Privacy Policy
Terms and Conditions of Use for the Transfer Exchanger Platform
Last updated: January 1, 2026
Please read these terms carefully before using the service. By clicking "Accept" or accessing the platform, you
agret to be bound by all the terms and conditions specified in this agreement.
1. Definitions
Under these Terms and Conditions, including any annexes, policies, and other related agreements, the following terms and conditions shall have the meanings defined below, unless the context otherwise requires:
1.1 Company means [specify name of the legal entity owning the platform] and shall include its affiliates, subsidiaries, agents, representatives, directors, employees, and advisors, whether currently or in the future.
1.2 Transfer exchanger (or "Platform") means the technological operating system owned or maintained by the Company, whether it be a website, mobile application, application programming interface (API), or any other electronic channel provided by the Company to support digital asset transactions and any other related services.
1.3 User means any natural or juristic person who has completed the registration process and been approved to open an account on the Transfer exchanger platform, whether to access or receive information. or to conduct any transactions as specified by the company.
1.4 Account means an electronic account provided by the company specifically for each individual user for use in logging in, checking asset balances, sending transaction orders, and keeping records of usage history on the platform.
1.5 Digital Asset means cryptocurrency and digital tokens,
including any other electronic data unit created on an electronic system or network with the purpose of being used as a medium of exchange or to determine any rights as supported by the platform.
1.6 Fiat Currency means currency issued by the government or central bank of any country,
which is legally recognized as acceptable for debt payment (e.g., Thai Baht, US Dollar), but does not include
Digital Assets
1.7 Digital Asset Wallet means the storage system or address used for receiving, sending, and safeguarding the confidentiality of a password (Private Key) for transactions involving digital assets of the user.
1.8 Transaction means the purchase, sale, exchange, transfer, receipt of transfer, or any other action
involving digital assets or currency conducted through the Transfer exchanger system.
1.9 Order means the expression of intent by the user through the platform's electronic system to
intend to conduct a specific transaction under the conditions, price, and quantity specified or accepted by the user.
1.10 Know Your Customer/Code of Decision (KYC/CDD) means the process of knowing your customer and verifying to ascertain the facts about the customer, including identification, verification of data accuracy, and risk assessment.
and verification of individual status in accordance with company policy and international standards.
1.11 Personal Data means information about an individual which makes it possible to identify that individual, whether directly or indirectly, as defined in the Personal Data Protection Act of Thailand.
1.12 Credentials means username, password, one-time password (OTP), two-factor authentication (2FA), biometrics, or any other information used to verify the right to access
an account.
1.13 Intellectual Property (Intellectual Property) means all copyrighted works, patents, trademarks, trade names, trade secrets, algorithms, source code, screen designs, and any other intellectual property rights, whether registered or not, relating to the Transfer exchanger.
1.14 Force Majeure means any event that may occur beyond the control of the Company, including but not limited to natural disasters, war, riots, strikes, declarations of emergency, failures of telecommunications or power networks, widespread cyberattacks, or changes to government regulations that affect the provision of services.
1.15 Manifest Error means an error, omission, or representation of pricing that is clearly inaccurate compared to the market price, whether caused by a defect in the computer system, data from a third party, or company employees.
1.16 Fork means a change in the rules or software of the blockchain network that results in...
This may lead to the splitting of the network into multiple paths and may result in the creation of new types of digital assets.
1.17 Network Event means any event occurring on the underlying blockchain network of the digital asset that is beyond the company's control, such as a 51% attack, double spending, or significant delays in transaction confirmation on the blockchain.
1.18 Applicable Law means all acts, decrees, codes, ministerial regulations, announcements, regulations, or orders of any competent authority in Thailand.
1.19 Business Day means the day the company is open for normal business operations, excluding Saturdays, Sundays, and public holidays as announced by the company.
1.20 Third-Party Services means services or applications operated by persons other than the company, which may be connected to or displayed on the platform to facilitate users.
Section 2. Risk notification and risk acceptance assurance.
