SPC RESERVES LTD – Terms and Conditions

Effective Date: [April 18, 2025]

1. Introduction and Acceptance of Terms

SPC Reserves LTD is a private limited company incorporated under the laws of the Dominica (company registration code 2024/C0127), with its registered address at 7 Cross Street, Roseau, Dominica​. These Terms and Conditions (the “Terms”) govern your access to and use of SPC Reserves LTD’ services, including crypto trading, fiat conversion, staking, and leveraged derivatives trading, as described herein (collectively, the “Services”).

By registering an account or using any of SPC RESERVES LTD’ Services, you (“you” or the “User”) acknowledge that you have read, understood, and agree to be bound by these Terms, as well as our Privacy Policy and any other policies or guidelines incorporated by reference. If you do not agree with any part of these Terms, you must not use the Services. Continued use of the Services constitutes your acceptance of these Terms as a binding agreement between you and SPC RESERVES LTD.

Important Notice: SPC RESERVES LTD is beta stage prior to be a licensed financial services provider supervised by the Bank of Dominica​ yet. Cryptocurrency and derivative trading involve a high degree of risk, and you may lose all invested funds. Use of our Services is appropriate only for individuals or entities who can bear the risk of total loss, who fully understand the risks of cryptocurrency markets, and who have a high risk tolerance​. By using our Services, you represent that you meet these criteria. Please carefully review the risk disclosures in Section 8 of these Terms.

2. Definitions

For purposes of these Terms, the following definitions apply:

• Account:A personal or entity account opened with SPC RESERVES LTD through which you access the Services.
• Digital Assets: Cryptocurrencies, tokens, or other virtual assets that are accepted on the SPC RESERVES LTD platform for trading, conversion, staking, or derivatives transactions.
• Fiat Currency: Government-issued currency (such as EUR, USD, etc.) that is designated as legal tender in its country of issuance.
• Services: All products and services provided by SPC RESERVES LTD, including but not limited to cryptocurrency trading services, fiat-to-crypto and crypto-to-fiat conversion, staking of supported digital assets, and leveraged derivatives trading (such as futures contracts), as well as any custodial or wallet services related to the foregoing.
• User (You): Any individual person or legal entity that meets the eligibility criteria in Section 4 and uses or attempts to use the Services.
• Third-Party Service Providers: Any third-party company or contractor integrated with SPC RESERVES LTD to facilitate the Services, such as external cryptocurrency exchanges (liquidity providers), identity verification (KYC) vendors, payment processors, analytics or transaction monitoring tools, etc.
• Applicable Law: Any law, regulation, rule, or regulatory order applicable to SPC RESERVES LTD or to your use of the Services. This includes, without limitation, relevant Dominican laws (such as the Law on Prevention of Money Laundering and Terrorist Financing and other laws governing Virtual Asset Service Providers), and any local laws in the jurisdiction where you reside or use the Services.

Other capitalized terms used in these Terms may be defined elsewhere in the text. In these Terms, unless the context requires otherwise, words in the singular include the plural and vice versa.

3. Scope of Services

SPC RESERVES LTD provides a platform and related Services that allow Users to engage in various cryptocurrency and digital asset related transactions. The Services we offer include:

3.1 Cryptocurrency Trading:SPC RESERVES LTD offers an online platform for buying, selling, and trading Digital Assets. Users can place orders to trade one cryptocurrency for another, or to trade cryptocurrencies against fiat currencies (where supported). SPC RESERVES LTD acts as a crypto broker, matching or routing your orders for execution. When you trade on our platform, you are not trading on a regulated securities exchange; you are trading against SPC RESERVES LTD or its liquidity partners in a brokered environment (sometimes referred to as a “B-Book” model, where SPC RESERVES LTD may act as the counterparty to trades). All trading is subject to market availability and liquidity. Prices of Digital Assets are volatile and can fluctuate rapidly – you agree that it is solely your responsibility to decide whether and how much to trade.

3.2 Fiat Conversion Services:Where supported, SPC RESERVES LTD enables conversion between Fiat Currency and Digital Assets. For example, you may purchase cryptocurrencies using fiat (buy crypto with a credit card, bank transfer, or other payment methods) or liquidate cryptocurrencies into fiat. These conversion services may be facilitated through Third-Party Service Providers such as banks or payment processors. Fiat deposit, withdrawal, or conversion transactions may have additional requirements (such as bank account verification) and may be subject to fees (see Section 7 on Fees). All fiat-related services are provided in compliance with financial regulations – SPC RESERVES LTD does not provide currency exchange services beyond facilitating crypto purchases/sales, and we are not a licensed bank or money transmitter in any jurisdiction except as registered under local laws for virtual asset services.

3.3 Staking Services: SPC RESERVES LTD may offer staking or yield-earning services for certain supported Digital Assets. “Staking” typically means you delegate or lock your cryptocurrency with us (or our staking partners) to support the operations of a blockchain network (for example, participating in proof-of-stake validation) and in return you may earn rewards (additional cryptocurrency) over time. When you use our staking service, you remain the owner of the staked assets, but you grant SPC RESERVES LTD the authority to stake the assets on your behalf and to collect and distribute any associated rewards. SPC RESERVES LTD does not guarantee any staking returns – any indicative annual percentage yield (APY) or reward rate is an estimate and subject to change based on the applicable blockchain network conditions. You acknowledge that staking involves risks: the underlying protocol may change rules, there may be slashing penalties by the network (for instance, if a validator fails or misbehaves), or other technical failures could result in loss of staked assets or rewards. We will use reasonable care in providing staking services, but we are not liable for losses arising from protocol-level issues or other risks inherent to staking. You may be required to keep assets locked for a certain minimum period when staking; any such requirements will be disclosed in the specific terms for the staked asset. SPC RESERVES LTD reserves the right to modify or discontinue staking services for any asset at any time (for example, if the regulatory environment changes or if the third-party staking provider experiences issues).

3.4 Leveraged and Derivatives Trading (Futures): SPC RESERVES LTD offers leveraged trading products, including futures contracts or other derivatives tied to Digital Asset prices. These products allow you to take leveraged positions (long or short) on cryptocurrencies – meaning you can gain greater exposure with a smaller upfront margin deposit. Leverage amplifies both potential profits and potential losses. When you engage in derivatives trading on SPC RESERVES LTD:

• You may be required to post collateral (margin) in either crypto or fiat as specified. The amount of leverage (e.g., 2x, 5x, 10x, etc.) will determine the required margin and maintenance levels.
• Margin Calls and Liquidation: You must monitor your positions and maintain sufficient collateral. If the value of your position moves against you and your account equity falls below required maintenance margins, SPC RESERVES LTD may automatically liquidateyour position in whole or in part to prevent further losses. Liquidation can happen without prior notice, and you are liable for any remaining deficit in your account after liquidation. In fast-moving markets, especially with high leverage, it is possible that your position could be liquidated at a loss larger than your collateral, resulting in a negative account balance. You agree to pay immediately any negative balance and authorize SPC RESERVES LTD to recover such amounts from your account or future deposits.
• No Guaranteed Stop-Loss: While you may set stop-loss orders or other risk management orders, SPC RESERVES LTD cannot guarantee that these will execute at your intended price, especially during periods of extreme volatility or market gaps. There may be instances of slippage or inability to execute orders at the specified price due to market conditions.
• Product Nature: The futures or derivative contracts offered are settled in cash or crypto (depending on the product) and do not necessarily involve delivery of the underlying asset. They are not traded on a regulated futures exchange; they are offered under SPC RESERVES LTD’s platform terms. These products are not suitable for inexperienced traders. By engaging in leveraged trading, you represent that you understand the product mechanics and risks.
• Regulatory Restrictions: Derivative products may be subject to additional legal restrictions in some jurisdictions (see Section 4 on Eligibility and Section 3.5 below on Restricted Jurisdictions). SPC RESERVES LTD may require you to pass additional suitability or knowledge checks before enabling certain high-risk products, in compliance with Applicable Law or internal risk policies.

3.5 Custody of Assets:In providing the above Services, SPC RESERVES LTD will at times hold your funds (whether Fiat Currency or Digital Assets) in one or more custodial accounts/wallets. SPC RESERVES LTD will segregate customer assets from the Company’s own assets and employ security measures to safeguard funds (including using cold storage for crypto when possible). You agree that SPC RESERVES LTD may use third-party banking partners or cryptocurrency custodians to hold your funds. Your assets may be pooled with those of other users in omnibus accounts for the sake of operational efficiency; however, detailed records are maintained to track your individual balances​. While under our custody, you authorize SPC RESERVES LTD to take actions with your assets as required to provide the Services (for example, transferring your crypto to a trading liquidity venue or staking node, converting currencies per your orders, etc.).

Important: Assets held with SPC RESERVES LTD are not insured or guaranteed by any government or regulatory insurance scheme. For example, cryptocurrency holdings are not covered by FDIC insurance in the United States or any deposit guarantee scheme in Dominica or the EU​. Likewise, Digital Assets are not considered “securities” or “investment” products that would benefit from investor compensation schemes in the EU. You bear the risk of loss of your assets (due to market conditions or otherwise) while they are held with SPC RESERVES LTD, except to the extent such loss is directly caused by SPC RESERVES LTD’ gross negligence or willful misconduct (in which case liability would be limited as described in Section 10).

SPC RESERVES LTD may introduce new services, or modify or discontinue existing services, at its discretion and in accordance with Applicable Law. We will notify users of material changes to our Services. Some Services may be provided under supplemental terms or product-specific agreements, which will be made available to you and shall be read together with these general Terms.

4. User Eligibility and Compliance Requirements

4.1 Eligibility Criteria:To register an Account and use SPC RESERVES LTD’ Services, you must meet all of the following conditions:

• Minimum Age and Capacity: You are at least 18 years old (or the minimum legal age in your jurisdiction to form a binding contract and engage in the activities offered, if higher). You have the full legal capacity to enter into these Terms. If you are an individual, you are not under any legal incapacity or impairment that would make you unable to accept these Terms. If you are registering on behalf of a legal entity, you represent that you are duly authorized to bind that entity to these Terms and that the entity is validly formed and in good standing.
• KYC Verification: You agree to provide accurate, current, and complete information about yourself (and, if applicable, your organization) as prompted by the registration and Know-Your-Customer (KYC) processes, and you agree to promptly update any information if it changes. This includes but is not limited to your full legal name, address, nationality, government identification number, and any documents or photographs necessary to verify your identity. SPC RESERVES LTD is required by law to verify the identity of its Users and to implement anti-money laundering (AML) measures​. You will comply with all requests from SPC RESERVES LTD or its KYC vendors for further information and documentation (for example, source of funds, proof of address, selfie or liveness check, etc.)​. We reserve the right to reject your account application or to suspend/terminate your Account if your information cannot be verified or if you do not satisfy our compliance checks.
• Clean Sanctions Screen: You represent that you are not subject to any international sanctions or watchlist, including but not limited to being listed on the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals list, the EU or UK financial sanctions lists, United Nations Security Council sanctions lists, or any equivalent list. You also represent that you are not a politically exposed person (PEP) as defined by AML laws, or if you are, you have disclosed that status to SPC RESERVES LTD and provided any additional documentation requested.

