Terms & Conditions

CTG LTD · Reg. No. 126357 · June 2026

1. Preamble

1.1. This document (the "Terms") sets out the rules governing the operation of the Cryptorg platform.

1.1a. CTG LTD is registered at: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, MH 96960, Marshall Islands. Registration number: 126357.

1.2. These Terms define the conditions under which CTG LTD (the "Administrator") grants the Client access to the System and its Services, and under which the Client agrees to use them.

1.3. These Terms constitute a public offer addressed to legal entities and individuals who have reached the age of majority.

1.4. Matters not covered by these Terms may be regulated by the Administrator's internal procedures, details of which will be provided to a Client upon written request.

2. Terms and Definitions

2.1. Authorisation Data — a combination of Login and Password used to access the System.

2.2. Authorisation — the process of verifying the Client's identity using their Login and Password.

2.3. Prohibited Activity — any activity that is: (a) criminally punishable in the Client's jurisdiction; (b) listed in Appendix I to these Terms; or (c) contrary to generally accepted ethical and moral standards.

2.4. Identification — the procedure by which the Client provides the Administrator with personal data required by law or these Terms.

2.5. Identified Client — a registered Client whose identity has been confirmed through the Identification procedure.

2.6. Client — any person entitled or obliged to transfer, receive, use, or acquire Funds in accordance with these Terms.

2.7. Wallet — a Client account registered in the System, stored in the System database, owned by the Client, and reflecting the balance of Funds belonging to that Client.

2.8. Unregistered Client — a Client who has not completed Registration and may use Funds with restrictions, as set out in these Terms.

2.9. Operation — any transfer of Funds carried out using the System.

2.10. Payment — Funds recorded on the Wallet and transferred between the Client and a third party.

2.11. Registration — the process of entering a person's data into the System, after which the Client is recognised by the System.

2.12. System — the hardware and software infrastructure used to provide the System Services to Clients.

2.13. Funds — electronic funds belonging to the Client and recorded on their Wallet.

2.14. Parties — the Administrator and the Client, referred to jointly.

2.15. Services (System Services) — Operations with Funds carried out via the System on Clients' Wallets.

2.16. Chargeback — a procedure for reversing a card payment, initiated by the cardholder through their bank.

3. Acceptance of These Terms

3.1. A Client accepts these Terms by: (1) completing the registration form on the Site, including creating Authorisation Data; (2) reviewing the Terms; and (3) checking the confirmation box on the registration form.

3.2. Acceptance constitutes full and unconditional agreement to all provisions of these Terms without exception, and is equivalent to entering into a written bilateral agreement.

3.3. There is no time limit on acceptance.

3.4. Access to the Services is granted only after the Client has accepted these Terms.

4. The Cryptorg System

4.1. Upon Registration, the Client opens a Wallet. The Wallet holds electronic funds and allows the Client to send and receive electronic payments. It is denominated in a currency chosen by the Client from those available.

4.2. Funds may be stored in the Wallet indefinitely. No interest accrues on Wallet balances.

4.3. Limits on deposits, payments, and withdrawals may apply depending on the Client's status and other factors assessed at the Administrator's discretion.

4.4. The Administrator offers both non-personalised and personalised Wallets.

4.5. To use the Services, the Client must open a Wallet by completing Registration on the Site and confirming agreement with these Terms. Individual Clients must be of legal age.

4.6. A Client may open a Wallet only if doing so is lawful in their jurisdiction.

4.7. Records of a Client's Operations and Wallet activity are stored by the Administrator for the duration of these Terms and for five years thereafter.

4.8. Any action by the Client that changes their Wallet balance constitutes confirmation that the Client agrees with the balance as it stood immediately prior to that action.

4.9. Access to the Wallet and execution of any Operations are possible only after Authorisation.

4.10. The Login is the Client's email address or an alphanumeric identifier chosen during Registration.

4.11. Passwords are created by the Client and may be changed at any time.

4.12. The Client is solely responsible for keeping their Authorisation Data confidential. Any action taken using valid Authorisation Data is deemed to have been carried out by the Client.