2.1 General Risk Characteristics of Digital Assets Users acknowledge and accept that transactions involving digital assets through the Transfer exchanger platform carry the highest level of risk (High Risk), which may lead to the loss of all of the user's investment or assets. Users agree to accept the following risks:
2.1.1 Price Volatility: The price and value of digital assets fluctuate wildly and rapidly, which may result from changes in supply and demand, global market conditions, speculation, or news that affects confidence. The value may decrease significantly or become zero in a short period of time.
2.1.2 Liquidity Risk: In some market conditions, certain types of digital assets may lack liquidity, making it impossible for users to buy, sell, or exchange them at the desired price, or they may not be able to do so at all. Transactions can be made immediately.
2.1.3 Lack of Underlying Infrastructure: Most digital assets do not have tangible assets backing their value and
are not legal tender. Their value therefore depends solely on the satisfaction and acceptance of holders within the system.
2.2 Technological and Blockchain Network Risks: Users acknowledge and agree that the company has no control over the underlying blockchain network of digital assets and agree to accept the following risks:
2.2.1 Network Events: Including but not limited to network forks, system attacks (51%), or protocol glitches, which may result in transaction disruptions or the loss or alteration of the value of digital assets held by the user.
2.2.2 Transaction Confirmation Delays: Transactions on the blockchain require network confirmation, the duration of which may be uncertain. 1.2.3 Irreversibility: Once a transaction is confirmed and recorded on the blockchain, it cannot be canceled, modified, or retrieved under any circumstances. Errors in providing a wrong digital asset wallet address are the sole responsibility of the user.
2.3 Security and Cybercrime Risks: Users are responsible for maintaining the security of their accounts and login information themselves, acknowledging the following risks:
2.3.1 Unauthorized Access: If login information, passwords, or two-factor authentication (2FA) are lost or stolen by third parties (Phishing, Malware), the company will not be liable for any losses incurred from transactions conducted through that account.
2.3.2 Risks from the User's Device: Malfunctions or virus infections on the computer or
1. Mobile phone usage by the user, which may lead to data interception or unauthorized transfer of assets, is a risk borne by the user.
2.4 Operational and System Stability Risks
2.4.1 System Outage: The Company may need to temporarily suspend services for maintenance or technical malfunctions beyond its control, which may prevent users from sending orders or checking asset balances during that time.
2.4.2 Manifest Error: In the event that the system displays an obvious error in price, data, or asset balance due to technical reasons, the Company reserves the right to cancel or correct such transaction to reflect the true situation. The user agrees to waive any claim for damages arising from such action.
2.5 Legal and Tax Risks
2.5.1 Changes in Legal Requirements: Laws and regulations concerning digital assets in the country.
Thailand's regulations are subject to change at any time, which may affect the rights to ownership or the ability to provide services of the platform in the future.
2.5.2 Tax Liability: Users are solely responsible for calculating, reporting, and paying any taxes arising from transactions on the platform as required by Thai law. The Company is not obligated to withhold taxes at source or provide tax advice to users.
2.6 Disclaimer of Protection
2.6.1 Not a Financial Institution: Users acknowledge that the Company is not a financial institution under the Depositary Institutions Act, and that assets deposited with the Company are not subject to any liability protection measures. "Not covered" by the Deposit Protection Institution.
2.6.2 As-Is Basis Service: The Company provides the Transfer exchanger platform "as is" and to the extent available, without any express or implied warranty regarding returns, success, or the accuracy or completeness of market information.
2.7 User's Risk Acceptance Declaration: By agreeing to this Agreement, the User certifies to the Company that:
The User has read, understood, and fully accepts all risks stated above.
The User has sufficient knowledge, experience, and financial standing to bear the risk of losing all assets.
The User makes its own decisions to conduct transactions (Self-Directed Transaction) and does not rely on advice or direction from the Company in making investment decisions.
The User agrees not to claim any damages from the Company, its directors, or its employees for any loss or damage incurred. Due to volatility.
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Section 3. User qualifications and account registration.
