Spondula Platform Terms of Use

Effective 11 June 2026

Part 1, Introduction, Definitions, Eligibility and Account Registration

1. Introduction

These Terms of Use (“Terms”) govern access to and use of the Spondula platform, website, applications, wallet infrastructure, S-Handle system and related services (collectively, the “Platform”).

By accessing or using the Platform, you agree to be bound by these Terms.

If you do not agree to these Terms, you must not access or use the Platform.

2. The Spondula Ecosystem

The Spondula ecosystem consists of various independent participants and service providers.

2.1 Spondula Ltd. Spondula Ltd provides:

user onboarding services;
identity verification services;
compliance support services;
monitoring services;
reporting services;
customer support services;
ecosystem administration services;
marketing and business development services.

2.2 Spondula Technology Ltd. Certain software, applications, intellectual property, wallet infrastructure, APIs, websites, databases, S-Handle systems and related technology used within the Platform are owned by or licensed from Spondula Technology Ltd.

2.3 Participating Prop Traders.Participating Proprietary Traders (“Prop Traders”) are independent participants operating within the ecosystem. Prop Traders may offer purchasing, selling, exchange, settlement or related transaction services to Users. Each Prop Trader acts solely for its own account and is independently responsible for its own activities.

2.4 Independent Participants. The Platform may also contain Operators, Merchants, Service Providers and other authorised participants operating independently within the ecosystem.

3. Important Transaction Disclosure

3.1 No Transaction Counterparty. Neither Spondula Ltd nor Spondula Technology Ltd:

buys assets;
sells assets;
exchanges assets;
redeems assets;
acts as a dealer;
acts as a broker;
acts as a market maker;
acts as an investment manager;
acts as a custodian;
acts as a transaction counterparty.

3.2 Transactions. Any purchase, sale, exchange, transfer, settlement or other transaction conducted through the ecosystem is conducted solely between the User and the relevant participating Prop Trader or other authorised participant.

3.3 No Principal Relationship. Neither Spondula Ltd nor Spondula Technology Ltd acts as principal in any transaction.

3.4 No Responsibility for Transactions. Spondula Ltd and Spondula Technology Ltd are not responsible for:

pricing;
liquidity;
execution;
settlement;
profitability;
availability of transactions offered by participants.

4. Eligibility

You may only use the Platform if:

(a) you are at least eighteen (18) years of age or the age of majority in your jurisdiction;
(b) you have legal capacity to enter into binding agreements;
(c) you are not subject to sanctions restrictions;
(d) your use of the Platform is lawful in your jurisdiction.

Spondula may restrict access in certain jurisdictions at its sole discretion.

5. Account Registration

To access certain Platform features you may be required to create an account.

You agree that all information provided during registration shall be:

accurate;
complete;
current;
not misleading.

You are responsible for maintaining the security of your account credentials.

You are responsible for all activity occurring under your account.

6. Identity Verification

Access to certain services may require identity verification.

Spondula Ltd may conduct or arrange:

identity verification;
document verification;
sanctions screening;
PEP screening;
compliance checks;
enhanced due diligence checks.

Additional information may be requested at any time.

Failure to provide requested information may result in restrictions or suspension.

7. Compliance Monitoring

Users acknowledge that Spondula Ltd may conduct monitoring activities for:

fraud prevention;
sanctions compliance;
regulatory compliance;
security purposes;
risk management.

Spondula reserves the right to suspend or restrict access where required for compliance, legal, operational or security reasons.

8. No Advice

Neither Spondula Ltd nor Spondula Technology Ltd provides:

investment advice;
financial advice;
legal advice;
tax advice;
accounting advice.

Any information made available through the Platform is provided for general informational purposes only.

Users remain solely responsible for their decisions and activities.

9. Limited Licence

Subject to these Terms, Users are granted a limited, non-exclusive, non-transferable and revocable licence to access and use the Platform.

This licence does not transfer ownership of any intellectual property.

10. Intellectual Property

All rights, title and interest in and to the Platform, including:

software;
source code;
S-Handle systems;
APIs;
databases;
branding;
documentation;
applications;

remain the property of Spondula Technology Ltd and/or its licensors.

No intellectual property rights are transferred to Users under these Terms.

11. Acceptance of Terms

By creating an account, accessing the Platform or continuing to use the Platform, you acknowledge that you have read, understood and agreed to these Terms.

Part 2, Platform Services, Wallets, S-Handles, Transactions and User Responsibilities

12. Platform Services

The Platform provides access to various technology, communication, wallet, payment, identity and ecosystem services.

Features may include:

Wallet functionality;
S-Handle functionality;
User directories;
Payment requests;
QR code functionality;
Merchant services;
Transaction interfaces;
Contact management;
Messaging functions;
Reporting tools;
Additional services introduced from time to time.

Not all services are available in all jurisdictions.

Spondula reserves the right to modify, suspend or discontinue any feature at any time.

13. Digital Wallets

The Platform may make wallet functionality available to Users.

Wallet functionality is intended to facilitate participation in the ecosystem.

Users acknowledge and agree that:

(a) wallet access may be restricted based on jurisdiction, risk profile or verification status;
(b) wallet functionality may be subject to transaction limits;
(c) wallet functionality may be suspended for compliance, legal, operational or security reasons;
(d) wallet access is provided on an “as available” basis.

Nothing in these Terms guarantees uninterrupted wallet availability.

14. S-Handles

The Platform may provide Users with a unique S-Handle identifier.

S-Handles are intended to simplify identification and interaction within the ecosystem.

Users acknowledge that:

(a) S-Handles are licensed, not owned;
(b) S-Handles remain part of the Platform;
(c) Spondula may suspend, revoke, modify or reassign S-Handles where necessary;
(d) S-Handles must not infringe the rights of third parties;
(e) S-Handles may not be used for unlawful, fraudulent or misleading purposes.

15. Participating Prop Traders

The Platform may provide access to services offered by participating Prop Traders.

Each Prop Trader:

(a) operates independently;
(b) acts solely for its own account;
(c) establishes its own pricing;
(d) manages its own inventory and liquidity;
(e) remains responsible for compliance with laws applicable to its activities.

Spondula does not control the commercial decisions of any Prop Trader.

16. Transactions

Users acknowledge and agree that:

(a) transactions are conducted directly between the User and the relevant participating Prop Trader or authorised participant;
(b) Spondula Ltd is not a party to any transaction;
(c) Spondula Technology Ltd is not a party to any transaction;
(d) neither Spondula Ltd nor Spondula Technology Ltd guarantees execution, pricing, availability or settlement of any transaction;
(e) transactions may be rejected, delayed or cancelled by the relevant participant.

17. User Responsibility for Transactions

Before entering into any transaction, Users remain solely responsible for:

reviewing transaction details;
reviewing pricing;
reviewing fees;
evaluating risks;
determining suitability.

Users must not rely upon Spondula to evaluate or recommend transactions.

18. Fees

Certain services may be subject to fees.

Applicable fees may include:

onboarding fees;
verification fees;
transaction fees;
removal fees;
conversion fees;
service fees;
merchant fees.

Fees may change from time to time.

Updated fees may be published through the Platform.

Users are responsible for reviewing applicable fees before using services.

19. Third-Party Service Providers

The Platform may utilise third-party service providers including:

identity verification providers;
compliance providers;
hosting providers;
communication providers;
infrastructure providers;
payment providers;
data providers.

Spondula is not responsible for interruptions caused by third-party providers.

20. User Conduct

Users agree not to:

(a) engage in fraud;
(b) engage in money laundering;
(c) engage in sanctions violations;
(d) engage in terrorist financing;
(e) provide false information;
(f) impersonate another person;
(g) interfere with Platform operations;
(h) attempt unauthorised access to systems;
(i) use the Platform for unlawful purposes.

