Terms of Use

Last Updated: March 17, 2025

1. INTRODUCTION

These Terms of Service (hereinafter referred to as the "Terms") constitute a legally binding agreement between Purple Pixel Private Limited, a company incorporated under the Companies Act, 2013, having its registered office at HD-276 WeWork, Hebbal, Bengaluru, India, including its licensors, subsidiaries, affiliates, successors, and assigns (hereinafter referred to as "Feo", "Company", "we", "us", or "our"), and any individual or entity accessing or utilizing any websites, mobile sites, mobile applications, desktop applications, products, or services (collectively, the "Online Platforms") operated or offered by Feo.

By accessing, registering for an account, or availing any Services through the Online Platforms, the user (hereinafter referred to as "User", "you", or "your") acknowledges that they have read, understood, and agree to be bound by these Terms in their entirety. If you do not agree to these Terms, you must immediately discontinue access to and use of our Online Platforms and Services.

Feo reserves the right, at its sole and absolute discretion, to modify, amend, supplement, or replace these Terms, in whole or in part, at any point in the future, without prior notification to you. In the event of any material change to these Terms, Feo shall endeavor to notify Users through the Online Platforms to the extent practicable. The updated version of these Terms will be made available on this page along with the date of last revision. Your continued use of the Online Platforms and/or Services following the posting of any changes to these Terms shall constitute your deemed acceptance of and agreement to be bound by such changes. It is your responsibility to regularly review these Terms to stay informed of any updates.

These Terms should be read in conjunction with our Privacy Policy, Anti-Money Laundering ("AML") Policy, Know Your Customer ("KYC") Policy, and any other additional terms and conditions referenced on our Online Platforms for any specific product or service, all of which are incorporated herein by reference and form an integral part of these Terms.

By accepting these Terms, you represent and warrant that you have the legal capacity and authority to enter into a binding agreement and to comply with these Terms, and that you are at least 18 years old or the age of majority, whichever is greater, in your jurisdiction of residence.

2. DEFINITIONS

For the purposes of these Terms, unless the context otherwise requires, the following terms shall have the meanings assigned to them below:

1. "Applicable Laws" means all applicable statutes, enactments, acts of legislature, laws, ordinances, rules, bye-laws, regulations, notifications, guidelines, policies, directions, directives and orders of any governmental authority, tribunal, board, or court having jurisdiction over the parties.

   2. "Content" means any and all information, text, graphics, images, videos, logos, button icons, photographs, audio clips, digital downloads, data compilations, software, or other materials uploaded, posted, or otherwise made available by the Company or the Users, which is accessible on the Online Platforms.

   3. "Digital Assets" refer to cryptocurrencies, virtual digital assets, or as may be referred to by any other names, including but not limited to Bitcoin, Litecoin, Ethereum, Ripple, etc., as well as proprietary coins and tokens, which represent a cryptographically secured digital representation of value or contractual rights that uses distributed ledger technology as its underlying technology.

   4. "Digital Wallet" means a non custodial wallet address accessible through the Online Platforms and controlled and operated by a User for the storage, management, transfer, and receipt of their Digital Assets. Users do not have access to or control over the private keys associated with their Digital Wallets.

   5. "Fiat Currency" means any government-issued currency that is designated as legal tender in its country of issuance through government decree, regulation, or law, including but not limited to Indian Rupees (INR).

   6. "Force Majeure Event" means any event or circumstance beyond the reasonable control of Feo, including but not limited to acts of God, natural disasters, epidemics, pandemics, quarantines, civil disturbances, governmental actions, wars, terrorist attacks, riots, strikes, lockouts, labor disputes, fires, explosions, floods, earthquakes, power outages, internet or communication failures, hardware failures, software bugs or vulnerabilities, blockchain network protocol changes or failures, hacking or cyber attacks, changes in laws or regulations, or any other cause beyond the reasonable control of Feo.

   7. "Intellectual Property Rights" means all patents, copyrights, design rights, trademarks, service marks, trade secrets, know-how, database rights, and other rights in the nature of intellectual property rights (whether registered or unregistered) and all applications for the same, anywhere in the world.

   8. "KYC Policy" means the know-your-customer policy of Feo, as may be amended from time to time, which sets out the procedures and requirements for verifying the identity of Users.

   9. "Linked Bank Account" refers to any bank account owned and operated by the User and held with a Scheduled Commercial Bank in India, the details of which were provided by the User during the account activation and verification process and which has been successfully linked to the User's account on the Online Platforms.

   10. "Order" means an instruction from a User to buy or sell Digital Assets or to convert Digital Assets into Fiat Currency or vice versa, at a specified price or at market price, which is placed through the Online Platforms.

   11. "Personal Information" means any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, email address, government identification numbers, financial and payment information, and other information that alone or in combination with other information could identify a User.

   12. "Services" means all services offered by Feo through the Online Platforms as detailed under Services of these Terms, including but not limited to, facilitating the buying, selling, and trading of Digital Assets, storage of Digital Assets, and related services.

   13. "Supported Digital Assets" refers to the Digital Assets in relation to which Feo provides any Services through the Online Platforms, as may be determined by Feo in its sole discretion from time to time.

   14. "Third Party Service Provider" means any person or entity engaged by Feo to support or provide any service to Feo which are required, related to, or in connection with the Services offered by Feo through the Online Platforms, which may include but are not limited to any third-party exchange, service provider engaged for user onboarding and verification, payment aggregator, network service providers, blockchain protocols, and other similar service providers.

   15. "Transaction" means any operation initiated by a User through the Online Platforms, including but not limited to deposits, withdrawals, transfers, exchanges, trades, or any other operation involving Digital Assets or Fiat Currency.

   16. "User Account" means the account created by a User on the Online Platforms to access and use the Services.

2. SERVICES

   1. The Online Platforms offer the following products and services related to Digital Assets (collectively referred to as the "Services"):
      1. Swapping Services: Enabling Users to exchange their Digital Assets with any other Supported Digital Assets at rates determined by Feo or its Third-Party Service Providers;
      2. Deposit and Withdrawal Services: Facilitating the deposit and withdrawal of Digital Assets into and from Users' Digital Wallets;
      3. Purchase and Sale Services: Enabling Users to purchase Supported Digital Assets using Fiat Currency and sell Supported Digital Assets in exchange for Fiat Currency;
      4. Custody Services: Providing custodial storage services for Users' Digital Assets through Feo-managed wallet systems;
      5. Trading Services: Enabling Users to trade Digital Assets amongst other users of the Online Platforms through an order matching system.
      6. Feo Pay - Transfer Services: In addition to the other Services described herein, Feo offers "Feo Pay," an off-chain internal transfer system that allows for the transfer of Digital Assets between verified Feo User accounts.
   2. Feo may, at its sole discretion, engage the services of Third-Party Service Providers to effectively provide the Services to Users. By accepting these Terms, you expressly understand, acknowledge, and agree to Feo's use of such Third-Party Service Providers.
   3. You hereby expressly consent and authorize Feo to initiate and execute transactions on your behalf which are placed by you through the Online Platforms, whether by clicking or giving commands in any other form through the Online Platforms. Feo only initiates and executes transactions as per your consent and request and facilitates the execution of your request/command.
   4. In order to provide a seamless, uninterrupted, and secure environment, Feo reserves the right, at its sole discretion and without any liability whatsoever, to change, modify, upgrade, repair, suspend, and halt the Services through the Online Platforms for any reason, including but not limited to system maintenance, updates, security concerns, or compliance with legal or regulatory requirements. Feo will strive to provide Users with minimum downtime; however, Feo does not warrant or guarantee that the Online Platforms and the Services will always be available or uninterrupted. Feo shall not be liable to you or any third party for any losses, damages, costs, or expenses incurred due to any interruption, suspension, or halt in the Services.
   5. Feo may suspend, withdraw, discontinue, or change all or any part of the Online Platforms without notice. Feo also reserves the right to restrict the availability of its Services in certain countries or regions based on legal, regulatory, or business considerations.
   6. Feo may, at its sole discretion, introduce new Services or features, modify existing Services or features, or discontinue any Services or features offered through the Online Platforms, at any time and without prior notice to Users. Any new Services or features shall be subject to these Terms unless otherwise specified.