• Permissible Jurisdiction: You are not a resident, citizen, or located in a country or region where our Services are prohibited or unauthorized. SPC RESERVES LTD does not offer accounts to users in certain Restricted Jurisdictions (see Section 5 below). By opening an account, you confirm that you are not a resident of, located in, or attempting to access the Services from any of the following: the United States of America (U.S.)​, United Kingdom(U.K.) (with respect to crypto-derivative products, which are banned for retail in the UK), Canada (including the provinces or territories that disallow unregistered crypto trading or derivatives), China, Russia,North Korea, Iran, Syria, Cuba, or any other country that is subject to comprehensive sanctions or where cryptocurrency trading or the specific Services we offer would violate Applicable Law or require SPC RESERVES LTD to obtain a license or registration which it has not obtained. You also agree that you will not use VPNs, proxies, or other techniques to misrepresent your location or identity to circumvent these restrictions​. If your residency or location changes to a restricted area, you must cease using the Services immediately and inform SPC RESERVES LTD.
• No Previous Bans: You have not been previously suspended or removed from SPC RESERVES LTD or any other cryptocurrency exchange or trading platform for violations of any user agreement or illegal conduct. If you have had such an incident, you must disclose this to SPC RESERVES LTD, and we reserve the right to refuse service.
• Legally Obtained Funds: You affirm that the Fiat Currency and Digital Assets you use on our platform are your lawful property and derived from legitimate sources. You will not deposit, trade, or withdraw any assets that are tainted by criminal activity, nor use the platform to conceal or transfer proceeds of crime. You also agree that you will only use payment methods or bank accounts in your own name for depositing or withdrawing funds; you will not use third-party payment instruments or accounts not legally yours.

If you do not meet all of these criteria, you are not eligible to use our Services. SPC RESERVES LTD may refuse to open an Account for you, or may limit or terminate your use of Services, if we believe you do not meet the eligibility requirements.

4.2 Account Registration:To use the Services, you must create an Account by providing all required information and completing any verification procedures. You agree to:

• Maintain Security: Choose strong security credentials for your Account (such as a robust password and enabling two-factor authentication (2FA) if available). You are responsible for maintaining the confidentiality of your login credentials. All activities under your Account are deemed authorized by you. If you suspect that your Account credentials have been lost, stolen, or compromised, or if there is any unauthorized use or suspicious activity in your Account, you must notify SPC RESERVES LTD immediately. SPC RESERVES LTD is not liable for any loss you incur due to unauthorized access to your Account (unless it is proven that SPC RESERVES LTD failed to employ reasonable security measures and that was the direct cause of the unauthorized access).
• One Account Rule: Unless expressly permitted by SPC RESERVES LTD in writing, you may only register and maintain one Account for your personal use (and if you are an entity, one Account per entity). Creating multiple accounts for the same user, or using someone else’s identity or information to create an account, is strictly prohibited. You also may not sell, rent, share, or otherwise transfer your Account to any other person.
• Accuracy of Information: You guarantee that all information you provide to SPC RESERVES LTD during signup and throughout your use of the Services is truthful, accurate, and up-to-date. If any of your information (such as address or tax residency or legal name changes) becomes outdated or incorrect, you agree to promptly update it in your Account or notify SPC RESERVES LTD support. Providing false information or documentation, or refusing to provide information as required for compliance, constitutes a serious breach of these Terms and could result in immediate suspension or termination of your Account.
• Continuous Compliance: Even after your Account is opened, SPC RESERVES LTD will continuously monitor account activity for compliance and risk purposes (including AML transaction monitoring). We may, at any time, request additional information or documentation from you as part of ongoing due diligence. You agree to comply with such requests promptly. This may include periodic re-validation of your identity, source of funds/wealth questionnaires, proof of ongoing residence, or other checks, especially if your transaction volumes or patterns change or if required by changes in law or our internal policies.
• Refusal and Closure: SPC RESERVES LTD reserves the right to refuse to open an Account for any applicant at our sole discretion, and we are not obligated to disclose the specific reasons. We also may suspend or close your Account as required by law (for example, if you become a sanctioned person, or if you engage in suspicious activities) or as otherwise permitted under these Terms (see Section 9 on Termination). If your Account is closed, we will, when legally permissible, return any funds belonging to you that are not subject to any legal hold or obligation, after deducting any amounts owed to SPC RESERVES LTD (e.g., fees, or negative balances).

4.3 Compliance with Laws (AML/CFT and Other Laws): SPC RESERVES LTD takes compliance seriously. By using our Services, you agree to abide by all Applicable Laws, including those concerning anti-money laundering (AML), countering the financing of terrorism (CFT), anti-fraud, and tax laws. Specifically:

• AML/CFT:SPC RESERVES LTD is subject to the Dominican Law on the Prevention of Money Laundering and Terrorist Financing and related regulations, as well as EU directives and other international AML standards​. We maintain an internal Anti-Money Laundering and Counter-Terrorism Financing Policy in line with these requirements​. We are prohibited from doing business with certain individuals or entities and from accepting anonymous or unverified customers​. You acknowledge that SPC RESERVES LTD will monitor transactions and may report any suspicious activity to the Financial Crime Investigation Service (FCIS) of Dominica or other relevant authorities without notice to you. Transactions that appear to involve fraud, money laundering, terrorist financing, or any predicate offenses will be investigated and may be frozen, reversed, or seized in accordance with law. It is also prohibited for Users to attempt to mask or anonymize their activities, for instance by using mixers/tumblers or by providing addresses associated with darknet marketplaces or other illicit activities. We use third-party blockchain analysis tools to screen crypto addresses; if an address or transaction triggers our risk criteria (e.g., associated with known criminal activity), we may refuse or halt the transaction and require further explanation from you.
• Sanctions: As noted, you represent you are not under sanctions. You must not attempt to use SPC RESERVES LTD to transact with any sanctioned person or entity or any person in a sanctioned jurisdiction. SPC RESERVES LTD will adhere to sanctions regimes (EU, U.S., UN, etc.) that are applicable to it. If we determine that your account is associated with a sanctioned jurisdiction or person, we will freeze the account and assets and may report it to authorities. You may not use your account to circumvent export controls or trade embargoes (for example, you cannot use our Services to send value to someone in a country that is embargoed).
• Fraud and Market Abuse: You agree not to engage in any fraudulent activity, insider trading, market manipulation, or any other abusive trading practices. This includes activities such as wash trading, self-dealing, pump-and-dump schemes, spoofing orders, layering, front-running, quote stuffing, or disseminating false or misleading information in order to influence market prices. Such behaviors are often illegal under securities or commodities laws and are strictly forbidden on our platform even if the assets traded are not formally classified as securities. SPC RESERVES LTD reserves the right to monitor trading activity and investigate any suspected abuse. We may, at our discretion or upon request from regulators, provide trading data to assist in investigations of market abuse.
• Consumer Protection and Other Laws: If you are using the Services as a consumer (for personal, non-commercial use), be aware that certain consumer protection laws may apply. SPC RESERVES LTD endeavors to comply with applicable consumer protection requirements, such as providing clear information about our Services, pricing, and enabling avenues for dispute resolution (see Section 13 and 14). However, given the nature of digital asset trading (which often involves financial market fluctuation), you acknowledge that you do not have a statutory right of withdrawal (cooling-off period) after entering into transactions, to the extent permitted by law, because the price of Digital Assets can fluctuate significantly in a short period and thus fall under exceptions for “goods or services with price dependent on financial market fluctuations” in consumer law. Nothing in these Terms will deprive you of any rights you have under mandatory consumer laws that by law cannot be waived​.
• Tax Compliance: You are solely responsible for understanding and fulfilling all tax obligations arising from your trading or holding of Digital Assets and use of our Services. This includes reporting and paying any applicable taxes (such as income tax, capital gains tax, value-added tax, or any other taxes) to your relevant tax authorities. Cryptocurrency gains may be taxable – for example, Dominica currently taxes gains from sales of crypto at 15% as income​ (with certain exemptions), and other jurisdictions have their own rules. SPC RESERVES LTD does not provide tax advice​, We recommend you consult with a tax advisor if you are unsure about your tax obligations. SPC RESERVES LTD may be required by law to report certain information about you or your transactions to government authorities (including tax authorities) or to withhold taxes from payouts in some cases. By using the Services, you acknowledge that we will comply with any legal requests for information sharing (for example, under EU Directive DAC7 or similar frameworks requiring crypto-asset reporting) and withholdings.

5. Restricted Jurisdictions and U.S. Persons

SPC RESERVES LTD’s Services are not available in certain jurisdictions. This section highlights these restrictions:

• United States: SPC RESERVES LTD is not registered as a Money Services Business in the U.S., nor as a futures commission merchant or any other regulated entity with the CFTC or SEC. Therefore, U.S. persons (including U.S. citizens, U.S. residents, anyone physically present in the United States, and anyone using our Services from within U.S. territory) are strictly prohibited from using SPC RESERVES LTD’ Services​. By “U.S. persons,” we also include green card holders and persons falling under the definition of U.S. Person in SEC Rule 902(k) or U.S. residents as defined under CFTC rules. If SPC RESERVES LTD suspects that you are a U.S. person or using the Service from the U.S., we may freeze and/or close your account. Transactions with U.S. financial institutions may also be restricted (for instance, we may not allow bank transfers to/from U.S. banks).
• Jurisdictions Banning Crypto or Requiring Local License: If you are in a country that has banned cryptocurrency trading, exchange, or futures (such as mainland China, which has banned crypto trading), you are not allowed to use our Services. Similarly, if you are in a jurisdiction that permits crypto trading only if the provider is locally licensed or registered, and SPC RESERVES LTD has not obtained such license, you must not use our Services. For example, in the United Kingdom, the Financial Conduct Authority (FCA) has banned the sale, distribution, or promotion of crypto-derivatives (including futures) to retail consumers​. Therefore, SPC RESERVES LTD does not allow UK-based retail Users to access our leveraged derivatives products. If you are accessing from the UK, you are limited to non-derivative Services (e.g., spot trading) and only if such use is lawful. Other examples include jurisdictions like Japan, South Korea, or Canada(certain provinces) that have licensing regimes – unless SPC RESERVES LTD has the required authorization in those places, Users in those places should not engage our Services. It is your responsibility to ensure that your use of the Services is legal in your jurisdiction. SPC RESERVES LTD shall not be liable if you misuse the Services in a country with legal restrictions; we will however take steps to prevent and detect such usage and terminate it when discovered.
• Sanctioned and High-Risk Countries: As noted in Section 4, Users from or in comprehensively sanctioned countries (e.g., North Korea, Iran, Syria, Cuba, Crimea region, the so-called Donetsk/Luhansk regions, etc.) cannot use the Service. Additionally, SPC RESERVES LTD may at its discretion restrict or prohibit services in countries that are considered high-risk or have unclear regulatory status for crypto, even if not officially sanctioned. This may include countries with extremely limited financial transparency or high levels of corruption where we cannot reasonably mitigate risk.
• Notice to Non-Dominican Users: SPC RESERVES LTD primarily operates under Dominican law. If you reside outside Dominica, ensure that you are allowed to use an overseas cryptocurrency service. By using SPC RESERVES LTD, you give an affirmative representation that you are not violating any laws by doing so. We reserve the right to implement controls to restrict access from any jurisdiction if required (such as IP address blocking or GPS location verification). Attempting to circumvent these controls (for example, by using Tor or VPN proxies to appear as if you are from a different country) is a violation of these Terms and may result in account termination.

SPC RESERVES LTD may update the list of Restricted Jurisdictions from time to time to account for changes in law or risk tolerance. Such changes may be made without prior notice if required by law. We may also request you to certify your location or nationality periodically. If you become a resident in a Restricted Jurisdiction, you must notify us and stop using the Services immediately.

