Terms and Conditions
General Provisions
Governing Law
These Terms and Conditions, together with any related policies, shall be governed by and construed in accordance with the laws and regulations of the Astana International Financial Centre (AIFC).
Jurisdiction and Dispute Resolution
Any dispute, claim, or controversy arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the AIFC Court and the AIFC International Arbitration Centre, unless otherwise required by applicable law.
Regulatory Supremacy
In the event of any conflict between these Terms and applicable laws, regulations, or binding instructions issued by the Astana Financial Services Authority (AFSA) or any other competent authority, such laws, regulations, or instructions shall prevail.
Severability
If any provision of these Terms is found to be unlawful, invalid, or unenforceable, such provision shall be severed and the remaining provisions shall continue in full force and effect.
No Waiver
Failure or delay by the Company to exercise any right, remedy, or power under these Terms shall not constitute a waiver of such right, remedy, or power, nor shall any single or partial exercise prevent further exercise thereof.
1. Purpose and Application
1.1. These Terms of Use establish the legal framework governing the relationship between Delta DA Ltd. (the “Company,” “we,” “us,” or “our”) and any individual or legal entity accessing or using the Company’s services (the “User” or “you”). These Terms form an integral part of the User Agreement and define the rights, duties, and liabilities of both parties in connection with the use of the Company’s digital asset trading and custody platform.
1.2. By creating an account, accessing the Company’s website, or using any services, applications, or technical interfaces provided by the Company (collectively, the “Platform”), you confirm that you have carefully reviewed and accepted the User Agreement in full, including these Terms of Use, the Privacy Policy, the AML/KYC Policy, and any other referenced documents. The User Agreement represents the complete and binding agreement between you and the Company. If you do not agree with any part of these Terms, you must refrain from using the Platform and its services.
1.3. The Company operates as a regulated digital asset service provider within the Astana International Financial Centre (AIFC) and conducts its activities under the supervision of the Astana Financial Services Authority (AFSA). All services provided by the Company are subject to the applicable regulatory framework of the AIFC, including rules on digital asset trading, custody, client protection, and financial crime prevention.
1.4. You acknowledge that engaging in transactions involving digital assets, including their purchase, sale, transfer, or custody, may expose you to substantial financial risk. The value of digital assets may fluctuate significantly, and the loss of funds is possible. The Company strongly advises Users to assess whether the use of digital asset trading or custody services is appropriate for their financial situation, experience, and risk tolerance before proceeding.
2. Publication, Applicability, and Amendments
2.1. The Company ensures that these Terms of Use, the Privacy Policy, and any additional documents governing the provision of its services are made publicly available on the main page of the Company’s website and Platform. This enables Users to easily access and review the governing legal and compliance framework at any time.
2.2. The Company may revise, update, or correct any part of the User Agreement as necessary to remain aligned with the regulatory standards of the Astana International Financial Centre and the Astana Financial Services Authority, as well as other applicable laws and industry best practices.
2.3. Any updates to these Terms will be communicated to Users through an official notice published on the Platform or by other appropriate means. Each notice will state the date from which the revised provisions become effective. Unless otherwise required by regulation, changes shall become binding after a reasonable notification period. Where an update materially affects Users’ rights or obligations, or where no effective date is specified, the changes will take effect ten (10) calendar days after publication. The latest revision date will always be indicated at the beginning of the relevant document.
2.4. If a User does not agree with the revised Terms, they may discontinue use of the Platform and close their Account before the effective date of the update. Failure to object or terminate access prior to the effective date will be treated as acceptance of the amended Terms.
2.5. Continued access to or use of the Platform on or after the effective date of the changes constitutes the User’s acknowledgement and acceptance of the updated Terms. Users are responsible for reviewing the most current version of the User Agreement and raising any compliance or legal concerns in a timely manner.
2.6. Where a User declines to accept updated Terms that are necessary for the Company to maintain compliance with AFSA or AIFC regulations, the Company reserves the right to restrict, suspend, or terminate the User’s access to the Services and/or their Account.
3. Supplementary Policies and Guidance
3.1. In addition to these Terms of Use, the Company may publish separate operational, compliance, or informational documents on its Platform. These may include, without limitation, user manuals, fee schedules, technical guidelines, and frequently asked questions. Such materials form part of the overall User Agreement and are intended to provide Users with practical instructions on how to access and use the Company’s digital asset trading and custody services.
3.2. The Company may also publish notices identifying jurisdictions, individuals, or entities that are restricted or prohibited from accessing the Services, including those subject to international sanctions or regulatory limitations. These supplementary documents may further outline applicable service charges, taxes, minimum transaction thresholds, and other operational requirements.
3.3. Users are responsible for reviewing and understanding the most recent versions of all documents and policies issued by the Company. Continued use of the Platform constitutes the User’s acknowledgement that they have taken reasonable steps to stay informed of any such updates or changes.
4. Client Access and Compliance Requirements
4.1. Public areas of the Company’s Platform may be viewed without registration. However, access to trading, custody, and other regulated services is granted only to Users who have successfully completed the Company’s onboarding and verification process and have been approved for a User Account.
4.2. Any individual or legal entity applying to use the Company’s Services (the “Applicant”) must submit a registration request and provide all information and supporting documentation reasonably required by the Company to determine eligibility. Approval of an Account is at the sole discretion of the Company.
4.3. To qualify for access to the Services, the Applicant must meet the following minimum conditions:
be at least eighteen (18) years of age (for natural persons);
have the legal capacity and authority to enter into a binding agreement;
not be a resident, national, or entity established in any jurisdiction that is subject to international sanctions or regulatory restrictions, as determined by the Company’s internal AML/CFT framework;
submit all identification and corporate documentation requested for the purposes of “Know Your Customer” (KYC) and “Know Your Business” (KYB);
not be listed on, or associated with, any financial crime or sanctions watchlists;
confirm that the Account is opened and used solely for the Applicant’s own benefit and not for the account of third parties;
accept and comply with these Terms of Use and the Privacy Policy;
satisfy any other onboarding or compliance criteria the Company may implement to meet its regulatory obligations under AFSA and AIFC law.
4.4. Where the Applicant is a legal entity, it must designate one or more authorised representatives who are permitted to communicate with the Company, provide instructions, and manage the User Account on behalf of that entity.
4.5. The Applicant agrees to supply accurate, complete, and up-to-date information at all times. The Company may request personal and corporate data including, but not limited to, identification details, beneficial ownership structure, source of funds, and bank account information. The Company is required to retain and review such data in order to comply with its AML/CFT and financial crime prevention obligations.