3. USER ACCOUNT

   1. Account Creation and Registration: To access and use the Services, you must create a User Account on the Online Platforms. You can create your account by registering directly with Feo by providing your email ID, phone number, and other details as required on the Online Platforms. Upon successful registration, you will receive a confirmation email or SMS containing a verification link or code, which you must use to verify your registration.
   2. Identity Verification: You will be required to activate your account by following the identity verification process outlined in Feo's KYC Policy. This process may require you to provide Personal Information, including but not limited to your full name, date of birth, residential address, and government-issued identification documents. Feo reserves the right to request additional information or documentation at any time for the purpose of identity verification and compliance with Applicable Laws.
   3. Bank Account Verification: You will also be required to share your bank account details and disclose the source of your funds as detailed in Feo's AML Policy available on the Online Platforms. For further details on the account registration, validation process, and anti-money laundering checks adopted by Feo, you are advised to read Feo's AML Policy as available on the Online Platforms.
   4. Account Security: You are solely and entirely responsible for maintaining the confidentiality of your User Account credentials, including your password and any other authentication factors. You agree not to disclose your password or any other authentication information to any third party. You agree that you will be solely responsible for any activities or actions taken through your User Account, whether authorized by you or not. You also agree to immediately notify Feo of any unauthorized access or use of your User Account by writing to us at [email protected]. Feo reserves the right to initiate any action, including legal action before a court or relevant law enforcement agencies, in case you impersonate or illegally access or attempt to access the User Account belonging to any other person.
   5. Account Validation: Activating or validating your User Account should not be construed as Feo granting you any license, allowing, permitting, encouraging, or supporting your use of the User Account or Digital Wallet for illegal, unlawful, fraudulent, unethical, or unauthorized purposes or to promote or facilitate any illegal, unlawful, fraudulent, unethical, or unauthorized activities. Feo reserves the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any Applicable Law, regulation, sanctions programs, legal process, or governmental request.
   6. Eligibility and Geographical Restrictions: The Services are only available for users who are residents of India, and you are not permitted or eligible to avail any of Feo's Services if you are in, under the control of, or a national or resident of any country other than India. Feo may implement controls to restrict access to the Services from any jurisdiction where the Services may be illegal or restricted. You represent and warrant that you are not accessing or using the Services from any such jurisdiction.
   7. Ongoing Due Diligence: Feo may require you to re-submit the user details including KYC and related documents or may require you to furnish any additional details as part of Feo's ongoing due diligence, due to any suspicious action, transaction, or behavior from your account, or under the order or direction from any government authority or court having competent jurisdiction. Your failure to comply with such requests may result in the suspension or termination of your User Account.
   8. User Responsibility for Security: You are solely responsible for keeping your electronic devices and User Account and Digital Wallet safe and secure by adopting reasonable security practices and operational safeguards. You are required to take all reasonable steps to avoid any loss, theft, misuse, or unauthorized access to your electronic device, which may result in unauthorized access to your User Account or Digital Wallet through the Online Platforms. Feo will not be liable for any loss, theft, compromise, or unauthorized access to your electronic device or your User Account, or for any funds held in your Digital Wallet or Linked Bank Account resulting from your failure to maintain adequate security measures.
   9. User Representations and Warranties: You represent and warrant:
      1. That you have attained the age of majority (18 years in most jurisdictions in India) and are competent to enter into a contract under the Indian Contract Act, 1872, or any other applicable law;
      2. That if you are registering on behalf of any entity, you are legally authorized to enter into agreements on behalf of the entity as per applicable laws, and have all necessary powers, permissions, and approvals to bind such entity to these Terms;
      3. That your use of the Services will not violate any and all laws and regulations including licensing or approval requirements, anti-money laundering, counter-terrorist financing, foreign exchange, privacy, data protection, and other laws or regulations as applicable to you in your jurisdiction;
      4. That all information provided by you to Feo during the registration process and thereafter is true, accurate, current, and complete, and you will keep your account details up to date and will immediately inform Feo in case of any change in user information;
      5. That you have not previously been suspended or removed from using the Services, and that you do not already have an existing User Account;
      6. That you are not using the Services on behalf of, or for the benefit of, any third party, and that you are not acting as an intermediary or nominee;
      7. That you are not a politically exposed person (PEP) as defined under the Prevention of Money Laundering Act, 2002, or if you are a PEP, you have disclosed this fact to Feo during the registration process.
   10. Multiple Accounts: Each User is permitted to have only one User Account. Feo reserves the right to suspend or terminate any additional accounts created by the same User.
   11. Account Updates: You agree to promptly update your User Account information in the event of any change to any information you have provided to Feo. Failure to update such information may result in the suspension or termination of your User Account.
   12. Inactive Accounts: Feo reserves the right to deactivate User Accounts that remain inactive for a continuous period of twelve (12) months or more. Prior to such deactivation, Feo shall make reasonable efforts to notify the User at the registered email address or mobile number.

4. PROHIBITED USE

   1. General Prohibition: The Users undertake that they will never use the Online Platforms for any illegal purpose or in any illegal way, and undertake to abide by the relevant laws and regulations of India, and to abide by all network protocols, rules, and procedures related to the Services.
   2. Specific Prohibitions: The Users agree and guarantee that they will not use the Online Platforms to engage in any infringement of the rights and interests of any other person or for any illegal conduct, and they shall bear any and all legal liabilities if they breach such guarantee. The above-mentioned infringements and conduct include, but are not limited to:
      1. Unauthorized Access: Accessing the Online Platforms in the name of any other person without being duly authorized by such person, or attempting to gain unauthorized access to the Online Platforms, other Users' accounts, computer systems, or networks connected to the Online Platforms through hacking, password mining, or any other means;
      2. Illegal Transactions: Engaging in any illegal transaction, such as trafficking of firearms, narcotics, forbidden drugs, pirated software, counterfeit goods, stolen items, or other prohibited items under the laws of India or any other relevant jurisdiction;
      3. Gambling: Providing gambling information or inducing in any manner any other person to engage in gambling, or using the Services for any gambling-related activities that are illegal under Applicable Laws;
      4. Financial Crimes: Engaging in suspected money laundering, terrorist financing, cash-out, pyramid selling activities, ponzi schemes, or any other fraudulent financial activities, or using the Services to facilitate any such activities;
      5. Computer Viruses: Engaging in any conduct that may result in the introduction of viruses, trojan horses, worms, logic bombs, or other material that is malicious or technologically harmful to the Online Platforms, or that may damage the Online Platforms or data therein;
      6. Network Disruption: Using the Online Platforms to engage in any activity that may adversely affect the normal operation of the Internet or mobile computer network, including but not limited to overloading, flooding, mail bombing, or crashing the Online Platforms;
      7. Market Manipulation: Maliciously interfering with the normal proceeding of Digital Asset transactions and disrupting the order of Digital Asset trading, including but not limited to wash trading, spoofing, layering, churning, front-running, or engaging in any other form of market manipulation;
      8. Technical Interference: Using any technical means or other means to interfere with the normal operation of or interfering with the use of the Online Platforms by any other User, including but not limited to through the use of automated scripts, bots, or other software programs;
      9. Defamation: Maliciously defaming the goodwill of the Platform by fabrication or exaggeration of facts, or making false or misleading statements about Feo, its Services, or the Online Platforms;
      10. Misrepresentation: Impersonating any person or entity, or falsely stating or otherwise misrepresenting your affiliation with a person or entity, or creating a false identity on the Online Platforms;
      11. Harassment: Harassing, intimidating, or threatening any other User, employee, or representative of Feo, or engaging in any other conduct that could reasonably be considered offensive, abusive, defamatory, or inappropriate;
      12. Intellectual Property Infringement: Violating or infringing upon the Intellectual Property Rights of Feo or any third party;
      13. Data Mining: Using data mining, robots, scraping, or similar data gathering and extraction methods on the Online Platforms;
      14. Violation of Terms: Violating any provision of these Terms or any other agreement with Feo;
      15. Other Prohibited Activities: Any other conduct that is justifiably deemed by Feo as inappropriate or contrary to the purpose and spirit of the Online Platforms and Services.
   3. Content Deletion: Feo reserves the right to delete all types of information of a User that does not conform to legal policies or is untrue or inappropriate on the basis of the independent judgment by Feo, without notifying the User and without assuming any responsibility. If the User fails to comply with the above provisions, Feo has the right to take measures such as suspending or closing the User's account on the basis of Feo's own independent judgment and without assuming any responsibility.
   4. Indemnification for Claims: The User agrees that if any third party initiates or launches any claim or demand for compensation (including attorney fees) on the ground that the User breaches these Terms or violates any document that is incorporated into these Terms by reference and becomes a part of these Terms, or that the User's use of the Online Platforms violates any law or infringes on any right of the third party, the User will indemnify and hold harmless Feo and affiliated parties thereof, cooperation partners, directors, and employees thereof against such claim or demand.
   5. Authenticity of Information: The User undertakes that the information uploaded or released by the User through the Online Platforms is authentic and valid, and any and all the information the User submits to Feo is authentic, valid, complete, detailed, and accurate. If Feo or any other user of the Online Platforms suffers any loss due to the User's breach of the above undertakings, the User will assume corresponding liabilities.
   6. Monitoring and Reporting: Feo reserves the right, but not the obligation, to monitor the use of the Online Platforms and Services for compliance with these Terms and Applicable Laws. Feo may report any suspicious or illegal activities to appropriate law enforcement or regulatory authorities, as required by Applicable Laws, and may cooperate with such authorities in investigations of suspected criminal violations.
   7. Consequences of Prohibited Use: Any violation of the prohibitions contained in this section may result in, without limitation, the termination or suspension of your User Account, forfeiture of Digital Assets in your Digital Wallet, and/or legal action. Feo shall have the right to report any suspected illegal, fraudulent, or unauthorized activity to appropriate regulatory or law enforcement authorities.

