MM Bitinvest OÜ

Narva mnt 5, Harju maakond, Tallinn

10117, Estonia

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TERMS AND CONDITIONS

These Terms of Service and any terms expressly incorporated herein (the “Terms”) govern

access to and use of all parts of the website and mobile application branded as MY NEO

GROUP / NEO Dash / NEO X / NEO ONE and referring to the domains https://myneogroup.com

https:// myneodash.com (the “Website”, “App”) and all documents, data, materials or other

information made available on the Websites.

Your access to and use of the Website and/or App is conditioned on your acceptance of and

compliance with these Terms. These Terms apply to all visitors, users, Clients and others who

access or use the Website and/ or App. These Terms contain the entirety of the applicable; any

conflicting or departing terms shall not be applicable, unless We expressly confirm the

applicability.

By clicking the “Sign up” button or by accessing or using the Website and/ or App, you

acknowledge and agree to be legally bound by these Terms and Privacy Policy as published on

the Website and/ or App at the time of each use. If you do not agree to the Terms and Privacy

Policy, please refrain from using the Website and/ or App. These Terms may be made available

in several languages; all versions are legally binding, but in the event of inconsistency between

the English version and a translated version, the English version prevails.

We cannot guarantee that Our Services will always meet your demands. As We grow, We will

likely add new services, change certain features and drop old features. However, We truly hope

You will always be satisfied with Us and Services We provide to You.

Last updated: 26

March, 2024.

CONTENT

Please click the links below if You wish to go directly to a particular section of these Terms. The

headings are for reference only and do not affect construction and interpretation.

1. DEFINITIONS

2. GENERAL PROVISIONS

3. REGISTRATION FOR A NEO DASH / NEO ONE ACCOUNT

4. SERVICES PROVIDED AND ACCESS

5. CLIENT OBLIGATIONS

6. LINKS TO OTHER WEB SITES

7. DISCLAIMER

8. RISK DISCLOSURE

9. LIABILITY

10. INDEMNIFICATION

11. CANCELLING YOUR ACCOUNT

12. ACCOUNT SUSPENSION AND CLOSURE

13. GENERAL PROVISIONS & APPLICABLE LAW

14. CONTACT US

15. MODIFICATIONS

16. PRIVACY POLICY

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1. DEFINITIONS

1.1. Capitalized terms not otherwise defined in these Terms will have the following meaning:

• Account an account on the Platform opened and held in the name of a Client and maintained

by NEO Dash and/or NEO X and/or NEO ONE.

• Client, “You” all the natural or legal persons who have registered on NEO Dash Platform or

NEO X / NEO ONE Apps.

• NEO Dash’s Terms of Services, “Terms” NEO Dash’s Terms of Services for the Clients

available on the Website and/ or App and as may be amended from time to time.

• My NEO GROUP, NEO Dash, NEO X, NEO ONE, “We”, “Us”or “Our” is a FinTech

organisation, developed by the MM BITINVEST OU company, which is based in Estonia with

the company registration number: 16019579 and with a registered address at: Narva mnt 5,

Harju maakond, Tallinn, Estonia 10117. “Collaboration Partner” provides different types of

Services to NEO Dash / NEO ONE end Clients. Through the confirmation of the present

Terms, the Client agrees to the Terms of Use and Privacy Policies of each Collaboration

Partner, without prejudice that any of these may require additional consent or validation

necessary for the part of the Service they are in charge. Collaboration Partners may restrict

their services to Client who does not comply with Collaboration Partner’s risk appetite. All

services regulated as e - money and/or payments services are exclusively provided by the

Collaboration Provider (and never by MM BITINVEST OU). Please find Our Collaboration

Partner list below in this document.

• Funds in account for both crypto and fiat currencies which hold inter-exchangeable value and

are operated within Our system. These funds can be digitally deposited, withdrawn,

transferred, and stored.

• GDPR Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April

2016 on the protection of natural persons with regard to the processing of personal data and

on the free movement of such data and repealing Directive 95/46/EC (General Data

Protection Regulation) (Text with EEA relevance), OJ L 119, 4.5.2016. If your country of

residence is based within the European Economic Area (“EEA”) and the GDPR applies to Our

processing of your personal data (within the meaning of GDPR), your representative within the

EEA for the purposes of the GDPR is Neo Dash App, Ltd. If your Country of Residence is

outside of the EEA, provisions related to the GDPR shall not apply to your use of the Services.

