GENERAL LAMA TERMS AND CONDITIONS FOR PERSONAL ACCOUNTS

This agreement is for individual customers who reside in the European Economic Area (EEA).

1. WHAT THIS AGREEMENT IS ABOUT

1.1 You should read this agreement before you start using our services. It will create a legally binding agreement between you and us governing the basis on which we provide services to you, including how we use information on you and your activities. It will also give you information on what you could do if you run into some problems in any aspect of the service provided to you.

1.2 Under this Agreement we provide services relating to cryptocurrencies and issuing and redemption of electronically stored money, including offering payment accounts and associated services that use the balances in the accounts that you hold with us.

1.3 Please note that the risk of loss in trading or holding cryptocurrencies can be substantial. As with any asset, the value of cryptocurrencies can go up or down (and can even drop to zero), may be very volatile and there can be a substantial risk that you lose money buying, selling, holding, or investing in cryptocurrencies. Cryptocurrency services are not currently regulated by the Bank of Lithuania or any other regulator in Lithuania. You should carefully consider whether trading or holding cryptocurrencies is suitable for you considering your own financial situation and attitude to risk, as evaluated by you carefully. We do not make any representations or recommendations regarding the advisability or otherwise of trading in cryptocurrencies or any particular transaction. Further information relating to the risks associated with Cryptocurrency is available on our Website and App.

1.4 By using our Services, including downloading and using our App, you confirm that you accept and agree to this Agreement and understand the risks associated with using our Services. Please do not use our Services if you do not understand these risks and/or do not wish to enter into this Agreement.

1.5 You can access a pdf version of this Agreement via the Website or our App.

2. WHO WE ARE

2.1 LamaTechnology FS UAB (“Lama”) is a company registered and incorporated in Lithuania with company number 305833209 and registered office at Mėsinių str. 5, LT-01130 Vilnius, Lithuania. Lama is registered by the Register of Legal Entities of Lithuania for the provision of cryptocurrency services. Lama’s cryptocurrency services are controlled by the Lithuanian Financial Crime Investigation Service (FCIS). Lama’s cryptocurrency services are not regulated by the Bank of Lithuania.

2.2 The issuing and redemption of electronically stored money in the European Economic Area (EEA) is supported by Modulr Finance B.V., authorised and regulated by De Nederlandsche Bank for issuance of electronic money under reference number R182870. Modulr Finance B.V., a company incorporated in Netherlands with registration number 81852401, whose registered office is at Weteringschans 165 C, 1017XD, Amsterdam. LamaTechnology FS UAB is an approved Distributor of Modulr Finance B.V.

2.3 You can contact us by email at support@mylama.eu, or via the App.

3. OUR SERVICES

3.1 We provide the following services to you through the App:

3.1.1 Cryptocurrency Services, which are provided by Lama in accordance with Annex 2;

3.1.2 E-Money Services, which are provided by Modulr in accordance with Annex 3;

3.2 Lama may also offer additional services from time to time, and such additional services would be provided as an additional Annex.

3.3 The main way we provide our services is through the Lama mobile app. The App is downloadable from Apple App Store for Apple devices and Google Play store for Android devices. However, we may provide our services in other ways too, like through web pages. These terms apply whenever and however you access our services. This means they apply to all the ways you can access our services.

3.4 This Agreement, including each applicable Annex, constitutes the entire framework agreement concluded between the Parties for the provision of the Services provided by us to you.

3.5 The clauses of this Agreement shall apply in full to each of the Services. The clauses applicable to a Service shall be supplemented by the Annex applicable to that service. Any conflict between the clauses or Annexes in relation to a Service shall be resolved using the following priority:

3.5.1 paragraph in an Annex;

3.5.2 clause of this Agreement.

4. ELIGIBILITY FOR A LAMA ACCOUNT

4.1 In order to use our Services, you need to:

4.1.1 Be resident in any of the countries of the European Economic Area,

4.1.2 be 18 years old or above and have capacity to enter into legally binding contracts,

4.1.3 you use our services only for yourself as an individual in your personal capacity and not on behalf of any other person or entity or for commercial trading.

4.2 By using our services, you confirm and represent that all the above are true.

4.3 You may only open one Lama Account unless we have agreed in writing the opening of additional accounts. Lama may refuse the creation of duplicate accounts for the same user. Duplicate accounts may be closed or merged at Lama’s discretion.

5. OPENING AN ACCOUNT

5.1 To access our Services, you must register and open a Lama Account and provide us with the information prompted in the App.

5.2 We are required by law to carry out all necessary security and customer due diligence checks in order to establish your identity and comply with all legal requirements before we provide you with access to our Services. You agree to comply with any request from us for further information and provide such information in a format acceptable to us. In addition, you agree that we may make, directly or through any third party, any inquiries we consider necessary to validate the information you provided to us, including checking commercial databases or credit reports. You authorise us to obtain one or more of your credit reports, from time to time, to establish, update, or renew your Lama Account with us or in the event of a dispute relating to this Agreement and activity under your Lama Account.

5.3 You confirm that all information you provide to us are complete, accurate and truthful at all times during the term of this Agreement. Upon successful identification and verification, Lama will open an account for you and you will receive confirmation for it as part of the on-boarding process. You must update this information whenever it changes. We cannot be responsible for any financial loss arising out of your failure to do so. We may ask you at any time to confirm the accuracy of your information and/or provide additional supporting documents.

6. ACCESSING YOUR ACCOUNT

6.1 We will provide you with the ability to securely access your Account by entering your security details (“Account Details”) and authentication and verification technology. To ensure the safety and security of your Lama Account, you must:

6.1.1 Have access to a mobile phone or any additional device Lama requires for security purposes.

6.1.2 Follow good password use and management practice – change your password regularly, choose a password- that cannot be easily guessed, and ensure that it is not reused across other online accounts. Lama requires a minimum password length of initially 6 (six) numbers.

6.1.3 You must reset passwords anytime you feel your password is compromised.

6.1.4 Use any optional additional security features which may be provided by Lama.

6.1.5 Keep your e-mail account secure.

6.1.6 You must NOT disclose your Lama Account password to anyone or let anyone access your account. You should make sure you do not let anyone see how you access your account. We recommend that you store your password safely.

