Effective Date: April 1, 2025

Last Updated: March 1, 2026

1.1. Introduction to the Zelencio Ecosystem

Zelencio (hereinafter referred to as “the Platform,” “the Company,” “Zelencio,” “we,” “us,” or “our”) provides a proprietary digital asset management environment designed to facilitate the storage, transfer, swap, and peer-to-peer exchange of virtual currencies and digital assets. Zelencio operates primarily as a high-performance software interface and technological infrastructure provider, enabling users to interact with decentralized blockchain networks and internal ledger systems with efficiency and security.

1.2. Binding Contractual Agreement

By accessing the Zelencio mobile application, creating an account, or utilizing any feature within the Zelencio infrastructure, you hereby enter into a legally binding contract with Zelencio. You acknowledge that you have read, understood, and voluntarily agreed to be bound by every article and sub-clause contained within these Terms of Service, as well as our Privacy Policy and AML/KYC Compliance Framework. If you do not agree to these terms in their entirety, you are strictly prohibited from accessing the platform and must immediately cease all use of Zelencio services.

1.3. Scope of Services

The Zelencio platform offers a comprehensive suite of digital asset tools, which include but are not limited to:

• Virtual Asset Wallets: Secure hosting of unique blockchain addresses for the receipt and storage of supported cryptocurrencies.

• Asset Swaps and Conversions: Algorithmic systems for the real-time exchange of one digital asset for another.

• Internal Transfer Protocols: Off-chain asset movements between verified users via Zelencio Identity Numbers (ZIN) and encrypted Zelencio Codes (Vouchers).

• P2P/C2C Marketplace: A managed venue for the direct exchange of digital assets between users, featuring a human-moderated Escrow Hub and multi-role participation (Buyer, Seller, and Middle Man).

• Automation Tools: Sophisticated trading logic, including the "Swap on Market Drop" (SOMD) feature, enabling users to set automated execution parameters based on real-time market data.

1.4. Jurisdictional Compliance and Local Law

Zelencio is a global technological provider. However, the availability of certain features (including Fiat-to-Crypto gateways and P2P trading) is subject to regional availability and the regulatory landscape of the user's specific jurisdiction.

• User Responsibility: You are solely responsible for ensuring that your use of Zelencio complies with all local, state, and national laws in your place of residence.

• Legal Restrictions: You represent and warrant that you are not a citizen or resident of a prohibited jurisdiction (including but not limited to the USA, UK, or EU) where specific financial licenses are required and not currently held by the platform.

• No Regulatory Guarantee: Zelencio makes no claim to be a licensed bank or traditional financial institution. Our services are provided as a Virtual Asset Service Provider (VASP) under a "Technology First" framework.

1.5. Modification of Terms

Zelencio reserves the unilateral right to amend, update, or replace any portion of these Terms at its sole discretion and without prior individual notice.

• Notification: Any changes will be posted on the Zelencio website and within the mobile application. The "Last Updated" date at the top of this document will reflect the most recent changes.

• Continuous Acceptance: Your continued use of the platform following the posting of changes constitutes your irrevocable acceptance of the modified Terms. It is your responsibility to review the Terms periodically for updates.

1.6. Contact and Official Support

For all legal inquiries, official notices, or technical support, the following channels are the only authorized points of contact:

• Primary Support Email: help@zelencio.com

• Official Help Center: help.zelencio.com

• Legal Portal: Zelencio.com/help

2.1. Representations and Warranties of the User

By registering an account with Zelencio, you represent and warrant that:

• Legal Capacity: You are an individual, at least 18 years of age (or the age of majority in your jurisdiction), and possess the full legal capacity to enter into this Agreement.

• Authorized Use: You are the sole authorized user of the account and will not allow any third party to access or trade on your behalf.

• Legal Status: You have not been previously suspended or removed from the Zelencio platform or any other digital asset exchange globally.

• Source of Funds: All digital assets deposited or traded on the platform are legally owned by you and are not derived from illegal activities, including but not limited to money laundering, fraud, or terrorism financing.

2.2. Restricted Jurisdictions and Prohibited Persons

Zelencio operates as a global Virtual Asset Service Provider (VASP). However, we do not provide services to users residing in "Restricted Jurisdictions."

• Geographic Restrictions: You warrant that you are not a resident of the United States, United Kingdom, or any country within the European Economic Area (EEA), unless specifically authorized by Zelencio under a localized license.

• Sanctions Compliance: You represent that you are not on any international sanctions list, including those maintained by the UN Security Council, the Office of Foreign Assets Control (OFAC), or any equivalent regulatory body in Africa.

• Consequences of Violation: If Zelencio detects that an account has been opened from a restricted region (via IP monitoring or KYC data), the account will be immediately suspended, and all assets will be frozen pending a legal review.