5. DIGITAL WALLET

   1. Creation and Purpose: On activation of your User Account, Feo will create and provide a Digital Wallet for you wherein your Digital Assets may be stored. You may use this Digital Wallet to hold your Digital Assets or to use your Digital Assets to avail any of the Services offered by Feo.
   2. Transactions: Any funds you unstake, swap, sell, or withdraw will be credited into/debited from this wallet, and any transfer of your funds to any external wallet will require verification regarding your ownership and control over that external wallet. You agree and represent that you will transfer Digital Assets to only external wallets that belong to you and are under your legal control.
   3. Supported Digital Assets: The Services offered through the Online Platforms are available only in connection with the Supported Digital Assets, and the list of Supported Digital Assets may change from time to time at Feo's sole discretion. Feo assumes no responsibility or liability in connection with any attempt to use your Digital Wallet to store, send, request, or receive any unsupported Digital Asset.
   4. Discontinuation of Support: Feo, in its sole discretion, may terminate its support for any particular Digital Asset by providing you a 10 days' notice. Feo may provide you a shorter period of notice if so directed or required under any law, regulation, or under the order of any court, law enforcement agency, or authority. Feo will withdraw any remaining Digital Assets which Feo stops supporting after the period of notice and will deposit the market value of the digital currency denominated in the Supported Digital Asset of Feo's choice.
   5. Wallet Security: You are solely responsible for maintaining the security of your Digital Wallet and for all transactions and other activities undertaken with your Digital Wallet. Feo shall not be responsible for any unauthorized access to your Digital Wallet or any resulting loss or damage, except to the extent directly caused by Feo's gross negligence or willful misconduct.
   6. Transaction Finality: All transactions involving your Digital Wallet are final and irreversible once initiated on the respective blockchain network, and Feo shall have no ability or obligation to reverse, cancel, or modify any transaction once it has been initiated.
   7. Wallet Addresses: You must ensure the accuracy of any wallet addresses provided for withdrawals or transfers of Digital Assets. Feo shall not be responsible for any loss of Digital Assets resulting from errors in wallet addresses provided by you.
   8. Minimum and Maximum Balances: Feo may impose minimum and/or maximum balance requirements for Digital Wallets at its sole discretion. Such requirements will be communicated to Users through the Online Platforms.
   9. Dormant Wallets: Digital Wallets that remain inactive for a continuous period of eighteen (18) months or more may be subject to additional security measures or fees, as communicated by Feo through the Online Platforms.
   10. Compliance Checks: Feo reserves the right to conduct compliance checks on transactions involving your Digital Wallet and may delay or refuse to process any transaction that Feo reasonably believes may violate Applicable Laws or these Terms.

6. DISCLOSURE OF RISK

   1. Market Risk: You understand, acknowledge, and agree that dealing or trading in Digital Assets are subject to market conditions and involve a high degree of risk. Price or value of Digital Assets is subject to constant and frequent fluctuations, and you may accordingly suffer a partial or complete loss of funds owned by you in your account. You understand and acknowledge that Feo bears no responsibility or liability to you or any other person whatsoever for any losses or gains incurred in connection with your use of the Services.
   2. No Financial Advice: You also understand, acknowledge, and agree that any services availed through the Online Platforms cannot be construed as financial, investment, or legal advice, and Feo or any of its directors, employees, or agents do not give financial, legal, or investment advice or recommendations regarding dealing, trading, or investment in Digital Assets. Feo is not a financial institution, bank, credit union, trust, hedge fund, broker, or investment or financial advisor, and is not subject to the laws, regulations, directives, or requirements applicable to such entities or persons. Availability of any service involving any particular Supported Digital Asset on the Online Platforms cannot be construed as any form of endorsement, recommendation, or support for that Digital Asset from Feo.
   3. Regulatory Risk: You also acknowledge and agree that Feo's ability to provide any service may be detrimentally impacted by regulatory action or changes in regulations applicable to Digital Assets. You are solely and exclusively responsible for all trading decisions made by you while using the Services. Feo is merely providing a technology platform, and you are solely and entirely responsible for the legal, regulatory, and tax compliance of all transactions carried out by you using the Services, subject to the terms of this agreement.
   4. Transaction Irreversibility: You understand and agree that transactions once initiated on any blockchain network cannot be reversed, undone, rectified, or modified. You are required to verify all details relating to a transaction before initiating the transaction as Feo will simply process the transactions as per your instructions. Feo will have no liability or responsibility in case you initiate any transaction with incomplete or incorrect details. Feo may also refuse to process or cancel any pending transaction if required by law, regulation, or any court or other authority, or if Feo has a reasonable suspicion of any money laundering, terrorist financing, fraud, or any other financial crime being involved in the transaction.
   5. Digital Asset Risks: Digital Assets carry significant risks, including but not limited to:
      1. Volatility Risk: Digital Assets are highly volatile and can experience rapid and significant price fluctuations over short periods of time. This volatility may result in significant losses to Users;
      2. Liquidity Risk: Digital Assets may have limited liquidity, meaning that it may be difficult to sell or exchange Digital Assets at desired prices or times;
      3. Technological Risk: Digital Assets rely on blockchain and related technologies that are still evolving. Technical issues, bugs, security vulnerabilities, or other technological problems could adversely affect the value, functionality, or availability of Digital Assets;
      4. Fork Risk: Blockchain protocols may undergo "forks" or changes to their operating rules, which could result in multiple versions of a Digital Asset, affect its value, or impact your ability to access or transfer your Digital Assets;
      5. Market Manipulation Risk: Digital Asset markets may be susceptible to manipulation by large holders of a particular Digital Asset or coordinated groups;
      6. Regulatory Risk: The regulatory framework governing Digital Assets is evolving and subject to change. Future regulatory changes could impact the legality, use, or value of Digital Assets;
      7. Cybersecurity Risk: Digital Assets may be vulnerable to theft, hacking, or other security breaches despite security measures;
      8. Operational Risk: Operational failures at Feo or its Third-Party Service Providers could impact the availability or security of the Services;
      9. Counterparty Risk: The insolvency, breach, or failure of Feo or any Third-Party Service Provider could result in the loss of your Digital Assets.
   6. No Guarantee of Profits: Feo does not guarantee any profits or returns from trading or holding Digital Assets. Past performance is not indicative of future results.
   7. Tax Implications: Please refer to Section 20.
   8. Understanding Before Investment: You should carefully consider your financial situation, risk tolerance, and investment objectives before trading or investing in Digital Assets. You should only trade or invest in Digital Assets if you have sufficient financial resources to bear the risk of loss.
   9. Independent Research: Before making any investment decision, you should conduct your own research and due diligence on the Digital Assets you wish to trade or invest in, including understanding the technological features, economics, and risks associated with the specific Digital Assets.

