Terms of Use for
CinCin Services

These Terms of Use for CinCin Services (“Terms”) govern your access to and use of the services provided by CinCin, including but not limited to those available through our Telegram bot and any other officially designated platforms or communication channels (“Platform(s)”), as determined by CinCin from time to time.

1. Entering into the Terms and their Scope

The Terms govern the provision of CinCin services to the Client, enabling the Client to send and receive services provided by CinCin.

By accessing or using the Bot or any associated services, you agree to be legally bound by these Terms, as well as any additional policies, terms, or notices presented to you. If you do not agree with these Terms, do not access or use the Services.

These Terms constitute a legally binding agreement between you (“User,” “you,” or “your”) and CinCin (“CinCin,” “we,” “us,” or “our”). You are encouraged to review these Terms periodically, as CinCin reserves the right to amend them at any time in accordance with Section 10 below.

These Terms apply to both individual and business users unless explicitly stated otherwise.

By using CinCin services, the Client agrees to these Terms. 

These Terms apply to both individual and business users unless explicitly stated otherwise.

The Client is encouraged to carefully review the Terms. If any provision is unclear or requires clarification, the Client should contact CinCin for further information.

It is recommended that the Client print or download a copy of the Terms and Fees for future reference. The latest version of the Terms is always available on the Bot.

2. Definitions

Authentication Tool — authentication mobile app, or combination of static password and one-time password, used for Client authentication or verification of the application of payment instrument.

Business Day – any day other than a Saturday or a Sunday or a public or bank holiday, or any other holiday previously announced by CinCin.

Bot – the official Telegram-based (@CinCinX_bot) conversational interface operated and maintained by CinCin for the purpose of providing Services to Users.

Platform(s) – any other official digital interface, website, application, or communication environment expressly designated by CinCin for the delivery of the Services.

Services – any and all functionalities, products, tools, and operations made available by CinCin through the Bot or the Platform, including but not limited to: cryptocurrency asset exchange, card purchase functionality, balance storage, and any ancillary services as may be offered from time to time.

User or Client – any natural or legal person who accesses, interacts with, or otherwise utilizes the Services, either directly or indirectly.

AML (Anti-Money Laundering) – procedures aimed at detecting, preventing, and reporting suspicious financial activity. CinCin implements AML measures via engagement with external qualified service providers.

Third-Party Service Provider – any external service provider, subcontractor, or technology platform engaged by CinCin while delivering or enabling the Services, including but not limited to providers of technical infrastructure, payment processing, analytics, and AML checks. The technical and functional operation of the Services relies on a number of integrated third-party service providers, including but not limited to:

• Telegram API (messaging interface),

Restricted Territories – means jurisdictions where Users are either prohibited or restricted from accessing the Services.

Digital Asset – means a digital representation of value, including but not limited to cryptocurrency, virtual currency, token, or other cryptographically secured units of account, transferable via blockchain or similar technology.

Card – any virtual or physical payment card made available to the User by or through CinCin via authorized issuance partners, subject to separate terms and conditions, if applicable.

Customer Service – CinCin customer service, which the Client can reach by sending a message to in Telegram support @cincin_support or the email ​​support@cincin.exchange or other indicated on the Bot or mobile application. Support services, compliance verification, and the review of any requests are carried out strictly during CinCin’s business hours, as indicated on the Bot (7:00 – 22:00 CET). Business hours may be periodically updated, and Clients are responsible for reviewing the latest information on the Bot.

Fees – the charges payable by the Client to CinCin for using CinCin services, available on the price section of the Bot/in the Bot.

Parties — the CinCin and the Client.

CinCin – digital assets services provider Sonder INC, a company incorporated under the laws of Republic of the Marshall Islands , with its registered office at Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960, registration number 130414. 

Terms – the Terms published on the Bot that may be amended from time to time.

3. Services Provided

CinCin provides Users with access to certain digital asset-related functionalities via its Telegram-based bot interface and other officially designated Platforms (collectively, the “Services”). The scope of the Services includes, but is not limited to, the following:

3.1 Exchange Functionality

Users may exchange supported virtual assets using the interface provided by CinCin. The exchange function is accessible directly within the Bot and allows Users to initiate and complete asset conversion transactions, subject to applicable fees and service conditions specified within the interface.

3.2 Card Purchase

CinCin offers Users the ability to purchase virtual and/or physical payment cards (the “Card Services”) via authorized third-party issuers. Card issuance, delivery, activation, and usage are subject to additional terms and conditions, and may vary depending on the User’s location and applicable restrictions. CinCin facilitates access to such services and communicates relevant pricing and procedures via the Bot at the time of transaction.

3.3 Wallet-Like Functionality

Although CinCin does not provide custodial wallet services or host on-chain wallets, Users are enabled to interact with internal balances linked to Services such as card purchase, virtual asset exchange, and transaction settlement. These balances are managed in accordance with third-party infrastructure and settlement processes and are not to be construed as formal e-wallets under applicable financial regulation.

3.4 Transaction Execution

All transactions initiated through the Services are processed via integrated third-party infrastructure. Upon execution of a transaction, the relevant order is considered final and binding. The User is solely responsible for verifying all input details prior to submission. CinCin reserves the right to refuse or reverse any transaction in the event of suspected breach of these Terms or applicable law.

3.5 Know-Your-Customer (KYC) and Anti-Money Laundering (AML)

CinCin does not independently perform KYC verification for Users. However, CinCin maintains and enforces anti-money laundering (AML) procedures in cooperation with authorized third-party providers. Transactional behavior may be monitored, and certain activity may be subject to enhanced due diligence or restrictions under applicable AML obligations.