6. Third-Party Services and Integration

To provide our Services efficiently, SPC RESERVES LTD relies on various third-party service providers and partners. By using SPC RESERVES LTD, you acknowledge and agree to the involvement of third parties in delivering the Services, and you consent to our sharing of necessary information with them as outlined below:

• Liquidity and Trade Execution (Exchange Integration):SPC RESERVES LTD may integrate with or route orders to external cryptocurrency exchanges or liquidity providers to execute your trades at the best available prices. For example, SPC RESERVES LTD might utilize the trading infrastructure or APIs of third-party exchanges such as KuCointo fill orders. This means that when you place an order on SPC RESERVES LTD, an equivalent order may be placed on a third-party platform in SPC RESERVES LTD’ name (for the benefit of SPC RESERVES LTD users). Your trading experience remains within the SPC RESERVES LTD interface, but behind the scenes, SPC RESERVES LTD may be conducting transactions on external venues. You authorize SPC RESERVES LTD to act as your agent in such cases for the purpose of executing trades. While SPC RESERVES LTD will use reputable exchange partners, we have limited control over their systems. Accordingly, you acknowledge that:
• Trade execution is subject to the operational integrity of third-party systems. Delays, outages, or errors on those external platforms can impact your trades with SPC RESERVES LTD. SPC RESERVES LTD is not liable for failures caused by these external venues beyond our control.
• Your orders might be exposed to the market through these third parties, which could involve some counterparty risk (e.g., if the external exchange fails financially or is hacked). SPC RESERVES LTD will exercise due diligence in choosing partners and will manage the custody of assets to minimize such risks, but any losses arising from a third-party exchange’s insolvency or security breach may ultimately affect SPC RESERVES LTD users. We disclaim liability for such losses to the extent permitted by law (see Section 10).
• The external exchanges may have their own terms of service and trading rules. We strive to ensure that nothing in our use of such services conflicts with these Terms or creates additional obligations for you. You will not have a direct relationship with those exchanges as a user; SPC RESERVES LTD will be the party contracting with them. However, certain market practices (like circuit breakers, trading halts, etc.) might indirectly affect your trading on SPC RESERVES LTD.
• Identity Verification (KYC) Providers: We may use third-party vendors to verify your identity and documents as part of compliance onboarding. These KYC providers (for example, specialized RegTech companies) will receive the personal information you submit (such as ID documents, selfies, personal details) and will conduct verification checks (which may include database checks, biometric comparisons, watchlist screenings, etc.). SPC RESERVES LTD contractually requires these providers to protect your data and use it only for verification purposes, but by using our Service you consent to our transfer of your data to such third parties for the purpose of KYC/AML verification. We remain responsible for compliance with data protection laws in this context (see Section 12 on Data Protection), but the process itself might be fulfilled by a third party. If a KYC provider cannot verify you to our satisfaction, we may ask for additional information or deny service.
• Payment Processors and Banking Partners: For handling fiat currency transactions (deposits, withdrawals, card processing, etc.), SPC RESERVES LTD integrates with banks, payment gateways, or electronic money institutions. For example, if you initiate a SEPA bank deposit or a credit card purchase of crypto, the transaction may be processed by an intermediary bank or a payment service provider contracted by SPC RESERVES LTD. These third parties might have access to your basic payment information (like your name, account number, etc.) as needed to execute the transaction. All fiat transfers are subject to the rules of the payment networks and the partner’s terms. You authorize us to share necessary transaction details with these partners. SPC RESERVES LTD isn’t responsible for delays or fees introduced by these partners (like a sending bank’s wire fee or a card processor’s charges), but we will help liaise with them to resolve issues when possible.
• Blockchain Network Providers and Nodes: For certain Services such as staking or facilitating deposits/withdrawals, SPC RESERVES LTD may run its own nodes or may rely on third-party node operators or wallet providers. If we use a custodial wallet provider or a third-party blockchain infrastructure provider, you acknowledge that your public addresses and transaction details will pass through those systems. Likewise, if we use a third-party staking service or pool to stake your assets, your assets might be delegated to that provider’s wallets. We carefully select such providers, but cannot guarantee their performance or security beyond what a reasonable assessment can ensure.
• Analytics and Monitoring Tools: SPC RESERVES LTD uses third-party tools for fraud prevention, transaction monitoring, and platform analytics. For example, we might use a blockchain analysis service to score transactions for risk (to detect potential illicit activity) or use analytics cookies on our website to understand how users navigate our platform. The usage of such tools may involve sharing some data (potentially pseudonymized where appropriate) with the tool providers. These activities are governed by our Privacy Policy. For instance, blockchain monitoring tools will see data related to cryptocurrency addresses and flows but not necessarily personal identifying information, unless needed for investigation.

5.1 Third-Party Terms and Liability:While these Terms govern your relationship with SPC RESERVES LTD, certain third-party services integrated into our platform might also impose their terms (for example, using an open banking payment method might invoke terms of the banking API provider). We will endeavor to inform you where any separate terms apply. By accepting these Terms, you also agree to abide by any relevant terms of our third-party providers that have been disclosed to you. If a third-party service used by SPC RESERVES LTD discontinues or changes its service or terms such that it affects SPC RESERVES LTD’ provision of Services, SPC RESERVES LTD may modify, suspend, or terminate the affected Services with or without notice as required.

SPC RESERVES LTD is not liable for the services and acts or omissions of third parties, except as required by law.To the extent a third-party integration fails or causes loss (for example, a bank holds your funds, or an exchange partner has downtime that causes you loss), SPC RESERVES LTD will, to a commercially reasonable extent, assist in rectifying the situation, but such issues may be outside our direct control and are provided on an “as is” basis. You agree that your sole remedies for third-party issues will be limited to what is available against that third party, and SPC RESERVES LTD makes no additional promises. However, nothing in this section waives your rights or our obligations under law – we will remain responsible for our legal duties as a data controller under GDPR when sharing data (see Section 12), and we will not disclaim liabilities that by law we cannot (if, for instance, a third-party was effectively our subcontractor and caused personal injury or other damage which cannot be disclaimed).

SPC RESERVES LTD may change or replace any Third-Party Service Provider at its sole discretion and without individual notice to users (we may announce general changes if significant). Continued use of the Services signifies your consent to such changes. If you have any concerns about a particular third-party integration, please contact us for more information or cease using the part of the Service that involves it.

7. User Obligations and Prohibited Activities

By using SPC RESERVES LTD Services, you agree to conduct yourself in a lawful and cooperative manner. This section describes your general obligations as a User and specifies certain prohibited activities. Violation of any part of this section is grounds for account suspension or termination (Section 9) and may also result in legal action against you or referral to law enforcement.

7.1 Your Obligations:You agree to the following general obligations:

• Use for Lawful Purposes: You will use the Services only for lawful purposes, in compliance with all Applicable Laws and these Terms. You will not use the platform to further any illegal activity, such as money laundering, terrorist financing, tax evasion, fraud, or any crime.
• Account Security and Integrity: You are responsible for maintaining the security of your Account as mentioned. Do not allow others to use your Account. You will not impersonate any person or use login credentials other than your own. If you are aware of any unauthorized access to your Account, you will notify us promptly (as stated in Section 4.2).
• Follow Instructions and Policies: You will follow any operational or security procedures that we communicate to you. This may include setting up two-factor authentication, abiding by withdrawal hold periods for large deposits, or following specific steps to authenticate high-value transactions. You also agree to follow our Platform Rules or User Guidelines if we publish any (for example, if we have a policy on how to respectfully communicate on any community forums or with support, you will abide by it).
• Cooperate in Investigations: If SPC RESERVES LTD is investigating suspected misconduct, whether by you or another user, you agree to cooperate with us to the extent reasonably required. This may include providing information or statements about transactional activity and assisting law enforcement if an official request is made (to the extent such cooperation is required by law).
• Maintain Equipment: You are responsible for the equipment and internet connection that you use to access the Services. Ensure that your computer, mobile device, software, and internet are functioning properly and using up-to-date security protections (antivirus, etc.). We are not liable for issues stemming from your own equipment failures, viruses/malware on your system, or connectivity problems.
• Financial Responsibility: You are responsible for any financial losses you incur from using the Services (trading or otherwise). You acknowledge that all trading decisions are made by you alone. You will not attempt to hold SPC RESERVES LTD responsible for market losses. Additionally, if you owe any amounts to SPC RESERVES LTD (for example, negative balance, chargeback fees, or reimbursement of investigation costs due to your violation of these Terms), you agree to pay such amounts promptly. We may deduct from your account or take collection actions as described elsewhere in these Terms.
• No Advice: You understand and agree that SPC RESERVES LTD provides execution-only services and does not provide investment advice, financial advice, trading advice, or any recommendation or opinion on the suitability of any transaction​. Any education materials, market analysis, or news on our website are for informational purposes only and not tailored to you. You are responsible for your own investment research and decisions. If you believe you need professional advice, you should consult qualified financial or legal professionals.

7.2 Prohibited Activities:You must not engage in any of the following activities when using SPC RESERVES LTD Services:

• Unlawful Use: Using the Services in any manner that violates any law or regulation. This includes, but is not limited to, using the platform for illegal gambling, fraud, extortion, dealing in stolen goods or data, financing criminal enterprises, or any activity that would be a crime or civil offense in any jurisdiction (e.g., selling drugs, financing prohibited weaponry, etc.).
• Unauthorized Financial Services: You may not use your SPC RESERVES LTD account to operate or assist in any type of unlicensed money services business, payment processing, banking, or financial services for a third party. For example, you cannot use your account to receive funds on behalf of others or to act as an intermediary for others’ trades outside the platform. Your account is for your personal (or your entity’s) use only, not for brokering trades for others or as a payment agent.
• Circumventing Security or Access Controls: Attempting to bypass, disable, or defeat any security measures that SPC RESERVES LTD uses to protect the platform and user accounts. This includes trying to hack into other users’ accounts, probing or testing the vulnerability of our systems or networks, breaching authentication measures, or accessing any systems or data not intended for you. You may not use any automated means (such as bots, scripts, scrapers) to access or collect data from the platform without our express permission. Additionally, you may not use the Services through any interface not provided by SPC RESERVES LTD (e.g., unauthorized third-party apps).
• Malicious Tech Behaviors: Introducing any malware, virus, Trojan horse, worm, logic bomb, or other harmful material into the platform. You shall not engage in Denial of Service (DoS) attacks or behave in a manner that imposes an unreasonable load on our infrastructure (e.g., excessive API calls outside allowed usage, spam transactions designed to clog networks, etc.).
• False or Misleading Information: Providing SPC RESERVES LTD or other users with false, misleading, or deceptive information at any time. This includes creating fake identities, falsifying documents, making false statements about transactions (e.g., falsely claiming unauthorized transactions or chargebacks without cause), or attempting to mislead SPC RESERVES LTD compliance personnel in the course of their duties. It also includes activities like price manipulation through spreading rumors or false news about a Digital Asset.
• Market Manipulation: Engaging in activities that manipulate or tamper with the markets on the SPC RESERVES LTD platform or on integrated liquidity venues. Prohibited manipulative behaviors include:
• Wash trading: where you (alone or with others) buy and sell the same asset to create artificial volume or price.
• Spoofing: placing orders with the intent to cancel before execution (to create a false impression of demand or supply).
• Layering: submitting multiple orders at different price levels without intent to execute, to move the market or book appearance.
• Pump and Dump schemes: coordinating with others to inflate the price of an asset you hold and then selling at the top.
• Insider trading: if you have non-public material information about a crypto asset or a company (for instance, from a job or an exploit knowledge), you must not trade on that basis if it violates any duty or law. Even if crypto markets aren’t fully regulated like securities, we expect ethical behavior in line with market integrity.
• Front-running: using knowledge of other users’ large pending orders or SPC RESERVES LTD’ own trading plans to take advantage by trading beforehand.

SPC RESERVES LTD may monitor trading patterns for such activities. While the decentralized nature of crypto might make some manipulation hard to detect, we reserve the right to enforce trading pauses, rollbacks, or other remedial measures if we determine market manipulation has occurred. We may also report serious incidents to regulators.

