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Terms of Service

Operator: The Choice Marketing Agency d.o.o. Novi Sad · Janka Čmelika 35a, 21000 Novi Sad, Republika Srbija · MB 21856886 · PIB 113382199 · effective from 17 Nov 2022 · version 2.0

1.1. These Terms of Service (the "Agreement") constitute a legally binding contract between The Choice Marketing Agency d.o.o. Novi Sad (the "Company", "we") and the individual using the Company's online platform (the "Platform", "Service").

1.2. The following are integral parts of the Agreement: the Privacy Policy, the AML/KYC Policy, the Cookie Policy, and the rates, limits, and rules for individual Platform features published in its interface (collectively, the "Platform Documents"). In the event of conflict, the specific rules for individual features take priority over the Agreement's general provisions with respect to those features.

1.3. Acceptance of the Agreement is deemed to occur upon any of the following actions by the User: checking the consent box during registration; creating an account; making the first deposit; actual use of the Platform's features. Acceptance means full and unconditional acceptance of all terms of the Agreement and the Platform Documents.

1.4. If you do not agree with any of the terms, you must stop using the Platform and refrain from making deposits.

1.5. The Company may amend the Agreement unilaterally. Users are notified of changes affecting deposits, withdrawals, verification, fees, or the procedure for entering into Deals no less than 14 calendar days in advance, by e-mail and/or via the Platform interface. Other changes take effect upon publication. Continued use of the Platform after changes take effect constitutes agreement with the new version. A User who disagrees with the changes may, before they take effect, close their account under Section 17 and withdraw their remaining funds.

1.6. Deals entered into before changes take effect are governed by the version of the Agreement in force at the time they were entered into, unless the new version expressly improves the User's position.

2.1. Platform (Service) — the Company's software and hardware complex, including the web interface, personal account, API, and mobile versions, through which the functions described in the Agreement are provided to the User.

2.2. User — a legally capable individual who has reached the age of 18 and has accepted the Agreement.

2.3. Account — a unique record in the Platform's system that identifies the User and provides access to the Service's features.

2.4. Balance — a record of the Company's monetary obligations to the User, reflecting the amount of deposits made and the results of Deals, less withdrawals and fees. The Balance is not a bank account, deposit, or electronic money within the meaning of banking legislation.

2.5. Deposit — the User's deposit of funds to top up the Balance.

2.6. Withdrawal — the transfer of funds from the Balance to the User's verified payment method.

2.7. Deal — a transaction carried out by the User on the Platform using Balance funds, the parameters of which (subject, amount, pricing model, term, and target metrics) are recorded in the Platform interface before the User confirms it.

2.8. Company Content — all materials placed by the Company on the Platform: source code, design, interfaces, databases, text, graphics, logos, trademarks, audio and video materials, and documentation.

2.9. User Content — any materials and data uploaded or created by the User on the Platform (text, images, creatives, settings, comments).

2.10. KYC (Know Your Customer) — procedures for identifying and verifying the User.

2.11. Business Day — any calendar day other than Saturday, Sunday, and official non-working public holidays of the Republic of Serbia; time is calculated in CET/CEST.

3.1. Only a legally capable individual who has reached the age of 18 (or a higher age of majority established by the law of the User's country of residence) may be a User.

3.2. The User represents and warrants that:

  • they are acting on their own behalf and in their own interest, and are not a nominee account holder acting for the benefit of third parties;
  • the funds deposited on the Platform were obtained lawfully and are not connected to any criminal activity;
  • use of the Service is not prohibited by the laws of their country of citizenship and/or residence, and they have independently verified this before registering;
  • they are not a resident of a Restricted Jurisdiction. The Service is aimed at users in EU/EEA member states and CIS countries, and is also available to users in other jurisdictions where its use is not prohibited. Restricted Jurisdictions include: the United States and its territories, North Korea, Iran, Syria, Cuba, and certain territories subject to comprehensive UN, EU, or OFAC sanctions (including Crimea and the Donetsk, Luhansk, Zaporizhzhia, and Kherson regions); this list may be expanded to meet payment provider requirements;
  • they are not included in the sanctions lists of the UN, EU, OFAC, the United Kingdom, or the Republic of Serbia, and are not acting for the benefit of any person included in such lists;
  • they are not a politically exposed person (PEP) or, if they are, they will disclose this to the Company during verification;
  • all information provided to the Company is accurate, complete, and up to date.