4.6. The User must promptly notify the Company of any changes to their registration or verification details. The Company may verify or re-verify User information at any time, directly or through approved third-party providers. The User acknowledges that their data may be shared with regulatory, compliance, and financial crime prevention authorities when required by law.
4.7. Access to certain Services may depend on the User’s verification status, risk profile, and jurisdiction. The Company may impose or adjust operational restrictions and transaction limits in accordance with its internal risk management procedures.
4.8. The User is responsible for maintaining secure access to their Account and for safeguarding all authentication credentials and devices. The Company supports enhanced security measures including two-factor authentication. Failure by the User to ensure the security of their Account may result in loss of assets for which the Company shall not be liable.
5. Updating User Information
5.1. Users may access their account on the Platform at any time to review and update their personal or corporate information using the procedures provided by the Company. Where necessary, Users may also submit requests for changes through the Company’s Customer Support.
5.2. The User is solely responsible for ensuring that all information provided to the Company remains accurate and up to date. The Company shall not be held responsible for any losses, delays, or service restrictions arising from the User’s failure to promptly update or notify the Company of changes to their information.
6. User Account Administration and Security
6.1. The Company may refuse or restrict the use of any User name or account designation that it reasonably considers misleading, inappropriate, or in conflict with legal or regulatory requirements. This includes, without limitation, cases where the account name may cause confusion with another individual or organisation, violate the rights of third parties, or suggest affiliation with the Company or its partners.
6.2. Each User Account is issued for the exclusive use of the approved User and is not transferable. Where the User is a legal entity, only its authorised representatives may access and manage the Account on its behalf, subject to the Company’s verification and compliance procedures.
6.3. The User is responsible for safeguarding all credentials and security tools used to access their Account, including passwords, authentication codes, and electronic devices. Users must not disclose or share their access details with unauthorised third parties. The User bears full legal and financial responsibility for any actions taken through their Account by individuals they have authorised.
6.4. The Company is entitled to rely on any instructions or transactions carried out through a validly authenticated Account session. The Company is not obliged to independently verify the authority of the person accessing the Account, and all such actions shall be deemed to have been made by the User unless the Company is formally notified otherwise.
6.5. If a User becomes aware of any unauthorised access, loss, theft, or compromise of their Account credentials, they must immediately notify the Company’s Customer Support. The Company may, at its discretion, suspend or limit access to the affected Account to protect Users and maintain compliance with its regulatory obligations.
6.6. The Company shall not be liable for any loss of digital assets or funds that results from the User’s failure to maintain proper security over their Account, devices, or authentication details.
6.7. Each User must ensure that their authorised representatives fully understand and comply with these Terms. The User remains responsible for all actions carried out by such representatives on the Platform.
6. User Account Governance
6.1. The Company reserves the right to refuse or restrict the use of any account name or identifier that may be misleading, inappropriate, infringe on third-party rights, or create a false impression of affiliation with the Company or any other entity.
6.2. User Accounts are strictly personal and non-transferable. Access and operation of a legal entity account may only be performed by its duly authorised representatives.
6.3. Users are solely responsible for maintaining the confidentiality and security of their account credentials, devices, and authentication methods. Any activity conducted through an authenticated session will be deemed valid and binding upon the User.
6.4. The Company is entitled to rely on instructions provided through a User Account and shall not be required to verify the authority of the individual accessing the Account.
6.5. Users must immediately notify the Company if their account credentials are compromised. The Company may suspend or restrict access to protect Users and maintain regulatory compliance.
6.6. The Company shall not be liable for any loss resulting from the User’s failure to maintain adequate account security.
7. Data Protection and Privacy
7.1. The Company processes all User data in accordance with its Privacy Policy and applicable AIFC and AFSA regulations.
7.2. Users confirm that they have obtained all necessary consents from their shareholders, directors, beneficial owners, and authorised representatives before submitting their personal or corporate data to the Company.
7.3. The User indemnifies the Company against any claims arising from the unlawful disclosure or misuse of third-party personal data.
8. Responsibilities of the Company
8.1. The Company will use commercially reasonable efforts to ensure the availability, reliability, and security of the Platform.
8.2. The Company maintains appropriate technical and organisational measures to protect User data and digital assets in compliance with AFSA regulatory requirements.
8.3. The Company shall address all valid User complaints in a fair and transparent manner.
9. User Conduct and Prohibited Activities
9.1. Users must comply with all applicable laws and must not misuse the Platform.
9.2. The following actions are strictly prohibited:
using the Platform for unlawful, fraudulent, or deceptive purposes;
acting on behalf of undisclosed third parties;
providing false or misleading information;
attempting to manipulate markets or pricing;
breaching cybersecurity safeguards or bypassing security controls;
introducing malicious software or engaging in system abuse;
scraping, harvesting, or collecting data without authorisation;
using the Company’s name, trademarks, or branding without permission;
engaging in any conduct that could harm the Company’s operations, clients, or reputation.
9.3. Any breach of these obligations may result in immediate suspension or termination of the User’s Account, and the Company may report such activity to AFSA or other competent authorities.
Corporate Transaction Oversight
9.4. Legal entity accounts may be subject to additional due diligence, monitoring, and operational limits depending on their risk profile, jurisdiction, and transaction behaviour. The Company reserves the right to increase, reduce, or suspend such limits at any time.
13. Regulated Digital Asset Services
This Section describes the core services provided by Delta DA Ltd. through its licensed digital asset platform.
13.1. Scope of Services
The Company may provide one or more regulated digital asset services to Users, subject to the laws and regulations of the Astana International Financial Centre and the Astana Financial Services Authority.
13.2. Digital and Fiat Wallet Services
The Company offers Users a secure digital wallet environment, enabling the holding, transfer, and management of supported digital assets and fiat currency balances.
13.3. Digital Asset Trading Facility
The Platform allows Users to place orders and execute trades in supported digital assets. The Company facilitates transactions between Users but does not issue or guarantee the value of any digital assets.
13.4. Digital Asset Conversion and Exchange
Users may exchange one digital asset for another or trade digital assets against fiat currency at prevailing market rates. Applicable network, platform, and regulatory fees may apply.
13.5. Service Availability
The Company aims to provide continuous access to the Platform, subject to scheduled or emergency technical maintenance.
13.6. Service Suspension and Termination
The Company may restrict or suspend access to any service where required for operational stability, compliance, security, or regulatory reasons, including:
maintenance or technical upgrades;
system malfunction or force majeure;
suspected financial crime or sanctions violations;
market disruption or cybersecurity risk;
or where required under AFSA regulations.
