Terms of Service

1. Acceptance of Terms

By accessing or using the services provided by Sirius Digital Pte. Ltd. ("Sirius Digital", "we", "us", or "our"), including our website, platform, mobile applications, and any related services (collectively, the "Services"), you ("you", "your", or "User") agree to be bound by these Terms of Service ("Terms") and all applicable laws and regulations.

If you do not agree to these Terms, you must not access or use the Services.

2. Definitions

In these Terms, unless the context requires otherwise:

• "Account" means your account with Sirius Digital for accessing and using the Services
• "Digital Assets" means cryptocurrencies, digital payment tokens, and other blockchain-based assets
• "Platform" means Sirius Digital's trading and services platform, including website and mobile applications
• "Services" means all services provided by Sirius Digital, including but not limited to account services, trading, custody, and related services
• "Transaction" means any order, trade, transfer, deposit, withdrawal, or other activity conducted through the Services

3. Eligibility

To use our Services, you must meet the following eligibility criteria:

3.1 Age and Legal Capacity

• You are at least 18 years of age (or the age of majority in your jurisdiction)
• You have full legal capacity to enter into binding contracts
• You are not under any legal disability or restriction that prevents you from entering into this agreement

3.2 Geographic and Regulatory Restrictions

• You are not a resident, citizen, or located in a jurisdiction where our Services are prohibited or restricted
• You are not subject to any sanctions imposed by Singapore, the United Nations, the United States, the European Union, or any other applicable authority
• You are not a Politically Exposed Person (PEP) unless you have disclosed this and received our approval

3.3 Compliance and Good Standing

• You will comply with all applicable laws and regulations
• You have not been previously suspended or removed from using our Services
• You are not using the Services for any illegal or unauthorized purpose

4. Account Registration and Verification

4.1 Account Creation

To use our Services, you must create an Account by:

• Providing accurate, complete, and current information
• Completing our identity verification (KYC) process
• Agreeing to these Terms and our policies

4.2 Know Your Customer (KYC) Verification

In accordance with Singapore law, we are required to verify your identity. You must provide:

• Valid government-issued identification documents
• Proof of residential address
• Beneficial ownership information (for corporate accounts)
• Source of funds and wealth information (if required)
• Any other information we reasonably request

For detailed information about our verification requirements, see our AML/KYC Policies.

4.3 Account Security

You are responsible for:

• Maintaining the confidentiality of your login credentials
• All activities that occur under your Account
• Immediately notifying us of any unauthorized access or security breach
• Using strong passwords and enabling two-factor authentication

We are not liable for any loss or damage arising from your failure to protect your Account credentials.

4.4 Account Accuracy and Updates

You must:

• Provide true, accurate, and complete information
• Promptly update any changes to your information
• Not use false identities or impersonate others
• Not create multiple accounts without our permission

5. Services Description

Sirius Digital provides digital asset services, which may include:

• Digital asset trading and exchange services
• Custody and wallet services
• Account management services
• Market information and analytics
• Payment and transfer services

Specific Services available to you may vary based on:

• Your jurisdiction and regulatory status
• Account type and verification level
• Risk assessment and compliance requirements
• Service availability and operational capacity

6. Fees and Charges

6.1 Fee Structure

We charge fees for our Services, which may include:

• Transaction Fees: Charged on trades and exchanges
• Deposit Fees: May apply to certain deposit methods
• Withdrawal Fees: Charged on withdrawals to cover network costs
• Account Fees: Monthly or annual account maintenance fees (if applicable)
• Currency Conversion Fees: Applied when converting between currencies
• Other Service Fees: As disclosed in our fee schedule

6.2 Fee Disclosure and Changes

• Current fees are displayed on our Platform and website
• We may change fees at any time with 30 days' advance notice
• Fee changes will be communicated via email or Platform notification
• Continued use of Services after fee changes constitutes acceptance

6.3 Payment of Fees

• Fees are automatically deducted from your Account balance
• You must maintain sufficient funds to cover applicable fees
• Failure to pay fees may result in suspension or termination of Services