7. CUSTODY SERVICES

   1. Nature of Custody: You acknowledge and agree that you do not have access to or control over the private keys associated with your Digital Wallets. All Digital Assets are held in custody by Feo on behalf of Users, and Feo shall exercise control over the underlying private keys in accordance with these Terms. Feo only holds the Digital Assets held in your Digital Wallet for your benefit on a custodial basis. As a custodian, Feo acts on your instructions and executes your instructions relating to any transaction with respect to such Digital Assets. The title to any Digital Asset held in your Digital Wallet shall at all times remain with you, and only you shall bear the risk or benefits for fluctuations in the price or value of such Digital Assets. Feo will not treat any Digital Assets held in your Digital Wallet as Feo's own and will not sell, transfer, loan, or otherwise alienate Digital Assets held in your Digital Wallet without your instruction or unless compelled by an order of the relevant Government, authorities, or competent court.
   2. Pooled Storage: You understand and agree that the Digital Assets in your Digital Wallet may be pooled with other users' Digital Assets at specific blockchain addresses controlled by Feo (for e.g., cold storage addresses). Feo will, however, always maintain at minimum a 1:1 ratio between user deposits and funds controlled by Feo's wallets. User funds are logically separated from Exchange funds and will never be used for operations, expenses, or any other costs of running the exchange. Feo will also never invest your funds without your prior express consent.
   3. Technical Limitations: You agree that your ability to withdraw or send assets from your Digital Wallet may be interrupted or suspended due to outages, downtime, network congestion, network maintenance, and other technical, network, and market conditions beyond Feo's control. You are required to employ standard security practices, remember your account and password details, and avoid unauthorized access of any third party to your account. Feo is under no obligation to issue any replacement Digital Assets in the event that any Digital Asset, password, or private key is lost, stolen, malfunctioning, destroyed, or otherwise inaccessible.
   4. Cold Storage: Feo will maintain a significant portion of Users' Digital Assets in offline, cold storage wallets to enhance security against potential cyber threats. The specific percentage of Digital Assets held in cold storage may vary by asset type and other factors, as determined by Feo in its sole discretion.
   5. Security Measures: Feo will implement and maintain industry-standard security measures to protect Users' Digital Assets held in custody, including but not limited to:
      1. Multi-signature technology requiring multiple authorized signatures for transactions;
      2. Encryption of sensitive data;
      3. Regular security audits by independent third parties;
      4. Physical security for cold storage systems;
      5. Access controls limiting employee access to custody systems.
   6. Insurance: Feo may, at its sole discretion, maintain insurance coverage for certain Digital Assets held in custody. However, such insurance may not cover all Digital Assets or all types of losses, and Feo makes no guarantee regarding the availability or adequacy of such insurance.
   7. Custody Fees: Please refer to Section 20.
   8. Return of Assets: Upon termination of your User Account or these Terms, Feo will return your Digital Assets to an external wallet address specified by you, subject to:
      1. Satisfaction of any outstanding obligations you may have to Feo;
      2. Completion of any required identity verification or other compliance procedures;
      3. Deduction of any applicable fees or charges;
      4. Technical feasibility of the transfer.
   9. No Interest: Feo will not pay interest or other compensation on Digital Assets held in custody. Any interest or other benefits accrued from the custody of Digital Assets shall belong to Feo, unless expressly agreed otherwise in writing.
   10. Audit and Verification: Feo may periodically conduct internal audits of its custody operations and may, at its discretion, publish proof-of-reserves or similar verification of its custody holdings. Users acknowledge that such audits or verifications may be limited by technical constraints, security considerations, or other factors.

8. MATCHING OF ORDERS

   1. Trading Mechanism: You can purchase or sell Supported Digital Assets by using your Digital Wallet and/or Linked Bank Account. You can undertake the sell or purchase activity by using Feo's order matching engine which will execute trades by matching them in the order book maintained by Feo. The functionalities available under this service enable users to trade the Digital Assets amongst each other by posting their buy and/or sell orders on the exchange, which Feo then further facilitates by providing the matching service that will pair their respective buy and sell orders. The order(s) placed by Users shall remain active for a time period as may be prescribed by Feo from time to time, post which Feo shall have the right to invalidate the said order(s).
   2. Order Types: Feo may support multiple order types, including but not limited to:
      1. Market Orders: Orders to buy or sell a specified quantity of a Supported Digital Asset at the best available market price;
      2. Limit Orders: Orders to buy or sell a specified quantity of a Supported Digital Asset at a specified price or better;
      3. Stop Orders: Orders that become active only when the market price reaches a specified trigger price;
      4. Other specialized order types as may be introduced by Feo from time to time.
   3. Order Execution: Orders will be executed in accordance with Feo's order matching algorithm, which generally prioritizes orders based on price and time of receipt. However, Feo makes no guarantee regarding the timing of order execution or the specific price at which an order will be executed. Market orders may be executed at prices significantly different from the market price at the time of order placement, particularly in volatile or illiquid markets.
   4. Order Book: All orders placed on the Online Platforms are recorded in Feo's order book. The order book is continuously updated to reflect new orders, executions, and cancellations. Information about the order book may be made available to Users through the Online Platforms, subject to any limitations or restrictions implemented by Feo.
   5. Order Cancellation: Users may request cancellation of their open orders through the Online Platforms. However, there is no guarantee that a cancellation request will be processed before the order is executed, particularly for market orders or during periods of high market volatility.
   6. Order Rejection: Feo reserves the right to reject any order, at its sole discretion, for any reason, including but not limited to:
      1. Insufficient funds or Digital Assets in the User's account;
      2. Violation of these Terms or Applicable Laws;
      3. Suspected market manipulation or other abusive trading practices;
      4. Technical issues with the Online Platforms; or
      5. Risk management considerations.
   7. Transaction Fees: Please refer to Section 20.
   8. Price Determination: The price at which orders are executed may be determined by:
      1. The orders placed by other Users on the Online Platforms;
      2. Reference prices from external exchanges or trading venues;
      3. A combination of internal and external price sources.
   9. Minimum and Maximum Order Sizes: Feo may implement minimum and maximum order sizes for trading each Supported Digital Asset. These limits may change from time to time and will be communicated through the Online Platforms.
   10. Trading Hours: While the Online Platforms are generally available 24 hours a day, 7 days a week, Feo reserves the right to suspend trading during maintenance windows or in response to market disruptions, technical issues, or other circumstances warranting a suspension of trading.
   11. Market Disruptions: In the event of market disruptions, extreme volatility, or other extraordinary market conditions, Feo reserves the right to implement special trading procedures, including but not limited to trading halts, price collars, or other measures designed to maintain orderly trading.

9. CRYPTO DEPOSIT/WITHDRAWAL

   1. Service Description: This service enables Users to undertake deposits/withdrawals of Supported Digital Assets, to the extent available and permitted. In order to make any deposit or withdrawal of Supported Digital Assets, users will be required to provide Feo with the relevant information in compliance with travel rules, and such deposits/withdrawals will be executed only after screening of involved digital wallets in compliance with Feo's AML Policy.
   2. Supported Digital Assets: Feo may from time to time determine types of Digital Assets that will be supported or cease to be supported for deposit and withdrawal. The list of Supported Digital Assets will be made available on the Online Platforms and may be updated from time to time without prior notice.
   3. Risk of Loss: If a User deposits or attempts to deposit Digital Assets which are not supported by Feo, or deposits/withdraws crypto assets (a) to an incompatible/incorrect crypto asset wallet address or (b) via an incompatible crypto asset network, then the User may lose such crypto assets since the above said actions are beyond Feo's control; Feo shall not be liable for recovery of the same and Feo shall have no other obligation in this regard whatsoever.
   4. Deposit Process: To deposit Supported Digital Assets into your Digital Wallet, you must transfer the Digital Assets from an external wallet to the deposit address provided by Feo for your User Account. Each deposit address is specific to a particular Digital Asset and to your User Account. You must ensure that:
      1. You are depositing only Supported Digital Assets;
      2. You are using the correct deposit address for the specific Digital Asset you wish to deposit;
      3. You are using a compatible blockchain network for the deposit;
      4. Any required memo, tag, or payment ID is included with the transfer, if applicable.
   5. Confirmation Requirements: Deposits of Digital Assets will be credited to your Digital Wallet only after receiving a minimum number of blockchain network confirmations, as determined by Feo at its sole discretion. The required number of confirmations may vary by Digital Asset and may change from time to time based on security considerations or other factors.
   6. Deposit Limits: Feo may impose minimum and maximum deposit limits for Digital Assets. These limits may vary by Digital Asset, user verification level, and other factors, and may change from time to time at Feo's discretion.
   7. Withdrawal Process: To withdraw Supported Digital Assets from your Digital Wallet, you must submit a withdrawal request through the Online Platforms, specifying:
      1. The type and amount of Digital Asset to be withdrawn;
      2. The external wallet address to which the Digital Assets should be sent;
      3. Any required memo, tag, or payment ID, if applicable;
      4. Any other information required by Feo.
   8. Withdrawal Verification: Withdrawals may be subject to additional security verification, including but not limited to email confirmation, two-factor authentication, or other security measures implemented by Feo. For larger withdrawals or withdrawals that trigger risk management alerts, Feo may require additional verification steps or impose a holding period before processing the withdrawal.
   9. Withdrawal Limits: Feo may impose minimum and maximum withdrawal limits for Digital Assets. These limits may vary by Digital Asset, user verification level, and other factors, and may change from time to time at Feo's discretion.
   10. Withdrawal Fees: Please refer to Section 20.
   11. Processing Time: While Feo will make reasonable efforts to process withdrawal requests promptly, processing times may vary based on:
       1. Network conditions and congestion;
       2. Security and risk management considerations;
       3. The need for additional verification;
       4. Other factors beyond Feo's control.
   12. Finality of Withdrawals: Once a withdrawal request has been submitted and processed by Feo, it cannot be reversed or cancelled. You are solely responsible for ensuring the accuracy of all withdrawal information provided.
   13. Compliance Screening: All deposits and withdrawals are subject to compliance screening in accordance with Feo's AML Policy and Applicable Laws. Feo reserves the right to delay, reject, or report any deposit or withdrawal that raises compliance concerns.