The Company shall not be responsible for any losses incurred by Users resulting from such suspensions or restrictions.
14. Use of the Platform
14.1. Deposits of Fiat Currency
Users may deposit fiat funds into the Company’s designated bank account. The Company maintains internal records of such balances for each User. Deposited fiat funds do not accrue interest for the benefit of the User.
14.2. Deposits of Digital Assets
Users may also deposit supported digital assets into their wallet. Once received, these assets will appear in the User’s account balance.
14.3. Placing Orders
Users may submit buy or sell orders only through the Company’s Platform interface and must maintain sufficient wallet balances to cover the transaction and applicable fees.
14.4. Order Execution
Orders are matched and executed automatically based on available counterparties. Once executed, transactions are final and binding.
14.5. Withdrawals and Transfers
Fiat withdrawals may only be made to a verified bank account held in the User’s name.
Digital asset withdrawals may only be made to approved external wallet addresses.
The Company may require additional verification before processing large or unusual transfers.
14.6. Accuracy of Payment Details
Users are fully responsible for ensuring that any bank or wallet address submitted for withdrawals is correct. The Company shall not be liable for losses resulting from incorrect transfer details provided by the User.
14.7. Regulatory and AML Checks
Prior to processing withdrawals or transfers, the Company may conduct compliance and risk reviews in line with its AML/KYC obligations.
14.8. No Investment Advice
The Company does not provide financial, tax, or investment advice. Users are solely responsible for their trading decisions and any resulting gains or losses.
14.9. Transaction Disputes
Users must report any unauthorised or disputed transactions within 30 calendar days. The Company may investigate and resolve such claims in accordance with its compliance procedures.
14.10. Market Disruption and Exceptional Circumstances
In cases of severe market volatility, regulatory intervention, cybersecurity risk, or force majeure, the Company may suspend trading, reject new orders, or settle open positions as necessary. The Company shall not be liable for losses resulting from such measures.
15. Custody and Trading Services
15.1. Custody models
The Company provides custody of supported Digital Assets using one or more custody arrangements, which may include:
in-house custody, where Digital Assets are held in wallets forming part of the Company’s infrastructure; and/or
third-party custody, where the Company engages regulated or professional custody technology/providers.
In all cases where the Company is recognised as custodian for Users, the Company remains responsible for applying appropriate security and control measures consistent with its regulatory obligations.
15.2. Private keys and security
The Company controls and secures the cryptographic keys necessary to administer custody wallets. Key management may use a combination of offline and online safeguards and access controls designed to reduce risks of unauthorised access and loss.
15.3. Withdrawals and irreversibility
Users may request withdrawals of Digital Assets by providing an external wallet address. Users must carefully verify transaction details prior to submission. Once a withdrawal is broadcast to the relevant blockchain network, it is generally irreversible and cannot be recalled.
15.4. Fees and charges
Withdrawals and trading activity may be subject to:
blockchain/network fees (including “gas” where applicable),
platform trading and transfer fees,
banking commissions for fiat movements,
and taxes (including VAT where applicable).
Where feasible, applicable charges will be shown to the User at or before confirmation of the relevant transaction.
15.5. Compliance-based restrictions
The Company may delay, reject, suspend, or cancel a transaction (including withdrawals) if:
required by applicable law or a competent authority;
the transaction triggers AML/CFT alerts or sanctions-related concerns;
additional verification or Enhanced Due Diligence is required; or
operational security controls deem the transaction high-risk.
15.6. Supported assets only
Custody, transfers, and trading are available only for Digital Assets and fiat currencies explicitly supported by the Company from time to time. Users must not attempt to deposit, store, or transfer unsupported assets to the Company’s wallet infrastructure. The Company may attempt to assist recovery where feasible, but does not guarantee recovery and is not responsible for losses arising from unsupported asset deposits.
15.7. Protocol risk, forks, and non-supported derivatives
Users acknowledge that the Company does not control the underlying open-source protocols governing Digital Assets. Protocol upgrades, congestion, errors, or “fork” events may affect availability, functionality, or value. The Company may suspend affected services and may decide, at its discretion, whether to support one branch of a fork. The Company does not generally support derivative or auxiliary protocols (including “wrapped”, “coloured”, sidechain-based, or similar extensions) unless expressly stated.
15.8. Digital Asset Trading Facility
The Platform enables Users to buy and sell supported Digital Assets and to exchange Digital Assets against fiat or other Digital Assets, subject to availability of trading pairs and liquidity.
Users may trade using balances held in their wallet(s) with the Company.
Orders will not be accepted if the User’s available balance is insufficient to cover the order amount and applicable fees.
Execution is subject to market conditions and counterparty availability; the Company does not guarantee execution at a particular price or time.
15.9. Price formation and spreads
Prices displayed on the Platform may reflect prevailing market conditions, available order book liquidity, and applicable spreads. Users accept that buy and sell prices may differ at any given time.
15.10. Payment methods and settlement
Where fiat purchase or redemption is available, Users may use payment methods supported by the Company (e.g., bank transfer, cards, or other methods). Availability depends on jurisdiction, verification level, third-party provider constraints, and applicable law. Fiat settlements are subject to bank processing timelines.
15.11. Market makers and liquidity providers
The Company may engage one or more liquidity providers or market makers (including affiliates or third parties) to support orderly trading and liquidity. In connection with order placement and execution, relevant order flow data may be shared with such providers to enable liquidity provision, subject to applicable confidentiality and compliance controls.
15.12. Service changes and discontinuation of assets
The Company may add, suspend, or remove Digital Assets, trading pairs, or features due to regulatory, operational, security, or market reasons. Where a service or asset is discontinued, Users may be required to convert or withdraw the affected asset within a specified timeframe. If Users do not act within the communicated timeframe, the Company may take reasonable steps to close positions or convert holdings to supported assets, where permitted, without liability for market movements.
19. Risk Disclosure
19.1. General statement
Use of the Platform and all Digital Asset services is carried out at the User’s own risk. The Company does not guarantee the value, performance, or legal status of any Digital Asset and shall not be liable for losses resulting from market volatility, technological failure, or User decisions.
19.2. Regulatory status
The Company operates as a licensed Digital Asset Trading Facility and Custody Service Provider under the supervision of the Astana Financial Services Authority (AFSA) within the AIFC regulatory framework.
19.3. Key digital asset risks
Users acknowledge and accept, among others, the following risks:
Market volatility: Digital Asset prices can fluctuate rapidly and unpredictably, potentially resulting in substantial or total financial loss.
Liquidity risk: There is no assurance that sufficient market liquidity will exist to execute or close positions.