• Payment Card: a payment card issued to you by an authorized Third-Party Service Provider,

enabling payment transactions in fiat money than can be funded with Virtual Assets stored in

your Wallet.

• Platform a publicly accessible internet-based information system which is branded as’NEO

Dash’, available via the Website and/ or App and operated or managed by MM BITINVEST

OU.

• Services connecting the Clients to technological tools through the use of the Platform NEO

Dash and/or NEO ONE app providing the different Collaboration Partners services,

including but not limited to (i) virtual and physical cards, (ii) crypto wallets, (iii) crypto

exchange, (iv) rewards center, (v) token staking and (vi) Marketplace in a single Platform.

• Third-Party Service Providers: authorized or regulated financial institutions, providers of

processing, identity verification, anti-money laundering services, and such other third parties

as we may partner with from time to time.

• Third-Party Services: services made available by Third-Party Service Providers.

• Third-Party Terms: terms, conditions, and policies of Third-Party Service Providers.

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• VIBAN Account: a virtual account opened for you by Striga that is linked to Striga’s payment

account opened by an authorized Third-Party Service Provider, enabling certain transactions

with fiat currency as further detailed in the Terms.

• Virtual Asset: a value represented in the digital form, which is digitally transferable,

preservable, or tradable and which natural persons or legal persons accept as a payment

instrument but that is not the legal tender of any country or funds for the purposes of Article

4(25) of Directive (EU) 2015/2366 of the European Parliament and of the Council on payment

services in the internal market, amending Directives 2002/65/EC, 2009/110/EC, and 2013/36/

EU and Regulation (EU) No 1093/2010, and repealing Directive 2007/64/EC (OJ L 337,

23.12.2015, pp 35–127) or a payment transaction for the purposes of points (k) and (l) of

Article 3 of the same Directive.

• Virtual Asset Services: any or all of the following:

•

Virtual Asset Wallet Service: a Service in the framework of which we host a Virtual Asset

Wallet or account that is managed with encrypted keys and enables the holding, storage,

and transfer of Virtual Assets.

•

Virtual Asset Transfer Service: a Service that allows a transaction to be conducted

electronically at least in part through us in your name with the aim of moving the Virtual

Asset to the recipient’s Virtual Asset Wallet or account.

•

Virtual Asset Exchange Service: a Service with the help of which you exchange a Virtual

Asset against a fiat currency or a fiat currency against a Virtual Asset, or a Virtual Asset

against another Virtual Asset.

• Wallet a storage which is used to store, send, and receive cryptocurrencies digital and

securely. NEO Dash has a multi-currency wallet allowing Our Clients to receive different types

of cryptocurrencies supported by the NEO Dash. The Wallet holds one or more public

addresses that act as cryptocurrency account numbers and can be used to receive that

particular asset. Blockchain is a linear chain of multiple linked blocks that are cryptographically

secured. Each block contains, among other things, a list of recent transactions and a

reference to the block which came immediately before it.

• Website the website branded as My NEO GROUP, Neo Dash and NEO ONE and

referring to the domains https://myneogroup.com and https://myneodash.com

https://myneoone.com

2. GENERAL PROVISIONS

2.1. The use of the Website App and its content is voluntary and falls under the responsibility of

the Client.

2.2. The Services are intended solely for users who are at least 18 years old or of legal age in their

respective country, if higher, and who satisfy the criteria described in these Terms. The Client must

represent and warrant that he/she: (i) as an individual, legal person, or other organization, have

full legal capacity and sufficient authorizations to enter into these Terms; (ii) have not been

previously suspended or removed from using Our Services; (iii) are not located in, or a citizen or

resident of the United States; (iv) is not a legal or natural person with US citizenship, domicile or tax

liability in the USA or according to the sanction lists of OFAC, the United Nations, the European

Union, the United Kingdom, Austria, Switzerland, Liechtenstein or other sanction lists and (v) is

not a Politically Exposed Person (PEP).

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2.3. Some Services may not be available in certain jurisdictions or regions or to certain users. We

reserve the right to change, modify or impose additional restrictions at Our discretion at any time.

2.4. As long as You agree to and comply with these Terms, We guarantee You the personal,

non-exclusive, non-transferable, non-sublicensable and limited right to enter and use the

Platform and the Services.

2.5. You are the only person authorized to use your Account and the Services and You may not

share your Account credentials with any other person.

2.6. Withdrawal of FIAT funds from the NEO Dash Platform and/or NEO ONE app is permissible

only to Your personal bank account, while transactions of virtual assets are allowed to third parties.

