This disclaimer should be read in conjunction with the platform's User Service Agreement (Terms). In essence, we want you to fully understand the relevant important compliance matters and liability provisions when using this platform for trading.

Purpose of This Statement

To establish and maintain a healthy and compliant digital asset trading environment, we have developed and implemented a comprehensive anti-money laundering, counter-terrorism financing, and trade and economic sanctions program, and clearly articulate the corresponding liability provisions. We are committed to promoting lawful and transparently operated business practices and establishing a positive corporate reputation among our user base, regulatory authorities, and throughout the digital asset industry.

Regulatory Framework Context

We recognize that regulatory authorities across different jurisdictions have adopted diverse regulatory and normative approaches toward digital assets, including defining or classifying digital assets as virtual financial assets (such as in Malta), convertible virtual currency (such as by FinCEN in the United States), or virtual commodities (such as in Hong Kong), among others. As a trading service provider, we consider all types of digital assets offered on the platform to fall within the category of innovative alternative assets and therefore should not be referred to as currency or money.

Material Disclosure Information

Digital assets are not legal tender and are not backed or guaranteed by any national government or central bank. While we may hold certain views regarding regulatory approaches adopted by governmental authorities in various countries, we strictly comply with the laws and regulations of the countries and regions where we operate. Additionally, we regularly engage with regulatory authorities and industry peers to discuss best regulatory practice solutions for digital asset business operations. We actively cooperate with government agencies and strictly adhere to applicable legal and regulatory requirements. As a responsible corporate citizen, when law enforcement agencies request information, we will actively cooperate within the scope permitted by law to assist law enforcement agencies in investigating and preventing illegal activities. This also means that our platform is only open to law-abiding customers. We look forward to providing you with quality services while also expecting you to comply with relevant laws and regulations when using the platform. Furthermore, based on market reputation maintenance and high compliance requirements, ETZ does not provide services to customers from certain jurisdictions. We have decided not to seek or accept customers from the following regions, including but not limited to: Afghanistan, Burundi, Cambodia, Canada, Central African Republic, mainland China, Cuba, Democratic Republic of the Congo, Hong Kong Special Administrative Region of China, Iran, Laos, Macao Special Administrative Region of China, Myanmar, the Netherlands, North Korea, Panama, Singapore, Somalia, United Kingdom, United States (including all U.S. territories and outlying islands), and the Crimea, Donetsk, and Luhansk regions of Ukraine. This list of restricted regions may be adjusted and modified, and the scope of restrictions may vary for different services. For more details, you may contact ETZ customer service for relevant information.

Anti-Money Laundering and Counter-Terrorism Financing Framework

Based on risk assessment, we have established a multi-layered control system and designed a proprietary anti-money laundering and counter-terrorism financing program to effectively prevent money laundering and terrorism financing activities. The first layer of our mechanism consists of a rigorous customer identity verification process, including verification and validation of individual or corporate customer identities. In addition to collecting identity documentation, we also obtain information on institutional ultimate beneficial owners/natural persons for non-natural person customers, which aligns with international standards such as those of the Financial Action Task Force (FATF). The second layer of our mechanism includes risk-based systematic control measures to ensure that enhanced customer due diligence is implemented. To this end, we screen customers based on institutional/individual information (including ultimate beneficial owners) published in sources such as the Hong Kong SAR Government Gazette, U.S. Office of Foreign Assets Control (OFAC) sanctions lists, and United Nations Security Council sanctions lists. We may also include other lists in our screening scope as circumstances warrant to protect the interests of the platform and customers. The third layer of our mechanism involves continuous monitoring for suspicious activities. When we suspect or have reasonable grounds to suspect the existence of suspicious transaction activities, we will submit suspicious transaction activity reports to local regulatory authorities as appropriate. Suspicious transactions typically refer to transaction behaviors that are inconsistent with a customer's known legitimate business activities or personal routine transaction activity patterns.

Risk Warning

Digital asset trading is considered a high-risk investment activity. Digital assets are not endorsed or guaranteed by any government or central bank. Trading or holding digital assets may involve significant risks. You should carefully assess whether trading, holding, or buying and selling digital assets is suitable for you based on your own financial circumstances.

Liability Provisions

Disclaimer of Warranties

For purposes of this document, "Services" refers to all services provided through the ETZ platform or its affiliates and/or partners, including cryptocurrencies and/or their derivative products and related trading services. To the maximum extent permitted by law, the Services, ETZ's materials, and any products, services, or other items provided by or on behalf of ETZ are provided on an "as is" and "as available" basis. Furthermore, you waive relevant rights and ETZ expressly disclaims any express or implied warranties, including warranties of accuracy, non-infringement, merchantability, and fitness for a particular purpose, or warranties arising from course of performance, course of dealing, or usage of trade. Without limiting the foregoing, ETZ makes no representations or warranties regarding the accuracy, completeness, reliability, validity, error-free nature, or freedom from viruses and other harmful components of the website, Services, or ETZ materials. ETZ does not guarantee that any order will necessarily be executed, accepted, recorded, or maintained in an incomplete status. Except for the statements expressly set forth in this Agreement, you hereby acknowledge and agree that you have not relied on any other written or oral representations or agreements in using and obtaining the Services. Without limiting the foregoing, you hereby understand and agree that ETZ shall not be liable for any loss or damage caused by or related to the following:

(A) Inaccuracies, defects, or omissions in digital asset price data;

(B) Any errors or delays in data transmission;

(C) Interruptions in data transmission;

(D) Damages caused by the actions, omissions, or breaches of agreement by other users.

Limitation of Damages and Liability

To the maximum extent permitted by law, ETZ, its affiliates, and their respective shareholders, members, directors, officers, employees, legal counsel, agents, representatives, suppliers, or contractors shall not, under any circumstances, be liable for any incidental, indirect, special, punitive, consequential, or similar damages or liabilities (including but not limited to loss of data, information, revenue, profits, or other business or financial benefits) arising from the Services, the performance or non-performance of the Services, or other products, services, or items provided by or on behalf of ETZ and its affiliates. Whether based on contract, law, strict liability, or other theory, even if ETZ has been advised of the possibility of such damages, unless a final judicial determination establishes that such damages were caused by ETZ's gross negligence, fraud, willful misconduct, or intentional violation of law. Certain jurisdictions do not permit the exclusion or limitation of liability for incidental or consequential damages, so the above limitations may not apply to your circumstances. Notwithstanding the foregoing, under no circumstances shall the aggregate liability of ETZ, its affiliates, and their respective shareholders, members, directors, officers, employees, legal counsel, agents, representatives, suppliers, or contractors arising from the Services provided by or on behalf of ETZ or its affiliates, the performance or non-performance of the Services, or any other products, services, or items, whether based on contract, law, strict liability, or other theory, exceed the amount of fees you have paid to ETZ under this Agreement prior to the event giving rise to the liability claim.

Governing Language

This statement may be published in multiple language versions. If there are any differences between language versions, the English version shall prevail.

ETZ Platform Disclaimer and Legal Notice