7. Trading and Transactions

7.1 Order Placement

• Orders are placed through our Platform interface
• You are responsible for the accuracy of all order details
• Orders, once submitted, may not be cancellable depending on execution status
• We reserve the right to reject or cancel orders at our discretion

7.2 Order Execution

• We will use reasonable efforts to execute orders in a timely manner
• Execution is subject to market conditions and liquidity
• Actual execution prices may differ from displayed prices due to market volatility
• We are not responsible for market movements or slippage

7.3 Transaction Limits

We may impose limits on:

• Transaction amounts (minimum and maximum)
• Daily, weekly, or monthly volume
• Number of transactions per time period
• Withdrawal amounts and frequency

Limits are based on your account type, verification level, jurisdiction, and our risk assessment.

7.4 Transaction Finality

Digital asset transactions are generally irreversible once confirmed on the blockchain. We cannot reverse, cancel, or refund completed transactions except in limited circumstances at our sole discretion.

8. Deposits and Withdrawals

8.1 Deposits

• Deposits must be from accounts in your own name
• We reserve the right to reject deposits from unverified sources
• Processing times vary based on payment method and verification requirements
• Minimum deposit amounts may apply

8.2 Withdrawals

• Withdrawals are processed to verified accounts or addresses only
• Additional verification may be required for large withdrawals
• Processing times depend on blockchain confirmation and compliance checks
• Withdrawal fees apply to cover network transaction costs

8.3 Holds and Delays

We may delay or suspend deposits or withdrawals if:

• Additional verification is required
• We suspect fraudulent or suspicious activity
• Compliance or regulatory requirements necessitate review
• Technical issues or system maintenance occurs
• Required by law or court order

9. Custody and Asset Protection

9.1 Custody Services

Digital assets held in your Account are:

• Held in custody by Sirius Digital or approved custodians
• Segregated from Sirius Digital's proprietary assets
• Secured using industry-standard security measures
• Subject to our custody policies and procedures

9.2 No Deposit Insurance

9.3 Title and Ownership

You retain ownership of digital assets in your Account. We act as custodian and do not claim ownership of your assets. However, we may have a lien or security interest in your assets to secure payment of fees or other amounts owed to us.

10. Prohibited Activities

You agree NOT to:

• Use the Services for any illegal purpose or in violation of any laws
• Engage in money laundering, terrorist financing, or other financial crimes
• Manipulate markets or engage in fraudulent trading practices
• Provide false, inaccurate, or misleading information
• Use another person's Account without authorization
• Circumvent any security measures or access controls
• Interfere with or disrupt the Platform or Services
• Use automated systems (bots) without our written permission
• Reverse engineer, decompile, or attempt to extract source code
• Violate any intellectual property rights
• Harass, threaten, or harm other users or our staff

11. Risk Warnings and Disclaimers

You acknowledge and understand that:

• Digital assets are highly volatile and speculative
• You may lose some, all, or more than all of your invested capital
• Past performance is not indicative of future results
• No guarantee or warranty is made regarding investment outcomes
• Market conditions can change rapidly and unpredictably

For comprehensive risk information, please review our Risk Warnings.

11.1 No Investment Advice

12. Intellectual Property

12.1 Our Intellectual Property

All content, features, and functionality of the Services, including but not limited to:

• Software, code, and algorithms
• Text, graphics, logos, images, and videos
• Trademarks, service marks, and trade names
• Design, look and feel, and user interface

are owned by Sirius Digital or our licensors and are protected by copyright, trademark, and other intellectual property laws.

12.2 Limited License

We grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Services for their intended purposes only. You may not copy, modify, distribute, sell, or exploit any part of the Services without our written permission.

13. Privacy and Data Protection

Your privacy is important to us. Our collection, use, and protection of your personal data is governed by our Privacy Policy, which is incorporated into these Terms by reference.

By using our Services, you consent to our collection and use of personal data as described in the Privacy Policy.

