Terms of Use

Last Updated: February 28, 2026

Primary Operator: CT Technologies spółka z ograniczoną odpowiedzialnością (Poland)

These Terms of Service (the "Terms") govern access to and use of all mobile applications, software products, websites, and related digital services (collectively, the "Services"). By accessing or using the Services, you confirm that you have read, understood, and agree to comply with these Terms.

1. Acceptance of Terms

By creating an account or using the Services, you confirm that:

• You enter into a legally binding agreement exclusively with CT Technologies spółka z ograniczoną odpowiedzialnością ("CT Technologies"), the primary operator and provider of the Services.
• Any other parties involved in the operation of the Services act solely in specifically limited roles defined in these Terms and are not your primary counterparties.
• You agree to comply with all obligations, restrictions, and rules set out in this document.

2. Corporate structure and allocation of roles

To ensure operational efficiency and compliance with regulatory requirements, the Services are provided through a clearly separated structure involving several legal entities:

2.1 Primary Service Provider

CT Technologies spółka z ograniczoną odpowiedzialnością (“CT Technologies”)

• Jurisdiction: Poland
• Address: ul. Michała Kleofasa Ogińskiego 11/9, 03-318 Warszawa
• KRS: 0001098738 | NIP: 5243003455 | REGON: 528307439

CT Technologies is the sole operator of the Services and is responsible for:

• compliance with regulatory requirements, including VASP registration and AML/KYC procedures;
• approval and execution of cryptocurrency payouts;
• overall operation of the digital environment provided to Users.

2.2 Technical contractor and app store billing operator

CryptoCompany OÜ (“CryptoCompany”)

• Jurisdiction: Estonia

CryptoCompany acts solely as a technical contractor and app store billing operator and is responsible for:

• software development, maintenance, and technical support of the Services;
• distribution of mobile applications via Google Play and Apple App Store;
• processing payments made through mobile app stores, strictly in accordance with the rules, policies, and consumer regimes of the respective app stores.

CryptoCompany does not establish independent commercial, financial, or refund policies for app store purchases.

2.3 Liquidity and infrastructure provider

Zafiro Innovation Systems LLC (“Zafiro”)

• Jurisdiction: Costa Rica

Zafiro acts exclusively as a corporate liquidity and infrastructure provider and is responsible for:

• providing corporate cryptocurrency liquidity used for approved payout operations;
• maintaining its own mining infrastructure and internal treasury resources.

Zafiro does not provide services directly to Users, does not determine User eligibility, and does not assume regulatory or consumer obligations toward Users.

The provisions of Sections 11-15 of these Terms apply to the User's use of the Services, software, and related technical and payment-settlement circuits provided by Ecosystem Participants. The rights to apply restrictions, protective measures, anti-fraud controls, and compliance procedures under those Sections may be exercised by the Operator and/or the relevant Ecosystem Participant within the scope of their role and applicable law.

Nothing in these Terms means that all Ecosystem Participants are equal contracting parties with the User; the Operator remains the primary contracting party unless expressly stated otherwise.

3. Definitions

For the purposes of these Terms:

• “CT Technologies” means CT Technologies spółka z ograniczoną odpowiedzialnością, the primary service provider and contracting party.
• “CryptoCompany” means CryptoCompany OÜ, acting solely as a technical developer and app store billing operator.
• “Zafiro” means Zafiro Innovation Systems LLC, acting solely as a corporate liquidity and infrastructure provider.
• “Operator” means CT Technologies spółka z ograniczoną odpowiedzialnością as the primary contracting party under these Terms.
• "Ecosystem Participants" means CT Technologies spółka z ograniczoną odpowiedzialnością, CryptoCompany OÜ, and Zafiro Innovation Systems LLC, each acting strictly within its role defined by these Terms and applicable law.
• “Services” means all software applications, digital environments, websites, and related functionality operated by CT Technologies.
• “Digital Mining Rewards” or “DMR” means internal digital indicators generated within the Services to track user progress. DMR are not cryptocurrency, are not financial assets, and do not exist on any blockchain network.
• "Loyalty Program" means any bonus, promotional, or incentive mechanics, including accruals for User activity in the Services.
• "Affiliate (Referral) Program" means any mechanics for attracting new users, including referral accruals, referral links, codes, and other similar functionality.
• "Conditional Accruals" means any bonuses, referral accruals, DMR, or other internal indicators before final confirmation through compliance and anti-fraud checks. Conditional Accruals do not create an independent property right for the User and are not subject to unconditional payout or conversion.
• "Hold Period" means a period of time during which Conditional Accruals may be displayed in the interface but are unavailable for payout, conversion, withdrawal, or other use.
• "Eligibility Criteria" means the set of conditions a User must satisfy to access the Loyalty Program, Affiliate Program, payouts, and/or conversion, including AML/KYC, anti-fraud checks, and compliance with these Terms.
• "Related Accounts" means accounts that CT Technologies reasonably considers to belong to the same person or to be acting in coordination, including based on technical, behavioral, payment, identification, and other relevant indicators.
• "Balance Coin" means the cryptocurrency denomination (unit of account) in which the current balance equivalent may be displayed in the Services user interface, as determined in accordance with these Terms.
• “Digital Mining Rewards System” means a proprietary internal software system developed by CryptoCompany that uses deterministic performance models, telemetry, and predefined allocation logic to calculate and display Digital Mining Rewards within the Services.
• "Dynamic Mining Coin Selection" means the operational mechanism for determining the cryptocurrency asset used in Zafiro's mining circuit, where selection is made based on a set of relevant factors, including market conditions, the current industry situation, network fees, execution costs, and other economically significant parameters.
• “Payout” means a discretionary, regulated transfer of cryptocurrency carried out by CT Technologies after internal approval and successful AML/KYC verification.