3. REGISTRATION FOR A NEO Dash / NEO ONE ACCOUNT

3.1. All users must apply for a NEO Dash and/or NEO ONE Account before using NEO Dash

and/or NEO X and/or NEO ONE Services.

3.2. When You register a NEO Dash and/or NEO ONE Account, You must provide your real

name, birthdate, country, mobile number, email address and password, and accept these

Terms, the Privacy Policy, and other Platform rules. Please use the letters of the Latin

alphabet in the sections where We ask you to fill in requested information.

3.3. From time to time We may be required to request further information regarding your

transactions in order to comply with applicable law and regulation. Failure to provide such

information in a timely fashion may result in the suspension of your ability to use the Services

(until you provide such information) or the closure of your Account.

3.4. You represent and warrant that any and all information provided to Us pursuant to the

registration process or otherwise is true, accurate and not misleading in any respect. If any such

information changes, it is your obligation to timely update such information as soon as possible

to maintain the integrity and accuracy of the information.

3.5. If there are any grounds for believing that any of the information You provided is incorrect,

false, outdated or incomplete, NEO Dash and/or NEO ONE reserves the right to send You a notice

to demand correction, directly delete the relevant information, and, as the case may be, terminate

all or part of NEO Dash and/or NEO ONE Services provided to You. If We are unable to reach You

with the contact information You provided, You shall be fully liable for any loss or expense caused

to NEO Dash and/or NEO ONE during your use of NEO Dash and/or NEO ONE Services.

3.6. For Our compliance purposes and in order to provide the Services to You, You hereby

authorize Us to, directly or through a Collaboration Partner, obtain, verify, and record information

and documentation that helps Us to verify your identity and personal Account information.

3.7. You must also keep your login data secret and take all responsible precautions to protect

the login data from unauthorized access. We reserve the right to change your login data or close

your account, if We discover that your account has been used by an unauthorized party.

4. SERVICES PROVIDED AND ACCESS

4.1. Access to the Services is granted through Our Website or Our App. Your use of the App

remains at all times subject to the terms of conditions and privacy policies of the relevant app

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store from which You downloaded it, for example the Google Play or the Apple App Store. To the

extent that there is a conflict between those terms and conditions and these Terms and

Conditions, these Terms prevail.

4.2. Certain Services or parts of the Platform may be accessible only by agreeing to the terms of

use and privacy policies of Our Collaboration Partner’s. We strongly advise You to read the terms

and conditions and privacy policies before applying for the Services. Please find Our Collaboration

Partner list below in this document.

4.3. We reserve the right to change, suspend, or discontinue any aspect of the Services at any

time and in any jurisdiction, including hours of operation or availability of any feature, without

liability. This will make changes to these Terms necessary.

4.4. We may decline to process any order and may limit or suspend your use of one or more

Services at any time, in our sole discretion. Suspension of your use of any of the Services will not

affect your rights and obligations pursuant to these Terms. We may, in Our sole discretion, decline

to process orders if (i) We believe the transaction is suspicious; (ii) the transaction may involve

fraud or misconduct; (iii) it violates applicable laws; or (vi) it violates the terms of these Terms.

Where permitted by law, We will notify you by the end of the business day if We have suspended

processing your orders and, if possible, provide Our reasons for doing so and anything You can

do to correct any errors leading to the stoppage.

4.5. You must not access without authority, penetrate, interfere with, damage or disrupt (or

attempt to do any of the same) any part of the Services or its security measures, any servers,

other equipment or networks connected to the Services or on which it is stored or any software

used in the provision of the Services, including in each case by transmitting any worms, computer

viruses, malware, logic bombs, Trojan horses, spyware, harmful components or any other

software, code or data of a corrupt, destructive, malicious or disruptive nature (the “Viruses”). You

also agree to take steps to ensure that the hardware and software that you employ to access the

Services does not introduce any form of computer Viruses or similar item into the Service and

agree to indemnify Us for any loss that it may suffer as a result of such introduction.

4.6. You agree to pay NEO Dash and/or NEO ONE the fees specified in NEO Dash and/or NEO

ONE service fees schedule. NEO Dash and/or NEO ONE may, in its discretion, update the fees at

any time. Any updated fees will apply to any sales or other transactions that occur following the

effective date of the updated fees. You authorize NEO Dash and/or NEO ONE to deduct from your

account any applicable fees that you owe under these Terms.

