Legal

Terms & Conditions

Last Updated: 28 April 2025

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1. EFFECTIVE DATE

The terms and conditions in this document shall come into effect on 28th April 2025.

2. IMPORTANT - PLEASE READ

It is important that you read this document carefully, and which comprises of two main parts:
1. The first part sets out the general terms and conditions that govern the provision and use of the StraitsX Website and StraitsX Services (“General T&Cs”); and
2. The second part, the Appendix, contains additional terms and conditions that govern your access and use of our various Services (“Additional T&Cs”).
  Together, the two parts constitute the complete StraitsX terms and conditions (“StraitsX T&Cs”)
The Additional T&Cs governing your access and use of our various Services are as follows, and will only apply to you when you sign up for or use the corresponding Services:‍
In case of conflict or any inconsistency between the General T&Cs and the Additional T&Cs applicable to the Services used by you, the latter (i.e. the Additional T&Cs) will prevail, subject to any exceptions stated therein. ‍
Legal Relationship - By electronically indicating your acceptance of the StraitsX T&Cs, you (i) acknowledge that you have read and understand the entirety of the StraitsX T&Cs and (ii) agree to be bound by them. This acceptance creates a legally binding contract between you (“user”, “you” or “your” as the context requires) and all relevant entities of StraitsX (as defined below) (collectively to be referred to as “we”, “us, “our”), under which the terms of the contract are exclusively those set forth in these StraitsX T&Cs. The StraitsX T&Cs govern all aspects of our relationship and apply to each electronic form and/or contract executed by you, unless expressly stated otherwise. For the avoidance of doubt, the StraitsX T&Cs govern any and all Services provided to you, including those Services you may currently not subscribe to or receive but may be offered to you in the future. As such, please read the StraitsX T&Cs carefully before acceptance. If you do not agree with any of the terms and conditions in the StraitsX T&Cs, please do not electronically indicate your acceptance of the StraitsX T&Cs and/or access and use any of our Services.‍
Applicable version of StraitsX T&Cs - your use of the Services is governed by the version of the StraitsX T&Cs in effect on the date of such use. We may amend the StraitsX T&Cs (and any additional incorporated terms and conditions) at any time by posting a revised version on the StraitsX Website. The revised version will be effective from the time we post it. If the revised version of the StraitsX T&Cs includes a material change, we will use reasonable efforts to provide you with notice of such changes, such as by providing notice through the StraitsX Website. If you do not agree to be bound by any revisions made by us to the StraitsX T&Cs, you must stop accessing and using all of our Services. By continuing to use any of our Services, you will be deemed to have agreed to all revisions made by us to the StraitsX T&Cs.‍
Right to offer, modify, suspend or terminate Services - the Services to be provided by us under these StraitsX T&Cs shall be offered at our sole discretion. We reserve the right, at our sole discretion, to offer, modify, suspend or terminate any or all of the Services provided to you under these StraitsX T&Cs at any time without penalty.‍
Sanctions Notice & High-Risk Locations - the Services are not available for use, and should not be used by, any person who is a citizen of or having habitual residence in any country, state, or territory that is the subject of any economic or trade sanctions or restrictive measures issued by Singapore, the United Nations, the United States or the European Union (“sanctions”), by any person who is the subject of sanctions, or by any person who is a citizen of or having habitual residence in any country, state, or territory where the buying, selling, trade, or dealing in digital assets (including stablecoins) is prohibited. Additionally, the Services are not available for use by any person from a location that we have identified as high risk based on our internal risk assessment. If you are from a country, state, or territory that is the subject of sanctions, are yourself subject to sanctions, or are from a country, state or territory where the buying, selling, trade, or dealing in digital assets (including stablecoins) is prohibited, or are from a location we have identified as high risk, you must not use, or attempt to use any of our Services, whether by vpn or otherwise. We reserve the right to terminate any use of our Services that is in breach of this notice. For a complete list of prohibited and high-risk countries, states, or territories, please refer to the list available on our StraitsX Website. If you are from a location on this list, you are not permitted to use any of our StraitsX services.