3.3. The representations in clause 3.2 are deemed repeated with each deposit, Deal, and withdrawal request. Any inaccuracy in these representations constitutes a material breach of the Agreement.

3.4. Each User may hold only one account. Creating repeat, duplicate, or related accounts, including in the name of relatives or third parties, is prohibited and constitutes grounds for blocking all related accounts.

3.5. The Company complies with applicable sanctions regimes. The range of available payment methods, currencies, and limits may vary depending on the User's country; certain transactions may be unavailable where their processing is restricted by sanctions legislation or payment system rules. Such a restriction is not deemed a breach of the Agreement by the Company and does not give rise to its liability.

4.1. To use the Platform, the User creates an account by providing a valid e-mail address and any other requested information.

4.2. The User must keep their account credentials (login, password, API keys, two-factor authentication codes) confidential. All actions performed using the User's credentials are deemed to have been performed by the User, unless proven otherwise.

4.3. If the User loses control of their credentials or suspects unauthorized access, they must immediately notify support. Until such notice is received, the Company is not liable for transactions performed under the User's account.

4.4. The Company recommends enabling two-factor authentication and may make it mandatory for certain operations (withdrawing funds, changing payment details, changing e-mail).

4.5. The Company may set technical requirements for passwords, sessions, and access devices, and may forcibly terminate sessions when it detects anomalous activity.

4.6. Account statuses. An account may be in one of the following statuses:

  • "Active" — the User has access to all Platform features within their verification tier;
  • "Restricted" — access to certain features (typically withdrawals and entering into new Deals) is suspended pending completion of verification or submission of requested documents; deposits and the performance of previously entered Deals continue unless the nature of the review requires otherwise;
  • "Suspended" — access to transactions is blocked on grounds provided for in the Agreement (Sections 3, 8, 9, 12) or by order of a competent authority; view-only access to the personal account is retained;
  • "Inactive" — a status assigned under clause 17.4;
  • "Closed" — the Agreement has been terminated, transactions are unavailable; data is retained for the periods established in Section 13.

4.7. The current account status and the grounds for its change are displayed in the personal account. When an account is moved to "Restricted" or "Suspended" status, the User is notified within 2 business days, stating the reason (to the extent permitted by law) and the list of actions required to restore "Active" status.

4.8. A change in account status does not terminate the Company's obligations to record and safeguard Balance funds, and does not deprive the User of the rights provided for in clauses 5.6, 8.5, 8.6, and Section 17.

5.1. The Company carries out User identification procedures in accordance with applicable anti-money laundering and counter-terrorist financing (AML/CFT) requirements, including the Law on the Prevention of Money Laundering and Financing of Terrorism of the Republic of Serbia.

5.2. Verification is mandatory in the following cases:

  • before the first withdrawal of funds;
  • when cumulative transaction volume thresholds established by applicable AML legislation and the Company's internal policies are reached;
  • when there are indications of suspicious activity;
  • when PEP status is identified or matches with sanctions lists are found (enhanced due diligence, EDD);
  • at the request of a payment provider or as required by law.

5.3. To complete verification, the User provides:

  • an identity document (passport, ID card, driver's license);
  • proof of residential address (a utility bill, a bank statement no older than 3 months) — upon request;
  • proof of ownership of the payment method (a photo of the card with the middle digits covered, a wallet screenshot) — upon request;
  • for enhanced due diligence — confirmation of the source of funds and/or source of wealth (Source of Funds / Source of Wealth);
  • a selfie with the document or completion of video identification — upon request;
  • other documents and information requested by the Company's support service as part of its review procedures.