4. Description of Services and licensing model

4.1 Purpose

The Services provide Users with access to interactive digital environments featuring mining-themed visuals, progress indicators, and software configurations.

4.2 Software Licensing

All digital items, boosters, configurations, and functional capabilities are provided strictly under a limited, non-exclusive, non-transferable, and revocable license.

The purchase of any digital item constitutes solely the purchase of a software license and does not grant:

• ownership rights to any hardware or infrastructure;
• ownership rights to Digital Mining Rewards;
• participation rights, profit-sharing rights, or investment rights.

5. User requirements

To use the Services, you must:

• be at least 18 years old;
• not be a resident of restricted or sanctioned jurisdictions;
• not use the Services for prohibited or unlawful financial activity;
• provide accurate and verifiable information upon request for AML/KYC purposes.

6. Nature of Digital Mining Rewards

6.1 Mining

The Services provided by CT Technologies do not include CT Technologies independently carrying out mining operations and do not imply provision to Users of cloud mining, equipment rental, or individualized allocation of real hash rate. Actual mining operations in the corporate circuit are performed by Zafiro Innovation Systems LLC based on contractual relations between CT Technologies and Zafiro. No cryptocurrency is mined by CT Technologies on behalf of Users.

6.2 Thematic representation

All mining-related terminology (including, without limitation, "hashrate," "power," and "mining speed") is used solely for thematic visualization and software gamification purposes.

6.3 No property rights

DMR have no intrinsic monetary value. CT Technologies reserves the right to recalculate, adjust, or remove DMR in cases of technical errors, abuse, or policy violations.

6.4 Corporate mining infrastructure and operating ecosystem

The Services operate within an integrated corporate ecosystem in which CT Technologies acts as the provider of customer service and the user-facing interface layer, while Zafiro Innovation Systems LLC provides the mining and infrastructure circuit.

Mining operations are performed by Zafiro using its own digital asset infrastructure, including computing capacity, treasury mechanisms, and liquidity resources.

The mining coin selected for a given period is not fixed and is determined through a dynamic selection model based on analysis of the most favorable mining conditions at the relevant time, including, without limitation, market conditions, volatility, industry constraints, network fees, and operational execution parameters.

Despite user interface settings, the displayed Balance Coin may be automatically set to the most economically efficient option at the relevant time to improve mining efficiency for a specific asset in view of current industry and market conditions.

Monitoring of this dynamic is carried out by the calculation-based financial model used by Zafiro; such display does not create any right for the User to demand mining of a specific coin, fixation of a specific selection algorithm, or grant of property rights to infrastructure or mined assets.

Nothing in the Services shall be construed as an investment product.

7. Conversion and payout process

DMR may be converted into cryptocurrency solely as a discretionary promotional option.

Conversion and/or interface display of a balance equivalent in a specific cryptocurrency does not mean that the User may require fixation of a particular Balance Coin, since the applicable denomination and related calculation profile may change in accordance with the Dynamic Mining Coin Selection model and current parameters of the market and industry environment.

A conversion request may be approved only if the following conditions are met:

• CT Technologies approves the request following internal review;
• Zafiro ensures the availability of sufficient corporate liquidity;
• The User successfully completes all required AML/KYC procedures.

Payouts are not guaranteed and may be limited, delayed, or rejected at CT Technologies' sole discretion.

8. Payments and software licenses

8.1 Nature of payments

All payments made by Users are fees for access to licensed software functionality. Payments are not investments, deposits, or savings.