CinCin reserves the right to deny or restrict access to the Services where required to comply with its AML obligations, or in the event that a User’s activity is deemed suspicious, inconsistent with applicable law, or otherwise incompatible with the integrity of the Platform.

CinCin reserves the right to modify or replace its compliance providers at any time without prior notice, provided that such changes do not reduce the overall level of AML protection required under applicable laws.

4. Third-Party Services and Integrations 

In order to ensure the stable and lawful provision of its Services, CinCin relies on a range of third-party service providers, platforms, and technological infrastructure partners. These Third-Party Providers are engaged to enable key functionalities, compliance controls, operational processes, and transaction execution within the CinCin ecosystem.

The User acknowledges and agrees that the use of the Services inherently involves the technical and legal engagement of such Third-Party Providers, and that certain aspects of the Services may be subject to their respective terms of use and policies, as referenced below.

4.1 Core Infrastructure and Functional Integrations

CinCin integrates and relies on the following third-party technologies for the operation of its Platform:

Telegram API – used as the primary messaging and user interface layer. All interactions between the User and CinCin are conducted via the Telegram messenger infrastructure. CinCin does not control the operation, availability, or security of the Telegram platform itself and disclaims any liability arising from its malfunction, suspension, or unauthorized access.

Card Issuer (Third-Party) – Payment cards offered via the CinCin platform are issued and managed by a licensed third-party card issuer. CinCin acts solely as a facilitator of access to such cards and does not itself issue, store, or manage payment cards or associated balances. The relationship between the User and the card issuer is subject to the issuer’s separate terms and policies, which the User is required to accept at the point of card order or activation.

4.2 Scope of Responsibility and Disclaimers

While CinCin endeavors to select reputable and industry-recognized Third-Party Providers, it makes no warranty, express or implied, as to the uninterrupted availability, security, or legal compliance of any such external service. The Services are provided on an “as-is” and “as-available” basis, and CinCin shall not be held liable for:

• any technical failure, downtime, error, or delay caused by Third-Party Providers;
• any direct or indirect loss or damage incurred as a result of the failure or conduct of a Third-Party Provider;

Users are advised to review the applicable terms of use and privacy policies of any Third-Party Provider referenced herein. The use of any functionality enabled by such third parties shall be deemed subject to such terms.

CinCin reserves the right to change, replace, or remove any Third-Party Provider at its sole discretion, with or without notice, provided such change does not materially degrade the availability or security of the Services.

5. User Registration and Data 

5.1 Absence of Account Registration

CinCin does not require traditional user account registration or the creation of login credentials. Users may access and interact with the Services directly through the CinCin Telegram bot by initiating a conversation and selecting available functionalities. There is no requirement to set a username, password, or user profile. Access to the Services is session-based and limited to the communication interface provided by Telegram or other officially designated Platforms.

5.2 Minimal Data Collection

In the course of providing the Services, CinCin collects and processes only the minimum data necessary to enable technical functionality, service delivery, and compliance with applicable regulations. The categories of data collected may include:

• Telegram user ID and username;
• Email address (if voluntarily submitted by the User when ordering a card or other product);
• Telephone number (optional);
• IP address and device information (e.g., device type, operating system);
• Technical metadata and event logs related to service interactions and transactional activity;
• Card-related activity (e.g., balance, transaction history, where applicable).

CinCin does not require or request the submission of official identity documents or passwords to access standard Services, except in cases expressly provided for by applicable law.

5.3 Verification and Risk Control

No formal verification is conducted. However, CinCin reserves the right to collect limited identifying information if required for compliance purposes, fraud prevention, or under applicable laws. Additionally, certain transactional behaviors may trigger automated anti-money laundering (AML) monitoring, as described in the Terms above.

5.4 Privacy and Data Handling

All personal and technical data collected in connection with the Services are processed in accordance with CinCin’s Privacy Policy, which forms an integral part of these Terms. CinCin acts as a data controller in relation to user data and implements appropriate technical and organizational measures to protect such data against unauthorized access, alteration, disclosure, or destruction.

The User acknowledges and agrees that certain categories of data may be shared with Third-Party Service Providers strictly for the purposes of delivering the Services, performing compliance-related checks, and ensuring system functionality. Such third parties include, but are not limited to, Telegram (messaging platform).

CinCin does not sell or otherwise commercialize user data.

5.5 Consent and Limitation of Liability

By using the Services, the User consents to the collection and limited transfer of data as described above. CinCin shall not be liable for any unauthorized access or breach arising from vulnerabilities outside its reasonable control, including those attributable to Telegram or other integrated platforms.

Users are encouraged to refrain from submitting any unnecessary personal data while using the Services.

6. Fees and Execution of Transactions

6.1 Service Fees

CinCin provides its Services subject to fees applicable to specific transaction types, including but not limited to digital asset exchanges, card issuance, and withdrawal operations. The User agrees to pay all such fees as presented within the CinCin Bot interface at the moment of confirming the relevant action (the “Service Fee”). All fees are displayed in a transparent manner prior to execution, and the User must confirm them explicitly before proceeding. CinCin does not charge any hidden or retroactive fees.

6.2 Indicative Price and Volatility Notice

The price displayed for the exchange of digital assets (the “Price”) at the time of the User’s request reflects the current indicative rate. Due to the inherently volatile nature of digital asset markets, the Price displayed at the initiation of a transaction may differ from the final execution rate. CinCin does not guarantee the stability or persistence of any Price quoted within the Bot.

6.3 Final Price and Execution

The final rate applied to the transaction (the “Final Price”) shall be the one displayed in the Bot interface immediately prior to the User’s confirmation. By confirming the transaction, the User authorizes CinCin and/or its integrated service providers to execute the transaction at the Final Price and to deduct the applicable Service Fee.