6.2 Each time you seek to access your Account, we will check your identity by asking for your Account Details. Lama reserves the right to have additional safety features in order to protect you and your account. As long as your correct Account Details and any additional security questions are provided by you, we will assume that you are the person that has accessed your Account and is giving Instructions and you will be liable for those Instructions unless otherwise stated in this Agreement.

6.3 If you have any indication or suspicion of your Lama Account, Account Details, password or other security features being lost, stolen, misappropriated, used without authorisation or otherwise compromised, you are advised to change your password. You must contact us by email to support@mylama.eu without undue delay but, in any event, no later than one business day after becoming aware of any loss, theft, misappropriation or unauthorised use of your Account, Account Details, password or other security features. Any undue delay in notifying us may not only affect the security of your Lama Account but may result in you being liable for any losses as a result. If you suspect that your Lama Account was accessed by someone else, you should also contact the police or any other relevant authority or third party and report the incident. We are not responsible for losses due to your negligence in keeping your password safe.

6.4 We may suspend your Lama Account or otherwise restrict its functionality on reasonable grounds relating to the security of the Lama Account or any of its security features or if we reasonably suspect that an unauthorised or fraudulent use of your Lama Account has occurred or that any of its security features have been compromised or that any use was made that is possibly illegal or not in accordance with any law or regulation. We will notify you of any suspension or restriction and of the reasons for such suspension or restriction in advance or, where we are unable to do so, immediately after the suspension or restriction has been imposed, unless notifying you or providing you with the reasons for the suspension or restriction would be unlawful or compromise our or our third party suppliers’ security interests.

6.5 You agree and accept all the risks associated with maintaining balances in currencies and assets that we may support, including any risks associated with fluctuations in the relevant exchange rates or value over time.

6.6 We do not allow negative Balances. If you have a negative Balance as a result of a Chargeback, the reversal of a transaction, a deduction of Fees or any other action carried by you, you are liable to repay the negative Balance immediately without any notice from us. Where you have a negative balance in your Cryptocurrency Wallet and where available, a positive Balance in your E-Money Wallet, or vice versa, you agree that we may carry out a transfer to or from the account with the positive Balance to repay the negative Balance on the other account. We may send you reminders or take such other reasonable actions to recover the negative Balance from you, for example, we may use a debt collection service or take further legal actions. We will charge you for any costs we may incur as a result of any such reasonable actions.

6.7 You are responsible for any taxes which may be applicable to payments you make or receive, and it is your responsibility to collect, report and pay the correct tax to the appropriate tax authority.

7. AVAILABILITY OF THE SERVICES

7.1 When applying for your Account, the App will show you which Services are available to you. We will inform you through the App or by email when we launch any additional Services under this Agreement.

7.2 We will try to make sure that our Services are available to you when you need them. However, we do not guarantee that our Services will always be available or be uninterrupted. We may suspend, withdraw, discontinue or change all or any part of our Service without notice. We will not be liable to you if for any reason our Services are unavailable at any time or for any period. You are responsible for making all arrangements necessary for you to have access to our Services.

8. EXECUTING A TRANSACTION AND REDEMPTIONS

8.1 You can submit an instruction to initiate a Payment Transaction using E-Money in your E-Money Wallet if available or Cryptocurrency in your Cryptocurrency Account through the App (an “Instruction”). Before submitting an Instruction, you must ensure that you have a sufficient Balance to cover the related Transaction, as applicable, and any related Fees (as set out in the Fee Schedule), otherwise we will refuse the relevant Instruction.

8.2 In order to carry out a Transaction, you may be required to authorise the payment with your Account Details and password or by any other means at our sole discretion. We may also ask you additional security questions relating to you or your Lama Account. If your Lama Account is protected by additional security measures, you need to follow the instructions provided to you with such additional security measures.

8.3 Execution of your Instructions shall be subject to the following terms and conditions:

8.3.1 Lama shall execute your instructions if the information required for execution has been provided through the App;

8.3.2 the instruction has been authorised by you; and

8.3.3 the available E-Money Wallet or Cryptocurrency Wallet, whichever is being used for the relevant Transaction, has sufficient credit balance available for the Transaction concerned; and

8.3.4 we consider at our sole discretion that executing the relevant Payment Transaction will not breach any anti-money laundering or other legal requirements and the jurisdiction, recipient or any other related party is not subject to any sanctions.

8.4 An Instruction shall be considered received by Lama:

8.4.1 if we and you mutually agree that execution of the Transaction is to take place on a specific day;

8.4.2 on the last day of a certain period; or

8.4.3 on the day on which you have put Funds at our disposal.

8.5 If and where appropriate, we may refuse to process any Transaction at our discretion and without this decision giving rise to any compensation on your part. Where possible (and subject to applicable law), we will provide you with the reasons for refusing to process any Transaction.

8.6 Unless clause 8.5 applies, once we have received your Instruction a confirmation will be sent to you and you may not withdraw your consent to a Transaction after it has been deemed to be received. Each Instruction is given a unique transaction number and is shown in the transaction history on your Lama Account. You should quote this transaction number when communicating with us about an Instruction.

8.7 Some transactions may take longer to complete, and we may consider this as pending until full completion is confirmed. In such cases, we will inform you as soon as we have confirmation of completion of a Transaction.

8.8 If we are unable to complete your Instruction, we will let you know and, if possible, provide you with the reasons for the refusal and, if applicable, an explanation of how to correct any factual errors. However, we are not required to notify you if such notification would be unlawful or contrary to our regulatory obligations.

8.9 You are responsible for making sure that the information you provide in setting up a transfer or transaction is correct and accurate. If we have processed your instructions in accordance with the information you have provided to us it will be considered correctly completed even if you have made a mistake. If you have provided incorrect information, you may lose your Cryptocurrency or where available, E-Money and we will not be held liable for this. Other than where required under applicable law, we will not reimburse any losses as a result of you providing incorrect information. If you have provided wrong information on the recipient, you may ask us to assist you in recovering funds relating to a Transaction, but we cannot guarantee that such efforts will be successful.

8.10 We reserve the rights to place limits on Transactions or redemptions that you may send per transaction or in relation to your Lama Account. We may also impose limits on your balances and activities in accordance with the legal and regulatory restrictions applicable to you. If you exceed any of these limits, we may decline your Instruction and may at times require you to provide additional documents so that we can carry out additional checks if necessary before allowing any further Transactions or redemptions. For more information on the applicable limits, please visit our FAQ.