CRYPTO CARD and vIBAN FEES

ONBOARDING

Onboarding fee – only in NEO DASH

5 €

Payable via credit card or via NRT

Customer onboarding (KYC)

Included

Monthly fee per Active User

Included

Monthly fee per Active Card

Included

SEPA

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vIBAN issuing

Included

SEPA incoming and outgoing per transaction

€

CARDS

Plastic Cards issuing

€

Virtual Cards issuing

1,50

€

Payment Fee per Authorization

(No additional scheme fees/settlement fees/ clearing fees)

Physical at POS

€

0,30

Online

€

0,30

Foreign Exchange Fees per transaction amount

0.0%

Fee per ATM cash withdraw

€3 + 4%

CARD SHIPPING

Post (not tracked) 9-10 days

5,00 €

Tracked 3-6 days

10,00 €

Express 1-2 days

30,00 €

CRYPTO

Digital Asset Withdrawal per amount withdrawn

This fee is in addition to the network-fee-based fee collected by our third-party provider

0.30%

Digital Asset Deposit per amount deposited

0.30%

Cryptocurrency exchange

0.70%

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4.7. Fees collection can happen directly by the Platform or through our Third-Party Providers,

guaranteeing the we instruct our Third-Party Providers to debit such fees from the customer’s

account in accordance with the pricing applicable to the customer, and we assume liability for

compensating charged fees to which the customer has not consented.

4.7.1 The onboarding fee can be paid via credit card (Stripe) or via the native crypto token of

the platform (NRT).

When the user reaches the onboarding fee payment page, they are presented with the option

to pay via credit card or the native crypto token.

a) If the user chooses to pay via credit card, they will be prompted redirected to Stripe, a third-

party payment processor, asked to enter their credit card details, including card number,

expiration date, CVC, and billing address. Stripe verifies the payment details and, upon

successful authorization, processes the payment for the onboarding fee. Once the payment is

successfully processed, the user receives a confirmation of the payment and their onboarding

process continues.

b) If the user chooses to pay via the native crypto token (NRT), they will be provided with the

necessary instructions for making the payment using the platform's supported cryptocurrency

wallet. Upon user acceptance of paying the onboarding fee via NRTs, the platform proceeds

with the debit of 8 NRT on user’s NRT wallet embedded in the NEO DASH platform. The

platform's system monitors the blockchain for the incoming transaction and waits for the

required number of confirmations to validate the payment. Upon successful verification, the

user receives confirmation of the NRT payment, and their onboarding process proceeds.

4.8. Subject to availability, as per our arrangements, we may provide you with access to our

Platform (through the application developed, maintained, and/or made available to you by the

respective Third-Party Service Provider) to use some or all the following Services:

4.8.1. Virtual Asset Wallet Service;

4.8.2. Virtual Asset Transfer Service;

4.8.3. Virtual Asset Exchange Service;

4.8.4. vIBAN Account;

4.8.5. vIBAN Account;

4.8.6. Card issuance;

4.8.7. Payment Services.

4.8.8 Crypto Payment Card issuance

4.9. We provide Virtual Asset Services only for a limited list of supported Virtual Assets as per our

arrangements with the relevant Third-party Providers. Subject to any legal, regulatory, technical,

or reputational considerations, we may change the list of supported Virtual Assets. The Third-Party

Provider, through whom you access the Services on the Platform, may provide or enable support

for additional Virtual Assets if the Third-Party Provider is authorized to do so under applicable law;

however, we are not bound by our Third-Party Provider’ product offering and do not assume any

liability to that effect.

4.10. By using the Third-Party Services, you acknowledge that Third-Party Services are

provided or made available by Third-Party Service Providers, and the Third-Party Terms may

apply to such services. You are required to read, acknowledge, accept, and comply with the

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Third-Party Terms, failure to do so may result in suspension or termination of providing the

Services and Third-Party Services to you.

4.11. In the normal course of providing our Virtual Asset Services, it may become necessary or

advantageous for MM Bitinvest OU to engage third parties to carry out certain administrative or

ancillary tasks. Our decision to involve third parties is driven by our commitment to enhance the

service experience and efficiency for our users.

While MM Bitinvest OU is dedicated to selecting third-party service providers with a

demonstrated track record of reliability and expertise, it is important for our users to understand

that MM Bitinvest OU's role is primarily that of facilitation and oversight. As such, we do not

assume direct liability for the defaults, acts, or omissions of these third parties.

We ensure a responsible approach to third-party collaborations through:

(i) A selective engagement process focusing on the expertise and reliability of third parties.

