Terms of Service
UPDATED February 2026
Welcome to mantra.finance, a website-hosted Client interface (the “Site") that we provide to allow our Clients to access the various products, services and information that offered by MANTRA Finance FZE, a company incorporated under the laws of the Emirate of Dubai, with business address at The Offices 4 at One Central, Dubai World Trade Centre - Sheikh Zayed Rd - Trade Centre - Trade Centre 2 - Dubai - United Arab Emirates (“MANTRA Finance”, “we”, “us” or the “Firm”). These Terms of Service (the “Agreement”) form a legally binding agreement between you (“you” or the “Client”) and MANTRA Finance.
MANTRA Finance is a wholly owned subsidiary of MANTRA Tech Limited, whose registered address is at Unit 8, 3/F, Qwomar Trading Complex, Blackburne Road, Port Purcell, Road Town, Tortola, British Virgin Islands, VG1110.
MANTRA Finance is a licensed Virtual Asset Service Provider under the regulation of the Virtual Assets Regulatory Authority in Dubai (“VARA”). It is permitted to conduct the following licensed activities subject to the applicable license conditions:
● Exchange Services;
● Broker-Dealer Services; and
● Management and Investment Services.
MANTRA Finance has submitted an application to VARA for a Virtual Asset Issuance Licence. Subject to the grant of this licence, MANTRA Finance may, in accordance with the Virtual Assets Issuance Rulebook issued by VARA, issue Asset-Referenced Virtual Assets (“ARVAs”) which are intended to provide investors with economic exposure to a range of underlying asset classes, including, without limitation to, private credit, funds, real estates and commodities. MANTRA Finance will provide timely updates regarding the status of its licence application, as well as further information on any ARVAs or related products that may be offered. Such updates will be made available through amendments to this Agreement and/or through publications on the Site as appropriate.
The products and services prescribed under this Agreement are generally not available to, or accessible by, persons, entities or organizations in Hong Kong, the United States or any OFAC sanctioned countries and regions. MANTRA Finance is entitled to adjust the list of blocked regions for any or all of its products and services at any time in its discretion.
Introduction
This Agreement explains the terms and conditions by which you may access and use the Site. You must read this Agreement carefully. By accessing or using the Site, you signify that you have read, understand, and agree to be bound by this Agreement in its entirety as well as our Privacy Policy. If you do not agree, you are not authorized to access or use the Site and should not use the Site.
As noted under the heading “Governing Law” below, this Agreement is governed by the laws of the Emirate of Dubai. We have drafted this Agreement with the intention that our relationship with you will comply with all applicable laws and regulations in Dubai, including all applicable consumer protection laws. We undertake to you that we will comply with applicable laws, as well as our obligations to you under this Agreement, at all times. In addition, we further undertake that this Agreement, and our interactions with you under this Agreement, will comply with the general requirement to act honestly, fairly and in the best interests of our Clients and the integrity of the market. Lastly, we have drafted this Agreement to be fair, transparent, accurate and sufficiently clear to you and our personnel, having regarded to the nature of the services we offer and the intended market for such services.
Before we get into the specifics of this Agreement, it is important that you know and understand that the risk of loss in trading or holding virtual assets of any kind can be substantial. The value of virtual assets can fluctuate significantly and there can be a substantial risk that you incur loss by buying, selling, holding, or investing in virtual assets. By using the Site, you agree that none of MANTRA Finance, or any person or company associated with MANTRA Finance, will be liable or responsible in any way for any losses that you might suffer as a result of using the Site.
Responsible Individuals of MANTRA Finance FZE
Stephen Peepels - Chief Legal Officer - [email protected]
Sebastian Heine - Chief Compliance Officer - [email protected]
DISCLAIMER
MANTRA Finance cannot and does not guarantee the value of virtual assets. You acknowledge and agree that the value of virtual assets is highly volatile and that buying, selling, trading and the holding of virtual assets involves a high risk of loss. You should therefore carefully consider whether buying, selling, trading or holding virtual assets is suitable for you in light of your financial condition. You should also be aware that neither the virtual assets you hold, or any client money that you use to purchase or hold virtual assets on this site, benefit from any form of deposit protection by any government entity or government regulator. If you are unable to bear the financial risk of loss, please do not use or access the site. You agree that you are solely responsible for any virtual asset transactions and the use of the Site.