3. ADDITIONAL DEFINITIONS

The below-listed capitalized terms shall have the following prescribed definitions in the StraitsX T&Cs (unless specifically provided for): ‍
1. “Acceptable Use Policy” refers to the Restricted Activity or Restricted Activities in this General T&Cs. ‍
2. “Accredited Investor” means any of the following persons:
  1. an individual mentioned in section 4A(1)(a)(i) of the Securities and Futures Act 2001;
  2. a corporation mentioned in section 4A(1)(a)(ii) of the Securities and Futures Act 2001;
  3. a trustee mentioned in section 4A(1)(a)(iii) of the Securities and Futures Act 2001 read with regulation 2(1) and 2(3) of the Securities and Futures (Classes of Investors) Regulations 2018; and
  4. a person mentioned in section 4A(1)(a)(iv) of the Securities and Futures Act 2001 read with regulation 2(2) of the Securities and Futures (Classes of Investors) Regulations 2018.
3. “API” means application programming interface.
4. “Applicable Laws” means any and all applicable laws, statutes and regulations, directives, notices, guidelines, codes, practice notes, circulars, policy statements, rules, ordinances, orders, requests, requirements, judgements, decrees or writs (in each case whether or not having the force of law) of any governmental, regulatory, judicial body, agency, from any jurisdiction including, without limitation:
  1. The Payment Services Act 2019 and all subsidiary legislation pertaining to the said Act, as the same may be amended, supplemented or replaced from time to time;
  2. Any directives, notices, guidelines, codes, practice notes, circulars, policy statements, rules, requests or requirements (in each case whether or not having the force of law) from time to time published or issued by the Monetary Authority of Singapore, as the same may be amended, supplemented or replaced from time to time, including but not limited to MAS Notices such as (i) PSN03 Notice on Reporting of Suspicious Activities and Incidents of Fraud, (ii) PSN04 Notice on Submission of Regulatory Returns, (iii) PSN07 Notice on Conduct and (iv) PSN08 Notice on Disclosures and Communications; and
  3. All laws, statutes, regulations, guidelines, directives, rules, directions, codes, ordinances, judgements, decrees, writs or orders enacted or issued in relation to anti-money laundering, countering the financing of terrorism and sanctions, including but not limited to the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992, the Terrorism (Suppression of Financing) Act 2002, the respective regulations promulgated under the Monetary Authority of Singapore Act 1970, MAS Notice PSN01 Prevention of Money Laundering and Countering the Financing of Terrorism – Specified Payment Services, MAS Notice PSN02 Prevention of Money Laundering and Countering the Financing of Terrorism – Digital Payment Token Service, and other related MAS-issued guidelines.
5. “Attached Bank Account” refers to the bank account(s) beneficially owned by you and which is linked to your StraitsX Accounts.
6. “Authorised Users” refers to individuals assigned the following specific roles within your StraitsX Accounts: such as ‘Owner’, ‘Admin’, ‘Operation’ and ‘Developer’, and anyone else that has control of your StraitsX Accounts and is able to transact on your behalf.
7. “Business Day” means a day other than a Saturday, Sunday or a public holiday in Singapore.
8. “Corporate Account” refers to any account opened with StraitsX meant for incorporated entities.
9. “Chargeback” means a request that a user files directly with his or her bank to invalidate a payment.
10. “Claim” means a challenge to a payment that a user files directly with us, and we, in our absolute discretion, are of the opinion that the underlying products/goods/assets/property or services paid for using our StraitsX Services were not received or significantly not as described.‍
11. “Communications” means any emails which we may send to the primary email address that you have provided to us as part of your Customer Information when you opened your StraitsX Accounts, as well as any text messages or calls, including autodialled and pre-recorded messages from us, which we may from time to time send to the telephone number (including your mobile telephone number) that you have provided to us.
12. “Communication Channel” means such method(s) of communication as approved by StraitsX and used between you and StraitsX from time to time, which may include (without limitation) telephone, email, Whatsapp, Telegram, online chat functionality and, if available, the StraitsX Dashboard. StraitsX may discontinue the use of a Communication Channel at any time for any reason.
13. “Counterfeit StraitsX Tokens” refers to alternative or derivative versions of StraitsX Tokens created by parties unaffiliated with StraitsX. These tokens may involve wrapping, altering the original StraitsX Tokens, or developing and deploying a smart contract on a blockchain system to pass off such tokens as genuine StraitsX Tokens.
14. “Customer Information” refers to the personal and business details provided by you or your Authorized Users to open and maintain your StraitsX Accounts. This includes, but is not limited to, identifying information such as full name and unique identification number, and contact information like primary email address and telephone number.
15. “Digital payment tokens” shall have the meaning ascribed to it under section 2(1) of the Payment Services Act 2019 and interpreted in light of other applicable regulatory materials, guidance and/or Frequently Asked Questions (FAQs) issued by the Monetary Authority of Singapore. For the avoidance of doubt, “digital payment tokens” would include stablecoins, including single-currency stablecoins.
16. “Downtime” refers to the extended period during which all activities related to StraitsX Tokens, such as issuance, redemption, purchase, sending, and receiving, are suspended. This suspension occurs in the event of a Fork of a StraitsX Token, and during this time, you will be unable to instruct us to perform any transactions involving StraitsX Tokens.
17. “E-money” shall have the meaning ascribed to it under section 2(1) of the Payment Services Act 2019 and interpreted in light of other applicable regulatory materials, guidance and/or Frequently Asked Questions (FAQs) issued by the Monetary Authority of Singapore.
18. “Executed Transaction” refers to an OTC or Swaps transaction for which Execution has occurred, meaning that you have accepted the Trade Confirmation by indicating your acceptance to StraitsX through a Communication Channel, thereby creating a binding and final agreement on the terms set out in the Trade Confirmation.
19. “Execution” refers to the act of indicating your acceptance of a Trade Confirmation through a Communication Channel, which constitutes a binding and final agreement to an OTC or Swaps transaction between StraitsX and you on the terms set out in the relevant Trade Confirmation‍
20. “External Blockchain Wallet” means any blockchain wallet which is not opened directly with StraitsX, and with a whitelisted/verified status which reflects that StraitsX has verified that you have ownership and control over such blockchain wallet, and satisfied such other requirements as StraitsX may deem fit.
21. “Fork” refers to a sudden change in the operating rules of a blockchain system that can occur when a significant portion of the users accepts a patch or upgrade of the source code. This can result in the creation of two separate networks, each storing records of the StraitsX Tokens, leading to multiple versions of the StraitsX Tokens that remain separate until the blockchain systems are merged.‍
22. “Information” means any information that you (or other users) provide to us, including but not limited to personal information, financial information (including the account number of your Attached Bank Account), or other information related to you, your business, any intended transaction or other users.
23. “Merchant Account” refers to any account opened with SPSPL or XPL meant for merchants to accept/withdraw fiat payments from/to any counterparty or to accept deposits/withdrawals of StraitsX Tokens and Non-StraitsX Tokens from/to any counterparty (whichever is applicable depending on the context).
24. “Merchant Account Users” any StraitsX user who holds or operates a Merchant Account.
25. “Non-StraitsX Account” means any account, device or facility that may hold StraitsX Tokens and/or Non-StraitsX Tokens, but which is not opened, maintained and/or operated by StraitsX. For the avoidance of doubt, this includes any account opened, maintained and/or operated by or with Platform Users or Merchant Account Users, and any blockchain address or wallet controlled by any person or entity (other than SPSPL or XIPL).
26. “Non-StraitsX Account Token Holder” means any person or entity that holds StraitsX Token(s) in a Non-StraitsX Account.
27. “Non-StraitsX Token” means any supported digital assets (including, without limitation, any digital tokens or stablecoins) or any other digital payment tokens not issued by StraitsX on a blockchain / distributed ledger.
28. “OTC” means over-the-counter. It may include the use of technology tools including automation by StraitsX.
29. “OTC & Swaps Services” refers to the combined offerings of OTC Service and Swaps Service by StraitsX.
30. “OTC Service” refers to the service where StraitsX may, at its sole discretion, permit you to buy, sell or exchange StraitsX Tokens and supported Non-StraitsX Token on an OTC basis (not via the StraitsX Dashboard) as specified in these StraitsX T&Cs (each specific transaction to be called “OTC transaction”).
31. “Personal Account” refers to any account opened with SPSPL or XPL meant for personal individual use.
32. “Platform User” refers to Merchant Account Users who integrate StraitsX Services into their platform or marketplace to manage the payment experience for their end-users. These Platform Users can create new StraitsX Accounts on behalf of their end-users, send payments, receive payments, and withdraw funds from their end-users' StraitsX Accounts on their behalf.‍
33. "Platform/Merchant Customer" refers to the end-users or customers of Platform Users and Merchant Account Users who may have Non-StraitsX Accounts opened and operated on their behalf by these Platform Users and Merchant Account Users.
34. “Policy” or “Policies” means any policy or other agreement between you and StraitsX that you entered into on the StraitsX Website, or in connection with your use of the StraitsX Services.
35. “Quoted Rate” means the exchange rate offered by StraitsX via the OTC Service for exchanging your StraitsX Tokens for Non-StraitsX Tokens (or vice versa).
36. “Relevant Money” shall, insofar as it relates to domestic money transfer service, cross-border money transfer service, merchant acquisition service and/or e-money issuance service that StraitsX (through XPL) provides as a Major Payment Institution, as defined, and under the Payment Services Act 2019 have the meaning ascribed to it in section 23(14) of the Payment Services Act 2019, except that:
  1. The reference to “major payment institution” in the definition of “relevant money” under section 23(14) of the Payment Services Act 2019 shall refer to the relevant StraitsX entity; and
  2. The reference to a “customer” in the definition of “relevant money” under section 23(14) of the Payment Services Act 2019 shall refer to any user (as defined herein).
  3. For the avoidance of doubt, "Relevant Money" shall exclude all moneys received from, or on account of, any user, in exchange for (i) the sale and/or issuance of StraitsX Tokens by StraitsX Payment Services Pte Ltd, or (ii) the sale of Non-StraitsX Tokens by StraitsX Payment Services Pte Ltd.
37. “Reversal” means StraitsX reverses a payment/transfer you received because (a) it is invalidated by the sender’s bank, (b) it was sent to you in error by StraitsX, its parent, subsidiaries, affiliates, or any direct or indirect StraitsX subsidiary, (c) the sender of the payment/the transferor did not have authorisation to send the payment or make the transfer (for example: the sender used a stolen internet banking account, debit card or credit card), (d) the sender of the payment or the transferor sent multiple payments or made multiple transfers erroneously, or such other manifest or obvious error, (e) you received the payment/transfer for activities that violated the StraitsX T&Cs, the Acceptable Use Policy, or any other Policy, or (f) StraitsX decided a Claim against you.
38. ‍“Reserve” means a percentage of the funds (including StraitsX Tokens and/or Non-StraitsX Tokens) in your StraitsX Accounts that we hold in order to protect against the risk of Reversals, Chargebacks, Claims or any other liability related to your StraitsX Accounts and/or use of the Services.
39. “Reserve Assets” refers to the assets held in segregated accounts by STX XSGD (where XSGD is concerned) and STX XUSD (where XUSD is concerned), equivalent to at least 100% of the par value of all outstanding XSGD and XUSD in circulation.
40. “Restricted Activity” or “Restricted Activities” refers to the prohibited activities described in clause 10.1 of the General T&Cs.
41. “Safeguarding Institution” shall have the meaning ascribed to it under section 23(14) of the Payment Services Act 2019 read with Regulation 16(6) of the Payment Services Regulations 2019.
42. “Safeguarding Person” refers to the external custodian with whom we will deposit the StraitsX Tokens and supported Non-StraitsX Tokens into a trust account pursuant to Regulation 18B(1) of the Payment Services Regulations 2019 (said regulation will be in force as of 4 October 2024).
43. “STX XSGD” refers to StraitsX SGD Issuance Pte Ltd, the StraitsX entity responsible for the issuance of the XSGD stablecoin.
44. “STX XUSD” refers to StraitsX USD Issuance Pte Ltd, the StraitsX entity responsible for the issuance of the XUSD stablecoin.
45. “SPSPL” refers to StraitsX Payment Services Pte Ltd, the StraitsX entity that (a) provides digital payment token services to StraitsX users, and (b) is the authorised distributor of various StraitsX Tokens such as XSGD and XUSD.
46. “StraitsX” refers to StraitsX Holdings Pte Ltd, SPSPL, STX XSGD, STX XUSD, XPL and XIPL (to be collectively or in any combination referred to as “StraitsX”, “we”, “us”, “our” as the context requires).
47. “StraitsX Accounts” refers to the StraitsX Digital Assets Account, StraitsX Earn Account, StraitsX Fiat Account and/or any other accounts that StraitsX may introduce for the purposes of holding, receiving, sending, or otherwise transacting in funds or any supported digital assets.
48. “StraitsX Credit” StraitsX Credits are non-refundable and non-redeemable credits in the form of StraitsX Tokens, Non-StraitsX Tokens, or StraitsX E-money, which may be obtained through promotional activities or direct purchase, deposited into your StraitsX Accounts, and used for select transactions or for paying StraitsX service fees.
49. “StraitsX Digital Assets Account” means any account opened directly with SPSPL (i.e. StraitsX Payment Services Pte Ltd), including a Personal, Corporate or Merchant Account, and includes any legacy and future types of accounts we may introduce, which may hold the following:
  1. Your user profile containing your Information; and
  2. Your StraitsX Digital Assets Wallet.‍
50. “StraitsX Dashboard” means the dashboard of your StraitsX Accounts, accessible at [https://app.straitsx.com/] or [https://biz.straitsx.com/].
51. “StraitsX Digital Asset Wallet” means a Wallet provided by us which you may use to store your StraitsX Tokens and/or any Non-StraitsX Tokens.
52. “StraitsX E-money” means any E-money issued by XPL and stored in your StraitsX Fiat Account.
53. “StraitsX Earn Account” means any account opened directly with XIPL (i.e. Xfers Investment Pte Ltd), including a Personal or Corporate Account, and any future types of accounts we may introduce, which may hold the following, where applicable:
  1. Your user profile containing your Information; and/or
  2. Your StraitsX Earn Wallet.
54. “StraitsX Fiat Account” means any account opened directly with XPL (i.e. Xfers Pte Ltd), including a Personal, Corporate, or Merchant Account, and includes any legacy and future types of Account we may introduce, which may hold the following:
  1. Your user profile containing your Information; and
  2. Your StraitsX E-Money.
    For the avoidance of doubt, all references to StraitsX Fiat Accounts include references to accounts previously referred to as “Fazz Accounts”.
55. “StraitsX Retention Period” refers to the specific timeframe determined by StraitsX during which transaction history data and personal data are retained and available for disclosure. ‍
56. “StraitsX Services” or “Services” means all products, services, features, technologies and/or functionalities offered by StraitsX via the StraitsX Website or through any other means, and includes but is not limited to, the following products and services:
  1. StraitsX Accounts;
  2. Purchase and redemption of StraitsX Tokens and Non-StraitsX Tokens;
  3. OTC & Swap Services;
  4. Making any payment, transfer or withdrawal using the StraitsX Tokens, Non-StraitsX Tokens and/or StraitsX E-money; and/or
  5. API services.
57. “StraitsX Tokens” means any digital payment token issued by StraitsX entities such as the XSGD and XUSD.
58. "StraitsX Token Contract" refers to the specific smart contract developed and deployed by StraitsX on the relevant blockchain system, governing the issuance, transfer, and management of StraitsX Tokens.
59. “StraitsX Website” refers to https://www.straitsx.com‍
60. “Swaps Service” refers to the service where StraitsX may, at its sole discretion, permit you to exchange StraitsX Tokens for supported Non-StraitsX Tokens via the StraitsX Dashboard, and vice versa, as specified in these StraitsX T&Cs (each specific transaction to be called “Swaps transaction”).
61. “Temporary Holding Balance” refers to the portion of funds in your StraitsX Accounts that exceeds the permitted limits and is held temporarily, pending withdrawal to your Attached Bank Account.‍
62. “Trade Instruction” refers to the request submitted by you to StraitsX to enter into an OTC or Swaps transaction based on an exchange rate. Each Trade Instruction must include the relevant trading pairs and the applicable notional amount, along with any other details requested by StraitsX from time to time.‍
63. “Trade Confirmation” refers to the written confirmation provided by StraitsX upon accepting a Trade Instruction from you, which sets out the key terms of the OTC or Swaps transaction. Each Trade Confirmation includes details such as the relevant trading pairs, the applicable exchange rate, and the notional amount of StraitsX Tokens and/or Non-StraitsX Tokens to be transacted.
64. “Verified Account '' refers to the status tagged to StraitsX Accounts that reflects that we have verified the identity of the account holder and such other requirements as we may deem fit. A Verified Account status does not constitute an endorsement of a user or a guarantee of a user’s business practices.
65. “Wallet” means a wallet which is able to hold stored value in the form of E-money or a cryptographic digital wallet capable of being used to store supported digital payment tokens.
66. “XIPL” refers to Xfers Investment Pte Ltd, the StraitsX entity that provides the StraitsX Earn Service to eligible StraitsX users.
67. “XPL” refers to Xfers Pte Ltd, the StraitsX entity that provides fiat and E-money related services to StraitsX users.
68. “XSGD” means the Singapore dollar denominated stablecoin issued by STX XSGD, and as acknowledged by the Monetary Authority of Singapore to be compliant with the upcoming stablecoin regulatory framework (as published by the Monetary Authority of Singapore in the ‘Response to Public Consultation on Proposed Regulatory Approach for Stablecoin-related activities’ paper dated 15 August 2023).
69. “XUSD” means the US dollar denominated stablecoin issued by STX XUSD, and as acknowledged by the Monetary Authority of Singapore to be compliant with the upcoming stablecoin regulatory framework (as published by the Monetary Authority of Singapore in the ‘Response to Public Consultation on Proposed Regulatory Approach for Stablecoin-related activities’ paper dated 15 August 2023

4. ELIGIBILITY

To be eligible to use any of our StraitsX Services, the following requirements must be met:
1. You must be able to form legally binding contracts under Singapore law. Without limiting the generality of the foregoing, this means that for individuals, you must be at least 18 years old or older; for corporate bodies, you must have obtained the necessary corporate and/or regulatory approvals to use our Services.
2. You affirm, represent and warrant that (i) you have the right, authority and capacity to agree to and be bound by the terms and conditions in the StraitsX T&Cs, (ii) you meet all of the eligibility requirements as set forth in this clause and any other clauses in the StraitsX T&Cs, and (iii) your access and use of the Services does not violate any Applicable Laws, including those in your jurisdiction.
3. You agree to abide by the terms and conditions of the StraitsX T&Cs.
4. You agree to perform (or refrain from performing) any and all such acts or things as may be required or expedient for the purposes of complying or facilitating our compliance with the StraitsX T&Cs, any Applicable Laws or to avoid violation of any Applicable Laws.