21. Prohibited Activities

The Platform must not be used in connection with:

unlawful activities;
fraud schemes;
sanctions evasion;
deceptive marketing;
unauthorised financial services;
market manipulation;
illegal gambling;
prohibited goods or services;
any activity prohibited by applicable law.

22. Suspension of Services

Spondula may suspend, restrict or terminate access to any service where:

(a) compliance concerns arise;
(b) fraud is suspected;
(c) sanctions concerns arise;
(d) security concerns arise;
(e) legal obligations require action;
(f) operational risks arise.

Suspension may occur without prior notice where necessary.

23. Security

Users are responsible for:

maintaining password security;
protecting authentication devices;
maintaining accurate contact details;
promptly reporting unauthorised access.

Users remain responsible for activity occurring under their account unless otherwise required by law.

24. Records

Users acknowledge that Spondula may maintain records relating to:

account activity;
verification activity;
compliance activity;
transaction activity;
support requests;
security activity.

Such records may be retained as required by law, compliance obligations or operational requirements.

25. No Guarantee of Availability

The Platform is provided on an “as available” and “as is” basis.

Neither Spondula Ltd nor Spondula Technology Ltd guarantees:

uninterrupted availability;
continuous access;
error-free operation;
compatibility with all devices;
availability of any particular feature.

Temporary interruptions may occur due to maintenance, security events, upgrades or operational requirements.

Part 3, Disclaimers, Liability, Termination, Governing Law and General Provisions

26. Disclaimers

The Platform, services, content, software, wallet functionality, S-Handle system and related infrastructure are provided on an “as is” and “as available” basis.

To the fullest extent permitted by law, neither Spondula Ltd nor Spondula Technology Ltd makes any representation or warranty regarding:

availability;
performance;
reliability;
accuracy;
suitability;
uninterrupted operation;
error-free operation;
profitability;
transaction outcomes.

Users use the Platform at their own risk.

27. No Financial or Investment Services

Users acknowledge and agree that:

(a) neither Spondula Ltd nor Spondula Technology Ltd provides investment services;
(b) neither Spondula Ltd nor Spondula Technology Ltd provides brokerage services;
(c) neither Spondula Ltd nor Spondula Technology Ltd provides dealing services;
(d) neither Spondula Ltd nor Spondula Technology Ltd provides portfolio management services;
(e) neither Spondula Ltd nor Spondula Technology Ltd provides financial advice.

Nothing contained within the Platform constitutes investment advice, financial advice, legal advice or tax advice.

28. No Transaction Liability

Users acknowledge and agree that:

(a) transactions are conducted solely between Users and participating Prop Traders or other authorised participants;
(b) neither Spondula Ltd nor Spondula Technology Ltd acts as principal in any transaction;
(c) neither Spondula Ltd nor Spondula Technology Ltd guarantees any transaction;
(d) neither Spondula Ltd nor Spondula Technology Ltd assumes liability for transaction outcomes.

Any dispute relating to a transaction shall be between the User and the relevant participant unless otherwise required by law.

29. Limitation of Liability

To the fullest extent permitted by law, neither Spondula Ltd nor Spondula Technology Ltd shall be liable for:

(a) loss of profits;
(b) loss of business;
(c) loss of opportunity;
(d) loss of reputation;
(e) loss of data;
(f) loss arising from transaction activity;
(g) indirect losses;
(h) consequential losses;
(i) special damages.

30. Maximum Liability

To the fullest extent permitted by law, the aggregate liability of Spondula Ltd and Spondula Technology Ltd arising from or relating to the Platform shall not exceed:

(a) the total fees paid by the User to Spondula during the twelve (12) months preceding the event giving rise to the claim; or
(b) £100,

whichever is greater.

Nothing in these Terms excludes liability that cannot be excluded under applicable law.

31. User Indemnity

Users agree to indemnify and hold harmless:

Spondula Ltd;
Spondula Technology Ltd;
their directors;
officers;
employees;
contractors;
affiliates;

against losses, claims, liabilities, damages, penalties, fines, costs and expenses arising from:

(a) breach of these Terms;
(b) unlawful conduct;
(c) fraud;
(d) sanctions violations;
(e) misuse of the Platform;
(f) false information provided by the User.

32. Suspension and Termination

Spondula may suspend, restrict or terminate access to the Platform where:

(a) these Terms are breached;
(b) compliance concerns arise;
(c) fraud is suspected;
(d) sanctions concerns arise;
(e) security concerns arise;
(f) legal obligations require action;
(g) operational risks require action.

Suspension may occur without notice where reasonably necessary.

33. Effect of Termination

Upon termination:

(a) access to the Platform may cease immediately;
(b) S-Handles may be suspended or revoked;
(c) wallet functionality may be restricted;
(d) records may be retained in accordance with legal and compliance obligations;
(e) accrued rights and obligations shall survive termination.

34. Privacy and Data

Users acknowledge that personal data may be processed in accordance with the Spondula Privacy Policy.

Users consent to the collection, processing, storage and transfer of personal data as described in applicable privacy documentation.

Identity verification, compliance monitoring and fraud prevention activities may require the processing of personal information.

35. Compliance Disclosures

Users acknowledge and agree that:

(a) Spondula may perform identity verification;
(b) Spondula may perform sanctions screening;
(c) Spondula may perform compliance monitoring;
(d) Spondula may report suspicious activity where required by law;
(e) Spondula may cooperate with regulatory authorities, law enforcement agencies and courts where legally required.

36. Force Majeure

Neither Spondula Ltd nor Spondula Technology Ltd shall be liable for delays or failures caused by events beyond their reasonable control, including:

natural disasters;
war;
terrorism;
cyber attacks;
utility failures;
internet failures;
government action;
regulatory action;
labour disputes.

37. Amendments

Spondula may amend these Terms from time to time.

Material changes may be communicated through the Platform.

Continued use of the Platform following publication of revised Terms constitutes acceptance of the revised Terms.

38. Assignment

Users may not assign or transfer their rights or obligations under these Terms without prior written consent.

Spondula may assign, transfer or novate its rights and obligations to an affiliate, successor or purchaser of all or part of its business.

39. Severability

If any provision of these Terms is determined to be invalid, unlawful or unenforceable, the remaining provisions shall remain in full force and effect.

40. Entire Agreement

These Terms, together with any policies incorporated by reference, constitute the entire agreement between the User and Spondula regarding use of the Platform.

41. Governing Law

These Terms shall be governed by and construed in accordance with the laws of England and Wales.

42. Jurisdiction

The courts of England and Wales shall have exclusive jurisdiction over any dispute arising out of or relating to these Terms, except where mandatory consumer protection laws provide otherwise.

43. Contact Information

Questions regarding these Terms may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Important Summary

By using the Platform, the User acknowledges and agrees that:

Spondula Ltd provides onboarding, compliance support, monitoring, reporting, support and ecosystem administration services.
Spondula Technology Ltd owns or licenses the technology, software and intellectual property used by the Platform.
Participating Prop Traders and other authorised participants conduct transactions for their own account.
Neither Spondula Ltd nor Spondula Technology Ltd is a buyer, seller, broker, dealer, custodian, investment manager or transaction counterparty.
Transactions occur solely between the User and the relevant participating Prop Trader or authorised participant.

Spondula Privacy Policy

1. Introduction

This Privacy Policy explains how personal information is collected, used, stored, shared and protected within the Spondula ecosystem.

This Privacy Policy applies to users of the Spondula platform, website, applications and related services.

By accessing or using the Platform, you acknowledge that your personal information may be processed in accordance with this Privacy Policy.

2. Who We Are

Spondula Ltd. Spondula Ltd is responsible for:

User onboarding;
Identity verification;
Compliance monitoring;
Customer support;
Ecosystem administration;
Related operational services.