5.4. The standard document review period is up to 3 (three) business days from the time a complete set of documents is submitted. If additional documents are requested, the period is recalculated from the time they are received. The User is notified of the verification result by e-mail and/or in the personal account.

5.5. The Company performs ongoing monitoring of transactions and may request re-verification if the User's risk profile changes, their documents expire, or the nature of their transactions changes materially.

5.6. The Company may refuse verification and service if the documents are inaccurate, illegible, or forged, or if the User does not meet the requirements of Section 3. If verification is refused, the remaining funds are returned to the User's original payment method after the legality of their origin has been confirmed, except where withholding the funds is expressly required by law or by order of a competent authority.

5.7. The User must keep their verification data current and notify the Company of any changes (change of document, address, payment details, acquisition of PEP status).

6.1. The Balance is topped up using the methods indicated in the Platform interface. The list of available methods depends on the User's jurisdiction and may change without prior notice.

6.2. Deposit amount limits, if any, are displayed in the Platform interface before the transaction is confirmed and may depend on the payment method, jurisdiction, and the User's verification tier.

6.3. Deposits must be made only from payment instruments belonging to the User. Funding from third-party cards, accounts, or wallets is prohibited; such funds may be returned to the sender less the actual fees charged by payment systems, and the account may be blocked pending clarification of the circumstances.

6.4. Funds are credited to the Balance after the payment is confirmed by the payment provider. Approximate crediting times: bank cards — up to 15 minutes; bank transfer — 1–3 business days; cryptocurrency — after the required number of network confirmations, shown in the interface during the deposit. These timeframes are approximate and depend on payment infrastructure.

6.5. The Company does not charge its own fee for deposits, unless otherwise indicated in the interface. Fees charged by payment systems, banks, and blockchain networks are borne by the User.

6.6. The Balance is recorded in the currency indicated in the Platform interface. For a deposit in another currency, conversion is performed at the payment provider's exchange rate at the time of the transaction; the applicable rate is displayed before the payment is confirmed. Exchange rate differences arising between the time a payment is initiated and the time it is executed are borne by the User.

6.7. A deposit is not a bank deposit, does not give rise to any interest obligation on the part of the Company, and is not covered by bank deposit insurance schemes. User funds are accounted for separately from the Company's own funds in segregated accounts.

7.1. Formation of a Deal. A Deal is deemed entered into from the moment the User confirms its parameters in the Platform interface (by clicking the confirmation button in the dialog showing the final terms). Before confirmation, the User is shown all material Deal parameters: subject, amount or rate, pricing model, term, applicable fees, and restrictions.

7.2. Electronic form. The parties acknowledge that Deals entered into through the Platform interface using the User's credentials are made in proper electronic form, are equivalent to transactions made in simple written form, and may not be challenged solely on the grounds that they were made electronically.

7.3. Reservation of funds. When a Deal is entered into, the corresponding amount is locked on the Balance and is unavailable for withdrawal or other Deals until the Deal is completed or cancelled. If the performance of the Deal involves the gradual spending of funds, charges are made as the Deal is performed, in accordance with the pricing model fixed at the time it was entered into.

7.4. Records and statistics. The Platform's accounting system data is the primary source of information on Deal performance. The User may dispute the recorded data through the claims procedure (Section 20) by presenting their own evidence; the Company reviews discrepancies and corrects the records if they are confirmed. Data from third parties (the User's trackers, analytics systems) has evidentiary but not priority value.

7.5. Modification and cancellation. The ability to modify or terminate a Deal early, and the consequences of doing so (refund of the unused remainder, deductions), are determined by the terms of the specific Deal, as displayed before it is confirmed. The unused remainder of a completed or cancelled Deal is unlocked and returned to the Balance within 1 (one) business day.

7.6. Cancellation for violations. The Company may cancel a Deal and its results if it was entered into or performed in breach of the Agreement, including through the use of technical errors, bots, artificial traffic, false data, or third-party payment instruments. Upon cancellation, legitimately deposited funds are returned to the Balance less the Company's documented expenses; any result obtained as a result of the violation is not subject to return or payout.