10. FIAT SERVICES

    1. Service Description: Users can use their Linked Bank Account in order to use Feo's provision of services related to fiat-to-digital asset exchange or vice versa. To deposit INR and buy Digital Assets, the users can use the bank account maintained in the name of Feo which is available at Online Platforms. While exchanging Digital Assets for INR, the users will only receive INR in their Linked Bank Account.
    2. Linked Bank Account: Users may link only bank accounts that are held in their own name with Scheduled Commercial Banks in India. The bank account details provided must match the User's verified identity on the Online Platforms. Feo reserves the right to reject any bank account that does not meet its verification requirements.
    3. Fiat Deposits: To deposit fiat currency (INR) into your account on the Online Platforms, you must initiate a transfer from your Linked Bank Account to Feo's designated bank account using the payment methods supported by Feo. All deposits must include any reference numbers or identifiers specified by Feo to ensure proper crediting to your account.
    4. Deposit Processing Time: Fiat deposits may not be credited to your account immediately. Processing times depend on the payment method used, banking hours, and other factors. Feo will make reasonable efforts to credit deposits promptly, but does not guarantee any specific processing time.
    5. Deposit Limits: Feo may impose minimum and maximum limits on fiat deposits. These limits may vary based on your verification level, account history, and other factors, and may change from time to time at Feo's discretion.
    6. Deposit Verification: Feo may require additional verification for fiat deposits, particularly for large deposits or deposits that trigger risk management alerts. Such verification may include confirmation of the source of funds and additional identification requirements.
    7. Fiat Withdrawals: To withdraw fiat currency from your account, you must submit a withdrawal request through the Online Platforms. Withdrawals will be processed only to your Linked Bank Account. Feo will not process withdrawals to third-party bank accounts under any circumstances.
    8. Withdrawal Processing Time: Fiat withdrawals may take up to five (5) business days to be credited to your Linked Bank Account, depending on banking processing times and other factors. Feo will make reasonable efforts to process withdrawals promptly but does not guarantee any specific processing time.
    9. Withdrawal Limits: Feo may impose minimum and maximum limits on fiat withdrawals. These limits may vary based on your verification level, account history, and other factors, and may change from time to time at Feo's discretion.
    10. Withdrawal Fees: Please refer to Section 20.
    11. Compliance Requirements: All fiat deposits and withdrawals are subject to compliance with Feo's AML Policy, KYC Policy, and Applicable Laws. Feo reserves the right to delay, reject, or report any deposit or withdrawal that raises compliance concerns.
    12. Currency Conversion: Feo only supports deposits and withdrawals in Indian Rupees (INR). Any attempt to deposit funds in other currencies may result in conversion fees imposed by the sending or receiving bank, or rejection of the deposit.
    13. Service Availability: Feo will strive to maintain continuity of its fiat services; however, Feo may suspend or halt such services subject to the disruption in functionality of its banking facilities, changes in regulatory requirements, or other circumstances beyond Feo's control. Feo disclaims any liability or loss that you may incur due to discontinuation in fiat services.
    14. Bank Holidays and Weekends: Processing of fiat deposits and withdrawals may be delayed during bank holidays, weekends, or other times when banking services are limited or unavailable.

11. EXCHANGE BETWEEN DIGITAL ASSETS

    1. Service Description: You can exchange your Digital Asset with any other Supported Digital Asset from the list of Feo's Supported Digital Assets. Your order for exchange may be fulfilled internally through Feo's own liquidity pool or may be provided to you with the help of any external exchange. Feo reserves the right to supply the required Digital Asset either internally or through any external exchange, and you acknowledge and consent to Feo's discretion when you execute any exchange transaction through the Online Platforms.
    2. Exchange Process: To exchange Digital Assets, you must submit an exchange request through the Online Platforms, specifying:
       1. The Digital Asset you wish to exchange from (the "Base Asset");
       2. The Digital Asset you wish to exchange to (the "Quote Asset");
       3. The amount of the Base Asset you wish to exchange;
       4. Whether you wish to execute the exchange at the current market rate or at a specified price.
    3. Exchange Rates: Exchange rates for Digital Assets are determined based on:
       1. Current market rates on Feo's trading platform;
       2. Rates available from Feo's liquidity providers;
       3. Order book depth and liquidity;
       4. Feo's risk management considerations.
    4. Exchange Fees: Please refer to Section 20.
    5. Minimum and Maximum Exchange Amounts: Feo may impose minimum and maximum limits on the amount of Digital Assets that can be exchanged in a single transaction. These limits may vary by Digital Asset pair and may change from time to time at Feo's discretion.
    6. Execution Time: While Feo will make reasonable efforts to execute exchange requests promptly, execution times may vary based on:
       1. Market conditions and liquidity;
       2. The specific Digital Assets being exchanged;
       3. Technical factors;
       4. Risk management considerations.
    7. Price Slippage: For market rate exchanges, the actual execution price may differ from the estimated price shown at the time of request submission due to price movements or changes in liquidity between the time of request and execution. This difference is known as "slippage" and is inherent in trading volatile assets in dynamic markets.
    8. Failed Exchanges: In certain circumstances, an exchange request may fail to execute, including but not limited to:
       1. Insufficient balance of the Base Asset;
       2. Market price movements that exceed acceptable slippage parameters;
       3. Technical issues with the Online Platforms or external liquidity providers;
       4. Compliance or security concerns.
    9. Order Cancellation: You may request cancellation of a pending exchange order before it is executed. However, once an exchange has been executed, it cannot be reversed or cancelled.
    10. External Liquidity Providers: Feo may utilize external liquidity providers to fulfill exchange requests. In such cases:
        1. The exchange may be subject to the terms, conditions, and limitations of the external liquidity provider;
        2. Additional fees or spreads may be applied;
        3. Processing times may be affected by the external liquidity provider's systems and procedures.
    11. Market Disruptions: In the event of extreme market volatility, technical issues, or other extraordinary circumstances, Feo reserves the right to temporarily suspend or limit exchange services to maintain orderly markets and protect Users.

12. FEO PAY

    1. Service Description. "Feo Pay" refers to the proprietary off-chain internal transfer system operated by Feo that facilitates the transfer of Digital Assets between verified Feo User accounts (hereinafter referred to as "Internal Transfers"). Feo Pay transactions occur within Feo's internal ledger system and do not utilize external blockchain networks or traditional banking infrastructure for settlement.
    2. Eligibility Requirements. To utilize Feo Pay services, both the sending and receiving Users must have successfully completed all applicable Know Your Customer ("KYC") and Anti-Money Laundering ("AML") verification procedures as determined by Feo in its sole discretion. Users must maintain their accounts in good standing, free from any restrictions, suspensions, or limitations to initiate or receive Feo Pay transfers.
    3. Transaction Parameters. Feo Pay transactions are subject to minimum and maximum transfer limits, which may vary based on User verification level, account history, risk assessment, and jurisdiction of operation. Feo shall determine, in its sole discretion, which Digital Assets and Fiat Currencies may be transferred through Feo Pay. While Feo Pay transactions are designed to be processed instantaneously, certain circumstances may result in delays for which Feo shall not be liable.
    4. Fee Structure. Feo may, at its sole discretion, charge fees for the use of Feo Pay services. Such fees may be based on transaction amount, asset type, User verification level, or transaction frequency. Current fee schedules will be published on the Online Platforms and may be modified at any time without prior notice. By initiating a Feo Pay transaction, User expressly authorizes Feo to deduct any applicable fees from the transaction amount or the User's account balance.
    5. Transaction Finality. All Feo Pay transactions that have been confirmed and processed are final and irrevocable. User acknowledges and agrees that once a Feo Pay transaction has been initiated and confirmed by the sender, it cannot be canceled, reversed, or modified. User is solely responsible for ensuring the accuracy of all transaction details, including but not limited to recipient information and transfer amount. Feo shall not be responsible for any losses arising from User errors in transaction details.
    6. Limitations of Liability. User acknowledges that Feo Pay transactions occur within Feo's internal ledger and not on any public blockchain. Accordingly, such transactions are not subject to the same security, immutability, or transparency features inherent in blockchain-based transactions. Feo reserves the right to review suspicious transactions and may delay, reject, or reverse any Feo Pay transaction that violates these Terms or applicable laws. Feo may, at its sole discretion, impose additional restrictions or enhanced due diligence measures on accounts demonstrating unusual transaction patterns.
    7. Prohibited Activities. User shall not use Feo Pay to engage in any illegal activities, including but not limited to money laundering, terrorist financing, fraud, or any other activity that violates applicable laws or these Terms. User shall not utilize Feo Pay to circumvent any limitations, restrictions, or security measures implemented by Feo on its Online Platforms. Feo reserves the right to report suspicious activities to relevant authorities without prior notice to User.
    8. Recordkeeping. Feo shall maintain records of all Feo Pay transactions in accordance with its internal policies and applicable laws. Such records shall be conclusive evidence of the transactions executed through Feo Pay. User may access their transaction history through their account on the Online Platforms, subject to availability and retention periods established by Feo.
    9. Service Availability. Feo reserves the right to modify, suspend, or discontinue Feo Pay services at any time and for any reason without prior notice. User acknowledges that Feo shall not be liable for any damages or losses resulting from such modification, suspension, or discontinuation.
    10. Risk Disclosures. In addition to the risks disclosed elsewhere in these Terms, User acknowledges the following specific risks associated with Feo Pay:
        1. Internal transfers are dependent on the continuous operation and security of Feo's systems and infrastructure;
        2. Transactions may be subject to delays or rejections based on compliance requirements, system maintenance, or security protocols;
        3. In the event of Feo's insolvency, User's ability to access or transfer assets may be impaired or eliminated;
        4. Internal transfers are subject to the laws and regulations of applicable jurisdictions, which may change at any time and affect the availability or functionality of Feo Pay services.