2.3. The Zelencio Tiered KYC Framework

To maintain platform security and comply with global regulatory standards, Zelencio employs a tiered Identity Verification (KYC) system. Every user must complete verification to access financial features.

• Tier 1: Basic Verification (Phase 1)

  • Requirements: Full legal name, date of birth, gender, nationality, and a live capture of a government-verified ID (e.g., International Passport, Voter’s Card, or Driver’s License).

  • Biometric Requirement: Users must complete a "Liveness Check," including a selfie video and specific facial movements (smiling, blinking, head rotation) to ensure physical presence.

  • Operational Limits: Tier 1 users are subject to daily deposit limits (

            $10,000 equivalent) and withdrawal limits ($
          

    5,000 equivalent).

• Tier 2: Advanced Verification (Phase 2)

  • Requirements: All Tier 1 data plus a verified "Proof of Residence" (e.g., utility bill or bank statement) issued within the last 90 days.

  • Operational Limits: Tier 2 users enjoy higher transaction thresholds ($50,000 daily deposit and $20,000 daily withdrawal).

• Tier 3: Institutional/High-Volume Verification (Phase 3)

  • Requirements: All Tier 2 data plus a "Proof of Funds" declaration and potentially a physical verification of the user's primary residence or business location.

  • Operational Limits: Tier 3 provides the highest level of access, including unlimited balances and institutional-grade withdrawal limits ($10M+).

2.4. Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF)

Zelencio maintains a zero-tolerance policy regarding illicit financial activity.

• Continuous Monitoring: Our security systems and AI-driven monitoring protocols scan all transactions 24/7. Any transaction that triggers a risk alert (e.g., rapid movement of large sums or interaction with flagged wallets) will result in an immediate temporary freeze.

• Suspicious Activity Reports (SAR): Zelencio complies with the laws of the jurisdictions in which it operates. We reserve the right to file Suspicious Activity Reports with relevant authorities without notifying the user, as required by law.

• Enhanced Due Diligence (EDD): If an account is flagged for high-risk behavior, Zelencio may require the user to provide additional documentation regarding the specific "Purpose of Transaction" or source of wealth.

2.5. Accuracy and Retention of Identity Data

• User Duty to Update: You agree to provide accurate, current, and complete information during the KYC process. You must update your information within 48 hours if your legal name, residency, or citizenship status changes.

• Data Retention: In accordance with global financial regulations, Zelencio will retain all KYC data, liveness recordings, and transaction logs for a period of no less than five (5) years following the closure of your account. This data is stored on encrypted third-party servers (e.g., Cloudinary for media) and is used solely for compliance and security purposes.

3.1. Wallet Infrastructure and Custodianship

Zelencio provides a multi-layer custodial wallet system. When you create an account, the platform generates unique blockchain addresses for each supported asset.

• Custody Agreement: You acknowledge that Zelencio acts as the custodian of your digital assets. This means Zelencio manages the private keys associated with your wallet addresses to ensure maximum security against external hacking attempts.

• Asset Segregation: User funds are held in segregated wallets and are not commingled with Zelencio’s operational corporate funds.

• Network Selection: You are solely responsible for ensuring that all on-chain deposits and withdrawals utilize the correct blockchain network (e.g., BNB Smart Chain, Ethereum, Tron). Zelencio shall not be liable for assets sent to an incorrect network or an incompatible wallet address.

3.2. Internal Ledger Transfers (ZIN and Username)

Zelencio facilitates near-instant, zero-fee asset transfers between verified users via the platform's internal ledger.

• Identification Methods: Transfers may be initiated using a recipient’s Zelencio Identity Number (ZIN), verified email address, username, verified phone number, or personal QR code.

• KYC Prerequisite: Both the sender and the receiver must maintain at least a Tier 1 KYC status to utilize internal transfer features.

• Verification Protocols: Before the execution of any internal transfer, Zelencio will display the recipient's avatar, username, and approximate location. It is the sender's absolute duty to verify these details. Once confirmed and executed, internal transfers are final and irreversible.

3.3. Zelencio Codes (Encrypted Vouchers)

The Zelencio Code system allows users to generate and redeem encrypted vouchers for the movement of assets within the ecosystem without sharing personal contact information.

• Generation and Limits: Codes consist of a 20-to-25 character alpha-numeric string. Users are limited to generating a maximum of five (5) codes per 24-hour period to prevent platform abuse.

• Fee Structure: A service fee (as displayed on the generation screen) is applied to every Zelencio Code. This service fee is final and non-refundable upon the generation of the code, regardless of whether the code is eventually redeemed or cancelled.

• Traceability: While the code allows for private interaction between users, it is not anonymous to the platform. Zelencio logs the Unique Identifier (UID) of both the creator and the redeemer. This data is stored for five (5) years to assist in fraud prevention and legal investigations.