3.1 General Qualifications of Individual Users Applying for Registration to Access the Transfer
exchanger Platform Users must meet the following criteria and maintain them for the duration of their user status:
3.1.1 Legal Capacity: Users must be individuals at least 20 years of age (having reached legal maturity according to the Civil and Commercial Code of Thailand) and must not be incapacitated, quasi-incapacitated, or have been placed under court-ordered receivership or declared bankrupt.
3.1.2 Prohibited Person Status: Users must not be listed on any of the designated lists of persons or persons at high risk of money laundering or financing of terrorism, as announced by the Anti-Money Laundering Office (AMLO) or any other regulatory agency. 3.1.3 Residence: The service user must not be a person whose nationality or residence is in a country where the company has prohibited the use of the service (Prohibited Jurisdictions) or a country with laws prohibiting transactions related to digital assets.
3.2 Qualifications of Legal Entities: In the event that the service user wishes to register in the name of a legal entity, such legal entity must have the following qualifications:
3.2.1 Registration: Must be a legal entity legally registered in the country of registration,
and have the authority to act in accordance with the objectives of conducting transactions related to digital assets.
3.2.2 Authority: The person registering on behalf of the legal entity must be authorized to act on behalf of the legal entity as specified.
In the certificate of registration or as a legally authorized representative, and entering into this agreement must not violate the regulations or resolutions of the board of directors of that legal entity.
3.2.3 Ultimate Beneficiary: The legal entity must be prepared to disclose information on the shareholding structure and identify the
ultimate beneficiary (Ultimate Beneficial Owner) according to the criteria set by the company.
3.3 Registration and Information Provision Process: In applying for an account, the user agrees and certifies that they will comply with the procedures set by the company as follows:
3.3.1 Accuracy of Information: The user certifies that all information, documents, and evidence presented to the company, whether personal information, contact information, or supporting identification documents, are true, complete, and in accordance with all laws.
3.3.2 Updating Information: In the event of any changes to information previously provided to the company, the user has the duty to promptly notify and update such information through the platform's system. If there is a delay in
3.3.2 Data Modification Causing Damage: The service user agrees to be solely responsible for such damage.
3.3.3 Consent to Verification: The service user agrees to allow the Company (or a third party authorized by the Company)
to verify the accuracy of the information and documents received, whether through the database of a government agency or any other verification as deemed appropriate by the Company for security purposes.
3.4 Know Your Customer (KYC/CDD) Verification: The Company has sole discretion to determine the level
of Identity Verification. The service user has the following responsibilities:
3.4.1 Submission of Additional Documents: In the event that the Company has doubts about the source of income, source of funds, or the accuracy of
transactions, the service user agrees to provide additional supporting documents as requested by the Company within the specified timeframe.
3.4.2 Risk Assessment: The Company reserves the right to rank the risk of the service user. If the service user is assessed as being in the high-risk group, the Company has the right to... Implementing stricter terms of use or limiting transaction amounts.
3.5 Account Privacy and Security
3.5.1 Personal Account Usage: Users agree that the account they are granted access to is a personal account. It is prohibited to buy, sell, rent, lend, or transfer access to the account to any other person for any reason whatsoever.
3.5.2 Password Confidentiality: Users are responsible for strictly maintaining the confidentiality of their username, password, one-time password (OTP), and private key. Any transactions that occur after logging in with correct login information shall be considered transactions performed by the user themselves and shall be binding.
In accordance with all applicable laws.
3.5.3 Reporting Abnormalities: If a user detects or has reasonable grounds to suspect that their account has been compromised or that a security vulnerability has occurred, the user must immediately notify the company through the support channel so that the company can temporarily suspend the account.
3.6 Company's Right to Refuse, Suspend, or Cancel Registration: The company reserves the absolute right to take the following actions without having to provide reasons or be liable for any damages to the user:
3.6.1 Refusal to Open an Account: The company has the right to refuse a registration request if it finds that the user does not meet the qualifications or has a history of involvement in illegal activities.