8.2 App store purchases

All purchases made through Google Play or Apple App Store:

• are processed in full accordance with the rules, billing systems, refund mechanisms, and consumer policies of the respective app store;
• are governed exclusively by the terms and conditions set by Google or Apple, respectively.

CryptoCompany acts only as the technical party and contract seller (merchant of record) required by app store requirements and does not establish independent billing, refund, or withdrawal policies.

8.3 Purchase of licenses with cryptocurrency

Certain software licenses may be purchased with cryptocurrency via the Operator's internal payment and settlement mechanism.

All cryptocurrency payments made by Users are transferred directly to blockchain addresses controlled by Zafiro and are payments to Zafiro for corporate liquidity and infrastructure purposes. CT Technologies does not custody Users' cryptocurrency funds.

Such purchases are subject to additional verification and compliance checks.

8.4 Non-refundability

All license purchases are final and non-refundable, except where otherwise expressly required by mandatory consumer protection law or app store rules.

9. Effect of refunds on rewards and eligibility

If a User receives a refund for any purchase, initiates a chargeback, or takes other actions that CT Technologies reasonably classifies as refund abuse:

• all DMR and other Conditional Accruals related to the corresponding license, purchase, subscription, Loyalty Program, or Affiliate Program may be canceled in whole or in part;
• the User's eligibility for future Payouts, conversion, participation in the Loyalty Program, and/or Affiliate Program may be limited, suspended, or terminated;
• the User account and/or Related Accounts may be suspended to prevent fraud, protect users, and ensure security and compliance;
• CT Technologies may apply hold, set-off, and/or clawback of previously granted benefits to the extent CT Technologies reasonably deems necessary to restore the proper settlement position.

10. Loyalty Program and Affiliate (Referral) Program

CT Technologies may grant Users access to the Loyalty Program and/or Affiliate Program on a discretionary basis.

10.1 General principles

• participation in the Loyalty Program and/or Affiliate Program is not an unconditional right of the User;
• any accruals within such programs are Conditional Accruals until final confirmation through compliance and anti-fraud checks;
• Conditional Accruals may be subject to a Hold Period and other restrictions established by CT Technologies;
• CT Technologies may at any time amend, limit, suspend, or terminate the Loyalty Program and/or Affiliate Program, including the calculation method, eligibility criteria, Hold Period, and list of rewarded actions, with or without notice, if necessary for security, compliance, business model sustainability, or user protection.

10.2 Prohibition of abuse in bonus and referral mechanisms

The User is prohibited, including but not limited to, from:

• creating, using, or controlling multiple accounts to obtain unlawful bonuses, accruals, or other benefits;
• engaging in self-referral, using Related Accounts, coordinated invitation schemes, circular, or other artificial affiliate accrual structures;
• buying, selling, renting, transferring, aggregating, or otherwise monetizing accounts, referral links, codes, traffic, or access rights in violation of these Terms;
• using bots, scripts, emulators, virtual devices, telemetry spoofing, device spoofing, VPN/proxy masking, or other means to circumvent restrictions and anti-fraud controls;
• taking actions aimed at artificial activity generation, fake registrations, fake purchases, or other fraud/abuse regarding bonus or referral mechanics.

10.3 Consequences of violations of bonus and referral mechanics

Violation of this section may result in one or more measures, including:

• cancellation, recalculation, hold, or annulment of Conditional Accruals;
• permanent disqualification from the Loyalty Program and/or Affiliate Program;
• restriction or termination of access to Payouts, conversion, and related functions;
• suspension or termination of the account, including Related Accounts;
• application of other measures provided in these Terms.

11. Prohibited conduct

Users are strictly prohibited from performing the following actions when using the Services, software, and related systems of the Operator and Ecosystem Participants:

• using bots, scripts, emulators, virtual devices, or any forms of automation to interact with the Services;
• using automated tools or software to interact with products or systems of the Operator and/or Ecosystem Participants;
• creating, operating, or controlling multiple accounts for one individual, including re-registration after account suspension or blocking in any service, product, or software of the Operator and/or Ecosystem Participants;
• using multiple accounts, abusing referral mechanisms, or otherwise circumventing account-level restrictions;
• transferring an account, credentials, access rights, sessions, licenses, or usage rights to third parties, including by sale, rental, shared use, delegated access, sublicensing, or any other form of transfer;
• simultaneously using the same software license on multiple devices or accounts;
• distributing licenses or memberships to third parties in any form;
• decompiling, disassembling, modifying, interfering with, or reverse engineering any part of the Services or related software;
• modifying software, its components, or client-side behavior in any way;
• exploiting errors, vulnerabilities, or system weaknesses, including attempts at unauthorized access to systems, infrastructure, or resources of the Operator and/or Ecosystem Participants;
• using vulnerabilities for personal gain or advantage;
• manipulating, distorting, falsifying, or otherwise interfering with DMR, mining indicators, telemetry, or results;
• circumventing technical, geographic, compliance, or security restrictions, or obtaining unintended benefits;
• using tools or methods to conceal or falsify location, identity, or device characteristics, including VPN, proxy, or similar technologies, if such use is aimed at circumventing restrictions or controls;
• distributing malicious software, malware, spyware, or any malicious code;
• using the Services for fraudulent, illegal, or otherwise unlawful purposes;
• violating applicable laws or regulatory requirements when using the Services;
• attempting to gain unauthorized access to accounts, data, or systems;
• providing false, misleading, or incomplete information during registration, verification, or compliance procedures.