• Infringement of Intellectual Property: You may not use SPC RESERVES LTD Services to host, transmit, or propagate any content that infringes on others’ intellectual property rights (e.g., uploading illegal copies of software via some future service, or posting copyrighted material without permission in any forum/chat associated with SPC RESERVES LTD). You also must not reverse engineer, decompile, or disassemble any of our software or the platform, nor attempt to derive source code or underlying trade secrets. Scraping content or data from the platform for unauthorized use is also prohibited.
• Abusive Behavior: You will not engage in threatening, harassing, or abusive behavior towards SPC RESERVES LTD staff or other users. This includes obscene or hateful language, doxxing (publishing personal info), or any kind of harassment. We understand that financial losses can be stressful, but we maintain a zero-tolerance policy for abuse of our support personnel or other users.
• Multiple Account Abuse: As noted, you cannot maintain multiple accounts or use multiple identities to bypass limits or restrictions. For example, if your account is suspended, you cannot open a new one. If we have trading limits or promotions intended per user, you cannot claim them multiple times via sock-puppet accounts.
• Using the Service for Commercial Data Usage: Unless expressly permitted by us, you should not use any data obtained from the SPC RESERVES LTD platform (such as market prices, volume, order book data) for commercial purposes outside the platform – for instance, operating your own price feed or as input for high-frequency trading bots that aren’t trading on SPC RESERVES LTD. (Note: If we provide API access with specific terms of service for data, you must adhere to those terms; unauthorized harvesting of data is disallowed.)
• Security Testing Without Authorization: While we appreciate responsible disclosure of security vulnerabilities (and have a process for it), you should not attempt to test the limits of our smart contracts, APIs, or platform in a way that could cause harm, without coordinating with us. For example, you should not intentionally exploit any glitch or bug you might discover – instead, report it. Exploiting a vulnerability for gain or performing attacks under the pretense of “testing” is prohibited and could be illegal.

This list of prohibited activities is not exhaustive. Any conduct that is analogous to the above, that is unlawful, or that in our judgment threatens our users, our operations, or our reputation, can also be deemed a violation. SPC RESERVES LTD reserves the right to take any appropriate measures if we suspect or detect prohibited activities, including blocking transactions, freezing funds, reporting to authorities, and pursuing civil remedies.

8. Fees and Taxes

8.1 Fees for Services:Using SPC RESERVES LTD Services may incur fees. Our fee schedule is published on our website or app and is hereby incorporated by reference. Fees may be updated from time to time, and we will endeavor to notify users of significant fee changes (for example, by posting an update or sending an email prior to changes taking effect). Types of fees that may apply include, but are not limited to:

• Trading Fees: When you execute a buy/sell trade on the platform, a commission or spread may be charged. This could be a percentage of the trade value or built into the price you pay (for instance, SPC RESERVES LTD may offer you a price slightly worse than market to include its fee). The fee might differ for “maker” orders (which add liquidity to order books) vs “taker” orders (which remove liquidity), or based on your 30-day trading volume or account tier. The current structure, if tiered, will be detailed in the fee schedule.
• Conversion Fees: For fiat-crypto conversions or vice versa, SPC RESERVES LTD may charge a fee or a spread. Additionally, third-party payment providers might charge their own fees (e.g., a credit card processor fee). We will disclose SPC RESERVES LTD’s own fees; third-party fees (like a bank’s wire fee) may not be fully within our control but we will try to inform you of typical charges where possible.
• Withdrawal/Deposit Fees:
• Crypto Withdrawals: When withdrawing Digital Assets from your SPC RESERVES LTD account to an external wallet, SPC RESERVES LTD may charge a fixed fee or a fee based on network costs. Often, we will pass along the blockchain transaction (miner) fee to you – either by deducting a preset amount or letting you choose a fee level. The fee schedule will list withdrawal fees per asset.
• Fiat Withdrawals: Bank withdrawals may incur a fee (for example, a SEPA or SWIFT transfer fee). Similarly, deposits via certain methods might carry fees (e.g., if you deposit by card, there might be a processing fee).
• Internal transfers: If SPC RESERVES LTD allows internal transfers between users, those might be free or have conditions, which would be specified.
• Staking Fees: If you participate in staking through SPC RESERVES LTD, we may take a commission from the staking rewards you earn. For example, if a network yields 5% and we charge 10% of rewards as a service fee, you effectively get 4.5%. The details of any such commission will be communicated per asset or in the staking offer details.
• Margin and Funding Fees: For leveraged positions, SPC RESERVES LTD may charge funding fees or interest on borrowed amounts. This can function similarly to margin interest or a periodic funding rate for perpetual futures. The rates for such funding are often dynamic (depending on market conditions or matched between long/short interest). We will disclose the mechanism in the product details. For instance, perpetual swaps might have a funding payment every 8 hours between longs and shorts; SPC RESERVES LTD might not take a fee on that (being just between traders), but if SPC RESERVES LTD itself is providing margin funding, an interest rate might be charged.
• Inactivity or Account Maintenance Fees: SPC RESERVES LTD generally does not charge fees just for having an account. However, if permitted by law, we reserve the right to introduce a modest inactivity fee for accounts that have a balance but no activity for an exceedingly long period (say, over 1-2 years), to cover the cost of maintaining custody. If we ever implement this, it will be clearly communicated in advance and will only apply where lawful (some jurisdictions forbid inactivity fees on certain accounts).

8.2 Fee Deduction and Payment:You agree that SPC RESERVES LTD is authorized to deduct any applicable fees from your account balances at the time of the transaction or on a periodic basis, as applicable. For example, if you have an open leveraged position, we may deduct accrued funding fees from your available balance periodically. If you owe a fee in a particular currency that you do not have in your account, SPC RESERVES LTD may deduct an equivalent value from other assets in your account (by converting at market rates if necessary). If your account balance is insufficient to cover fees, we may decline to execute the relevant transaction or may require you to deposit funds.

Fees are generally charged in the asset you are receiving. For instance, if you buy BTC with EUR, a trading fee might be charged in BTC or EUR as specified by the fee schedule. We may also sometimes offer the option to pay fees in a specific cryptocurrency for a discount (for example, some platforms allow paying fees in their own token for a reduced rate – SPC RESERVES LTD might introduce such a program, and details would be provided).

All fees charged by SPC RESERVES LTD are exclusive of any taxes (see below on taxes). We do not charge VAT on trading fees as financial services are often exempt, but if any tax is applicable, we will handle it as required.

8.3 Changes to Fees: SPC RESERVES LTD reserves the right to change its fees at any time. Fee changes that are material will typically be announced or updated in the fee schedule. Your continued use of the Services after a fee change constitutes your acceptance of the new fees. If you do not agree with any new fee, you should stop using the Service affected by that fee.

8.4 Taxes: SPC RESERVES LTD does not withhold or pay taxes on your behalf except as required by law in specific circumstances. You are solely responsible for calculating, reporting, and paying any taxes applicable to your use of the Services. This can include, for example:

• Income tax or capital gains tax on profits you realize from trading or staking rewards.
• Any applicable sales, use, value-added, or goods and services tax on fees (if any such tax were deemed applicable by authorities).
• Any stamp duties, transfer taxes, or other taxes that might be imposed on cryptocurrency transactions by local law (not common as of now, but could exist in some jurisdictions).

In certain jurisdictions, SPC RESERVES LTD may be required to report your transaction history or balance to tax authorities (for instance, under the OECD’s Crypto-Asset Reporting Framework or EU’s DAC8 rules, or similar U.S. 1099 reporting for U.S. persons, though we currently do not serve U.S. persons). If such a law applies to SPC RESERVES LTD, you acknowledge that we will comply with it and that such reporting is not a breach of privacy.

If any tax authority or law requires SPC RESERVES LTD to withhold a portion of any withdrawal or reward (for example, withholding tax on staking rewards to non-residents), SPC RESERVES LTD will deduct such tax before remitting the remainder to you. We will try to inform you if this is the case, and provide documentation of the withheld tax so you can potentially claim a credit.

You should maintain your own records of transactions for tax purposes (we will provide account statements and a history as needed in your account interface, but it’s wise to keep backups). SPC RESERVES LTD may provide summary reports to assist with tax filing, but it remains your responsibility to verify and use them appropriately.

Keep in mind that tax laws relating to cryptocurrency are evolving and may vary significantly by jurisdiction. For instance, some countries treat frequent trading as business income, some have specific thresholds for tax exemptions, etc. It is strongly recommended that you seek advice from a qualified tax professional to understand your situation​. SPC RESERVES LTD will not be responsible for any tax liability you incur, nor for providing you with tax advice.

In summary, you are responsible for all taxes or obligations arising from your use of SPC RESERVES LTD, and you will indemnify SPC RESERVES LTD for any liability (including penalties or interest) that we incur due to your failure to pay taxes owed or provide necessary tax-related documentation (for example, if we ask for your tax residency information or tax ID for reporting and you fail to provide it, and we get penalized, that would be on you).

9. Risk Disclosures and Acknowledgment

Trading and investing in Digital Assets, as well as using related financial services, carry significant risks.By using SPC RESERVES LTD’ Services, you expressly acknowledge and accept the following risk factors (this list is not exhaustive):