3.6.2 Temporary Suspension of Use: In the event that abnormal usage behavior is detected or for the purpose of security verification, the company has the right to immediately suspend access to the user account (Freeze Account).
3.6.3 Permanent Account Closure: If a user violates the terms of this section or provides significantly false information,
the company has the right to cancel the user account and notify the user.
Section 4. Scope of Service Use and Prohibited Actions (Usage and Prohibitions)
4.1 Scope and Nature of Services The Company agrees to provide the Transfer exchanger platform as a technological tool to facilitate users in conducting transactions involving digital assets, including but not limited to placing buy/sell orders, exchanging, depositing, withdrawing, and checking transaction history, subject to the following conditions:
4.1.1 Independent Decision: Any transaction entered into on the platform is considered an independent decision by the user (Self-Directed Transaction). The Company acts only as a system provider and technical liquidity provider.
4.1.2 Transaction Completeness: Users acknowledge that all orders confirmed and executed through the Company's system are final and cannot be canceled, revoked, or changed (Final and Irrevocable).
4.1.3 Technical Limitations: The Company reserves the right to Minimum transaction volume, maximum transaction limit, or service fee will be determined as deemed appropriate by the company and announced on the platform.
4.2 Transaction Order Procedures and Conditions: By using the service, users agree to comply with the following order submission guidelines:
4.2.1 Accuracy of Destination Information: When transferring or withdrawing digital assets to an external digital asset wallet,
the user is responsible for verifying the accuracy of the address and network to match the type of asset. The company will not be responsible for recovering the assets under any circumstances due to errors in information identification.
4.2.2 Balance Verification: The system will only process the order if the user has sufficient digital assets or funds in their account to complete the transaction, including any associated fees. If there is insufficient quantity, the order will be automatically suspended.
4.2.3 Payment and Delivery: A transaction will be considered complete only when the information has been fully recorded in the platform's accounting system
or on the relevant blockchain network.
4.3 General Prohibitions: The user agrees and warrants not to engage in any of the following actions, directly or indirectly:
4.3.1 Use of False Information: It is prohibited to use the information, name, address, or documents of another person to impersonate them or to falsify the source of assets used in transactions on the platform.
4.3.2 Illegal Transactions: It is prohibited to use the platform as a channel for money laundering, terrorism financing, transactions involving narcotics, gambling, illegal goods, or any other activities. That is contrary to public order or good morals.
4.3.3 Price manipulation and unfair behavior: It is prohibited to place buy or sell orders in a manner that may mislead the general public about the price or trading volume (Market Manipulation), such as placing buy or sell orders in a matched manner (Wash Trading) or price manipulation (Pump and Dump), even if the platform is an independent system.
4.4 Technical prohibitions and system violations (Technical Prohibitions) To maintain the stability of the system, users must not
do the following:
4.4.1 Unauthorized access: It is prohibited to attempt to hack, intrude, or access any part of the platform or
4.4.1 Unauthorized Network Interference: It is prohibited to use any software, algorithms, bots, or automated tools to interfere with,
extract data (data scraping), or burden the system beyond the normal usage of a typical individual.
4.4.2 Reverse Engineering: It is prohibited to copy, modify, translate, edit, or reverse engineer the source code, screen design, or any other intellectual property of the company.
4.5 Company's Right to Stop and Intervene: Insofar as it does not violate the law, the company reserves the right to
take the following actions to prevent damage:
4.5.1 Freezing Assets: In the event that there is reasonable suspicion that assets in the account were obtained illegally or are related to crime, the company has the right to freeze such account and assets for investigation without prior notice.
4.5.2 Cancellation of Abnormal Transactions: If any transaction occurs due to a system error (bug) or due to the exploitation of an unwanted technical vulnerability, the company reserves the right to cancel the transaction. The Company reserves the right to cancel and adjust asset balances to their normal state before the error occurred.
4.5.3 Termination of Individual Services: The Company has the right to temporarily or permanently suspend the service of a user if it is found that they have violated the prohibitions under clauses 4.3 or 4.4. The Company shall not be liable for any lost profits or business opportunities of the user.