Once confirmed, the transaction shall be processed as soon as reasonably practicable. Until actual execution, any transaction request shall be considered pending and non-binding. CinCin shall not be liable for any fluctuation, loss, or discrepancy caused by processing delays, technical latency, or blockchain-related delays.

6.4 Delivery and Confirmation

Upon execution, CinCin shall deliver a transaction confirmation to the User via the Bot, including the Final Price, the amount exchanged or disbursed, and any fees deducted. In the case of card issuance or fiat withdrawal, CinCin will forward the transaction request to the respective partner platform (e.g., card issuer), and settlement will be subject to third-party processing times and systems.

6.5 Transaction Irreversibility

The User acknowledges that all executed transactions are final, non-cancelable, and non-reversible, including those involving digital assets, fiat payout, or card-related Services. CinCin is under no obligation to amend, revoke, or refund any transaction once confirmed by the User, regardless of error, change of intention, or price fluctuation. Notwithstanding the foregoing, CinCin may, at its sole discretion and without any obligation, consider a User’s cancellation request, provided the transaction has not yet been executed.

6.6 Wallet Ownership

For any transaction involving external delivery (e.g., receipt of digital assets), the User represents and warrants that the wallet address or payment destination provided is fully owned and controlled by the User. CinCin shall not be responsible for verifying the legal ownership of any address submitted, nor for losses resulting from the use of incorrect, compromised, or unauthorized wallet addresses.

6.7 Right to Refuse Processing

CinCin reserves the right to decline, cancel, or delay the execution of any transaction at any time, without liability, if:

• required to do so by law, regulation, or order of a competent authority;
• the transaction is suspected to violate these Terms, AML rules, or applicable legal requirements;
• the transaction exceeds internal volume or frequency limits;
• the transaction, in CinCin’s sole discretion, poses a reputational, financial, legal, or technical risk.

CinCin may take additional protective measures, including freezing or suspending a transaction pending further review.

6.8 User Responsibility

The User remains fully and solely responsible for ensuring that sufficient funds are available to cover the full value of the transaction and associated fees. CinCin may decline to execute any transaction if insufficient funds are detected at the time of confirmation. In no event shall CinCin be liable for any indirect or consequential loss resulting from failed or delayed processing.

6.9. No Refund Policy

Fees paid for completed Services (e.g., successful exchange, card issuance, withdrawal) are non-refundable. The User shall have no right to claim reimbursement unless otherwise required by applicable law or unless the transaction was not executed due to a technical failure attributable to CinCin.

7. User Conduct and Prohibited Use

7.1 Lawful Use Obligation

By accessing or using the Services, the User agrees to comply with all applicable laws, regulations, and rules in their country of residence, as well as those governing the use of virtual assets, payment services, and digital platforms internationally.

The Services may only be used for lawful purposes and in a manner consistent with these Terms. Any use of the Services for, or in connection with, criminal, fraudulent, or unauthorized activities is strictly prohibited.

7.2 Prohibited Activities

The User shall not use the Services, directly or indirectly, to engage in, support, promote, or facilitate any of the following activities (non-exhaustively):

• Money laundering, terrorist financing, or violation of anti-money laundering (AML) laws;
• Fraud, extortion, identity theft, or unauthorized access to third-party accounts;
• Transactions involving child exploitation, violence, hate crimes, or unlawful content;
• Unlicensed gambling, betting, or lottery services;
• Trade in prohibited goods or services, including to send or receive payments for goods or services related to child exploitation, violent or hate-related content, weapons and firearms, unlicensed gambling, counterfeit or copyright-infringing goods, tobacco products, subscription-based services with automatic renewals requiring negative response cancellations, services exceeding one year in length, direct marketing schemes relying on unclaimed incentives (“breakage”), multilevel marketing, unauthorized supply chain manipulation (“up supplying”), grey market transactions exploiting regulatory loopholes, telemarketing services (both inbound and outbound), reverse auctions, raffles, prize draws, pyramid schemes, and any services that facilitate illegal activities, environmentally destructive businesses, trade in protected species, counterfeit goods, religious organizations, unlicensed money transfer services (such as Hawala), bearer share companies, unregulated businesses requiring licenses, pyramid or Ponzi schemes, conflict diamond trading, adult content (including live streams, webcams, and offensive material), boiler room frauds, land banking, carbon trading, political parties, offshore banks, businesses involved in adult entertainment, illegal drug paraphernalia, and entities associated with terrorism, such as Al-Qaida, the Taliban, and those listed under the Justice for Victims of Corrupt Foreign Officials Act. CinCin reserves the right, at its sole discretion, to expand this list;
• Use of third-party payment instruments or wallets without legal ownership or authorization;
• Tampering with or attempting to circumvent AML screening systems, transaction controls, or service limitations;
• Use of automated tools, bots, or exploits to manipulate the Services or infrastructure.

It is the Client’s and not CinCin responsibility to ensure that the Client only sends payments to or receive payments from persons or entities for the sale or supply of goods and services that the Client may provide or receive in compliance with any applicable laws and regulations. The mere fact that a person or entity accepts payments through CinCin is not an indication of the legality of the supply or provision of their goods and services. If the Client is in doubt as to the legality of a supply or purchase, the Client should not continue with the Client’s payment. It is the Client’s and not CinCin responsibility to ensure account details are entered correctly to avoid payment errors and any charges.

7.3 Restricted Territories

CinCin does not provide Services to Users located in, or otherwise associated with, countries or territories subject to comprehensive international sanctions, embargoes, or financial restrictions.

