Legal

MSB Registration

As part of our commitment to being proactive towards regulatory compliance, we have registered DINNGO as a money services business (MSB) with the U.S. Financial Crimes Enforcement Network (FinCEN), the country’s anti-money-laundering regulator. As a registered MSB, we will be in an even stronger position to prevent fraud and money laundering and to protect DINNGO users with a robust Anti-Money Laundering (AML) compliance program. Our registration number is 31000137555788. You can find the registration from the link here.

Cookie Policy

Last updated: March 15, 2019

1. SCOPE

This Privacy Policy describes how DINNGO Pte Ltd ("DINNGO") collects, uses, stores, shares, and protects your information whenever you use DINNGO, dinngo.co platform, a DINNGO mobile app, any DINNGO API or third-party applications relying on such an API, or any other DINNGO services (collectively, the "Services"). By using the Services, you consent to the data practices prescribed in this statement.

This Privacy Policy applies to any DINNGO Services, as defined below, regardless of how you access or use them, including through mobile devices. If you use the Services, you consent to the collection, use, storage, and sharing of your information pursuant to this Privacy Policy.

We may periodically post changes to this Privacy Policy on this page, and it is your responsibility to review this Privacy Policy from time to time to ensure you have reviewed the most recent version thereof. When required by law, we will notify you of any changes to this Privacy Policy.

2. DEFINITIONS

2.1.

As used herein, the following terms are defined as follows:

2.1.1.

DINNGO: DINNGO Pte Ltd., with its registered address at 100 Tras Street #16-01, Singapore 079027.

2.1.2.

Service(s): Any services made available through DINNGO-branded websites, applications or tools operated by DINNGO.

2.1.3.

We/Us/Our: DINNGO Pte Ltd.

2.1.4.

Personal Information/Personal Data/your data: Any information relating to an identified or identifiable natural person, such as name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of that natural person.

3. HOW DINNGO COLLECTS INFORMATION ABOUT YOU

When you use the Services, we collect information sent to us through your computer, mobile phone, or other access devices. This information may include your IP address and device information, including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website.

DINNGO does not direct its websites, mobile app, API, or any of the Services to children. DINNGO does not intentionally collect information from children. If we become aware that we have inadvertently received personal information from a user under the age of 21 (or any lower age pursuant to applicable law), we will delete such information from our records.

If you create an account or use the Services, we, or our affiliates or vendors acting on our behalf, may collect the following types of information:

Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number and/or resident address.

Account information: email address and/or password.

Formal Identification Information: ID number, passport number, driver's license details, national identity card details, photograph identification cards, your selfie along with the above mentioned ID documents, and/or visa information.

Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, source of fund, image of bank statement or similar information, withdraw address, and/or tax identification.

Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.

Employment Information: Office location, job title, and/or description of role.

Geo-location Information: real-time location based information from your device at any time while you download or use our services. We may use this information to optimize your experience.

Online Identifiers: Login information, operating system/platform, browser fingerprint, time zone setting, OS, browser name and version, and/or personal IP addresses.

Usage Data: Survey responses, information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and/or similar technologies. By using our services, you agree to our use of these methods as set forth in our .

If you seek permission to raise the buy and sell limits associated with your DINNGO account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal information. We may also obtain information about you from third parties such as credit bureaus and identity verification services.

When you use the Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect information about your computer, mobile device, or other access devices for fraud prevention purposes, to monitor for possible breach of your DINNGO account, and to identify any malicious software or other activity that may harm DINNGO or its users. You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook, Google, Twitter and any other Third Party). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization thereof. By associating an account managed by a third party with your DINNGO account and authorizing DINNGO to have access to this information, you agree that DINNGO may collect, store, and use this information in accordance with this Privacy Policy.

Finally, we may collect additional information that may be disclosed to our customer success team.

4. OUR COOKIE POLICY

When you use the Services, DINNGO, its affiliates, or companies we work with, may place small data files called cookies or pixel tags on your computer or other devices. We have demonstrated our cookie policy in a separate document at .

5. HOW DINNGO PROTECTS AND STORES PERSONAL INFORMATION

Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. This Privacy Policy does not apply to personal information that has been anonymized so that it does not and cannot be used to identify a specific user. DINNGO takes reasonable precautions, as described herein, to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

We store and process your personal and transactional information, including certain payment information, where DINNGO facilities or our service providers are located, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable laws. We employ safeguards such as firewalls and data encryption, physical access controls to our buildings and files, and restricted access to personal information only for those employees who require it to fulfill their job responsibilities.

We store your personal information securely throughout the life of your DINNGO account. DINNGO will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.

6. HOW DINNGO USES THE PERSONAL INFORMATION WE COLLECT

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:

provide the Services and requested customer support;

process transactions and send notices about your transactions;

resolve disputes, collect fees, and troubleshoot problems;

prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;

customize, measure, and improve DINNGO Services and the content and layout of our website and applications;

deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and

verify your identity by comparing your personal information against third-party databases.

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your consent. From time to time we may request your consent to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features of the Services may not be available to you.

We will never sell or rent your personal information to third parties.

Any communications we send to you will either be related to your account or will be related to DINNGO services or products. In the event DINNGO sends any communication to you which is not related specifically to your account, DINNGO will provide you with an "unsubscribe" mechanism through which you may opt out of receiving other similar messages in the future.

7. HOW PERSONAL INFORMATION IS SHARED

If you use your DINNGO account to transfer digital currency in connection with the purchase or sale of goods or services, we or you may also provide the seller with your shipping address, name, and/or email to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have given prior consent. If an attempt to transfer digital currency to your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful transfer. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.