(ii) Establishing clear expectations and guidelines for performance and compliance to ensure

alignment with our service standards.

It is our policy to monitor the performance and compliance of third-party service providers to

ensure that their contributions positively impact the services we provide. However, the direct

legal and operational responsibilities between these third parties and our users are governed

by their own terms and agreements.

Our users' trust and satisfaction are paramount. Should any issues arise from the involvement

of third parties, MM Bitinvest OU commits to acting as a mediator to facilitate a resolution,

leveraging our relationships and agreements with these providers.

This approach allows us to extend the range and quality of our services while maintaining a

clear and responsible stance on our role and the extent of our liabilities.

4.12 PROHIBITED JURISDICTIONS Currently, we are unable to provide or make Services

available to citizens or residents of the following jurisdictions: Afghanistan, Albania, Algeria,

Armenia, Azerbaijan, Barbados, Belarus, Botswana, Burkina Faso, Burundi, Cambodia,

Cameroon, Cayman Islands, Central African Republic, Chad, Cuba, Democratic Republic of

Congo, Democratic People’s Republic of Korea (North Korea), Egypt, Equatorial Guinea,

Ghana, Guinea, Guinea Bissau, Haiti, Iran, Iraq, Jamaica, Japan, Jordan, Kazakhstan, Kenya,

Kyrgyzstan, Lebanon, Libya, Mali, Mauritius, Moldova, Morocco, Mozambique, Myanmar,

Nicaragua, Niger, Nigeria, Pakistan, Palestinian Authority, Panama, Philippines, Russia, Saudi

Arabia, Senegal, Somalia, South Sudan, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania,

Trinidad and Tobago, Tunisia, Turkmenistan, Türkiye, Uganda, Ukraine, United Arab Emirates,

United States of America, Uzbekistan, Vanuatu, Venezuela, Yemen, Zimbabwe.

The Services are not accessible from the countries, territories, regions, and jurisdictions

provided above. We also do not open accounts for residents of the United Kingdom of Great

Britan and Northern Ireland.

4.13 EXCLUDED PAYMENT CARD USE AREA Using the Payment Card is not possible within

the following countries, territories, regions, or jurisdictions: Afghanistan, Albania, Algeria,

Bahamas, Barbados, Belarus, Botswana, Burkina Faso, Burundi, Cambodia, Cayman Islands,

Congo, Cuba, Democratic Republic of Congo, Democratic People’s Republic of Korea (North

Korea), Egypt, Equatorial Guinea, Ghana, Guinea Bissau, Haiti, Iran, Iraq, Jamaica, Jordan,

Lebanon, Libya, Mali, Mauritius, Morocco, Mozambique, Myanmar, Nicaragua, Niger, Nigeria,

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Pakistan, Palestinian Authority, Panama, Russia, Saudi Arabia, Senegal, Somalia, South

Sudan, Sudan, Syria, Trinidad and Tobago, Tunisia, Turkmenistan, Türkiye, Uganda, Ukraine,

United Arab Emirates, Uzbekistan, Vanuatu, Venezuela, Yemen, Zimbabwe.

5. CLIENT OBLIGATIONS

5.1. When using the NEO Dash and/or NEO ONE Services, You must comply with the applicable

laws. You must not:

5.1.1. attack Our network security, in particular by uploading or attaching files that are infected with

viruses or other harmful components capable of impairing the operation of another user's

device;

5.1.2. impair or in any way attempt to impair other users' access to or use of the Website or the

Services (e.g., by generating, whether manually or by automated means, an unusually high

number of accesses);

5.1.3. harvest or otherwise collect information about users, including email addresses, without their

consent;

5.1.4. post false, inaccurate, misleading, defamatory, unlawful, harassing, libellous, privacy-

invading, abusive, threatening, harmful, vulgar, obscene, or otherwise objectionable content

on Our Website or through/on Our Services or commercialize any Our services, application,

or any information or software associated with them;

5.1.5. use, copy, reproduce, modify, translate, publish, broadcast, transmit, distribute, perform,

upload, display, license, sell or otherwise exploit for any purpose any content of the Website

not owned by you in a way that violates someone else’s (including Ours) rights;

5.1.6. commercialize any Our Services, application, or any information or software associated with

them.

5.2. We reserve the right to settle any damages caused due to the breach of these Terms from

the funds stored in Your account.

6. LINKS TO OTHER WEBSITES

6.1. The Platform may contain links to third-party (including, but not limited to, Collaboration

Partner) websites or services that are not owned or controlled by Us. These links are provided

solely as a convenience to you.