Access to the Services is explicitly prohibited for Users who are citizens, residents, or located in any of the following jurisdictions (collectively, the “Restricted Territories”):

CinCin does not offer, market, or provide its crypto-related Services to individuals or entities who are citizens, residents, or located in the jurisdiction where such limitation is required by local law, regulation, or directive of a competent regulatory authority. Specifically:

United Kingdom: CinCin and its technology and compliance partners are not registered with or authorized by the Financial Conduct Authority (FCA). CinCin does not cooperate with an FCA-approved entity and therefore is not permitted to market or provide crypto services to UK residents. This measure is intended to ensure compliance with the UK’s Financial Services and Markets Act 2000 (as amended), as well as the FCA’s regime for cryptoasset promotions effective from 2023.

United Arab Emirates (UAE): CinCin does not hold a license from the Virtual Assets Regulatory Authority (VARA) or any other UAE federal or emirate-level regulator. In light of the UAE’s mandatory licensing requirements for virtual asset service providers (VASPs), and in order to mitigate regulatory and enforcement risks, CinCin does not offer services to Users residing in or accessing the Services from the UAE. Chin Chin does not promote, market, or offer any virtual asset services within the territory of the United Arab Emirates (UAE). Any references to Chin Chin found on social media or in third-party materials are not intended as public promotion in the UAE. Users located in the UAE are strictly prohibited from accessing or using the Services.

Japan: The Japanese Financial Services Agency (JFSA) requires all virtual currency exchange service providers to register and comply with extensive licensing and reporting obligations under the Payment Services Act and related legislation. CinCin is not registered with the JFSA and therefore does not serve Japanese residents or citizens.

United States of America: CinCin is not registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN) and does not hold any state-level licenses within the United States. In accordance with FinCEN requirements and applicable state laws, the provision of crypto-related services without proper registration is prohibited. As such, CinCin does not offer or promote its Services to U.S. residents or persons located within the territory of the United States.

Other Jurisdictions: CinCin reserves the right to restrict or discontinue the provision of its Services in any other jurisdiction where such limitation is required by local law, regulation, or directive of a competent regulatory authority.

In addition CinCin does not offer access to its Services – including card issuance, or withdrawal functionality – to Users who are located in, residents of, or using documentation issued in the following jurisdictions: Iran, North Korea, Syria, Venezuela, Russia, Afghanistan, Belarus, Cuba, Myanmar, Somalia, and Ukraine.

The Client may not use CinCin services if the Client is residing in any of the countries of FATF blacklist, OFAC Sanctions List and other countries mentioned in various sanction lists or in recommendations of regulating authorities against cooperation. This list is not exhaustive and CinCin may decide in its sole discretion to discontinue or restrict CinCin’s services in other countries at any time and without prior notice.

Furthermore, Users whose names appear on any official list of sanctioned individuals or entities—including but not limited to the U.S. Specially Designated Nationals (SDN) list or the EU Consolidated Sanctions List—are strictly prohibited from using the Services.

By using the Services, the User represents and warrants that THEY ARE NOT LOCATED IN A RESTRICTED TERRITORY, are NOT SUBJECT TO ANY SANCTIONS OR TRADE RESTRICTIONS, AND ARE NOT ACTING ON BEHALF OF ANY SANCTIONED ENTITY OR INDIVIDUAL.

CinCin reserves the right to deny access, suspend transactions, or permanently restrict Service availability to any User or region at any time where it reasonably believes such action is necessary to comply with applicable laws or internal risk policy.

8. Limitations of Liability 

8.1 General Disclaimer & Right to Conduct Scheduled or Unscheduled Technical Maintenance

To the maximum extent permitted by applicable law, the Services are provided on an “as is” and “as available” basis. CinCin makes no express or implied representations, warranties, or guarantees regarding the availability, reliability, performance, or accuracy of the Services or any content, transaction, or data provided via the Bot or Platform.

Chin Chin reserves the right to conduct scheduled or unscheduled technical maintenance, upgrades, or system improvements, which may result in temporary interruptions, partial unavailability, or suspension of access to the Services. Chin Chin shall not be held liable for any delays, missed opportunities, or financial losses resulting from such periods of downtime.

The User should carefully evaluate their financial situation, technical understanding, and tolerance for risk prior to using Chin Chin.

Use of the Services is at the User’s sole risk.

8.2 Limitation of Liability for User Actions

CinCin shall not be held liable for any damages, losses, or liabilities arising out of:

• the User’s failure to comply with these Terms or any applicable law or regulation;
• incorrect input, execution, or authorization of transactions by the User (including errors in asset amounts, addresses, or instructions);
• misuse or abuse of the Services;
• unauthorized access to the Services as a result of the User’s failure to secure their Telegram account or device;
• the User’s use of the Services in violation of any restriction set out in Terms.
• The User is solely responsible for verifying all transaction details and ensuring lawful use of the Services.

8.3 Limitation of Liability for Third-Party Services

CinCin integrates with various independent third-party providers to deliver the Services (as described in Terms), including but not limited to: Telegram  and the card issuer.

• CinCin shall not be liable for:
• service disruptions, malfunctions, or errors caused by such third-party providers;
• delays, losses, or damages resulting from third-party actions, omissions, or system failures;
• any breach of data protection, privacy, or contractual obligations by third-party platforms;
• suspension or deactivation of User access due to third-party risk or compliance decisions.

Use of any third-party service in connection with the Services is at the User’s own risk and subject to the terms and conditions of the relevant provider.