In connection with a digital currency transfer between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a DINNGO customer, that digital currency transfers are enabled, and/or to notify you that you have received digital currency. If you request that we validate your status as a DINNGO customer with a third party, we will do so. You may also choose to send digital currency to or request digital currency from an email address. In such cases, your username will be displayed in an email message notifying the user of the designated email address of your action. Please note that merchants you interact with may have their own privacy policies, and DINNGO is not responsible for their operations, including, but not limited to, their information practices.

If you authorize one or more third-party applications to access your DINNGO account, then the information you have provided to DINNGO may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions made during your use of the Services.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

Due to the inherent transparency of blockchains, balance and transaction history of any public digital asset may be publicly accessible. This includes, but not limited to, your public sending address, the public address of the receiver, the amount sent or received, and any other data you have chosen to include in a given transaction. Transactions and addresses may reveal information about your identity and information. Information stored on a blockchain may be public, immutable, and difficult or even impossible to be removed or deleted. Because blockchains are decentralized or third-party networks which are not controlled or operated by us or our affiliates, we are not able to erase, modify, or alter personal information from such networks.

8. HOW DINNGO SHARES PERSONAL INFORMATION WITH OTHER PARTIES

We may share your personal information with the following parties for the following reasons.

8.1. Third-party identity verification services

This allows DINNGO to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.

8.2. Various service providers

These service providers are those under contract to help with parts of our business operations, such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.

8.3. Partner Financial Institutions

These institutions are those with a bank account and routing numbers associated with your DINNGO account.

8.4. Prospective M&A Partners

Our business plans may entail discussions with companies or other entities that we plan to merge with or be acquired by, or companies intending to acquire certain portions of our business. Should such a merger or acquisition occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policy.

8.5. Law enforcement, government officials, or other third parties

We may be required to disclose personal information if and when compelled to do so by a subpoena, court order, or similar legal procedure.

8.6. Miscellaneous

We may also make disclosures of personal information if we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use.

Before DINNGO shares your information with any third party, DINNGO will, to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement requiring that the third party to provide at least the same level of privacy protection as required hereunder.

If you establish a DINNGO account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a DINNGO website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.

In general, we will notify you of material changes to this policy by updating the last updated date at the top of this page, and we will provide you with explicit notice of material changes as required by law. We recommend that you visit this page frequently to check for changes.

9. SPECIFIC CONSENT BY USERS IN SINGAPORE

If you are located in, or a resident of, Singapore, you specifically and voluntarily consent to the transfer of your personal information to our related entity and service providers in USA and/or the UK, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.

The USA and/or the UK may not have protections in place for personal information as extensive as those within Singapore. However, we require our service providers to treat your personal information in strict confidence and use appropriate security measures to protect it. We also require them to uphold all of our other obligations under this Privacy Policy.

You may revoke your consent to this section at any time by emailing dpo@dinngo.co with the subject line "Revoke Singapore data consent".

10. RIGHT TO ERASURE OF PERSONAL INFORMATION

You are entitled to the right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.

Should you wish to obtain the erasure of your personal information, please email dpo@dinngo.co with the subject line "Erasure of Personal Information".

11. RIGHT TO ERASURE OF PERSONAL INFORMATION

You may opt out of any future contacts from us at any time. You can do so at any time by contacting us at dpo@dinngo.co.

12. RIGHT TO ERASURE OF PERSONAL INFORMATION

If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page, by emailing to dpo@dinngo.co.

13. EEA USERS & DATA

If you are a resident of the EEA, DINNGO is the data controller with respect to your personal data. As data controller, we determine the means and purposes of processing data in relation to cryptocurrency transactions.

13.1. OUR LAWFUL BASIS FOR PROCESSING PERSONAL DATA

Under EEA Data Protection Law, we are required to described our lawful basis for processing your personal data. We will only use your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal data. In every case, the legal ground will be one of the following:

CONTRACT

It is necessary to process your personal data in order to fulfill the contract we have with you, such as to provide you with access to DINNGO websites and to enable you to use the Services.

LEGITIMATE INTERESTS

We process certain of your personal data on the basis of our legitimate interests where it is necessary in pursuit of our business interests. For example, we will rely on our legitimate interest to carry out marketing analysis to determine what services may be relevant to the interests of our users.

LEGAL AND REGULATORY OBLIGATIONS

In some cases, we obtain, collect and process your personal data to comply with a legal obligation, such as to respond to a court order or a regulator.

CONSENT

We process your personal data on the basis where you have provided your consent for specific purpose, such as receiving marketing emails from us.

13.2. DIRECT MARKETING

We deliver marketing communications only by electronic means (email or SMS). Where required by law, we will ask you to explicitly opt in to receive marketing from us. If we send you a marketing communication it will include instructions on how to opt out of receiving these communications in the future. Honoring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising. Where we send marketing emails, we provide unsubscribe options for your use within our emails. To update your email marketing preferences, please visit the applicable email preference center, a link to which will normally be included in emails you receive from us.

13.3. INDIVIDUAL RIGHTS

Under applicable data protection laws, EEA residents have the rights set out below, which can be exercised by contacting us at dpo@dinngo.co. Please note that these rights are not absolute and are subject to certain exemptions under applicable data protection law.

13.3.1. Right to withdraw consent.

You have the right to withdraw any consent you have previously given us to the processing of your personal data. If you withdraw your consent, this will not affect the lawfulness of DINNGO's processing of your personal data prior to the withdrawal of your consent

13.3.2. Right to access

You have the right to request for details of your personal data and a copy of that personal data. The provision of this information is subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others.

13.3.3. Right to rectification

You have the right to have any inaccurate personal data about you corrected or removed.

13.3.4. Right to erasure ('right to be forgotten')

In below circumstances, you have the right to have your personal data erased:

Your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.