For the purposes of applicable data protection laws, Spondula Ltd will generally act as a Data Controller in relation to onboarding, compliance and support activities.

Spondula Technology Ltd. Spondula Technology Ltd owns and operates certain software, infrastructure, databases, APIs, websites, applications and technical systems used within the Platform.

Spondula Technology Ltd may process data in connection with operation, maintenance, security and development of the Platform.

3. Information We Collect

We may collect:

Identity Information

Full name
Date of birth
Nationality
Residential address
Government identification documents
Selfies and biometric verification data

Contact Information

Email address
Telephone number
Communication preferences

Account Information

Username
S-Handle
Account settings
Security credentials

Technical Information

IP address
Device identifiers
Browser information
Operating system information
Log files

Compliance Information

KYC records
AML records
Sanctions screening results
PEP screening results
Risk assessments

Transaction Information

Transaction references
Wallet identifiers
Activity records
Account usage data

4. How We Use Information

We may use information to:

Verify identity;
Perform KYC checks;
Conduct sanctions screening;
Conduct compliance monitoring;
Prevent fraud;
Provide customer support;
Improve Platform functionality;
Maintain security;
Meet legal obligations;
Respond to law enforcement requests;
Communicate with users.

5. Legal Basis for Processing

Where applicable, processing may be based upon:

Contractual necessity;
Legal obligations;
Legitimate interests;
User consent;
Establishment, exercise or defence of legal claims.

6. Sharing of Information

Information may be shared with:

Verification Providers. Identity verification providers.

Compliance Providers. AML, sanctions and risk screening providers.

Technology Providers. Hosting providers, cloud providers and infrastructure providers.

Professional Advisers. Lawyers, accountants and auditors.

Authorities. Regulators, courts, law enforcement agencies and governmental authorities where legally required.

7. Data Retention

Information may be retained:

For the duration of account activity;
For compliance purposes;
For fraud prevention purposes;
As required by law.

Retention periods may extend beyond account closure where legally required.

8. Security

Reasonable technical and organisational measures are used to protect personal information.

However, no system can guarantee absolute security.

Users remain responsible for maintaining account security.

9. International Transfers

Information may be processed in multiple jurisdictions.

Where required, appropriate safeguards shall be implemented to protect personal information.

10. User Rights

Subject to applicable law, users may have rights to:

Access information;
Correct information;
Delete information;
Restrict processing;
Object to processing;
Remove consent;
Request portability.

Certain rights may be restricted where legal or compliance obligations apply.

11. Cookies

The Platform may use cookies and similar technologies for:

Security;
Authentication;
Analytics;
Performance;
User preferences.

Further information may be provided in a separate Cookie Policy.

12. Changes to This Policy

This Privacy Policy may be updated from time to time.

Updated versions may be published on the Platform.

Continued use of the Platform constitutes acceptance of the revised Policy.

13. Contact

Privacy enquiries may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Spondula KYC, Identity Verification and Compliance Policy

1. Purpose

This KYC, Identity Verification and Compliance Policy (“Policy”) explains how identity verification, customer due diligence, sanctions screening, compliance monitoring and related compliance activities are conducted within the Spondula ecosystem.

This Policy forms part of the Spondula legal framework and should be read together with the Terms of Use and Privacy Policy.

2. Role of Spondula

Spondula Ltd provides identity verification, compliance support, monitoring and related services within the Spondula ecosystem.

Spondula Ltd does not act as:

a buyer;
a seller;
a broker;
a dealer;
a custodian;
an investment adviser;
a transaction counterparty.

Identity verification does not constitute approval, recommendation or endorsement of any transaction.

3. Verification Requirements

Users may be required to complete identity verification before accessing certain Platform features.

Verification requirements may vary depending upon:

jurisdiction;
risk profile;
account activity;
transaction activity;
legal requirements;
compliance requirements.

4. Information That May Be Requested

Users may be asked to provide:

Identity Information

Full legal name
Date of birth
Nationality
Residential address

Identification Documents

Passport
National identity card
Driving licence
Residence permit

Verification Information

Selfie verification
Liveness checks
Biometric verification
Additional verification data

Additional Information. Where required, users may be asked to provide:

Proof of address
Source of funds information
Source of wealth information
Employment information
Business information
Additional supporting documentation

5. Sanctions Screening

Users may be screened against:

International sanctions lists
Government sanctions databases
Watchlists
Restricted person databases

Users who appear on sanctions lists may be denied access to the Platform.

6. Politically Exposed Persons

Users may be screened to determine whether they are:

Politically Exposed Persons (PEPs);
Family members of PEPs;
Close associates of PEPs.

Additional due diligence may be required in such circumstances.

7. Ongoing Monitoring

Verification is not a one-time process.

Spondula may conduct ongoing monitoring including:

Account activity reviews;
Transaction monitoring;
Risk assessments;
Sanctions re-screening;
Identity refresh procedures.

Users may be asked to provide updated information at any time.

8. Enhanced Due Diligence

Enhanced Due Diligence (“EDD”) may be required where:

Higher risk indicators exist;
Unusual activity is identified;
Regulatory obligations require additional checks;
Additional verification is considered appropriate.

EDD may include requests for additional documentation or information.

9. Fraud Prevention

Spondula may implement fraud prevention measures including:

Device analysis;
Behavioural monitoring;
Risk scoring;
Identity verification tools;
Security reviews.

Accounts suspected of fraud may be suspended or terminated.

10. Failure to Complete Verification

Users who fail to complete required verification procedures may:

Have access restricted;
Have features disabled;
Be prevented from conducting certain activities;
Have accounts suspended or terminated.

11. Record Keeping

Verification records may be retained:

For legal purposes;
For compliance purposes;
For fraud prevention purposes;
As required by applicable laws and regulations.

Retention periods may continue after account closure.

12. Disclosure to Authorities

Information may be disclosed to:

Regulators;
Courts;
Law enforcement agencies;
Government authorities;

where required by law or legal process.

13. No Guarantee

Successful verification does not guarantee:

Account approval;
Transaction approval;
Access to particular services;
Continued access to the Platform.

Verification status may be reviewed at any time.

14. Changes to This Policy

Spondula may amend this Policy from time to time.

Updated versions may be published through the Platform.

Continued use of the Platform constitutes acceptance of revised versions.

15. Contact

Questions regarding this Policy may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Spondula Risk Disclosure Statement

Important Notice

This Risk Disclosure Statement (“Statement”) is provided to help Users understand certain risks associated with using the Spondula Platform and participating in the Spondula ecosystem.

This Statement does not describe every risk and should not be relied upon as a complete description of all risks.

Users should carefully consider their own circumstances and obtain independent professional advice where appropriate.

1. Role of Spondula

Users acknowledge and agree that:

Spondula Ltd. Spondula Ltd provides:

onboarding services;
identity verification services;
compliance support services;
monitoring services;
reporting services;
customer support services;
ecosystem administration services.

Spondula Technology Ltd. Spondula Technology Ltd owns or licenses certain software, applications, infrastructure, databases, APIs, websites and related technology used within the Platform.

Neither Spondula Entity. Neither Spondula Ltd nor Spondula Technology Ltd:

buys assets;
sells assets;
exchanges assets;
redeems assets;
acts as a broker;
acts as a dealer;
acts as a custodian;
acts as a market maker;
acts as an investment manager;
acts as a transaction counterparty.

2. Transaction Counterparty Risk

Transactions may be conducted with participating Prop Traders or other authorised participants.

Users acknowledge that:

transactions occur directly with the relevant participant;
transaction obligations are the responsibility of the relevant participant;
pricing is determined by the relevant participant;
liquidity is determined by the relevant participant.

Spondula does not guarantee the performance of any participant.

3. Market Risk

The value of assets, instruments, products or services available through ecosystem participants may change over time.

Users may experience gains or losses.

Past performance is not indicative of future results.

