1 - Acceptance Of Terms

Thank you for choosing STARLINK FX. The following Terms and Conditions (the “Terms”) apply to any person that registers for and/or opens a STARLINK FX Account through STARLINK FX.com or any associated mobile or web applications, website, or APIs.

The Terms constitute a legally binding agreement between you and STARLINK FX Payments Limited (“STARLINK FX”), a company incorporated under the laws of the United States of America's Brokers code and govern your access to and use of the STARLINK FX cryptocurrency exchange platform (the ‘‘Platform’’). For further information on STARLINK FX Payments Limited, and its operating subsidiaries, please see the [About page] on the STARLINK FX website. For the purposes of these Terms, any reference to “we” “us” “our” “STARLINK FX” and/or any similar term shall be construed as reference to STARLINK FX Payments Limited.

By registering for and opening a Innovatcerypto Account, you unconditionally accept these Terms and agree to be bound by and act in accordance with them. You also accept and agree that you are solely responsible for understanding and complying with all laws, rules, regulations and requirements of the jurisdiction in which you live that may be applicable to your use of the STARLINK FX website and/or your STARLINK FX Account, including but not limited to, those related to, taxes or foreign currency transactions.

Please read these Terms carefully before using the Platform because they affect your legal rights and obligations.

2 - Amendment Of Terms

STARLINK FX may amend the Terms from time to time. You should visit the terms and conditions page on the Platform regularly to check when the Terms were last updated (as displayed at the top of this document) and to review the current Terms. We will do our best to notify you of any amendments to the Terms that we consider likely to materially affect your rights and obligations. Any such notice will be posted on the Platform, or sent to the email address associated with your STARLINK FX Account.

The continued use of your STARLINK FX Account, after any amendment to these Terms, constitutes your acceptance of the Terms, as modified by such amendment. If you do not accept the Terms, or any amendment to them, you must immediately stop using the Platform and your STARLINK FX Account.

3 - Registration And Onboarding

Where any part of the Platform requires you to register in order to use it, you are obliged to provide accurate and complete registration information. It is your responsibility to update and maintain any changes to that information by altering your details as appropriate.

The Platform shall allow you access to use registration areas of the Platform on the basis that:

You satisfy all the eligibility criteria stipulated in clause 3 below;

Your personal details including your email address and password are personal to you and may not be used by anyone else;

You shall not do anything to assist anyone who is not a registered user to gain unathorised access to any area of the Platform or use your account to carry out transactions on behalf of a third party;

You submit and consent to all verification of all KYC documentation, including but not limited to BVN validation and antimoney laundering checks that may be conducted by STARLINK FX in compliance with applicable laws;

You will not use your STARLINK FX Account for or in relation to any illegal or prohibited activity in violation of any laws, statutes, ordinances or regulations;

You shall not maliciously create accounts for the purpose of abusing the functionality of the Platform, or other users, nor do you seek to pass yourself off as another user;

You are responsible for all activities that occur under your account, regardless of whether the activities are undertaken by you, your employees or a third party (including a spouse, children and other relatives) and, except to the extent caused by our breach of this Terms.

We and our affiliates shall not responsible for unauthorized access to your account, and you will contact us immediately you notice an unauthorized third party may be using your account or if your account information is lost or stolen; and

You shall comply at all times with the terms herein (as may be amended from time to time).

By opening a STARLINK FX Account, you expressly warrant and represent that:

You are 18 years of age or over and have full capacity to accept the Terms and enter any transaction available through the Platform;

You will not open, or attempt to open, a STARLINK FX Account under any name except your own; or use your STARLINK FX Account to carry out transactions on behalf of a third party;

You will follow the STARLINK FX business account application process if you seek to open and use a STARLINK FX Account for a non-individual legal entity (e.g. a company, trust or partnership);

You will not have more than one STARLINK FX Account; use or access any Innovatcerypto Account other than your own; or assist any other person in obtaining unauthorised access to any STARLINK FX Account;

You will provide security for transactions carried out through your STARLINK FX Account by ensuring there is sufficient Local Currency or digital currency (as the case may be) in your STARLINK FX Account in advance of any transaction;

You will not allow or facilitate the deposit of Local Currency into your STARLINK FX Account unless that deposit is made in accordance with the Deposit Requirements stated on our website from time to time;

You will not allow or facilitate the withdrawal of Local Currency from your STARLINK FX Wallet to a bank account held in the name of a third party (see Withdrawals);

You will not use your STARLINK FX Account for or in relation to any illegal activity, any Prohibited Activity, in violation of any laws, statutes, ordinances or regulations, or in breach of STARLINK FX’s Export Controls and Sanctions requirements;

You are not a national or resident of the United States of America. Reference in these Terms to “Local Currency” means fiat or government issued currency (e.g. NGN, USD, GBP, EUR).