Your personal data was collected in relation to processing that you previously consented, but later withdraw such consent.

Your personal data was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

If we have made your personal data public and are obliged to erase the personal data, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other parties that are processing your personal data that you have requested the erasure of any links to, or copy or replication of your personal data. The above is subject to limitations by relevant data protection laws.

13.3.5. Right to data portability

In case the processing is based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal data in a structured, commonly used and machine-readable format and you may request us to transmit your personal data directly to another controller where this is technically feasible.

13.3.6. Right to restriction of processing

You have the right to restrict how your personal data is used in certain circumstances including if you contest the accuracy of your personal data that we processed or that our use of your personal data is unlawful. Where applicable, you also have the right to object to us processing your personal data for certain purposes.

13.3.7. Right to object to processing

Where we reply on consent, contract or legitimate interests to process your data, you may object, at any time, to the processing of your personal data. We will refrain from processing your personal data unless we can demonstrate an overriding legitimate grounds to continue the processing.

13.3.8. Right related to automated individual decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal effects concerning you or similarly significantly affects you. You can object to your personal data being used in this way.

13.3.9. Right to lodge a complaint

In the event that you are not content with how we manage your personal data, we encourage you to contact us first at dpo@dinngo.co so that we can try to resolve the issue or dispute informally. You also have the right to lodge a complaint with the data protection supervisory authority located in the EU jurisdiction where you reside. In the UK, the supervisory authority is the UK Information Commissioner's Office (ICO).

13.4. PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED

We will process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by European legislator or any applicable laws to which the controller is subject to.

13.5. CONTACT US

If you have any questions about how we use your personal data or if you have any concern about how your personal data is used, please email our Data Protection Officer at dpo@dinngo.co.

Last updated: March 11, 2019

This Cookie Policy explains how cookies and similar technologies (collectively, "Cookie(s)") are used when you use our websites, apps, APIs or Services, what these technologies are and why they are used, as well as your right to control their use.

DINNGP Pte Ltd ("DINNGO", "we", "our" or "us") uses Cookies on dinngo.co (and related sites), DINNGO-branded applications ("apps"), DINNGO API or third-party applications relying on such an API, or any other DINNGO services (collectively, the "Services"). By using our websites, apps, APIs or Services, you consent to the placement and use of Cookies on your device. This Cookie Policy forms part of the .

1. WHAT ARE COOKIES

Cookies are text files containing small amounts of information that are downloaded to your computer, mobile or tablet device when you visit a website or application. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. When you return to websites, or visit websites that use the same Cookies, they recognise these Cookies and therefore your browsing device.

2. HOW DO WE USE COOKIES

When you use our websites, apps, APIs or Services, we may place Cookies on your computer or other devices. We do not use Cookies to store any personal information that could be read or understood by others. When you quit your browser, some Cookies are stored in your computer's memory, while some expire or disappear. Cookies are used primarily for administrative purposes to improve your experience with our websites.

"Session Cookies" expire and no longer have any effect when you log out of your account or close your browser. "Persistent Cookies" remain on your browser until you erase them or they expire. We use both session and persistent Cookies when you access our websites, apps, APIs or Services. Please note that NOT all cookies may be used in all jurisdictions or websites. Below are the types of Cookies that we use.

STRICTLY NECESSARY COOKIES

What are they? These Cookies are essential to enable you to move around our website and use its features, such as accessing secure areas of the website.

PERFORMANCE COOKIES

What are they? These Cookies collect information about how you use our website, such as which webpage you go to most often, and if you receive error messages from the page. They help us make sure that our website and app are working properly and fix any errors. All information these Cookies collect is anonymous and is only used to improve how our website and app work.

FUNCTIONALITY COOKIES

What are they? These Cookies allow us to remember choices you make (such as your user name, language or the region you are in) and provide more enhanced and personal features. The information these Cookies collect cannot track your browsing activity on other websites. They don't gather any information about you that could be used for advertising or remembering where you've been on the Internet outside our site. Without these cookies, we are not able to remember choices you've previously made or personalise your browsing experience.

TARGETING COOKIES OR ADVERTISING COOKIES

What are they? These Cookies gather information about your browsing habits. We may use third parties to serve advertisements and to do so, these parties may place or recognize targeting Cookies on your browser (including through the use of pixel tags) to gather information concerning your use of our site and Services and, based on that information, provide you with ads that are more relevant to you and your interests.

3. WHY DO WE USE COOKIES

We encode our Cookies so that only we can interpret the information stored in them. We use Cookies to:

Improve Our Security

By "authenticating" you as DINNGO customer when you sign-in to our site to ensure our site security. By detecting irregular or suspicious account activities to ensure that your account security has not been compromised. We also use Local Shared Objects, commonly referred to as "Flash Cookies," to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud, and to support our sites and services.

Ensure Our Compliance With Bank Secrecy Act and Anti-money Laundering Obligations

By collecting information about your computer or other access devices to mitigate risk, help prevent fraud, and improve trust and safety.

Better Customize Our Services and Contents

By keeping track of your specified preferences such as language, time zone and timeouts after periods of inactivity.

By remembering your identity so that you do not have to repeatedly login as you move between pages or services.

By conducting research and analytics from the statistical information we collect, including the frequency of your use of our sites and Services, the pages visited and the length of each visit.

Measure Promotional Effectiveness

When you visit websites of third parties with whom we have marketing relationships, you may be displayed advertisements. These parties may gather information concerning your use of other websites and provide us with anonymous information about you (such as demographic information or the names of sites where you have been shown ads) to help us measure the effectiveness of our advertising efforts.

4. HOW TO DISABLE COOKIES

You are free to decline our Cookies if your browser or browser add-on permits, but doing so may interfere with your use of the Services. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling Cookies.