6.2. We have no control over, and We assume no responsibility for, the information, content,

privacy policies, or practices of any third-party websites or services. You further acknowledge and

agree that We shall not be responsible or liable, directly or indirectly, for any damage or loss caused

or alleged to be caused by or in connection with use of or reliance on any such information, content,

goods or services available on or through any such websites or services.

6.3. We do not assume any liability for the content of any referenced or linked off-site page and are

not liable for that content. The risk of injury rests entirely with You. Links from the Platform to other

websites do not constitute an endorsement, a recommendation or an approval from Us. It is your

responsibility to evaluate the content and usefulness of information obtained from other websites.

7. DISCLAIMER

7.1. There is a risk that We may be temporarily or permanently not able to provide access to the

Platform and thus also to the Services. The Platform is provided “as is” and “as available”. We and

our Collaboration Partner’s, expressly disclaim all representations or warranties of any kind,

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whether express, implied, statutory or otherwise about the Platform and Services, including, without

limitation, any implied warranties of merchantability, fitness for a particular purpose, non-

infringement or course of performance.

7.2. NEO Dash and/or NEO ONE strive to ensure the Platform operates with a high standard of

reliability and security. We acknowledge that (i) the Platform may experience interruptions and may

not be available at all times or locations; (ii) we are committed to promptly addressing errors or

defects, though immediate resolution cannot be guaranteed for every instance; (iii) the Platform is

designed to be free from viruses and other harmful components, with robust security measures in

place to protect our users; however, we recognize the evolving nature of digital threats and remain

vigilant in our efforts to safeguard against them; (iv) while we take extensive measures to secure

all content and data, including your data, absolute security cannot be assured; (v) we cannot

guarantee the accuracy or reliability of results obtained from using the Services, nor that such

results will meet your specific requirements or expectations. MM Bitinvest OU is dedicated to

actively managing and mitigating the risks associated with the use of digital services, committing

to enhance security and user protection without assuming undue liability beyond what is reasonably

within our control and legal scope.

8. RISK DISCLOSURE

8.1. By accessing or utilizing the NEO Dash and/or NEO ONE Services, you acknowledge that you

are engaging voluntarily in transactions that involve sophisticated digital assets, which are inherently

risky. You recognize the various risks associated with using these Services and engaging in

cryptocurrency transactions. These risks include, but are not limited to, the potential for financial loss,

technological issues (not limited to blockchain technology flaws), and the possibility of security

breaches.

While NEO Dash and/or NEO ONE commits to implementing advanced security measures and

maintaining our systems to the highest standards possible, it is important for you to understand that

some risks in the digital asset environment are unavoidable. Technical difficulties, such as problems

with depositing or trading cryptocurrencies, may occur and could require an extended period to

resolve. We emphasize that some issues might not be resolvable.

By accepting these Terms, you acknowledge that you are aware of these risks. It is crucial to note

that NEO Dash and/or NEO ONE's role is to facilitate transactions on the Platform, and while we strive

to ensure the security and functionality of our services, we do not assume liability for the intrinsic risks

of cryptocurrency transactions. You, as the user, assume full responsibility for understanding and

accepting the risks associated with digital asset transactions, including any technological or security

risks.

This acknowledgment does not diminish the responsibility of NEO Dash and/or NEO ONE to exercise

reasonable care in providing its services. However, it is clarified that NEO Dash and/or NEO ONE,

while facilitating transactions involving digital assets through its platform, does not bear liability for

losses arising directly from the inherent risks of digital asset transactions that are beyond our control.

9. LIABILITY

9.1. In no event shall NEO Dash and/or NEO ONE, its Board Members, Employees,

Collaboration Partner’s or entities of the NEO Dash’s group, be liable for any indirect, incidental,

special, consequential or

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punitive damages, including without limitation, loss of profits, data, use, goodwill, or other

intangible losses, resulting from (i) your access to or use of or inability to access or use the

Platform; (ii) any conduct, content of any third party on the Platform; (iii) any content obtained

from the Platform; and (iv) unauthorized access, use or alteration of your transmissions,

content, whether based on warranty, contract, tort (including negligence) or (v) any other legal

theory, whether or not We have been informed of the possibility of such damage, and even if a

remedy set forth herein is found to have failed of its essential purpose.