• Volatility Risk: Cryptocurrency markets are highly volatile. Prices can fluctuate dramatically over short periods of time, and an asset’s value can drop to zero. Sudden news events, changes in investor sentiment, regulatory developments, hacks, market manipulation, or other forces can lead to extreme price swings​. You should be prepared for the possibility of large losses. Only trade or invest funds that you can afford to lose entirely.
• Market Risk: The markets may move against your positions. There is no guarantee that any Digital Asset will maintain or increase its value. Past performance of an asset (even if it has risen in the past) is not indicative of future results. Markets can also experience liquidity shortages, where it becomes difficult to execute large orders without affecting the price. In extreme cases, you may not be able to sell an asset at all for a time (if buy orders disappear). Thinly traded assets are particularly susceptible to liquidity risk. We advise caution especially when dealing in newer, less established cryptocurrencies.
• Leverage Risk: If you engage in leveraged or margin trading (futures, margin trades, etc.), your risk is magnified. Leverage can lead to losses that exceed your initial deposit. Even a small market move (adverse to your position) can have a large impact on your equity. If the market moves against you significantly, you may be liquidated quickly, potentially at a loss of most or all of your margin. In volatile conditions, the liquidation might occur at a price that leaves you with zero or negative balance, meaning you could owe additional funds. You should not use leverage unless you fully understand the mechanics (maintenance margins, liquidation process, etc.) and are prepared for the possibility of losing more than your initial investment. SPC RESERVES LTD does not cover your losses; you are responsible for any deficit. While we employ automatic risk management mechanisms (like auto-liquidation) to prevent negative balances, they are not foolproof under extreme conditions.
• Technical and System Risk: Using an online platform like SPC RESERVES LTD involves technology that may fail or behave unexpectedly.You may encounter system outages or downtime on our platform, making it temporarily impossible to initiate or complete transactions. This could happen due to scheduled maintenance, software bugs, high traffic (overload), power outages, hardware failures, or cyber-attacks. SPC RESERVES LTD employs safeguards and redundancy to minimize downtime, but zero downtime cannot be guaranteed. There is also the risk of communication failure – e.g., delays or interruptions on the internet between you and our servers. Orders might be delayed or lost. You should maintain alternative means to monitor the markets (don’t rely solely on our interface if you have critical positions – consider having price alerts elsewhere too). In extreme cases, SPC RESERVES LTD might need to pause trading or rollback transactions (for example, if a critical bug or hack is detected). Such actions, while aimed at protecting the platform and users, could adversely affect your positions or trades (you may not be able to trade at desired moments, or certain trades might be undone).
• Cybersecurity Risk: Digital Assets themselves and platforms dealing with them are attractive targets for hackers. If SPC RESERVES LTD or one of its critical partners (liquidity providers, custodians) suffers a security breach, your assets could be stolen, and you could incur losses. We implement robust security, including encryption, cold storage, and regular security audits. However, no system is perfectly secure. Additionally, your own security practicesgreatly influence your risk: if your account credentials are stolen via phishing or malware on your device, attackers could withdraw your assets. SPC RESERVES LTD will never ask for your password via email or chat. Always verify you are on the official SPC RESERVES LTD site or app. Use 2FA to protect your login. If you fall victim to a phishing site or other user-end attack, that is a risk you accept and we may be unable to recover your funds.
• Custodial Risk: When you hold funds with SPC RESERVES LTD (custodial), you are entrusting us and our partners with your assets. Unlike holding cryptocurrency in your personal wallet, you do not control the private keys – SPC RESERVES LTD does. This arrangement has inherent risk: if SPC RESERVES LTD or its custodians become insolvent or go into bankruptcy, or if funds are mismanaged, you may become an unsecured creditor and might not recover all your assets. While we maintain segregation of assets and pursue any legally required licensing or bonding (and soon under EU MiCA regulations, custody providers will have specific obligations), the crypto industry does not have protections like deposit insurance or guaranteed recourse. By using the platform, you acknowledge this risk. Diversifying where you hold assets or only keeping active trading balances on exchanges is a way some users mitigate this.
• Regulatory and Legal Risk: Cryptocurrency regulation is evolving. Legal changes or government actions can significantly impact the value and use of Digital Assets. For example, a country may ban cryptocurrency trading or usage, declare certain tokens as securities (impacting their legality on exchanges), or impose strict reporting and tax obligations. SPC RESERVES LTD itself could be affected by regulatory changes – we might have to discontinue certain services or delist certain assets if laws change. You might also be impacted if your jurisdiction of residence changes its laws (you may suddenly not be allowed to use the Service or may have to pay hefty taxes on crypto). Regulatory crackdowns or announcements often lead to sharp market movements as well. Furthermore, specific assets could be deemed illegal or problematic (e.g., privacy coins might be outlawed in some places). There is also a risk that you might inadvertently violate a law by using crypto (for instance, if you’re in a jurisdiction that newly bans it and you continue to trade).It is your responsibility to stay informed about the legal status of cryptocurrency activities in your locale.
• Risk of Forks and Protocol Changes: Many blockchain networks can undergo “forks” (splits in the chain) or updates. A fork can result in the creation of a new asset (e.g., Ethereum vs Ethereum Classic, or Bitcoin vs Bitcoin Cash) and can cause significant confusion and price volatility during the event. SPC RESERVES LTD may not support both sides of a fork. Our policy on how we handle forks will typically be: we will make a best effort to support the dominant chain (as determined by us in good faith, considering factors like community support, hashrate, etc.), and we might or might not support the alternate forked asset. If a fork is anticipated, we may temporarily suspend deposits and withdrawals of the impacted asset for safety. You should be aware that if a fork is not supported by SPC RESERVES LTD, you may not receive the forked asset that you would have if you held the coins in a personal wallet. Protocol changes (including contract upgrades in smart contract tokens) can also affect functionality, and there’s a risk that something that was expected (like a reward distribution) fails due to a bug or change.
• Smart Contract and Token Risk: If you trade tokens that are built on smart contract platforms (like ERC-20 tokens on Ethereum, BEP-20 on BSC, etc.), you should understand that smart contracts can have vulnerabilities. A flaw or exploit in a token’s smart contract could result in that token losing value or being frozen. Similarly, if you participate in decentralized finance (DeFi) products via SPC RESERVES LTD (if such integration exists in future), the underlying smart contracts might fail. Tokens could also be rug-pulled by their creators (flooding the market or removing liquidity), essentially collapsing the value. SPC RESERVES LTD does some due diligence on assets we list, but we cannot guarantee their soundness. By trading any token, you accept the technology risk inherent to that token’s design.
• Operational Risk: There is a general risk of loss due to unanticipated operational issues – these might include human error (e.g., our support staff accidentally executes a wrong operation), process failures, or other internal issues. We maintain internal controls and redundancies to minimize this, but operational errors could theoretically lead to situations like accidental suspension of your account, mistaken trade execution, etc. We will correct any known errors as soon as possible, but there’s a risk of inconvenience or temporary loss.
• Third-Party Risk: As noted earlier, SPC RESERVES LTD works with third parties. If any of those third parties fail (financially or performance-wise), you could be impacted. For instance, if our banking partner for fiat payments fails, you might temporarily lose access to deposit/withdraw fiat. If an exchange we use for liquidity goes down or becomes insolvent, it could affect pricing or cause losses if they held some SPC RESERVES LTD funds. We try to mitigate these by spreading risk and monitoring partners, but you acknowledge these indirect risks.
• No Guaranteed Returns: No investment on SPC RESERVES LTD (or anywhere in crypto) is guaranteed. Any statement about potential earnings (like APY for staking) is purely indicative. Real returns can be lower or none. There are no government or other guarantees on any assets you hold. Be wary of anyone promising you profits or “safe” returns in crypto – those are likely scams or at least very high-risk schemes.
• Risk of Scams and Fraud: Outside of the SPC RESERVES LTD platform, you may encounter scammers who target crypto users. This might include phishing websites or emails that look like SPC RESERVES LTD (to steal your credentials), fraudulent “investment managers” who ask you to send them crypto, fake tech support pretending to be SPC RESERVES LTD and asking for your information, or fake token sales and airdrops. Always exercise extreme caution. SPC RESERVES LTD will never ask for your password or 2FA codes outside of our secure login. We also will not ask you to send funds to any “secure wallet” or something because “your account is at risk” – those are common scams. The risk here is that if you fall for a scam, your assets can be irreversibly stolen (cryptocurrency transactions are typically final and irreversible). We cannot generally help recover funds sent to a scammer. Education and vigilance are your best defenses.

By using our Services, you acknowledge that you have considered and understood the above risks and that you are willing to assume these risks. SPC RESERVES LTD does not assume liability for these inherent risks of cryptocurrency trading. You agree that SPC RESERVES LTD is not responsible for any losses you incur due to the materialization of any of these risks, except as otherwise set forth in these Terms or required by law.

If any of these risks or any new, unforeseen risk makes you uncomfortable with using our Services, you should stop using the Services immediately. You are free to withdraw your assets (assuming such withdrawal is technically possible and not prevented by law or these Terms) at any time if you want to eliminate the risks associated with keeping them on our platform.

We encourage you to continuously educate yourself about Digital Assets and to employ risk management techniques. This might include diversifying assets, not investing more than you can afford to lose, setting stop-loss orders, using only low leverage or no leverage, etc., according to your own financial situation and risk appetite.

10. Suspension, Termination, and Account Closure

10.1 Voluntary Account Closure by You:You may request to close your SPC RESERVES LTD Account at any time, provided that:

• You have no pending transactions or open orders.
• You do not have any outstanding obligations to SPC RESERVES LTD (such as unpaid fees or negative balances).
• Your account is not currently subject to a hold, investigation, or legal process that would prevent closure.

To close your account, you should withdraw any remaining balances (both fiat and crypto) and then follow the account closure procedure as outlined in our help center or by contacting customer support. We may require you to provide identity verification again at withdrawal/closure time to prevent unauthorized closure. Once your account is closed, your contractual relationship with SPC RESERVES LTD under these Terms is terminated, except for provisions that survive (see Section 15.8 on Survival). Please note that we will retain your account information and transaction history for a period as required by law (e.g., AML regulations require retention of records for a number of years). During that retention period, while your account will be inactive and closed, SPC RESERVES LTD may still be required to hand over information if requested by authorities, or honor any outstanding legal requests relating to the period when you were a customer.

If you later wish to re-open an account, you will likely have to go through the onboarding process anew and there is no guarantee we will accept you if circumstances (like residency or other factors) have changed.

10.2 Suspension or Termination by SPC RESERVES LTD: SPC RESERVES LTD reserves the right to suspend, restrict, or terminate your Account and/or access to some or all of the Services at our discretion, with or without prior notice, for reasons including (but not limited to):

• Breach of Terms: If you violate any of the provisions of these Terms or any other policy that you have agreed to (such as the Privacy Policy or specific product terms), we may suspend or terminate your access. For example, if we discover you are engaging in a Prohibited Activity (Section 7.2), we will likely take immediate action to suspend.
• Suspicious or Illegal Activity: If your account activity triggers suspicion of fraud, money laundering, terrorist financing, sanctions violations, or any other illegal or prohibited behavior, SPC RESERVES LTD can freeze your account while investigating​. We may also suspend if transactions from/to your account appear on known illicit lists (e.g., your crypto withdrawal is going to an address associated with theft). In some cases, we might be required by law to freeze your funds(for example, if law enforcement provides a seizure order or if we confirm the funds are stolen). We will comply with such legal requirements.
• Required by Law or Regulator: If a court order, regulatory demand, or law enforcement request requires us to suspend or terminate your account, we will do so. Similarly, if a change in law makes it illegal or very onerous to continue providing our Services to you (e.g., your jurisdiction bans crypto or you become a resident of a Restricted Jurisdiction), we may terminate the account.
• Security Threats: We may suspend accounts that we believe have been compromised or are being used in an unauthorized manner. If we suspect that your login credentials have been hacked or that there’s malware affecting your account, we might lock it to prevent harm. We will attempt to contact you to resolve it (unless we suspect you are involved in the compromise).
• Inactivity: SPC RESERVES LTD <b>generally will not</b> terminate for inactivity alone (we prefer to leave accounts dormant). However, if an account has been completely inactive for an extremely long time and has negligible balance, we might close it (particularly if maintaining it poses any risk or cost). We would attempt notice in such a scenario. If the account has any balance, we would not just confiscate it — funds remain yours and we'd try to contact you to withdraw them. Unclaimed funds might eventually be treated in accordance with unclaimed property laws.
• Technical or Operational Need: We may temporarily suspend accounts or Services as needed for maintenance or to address any technical issues. This kind of suspension (for maintenance) is not a disciplinary or termination-related action, but it does restrict access for a time. We try to schedule maintenance and give notice to minimize impact.
• Our Convenience (with Notice): In rare cases, SPC RESERVES LTD might choose to terminate the relationship with a user or discontinue a particular service for business reasons not related to misconduct (for example, if we decide to cease operations in a certain country). In such cases, we will give users as much notice as reasonably practicable to allow them to withdraw assets. We would aim to provide notice via email and/or in-app announcement, providing instructions and a timeline for users to remove funds before termination.

10.3 Effects of Suspension/Termination:

• During Suspension: If your account is suspended (temporarily restricted), you will generally be unable to execute new transactions (trades, withdrawals, etc.), and your login access may be disabled. We may permit you to log in in a “view-only” mode to see your balances or transaction history (unless viewing is itself deemed risky). Any open orders may be canceled. Open positions might be liquidated if needed (especially if related to a violation). For instance, if we suspend due to suspected market manipulation and you have open leveraged positions, we might close them out to prevent further issues. In the case of suspected fraud or law enforcement interest, we might maintain the freeze on funds until cleared.
• Termination Process: When an account is terminated (closed by us), we will, subject to the outcome of any investigations or legal proceedings, return any remaining legitimate funds to the user. “Legitimate” means that if certain funds are proven to be linked to unlawful activity or subject to legal seizure, those will not be returned to the user but rather handled as per law (e.g., handed to authorities or victims). Assuming no such complication, we will ask you for details of an external wallet or bank account to transfer your assets out. We might require verification that the destination is controlled by you (to prevent fraudsters from tricking us to send your money elsewhere). If you do not withdraw funds when asked, we may after a certain period convert crypto to fiat at prevailing rates and send to your last known bank account or send a check to your address on file, as appropriate and if possible. For crypto, we prefer you provide a wallet address. If we cannot reach you to return assets, they will be kept safeguarded for the period required by law, then possibly deemed unclaimed property.
• No Account Access: After termination, you will no longer be able to access the SPC RESERVES LTD platform with that account. You should retain your own records of transaction history as access to those through the site may not be available (we can provide copies upon request even post-termination, within record-keeping period).
• Forfeiture of Rewards/Promotions: If your account is terminated due to misconduct, you may forfeit any rewards, referral bonuses, or other promotional credits that you have accumulated. SPC RESERVES LTD reserves the right to cancel such benefits upon termination.
• Liability for Fees or Negative Balances: Termination of an account does not absolve you of any liabilities incurred prior to termination. You will remain responsible for any fees owed or negative balances on the account. If after closing the account, you have a negative balance or owe monies to SPC RESERVES LTD, you agree to pay these within 7 days of notice. If you do not, SPC RESERVES LTD reserves the right to take legal action to recover debts, including using third-party collections if necessary. We also may offset any amounts you owe against any of your assets we still hold (if, say, you had some funds but also a bigger debt, we might deduct and send you net if any).
• Notification: Where feasible and lawful, SPC RESERVES LTD will notify you of the suspension or termination, and if applicable, the reason for it. In cases involving law enforcement or security concerns, we may be restricted from providing details or even informing you (e.g., a court order may bar us from telling a user about an investigation). In more straightforward cases (like violation of terms), we would send an email or notification with a brief explanation and steps (like “please withdraw your funds by X date”).
• Appeal/Review: If you believe your account was suspended or terminated in error, you may contact our support or compliance team to request a review. We will review any relevant information you provide and determine, at our sole discretion, whether to reinstate the account. Our decisions in this regard are final. (For example, if your account was flagged for suspicious activity but you have an innocent explanation and can provide documentation, we will consider that).
• Surviving Terms: Even after your account is terminated, certain sections of these Terms will remain in effect, particularly those concerning liability, indemnification, governing law, and dispute resolution. In other words, you can’t escape liability or obligations just by closing the account if those obligations were incurred during the period of active use.