8.11 We are not responsible for the time it takes for payments to reach us if you fund your account from persons who do not hold a Lama Account.

9. YOUR DATA

9.1 The processing of your data is governed by our Privacy Policy which can be found on the Lama Website. By accepting these Terms and Conditions, you also agree to the terms of our Privacy Policy

10. INTELLECTUAL PROPERTY RIGHTS

10.1 In this clause, “Lama IP Rights” means in relation to Lama, all: (i) patents, inventions, designs, copyright and related rights, database rights, knowhow and confidential information, trademarks and related goodwill, trade names (whether registered or unregistered), and rights to apply for registration; (ii) all other rights of a similar nature or having an equivalent effect anywhere in the world which currently exist or are recognised in the future; and (iii) all applications, extensions and renewals in relation to any such rights.

10.2 Except as expressly set out in this Agreement, you are not entitled, for any purpose, to any Lama IP Rights. We shall at all times retain ownership, including all rights, title and interests in and to all Lama IP Rights and you understand and accept that by using the Services you shall not:

10.2.1 acquire or otherwise be entitled to any Lama IP Rights;

10.2.2 make a claim in respect of any Lama IP Rights or any other equivalent rights; or

10.2.3 use, attempt to use, copy, imitate or modify (whether in whole or in part) any Lama IP Rights, except with our prior written consent.

10.3 You may not, and may not directly or indirectly, or attempt to directly or indirectly:

10.3.1 transfer, sublicense, loan, sell, assign, lease, rent, distribute or grant rights in any Lama IP Rights to any person or entity;

10.3.2 remove, obscure, or alter any notice of any Lama IP Rights;

10.3.3 modify, copy, tamper with or otherwise create derivative works of any Lama IP Rights; or

10.3.4 reverse engineer, disassemble, or decompile any part of the Services or Lama IP Rights or apply any other process or procedure to derive the source code of any software included in the Services or any Lama IP Rights.

11. INFORMATION SECURITY

11.1 You are responsible for configuring your information technology, computer programmes and platform in order to access our Services. You should use your own virus protection software. We cannot guarantee that our Services will be free from bugs or viruses.

11.2 You must not misuse our Services by introducing viruses, trojans, worms, logic bombs or other materials which are malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, our servers, computers or databases. You must not attack our Website with any type of denial of service attack. By breaching this provision, you may commit a criminal offence and we will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website and/or our Services will cease immediately.

11.3 We will not be liable for any loss or damage caused by a virus, or other technological attacks or harmful material that may infect your computer equipment, computer programmes, data or other proprietary material related to your use of our Services.

12. HOW WE MAY CONTACT YOU

12.1 We usually contact you via email. For this purpose, you must at all times maintain at least one valid email address in your Lama Account profile. You should check for incoming messages regularly and frequently. These emails may contain links to further communication on our Website. If you don’t maintain or check your email and other methods of communications, you will miss emails about your transactions and our Services. We cannot be liable for any consequence or loss if you don’t do this. If we have reasonable concerns either about the security of your Lama Account, or any suspected or actual fraudulent use of your Lama Account, we will contact you via telephone, email, or both (unless contacting you would be unlawful or compromise our reasonable security measures).

12.2 In addition to communicating via email, we may contact you via telephone where appropriate. If you use any mobile services, we may also communicate with you via SMS. Any communications or notices sent by:

12.2.1 Email will be deemed received by you on the same day if it is received in your email inbox before 5pm on a Business Day. If it is received in your email inbox after 5pm on a Business Day or at any other time, it will be deemed received on the next Business Day.

12.2.2 SMS will be deemed received the same day.

12.3 Where legislation requires us to provide information to you on a durable medium, we will either send you an email (with or without attachment) or send you a notification pointing you to information on our Website in a way that enables you to retain the information in print format or other format that can be retained by you permanently for future reference. We recommend you keep copies of all communications we send or make available to you.

12.4 Documents or communications in any other languages are for your convenience and only the English language version of them are official.

12.5 You can request a copy of the current Agreement or any other contractual document relevant to you by contacting us.

13. LIABILITY AND INDEMNITY

13.1 To the fullest extent permitted by applicable law, in no circumstances shall any of us and any of our respective past, present and future employees, officers, directors, contractors, consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns (the “Indemnified Parties”) be liable for any direct, indirect, special, incidental or consequential loss of any kind (including, but not limited to, loss of revenue, income, business or profits, loss of contract or depletion of goodwill, loss of anticipated savings, loss of use or data, or damages for business interruption or any like loss) arising out of or in any way related to the Services or otherwise related to this Agreement, regardless of the cause of action, whether based in contract, tort (including negligence), breach of statutory duty, restitution or any other legal or equitable basis (even if any of the Indemnified Parties have been advised of the possibility of such losses and regardless of whether such losses were foreseeable).

13.2 We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for the gross negligence, fraud or intentional, wilful or reckless misconduct of any indemnified Party, nor shall it limit or exclude any losses for which, as a matter of applicable law, it would be unlawful to limit or exclude liability.

13.3 To the fullest extent permitted by applicable law, you will indemnify, defend and hold harmless the Indemnified Parties from and against any and all claims, demands, actions, damages, losses, costs and expenses (including reasonable professional and legal fees) that arise from or relate to:

13.3.1 Your use of any of the Services (including the Cryptocurrency Wallet and where available, the E-Money Wallet);

13.3.2 your use of the App;

13.3.3 your acquisition or holding of any Cryptocurrencies under this Agreement;

13.3.4 the performance or non-performance of your responsibilities, representations, warranties or obligations under this Agreement;

13.3.5 your breach of any of the terms and conditions set out in this Agreement;

13.3.6 your breach of any rights of any other person or entity.

13.4 The indemnity set out in this clause 13 is in addition to, and not in lieu of, any other remedies that may be available to any Indemnified Parties under applicable law or any other contract or rights.

13.5 We have no control over websites linked to and from our Website or App and we assume no responsibility for their content or any loss or damage that may arise from your use of them.

13.6 In the unlikely event of loss or claims or costs and expenses arising out of your breach of this Agreement, any applicable law or regulation and/or your use of our Services, you agree to compensate us and our affiliates and hold us harmless. This provision will continue after this Agreement is terminated.

