HuiLink Pay · User Agreement

Version: v2.0 (Official Release)

Drafted: 2026-07-08 · Published: 2026-09-12

Effective: 2026-09-12

⚠️ Technical compliance template · not legal advice · must be reviewed and localized by qualified legal counsel before publication.

📚 Version Index

1. Agreement Relationship

This User Agreement is the core contract between you (the "User") and Ecoin Digital Asset Exchange LTD ("the Platform", "we") regarding your use of the HuiLink Pay service.

Together with the Terms of Service and Privacy Policy, this Agreement forms the entire agreement. Registering an account constitutes full acceptance.

2. Account Rules

2.1 Registration and Identity

• Register with true identity · one natural person may hold only **one** individual account
• KYC required for transaction features
• Never use another's identity, rent an account, or register by proxy

2.2 Account Security

• You are **fully responsible** for password, payment password, and 2FA security
• Change passwords periodically · never share
• Upon anomaly, freeze via "Me → Security" or contact support immediately

2.3 Device Recognition

• Platform records regular devices and locations
• Unusual devices/locations may trigger 2FA challenges
• Ensure registration phone/email remain accessible long-term

3. Transaction Conduct

3.1 Before

• Read and understand ad price, limits, payment window, methods
• Confirm your funds source is legal
• Confirm your jurisdiction permits the transaction

3.2 During

• Strictly use the **payment method** and **amount** stated in the order
• Pay from an account **in your own name** (no proxy, no third-party pass-through)
• Upload payment proof promptly
• Communicate via order chat · do not switch to off-platform channels

3.3 After

• Confirm receipt or raise appeal within 15 minutes of merchant release
• Retain payment proofs for 3 months

4. Your Warranties

You solemnly warrant:

• ✅ You are **at least 18 years old** (or age of legal majority, whichever higher) with full contractual capacity
• ✅ You are **NOT** on OFAC / UN / EU sanctions lists
• ✅ You will **NOT** use the Platform for illegal activities (money laundering, drug trafficking, terrorism financing, tax evasion, fraud, gambling, etc.)
• ✅ You will **NOT** operate on behalf of others or allow others to operate your account
• ✅ You understand **exchange rate volatility risk** · the Platform does not guarantee rates
• ✅ You understand **counterparty risk in P2P exchange** · the Platform only matches information
• ✅ All information you submit (account, KYC, payment, chat) is **truthful, accurate, lawful**
• ✅ You comply with **all applicable laws** in China and jurisdictions involved

5. Prohibited Conduct

The following will result in immediate ban, fund freeze, and possible law enforcement referral:

• False identity / forged documents
• Trading with sanctioned regions or individuals
• Using proceeds of crime
• Money laundering, financial fraud, illegal gambling via the Platform
• Attacking, disrupting, or bypassing Platform security
• Bots, scripts, plugins (unauthorized automation)
• Directing counterparties off-platform to evade rules
• Malicious refusal to pay/receive, malicious appeals
• Disclosing counterparty passwords, private keys
• IP, privacy, reputation infringement

6. Fees

• Platform charges a **percentage of order amount** · see in-app disclosure
• Denominated in **USDT or equivalent** · charged at settlement
• Rate may change · with 7 days advance notice
• Some currency deposits/withdrawals incur channel fees (charged by third-party payment providers, unrelated to Platform)

7. Dispute Handling

• First resolve via order chat
• Unresolved in 15 minutes → raise platform appeal
• Upload evidence (payment screenshots, chat, bank statements)
• Platform arbiter rules based on evidence · **platform-final**
• You retain the right to sue in court under applicable law

8. Platform Rights

We reserve the following rights, without prior notice:

• Refuse or terminate service for compliance, risk, operational reasons
• Suspend your account for review (funds-safety preserved)
• Freeze suspicious transaction funds under AML law
• Report suspicious activity to law enforcement
• Temporarily interrupt service for maintenance
• Disclose your information as legally required

9. Your Rights

You are entitled to:

• Close your account at any time via App (settle in-progress orders first)
• Query, correct, export personal information (see Privacy Policy)
• Disable push / withdraw consent
• Complain and sue as permitted by law
• Priority notice of **material service changes**

10. Account Closure

10.1 Voluntary

• Initiate via "Me → Account Security → Close Account"
• Must settle all in-progress orders, return borrowed funds, no pending appeals
• 30-day cool-off (may reverse)
• After cool-off, account deleted · personal data handled per Privacy Policy

10.2 Involuntary

• Violation of this Agreement, legal requirement, risk reasons → we may unilaterally terminate
• You remain responsible for **pre-termination obligations** (e.g. incurred but unsettled transactions)

11. Agreement Changes

• This Agreement may be updated
• **Material changes**: 30 days advance notice via App modal / email
• **Minor changes**: effective upon publication
• Continued use = acceptance; close account if you disagree

12. Governing Law

This Agreement is interpreted and applied under the laws of the laws of the State of Colorado, United States.

13. Contact

• Customer support: support@huilinkpay.com
• Complaints: support@huilinkpay.com
• Legal: legal@huilinkpay.com
• Mail: 5142 N Academy Blvd Unit #4322, Colorado Springs, CO 80918, United States

You have read and agree to all terms of this Agreement and undertake the corresponding rights and obligations.

_v2.0 · Official Release_