptocurrency is credited after payment clearance.
4.4.3. Transaction fees apply and are deducted accordingly.
4.4.4. Lunu Pay may deduct outstanding fees from available balances.
4.4.5. Wallet balances adjust based on transactions, fees, and cancellations.

Transaction Orders
4.5.1. Transactions are processed only if the Client holds sufficient cryptocurrency.
4.5.2. Orders requiring additional funds may be declined.
4.5.3. If available balance is insufficient, the order is automatically refused.
4.5.4. Orders must include:
(i) Transaction amount and currency;
(ii) Recipient details;
(iii) Date of execution and any required supporting documents.
4.5.5. Orders are final once confirmed.
4.5.6. Transactions are credited to the recipient’s wallet as instructed.
4.5.7. Execution occurs on the next business day if the order is received outside business hours.
4.5.8. Transactions within the Lunu Pay system are processed immediately unless regulatory review is required.

5. ORDER EXECUTION

Crypto transactions must follow Lunu Pay’s system instructions at the time of transfer. If the Client is the Recipient, they must ensure the Payer provides accurate payment details.

If an incorrect order is submitted but not yet processed, the Payer may request a correction. A fee may apply.

Lunu Pay may refuse to execute an order if there are discrepancies in payment details.

Orders may be processed based on the provided wallet address or IBAN alone. Lunu Pay is not obligated to verify whether the details match the Recipient’s name.

If Lunu Pay receives funds but cannot credit them to the Recipient (e.g., due to a closed account or incorrect details), the funds will be returned to the sender, minus applicable fees.

If the Payer’s incorrect details prevent processing, the order may be canceled, and funds returned.

If funds are already credited, they can only be returned upon written request from the Payer and the Recipient’s agreement. A cancellation fee may apply.

If funds are mistakenly credited or deducted, the Client must notify Lunu Pay immediately. Lunu Pay may deduct the incorrect amount without requiring further authorization. If funds are insufficient, the Client must promptly cover the shortfall.

If Lunu Pay incorrectly executes an order, the Client’s balance will be restored, and the transaction will be resubmitted correctly.

If returned funds cannot be credited due to reasons beyond Lunu Pay’s control, they will be credited back to the Client. Transaction fees are non-refundable.

Orders must be clear, accurate, and executable. Lunu Pay is not responsible for errors, inconsistencies, or incomplete details in submitted orders. Orders that lack required information may be refused or processed based on the available details.

If Lunu Pay refuses to process an order, the Client will be notified unless restricted by legal or technical reasons.

Lunu Pay will not process orders if funds are frozen, subject to legal restrictions, or if the Client’s rights to dispose of funds are legally limited.

Orders cannot be withdrawn once submitted and deemed irrevocable.

Lunu Pay retains transaction records for at least five years, extendable as required by regulatory authorities. These records may be shared with authorized parties when legally required.

Lunu Pay may request proof of the lawful origin of funds. If the Client fails to provide documentation, Lunu Pay may refuse to process the order.

The Client guarantees that:
(i) Funds used in transactions are legally sourced and not derived from criminal activities.
(ii) Lunu Pay’s services will not be used for illicit purposes, including money laundering or terrorism financing.

The Client is solely responsible for the accuracy of their warranties. Lunu Pay is not liable for any losses resulting from false or misleading Client information.

6. USAGE OF LUNU PAY SERVICES

Clients must provide accurate transaction details. Lunu Pay is not responsible for losses due to incorrect recipient information.

If cryptocurrency is mistakenly credited, the Client must notify Lunu Pay and return the funds within three business days. The Client has no right to use mistakenly received funds.

The Client confirms that:
(i) Incoming cryptocurrency is legally sourced and not linked to criminal activity.
(ii) Lunu Pay’s services will not be used for illicit purposes, including money laundering or fraud.

Submitting an order through Lunu Pay’s system constitutes the Client’s consent to execute the transaction. Orders cannot be canceled once confirmed.

If a Client’s transaction exceeds predefined limits, additional verification steps may be required.

If the Client does not have sufficient funds for a transaction, the order will be canceled.

Recurring Transactions
(i) Clients may set up recurring cryptocurrency transactions based on selected intervals (e.g., daily, weekly, monthly).
(ii) If a scheduled transaction falls on a non-business day or is delayed due to banking issues, it will be processed on the next available business day.
(iii) Clients can modify, pause, or cancel recurring transactions via their Profile.
(iv) Lunu Pay is not responsible for failed recurring transactions, overdraft fees, or insufficient funds. Clients must ensure their payment method has enough balance.
(v) Lunu Pay reserves the right to terminate recurring transactions with prior notice.