13. NO WARRANTIES

    1. "As Is" and "As Available" Basis: Feo makes no warranties about the availability and functionality of any product, feature, service, or attribute of the Online Platforms as the services are available through the Online Platforms on an "as is" and "as available" basis. Feo does not make any express or implied warranty that the services or your access to the services will be uninterrupted, seamless, timely, fast, or error-free.
    2. No Warranty of Accuracy: Any material available on the Online Platforms is only tentative and for information purposes only. Feo makes no representation or warranty about the relevance, accuracy, timeliness, or completeness of such information and encourages you to independently check and verify such information from independent sources.
    3. Disclaimer of Warranties: To the maximum extent permitted by applicable law, Feo expressly disclaims all warranties and conditions of any kind, whether express, implied, or statutory, including, but not limited to:
       1. Implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement;
       2. Warranties concerning accuracy, reliability, timeliness, or appropriateness of the content, products, services, text, graphics, links, or communications provided on or through the use of the Online Platforms;
       3. Warranties concerning the transmission or delivery of the Online Platforms or any part thereof, the security of the Online Platforms, or that the Online Platforms will meet your requirements;
       4. Warranties concerning the accuracy or reliability of any information or advice obtained through the Online Platforms;
       5. Warranties that the Online Platforms will be uninterrupted, secure, free of viruses, trojan horses, malware, or other harmful components, or other errors;
       6. Warranties concerning the products, services, information, or materials purchased or obtained by you through the Online Platforms or transactions entered into through the Online Platforms;
       7. Warranties concerning any communication, goods, services, information, or materials purchased or obtained from a third party through the use of the Online Platforms;
       8. Warranties concerning the compliance of the Online Platforms with the laws of any country outside of India, or the compliance of the Online Platforms with any rules, regulations, or guidelines established by third parties;
       9. Warranties concerning any third-party content, goods, or services featured on the Online Platforms.
    4. No Third-Party Warranties: Any warranties provided by third parties in relation to third-party products or services accessible through the Online Platforms are the sole responsibility of such third parties, and Feo makes no representations or warranties with respect to such third-party warranties.
    5. Technical Limitations: You acknowledge and agree that Feo does not warrant that the Online Platforms will function with your hardware or software configurations or with any other application that you may use, or that the operation of the Online Platforms will be uninterrupted or error-free.
    6. Service Modifications: Feo reserves the right to modify, suspend, or discontinue any part of the Services at any time without notice or liability.
    7. No Reliability Warranty: Feo does not warrant that any errors in the Online Platforms will be corrected, or that the Online Platforms or the server that makes it available are free of viruses or other harmful components.
    8. Blockchain Network Limitations: Feo does not warrant or guarantee the performance, reliability, security, or stability of any blockchain network underlying any Digital Asset, and you acknowledge that Feo has no control over such networks.

14. USER COVENANTS AND REPRESENTATIONS

    1. Legal Compliance: You represent that your access to Online Platforms and availing the Services are legal and allowed under applicable laws, and you will use the Online Platforms only for legal purposes.
    2. Technical Integrity: You represent and agree not to circumvent, remove, degrade, deactivate, use any robot, spider, scraper, or other means to access the Services. You also agree not to decompile, reverse engineer, and disassemble any software or other products or services available on the Online Platforms. Additionally, you agree not to upload, post, e-mail, or otherwise send or transmit any material designed to interrupt, destroy, or limit the functionality of the service.
    3. Compliance with Terms: You understand and agree that Feo may terminate or restrict your use of the Services or access to your Account if you violate these Terms or engage in any illegal or fraudulent use of the service. Feo may also initiate any action under the order or direction of the Government, law enforcement authority, or court. Under such order or direction, Feo may:
       1. Suspend your User Account;
       2. Terminate your User Account;
       3. Require you to withdraw funds or Digital Assets from your User Account or Linked Bank Account within a certain period of time;
       4. Withhold or transfer your Digital Assets or Funds.
    4. No Liability for Legal Compliance: Feo will not be responsible for any losses, whether direct or indirect, that you may incur as a result of Feo's complying with Applicable Laws, the guidance or direction of any such regulatory authority or government agency, or any writ of attachment, lien, levy, subpoena, warrant, or other legal order.
    5. Technical Limitations Acknowledgment: You acknowledge that the Online Platforms may be subject to restrictions, limitations, delays, and other problems inherent in the use of the internet and electronic communications, blockchain networks, or an industry involving regulatory uncertainties.
    6. Accurate Information: You covenant that all information provided to Feo during registration and throughout your use of the Services is true, accurate, current, and complete. You further covenant to promptly update any information that becomes inaccurate, misleading, or incomplete.
    7. Tax Compliance: Please refer to Section 20.
    8. No Fraudulent Activity: You covenant not to engage in any fraudulent activity, including but not limited to:
       1. Providing false or misleading information;
       2. Creating multiple accounts for abusive purposes;
       3. Engaging in any form of market manipulation;
       4. Using stolen payment instruments;
       5. Engaging in any other deceptive practices.
    9. Security Cooperation: You covenant to cooperate with Feo in any security investigation or audit, including providing information about your account activity if requested.
    10. No Harmful Use: You covenant not to use the Services in any manner that could damage, disable, overburden, or impair the functioning of the Online Platforms or interfere with any other party's use and enjoyment of the Services.
    11. Notification of Unauthorized Use: You covenant to immediately notify Feo of any unauthorized use of your account or any other breach of security of which you become aware.
    12. Compliance with Notices: You covenant to comply with all notices, guidelines, rules, terms, and conditions posted on the Online Platforms or provided to you in connection with the Services.
    13. No Circumvention: You covenant not to attempt to circumvent any security measures, access controls, or usage limitations implemented by Feo.

15. LIMITATION OF LIABILITY

    1. General Limitation: To the extent permitted by law, Feo will not be liable for any loss or damage caused to you through use of the Online Platforms or in relation to or on account of access or inability to access the Online Platforms.
    2. Exclusion of Certain Damages: Feo, its subsidiaries, affiliates, its shareholders, its directors, officers, employees, representatives, contractors, suppliers shall not be liable for any incidental, special, punitive, consequential, or similar damages or liabilities whatsoever arising out of the Services, any performance or non-performance of Services, or any product provided by Feo.
    3. Maximum Liability: Feo's total liability to any user shall not in any event exceed the fees paid by such user during the 6 (six) months immediately preceding the date of claim for any direct, indirect, or consequential loss or damage irrespective of the nature of the claim.
    4. Cyber Attack Disclaimer: Digital Assets may be targeted by hackers or malicious groups or organizations who may attempt to interfere with any transactions related to your Digital Assets through various means including malware attacks, hacking, distributed denial of service, consensus-based attacks, sybil attacks, phishing, smurfing, and hacking. Feo will adopt and maintain a reasonable standard of security; however, Feo will not be liable to you for any loss or damage caused to you on account of any such attack or interference.
    5. Third Party Service Providers: Feo may engage the services of Third Party Service Providers in connection with the development, operation, and maintenance of the Online Platforms and Services or onboarding and verification of customers. Feo shall not be liable for any suspension, halt, or interruption of the Services through the Online Platforms where such circumstances arise or result from any interruptions, errors, default, or otherwise by any such third parties.
    6. Specific Exclusions: Notwithstanding any provision in this Agreement to the contrary, Feo shall not in any circumstances be liable for any loss, damage, liability, expense, fines, or penalties or any other amount directly or indirectly caused by:
       1. The use or operation of the Online Platforms;
       2. The introduction of viruses, worms, or other destructive programs;
       3. Any commercial or economic losses;
       4. Losses arising out of or in connection with third party cyber-attacks or unauthorized access or use of the Online Platforms;
       5. The loss of any Indian Rupees or Digital Assets that can be transferred, stored, or traded on the Online Platforms;
       6. Assets surrendered to the courts or regulators or other statutory authorities under the Applicable Laws.
    7. Force Majeure: Feo shall not be liable for any delay or failure to perform due to a Force Majeure Event.
    8. Limitation Period: Any claim against Feo arising out of or related to these Terms or the Services must be filed within one (1) year after such claim arose, failing which the claim shall be permanently barred.
    9. Allocation of Risk: The limitations of liability set forth in these Terms reflect the allocation of risk between the parties, and the parties have relied on these limitations in determining whether to enter into these Terms.
    10. Indispensability: The limitations of liability provided in these Terms are fundamental elements of the basis of the bargain between Feo and you. The Online Platforms and Services would not be provided without such limitations.
    11. Severability of Limitations: If any part of this limitation of liability is found to be invalid or unenforceable, the remaining portions shall remain in full force and effect to the maximum extent permitted by law.