VARA has not made any representation and does not provide any warranties regarding any issuer or virtual asset including, but not limited to, their fitness for purpose, suitability or regulatory status in any jurisdiction other than the emirate of Dubai, UAE.
Public Disclosures
MANTRA Finance is committed to the highest levels of transparency and probity in line with the regulatory framework established by VARA. The main purpose of our public disclosures is to ensure that clients and other relevant parties have access to timely, accurate, and complete information regarding our services, performance, and adherence to regulatory standards.
To provide a comprehensive overview, we maintain a separate “Regulatory Disclosures & Risk Warnings” which is publicly available on the Site and contains detailed information, including but not limited to:
Our VARA License information and the scope of our licensed activities.
A comprehensive Risk Disclosure Statement outlining the material risks associated with virtual assets.
Links to key policies, including our Data Privacy, Whistleblowing, and Client Complaint Handling procedures.
Specific disclosures related to our Broker-Dealer and other licensed services, as required by VARA.
We encourage you to read this document carefully to fully understand our services and the associated risks. If we need to communicate with you directly regarding any matter, we will do so using the email address you have provided to us.
We will communicate with you through the email address you provide during registration for all account-specific and legal notices, including changes to this Agreement. We may also provide general notices and announcements through the Site and other official social media channels listed on our Site. You are responsible for keeping your email address up to date and regularly checking all official communication channels for updates.
USE OF SERVICES
Eligibility
To access or use the Site, you must be able to form a legally binding contract with us. Accordingly, you represent that you are at least the 21 years of age, or the age of majority in your jurisdiction (whichever is greater) and have the full right, power, and authority to enter into and comply with the terms and conditions of this Agreement on behalf of yourself and any company or legal entity for which you may access or use the Site.
You further represent that you are not (i) the subject of economic or trade sanctions administered or enforced by any governmental authority or otherwise designated on any list of prohibited or restricted parties (including but not limited to the list maintained by the Office of Foreign Assets Control of the U.S. Department of the Treasury) or (ii) a citizen, resident, or organized in a jurisdiction or territory that is the subject of comprehensive country-wide, territory-wide, or regional economic sanctions by the United States or any governmental authority. Finally, you represent that your access and use of the Site will fully comply with all applicable laws and regulations, and that you will not access or use the Site to conduct, promote, or otherwise facilitate any illegal activity.
To use the Site, you will need to provide various personal information as explained below. We may, at our sole discretion, refuse to provide services to you if we are not satisfied with our ability to properly identify you.
Identity Verification
You agree to provide us with all information we request for the purposes of verifying your identity and for the detection of third-party payments, money laundering, terrorist financing, fraud, or any other type of financial crime, and permit us to keep a record of such information indefinitely. You will be required to complete certain verification procedures before you are permitted to use our services. Your access to one or more of our services, and the limits that apply to your use of these services, may be altered because of information collected on an ongoing basis. The information we request may include certain personal information, including, but not limited to, your full name, your registered address, your registered telephone number (fixed or mobile), your valid email address, your date of birth, your taxpayer identification number, your government identification number or your passport number.
In providing us with this or any other information that may be required by us for verification purposes, you confirm that the information you provide us is accurate and true. You agree to keep us updated if any of the information you provide us changes. You authorize us to make any necessary inquiries, whether directly or through third parties, that we deem necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take any action we reasonably deem appropriate and necessary based on the results of such inquiries. When we carry out these inquiries, you acknowledge and agree that your personal information may be disclosed to fraud prevention or financial crime agencies, and that these agencies may respond to our inquiries in full. Additionally, we may require you to wait a certain period after completion of a transaction, before permitting you to further use our services and/or before permitting you to engage in transactions beyond certain limits.
Compliance, Legal Disclosures, and Engagement with Authorities
Disclosure to Authorities: You acknowledge and agree that MANTRA Finance is committed to full compliance with all applicable laws and regulations in the United Arab Emirates. We reserve the right to share or disclose your personal information, transactional data, or any other information we hold to competent governmental, regulatory, law enforcement, or tax authorities. This may be done to comply with applicable laws, regulations, court orders, legal processes, or other official requests, and we may do so with or without prior notice to you.
Engagement with UAE Financial Intelligence Unit (FIU): MANTRA Finance is registered as a Reporting Entity to the UAE Central Bank FIU for the purposes of submitting informational reports relating to the suspected or actual use of our services to facilitate any financial crime. We are committed to our engagement with the FIU and in our fight against money laundering and terrorism financing. You agree that we have no obligation to notify you of any information we provide to the FIU in relation to your use of the Site and/or our services.
