1. Acceptance of Terms

   By accessing or using this platform (“the Platform”), you agree to comply with these Terms and Conditions (“Terms”). If you do not agree, you must not use the Platform.

2. Services

   The Platform provides access to online trading and digital asset exchange services. The Company does not provide investment advice or portfolio management. All trading activities are executed at the user’s own risk and discretion.

3. Eligibility

   Users must be at least 18 years old and legally capable of entering binding agreements. By registering, you confirm that all information provided is accurate, complete, and up-to-date.

4. Account Registration and Verification

   Users must complete registration and comply with KYC/AML verification procedures. The Company reserves the right to deny, suspend, or terminate accounts failing compliance checks or suspected of illicit activity.

5. Risk Acknowledgment

   Trading involves substantial risk. Prices may fluctuate significantly, and users may lose part or all of their invested capital. The Company is not responsible for losses caused by market movements, system errors, or user actions.

6. Use of the Platform

   Users agree not to:

   • Use the Platform for illegal or fraudulent purposes;
   • Manipulate prices or conduct market abuse;
   • Engage in money laundering or terrorist financing;
   • Violate intellectual property rights or misuse Company software.

7. Limitation of Liability

   The Platform and its services are provided “as is” and “as available.” The Company disclaims all warranties, express or implied. In no event shall the Company be liable for indirect, incidental, or consequential damages arising from use or inability to use the Platform.

8. Account Suspension or Termination

   The Company may, without prior notice, suspend or terminate a user account for violations of these Terms, regulatory requirements, or suspected illegal activity.

9. Intellectual Property

   All Platform content, design, logos, and software are the exclusive property of IT Technology and Partner LLC. Users are granted a limited, revocable license for personal, non-commercial use only.

10. Governing Law and Jurisdiction

    These Terms are governed by the laws of Georgia. Any dispute shall be resolved exclusively in the courts of Tbilisi, Georgia.

11. Amendments

    The Company reserves the right to modify or update these Terms at any time. Changes take effect immediately upon publication. Continued use of the Platform constitutes acceptance of the revised Terms.

Risk Disclosure Statement

Company: IT Technology and Partner LLC

Legal Address: Nino and Ilia Nakashidze Street No.1, Building No.3, Apt.3, Tbilisi, Georgia

Email: compliance@gnapay.com

Effective Date: 10/16/2025

1. Purpose of This Document

   This Risk Disclosure Statement informs users (“Clients”) about potential risks associated with trading activities offered by the Platform operated by IT Technology and Partner LLC (“the Company”).

2. General Risk Warning

   Trading in financial instruments and digital assets involves a high level of risk and may not be suitable for all investors. The value of assets can fluctuate sharply, and you may lose part or all of your invested capital.

3. Market Risk

   Market prices can change rapidly due to volatility, economic events, or geopolitical developments. Past performance is not indicative of future results.

4. Liquidity Risk

   Certain assets may have limited liquidity, making it difficult to buy or sell positions at desired prices or times.

5. Leverage Risk

   Leverage can magnify both profits and losses. Even a small price movement can result in substantial losses relative to the invested margin.

6. Operational and Technical Risks

   Internet connectivity, hardware or software failures, or cyberattacks may delay or prevent order execution. The Company is not responsible for technical issues beyond its control.

7. Legal and Regulatory Risks

   Regulatory changes may affect the legality or taxation of trading activities. Clients must ensure compliance with all applicable local laws in their jurisdiction.

8. No Guarantee of Profit

   The Company does not guarantee any profit, income, or performance outcome. All trading decisions are made solely by the Client.

9. Client Responsibility

   Clients should trade only with funds they can afford to lose and are encouraged to seek independent financial and legal advice before trading.

10. Acknowledgment

    By using the Platform, the Client confirms they have read, understood, and accepted the risks outlined in this statement.

This document is provided for informational purposes and does not constitute legal or investment advice.