• Cancellation: Unredeemed codes may be cancelled by the creator. Upon cancellation, the principal asset amount will be returned to the creator’s balance, but the service fee will remain with the platform.

3.4. Internal Account Segregation (Asset Buckets)

To provide an organized trading experience, your assets may be distributed across several sub-accounts:

• Crypto Account: The primary wallet for standard on-chain and internal transactions.

• Zelencio Crypto Account: Reserved for spot trading, internal transactions and SOMD (Automation) activities.

• Earn Account: Dedicated to assets participating in rewards, referrals, or promotional programs.

• In-Use Balance: Funds currently locked in active Escrow Hub deals,  open trades,  moving balance or pending P2P/C2C orders.

• Security Account: Funds locked by the platform during an active security investigation or due to a detected policy violation and needs attention.

3.5. Prohibited Use of Transfer Features

You are strictly prohibited from using Zelencio internal transfers or Zelencio Codes to:

• Facilitate the sale of illegal goods or services.

• Conduct unlicensed commercial currency exchange (money changing).

• Circumvent regional financial regulations or sanctions.

• Engage in any form of "triangular fraud" or structured money movements.
  Violation of this Article 3.5 will result in the immediate and permanent termination of your account.

4.1. The Zelencio Internal Ledger System

Zelencio operates as a high-frequency digital asset exchange utilizing a proprietary matching engine and an internal ledger.

• Off-Chain Execution: You acknowledge and agree that when you execute a trade (Spot, Swap, or SOMD) within the Zelencio platform, the transaction occurs on Zelencio’s private internal ledger. Assets are not moved on the public blockchain for every individual trade; instead, balances are updated within the Zelencio ecosystem to ensure near-instant execution and zero-latency performance.

• Settlement: On-chain settlement only occurs when a user initiates an "On-Chain Withdrawal" to an external wallet address.

4.2. Advanced Order Types and Execution Parameters

Zelencio provides professional-grade trading tools. By using these tools, you represent that you possess the necessary financial knowledge to understand the risks involved.

• Market Orders: An order to buy or sell immediately at the best available current price on the internal ledger.

• Limit and Smart Limit Orders: Orders to buy or sell at a specific price or better. Zelencio does not guarantee that a Limit Order will be filled, even if the market price briefly touches your limit price.

• Stop-Loss (SL) and Take-Profit (TP): Automated triggers designed to protect capital or lock in gains. You acknowledge that "slippage" may occur during high volatility, and the final execution price may differ from your trigger price.

• Conditional and Iceberg Orders: Advanced algorithmic orders designed for high-volume traders. Zelencio reserves the right to throttle or limit the use of Iceberg orders if they are detected to be causing artificial market stress or liquidity fragmentation.

4.3. One-Click Swap and Asset Conversion

The "One-Click Swap" feature provides a simplified interface for instant asset conversion.

• The Price Lock Protocol: Due to the volatile nature of digital assets, Zelencio provides a "Price Lock" window (typically 15 to 17 seconds). You must confirm the transaction within this window. If the timer expires, the rate will automatically refresh based on the latest market data.

• Finality of Swaps: Once you "Slide to Confirm" a swap, the transaction is processed instantly. Swaps are final, non-reversible, and cannot be cancelled once the internal ledger has been updated.

4.4. Market Auto-Swap on Market Drop (SOMD) Automation

The SOMD feature is a proprietary risk-mitigation tool that allows users to pre-set automation strategies.

• Nature of Automation: SOMD is a software-based automation tool. It is NOT a managed investment product, and Zelencio does not act as your investment manager.

• Execution Risk: You are solely responsible for setting the "Target Value" and "Market Drop/Raise" percentages. Zelencio is not liable for losses resulting from strategies that were incorrectly configured by the user.

• Service Fees for Automation: A flat execution fee (typically 1%) is applied upon the successful trigger and execution of an SOMD strategy. This fee covers the computational resources and liquidity maintenance required for 24/7 monitoring.

• No Guarantee of Profit: Automation does not eliminate market risk. Zelencio makes no representation that SOMD will prevent losses or guarantee profits.

4.5. Market Data, Pricing, and Transparency

• Data Sourcing: Zelencio aggregates real-time market data (Price, Volume, Market Cap, PnL) from global liquidity providers and external WebSockets.

• Data Latency: While we strive for millisecond accuracy, "Network Lag" or "API Latency" from third-party providers may cause a discrepancy between the price shown on the Zelencio dashboard and the price on other global exchanges.

• Transparency Disclaimer: Market data is provided for informational purposes only. Zelencio is not responsible for any "Trading Losses" incurred due to reliance on the visual charts or indicators (MACD, RSI, BOLL, etc.) provided within the app.

4.6. Trading Fees and Platform Commission

• Fee Disclosure: All fees (Service Fees, Network Charges, and Spreads) are calculated in real-time and disclosed on the "Confirm Transaction" screen.