No legal tender protection: Digital Assets are not government-issued currency and are not protected by deposit insurance or investor compensation schemes.
Regulatory changes: Amendments to applicable laws or directives by AFSA or other authorities may affect the legality, availability, or value of Digital Assets.
Irreversible transactions: Blockchain-based transfers are generally final and cannot be reversed or recovered.
Operational and cybersecurity risk: The Company may experience system outages, cyber incidents, or network disruptions that may prevent Users from accessing or transferring assets.
Protocol risks and forks: Digital Asset protocols may change, split, or fork, which may impact usability or asset value. The Company may, at its discretion, support only selected protocol branches.
Counterparty risk: Trades occur between Users. The Company is not responsible for the financial stability or performance of counterparties.
Asset loss risk: The aggregate balance held in client wallets may not be sufficient to compensate Users in the event of unforeseen technical or operational failure.
19.4. User responsibility
The User is solely responsible for assessing the suitability of Digital Asset trading and custody in light of their own financial position, risk tolerance, and experience. The Company does not provide investment, financial, or legal advice.
19.5. No exhaustive list
This Section does not outline all potential risks. Users should conduct independent due diligence before engaging in Digital Asset transactions.
20. Limits and Operational Restrictions
20.1. Account access controls
The Company may suspend or restrict a User’s Account where necessary for security, compliance, or operational reasons, including in cases of:
repeated failed login attempts;
suspected unauthorised access;
breach of these Terms;
or any other event deemed high-risk by the Company’s internal compliance framework.
20.2. Transaction monitoring and restrictions
The Company may delay, refuse, or restrict deposits, withdrawals, or transfers of fiat or Digital Assets if:
User identity or bank account details cannot be verified;
required transaction information is incomplete or inaccurate;
AML/CFT alerts are triggered;
or the restriction is required under applicable AFSA regulations or internal compliance policy.
20.3. Risk-based onboarding tiers
Limits for Users, including legal entities, are assigned based on verification level, jurisdiction, and risk profile. These limits may be increased or reduced at the Company’s discretion.
20.4. Enhanced Due Diligence (EDD)
For higher transaction thresholds, the Company may require additional documentation, meetings, or verification. Costs of such checks may be charged to the User where permitted.
20.5. Objections and appeals
If a User believes that a restriction was applied in error, they may submit a request for review. The Company may restore access or limits once concerns are resolved.
21. Suspension and Termination of Services
21.1. User-initiated termination
A User may request closure of their Account at any time through the Platform interface or by contacting Customer Support. The Company may require a notice period of up to fourteen (14) days in order to complete outstanding compliance and settlement procedures.
21.2. Company-initiated suspension or termination
The Company reserves the right, at its sole discretion, to:
approve or reject any application for registration;
suspend, restrict, or permanently terminate a User’s Account and/or Wallet;
refuse or cancel any pending transaction;
or discontinue access to any part of the Services.
Such actions may be taken immediately, or with reasonable notice where feasible, if the Company determines that:
compliance with Applicable Law or AFSA regulation requires it;
the User has breached these Terms;
the integrity or security of the Account or Wallet is compromised;
there is suspicion of financial crime, fraud, sanctions exposure, or market abuse;
or where operational, technical, or risk-management considerations justify suspension.
The Company is not obliged to disclose the internal criteria used in reaching such decisions.
21.3. Transaction rejection for insufficient funds
The Company may decline to execute any transaction where the User’s wallet balance is insufficient to cover the requested transfer, fees, or taxes.
21.4. Prohibited use of Services
Users are strictly prohibited from using the Services in connection with:
financial crime, including money laundering or terrorist financing;
market manipulation or fraudulent trading activity;
unlawful goods or services, including controlled substances, weapons, or prohibited materials;
transactions that infringe intellectual property rights;
or any activity contrary to Applicable Law, public order, or AFSA regulations.
21.5. Notification of restrictions
Where not prohibited by law, the Company will notify the User of any suspension or termination of Services, including the reason for such action. Access may be restored once the underlying issue is resolved, but the Company is not required to execute transactions at prior market prices.
21.6. Effect of termination
Termination of an Account does not relieve either party of any outstanding financial, legal, or compliance obligations incurred prior to the termination date.
21.7. Settlement after termination
Following termination, all outstanding fees, liabilities, or obligations of the User become immediately due. The Company may deduct such amounts from the User’s remaining wallet balance, as permitted under Applicable Law.
21.8. Record retention and data handling
In accordance with AIFC and AFSA record-keeping requirements, the Company may retain User information and transaction records for a legally required period after Account closure. Personal Data will be handled in line with the Company’s Privacy Policy.
22. Communications and Notices
The Company may deliver official notices to Users through:
email to the most recently provided address;
written correspondence to the registered physical address;
or by posting an announcement on the Platform.
Such communications are deemed effective upon dispatch or publication.
27. Confidentiality
27.1. Definition of Confidential Information
For the purposes of this Agreement, “Confidential Information” means any non-public information relating to a party’s business, technology, operations, financial condition, organisational structure, or clients that is disclosed or made available in connection with the Services. Information shall not be considered confidential if it:
is already in the public domain without breach of this Agreement or applicable law;
is lawfully received from a third party without restriction;
is independently developed without use of such information; or
has been expressly approved for disclosure by the originating party.
27.2. User obligations
Users shall use the Company’s Confidential Information only for the purposes of accessing and using the Services and shall not disclose such information to any third party without the Company’s prior written consent.
27.3. Disclosure required by law
Where disclosure of Confidential Information is required by law, court order, or competent regulatory authority, the User must promptly notify the Company unless such notification is prohibited by law.
27.4. Return or destruction of information
Upon the Company’s request, the User shall securely return or destroy any Confidential Information received from the Company, including all copies and records derived from it.
27.5. Company confidentiality commitment
The Company shall treat all User data and account information as confidential, except where disclosure is necessary for regulatory, operational, or legal purposes.
27.6. Permitted disclosures by the Company
The Company may share User information, including personal and corporate data, with:
its directors, officers, employees, affiliates, auditors, and legal advisers;
regulated third-party service providers supporting the Services;
payment institutions and liquidity partners;
and AFSA or other competent authorities, where required to comply with applicable law or regulatory obligations.
In all cases, the Company ensures that recipients are subject to equivalent confidentiality standards.
27.7. User representations and indemnity
The User represents that all individuals and related parties whose data has been submitted to the Company have provided the necessary consent for such disclosure and processing. The User agrees to indemnify the Company against any losses arising from claims related to unauthorised disclosure of third-party information.