13.7 In the event you are liable for any amounts owed to us, we may immediately remove such amounts from your Balance (if available). If there are insufficient funds in your Balance to cover your liability, we reserve the right to collect your debt to us by using any payments (or cryptocurrency) received in your Lama Account and otherwise you agree to reimburse us through other means. We may also recover amounts you owe us through legal means, including, without limitation, through the use of a debt collection agency.

14. CHANGES TO THE AGREEMENT

14.1 Subject to paragraph 15.2 below:

14.1.1 where any changes to this Agreement relate to the E-Money Services, or the terms and conditions that apply to the E-Money Services, we may change this Agreement by giving you at least two months’ prior written notice. If we do this, you can terminate this Agreement immediately by providing written notice to us during this notice period. If you do not contact us to terminate this Agreement during the notice period, you will be considered as having accepted the proposed changes and the amended Agreement will apply to you from the effective date specified on the notice;

14.1.2 where the changes to this Agreement do not fall within clause 14.1.1, we may change this Agreement at any time by giving you notice. Any changes made by us under this clause 14.1.2 shall apply immediately or on the effective date specified on the notice provided to you and will be binding on you from that point in time. In the event that you object to any changes proposed by us pursuant to this clause 14.1.2, you have the right to terminate this Agreement by giving us notice. Upon receipt of any such notice from you, the procedure set out in clause 15 shall apply.

14.2 Changes to exchange rates shall come into effect immediately without notice and you shall not have the right to object to such a change.

15. SUSPENDING OR TERMINATING THIS AGREEMENT

15.1 This Agreement is concluded for an indefinite period of time and shall enter into force from the date that your application for a Lama Account is accepted by us.

15.2 You may terminate this Agreement with us and Close your Lama Account at any time, subject to you providing us a period of two weeks' prior notice, by contacting us at support@mylama.eu. We may end this Agreement and close your Lama Account or any service associated with it by giving you two months’ prior notice.

15.3 We may at any time suspend or close your Lama Account and/or end this Agreement without notice if:

15.3.1 you breach any provision of this Agreement or documents referred to in this Agreement;

15.3.2 we are requested or directed to do so by any competent court of law, government authority, public agency, or law enforcement agency;

15.3.3 we have reason to believe you are in breach of any applicable law or regulation; or

15.3.4 we have reason to believe you are involved in any fraudulent activity, money laundering, terrorism financing or other criminal or illegal activity.

15.4 We may suspend your Lama Account or restrict its functionality if in our sole discretion we have concerns about the security of your Lama Account, suspected unauthorised or fraudulent use of your Lama Account, suspect money laundering or relates to money laundering activities or breach of applicable law.

15.5 We will give you notice of any suspension or restriction and the reasons for such suspension or restriction as soon as we can, either before the suspension or restriction is put in place, or immediately after, unless notifying you would be unlawful or compromise our reasonable security measures. We will lift the suspension and/or the restriction as soon as practicable after the reasons for the suspension and/or restriction have ceased to exist.

15.6 On termination for any reason all rights granted to you in connection with the App shall cease, you must immediately delete or remove the App from your devices.

15.7 At the time of closure, if you still have E-Money or Cryptocurrency in your Lama Account, you must redeem or transfer this within the notice period set out in clause 15.2. After this time, you will no longer have access to your Lama Account but you can still withdraw your Funds by contacting us at support@mylama.eu. You have the right to do this for a period of 6 years from the date your Lama Account is closed.

15.8 You must not close your Lama Account to avoid an investigation. Subject to applicable law, if you attempt to close your Lama Account during any investigation we may hold any Funds in your Lama Account until the investigation is fully completed in order to protect our or a third party’s interest.

16. TAXATION

16.1 Unless otherwise informed through the App, you are solely responsible for determining whether your use of the App and any of the Services will give rise to any tax implications on your part.

16.2 You are also solely responsible for withholding, collecting, reporting, paying, settling and/or remitting any and all taxes to the appropriate tax authorities in such jurisdiction(s) in which you may be liable to pay tax. We shall not be responsible for withholding, collecting, reporting, paying, settling and/or remitting any taxes (including, but not limited to, any income, capital gains, sales, value added or similar tax) which may arise from your activities, including in relation to Cryptocurrencies, under or in connection with this Agreement.

16.3 You agree not to hold any of us or any of the Indemnified Parties liable for any tax liability associated with or arising from your activities, including in relation to Cryptocurrencies, under or in connection with this Agreement.

17. COMPLAINTS

17.1 If you have a complaint, please contact us and we'll do our best to fix the problem. You may send an email to support@mylama.eu or chat with us in the App.

17.2 If you are not satisfied with our handling of your complaint, for matters related to e-money services, you may be able to refer it to the Financial Services Complaints Institute (Kifid) in the Netherlands. For matters related to cryptocurrency services, you will NOT be able to refer your complaint to the Financial Services Complaints Institute.

18. FORCE MAJEURE

18.1 If the Affected Party is prevented, hindered or delayed from or in performing any of its obligations under this Agreement by a Force Majeure Event, its obligations under this Agreement shall be suspended while the Force Majeure Event continues to the extent that the Force Majeure Event prevents, hinders or delays its performance of those obligations.

18.2 If the period of delay or non-performance arising due to a Force Majeure Event continues for 4 weeks then the non-Affected Party may terminate this Agreement by giving 7 calendar days' written notice to the Affected Party.

19. OTHER MATTERS

19.1 This Agreement is between you and us. No other person shall have any rights to enforce any of its terms. Neither of us will need to get the agreement of any other person in order to end or make any changes to this Agreement.

19.2 You acknowledge that by entering into this Agreement, you:

19.2.1 have not relied on any oral or written statements, warranties, assurances, representations or undertakings which were or may have been made by us or on our behalf by any of the Indemnified Parties and/or a related entity or undertaking in relation to the subject matter of this Agreement at any time before your acceptance of them (“Pre-Contractual Statements”), other than those set out in this Agreement. You hereby waive any and all rights and remedies which might otherwise be available in relation to such Pre-Contractual Statements; and

19.2.2 we do not provide any financial, accounting, taxation or legal advice in relation to this Agreement or the Services and you are solely responsible for making your own independent appraisal and investigation of the risks of using the App and any of the Services and you should obtain your own legal, accounting, tax and/or financial advice in relation to such matters as you consider necessary.