4. Liquidity Risk

Users may not always be able to:

buy;
sell;
transfer;
exchange;
settle;

assets at desired prices or within desired timeframes.

Liquidity may vary depending upon market conditions and participant activity.

5. Counterparty Risk

Users are exposed to the risk that a participant may:

delay performance;
fail to perform;
become insolvent;
cease operations;
become subject to regulatory action.

Spondula does not guarantee participant performance.

6. Technology Risk

Technology systems may experience:

outages;
delays;
interruptions;
software defects;
security incidents;
communication failures.

Access to services may be interrupted or unavailable from time to time.

7. Cybersecurity Risk

Users acknowledge the risk of:

hacking;
phishing;
malware;
account compromise;
unauthorised access.

Users remain responsible for maintaining the security of their credentials and devices.

8. Regulatory Risk

Laws and regulations may change.

Changes may affect:

Platform services;
participant activities;
availability of services;
access to accounts;
transaction functionality.

Spondula cannot guarantee continued availability of any service.

9. Compliance Risk

Users may be subject to:

identity verification;
sanctions screening;
compliance reviews;
account restrictions;
account suspension.

Access may be restricted where required by law, regulation or risk management requirements.

10. Third-Party Provider Risk

The Platform may rely upon third-party providers including:

identity verification providers;
hosting providers;
infrastructure providers;
communication providers;
compliance providers.

Service interruptions affecting such providers may impact Platform functionality.

11. Data Risk

Despite reasonable safeguards, risks associated with electronic storage and transmission of information cannot be eliminated entirely.

Users acknowledge the risk of unauthorised access, disclosure or loss of information.

12. No Guarantee of Profits

Neither Spondula Ltd nor Spondula Technology Ltd guarantees:

profits;
returns;
performance;
transaction outcomes;
participant performance.

Users assume responsibility for their own decisions.

13. No Advice

Nothing made available through the Platform constitutes:

investment advice;
financial advice;
legal advice;
tax advice;
accounting advice.

Users should seek independent professional advice where appropriate.

14. User Responsibility

Users are responsible for:

evaluating risks;
reviewing transaction details;
reviewing fees;
understanding participant terms;
determining suitability.

Users must not rely upon Spondula to assess the suitability of any transaction.

15. Acknowledgement

By using the Platform, Users acknowledge that:

(a) they have read and understood this Risk Disclosure Statement;
(b) they understand that transactions occur with participating Prop Traders or other authorised participants;
(c) neither Spondula Ltd nor Spondula Technology Ltd is a transaction counterparty;
(d) they accept the risks associated with use of the Platform and participation in the ecosystem.

Contact

Questions regarding this Statement may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Spondula Acceptable Use Policy

1. Purpose

This Acceptable Use Policy (“Policy”) establishes the rules governing use of the Spondula Platform and participation in the Spondula ecosystem.

This Policy applies to:

Users;
Prop Traders;
Operators;
Merchants;
Service Providers;
Business Clients;
Any person accessing the Platform.

This Policy forms part of the Spondula legal framework and should be read together with the Terms of Use, Privacy Policy, KYC Policy and Risk Disclosure Statement.

2. General Principles

All participants must:

act lawfully;
act honestly;
provide accurate information;
cooperate with compliance requirements;
respect the rights of other participants;
avoid conduct that may damage the ecosystem.

3. Prohibited Activities

The Platform may not be used for:

Criminal Activity

Fraud;
Theft;
Money laundering;
Terrorist financing;
Corruption;
Bribery;
Tax evasion;
Sanctions evasion;
Identity theft.

Deceptive Conduct

Misrepresentation;
False advertising;
Fake identities;
Impersonation;
Fraudulent schemes;
Deceptive business practices.

Technical Abuse

Hacking;
Malware distribution;
Denial of service attacks;
Unauthorised access;
System interference;
Reverse engineering.

Market Abuse

Manipulation;
Wash trading;
Artificial pricing;
Misleading activity;
Abusive trading practices.

4. Prohibited Products and Services

The Platform must not be used in connection with:

Illegal goods;
Counterfeit goods;
Stolen property;
Unlicensed financial services;
Illegal gambling;
Human trafficking;
Child exploitation;
Illegal drugs;
Prohibited weapons;
Terrorist organisations;
Sanctioned persons or entities.

Spondula may expand or modify this list from time to time.

5. Sanctions Compliance

Participants must not:

use the Platform while subject to sanctions;
transact on behalf of sanctioned persons;
facilitate sanctions evasion;
conceal beneficial ownership.

Spondula may suspend access immediately where sanctions concerns arise.

6. Account Security

Participants must:

maintain secure credentials;
protect authentication devices;
maintain accurate contact information;
notify Spondula of security incidents promptly.

Participants are responsible for activity occurring through their accounts unless otherwise required by law.

7. Identity Requirements

Participants must:

provide accurate identity information;
provide truthful documentation;
cooperate with verification requests;
provide additional information when reasonably requested.

False or misleading information may result in suspension or termination.

8. Prop Trader Requirements

Prop Traders participating in the ecosystem must:

operate lawfully;
maintain required licences and approvals;
maintain adequate records;
cooperate with compliance reviews;
provide required reporting information;
maintain appropriate internal controls.

Prop Traders remain solely responsible for their own regulatory obligations.

9. Operator Requirements

Operators participating in the ecosystem must:

comply with applicable laws;
maintain records;
cooperate with compliance requests;
provide accurate information;
maintain operational standards required by Spondula.

10. Merchant Requirements

Merchants participating in the ecosystem must:

operate legitimate businesses;
provide accurate business information;
comply with consumer protection requirements;
comply with applicable laws and regulations.

11. Communications

Participants must not use the Platform to:

harass others;
threaten others;
abuse others;
distribute unlawful content;
distribute misleading content;
distribute malicious software.

12. Monitoring

Spondula may monitor Platform activity for:

compliance purposes;
fraud prevention;
security purposes;
operational purposes;
legal purposes.

Monitoring may occur with or without notice.

13. Investigations

Spondula may investigate suspected violations of this Policy.

Participants agree to cooperate fully with investigations.

Failure to cooperate may result in suspension or termination.

14. Enforcement Actions

Where Spondula reasonably believes that a violation has occurred, Spondula may:

issue warnings;
request information;
restrict access;
suspend services;
terminate access;
report activity to authorities;
take other actions reasonably necessary to protect the ecosystem.

Such actions may occur without prior notice where necessary.

15. No Transaction Relationship

Nothing in this Policy shall be interpreted as creating a transaction relationship between:

Users and Spondula Ltd; or
Users and Spondula Technology Ltd.

Transactions are conducted solely between Users and participating Prop Traders or other authorised participants.

Neither Spondula Ltd nor Spondula Technology Ltd acts as a buyer, seller, broker, dealer, custodian or transaction counterparty.

16. Policy Changes

Spondula may amend this Policy from time to time.

Updated versions may be published through the Platform.

Continued use of the Platform constitutes acceptance of revised versions.

17. Contact

Questions regarding this Policy may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Acknowledgement

By using the Platform, Participants acknowledge and agree that:

they have read and understood this Policy;
they will comply with this Policy;
violations may result in suspension or termination;
Spondula may take enforcement action where necessary to protect the ecosystem.

Spondula Platform Terms of Use

Effective 11 June 2026

Part 1, Introduction, Definitions, Eligibility and Account Registration

1. Introduction

By accessing or using the Platform, you agree to be bound by these Terms.

If you do not agree to these Terms, you must not access or use the Platform.

2. The Spondula Ecosystem

The Spondula ecosystem consists of various independent participants and service providers.

2.1 Spondula Ltd. Spondula Ltd provides:

user onboarding services;
identity verification services;
compliance support services;
monitoring services;
reporting services;
customer support services;
ecosystem administration services;
marketing and business development services.