We retain the absolute right to prevent you from accessing the Platform, without prejudice to any of our accrued rights, where the Platform, at our sole discretion, consider that you have, or are contravening the Terms.

By opening a STARLINK FX Account you accept and agree that STARLINK FX may, without further notice and in its sole discretion, terminate, suspend or restrict the account of any customer who uses, or who we reasonably suspect may be using, the Platform or any STARLINK FX Account in a manner that is inconsistent with the letter or spirit of these Terms.

4 - Risks

Before using the Platform, you should ensure that you understand the risks involved in buying, selling or trading digital currencies. Digital currency markets are volatile and prices can fluctuate significantly, which could result in sudden and significant increases or decreases in the value of your assets. This market volatility and other risks involved in buying, selling or trading digital currencies are explained on the risk warning page of the STARLINK FX website. There may be additional risks not identified in these Terms or in the risk warning page.

You should carefully assess whether your financial situation and risk tolerance is suitable for buying, selling or trading digital currency. You accept and agree that you are solely responsible for any decision to buy, sell, trade or otherwise hold or deal with digital currency

5 - Identity Verification

STARLINK FX implements and maintains the highest standards of Know Your Customer (“KYC”) processes and controls as part of our commitment to combating fraud and assisting in the prevention of money laundering and terrorist financing. While our industry is largely unregulated, STARLINK FX voluntarily adheres to local and international compliance standards in relation to customer due diligence, as explained on the Compliance page of the STARLINK FX website.

To ensure we meet these standards, our customers are required to provide certain personal details and documents when opening a STARLINK FX Account (“Identity Verification”). The nature and extent of the Identity Verification required will depend upon which of our supported countries you are resident in, and the deposit and withdrawal limits that you wish to apply to your STARLINK FX Account. In certain circumstances, STARLINK FX may also perform enhanced due diligence (“EDD”) procedures in relation to your STARLINK FX Account. You accept and agree that you will remain subject to such procedures at all times.

STARLINK FX reserves the right to, at any time:

restrict or suspend your STARLINK FX Account when we, in our sole discretion, consider it necessary to carry out further Identity Verification and/or EDD; or

terminate your STARLINK FX Account if you provide, or we suspect you have provided, false information or refuse to provide information we require for Identity Verification and/or EDD.

You accept and agree that there may be delays in accessing your STARLINK FX Account, or in carrying out transactions through your STARLINK FX Account, while we undertake any Identity Verification and/or EDD procedures.

Retention of information. STARLINK FX is required to retain certain information and documentation obtained as part of the Identity Verification and EDD procedures. These requirements apply even when you have terminated your relationship with STARLINK FX. We reserve the right to keep such information and documentation for the required period and you accept and agree that information and documentation you provide to STARLINK FX may be retained by us, including following the closure of your STARLINK FX Account.

6 - The STARLINK FX Wallet

The STARLINK FX Wallet allows you to send, receive and store digital currency (together, “STARLINK FX Wallet Transactions”).

Supported Digital Currencies.The STARLINK FX Wallet is only available in relation to the digital currencies that STARLINK FX, in its sole discretion, decides to support (“Supported Digital Currency” or “Supported Digital Currencies”). The Supported Digital Currencies may change from time to time. Under no circumstances should you attempt to carry out a STARLINK FX Wallet Transaction in relation to a digital currency other than a Supported Digital Currency. In particular, but without limiting the generality of the foregoing, you accept and agree that you will have no access, entitlement or claim:

to any digital currency sent to a receive address associated with your STARLINK FX Wallet where that digital currency is not a Supported Digital Currency; or

to any digital currency sent to a receive address associated with your STARLINK FX Wallet, where that receive address is associated with another digital currency. For example, you will have no access, entitlement or claim to any Bitcoin Cash (BCH) sent to a Bitcoin (BTC) receive address.

Information about the Supported Digital Currencies can be found on the Fees and Features page of the STARLINK FX website.

Local Currency in your STARLINK FX Wallet. Local Currency deposited into your STARLINK FX Wallet is solely for (1) the purchase of Supported Digital Currencies and/or (2) Withdrawal to an approved bank account (see Withdrawals). In certain countries we may also allow you to purchase specific goods and/or services from selected third parties using your Local Currency balance (for example, Airtime in South Africa). You accept and agree that any such purchase will be subject to these Terms.