16. INDEMNIFICATION

    1. Scope of Indemnification: You shall indemnify and hold harmless Feo, its affiliates, subsidiaries, officers, directors, agents, and employees, from any claim or demand, or actions including reasonable attorneys' fees, made by any third party or penalty imposed due to or arising out of or relating to:
       1. Your use of the Services;
       2. Your breach of these Terms;
       3. Your violation of any law, rules, or regulations;
       4. Your violation of the rights of any other user or a third party.
    2. Procedure for Indemnification: In the event that Feo is subject to any claim for which it is entitled to indemnification from you under these Terms:
       1. Feo will promptly notify you of such claim, provided that failure to promptly notify will not relieve you of your indemnification obligations except to the extent that such failure materially prejudices your ability to defend the claim;
       2. You will, at your option and expense, defend such claim through counsel of your choice, provided that such counsel is reasonably acceptable to Feo;
       3. Feo will cooperate reasonably with you in the defense of such claim, at your expense;
       4. You will not settle any such claim without Feo's prior written consent, which shall not be unreasonably withheld, unless such settlement fully and unconditionally releases Feo from all liability and does not impose any obligations on Feo or adversely affect Feo's business or interests.
    3. Feo's Right to Defend: If you fail to promptly and diligently pursue the defense of any claim for which Feo is entitled to indemnification, Feo will have the right, but not the obligation, to defend itself against such claim at your expense.
    4. Survival of Indemnification Obligations: Your indemnification obligations will survive the termination of these Terms and your use of the Services.
    5. No Limitation: The indemnification provided for in these Terms is in addition to, and not in lieu of, any other remedies that may be available to Feo under these Terms or applicable law.
    6. Third-Party Claims: In addition to claims by Feo, you also agree to indemnify and hold harmless Feo from any claims made by third parties arising from your use of the Services.
    7. Costs and Expenses: The indemnification obligations include, but are not limited to, all costs, expenses, and liabilities incurred in investigating, defending, or settling any claim, including reasonable attorneys' fees and costs of litigation.

17. SUSPENSION, TERMINATION AND CANCELLATION

    1. Feo's Right to Suspend or Terminate: Feo reserves the right to suspend, block, cancel or reverse a transaction and/or refuse to continue access to the Online Platforms (even if funds have been debited from your User Account) if Feo discovers that you are in breach of the Terms and Applicable Law.
    2. Account Closure Process: If your account is closed/suspended/cancelled/deactivated, your Digital Assets or other funds will only be returned or allowed to be withdrawn upon payment of all outstanding charges to Feo, and you may be required to produce your identity and other KYC documents and/or any additional details depending on the reason for closure/suspension/cancellation/deactivation. Feo also, in its sole discretion, may direct you to withdraw all your Digital funds within a reasonable period of time and subsequently close your account with Feo.
    3. Grounds for Suspension or Termination: Feo may suspend or terminate your access to the Services or your User Account for any of the following reasons:
       1. Violation of these Terms or any other agreement with Feo;
       2. Violation of any Applicable Laws;
       3. Upon the request or order of any regulatory authority, law enforcement agency, or court of competent jurisdiction;
       4. If Feo reasonably suspects that you are engaged in fraudulent, illegal, or abusive activities;
       5. If you provide false, incomplete, inaccurate, or misleading information;
       6. If your account has been inactive for a continuous period of twelve (12) months or more;
       7. If you engage in any activity that could damage the reputation or business of Feo;
       8. If you engage in any activity that could impose an unreasonable or disproportionately large load on Feo's infrastructure;
       9. If you engage in any activity that could interfere with the proper operation of the Online Platforms;
       10. For any other reason at Feo's sole discretion.
    4. Effect of Suspension or Termination: Upon suspension or termination of your User Account:
       1. You may lose access to some or all of the Services;
       2. Feo may cancel any pending transactions;
       3. You will remain liable for all obligations related to your User Account incurred prior to the suspension or termination;
       4. Feo may retain your personal information and Digital Assets as required by Applicable Laws or as necessary to protect Feo's rights or the rights of third parties.
    5. Notice of Suspension or Termination: Feo will make reasonable efforts to provide you with notice of suspension or termination of your User Account, except in cases where:
       1. Providing notice would violate Applicable Laws or a legal order;
       2. Providing notice would compromise Feo's security measures or the security of other Users;
       3. Providing notice would be impractical due to technical limitations;
       4. Immediate action is required to prevent harm to Feo, other Users, or third parties.
    6. User-Initiated Account Closure: You may request the closure of your User Account at any time by following the procedures specified on the Online Platforms. Prior to account closure, you must:
       1. Withdraw or transfer all Digital Assets from your Digital Wallet;
       2. Complete any pending transactions;
       3. Pay any outstanding fees or charges.
    7. Survival of Terms: The provisions of these Terms that by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnification, and limitations of liability.

18. INTELLECTUAL PROPERTY RIGHTS

    1. Ownership and Reservation of Rights. All rights, title, and interest in and to the Online Platforms, including without limitation all intellectual property rights, are and shall remain the exclusive property of Feo and its licensors. The visual interfaces, graphics, design, compilation, information, computer code (including source code and object code), products, software, services, and all other elements of the Online Platforms provided by Feo (collectively, the "Feo Materials") are protected by applicable intellectual property laws, including but not limited to copyright, patent, trademark, and trade secret laws. User hereby acknowledges that no title or ownership of the Feo Materials or any part thereof is transferred to User under these Terms or otherwise.
    2. License to Use. Subject to User's compliance with these Terms, Feo grants User a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Online Platforms solely for User's personal, non-commercial purposes. User shall not use, copy, adapt, modify, prepare derivative works based upon, distribute, license, sell, transfer, publicly display, publicly perform, transmit, stream, broadcast, or otherwise exploit the Online Platforms or any portion thereof, except as expressly permitted in these Terms. No licenses or rights are granted to User by implication or otherwise under any intellectual property rights owned or controlled by Feo or its licensors, except for the licenses and rights expressly granted in these Terms.
    3. Trademarks and Brand Assets. The Feo name, logo, and all related names, logos, product and service names, designs, and slogans are trademarks of Feo or its affiliates or licensors. Other names, logos, product and service names, designs, and slogans that appear on the Online Platforms are the property of their respective owners and may not be used without permission. User shall not use such marks without the prior written permission of Feo. Additionally, User shall not remove, alter, or obscure any copyright, trademark, service mark, or other proprietary rights notices incorporated in or accompanying the Online Platforms.
    4. User Content. User acknowledges and agrees that any feedback, comments, suggestions, ideas, proposals, or other material provided by User relating to the Online Platforms or Feo (collectively, "User Content"), whether publicly posted or privately transmitted, shall be the sole and exclusive property of Feo. User hereby irrevocably transfers and assigns to Feo all right, title, and interest in and to all User Content, including without limitation all intellectual property rights therein, and waives any moral rights or other rights of authorship as to such User Content. Feo shall be entitled to the unrestricted use and dissemination of such User Content for any purpose, commercial or otherwise, without acknowledgment or compensation to User.
    5. DMCA and Copyright Policy. Feo respects the intellectual property rights of others and expects Users to do the same. In accordance with the Digital Millennium Copyright Act ("DMCA") and other applicable laws, Feo has adopted a policy of terminating, in appropriate circumstances and at Feo's sole discretion, the accounts of Users who are deemed to be repeat infringers. If you believe that your work has been copied in a way that constitutes copyright infringement, please provide Feo's copyright agent with the following information in accordance with the DMCA:
       1. A physical or electronic signature of the person authorized to act on behalf of the owner of the copyright interest;
       2. A description of the copyrighted work that you claim has been infringed;
       3. A description of where the material that you claim is infringing is located on the Online Platforms;
       4. Your address, telephone number, and email address;
       5. A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law;
       6. A statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner's behalf.