4.13. If the Client loses their Authorisation Data, the Administrator will provide a procedure for restoring Wallet access.

4.14. The Administrator may lock a Wallet (suspend outgoing Payments) in the circumstances set out in these Terms or as required by law.

4.15. A Client may close their Wallet by contacting Support.

5. Transactions and Funds

5.1. The Client may top up their Wallet via the Personal Account on the Site by following the relevant instructions.

5.2. Wallet top-up methods are provided by third-party payment services and are not part of the System Services.

5.3. The Administrator may restrict available top-up methods for certain categories of Clients.

5.4. When a Wallet is topped up via a third party, all rights and obligations in respect of the credited Funds vest in the Client. Third-party actions are treated as having been taken in the Client's interest.

5.5. Deposit limits apply for security purposes.

5.6. Fees may apply to Wallet top-ups.

5.7. Fund transfers are executed on the basis of an electronic instruction submitted by the Client through their Wallet.

5.8. Upon receiving a transfer instruction, the Administrator verifies the Client's right to dispose of the Funds by authenticating the Client's Authorisation Data.

5.9. The Administrator may restrict the list of eligible recipients for certain categories of Clients. Specific restrictions are published on the Site.

5.10. All Operations carried out by the Client through the System are final and are not subject to dispute, review, or cancellation, except for Wallet top-up transactions subsequently identified as fraudulent.

6. Reporting

6.1. The Client may independently generate reports for any period via the Personal Account in the System.

6.2. The Client is responsible for ensuring that their information in the System is accurate and up to date.

7. Personal Data

7.1. The Administrator may collect, store, and process personal data entered by Clients during Transactions, as well as data automatically transmitted in the course of using the System. This data may be shared with third parties to the extent required to comply with these Terms, ancillary agreements, or applicable law.

7.2. The Administrator may collect and process information about purchases and paid services for targeted advertising and statistical purposes, and may share aggregated statistical data with third parties without disclosing Clients' personal data.

8. Rights and Obligations of the Parties

8.1. The Client has the right to: access all System Services available under their status and applicable limits; open a Wallet; and receive technical and informational support.

8.2. The Administrator has the right to: expand the range of Services; modify software, interfaces, procedures, and Services; suspend the System for maintenance or to prevent unauthorised access; request identifying documents from the Client where required; refuse to execute Operations in cases set out in these Terms (including where the Client attempts to carry out Prohibited Activities); take action against Clients in case of a breach; and charge fees in accordance with the applicable rate schedule.

8.3. The Client is obliged to: comply with these Terms; provide accurate data during Registration and Identification; not share Authorisation Data or grant third parties access to their Wallet; notify the Administrator immediately upon discovering any unauthorised Operation or loss of Authorisation Data (all Operations carried out using valid credentials prior to such notification are deemed to have been authorised by the Client); maintain up-to-date security software on any device used to access the System; cooperate with any investigation and provide identity verification or other information upon request; not use the System for illegal purposes or Prohibited Activities; independently account for and pay taxes on income derived from Operations; and not maintain a negative Wallet balance.

8.4. The Administrator is obliged to: establish these Terms and monitor Client compliance; provide Clients with access to the System; send transaction notifications to the Client's registered email address; and maintain a support service.

9. Liability

9.1. In the event of failure to perform or improper performance of obligations under these Terms, the Parties shall be liable in accordance with these Terms and the laws of the Kingdom of Bahrain.

9.2. For any delay by the Client in fulfilling a monetary obligation under these Terms, the Client shall pay a penalty of 0.1% of the outstanding amount per day of delay, payable within 3 business days of receiving the Administrator's demand. Charging this penalty is a right, not an obligation, of the Administrator.

9.3. The Client agrees to indemnify the Administrator for any losses arising from payments collected from the Administrator due to the Client's violations of applicable law.

9.4. The Client is fully responsible for all Operations recorded on their Wallet, including those carried out using bank payment cards, and for any Operations performed by employees, managers, subcontractors, agents, authorised persons, affiliates, or any other person who has accessed the Client's Wallet.