• Deduction Method: By executing a trade, you authorize Zelencio to automatically deduct the applicable fees from your account balance.

• Non-Refundable Policy: Trading fees are payment for the technical service of executing your order. Under no circumstances—including market crashes, app downtime, or account suspension—will trading fees be refunded.

4.7. System Integrity and "Error" Trades

Zelencio reserves the right to reverse or cancel trades that result from:

• System Malfunction: Obvious technical glitches or "Fat Finger" errors in the matching engine.

• Price Manipulation: Any detected attempt to "wash trade" or manipulate the internal ledger prices.

• Legal Mandate: Requests from authorized governmental or regulatory bodies to freeze or reverse specific transaction IDs.

5.1. Definition and Scope of U2U Trading

Zelencio provides a User-to-User (U2U) Peer-to-Peer (P2P) trading environment that allows verified users to directly exchange digital assets (cryptocurrencies) with one another. In these transactions, Zelencio acts as a facilitator and an asset custodian but is not a party to the fiat currency exchange that occurs between the users.

5.2. Mandatory KYC for U2U Activities

Engagement in U2U trading is strictly limited to users who have completed at least Tier 1 Identity Verification. To ensure the safety of our marketplace, Zelencio reserves the right to enforce higher KYC requirements for users acting as "Merchants" or those posting high-value advertisements.

5.3. External Fiat Payments

• Direct Interaction: Users are solely responsible for executing the fiat (cash/bank) portion of a trade. This payment occurs outside of the Zelencio platform via third-party bank transfers or mobile money apps.

• No Fiat Tracking: Zelencio does NOT track, verify, or have access to the fiat banking systems of our users. We cannot confirm if a payment has been sent or received by any bank.

• Approval Responsibility: It is the Seller’s absolute responsibility to confirm the receipt of cleared funds in their bank account before clicking "Confirm Payment" to release the crypto. Zelencio is not liable for assets released prematurely by a Seller.

5.4. Merchant Reputation and Completion Rates

To foster trust, Zelencio calculates and displays public performance metrics for U2U traders, including:

• Completion Rate: Percentage of orders successfully finalized in the last 30 days.

• Average Release/Payment Time: Historical speed of transaction completion.

• User Reviews: Feedback and ratings from previous trading partners.
  Zelencio reserves the right to suspend any user whose reputation score falls below platform standards.

5.5. Prohibited P2P Practices

Users are strictly prohibited from:

• Third-Party Payments: Using a bank account that does not match the name on their Zelencio KYC profile (unless they pass the Platform’s mandatory "Third-Party Face Verification" check).

• Crypto Slang in References: Mentioning "BTC," "Crypto," or the platform name in bank transfer descriptions, as this may result in the freezing of both parties' bank accounts by financial regulators.

• Off-Platform Negotiation: Attempting to move the trade to external chat apps like Telegram or WhatsApp. Only records within the Zelencio P2P Chat are admissible in disputes.

6.1. Dedicated Venue for Digital Products

The Zelencio Escrow Hub is a specialized feature designed for the secure exchange of digital products and services (e.g., domain names, social media profiles, freelance deliverables). It is technically distinct from the U2U Crypto Trading system and governed by different security protocols.

6.2. Roles in the Escrow Hub

An Escrow Hub deal may involve up to three parties:

• The Buyer: The party seeking to acquire the digital product and providing the funds.

• The Seller: The party providing the digital product/service.

• The Middle Man (Optional): A third-party verified user who oversees the deliverable's quality and ensures both parties adhere to the agreement.

6.3. Deal Creation and Fee Allocation

• Terms and Conditions: Every escrow deal must include "Full deal terms and description" at the time of creation.

• Fee Customization: The platform allows the creator of the deal to select who pays the Escrow Fee: "Buyer pays everything," "Seller pays everything," "Middle Man pays everything," or a "Split Fee."

• Asset Locking: Once an Escrow deal is initiated, the required assets are moved into an "In-Use Balance" and locked by the platform. These funds cannot be withdrawn or traded until the deal is completed, cancelled, or settled via dispute.

6.4. Item Proof and Verification

• Evidence Upload: Users are permitted to upload up to three (3) screenshots as "Item Proof" during the setup and delivery phases.

• Milestone Logic: For complex services, deals can be broken down into milestones. Releasing a milestone signifies the Buyer’s satisfaction with that portion of the work and is irreversible.

6.5. Human-Moderated Dispute Resolution

In the event that a digital product is not delivered as described or payment is contested:

• Grace Period: A 72-hour grace period applies to all Escrow disputes to allow for mutual resolution.

• Support Intervention: If no resolution is reached, a Zelencio human moderator will join the trade chat. The moderator will review all evidence uploaded within the hub.