Governing Law
These Terms and Conditions, together with any related policies, shall be governed by and construed in accordance with the laws and regulations of the Astana International Financial Centre (AIFC).
Jurisdiction and Dispute Resolution
Any dispute, claim, or controversy arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the AIFC Court and the AIFC International Arbitration Centre, unless otherwise required by applicable law.
Regulatory Supremacy
In the event of any conflict between these Terms and applicable laws, regulations, or binding instructions issued by the Astana Financial Services Authority (AFSA) or any other competent authority, such laws, regulations, or instructions shall prevail.
Severability
If any provision of these Terms is found to be unlawful, invalid, or unenforceable, such provision shall be severed and the remaining provisions shall continue in full force and effect.
No Waiver
Failure or delay by the Company to exercise any right, remedy, or power under these Terms shall not constitute a waiver of such right, remedy, or power, nor shall any single or partial exercise prevent further exercise thereof.
1. Purpose and Application
1.1. These Terms of Use establish the legal framework governing the relationship between Delta DA Ltd. (the “Company,” “we,” “us,” or “our”) and any individual or legal entity accessing or using the Company’s services (the “User” or “you”). These Terms form an integral part of the User Agreement and define the rights, duties, and liabilities of both parties in connection with the use of the Company’s digital asset trading and custody platform.
1.2. By creating an account, accessing the Company’s website, or using any services, applications, or technical interfaces provided by the Company (collectively, the “Platform”), you confirm that you have carefully reviewed and accepted the User Agreement in full, including these Terms of Use, the Privacy Policy, the AML/KYC Policy, and any other referenced documents. The User Agreement represents the complete and binding agreement between you and the Company. If you do not agree with any part of these Terms, you must refrain from using the Platform and its services.
1.3. The Company operates as a regulated digital asset service provider within the Astana International Financial Centre (AIFC) and conducts its activities under the supervision of the Astana Financial Services Authority (AFSA). All services provided by the Company are subject to the applicable regulatory framework of the AIFC, including rules on digital asset trading, custody, client protection, and financial crime prevention.
1.4. You acknowledge that engaging in transactions involving digital assets, including their purchase, sale, transfer, or custody, may expose you to substantial financial risk. The value of digital assets may fluctuate significantly, and the loss of funds is possible. The Company strongly advises Users to assess whether the use of digital asset trading or custody services is appropriate for their financial situation, experience, and risk tolerance before proceeding.
2. Publication, Applicability, and Amendments
2.1. The Company ensures that these Terms of Use, the Privacy Policy, and any additional documents governing the provision of its services are made publicly available on the main page of the Company’s website and Platform. This enables Users to easily access and review the governing legal and compliance framework at any time.
2.2. The Company may revise, update, or correct any part of the User Agreement as necessary to remain aligned with the regulatory standards of the Astana International Financial Centre and the Astana Financial Services Authority, as well as other applicable laws and industry best practices.
2.3. Any updates to these Terms will be communicated to Users through an official notice published on the Platform or by other appropriate means. Each notice will state the date from which the revised provisions become effective. Unless otherwise required by regulation, changes shall become binding after a reasonable notification period. Where an update materially affects Users’ rights or obligations, or where no effective date is specified, the changes will take effect ten (10) calendar days after publication. The latest revision date will always be indicated at the beginning of the relevant document.
2.4. If a User does not agree with the revised Terms, they may discontinue use of the Platform and close their Account before the effective date of the update. Failure to object or terminate access prior to the effective date will be treated as acceptance of the amended Terms.
2.5. Continued access to or use of the Platform on or after the effective date of the changes constitutes the User’s acknowledgement and acceptance of the updated Terms. Users are responsible for reviewing the most current version of the User Agreement and raising any compliance or legal concerns in a timely manner.
2.6. Where a User declines to accept updated Terms that are necessary for the Company to maintain compliance with AFSA or AIFC regulations, the Company reserves the right to restrict, suspend, or terminate the User’s access to the Services and/or their Account.
3. Supplementary Policies and Guidance
3.1. In addition to these Terms of Use, the Company may publish separate operational, compliance, or informational documents on its Platform. These may include, without limitation, user manuals, fee schedules, technical guidelines, and frequently asked questions. Such materials form part of the overall User Agreement and are intended to provide Users with practical instructions on how to access and use the Company’s digital asset trading and custody services.
3.2. The Company may also publish notices identifying jurisdictions, individuals, or entities that are restricted or prohibited from accessing the Services, including those subject to international sanctions or regulatory limitations. These supplementary documents may further outline applicable service charges, taxes, minimum transaction thresholds, and other operational requirements.
3.3. Users are responsible for reviewing and understanding the most recent versions of all documents and policies issued by the Company. Continued use of the Platform constitutes the User’s acknowledgement that they have taken reasonable steps to stay informed of any such updates or changes.
4. Client Access and Compliance Requirements
4.1. Public areas of the Company’s Platform may be viewed without registration. However, access to trading, custody, and other regulated services is granted only to Users who have successfully completed the Company’s onboarding and verification process and have been approved for a User Account.
4.2. Any individual or legal entity applying to use the Company’s Services (the “Applicant”) must submit a registration request and provide all information and supporting documentation reasonably required by the Company to determine eligibility. Approval of an Account is at the sole discretion of the Company.
4.3. To qualify for access to the Services, the Applicant must meet the following minimum conditions:
be at least eighteen (18) years of age (for natural persons);
have the legal capacity and authority to enter into a binding agreement;
not be a resident, national, or entity established in any jurisdiction that is subject to international sanctions or regulatory restrictions, as determined by the Company’s internal AML/CFT framework;
submit all identification and corporate documentation requested for the purposes of “Know Your Customer” (KYC) and “Know Your Business” (KYB);
not be listed on, or associated with, any financial crime or sanctions watchlists;
confirm that the Account is opened and used solely for the Applicant’s own benefit and not for the account of third parties;
accept and comply with these Terms of Use and the Privacy Policy;
satisfy any other onboarding or compliance criteria the Company may implement to meet its regulatory obligations under AFSA and AIFC law.
4.4. Where the Applicant is a legal entity, it must designate one or more authorised representatives who are permitted to communicate with the Company, provide instructions, and manage the User Account on behalf of that entity.
4.5. The Applicant agrees to supply accurate, complete, and up-to-date information at all times. The Company may request personal and corporate data including, but not limited to, identification details, beneficial ownership structure, source of funds, and bank account information. The Company is required to retain and review such data in order to comply with its AML/CFT and financial crime prevention obligations.