19.3 You may not transfer, assign, mortgage, charge, subcontract, declare a trust over or deal in any other manner with any or all of your rights and obligations under this Agreement (including the Lama Account) without our prior written consent. We reserve the right to transfer, assign or novate this Agreement (including the Account) or any right or obligation under this Agreement at any time without your consent. This does not affect your rights to close your Account as stipulated in this agreement.

19.4 Each of the paragraphs of this Agreement operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.

19.5 Nothing in this Agreement shall be deemed to create any form of partnership, joint venture or any other similar relationship between you and us, and/or other individuals or entities involved with the development and deployment of the App.

19.6 If we delay in asking you to do certain things or in taking action, it will not prevent us taking steps against you at a later date.

19.7 This Agreement supersedes and extinguishes all previous agreements between you and us, whether written or oral, relating to its subject matter and constitutes the entire Agreement between you and us.

19.8 Any dispute between you and us arising out of or in connection with your Lama Account and/or this Agreement (including non-contractual disputes or claims) shall be governed by the laws of England and Wales and shall fall within the exclusive jurisdiction of the courts of England and Wales.

ANNEX 1 - DEFINITIONS

The following definitions apply:

ANNEX 2 - CRYPTOCURRENCY SERVICES

20. CRYPTOCURRENCY RISKS

20.1 The risk of loss in trading or holding cryptocurrencies can be substantial. As with any asset, the value of cryptocurrencies can go up or down (and can even drop to zero), may be very volatile and there can be a substantial risk that you lose money buying, selling, holding, or investing in cryptocurrencies. Cryptocurrency services are not currently regulated by the Bank of Lithuania or any other regulator in Lithuania. You should carefully consider whether trading or holding cryptocurrencies is suitable for you in light of your own financial situation and attitude to risk, as evaluated by you carefully. We do not make any representations or recommendations regarding the advisability or otherwise of trading in cryptocurrencies or any particular transaction.

20.2 Further information relating to the risks associated with Cryptocurrency are available on our Website and App.

20.3 By entering into this Agreement, you acknowledge and agree that using our Services carries significant financial, regulatory and reputational risks including but not limited to those set out on the Lama Website.

20.4 By entering into this Agreement you expressly acknowledge that you understand and accept the risks set out in on the Lama Website.

21. CRYPTOCURRENCY SERVICES

21.1 We provide the following Cryptocurrency Services through the App:

21.1.1 allowing you to purchase Cryptocurrency (“Cryptocurrency Purchase”);

21.1.2 Cryptocurrency storage (“Cryptocurrency Wallet) services; whereby Cryptocurrency (whether purchased from Lama Platform or transferred from an external Cryptocurrency wallet) can be held in a Cryptocurrency Wallet;

21.1.3 Cryptocurrency transfer (“Cryptocurrency Transfer”) services, whereby Cryptocurrency stored in your Cryptocurrency Wallet is transferred to another customer’s wallet without Cryptocurrency conversion.

21.1.4 Cryptocurrency conversion (“Cryptocurrency Conversion”) services, whereby Cryptocurrency stored in your Cryptocurrency Wallet is transferred to:

(a) another customer’s Cryptocurrency Wallet, in exchange for either;

(i) E-Money paid into your E-Money Wallet; or

(ii) Another Cryptocurrency which is paid into your corresponding Cryptocurrency Wallet; or

21.1.5 Cryptocurrency withdrawals, whereby Cryptocurrency stored in your Cryptocurrency Wallet is withdrawn from your Lama Account and sent to a Cryptocurrency wallet, being either your Cryptocurrency wallet or another person’s Cryptocurrency wallet, maintained and operated by a third party (“Cryptocurrency Withdrawal”) and therefore is operated outside Lama App.

21.2 Use of cryptocurrency may be illegal in some jurisdictions. It is your responsibility to know the regulatory requirements concerning transactions with cryptocurrency in your jurisdiction before using the Services.

22. FUNDING YOUR CRYPTOCURRENCY WALLET

22.1 Once your Lama Account has been opened, there are two methods by which you can add Cryptocurrency to your Cryptocurrency Wallet:

22.1.1 you or a third party may transfer Cryptocurrency to your Cryptocurrency Wallet; or

22.1.2 you may carry out a Cryptocurrency Purchase.

22.2 You or any other party may transfer Cryptocurrency to your Cryptocurrency Wallet by sending the relevant Cryptocurrency we support to the relevant Cryptocurrency Wallet address available via the App. We are not responsible for any attempted transfer made relating a cryptocurrency that cannot be held in the Cryptocurrency Wallet or any Cryptocurrency we do not support.

22.3 You may purchase Cryptocurrency from us or a third party via the App, subject to the applicable Fees. The price, exchange rate, and amount of the Cryptocurrency that you wish to purchase will be confirmed via the App at the time that you place an order for a Cryptocurrency Purchase.

22.4 There are three methods by which you can make a Cryptocurrency Purchase:

22.4.1 you may use E-Money held in your E-Money Wallet to purchase Cryptocurrency;

22.4.2 you may purchase a Cryptocurrency using another Cryptocurrency; or

22.4.3 you may purchase Cryptocurrency via the App using any other Accepted Payment Method.

22.5 Acceptance of an order for a Cryptocurrency Purchase does not guarantee that you will receive the corresponding amount of Cryptocurrency into your Cryptocurrency Wallet (as defined below). The Cryptocurrency Purchase is conditional upon actual receipt of the funds, as well as payment of any applicable Fees.

22.6 Subject to the terms of this Agreement and the transaction being honoured by your bank or other relevant party, Cryptocurrency Purchases will be credited to the Cryptocurrency Wallet as soon as possible once the Cryptocurrency Purchase has been confirmed by the relevant Cryptocurrency network.

23. PROVIDING YOUR CRYPTOCURRENCY WALLET

23.1 When you create a Cryptocurrency Wallet, we will manage a cryptographic private and public key pair (the “Keys”) on your behalf that Lama may use to send and receive Cryptocurrency to or from your Cryptocurrency Wallet.