5. YOUR INSTRUCTIONS AND AUTHORISATIONS

Giving instruction

You are solely responsible for accurately entering any instruction and/or information in respect of any transaction to be carried out using our StraitsX Services, including the purchase, crediting, payment, transfer, exchange, redemption or withdrawal of StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens. You are required to, and agree to provide us with all accurate and complete information that we may require from you, including but not limited to any information required by us to comply with any regulatory reporting obligation or any Applicable Laws, failing which we reserve the right to not carry out any of your instructions.

Authorisation to act on any instruction emanating from your StraitsX Accounts

You unconditionally authorise StraitsX, regardless of the circumstances prevailing at the time of such instructions, the nature of the arrangement, services or transaction made pursuant to such instruction or the amount of money involved and notwithstanding any error, misunderstanding, unauthorised access to your StraitsX Accounts, fraud, forgery or lack of clarity or authorisation in the terms of such instruction, to:
1. Act on any and all instructions (including any duplicate or erroneous instructions) that emanate from your StraitsX Accounts, including but not limited to any instruction which we believe was given by you, your Authorised Users, or any Platform User or Merchant Account User linked to your StraitsX Accounts; and
2. Charge your StraitsX Accounts, Attached Bank Accounts, or debit card, based on any instructions that emanate from your StraitsX Accounts.
Any instruction emanating from your StraitsX Accounts is irrevocable, unconditional and binding on you, and is deemed to have been issued by you or on your behalf. Once the instruction is issued through your StraitsX Accounts, you shall not rescind or withdraw such instruction without our consent.

No obligation to confirm, act or refuse to process instruction

You acknowledge that StraitsX is under no obligation to (a) act, confirm or refuse to act on any instruction and/or information, (b) monitor or detect any inaccuracies in any instruction provided by you, including any duplicate or erroneous instruction, and (c) refuse to process such inaccurate instructions.

No obligation to verify identity or authority of any person giving any instruction

StraitsX shall not be under any obligation to verify the identity or authority of any person responsible for issuing any instruction through your StraitsX Accounts, and the legitimacy and authenticity of such instruction.

Receipt and records of instruction

Your instructions shall not be considered to be received by us until they have actually reached our central system successfully.
Our records of all instructions issued from your StraitsX Accounts will be conclusive and binding on you for all purposes.

Authorising Platform Users or Merchant Account Users

In order to be able to provide you with the use of their services or platforms, Platform Users or Merchant Account Users may require you to link your StraitsX Accounts to their website, app, software or service. If you do so, you agree and authorise that we may permit these users to (without any further action or confirmation on your part):
1. Access your StraitsX Accounts, including the account balances, payment data and transaction history;
2. Create charges and transactions in your StraitsX Accounts;
3. Make transfers, send payments, receive payments and redeem/withdraw StraitsX Tokens / Non-StraitsX Tokens from your StraitsX Accounts into a bank account, or give us such other instructions on your behalf (which shall be deemed to have come from you); and
4. Deduct from your StraitsX Accounts (where there are sufficient funds) fees and charges arising from services provided or transactions conducted through the Platform User’s or Merchant Account User’s services.
If you link your StraitsX Accounts to a Platform User’s or Merchant Account User’s website, app, software or service, you agree and authorise that we may provide them with your information, including your personal information and information relating to your StraitsX Accounts. These Platform Users and Merchant Account Users may have their own privacy policy, and you agree that we shall not be liable for how these users use, share or disclose your Information.

Rejecting instructions

You acknowledge and agree that we may refuse to (a) act upon an instruction, (b) defer acting thereon or (c) seek further information with respect to the instruction, for any reason, including but not limited to our suspicion on any of the following matters:
1. Your StraitsX Accounts are suspected by us to have been used, or the instruction is been suspected to have been issued, in furtherance of (a) a Restricted Activity, (b) a breach of the StraitsX T&Cs, or (c) an illegal, unlawful or criminal activity, including but not limited to any money laundering and terrorism financing activity, or any activity in breach of sanctions laws.
2. Your StraitsX Accounts are suspected by us, or a third party service provider to be a counterfeit, or to have been fraudulently or illegally issued or revalued, or to have been illegally accessed, modified or used in any way.
3. The StraitsX Tokens and/or Non-StraitsX Tokens in your StraitsX Accounts are insufficient or have been exhausted.
4. There is any breakdown in any StraitsX systems or a part of it, which disrupts the provision of any StraitsX Services to you, or disables you from accepting or processing the StraitsX Accounts as a means of effecting payment or a transaction.
5. StraitsX determines that the StraitsX Tokens and/or Non-StraitsX Tokens in your StraitsX Accounts are incorrectly or erroneously stated or reflected in the StraitsX Accounts or any records as having a higher or other value than its actual value due to any defect, damage, error or failure of, or programming in relation to, of any StraitsX system (including any data processing system or network system) or for any reason.

6. YOUR AUTHORISATION

You agree and authorise that (upon receiving your instruction to issue StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens to be credited into your StraitsX Accounts), StraitsX may act upon such instruction and to effect your selected payment method to pay for the amount of StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens to be credited (less any applicable fees).
You agree and authorise that (upon receiving your instruction to send StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens to another user or Non-StraitsX Account), we may act upon such instruction and to transfer the StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens from your StraitsX Accounts, bank account or debit card to the receiving user’s StraitsX Accounts or bank account or the receiving Non-StraitsX Account (less any applicable fees).
You agree and authorise that (upon receiving your instruction to receive StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens from another user or Non-StraitsX Account holder), we may act upon such instruction and to receive the StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens in your StraitsX Accounts (less any applicable fees).
You agree and authorise that (upon receiving your instruction to redeem, withdraw and/or sell some or all of your StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens in your StraitsX Accounts), we may act upon such instruction and to debit the corresponding amount (less any applicable fees) from your StraitsX Accounts to pay you with the withdrawal method you specify (subject to any restrictions or limits in the StraitsX T&Cs).

7. ATTACHED BANK ACCOUNT

You may specify your bank account(s) which are to be linked to your StraitsX Accounts (i.e Attached Bank Account). If you do so, you hereby represent that you are the lawful and authorised holder of the Attached Bank Account.
By specifying your Attached Bank Account, you hereby agree and authorise that we may effect, at any time, withdrawal of some or all of your funds (including StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens) in your StraitsX Accounts to your Attached Bank Account without your prior instruction. The withdrawal of the StraitsX Tokens and/or Non-StraitsX Tokens will be effected through a redemption / purchase of the StraitsXTokens and/or Non-StraitsX Tokens from you, for a corresponding amount of fiat currency, followed by the withdrawal of such fiat currency to your Attached Bank Account.

8. OUR ERRORS

We will rectify any error that we discover.
1. If an error results in you having less than the correct amount which you are entitled to, StraitsX will restore the balance of your StraitsX Accounts with the difference.
2. If an error results in you having more than the correct amount which you are entitled to, you authorise us to debit the extra funds from your StraitsX Accounts. If the deduction results in the balance of your StraitsX Accounts becoming negative, you agree to add funds into your StraitsX Accounts as soon as possible to restore your StraitsX Accounts to a zero or positive balance.

9. YOUR ERRORS

You provided a wrong bank account to us or wrong amount to be transferred

If you provided StraitsX with a wrong bank account for any transaction (including, but not limited to, redemptions, withdrawals, or third-party payments) or a wrong amount for any transaction, and the transaction was executed based on this information, you should: (a) immediately notify us by submitting a support ticket via the StraitsX Website, and provide details of the erroneous transaction; and (b) make efforts to contact the bank to which the funds were sent, requesting them to reverse or refund the transaction.
StraitsX will assist where possible, but is not responsible for the recovery of funds once they have been transferred based on the account information you provided

Erroneous transfer of funds to a wrong bank account not belonging to StraitsX

If you erroneously transferred money to the wrong bank account (i.e. a bank account that is not a StraitsX designated bank account), your only recourse will be to contact your bank and ask them to cancel the transfer. If you have transferred money successfully into the StraitsX designated bank account(s) but you entered the wrong initials / transaction reference code when initiating the bank transfer, you should contact StraitsX by submitting a support ticket via the StraitsX Website and send the necessary screenshots and documents to prove that the transfer originated from you. We are under no obligation to credit your StraitsX Accounts with StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens unless we are satisfied that your funds were successfully transferred into StraitsX designated bank account and with the correct initials / transaction reference code (as generated by the StraitsX system).

Outgoing transfers from StraitsX Digital Assets Wallet:

If you transferred StraitsX Tokens and/or Non-StraitsX Tokens from your StraitsX Digital Assets Wallet to a wrong Non-StraitsX Account:
1. You are solely responsible for ensuring that you have entered the correct wallet address tagged to the recipient Non-StraitsX Account.
2. If you erroneously transferred your StraitsX Tokens and/or Non-StraitsX Tokens from your StraitsX Digital Assets Wallet to a wrong Non-StraitsX Account, you may contact us by submitting a support ticket via the StraitsX Website. It is important to understand that such tokens might be irretrievably lost. You should concurrently also make efforts to contact the Non-StraitsX Account holder and/or service provider (if any) who has opened, maintained and/or operated the Non-StraitsX Account which the StraitsX Tokens and/or Non-StraitsX Tokens have been erroneously sent to.
If you transferred StraitsX Tokens and/or Non-StraitsX Tokens from your StraitsX Digital Assets Wallet to a Non-StraitsX Account that does not support such tokens, or if you transferred the said tokens via an unsupported blockchain system:
1. You are solely responsible for ensuring that the Non-StraitsX Account into which you are transferring StraitsX Tokens and/or Non-StraitsX Tokens supports such tokens. Additionally, you must ensure that the correct blockchain system is used for such transfers.
If you attempt to send StraitsX Tokens and/or Non-StraitsX Tokens from your StraitsX Digital Assets Wallet to a Non-StraitsX Account that does not support such tokens, or if you send supported tokens over an unsupported blockchain system, your StraitsX Tokens and/or Non-StraitsX Tokens may be lost forever.