Proceeds from the sale of Supported Digital Currencies will be credited to your Local Currency STARLINK FX Wallet, less any applicable fees (as explained in Fees, and on the Fees and Features page of the STARLINK FX website). STARLINK FX does not pay interest on Local Currency or Supported Digital Currency balances held in your STARLINK FX Wallet.

Transaction instructions. STARLINK FX will process STARLINK FX Wallet Transactions according to your instructions. You accept and agree that Innoavtecrypto does not:

guarantee the identity of any user, receiver, or other party to a STARLINK FX Wallet Transaction. You are solely responsible for ensuring all transaction details are correct, and you should carefully verify all transaction information prior to submitting transaction instructions to STARLINK FX;

have any control over, or any liability in relation to, the delivery, quality or any other aspect of any goods or services that you may buy from or sell to any third party. STARLINK FX shall not be responsible for, and will take no action in relation to, ensuring that any buyer or seller you transact with using your Innovativecrypto Wallet completes the relevant transaction or has the requisite authority to do so.

Receiving digital currency. You may receive Supported Digital Currency into your STARLINK FX Wallet by providing the sender with a receive address generated in your STARLINK FX Wallet. Your STARLINK FX Wallet will only be credited with Supported Digital Currency sent to a receive address generated through your Innovatcrypto Wallet and associated with that Supported Digital Currency. For example, your STARLINK FX Wallet will be credited with ETH when it is sent to an ETH receive address generated through your Innovatcrypto Wallet.

Funds received in error. In the event you know, suspect, or should reasonably know or suspect, that any Local Currency or digital currency has been credited to your STARLINK FX Wallet (or to any bank account) in error, you must immediately notify STARLINK FX of the error by submitting a ticket through the STARLINK FX Help Centre. You accept and agree that you have no claim or entitlement to any Local Currency or digital currency received in error, and must immediately return such funds in accordance with the instructions received from STARLINK FX.

7 - Deposits

Where your identity has been verified, you may deposit Local Currency into your STARLINK FX Wallet by depositing funds into a STARLINK FX bank account (a “Deposit”).

Details of the STARLINK FX bank account into which you must make the Deposit will be provided to you by STARLINK FX, and any such bank account will be held and operated by a STARLINK FX operating entity in your country or region (for more information on these entities, see the Company Information page on the STARLINK FX website). You accept and agree that any information you provide to STARLINK FX may be shared with such local entity, which will process Local Currency transactions in accordance with STARLINK FX’s instructions.

The payment methods by which you may Deposit Local Currency will depend upon the country you are in, and are set out on the Fees and Features page of the STARLINK FX website (for the purposes of these Terms, the “Supported Deposit Methods”). Where you have made a Deposit using a Supported Deposit Method, and have adhered to the Deposit Requirements (explained below), your Deposit will be allocated to your STARLINK FX Wallet.

Due to legal and operational constraints, you must strictly adhere to the following Deposit requirements (the “Deposit Requirements”):

you may only make a Deposit from a bank account (or other Supported Deposit Method) held in your own name. You must not allow any third party to make a Deposit into your STARLINK FX Wallet;

you may only Deposit Local Currency from a bank account (or other Supported Deposit Method) compatible with the deposit methods available in your country or region;

you may only make Deposits denominated in the Local Currency associated with your STARLINK FX Wallet. For example, if you have a ZAR wallet, you must only make Deposits in South African Rand;

you must not use cash or cheques to make a Deposit. STARLINK FX reserves the right to refuse any Deposit made by cash or cheque. Should STARLINK FX decide, in its sole discretion, to allow a Deposit by cash or cheque on an exceptional basis, the allocation of such Deposit will be delayed to allow fraud and compliance checks to take place, and a Cash Deposit Penalty (see the Fees and Features page of the STARLINK FX website) may be deducted from it. Any STARLINK FX Account that receives more than one cash or cheque deposit may, at STARLINK FX’s sole discretion, be suspended indefinitely.

You agree to abide by the Deposit Requirements and agree and accept that failure to do so may cause delay in or failure of any Deposit reflecting in your STARLINK FX Wallet, and/or restriction, suspension or termination of your STARLINK FX Account.

Allocation of deposits. When you request to make a Deposit through your STARLINK FX Wallet, you will be provided with a Reference Number or Unique Deposit Amount. To permit timely and successful allocation of a Deposit to your STARLINK FX Wallet, you must use the Reference Number or Unique Deposit Amount when you make an online bank transfer or use any other Supported Deposit Method. STARLINK FX will not be responsible for any delay in or non-allocation of Deposits to your STARLINK FX Wallet where you fail to specify the required Reference Number or Unique Deposit Amount.