SPC RESERVES LTD shall not be liable to you for any damages resulting from the suspension or termination of your account or access to Services, unlesssuch suspension/termination is determined to have been wrongful and in breach of these Terms. (And even in that event, any liability would be limited as per Section 11.)

11. Disclaimers of Warranties and Limitation of Liability

11.1 “As Is” Service and No Warranty:SPC RESERVES LTD provides the Services to you on an “as is” and “as available” basis, without any warranty of any kind, whether express, implied, or statutory, to the maximum extent permitted by applicable law. Use of our Services is at your own risk.

To the fullest extent permitted by law, SPC RESERVES LTD (including our officers, directors, employees, and agents) specifically disclaims any and all warranties, express or implied, regarding the Services, including but not limited to:

• Implied Warranties: Any implied warranties of merchantability, fitness for a particular purpose, and non-infringement are disclaimed. We do not guarantee that the Services are suitable for your needs, or that they will achieve any particular results.
• Accuracy and Reliability: We do not warrant that the content (e.g., price feeds, data, information, analytics) provided on our platform is accurate, complete, or up-to-date. While we strive for accuracy, there may be delays, omissions, or inaccuracies. You should independently verify information before relying on it. For instance, price data may come from third-party sources and could have errors; SPC RESERVES LTD is not responsible for those errors.
• Continuous or Error-Free Operation: SPC RESERVES LTD does not warrant that the Services will be available uninterrupted or that operation will be error-free or secure. We cannot promise that communications, such as inquiries or requests, will always be delivered or that our site will be free of viruses or other harmful components. All software, interfaces, and APIs have the potential for unforeseen bugs or vulnerabilities; we provide no guarantee against these.
• Third-Party Content: If our platform displays or links to any third-party content or resources (like articles, market news, external websites, advertisements, etc.), that content is not warranted by us. We do not endorse or assume responsibility for any third-party offerings.
• Security: While we invest in security, we make no guarantee that our security measures will prevent unauthorized access to or use of our systems or your data. We disclaim liability for any theft or loss of data or assets due to hacking, cyber attack, or other unauthorized access, except to the extent such event is directly due to our gross negligence (even then, see liability limits below).

Some jurisdictions do not allow the exclusion of certain warranties, so to that extent, some of the above exclusions may not fully apply to you. In such cases, any required warranty will be limited to the minimum duration and scope required by law.

11.2 Limitation of Liability:To the fullest extent permitted by law, in no event shall SPC RESERVES LTD, its affiliates, or any of their respective officers, directors, employees, agents, or representatives, be liable to you or any third party for:

• Any indirect, special, incidental, intangible, or consequential damages, or for any loss of profits, revenue, business, opportunity, goodwill, or data, even if we have been advised of the possibility of such damages. This includes, for example, losses you may incur from:
• Trading losses or lost profits (whether arising from market movements, missed opportunities due to downtime, or otherwise).
• Loss of data or costs of procurement of substitute services.
• Any reliance placed by you on information obtained from SPC RESERVES LTD (like using an incorrect price).
• Your inability to access your account or Services for any reason (e.g., communication line failures, or our decision to suspend your account).
• Any punitive or exemplary damages. We (and you, by agreeing to these Terms) each waive any right to seek any punitive awards.
• Any damages arising out of or related to events beyond SPC RESERVES LTD’ reasonable control (Force Majeure events), including but not limited to: acts of God, war, terrorism, network or utility failures, labor disputes, pandemics, acts of government, or other events of force majeure. If such an event occurs that affects our ability to perform, our obligations will be suspended for the duration of the event.
• Any damages arising from unauthorized access to or use of your account— for instance, if someone hacks your account because they obtained your credentials from you or through a breach on your side, we are not responsible for the financial losses that result. We are only responsible for securing our systems within reasonable standards.

11.3 Cap on Liability:To the extent that the foregoing limitation of liability is held to be unenforceable or does not fully shield SPC RESERVES LTD from liability, our aggregate liability to you for any and all claims arising from or related to the Services or these Terms shall not exceed the total amount of fees actually received by SPC RESERVES LTD from you in the six (6) months immediately preceding the event giving rise to the claim, or EUR 1,000, whichever is lower.** This means if you have a claim, the maximum compensation you could seek from SPC RESERVES LTD (absent willful misconduct or other exceptions mentioned below) is limited to that amount. If you’ve paid very little in fees (or the service was free), our liability is accordingly minimal.

This cap on liability applies per user. If you have multiple claims or multiple accounts, it doesn’t increase the cap (it’s not per incident, it’s total across everything). Also, it covers all types of claims (contract, tort, etc.), aggregated.

11.4 Exceptions: Nothing in these Terms shall operate to limit or exclude liability that cannot be limited or excluded by law. This includes:

• SPC RESERVES LTD’ liability for its own fraud or fraudulent misrepresentation is not limited.
• Liability for death or personal injury caused by negligence, where such liability is mandated by law (though it’s hard to see how using an online exchange would cause personal injury, this is a standard legal reservation).
• Any other liability which by applicable law cannot be excluded or limited (for example, some jurisdictions do not allow exclusion of gross negligence, or have certain consumer protections that impose minimum liabilities).

However, to the extent that the law allows limitation, all limitations and disclaimers herein shall apply.

11.5 No Liability for Actions of Others:You agree that SPC RESERVES LTD is not liable for the conduct of third parties, including other users of the Services, and for events outside our control. For example, if another user defrauds you or if there is a problem with the blockchain itself, or the actions of any third-party service integrated with SPC RESERVES LTD cause you harm, SPC RESERVES LTD isn’t liable for those.

11.6 Release: If you have a dispute with any third party (including, for instance, a counterparty to a trade or a third-party service provider), you release SPC RESERVES LTD (and our officers, directors, agents, affiliates, and employees) from any and all claims, demands and damages of every kind and nature arising out of or in any way connected with such disputes.

11.7 Application of Limitations:All the limitations of liability in this section (and elsewhere in these Terms) apply regardless of the form of action, whether in contract, tort (including negligence), strict liability, product liability, or any other legal or equitable theory. They apply even if a limited remedy provided in these Terms is found to have failed its essential purpose.

11.8 Indemnity:(Related to liability, we include indemnity here) – You agree to indemnify and hold harmless SPC RESERVES LTD, its affiliates, and their respective officers, directors, employees, and agents from and against any and all claims, losses, damages, liabilities, costs, and expenses (including reasonable attorneys’ fees) arising out of or related to:

• Your breach of these Terms or any applicable laws or regulations.
• Your misuse of the Services or violation of any rights of a third party.
• Any claim by a third party caused by your actions (for example, if another person sues SPC RESERVES LTD because of something you did, you will indemnify us).
• Any taxes, fines, or penalties that we incur as a result of your failure to pay taxes or comply with any law.

We will attempt to provide you with prompt notice of any such claim, and you will cooperate with us in defending such claims. We reserve the right to assume exclusive defense and control of any matter subject to indemnification by you, but doing so will not excuse your indemnity obligations.

11.9 Consumer Law Notice:If you are a consumer (not a business user) in a jurisdiction that provides for certain consumer rights, some of the above exclusions or limitations may not apply to you. In such a case, the scope and duration of any statutory warranty and the extent of liability will be the minimum permitted under applicable law. These Terms are not intended to deprive consumers of any rights provided by mandatory law. We specifically note that in Dominica and the EU, unfair terms in consumer contracts can’t be enforced, so we clarify that we do not seek to exclude or limit any mandatory liability beyond what’s allowed. That said, the Services being financial in nature and with inherent risks, the above disclaimers are provided to clarify the allocation of risk between you and us.

12. Intellectual Property Rights

12.1 Ownership of Platform and Content:All content and materials on the SPC RESERVES LTD platform, including but not limited to the website design, text, graphics, logos, software (source code and object code), algorithms, trade secrets, features, functionalities, user interface design, images, audio clips, video clips, and content created by SPC RESERVES LTD (collectively, the “Platform Content”), are the intellectual property of SPC RESERVES LTD or its licensors. This includes any and all rights under patent, copyright, trademark, trade secret, or other intellectual property laws. SPC RESERVES LTD retains all rights, title, and interest in and to the Platform Content and the Services, and nothing in these Terms shall be construed to transfer, license, or assign any of those rights to you except for the limited use license expressly provided below.

Our name “SPC RESERVES LTD”, our logos, and any product or service names or slogans we may adopt are trademarks or service marks of SPC RESERVES LTD (the “Marks”). You may not use any of these Marks without our prior written permission, including in any manner that is likely to cause confusion as to origin or to falsely imply our endorsement of any product or service. All other names or marks of third parties appearing on our platform (for example, names of cryptocurrencies, or third-party service names) are the property of their respective owners and are used on the platform solely to refer to those parties or products.

12.2 Limited License to Users:We grant you a limited, non-exclusive, non-transferable, non-sublicensable, and revocable license to access and use the SPC RESERVES LTD platform and Platform Content for the sole purpose of using the Services in accordance with these Terms. This license allows you to view information and materials we make available to you, and to interact with our website/app to the extent necessary for your personal (or internal business) use of the Services.

This license does not give you any ownership of any intellectual property rights in our Platform Content. We can revoke this license at any time if you violate these Terms or for any other reason, upon notice to you (or in the event of account termination).

12.3 Prohibited IP Uses:Under this license, you shall NOT:

• Copy, reproduce, modify, adapt, distribute, display, publish, perform, broadcast, translate, or create derivative works of any Platform Content, except as strictly necessary to use the Services or as otherwise expressly authorized by SPC RESERVES LTD in writing.
• Reverse engineer, decompile, disassemble, or attempt to discover the source code, underlying ideas, or algorithms of any portion of the Services or Platform Content (except to the limited extent that applicable law permits reverse engineering for interoperability, and then only after giving us notice and an opportunity to provide interoperability information).
• Remove or obscure any copyright, trademark, or other proprietary notices contained in the Platform Content or on the website/app.
• Use any automated means (such as bots, spiders, scrapers) to access or extract data from the platform without our permission (as stated earlier in prohibited activities).
• Use our Marks, name, or branding in any way, including in metatags or hidden text, without our explicit written consent, except as needed to identify your account (e.g., stating "I trade on SPC RESERVES LTD" is fine, but using our logo on your website or presenting yourself as affiliated is not).
• Frame or mirror any part of the platform on any other site, without our prior written authorization.
• Use Platform Content for any commercial purpose outside the scope of the Services, such as reselling our data or offering a service built off our data, without a separate contract with us.

12.4 Feedback: We welcome feedback, suggestions, or ideas from users about improving SPC RESERVES LTD (“Feedback”). If you choose to provide Feedback, you agree that SPC RESERVES LTD is free to use, disclose, reproduce, license, or otherwise distribute and exploit the Feedback as we see fit, without any obligation or compensation to you. You agree that any Feedback you provide is non-confidential and non-proprietary. For example, if you suggest a new feature or improvement, we might implement it and not owe you anything. (This clause simply ensures we don’t get in trouble for using user suggestions that overlap with things we’re already working on or decide to pursue.)