Incoming transfers into your StraitsX Digital Assets Wallet:

If you wanted to transfer StraitsX Tokens and/or Non-StraitsX Tokens from a Non-StraitsX Account to your StraitsX Digital Assets Wallet but entered the wrong designated wallet address:
1. You are solely responsible for ensuring that you have entered the correct designated wallet address tagged to your StraitsX Digital Assets Wallet.
2. If you erroneously transferred your StraitsX Tokens and/or Non-StraitsX Tokens into a wallet address other than your StraitsX Digital Assets Wallet designated wallet address as specified in the payment instructions, you should contact StraitsX by submitting a support ticket via the StraitsX Website, and send the necessary screenshots and documents to prove that the transfer originated from you. It is important to understand that such tokens might be irretrievably lost. Furthermore, StraitsX does not guarantee that it will credit your StraitsX Digital Assets Account with the tokens that have been erroneously transferred to a wallet address other than the one designated by StraitsX.
If you transferred unsupported digital assets from a Non-StraitsX Account to your StraitsX Digital Assets Wallet, or if you transferred StraitsX Tokens and/or Non-StraitsX Tokens from a Non-StraitsX Account to your StraitsX Digital Assets Wallet via an unsupported blockchain system:
1. You are solely responsible for ensuring that only supported StraitsX Tokens and/or supported Non-StraitsX Tokens are sent to your StraitsX Digital Assets Wallet, and that the correct blockchain system is used for such transfers. For the avoidance of doubt, supported StraitsX Tokens are digital assets issued, recognized, and maintained by StraitsX on officially supported blockchain networks. These include tokens that are natively issued by StraitsX on a specific blockchain (e.g. XSGD on Polygon). These do not include any alternative or derivative versions of such tokens, including but not limited to (i) bridged, (ii) wrapped, (iii) otherwise altered versions of the original StraitsX Tokens or Non-StraitsX Tokens issued on other blockchain networks by third parties, or (iv) any token created or modified through the development and deployment of a smart contract on a blockchain system by any unauthorized party. Such tokens will be collectively referred to as “Unsupported Digital Assets”.
2. StraitsX does not support, recognize, or accept Unsupported Digital Assets Holder(s) of such Unsupported Digital Assets shall not be entitled to redeem or exchange them for fiat money with StraitsX, nor will they be able to assert any rights under these StraitsX T&Cs in relation to these Unsupported Digital Assets.
3. If you or any third party (including Non-StraitsX Account holders) attempt to send such Unsupported Digital Assets into your StraitsX Digital Assets Account (which includes sending a StraitsX Token or Non-StraitsX Token via an unsupported blockchain system), you may contact StraitsX by submitting a support ticket via the StraitsX Website. It is important to understand that such tokens might be irretrievably lost and that StraitsX does not guarantee that it will be able to assist with the recovery of the tokens in these situations.

Transfers between Non-StraitsX Accounts

If you transferred StraitsX Tokens and/or Non-StraitsX Tokens from a Non-StraitsX Account to a wrong Non-StraitsX Account:
1. If you erroneously transferred your StraitsX Tokens and/or Non-StraitsX Tokens from a Non-StraitsX Account to another Non-StraitsX account, your only recourse is to contact the other recipient account holder and/or the service provider (if any) responsible for that account to which the StraitsX Tokens and/or Non-StraitsX Tokens have been sent.

StraitsX has no obligation to assist with recovery

StraitsX is not responsible for, nor does it have any obligation to facilitate, the recovery or reimbursement of any losses, including and not limited to the loss of your funds, StraitsX Tokens, Non-StraitsX Tokens, Unsupported Digital Assets, and/or any unsupported tokens, incurred by you or anyone else due to your errors, including those reflected above in this clause 9. Any assistance provided by StraitsX is at its sole discretion. In cases where StraitsX is able and willing to facilitate the recovery, StraitsX reserves the right to charge a service recovery fee as well as any associated costs, such as gas fees, required to execute the recovery.

10. RESTRICTED ACTIVITY / ACCEPTABLE USE POLICY

In connection with your use of the StraitsX Website, your StraitsX Accounts, any of the StraitsX Services, or in the course of your interactions with us, our employees, other StraitsX users, or third parties, you agree to not:
1. Breach the StraitsX T&Cs or any other agreement or policy that you have agreed to with StraitsX;
2. Violate, attempt to violate, or instigate, facilitate, conspire or assist to violate, any Applicable Laws, including but not limited to any law, statute, ordinance, regulation, notice, order relating to sanctions, money laundering and terrorism financing;
3. Infringe our or any third party’s copyright, patent, trademark, trade secret or other intellectual property rights, or rights of publicity or privacy;
4. Sell counterfeit goods;
5. Sell any goods or provide any services that is (in our absolute opinion) undesirable, questionable or immoral;
6. Use StraitsX Services in relation to pyramid or ponzi schemes, matrix programs, other “get rich quick” schemes or such multi-level marketing programmes;
7. Use StraitsX Services in relation to betting, gambling, gaming or participating in a lottery (each of which are as defined in the Gambling Control Act 2022, including, but not limited to casino games, sports betting, horse or greyhound racing, fantasy sports, lottery tickets, other ventures that facilitate gambling, any games involving an element of chance for money or money’s worth, and sweepstakes);
8. Act in a manner that is defamatory, trade libellous, threatening or harassing;
9. Provide any false, inaccurate, or misleading Information, including but not limited to Customer Information, KYC data, and any supporting documentation related to such Information;
10. Use your StraitsX Accounts or the StraitsX Services to intentionally defraud StraitsX customers, or any other users, including but not limited to engaging in behavior intended to deceive, scam, or exploit for financial or other gain.
11. Engage in potentially fraudulent or suspicious activity and/or transactions;
12. Refuse to cooperate in an investigation or provide confirmation of your identity or any Information you provide to us;
13. Receive or attempt to receive funds, including StraitsX Tokens and Non-StraitsX Tokens, from both StraitsX and the other user (or bank, where applicable) for the same transaction;
14. Control StraitsX Accounts linked to other StraitsX Accounts that is suspected to have engaged in any of these Restricted Activities;
15. Conduct your business or use the StraitsX Services in a manner that results in or may result in complaints, disputes, Claims, Reversals, Chargebacks, fees, fines, penalties and other liability to StraitsX, other users, third parties or you;
16. Have a credit score from a credit reporting agency that indicates a high level of risk associated with your use of the StraitsX Services;
17. Use your StraitsX Accounts or the StraitsX Services in a manner that StraitsX, banks, Visa, MasterCard, American Express, Discover, JCB, Union Pay or any other electronic funds transfer network reasonably believes to be an abuse of the funds transfer system or card system or a violation of card association or network rules;
18. Use a credit card with your StraitsX Accounts to provide yourself a cash advance (or help others to do so);
19. Use StraitsX Services to make transactions for the primary purpose of earning rewards, perks, miles, points etc. with your credit card, debit card, or bank account (or help others to do so);
20. Allow your StraitsX Accounts to have a negative balance;
21. Access the StraitsX Services from a country that is not listed on StraitsX Worldwide page;
22. Disclose or distribute another user’s Information to a third party or use the Information for marketing purposes, unless you receive the user’s express consent to do so;
23. Send unsolicited email to a user or use the StraitsX Services to collect payments for sending, or assisting in sending, unsolicited email to third parties;
24. Take any action that imposes an unreasonable or disproportionately large load on our infrastructure;
25. Facilitate any viruses, trojan horses, worms or other computer programming routines that may damage, detrimentally interfere with, surreptitiously intercept or expropriate any system, data or Information;
26. Use an anonymising proxy;
27. Use any robot, spider, other automatic device, or manual process to monitor or copy the StraitsX Website without our prior written permission;
28. Use any device, software or routine to bypass our robot exclusion headers, or interfere or attempt to interfere with the StraitsX Website or the StraitsX Services;
29. Take any action that may cause us to lose any of the services from our Internet service providers, payment processors, or other suppliers;
30. Use, or allow the use of, your StraitsX Accounts or StraitsX Services to retain, acquire, possess, use, transfer, convert or conceal benefits that are known or suspected to originate from criminal conduct as defined by applicable laws, including but not limited to offences outlined in the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 or any similar legislation in any other jurisdiction;
31. Use your StraitsX Accounts to provide any type of payment service in Singapore without the necessary licence under the Payment Services Act 2019;
32. Use your StraitsX Accounts to conduct transactions with, or provide services to, individuals and entities listed on any sanctions-related list maintained by international bodies such as United Nations, European Union, United States Office of Foreign Assets Control;
33. Use your StraitsX Accounts to conduct transactions with, or provide services to, persons that are located in, or residents of, a country, territory or geographical region that is the subject or target of any territory wide sanctions or internally restricted countries; and
34. Use your StraitsX Accounts to transact with, or send funds to, digital wallet addresses that have indices of interactions with questionable and higher risk actors including “Darknet” markets and other services or websites that act as a marketplace for illegal goods.