Virtual Asset Transactions
We will process virtual asset transactions in accordance with the instructions we receive from you. You should verify all transaction information prior to submitting the instructions to us. We do not guarantee the identity of any Client, receiver, requester or other parties. Virtual asset transactions cannot be reversed once they have been broadcast to the relevant virtual asset blockchain.
Once submitted to the relevant virtual asset blockchain, a virtual asset transaction will be unconfirmed for a period of time pending sufficient confirmation of the transaction by the virtual asset blockchain. A virtual asset transaction is not complete while it is in a pending state. Virtual assets associated with transactions that are in a pending state will be designated accordingly and will not be included in your account balance or be available to conduct virtual asset transactions with.
By initiating a virtual asset transaction, you agree to pay all applicable fees related to the transaction including, but not limited to service fees, conversion fees or blockchain network fees.
We reserve the right to refuse to process, or to cancel or reverse (where applicable), any transaction of virtual assets at our sole discretion, including, but not limited to, instances where we suspect the transaction involves (or has a high risk of involvement in) a third party payment, money laundering, terrorist financing, fraud, or any other type of unlawful activity, in response to a subpoena, court order, or other government order, or if we suspect the transaction is unlawful or violates any other clause of this Agreement.
Supported Virtual Assets
Our virtual asset services are only available in connection with those virtual assets that we support, which may change from time to time. Under no circumstances should you attempt to use your account to store, send, request, or receive virtual assets in any form that we do not support. We assume no responsibility or liability in connection with any attempt to use your account for virtual assets that we do not support.
Forks and Airdrops
Forks and Airdrops (together “Network Events”) may affect the features, functions, operation, use or other properties of any virtual asset, network or platform. Network Events may result in multiple versions of a virtual asset (each a “New Virtual Asset”) and could lead to the dominance of one or more such versions (each a “Dominant Virtual Asset”) and the partial or total abandonment or loss of value of any other versions of such virtual asset (each a “Non-Dominant Virtual Asset”). MANTRA Finance is not obliged to support any Network Event, including any New Virtual Asset, Dominant Virtual Asset or Non-Dominant Virtual Asset resulting from such Network Event. MANTRA Finance will assess the impact of any Network Event with commercially reasonable efforts as soon as practically possible upon becoming aware of the occurrence, nature and impact of such Network Event. If we decide, at our sole discretion, to support a Network Event, we will make a public announcement through the Site or otherwise notify the Clients.
For the purposes of this Agreement,
“Fork” means changes in operating rules of the underlying protocols of a virtual asset that may result in more than one version of that virtual asset or other material changes in the value, function, and/or the name of a virtual asset; and
“Airdrop” means a distributed or attempted distribution where an address that holds a virtual asset receives or is allocated a certain amount of the same or another virtual asset.
Your Security Responsibilities
As the Site offers purely non-custodial services, you are solely responsible for the custody and security of your cryptographic private keys and seed phrases for the virtual asset wallets you use. To help you protect your assets, we strongly recommend that you:
Use strong, unique passwords for your accounts and devices.
Enable two-factor authentication (2FA) on your MANTRA Finance and wallet associated email accounts.
Never share your private keys, seed phrases, or passwords with anyone, including MANTRA Finance staff. We will never ask for this information.
Store your seed phrases and private keys securely offline. Do not store them on a device that is connected to the internet.
Be vigilant against phishing and spoofing attacks. Always verify that you are on the official MANTRA Finance website before entering any information.
You acknowledge that failing to follow these security best practices may result in the loss of or unauthorized access to your virtual assets, for which MANTRA Finance bears no responsibility.
3. OUR SERVICES
Listing Virtual Assets
MANTRA Finance is committed to conducting comprehensive due diligence on all virtual assets prior to listing any new virtual asset. Our team will thoroughly assess each virtual asset against our internal standards which address key considerations around market metrics, design features, regulatory posture, security properties, and more.
Listing Request
MANTRA Finance accepts requests to list a new asset through either the Firm’s internal business development team or external projects that wish to list their tokens on MANTRA Finance. All requests are routed through the same team to ensure proper documentation and analysis of the asset before moving to the assessment stage.