4.4 Liability and Indemnification: If a user violates any prohibition specified in this agreement,
resulting in damage to the Company, its directors, employees, or other users, whether it be damage to property, reputation, or fines imposed by government agencies, the user agrees to be fully liable to compensate the Company for all actual damages incurred, including reasonable court fees and attorney's fees.
Section 5. Service Fees and Settlement
5.1 Fee Payment Agreement The User agrees and acknowledges that, upon accessing the service or conducting any transactions on the Transfer exchanger platform, the User is obligated to pay a service fee to the Company,
according to the rates and conditions stipulated in this Agreement. Such fee shall be considered compensation for providing
operating systems, technical liquidity maintenance, and facilitating asset matching or exchange.
5.2 Standard Fee Rate The Company will charge a service fee at a rate of 10% (10%) of the total value of all transactions occurring on the platform, with the following enforcement details:
5.2.1 Exchange Transactions: When placing a buy, sell, or exchange order for one type of digital asset with another type of digital asset or with another type of currency, the Company will calculate a fee of 10% of the total amount of assets traded. 5.2.1 Transfer Transactions: In the event of asset transfers between user accounts, or from an external digital asset wallet into the system, or from the system to the outside, the company has the right to charge a fee at a rate of
10% of the value of the transferred asset.
5.2.2 Calculation Criteria: The fee calculation will be based on the market price on the platform at the time the transaction is confirmed, or on the number of units of digital assets specified in the transaction order, whichever is applicable.
5.3 Automatic Fee Collection and Deduction Method: For the convenience and speed of service, the user agrees
and authorizes the company to automatically collect and deduct fees. The following procedures will be followed:
5.3.1 Net Settlement: The company has the right to deduct a 10% fee from the amount of assets that the user will receive or will automatically process the transaction immediately upon completion. The company will display the details of the net amount of assets received by the user after deducting the fee in the transaction history.
5.3.2 Reserve: In some cases, the system may temporarily hold an amount equal to the transaction value,
plus the 10% fee, to ensure that the user has sufficient assets to pay the fee before the transaction is completed. Operation Completed
5.4 Third-Party Fees and Other Related Expenses The User acknowledges that the 10% fee of
the Company is solely for the platform service fee and does not include the following expenses:
5.4.1 Network/Gas Fee: Fees for recording transaction data on the blockchain (Network Fee)
or Gas Fee) charged by the blockchain network system are the responsibility of the User separately from
the Company's fees.
5.4.2 Bank Fees: In the case of deposits or withdrawals of fiat currency, international money transfer fees, or commercial bank service fees (if any) are the responsibility of the User.
5.5 Taxes and Legal Obligations
5.5.1 Inclusion or Separation of Taxes: The 10% fee rate specified herein shall be considered as
excluding Value Added Tax (VAT) or any other applicable taxes. 5.5.1.1 Tax obligations of the user: The user is responsible for reporting income information and paying capital gains tax to the Revenue Department themselves. The company is not obligated to provide advice or act on behalf of the user in this matter.
5.5.1 Tax obligations of the user: The company reserves the right to adjust or change the service fee rates at its discretion, considering economic conditions, operating costs, or company policy, subject to the following conditions:
5.5.1 Tax obligations of the user: The company will notify users of any changes to the new fee rates via the website, application, or pre-registered email.
5.6.2 Impact of continued use: If a user continues to access the platform or conduct transactions after the date of the fee change, 5.7 Non-Refundable Policy: Once a transaction has been processed and fees have been deducted, the user agrees and acknowledges that such fees are "non-refundable" under any circumstances,
regardless of whether the transaction was due to an error on the user's part or the user wishes to cancel the transaction later, except in cases where the error is directly caused by the company's operating system and can be clearly proven.
5.8 Fee Disputes: In the event of a dispute regarding the amount or calculation of fees, the user
must notify the company within 15 days of the transaction date through the customer support channel. If this period is exceeded, the user will be deemed to have accepted the accuracy and completeness of the fees for that transaction in all respects.
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Section 6. Limitation of Liability and Disclaimers
6.1 As-Is and As-Available Basis Services: Users agree and acknowledge that the Company provides the Transfer exchanger platform, including related content, data, and other services, "as is" and "as available." The Company makes no express or implied warranties or guarantees regarding the following:
6.1.1 Continuity: The Company does not guarantee that the use of the platform will not be interrupted, disrupted, or free from technical errors at all times.
6.1.2 Accuracy of Market Data: The Company does not guarantee the accuracy or timeliness of the price data, charts, or statistics displayed on the platform, which may be delayed due to database systems or internet networks.
6.1.3 Security Against Threats: While the Company uses appropriate security standards, it does not guarantee that the platform will be free from viruses, malware, or other elements that may damage the user's equipment or data.
6.2 Exclusion of Liability for Technical and Network Damages: The Company, its directors, employees, and affiliates shall not be liable for any damages, losses, or expenses for technical and network damages. Whether directly or indirectly arising from:
The following events:
6.2.1 Blockchain Network Events: Damage caused by network forks, 51% attacks, smart contract vulnerabilities, or any event affecting the underlying digital asset structure that is beyond the company's technical control.
6.2.2 Third-Party Disruptions: Damages resulting from delays or errors by commercial banks, telecommunication network providers, cloud providers, or external digital asset custody providers used by the company.
6.2.3 Manifest Errors: The company will not be liable for losses or damages resulting from price deviations from actual market conditions due to calculation system defects or erroneous price data obtained from external sources.
6.3 Exclusion of Liability Arising from User Actions: The company will not be liable for property losses.
Digital assets or user currency resulting from the following circumstances:
6.3.1 Confidentiality of Personal Information: Damage caused by the user disclosing or making known to others their name,
username, password, private key, or two-factor authentication (2FA), whether intentionally or through negligence.
6.3.2 Erroneous Transaction Endpoint: Transfer of digital assets to an incorrect address or identification of a network that does not match the platform's specifications, resulting in irrecoverable loss of assets.
6.3.3 Communication Equipment: Damage caused by the user's computer or mobile phone being compromised by phishing or controlled by unwanted programs (remote access tools).
6.4 Limitation of Liability for Consequential Damages and Expected Profits: To the maximum extent permitted by Thai law,
the Company will not be liable to the user or third parties for any damages resulting from the following circumstances. For the following types of damages:
Loss of Profit
Loss of Business Opportunity
Loss of Data
Loss of Investment or Expected Futures Revenue
Indirect Damage, Contingent Damage, or any Special Damage, even if the Company has been notified of the possibility of such damage occurring.
6.5 Limitation Cap In the event that a court with jurisdiction determines that the Company is liable to the User
due to a breach of contract or any tort caused by the Company's negligence (except gross negligence or fraudulent act), the parties agree that the "Company's maximum liability" will be limited to
no more than the amount of fees actually received by the Company from that User during the last 3 (three) months prior to the claim.
Only in the event of such claim shall the Company be liable for any delay or inability to fulfill contractual obligations
resulting from force majeure events, including but not limited to natural disasters, riots, war, terrorism, disease outbreaks, government declarations of emergency, widespread power or internet disruptions nationwide, or changes in laws and government orders that prevent the Company from providing normal services.
6.7 Time Limit for Claims The User agrees that any claim arising from or related to the use of the Transfer exchanger platform must be made within 6 (six) months from the date of the event giving rise to the dispute. After this period, the User shall be deemed to have waived their right to claim damages or compensation. 6.8 Indemnity by the User. The User agrees to defend, indemnify, and protect the Company, its directors, and employees from any liability, claims, damages, or expenses (including reasonable attorneys' fees) arising from:
The User's breach of these Terms and Conditions;
Usage of the Service that is illegal or infringes on the rights of a third party;
Unauthorized access to the User's account by another person using the User's login information.
To ensure the content in this section is detailed, covers the risks, and is approximately two A4 pages long, in accordance with professional contract drafting standards.