2.4 Independent Participants. The Platform may also contain Operators, Merchants, Service Providers and other authorised participants operating independently within the ecosystem.

3. Important Transaction Disclosure

3.1 No Transaction Counterparty. Neither Spondula Ltd nor Spondula Technology Ltd:

buys assets;
sells assets;
exchanges assets;
redeems assets;
acts as a dealer;
acts as a broker;
acts as a market maker;
acts as an investment manager;
acts as a custodian;
acts as a transaction counterparty.

3.3 No Principal Relationship. Neither Spondula Ltd nor Spondula Technology Ltd acts as principal in any transaction.

3.4 No Responsibility for Transactions. Spondula Ltd and Spondula Technology Ltd are not responsible for:

pricing;
liquidity;
execution;
settlement;
profitability;
availability of transactions offered by participants.

4. Eligibility

You may only use the Platform if:

(a) you are at least eighteen (18) years of age or the age of majority in your jurisdiction;
(b) you have legal capacity to enter into binding agreements;
(c) you are not subject to sanctions restrictions;
(d) your use of the Platform is lawful in your jurisdiction.

Spondula may restrict access in certain jurisdictions at its sole discretion.

5. Account Registration

To access certain Platform features you may be required to create an account.

You agree that all information provided during registration shall be:

accurate;
complete;
current;
not misleading.

You are responsible for maintaining the security of your account credentials.

You are responsible for all activity occurring under your account.

6. Identity Verification

Access to certain services may require identity verification.

Spondula Ltd may conduct or arrange:

identity verification;
document verification;
sanctions screening;
PEP screening;
compliance checks;
enhanced due diligence checks.

Additional information may be requested at any time.

Failure to provide requested information may result in restrictions or suspension.

7. Compliance Monitoring

Users acknowledge that Spondula Ltd may conduct monitoring activities for:

fraud prevention;
sanctions compliance;
regulatory compliance;
security purposes;
risk management.

Spondula reserves the right to suspend or restrict access where required for compliance, legal, operational or security reasons.

8. No Advice

Neither Spondula Ltd nor Spondula Technology Ltd provides:

investment advice;
financial advice;
legal advice;
tax advice;
accounting advice.

Any information made available through the Platform is provided for general informational purposes only.

Users remain solely responsible for their decisions and activities.

9. Limited Licence

Subject to these Terms, Users are granted a limited, non-exclusive, non-transferable and revocable licence to access and use the Platform.

This licence does not transfer ownership of any intellectual property.

10. Intellectual Property

All rights, title and interest in and to the Platform, including:

software;
source code;
S-Handle systems;
APIs;
databases;
branding;
documentation;
applications;

remain the property of Spondula Technology Ltd and/or its licensors.

No intellectual property rights are transferred to Users under these Terms.

11. Acceptance of Terms

By creating an account, accessing the Platform or continuing to use the Platform, you acknowledge that you have read, understood and agreed to these Terms.

Part 2, Platform Services, Wallets, S-Handles, Transactions and User Responsibilities

12. Platform Services

The Platform provides access to various technology, communication, wallet, payment, identity and ecosystem services.

Features may include:

Wallet functionality;
S-Handle functionality;
User directories;
Payment requests;
QR code functionality;
Merchant services;
Transaction interfaces;
Contact management;
Messaging functions;
Reporting tools;
Additional services introduced from time to time.

Not all services are available in all jurisdictions.

Spondula reserves the right to modify, suspend or discontinue any feature at any time.

13. Digital Wallets

The Platform may make wallet functionality available to Users.

Wallet functionality is intended to facilitate participation in the ecosystem.

Users acknowledge and agree that:

(a) wallet access may be restricted based on jurisdiction, risk profile or verification status;
(b) wallet functionality may be subject to transaction limits;
(c) wallet functionality may be suspended for compliance, legal, operational or security reasons;
(d) wallet access is provided on an “as available” basis.

Nothing in these Terms guarantees uninterrupted wallet availability.

14. S-Handles

The Platform may provide Users with a unique S-Handle identifier.

S-Handles are intended to simplify identification and interaction within the ecosystem.

Users acknowledge that:

(a) S-Handles are licensed, not owned;
(b) S-Handles remain part of the Platform;
(c) Spondula may suspend, revoke, modify or reassign S-Handles where necessary;
(d) S-Handles must not infringe the rights of third parties;
(e) S-Handles may not be used for unlawful, fraudulent or misleading purposes.

15. Participating Prop Traders

The Platform may provide access to services offered by participating Prop Traders.

Each Prop Trader:

(a) operates independently;
(b) acts solely for its own account;
(c) establishes its own pricing;
(d) manages its own inventory and liquidity;
(e) remains responsible for compliance with laws applicable to its activities.

Spondula does not control the commercial decisions of any Prop Trader.

16. Transactions

Users acknowledge and agree that:

(a) transactions are conducted directly between the User and the relevant participating Prop Trader or authorised participant;
(b) Spondula Ltd is not a party to any transaction;
(c) Spondula Technology Ltd is not a party to any transaction;
(d) neither Spondula Ltd nor Spondula Technology Ltd guarantees execution, pricing, availability or settlement of any transaction;
(e) transactions may be rejected, delayed or cancelled by the relevant participant.

17. User Responsibility for Transactions

Before entering into any transaction, Users remain solely responsible for:

reviewing transaction details;
reviewing pricing;
reviewing fees;
evaluating risks;
determining suitability.

Users must not rely upon Spondula to evaluate or recommend transactions.

18. Fees

Certain services may be subject to fees.

Applicable fees may include:

onboarding fees;
verification fees;
transaction fees;
removal fees;
conversion fees;
service fees;
merchant fees.

Fees may change from time to time.

Updated fees may be published through the Platform.

Users are responsible for reviewing applicable fees before using services.

19. Third-Party Service Providers

The Platform may utilise third-party service providers including:

identity verification providers;
compliance providers;
hosting providers;
communication providers;
infrastructure providers;
payment providers;
data providers.

Spondula is not responsible for interruptions caused by third-party providers.

20. User Conduct

Users agree not to:

(a) engage in fraud;
(b) engage in money laundering;
(c) engage in sanctions violations;
(d) engage in terrorist financing;
(e) provide false information;
(f) impersonate another person;
(g) interfere with Platform operations;
(h) attempt unauthorised access to systems;
(i) use the Platform for unlawful purposes.

21. Prohibited Activities

The Platform must not be used in connection with:

unlawful activities;
fraud schemes;
sanctions evasion;
deceptive marketing;
unauthorised financial services;
market manipulation;
illegal gambling;
prohibited goods or services;
any activity prohibited by applicable law.

22. Suspension of Services

Spondula may suspend, restrict or terminate access to any service where:

(a) compliance concerns arise;
(b) fraud is suspected;
(c) sanctions concerns arise;
(d) security concerns arise;
(e) legal obligations require action;
(f) operational risks arise.

Suspension may occur without prior notice where necessary.

23. Security

Users are responsible for:

maintaining password security;
protecting authentication devices;
maintaining accurate contact details;
promptly reporting unauthorised access.

Users remain responsible for activity occurring under their account unless otherwise required by law.

24. Records

Users acknowledge that Spondula may maintain records relating to:

account activity;
verification activity;
compliance activity;
transaction activity;
support requests;
security activity.

Such records may be retained as required by law, compliance obligations or operational requirements.

25. No Guarantee of Availability

The Platform is provided on an “as available” and “as is” basis.

Neither Spondula Ltd nor Spondula Technology Ltd guarantees:

uninterrupted availability;
continuous access;
error-free operation;
compatibility with all devices;
availability of any particular feature.

Temporary interruptions may occur due to maintenance, security events, upgrades or operational requirements.