• Final Judgement: By using the Escrow Hub, you agree that the final decision of the Zelencio moderator regarding the release or refund of funds is final, binding, and non-appealable.

7.1. Operational Service Fees

Zelencio charges service fees for the use of its proprietary matching engine, secure custodianship, and technological infrastructure. By utilizing any financial feature of the platform, you acknowledge and agree that:

• Remuneration for Services: Fees are charged to ensure the operational sustainability, security, and 24/7 maintenance of the Zelencio ecosystem.

• Automatic Deduction: You authorize Zelencio to automatically deduct all applicable fees from your account balance at the moment of transaction execution or order placement, as specified for each feature.

7.2. Trading and Swap Fee Schedules

• Spot Trading Fees: Every order executed on the Zelencio Internal Ledger (Buy/Sell) is subject to a trading fee. This fee is calculated as a percentage of the total transaction volume and is displayed clearly in the trade confirmation module.

• One-Click Swap Fees: Conversions performed via the Swap interface include a service fee to cover liquidity provision and price-lock risks. These fees are built into the "Receive Amount" displayed before confirmation.

• SOMD (Automation) Fees: Automated strategies executed via the "Swap on Market Drop" system incur a specialized "Automation Execution Fee" (typically 1%). This fee applies only upon the successful trigger and completion of the pre-set strategy.

7.3. Transfer and Voucher (Zelencio Code) Fees

• Internal Transfers: While transfers via ZIN, Email, or Username are generally offered as a zero-fee service to encourage ecosystem growth, Zelencio reserves the right to implement a nominal "Ledger Maintenance Fee" with prior notice.

• Zelencio Code Generation: The creation of an encrypted voucher code is a premium service. A non-refundable service fee (e.g., 3.6% or as displayed) is charged at the moment the code is generated.

• Cancellation Logic: If a user chooses to cancel an unredeemed Zelencio Code, the platform will return the principal asset amount to the user’s wallet, but the service fee will not be returned, as the technical service of code generation and encryption was already provided.

7.4. Escrow Hub and P2P Marketplace Fees

• Escrow Service Fee: To facilitate the secure exchange of digital products, Zelencio charges a platform fee for every deal created in the Escrow Hub.

• Fee Allocation: The party responsible for this fee (Buyer, Seller, or Middle Man) is determined by the deal creator during the setup process.

• Dispute Handling Costs: In complex dispute cases requiring extensive human investigation, Zelencio reserves the right to charge an additional "Administrative Review Fee" from the locked escrow amount.

7.5. On-Chain Network (Gas) Fees

• Third-Party Costs: When withdrawing assets to an external blockchain address (On-Chain Withdrawal), users must pay a "Network Fee" (Gas). This fee is not set by Zelencio but is determined by the congestion and requirements of the specific blockchain (e.g., Ethereum, BNB Smart Chain, Tron).

• Withdrawal Surcharge: Zelencio may apply a small administrative surcharge on top of the base network fee to cover the costs of secure wallet management and broadcast.

• Inaccurate Estimates: While Zelencio provides an "Arrival Estimate" and "Estimated Fee," you acknowledge that blockchain conditions change rapidly. Zelencio is not responsible for delays or higher-than-expected gas costs once a transaction is broadcast to the network.

7.6. Absolute Non-Refundable Policy

THIS IS A CRITICAL PROVISION. PLEASE READ CAREFULLY.

• Technical Finality: All fees paid to Zelencio—including but not limited to trading fees, voucher fees, swap fees, and escrow fees—are 100% non-refundable.

• User Error: Service fees will not be refunded in the event of user error, such as sending funds to the wrong address, selecting an incorrect network, or failing to complete a P2P trade.

• Platform Suspension: In the event that your account is suspended or terminated for a policy violation (e.g., fraud or AML red flags), any fees already paid for pending or completed transactions will be forfeited to the platform.

7.7. Tax Obligations and Reporting

• User Responsibility: You are solely responsible for determining whether, and to what extent, any taxes apply to any transactions you conduct through Zelencio (e.g., Capital Gains Tax, Value Added Tax (VAT), or Income Tax).

• No Withholding: Unless strictly required by the local laws of a specific jurisdiction, Zelencio does not withhold or calculate taxes on your behalf.

• Government Reporting: You acknowledge that Zelencio may be legally compelled to provide your transaction history and KYC data to tax authorities (such as the FIRS in Nigeria) upon receiving an official legal request or court order. Zelencio is not liable for any tax penalties or interest you may incur.

8.1. Prohibited Use of Services

You are strictly prohibited from using the Zelencio platform, its internal ledger, or its transfer protocols (Zelencio Codes/Internal Transfers) for any of the following activities:

• Illegal Transactions: The purchase or sale of illegal drugs, weapons, stolen goods, or any other items prohibited by international law.

• Unlicensed Financial Activity: Operating as an unauthorized money transmitter, currency exchange (Bureau de Change), or providing banking services without a local license using Zelencio’s infrastructure.