Section 7. Suspension, Termination, and Cancellation of Services and Contracts.
7.1 Company's Right to Temporarily Suspend Services (Account Suspension/Freeze) The Company reserves the exclusive and sole right to suspend access to user accounts or restrict the ability of users to conduct transactions (collectively referred to as "Account Freeze") without prior notice and without liability for any damages in the following cases:
7.1.1 For system security: When the Company discovers or has reasonable grounds to suspect unauthorized access to user accounts, or
an attempt to hack the system, or a breach of password confidentiality.
7.1.2 Investigation of Abnormal Behavior: When the Company detects trading or asset transfer behavior that is
abnormal, inconsistent with the general purpose of the platform, or constitutes manipulation. 7.1.2 Price manipulation or order creation
7.1.3 Compliance with laws and government orders: When the Company receives an order from an investigating officer, court, or government agency
with authority under Thai law to suspend the use or freeze assets within the account.
7.1.4 Ownership disputes: In the event that a third party reports and provides preliminary evidence that assets in the user's account were acquired illegally, or there is a dispute regarding the ownership of such assets.
7.2 Account termination and contract termination by the Company (Termination for Cause) The Company has the right to terminate the user account
and terminate this agreement with immediate effect, and may permanently block access to the platform in the following cases:
7.2.1 Serious breach of the agreement: The user violates the terms of the agreement. 7.2.1 Defective Information: Information or documents provided by the user during registration or use of the platform are false, inaccurate, or intentionally conceal material facts.
7.2.2 Involvement in Illegitimate Activities: The company has reasonable grounds to believe that the user is using the platform as a tool for money laundering, financing terrorism, or other economic crimes.
7.2.3 Cessation of Business Operations: The company intends to terminate the Transfer exchanger platform service, in whole or in part, and will notify the user in advance for a period deemed appropriate by the company.
7.3 Termination of Service by User: The user has the right to request account cancellation and contract termination at any time. The following conditions must be met:
7.3.1 Cancellation Notification: A cancellation request must be submitted through the platform's system or by contacting customer support according to the procedures specified by the company.
7.3.2 Outstanding Obligations: Account cancellation can only be done when there are no outstanding transactions in the system and the user must
pay any fees or debts (if any) to the company in full before closing the account.
7.4 Handling of Remaining Assets: In the event of account cancellation or closure,
whether by the company or the user, the parties agree to handle the assets as follows:
7.4.1 Normal Withdrawal of Assets: The user has 30 (thirty) days from the date of notification of termination (except in cases of suspension due to reasons under clauses 7.1.3 or 7.2.3) to withdraw or transfer digital assets and remaining funds
from the system. The user must still pay... 7.4.1 A fee of 10% will be charged as usual.
7.4.2 Seizure of Assets in Case of Fraud: If the account closure is due to suspicion of illegal activity, the Company has the right to
retain the asset until further orders are received from the relevant authority or until the dispute is finalized.
7.4.3 Unclaimed Assets: If the user fails to withdraw the asset within the specified period, the Company has the right to
charge a maintenance fee on the remaining asset at a rate determined by the Company until
the asset is depleted or a request for its return is made.
7.5 Dormant Account: If an account has no transactions (purchase, sale, transfer,
or withdrawal) for more than 12 (twelve) months, the Company has the right to consider taking the following actions:
Temporarily suspend the account for security reasons.
Charge a monthly maintenance fee for the dormant account, deducted from the remaining asset balance in the account.
If the remaining asset balance is zero, the company reserves the right to close the account without prior notice.
7.6 Death or Dissolution of a Legal Entity: In the event that the user dies or the legal entity ceases to exist according to law,
the company will immediately suspend transactions in that account upon notification and will only allow a person with legal rights (e.g., an executor or liquidator) to manage the assets after providing proper and complete Thai legal evidence to the company's satisfaction.
7.7 Effects of Termination of Contract (Survival of Terms): Even if the contract is terminated, some terms and conditions will remain binding on the parties, including the terms regarding the limitation of liability (Clause 6), outstanding fees (Clause 5), compensation for damages, confidentiality of personal data, and applicable laws including dispute resolution.