23.2 In relation to any Transactions using Cryptocurrency outside the Lama network, you acknowledge and confirm that you understand that:

23.2.1 when using the Cryptocurrency Wallet, you may be directly communicating with network relating to the relevant Cryptocurrency and any such transactions are irreversible. The Cryptocurrency Wallet is not a custodian of your assets;

23.2.2 all such transactions must be confirmed and recorded on the network relating to the relevant Cryptocurrency;

23.2.3 Lama has no control over the network relating to the relevant Cryptocurrency and therefore:

(a) the transaction you submit via Cryptocurrency Wallet may not be completed, or may be substantially delayed, by the network relating to the relevant Cryptocurrency when processing the transaction;

(b) cannot and does not ensure that any transaction details you submit through our App will be confirmed on the network relating to the relevant Cryptocurrency;

(c) cannot assist you to cancel or otherwise modify your transaction or transaction details and does not have the ability to facilitate any cancellation or modification requests; and

(d) does not guarantee that our Services can transfer title or right in any Cryptocurrency or make any warranties whatsoever with regard to such title.

23.3 We provide you the ability to hold Cryptocurrencies in your Cryptocurrency Wallet. We have the right to remove the ability to hold a particular Cryptocurrency in your Cryptocurrency Wallet at any time and in such cases, we shall use our best endeavours to inform you in advance to give you the opportunity to move your Cryptocurrency to another Cryptocurrency or withdraw them from your Account as you may find appropriate.

23.4 In the event of a “fork”, we may not be able to support activity related to the any Cryptocurrency held in your Cryptocurrency Wallet. You agree and understand that, in the event of a fork, the transactions may not be completed, completed partially, incorrectly completed, or substantially delayed. We are not responsible for any loss incurred by you if caused in whole or in part, directly or indirectly, by a fork.

23.5 You agree to take responsibility for all activities that occur in relation to your Cryptocurrency Wallet and that you accept all risks of any authorised or unauthorised access to your Cryptocurrency Wallet, subject to applicable law.

24. TRANSFERRING AND WITHDRAWING CRYPTOCURRENCY

24.1 Cryptocurrency (or part thereof) held in a Cryptocurrency Wallet may be transferred to another customer’s Cryptocurrency wallet or an external Cryptocurrency wallet maintained and operated by a third party. Lama shall specify the information required to effect a Cryptocurrency Transfer or Cryptocurrency Withdrawal at the point of instruction but, as a minimum, Lama shall require the:

24.1.1 address of the recipient’s wallet; and

24.1.2 amount to be transferred.

24.2 We may charge additional network fees (“gas” fees) to process a Cryptocurrency Transfer or Cryptocurrency Withdrawal to a Wallet outside the Lama network. We will calculate the network fee at our discretion, although we will always notify you of the chargeable network fee at or before the time you authorise the Cryptocurrency Transfer or Cryptocurrency Withdrawal.

24.3 The Fees applicable to a Cryptocurrency Transfer and Cryptocurrency Withdrawal are set out in the Fee Schedule.

25. CRYPTOCURRENCY CONVERSION –

25.1 You may convert the Cryptocurrency or where available, E-Money held in in your Lama Account into other Cryptocurrencies or Fiat Currencies that we support at that time. The applicable exchange rate to a Conversion will be shown to you prior to a Conversion taking place and by confirming the Conversion transaction, you agree to the exchange rate that has been provided to you.

25.2 Any exchange rates provided in relation to a Conversion are only guaranteed for the set period of time stated in the proposed Conversion notification. You are not able to cancel any Exchange Transaction and so before making any transaction you should make sure that you are certain you want to proceed.

26. FEES

26.1 You must pay the Fees in connection with the use of our Services as set out in the Fee Schedule.

26.2 We will let you know the exact amount of any Fees that are payable by you when you send us Instructions. When you confirm the Instruction and that the relevant Transaction should take place, you accept the applicable Fees. Any Fees are chargeable from the source Cryptocurrency Wallet or where available, E-Money Wallet as part of a Transaction.

26.3 If you do not have sufficient Cryptocurrency or where available, E-Money in your Lama Account to cover the Fees required to execute a transaction, we may refuse to execute the Transaction or provide any Services to you.

ANNEX 3 - E-MONEY SERVICES

27. E-MONEY SERVICES

27.1 Lamatechnology FS UAB ("Lama") is a distributor of Modulr Finance B.V. for the provision of issuing and redemption of electronically stored money.

27.2 The issuing and redemption of electronically stored money in the EEA is supported by Modulr Finance B.V. (Modulr). Modulr Finance B.V. is authorised and regulated by De Nederlandsche Bank for issuance of electronic money under reference number R182870. Modulr Finance B.V., a company incorporated in Netherlands with registration number 81852401, whose registered office is at Weteringschans 165 C, 1017XD, Amsterdam.

27.3 Before you can use the E-money services provided by Modulr, you must agree with Modulr's Terms and Conditions in addition to Lama's Terms and Conditions. Each of which constitutes an entirely separate agreement. Where you make use of the services, these are provided on the understanding that you have agreed to each agreement independently, as relevant to the services you use.

27.4 Modulr Terms and Conditions are available for your convenience in our app and website.

27.5 When Modulr holds Electronic Money on your behalf is not the same as a Bank holding money in that:

27.5.1 Modulr cannot and will not use the funds to invest or lend to other persons or entities;

27.5.2 the Electronic Money will not accrue interest; and

27.5.3 the Electronic Money is not covered by any Financial Services Compensation Scheme.

27.6 The Client may hold Electronic Money indefinitely. However, if Modulr holds Electronic Money for a Client for more than two years without activity, Lama shall use reasonable endeavours to contact the Client to redeem the Electronic Money and return the corresponding funds to the Client. If Lama is unable to contact the Client, it may redeem the Electronic Money and send the corresponding funds, less any of its costs incurred, to the last known bank account Lama has on file for the Client.

ANNEX 4 - REFERRAL PROGRAM

28. WHO IS ELIGIBLE TO PARTICIPATE?

28.1 To be eligible for the Lama bonus, you must:

28.1.1 Be at least 18 years of age

28.1.2 Live in one of the countries supported by Lama.

28.1.3 Complete the verification of your account. You will be required to complete ID and photo verification.

28.1.4 Have only one Lama account

29. PAYMENT OF BONUS

29.1 Bonus will be credited in your Lama account as soon as you achieve the relevant targets.

30. ADDITIONAL INFORMATION

30.1 Lama reserves the right to change or modify any of the terms of their bonus or referral program, at any time and in its sole discretion. By participating in the bonus/referral program, you acknowledge that receiving payouts is not guaranteed by Lama.