You may encounter DINNGO Cookies on websites that we do not control. For example, if you view a web page created by a third party or use an application developed by a third party, there may be a Cookie placed by the web page or application. Likewise, these third parties may place Cookies that are not subject to our control and the DINNGO Privacy Policy does not cover their use.

If you would prefer not to accept Cookies, most browsers will allow you to:

change your browser settings to notify you when you receive a Cookie, which lets you choose whether or not to accept it;

disable existing Cookies; or

set your browser to automatically reject Cookies.

Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all Cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.

5. HOW CAN YOU CONTACT US

If you would like to contact us in respect of any element of this Cookie Policy, please email to support@dinngo.co.

Last updated: March 5, 2019

You agree that by registering for an account on our Site or otherwise accessing our Services, you are agreeing to the terms and conditions (the "Terms") of use set forth below. If you do not agree to these Terms, do not register for an Account or otherwise access our Services.

Please note that your use of the Services is also subject to our Privacy Policy. The Company reserves the right to update the Terms and Privacy Policy at any time without prior notice to you.

1. DEFINITIONS

Account(s): One or more accounts created by a User on the Platform for the purpose of accessing the Services.

App: Refers to the DINNGO application, a computer program developed by the Company and/or its affiliates that is designed to run on a mobile device such as a smartphone or tablet computer. All or part of the Services may be available for access via the App.

DGO Tokens: Functional utility tokens available via the Platform. DGO tokens are not for speculative investment and do not represent security interests in or of the Company (or any company). DGO tokens do not represent any rights with respect to the Company (or any company), including, but not limited to, any right of participation in the Company's profit distributions or decision-making process. DGO tokens are sold as a functional good and all proceeds received by Company from such sales may be spent in the Company's discretion. No promises or guarantees of future performance or value are or will be made with respect to any sale of DGO tokens, including, but not limited to: any promises of intrinsic or exchange value; any promise of continuing payments; and any guarantee that DGO tokens will hold any particular value.

Company: DINNGO Pte Ltd., with its registered address at: 100 Tras Street #16-01, Singapore 079027. (All terms "we," "us," and "our" herein refer to the Company).

Platform: The platform published by the Company and/or its affiliates, which permits Users to exchange Tokens with other Users, including DGO tokens. The Platform permits Users to exchange Tokens for legal currency.

Services: Any services made available through the Site, affiliated websites, the App, and the Platform.

Site: DINNGO's website, having its URL at: https://dinngo.co/.

Tokens: Any cryptographic tokens available or exchanged over the Platform, the App, or the Services (including DGO Tokens).

Users: Any user of the Services (all references to "you" or "your" herein refer to each User).

2. ELIGIBILITY, RESTRICTED AREA, AND PERMITTED USE

Eligibility. By accessing the Services, you represent and warrant that you:

are at least 21 years of age, or at least the minimum age required by applicable law such that the Services may be lawfully provided to you without parental consent;

accede to these Terms (and are legally capable of doing so);

are not prohibited by applicable law from accessing and using the Services;

have not previously been suspended or removed from the Site;

own all Tokens used by you in connection with the Platform (or such Tokens are those with which you are able to carry out authorized transaction);

have all necessary consents and authorizations to carry out all transactions initiated from your Account;

have provided true, accurate, and complete information in creating your Account(s); and

have reviewed the risk disclosure statement contained in these Terms, and consent to the bearing of all risks described therein.

Restricted Area. The Company monitors the IP addresses of all inbound traffic to determine the originating location of any user, and accordingly will attempt to prevent access to the Services by users where regulatory requirements restrict the Services. The Company may restrict any geographic location, residency, or IP address at its sole discretion, at any time, without notice. By accessing the Services, you represent and warrant that

your residency or geographic location is not in the United States of New York, Hawaii or Washington, or

North Korea, Palestinian Authority, Western Balkans, Belarus, Burundi, Cuba, Democratic Republic of the Congo, Iran, Iraq, Lebanon, Libya, Nicaragua, Somalia, Sudan, Syria, Crimea region of Ukraine, Venezuela, Yemen, Zimbabwe, or

other jurisdictions where using and/or accessing the Services is prohibited or

in any manner restricted by applicable laws or regulations, or

will become so prohibited or

restricted at any time after these Terms become effective.

You agree that if you use the Service from one of the aforementioned jurisdictions, you will lose access to your account and your funds will be frozen until the direct withdrawal function activates and you can interact with the Company contract directly to withdraw your funds.

Permitted Use. You agree that you will comply with all applicable laws and regulations when accessing the Services. You agree not to use the Services for any unlawful activity, including, but not limited to, illegal gambling, money laundering, fraud, blackmail, extortion, ransoming data, terrorism financing, or other violent activities. You further agree that you will not hack, decompile, reverse engineer, disassemble, attempt to derive the source code of, decrypt, or otherwise compromise the integrity and security of the Platform, Site, and App. You further agree that you will not falsify any account registration details provided to us, falsify or materially omit any information or provide misleading information requested by us in the course of, directly or indirectly relating to, or arising from your activities on the Platform or the use of any services, including at registration.

3. ACCOUNT

You must create an Account to access and use the Services, and you must provide a valid email address to create your Account. You must provide complete, accurate, and current information when creating your Account and promptly update such information should there be any changes. You may request the Company to delete or remove any information you provide; however, you acknowledge and agree that the Company may, in its sole discretion, refuse your request or restore any previously deleted or removed information. You must be responsible for all activities that occur under your Account and accept all risks of unauthorized access.

You agree to maintain the security and confidentiality of your login credentials, and restrict unauthorized access—whether via the Site, App, or otherwise—to your Account. You must promptly notify the Company if you discover or otherwise suspect any unauthorized access to or use of your Account.