4.6. The User must promptly notify the Company of any changes to their registration or verification details. The Company may verify or re-verify User information at any time, directly or through approved third-party providers. The User acknowledges that their data may be shared with regulatory, compliance, and financial crime prevention authorities when required by law.
4.7. Access to certain Services may depend on the User’s verification status, risk profile, and jurisdiction. The Company may impose or adjust operational restrictions and transaction limits in accordance with its internal risk management procedures.
4.8. The User is responsible for maintaining secure access to their Account and for safeguarding all authentication credentials and devices. The Company supports enhanced security measures including two-factor authentication. Failure by the User to ensure the security of their Account may result in loss of assets for which the Company shall not be liable.
5. Updating User Information
5.1. Users may access their account on the Platform at any time to review and update their personal or corporate information using the procedures provided by the Company. Where necessary, Users may also submit requests for changes through the Company’s Customer Support.
5.2. The User is solely responsible for ensuring that all information provided to the Company remains accurate and up to date. The Company shall not be held responsible for any losses, delays, or service restrictions arising from the User’s failure to promptly update or notify the Company of changes to their information.
6. User Account Administration and Security
6.1. The Company may refuse or restrict the use of any User name or account designation that it reasonably considers misleading, inappropriate, or in conflict with legal or regulatory requirements. This includes, without limitation, cases where the account name may cause confusion with another individual or organisation, violate the rights of third parties, or suggest affiliation with the Company or its partners.
6.2. Each User Account is issued for the exclusive use of the approved User and is not transferable. Where the User is a legal entity, only its authorised representatives may access and manage the Account on its behalf, subject to the Company’s verification and compliance procedures.
6.3. The User is responsible for safeguarding all credentials and security tools used to access their Account, including passwords, authentication codes, and electronic devices. Users must not disclose or share their access details with unauthorised third parties. The User bears full legal and financial responsibility for any actions taken through their Account by individuals they have authorised.
6.4. The Company is entitled to rely on any instructions or transactions carried out through a validly authenticated Account session. The Company is not obliged to independently verify the authority of the person accessing the Account, and all such actions shall be deemed to have been made by the User unless the Company is formally notified otherwise.
6.5. If a User becomes aware of any unauthorised access, loss, theft, or compromise of their Account credentials, they must immediately notify the Company’s Customer Support. The Company may, at its discretion, suspend or limit access to the affected Account to protect Users and maintain compliance with its regulatory obligations.
6.6. The Company shall not be liable for any loss of digital assets or funds that results from the User’s failure to maintain proper security over their Account, devices, or authentication details.
6.7. Each User must ensure that their authorised representatives fully understand and comply with these Terms. The User remains responsible for all actions carried out by such representatives on the Platform.
6. User Account Governance
6.1. The Company reserves the right to refuse or restrict the use of any account name or identifier that may be misleading, inappropriate, infringe on third-party rights, or create a false impression of affiliation with the Company or any other entity.
6.2. User Accounts are strictly personal and non-transferable. Access and operation of a legal entity account may only be performed by its duly authorised representatives.
6.3. Users are solely responsible for maintaining the confidentiality and security of their account credentials, devices, and authentication methods. Any activity conducted through an authenticated session will be deemed valid and binding upon the User.
6.4. The Company is entitled to rely on instructions provided through a User Account and shall not be required to verify the authority of the individual accessing the Account.
6.5. Users must immediately notify the Company if their account credentials are compromised. The Company may suspend or restrict access to protect Users and maintain regulatory compliance.
6.6. The Company shall not be liable for any loss resulting from the User’s failure to maintain adequate account security.
7. Data Protection and Privacy
7.1. The Company processes all User data in accordance with its Privacy Policy and applicable AIFC and AFSA regulations.
7.2. Users confirm that they have obtained all necessary consents from their shareholders, directors, beneficial owners, and authorised representatives before submitting their personal or corporate data to the Company.
7.3. The User indemnifies the Company against any claims arising from the unlawful disclosure or misuse of third-party personal data.
8. Responsibilities of the Company
8.1. The Company will use commercially reasonable efforts to ensure the availability, reliability, and security of the Platform.
8.2. The Company maintains appropriate technical and organisational measures to protect User data and digital assets in compliance with AFSA regulatory requirements.
8.3. The Company shall address all valid User complaints in a fair and transparent manner.
9. User Conduct and Prohibited Activities
9.1. Users must comply with all applicable laws and must not misuse the Platform.
9.2. The following actions are strictly prohibited:
using the Platform for unlawful, fraudulent, or deceptive purposes;
acting on behalf of undisclosed third parties;
providing false or misleading information;
attempting to manipulate markets or pricing;
breaching cybersecurity safeguards or bypassing security controls;
introducing malicious software or engaging in system abuse;
scraping, harvesting, or collecting data without authorisation;
using the Company’s name, trademarks, or branding without permission;
engaging in any conduct that could harm the Company’s operations, clients, or reputation.
9.3. Any breach of these obligations may result in immediate suspension or termination of the User’s Account, and the Company may report such activity to AFSA or other competent authorities.
Corporate Transaction Oversight
9.4. Legal entity accounts may be subject to additional due diligence, monitoring, and operational limits depending on their risk profile, jurisdiction, and transaction behaviour. The Company reserves the right to increase, reduce, or suspend such limits at any time.
13. Regulated Digital Asset Services
This Section describes the core services provided by Delta DA Ltd. through its licensed digital asset platform.
13.1. Scope of Services
The Company may provide one or more regulated digital asset services to Users, subject to the laws and regulations of the Astana International Financial Centre and the Astana Financial Services Authority.
13.2. Digital and Fiat Wallet Services
The Company offers Users a secure digital wallet environment, enabling the holding, transfer, and management of supported digital assets and fiat currency balances.
13.3. Digital Asset Trading Facility
The Platform allows Users to place orders and execute trades in supported digital assets. The Company facilitates transactions between Users but does not issue or guarantee the value of any digital assets.
13.4. Digital Asset Conversion and Exchange
Users may exchange one digital asset for another or trade digital assets against fiat currency at prevailing market rates. Applicable network, platform, and regulatory fees may apply.
13.5. Service Availability
The Company aims to provide continuous access to the Platform, subject to scheduled or emergency technical maintenance.
13.6. Service Suspension and Termination
The Company may restrict or suspend access to any service where required for operational stability, compliance, security, or regulatory reasons, including:
maintenance or technical upgrades;
system malfunction or force majeure;
suspected financial crime or sanctions violations;
market disruption or cybersecurity risk;
or where required under AFSA regulations.
The Company shall not be responsible for any losses incurred by Users resulting from such suspensions or restrictions.