Part 3, Disclaimers, Liability, Termination, Governing Law and General Provisions

26. Disclaimers

The Platform, services, content, software, wallet functionality, S-Handle system and related infrastructure are provided on an “as is” and “as available” basis.

To the fullest extent permitted by law, neither Spondula Ltd nor Spondula Technology Ltd makes any representation or warranty regarding:

availability;
performance;
reliability;
accuracy;
suitability;
uninterrupted operation;
error-free operation;
profitability;
transaction outcomes.

Users use the Platform at their own risk.

27. No Financial or Investment Services

Users acknowledge and agree that:

(a) neither Spondula Ltd nor Spondula Technology Ltd provides investment services;
(b) neither Spondula Ltd nor Spondula Technology Ltd provides brokerage services;
(c) neither Spondula Ltd nor Spondula Technology Ltd provides dealing services;
(d) neither Spondula Ltd nor Spondula Technology Ltd provides portfolio management services;
(e) neither Spondula Ltd nor Spondula Technology Ltd provides financial advice.

Nothing contained within the Platform constitutes investment advice, financial advice, legal advice or tax advice.

28. No Transaction Liability

Users acknowledge and agree that:

(a) transactions are conducted solely between Users and participating Prop Traders or other authorised participants;
(b) neither Spondula Ltd nor Spondula Technology Ltd acts as principal in any transaction;
(c) neither Spondula Ltd nor Spondula Technology Ltd guarantees any transaction;
(d) neither Spondula Ltd nor Spondula Technology Ltd assumes liability for transaction outcomes.

Any dispute relating to a transaction shall be between the User and the relevant participant unless otherwise required by law.

29. Limitation of Liability

To the fullest extent permitted by law, neither Spondula Ltd nor Spondula Technology Ltd shall be liable for:

(a) loss of profits;
(b) loss of business;
(c) loss of opportunity;
(d) loss of reputation;
(e) loss of data;
(f) loss arising from transaction activity;
(g) indirect losses;
(h) consequential losses;
(i) special damages.

30. Maximum Liability

To the fullest extent permitted by law, the aggregate liability of Spondula Ltd and Spondula Technology Ltd arising from or relating to the Platform shall not exceed:

(a) the total fees paid by the User to Spondula during the twelve (12) months preceding the event giving rise to the claim; or
(b) £100,

whichever is greater.

Nothing in these Terms excludes liability that cannot be excluded under applicable law.

31. User Indemnity

Users agree to indemnify and hold harmless:

Spondula Ltd;
Spondula Technology Ltd;
their directors;
officers;
employees;
contractors;
affiliates;

against losses, claims, liabilities, damages, penalties, fines, costs and expenses arising from:

(a) breach of these Terms;
(b) unlawful conduct;
(c) fraud;
(d) sanctions violations;
(e) misuse of the Platform;
(f) false information provided by the User.

32. Suspension and Termination

Spondula may suspend, restrict or terminate access to the Platform where:

(a) these Terms are breached;
(b) compliance concerns arise;
(c) fraud is suspected;
(d) sanctions concerns arise;
(e) security concerns arise;
(f) legal obligations require action;
(g) operational risks require action.

Suspension may occur without notice where reasonably necessary.

33. Effect of Termination

Upon termination:

(a) access to the Platform may cease immediately;
(b) S-Handles may be suspended or revoked;
(c) wallet functionality may be restricted;
(d) records may be retained in accordance with legal and compliance obligations;
(e) accrued rights and obligations shall survive termination.

34. Privacy and Data

Users acknowledge that personal data may be processed in accordance with the Spondula Privacy Policy.

Users consent to the collection, processing, storage and transfer of personal data as described in applicable privacy documentation.

Identity verification, compliance monitoring and fraud prevention activities may require the processing of personal information.

35. Compliance Disclosures

Users acknowledge and agree that:

(a) Spondula may perform identity verification;
(b) Spondula may perform sanctions screening;
(c) Spondula may perform compliance monitoring;
(d) Spondula may report suspicious activity where required by law;
(e) Spondula may cooperate with regulatory authorities, law enforcement agencies and courts where legally required.

36. Force Majeure

Neither Spondula Ltd nor Spondula Technology Ltd shall be liable for delays or failures caused by events beyond their reasonable control, including:

natural disasters;
war;
terrorism;
cyber attacks;
utility failures;
internet failures;
government action;
regulatory action;
labour disputes.

37. Amendments

Spondula may amend these Terms from time to time.

Material changes may be communicated through the Platform.

Continued use of the Platform following publication of revised Terms constitutes acceptance of the revised Terms.

38. Assignment

Users may not assign or transfer their rights or obligations under these Terms without prior written consent.

Spondula may assign, transfer or novate its rights and obligations to an affiliate, successor or purchaser of all or part of its business.

39. Severability

If any provision of these Terms is determined to be invalid, unlawful or unenforceable, the remaining provisions shall remain in full force and effect.

40. Entire Agreement

These Terms, together with any policies incorporated by reference, constitute the entire agreement between the User and Spondula regarding use of the Platform.

41. Governing Law

These Terms shall be governed by and construed in accordance with the laws of England and Wales.

42. Jurisdiction

The courts of England and Wales shall have exclusive jurisdiction over any dispute arising out of or relating to these Terms, except where mandatory consumer protection laws provide otherwise.

43. Contact Information

Questions regarding these Terms may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Important Summary

By using the Platform, the User acknowledges and agrees that:

Spondula Ltd provides onboarding, compliance support, monitoring, reporting, support and ecosystem administration services.
Spondula Technology Ltd owns or licenses the technology, software and intellectual property used by the Platform.
Participating Prop Traders and other authorised participants conduct transactions for their own account.
Neither Spondula Ltd nor Spondula Technology Ltd is a buyer, seller, broker, dealer, custodian, investment manager or transaction counterparty.
Transactions occur solely between the User and the relevant participating Prop Trader or authorised participant.

Spondula Privacy Policy

1. Introduction

This Privacy Policy explains how personal information is collected, used, stored, shared and protected within the Spondula ecosystem.

This Privacy Policy applies to users of the Spondula platform, website, applications and related services.

By accessing or using the Platform, you acknowledge that your personal information may be processed in accordance with this Privacy Policy.

2. Who We Are

Spondula Ltd. Spondula Ltd is responsible for:

User onboarding;
Identity verification;
Compliance monitoring;
Customer support;
Ecosystem administration;
Related operational services.

For the purposes of applicable data protection laws, Spondula Ltd will generally act as a Data Controller in relation to onboarding, compliance and support activities.

Spondula Technology Ltd. Spondula Technology Ltd owns and operates certain software, infrastructure, databases, APIs, websites, applications and technical systems used within the Platform.

Spondula Technology Ltd may process data in connection with operation, maintenance, security and development of the Platform.

3. Information We Collect

We may collect:

Identity Information

Full name
Date of birth
Nationality
Residential address
Government identification documents
Selfies and biometric verification data

Contact Information

Email address
Telephone number
Communication preferences

Account Information

Username
S-Handle
Account settings
Security credentials

Technical Information

IP address
Device identifiers
Browser information
Operating system information
Log files

Compliance Information

KYC records
AML records
Sanctions screening results
PEP screening results
Risk assessments

Transaction Information

Transaction references
Wallet identifiers
Activity records
Account usage data

4. How We Use Information

We may use information to:

Verify identity;
Perform KYC checks;
Conduct sanctions screening;
Conduct compliance monitoring;
Prevent fraud;
Provide customer support;
Improve Platform functionality;
Maintain security;
Meet legal obligations;
Respond to law enforcement requests;
Communicate with users.

5. Legal Basis for Processing

Where applicable, processing may be based upon:

Contractual necessity;
Legal obligations;
Legitimate interests;
User consent;
Establishment, exercise or defence of legal claims.

6. Sharing of Information

Information may be shared with:

Verification Providers. Identity verification providers.