You agree that the Company reserves the right to limit the number of Accounts that any User or such User's affiliates may create.

You agree that the Company reserves the right and sole discretion to terminate your Account for any reason at any time.

4. RISK DISCLOSURE STATEMENT

(a) Technology

Sophistication. Tokens are often described in exceedingly technical language; a comprehensive understanding of applied cryptography and computer science is required in order to appreciate inherent risks. By using the Services, you represent and warrant that you have sufficient knowledge, market sophistication, experience, and/or professional advice sufficient to undertake a prudent evaluation of the merits and risks of all transactions conducted by you pursuant to the Services. You agree to bear sole responsibility for the aforementioned evaluation.

No guarantee. Neither the Company nor its affiliates own or controls any of the underlying software through which blockchain networks are formed and with which any Tokens are created and transacted. Neither the Company nor its affiliates make any guarantee of functionality, security, or availability of such software and networks.

Forks. The blockchain technology underlying Tokens is subject to change at any time, including changes in operating rules (commonly referred to as "forks"), and blockchain networks may go offline as a result of bugs, hard forks, or a number of other unforeseeable reasons. Such changes may materially and adversely affect the value or function of the Tokens in your Account. You agree that you are fully responsible for monitoring such changes and agree to bear all risks arising therefrom or relating thereto.

Cyber-attacks. In the event of a cyber attack on the Platform, App, Site, or any other component of the Services, your Account and the Tokens therein may be adversely affected. Neither the Company nor its affiliates make any guarantee that it may foresee, prevent, mitigate, or take corrective action in the event of such attack.

Suspension/Discontinuation of Support/Withdrawal. In the event of a fork or a cyber-attack regarding a particular Token traded on the Platform, you agree that the Company may temporarily suspend the Services (with or without advance notice to you) for the Token in question and that the Company may, in its sole discretion, decide not to support (or cease supporting) the forked Token entirely. The Company will provide you with an opportunity to withdraw such Tokens if feasible. Resolutions concerning deposits, withdrawals, and User balances for an attacked Token will be determined on a case-by-case basis by the Company in its sole discretion. The Company makes no representations or warranties with respect to the security of the Platform, and shall not be liable for any lost value or stolen property, regardless of whether the Company was negligent in providing the proper security.

Disclaimer. The Company hereby disclaims all responsibility for any loss or damage arising from or relating to your use of any Services (including, but not limited to, risk of losses due to trading or due to factors beyond its control regarding the viability of any specific blockchain network) or your failure to understand the risks involved in Token use generally or your use of our Services. The Company further disclaims all responsibility for any loss or damages arising from or relating to any cyber-attacks (including without limitation the theft of your personal information), unprecedented surges in trading volume, any disruption or shut down of the Services, or other technical difficulties with respect to the Services.

(b) Prevailing rate

While the Company uses commercially reasonable methods to provide exchange rate information to you through our Services, such information may differ from prevailing exchange rates made available by third parties. Moreover, the actual market rate at the time of your trade may be different from the indicated prevailing rate depending on the velocity of trading in the Tokens involved in your trade. The Company hereby disclaims all responsibility for any loss or damage arising from or relating to price fluctuations, latencies, or differences in actual versus indicated prevailing rates.

(c) Transaction failure; Terms of Online Deposit

A transaction on the Platform may fail for several reasons, including but not limited to change in seller prices, insufficient margin, or unanticipated technical difficulties. The Company makes no representations or warranties that any transaction will be executed properly. The Company hereby disclaims all losses and damages arising from or relating to any transaction failure. You agree and consent that the Company shall not be responsible for notifying you of a transaction failure.

The Company may refuse to execute a trade or impose trade amount limits or restrictions at any time, without prior notice, and in its sole discretion. Specifically, the Company reserves the right to refuse to process, or to cancel or reverse, any transaction or disable a User's Account where the Company suspects possible money laundering, terrorism financing, fraud, or any other unlawful conduct, or where the Company suspects the transaction violates these Terms (e.g. transactions involving the opening of an Account and subsequent closure without any actual trading). While the Company may in its discretion reverse a trade, a User may not change, withdraw, or cancel its authorization to make a transaction, except with respect to partially filled orders.

The Company may correct, reverse, or cancel any trade impacted by an error in processing your trading instructions or otherwise. Your remedy in the event of an error will be limited. You may seek to cancel your order or obtain a refund of any amounts charged to you, but such cancellations or refunds are not guaranteed.

The Company's Platform operates such that each User's orders are matched with those of other Users. Orders may be partially filled or may be filled by a number of orders, depending on the trading activity at the time an order is placed.

You acknowledge that the Company provides each Account with cryptographic token deposit capabilities in order to enable trading. You acknowledge and agree that the Company does not allow Users to use such deposit capabilities for purposes other than those required for the trading of cryptographic tokens in accordance with these Terms; such prohibited uses include using Accounts as "web wallets" or for address registration purposes. We reserve the right to halt deposit activity at our sole discretion.

(d) Modification and Discontinuation

The Company reserves the right to discontinue the Services and/or the availability of a Token previously available via the Services, modify any portion of the Services and/or smart contracts of the Platform, temporarily or permanently, with or without prior notice at anytime, to (i) maintain and/or improve upon the underlying code, or (ii) if legally obligated or compelled to do so by a court of law or other governmental body that has proper jurisdiction. The Services may be periodically unavailable during the modification or discontinuation. In the event of the Tokens discontinuation, the Company will provide you with an opportunity to withdraw such Tokens.

You acknowledge that the Company is not liable or responsible to you for any inconvenience or damage as a result of the modification or discontinuation of the Services. You also agree and understand that when Services resume, market conditions and prices may differ significantly from the market conditions and prices prior to such modification or discontinuation of Services.