14. Disclaimers and Limitations of Liability

14.1 Service Disclaimers

14.2 Limitation of Liability

To the maximum extent permitted by law, Sirius Digital, its affiliates, officers, directors, employees, agents, and licensors shall NOT be liable for:

• Indirect, incidental, special, consequential, or punitive damages
• Loss of profits, revenue, data, or business opportunities
• Loss or damage to digital assets due to market conditions
• Delays, interruptions, or errors in Services
• Unauthorized access to your Account by third parties
• Actions or inactions of third-party service providers

Our total liability to you for all claims arising out of or related to these Terms or the Services shall not exceed the fees paid by you to us in the 12 months preceding the event giving rise to liability, or SGD $1,000, whichever is less.

14.3 Force Majeure

We are not liable for any failure or delay in performance due to events beyond our reasonable control, including but not limited to natural disasters, war, terrorism, riots, government actions, network failures, power outages, or labor disputes.

15. Indemnification

You agree to indemnify, defend, and hold harmless Sirius Digital, its affiliates, officers, directors, employees, agents, and licensors from and against any claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys' fees) arising out of or related to:

• Your use or misuse of the Services
• Your violation of these Terms
• Your violation of any laws or regulations
• Your violation of any rights of third parties
• Any information or content you provide

16. Suspension and Termination

16.1 Our Right to Suspend or Terminate

We may suspend, restrict, or terminate your Account and access to Services at any time, with or without notice, if:

• You violate these Terms or our policies
• We suspect fraudulent, illegal, or suspicious activity
• We are required to do so by law, regulation, or court order
• Your Account poses a risk to us, other users, or third parties
• You fail to pay fees or amounts owed
• We decide to discontinue Services

16.2 Your Right to Terminate

You may close your Account at any time by:

• Submitting a closure request through the Platform
• Withdrawing all assets from your Account
• Satisfying all outstanding obligations

16.3 Effect of Termination

Upon termination:

• Your access to Services will be immediately revoked
• You must withdraw your assets within a specified timeframe
• We may continue to hold records as required by law
• Provisions of these Terms that should survive termination will remain in effect

17. Complaints and Dispute Resolution

17.1 Internal Complaints Process

If you have a complaint, please contact:

We will:

• Acknowledge your complaint within 3 business days
• Investigate and provide a response within 30 days

17.2 FIDReC

If you are not satisfied with our resolution, you may refer the matter to the Financial Industry Disputes Resolution Centre (FIDReC) at www.fidrec.com.sg.

18. Governing Law and Jurisdiction

These Terms are governed by and construed in accordance with the laws of the Republic of Singapore, without regard to its conflict of law provisions.

You agree that any dispute arising out of or relating to these Terms or the Services shall be subject to the exclusive jurisdiction of the courts of Singapore.

19. Amendments to Terms

We may modify these Terms at any time by:

• Posting updated Terms on our website
• Notifying you via email or Platform notification
• Providing at least 30 days' notice for material changes (where required)

Your continued use of the Services after changes become effective constitutes your acceptance of the modified Terms. If you do not agree to the changes, you must stop using the Services and close your Account.

20. General Provisions

20.1 Entire Agreement

These Terms, together with our Privacy Policy, AML/KYC Policies, Risk Warnings, and other referenced policies, constitute the entire agreement between you and Sirius Digital regarding the Services.

20.2 Severability

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions will remain in full force and effect.

20.3 No Waiver

Our failure to enforce any provision of these Terms shall not constitute a waiver of that provision or any other provision.

20.4 Assignment

You may not assign or transfer these Terms or your Account without our written consent. We may assign or transfer these Terms at any time.

20.5 No Partnership

Nothing in these Terms creates a partnership, joint venture, agency, or employment relationship between you and Sirius Digital.

20.6 Notices

All notices to you will be sent to the email address or physical address associated with your Account. Notices to us should be sent to:

21. Contact Information

For questions about these Terms or our Services: