Public Offer

PUBLIC OFFER
on the conclusion of the Agreement for the provision of services for the storage, receipt and dispatch of Cryptoassets (for natural persons) City of Tashkent December 16, 2025

The joint venture in the form of a limited liability company “CITY PAY GATE” (TIN 311606433), acting on the basis of the Charter and licenses of the crypto-depository CD No. 0004 and the crypto-store CS No. 0012, issued by the National Agency of Promising Projects of the Republic of Uzbekistan on February 24, 2025 (hereinafter referred to as “CityPay”, “Contractor”), hereby addresses to legally capable individuals (hereinafter referred to as the “User”) an official proposal (public offer) to conclude an agreement on the terms and conditions set out below (hereinafter referred to as the “Agreement”, “Offer”).
The subject of this Offer is the provision by CityPay of services for custodial storage, receipt (deposit) and sending (withdrawal/transfer) of Supported Cryptoassets through the web interface of the personal account on the website https://citypay.uz/. CityPay provides services in accordance with the laws of the Republic of Uzbekistan and the regulations of authorized bodies regulating activities with Cryptoassets. Access to the Services is provided through the website https://citypay.uz/. The procedure and moment of acceptance are defined in Section 1 of this Offer and imply an explicit expression of consent in the web interface.

GENERAL PROVISIONS
1.1. This Public Offer is addressed to legally competent individuals and contains all essential terms of the Agreement within the meaning of Article 369 of the Civil Code of the Republic of Uzbekistan.
1.2 The current version of the Offer is posted on the website https://citypay.uz/ (hereinafter referred to as the “Website”).
1.3. Acceptance Procedure and Moment. The Agreement is considered concluded only from the moment the User checks the box or clicks the “I accept the terms of the Offer” button in the Website’s web interface. Any implicit actions do not constitute acceptance. Acceptance is recorded, including the date/time (UTC+5, Tashkent time zone), IP address, and session/browser ID. Prior to acceptance, transaction functionality is unavailable.
Acceptance of the Offer constitutes the User’s agreement with the terms of the Agreement; however, it does not automatically grant unconditional access to all Services or automatically open a Custodial Crypto Wallet. CityPay reserves the right, prior to the commencement of service or during the execution of the Agreement, to request the User to complete additional identification and verification procedures, including completing a KYC questionnaire, in order to comply with the requirements of the legislation of the Republic of Uzbekistan, AML/CFT/FP measures, and sanctions compliance. If CityPay makes such a request, the User is required to complete the relevant procedures, including the KYC questionnaire. Prior to completion of the requested procedures, CityPay reserves the right to:
• not open a Custodial Crypto Wallet;
• restrict access to functionality;
• suspend or refuse transactions, without such actions being deemed a violation of the Agreement.
1.4. Acceptance signifies the User’s full and unconditional agreement with the terms of this Offer, the Privacy Policy, the Terms and Conditions, the Cookie Policy, as well as the applicable technical and operational regulations of CityPay posted on the Website.
1.5. Scope of Services. Under this Offer, CityPay provides custody services, receiving (depositing) and sending (withdrawing/transferring) Supported Cryptoassets through the Personal Account on the Website. A Custodial Crypto Wallet is opened to the User after accepting the Offer and completing the KYC procedures specified in Section 4.
1.6. Access Method. Access to the Services is provided through the Website.
1.7. Age and legal status. Services are provided to individuals who are 18 years of age or older, have full legal capacity, and comply with the requirements of the legislation of the Republic of Uzbekistan and the acts of authorized bodies (including personal identification and measures to combat Money Laundering, Terrorist Financing, and the Financing of the Proliferation of Weapons of Mass Destruction, as well as sanctions compliance), including mandatory completion of a KYC questionnaire and/or provision of information/documents upon request by CityPay.
1.8. Communications and Notifications. Interaction with the User occurs exclusively within the Personal Account on the Website (displaying statuses and transaction history, informational messages). When a new version of the Offer is posted, information about it is displayed to the User via push notification the next time they log in to their Personal Account. The display of a push notification is considered proper notification, confirmation of familiarization with, and acceptance of the new version of the Offer by the User.
1.9. Electronic Documents. Personal Account entries (including transaction history and statuses) have the legal force of electronic documents and are recognized as adequate evidence of actions and exchanges of messages between the Parties, within the limits permitted by the legislation of the Republic of Uzbekistan.
1.10. Personal Data and Localization. Personal data is processed in accordance with the legislation of the Republic of Uzbekistan and the CityPay Privacy Policy. Storage of the required data is ensured on servers located in the Republic of Uzbekistan. The storage period is at least five (5) years from the date of termination of the relationship with the User, or another period established by law.
1.11. Features of Blockchain Technologies. Transactions in distributed ledgers (blockchain networks) are irrevocable and depend on network confirmations. Additional terms and risks are disclosed in Sections 4, 5, and 9, as well as in Appendix No. 1.
1.12. Priority of Documents. The terms of the Offer take precedence over any informational or marketing publications on the Website.
1.13. Amendments to the Offer. The Contractor reserves the right to amend the Offer by posting a new version on the Website. The new version will be effective from the moment it is posted (unless a different date is expressly stated). The next time the User logs into their Personal Account, a push notification about the new version will be displayed. The moment the push notification is displayed is recorded in the system (date/time UTC+5, IP address, session/browser ID) and is considered acceptance of the new version and confirmation of familiarization with it, without the need for the User to take any further action.
1.14. Transaction Processing Times. Each transaction involving the receipt, sending, and internal transfer of Cryptoassets is processed within 24 (twenty-four) hours.
TERMS
In this Offer, capitalized terms have the meanings specified below, unless the context requires otherwise.
2.1. CityPay — JV LLC “CITY PAY GATE” (TIN 311606433), acting on the basis of the Charter and licenses of the crypto-depository CD No. 0004 and the crypto-store CS No. 0012, issued by the National Agency for Promising Projects of the Republic of Uzbekistan on February 24, 2025, providing Services under this Offer.
2.2 Website — the official CityPay website https://citypay.uz/, including a secure web interface of Personal Account.
2.3 Personal Account – a section of the Website accessible after User authorization, through which Services are used, Orders are generated, and transaction history and statuses are displayed.
2.4. User – a legally competent individual who has completed registration/identification and accepted this Offer.
2.5 Cryptoasset – a property right in the form of digital records in a distributed ledger (blockchain), having value and an owner within the meaning of the legislation of the Republic of Uzbekistan. Supported Cryptoassets and networks are listed in Appendix No. 2. Privacy tokens are not supported.
2.6 Supported Networks – blockchain networks through which CityPay technically facilitates the deposit/withdrawal/transfer of the corresponding Supported Cryptoassets. The list of networks is provided in Appendix No. 2 and is subject to change for security and compliance reasons.
2.7. CityPay Custodial Cryptowallet – CityPay’s software and hardware infrastructure for storing Supported Cryptoassets;
2.8 Address (wallet address) – a unique identifier (public key/address) for receiving/sending a Cryptoassets on the corresponding network.
2.9 Transaction is an operation initiated through the Personal Account involving a Cryptoasset: receiving (depositing) or sending (withdrawing/transferring).
2.10. Intra-system transfer is a transfer of a Cryptoasset between wallets serviced within the CityPay infrastructure (off-chain/internal clearing). CityPay does not charge a commission for intra-system transfers, and no network fee applies.
2.11. External transfer is a transfer of a Cryptoasset to an external address not serviced within the CityPay infrastructure (on-chain). A network fee applies to external transfers according to the rules of the relevant network.
2.12. Transaction Order is a User’s electronic declaration of intent to execute a Transaction under the terms displayed in the interface (asset/network, volume, recipient address, proposed Network Fee, etc.).
2.13. Network Fee is a fee paid to validators/miners of the relevant network for including a transaction in the blockchain. The fee is determined by the network rules and is not set by CityPay. For External Transfers, CityPay deducts the Network Fee from the User and pays it to the network.
2.14. Identification (KYC) — procedures to verify the User’s identity, including verification of information and documents, as well as completion of a KYC questionnaire, carried out at CityPay’s request to the extent stipulated by the legislation of the Republic of Uzbekistan and CityPay’s internal rules.
KYC is mandatory from the moment the corresponding request is submitted to CityPay.
2.15. AML/CFT/FP control – measures to combat the legalization of proceeds from criminal activity (Anti-Money Laundering, AML), the financing of terrorism (Counter-Financing of Terrorism, CFT) and the financing of the proliferation of weapons of mass destruction (Financing of Proliferation, FP), including sanctions screening and transaction monitoring.
2.16. Authorization means — login, password, and other mechanisms used to access the Personal Account and confirm Orders.
2.17. Offer Push Notification – an automatic message within the Personal Account about the posting of a new version of the Offer. The fact of displaying such a Push Notification is considered proper notification, confirmation of familiarization with and acceptance of the new version of the Offer by the User.
2.18. Limits are quantitative/value restrictions on transactions set by CityPay and applied equally to all Users, denominated in USDT:
(a) one-time sending — up to 3,000 USDT;
(b) one-time receiving — up to 10,000 USDT;
(c) daily cumulative volume (sending and receiving) — up to 10,000 USDT;
(d) monthly cumulative volume (sending and receiving) — up to 50,000 USDT;
(e) maximum 30 transactions within 24 hours.
If a transaction is made in another Cryptoasset, for the purposes of limit control, its volume is converted into USDT at the market rate used by CityPay at the time the transaction is registered in the system. Days/months are calculated based on Tashkent time (UTC+5).
2.19. Minimum Send Amount — the minimum permissible size of an Order to “send” a Cryptoasset, equal to 10 USDT or the equivalent of 10 USDT for transactions in other Cryptoassets at the market rate used by CityPay at the time of registration of the transaction.
SUBJECT OF THE AGREEMENT
3.1. Composition of Services. Under this Offer, CityPay provides the User with the following Services in relation to Supported Cryptoassets via the Website:
(a) custodial storage of the User’s Cryptoassets;
(b) receiving (depositing) Cryptoassets to addresses/wallets serviced by the CityPay infrastructure;
(c) sending (withdrawing/transferring) Cryptoassets from addresses/wallets serviced by the CityPay infrastructure to internal addresses (wallets serviced by CityPay) or to external addresses in the Supported Networks.
The provision of certain Services, as well as the scope of available functionality, may be conditioned by the User’s compliance with identification requirements, compliance checks, and/or completion of a KYC questionnaire if such requirements are requested by CityPay in accordance with the legislation of the Republic of Uzbekistan and CityPay’s internal rules.
3.2. Custody model and asset title. Custody storage is provided by CityPay as a licensed crypto depository. The private keys of the corresponding addresses/wallets are controlled by CityPay. At the same time:
(a) ownership of the Cryptoassets always belongs to the User;
(b) The User’s Cryptoassets are not the property of CityPay, are not included in CityPay’s bankruptcy estate, are not encumbered by third-party rights, and are not used by CityPay (including loans/collateral) without the User’s Instruction.
3.3 Receipt (Deposit) of Cryptoassets.
(a) Deposits are made by crediting a confirmed transaction on the Supported Network to the address/wallet specified in the User’s Personal Account.
(b) A minimum number of network confirmations and/or specification of network-specific attributes (e.g., a memo/tag) may be required.
(c) The deposit is reflected in the Personal Account after the requirements of the clause 3.3(b) are met. Failure to comply with the network/asset/attribute instructions (incorrect network, missing tag, etc.) may result in the deposit not being credited. The User bears the risk of losing access to such funds.
3.4. Sending (withdrawing/transferring) Cryptoassets.
(a) Sending is carried out based on a User Request through the Personal Account, specifying the Supported Asset/Network, volume, and recipient address.
(b) External Transfers. A network fee applies, the amount of which is determined by the rules of the relevant network and is displayed to the User before the Request is confirmed. CityPay deducts the specified Network Fee from the User and pays it to the network;
(c) Intra-system transfers. Transfers between wallets serviced within the CityPay infrastructure are carried out without charging the CityPay Commission and without the Network Fee (off-chain/internal clearing).
(d) Transactions sent to the network are irrevocable and irreversible. CityPay cannot cancel or modify a transaction once it has been transmitted to the network. The risk of address/network/parameter errors is borne by the User.
3.5. Supported assets and networks. The list of Supported Cryptoassets and Networks is provided in Appendix No. 2 and is subject to change by CityPay based on legislation, regulations of authorized bodies, security and compliance requirements, and technological feasibility. Privacy tokens are not supported.
3.6. Addresses and details. The User confirms that each recipient address (external or internal) provided by them is intended for the receipt of the corresponding Supported Asset on the corresponding network and is under the control of its legal owner. CityPay is under no obligation to verify the ownership or accuracy of addresses and is not responsible for any errors made by the User.
3.7. Information support. Information on deposit/withdrawal/transfer statuses is displayed in the Personal Account interface.
3.8. Execution times. CityPay executes receipts (deposits), sendings (withdrawals/transfers), and internal system transfers within 24 (twenty-four) hours from the time the Order is correctly submitted/funds are received at the appropriate address. Actual timing depends on the network and security/compliance checks and may vary. For external transfers, the moment the transaction is included in the blockchain is determined by the network rules.
3.9. Refusal/Suspension of Execution. CityPay reserves the right to refuse to execute an Order or to suspend/freeze/cancel the transaction and block the account in cases stipulated by this Offer and the law, including measures to combat money laundering (AML), the financing of terrorism (CFT) and the financing of the proliferation of weapons of mass destruction (FP), sanctions compliance, orders of authorized bodies, as well as in the presence of justified technical risks/incidents or suspicions of violation by the User of the law and/or the terms of the Offer.
TERMS OF SERVICE
4.1. Registration and Access. Access to the Services is provided through the Personal Account on the Website after registration and acceptance of the Offer. Prior to acceptance, transaction functionality is unavailable. Registration and acceptance of the Offer do not automatically guarantee access to all Services. CityPay reserves the right to establish additional access conditions, including identification and a KYC questionnaire, upon request.
4.2. Identification (KYC) and Compliance.
4.2.1. CityPay has the right, at any time, prior to the commencement of service or during the execution of the Agreement, to request the User to undergo identification, including completing a KYC questionnaire, providing information and documents necessary to comply with the requirements of the legislation of the Republic of Uzbekistan, AML/CFT/FP and sanctions compliance.
4.2.2. From the moment CityPay sends a request for identification and/or completion of a KYC questionnaire, the User is obligated to comply with such request.
Failure to provide information, refusal to complete the KYC questionnaire, or provision of inaccurate data will result in denial of service, suspension of transactions, and/or termination of the Agreement.
4.2.3. CityPay has the right to carry out continuous monitoring of transactions and re-identification and verification to the extent stipulated by the legislation of the Republic of Uzbekistan and internal regulations.
4.3. Authorization tools and security.
4.3.1. The User is obliged to ensure the confidentiality of their login/password and the protection of the devices/browser from which they access the service.
4.3.2. Actions performed using correct authorization means are considered to be the actions of the User, unless proven otherwise.
4.3.3. The User is obliged to immediately notify CityPay of any compromise or loss of authorization means via the contacts specified on the Website.
4.4. Creating Orders.
4.4.1. Orders are created in the Personal Account and must contain the following mandatory parameters (asset, network, amount, recipient/sender address, memo/tag/other network attributes, if necessary).
4.4.2. Before confirming the Order, the User is shown the applicable amounts, including the estimated amount of the Network Fee for external transfers.
4.4.3. A confirmed Order is sent for execution and may be suspended/rejected on the grounds specified in the clause 4.10.
4.5. Receipt (Deposit) of Cryptoassets.
4.5.1. The address/wallet specified in the Personal Account is used for input. The User is required to use a valid address and the correct network.
4.5.2. The minimum number of network confirmations and/or mandatory attributes (memo/tag) may be applied for crediting, if required by the relevant network.
4.5.3. Transfers to the wrong network/asset, to an outdated address, without the mandatory memo/tag may not be credited; the risk of such consequences is borne by the User.
4.5.4. Receiving Limit Exceeded. If an incoming transaction exceeds the one-time receiving limit of 10,000 USDT (or results in daily/monthly limits being exceeded), the amount will not be credited. CityPay reserves the right to: (a) return the assets to the sender (if technically feasible) minus the network fee and unavoidable expenses; or (b) temporarily freeze the assets until verification is completed/document receipt is received; (c) apply clause 4.16 if there is evidence of increased/prohibited risk. For transactions in other assets, the excess is determined by the USDT equivalent at the time of transaction registration.
4.6. Sending (withdrawing/transferring) Cryptoassets.
4.6.1. Intra-system transfers (between wallets serviced by the CityPay infrastructure) are carried out without charging CityPay Commission and without Network Fees (off-chain clearing).
4.6.2. External transfers (to addresses outside the CityPay infrastructure) require the payment of a Network Fee determined by the rules of the relevant network; the amount of the Network Fee is displayed before the order is confirmed. CityPay withholds the specified Network Fee amount from the User and transfers it to the network validators/miners.
4.6.3. Once the transaction is released to the network, the operation is irrevocable and irreversible. CityPay is not obligated to cancel/change on-chain transactions.
4.6.4. Exceeding limits when sending. Orders exceeding the one-time/daily/monthly limit, or the limit on the number of transactions (see clause 2.18), are not accepted or are suspended. For transactions in other assets, compliance with the limits is assessed based on the USDT equivalent at the time the transaction is registered.
4.6.5. Minimum send amount. Send requests with amounts less than the minimum send amount are either not accepted or rejected. For transactions in other Cryptoassets, compliance with the minimum send amount is assessed based on the USDT equivalent at the time the transaction is registered.
4.7. Technical requirements for transactions.
4.7.1. CityPay does not accept or process transactions with unsupported assets/networks.
4.7.2. CityPay has the right to reject transactions that do not meet the technical requirements of the network (including the absence of a mandatory memo/tag, incorrect address format, etc.).
4.8. Status display.
Transaction statuses (“accepted,” “processing,” “completed,” “rejected,” “paused”) are displayed in the Personal Account interface only.
4.9. Execution times.
4.9.1. CityPay executes receipt (input), sending (withdrawal/transfer), and intra-system transfers within 24 (twenty-four) hours from the moment of correct Instruction and/or receipt of funds at the corresponding address.
4.9.2. For external transfers, the moment when the transaction is included in the blockchain is determined by the network rules and may depend on its load. At the same time, the CityPay Order for sending is formed and transmitted to the network within the time frame specified in the clause 4.9.1. The timeframes are approximate and depend on the network and inspections.
4.10. Grounds for suspension/denial/freezing/cancellation and freezing of assets. CityPay reserves the right to suspend/freeze or refuse to execute Orders, block access to the Personal Account and account, suspend wallet/account transactions, and freeze Cryptoassets if:
(a) the User has provided false/incomplete information or has failed to comply with identification/verification procedures;
(b) this is expressly provided for by the legislation of the Republic of Uzbekistan and/or the instructions of authorized bodies;
(c) it is required in accordance with the Internal Control Rules on Combating Money Laundering, Terrorist Financing, and the Financing of Proliferation of Weapons of Mass Destruction (AML/CFT/FP), including sanctions screening and transaction monitoring;
(d) The User, their transactions/counterparties are related to the lists of persons involved or suspected of involvement in terrorist activities or the proliferation of weapons of mass destruction - in such a case, CityPay freezes the assets in the manner and for the period prescribed by law;
(e) transactions/transactions suspected of money laundering, terrorist financing, or proliferation of weapons of mass destruction, or related to gambling, are detected – measures are also applied in accordance with CityPay’s internal documents;
(f) there are technical risks/incidents, signs of compromise of authorization tools, non-compliance with network/Application technical requirements, exceeding limits, or insufficient balance;
(g) the User has failed to comply with CityPay’s request to provide the documents/information stipulated in clauses 4.2.1 and 4.2.4 of this Offer.
(h) the User has indicated an incorrect network/asset/address or is missing the required memo/tag;
(i) other cases stipulated by the Offer and law.
(j) the amount of the “send” Order is less than the Minimum Send Amount.
Notification of suspension/freezing is made in the manner and to the extent stipulated by the legislation of the Republic of Uzbekistan, unless such notification is prohibited by law.
Information about suspension/refusal is reflected in the Personal Account.
4.11. Responsibility for details. The User is responsible for the correctness of the specified addresses, network, asset, memo/tags, and other parameters. CityPay is not obliged to verify the ownership of the recipient’s addresses and is not responsible for the consequences of the User’s errors.
4.12. Changeability of the List of Assets/Networks and Functions. CityPay has the right to change the List of Supported Cryptoassets/Networks and to suspend/resume the deposit/withdrawal of individual assets on the grounds of security, compliance, regulatory requirements, and/or technological expediency.
4.13. Adding and Excluding Cryptoassets
4.13.1. General Provisions.
CityPay independently determines the list of Supported Cryptoassets and Networks, guided by the requirements of the legislation of the Republic of Uzbekistan, regulations of the National Agency for Advanced Projects, as well as internal security and compliance policies.
Addition (listing) and exclusion (delisting) of Cryptoassets/networks are carried out without the separate consent of Users and are considered non-material changes to the terms of the Offer within the meaning of clause 12.1 (c).
4.13.2. Addition (listing) of Cryptoassets.
(a) The decision to add (list) a Cryptoasset or network is made by CityPay based on an assessment of:
• compliance with legislation and National Agency for Prospective Projects (NAPP) requirements;
• network stability and technical reliability;
• availability of liquidity and stable infrastructure operation;
• AML/CFT/FP risk level and sanctions compliance;
• technical integrability into the CityPay platform.
(b) After the decision is made, CityPay updates Appendix No. 2, publishes a notice on the Website and in the Personal Account, and specifies the start date of support for the new Cryptoasset/network.
(c) From the moment of publication, the User may use the new Cryptoasset/network under the terms of this Offer.
4.13.3. Delisting of Cryptoassets.
(a) Delisting of Cryptoassets means the termination of technical and operational support for the Cryptoasset/network.
(b) Grounds for delisting of Cryptoassets:
• Instructions from the NAPP or other government agencies;
• Violation of legal/sanction requirements or the emergence of compliance risks;
• Significant technical failures of the network, termination of support by validators;
• Loss of liquidity or objective impossibility of secure service;
• CityPay’s decision to terminate support for internal security or operational efficiency reasons.
(c) When delisting Cryptoassets, CityPay will notify Users on the Website and/or in their Personal Account at least 30 (thirty) calendar days prior to the termination of support, indicating the date after which deposits/withdrawals for the Cryptoasset will no longer be available.
(d) During the notification period, the User has the right to transfer the relevant Cryptoassets to an external address.
(e) Upon expiration of the specified period, Cryptoasset transactions will cease. If withdrawal is technically impossible or legal restrictions exist, assets will be frozen until orders from competent authorities are received.
(f) In emergency cases - sanctions, failures, network compromise, or regulatory orders - CityPay reserves the right to delist Cryptoassets immediately without prior notice, with subsequent posting of information on the Website and/or in the Personal Account.
4.13.4. Legal Consequences.
(a) Delisting Cryptoassets under this clause does not constitute a breach of CityPay’s obligations.
(b) Following the delisting date, Cryptoasset transactions are no longer available. CityPay maintains records of the relevant balances until they are lawfully withdrawn or disposed of in accordance with the procedure established by law.
(c) The return or freezing of assets upon delisting of Cryptoassets is carried out in accordance with clause 4.16 and the instructions of authorized bodies.
(d) CityPay does not automatically convert delisted Cryptoassets into other assets or stablecoins and does not provide exchange services unless otherwise expressly required by law or the regulator.
4.13.5. Legislation prevails.
All decisions regarding listing and delisting are made and executed strictly in accordance with the laws of the Republic of Uzbekistan.
4.14. Service and support. Requests are accepted through the communication channels specified on the Website. Response times depend on the complexity of the request and the operating mode.
4.15. Localization and storage of transaction data. Transaction records and log data (date/time, IP/identifiers, order parameters) are maintained and stored by CityPay to the extent and for the period specified by the legislation of the Republic of Uzbekistan and internal rules (at least 5 years or another period specified by law).
4.16. Special AML/CFT/FP rules: return/non-return and freezing of assets.
4.16.1. Classification of sources/recipients. CityPay uses internal algorithms and external blockchain analytics providers to monitor transactions. The following categories are distinguished, among others:
— high-risk (Illicit Activity): darknet markets, mixers, scam/phishing schemes, and similar sources of obfuscation;
— prohibited: sanctioned addresses/entities, drug sales, illegal gambling, terrorist financing, child sexual abuse material (CSAM), Democratic People’s Republic of Korea, and other categories expressly prohibited by law (Obfuscating & Misc., Gambling, Sanctioned, TF & CSAM, DPRK, etc.).
4.16.2. Incoming transactions (Receiving).
(a) If a transaction is received from a high-risk source (Illicit Activity), CityPay reserves the right to deny credit the funds, freeze them, and may or may not return them to the sender (if technically feasible), minus the network fee and other unavoidable costs.
(b) If a transaction is received from a prohibited source (sanctions, drugs, illegal gambling, TF, CSAM, DPRK, etc.), the funds are frozen and not returned. CityPay operates in accordance with legal requirements and the instructions of authorized bodies.
4.16.3. Outgoing Transactions (Sending).
(a) If the Order is sent to a high-risk source (Illicit Activity), CityPay reserves the right to refuse to execute it, freeze it, and return or withhold the assets to the User (minus the network fee/inevitable costs), suspending the transaction until verification is completed.
(b) If the Order is sent to a prohibited source, the assets intended for sending are frozen and not returned, the transaction is not executed; further actions are subject to legal requirements.
4.16.4. Account Blocking and Asset Freezing. If the signs specified in clauses 4.16.2–4.16.3 are detected, or if the required documents/explanations are not provided, CityPay reserves the right to block access to the Personal Account (in whole or in part) and freeze assets until the investigation is completed/orders are received. No prior notice to the User is required, unless otherwise required by law.
4.16.5. Prevalence of the law. The return/non-return of assets, as well as their freezing/seizure, are carried out in strict compliance with the law and the instructions of competent authorities.
COMMISSIONS AND FEES
5.1. General principle.
When conducting Transactions under this Offer, only the Network Fee applies – a fee paid to validators/miners of the relevant blockchain network. The amount of the Network Fee is determined by the network rules and is not set by CityPay.
CityPay withholds the Network Fee from the User and transfers it to the relevant network.
5.2. Intra-system transfers.
Transfers of Cryptoassets between wallets serviced by the CityPay infrastructure are carried out without charging CityPay Fees and without a Network Fee (internal clearing).
5.3. Receipt (Deposit) of Cryptoassets.
Incoming transfers to addresses/wallets serviced by CityPay are credited without CityPay commission. The Network Fee for forming an incoming transaction is paid by the sender (external address), if provided for by the network rules.
5.4. Sending to an external address (external transfers).
(a) External transfers are subject to a Network Fee, the amount of which depends dynamically on the network load and the rules for including transactions in a block/slot; CityPay does not control or set this fee.
(b) The method of withholding the Network Fee (from the amount sent or in the base token of the network) is determined by the rules of the relevant network and is displayed to the User before the Order is confirmed.
(c) CityPay does not charge a commission for external transfers.
5.5. Transparency until confirmation.
Until the Order is confirmed, the following information is displayed in your Personal Account: Transaction type, asset/network, amount, recipient’s address, estimated Network Fee, and the total amount to be sent/received. Confirmation of the Order means agreement with the specified parameters.
5.6. Dynamic nature of the Network Fee.
The estimated Network Fee displayed prior to confirmation is approximate and may differ from the actual amount debited due to changes in network parameters at the time the transaction is sent. In such cases, the Network Fee may be adjusted in accordance with network rules.
5.7. Minimum network amounts and rounding.
If network rules stipulate minimum transfer/balance amounts (e.g., dust, rent-exempt, etc.), Orders below the network threshold may be rejected. Amounts may be rounded within the technical accuracy of the relevant network/token.
RIGHTS AND RESPONSIBILITIES OF THE PARTIES
6.1. CityPay’s obligations:
(a) to provide the Services properly within the scope of the Offer’s functionality (custodial storage, receipt, dispatch/transfer);
(b) to apply organizational and technical protection measures;
(c) to comply with the legislation of the Republic of Uzbekistan, including measures to combat money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction, as well as requirements regarding personal data and the instructions of authorized bodies;
(d) to reflect the status of transactions and the amount of the Network Fee applied in the Personal Account;
(e) to store information and documents to the extent and for the period specified by law and the Offer.
6.2. CityPay rights:
(a) to request information/documents from the User, conduct re-identification and continuous monitoring of transactions;
(b) to set and change technical parameters of transactions and processing modes necessary for the safe and stable operation of the service;
(c) to suspend/reject/freeze/cancel Orders, block assets and/or access to the Personal Account in cases provided for by the Offer and the law (sanctions screening, signs of fraud, violation of the Offer, regulations of authorities, technical incidents, etc.);
(d) to temporarily restrict the functionality, deposit/withdrawal of certain assets/networks for reasons of security, compliance, regulatory requirements, or technical maintenance;
(e) to change the list of Supported Cryptoassets/Networks (Appendix No. 2) on the grounds specified in the Offer;
(f) to correspond and send legally significant messages in electronic form in cases expressly provided for by law.
(g) to request the User to complete a KYC questionnaire or other identification procedures; suspend access to the Services until they are completed or refuse service if the User refuses.
6.3. User Obligations:
(a) to provide accurate data during registration/identification and update it in a timely manner;
(b) to use the Services personally, on their own behalf and in their own interests, as the beneficial owner of Cryptoassets;
(c) to comply with the Offer and the legislation of the Republic of Uzbekistan, including measures to combat the legalization of proceeds from crime, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, as well as sanctions restrictions;
(d) to ensure the confidentiality of Authorization tools and the security of devices/browsers; immediately inform CityPay of any compromise;
(e) to specify the correct parameters of Orders (asset, network, address, memo/tag, etc.) and check them before confirmation;
(f) not to use the service for activities prohibited by law, including transactions involving illegal goods/services;
(g) independently to track the status of transactions in your Personal Account.
(h) upon request by CityPay, to undergo identification procedures, including completing the KYC questionnaire, and provide reliable information and documents within the specified timeframes.
6.4. User Rights:
(a) to access the Services through the Personal Account after accepting the Offer and passing the necessary checks;
(b) to create Orders for receiving/sending Cryptoassets in compliance with technical requirements;
(c) to view the status of transactions, the amount of the Network Fee applied, and the activity log in the Personal Account;
(d) to contact CityPay support for service issues in accordance with the procedure established by the Offer.
6.5. Responsibility for details and confirmations.
All actions performed using correct Authorization tools and confirmed in the interface are considered to be actions of the User. The User bears the risks of incorrect network/address/tag specification, sending unsupported assets, and the irrevocability of on-chain transactions.
6.6. Restrictions on the use of the service:
(a) attempts to interfere with the operation of the Site/API, circumvent technical restrictions, DDoS, scraping, reverse engineering are prohibited;
(b) it is prohibited to use the service for operations that directly or indirectly violate the law, the rights of third parties, or sanctions;
(c) it is prohibited to transfer access to third parties, assign accounts, or perform other actions that create a risk of unauthorized access.
6.7. Assistance and documents.
Upon request by CityPay, the User is obliged to promptly provide the required information/documents. Failure to provide or refusal to provide such information/documents shall be grounds for suspension/refusal of transactions and/or termination of the Agreement.
6.8. Communications.
The User is obliged to keep their contact details in their Personal Account up to date and to independently check the information posted there. CityPay is not obliged to send separate notifications; messages may only be sent in cases expressly provided for by law.
6.9. Evidence.
CityPay electronic journals (metadata, authorization and confirmation logs, technical fingerprints) may be used as valid evidence of actions taken between the parties within the limits permitted by law.
USER REPRESENTATIONS AND WARRANTIES
USER REPRESENTATIONS AND WARRANTIES
By accepting this Offer, the User confirms, represents, and warrants that, as of the date of acceptance and throughout the term of the Agreement, the following is true:
7.1. Identity and legal capacity.
(a) The User is at least 18 years of age, has full legal capacity, and is entitled to enter into and perform this Agreement.
(b) The User acts on their own behalf and in their own interests, is the beneficial owner of the Cryptoassets, and does not act on behalf of/in the interests of a third party without legal grounds.
(c) The User has the right to use the Services in accordance with the applicable law of the Republic of Uzbekistan.
7.2. Accuracy of information.
(a) All data and documents provided during registration/identification and in the course of service are accurate, reliable, up-to-date, and complete.
(b) The User shall immediately update the information if it changes.
(c) The source of origin of Cryptoassets/funds is legal; the assets are not encumbered by the rights of third parties.
7.3. Compliance with laws, sanctions, and compliance measures.
(a) The User is not included in national/international sanctions lists and other lists of restrictions and is not subject to prohibitions that make service impossible.
(b) The User shall not use the Services for activities prohibited by law, including money laundering, terrorist financing, financing the proliferation of weapons of mass destruction, fraud, violation of export controls and sanctions regimes.
(c) At CityPay’s request, the User shall provide the documents and information necessary for identification procedures (KYC) and checks to combat money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction (AML/CFT/FP), and shall assist in their implementation.
The User acknowledges and accepts CityPay’s right to request completion of a KYC questionnaire and other identification procedures, and agrees that failure to complete them may result in a denial of Services or termination of the Agreement.
7.4. Details and addresses.
(a) Each address and other details specified by the User: (i) are intended for the relevant Supported Cryptoasset and network; (ii) belong to the User and are under their control; (iii) are correct and verified by the User before confirming the Order.
(b) The User understands that errors in the address/network/memo (tag) may result in the irretrievable loss of assets; the risk of such consequences is borne by the User.
7.5. Technological risks and irreversibility.
(a) Transactions in blockchain networks are irrevocable and irreversible. Speed/cost/availability depend on the rules and congestion of the relevant network.
(b) A Network Fee applies to external transfers, which is not set by CityPay and is dynamic in nature; the fee estimate prior to confirmation of the Order is approximate.
(c) The cost of Cryptoassets is volatile. CityPay does not guarantee the safety/stability of the market price.
7.6. Access security.
The User shall ensure the confidentiality of Authorization tools, shall not transfer access to third parties, shall use reliable device/browser security settings, and shall immediately notify CityPay of any compromise.
7.7. Communications.
The User independently monitors information and push notifications in their Personal Account. Messages/materials posted in the Personal Account are considered received by the User if there is objective confirmation of their posting; no additional external notifications are required.
7.8. Full familiarization.
The User has read the terms of the Offer and CityPay’s Privacy Policy, understands and accepts them.
7.9. Breach of warranties.
A breach of any of the representations/warranties in this section shall constitute a material breach of the Agreement and shall entitle CityPay, to the extent permitted by law and the Offer, to suspend/refuse transactions, freeze assets/access, terminate the Agreement unilaterally, and claim damages and other remedies provided by law.
ESSENTIAL TERMS AND CONDITIONS FOR THE EXECUTION OF ORDERS
8.1. The moment of execution by CityPay for “input” (crediting) transactions.
8.1.1. CityPay’s obligation to credit Cryptoassets is considered fulfilled from the moment the receipt is reflected in the User’s Personal Account after fulfilling the requirements of the relevant network and internal security checks, including, if necessary: a minimum number of network confirmations, verification of the correctness of the selected network/asset/memo (tag), as well as measures to combat money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction (AML/CFT/FP).
8.1.2. Until the moment specified in the clause 8.1.1, crediting may be temporarily suspended until the identified risks/discrepancies are eliminated or additional information/documents are received from the User.
8.2. The moment of CityPay’s execution of Intra-system transfers.
8.2.1. CityPay’s obligation is considered fulfilled at the moment of internal transfer according to CityPay’s records (outside the blockchain) with simultaneous reflection of the debit from the sender and credit to the recipient in the Personal Account.
8.2.2. CityPay does not charge a commission for Intra-system transfers, and no Network Fee applies.
8.3. CityPay’s moment of execution for external transfers.
8.3.1. CityPay’s obligation for an external transfer is considered fulfilled at the moment the transaction is transferred to the relevant network (assignment of a transaction identifier/TxID with recording of this event in CityPay’s logs and in the Personal Account).
8.3.2. From that moment on, all risks associated with transaction confirmation, block inclusion time, possible retransmission of the transaction to the network due to protocol conditions and other network events are transferred to the User.
8.3.3. The Network Fee for external transfers is withheld from the CityPay User and then paid to the relevant network in accordance with the procedure set out in Section 5 of this Offer; the actual amount may differ from the preliminary estimate due to network dynamics.
8.4. Grounds for suspension/refusal of execution.
An Order may be suspended/rejected and assets temporarily blocked if:
(a) The Order does not meet the network requirements (e.g., the network/asset/address is incorrect, or a memo/tag is required but not specified);
(b) AML/CFT/FP risks, sanctions risks, or links to high-risk sources are identified;
(c) the information requested for identification, verification of the source of funds/assets is missing/insufficient, including refusal to complete the KYC questionnaire or failure to provide the information requested by CityPay as part of the identification;
(d) there is a technical incident or suspicion of compromise of Authorization tools;
(e) an Order has been received from an authorized body or required by law.
Information about the current status of the Order is displayed in your Personal Account; separate notifications/receipts are not sent.
8.5. Irreversibility and non-revocability.
8.5.1. External transactions in blockchain networks are irrevocable and irreversible.
8.5.2. Internal transfers can only be canceled by CityPay until the moment of internal processing; after the debit/credit has been reflected, cancellation is impossible, except for the correction of an obvious technical error by CityPay.
8.6. Service availability.
CityPay strives to ensure the availability of the Website and Personal Account, but does not guarantee uninterrupted and error-free operation, given its dependence on external infrastructure (communication providers/data centers, blockchain protocols). During technical work and incidents, temporary restrictions and delays in the execution of Orders are possible.
8.7. Information procedure.
Order statuses (accepted, in progress, executed/TxID, rejected, suspended) are available in the Personal Account.
8.8. Priority of law and regulations.
In the event of a conflict between the terms of the Order and the mandatory requirements of the legislation of the Republic of Uzbekistan/regulations of authorized bodies, execution shall be carried out to the extent strictly required by such legislation/regulations.
8.9. Execution time.
8.9.1. The standard execution time for Orders for “send,” “receive (deposit),” and “intra-system transfer” transactions is no later than 24 (twenty-four) hours, respectively:
— for “send” transactions – from the moment the Order is confirmed by the User in their Personal Account;
— for “input” — from the moment the transaction is received by the network at the address serviced by CityPay, subject to compliance with network requirements and internal checks;
— for “intra-system transfer” — from the moment the Order is confirmed.
8.9.2. During the period of lawful suspension in accordance with the clause 8.4 (including AML/CFT/FP checks, regulatory requirements, and other grounds provided for by law), the specified period shall be suspended until the grounds for suspension are eliminated.
8.10. Limits and refusal to accept/execute.
Transactions that exceed the Limits are rejected or suspended. For incoming transactions over 10,000 USDT, clause 4.5.4 and, if necessary, clause 4.16 apply. For transactions in other assets, limits are checked based on the USDT equivalent at the time the transaction is registered.
LIMITATIONS AND LIABILITY
9.1. General principle.
The Services are provided “as is” within the scope of the functionality described in the Offer (custodial storage, receipt, dispatch/transfer). To the extent permitted by the laws of the Republic of Uzbekistan, CityPay shall only be liable for direct actual damage caused to the User as a result of culpable (intentional or grossly negligent) actions/omissions on the part of CityPay. Liability for lost profits, moral damages, indirect/incidental damages, and penalties is excluded.
9.2. Cases for which CityPay is not liable.
CityPay is not liable, including for:
(a) actions/errors of the User (incorrect address, choice of network/asset, lack of a mandatory memo/tag, sending an unsupported asset, compromise of authorization funds, malicious software on devices, etc.);
(b) the operation of blockchain networks (overload, changes in network rules and fees, delays in including transactions in a block, forks, and other features of protocols);
(c) Network Fees and their amount/method of deduction: these are determined by the rules of the relevant network, deducted by CityPay from the User, and then paid to the network itself on behalf of CityPay;
(d) external infrastructure of third parties (communication providers/data centers, authentication services, KYC/AML verification providers, postal and SMS operators, etc.);
(e) legal restrictions and requirements of authorized bodies, as well as measures to combat money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction (AML/CFT/FP), due to which the transaction is suspended/rejected/assets are temporarily frozen;
(f) continuity of the Website/Personal Account, if the interruption is caused by scheduled maintenance, security incidents, failure of external infrastructure, or other circumstances specified in sections 8 and 10;
(g) volatility of the value of Cryptoassets and any losses due to changes in their market price.
9.3. Irreversibility of transactions.
External transactions in blockchain networks are irrevocable once they have been transmitted to the network. CityPay is not obligated and, as a rule, cannot cancel or reverse such a transaction. The User bears the risk of specifying incorrect parameters.
9.4. Limitation of liability.
CityPay’s total liability for each transaction is limited to the amount of the relevant Cryptoasset wrongfully debited due to CityPay’s fault, or the amount of direct actual damage proven by the User and causally related to CityPay’s culpable actions/inaction (whichever is less).
9.5. Third Party Actions.
CityPay is not responsible for the actions/inaction of third parties beyond its control (owners of external addresses, network/communication providers, banks, payment systems, verification services, etc.), nor for the consequences arising after CityPay has duly fulfilled its obligations under the Order.
9.6. Terms of execution.
The term for the execution of “send”, “receive (input)” and “intra-system transfer” operations is no later than 24 (twenty-four) hours in accordance with the procedure established in the clause 8.9. Delays in confirmation specifically in the blockchain network (after the transaction has been transferred to the network) and/or lawful suspension on the grounds specified in the clause 8.4 shall not give rise to liability on the part of CityPay.
9.7. Investment/brokerage/insurance disclaimers.
CityPay does not provide investment, tax, or legal advice; it is not a broker/dealer/bank; Cryptoasset accounts are not bank deposits and are not covered by deposit insurance. Any information on the Website is for informational purposes only.
9.8. Compensation for losses incurred by CityPay.
The User undertakes to compensate CityPay for documented losses, expenses, and penalties incurred as a result of the User’s violation of the law and/or the terms of the Offer (including non-compliance with AML/CFT/FP requirements, provision of inaccurate data, unauthorized use of the service), to the extent permitted by the laws of the Republic of Uzbekistan.
FORCE MAJEURE (FORCE MAJEURE CIRCUMSTANCES)
FORCE MAJEURE (FORCE MAJEURE CIRCUMSTANCES)
10.1. Concept and general principle.
The Parties shall be exempt from liability for full or partial failure to perform this Offer if it is caused by circumstances arising after acceptance that are beyond the control of the Parties and beyond their reasonable control (hereinafter referred to as “Force Majeure”), provided that reasonable measures are taken to minimize the consequences.
10.2. List of Force Majeure Events.
Force Majeure Events include, in particular: natural disasters; epidemics/pandemics and mandatory acts of health authorities; wars, terrorist acts, armed conflicts, mass riots, strikes; mandatory acts/decisions of state authorities, changes in legislation that make performance illegal or virtually impossible; prolonged accidents/interruptions in power systems, communications, data centers, large-scale failures of Internet infrastructure; systemic technical incidents of blockchain networks (mempool overload, protocol shutdown/defect, forks, “51%+1” attacks, etc.) beyond CityPay’s control. A change in the market value of Cryptoassets does not in itself constitute a Force Majeure event.
10.3. Information procedure.
The party affected by Force Majeure shall, without undue delay, post information about the fact and nature of such circumstances and their expected duration on the Website and/or in the Personal Account. Individual messages (e-mail, SMS, push) shall not be sent, unless otherwise required by law.
10.4. Confirmation.
The fact and duration of Force Majeure may be confirmed by documents from competent authorities (including the Chamber of Commerce and Industry of the Republic of Uzbekistan) and other appropriate evidence (official communications from regulators/infrastructure providers, public reports on network failures, etc.).
10.5. Consequences.
During the period of Force Majeure, the performance of the affected obligations under the Offer shall be suspended for the duration of such circumstances and a reasonable time to eliminate their consequences. The deadlines for performance shall be extended proportionally. Monetary obligations arising prior to the occurrence of Force Majeure shall remain in force unless their performance has become illegal or objectively impossible.
10.6. Mitigation and resumption.
The party invoking force majeure shall take reasonable measures to minimize damage and resume performance, and upon termination of Force Majeure, shall post information about the resumption on the Website/in the Personal Account.
10.7. Prolonged Force Majeure.
If Force Majeure lasts for more than 30 (thirty) consecutive calendar days, either Party shall have the right to terminate the Agreement unilaterally without penalties by posting the relevant information on the Website and/or in the Personal Account. In this case, CityPay shall complete the legally permissible and technically feasible operations to return the Cryptoassets belonging to the User in a manner not prohibited by law and regulations of the authorities, taking into account the applicable restrictions.
10.8. Priority of mandatory rules and time.
Nothing in this section limits CityPay’s compliance with the mandatory requirements of the legislation of the Republic of Uzbekistan and the regulations of the authorized authorities. The terms specified in this section are calculated according to Tashkent time (UTC+5), unless otherwise specified.
PERSONAL DATA
11.1. Legal grounds for processing.
The processing of the User’s personal data (hereinafter referred to as “Personal Data”) is carried out by CityPay in accordance with the legislation of the Republic of Uzbekistan, including the Law of the Republic of Uzbekistan “On Personal Data”, as well as laws on combating the legalization of proceeds from criminal activity, terrorism financing, and financing the proliferation of weapons of mass destruction, on the following grounds:
(a) fulfillment of this Offer — creation and maintenance of a Personal Account, receipt and sending of Cryptoassets, display of transaction statuses in the Personal Account;
(b) fulfillment of legal requirements — identification (KYC), compliance control for AML/CFT/FP and sanctions, storage of documents and logs, responses to requests from authorized bodies.
11.2. Purposes of processing.
Personal data is processed to the extent necessary for:
(a) registration, authentication, and maintenance of the Personal Account;
(b) execution of Orders (receipt/transfer of Cryptoassets), display of transaction statuses in the Personal Account;
(c) conducting identification/verification (KYC), including document/identity verification, sanctions and other compliance screening;
(d) preventing fraud, ensuring security, maintaining event logs, and investigating incidents;
(e) fulfilling lawful requests from authorized bodies;
(f) improving the quality of service and stability of the Website based on anonymized/aggregated data;
(g) informing you about the new version of the Offer via push notification the next time you log into your Personal Account.
11.3. Composition of Personal Data and sources.
The following may be processed:
(a) identification data: full name, date of birth, citizenship, Taxpayer Identification Number/Personal ID, details of the identity document;
(b) contact details: telephone number, e-mail, residential/stay address;
(c) data on transactions/orders: asset/network, volumes, sender/recipient addresses, TxID/hash, statuses, network fees applied;
(d) technical data: IP address, date/time, browser/device information, cookies/session markers, authorization and confirmation logs;
(e) results of compliance checks (sanctions screening, signs of high-risk sources) — to the extent required by law;
(f) correspondence and support requests.
Sources: the User themselves; authorized KYC/AML verification providers; publicly available and/or government registries within the limits of the law; CityPay technical systems.
11.4. Transfer to third parties.
Personal Data shall not be disclosed to third parties, except as provided by law and/or this Offer, including:
(a) identification/verification (KYC), sanctions and compliance screening providers;
(b) IT providers (data centers, clouds, security tools) — to the extent necessary to provide the Services;
(c) auditors, consultants, and other processors under confidentiality and Personal Data protection agreements;
(d) authorized state bodies — in cases and in the manner established by law.
The transfer is carried out in compliance with confidentiality and security measures.
11.5. Localization and cross-border transfer.
The collection, systematization, and storage of Personal Data of citizens of the Republic of Uzbekistan are carried out in databases on the territory of the Republic of Uzbekistan to the extent established by law. Cross-border transfer of Personal Data is permitted only in cases and in the manner provided for by law.
11.6. Storage periods.
Personal Data shall be stored for the duration of the Agreement and, after its termination, for the period established by law and/or necessary to protect the rights and legitimate interests of CityPay (including AML/CFT/FP requirements and limitation periods). The minimum storage period for documents and transaction logs is at least 5 (five) years or another period as required by law.
11.7. Personal Data security.
CityPay implements the necessary organizational and technical measures to protect Personal Data: access control, encryption, event logging and monitoring, perimeter protection, vulnerability management, backup, staff training, access auditing, etc. The user complies with the requirements of clause 4.3 and section 6.
11.8. Cookies and technical accounting.
The Website uses cookies and similar technologies (local storage, web beacons) for login, saving settings, security, and analytics in an anonymized form. Cookie management — in browser settings.
11.9. Rights of the Personal Data subject and procedure for exercising them.
The User has the right, to the extent established by law, to:
(a) receive information about their Personal Data and the purposes/grounds for its processing;
(b) request clarification (updating, correction) of Personal Data if it is incomplete or inaccurate;
(c) request the blocking/destruction of Personal Data if it is processed in violation of the law;
(d) withdraw consent — for those purposes where consent is the basis for processing (does not affect the legality of processing prior to withdrawal and does not apply to processing that is mandatory by law/contract, including AML/CFT/FP).
Requests are sent via the contacts on the Website. CityPay considers them within the time limits established by law, if necessary, after identifying the applicant.
TERMINATION AND AMENDMENT OF THE AGREEMENT
12.1. Procedure for changing an Offer.
(a) CityPay has the right to unilaterally amend (supplement, revise) this Offer by publishing an updated version on the Website and simultaneously placing a push notification in the Personal Account the next time the User logs in.
(b) Significant changes are subject to repeated explicit acceptance by the User in the push notification/Personal Account interface (checkbox/Accept button). Access to operations may be restricted until repeated acceptance. Significant changes include, in particular:
• the introduction of any CityPay Commission;
• changes that expand the scope of services (connection of purchase/sale/exchange functions) or change the storage/risk model;
• changes affecting the distribution of responsibility, grounds for blocking/suspending, terms and procedure for returning assets;
• changes requiring new consents for the processing of personal data;
• other changes expressly designated by CityPay as “significant.”
(c) Editorial/clarification changes, as well as updates to Appendix No. 2 (List of Supported Assets/Networks) and reference information, are considered insignificant and take effect upon publication on the Website (unless otherwise specified).
(d) If the changes are caused by the requirements of the law/regulations of authorized bodies or are necessary to prevent a security/compliance incident, CityPay has the right to apply them immediately, simultaneously posting the information on the Website and sending push notifications to the Personal Account.
12.2. Notifications of changes.
Notifications are made exclusively by publication on the Website and display of a push notification the next time the User logs into their Personal Account. The fact of the push notification being displayed is recorded in the logs and is considered to be proper notification. Acceptance of the changes is made by clicking the consent button in the push notification/Personal Account.
12.3. The User’s right to refuse.
The User has the right not to accept significant changes and to stop using the Services by initiating the closure of the account (clause 12.5) and transferring their Cryptoassets to an external address. Access to operations may be restricted until significant changes are accepted.
12.4. Termination at the initiative of CityPay.
CityPay has the right to suspend service and/or terminate the Agreement unilaterally without prior notice to the User (unless notice is required by law) if:
(a) the User violates the Offer and/or legal requirements (including AML/CFT/FP and sanctions restrictions);
(b) the User has not passed/evades KYC/periodic verification, has not provided the requested documents;
(c) there are signs of compromise of authorization funds, fraud, use of mixer services and/or other high-risk sources;
(d) mandatory instructions from authorized bodies have been received or restrictions have been imposed by law;
(e) there are objective security/technical reasons (critical vulnerabilities, incidents);
(f) the license/right to engage in the relevant type of activity has been terminated/suspended or the provision of Services is being terminated.
12.5. Termination at the initiative of the User.
The User has the right to terminate the Agreement at any time by submitting a request to close the account through the Personal Account/support service. Before closing the account, the User is obliged to transfer all Cryptoassets to an external address. If the transfer is impossible due to legal reasons/regulations/blocking, CityPay shall act within the limits of legal restrictions.
12.6. Consequences of termination.
(a) From the date of termination of the Agreement, access to the Personal Account may be restricted (except for functions necessary for the legally permissible return of assets/receipt of statements).
(b) CityPay shall cease processing new Orders, except for transactions necessary to return assets to the User and/or complete previously initiated procedures to the extent not prohibited by law.
(c) CityPay’s obligations to store documents/logs, maintain confidentiality, and protect personal data shall remain in effect for the periods established by law and the Offer.
(d) The provisions of the Offer that, by their nature, remain in force after termination (liability, dispute resolution, personal data, force majeure, etc.) shall remain in force.
12.7. Withdrawal of Offer.
CityPay has the right to withdraw this public Offer at any time for new Users. The withdrawal does not affect previously concluded Agreements; they remain in force until terminated in accordance with this section.
FINAL PROVISIONS
13.1. Applicable law.
This Offer, Agreement, and the relations between the Parties shall be governed by the laws of the Republic of Uzbekistan.
13.2. Dispute resolution.
(a) The parties shall comply with the pre-trial procedure: the claim shall be sent electronically to CityPay’s email address. The claim shall be considered within 30 (thirty) calendar days.
(b) If no agreement is reached, the dispute shall be considered by the competent courts at the place of registration of CityPay, unless mandatory rules dictate otherwise.
13.3. Entry into force and term of validity.
The Offer shall enter into force upon its publication on the Website and shall remain in force until its withdrawal/replacement with a new version. An individual Agreement between CityPay and the User shall be deemed concluded upon explicit acceptance of the Offer in the web interface (checkbox/consent button) only. Implicative actions are not recognized as acceptance. The Agreement is valid indefinitely until terminated in accordance with Section 12.