Compliance Providers. AML, sanctions and risk screening providers.

Technology Providers. Hosting providers, cloud providers and infrastructure providers.

Professional Advisers. Lawyers, accountants and auditors.

Authorities. Regulators, courts, law enforcement agencies and governmental authorities where legally required.

7. Data Retention

Information may be retained:

For the duration of account activity;
For compliance purposes;
For fraud prevention purposes;
As required by law.

Retention periods may extend beyond account closure where legally required.

8. Security

Reasonable technical and organisational measures are used to protect personal information.

However, no system can guarantee absolute security.

Users remain responsible for maintaining account security.

9. International Transfers

Information may be processed in multiple jurisdictions.

Where required, appropriate safeguards shall be implemented to protect personal information.

10. User Rights

Subject to applicable law, users may have rights to:

Access information;
Correct information;
Delete information;
Restrict processing;
Object to processing;
Remove consent;
Request portability.

Certain rights may be restricted where legal or compliance obligations apply.

11. Cookies

The Platform may use cookies and similar technologies for:

Security;
Authentication;
Analytics;
Performance;
User preferences.

Further information may be provided in a separate Cookie Policy.

12. Changes to This Policy

This Privacy Policy may be updated from time to time.

Updated versions may be published on the Platform.

Continued use of the Platform constitutes acceptance of the revised Policy.

13. Contact

Privacy enquiries may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Spondula KYC, Identity Verification and Compliance Policy

1. Purpose

This Policy forms part of the Spondula legal framework and should be read together with the Terms of Use and Privacy Policy.

2. Role of Spondula

Spondula Ltd provides identity verification, compliance support, monitoring and related services within the Spondula ecosystem.

Spondula Ltd does not act as:

a buyer;
a seller;
a broker;
a dealer;
a custodian;
an investment adviser;
a transaction counterparty.

Identity verification does not constitute approval, recommendation or endorsement of any transaction.

3. Verification Requirements

Users may be required to complete identity verification before accessing certain Platform features.

Verification requirements may vary depending upon:

jurisdiction;
risk profile;
account activity;
transaction activity;
legal requirements;
compliance requirements.

4. Information That May Be Requested

Users may be asked to provide:

Identity Information

Full legal name
Date of birth
Nationality
Residential address

Identification Documents

Passport
National identity card
Driving licence
Residence permit

Verification Information

Selfie verification
Liveness checks
Biometric verification
Additional verification data

Additional Information. Where required, users may be asked to provide:

Proof of address
Source of funds information
Source of wealth information
Employment information
Business information
Additional supporting documentation

5. Sanctions Screening

Users may be screened against:

International sanctions lists
Government sanctions databases
Watchlists
Restricted person databases

Users who appear on sanctions lists may be denied access to the Platform.

6. Politically Exposed Persons

Users may be screened to determine whether they are:

Politically Exposed Persons (PEPs);
Family members of PEPs;
Close associates of PEPs.

Additional due diligence may be required in such circumstances.

7. Ongoing Monitoring

Verification is not a one-time process.

Spondula may conduct ongoing monitoring including:

Account activity reviews;
Transaction monitoring;
Risk assessments;
Sanctions re-screening;
Identity refresh procedures.

Users may be asked to provide updated information at any time.

8. Enhanced Due Diligence

Enhanced Due Diligence (“EDD”) may be required where:

Higher risk indicators exist;
Unusual activity is identified;
Regulatory obligations require additional checks;
Additional verification is considered appropriate.

EDD may include requests for additional documentation or information.

9. Fraud Prevention

Spondula may implement fraud prevention measures including:

Device analysis;
Behavioural monitoring;
Risk scoring;
Identity verification tools;
Security reviews.

Accounts suspected of fraud may be suspended or terminated.

10. Failure to Complete Verification

Users who fail to complete required verification procedures may:

Have access restricted;
Have features disabled;
Be prevented from conducting certain activities;
Have accounts suspended or terminated.

11. Record Keeping

Verification records may be retained:

For legal purposes;
For compliance purposes;
For fraud prevention purposes;
As required by applicable laws and regulations.

Retention periods may continue after account closure.

12. Disclosure to Authorities

Information may be disclosed to:

Regulators;
Courts;
Law enforcement agencies;
Government authorities;

where required by law or legal process.

13. No Guarantee

Successful verification does not guarantee:

Account approval;
Transaction approval;
Access to particular services;
Continued access to the Platform.

Verification status may be reviewed at any time.

14. Changes to This Policy

Spondula may amend this Policy from time to time.

Updated versions may be published through the Platform.

Continued use of the Platform constitutes acceptance of revised versions.

15. Contact

Questions regarding this Policy may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Spondula Risk Disclosure Statement

Important Notice

This Risk Disclosure Statement (“Statement”) is provided to help Users understand certain risks associated with using the Spondula Platform and participating in the Spondula ecosystem.

This Statement does not describe every risk and should not be relied upon as a complete description of all risks.

Users should carefully consider their own circumstances and obtain independent professional advice where appropriate.

1. Role of Spondula

Users acknowledge and agree that:

Spondula Ltd. Spondula Ltd provides:

onboarding services;
identity verification services;
compliance support services;
monitoring services;
reporting services;
customer support services;
ecosystem administration services.

Spondula Technology Ltd. Spondula Technology Ltd owns or licenses certain software, applications, infrastructure, databases, APIs, websites and related technology used within the Platform.

Neither Spondula Entity. Neither Spondula Ltd nor Spondula Technology Ltd:

buys assets;
sells assets;
exchanges assets;
redeems assets;
acts as a broker;
acts as a dealer;
acts as a custodian;
acts as a market maker;
acts as an investment manager;
acts as a transaction counterparty.

2. Transaction Counterparty Risk

Transactions may be conducted with participating Prop Traders or other authorised participants.

Users acknowledge that:

transactions occur directly with the relevant participant;
transaction obligations are the responsibility of the relevant participant;
pricing is determined by the relevant participant;
liquidity is determined by the relevant participant.

Spondula does not guarantee the performance of any participant.

3. Market Risk

The value of assets, instruments, products or services available through ecosystem participants may change over time.

Users may experience gains or losses.

Past performance is not indicative of future results.

4. Liquidity Risk

Users may not always be able to:

buy;
sell;
transfer;
exchange;
settle;

assets at desired prices or within desired timeframes.

Liquidity may vary depending upon market conditions and participant activity.

5. Counterparty Risk

Users are exposed to the risk that a participant may:

delay performance;
fail to perform;
become insolvent;
cease operations;
become subject to regulatory action.

Spondula does not guarantee participant performance.

6. Technology Risk

Technology systems may experience:

outages;
delays;
interruptions;
software defects;
security incidents;
communication failures.

Access to services may be interrupted or unavailable from time to time.

7. Cybersecurity Risk

Users acknowledge the risk of:

hacking;
phishing;
malware;
account compromise;
unauthorised access.

Users remain responsible for maintaining the security of their credentials and devices.

8. Regulatory Risk

Laws and regulations may change.

Changes may affect:

Platform services;
participant activities;
availability of services;
access to accounts;
transaction functionality.

Spondula cannot guarantee continued availability of any service.

9. Compliance Risk

Users may be subject to:

identity verification;
sanctions screening;
compliance reviews;
account restrictions;
account suspension.

Access may be restricted where required by law, regulation or risk management requirements.

10. Third-Party Provider Risk

The Platform may rely upon third-party providers including:

identity verification providers;
hosting providers;
infrastructure providers;
communication providers;
compliance providers.

Service interruptions affecting such providers may impact Platform functionality.

11. Data Risk

Despite reasonable safeguards, risks associated with electronic storage and transmission of information cannot be eliminated entirely.

Users acknowledge the risk of unauthorised access, disclosure or loss of information.