11. YOUR LIABILITY & INDEMNITY

YOU ARE LIABLE FOR (A) REVERSALS, CHARGEBACKS, CLAIMS, AND/OR (B) ANY AND ALL LOSSES, DAMAGES, EXPENSES, FEES, FINES, PENALTIES AND ANY OTHER LIABILITIES INCURRED BY US, ANY STRAITSX USER OR A THIRD PARTY ARISING OUT OF, OR CAUSED BY, YOUR ACTIONS OR INACTIONS IN THE FOLLOWING CIRCUMSTANCES:
1. YOUR FAILURE TO ADHERE TO THE STRAITSX T&CS AND/OR APPLICABLE LAWS, INCLUDING BUT NOT LIMITED TO LAWS RELATING TO MONEY LAUNDERING, TERRORISM FINANCING, AND SANCTIONS;;
2. YOUR FAILURE TO ADHERE TO ANY INSTRUCTION(S) OR DIRECTION(S) ISSUED BY STRAITSX;
3. YOUR FAILURE TO UPDATE OR MAINTAIN ACCURATE CUSTOMER INFORMATION WITH STRAITSX;
4. YOUR USE OF THE SERVICES OF OUR THIRD-PARTY SERVICE PROVIDERS IN A PROHIBITED MANNER OR PROVIDING INACCURATE OR INCOMPLETE INFORMATION WHILE USING THEIR SERVICES;
5. YOUR FAILURE TO PARTICIPATE IN NECESSARY UPDATES, UPGRADES, OR MIGRATIONS OF STRAITSX TOKENS; AN
6. YOUR ERRORS OR OMISSIONS AS SPECIFIED IN CLAUSE 9 OF THIS GENERAL T&CS.
YOU SHALL INDEMNIFY AND HOLD HARMLESS STRAITSX, ITS AFFILIATES, OFFICERS, DIRECTORS, AGENTS, AND EMPLOYEES FROM ANY EXPENSES, CLAIMS, DAMAGES, LOSSES (INCLUDING CONSEQUENTIAL LOSSES AND SPECIAL DAMAGES), LIABILITIES, PROCEEDINGS, ACTIONS OR COSTS (INCLUDING LEGAL FEES ON A FULL INDEMNITY BASIS), SUFFERED OR INCURRED BY STRAITSX OR ANY THIRD PARTY ARISING FROM YOUR ACT, OMISSION, DEFAULT, FRAUD, NEGLIGENCE, WILLFUL MISCONDUCT, OR BREACH OF ANY TERMS OF THESE STRAITSX T&CS OR ANY APPLICABLE LAWS. FOR THE AVOIDANCE OF DOUBT, THIS INDEMNITY COVERS ANY INVOLVEMENT BY STRAITSX IN ANY DISPUTE RESOLUTION PROCESSES ARISING OUT OF OR CONNECTED TO SUCH CLAIMS, INCLUDING BUT NOT LIMITED TO LITIGATION, ARBITRATION, MEDIATION AND SETTLEMENT NEGOTIATIONS, OR ANY OTHER DISPUTE RESOLUTION PROCESS WHERE WE PURSUE ANY CLAIM, COUNTERCLAIM, OR CAUSE OF ACTION AGAINST YOU FOR BREACH OR NON-COMPLIANCE WITH ANY TERMS AND CONDITIONS IN THE STRAITSX T&CS, OR WHEN STRAITSX ENFORCES ANY OF THE TERMS OF THE STRAITSX T&CS.
For clarity, nothing in this clause 11 shall exclude or limit your liability or indemnity obligations which might otherwise exist under (a) any other clause of the StraitsX T&Cs, (b) civil cause of action, (c) common law, or (d) Applicable Laws.

Reimbursement for your liability

If you are liable for any amounts owed to us, we may immediately remove such amounts from the account balance of your StraitsX Accounts. If the said account balance is insufficient to meet your liability, we will remove any funds remaining in your StraitsX Accounts and instate your StraitsX Accounts with a negative balance up to the remaining amount of your liability, and you shall add funds into your StraitsX Accounts (whether through crediting/transfer of StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens to your StraitsX Accounts) as soon as possible to restore your StraitsX Accounts to a zero or positive balance, or to pay us through an alternative method agreed to by us.

Liability for violation of our Acceptable Use Policy

IF YOU VIOLATE THE ACCEPTABLE USE POLICY, THEN IN ADDITION TO THE ABOVE ACTIONS AS DESCRIBED IN THE STRAITSX T&CS, YOU WILL BE LIABLE TO STRAITSX FOR DAMAGES FOR EACH VIOLATION OF THE ACCEPTABLE USE POLICY. YOU AGREE THAT $500.00 SGD (OR EQUIVALENT) PER TRANSACTION IN VIOLATION OF THE ACCEPTABLE USE POLICY IS PRESENTLY A REASONABLE MINIMUM ESTIMATE OF ACTUAL DAMAGES THAT STRAITSX MIGHT SUFFER CONSIDERING ALL CURRENTLY EXISTING CIRCUMSTANCES, INCLUDING THE RELATIONSHIP OF THE SUM TO THE RANGE OF HARM TO STRAITSX THAT REASONABLY COULD BE ANTICIPATED BECAUSE DUE TO THE NATURE OF THE VIOLATIONS OF THE ACCEPTABLE USE POLICY, ACTUAL DAMAGES WOULD BE IMPRACTICAL OR EXTREMELY DIFFICULT TO CALCULATE. STRAITSX MAY DEDUCT SUCH DAMAGES DIRECTLY FROM ANY EXISTING BALANCE IN THE OFFENDING STRAITSX ACCOUNTS, OR ANY OTHER STRAITSX ACCOUNTS THAT YOU CONTROL.

12. ACTIONS BY STRAITSX – RESTRICTED ACTIVITY OR JUDGMENT, ORDER OR DIRECTIVE FROM A REGULATORY BODY OR LAW ENFORCEMENT AGENCY OR COURT OF LAW

If (a) we believe that you may have engaged in any Restricted Activity, or (b) if there is any notice, judgment, order or directive (or anything of a similar nature) issued by any regulatory body, a law enforcement agency or any court of law, we may, in our sole discretion, take various actions to enforce compliance with the StraitsX T&Cs or the issued notice, judgment, order or directive. The actions that may be taken include but are not limited to the following:
1. We may close, suspend, freeze, or limit your access to your StraitsX Accounts or the Services.
2. We may freeze your ability to transfer, use, redeem, purchase and/or withdraw StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens, whether in respect of your StraitsX Accounts or Non-StraitsX Accounts.
3. We may refuse to provide the Services to you now and/or in the future.
We may freeze/hold all or part of your funds, including StraitsX E-money, StraitsX Tokens, and/or Non-StraitsX Tokens, for a period determined at our sole and absolute discretion. This may include freezing/holding the funds until we receive a formal disposal direction, notice, order, judgment, or similar directive from a regulatory body, law enforcement agency, or court of law, instructing us on how the funds should be handled or disposed of.
We may carry out any other actions necessary to comply with a notice, judgment, order or directive (or anything of a similar nature) issued by any regulatory body, a law enforcement agency or any court of law.

13. ACTIONS BY STRAITSX - HOLDS

Risk-based holds

We may, in our sole and absolute discretion, place a hold on any or all of the payments/transfers you receive/send when we believe there may be a high level of risk associated with you, your StraitsX Accounts, or any or all of your transactions. Our determination may be based on different factors and we may rely on information we receive from third parties. If we place a hold on a payment/transfer, the funds and the payment/transfer status may appear as “pending”. We will release the hold on any payment/transfer after 30 calendar days from the date the payment/transfer was received into your StraitsX Accounts unless we have a reason to continue to hold the payment such as (a) the receipt of a dispute, Claim, Chargeback, or Reversal, (b) we believe that you have violated the StraitsX T&Cs, any agreement or Policy that you have entered into with StraitsX, or any Applicable Laws, and that such a violation results in the need to continue holding the funds, or (c) we believe that you may be engaging in potentially fraudulent or suspicious activity and/or transactions. In such an event, we may continue holding the payment/transfer in your StraitsX Accounts until the matter is resolved pursuant to the StraitsX T&Cs. We may, in our sole and absolute discretion, release the hold earlier under certain circumstances, for example when you upload tracking information of the item you shipped or when the paying user confirms that you have delivered the goods or services promised.

Disputed transaction holds

If a user files a dispute, Claim, Chargeback or Reversal on a payment you received, we may place a temporary hold on the funds in your StraitsX Accounts to cover the amount of the liability. If you win the dispute, we will lift the temporary hold. If you lose the dispute, we will remove the funds from your StraitsX Accounts.

14. ACTIONS BY STRAITSX - RESERVE ON FUNDS

We may, in our sole and absolute discretion, place a Reserve on funds (including StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens) held in your StraitsX Accounts for any reason we deem necessary. If we place a Reserve in your StraitsX Accounts, transactions may be shown as “pending” in your StraitsX Accounts balance, and you will not have access to the funds until the “pending” status is cleared. The terms of the Reserve may require that a certain percentage of the amounts received into your StraitsX Accounts are held for a certain period of time, or that a certain amount of money is held in Reserve, or anything else that we determine is necessary. We may change the terms of the Reserve at any time by providing you with notice of the new terms.

15. ACTIONS BY STRAITSX - BLACKLISTING OF STRAITSX ACCOUNTS AND/OR NON-STRAITSX ACCOUNT

We may, in our sole and absolute discretion, blacklist your StraitsX Accounts or Non-StraitsX Account, when we believe there may be a high level of risk associated with you, your StraitsX Accounts and/or Non-StraitsX Account, or any or all of your transactions. Our determination may be based on different factors and we may rely on information we receive from third parties. If we blacklist your StraitsX Accounts or Non-StraitsX Account, you will not be able to:
1. Receive transfers or payments (whether in StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens) into your blacklisted StraitsX Accounts/Non-StraitsX Account; or
2. Transfer or make payments (whether using StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens) from your blacklisted StraitsX Accounts/Non-StraitsX Account to another StraitsX Accounts/Non-StraitsX Account.
Even if your StraitsX Accounts have not been blacklisted, you will not be able to:
1. Receive transfers or payments (whether in StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens or otherwise) from a blacklisted StraitsX Accounts/Non-StraitsX Account; or
2. Transfer or make payments (whether using StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens) from your StraitsX Accounts to a blacklisted StraitsX Accounts/Non-StraitsX Account.

16. ACTIONS BY STRAITSX – ACCOUNT CLOSURE; TERMINATION OF SERVICE; LIMITED ACCOUNT ACCESS

We may, in our sole and absolute discretion, close your StraitsX Accounts, terminate the agreement between StraitsX and yourself, and/or stop or limit your access to any StraitsX Services for any reason and at any time with or without any notice to you. This action may be taken for various reasons including, but not limited to, (a) your violation of the StraitsX T&Cs, (b) account inactivity, (c) misuse of our Services, (d) if your account is compromised or used in a manner that could harm or pose a potential threat to StraitsX and/or its users, and (e) or in response to any notice, judgment, order or directive (or anything of a similar nature) issued by a regulatory body, a law enforcement agency or any court of law. If we close your StraitsX Accounts, we will pay you any unrestricted funds held in your remaining balance of your StraitsX Accounts, unless:
1. There are reasonable grounds to believe that your StraitsX Accounts and/or your StraitsX E-money StraitsX Tokens and/or Non-StraitsX Tokens may have been used to commit, or were involved in the commission, of any Restricted Activity;
2. We are entitled to withhold payment of your remaining balance under the StraitsX T&Cs; and/or
3. We are prohibited from doing so under (a) any Applicable Laws, or (b) any notice, judgment, order or directive (or anything of a similar nature) issued by a regulatory body, a law enforcement agency or any court of law.
If we limit access to your StraitsX Accounts, you may have the opportunity to request restoration of access if, in our sole and absolute discretion, we deem it appropriate.