9.2. We endeavor to ensure but cannot guarantee essentially uninterrupted availability of the

Platform and the Services and error-free transmissions. Access to the Platform or the Services

may also be suspended or restricted from time to time to allow for repairs and maintenance or the

introduction of new services or tools. 9.3. We are not liable for any damages or impairments which

are the result of an improper or incorrect use of our Services by You.

10. INDEMNIFICATION

10.1. You agree to fully compensate Us for any and all claims, civil responsibilities, damages,

expenses and costs (including the costs of our necessary legal defense, e.g. court and lawyer

fees), as well as You allow Us to make any deduction from your Account, caused by or arising

from your use of the Services, your violation of these Terms or your infringement, or infringement

by any other person of your account (including, but not limited to, exploitation of the Platform’s

software error/glitch).

11. CANCELING YOUR ACCOUNT

11.1. You may cancel your Account at any time. If you do not use your Account for an extended

period and reman inactive, We reserve the right to cancel your Account and Account information

stored in the Services may be made unavailable. To cancel your account email

support@myneodash.com with your primary email address or click on the account closure button

from your profile and make sure all your funds have been withdrawn to the account that only

belongs to You.

11.2. In case there is crypto currency balance that is too small to be withdrawn (crypto dust) You

hereby waive the ownership or any current or future claims to Your remaining account balance and

agree that this amount becomes the crypto dust

12. ACCOUNT SUSPENSION AND CLOSURE

12.1. We may, in Our sole and absolute discretion, without liability to You or any third party, refuse

to let You open an Account, suspend your Account, consolidate Accounts if You have more than

one or terminate your Account or your use of one or more of the Services. Such actions may be

taken as a result of one or more of a number of factors, including without limitation account

inactivity, failure to respond to customer support requests, failure to provide positive identification,

a court order, illegal/fraudulent activities or your violation of the Terms. We may also temporarily

suspend access to your Account in the event that a technical problem causes a system outage or

Account errors until the problem is resolved. We are entitled to take all and any of the

aforementioned actions in regards to your Account for compliance reasons without the need for

providing You with more detailed explanation thereof than just “for compliance reasons” in order

to prevent the tipping-off risk.

MM Bitinvest OÜ

Narva mnt 5, Harju maakond, Tallinn

10117, Estonia

Pagina 12 di 43

12.2. We will determine, in Our sole discretion, whether there has been a breach of these Terms

through your use of the Services. When such a breach has occurred, We may take such action as

We deem appropriate, including all or any of the following actions:

12.2.1. immediate, temporary or permanent withdrawal of your right to use the Platform and

Services;

12.2.2. issue of a warning to You;

12.2.3. legal proceedings against You for reimbursement of all costs resulting from the breach;

12.2.4. further legal action against You; and/or

12.2.5. disclosure of such information to law enforcement authorities as We reasonably feel is

necessary.

12.3. The responses described above are not limited and We may take any other action We

reasonably deem appropriate.

12.4. We reserve the right to restrict or refuse to permit withdrawals from your Account if (i) your

Account has otherwise been suspended or closed by Us in accordance with these Terms; (ii) to do

so would be prohibited by law or a court order or We have determined that the assets were obtained

fraudulently; or (iii) You have not undergone the required identity verification procedure such that

your identity has been verified, as indicated by your Account.

12.5. Fees paid for upgrade of tier levels or any other fees paid when using our Services are not

refundable nor will be returned to you if your Account is closed or suspended whether on your

initiative or for any other reason by us.

12.6. You acknowledge and agree that closure of your Account may incur additional charges.

12.7. In the event that You or We terminate your access to the Services, or deactivate or cancel

your Account, You remain liable for all activity conducted with or in connection with your Account

while it was open and for all amounts due.

12.8. We reserve the right to maintain your account registration and trading information, after You

close your Account, for business and regulatory compliance purposes, for a period no less than

5 years, subject to applicable laws and regulations.

13. GENERAL PROVISIONS & APPLICABLE LAW

13.1. You acknowledge that we reserve the right to assign, sub-license, or otherwise transfer any of

our rights and/or obligations under these Terms to any third party at any time. It is our commitment to

ensure that any such transfer will be conducted in a manner that respects the continuity and quality

of the service provided to you and upholds your rights under these Terms.

In the event of an assignment, sub-license, or transfer, we will provide you with adequate notice to

inform you of any changes that may affect your access to and use of the Services. Your rights as

outlined in these Terms, including but not limited to privacy, data protection, and access to services,

will be maintained and respected throughout the process. We understand the importance of

transparency and the value of your trust in our services. As such, we pledge to uphold the highest

standards of service and respect for your rights, ensuring that any changes in the assignment, sub-

licensing, or transfer of obligations are communicated clearly and effectively to you.