7. TRANSACTION DISPUTE

A crypto transaction is considered authorized once the Client provides consent through authentication methods such as passwords, descriptors, or other identity confirmation tools. Such consent holds the same legal validity as a signed agreement and can be used as evidence in case of disputes. Transactions confirmed by consent cannot be disputed.

By executing a crypto transaction, the Client agrees that Lunu Pay may share necessary personal data with payment providers, financial institutions, and other entities involved in transaction processing.

Clients must report any disputes or claims related to transactions as soon as possible by contacting Lunu Pay support. Disputes should be raised within 13 months from the transaction date.

If a transaction is found to be unauthorized, Lunu Pay will refund the amount and restore the Client’s balance to what it would have been before the disputed transaction, including applicable fees and interest.

Clients may dispute an authorized transaction if the final amount is significantly different from what they reasonably expected based on their profile and past transactions. Such claims must be submitted within 8 weeks of execution. If justified, Lunu Pay will process a refund within 10 business days. If reimbursement is denied, Lunu Pay will provide a reasoned explanation. Transaction fees related to the dispute may not be refunded unless the dispute is deemed valid.

8. CLIENT’S OBLIGATIONS

When using Lunu Pay services, the Client agrees to:
(i) Comply with these Terms and all applicable AML/CTF regulations.
(ii) Provide accurate information and cooperate with Lunu Pay’s verification procedures.
(iii) Complete all KYC requirements and provide necessary documents for compliance.
(iv) Respond to Lunu Pay’s requests within three business days unless otherwise specified.
(v) Promptly update any changes to previously submitted information. Lunu Pay is not responsible for losses due to outdated or incorrect data, and service may be suspended until updates are made.
(vi) Ensure that all funds used in transactions are legally obtained.
(vii) Avoid any use of Lunu Pay’s services that may result in financial, legal, or reputational damage to Lunu Pay or third parties.
(viii) Refrain from using anonymizing tools (e.g., proxies, VPNs) to access the system or registering multiple profiles without authorization.
(ix) Not use Lunu Pay’s services for transactions involving illegal goods or services.
(x) Avoid spreading false or misleading information about Lunu Pay.
(xi) Respect Lunu Pay’s and third-party intellectual property rights.
(xii) Not introduce malware, disrupt the system, or cause damage to Lunu Pay’s infrastructure.
(xiii) Keep login credentials confidential and prevent unauthorized access.
(xiv) Indemnify Lunu Pay for any losses, fines, or liabilities caused by the Client’s failure to comply with these Terms.

The Client is responsible for any damages or financial losses incurred by Lunu Pay, its Clients, or third parties due to violations of these Terms.

The Client must reimburse Lunu Pay for any penalties, fines, or damages resulting from non-compliance.

If login credentials are compromised, the Client must notify Lunu Pay immediately to request account access restrictions.

Upon receiving such a notification, Lunu Pay will block access to prevent unauthorized use. The Client may request proof of this action within 12 months.

Lunu Pay is not liable for unauthorized account access if the request to block an account was submitted by someone other than the Client or an authorized representative.

If login details are stolen or fraudulently used, Lunu Pay may require supporting documentation, such as a police report or incident details, from the Client.

9. FUNDS AND TRANSACTION PROCESSING

Clients must ensure that funds used for transactions originate from a verified source. Lunu Pay may require verification of external payment accounts before processing transactions.

The time required for fund transfers depends on third-party payment providers. Lunu Pay does not guarantee transaction completion timeframes.

Lunu Pay records and stores transaction data for compliance and regulatory purposes. These records may be shared with authorized parties when required by law.

Lunu Pay may refuse to process an order if there are doubts about its legitimacy, such as suspected fraud, falsified documents, or discrepancies in transaction details. Additional verification may be required at the Client’s expense.

Transactions may be rejected if risk analysis determines that the wallet address has a high-risk rating.

Blocked virtual currency may be refunded once the Client provides documents proving a lower risk level. Refunds are processed at Lunu Pay’s discretion, and in exceptional cases, they may be refused.

Transaction fees, review fees for risk assessment, and fees for unlocking blocked funds are non-refundable.

Lunu Pay may require proof of the legal source of funds before executing an order. Failure to provide such documentation may result in transaction rejection.

Transactions may be suspended or canceled if required by law or for other security reasons.

If an order is rejected, Lunu Pay will notify the Client unless restricted by legal or technical constraints.

Lunu Pay will not process transactions if funds are frozen, legally restricted, or subject to regulatory actions.