17. ACTIONS BY STRAITSX – CONVERSION AND WITHDRAWAL OF STRAITSX TOKENS/NON-STRAITSX TOKENS

We may, in our sole and absolute discretion, convert the StraitsX Tokens and/or Non-StraitsX Tokens held in your StraitsX Digital Assets Account into either other forms of StraitsX Tokens and/or Non-StraitsX Tokens or any supported fiat currency under certain circumstances deemed necessary by us. These circumstances include, but are not limited to, (a) the closure of your StraitsX Accounts, (b) discontinuation of support for specific StraitsX Tokens and/or Non-StraitsX Tokens, (c) compliance with any Applicable Laws or notice, judgment, order or directive (or anything of a similar nature) issued by a regulatory body, a law enforcement agency or any court of law, or (d) any other scenarios that may arise in the ordinary course of business. The conversion rate will be determined at our sole discretion based on the prevailing market prices at the time of conversion. Where necessary for the purposes of this clause, you also irrevocably authorize us to withdraw some or all of your funds into your Attached Bank Account.

18. ACTIONS BY STRAITSX - NO OBLIGATION TO DISCLOSE REASONS, PROVIDE NOTICE OR REVEAL INTERNAL CONFIDENTIAL CRITERIA

You acknowledge that our decision to take any of the actions provided for in the StraitsX T&Cs may be based on confidential criteria that are essential to our management of risk, the security of StraitsX users and the StraitsX system. These actions may be taken pursuant to scenarios including, but not limited to, (a) our internal risk assessment frameworks, or (b) any notice, judgment, order, or directive (or anything of a similar nature) issued by a regulatory body, law enforcement agency, or any court of law.
You understand and acknowledge that we will strive to provide notice to you of any such intended actions if (a) it is not prohibited by law, any regulatory body or law enforcement agency, and/or (b) such notice does not compromise (i) our security measures or risk management efforts or (ii) our ability to comply with any notice, judgment, order, or directive (or anything of a similar nature) issued by a regulatory body, law enforcement agency, or any court of law. You acknowledge that we are under no obligation to disclose the details of our risk management, security procedures, internal assessments, or the specific grounds for taking any particular action to you.

19. SET-OFF ETC.

If you owe StraitsX or to any entity within our corporate group (including any parent, subsidiary, sister company or affiliate, irrespective of common control) any amounts, including fees, interest, commission, costs or other charges (whether due immediately or later), you agree to the following:
1. StraitsX has the right of lien, right of retention, and/or sale over the StraitsX Tokens and Non-StraitsX Tokens held by us on your behalf in the trust accounts. In addition, where StraitsX acts as a safeguarding person under Regulation 18B of the Payment Services Regulations 2019 for you, a licensee under the Payment Services Act (and the regulations made thereunder), you also agree to obtain written consent from your users for such lien, right of retention, or sale and to notify StraitsX in writing of the same.
2. StraitsX has the right to set off and deduct such amounts from: (a) the balance of your StraitsX Accounts, (b) your StraitsX Credits, (c) any amounts, prepaid amount, security deposit or any other funds held with StraitsX, and/or (d) any amounts (including benefits or liabilities) payable, distributable, or due to you by StraitsX.
If there are insufficient funds (including StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens) in your StraitsX Accounts, insufficient StraitsX Credits or other funds held by us to cover your liability, you also agree to make payment to StraitsX through other means.

20. DISPUTES

Disputes with other users/Non-StraitsX Account Token Holder regarding any underlying transaction

If you have any disputes with any StraitsX user(s) and/or Non-StraitsX Account Token Holder regarding the underlying transaction, you should take it up with the other user(s) and/or Non-StraitsX Account Token Holder (as the case may be) directly. We shall not be involved in any dispute that may arise between or amongst users and/or Non-StraitsX Account Token Holder unless all of the following criteria are met:
1. Such dispute relates specifically to the use of the StraitsX Services;
2. Such dispute does not relate in any way to, or involve a Non-StraitsX Account;
3. Such dispute does not relate to a transaction conducted through a Platform User’s website, app, software or service;
4. Such dispute is notified to StraitsX within 30 calendar days of the date of occurrence of the dispute;
5. Such dispute or claim arises from a transaction through the users’ email addresses or mobile telephone numbers registered with StraitsX for the use of the Services; and
6. You have furnished StraitsX with all materials and information relating to the said dispute which we may reasonably request for the purpose of our investigations.

Receiving user’s/Non-StraitsX Account Token Holder's responsibility

If you are a user and/or Non-StraitsX Account Token Holder receiving funds (including StraitsX E-money, StraitsX Tokens and/or Non-StraitsX Tokens) via the StraitsX Services or a Platform User, it shall be your sole responsibility to comply with all Applicable Laws and obligations relating to your provision of goods or services to your customers or end-users. You shall also deal with all customer service issues, notifications, handling of refunds, and complaints made by the sending user and/or Non-StraitsX Account Token Holder (or other third parties) in respect of the products/goods/assets/property (whether tangible or intangible) or services supplied by you or your end-users under the StraitsX Services.

Release of StraitsX

If you have a dispute with one or more users and/or Non-StraitsX Account Token Holder, you release StraitsX, its parent, subsidiaries and affiliates (and any of the aforementioned entities’ officers, directors, agents, joint ventures, employees and suppliers) from any and all claims, demands and losses and damages (direct or indirect) (actual and consequential) of every kind and nature arising out of or in any way connected with such disputes.

Disputes with StraitsX regarding StraitsX Services

If a dispute arises between you and StraitsX, our goal is to learn about and address your concerns and, if we are unable to do so to your satisfaction, to provide you with a neutral and cost effective means of resolving the dispute quickly. As such, please contact StraitsX first by submitting a support ticket via the StraitsX Website.

Arbitration

For any claim (excluding claims for injunctive or other equitable relief) where the total amount of the award sought is less than $10,000.00 SGD (or other currencies equivalents), the party requesting relief may elect to resolve the dispute in a cost effective manner through binding non-appearance-based arbitration. If a party elects arbitration, that party will initiate such arbitration through the Singapore International Arbitration Centre or any other established alternative dispute resolution (“ADR”) provider mutually agreed upon by the parties. The ADR provider and the parties must comply with the following rules: (a) the arbitration shall be conducted by telephone, online and/or be solely based on written submissions, the specific manner shall be chosen by the party initiating the arbitration; (b) the arbitration shall not involve any personal appearance by the parties or witnesses unless otherwise mutually agreed by the parties; and (c) any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction.

Governing law and forum for disputes

This agreement between StraitsX and yourself, which incorporates the terms and conditions of the StraitsX T&Cs, shall be governed in all respects by the laws of Singapore as such laws are applied to agreements entered into and to be performed entirely within Singapore, without regard to conflict of law provisions.
Except as otherwise agreed by the parties or as described in clause 20.5 (see above), you agree that any claim or dispute you may have against StraitsX must be resolved by a court located in Singapore or where the defendant is located. You agree to submit to the personal jurisdiction of the courts located within Singapore for the purpose of litigating all such claims or disputes.

Improperly filed litigation

All claims you bring against StraitsX must be resolved in accordance with the StraitsX T&Cs. All claims filed or brought contrary to the StraitsX T&Cs shall be considered improperly filed and a breach of the agreement between StraitsX and yourself. Should you file a claim contrary to the StraitsX T&Cs, StraitsX may recover all attorneys’ fees and costs (including in-house attorneys and paralegals), provided that StraitsX has notified you in writing of the improperly filed claim, and you have failed to promptly withdraw the claim.

21. NOTICES

Notices to you

You agree that StraitsX may send you Communications (including any notice) about your StraitsX Accounts and/or any of the StraitsX Services electronically. StraitsX reserves the right to close your StraitsX Accounts if you withdraw your consent to receive electronic communications. Any electronic communications will be considered to be received and read by you: (1) within 24 hours of the time we post it to the StraitsX Website; or (2) immediately upon our sending of an email to you. Any Communication sent to you by postal mail will be considered to be received and read by you 3 Business Days after we send it.
In relation to the above, if you do not receive any Communications via email because your primary email address provided to us was incorrectly provided, out of date, blocked by your service provider, or you are otherwise unable to receive any Communications via email for any reason, we will be deemed to have provided the Communications to you. Please note that if you use a spam filter that blocks or re-routes emails from senders not listed in your email address book, you must add our email address to your address book so that you will be able to receive the Communications and/or notice we send to you.
Please note that as per the Additional T&Cs pertaining to StraitsX Accounts, it is your responsibility to ensure that your Customer Information (including your primary email address and telephone/mobile) remains valid and up-to-date. You can do this any time by submitting a support ticket through the StraitsX Website.

Notices to you from our third party service providers

You authorise us to receive notices and forms on your behalf from third party service providers. StraitsX reserves the right to close your StraitsX Accounts or restrict the Services provided to you if you withdraw your consent to enable us to receive such notices or forms.

Notice to StraitsX

Unless otherwise stated in the StraitsX T&Cs, any notice to StraitsX must be sent by postal mail to the registered address of StraitsX, Attention: Legal Department.