7.7. Obvious errors. If, due to a technical malfunction, the interface displays clearly erroneous terms (a price, rate, or parameter differing by an order of magnitude or more from market values or values usual for the Platform), the Company may cancel Deals entered into on such terms, refunding the User the funds actually charged, having notified them within 5 business days of discovering the error.

7.8. No guarantee of results. The Company ensures the technical performance of a Deal in accordance with its parameters, but does not guarantee that the User will achieve any commercial goals or metrics, unless expressly provided otherwise by the specific Deal.

7.9. Taxes. The User is solely responsible for determining their tax obligations and for calculating and paying any taxes and levies arising in connection with Deals and transactions on the Platform (including personal income tax), in accordance with the law of their country of tax residence. The Company does not provide tax advice and is not the User's tax agent, except where such an obligation is expressly imposed on it by applicable law; in such cases, the Company may withhold the relevant amounts upon payment, having notified the User.

7.10. Tax reporting and information exchange. Upon the User's request, the Company will provide a statement of transactions on their account for the requested period for tax accounting purposes. The User is aware that the Company may be required to disclose information about User transactions to competent tax authorities under applicable automatic information exchange and digital platform reporting regimes (including the DAC7 directive for EU Users), as well as pursuant to lawful requests from tax authorities. The User undertakes to provide, at the Company's request, information on their tax residence and taxpayer identification number (TIN) where its collection is required by applicable law; failure to provide such information may be grounds for restricting the account until it is received.

8.1. Withdrawals are made at the User's request from the personal account to a verified payment method.

8.2. Withdrawal conditions:

  • withdrawals are available only to Users who have completed verification (Section 5);
  • a withdrawal is made using the same method used for the deposit, where technically possible; where this is not possible, it is made to a bank account or another verified method in the User's name;
  • withdrawal limits, if any, are displayed in the Platform interface before the request is confirmed and may depend on the payment method and the User's verification tier;
  • funds locked under active Deals (clause 7.3) are not available for withdrawal until they are unlocked.

8.3. Timeframes: a withdrawal request is processed by the Company within 24 hours of submission (on business days, CET/CEST). After approval, the crediting time is determined by the payment system: cards — 1–5 business days, bank transfer — 1–3 business days, cryptocurrency — up to 24 hours.

8.4. The amount of the Company's withdrawal fee, if any, is displayed in the Platform interface before the request is confirmed. Fees charged by payment systems and networks are borne by the User.

8.5. The Company may suspend the processing of a withdrawal request only on the following grounds:

  • mandatory verification has not been completed, or additional documents have been requested as part of an AML review;
  • there are reasonable indications of fraud, use of third-party payment instruments, or a breach of Section 3;
  • a review under clause 7.6 is underway in respect of Deals whose result is included in the amount being withdrawn;
  • this is required by an order of a competent government authority or payment provider.

The User is notified of the suspension and its reasons (to the extent permitted by law) within 2 business days. The suspension may not last longer than the duration of the relevant review; upon its completion, the funds are paid out or the User is sent a reasoned refusal.

8.6. The Company may not refuse to withdraw funds lawfully belonging to the User for reasons not specified in this Agreement.

8.7. Withdrawal currency and details. Withdrawals are made in the Balance currency; for a withdrawal in another currency, conversion is performed at the payment provider's exchange rate, displayed before the request is confirmed. The User is responsible for the accuracy of the details provided; fees and losses caused by a payment being returned due to incorrect details are borne by the User.

8.8. One active request. Only one User withdrawal request may be processed at a time. Before the request is passed to the payment provider, the User may cancel it in the personal account; the cancelled amount is returned to the Balance immediately.

8.9. Protective delay upon data changes. To protect against unauthorized access, a withdrawal to new payment details may be suspended for up to 48 hours from the time of the change, following a password change, disabling of two-factor authentication, or a change of payment details. The delay is lifted early if the change is confirmed by the User via an additional channel.