If funds cannot be credited to the intended recipient due to external factors (e.g., incorrect details, closed account), they will be returned to the Client, minus applicable fees.

Clients must provide transaction-related documents within three business days when requested. Failure to do so may result in service suspension.

Withdrawal transactions are reviewed for compliance with AML regulations. Lunu Pay may refuse withdrawals linked to suspicious activity.

Fiat funds processed through Lunu Pay are intended for cryptocurrency transactions or withdrawals to verified external accounts. Lunu Pay does not pay interest on stored fiat balances.

Only Lunu Pay-approved payment methods may be used for transactions.

All fiat-to-crypto and crypto-to-fiat exchanges are final. Refunds are only processed under specific conditions outlined in these Terms.

Lunu Pay only supports transactions listed here: https://lunu.io/supported-wallets. Unsupported cryptocurrencies sent to a Lunu Pay Wallet can not be processed. Refunds for unsupported assets may take up to 60 days and, in exceptional cases, may not be possible.

Fiat settlements (pay-ins and pay-outs) are processed through Lunu Pay’s designated service providers.

10. PROHIBITED ACTIVITIES

Clients using Lunu Pay services are prohibited from:
(i) Violating these Terms, legal regulations, or AML/CTF laws.
(ii) Providing false, misleading, or inaccurate information.
(iii) Refusing to provide requested verification documents.
(iv) Transacting with illegally obtained funds.
(v) Failing to cooperate with investigations related to compliance or fraud.
(vi) Using services in a way that causes financial, legal, or reputational harm to Lunu Pay or third parties.
(vii) Engaging in actions that disrupt Lunu Pay’s operations or systems.
(viii) Conducting transactions for illegal goods or services.
(ix) Disclosing security credentials or allowing unauthorized access.
(x) Breaching applicable financial or regulatory laws.
(xi) Accessing Lunu Pay services from restricted jurisdictions.
(xii) Using anonymized identities to bypass security measures.

Clients are liable for all damages, fines, and penalties imposed on Lunu Pay due to their violations of these Terms.

11. TERMINATION AND SUSPENSION OF SERVICES

Lunu Pay reserves the right to terminate services and cease business relations with a Client by providing one month’s notice, including instructions for fund withdrawal.

Clients may terminate their use of Lunu Pay services by providing one month’s notice, provided all obligations have been met and no outstanding balances remain.

Upon termination, any remaining funds will be transferred to the Client’s verified external wallet or account, minus applicable fees and unpaid obligations. Disputed funds may be withheld until resolution.

Lunu Pay may immediately suspend services and restrict transactions if:
(i) The Client violates these Terms or legal regulations.
(ii) The Client fails to complete identity verification or provides suspicious documentation.
(iii) Lunu Pay has reason to believe the Client is engaged in fraud, money laundering, or other illicit activity.
(iv) Unauthorized or fraudulent use of services is detected.
(v) The Client undergoes liquidation or bankruptcy.
(vi) Suspension is required by law or regulatory authorities.
(vii) The Client’s activities pose a risk to Lunu Pay’s reputation or third parties.

In cases of suspension, Lunu Pay will notify the Client unless restricted by regulatory obligations.

If there is a reasonable suspicion of financial crime, Lunu Pay may block funds for 30 days, extendable indefinitely until investigations are complete. A Suspicious Activity Report (SAR) may be filed with relevant authorities.

Inactive Clients (no transactions for six months) may have their business relationship terminated. One month’s notice will be given if their balance is zero.

For accounts holding a balance upon termination, Clients will have three months to withdraw funds before they are blocked. Fees may be deducted for delayed withdrawals.

Clients must complete required actions for cryptocurrency redemption. Lunu Pay may, at its discretion, process redemptions where the Client has failed to act.

Lunu Pay is not responsible for losses resulting from service suspension or termination if actions are taken in accordance with these Terms.

Lunu Pay is not liable for transaction delays or interruptions caused by third-party providers but will take reasonable measures to ensure timely execution.

12. FEES AND CHARGES

Fees for Lunu Pay services are listed in the Fee Schedule available on the official website.

Lunu Pay reserves the right to update fees at its discretion and will notify Clients in advance where applicable. Clients should regularly check the website for updates.

Fees depend on the type of service used. All applicable charges will be displayed before transaction execution.

Fees are deducted at the time of transaction execution. If additional conditions apply, they will be specified in a separate agreement.

If the Client’s balance is insufficient to cover the transaction fee, Lunu Pay may decline the transaction until sufficient funds are available.

Payments due to Lunu Pay must be made in the currency specified in the Fee Schedule. Currency exchange fees may apply if conversion is required.