8.4 Technical Interruptions and Force Majeure

(a) No Guarantee of Uninterrupted Service

CinCin does not provide, and expressly disclaims, any representation, warranty, or guarantee that the Services will operate without interruption, delay, or error. The nature of the Services—including their reliance on third-party infrastructures, APIs, and distributed networks—means that disruptions may occur beyond CinCin’s control. The User expressly acknowledges that such disruptions do not constitute a breach of these Terms.

(b) Telegram Platform Dependency

As the Services are primarily delivered via Telegram bot interface, CinCin is inherently dependent on the continuous availability, operability, and accessibility of the Telegram platform. Any limitation, suspension, degradation, or termination of Telegram’s services, policies, infrastructure, or availability—whether due to internal Telegram policies, government blocking, denial-of-service attacks, or regional restrictions—may result in partial or complete unavailability of CinCin’s Services.

CinCin shall not be held liable for any inability to access the Services arising from Telegram-related failures or limitations, including:

• Suspension or deletion of the CinCin Telegram bot;
• Regional blocks or IP restrictions affecting Telegram traffic;
• Device-level incompatibility or user-side misconfiguration;
• Delays in Telegram API response time or message delivery failures.

(c) Third-Party Infrastructure and Service Providers

CinCin does not assume responsibility for the continued operability, commercial availability, or uninterrupted performance of these services. Technical errors, misconfigurations, or disruptions within these platforms may cause service outages, transaction delays, or loss of functionality.

(d) Blockchain Network Factors

For Services involving cryptocurrency exchange or blockchain-based operations, CinCin does not control the underlying networks. Delays in block confirmation, chain reorganization, or network congestion may affect the speed, reliability, or finality of transactions. CinCin shall not be liable for:

• Missed exchange rates due to delayed execution;
• Failed or orphaned blockchain transactions;
• Gas fee fluctuations or priority-based delays;
• Failure to complete a transaction due to network unavailability.

(e) Force Majeure Events

CinCin shall not be liable for any failure or delay in the performance of its obligations if such failure or delay results from events, circumstances, or causes beyond its reasonable control (“Force Majeure Events”). These include, without limitation:

• Acts of God, natural disasters, severe weather conditions;
• Armed conflict, civil unrest, terrorism, or sabotage;
• National emergency, martial law, or military actions;
• Pandemic, epidemic, or quarantine restrictions;
• Regulatory intervention, government orders, embargoes, or sanctions;
• Failure of third-party telecommunications, hosting, DNS services, or power supply;
• Labor disputes, strikes, or lockouts (not involving CinCin personnel);
• Zero-day vulnerabilities or security incidents outside CinCin’s infrastructure;
• Legal prohibitions or revocation of necessary regulatory permissions.

Where a Force Majeure Event occurs:

CinCin shall be excused from the performance of its obligations under these Terms to the extent and for the duration that performance is prevented, hindered, or delayed.

CinCin shall use reasonable commercial efforts to mitigate the effects of the Force Majeure Event and to resume operations as soon as practicable.

The User shall not be entitled to compensation, refund, or damages for any resulting delay, suspension, or termination of Services.

(f) Pending Transactions During Interruption

If a User initiates a transaction prior to or during a period of technical interruption or Force Majeure, CinCin cannot guarantee its execution, finality, or correctness. In such circumstances:

• Transactions may remain pending until systems are restored;
• Transactions may be cancelled by CinCin for operational or risk reasons;
• Exchange rates or terms applicable at the time of initiation may no longer be valid;
• Card orders or withdrawals may be delayed or declined.

(g) No Service-Level Agreement (SLA)

CinCin does not provide any specific uptime guarantee or Service-Level Agreement. The Services are offered on a best-effort basis. Users accept that technical availability is dependent on a complex ecosystem of distributed services and that short-term or extended interruptions may occur.

8.5 Indirect and Consequential Damages

To the fullest extent permitted by law, CinCin shall not be liable for any indirect, incidental, special, punitive, or consequential damages of any kind, including but not limited to:

• loss of revenue, profit, goodwill, or business opportunity;
• loss of data or digital assets;
• reputational harm or inability to access Services.

9. Termination of Use 

9.1 Termination by the User

The User may at any time discontinue use of the Services by submitting a written request to CinCin via official communication channels, namely:

• direct support via the Telegram bot; or
• email sent to the designated CinCin support address.

Such request must clearly identify the User’s Telegram ID or email address associated with any prior Service interactions. CinCin reserves the right to request additional information or identity confirmation to prevent unauthorized or fraudulent termination requests.

Upon successful verification, CinCin will proceed to deactivate the User’s access to the Services. However, CinCin shall not be obligated to delete or return any data, transaction history, or Service output unless required by applicable law. Any obligations incurred by the User prior to termination, including fees, transaction errors, or suspected violations, shall survive termination and remain enforceable.

No refund or compensation shall be issued for terminated use initiated by the User, and CinCin shall not be liable for any loss of access, opportunity, or funds related to such termination.

9.2 Termination or Suspension by CinCin

CinCin reserves the unrestricted right to suspend, limit, or permanently terminate the User’s access to any or all Services, with or without notice, at its sole discretion, and without any obligation to provide justification, particularly in the following scenarios:

(a) Technical or Operational Grounds:

• Service maintenance or decommissioning of technical infrastructure;
• Withdrawal of the Bot from Telegram or replacement of Platform architecture;
• Disruption or loss of functionality due to third-party provider actions;
• Migration, redesign, or termination of business model or Services.

(b) Legal, Regulatory, or Policy-Based Grounds:

• Required compliance with any applicable law, court order, administrative directive, sanction, embargo, or regulatory restriction;
• Enforcement of contractual obligations with licensed partners, payment providers, or compliance vendors;
• Detection of potentially unlawful or unauthorized use of the Services.