Section 8. Personal Data Protection
8.1 Collection of Personal Data Users acknowledge and agree to allow the Company to collect, use, and disclose their personal data for the purpose of providing services on the Transfer Exchanger platform, identity verification, and compliance with applicable laws. The data collected by the Company includes, but is not limited to:
8.1.1 Identification information: Full name, national identification number, passport information, date of birth, facial photograph (Biometrics) for Liveness Check.
8.1.2 Contact information: Registered address, current address, email, telephone number. and social media accounts.
8.1.3 Technical and transactional data: IP address, login history, cookies, digital asset wallet address, transaction history, and 10% fee information.
8.2 Purposes of data processing The Company will process personal data on a lawful basis as follows:
8.2.1 For contractual compliance: To open accounts, process transactions, and provide customer support.
8.2.2 For legal compliance: To investigate and prevent money laundering (Anti-Money Laundering) and fraud, in which case the Company may need to disclose information to government agencies when requested by law.
8.2.3 For legitimate interests: To improve the efficiency of the platform, analyze data to prevent cyber attacks, and maintain the overall system security.
8.3 Disclosure of information to third parties The Company may disclose personal information of third parties. The company may provide services to individuals or entities as follows, as necessary:
External service providers (Outsource), such as cloud server providers, Know Your Customer (KYC) service providers.
Or legal counsel.
Law enforcement agencies in Thailand, such as the Royal Thai Police or agencies with authority by court order.
In the event of organizational restructuring, mergers, or transfer of rights in the platform, the company may transfer personal data to the transferee under the same data protection conditions.
8.4 Rights of the service user as a data subject under the Personal Data Protection Act (PDPA) of Thailand. The service user has the following rights:
The right to access and request a copy of their personal data.
The right to request correction of inaccurate data or addition of incomplete data.
The right to request the deletion or destruction of data (Right to be Forgotten) after the period stipulated by law. 8.5 Data Retention Period: The Company shall retain the personal data of users for as long as they remain users and shall continue to retain it for a further period of 10 (ten) years from the date of termination of the relationship (closure of the account) for the purpose of retrospective auditing in accordance with international standards for the prevention of financial crimes and accounting.
Section 9. Governing Law and Dispute Resolution
9.1 Governing Law: These Terms and Conditions, including all actions occurring on the Transfer Exchanger platform, shall be governed by and interpreted in accordance with the "Laws of Thailand" in all respects, without applying the principles of Conflict of Laws.
9.2 Dispute Resolution: In the event of any dispute, disagreement, or claim arising from or related to this Agreement, the parties agree to proceed as follows:
9.2.1 Peaceful Negotiation: The parties will first endeavor to negotiate a mutually fair resolution within 30 days from the date one party notifies the dispute in writing.
9.2.2 Jurisdiction: If a resolution cannot be reached through negotiation, the parties agree to allow the court with jurisdiction in Thailand to resolve the matter.
(Specifically, the court in Bangkok or the district where the company's headquarters are located) is the sole authority to
consider and decide on such disputes.พ
Section 10. General Provisions (Miscellaneous)
10.1 Severability of the Agreement: If any text or part of this Agreement becomes void, invalid, or unenforceable by law, the remaining part of the Agreement shall remain valid and binding on both parties. The parties shall endeavor to find a replacement for the voided portion with the closest equivalent effect.
10.2 No Waiver: The Company's failure to exercise any rights as stipulated in this Agreement shall not be deemed a waiver of those rights, nor shall it preclude the Company from exercising those rights in the future.
10.3 Amendments to the Agreement: The Company reserves the right to amend, add to, or improve these Terms and Conditions at any time. The Company will announce any such amendments through the platform. Continued use of the platform after any amendment shall be deemed as express acceptance of the amended terms and conditions.
10.4 Language Used: In the event that this Agreement is translated into another language, And in the event of discrepancies between the Thai version and other languages,
the "Thai" version shall prevail in interpretation.