    Feo's designated copyright agent for notice of claims of copyright infringement can be reached at: [email protected]

    6. Third-Party Websites and Content. The Online Platforms may contain links to third-party websites and services, including but not limited to social media platforms (collectively, "Third-Party Services"). Such Third-Party Services may have their own terms of use and privacy policies, and User's use of such Third-Party Services will be governed by those terms and policies. Feo does not endorse, is not responsible for, and makes no representations or warranties regarding such Third-Party Services, including without limitation their content, accuracy, quality, legality, or reliability. Feo shall not be liable for any damage or loss arising from User's use of or reliance on any Third-Party Services.

19. FEES & TAXES

    1. Fee Schedule. All fees for Services (transaction fees, exchange fees, withdrawal fees, custody fees, fiat‑service fees, etc.) are set out in the Fee Schedule available on the Online Platforms and may be updated by Feo from time to time.

    2. Custody Fees. Feo reserves the right to charge fees for custody services, which will be disclosed to Users through the Online Platforms. Feo may modify such fees upon notice to Users.

    3. Withdrawal Fees: Withdrawals of Digital Assets may be subject to network transaction fees, which will be disclosed at the time of withdrawal request. These fees may vary based on network conditions and may be adjusted by Feo from time to time.

    4. Fiat Withdrawal Fees: Fiat withdrawals may be subject to processing fees, which will be disclosed at the time of withdrawal request. These fees may be adjusted by Feo from time to time.

    5. Exchange Fees. Exchanges between Digital Assets are subject to fees, which will be disclosed at the time of the exchange request. The User is required to maintain sufficient balances of INR or the relevant Digital Asset, as the case may be, for the execution of the relevant trade. By placing an order, you authorize Feo to deduct applicable fees from your account upon execution of the order. These fees may vary based on:

       1. The specific Digital Assets being exchanged;
       2. The User's trading volume and account tier;
       3. Market conditions; and
       4. Other factors determined by Feo.

    6. Tax Deduction at Source (TDS). Under the Indian Income Tax Act, 1961 and related rules, Feo will deduct tax at source (TDS) at the rate of 1% on:

       1. Sale of Digital Assets for Fiat Currency
       2. Trades between one Digital Asset and another Digital Asset.

       Such TDS will be reflected in your transaction statements and may be claimed as a credit when filing your tax returns.** Feo itself does not advise on tax matters and is not responsible for your ultimate tax liability.

    7. Other Taxes. You are solely responsible for determining and complying with all taxes on your Digital Asset transactions, including reporting and remitting them to the appropriate authorities (Income, GST, stamp duty, etc.) on your transactions

20. MISCELLANEOUS

    1. Governing Law. These Terms and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of India, without giving effect to any choice or conflict of law provision or rule (whether of India or any other jurisdiction) that would cause the application of the laws of any jurisdiction other than India.
    2. Dispute Resolution.
       1. Mandatory Arbitration. Any dispute, controversy, or claim arising out of or relating to these Terms, including the validity, invalidity, breach, or termination thereof, or any dispute regarding non-contractual obligations arising out of or relating to these Terms, shall be resolved by arbitration in accordance with the Arbitration and Conciliation Act, 1996 (as amended) in force at the time such arbitration is commenced.
       2. Arbitration Procedure. The arbitration shall take place in Bengaluru, India, and shall be conducted in the English language. The arbitral tribunal shall consist of a sole arbitrator to be appointed by Feo. The arbitration proceedings shall be confidential, and neither party shall disclose to any person any information about the arbitration proceedings, including but not limited to the existence of the arbitration, the arbitral award, and any submissions, materials, or evidence disclosed within the arbitration proceedings. The costs of arbitration shall be borne equally by the parties, unless otherwise awarded by the arbitrator.
       3. Exceptions to Arbitration. Notwithstanding the foregoing, nothing in these Terms shall prevent Feo from seeking injunctive or other equitable relief in any court of competent jurisdiction, and User agrees to submit to the personal jurisdiction of the courts located in Bengaluru, India for such purposes.
       4. Class Action Waiver. User agrees that any arbitration or other dispute resolution proceedings between User and Feo shall be conducted solely on an individual basis and not in a class, consolidated, or representative action. User expressly waives any right to participate in a class action lawsuit, class-wide arbitration, or any other representative proceeding.
    3. Severability. If any provision of these Terms is held by a court or other tribunal of competent jurisdiction to be invalid, illegal, or unenforceable for any reason, such provision shall be eliminated or limited to the minimum extent necessary, and the remaining provisions of these Terms will continue in full force and effect.
    4. Entire Agreement. These Terms, together with the Privacy Policy and any other agreements expressly incorporated by reference herein, constitute the entire and exclusive understanding and agreement between User and Feo regarding the Online Platforms and Services, and these Terms supersede and replace any and all prior oral or written understandings or agreements between User and Feo regarding the Online Platforms and Services.
    5. Assignment. These Terms, and any rights and licenses granted hereunder, may not be transferred or assigned by User without the prior written consent of Feo. Feo may assign or transfer these Terms, in whole or in part, without restriction and without notice to User. Any attempted transfer or assignment in violation hereof shall be null and void.
    6. Waiver. No failure or delay by Feo in exercising any right, power, or privilege under these Terms shall operate as a waiver thereof, nor shall any single or partial exercise of any right, power, or privilege preclude any other or further exercise thereof or the exercise of any other right, power, or privilege. The rights and remedies provided in these Terms are cumulative and not exclusive of any rights or remedies provided by law.
    7. No Agency. Nothing in these Terms shall be construed as creating any agency, partnership, joint venture, employment relationship, or franchise relationship between User and Feo.
    8. Survival. Upon termination of these Terms, any provision which, by its nature or express terms should survive, shall survive such termination or expiration.
    9. Force Majeure. Feo shall not be liable for any failure or delay in performing its obligations under these Terms to the extent such failure or delay is caused by a Force Majeure Event.
    10. Notices.
        1. To User. Feo may provide any notice to User under these Terms by: (i) sending a message to the email address specified in User's account; or (ii) posting a notice on the Online Platforms. Notices sent by email will be effective when Feo sends the email, and notices provided by posting will be effective upon posting. It is User's responsibility to keep their email address current.
        2. To Feo. To give Feo notice under these Terms, User must contact Feo by email at [email protected] or by personal delivery, overnight courier, or registered or certified mail to the address specified on the Online Platforms. Feo may update the address for notices by posting a notice on the Online Platforms. Notices provided by personal delivery will be effective immediately. Notices provided by overnight courier will be effective one business day after they are sent. Notices provided by registered or certified mail will be effective three business days after they are sent.
    11. Electronic Communications. User consents to receive communications from Feo electronically. Feo may communicate with User by email or by posting notices on the Online Platforms. User agrees that all agreements, notices, disclosures, and other communications that Feo provides to User electronically satisfy any legal requirement that such communications be in writing.
    12. Headings. The section titles in these Terms are for convenience only and have no legal or contractual effect.
    13. Language. These Terms are drafted in the English language. If these Terms are translated into any other language, the English language text shall prevail.
    14. Independent Consideration. User acknowledges that these Terms represent a reasonable allocation of risk and that Feo would not enter into these Terms without User's agreement to the limitations of liability and disclaimers set forth herein.
    15. Taxes. User is solely responsible for all taxes, duties, levies, or similar governmental assessments of any nature, including, for example, value-added, sales, use, or withholding taxes, assessable by any jurisdiction (collectively, "Taxes") associated with User's use of the Services, including without limitation the purchase, holding, transfer, or exchange of Digital Assets. User acknowledges and agrees that Feo is not responsible for determining whether, or which, Taxes apply to User's transactions, and Feo is not responsible for collecting, reporting, withholding, or remitting any Taxes arising from any transactions occurring on the Online Platforms.
    16. Updates to Terms. Feo reserves the right, at its sole discretion, to modify or replace these Terms at any time. By continuing to access or use the Online Platforms after any revisions become effective, User agrees to be bound by the revised Terms. If User does not agree to the new Terms, User must stop using the Online Platforms and Services.
    17. Contact Information. Questions, complaints, or claims with respect to the Online Platforms should be directed to:

    Purple Pixel Private Limited Attention: Legal Department Email: [email protected] Address: HD-276 WeWork, Hebbal, Bengaluru, India

    BY ACCESSING OR USING THE ONLINE PLATFORMS OR SERVICES, USER ACKNOWLEDGES THAT USER HAS READ, UNDERSTOOD, AND AGREES TO BE BOUND BY THESE TERMS OF SERVICE AND ALL OTHER APPLICABLE POLICIES, INCLUDING THE PRIVACY POLICY.