(c) User Misconduct or Breach:

• Violation of these Terms, including but not limited to Section 7 (Prohibited Use);
• Use of Services for fraudulent, abusive, misleading, or deceptive purposes;
• Attempted circumvention of security mechanisms or AML controls;
• Impersonation, false declarations, or use of fake or spoofed accounts.

(d) Risk-Based Internal Discretion:

• Detection of high-risk transactional behavior, including patterns indicative of sanctions violations, obfuscation, or “smurfing”;
• Reports or alerts from third-party AML services or infrastructure partners;
• Prior violations of CinCin’s terms in any capacity or through associated Telegram IDs or email addresses.

CinCin shall not be liable to the User or any third party for any damages, claims, losses, or costs arising from or in connection with such suspension or termination, including, without limitation, lost profits, lost access, or expected outcomes of pending transactions.

9.3 Consequences of Termination

Upon termination (whether initiated by the User or CinCin):

• The User shall immediately cease all use of the Services;
• CinCin may cancel, suspend, or block any pending or unconfirmed transactions;
• CinCin shall have no obligation to return, recover, or re-execute transactions or instructions lost due to termination;
• CinCin may retain any personal data, transactional logs, and communication metadata in accordance with its Privacy Policy, internal compliance program, and applicable data retention laws;
• The User shall remain liable for any amounts due, regulatory investigations arising from their use, or damage caused to CinCin’s systems, business, or reputation.

Re-access to the Services following termination is strictly prohibited unless explicitly permitted in writing by CinCin. CinCin reserves the right to reject any future access attempts by the same User or affiliated Telegram IDs, email addresses, or devices.

9.4 Finality and No Right to Appeal

The User explicitly agrees that CinCin shall have the unilateral right (but not obliged) to terminate or restrict access to the Services without advance notice or formal dispute resolution process, and without obligation to explain the underlying rationale, where necessary to protect the legal, commercial, or reputational interests of CinCin.

All such decisions shall be final, and CinCin shall not be required to restore access or provide any form of compensation, unless otherwise mandated by law.

10. Amendments 

10.1 Right to Amend

CinCin reserves the right, at its sole discretion, to amend, modify, supplement, or replace these Terms, in whole or in part, at any time and without the obligation to obtain prior consent from the User. Such amendments may be introduced to reflect changes in:

• the scope or nature of the Services;
• applicable laws, regulations, or licensing requirements;
• technological infrastructure or third-party integrations;
• risk management or internal policies;
• commercial terms, pricing, or business model.

Amendments may include changes to legal definitions, new or revised obligations, limitations of liability, jurisdiction, or other material provisions.

10.2 Notification Procedure

CinCin will notify Users of any material amendments to these Terms by delivering an in-bot message or automated notice through the CinCin Telegram Bot or other official communication channels used by the User (e.g., system message, email if provided). CinCin may additionally make updated versions of the Terms available via hyperlinks within the Bot or via a designated public repository.

The User acknowledges and agrees that:

• such notice constitutes sufficient and effective delivery of amendments;
• it is the User’s responsibility to monitor system notifications and to review the Terms periodically;
• CinCin is not required to provide individualized, personalized, or legally certified notice of changes.

10.3 Effective Date of Amendments

Unless otherwise explicitly stated in the notice, all amendments shall become effective immediately upon publication or the date specified in the update notice (“Effective Date”).

Continued access to or use of the Services after the Effective Date shall constitute full and irrevocable acceptance of the amended Terms by the User.

If the User does not accept the amended Terms, their sole and exclusive remedy is to discontinue the use of the Services and submit a termination request pursuant to Section 9.

CinCin shall not be liable for any loss, disruption, or expectation damages incurred by the User as a result of amendments to these Terms or the exercise of its termination rights in accordance therewith.

11. Governing Law and Dispute Resolution

11.1 Governing Law

These Terms, and any dispute, claim, or controversy arising out of or in connection with them or the use of the Services (whether in contract, tort, equity, or otherwise), shall be governed by and construed in accordance with the laws of England, without regard to its conflict of law rules.

The User acknowledges that CinCin is not established or licensed in all jurisdictions and that the applicability of certain consumer protection or financial regulations may be limited based on CinCin’s jurisdiction of incorporation and operation.

11.2 Mandatory Informal Dispute Resolution

Before initiating formal proceedings, the User agrees to attempt to resolve any issue or dispute by first contacting CinCin’s support team via the official support channels (email or Telegram). CinCin shall have up to thirty (30) calendar days to review and respond to such claim in good faith.

11.3 Arbitration Agreement

Subject to the informal resolution procedure above, any dispute, controversy, or claim arising out of or in connection with these Terms, including the validity, breach, termination, or enforceability thereof, shall be finally settled by arbitration under the Rules of the London Court of International Arbitration (LCIA), which rules are deemed to be incorporated by reference into this clause.

The number of arbitrators shall be one (1).

The seat or legal place of arbitration shall be London, United Kingdom.

The language of the arbitration shall be English.

The governing law of the arbitration agreement and the arbitration proceedings shall be the laws of England and Wales.

The decision and award rendered by the arbitrator shall be final and binding upon both parties and may be enforced in any court of competent jurisdiction.

11.4 Class and Collective Action Waiver

To the fullest extent permitted under applicable law, all claims shall be brought in the parties’ individual capacity, and not as a plaintiff or class member in any purported class, collective, representative, or group proceeding. The User expressly waives any right to bring or participate in a class action or class arbitration against CinCin.