8.10. Owner match. The name of the owner of the payment method to which a withdrawal is requested must match the name of the verified User. Withdrawals to third-party payment methods are not made. On the first withdrawal to a new payment method, the Company may request confirmation that it belongs to the User (clause 5.3).

8.11. Refund of unused deposits. Deposit funds not used in Deals are returned to the original payment method by way of a refund, where technically possible; this rule is applied for AML purposes and does not limit the User's right to receive these funds.

8.12. Large amounts. If the amount of a request exceeds the threshold established by the Platform's rates, the payout may be made in installments — equal tranches with an interval of no more than 7 calendar days between them, of which the User is notified when submitting the request. Splitting into tranches is not grounds for withholding any part of the amount.

8.13. Unresolved disputes. If there is an unresolved chargeback dispute or an investigation under Section 9 in respect of the account, the withdrawal of the disputed amounts is suspended until the dispute is resolved; amounts not affected by the dispute are withdrawn in the ordinary manner.

8.14. Account compromise. Upon receipt of a notice under clause 4.3 or the identification of signs of unauthorized access, withdrawals are blocked until the User regains control of the account and confirms their identity.

9.1. Funds credited in error are subject to return. The User must report an erroneous credit; the Company may debit such funds from the Balance and, if insufficient, demand their return, including by offsetting them against future receipts.

9.2. A User initiating an unjustified chargeback for a service actually provided is deemed a material breach of the Agreement. The Company may block the account pending resolution of the dispute, contest the chargeback by providing the payment system with data on the User's transactions, and deduct from the Balance the documented costs of processing the chargeback.

9.3. Refunds for Deals that have been made and performed are given only in the cases provided for in Section 7 or by mandatory provisions of applicable consumer protection law.

10.1. The amounts of the Company's fees are published in the Platform interface and/or in a separate rates document that forms part of the Platform Documents.

10.2. Users are notified of fee increases and the introduction of new fees no less than 14 calendar days in advance. Deals entered into before the changes take effect are subject to the previous rates.

10.3. The Company may charge a maintenance fee for inactive accounts under clause 17.4.

11.1. The Company's rights. All exclusive rights to the Platform and the Company Content, including source code, architecture, databases (including as a database maker's related right), design, interfaces, trademarks, logos, corporate identity, text, graphic, audio, and video materials, and documentation, belong to the Company or are used by it under licenses from the rightsholders. These rights are protected by the copyright and related rights legislation of the Republic of Serbia, international treaties (the Berne Convention, the TRIPS Agreement, WIPO treaties), and the applicable national law of Users' countries.

11.2. License to the User. For the term of the Agreement, the Company grants the User a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to use the Platform solely for its intended functional purpose. The license does not include any rights to the Company Content beyond its display in the Platform interface.

11.3. Prohibitions. Without the Company's prior written consent, the User may not:

  • copy, reproduce, distribute, publish, translate, or modify the Company Content, or create derivative works based on it;
  • decompile, disassemble, or reverse-engineer the Platform's code, except where expressly permitted by mandatory provisions of applicable law;
  • extract and reuse substantial parts of the Platform's databases, or use automated data collection tools (parsing, scraping);
  • remove, obscure, or alter copyright notices, trademarks, and other indications of the rightsholder;
  • use the Company's trademarks, logos, and corporate identity, including in domain names, advertising, and materials that create the impression of a connection with the Company;
  • register, in their own name or in the name of third parties, rights to objects confusingly similar to the Company's intellectual property.

11.4. User Content. Exclusive rights to User Content are retained by the User or its rightsholders. By uploading User Content, the User grants the Company a non-exclusive, royalty-free, worldwide license to store, reproduce, technically process (convert, resize), and display it to the extent necessary to operate the Platform, perform Deals, ensure security, and comply with the law, for the period the content remains on the Platform and a reasonable period of backup retention thereafter.