9.5. The Client is solely responsible for compliance with applicable law in their jurisdiction.

9.6. Amounts owed by the Client to the Administrator may be debited from the Client's Wallet without prior notice. If the Wallet balance is insufficient, the Administrator may demand immediate replenishment or initiate debt recovery proceedings.

9.7. The Client agrees not to take any actions that mislead others regarding the Administrator's services or that damage the Administrator's reputation — including impersonating the Administrator, falsifying System data (transaction numbers, wallet details, or any other information), or creating clone sites. In case of violation, the Administrator reserves the right to block accounts, freeze funds pending resolution, and pursue legal action in courts of competent jurisdiction.

10. Limitation of Liability

10.1. The Administrator is not liable to the Client for losses arising from: the Client sharing their data with or granting Wallet access to third parties; malware present on the Client's devices; unlawful actions by third parties, including misuse of the Client's Registration credentials or email; disputes between Clients regarding transactions conducted through the System; or claims by tax, regulatory, or law enforcement authorities in respect of the Client's transactions.

10.2. The Administrator is not liable for temporary System unavailability, hardware or software failures, or interruptions to power, communications, or third-party services beyond the Administrator's control, nor for any resulting losses to the Client.

10.3. The Administrator is not liable for: the Client's inability to access the necessary software or hardware; consequences arising from the Client providing inaccurate or outdated contact details; losses resulting from the Client's failure to complete Identification; third-party payment services used by the Client; or losses resulting from the Client's failure to review the current version of these Terms.

10.4. Where Authorisation Data is lost, the Wallet is blocked, or any other event occurs that cannot be resolved without identifying the Client, the Administrator bears no liability to an Unidentified Client for resulting losses or the inability to use the Wallet.

10.5. The Administrator is not responsible for losses to the Client or third parties arising from: a Wallet lock; inability to carry out Operations regardless of cause; incorrectly submitted Operation instructions; erroneous instructions for crediting or debiting Funds; the Client's failure to follow payment procedures; compliance by either Party with legal or regulatory requirements; or the Client's breach of these Terms or any related agreement.

10.6. In any event, the Administrator's total liability to the Client shall not exceed the total fees charged to that Client in the preceding three-month period.

10.7. The Administrator is not liable for any indirect losses, including lost profits, loss of income, contracts, customers, data, or reputational damage.

10.8. The Client agrees to defend, indemnify, and hold harmless the Administrator and its affiliates from any claims, expenses, fines, or penalties (including legal costs) arising from the Client's breach of these Terms, applicable law, or misuse of the System. This obligation survives termination of the relationship between the Parties.

10.9. The Administrator does not work with shell banks. A shell bank is defined as a bank registered in a jurisdiction where it has no physical presence and which is not affiliated with any regulated financial institution.

10.10. KYC and AML procedures — including Politically Exposed Persons (PEP) screening and Source of Wealth / Source of Funds verification — are carried out by our partner Sum & Substance Limited (Sumsub).

11. Communications

11.1. Upon Registration, the Client must provide the Administrator with accurate contact details for notifications and correspondence.

11.2. By default, the Client is notified of Transactions by email to the address provided during Registration.

11.3. The Client may contact the Administrator at any time by submitting a message or calling the Support Service during its operating hours.

11.4. The Administrator may notify the Client of material changes to the System via email or news posts in the Client's personal area on the Site.

12. Security

12.1. The Client must take all reasonable steps to keep their Password secure and must not disclose it to anyone.

12.2. The Client bears full responsibility for all risks associated with internet use when interacting with the Administrator or other parties through the System.

12.3. The Client assumes full responsibility for the security of their Authorisation Data and all risks associated with its loss or compromise.

12.4. To protect the Wallet and prevent unauthorised or fraudulent use, the Administrator may take any action permitted by applicable law and these Terms, including locking the Wallet.

13. Term and Termination

13.1. The Client may unilaterally terminate these Terms provided that: all obligations to the Administrator and any third parties interacting through the System have been fulfilled; and the Administrator has received written notice of termination at least 30 calendar days in advance.

13.2. The Administrator may terminate these Terms with respect to a particular Client unilaterally, with written notice at least 3 days in advance.