11.5 Injunctive and Interim Relief

Nothing in this section shall prevent either party from seeking urgent injunctive or equitable relief in the courts of England and Wales to preserve the status quo or prevent irreparable harm, pending the outcome of arbitration.

12. No Custody / No Wallet Ownership Disclaimer

12.1 CinCin Is a Technical Interface

CinCin provides access to certain functionalities—such as asset exchange, card issuance, and payment initiation—through a conversational interface delivered via the Telegram platform and other officially designated channels (the “Bot”). CinCin acts solely as a non-custodial technical interface that facilitates interactions with third-party service providers and payment channels.

CinCin does not offer, operate, or maintain any form of:

• hosted wallet or custodial account;
• user-owned blockchain wallet infrastructure;
• safekeeping or direct storage of digital assets or fiat currency.

All transactions executed through the Bot are conducted via third-party platforms and service providers. CinCin does not take possession of, store, or directly transfer funds or digital assets on behalf of Users.

12.2 No Access to Private Keys or Wallet Balances

CinCin does not generate, request, store, or control any private keys, seed phrases, or wallet credentials associated with blockchain-based accounts. The User acknowledges that:

• any wallet address used in connection with the Services is provided and controlled solely by the User or third-party providers (e.g., card issuer, payment processor);
• CinCin cannot recover lost access to wallet addresses or reverse transactions once executed;
• CinCin cannot monitor or guarantee the availability or balances of any User-controlled wallets.

The User is solely responsible for the security, confidentiality, and accuracy of their wallet addresses and transaction details.

12.3 No Fiduciary Relationship

CinCin does not act as a custodian, trustee, fiduciary, agent, or escrow provider in any capacity. Nothing in these Terms or in the use of the Services shall be interpreted as creating any fiduciary duty or trust obligation between CinCin and the User.

12.4 Third-Party Payment Channels

Where Users access balance-related functionality (e.g., topping up a card, exchanging assets, checking a service-related balance), such balances are recorded and maintained by external financial institutions, payment processors or card issuers under their own terms and conditions. CinCin has no control over such balances, and shall not be held liable for:

• delays in settlement;
• loss of funds held by a third party;
• failure or insolvency of external payment providers;
• account freezes or regulatory seizure of balances outside CinCin’s control.

12.5 Finality of Transactions

All transactions facilitated through the Bot or Platform are final and irreversible once executed. CinCin cannot intervene to reverse or modify executed instructions, nor can it provide guarantees regarding settlement timeframes or outcomes.

13. Risk Disclosure

13.1 Acknowledgment of Risk

By accessing or using the Services, the User expressly acknowledges and accepts the inherent risks associated with transactions involving digital assets, including cryptocurrencies, tokens, and blockchain-based instruments.

Such risks include, but are not limited to:

• Price Volatility: The value of digital assets may fluctuate significantly and unpredictably over short periods of time. Prices may rapidly increase or decrease, and CinCin does not guarantee any particular value at any time.
• Irreversibility: Transactions executed via blockchain networks or third-party payment systems are generally irreversible. Once submitted, transactions cannot be cancelled, withdrawn, or modified.
• Technology Risks: Transactions may be delayed, rejected, or lost due to failures in network connectivity, third-party service outages, smart contract vulnerabilities, or blockchain malfunctions.
• Regulatory Risk: The legal status of digital assets varies across jurisdictions and may change without notice. Regulatory actions may impact the availability, legality, or functionality of the Services or associated third-party systems.
• Security Risk: While CinCin does not hold or control user funds, Users remain responsible for securing their wallets, private keys, devices, and Telegram account access credentials. Loss of such access may result in irreversible loss of assets.

13.2 No Guarantee

CinCin does not provide any warranty as to the availability, accuracy, or timeliness of rates, blockchain confirmations, card processing, or payment channels. The User assumes full responsibility for all outcomes resulting from the use of the Services.

The User should carefully evaluate their financial situation, technical understanding, and tolerance for risk prior to using CinCin.

14. No Financial Advice

The User acknowledges and agrees that:

• CinCin is not a licensed financial advisor, broker, asset manager, or investment firm under the laws of any jurisdiction;
• The Services provided via the Bot and Platform are offered strictly on a non-advisory, execution-only, and non-fiduciary basis.

No communication from CinCin, whether via the Bot, support channels, or related materials (including price quotes, currency comparisons, transaction examples, or automated suggestions) shall be construed as:

• financial, investment, or legal advice;
• a recommendation to buy, sell, hold, or use any particular digital asset or financial instrument;
• an endorsement of any external platform, payment system, exchange, or protocol.

All decisions made by the User in connection with the Services are made at their own discretion and sole risk. CinCin disclaims any and all liability for losses or damages incurred as a result of such decisions.

The User is strongly advised to consult their own independent legal, financial, and tax advisors before engaging in any activity involving digital assets.

15. Liability and Indemnification

If an unauthorized or incorrectly executed payment occurs due to an error by CinCin, the Client may request an immediate refund, including any fees deducted. However, this does not apply if:

• The Client fails to notify CinCin without undue delay after becoming aware of any security compromise affecting their CinCin, in which case the Client remains liable for losses incurred until notification is provided.
• The Client has compromised the security of their CinCin intentionally or through gross negligence, making them solely responsible for all resulting losses.
• The Client does not dispute the unauthorized or incorrect transaction within 12 months from the transaction date.

If a transaction occurs after the Client has notified CinCin (taking into account the reasonable time that the support service may need to prevent the risk) about a security compromise, CinCin remains liable and will refund any unauthorized transaction immediately.

Clients are advised to regularly check their transaction history and contact Customer Service if they have any concerns. In cases of incorrect or misdirected payments, CinCin will take reasonable measures to assist in tracing and recovering such payments.