(e) Illiquidity

You may find it difficult or impossible to liquidate a position. This can occur if there is insufficient liquidity in the market. Placing contingent orders, such as "stop-loss" or "stop-limit" orders, will not necessarily limit your losses to the intended amounts, because it may be impossible to execute such orders due to market conditions. Factors, including but not limited to regulatory scrutiny, market manipulation or unexplainable price volatility can all affect market liquidity for a particular Token.

(f) Default and Liquidation

You agree to maintain a sufficient number of Tokens in your Account(s) at all times to meet the Company's minimum balance requirements, as such requirements may be modified from time to time at the Company's sole discretion. If the value of the assets in your Account falls below the minimum balance requirement, or if your Account appears to be in danger of defaulting on a loan, the Company may seize and liquidate any or all of your positions and assets on any balance in your Account in order to settle your debt to other Users. If, after your positions and assets are liquidated, your Account still contains insufficient Tokens to settle your debts to other Users, you are solely responsible for any additional Tokens owed.

(g) Company Bank Account

If at any point the Company's bank accounts become frozen, you acknowledge and agree that the Company may take steps to unfreeze the account, but under no circumstances will the Company be liable for any loss that you may or may not incur as a result of the account freeze.

(h) No trading advice

If at any point the Company or its representatives or affiliates provide trading recommendations, market commentary, or any other information, you acknowledge and agree that such communications do not constitute trading advice. You further acknowledge and agree that you have the sole responsibility with respect to evaluating any transactions you conduct via your use of the Services, and that the Company has no obligation of due diligence or fiduciary duty toward any of the User's transaction decisions.

(i) Compliance by Users

You acknowledge and agree that the Company is not responsible for determining whether or which laws, rules, or regulations apply or may apply to your transactions (including, without limitation, any anti-money laundering laws, securities laws, and tax laws). You acknowledge and agree that you are solely responsible for compliance with all such laws, rules, or regulations as may be applicable to your transactions. Without limiting the foregoing, you acknowledge and agree that you are solely responsible for all tax obligations arising from your use of the Services. You further acknowledge and agree that the Company shall not be liable, whether directly or indirectly, for any of your tax obligations. These Terms alone do not create a joint venture, partnership, or principal-agent relationship between you and the Company, or any other users, and nothing in these Terms may be used to imply such a relationship. You agree to indemnify, defend and hold the Company harmless from any liability for, or assessment of, any claims or penalties with respect to such taxes, labor, or employment requirements, including any liability for, or assessment of taxes imposed on the Company by the relevant taxing authorities with respect to any fees paid to you as the result of using the Platform.

(j) Company Compliance

You acknowledge and agree that the Company's record keeping and customer verification procedures may be, without prior notice, subject to change at any time as required by applicable regulations or state of the art practices.

Applicable law, regulation, and executive orders may require the Company to, upon request by government agencies, freeze or suspend withdrawals or trading (or both), or disclose information regarding your Account(s). In the event such disclosure is compelled, you agree that the Company may disclose information regarding your Accounts. While the Company will endeavor to, where commercially reasonable, give you prior notice of such disclosure, the Company makes no guarantees that such prior notice will be made.

You acknowledge and agree that the Company does not represent or warrant, whether explicitly or implicitly, the timely or successful deposit or withdrawal of any legal currency or Tokens in your Account. You acknowledge and agree that the Company shall not be liable for any losses arising from any delay or unsuccessful deposit or withdrawal of any legal currency or Tokens in your Account.

You acknowledge and agree that the Company retains the sole discretion in deciding whether Users from any particular jurisdiction may deposit or withdraw legal currency or Tokens in the Accounts.

You acknowledge and agree that the Company may, at its sole discretion and at any time, suspend or terminate the deposit or withdrawal of legal currency or Tokens in your Account. Users of Accounts terminated in accordance with the previous sentence may apply for a refund of the balance, if any, of the legal currency or Tokens remaining in the Account within 30 days after termination of the Account; provided that, if the source of the funds are, or reasonably suspected to be, illegal, the Company shall not be obligated to refund the funds and may report such illegality to the appropriate authorities.

5. FEES

Amount of Fees.

The Company charges transaction fees for the Services as set forth in the Whitepaper, which is available at https://crowdsale-files.dinngo.co/whitepaper. The Whitepaper is subject to modification by the Company at any time at its sole discretion. Unless otherwise indicated, the version of the Whitepaper as published on https://crowdsale-files.dinngo.co/whitepaper shall be deemed to be the most current version of the Whitepaper.

There may be certain regulatory or other fees charged by third parties relating to your use of the Services. You acknowledge and agree that the Company will not be liable for any such fees charged on your deposits or transactions and that you are solely responsible for such fees.

Payment of Fees.

You authorize us, or our designated payment processor, to charge or deduct any legal currency or Tokens from your Account(s) in satisfaction of payment for any fees incurred from our provision of the Services. You authorize the Company to deduct any applicable fees from your Account(s) at the time you make a given transaction.

Collection-Related Costs.

If you fail to pay fees incurred from our provision of Services or any other amounts otherwise owed to the Company, you acknowledge and agree that you will be liable for any collection-related costs as permitted by applicable law.

6. LIMITED LICENSE

The Company grants you a limited, non-exclusive, non-transferable license to access and use the Services (whether via the App or the Site), solely for the intended functions of the Services and other approved purposes as expressly permitted by the Company. Any other use of the Services is expressly prohibited.

When using the App, you agree not to:

decompile, reverse engineer, disassemble, attempt to derive the source code of, or decrypt the App;

make any modification, adaptation, improvement, enhancement, translation, or derivative work to or from the App;

violate any applicable laws, rules, or regulations in connection with your access or use of the App;

remove, alter, or obscure any proprietary notice of the Company or of its affiliates, partners, suppliers or the licensors of the App;

use the App for any other purpose for which it is not designed or intended;

make the App available over a network, or otherwise permitting access to or use thereof by multiple mobile devices or users at the same time;

use the App to send automated queries to any website or to send any unsolicited commercial e-mail; or

make any unauthorized use of proprietary information or intellectual property of the Company or its affiliates (including, but not limited to, the "DINNGO" trademark).

The Platform and its entire contents, features and functionality (including but not limited to all information, software, text, displays, images, video and audio, and the design, selection, and arrangement thereof), are owned by the Company, its licensors, or other providers of such material and are protected by international copyright, trademark, patent, trade secret, and other intellectual property or proprietary rights laws.

These Terms permit you to use the Platform for your use only, subject to the following restrictions:

You must not reproduce, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store, or transmit any of the material on the Platform, including any of the Company's intellectual properties, except as it is created and owned by you.

No right, title or interest in or to the Platform or any content on the Platform is transferred to you, and all rights not expressly granted are reserved by the Company.

7. USER CODE OF CONDUCT

When using or accessing the Services, you agree not to:

gain, or attempt to gain, unauthorized access to the Site, Accounts of other Users, or any other component of the Service, whether through password mining or otherwise;

use or attempt to use a web crawler on the Site or any component of the Service;

cause a disproportionately large load on our infrastructure; or

upload any material to the Site that contains computer viruses, Trojan horses or worms.

8. PRIVACY POLICY

Your privacy is important to us. However, we may be compelled to share your information pursuant to applicable laws, rules, or regulations. Please refer to our for more details.

9. ANTI-MONEY LAUNDERING (AML) & KNOW YOUR CUSTOMER (KYC) POLICY

The Company enforces bank-level KYC ("know-your-customer") processes to comply with AML (anti-money-laundering) laws. The Company cross-checks User data against government watch lists. If a User or a User's transaction is flagged as suspicious, the Company will require additional proof of identification from the User, and may suspend any trades, deposits, and/or withdrawals by such User until such identification is received to the satisfaction of the Company.

The Company maintains an internal policy on User verification levels. The Company reserves the right to determine, in its sole discretion, the appropriate verification level and criteria for any User, and the right to downgrade Users without prior notice. The Company may, from time to time, implement policies restricting verification levels and criteria by nationality, country of residence, or any other factor.

You agree that if you fail to achieve a desired level of verification, you may be unable to deposit and/or withdraw any legal currency or Tokens. You agree to be solely responsible and not hold the Company or its affiliates liable for such losses.

You hereby authorize the Company to, directly or through third parties, make any inquiries we consider necessary to verify your identity and/or protect against fraud, including to query identity information contained in public reports (e.g., your name, address, past addresses, or date of birth), to query account information associated with your linked bank account (e.g., name or account balance), and to take action we reasonably deem necessary based on the results of such inquiries and reports. You further authorize any and all third parties to which such inquiries or requests may be directed to fully respond to such inquiries or requests.

10. NO TRANSFERABILITY

While the Account(s) and the Services provided to a User are non-transferrable, the Company reserves the right to transfer, assign, or sell all the rights, benefits, or obligations thereof to any person or entity and these Terms shall continue to be in force and effect for the benefit of the successors and assigns of the Company or its lenders, if any.

11. PERMANENT WITHDRAWAL OF SERVICE

The Company may (i) suspend or terminate your access to the Services and (ii) deactivate or cancel your Account if so compelled by applicable laws, rules, or regulations, or if the Company suspects you or others of using your Account in furtherance of illegal activity. In such event, you will be permitted to transfer any legal currency or Tokens associated with your Account for a period of sixty (60) days after Account deactivation or cancellation unless such transfer is otherwise prohibited by applicable law. If any transaction is in a pending state at the time your Account is canceled or suspended, such transaction may be canceled and/or refunded as appropriate.

Upon cancellation of your Account, you authorize the Company to cancel or suspend pending transactions and, after providing notice to you via the Service or App, return the Tokens associated with such transactions to the wallet address the Company has on file for you.

If the Company is unable to return your Tokens to the wallet address the Company has on file for you through commercially reasonable efforts, the Company may report and remit the Tokens to an applicable government agency pursuant to unclaimed property laws of Singapore.

12. DISCLAIMER OF WARRANTIES; EXCLUSION OF LIABILITY

THE SERVICES AND THE APP ARE PROVIDED "AS-IS" AND "AS AVAILABLE" AND COMPANY DOES NOT GUARANTEE OR PROMISE ANY SPECIFIC RESULTS FROM USE OF OR CONTINUOUS AVAILABILITY OF THE SERVICES. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY AND ITS AFFILIATES (AND THOSE THAT THE COMPANY WORKS WITH TO PROVIDE THE SERVICES) EXPRESSLY DISCLAIM ANY WARRANTIES AND CONDITIONS OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT, AND WARRANTIES IMPLIED FOR A COURSE OF PERFORMANCE OR COURSE OF DEALING.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY AND ITS AFFILIATES (AND THOSE THAT THE COMPANY WORKS WITH TO PROVIDE THE SERVICES) SHALL NOT BE LIABLE TO YOU OR ANY OTHER PERSON FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, OR ANY LOSS OF DATA, OPPORTUNITIES, REPUTATION, PROFITS OR REVENUES, RELATED TO THE SERVICES (E.G. LOSSES ARISING FROM OR RELATING TO TECHNICAL DIFFICULTIES OF THE APP, THE PLATFORM, OR THE SERVICE).