Deposits may take time to reflect in your STARLINK FX Wallet due to bank processing times, operational processes, and/or failure by you to adhere to the Deposit Requirements. Under no circumstances will STARLINK FX have any liability to you in relation to any delay in or failure of a Deposit reflecting in your STARLINK FX Wallet.

STARLINK FX will make all reasonable efforts to allocate Deposits that do not meet the Deposit Requirements. However, any Deposits less than the Minimum Unallocated Deposit Amount that cannot be allocated within a one month period will be retained by STARLINK FX and you accept and agree that you shall have no further claim or entitlement to such funds. The Minimum Unallocated Deposit Amount shall until otherwise determined by STARLINK FX be USD10.00 or the equivalent in your Local Currency.

8 - Withdrawals

Where you have added your local bank account details to your STARLINK FX Account, you may withdraw funds from your STARLINK FX Wallet to your bank account (a “Withdrawal”). STARLINK FX will process Withdrawals in accordance with your instructions. You are solely responsible for ensuring that any Withdrawal instructions provided to STARLINK FX, including the relevant bank account number, are complete and correct and you accept and agree that under no circumstances will STARLINK FX be under any obligation to reverse or amend any Withdrawal.

STARLINK FX will make all reasonable efforts to process Withdrawals each business day, in accordance with the Deposit and Withdrawal Schedule on the STARLINK FX website, but you accept and agree that STARLINK FX provides no guarantee in relation to the Withdrawal processing period.

Withdrawals to the bank account of any third party are expressly prohibited. You agree not to make, or attempt to make, any Withdrawal of funds from your STARLINK FX Wallet to the bank account of a third party and accept that any such Withdrawal may be refused and/or result in the restriction, suspension or termination of your STARLINK FX Account.

9 - Fees

The fees applicable to transactions undertaken on the Platform can be viewed on the Fees and Features page of the STARLINK FX website. STARLINK FX reserves the right to change our fees at any time and will update the Fees and Features page accordingly. In certain circumstances, and at our sole discretion, STARLINK FX may notify selected customers of a specific fee change, where we consider a change to be of particular relevance to such customers.

Send and Receive fees. You may be charged a fee to send Supported Digital Currency from your STARLINK FX Wallet and/or to receive Supported Digital Currency into your STARLINK FX Wallet. Fees will apply where Supported Digital Currency is sent to or received from a Supported Digital Currency address (e.g. a Bitcoin address); no fees will apply where Supported Digital Currency is sent to or received from a mobile telephone number or email address. Please see the Fees and Features page of the STARLINK FX website for further information on send and receive fees.

Deposit and Withdrawal fees. All Withdrawals from your STARLINK FX Wallet will incur a fee. Such fees differ by country and are set out on the Fees and Features page of the STARLINK FX website. Some Deposits made using a Supported Deposit Method may incur a fee, as set out on the Fees and Features page, and cash Deposits may incur a Cash Deposit Penalty (see Deposits). Such fees will be displayed in your transaction history upon completion of the transaction.

Instant Buy and Sell fees. The quoted exchange rate in relation to any buy or sell order placed using the Instant Buy and Sell service will include an amount to reflect STARLINK FX’s facilitation of the relevant trade, the percentage of which will vary with market conditions (see Instant Buy or Sell).

Trade fees. STARLINK FX applies a [Maker / Taker fee structure] for customers using the Platform, which is explained in the STARLINK FX Help Centre. Please consult the Fees and Features page of the STARLINK FX website for further information on applicable Maker and Taker fees. STARLINK FX will, at the time of any transaction on the Platform, notify you of any fees that will apply to the transaction. By proceeding with any transaction, you accept and agree to the applicable fees. Such fees will also be displayed in your transaction history upon completion of the transaction.

10 - Account Security

STARLINK FX takes security very seriously and the measures we have in place to protect your STARLINK FX Account are explained on the Security page of the STARLINK FX website. However, you are solely responsible for:

maintaining adequate security and control over your STARLINK FX Account sign-in details, including but not limited to any passwords, personal identification numbers (PINs), API keys, or any other codes associated with your STARLINK FX Account;

enabling any additional security features available to you, including the activation of two factor authentication on your STARLINK FX account (see the STARLINK FX Help Centre);

keeping your contact details up to date so that you can receive any notices or alerts we may send to you in relation to security (see Electronic Communications);

maintaining security and control over the email mailbox, phone number and twofactor authentication applications or devices associated with your STARLINK FX Account.

Failure to take the above measures, and any other security measures available to you, may result in unauthorised access to your STARLINK FX Account and the loss or theft of any digital currency and/or Local Currency balances held in your STARLINK FX Wallet or any linked bank account(s). STARLINK FX shall have no liability to you for or in connection with any unauthorised access to your STARLINK FX Account, where such unauthorised access was due to no fault of STARLINK FX, and/or any failure by you to act upon any notice or alert that we send to you.