12. Response measures, sanctions, and right to impose restrictions

In case of an actual violation, reasonable suspicion of a violation, or detection of anomalous activity, the Operator and/or the relevant Ecosystem Participant may, at their discretion, apply one or more measures without prior notice if necessary to protect users, ensure Service security, comply with regulatory requirements, or prevent losses.

Such measures may include:

• suspension, restriction, blocking, or termination of account access;
• freezing, holding, recalculation, annulment, or confiscation of Conditional Accruals, DMR, and/or other benefits;
• restriction, delay, rejection, or permanent termination of Payouts and/or conversion;
• permanent disqualification from bonus, loyalty, and/or affiliate mechanics;
• prohibition of re-registration and application of restrictions to Related Accounts;
• taking necessary legal actions to protect the legitimate interests of the Operator and/or the relevant Ecosystem Participant.

Application of a specific measure depends on the nature and degree of risk, and the Operator and/or the relevant Ecosystem Participant are not obligated to apply measures sequentially or exhaustively.

13. No financial guarantees

Neither the Operator nor other Ecosystem Participants provide any guarantees regarding:

• availability, timing, or amount of DMR, bonuses, referral accruals, or Payouts;
• uninterrupted or error-free operation of the Services;
• future availability of conversion functions, loyalty, bonus, or affiliate mechanics.

14. Limitation of liability

Neither the Operator nor other Ecosystem Participants shall be liable for:

• loss of DMR, bonuses, referral accruals, or other benefits due to User actions or negligence, as well as due to applied compliance and anti-fraud measures;
• indirect, incidental, or consequential damages;
• blockchain delays, failures of third-party services, liquidity constraints, or mandatory restrictions applied for security and compliance purposes.

15. AML/KYC compliance, investigations, and cooperation with authorities

The Operator follows strict AML/KYC policies and reserves the right to:

• request identity verification, liveness checks, additional documents, and explanations regarding source of funds, nature of transactions, and other circumstances;
• freeze or suspend accounts posing compliance or anti-fraud risks;
• apply adverse inference if the User fails to provide information or documents within the specified period;
• refuse payouts, conversion, and/or participation in bonus programs when risks of fraud, restriction circumvention, or other violations are identified;
• report suspicious activity to competent, law enforcement, regulatory, and other authorized authorities to the extent required or permitted by applicable law;
• engage relevant Ecosystem Participants in verification, monitoring, and response procedures within the scope of their role and applicable law.

The Operator and/or the relevant Ecosystem Participant may choose not to disclose to the User internal criteria, signals, models, and risk management procedures if such disclosure may reduce the effectiveness of anti-fraud and compliance controls or conflict with security and legal requirements.

16. Changes to the Services and the Terms

CT Technologies reserves the right to modify the Services, reward logic, payout terms, Loyalty Program and Affiliate Program parameters, and these Terms at any time. Continued use of the Services means acceptance of the updated Terms.

17. Governing law and jurisdiction

• General Services and VASP operations: governed by the laws of Poland; exclusive jurisdiction belongs to the competent courts of Warsaw, Poland.
• App store billing and payments: all payments, subscriptions, refunds, chargebacks, and billing disputes arising from purchases through Google Play or Apple App Store are governed exclusively by the rules, policies, and dispute resolution procedures of the respective app store. Neither CT Technologies nor CryptoCompany determines the applicable jurisdiction for such disputes.
• Cryptocurrency liquidity operations and the Operator's internal payment and settlement mechanism: governed by internal terms, compliance rules, and applicable law governing the activities of Zafiro Innovation Systems LLC (Costa Rica).

18. Contact information

For legal or technical inquiries:

Email: [email protected]

CT Technologies spółka z ograniczoną odpowiedzialnością

ul. Michała Kleofasa Ogińskiego 11/9, 03-318 Warszawa, Poland

KRS: 0001098738 | NIP: 5243003455 | REGON: 528307439