11.5. Warranties regarding User Content. The User represents that they hold all rights necessary to upload and use the User Content, and that such content does not infringe the rights of third parties (copyright, related rights, trademark rights, image rights, personal data) or the requirements of the law. The User will settle, at their own expense, any third-party claims related to the User Content.

11.6. Rights infringement complaints. A rightsholder who believes that content placed on the Platform infringes their rights may submit a reasoned complaint through the support channels indicated in the Platform interface, specifying: the protected work and confirmation of their rights to it; the exact location of the disputed content; and the complainant's contact details. The Company reviews the complaint within 10 business days and, if it is well-founded, restricts access to the disputed content, notifying the User who posted it. Repeated violations are grounds for terminating service to the User.

11.7. Feedback. By sending the Company suggestions, ideas, and comments on improving the Platform, the User agrees that the Company may use them without restriction and without paying compensation, and that such materials are not considered the User's confidential information.

11.8. Third-party trademarks. Third-party trademarks, names, and logos mentioned on the Platform belong to their respective rightsholders and are used solely for informational purposes; such mention does not imply affiliation with or endorsement by the rightsholders.

11.9. A breach of this Section constitutes a material breach of the Agreement and may result in civil, administrative, and criminal liability under applicable law. The User's obligations under this Section survive termination of the Agreement.

12.1. The User may not:

  • use the Platform to legalize (launder) proceeds, finance terrorism, evade sanctions, or engage in other unlawful activity;
  • use bots, scripts, emulators, or other automation tools without the Company's written permission;
  • generate artificial, incentivized, or fraudulent traffic, or otherwise distort the results of Deals;
  • exploit technical errors and vulnerabilities in the Platform; the User must report any vulnerabilities discovered to the Company and must not disclose them to third parties until they are fixed;
  • use anonymization tools (VPN, proxies, TOR) to bypass territorial restrictions or misrepresent their location;
  • transfer their account to third parties, or sell, give away, or otherwise dispose of access to it;
  • interfere with the Platform's operation, carry out DoS/DDoS attacks, scan its infrastructure, or intercept the traffic of other Users;
  • post malicious code, spam, or materials that violate the law or the rights of third parties;
  • impersonate a Company representative or otherwise mislead third parties about their connection with the Company.

12.2. If violations are identified, the Company may: suspend or restrict access to individual features; cancel the results of transactions obtained as a result of the violation (clause 7.6); block the account; terminate the Agreement under Section 17. The remaining funds, once their legitimacy has been confirmed, are returned to the User.

12.3. The Company may report identified signs of offenses to competent authorities and payment providers to the extent required by law.

13.1. Personal data, including verification documents, is processed in accordance with the Privacy Policy and the Law on Personal Data Protection of the Republic of Serbia (ZZPL).

13.2. For Users from the EU/EEA, Regulation (EU) 2016/679 (GDPR) additionally applies: the User has the rights to access, rectification, erasure, restriction of processing, data portability, and objection to processing, as well as the right to lodge a complaint with a supervisory authority. The procedure for exercising these rights and contact details for inquiries are set out in the Privacy Policy.

13.3. Users' personal data is stored and processed on infrastructure located within the EU/EEA. For Users from the Russian Federation, processing takes into account the applicable requirements of Federal Law No. 152-FZ "On Personal Data"; a User from the Russian Federation, by providing their data, confirms their consent to its cross-border transfer and processing on the said infrastructure.

13.4. Verification documents are retained for 5 (five) years after the account is closed, or for a longer period if required by applicable AML legislation, after which they are destroyed.

13.5. Personal data may be transferred to payment providers, KYC providers, and other processors, including outside the User's country, using the cross-border transfer mechanisms provided for by law.

14.1. The Platform is provided on an "as is" and "as available" basis. To the fullest extent permitted by applicable law, the Company disclaims any implied warranties, including warranties of fitness for a particular purpose, merchantability, and non-infringement of third-party rights.

14.2. The Company does not guarantee: uninterrupted, error-free, and failure-proof operation of the Platform; the Platform's compatibility with any of the User's software or hardware; or that the User will achieve any commercial results.