To apply for listing, an applicant is required to submit a comprehensive listing form and provide detailed and truthful information about the project and the token, which include, but is not limited to:
Project information (Project name, founders, team, official website)
Company Structure
Token Information (token name & symbol, contract address, tokenomics)
Product offering description (background, github code repo, stage of development)
Commercial details (token sale, cashflow forecast)
Assessment
MANTRA Finance will conduct assessment on the virtual asset from multiple aspects before approving or rejecting its listing application, which include, but are not limited to:
Regulatory classification (e.g. registered security, commodity, approved for trading) and approvals in major jurisdictions;
Compliance with regulations in jurisdiction(s) of issuance and any bans/limitations imposed by countries due to sanctions;
Technology audit assessments of security, privacy and decentralization level;
Risks related to anonymity, control by a single entity and ability to monitor transactions;
Previous regulatory or legal actions against developers, exchanges, or restrictions on advertising;
Economic model and inherent risks flagged in research reports or whitepapers;
Considerations like legal tender status, government backing, and adequacy of KYT/AML protocols;
Classification for tax purposes in primary economies and global sanctions compliance; and
Ongoing monitoring of regulatory waivers, changes in legal status, or classification trends worldwide.
On-going Review
After a virtual asset is approved to be listed on the Site, MANTRA Finance will conduct continual monitoring of the virtual asset including its status of compliance with applicable regulations. The Firm will notify the issuer of the virtual asset if any event has occurred that may affect the listing status of the virtual asset on MANTRA Finance. If MANTRA Finance determines that a virtual asset is no longer suitable to be listed on its Site, it may suspend or cancel the listing of such virtual asset in its sole discretion with notifications provided to its clients and VARA as required under applicable laws and regulations.
Client Assets
MANTRA Finance is a non-custodial platform, which means client assets are in their own custody and they can withdraw from the investments at any time subject to the terms and conditions applicable to the relevant services. A Client’s assets remain legally owned by the Client until:
when utilizing Broker-Dealer Services offered by MANTRA Finance, the Client executes a transaction and transfers its assets to the counterparty to settle such transaction; and
when utilizing the Management and Investment Services offered by MANTRA Finance, the Client subscribes to an investment management scheme or product (e.g. staking related products) and transfers its assets to MANTRA Finance which represent the subscription proceeds.
Upon such transfers, the Client no longer holds the legal title to the relevant assets. And such assets no longer constitute Client VAs or Client Money as defined under VARA’s Compliance and Risk Management Rulebook.
All transactions can be referenced on-chain, and transparent product updates are made to the customers for tracking purposes.
Execution Criteria
MANTRA Finance will consider multiple factors when executing an order for the Client, which include, but are not limited to:
the characteristics of the Client order (such as the size and type of the transaction and the terms and conditions of the order);
the characteristics of virtual assets that are the subject of that order (e.g., price, spreads, volatility, relative liquidity, and pressure on communications);
the characteristics and number of the execution venues to which that order can be directed or other sources of liquidity checked; and
accessibility of quotes to trade in the virtual asset subject to the order under the market conditions prevailing at the time.
When the Firm executes an order on behalf of the Client, the best possible result shall be determined in terms of the total consideration, representing the price of the virtual assets and the costs related to execution, which shall include all expenses incurred by the Client that are directly related to the execution of the order, including execution venue fees, clearing and settlement fees if any, and any other fees paid to third parties involved in the execution of the order.
For the purposes of delivering the best execution where there is more than one competing venue to execute an order, in order to assess and compare the results for the Client that would be achieved by executing the order on each of the execution venues listed in the Firm's order execution policy that is capable of executing that order, the Firm’s own commissions and costs for executing the order on each of the eligible execution venues shall be taken into account in that assessment. The Firm shall disclose to the Client both prior to execution of the order and in the trade confirmation, the portion of the amount payable by the Client that is retained by the Firm as fees or commission for the trade, except where the Firm provides another virtual asset service provider, a qualified investor or an institutional investor with a quote to execute at the Firm’s discretion. For avoidance of doubt, where the Firm deals with Client orders as principal with the Client, the Firm shall disclose the portion of the amount payable by the Client that will be retained as fees or commission.
The Firm should at any time take all reasonable steps to obtain, when executing orders, the best possible result for its Clients taking into account the price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.
When the Firm provides Exchange Services to the Client, it shall complete the final settlement of a Virtual Asset transaction within twenty-four (24) hours of the transaction being executed, subject to any factors outside the Firm's control, including but not limited to any limitations or malfunctioning of any distributed ledger technology not controlled by the Firm or its group affiliates.