Third-party financial institutions may apply additional fees beyond those charged by Lunu Pay. Lunu Pay is not responsible for such external charges.

Fee changes will be communicated as follows:
(i) Private Clients: Increases or new fees – 60 days' notice before taking effect.
(ii) Business Clients: Increases or new fees – 30 days' notice before taking effect.
(iii) Fee reductions or removals – effective immediately upon update.

If a Client disagrees with a fee change, they may terminate their relationship with Lunu Pay, provided there are no outstanding obligations.

Clients can contact Lunu Pay support for any inquiries regarding fees at support@lunu.io.

13. SECURITY

Lunu Pay ensures compliance with industry security standards and regulatory requirements to protect Client data and transactions.

Lunu Pay may temporarily suspend services for security, maintenance, or technical reasons. Such interruptions will be minimized.

Lunu Pay is not liable for unauthorized access, delays, data theft, or system errors caused by third parties. Clients are responsible for securing their access credentials.

Lunu Pay ensures the confidentiality of data exchanged within its system in accordance with applicable privacy and security policies.

Lunu Pay is responsible for securing transactions and client data during their interaction with Lunu Pay services.

14. COMMUNICATION AND NOTIFICATIONS

Clients agree to receive notifications from Lunu Pay via email and through the website.

Lunu Pay may adjust fees based on changes by third-party service providers and will notify Clients at least 30 days in advance unless a shorter timeframe is required.

Official communication will be sent via the registered email or through the system. Clients must check their email regularly, at least once per business day, for updates.

Lunu Pay may also send notices by post, which will be considered received within three business days unless proven otherwise.

Clients must keep their contact details up to date and notify Lunu Pay within one business day of any changes.

Clients must inform Lunu Pay immediately if their identity documents are lost or stolen.

Any significant changes affecting the Terms (e.g., personal details, legal status, or bankruptcy) must be reported to Lunu Pay within 10 business days.

Lunu Pay reserves the right to suspend services or request additional documents if provided information is incomplete, incorrect, or does not meet legal requirements.

Clients can access the latest Terms, Supplements, and Fee Schedule on the Lunu Pay website at any time.

Messages from Clients are considered received on the same business day if submitted during working hours; otherwise, they will be processed the next business day.

All communication will be conducted in English unless otherwise agreed.

Clients should use official channels (email or system messages) to contact Lunu Pay. Emails must be sent from the registered address; otherwise, they may be considered invalid.

Clients can reach Lunu Pay at support@lunu.io for inquiries.

15. AMENDMENTS TO THE TERMS

Lunu Pay reserves the right to modify or update these Terms by following the notification procedure outlined herein.

Clients cannot unilaterally modify these Terms.

If a Client disagrees with an amendment, they may terminate their use of Lunu Pay services by providing 30 days’ notice.

Clients cannot alter the Fee Schedule or other contractual terms independently.

Notifications sent via the system or to the registered email will be considered properly delivered.

Specific amendments may be introduced via supplementary agreements, which will override general Terms if stated.

Clients may request a draft of proposed amendments or consult Lunu Pay before changes take effect.

16. CONFIDENTIALITY AND DATA PROTECTION

Both Lunu Pay and the Client agree to protect each other’s technical and commercial information. The Client may not share Lunu Pay’s confidential information without written consent.

Lunu Pay ensures the security of cardholder data when processing transactions.

If the Client loses login credentials, they must reset their password immediately or notify Lunu Pay within one calendar day. Lunu Pay is not responsible for losses resulting from delayed notifications.

Upon receiving a security breach report, Lunu Pay will suspend access until the issue is resolved.

The Client is responsible for securing their email and login credentials. Any unauthorized use due to Client negligence is the Client’s responsibility.

Emails and electronic messages exchanged between the parties may serve as evidence in disputes.

Personal data processing is governed by Lunu Pay’s Privacy Policy, in compliance with GDPR and other applicable regulations.

The Client agrees to Lunu Pay processing personal data for identity verification, compliance with AML/CTF laws, and service provision.

Personal data will not be disclosed without a legal or legitimate reason.

Lunu Pay may verify the Client’s identity through third-party data providers to prevent fraud.

The Client must protect Lunu Pay’s confidential business and technical information from unauthorized disclosure.

Personal data will be stored only for the legally required period.

The Client acknowledges that data collection, processing, and access are subject to Lunu Pay’s Privacy Policy.

17. LIABILITY OF THE PARTIES

Each party is responsible for losses, fines, or penalties resulting from their violation of these Terms.