• Abuse of Vouchers: Using Zelencio Codes to facilitate high-frequency commercial arbitrage or to obscure the origins of criminal proceeds.

• Sanctions Evasion: Utilizing the platform if you are a resident of a restricted jurisdiction or a person named on a global sanctions list (OFAC, UN, EU).

8.2. Market Manipulation and Technical Abuse

Zelencio maintains a zero-tolerance policy regarding the integrity of its internal matching engine. You agree not to:

• Wash Trading: Executing trades with yourself or through coordinated accounts to create a false impression of market volume or price.

• System Exploitation: Attempting to exploit technical glitches, "latency arbitrage," or API vulnerabilities within the One-Click Swap or SOMD features.

• Reverse Engineering: Attempting to decompile, reverse-engineer, or "scrape" the proprietary code or market data of the Zelencio application.

• Botting: Using unauthorized third-party scripts or bots to interact with the platform in a way that causes "Artificial Stress" to the server infrastructure.

8.3. P2P and Escrow Fraud Prevention

To maintain a safe marketplace for African digital commerce, the following actions will result in immediate permanent bans:

• Doxing and Harassment: Sharing a trading partner’s bank details or personal info outside the platform.

• Fake Evidence: Uploading doctored or forged screenshots of bank transfers within the P2P Chat or Escrow Hub.

• Off-Platform Solicitation: Encouraging a user to complete a trade on WhatsApp, Telegram, or any other external app to bypass Zelencio’s security escrow.

• Triangular Scams: Using a third party’s bank account to pay a Seller without passing the mandatory "Zelencio Face Verification" protocol.

8.4. Monitoring and AI Fraud Detection

• 24/7 Surveillance: You acknowledge that Zelencio utilizes human moderators and AI-driven behavior analysis to monitor all platform interactions.

• Risk Scoring: Every account is assigned a dynamic "Internal Risk Score." High-risk scores (triggered by frequent cancellations, failed KYC, or IP-mismatches) may result in automatic account restrictions.

• Cooperation with Authorities: Zelencio reserves the right to provide your UIDs, transaction logs, and P2P chat history to authorized local and international law enforcement agencies (e.g., EFCC in Nigeria) without your prior consent.

8.5. Account Suspension and Permanent Termination

Zelencio reserves the right to suspend or terminate your account immediately, without notice, if:

• We believe, in our sole discretion, that you have violated any article of these Terms.

• Your account is being used for fraudulent, deceptive, or malicious activity.

• A government body or regulatory authority issues a formal request to freeze your assets.

• You fail to complete mandatory KYC updates or provide valid proof of funds when requested.

8.6. Treatment of Assets Upon Termination

In the event that your account is terminated due to a policy violation:

• Asset Freeze: All funds in your Crypto, Zelencio Crypto, and Earn accounts will be frozen.

• Investigation Period: Zelencio may hold assets for up to 180 days (or longer if required by law) to ensure all P2P disputes and bank-related inquiries are resolved.

• Forfeiture: If assets are found to be derived from criminal activity or if the account was used to defraud other Zelencio users, you agree that such funds may be forfeited to the platform or returned to the victims, as determined by a legal audit or court order.

8.7. Withdrawal of Access (The "Right to Refuse")

Zelencio is a private platform. We reserve the right to refuse service to any individual or entity for any reason, provided that such refusal does not violate the fundamental human rights laws of the operating jurisdiction.

8.8. Crypto Gift and Giveaway Abuse

The Crypto Gift feature is provided for promotional and personal gifting purposes only. To prevent the "Structuring" of illegal funds, the following are strictly prohibited:

• Commercial Exchange: Using Crypto Gifts as a method of payment for unregulated commercial goods or services.

• Mule Accounts: Creating gifts for the sole purpose of moving assets between multiple accounts controlled by the same individual to obscure the "Audit Trail."

• Automated Claiming: Using scripts, bots, or any form of automation to monitor and claim "Random Amount" gifts faster than humanly possible.

• False "Purpose": Entering deceptive or vague information in the mandatory "Purpose of Gift" field. Zelencio reserves the right to terminate any gift code if the stated purpose is found to be fraudulent.

8.9. Referral Program Integrity (Anti-Sybil Policy)

Zelencio operates a 1-level referral system (User A invites User B). To maintain a fair ecosystem, the following "Referral Fraud" actions will result in the immediate disqualification of rewards and potential account suspension:

• Self-Referral: Creating multiple accounts under your own control (using different emails/IPs) to refer yourself and harvest signup bonuses.

• Incentivized Traffic: Paying third parties to create "Ghost Accounts" that complete KYC but never perform genuine trades.

• Deceptive Promotion: Using the Zelencio name to promote "Get Rich Quick" schemes or using misleading advertisements to get users to sign up under your link.