14.3. Information published on the Platform (articles, reviews, statistics, educational materials) is for informational purposes only and does not constitute professional, legal, tax, financial, or investment advice.

14.4. The Company may carry out scheduled technical work, of which Users are notified in advance where possible via the Platform interface. Access to certain features may be restricted during such work; the processing times for requests falling within the work period are extended for its duration.

14.5. The provisions of this Section do not affect the warranties expressly provided by the Agreement (including Sections 7 and 8) or the rights of consumers provided for by mandatory provisions of applicable law.

15.1. The Company is not liable for: delays and failures caused by the operation of banks, payment systems, blockchain networks, communications, or hosting providers; losses arising from the User providing inaccurate data or details; losses from unauthorized account access that occurred before notice was given under clause 4.3; or the actions and content of third parties, including external resources linked to from the Platform.

15.2. To the fullest extent permitted by applicable law, the Company is not liable for indirect losses, lost profits, or loss of business reputation or data.

15.3. The Company's aggregate liability to the User on any grounds is limited to the amount of the remaining balance on their Balance at the time the grounds for liability arose.

15.4. The limitations in clauses 15.2–15.3 do not apply to: liability for the Company's intent or gross negligence; harm to life or health; or other cases where a limitation of liability is not permitted by mandatory provisions of applicable law. Nothing in the Agreement limits the rights of a consumer User provided by the mandatory provisions of the law of their country of residence.

15.5. Indemnification of the Company. The User undertakes to indemnify the Company for documented losses, payment system penalties, and reasonable legal defense costs arising from: the User's breach of the Agreement; the inaccuracy of their representations (clauses 3.2, 11.5); or third-party claims related to the User Content or the User's actions. This clause does not apply to consumer Users to the extent it conflicts with mandatory provisions of the consumer protection law of their country of residence.

16.1. The parties are released from liability for failure to perform obligations caused by force majeure circumstances: natural disasters, military actions, acts of government authorities (including sanctions imposed after the Agreement was entered into), large-scale power or communications outages, epidemics, and failures of payment and banking infrastructure that are beyond the reasonable control of the parties.

16.2. The party affected by such circumstances shall notify the other party within a reasonable time; the deadlines for performing obligations are extended for the duration of the circumstances. If the circumstances persist for more than 60 calendar days, either party may withdraw from the Agreement; in this case, the Company will take reasonable steps to return the User's remaining funds by available lawful means.

16.3. Force majeure does not release the Company from its obligation to return the User's remaining funds after the relevant circumstances cease.

17.1. The Agreement takes effect upon acceptance and remains in force indefinitely until terminated on grounds provided for by the Agreement or by law.

17.2. Termination at the User's initiative. The User may close their account at any time, having first completed any active Deals and withdrawn their remaining funds. The remaining balance is withdrawn in full, less the actual fees charged by payment systems; if it is technically impossible to withdraw an insignificant remainder, it is deemed voluntarily forfeited by the User.

17.3. Termination at the Company's initiative. The Company may: terminate the Agreement with 14 days' notice without stating reasons, giving the User the opportunity to complete their Deals and withdraw their remaining funds; or terminate the Agreement immediately in the event of a material breach of the Agreement by the User (Sections 3, 11, 12), with the remaining funds returned in the manner and subject to the exceptions provided for in clauses 5.6, 7.6, and 8.5.

17.4. Inactive accounts. An account with no transactions or logins for more than 12 consecutive months is deemed inactive. The Company notifies the User by e-mail no less than 30 days before the account is deemed inactive. A maintenance fee may be charged on an inactive account in the amount set by the Platform's rates, but not exceeding the Balance amount; charging stops once activity resumes. After the periods established by applicable unclaimed property law have elapsed, the remaining balance is handled in the manner provided for by such law.

17.5. Termination of the Agreement does not release the parties from performing obligations that arose before termination. Sections 7.9, 9, 11, 15, 20, and 21 survive termination of the Agreement.