13.4. Electronic form and legally significant messages.
(a) The Parties recognize the legal force of electronic documents and messages generated and posted on the Website/in the Personal Account, including push notifications upon login. A message is considered delivered if there is objective confirmation of its placement/display in the Personal Account (system logs).
(b) All dates/terms specified in the Offer and electronic documents are determined according to Tashkent time (UTC+5), unless otherwise specified.
13.5. Contact details.
JV LLC “City Pay Gate” (TIN: 311606433)
Address: 100100, Republic of Uzbekistan, city of Tashkent, Yakkasaray district, Mukhandislar MFY, Shota Rustaveli street, bldg. 53B
Website: https://citypay.uz
E-mail address: uzsupport@citypay.io
13.6. Language.
The Offer is provided in Uzbek, Russian, and English. In case of discrepancies, the Russian version shall prevail, unless otherwise specified in the publication notice.
13.7. Entire Agreement.
The Offer and the Appendixes/Privacy Policy attached thereto constitute the Entire Agreement between the Parties and supersede any prior agreements on the subject matter of the Offer.
13.8. Invalidity of Certain Provisions.
If any provision of the Offer is found by a court to be invalid or unenforceable, this shall not affect the validity of the remaining provisions. Such provision shall be interpreted or replaced to the maximum extent permitted by law to achieve the original purpose.

Appendix No. 1
to the Public Offer of JV LLC “City Pay Gate” dated December 16, 2025 SERVICES

Description of Services
The Contractor provides the User with the following services through the Personal Account on the Website https://citypay.uz:
• creation and maintenance of a custodial crypto wallet for Supported Cryptoassets (list in Appendix No. 2), with viewing of balances and transaction history;
• receipt (crediting) of Cryptoassets to the User’s wallet;
Transfers of Cryptoassets:
• intra-system (between wallets serviced by CityPay) — without CityPay commission and without Network Fees;
• external (to addresses outside the platform) — with only the Network Fees of the relevant network being withheld, as displayed prior to confirmation of the transaction.
Terms and conditions for transactions (receipt/transfer)
2.1 Receiving (depositing) of Cryptoassets
(a) The User selects an asset and network in their Personal Account and uses the specified details (address/QR; if necessary, memo/tag).
(b) The transfer is credited after the required network confirmations and mandatory checks in accordance with the law.
(c) Sending assets to an unsupported network, to an incorrect address, or without the required memo/tag may result in irretrievable loss. The Contractor is not obligated to restore such transactions.
(d) CityPay processing time is up to 24 hours from the moment the conditions of clause (b) are met.
2.2 Intra-system transfer
(a) Initiated by the identifier/address specified in the Personal Account.
(b) No CityPay commission or Network Fee is charged.
(c) The transaction cannot be canceled after confirmation by the User.
(d) CityPay processing time — up to 24 hours.
2.3 External transfer (to an external wallet)
(a) The User specifies the asset, network, and recipient’s address (and, if necessary, memo/tag).
(b) Before confirmation, the estimated amount of the Network Fee and the total amount to be debited are displayed in the Personal Account.
(c) The Network Fee is deducted by CityPay from the User and transferred to the relevant network. The fee amount is determined by the network rules and may differ from the preliminary estimate due to network congestion.
(d) Once the transaction is sent to the network, the operation is irreversible. The speed and success depend on the network and third-party infrastructure.
(e) CityPay processing time is up to 24 hours (further network confirmation time does not depend on CityPay).
(f) Minimum send amount. Sending transactions less than the minimum amount are not accepted/rejected. For other Cryptoassets, the equivalent of 10 USDT is applied, based on the CityPay exchange rate at the time the send request is received.
2.4. Cancellation, refusal, suspension
(a) Before sending a transaction to the network, the Contractor has the right to cancel/refuse the transaction on grounds provided for by law (including AML/CFT/FP control and sanctions compliance) and/or for technical reasons.
(b) Once the transaction has been sent to the network, cancellation is not possible; the network fee retained is non-refundable.
(c) The Contractor may request additional information/documents required by law; until they are provided, the transaction may be suspended.
(d) Information about the status is always available in your Personal Account.
2.5 Terms of Completion
(a) All transactions processed by CityPay (receipt after network confirmations, internal and external transfers before broadcasting to the network) are completed within 24 hours.
(b) For external transfers, subsequent network confirmations are subject to the rules of the relevant network and may take additional time, over which CityPay has no control.
2.6 Confirmation and statuses
(a) Before sending a transaction, the User confirms it in their Personal Account.
(b) The Personal Account provides information about the status, amounts, and Network Fees withheld; for external transfers, it also provides the transaction identifier (TxID).
2.7. Additional Terms and Risks
(a) Supported Assets and Networks are listed in Appendix No. 2. Sending assets outside of Supported Networks, to incorrect addresses, or through third-party bridges/contracts is not supported and may result in the loss of assets.
(b) The User is responsible for verifying the correctness of the details and bears the risks associated with incorrectly specified addresses/networks/memos (tags).
(c) When high-risk/prohibited sources/recipients are identified, the rules of clause 4.16 of the Offer (return/non-return, freezing of assets, reporting of a suspicious transaction) shall apply.
2.8 Transaction limits (uniform for all, in USDT).
(a) one-time sending — up to 3,000 USDT;
(b) one-time receiving — up to 10,000 USDT;
(c) daily cumulative volume (sending and receiving) — up to 10,000 USDT;
(d) monthly cumulative volume (sending and receiving) — up to 50,000 USDT;
(e) maximum 30 transactions within 24 hours.
(f) The minimum sending amount is 10 USDT (or equivalent).
If a transaction is made in another asset, its volume for limit purposes is converted into USDT based on the CityPay rate at the time of registration. Incoming transactions in excess of 10,000 USDT are not credited and are subject to return to the sender (if possible) minus the network fee, or are frozen in the cases specified in clause 4.16 of the Offer. Limits and the minimum sending amount are controlled using the USDT equivalent at the time of transaction registration.

Appendix No. 2
to the Public Offer of JV LLC “City Pay Gate” dated December 16, 2025 THE LIST OF SUPPORTED CRYPTOASSETS AND NETWORKS

List of Assets
As of the date of publication, the following Cryptoassets are supported:
- BTC (Bitcoin) - BTC Network (Bitcoin)
- LTC (Litecoin) - LTC Network (Litecoin)
- ETH (Ethereum) - Ethereum Network (ETH)
- XRP (XRP Ledger) - XRP Ledger Network (XRP)
- SOL (Solana) - Solana Network (SOL)
- BNB (BNB Smart Chain / BSC) - BNB Smart Chain Network (BEP20)
- USDT (Tether USD) – Polygon (Polygon POS), Tron (TRC-20), Ton (TON), BNB Smart Chain (BEP20) Networks
- TON (Toncoin) - TON Network
- XAUT (Tether Gold) - Ethereum Network (ETH)
Commissions and internal transfers
• For external transfers, only the Network Fee of the relevant network is withheld (displayed before the transaction is confirmed). CityPay withholds the Network Fee from the User and transfers it to the network.
• Transfers between CityPay wallets are free of Commission and Network Fees.
Important warnings for the User
• Always check the asset, network, and address before sending.
• Sending to a different network, to an incorrect address, or without the required memo/tag may result in irretrievable loss.
• Cross-network bridges/exchanges are not provided as part of the Offer.
• Technical requirements of the networks themselves may apply (e.g., minimum amount/dust, mandatory memo/tag).
• CityPay transactions (receipt after network confirmations, internal and external transfers before broadcasting to the network) are processed within 24 hours; further confirmations on the network depend on the rules of the respective network.
• The minimum sending amount is 10 USDT (or equivalent);
Updating the list
The list of Assets and Supported Networks may be changed by CityPay unilaterally in accordance with the procedure provided for in the Offer. The current version is always available in your Personal Account/on the Website.