The Client agrees to indemnify and hold CinCin harmless from any claims, expenses, or costs (including legal fees, fines, or penalties) arising from their breach of the Terms, applicable laws, or misuse of services. This obligation continues after the termination of the Client’s relationship with CinCin.

If the Client is a legal entity, the authorized officer(s) confirm they have full authority to act on behalf of the entity and acknowledge that CinCin must not be used for transactions related to:

• Sales under a different trade name or business affiliation than stated in the application.
• Any transactions that violate applicable laws, ordinances, or regulations.

16. Limitations of Financial Liability

CinCin’s financial liability to the Client is strictly limited unless otherwise required by applicable law. In no event shall CinCin be liable for any indirect, incidental, punitive, or consequential damages, including but not limited to loss of profits, business interruption, or reputational harm, even if the possibility of such damages was known.

CinCin’s liability for any claims related to the use of its services shall be limited to a maximum amount of the minimum amount established by applicable law..

If applicable law mandates a different liability standard, CinCin’s financial liability shall be limited to the minimum extent required by such law. CinCin does not assume liability for losses resulting from legal or regulatory changes, currency fluctuations, system outages, force majeure events, or third-party service providers’ actions beyond its control.

The Client acknowledges that CinCin is not responsible for the financial consequences of unauthorized transactions, errors, or losses arising from the Client’s failure to maintain data security, notify CinCin of suspicious activity, or comply with the Terms.

These limitations apply to the fullest extent permitted by applicable law and remain in effect after the termination of the Client’s relationship with CinCin.

CinCin is not liable for service disruptions or impairments caused by abnormal or unforeseeable circumstances beyond its control or those of its intermediaries, including errors, failures, malfunctions of software Kyrrex.

17. Force Majeure 

CinCin shall not be held liable for any failure or delay in performing its obligations under these Terms due to circumstances beyond its reasonable control, including but not limited to:

• Acts of God, natural disasters, earthquakes, floods, fires, hurricanes, or other extreme weather conditions.
• Pandemics, epidemics, public health emergencies, or government-imposed quarantines.
• War, military conflicts, invasions, hostilities (whether war is declared or not), terrorist attacks, civil unrest, riots, or protests.
• Strikes, labor disputes, industrial actions, or lockouts affecting CinCin or its service providers.
• Government actions, sanctions, embargoes, changes in laws, regulatory restrictions, or currency controls.
• Power failures, breakdown of infrastructure, transportation blockages, fuel shortages, or supply chain disruptions.
• Telecommunications or internet failures, system outages, cyberattacks, hacking, or other disruptions in digital infrastructure, including errors, failures, malfunctions of software,.
• Bank failures, payment system collapses, or insolvency of financial institutions affecting CinCin’s ability to process transactions.
• Freezing of accounts or assets due to regulatory orders, investigations, or court mandates.
• Any other event beyond CinCin’s reasonable control that prevents it from fulfilling its obligations.

In the event of a force majeure situation, CinCin shall make reasonable efforts to mitigate the impact on its services and resume normal operations as soon as possible. However, CinCin shall not be responsible for any losses, damages, or liabilities incurred by the Client due to such events. The Client acknowledges that interruptions caused by force majeure events may impact transactions, withdrawals, deposits, or other services without prior notice.

If a force majeure event continues for a prolonged period, CinCin reserves the right to suspend or terminate affected services without liability. Any obligations suspended due to force majeure shall be resumed once the force majeure event ceases, provided it is feasible.

These limitations apply to the fullest extent permitted by applicable law and shall remain in effect regardless of the duration or severity of the force majeure event.

18. Miscellaneous

Enforceability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a competent court or regulatory authority, the remaining provisions shall continue in full force and effect. Any unenforceable provision shall be replaced by a valid provision that reflects as closely as possible the original intent of the parties. If any part of the Terms and Conditions is found by a court of competent jurisdiction to be invalid, unlawful or unenforceable then such part shall be severed from the remainder of the Terms and Conditions, which shall continue to be valid and enforceable fully permitted by law.

Survival

Any obligations or rights under these Terms that by their nature should survive termination, including but not limited to disclaimers, limitations of liability, indemnities, confidentiality obligations, and dispute resolution provisions, shall continue to apply after the termination of the Client’s relationship with CinCin.

Assignment

The Client may not assign or transfer any of its rights or obligations under these Terms without CinCin’s prior written consent. CinCin may assign, transfer, or delegate its rights and obligations under these Terms to any affiliate, subsidiary, or third party without requiring prior consent from the Client. Such assignment will not affect the rights and obligations of the Client under these Terms.

These provisions ensure the continued enforceability of the Terms, the survival of key obligations, and the ability of CinCin to transfer its rights when necessary.

19. Contact and Support

CinCin provides user support exclusively through digital channels. Users may contact CinCin’s support team using one of the following official methods:

• Telegram Support: accessible via the official CinCin Bot interface;
• Email: support@cincin.exchange or another official address as may be designated by CinCin from time to time.

Support is available daily from 07:00 to 22:00 CET, but excluding weekends, public holidays or during periods of force majeure, technical maintenance, or system outages. Requests received outside of support hours will be processed on the next available working day.

CinCin does not offer support via telephone, social media, or unauthorized channels. Communications sent via unverified means shall not be considered valid or binding upon CinCin.

All inquiries should be submitted with sufficient detail to enable proper review. CinCin reserves the right to request additional information for verification or compliance purposes prior to responding to any request.

Users are responsible for monitoring their own communication tools (Telegram or email) and ensuring that messages sent by CinCin are not blocked, filtered, or ignored.