18.1. Legally significant communications are sent: to the User — to the e-mail address on their account and/or to their personal account; to the Company — through the support channels indicated in the Platform interface, or by post to the Company's registered address.

18.2. A communication is deemed received by the User on the day it is sent to the e-mail address they provided, or posted in their personal account. The User bears the risk of not receiving communications due to an outdated e-mail address.

18.3. The parties acknowledge the legal validity of documents and communications exchanged electronically through the Platform and the indicated channels, and of the Platform's logs as evidence of transactions performed.

18.4. Transaction statements. The transaction history for an account is available to the User in their personal account. At the User's request, the Company will generate a statement of transactions for the specified period, in machine-readable and/or printed format, within 5 business days of the request.

18.5. Death or incapacity of the User. In the event of the User's death, the remaining Balance funds form part of their estate and are paid to their heirs upon presentation to the Company of documents confirming their right to inherit in accordance with applicable law (a certificate of inheritance, a court decision, or an equivalent document), after a review similar to the verification under Section 5. Upon receipt of confirmed information of the User's death, active Deals are completed or terminated, with the unused remainder returned to the Balance. A similar procedure applies, in respect of their legal representative, if the User is declared incapacitated.

19.1. The User may not assign rights or transfer obligations under the Agreement without the Company's written consent.

19.2. The Company may assign its rights and obligations under the Agreement to an affiliate or to an acquirer of its business, with notice to Users; in doing so, the scope of Users' rights may not be reduced, and the warranties under Sections 6–8 are retained in full.

20.1. The Agreement is governed by the law of the Republic of Serbia, without regard to its conflict-of-laws rules.

20.2. The choice of governing law does not deprive a consumer User of the protection afforded to them by mandatory provisions of the law of their country of habitual residence. In particular:

  • for consumers from the EU/EEA, the rights provided for by the mandatory provisions of the law of their country of residence are retained under Article 6 of the Rome I Regulation, including rights under Directive 2011/83/EU on consumer rights;
  • for consumers from the Russian Federation, the rights provided for by the Russian Federation Law "On Protection of Consumer Rights" and Article 1212 of the Russian Civil Code are retained, including the right to bring a claim at their place of residence.

20.3. A pre-litigation claims procedure is mandatory: claims are sent through the support channels indicated in the Platform interface, or by post to the Company's registered address, and are reviewed within 14 calendar days, with a reasoned response provided.

20.4. If no agreement is reached, the dispute is referred to the competent court of Novi Sad, Serbia, except where mandatory provisions of the law of the consumer User's country of residence establish a different jurisdiction (including clause 20.2).

20.5. Users from the EU may use the European Commission's online dispute resolution platform: https://ec.europa.eu/consumers/odr.

20.6. The Agreement is published in English and Russian; in the event of discrepancies, the English version prevails. The Company may publish translations into other languages for informational purposes.

21.1. Severability. If any provision of the Agreement is found to be invalid or unenforceable, this does not render the remaining provisions invalid. The invalid provision is replaced with a valid one that most closely matches its legal and economic effect.

21.2. Entire agreement. The Agreement, together with the Platform Documents, constitutes the entire agreement between the parties on its subject matter and supersedes all prior negotiations and correspondence, except for individual written agreements expressly entered into by the parties.

21.3. No waiver. A party's failure to exercise any right under the Agreement does not constitute a waiver of that right and does not prevent its exercise in the future.

21.4. No partnership. The Agreement does not create any partnership, agency, employment, or joint venture relationship between the parties.

21.5. Interpretation. Section headings are provided for convenience and do not affect interpretation. Words in the singular include the plural and vice versa, unless the context requires otherwise.

21.6. In all matters not governed by the Agreement, the parties are guided by applicable law.

The Choice Marketing Agency d.o.o. Novi Sad. Janka Čmelika 35a, 21000 Novi Sad, Republika Srbija. MB: 21856886 | PIB: 113382199. Contact details for support and legal inquiries are provided in the Platform interface.

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