12. No Guarantee of Profits

Neither Spondula Ltd nor Spondula Technology Ltd guarantees:

profits;
returns;
performance;
transaction outcomes;
participant performance.

Users assume responsibility for their own decisions.

13. No Advice

Nothing made available through the Platform constitutes:

investment advice;
financial advice;
legal advice;
tax advice;
accounting advice.

Users should seek independent professional advice where appropriate.

14. User Responsibility

Users are responsible for:

evaluating risks;
reviewing transaction details;
reviewing fees;
understanding participant terms;
determining suitability.

Users must not rely upon Spondula to assess the suitability of any transaction.

15. Acknowledgement

By using the Platform, Users acknowledge that:

(a) they have read and understood this Risk Disclosure Statement;
(b) they understand that transactions occur with participating Prop Traders or other authorised participants;
(c) neither Spondula Ltd nor Spondula Technology Ltd is a transaction counterparty;
(d) they accept the risks associated with use of the Platform and participation in the ecosystem.

Contact

Questions regarding this Statement may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Spondula Acceptable Use Policy

1. Purpose

This Acceptable Use Policy (“Policy”) establishes the rules governing use of the Spondula Platform and participation in the Spondula ecosystem.

This Policy applies to:

Users;
Prop Traders;
Operators;
Merchants;
Service Providers;
Business Clients;
Any person accessing the Platform.

This Policy forms part of the Spondula legal framework and should be read together with the Terms of Use, Privacy Policy, KYC Policy and Risk Disclosure Statement.

2. General Principles

All participants must:

act lawfully;
act honestly;
provide accurate information;
cooperate with compliance requirements;
respect the rights of other participants;
avoid conduct that may damage the ecosystem.

3. Prohibited Activities

The Platform may not be used for:

Criminal Activity

Fraud;
Theft;
Money laundering;
Terrorist financing;
Corruption;
Bribery;
Tax evasion;
Sanctions evasion;
Identity theft.

Deceptive Conduct

Misrepresentation;
False advertising;
Fake identities;
Impersonation;
Fraudulent schemes;
Deceptive business practices.

Technical Abuse

Hacking;
Malware distribution;
Denial of service attacks;
Unauthorised access;
System interference;
Reverse engineering.

Market Abuse

Manipulation;
Wash trading;
Artificial pricing;
Misleading activity;
Abusive trading practices.

4. Prohibited Products and Services

The Platform must not be used in connection with:

Illegal goods;
Counterfeit goods;
Stolen property;
Unlicensed financial services;
Illegal gambling;
Human trafficking;
Child exploitation;
Illegal drugs;
Prohibited weapons;
Terrorist organisations;
Sanctioned persons or entities.

Spondula may expand or modify this list from time to time.

5. Sanctions Compliance

Participants must not:

use the Platform while subject to sanctions;
transact on behalf of sanctioned persons;
facilitate sanctions evasion;
conceal beneficial ownership.

Spondula may suspend access immediately where sanctions concerns arise.

6. Account Security

Participants must:

maintain secure credentials;
protect authentication devices;
maintain accurate contact information;
notify Spondula of security incidents promptly.

Participants are responsible for activity occurring through their accounts unless otherwise required by law.

7. Identity Requirements

Participants must:

provide accurate identity information;
provide truthful documentation;
cooperate with verification requests;
provide additional information when reasonably requested.

False or misleading information may result in suspension or termination.

8. Prop Trader Requirements

Prop Traders participating in the ecosystem must:

operate lawfully;
maintain required licences and approvals;
maintain adequate records;
cooperate with compliance reviews;
provide required reporting information;
maintain appropriate internal controls.

Prop Traders remain solely responsible for their own regulatory obligations.

9. Operator Requirements

Operators participating in the ecosystem must:

comply with applicable laws;
maintain records;
cooperate with compliance requests;
provide accurate information;
maintain operational standards required by Spondula.

10. Merchant Requirements

Merchants participating in the ecosystem must:

operate legitimate businesses;
provide accurate business information;
comply with consumer protection requirements;
comply with applicable laws and regulations.

11. Communications

Participants must not use the Platform to:

harass others;
threaten others;
abuse others;
distribute unlawful content;
distribute misleading content;
distribute malicious software.

12. Monitoring

Spondula may monitor Platform activity for:

compliance purposes;
fraud prevention;
security purposes;
operational purposes;
legal purposes.

Monitoring may occur with or without notice.

13. Investigations

Spondula may investigate suspected violations of this Policy.

Participants agree to cooperate fully with investigations.

Failure to cooperate may result in suspension or termination.

14. Enforcement Actions

Where Spondula reasonably believes that a violation has occurred, Spondula may:

issue warnings;
request information;
restrict access;
suspend services;
terminate access;
report activity to authorities;
take other actions reasonably necessary to protect the ecosystem.

Such actions may occur without prior notice where necessary.

15. No Transaction Relationship

Nothing in this Policy shall be interpreted as creating a transaction relationship between:

Users and Spondula Ltd; or
Users and Spondula Technology Ltd.

Transactions are conducted solely between Users and participating Prop Traders or other authorised participants.

Neither Spondula Ltd nor Spondula Technology Ltd acts as a buyer, seller, broker, dealer, custodian or transaction counterparty.

16. Policy Changes

Spondula may amend this Policy from time to time.

Updated versions may be published through the Platform.

Continued use of the Platform constitutes acceptance of revised versions.

17. Contact

Questions regarding this Policy may be directed to:

SPONDULA LTD
Email: [email protected]
Website: https://spondula.com

Acknowledgement

By using the Platform, Participants acknowledge and agree that:

they have read and understood this Policy;
they will comply with this Policy;
violations may result in suspension or termination;
Spondula may take enforcement action where necessary to protect the ecosystem.

The fine print.

Spondula Platform Terms of Use

Part 1, Introduction, Definitions, Eligibility and Account Registration

1. Introduction

2. The Spondula Ecosystem

3. Important Transaction Disclosure

4. Eligibility

5. Account Registration

6. Identity Verification

7. Compliance Monitoring

8. No Advice

9. Limited Licence

10. Intellectual Property

11. Acceptance of Terms

Part 2, Platform Services, Wallets, S-Handles, Transactions and User Responsibilities

12. Platform Services

13. Digital Wallets

14. S-Handles

15. Participating Prop Traders

16. Transactions

17. User Responsibility for Transactions

18. Fees

19. Third-Party Service Providers

20. User Conduct

21. Prohibited Activities

22. Suspension of Services

23. Security

24. Records

25. No Guarantee of Availability

Part 3, Disclaimers, Liability, Termination, Governing Law and General Provisions

26. Disclaimers

27. No Financial or Investment Services

28. No Transaction Liability

29. Limitation of Liability

30. Maximum Liability

31. User Indemnity

32. Suspension and Termination

33. Effect of Termination

34. Privacy and Data

35. Compliance Disclosures

36. Force Majeure

37. Amendments

38. Assignment

39. Severability

40. Entire Agreement

41. Governing Law

42. Jurisdiction

43. Contact Information

Important Summary

Spondula Privacy Policy

1. Introduction

2. Who We Are

3. Information We Collect

4. How We Use Information

5. Legal Basis for Processing

6. Sharing of Information

7. Data Retention

8. Security

9. International Transfers

10. User Rights

11. Cookies

12. Changes to This Policy

13. Contact

Spondula KYC, Identity Verification and Compliance Policy

1. Purpose

2. Role of Spondula

3. Verification Requirements

4. Information That May Be Requested

5. Sanctions Screening

6. Politically Exposed Persons

7. Ongoing Monitoring

8. Enhanced Due Diligence

9. Fraud Prevention

10. Failure to Complete Verification

11. Record Keeping

12. Disclosure to Authorities

13. No Guarantee

14. Changes to This Policy

15. Contact

Spondula Risk Disclosure Statement