13.2. We understand the importance of transparency and the value of your trust in our services.

As such, we pledge to uphold the highest standards of service and respect for your rights, ensuring

that any changes in the assignment, sub-licensing, or transfer of obligations are communicated

clearly and effectively to you. We will have no liability to You for any failure or delay in performing

any of Our obligations under these Terms to the extent that such failure or delay is caused or

contributed to by You or by an event or circumstance beyond Our reasonable control.

MM Bitinvest OÜ

Narva mnt 5, Harju maakond, Tallinn

10117, Estonia

Pagina 13 di 43

13.3. These Terms (together with the Client registration form on the Website and/or App and Our

matter of the agreement between us and supersedes all prior agreements, understandings or

arrangements (both oral and written) relating to the same.

13.4. If any provision of these Terms is found to be invalid for any reason, the invalidity of that

provision will not affect the remaining provisions of these Terms, which will remain in full force

and effect. You agree to mutually replace the respective provision by a new legal, valid and

enforceable provision which comes closely to the intent and economic effect of the invalid

provision. This also applies in case of contractual gaps .

13.5. Failure by either You or Us to exercise any right or remedy under these Terms does not

constitute a waiver of that right or remedy.

13.6. Any dispute, controversy, or claim arising out of or in connection with Our Services,

or the breach, termination, or invalidity thereof, shall be settled in accordance with the laws

of Estonia. To provide clarity and ensure a more streamlined dispute resolution process for

our users, Estonia has been selected as the sole jurisdiction for the resolution of disputes

related to these Terms & Conditions and the use of Our Services. This decision reflects

our aim to align with the legal framework most relevant to our users within the European

Economic Area (EEA). In the event of a dispute, users are encouraged to contact us

directly to seek a resolution before proceeding to legal action. Should a dispute require

legal intervention, proceedings shall be brought exclusively in the competent courts of

Estonia, which shall have exclusive jurisdiction over such disputes.

14. CONTACT US

14.1. Any Client who is dissatisfied with Our Services, has found a deficiency, or identified

dishonesty, should contact Our customer services team via Our email support@myneodash.com,

support@myneoone.com, or ticketing service available from your Account under the section NEO

HELP ([email protected], [email protected]m). All requests will be processed

according to the cue and processed within 24-48 hours during business days.

14.2. The Customer Support service is available from Monday to Saturday 9am - 5pm (GMT+1)

for any questions You may have.

14.3. We will do Our best to resolve your request as soon as possible, but this may not always

be possible.

14.4. We will keep You updated on the progress of handling your complaint and reply to your

reasonable information requests made in this regard by You without any undue delay.

14.5. We will keep You updated on the progress of handling your complaint and reply to your

reasonable information requests made in this regard by You without any undue delay.

15. MODIFICATIONS

15.1. We reserve the right, at Our sole discretion to modify, restrict, refuse, move, remove,

disable or discontinue, entirely or in part, at any time and without prior notice, these Terms, the

Services and content, including Client content, on the Platform. In all such cases, We will take

account of the Clients' interests.

15.2. We will inform Our Clients on all material amendments to these Terms by publishing the

updated version of these Terms on the Platform..

15.3. You consent to these Terms anew each time You use the Platform and are bound by them

as currently published on the Website at the time of each use.

MM Bitinvest OÜ

Narva mnt 5, Harju maakond, Tallinn

10117, Estonia

Pagina 14 di 43

16. PRIVACY POLICY

16.1. We care about your data protection, its security and confidentiality. Please see Our Privacy

Policy to find information on how We will process your personal data when You visit or use Our

Website or contact Us.

16.2 For Third Party services, we process the customer’s data upon the instructions of Third

Party services providers and the card issuer. We act as a data processor, but upon processing

any additional customer’s data, we act as a data controller.

Third party provider

MM Bitinvest OÜ

Narva mnt 5, Harju maakond, Tallinn

10117, Estonia

Pagina 15 di 43

Virtual asset services provided by Striga Technology OÜ (registry code: 16298772), address:

Sepapaja 6, Tallinn, Estonia, in accordance with its terms and conditions pag. 13 of these T&C.

Crypto Card is issued and related payment services are provided by Wallester AS (registry

code: 11812881), address F.R. Kreutzwaldi 4, 10120 Tallinn, Estonia, in accordance with its

terms and conditions pag. 37 of these T&C.