14. Use of the Platform
14.1. Deposits of Fiat Currency
Users may deposit fiat funds into the Company’s designated bank account. The Company maintains internal records of such balances for each User. Deposited fiat funds do not accrue interest for the benefit of the User.
14.2. Deposits of Digital Assets
Users may also deposit supported digital assets into their wallet. Once received, these assets will appear in the User’s account balance.
14.3. Placing Orders
Users may submit buy or sell orders only through the Company’s Platform interface and must maintain sufficient wallet balances to cover the transaction and applicable fees.
14.4. Order Execution
Orders are matched and executed automatically based on available counterparties. Once executed, transactions are final and binding.
14.5. Withdrawals and Transfers
Fiat withdrawals may only be made to a verified bank account held in the User’s name.
Digital asset withdrawals may only be made to approved external wallet addresses.
The Company may require additional verification before processing large or unusual transfers.
14.6. Accuracy of Payment Details
Users are fully responsible for ensuring that any bank or wallet address submitted for withdrawals is correct. The Company shall not be liable for losses resulting from incorrect transfer details provided by the User.
14.7. Regulatory and AML Checks
Prior to processing withdrawals or transfers, the Company may conduct compliance and risk reviews in line with its AML/KYC obligations.
14.8. No Investment Advice
The Company does not provide financial, tax, or investment advice. Users are solely responsible for their trading decisions and any resulting gains or losses.
14.9. Transaction Disputes
Users must report any unauthorised or disputed transactions within 30 calendar days. The Company may investigate and resolve such claims in accordance with its compliance procedures.
14.10. Market Disruption and Exceptional Circumstances
In cases of severe market volatility, regulatory intervention, cybersecurity risk, or force majeure, the Company may suspend trading, reject new orders, or settle open positions as necessary. The Company shall not be liable for losses resulting from such measures.
15. Custody and Trading Services
15.1. Custody models
The Company provides custody of supported Digital Assets using one or more custody arrangements, which may include:
in-house custody, where Digital Assets are held in wallets forming part of the Company’s infrastructure; and/or
third-party custody, where the Company engages regulated or professional custody technology/providers.
In all cases where the Company is recognised as custodian for Users, the Company remains responsible for applying appropriate security and control measures consistent with its regulatory obligations.
15.2. Private keys and security
The Company controls and secures the cryptographic keys necessary to administer custody wallets. Key management may use a combination of offline and online safeguards and access controls designed to reduce risks of unauthorised access and loss.
15.3. Withdrawals and irreversibility
Users may request withdrawals of Digital Assets by providing an external wallet address. Users must carefully verify transaction details prior to submission. Once a withdrawal is broadcast to the relevant blockchain network, it is generally irreversible and cannot be recalled.
15.4. Fees and charges
Withdrawals and trading activity may be subject to:
blockchain/network fees (including “gas” where applicable),
platform trading and transfer fees,
banking commissions for fiat movements,
and taxes (including VAT where applicable).
Where feasible, applicable charges will be shown to the User at or before confirmation of the relevant transaction.
15.5. Compliance-based restrictions
The Company may delay, reject, suspend, or cancel a transaction (including withdrawals) if:
required by applicable law or a competent authority;
the transaction triggers AML/CFT alerts or sanctions-related concerns;
additional verification or Enhanced Due Diligence is required; or
operational security controls deem the transaction high-risk.
15.6. Supported assets only
Custody, transfers, and trading are available only for Digital Assets and fiat currencies explicitly supported by the Company from time to time. Users must not attempt to deposit, store, or transfer unsupported assets to the Company’s wallet infrastructure. The Company may attempt to assist recovery where feasible, but does not guarantee recovery and is not responsible for losses arising from unsupported asset deposits.
15.7. Protocol risk, forks, and non-supported derivatives
Users acknowledge that the Company does not control the underlying open-source protocols governing Digital Assets. Protocol upgrades, congestion, errors, or “fork” events may affect availability, functionality, or value. The Company may suspend affected services and may decide, at its discretion, whether to support one branch of a fork. The Company does not generally support derivative or auxiliary protocols (including “wrapped”, “coloured”, sidechain-based, or similar extensions) unless expressly stated.
15.8. Digital Asset Trading Facility
The Platform enables Users to buy and sell supported Digital Assets and to exchange Digital Assets against fiat or other Digital Assets, subject to availability of trading pairs and liquidity.
Users may trade using balances held in their wallet(s) with the Company.
Orders will not be accepted if the User’s available balance is insufficient to cover the order amount and applicable fees.
Execution is subject to market conditions and counterparty availability; the Company does not guarantee execution at a particular price or time.
15.9. Price formation and spreads
Prices displayed on the Platform may reflect prevailing market conditions, available order book liquidity, and applicable spreads. Users accept that buy and sell prices may differ at any given time.
15.10. Payment methods and settlement
Where fiat purchase or redemption is available, Users may use payment methods supported by the Company (e.g., bank transfer, cards, or other methods). Availability depends on jurisdiction, verification level, third-party provider constraints, and applicable law. Fiat settlements are subject to bank processing timelines.
15.11. Market makers and liquidity providers
The Company may engage one or more liquidity providers or market makers (including affiliates or third parties) to support orderly trading and liquidity. In connection with order placement and execution, relevant order flow data may be shared with such providers to enable liquidity provision, subject to applicable confidentiality and compliance controls.
15.12. Service changes and discontinuation of assets
The Company may add, suspend, or remove Digital Assets, trading pairs, or features due to regulatory, operational, security, or market reasons. Where a service or asset is discontinued, Users may be required to convert or withdraw the affected asset within a specified timeframe. If Users do not act within the communicated timeframe, the Company may take reasonable steps to close positions or convert holdings to supported assets, where permitted, without liability for market movements.
19. Risk Disclosure
19.1. General statement
Use of the Platform and all Digital Asset services is carried out at the User’s own risk. The Company does not guarantee the value, performance, or legal status of any Digital Asset and shall not be liable for losses resulting from market volatility, technological failure, or User decisions.
19.2. Regulatory status
The Company operates as a licensed Digital Asset Trading Facility and Custody Service Provider under the supervision of the Astana Financial Services Authority (AFSA) within the AIFC regulatory framework.
19.3. Key digital asset risks
Users acknowledge and accept, among others, the following risks:
Market volatility: Digital Asset prices can fluctuate rapidly and unpredictably, potentially resulting in substantial or total financial loss.
Liquidity risk: There is no assurance that sufficient market liquidity will exist to execute or close positions.
No legal tender protection: Digital Assets are not government-issued currency and are not protected by deposit insurance or investor compensation schemes.