Lunu Pay is only liable for direct damages resulting from a breach of these Terms and only for losses that could have been reasonably anticipated.

Lunu Pay does not guarantee uninterrupted service, as operations may be affected by external factors.

Lunu Pay is not responsible for:
(i) Unauthorized transactions resulting from compromised Client credentials.
(ii) Errors caused by banks, payment processors, or third parties.
(iii) Losses resulting from account termination or service suspension in accordance with these Terms.

The Client is fully responsible for the accuracy of submitted data and bears all losses resulting from incorrect information.

Neither party is liable for failure to perform obligations due to force majeure events. The affected party must notify the other within 10 days of such an event.

The Client must monitor their transactions and notify Lunu Pay immediately of unauthorized activity.

Lunu Pay does not provide financial, investment, or tax advice. Clients must assess risks before using Lunu Pay services.

Lunu Pay is not responsible for any disputes between the Client and third-party recipients of transactions. The Client assumes full responsibility for their transactions.

If Lunu Pay fails to comply with these Terms, it is only liable for foreseeable damages caused by negligence but not for indirect, incidental, or consequential losses.

Lunu Pay is not responsible for losses caused by the Client’s failure to provide accurate and up-to-date information.

While Lunu Pay ensures the security of stored data, the Client acknowledges that online services cannot be completely secure. Lunu Pay is only responsible for data breaches caused by its own negligence.

To the fullest extent permitted by law, Lunu Pay is not liable for lost profits, reputational damage, or business disruptions.

Each party is independently responsible for fulfilling tax obligations. Lunu Pay does not assume responsibility for the Client’s tax reporting or compliance.

18. EVENTS OUTSIDE THE CONTROL OF A PARTY

Neither Lunu Pay nor the Client is liable for failure or delays in fulfilling obligations due to circumstances beyond their control.

Such Events Outside Control include, but are not limited to, natural disasters, strikes, civil unrest, wars, terrorist attacks, government restrictions, and failures in telecommunications or banking systems.

If an Event Outside Control lasts for more than 30 days, either party may choose to terminate the business relationship.

19. MISCELLANEOUS

These Terms and any related agreements constitute the full understanding between Lunu Pay and the Client. If any part of the Terms is found invalid, the remaining provisions will remain in effect.

If a provision is invalidated by law or regulation, it will be replaced by one that closely aligns with the original intent.

These Terms do not grant rights to third parties outside of Lunu Pay and the Client.

The Terms take effect when the Client accepts them and begins using Lunu Pay’s services. They remain in effect until terminated.

The Client cannot transfer their rights or obligations under these Terms to a third party. Unauthorized transfers may lead to immediate termination of services.

Lunu Pay aims to resolve disputes amicably. Clients should contact Lunu Pay before taking legal action.

Lunu Pay may assign its rights and obligations to another entity with 60 days’ notice. The Client’s rights will not be affected.

Complaints about Lunu Pay’s services must be submitted via email, providing relevant details and supporting documents.

Lunu Pay will acknowledge complaints within 5 business days and respond within 30 days, unless regulatory requirements dictate otherwise.

If Lunu Pay cannot resolve a complaint within 30 days, the Client will be informed of the reason and the expected resolution timeframe.

If unsatisfied with Lunu Pay’s resolution, the Client may escalate the complaint to the Financial Ombudsman Service, South Quay Plaza, London E14 9SR, UK.

Complaints regarding regulated services must be resolved within 15 days (PSRs 2017 complaints) or 8 weeks for other disputes.

If Lunu Pay fails to resolve a regulatory complaint within the stipulated time, the Client may refer it to the Financial Ombudsman Service.

These Terms are governed by the laws of England and Wales, and disputes will be subject to the jurisdiction of English courts.

20. SAFEGUARDING AND FINANCIAL PROTECTION

Lunu Pay is a non-banking financial service provider and does not offer deposit protection under the UK’s Financial Services Compensation Scheme (FSCS).

Client funds are safeguarded under Electronic Money Regulations 2011 (EMRs) and Payment Services Regulations 2017 (PSRs).

Client funds are held in segregated accounts with Bank of Lithuania or another authorized financial institution to ensure protection from creditors in case of insolvency.

In the event of Lunu Pay’s insolvency, a liquidator or administrator will oversee fund distribution. Clients may face delays and cost deductions imposed by the liquidator.

Lunu Pay regularly reviews its safeguarding procedures and ensures compliance with FCA safeguarding requirements.

If the Client has concerns about fund protection, they can contact Lunu Pay’s support team at support@lunu.io or escalate concerns to the Financial Ombudsman Service.