22. LIMITATION OF LIABILITY

NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HERE, AND SUBJECT TO ANY APPLICABLE LAWS, THE SAFEGUARDING INSTITUTION, STRAITSX AND THEIR RESPECTIVE PARENT, SUBSIDIARIES AND AFFILIATES, OFFICERS, DIRECTORS, AGENTS, JOINT VENTURES, EMPLOYEES OR SERVICE PROVIDERS SHALL NOT BE LIABLE, WHETHER OR NOT ARISING OUT OF NEGLIGENCE OF EACH OF THE SAFEGUARDING INSTITUTION, STRAITSX AND THEIR RESPECTIVE PARENT, SUBSIDIARIES AND AFFILIATES, OFFICERS, DIRECTORS, AGENTS, JOINT VENTURES, EMPLOYEES OR SUPPLIERS, FOR ANY LOSSES (DIRECT OR INDIRECT), LOSS OF PROFITS, CONSEQUENTIAL OR SPECIAL LOSSES, DAMAGES, EXPENSES, CLAIMS, LIABILITY AND COSTS (INCLUDING COST ON A SOLICITOR AND CLIENT BASIS) THAT YOU MAY INCUR OR SUFFER IN CONNECTION WITH:
1. THE CREATION, USE, SUSPENSION OR CLOSURE OF YOUR STRAITSX ACCOUNTS.
2. THE CREATION, USE, SUSPENSION OR CLOSURE OF A NON-STRAITSX ACCOUNT.
3. ANY DELAY IN CREATION AND VERIFICATION OF STRAITSX ACCOUNTS OR SUSPENSION AND DISCONTINUANCE OF CREATION AND VERIFICATION OF STRAITSX ACCOUNTS OR APPROVAL OF A NON-STRAITSX ACCOUNT.
4. ANY PERIOD WHERE ANY EQUIPMENT, SOFTWARE OR SYSTEM IS UNAVAILABLE FOR PROCESSING THE USE OF STRAITSX ACCOUNTS FOR PAYMENT.
5. ANY DELAY OR DETENTION ARISING FROM USE OF STRAITSX ACCOUNTS (INCLUDING LOCKED OR SUSPENDED STRAITSX ACCOUNTS).
6. ANY DELAY OR FAILURE IN THE REDEMPTION, PURCHASE, TRANSFER OR WITHDRAWAL OF FUNDS OR STRAITSX TOKENS AND NON-STRAITSX TOKENS, CAUSED BY STRAITSX OR ANY OF ITS AFFILIATES, AGENTS AND/OR EMPLOYEES.
7. ANY DELAY IN SENDING OR RECEIVING STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS ARISING FROM ANY ATTACKS ON OR ISSUES THAT MIGHT ARISE WITH THE BLOCKCHAIN LEDGERS ON WHICH STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS ARE SUPPORTED..
8. ANY PERIOD WHERE STRAITSX MAY, AT ITS DISCRETION, SUSPEND ALL ACTIVITIES OR SERVICES RELATING TO STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS (INCLUDING ISSUANCE, PURCHASE, CREDITING, TRANSFERS, REDEMPTIONS AND/OR WITHDRAWALS OF STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS) DUE TO ISSUES WITH THE STRAITSX TOKEN CONTRACT AND/OR BLOCKCHAINS ON WHICH THE STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS ARE SUPPORTED. FOR THE AVOIDANCE OF DOUBT, STRAITSX SHALL NOT BE LIABLE UNDER THIS CLAUSE 22.1.8 REGARDLESS OF WHETHER STRAITSX CHOOSES TO SUSPEND OR MAINTAIN OPERATIONS.
9. ACTING ON ANY INSTRUCTION, WITH OR WITHOUT VERIFYING THE IDENTITY OR AUTHORITY OF THE PERSON GIVING THE INSTRUCTION, THAT EMANATES FROM YOUR STRAITSX ACCOUNTS, REGARDLESS OF WHO ISSUED THE INSTRUCTIONS AND THE CIRCUMSTANCES SURROUNDING THEIR ISSUANCE. THIS INCLUDES THE NATURE OF THE ARRANGEMENT, SERVICES, OR TRANSACTION MADE PURSUANT TO SUCH INSTRUCTIONS, THE AMOUNT OF MONEY INVOLVED, AND NOTWITHSTANDING ANY ERROR, MISUNDERSTANDING, UNAUTHORIZED ACCESS TO YOUR STRAITSX ACCOUNTS, FRAUD, FORGERY, OR LACK OF CLARITY OR AUTHORIZATION IN THE TERMS OF SUCH INSTRUCTIONS.
10. ANY DELAY, FAILURE OR LOSS OF FUNDS, INCLUDING FIAT, STX TOKENS, NON-STX TOKENS AND/OR UNSUPPORTED DIGITAL ASSETS DUE TO YOUR ERROR, INCLUDING THOSE LISTED IN CLAUSE 9 OF THE GENERAL T&CS
11. ANY UNAUTHORIZED ACCESS TO YOUR STRAITSX ACCOUNTS AND/OR SERVICES, UNAUTHORIZED TRANSACTIONS, OR ANY OTHER SECURITY BREACHES ARISING FROM YOUR FAILURE TO ADHERE TO: (A) ANY OBLIGATIONS OR SECURITY MEASURES SPECIFIED IN THE STRAITSX T&CS (E.G. SEE THE USER OBLIGATIONS IN CLAUSE 13 OF THE ADDITIONAL T&CS PERTAINING TO STRAITSX ACCOUNTS), OR (B) ANY AD-HOC SECURITY MEASURE AND/OR INSTRUCTIONS ISSUED BY STRAITSX. FOR CLARITY, AND WITHOUT LIMITING THE SCOPE OF THIS CLAUSE, THE FOLLOWING SCENARIOS ARE INCLUDED:
  1. FAILURE TO SECURE LOGIN CREDENTIALS: ANY UNAUTHORIZED ACCESS TO YOUR STRAITSX ACCOUNTS AND/OR SERVICES, UNAUTHORIZED TRANSACTIONS, OR ANY OTHER SECURITY BREACHES RESULTING DIRECTLY FROM YOUR FAILURE TO SECURELY MAINTAIN YOUR LOGIN CREDENTIALS;
  2. USE OF COMPROMISED/UNSUPPORTED HARDWARE/SOFTWARE: ANY UNAUTHORIZED ACCESS TO YOUR STRAITSX ACCOUNTS AND/OR SERVICES, UNAUTHORIZED TRANSACTIONS, OR ANY OTHER SECURITY BREACHES RESULTING DIRECTLY FROM YOUR USE OF COMPROMISED OR UNSUPPORTED HARDWARE OR SOFTWARE TO ACCESS THE STRAITSX ACCOUNTS AND/OR SERVICES, INCLUDING BUT NOT LIMITED TO USING DEVICES THAT ARE 'ROOTED' OR 'JAILBROKEN';
  3. FAILURE TO IMPLEMENT MULTI-FACTOR AUTHENTICATION: ANY UNAUTHORIZED ACCESS TO YOUR STRAITSX ACCOUNTS AND/OR SERVICES, UNAUTHORIZED TRANSACTIONS, OR ANY OTHER SECURITY BREACHES RESULTING DIRECTLY FROM YOUR FAILURE TO ENABLE, CONFIGURE, OR MAINTAIN MULTI-FACTOR AUTHENTICATION AS REQUIRED OR RECOMMENDED BY STRAITSX; AND
  4. NON-COMPLIANCE WITH SECURITY UPDATES AND PROTOCOLS: ANY UNAUTHORIZED ACCESS TO YOUR STRAITSX ACCOUNTS AND/OR SERVICES, UNAUTHORIZED TRANSACTIONS, OR ANY OTHER SECURITY BREACHES RESULTING DIRECTLY FROM YOUR NON-COMPLIANCE WITH ANY UPDATES, PATCHES, ANTIVIRUS INSTALLATIONS, OR PASSWORD STRENGTH REQUIREMENTS AS ADVISED BY STRAITSX, RESULTING IN SECURITY VULNERABILITIES EXPLOITED BY UNAUTHORIZED PARTIES.
12. ANY LOSS OF STRAITSX TOKENS, WHETHER DIRECT OR INDIRECT, RESULTING FROM YOUR FAILURE TO OBSERVE OR PARTICIPATE IN ANY INSTRUCTIONS PERTAINING TO, UPDATES, UPGRADES, OR MIGRATIONS OF STRAITSX TOKENS. THIS INCLUDES ANY LOSS INCURRED BY YOU FROM SENDING YOUR STRAITSX TOKENS TO (A) A NON-STRAITSX ACCOUNT THAT IS INCOMPATIBLE WITH THE UPDATED BLOCKCHAIN, (B) AN INCORRECT OR OUTDATED STRAITSX DESIGNATED WALLET ADDRESS, OR (C) A BLOCKCHAIN SYSTEM NO LONGER SUPPORTED BY STRAITSX.
13. ANY (A) DELAY OR FAILURE IN THE REDEMPTION, PURCHASE, TRANSFER OR WITHDRAWAL OF FUNDS, STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS, OR (B) LOSS OF (I) VALUE OF STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS OR (II) THE RESERVE ASSETS BACKING THE REDEMPTION / PURCHASE OF SUCH STRAITSX TOKENS, CAUSED (DIRECTLY OR INDIRECTLY) BY: (A) ANY BANK, DEPOSITORY, THIRD-PARTY CUSTODIAN, BORROWER, OR PAYMENT PROCESSOR HOLDING OR PROCESSING THE RESERVE ASSETS, THE STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS, (B) THE THEFT OR LOSS OF RESERVE ASSETS, THE STRAITSX TOKENS AND/OR NON-STRAITSX TOKENS, (C) ANY AUDIT OR INVESTIGATIONS BY ANY REGULATORY BODY OR LAW ENFORCEMENT AGENCY, OR (D) ANY NOTICE, JUDGMENT, ORDER, OR DIRECTIVE (OR ANYTHING OF A SIMILAR NATURE) ISSUED BY A (I) REGULATORY BODY, (II) LAW ENFORCEMENT AGENCY, (III) VIA ANY OTHER LEGAL PROCESSES ASSERTED BY A GOVERNMENT, OR (IV) ANY COURT OF LAW.
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14. ANY FAILURE ON YOUR PART TO KEEP YOUR CUSTOMER INFORMATION UPDATED.
15. ANY FAILURE TO MONITOR ANY NOTIFICATIONS OR COMMUNICATIONS SENT TO YOU BY STRAITSX.
16. ANY ACTION THAT STRAITSX IS ENTITLED TO TAKE UNDER THE STRAITSX T&CS, INCLUDING BUT NOT LIMITED TO LIMITING ACCOUNT ACCESS, ACCOUNT CLOSURE, ANY HOLDS, FUND WITHHOLDING, TOKEN FREEZING, BLACKLISTING, AND CONVERSIONS OF TOKENS.
17. ANY AMENDMENTS, ADJUSTMENTS, REVOCATIONS, OR UPDATES TO THE SWAPS RATE OR OTC QUOTED RATE, OR FROM THE CANCELLATION OR UNWINDING OF ANY EXECUTED TRANSACTION. FOR THE AVOIDANCE OF DOUBT, BY ACCEPTING ANY AMENDED SWAPS RATE OR OTC QUOTED RATE, YOU WAIVE ANY RIGHT TO CLAIM DAMAGES, WHETHER DIRECT, INDIRECT, CONSEQUENTIAL, OR OTHERWISE, ARISING FROM SUCH EXCHANGE RATE ADJUSTMENTS.
18. ANY DELAYS IN THE PROCESSING OR SETTLEMENT OF ANY OTC TRANSACTION OR SWAPS TRANSACTION, REGARDLESS OF THE CAUSE. THIS INCLUDES, BUT IS NOT LIMITED TO, DELAYS RESULTING FROM TECHNICAL ISSUES, COMPLIANCE REVIEWS, REGULATORY CHANGES, OR MARKET VOLATILITY.
19. ANY DELAY OR FAILURE TO PROCESS WITHDRAWALS FROM YOUR STRAITSX EARN ACCOUNT WITHIN THE SPECIFIED TIME, FAILURE TO PAY OUT REWARDS (AS REWARDS IS NOT GUARANTEED), OR FAILURE TO RETURN THE PRINCIPAL SUM.
20. YOUR PARTICIPATION OR SUBSCRIPTION TO THE STRAITSX EARN PRODUCT.
In all other cases, the total liability of StraitsX and its parent, subsidiaries and affiliates, officers, directors, agents, joint ventures, employees or service providers shall be limited to the actual amount of direct damages and shall not exceed $500.00 SGD or the balance of your StraitsX Accounts as of the date your claim arises, whichever is lower.