12.5 Third-Party Intellectual Property:Some features of the Services may include content or software from third parties, which might be subject to separate open source or third-party license terms. Where applicable, we will provide notice of these and you agree to comply with such terms. For instance, if we use an open-source library in our app, that library might come with its own license that allows your use under certain conditions.

If you believe that any content on our platform infringes your copyright or other intellectual property rights, please notify us with detailed information (for copyright, you may follow a DMCA-like takedown notice approach, even though as a Dominican entity we abide by EU copyright rules, we will still process such complaints diligently).

12.6 Content You Provide:In general, our platform is not meant for users to provide content beyond the data needed to use the Services (we are not a social media or content sharing site). However, if in any support ticket, forum, or other communication with us you provide any content (like screenshots, explanatory text, etc.), you ensure you have the right to provide such content and you grant us a license to use it for addressing your issue and improving our services. If, hypothetically, the platform allows user-generated content (like comments on a blog or something), you would retain your ownership of content you create but grant us a license to use it as needed for operation.

12.7 Termination of License:This license to use our Platform Content will terminate when you cease using the Services or upon termination of your Account. However, ephemeral copies in your browser cache or backup may remain; you must destroy any downloaded materials from the platform when the license ends (except to the extent you have a legal right to keep them, for instance, records of your transactions for legal purposes).

Misuse of our intellectual property is a serious breach of the Terms and may also violate law. We reserve the right to take appropriate legal action, including seeking injunctive relief (since monetary damages might not fully remedy unauthorized use of IP).

13. Data Protection and Privacy

13.1 Compliance with GDPR and Data Laws:SPC RESERVES LTD is committed to protecting your personal data and privacy. As a company established in Dominica and serving users in the European Economic Area (EEA) (among other regions), SPC RESERVES LTD processes personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Dominican data protection laws. We have implemented technical and organizational measures to safeguard personal data, and we maintain a Privacy Policy which provides detailed information on how we collect, use, store, and disclose personal information. By using the Services, you acknowledge that you have read our Privacy Policy and understood that your personal data will be processed as described therein.

In summary, and in line with GDPR principles​:

• We process personal data lawfully, fairly, and transparently, only for legitimate purposes such as providing the Services (e.g., executing transactions, securing your account), complying with legal obligations (e.g., KYC/AML requirements), and pursuing our legitimate interests (e.g., improving our platform, preventing fraud), or on the basis of your consent where applicable (e.g., for certain marketing communications).
• Weminimize data collection to what is relevant and necessary. Typically, the data we collect includes identification information (name, contact details, government ID, selfie, etc.), financial information (bank account details for fiat transactions), transactional records (deposits, trades, withdrawals), device and usage information (IP addresses, browser type, log-in logs), and any correspondence or feedback you provide.
• We retain personal data only for as long as needed for the purposes or as required by law. For instance, under AML laws, we may retain KYC records and transaction logs for a minimum of 8 years from the end of the business relationship or the date of an occasional transaction​.
• We ensure data accuracy and give you the ability to update your information.
• We secure personal data with appropriate measures (encryption in transit, access controls, regular security audits, etc.) to prevent unauthorized access or breaches.
• We respect your data subject rights (detailed below in 13.4).

13.2 Data Usage and Sharing:You agree that SPC RESERVES LTD may collect and process your personal data for the following purposes:

• Provision of Services: to set up and administer your Account, enable trading and transactions, provide customer support, and deliver the features you expect (e.g., sending confirmations, 2FA texts).
• Identity Verification and Compliance: to verify your identity and fulfill legal obligations under AML/KYC regulations. This involves using third-party KYC service providers as described in Section 6. We will share necessary personal data (such as your name, DOB, ID documents, biometric info for liveness checks) with those providers strictly for verification purposes. They are bound to treat your info in line with data protection laws and our instructions.
• Transaction Monitoring: to monitor transactions for fraud prevention, suspicious activity, or violations of these Terms. We may use automated systems and third-party analytics (like blockchain analysis tools) which involve analyzing data related to your account and transaction patterns. If automated tools flag something, human review may follow.
• Communications: to contact you regarding your account, security, service updates, and – if you have not opted out – marketing communications about new features or promotions. We may use your email and phone number to send service-related announcements (which are not subject to opt-out as they are necessary for service, like notices of changes or alerts) and marketing messages (which you can opt-out of). We might also use analytics to tailor marketing to your interests (but we do not “sell” your personal data to third parties for their own marketing).
• Improvement of Services: to analyze usage of the platform (e.g., what features are used the most, how users navigate), through cookies or similar technologies, in order to improve user experience, troubleshoot issues, and develop new features. For example, we might record that many users click a certain button, which helps design better UI.
• Legal and Regulatory: to comply with subpoenas, court orders, regulatory reporting (like tax or transaction reporting laws), and to assert or defend against legal claims. This may involve disclosing certain data to authorities or courts. For instance, if law enforcement provides proper documentation, we might have to furnish your account records​.
• Business Transfers: If SPC RESERVES LTD undergoes a business transaction like a merger, acquisition, or asset sale, your data may be transferred to the successor entity. In such case, we will ensure the successor is bound to respect your rights and privacy at least to the same standard, and we will notify you of the change if it materially affects your data.

13.3 Third-Party Data Sharing:As mentioned in Section 6 and above:

• We share personal data with KYC verification providers (for identity checks)​
• Withanalytics and monitoring providers (though these often handle pseudonymous data like hashed info or transaction patterns rather than plain personal data).
• Withcloud service providers or IT support who may host or maintain our systems. For example, if our servers are on a reputable cloud platform, the provider might incidentally have access to stored data (though typically encrypted).
• Withmarketing or communication tools (like an email service platform to send newsletters, which then has your email).
• Withaffiliates of SPC RESERVES LTD (if any, like parent or sister companies) for similar purposes as ourselves and in line with this policy.
• Withbanks or payment processors when you move fiat; they will see your name, account number, etc.
• Any sharing is done under confidentiality and data processing agreements as required by GDPR (meaning the third party can only use it to provide services to us, not for their own use, unless they're an independent controller like a bank or as required by law).

We do not sell personal data to third parties for profit or allow third parties to profile you for their own unrelated purposes without your consent.

13.4 Your Rights: Under GDPR and similar laws, you have rights regarding your personal data. These include:

• Right of Access: You can request a copy of the personal data we hold about you, and information about how we process it​.
• Right to Rectification: You can ask us to correct or update inaccurate or incomplete personal data.
• Right to Erasure (“Right to be Forgotten”): You can request that we delete your personal data. We will honor such requests to the extent required by law, but note that this right is not absolute. We may retain certain data if we have a legal obligation or compelling legitimate interest (e.g., we cannot erase your transaction records that we must keep for AML compliance until the retention period expires, even if you request deletion, due to legal obligation overrides). We will inform you if that’s the case.
• Right to Restrict Processing: You can ask us to restrict or pause processing of your data under certain conditions (for example, if you contest accuracy and we are verifying, or if processing is unlawful but you don’t want deletion).
• Right to Data Portability: You can request to receive your personal data that you provided to us in a commonly used machine-readable format, and have the right to transmit it to another controller where technically feasible (this mainly applies to data you gave us, not derived data).
• Right to Object: You can object to our processing of your personal data if such processing is based on our legitimate interests or for direct marketing. For instance, you have the absolute right to object to direct marketing – if you opt out, we will stop sending marketing emails. If you object to processing based on legitimate interest (like some analytics), we will consider your objection and whether our interests are overridden by your privacy rights.
• Right not to be subject to automated decisions: If we ever do fully automated decision-making with legal or similarly significant effects (like automated refusal of service based solely on an algorithm), you have the right to have human intervention or to contest the decision. Generally, our compliance-related decisions do involve human review (e.g., if a machine flags you for AML, a person reviews it), so this likely isn’t triggered.
• Right to Withdraw Consent: If any processing is based on your consent (e.g., optional marketing, or certain optional data you provided), you can withdraw consent at any time, and we will stop that processing going forward.

To exercise any of these rights, you can contact us at the contact details provided in our Privacy Policy or via customer support. We may ask you to verify your identity before fulfilling such requests (to ensure we don’t give your data to an impostor). We will respond within the time frame required by law (usually one month, extendable by two more if request is complex; we’ll inform you if extension is needed).

If you have concerns about our data practices, we encourage you to contact us so we can address them. However, you also have the right to lodge a complaint with a Data Protection Supervisory Authority, particularly in the EU member state of your habitual residence or where we are based (in Dominica, this would be the State Data Protection Inspectorate (VDAI)).

13.5 International Data Transfers:SPC RESERVES LTD primarily stores and processes data in the EEA. However, in certain cases, personal data may be transferred to and processed in countries outside the EEA, for example if we use a U.S.-based cloud service or if our support team is in another country. We ensure that any such international transfers are done in compliance with GDPR Chapter V. This means:

• We may rely on an adequacy decision (if the receiving country is deemed by the European Commission to have adequate data protection laws).
• If no adequacy, we use Standard Contractual Clauses (SCCs) or equivalent contractual safeguards with the recipient, and implement additional measures as needed to ensure essentially equivalent protection as in the EU.
• In some cases, we might rely on your explicit consent for a transfer (if, for instance, no other mechanism is available and the transfer is necessary, though this is rare).

For example, our KYC provider might be outside EEA; we will have SCCs in place with them​. By agreeing to these Terms, you authorize SPC RESERVES LTD to transfer your data internationally in accordance with our Privacy Policy and these safeguards.

13.6 Data Breach Notification:While we strive to keep your data secure, in the event of a personal data breach (as defined by GDPR) that is likely to result in a high risk to your rights and freedoms, SPC RESERVES LTD will notify you and the appropriate supervisory authority in a timely manner as required by law. We will inform you of the nature of the breach, the likely consequences, the measures taken or proposed to address it, and steps you might consider to mitigate any potential adverse effects.

13.7 Cookies and Tracking:The platform uses cookies and similar tracking technologies to provide and improve the user experience (for things like keeping you logged in, remembering preferences) and to collect analytics information. By using our site, you consent to our use of cookies as described in our Cookie Policy (if separate) or Privacy Policy. You can usually control cookies via your browser settings or other tools, but disabling essential cookies may affect functionality of the Services.

13.8 Marketing Communications:We mentioned marketing under your rights, but to reiterate: If you consentto receive marketing communications (or as otherwise permitted by applicable e-privacy laws for existing customers), SPC RESERVES LTD may use your personal contacts to send you newsletters, product updates, promotions, or other marketing materials that may be of interest. You have the right to opt out of these at any time. Each marketing email will contain an “unsubscribe” link. You can also adjust preferences in your account settings or by contacting support. Opting out of marketing will not affect our ability to send transactional or necessary account communications.

13.9 Privacy Policy:These Terms include general data protection language, but for more detailed and specific information, please refer to our Privacy Policy, which is available on our website. The Privacy Policy is considered a part of these Terms with regard to explaining our data handling practices. If there is any conflict between the Privacy Policy and these Terms regarding data privacy matters, the Privacy Policy will prevail for those matters.

13.10 Confidentiality of Communications:As part of privacy, any sensitive communications between you and SPC RESERVES LTD (for example, reports you make or issues around your account) will be treated as confidential by SPC RESERVES LTD, to the extent possible. However, you understand that communications transmitted via email or messaging might not be fully secure and that we have to balance confidentiality with legal duties (like if a regulator asks for details of a complaint, we might have to share it).

13.11 Data Protection Officer:If required by law (for instance, if our processing activities mandate it), SPC RESERVES LTD will appoint a Data Protection Officer (DPO) whose contact info will be in the Privacy Policy. The DPO (if appointed) would oversee our data protection strategy and compliance, and you may contact them for any concerns specifically about personal data.