30.2 Bonus will be paid only once for an individual per qualifying round. Duplicate accounts will be disqualified and Lama will not pay out the bonuses on accounts that maliciously create fictitious and double accounts. If you redeem your bonus you will have to start collecting from zero again.

30.3 If you do not comply with these terms, you could lose your bonus and you may be excluded from participating in future Lama Bonuses Programs.

Privacy Policy

We take data privacy very seriously and recognise the importance of protecting and respecting your personal data. This Privacy Policy describes the information we collect, how we use that information, to whom we pass the information, your rights and key contact information.

By visiting this website, or providing your personal information to one of our employees, for example by email, you accept and expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

1. What Information we collect

1.1 Information we may collect from you

You may provide us with information by filling in forms on our website, or by talking with us via email or otherwise.

This includes information you provide when you browse our website, register for an account via our app, enter into a contract for the supply of cryptocurrency services, promotion or survey and when you contact us for other reasons.

1.1.1 Initial information

To use Lama Services, you must provide your name, address, phone number and email address – and we may ask you to provide identity document number(s) and copies of identification documents, for example your driving license or passport, or a utility bill.

1.1.2 Additional verification information:

We may ask you to send us additional information if:

• we cannot verify the information that you provide; or

• a query is raised by background checks (see below); or

• Iif you send or receive certain high-value transactions or high overall payment volumes through Lama Services; or

• as is otherwise required in order for us to comply with our obligations under money laundering regulations.

The additional information may include a copy of your driving licence, passport, and/or a recent utility bill, or other information verifying your identity and address, or to answer additional questions to help verify your information or transaction.

We may also ask for evidence of source of funds or wealth, for example bank statements, investment statements, proof of property sale or probate documents.

1.1.3 When we communicate

When you communicate with us for customer service or other purposes, including by email or using other methods, we retain that information and our responses to you.

1.1.4 Transaction information

When you use Lama Services to send currency, we may ask you to provide information related to that transaction. For crypto transactions, this information will include amount, crypto, source of funds and external wallet. For fiat transactions, this information includes the amount, currency and type of the transaction, source of funds, exchange rate, recipient name and bank details ((account number, sort code and IBAN), recipient address for some jurisdictions and, optionally, the recipient’s email address and phone number.

1.2 Information we collect when you use our website

When you arrive at or leave Lama website, whether connected by a fixed line or wirelessly, we receive the web address of the site that you came from or are going to.

While you are using our site we collect information on the services you search for or view, page response times and length of visits to specific pages, how you interacted with each page (including scrolling, clicks and mouse-overs), and methods used to browse away from the page.

We collect information about the device you are using, such as the type of device, operating system and platform, the type and version of browser, browser plug-in types and versions, the times you access our website/app and the time zone setting, mobile network information and unique device identifier, which may include your Device's IMEI number and/or MAC address, or the mobile phone number used by the Device. We do not capture GPS information about you.

1.3 Information about you that we receive from third parties

1.3.1 Identity verification using Photographs and facial imaging

To protect ourselves and our customers against fraud, we verify the information you provide with identity verification agencies to undertake required verification, regulatory and fraud prevention checks. In the course of verification, we may ask you to upload a photograph of your identity document and/or use the Device’s camera to verify your identity using facial recognition in order to provide these specific services. We receive information about you from such services

1.4 Sensitive data

Data privacy regulations prohibit the processing of ‘special categories of personal data’, also called ‘sensitive data’ unless you have given your consent.

Sensitive data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life or sexual orientation. There are also restrictions on processing of criminal convictions and offences.

To avoid infringing these restrictions, it is Lama’s policy that we do not ask for or collect any of the above data from you or any other party, so we therefore ask that you please do not reveal any sensitive data about yourself or others in any communication with us.

If you do reveal sensitive data, for example by phone or in an email, you will be giving express consent for us to process that information by storing the recording of the telephone call, or the email or other communication.

2 How we use your information?

By submitting your information to Lama you agree that we may use your information for the following purposes:

2.1. Fulfilling your requests

We will use your information to:

• provide you with the information, products and services that you request from us, including providing you with crypto services;

• complete any transaction you are undertaking with us; and

• administer any promotion, survey or competition that you enter via our website.

2.2 Compliance and risk managemen

As a registered cryptoasset provider, we are obliged to carry out background checks on individuals and connected parties, and to monitor ongoing transactions. This is to prevent fraud and money laundering, including to help protect your accounts from fraudulent activity.

We carry out checks to ensure we do not deal with countries, entities or individuals that are subject to sanctions, to comply with counter-terrorist financing and anti-money laundering regulations and to identify high-risk individuals where we need to add additional controls. We also conduct investigations into actual or suspected violations of our Terms of Use.

2.3 Communication and customer service

We communicate with our users on a regular basis via email to provide requested services and help you manage your account. These activities may include:

• responding to requests for customer service;

• confirming information concerning a user's identity, business or account activity;

• resolving customer complaints;

• carrying out collection activities; and

• conducting customer surveys;

We use your email address and phone number to:

• confirm your opening of a Lama account;

• send you notice of transactions that you send or receive through Lama;

• send you information about important changes to our products and services, including notice of any times that our services may not be available; and

• send notices and other disclosures required by law.

Users cannot opt out of these communications, as we are obligated to send these communications to current customers, but they will be primarily service-oriented rather than promotional.

2.4 Marketing

We also use your email address to send you other types of communications that you can control, including newsletters and special promotions. These communications are to:

• provide you with information about services we offer that are similar to those that you have already enquired;

• provide you with updates on the services we offer, and promotional offers based on your activities when using Lama Services;

• Keep you informed about market events and news; and

• tell you about new products and features we are developing that you may find useful.

You can choose whether to receive some, all or none of these communications.

2.5 Service improvements and account management

We will use your information to deliver and improve Lama Services and manage your account, including:

• verifying your identity, including during account creation;

• validating the accuracy of information, and verifying it with third parties;

• resolving disputes, collecting fees and troubleshooting problems;

•allowing us to manage risk and to detect, prevent, and/or remediate fraud or other illegal or prohibited activities;

• detecting, preventing or remediating violations of our policies, Terms and Conditions or other user agreements;

• providing you with customer support services including notifying you of changes to our service, including any outages, and to send you service emails relating to your account and transactions on your account;

• improving our existing, and developing new, products, services, websites, and capabilities; and

• managing and protecting our information technology infrastructure as part of our efforts to keep our site safe and secure.

