HuiLink Pay · Terms of Service

Version: v2.0 (Official Release)

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

Effective: 2026-09-12

Last updated: 2026-09-12

⚠️ This is a technical compliance template, not legal advice. Must be reviewed by qualified legal counsel and localized to target jurisdictions before publication.

📚 Version Index

1. Acceptance

These Terms of Service ("Terms") form a legal agreement between you and Ecoin Digital Asset Exchange LTD ("we", "us", "the Platform") regarding the HuiLink Pay service. By registering an account, using the application, or clicking "I agree", you fully accept these Terms.

If you disagree with any provision, stop using immediately and close your account.

2. Service Definition

HuiLink Pay is an information-matching platform providing users and verified merchants:

• Information matching for peer-to-peer / OTC cross-border fiat and stablecoin exchange
• Merchant identity verification and tiering
• Order chat and payment proof custody
• Wallet balance display and transaction history
• Dispute appeal and arbitration

The Platform is NOT:

• A bank or licensed financial institution (unless we hold the corresponding license)
• A counterparty (we do not trade with you directly)
• A custodian (P2P settlements are peer-to-peer; the Platform only holds merchant collateral)
• An investment advisor
• An insurance provider

3. Eligibility

To use the service you must:

• Be **at least 18 years old** (or the age of legal majority in your jurisdiction, whichever is higher)
• Have full legal capacity to contract
• **Not** be listed on OFAC, UN, EU sanctions lists or other applicable sanctions
• **Not** be prohibited from similar financial services under local law
• Reside in a jurisdiction whose laws permit similar services
• Pass our KYC (some features may require KYB)

We reserve the right to refuse or terminate service for compliance, risk, or operational reasons, without prior notice.

4. Accounts

4.1 Account Security

• You are **fully responsible** for safeguarding your password, payment password, 2FA keys, private keys
• We are **NOT liable** for account theft/loss caused by your own negligence
• Upon detecting anomalies, immediately use in-app "Force Logout" or contact support to freeze

4.2 Account Uniqueness

• A natural person may register **only one** individual account
• Merchant accounts require KYB · no multi-entity sharing
• Buying, renting, or proxy-registering accounts is strictly prohibited

5. KYC and Compliance

• Transaction features require KYC (at least Level 1)
• Large transactions may trigger EDD (Enhanced Due Diligence)
• We reserve monitoring, reporting, freezing, and refusal rights under AML law
• You warrant that submitted materials are **truthful, accurate, and complete**
• Falsification may result in permanent ban and legal action

6. Merchants

6.1 Onboarding

Merchants must pass KYB, sign the Merchant Cooperation Supplementary Agreement, and post collateral.

6.2 Collateral

• Ad capacity = collateral × leverage (both determined by tier)
• Platform may adjust leverage based on risk
• Non-compliant merchants may forfeit collateral for: victim compensation / platform loss / penalties

6.3 Obligations

• Ad prices and commitments must be **truthful and non-deceptive**
• Release funds within **30 minutes** after user payment
• No cancellation or refusal without cause
• Comply with ad rules (no illegal assets / money laundering / sanction evasion)

7. Orders and Settlement

• Placing an order constitutes an **offer to exchange** to the merchant
• Order is formed upon merchant acceptance; both parties execute at stated price and quantity
• User payment must use the **payment method stated in the order** · no substitution or third-party payment
• Merchant releases funds against proof of payment · disputes may be raised
• The Platform **does not intervene** in the payment rails and does not guarantee counterparty performance

7.1 Fees

• Platform charges a fee based on order amount · see in-app disclosure
• Denominated in USDT or equivalent · charged at settlement
• Rate may change · with 7 days advance notice

7.2 Exchange Rate

• Official reference rate source is disclosed in the app (e.g. European Central Bank)
• Merchant ad prices are set by merchants
• Platform does not warrant any given deviation from market rates

8. Appeals and Arbitration

• Parties should first resolve via order chat
• Unresolved within 15 minutes → raise **platform appeal**
• Platform rules based on submitted evidence · rulings are **platform-final** (does not preclude your right to court action under applicable law)
• Rulings may include: release to user / refund to merchant / forfeit merchant collateral

9. Prohibited Conduct

The following are strictly prohibited (violation may result in account ban, fund freeze, law enforcement referral):

• Using another's identity or falsified materials
• Trading funds related to money laundering, drug trafficking, terrorism financing, tax evasion, fraud, gambling
• Using the Platform to circumvent international sanctions
• Illegal virtual currency exchange (per your jurisdiction's law)
• Attacking, disrupting, or bypassing Platform security
• Using bots / scripts / automated tools (without authorization)
• Uploading malware / viruses / abusive content
• Infringing others' IP / privacy / reputation
• Sharing counterparty sensitive credentials (password, private key) in chat
• Directing counterparty to off-platform transactions to evade Platform rules

10. Limitation of Liability

To the maximum extent permitted by law, the Platform is not liable for:

• Service interruption due to **force majeure** (natural disaster, war, regulatory change, etc.)
• **Third-party causes** (bank clearing delay, payment channel failure, KYC provider outage)
• **User self-error** (wrong account, password disclosure)
• **Contract performance disputes** between users and merchants (Platform only provides matching)
• **Market rate fluctuation** losses
• **Network attacks** (e.g. MITM intercepting SMS OTP) · we take reasonable protective measures
• **Indirect losses** (lost profit, opportunity cost, etc.)

Aggregate liability cap: Platform liability (if any) is capped at the total fees you paid to the Platform for the disputed transactions in the preceding 6 months.

11. Intellectual Property

• HuiLink Pay trademarks, logo, UI design, and code are owned by Ecoin Digital Asset Exchange LTD
• You may **NOT** copy, decompile, reverse-engineer, or distribute our software
• Content you upload (e.g. chat) — you retain ownership · grant Platform necessary license to provide the service (display to counterparty, archival, legal cooperation)

12. Changes and Termination

12.1 Service Changes

• Platform may modify, suspend, terminate any part of the service at any time
• Material changes with 30 days advance notice

12.2 Terms Changes

• These Terms may be updated
• Updates surfaced via in-app modal / mandatory read on next launch
• Continued use constitutes acceptance

12.3 Termination

• You may close your account anytime (must first settle all in-progress orders)
• We may terminate for violation, legal requirement, or risk reasons
• Post-termination data handling per Privacy Policy (some data subject to statutory retention)

13. Dispute Resolution

• First resolve via in-app customer support
• If unresolved, submit to arbitration at the American Arbitration Association (AAA), seat Colorado Springs, Colorado, United States, language English
• Award is final

14. Governing Law

These Terms are interpreted and applied under the laws of the laws of the State of Colorado, United States.

15. Miscellaneous

• **Severability**: invalidity of any clause does not affect others
• **Waiver**: non-enforcement of a right is not a waiver
• **Entire Agreement**: these Terms together with the Privacy Policy and User Agreement form the entire agreement
• **Contact**: support support@huilinkpay.com · legal legal@huilinkpay.com · mail 5142 N Academy Blvd Unit #4322, Colorado Springs, CO 80918, United States

_v2.0 · Official Release_