By agreeing to these Terms, you also confirm that you have been informed about how and why we process your personal data, as set out above and in the Privacy Policy. If you do not agree with such processing, your remedy is to cease using the Services.

14. Governing Law and Jurisdiction

14.1 Governing Law:These Terms, and any disputes or claims arising out of or in connection with these Terms, the Services, or your use of the Services (including non-contractual disputes or claims), shall be governed by and construed in accordance with the laws of the Republic of Dominica, without regard to its conflict of law principles. We choose Dominican law because SPC RESERVES LTD is registered and operating under Dominican jurisdiction, and having a single governing law helps with consistency and predictability of legal outcomes.

This choice of law means that, to the maximum extent permissible, Dominican law will apply to determine issues such as the interpretation of contract terms and the availability of legal remedies, even if you reside or use the service in another country. However, if you are a consumer residing in another country, you may also have certain protections under the mandatory laws of your country of residence. Nothing in this Section 14.1 shall deprive a consumer of the protections afforded to them by provisions of law that cannot be derogated from by agreement by virtue of the law of the consumer’s habitual residence (for instance, some consumer rights in the EU are unwaivable). We clarify that we do not seek to override those mandatory protections; in any case where Dominican law conflicts with a mandatory law of your country (that is more protective of you), that mandatory law may prevail.

14.2 Jurisdiction: You and SPC RESERVES LTD agree that any dispute that cannot be amicably resolved, and which results in litigation, shall be submitted to the exclusive jurisdiction of the courts of Dominica​. Specifically, unless an imperative law specifies otherwise, the courts located within the jurisdiction of the city of Vilnius, Dominica shall be the proper venue for the resolution of such disputes. You and we each consent to the personal jurisdiction of such courts and waive any objections to jurisdiction, venue, or inconvenient forum in those courts.

For example, if you decide to bring a legal claim against SPC RESERVES LTD regarding a loss on our platform, you should file that claim in a competent court in Vilnius, Dominica. Similarly, if SPC RESERVES LTD needs to take legal action against you (say, for a debt or misuse of the platform), we would do so in Dominica.

14.3 No Arbitration / No Class Action:(Note: The user specifically asked to exclude arbitration or specific dispute resolution procedures; thus, we confirm here that) there is no mandatory arbitration clause in these Terms and no requirement to go through any alternative dispute resolution before resorting to courts (aside from any mediation we might voluntarily undertake). Both parties have the right to seek remedies in court as specified above. Furthermore, to the extent permitted by law, you and SPC RESERVES LTD agree that any litigation shall be conducted solely on an individual basis and not in a class, consolidated, or representative action. This means you may not consolidate your claim with others or pursue any claim as a class representative or class member (no class actions). Each side waives the right to a trial by jury if applicable, given that typically, in Dominica and civil law jurisdictions, jury trials are not used for these matters anyway.

14.4 Consumer Exception:If you are acting as a consumer (i.e., for personal use, outside of business), mandatory consumer protection provisions might grant you the right to bring a claim in your home country or otherwise enjoy certain jurisdictional privileges. For instance, under EU law, consumers can sometimes sue in their home forum and can’t be deprived of that right by a business in some contexts. While we maintain that Dominican courts have exclusive jurisdiction, this is without prejudice to any rights you may have as a consumer under applicable law to bring proceedings in your country of residence or to benefit from legal provisions that are more favorable to you.Basically, we’re not trying to unlawfully force a foreign consumer to litigate in Dominica if their local laws say they can litigate at home. But if no such law applies, Dominica is the venue.

14.5 Language and Interpretation:These Terms are drawn up in the English language. In any dispute, the English version of these Terms shall prevail. Any translation (if we provide one) is for convenience only. All proceedings will be conducted in either Dominican or English language (the parties can agree on English even in Dominican courts, or the necessary translations will be made). The section headings in these Terms are for reference only and do not affect interpretation. The words “including” or “for example” shall mean including without limitation.

15. Miscellaneous

15.1 Entire Agreement:These Terms (including documents incorporated by reference, such as the Privacy Policy and any product-specific terms or annexes provided to you) constitute the entire agreement between you and SPC RESERVES LTD regarding the Services. They supersede and replace any prior or contemporaneous understandings, agreements, or representations, whether written or oral, concerning the subject matter. No oral or written information or advice given by any party (including SPC RESERVES LTD employees or agents) shall create any additional obligations or warranties beyond those expressly stated in these Terms. You acknowledge that you have not relied on any representation or information that is not expressly included in these Terms in deciding to enter into this agreement.

15.2 Amendments: SPC RESERVES LTD may amend or update these Terms from time to time. If we make material changes, we will notify you through appropriate means (for example, via email to the address associated with your Account, or by posting a notice on our website or through the user interface) prior to the change becoming effective. The notice will designate a reasonable advance notice period (depending on the nature of the change and applicable laws; typically at least 14 days for significant changes, or longer if required by law). Your continued use of the Services after the effective date of any changes to these Terms constitutes your acceptance of the revised Terms. If you do not agree to the changes, you must stop using the Services and may terminate your account as described in Section 10. For non-material changes (such as clarifications, corrections, or enhancements that do not reduce your rights), we may not provide advance notice, and the updated Terms will be posted on our site with a new effective date. It is your responsibility to check for updates to the Terms periodically. We will indicate the date of the “Last Updated” at the top or bottom of the Terms document.

15.3 No Waiver: Our failure or delay in exercising any right, power, or privilege under these Terms shall not operate as a waiver thereof. Similarly, a single or partial exercise of any right, power, or privilege does not preclude any other or further exercise of it or the exercise of any other right, power, or privilege. If we do waive a breach of any provision of these Terms, that waiver is limited to the particular breach and does not mean we will waive any future breaches. Any waiver by SPC RESERVES LTD of any provision of these Terms will be effective only if in writing and signed by an authorized representative of SPC RESERVES LTD.

15.4 Severability: If any provision of these Terms is held to be invalid, illegal, void, or unenforceable by a court of competent jurisdiction, then such provision shall be deemed severed from these Terms and shall not affect the validity or enforceability of the remaining provisions​. The remainder of the Terms will continue in full force. In such case, the parties agree that the court should endeavor to modify or replace the invalid provision in a manner that comes closest to the intended effect of the original provision, within the limits of applicable law. If a provision is so fundamental that its invalidity defeats the purpose of these Terms, the parties shall in good faith negotiate a lawful and enforceable substitute provision that, to the maximum extent possible, achieves the intended economic, legal, and commercial objectives of the original provision.

15.5 Assignment: You may not assign or transfer any of your rights or obligations under these Terms without the prior written consent of SPC RESERVES LTD. Any attempted assignment by you without consent will be null and void. SPC RESERVES LTD may assign or transfer these Terms or any rights/obligations hereunder to any affiliate or in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of our assets, or by operation of law or otherwise, and you hereby give your approval to such assignment (and waive any further notice, to the extent permitted by law). These Terms will bind and inure to the benefit of the parties, their successors, and permitted assigns.

15.6 No Third-Party Beneficiaries:These Terms are intended for the sole benefit of you and SPC RESERVES LTD and are not intended to confer any rights or remedies upon any other person or entity, other than SPC RESERVES LTD’ affiliates, which are expressly deemed third-party beneficiaries hereof with the right to enforce relevant provisions (for example, the limitation of liability and indemnification extends to our affiliates, and they can enforce those terms). Aside from such affiliates, no other third party has any rights under these Terms. In particular, nothing in these Terms shall be construed to give any person other than the parties any legal or equitable right, remedy, or claim under or in respect of these Terms.

15.7 Relationship of the Parties:SPC RESERVES LTD is an independent contractor for all purposes. Nothing in these Terms is intended to create any partnership, joint venture, agency, employment, or fiduciary relationship between you and SPC RESERVES LTD. You and SPC RESERVES LTD are independent parties. You may not make any commitment for or on behalf of SPC RESERVES LTD, and you are solely responsible for reporting and paying any taxes on income you earn (if any) through the use of our Services (e.g., trading gains are your income, not wages from us). Similarly, SPC RESERVES LTD’s provision of the Services to you should not be interpreted as SPC RESERVES LTD acting as your broker or agent (in the legal sense) beyond providing a service; we are not giving you personalized advice or acting on your behalf beyond executing your instructions as per our system.

15.8 Survival: All provisions of these Terms which by their nature should survive termination of the user relationship (or of the Services) shall survive such termination. Without limitation, the sections relating to Limitation of Liability (Section 11), Indemnification (in Section 11), Intellectual Property (Section 12), Data Protection (Section 13, to the extent we must continue handling data post-termination), Governing Law and Jurisdiction (Section 14), and Miscellaneous (Section 15), as well as any other clauses that implicitly or explicitly ought to remain valid after termination (such as outstanding payment obligations, or the interpretation of terms), will remain in effect.

15.9 Notices:

• To You:SPC RESERVES LTD may provide notices or communications to you through the website user interface, via e-mail (to the email address on file in your Account), via text message or mobile push notification (if you provided a phone number and agreed to such texts), or through other reasonable means. You are responsible for keeping your contact information (especially email) up to date in your Account. Official notices of legal nature (like changes to terms, security alerts, etc.) will be considered received by you within 24 hours of the time they are sent or posted. We are not responsible if you fail to receive a notice because your contact info was wrong or out of date, or due to spam filtering, etc., as long as we sent it to the address you provided.
• To Us:You may need to send notices to SPC RESERVES LTD for various reasons (e.g., to report fraud, to make a legal claim, etc.). Unless a specific method is prescribed in these Terms or by mandatory law, you can send general notices to us via our official support email or contact form as listed on our website. For legal notices (such as a formal dispute notice or service of process in a lawsuit), you should send it to our registered address (SPC RESERVES LTD, UAB, Laisvės pr. 60, Vilnius, LT-05120, Dominica) attn: Legal Department. We may specify an email for legal notices in the future which we will communicate if so.

15.10 Further Assurances:You agree to execute and deliver such other documents and to take such other actions as may be reasonably requested by SPC RESERVES LTD to carry out the intent and purposes of these Terms.

15.11 Interpretation: In these Terms, unless the context otherwise requires, words in the singular include the plural and vice versa, and “including” means “including without limitation.” Any examples or references to “such as,” “for example,” or similar phrases are illustrative and do not limit the generality of the surrounding words. The headings are for convenience only and do not affect interpretation. If these Terms are translated into another language, the English version governs in the event of any conflict.

15.12 Complaints and Dispute Resolution:If you have any complaints or disputes with SPC RESERVES LTD, we encourage you to first contact our support team to seek an amicable resolution. You can email support or use the complaint channel described in our policies. We will attempt to resolve issues in good faith. While we have not included a formal dispute resolution clause (such as arbitration) as per the user’s preference, we remain open to resolving disputes through negotiation or mediation if both parties agree.

15.13 Law Enforcement Requests:A note that while not exactly user-facing, SPC RESERVES LTD will comply with legitimate law enforcement and regulatory requests. You acknowledge that we may have to provide information or freeze assets when legally compelled, as already noted in various sections.

By accepting these Terms, you affirm that you have read and understood all the provisions above. You agree that these Terms are fair and reasonable, and you agree to be bound by them. If you have any questions about these Terms, please contact SPC RESERVES LTD support for clarification before proceeding.

ATTENTION DOMINICAN USERS

Pursuant to SPC RESERVES LTD’s compliance with Dominican financial regulations and internal risk policies, residents and citizens of Dominica are strictly prohibited from accessing or using our Services. This restriction applies to:

• Creating an account.
• Depositing funds (fiat or crypto).
• Engaging in trading, staking, or derivatives activities.

Why is this restricted?

• Dominica’s regulatory framework prohibits unlicensed entities from offering certain crypto services locally.
• SPC RESERVES LTD is registered in Dominica but operates under international licenses; services are not intended for Dominican residents.

Immediate Action Required:

• If you are a Dominican resident/citizen, close your account and withdraw funds immediately.
• Accounts flagged for Dominican residency will be suspended, and funds may be frozen pending investigation.