2.6 Third party information

We will combine third party information with information you give to us and that we collect about you. We will use all of this information:

• to help us better understand your financial circumstances and behavior so that we may make decisions about how we manage your Account;

• to process applications for products and services available through us including making decisions about whether to agree to approve any applications;

4 Sharing Information with third parties

4.1 To support our business and provide services to you

Just like most financial service providers, Lama works with third-party service providers who support our business operations, such as fraud prevention, customer service and technology services. We need to disclose user data to them from time to time so that the services can be performed. Our contracts dictate that these business partners only use your information in connection with the services they perform for us and not for their own benefit.

By accepting this Privacy Policy and maintaining an account with Lama, you expressly consent to the transfer of your data to those third parties for the purposes listed.

4.2 Banks

When withdrawing fiat currency, we will provide your information to the business partners who are contracted to Lama to complete this transaction, for example passing bank details to correspondent bank(s) or payment provider(s) involved in the transaction.

4.3 Anti-fraud, anti-money laundering, sanctions and risk management

To carry out the checks described above, we will provide your information to our third-party business partners who carry out these checks.

4.4 Where required by law

We may disclose necessary information to the police and other law enforcement agencies, security forces, competent governmental, intergovernmental or supranational bodies, competent agencies, departments or regulatory authorities, where we are legally compelled and/or permitted to do so.

5 Transferring data overseas

Lama is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.

The information that we collect from you may be transferred to, and stored in, a country outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for our suppliers. These staff may be engaged in the fulfilment of your request, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

By submitting your information and making use of Lama Services, you agree to such transfers, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

6 Data Retention Policy

We are obliged by financial markets laws to retain account data for 5 years after the closure of an account. In some circumstances, such as an enquiry from a law enforcement agency, we may have to hold it longer. We may also retain information if required to protect our interests, for example in case of litigation. When data falls outside those retention periods we will take steps to delete it from our system. Where you have asked us not to contact you, we will retain that information on a ‘do not contact’ list to reduce the risk of us contacting you in the future.

7 Systems Security Policy

Lama has security measures in place designed to prevent data loss, to preserve data integrity, and to control access to the data. Only authorised employees of Lama and our business partners processing data on our behalf have access to your personal data. All Lama employees who have access to your personal data are required to comply with our privacy policy. All business partners are requested by Lama to ensure that any of their employees who have access to your personal data have signed non- disclosure agreements. Contracts with business partners acting as data processors for Lama involving personal data require an adequate level of security and require that personal data is processed only as instructed by Lama.

To ensure data privacy, confidentiality and integrity, all information disclosed, shared, stored or used and any transactions performed by you through our website are encrypted.

To provide a secure environment for our website, we hold your data in secure data centres with high levels of physical and technical security, including using firewall systems, data encryption and anti- virus protection. We use security surveillance systems to detect and prevent illegitimate access to and activities on our systems.

8 Customers rights

You have the following rights:

To ask us to correct any information we hold about you if it is incorrect.

Whilst we endeavor at all times to keep your information accurate, we welcome your corrections. We may ask you for additional verification information if you are changing certain details such as your name or your address.

To ask us to erase your information if we no longer have any reason to hold it, also known as the ‘right to be forgotten’.

Our Data Retention Policy explains the circumstances when we can or are obliged to retain information, however outside of those periods we will delete your information in line with our data retention policy and on request. We will maintain a record that you made an erasure request to reduce the likelihood of us contacting you in the future but we will use that information for no other purpose.

To ask us to return to you information you provided to us, also known as ‘data portability’.

You can ask us to send you in electronic format the information you provided to us under our Terms and Conditions or under consent.

To ask us not to process your information where you previously gave consent or where we are exercising our legitimate interest

If you make a request for us to stop processing your information, we will investigate to see if there is a compelling reason for processing to continue and will discuss the conclusion of the investigation with you.

You cannot object to processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party. If you previously gave consent and we processed your data on the basis of that consent, you cannot object to that past processing, however you can ask us to stop processing it in the future.

To ask not to be subjected to automated decision making and profiling.

At Lama there are no circumstances when profiling or other automated decision making will have a legal impact on you without a person reviewing and making a decision on the result. If you feel you may have been unfairly impacted by profiling, our team can manually assess whether the decision is fair and discuss the situation with you.

To ask for a copy of the information we hold about you.

We will endeavour to respond to your request within 30 days, however at time of high demand we may need 90 days to compile a full response.

9 Contacting Us

9.1 Data Controller

The Data Controller is LamaTechnology FS UAB a company registered and incorporated in Lithuania with company number 305833209 and registered office at Mėsinių str. 5, LT-01130 Vilnius, Lithuania.

9.2 Contacting us with questions or requests

If you want to exercise your right to access your information or have any questions about this Privacy Policy, you can contact us at support@lamatechnology.com

9.3 Complaints to the Data Protection Officer

If you believe that we have breached a privacy law with which we should comply, please send an email to support@lamatechnology.com. We aim to respond in a reasonable time, normally within 30 days. Our Compliance team and Data Protection Officer will look after your complaint and will give you additional information about how it will be managed.

9.4 Complaints to the UK Information Commissioner

If your complaint is in relation to Data Protection related to our Electronic Money Services, you have the right to complain to the Dutch Data Protection Authority, if you believe we have not handled your request in an appropriate manner. For information on contacting the Data Protection Authority please see their website (https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us))

Complaints to the Lithuanian Data Protection Authority

If your complaint is in relation to Data Protection related to our Crypto Services, you have the right to complain to the State Data Protection Inspectorate (the “Inspectorate”), if you believe we have not handled your request in an appropriate manner. For information on contacting the Data Protection Authority please see their website (https://vdai.lrv.lt/en)

10 Changes to this privacy policy

We may amend this Privacy Policy at any time, as new features are added to Lama Services or as we incorporate suggestions from our customers. Any changes we may make will be posted on our website, so please check back frequently.

Your continued use of our website after a posting of a new version of this Policy will constitute your acceptance of, and agreement to, any changes. If you disagree with the terms of this Privacy Policy, you may close your account at any time.