IN NO EVENT SHALL THE LIABILITY OF THE COMPANY AND ITS AFFILIATES (AND THOSE THAT THE COMPANY WORKS WITH TO PROVIDE THE SERVICES) EXCEED, IN THE AGGREGATE FOR ALL CLAIMS, AN AMOUNT EXCEEDING THE AGGREGATE FEES PAID BY YOU FOR THE SERVICES IN THE SIX (6) MONTHS IMMEDIATELY PRECEDING SUCH CLAIMS.

13. THIRD PARTY CONTENT

The Company may provide third party content on the Site and may provide links to web pages and content that are not owned or controlled by the Company ("Third Party Content"). The Company does not control, endorse, or adopt any Third Party Content and makes no representation or warranties of any kind regarding the Third Party Content, including but not limited to the accuracy or completeness thereof. You acknowledge and agree that the Company is not responsible or liable in any manner for any Third Party Content and undertakes no responsibility to update or review any Third Party Content. You acknowledge that your use of such Third Party Content is at your own risk. Your business dealings or correspondence with, or participation in promotions of, any third parties, and any terms, conditions, warranties, or representations associated with such dealings or promotions, are solely between you and such third parties. The Company is not responsible or liable for any loss or damage of any sort incurred as the result of any such dealings or promotions or as the result of the presence of such Third Party Content on the Site or otherwise via the provision of the Services.

14. INDEMNIFICATION

You agree to indemnify, defend, and hold the Company and its affiliates and each of their respective officers, directors, agents and employees harmless from any claim or demand (including any fines, fees or penalties imposed by any regulatory authority, attorney's fees and court costs) arising out of or related to (i) your breach of these Terms, (ii) your use and/or misuse of Services or Platform, or (iii) your violation of any law, rule, or regulation, or the rights of any third party.

15. APPLICABLE LAW AND DISPUTE RESOLUTIONS

These Terms of Use shall be governed by the laws of Singapore, and shall be interpreted in all respects as a Singaporean contract. Any claim or action arising from or related to these Terms of Use, including tort claims, shall be governed by and construed and enforced in accordance with the laws of Singapore.

To expedite and control the cost of disputes, you agree that any legal or equitable claim arising out of or relating to your use of the Services or these Terms, including the formation, validity, enforceability, scope, or applicability of these Terms (referred to as a "Claim") will be resolved as follows: except for claims for injunctive or equitable relief or claims regarding intellectual property rights (which may be brought in any competent court without the posting of a bond), any dispute arising under your use of the Services shall be finally settled on an individual basis through confidential, binding arbitration in accordance with the Singapore International Arbitration Centre (the "Centre"). This means that all claims other than intellectual property lawsuits, such as copyright or trademark infringement lawsuits, or claims seeking non-monetary relief will be subject to binding arbitration. The arbitration shall take place in Singapore, in the English language and the arbitral decision may be enforced in any court.

To begin an arbitration proceeding pursuant to these Terms, you must send a letter by mail requesting arbitration and describing your claim to us:

DINNGO Pte Ltd

Address: 100 Tras Street #16-01, Singapore 079027

Attn: DINNGO Support Team

16. NO CLASS ACTION

You and the Company may bring claims against the other only in your or its individual capacity, and not as a plaintiff or class member in any purported class, representative, consolidated or multi-claimant proceeding.

You and the Company each waive any right to a jury trial.

17. SEVERABILITY; WAIVER

If any provision of these Terms is deemed unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from these Terms and will not affect the validity and enforceability of any remaining provisions. Any delay or failure by the Company to enforce any of its rights shall not constitute a continuing waiver of such rights.

18. INTEGRATION

These Terms and any policies or operating rules posted by the Company constitute the entire agreement and understanding between you and the Company, and supersede any prior or contemporaneous agreements, communications and proposals, in any form, between you and the Company (including, but not limited to, any prior versions of these Terms).

19. FORCE MAJEURE

In addition to applicable disclaimers stated above, the Company's performance under these Terms shall be excused in the event of interruption and/or delay due to, or resulting from, causes beyond its reasonable control, including but not limited to acts of God, acts of any government, war or other hostility, civil disorder, fire, flood, snowstorm, earthquake, explosion, embargo, acts of terrorism, power failure, equipment failure, industrial or labor disputes or controversies, acts of any third party data provider(s) or other third-party information provider(s), third party software, or communication method interruptions.

20. NOTICE AND COMMUNICATION

All notices, requests, demands and other communications under these Terms shall be deemed to have been duly given if given as follows:

To contact the Company: Go to Support at https://support.dinngo.co/hc/en-us/requests/new and open a ticket. Please provide all relevant information, including your DINNGO Username and transaction IDs of any related deposits. Although we make no representations or provide no warranties about the speed of response, we will get back to you as soon as possible.

To contact User: The Company will send all communications to the email you have on file with the Company, or to your Account on the App or the Site. You understand and agree that if the Company sends you an electronic communication but you do not receive it because your email address on file is incorrect or out of date, or because our email is blocked by your service provider or intercepted by your spam filter, or you are otherwise unable to receive electronic communications, the Company will be deemed to have provided the communication to you regardless.

21. MODIFICATION

The Company may, in its sole discretion, amend, delete, or otherwise modify any of the terms of this Terms of Use and the Privacy Policy at any time.

22. SUSPENSION AND TERMINATION OF THE SERVICES

The Company may, in its sole discretion and for any reason, temporarily suspend, or finally terminate, the Services, with or without advance notice to you. Without limiting the foregoing, you acknowledge and agree that, in the event of an unstable or irrational market condition, the Company may, in its sole discretion, finally terminate the Services, with or without advance notice to you, by initiating a trading curb or any other appropriate measure.