13.3. From the date of termination, no further transfer instructions will be accepted on behalf of the Client, and all outstanding fees become immediately payable. Monetary obligations existing prior to termination remain in force until fully discharged.

13.4. The Administrator may withhold the Client's Funds until all obligations are fully settled and may apply those Funds toward outstanding amounts owed.

14. Amendments

14.1. The Administrator may amend these Terms at any time.

14.2. The updated Terms are published on the public section of the Site.

14.3. Continued use of the System after amendments take effect constitutes the Client's unconditional acceptance of the updated Terms.

15. Governing Law and Jurisdiction

15.1. All Services are provided in accordance with applicable law. If the Client's use of the System or Services is contrary to the laws of their jurisdiction, they must not use the Services. The Client is solely responsible for compliance with the laws of their jurisdiction and for any losses resulting from non-compliance.

15.2. These Terms are governed by the laws of the Kingdom of Bahrain.

16. Dispute Resolution

16.1. All disputes arising from the use of the System under these Terms shall be resolved through negotiation.

16.2. A dispute is formally initiated by one Party submitting a written claim to the other. Claims are reviewed within 30 days of receipt. If the dispute cannot be resolved through this procedure within that period, either Party may refer the matter to the courts at the Administrator's place of registration.

17. Force Majeure

17.1. Neither Party shall be liable for delays or failures in performance caused by circumstances beyond their reasonable control. A Party affected by force majeure must notify the other Party within 10 days of the occurrence of such circumstances.

18. General Provisions

18.1. The Client may not assign their rights or obligations under these Terms to any third party without the prior written consent of the Administrator.

18.2. If any provision of these Terms is held invalid by a court or rendered invalid by a change in applicable law, the remaining provisions shall continue in full force.

18.3. The Administrator may amend these Terms to bring them into compliance with new legislation.

18.4. All appendices to these Terms form an integral part thereof.

Appendix I — Prohibited Goods, Works, and Services

The following categories are prohibited on the Cryptorg platform:

• Weapons, ammunition, self-defence equipment, and replicas of firearms or bladed weapons.
• Narcotic and equivalent substances, plants, their precursors, or any materials or instructions for their production.
• Prescription medicines and medical products, or raw materials and instructions for their production.
• State awards or official insignia.
• Identity documents and government-issued documents, including forgeries, and any materials related to the creation or procurement of false identity or government documents.
• Uniforms of state bodies.
• Specialist equipment associated with police or law enforcement.
• Electronic equipment prohibited in the relevant territory.
• Devices for picking or bypassing locks.
• Information containing personal data or data that could be used for illegal purposes, including spam.
• Information containing state, banking, or commercial secrets.
• Intellectual property whose sale infringes copyright, related rights, trademarks, or patents.
• Information that violates privacy or damages the honour, dignity, or business reputation of individuals or legal entities.
• Intangible information not recorded on any material medium (ideas, methods, principles, etc.).
• Objects of archaeological heritage.
• Items or services that violate public morality, including but not limited to child pornography, Nazi memorabilia, escort services, and prostitution.
• Equipment for organising or conducting gambling.
• Items with removed or altered serial numbers.
• Malicious software.
• Goods or services that incite unlawful acts, including propaganda of social, racial, religious, or ethnic hatred, discrimination, violence, or terrorism.
• Perishable goods.
• Counterfeit goods.
• Equipment intended to circumvent copyright protection or regional restrictions on digital content.
• Dangerous goods, including items containing explosive, toxic, or radioactive materials.
• Instructions for the manufacture of explosive, pyrotechnic, or incendiary substances or devices.
• Human organs or remains.
• Goods or services with no consumer value.
• Auction or trading services that exclude the transfer of goods or services with genuine consumer value.
• Financial or payment instruments whose accounting systems do not provide proper owner identification for the purposes of combating illegal trade, financial fraud, or money laundering.
• Asset management and investment services without the required licences, and any intermediary activity facilitating the transfer of funds between parties engaged in transactions prohibited by this list.
• Objects of cultural heritage.
• Advertising or promotional services for any goods, works, or services listed in items 1–31 above.

For questions regarding these Terms, please contact us: [email protected]

Last updated: June 2026