23. FEES FOR STRAITSX SERVICES

You agree to pay StraitsX any and all prevailing fees charged by us from time to time in connection with the provision or use of the StraitsX Services. Where applicable, the default fees for certain StraitsX Services are published on the StraitsX Website and may also be disclosed to you prior to the confirmation of a transaction via the StraitsX Dashboard. In the event of any inconsistency, the fees disclosed to you prior to confirmation of the transaction will prevail over the fees stated on the StraitsX Website.The default fees for other Services (such as API services or custom integrations) may not be publicly disclosed but may be notified to you separately (e.g. via a pricing proposal).
Where a separate pricing agreement has been signed between you and StraitsX, that agreement shall prevail. However, if such agreement is not signed, terminated or has expired, you agree that StraitsX reserves the right to apply its default pricing for the relevant Services, which may or may not be published on the StraitsX Website.
We may revise our fees, including introducing new fees, from time to time. Such changes will be published on the StraitsX Website and/or disclosed to you prior to the confirmation of a relevant transaction. The revised fees will be binding on you if you continue to maintain or use the StraitsX Services after the effective date of the changes.

24. MISCELLANEOUS TERMS

Services limitation

StraitsX is not a bank and the StraitsX Services are payment processing services rather than banking services. StraitsX is not acting as a trustee, fiduciary or escrow with respect to your funds, but is acting only as an agent and custodian. StraitsX does not have control of, nor liability for, the products or services that are paid for with the StraitsX Services. We do not guarantee the identity of any user and/or Non-StraitsX Account Token Holder or ensure that a buyer or a seller will complete a transaction.

No warranty

The StraitsX Services are provided “as is” and without any representation of warranty, whether express, implied or statutory. StraitsX, our parent, subsidiaries and affiliates, our officers, directors, agents, joint ventures, employees and our suppliers specifically disclaim any implied warranties of title, merchantability, fitness for a particular purpose and non-infringement. StraitsX does not have any control over the products or services that are paid for with the StraitsX Services and we cannot ensure that a buyer or a seller you are dealing with will actually complete the transaction or is authorised to do so. StraitsX does not guarantee continuous, uninterrupted or secure access to any part of the StraitsX Services, and operation of our site may be temporarily suspended for maintenance or upgrade or interfered with by numerous factors outside of our control. StraitsX will make reasonable efforts to ensure that requests for electronic debits and credits involving bank accounts are processed in a timely manner but StraitsX makes no representations or warranties regarding the amount of time needed to complete processing because the StraitsX Services are dependent upon many factors outside of our control, such as delays in the banking system or mail service. StraitsX also has limited or no control over the StraitsX Tokens and/or Non-StraitsX Tokens stored on Non-StraitsX Accounts, and StraitsX cannot ensure nor enforce your rights in respect of such StraitsX Tokens and/or Non-StraitsX Tokens held on a Non-StraitsX Account. Some jurisdictions do not allow the disclaimer of implied warranties, so the foregoing disclaimers may not apply to you. This paragraph gives you specific legal rights and you may also have other legal rights that vary from country to country.

Force majeure event

Neither StraitsX nor any of its parent, subsidiaries and affiliates, officers, directors, agents, joint ventures, employees or suppliers shall be liable for non-performance, error, interruption or delay in the performance of their obligations under this Agreement, in the StraitsX system’s operations, if this is due, in whole or in part, directly or indirectly to an event or failure which is beyond its reasonable control which includes without limitation:
1. Flood, lightning, acts of God, fire, earthquakes, epidemics, pandemics and other natural disasters;
2. Judgements, legislation, acts, orders, directives, policies, restrictions, regulations, bye-laws, prohibitions or measures of any kind on the part of any court, governmental, parliamentary and/or regulatory authority imposed or to be imposed after the fact;
3. Power failure;
4. Acts or defaults of any telecommunications network operator;
5. Circumstances where communications lines and/or computer systems of StraitsX, Safeguarding Institution or any of their respective parent, subsidiaries and affiliates, officers, directors, agents, joint ventures, employees or suppliers cannot be used for reason attributable to third party telecommunications carriers; and
6. Acts or omissions of any service provider or any party for whom StraitsX and/or any of its parent, subsidiaries and affiliates, officers, directors, agents, joint ventures, employees or suppliers are/is not responsible.

Intellectual property

“STRAITSX” and all other URLs, logos and trademarks related to the StraitsX Services are either trademarks or registered trademarks of StraitsX or its licensors. You may not copy, imitate or use them without StraitsX’s prior written consent. In addition, all page headers, custom graphics, button icons, and scripts are service marks, trademarks, and/or trade dress of StraitsX. You may not copy, imitate, or use them without our prior written consent. You may use HTML logos provided by StraitsX through our merchant services or affiliate programs without prior written consent for the purpose of directing web traffic to the StraitsX Services. You may not alter, modify or change these HTML logos in any way, use them in a manner that is disparaging to StraitsX or the Services or display them in any manner that implies StraitsX’s sponsorship or endorsement. All right, title and interest in and to the StraitsX Website, any content thereon, the StraitsX Services, the technology related to the StraitsX Services, and any and all technology and any content created or derived from any of the foregoing is the exclusive property of StraitsX and its licensors.

Personal data protection

You acknowledge that you have read and accepted our Additional T&Cs pertaining to StraitsX Data Privacy Policy, and you give your consent for our collection, use, and disclosure of your personal data, including your Customer Information and KYC data along with all relevant supporting documentation, in a manner described in our StraitsX Data Privacy Policy. This includes sharing your personal data with members of our corporate family and affiliates for the purposes of providing products, services, registration, transactions, customer support, and for marketing communications if you have requested their services.
We have appointed a Data Protection Officer who is responsible for overseeing enquiries in relation to StraitsX Data Privacy Policy. If you have any enquiries or feedback about our policy, our privacy practices or if you wish to make any request pertaining to your rights in respect of your personal data, including the withdrawal of your consent to any collection, use or disclosure of your personal data, please contact our Data Protection Team at dataprotection@straitsx.com. However, please note that we may have to limit your StraitsX Accounts or decline to offer you certain Services if you withdraw your consent.

Transaction statement history

You may request for transactional statements for your StraitsX Accounts. We reserve the right to determine the period for which we will provide transaction history data (i.e. StraitsX Retention Period). While we may collect and retain personal data as mandated by Applicable Laws, we are not obligated to provide transactional statements or personal data beyond the StraitsX Retention Period. Requests for transaction history or personal data disclosures will be fulfilled only within the limits of the StraitsX Retention Period and in accordance with Applicable Laws.

Confidentiality

If you receive Information about another user through the StraitsX Services, you must keep the Information confidential and only use it in connection with the StraitsX Services. You may not disclose or distribute a user’s Information to a third party or use the Information for marketing purposes, unless you receive that user’s express consent to do so.

Taxes

It is your responsibility to determine what, if any, taxes apply to the payments you make or receive, and it is your responsibility to collect, report and remit the correct tax to the appropriate tax authority. StraitsX is not responsible for determining whether taxes apply to your transaction, or for collecting, reporting or remitting any taxes arising from any transaction.
Please be advised that you may be subject to withholding taxes or other tax liabilities with respect to importing services from a foreign entity. In addition, you may be subject to GST, sales tax, income tax, or other tax liabilities as a seller of goods or services. It is your responsibility to check with your local tax advisor to determine which taxes apply to you, and it is your responsibility to pay such taxes to the appropriate tax authority. All fees related to the StraitsX Services are made free and clear of, and without any deduction or withholding for and on account of, any taxes, duties or other deductions. Any such deduction or withholding, if required by the laws of any country are your sole responsibility.

Complete agreement and survival

The StraitsX T&Cs, along with any applicable Policies, sets forth the entire understanding between you and StraitsX with respect to the StraitsX Services, save that the placement, transfer, purchase, crediting, exchange, redemption and/or withdrawal of StraitsX Tokens and/or Non-StraitsX Tokens may also be subject to further terms imposed by the person or entity that opens, maintains and/or operates the Non-StraitsX Account which holds your StraitsX Tokens and/or Non-StraitsX Tokens.
Where the agreement (whose terms are the StraitsX T&Cs) between StraitsX and yourself is terminated, any provisions of the StraitsX T&Cs which by their nature extend beyond the termination of this agreement shall continue to be in effect. This includes, but is not limited to, any clause in the StraitsX T&Cs that allow StraitsX to assert rights or obligations which accrued prior to termination, or even after termination, such as:
1. Your liability for any amounts due to StraitsX, including but not limited to fees, charges etc.
2. Your obligation to pay compensation, damages, penalties, fees, etc., to StraitsX, including any payment obligation arising from your breach of any clause of the StraitsX T&Cs.
3. StraitsX’s right to set off against any amounts owed to you against any amounts due to StraitsX or any members of its corporate group.
4. The limitation of liability clauses that protect StraitsX from certain claims.
5. Indemnity provided by yourself, which shall continue to protect StraitsX against any claims, damages, losses, and expenses, including legal fees, arising from your use of the StraitsX Services or breach of the StraitsX T&Cs.
If any provision (or parts thereof) of the StraitsX T&Cs is held to be invalid or unenforceable, such parts of the provision shall be struck out to the extent of the invalidity/unenforceability and the remaining provisions shall be enforced.

Assignment

You may not transfer or assign any rights or obligations you have under the StraitsX T&Cs without StraitsX’s prior written consent. StraitsX reserves the right to transfer or assign the agreement between StraitsX and yourself, and/or any right or obligation under the StraitsX T&Cs to any party (including members of our corporate family) at any time. If you object to such transfer or assignment, you may stop accessing and using our Services and request for the closure of your StraitsX Accounts.

Contract (Rights of Third Parties) Act 2001

All other persons who are not a party to the agreement between StraitsX and yourself have no right under the Contract (Rights of Third Parties) Act 2001 to enforce any term of the StraitsX T&Cs.

Translated agreement

Any translation of the StraitsX T&Cs is provided solely for your convenience and is not intended to modify the terms of the agreement between StraitsX and yourself. In the event of a conflict between the English version of the StraitsX T&Cs and a version in a language other than English, the English version shall apply.

No waiver

No delay or failure on the part of StraitsX in exercising any power, right or remedy under the StraitsX T&Cs shall operate as a waiver of such power, right or remedy.

Assumption of rights

If StraitsX pays out a Claim, Reversal or Chargeback that you file against a recipient of your payment, you agree that StraitsX assumes your rights against the recipient and third parties related to the payment, and may pursue those rights directly or on your behalf, in StraitsX’s absolute discretion.

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