Regulatory changes: Amendments to applicable laws or directives by AFSA or other authorities may affect the legality, availability, or value of Digital Assets.
Irreversible transactions: Blockchain-based transfers are generally final and cannot be reversed or recovered.
Operational and cybersecurity risk: The Company may experience system outages, cyber incidents, or network disruptions that may prevent Users from accessing or transferring assets.
Protocol risks and forks: Digital Asset protocols may change, split, or fork, which may impact usability or asset value. The Company may, at its discretion, support only selected protocol branches.
Counterparty risk: Trades occur between Users. The Company is not responsible for the financial stability or performance of counterparties.
Asset loss risk: The aggregate balance held in client wallets may not be sufficient to compensate Users in the event of unforeseen technical or operational failure.
19.4. User responsibility
The User is solely responsible for assessing the suitability of Digital Asset trading and custody in light of their own financial position, risk tolerance, and experience. The Company does not provide investment, financial, or legal advice.
19.5. No exhaustive list
This Section does not outline all potential risks. Users should conduct independent due diligence before engaging in Digital Asset transactions.
20. Limits and Operational Restrictions
20.1. Account access controls
The Company may suspend or restrict a User’s Account where necessary for security, compliance, or operational reasons, including in cases of:
repeated failed login attempts;
suspected unauthorised access;
breach of these Terms;
or any other event deemed high-risk by the Company’s internal compliance framework.
20.2. Transaction monitoring and restrictions
The Company may delay, refuse, or restrict deposits, withdrawals, or transfers of fiat or Digital Assets if:
User identity or bank account details cannot be verified;
required transaction information is incomplete or inaccurate;
AML/CFT alerts are triggered;
or the restriction is required under applicable AFSA regulations or internal compliance policy.
20.3. Risk-based onboarding tiers
Limits for Users, including legal entities, are assigned based on verification level, jurisdiction, and risk profile. These limits may be increased or reduced at the Company’s discretion.
20.4. Enhanced Due Diligence (EDD)
For higher transaction thresholds, the Company may require additional documentation, meetings, or verification. Costs of such checks may be charged to the User where permitted.
20.5. Objections and appeals
If a User believes that a restriction was applied in error, they may submit a request for review. The Company may restore access or limits once concerns are resolved.
21. Suspension and Termination of Services
21.1. User-initiated termination
A User may request closure of their Account at any time through the Platform interface or by contacting Customer Support. The Company may require a notice period of up to fourteen (14) days in order to complete outstanding compliance and settlement procedures.
21.2. Company-initiated suspension or termination
The Company reserves the right, at its sole discretion, to:
approve or reject any application for registration;
suspend, restrict, or permanently terminate a User’s Account and/or Wallet;
refuse or cancel any pending transaction;
or discontinue access to any part of the Services.
Such actions may be taken immediately, or with reasonable notice where feasible, if the Company determines that:
compliance with Applicable Law or AFSA regulation requires it;
the User has breached these Terms;
the integrity or security of the Account or Wallet is compromised;
there is suspicion of financial crime, fraud, sanctions exposure, or market abuse;
or where operational, technical, or risk-management considerations justify suspension.
The Company is not obliged to disclose the internal criteria used in reaching such decisions.
21.3. Transaction rejection for insufficient funds
The Company may decline to execute any transaction where the User’s wallet balance is insufficient to cover the requested transfer, fees, or taxes.
21.4. Prohibited use of Services
Users are strictly prohibited from using the Services in connection with:
financial crime, including money laundering or terrorist financing;
market manipulation or fraudulent trading activity;
unlawful goods or services, including controlled substances, weapons, or prohibited materials;
transactions that infringe intellectual property rights;
or any activity contrary to Applicable Law, public order, or AFSA regulations.
21.5. Notification of restrictions
Where not prohibited by law, the Company will notify the User of any suspension or termination of Services, including the reason for such action. Access may be restored once the underlying issue is resolved, but the Company is not required to execute transactions at prior market prices.
21.6. Effect of termination
Termination of an Account does not relieve either party of any outstanding financial, legal, or compliance obligations incurred prior to the termination date.
21.7. Settlement after termination
Following termination, all outstanding fees, liabilities, or obligations of the User become immediately due. The Company may deduct such amounts from the User’s remaining wallet balance, as permitted under Applicable Law.
21.8. Record retention and data handling
In accordance with AIFC and AFSA record-keeping requirements, the Company may retain User information and transaction records for a legally required period after Account closure. Personal Data will be handled in line with the Company’s Privacy Policy.
22. Communications and Notices
The Company may deliver official notices to Users through:
email to the most recently provided address;
written correspondence to the registered physical address;
or by posting an announcement on the Platform.
Such communications are deemed effective upon dispatch or publication.
27. Confidentiality
27.1. Definition of Confidential Information
For the purposes of this Agreement, “Confidential Information” means any non-public information relating to a party’s business, technology, operations, financial condition, organisational structure, or clients that is disclosed or made available in connection with the Services. Information shall not be considered confidential if it:
is already in the public domain without breach of this Agreement or applicable law;
is lawfully received from a third party without restriction;
is independently developed without use of such information; or
has been expressly approved for disclosure by the originating party.
27.2. User obligations
Users shall use the Company’s Confidential Information only for the purposes of accessing and using the Services and shall not disclose such information to any third party without the Company’s prior written consent.
27.3. Disclosure required by law
Where disclosure of Confidential Information is required by law, court order, or competent regulatory authority, the User must promptly notify the Company unless such notification is prohibited by law.
27.4. Return or destruction of information
Upon the Company’s request, the User shall securely return or destroy any Confidential Information received from the Company, including all copies and records derived from it.
27.5. Company confidentiality commitment
The Company shall treat all User data and account information as confidential, except where disclosure is necessary for regulatory, operational, or legal purposes.
27.6. Permitted disclosures by the Company
The Company may share User information, including personal and corporate data, with:
its directors, officers, employees, affiliates, auditors, and legal advisers;
regulated third-party service providers supporting the Services;
payment institutions and liquidity partners;
and AFSA or other competent authorities, where required to comply with applicable law or regulatory obligations.
In all cases, the Company ensures that recipients are subject to equivalent confidentiality standards.
27.7. User representations and indemnity
The User represents that all individuals and related parties whose data has been submitted to the Company have provided the necessary consent for such disclosure and processing. The User agrees to indemnify the Company against any losses arising from claims related to unauthorised disclosure of third-party information.
010000,Astana,Nura district,50/3,Turan,office NP-5
© 2026 Delta DA