• Commission Structure: You acknowledge that referral commissions are only paid for direct invitees. Any attempt to structure "Multi-Level Marketing" (MLM) or "Pyramid" schemes using Zelencio links is a violation of international financial law.

8.10. Daily Tasks and Milestone Manipulation

The "Daily Task" and "Trade and Earn" rewards are intended to incentivize genuine platform activity. You agree not to engage in:

• Wash Trading: Executing high-frequency trades with no economic purpose (trading the same asset back and forth) solely to hit volume milestones (e.g., the "$10,000 spot trade" task).

• Fake P2P Activity: Creating and completing P2P/C2C orders with coordinated partners or secondary accounts to farm "Trade Count" rewards.

• Task Automations: Using automated software to perform "Daily Check-ins" or task completions.

• Right to Reclaim: Zelencio reserves the absolute right to audit reward histories. If we detect that a user’s "GBRT" or "USDC" rewards were earned through artificial activity, we will deduct the equivalent value from your main balance without prior notice.

8.11. Account Multiplicity and Botting

• One Human, One Account: In accordance with our KYC policy, each physical individual is permitted only one (1) verified Zelencio account. Detection of multiple verified accounts belonging to the same person will result in the permanent closure of all associated accounts.

• Hardware Fingerprinting: Zelencio uses "Authorized Device" tracking and hardware fingerprinting to detect users operating dozens of accounts from the same physical device.

8.12. Reputation and Review Manipulation

In the P2P Marketplace and Escrow Hub:

• Review Farming: You may not post fake positive reviews for yourself or coordinated partners.

• Malicious Ratings: You may not post fake negative reviews to damage the reputation of a competitor merchant.

• Reputation Reset: Zelencio reserves the right to reset a user's "Success Rate" or "Reputation Score" if evidence of manipulation is found.

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9.1. User Responsibility for Account Security

Zelencio provides industry-leading security tools, but the ultimate safety of your assets depends on your personal security hygiene.

• Confidentiality: You are solely responsible for maintaining the confidentiality of your login credentials, including your email password, 5-digit App PIN, and Google Authenticator (2FA) secret keys.

• Unauthorized Use: You agree to notify Zelencio immediately at security@zelencio.com if you suspect any unauthorized access, security breach, or compromise of your mobile device.

• Negligence: Zelencio shall not be liable for any loss of funds resulting from your failure to secure your account or for "Social Engineering" attacks (e.g., sharing your PIN or 2FA code with a third party pretending to be Zelencio Support).

9.2. Multi-Layered Authentication (MFA) Protocols

To ensure the standard of a global financial exchange, Zelencio enforces a multi-layered authentication framework:

• The App PIN: A mandatory 5-digit numeric code required to access the application and execute sensitive internal actions.

• Biometric Authentication: Zelencio utilizes official Android/iOS Biometric APIs (Fingerprint and Face ID) for rapid access. You acknowledge that biometric data is stored locally on your device and is not transmitted to Zelencio servers.

• Google 2FA (The "Hard Lock"): For all outbound transactions (Withdrawals, Vouchers, P2P release), Google Authenticator (2FA) is mandatory. You acknowledge that if you lose access to your 2FA device without having saved your "Recovery Key," the account recovery process may take up to 7 business days and require manual physical verification.

9.3. Authorized Device Tracking and Fingerprinting

Zelencio logs technical metadata to detect and prevent unauthorized logins.

• Logged Data: To protect your account, we record the Device IP, Device Name/Model, Network Type, and Approximate Location for every login session.

• Source Verification: In the event of a login from an unrecognized device or a high-risk IP address (e.g., a known malicious VPN), Zelencio may automatically suspend withdrawal features for 24–48 hours as a security precaution.

• Device Management: Users can view and manage "Authorized Devices" within the Security Settings. Removing a device will immediately invalidate all active sessions on that hardware.

9.4. Secure Transaction Approval (The "Confirmation Loop")

All financial movements on the Zelencio Internal Ledger require a "Confirmation Loop":

• Visual Review: A summary of the asset, amount, and fees is displayed.

• Slide-to-Confirm: A high-friction gesture to prevent accidental "pocket-trading" or unintended execution.

• The Final Auth: Execution is only completed after the input of the 5-digit PIN and/or the 6-digit 2FA code. You agree that once these credentials are submitted, the transaction is considered "User-Authorized" and cannot be reversed by the platform.

9.5. Data Storage and Encryption Standards

Zelencio adheres to the principle of "Data Segregation" to ensure the highest levels of privacy:

• Confidential KYC Data: All sensitive identity documents, liveness videos, and personal information are stored on high-security, AES-256 encrypted internal servers. This data is never shared with third-party marketing firms.

• Non-Confidential Media: Profile pictures and P2P chat attachments may be processed via encrypted third-party storage providers (e.g., Cloudinary). By uploading media, you consent to this processing.