The security of your STARLINK FX Account may be compromised, or interruption caused to it, by phishing, spoofing or other attack, computer viruses, spyware, scareware, Trojan horses, worms or other malware that may affect your computer or other equipment. STARLINK FX strongly recommends that you regularly use reputable virus screening and prevention software and remain alert to the fact that SMS, email services and search engines are vulnerable to spoofing and phishing attacks.

Care should be taken in reviewing messages purporting to originate from STARLINK FX and, should you have any uncertainty regarding the authenticity of any communication, you should log in to your STARLINK FX Account through the STARLINK FX website (specifically, https://www.brfxpro.com, and not any other domain name or website purporting to be, or to be related to, STARLINK FX) to review any transactions or required actions.

To the maximum extent permitted by applicable law, you accept and agree that you have full responsibility for all activity that occurs in or through your STARLINK FX Account and accept all risks of any unauthorised or authorised access to your STARLINK FX Account.

Private keys. STARLINK FX securely stores all Supported Digital Currency private keys (“Private Keys”) associated with any STARLINK FX Account. You accept and agree that STARLINK FX shall retain full ownership and control of the Private Keys associated with your STARLINK FX Account and that you shall have no control of, access to, or the ability to use, such Private Keys. For example, but without limiting the generality of the foregoing, STARLINK FX will not:

accept or adhere to any instruction to sign any data with a Private Key;

give access to any funds associated with your private keys, other than those of the Supported Digital Currency associated with your digital currency wallet;

allow the creation of any receive addresses associated with a Private Key other than receive addresses created through your STARLINK FX Wallet. STARLINK FX will not credit to your STARLINK FX Wallet any digital currency associated with a Private Key other than where such funds have been received via a receive address generated through your STARLINK FX Wallet.

11 - Service Availability

While we will do everything we can to provide continuous operations, STARLINK FX does not provide any warranty in relation to the availability of the Platform or your STARLINK FX Account. Without limiting the generality of the foregoing, we do not guarantee continuous access to the Platform or your STARLINK FX Account and make no representation that the Platform, STARLINK FX API, your STARLINK FX Account and/or any products or services offered therein will be available without interruption; or that there will be no delays, failures, errors, omissions or loss of transmitted information.

12 - Transactions On Digital Currency Networks

When you use your STARLINK FX Account to send or receive digital currency, the transaction must be confirmed and recorded in the public ledger associated with the relevant digital currency network (e.g. the Bitcoin network or the Ethereum network). That digital currency network is solely responsible for verifying and confirming any such transactions. STARLINK FX cannot confirm, cancel or reverse transactions on a digital currency network, other than confirming to you that the network has completed the transaction. You accept and agree that:

Once submitted to a digital currency network, a transaction will be unconfirmed for a period of time pending sufficient confirmation of the transaction by the network. A transaction is not complete while it is in a pending state. Funds associated with transactions that are in a pending state will be designated accordingly, and will not be included in your STARLINK FX Wallet balance or be available to you to conduct transactions;

When you send digital currency from your STARLINK FX Account, you are authorising us to submit your transaction request to the relevant digital currency network. Once a transaction request has been submitted to the relevant digital currency network, the network will automatically complete or reject the request and neither you or STARLINK FX will be able to cancel or otherwise modify your transaction.

Digital currency networks are operated by decentralised networks of independent third parties. They are not owned, controlled or operated by STARLINK FX so we cannot ensure that any transaction details you submit will be confirmed by the relevant digital currency network. You agree that any transaction details you submit may not be completed, or may be substantially delayed, by the digital currency network used to process the transaction.

Network protocols and operating rules. The underlying software protocols that govern the operation of the Supported Digital Currencies are open source. Accordingly, anyone can use, copy, modify, and distribute them and STARLINK FX has no ownership of or control over these protocols. By using the Platform, you accept and agree that:

STARLINK FX is not responsible for the operation of any digital currency network’s underlying software protocols and makes no guarantee as to their availability, security, or functionality; the underlying software protocols are subject to sudden changes in operating rules (known as “forks”), and that such forks may materially affect the value, function, and/or name of any digital currency you store in your STARLINK FX Account. Should a fork occur, STARLINK FX may, with or without notice to you, temporarily suspend our operations and, in our sole discretion, decide whether or not to support either branch of the forked protocol entirely; and

in the event STARLINK FX decides not to support a branch of a forked protocol, you will not be given access to the assets on that fork. Those assets will be securely held by STARLINK FX and we will not buy or sell them.