• Zero-Knowledge PINs: Zelencio does not store your App PIN in a readable format. It is cryptographically "hashed," meaning even Zelencio employees cannot view your PIN.

9.6. System Integrity and Maintenance

• Downtime: Zelencio strives for 99.9% uptime. However, periodic maintenance is required to update the matching engine and security protocols. Zelencio is not liable for losses caused by the inability to execute trades during scheduled or emergency maintenance windows.

• Software Updates: To maintain security, you are required to use the latest version of the Zelencio app. Using an outdated or "Jailbroken/Rooted" device violates this security policy and may result in account restriction.

9.7. Limitation of Technological Liability

While we utilize global WebSockets and enterprise-grade infrastructure, you acknowledge that no digital system is 100% secure. Zelencio is not liable for "Force Majeure" events, including large-scale internet outages, blockchain network failures (forks/hacks), or sophisticated zero-day exploits beyond the reasonable control of the platform.

10.1. Zelencio Intellectual Property Rights

The Zelencio platform, including but not limited to its source code, object code, proprietary matching engine algorithms, "One-Click" logic, SOMD automation protocols, user interface design, graphics, logos, and market data visualizations, are the exclusive property of Zelencio and its licensors.

• Proprietary Rights: All rights, title, and interest in the platform are protected by international copyright, trademark, and patent laws.

• Limited License: Zelencio grants you a limited, non-exclusive, non-transferable, and revocable license to access the platform for personal, non-commercial use. This license does not grant you any ownership rights or the right to reproduce or distribute any part of the platform.

• Prohibition on Reverse Engineering: You are strictly prohibited from attempting to decompile, reverse-engineer, or extract the source code of the Zelencio mobile application or its backend API.

10.2. User-Generated Content (UGC) and Moderation

Zelencio provides features that allow users to upload or broadcast content, including profile pictures, P2P/Escrow chat messages, and Livestreams.

• Ownership and License: You retain ownership of any content you upload. However, by posting content on Zelencio, you grant the Platform a global, royalty-free, perpetual license to host, store, and display that content solely to provide the requested services.

• Prohibited Content: You agree not to upload or broadcast any content that is defamatory, obscene, fraudulent, inciting violence, or infringing on the intellectual property of others.

• Mandatory Moderation: In compliance with Google Play and Apple App Store policies, Zelencio employs a robust moderation system. We reserve the right to remove any content and block any user who violates our UGC standards.

• Reporting and Blocking: Every social interface within Zelencio (Chat/Profile/Livestream) includes a "Report" and "Block" function. Users are encouraged to report any malicious or fraudulent behavior immediately.

10.3. Indemnification

You agree to indemnify, defend, and hold harmless Zelencio, its parent company, subsidiaries, affiliates, and their respective directors, employees, and agents from and against any and all claims, damages, obligations, losses, liabilities, costs, or debt (including attorney’s fees) arising from:

• Your violation of any article within these Terms of Service.

• Your use of the platform to conduct illegal financial activities.

• Any claim that your user-generated content caused damage to a third party.

10.4. Disclaimer of Warranties

The Zelencio platform is provided on an “AS IS” and “AS AVAILABLE” basis. Zelencio makes no warranties, express or implied, regarding the platform’s operation, the accuracy of market data, or the continuous availability of liquidity. We do not warrant that the app will be error-free or that the servers are free of viruses or other harmful components.

10.5. Governing Law and Dispute Resolution

• Governing Law: These Terms shall be governed by and construed in accordance with the laws of the primary operating jurisdiction of the platform (e.g., the Federal Republic of Nigeria), without regard to its conflict of law provisions.

• Arbitration: You agree that any legal dispute or claim arising from your use of Zelencio that cannot be resolved through our 24/7 Support team must be settled via binding arbitration rather than in a general court.

• Class Action Waiver: You agree to resolve disputes with Zelencio on an individual basis and waive your right to participate in a class-action lawsuit or class-wide arbitration.

10.6. Force Majeure

Zelencio shall not be liable for any delay or failure to perform resulting from causes outside its reasonable control, including but not limited to:

• Acts of God, war, or terrorism.

• Large-scale internet or power outages.

• Changes in government regulations or central bank mandates.

• Blockchain forks or network congestion.

10.7. Severability and Survival

• Severability: If any provision of these Terms is found by a court or arbitrator to be invalid or unenforceable, the remaining provisions will remain in full force and effect.

• Survival: All provisions of these Terms which by their nature should survive termination shall survive, including ownership provisions, warranty disclaimers, and limitations of liability.

10.8. Entire Agreement

These Terms of Service, along with the Privacy Policy and KYC/AML Framework, constitute the entire agreement between you and Zelencio regarding the use of the platform and supersede any prior agreements or understandings.