Price
The Client acknowledges and accepts that, regardless of any information which may be offered by MANTRA Finance, the value of investments may fluctuate significantly and may become of no value. The Client acknowledges and accepts the prices of the different markets are generated electronically by MANTRA Finance execution venues. These Prices will take into account market data from various sources, in order to enable the execution venues to check whether their prices are fair. However, prices may not match prices that you see elsewhere (including prices quoted on any trading venue provided by other service providers). Note that in case of market fluctuations and/or technical conditions, in addition to circumstances outside MANTRA Finance and its execution venues’ control, the prices you see on your device and/or which you are provided when you place an order, may not be identical to the price at which the Trade is executed. Besides, there may not be enough liquidity in the relevant markets or there may be limitations on liquidity or other restrictions imposed on MANTRA Finance. The Client accepts and commits to hold MANTRA Finance harmless from any result of such situations.
The prices shown on the online trading platform are indicative only and when
placing an order, the confirmed price may differ when executing the order from
the price seen on the terminal.
The Client understands and accepts the final confirmed price will depend on the price at actual execution.
MANTRA Finance has the right to review the Client's order details in terms of price, time, volume and the validity of execution type whether they are in the form "pending" or "Market" orders through the online trading system. In case of any manifest errors or discrepancies, the Firm may (but is not obliged to) take the proper actions to correct the details of the given orders without prior notice. The Client shall accept to hold the Firm harmless in relation to any such alteration.
Any specific instructions from a Client may prevent the Firm from taking the steps that have been designed and implemented in its execution policy to obtain the best possible result from the execution of those orders in respect of the elements covered by those instructions, hence such orders are executed under the Client’s responsibility with no liability on the Firm.
The Client acknowledges that the online trading system is an alternative solution for executing the orders. The Firm maintains its trading system on a real time basis. The Client understands that the trading system may not be available for trading all the time. Any trades which have been wrongly confirmed might be reversed or corrected. This can happen in particular in the event of totally or partially illiquid markets, failure of electronic or telecommunications systems or any force action (force majeure) which might be applied on certain instruments by the Firm during abnormal market conditions.
The Client acknowledges and accepts to monitor the online trading platform and statements at all times to make sure that any mistake is immediately communicated to the Firm.
Broker-Dealer Services
MANTRA Finance is committed to maintaining the highest standards of integrity, transparency, and compliance in our capacity as a Virtual Asset Service Provider (VASP) offering Broker-Dealer Services. It is important to note that when MANTRA Finance acts as the broker-dealer, it is not the principal or counterparty under any transaction involving the Clients, and does not bear the corresponding responsibility or liability as a principal.
Virtual Asset Investment Product
MANTRA Finance platform displays information of the investment products clearly for the Client to make an informed decision. Details may include:
Description of the investment products;
Terms of the products, such as the tenor and estimated rewards;
Clients acknowledge and agree that any estimated reward provided on the platform is an indicated estimation and may vary from the actual reward.
As part of the ongoing due diligence process, in case MANTRA Finance finds that the Client is or becomes unsuitable for the investment products, MANTRA Finance may terminate the investment of the Client with notification provided to the Client.
Proceeds From Rewards
By participating in our investment strategies and products, the Clients may be entitled to receive various forms of rewards, gains, and returns generated from these underlying operations. The specific details of how such proceeds are calculated and distributed will depend on the particular investment strategy or platform feature that have been utilized. Generally, the proceeds will be determined based on the Client’s proportional share or ownership within the relevant investment pool. The platform will maintain detailed records of all such proceeds, which will be visible to the Clients through their personalized dashboard on our platform. This is to ensure transparency and allow tracking of their earnings and entitlements at any time.
It is important to note that the actual returns may vary depending on a variety of factors, such as the performance of the underlying investment activities, network conditions, market fluctuations, and other external variables. In the event of significant changes or fluctuations in the expected returns, the platform will endeavor to communicate such information to the Clients through appropriate channels, such as email or website updates.
The Firm is committed to maintaining robust records and documentation of all proceeds distributions to comply with applicable regulations and facilitate effective complaint handling and auditing processes.
Redemption And Withdrawal Process
After any applicable maturity period of an investment product has concluded, you may initiate a withdrawal request at any time through the Site. Initiating a withdrawal will trigger the required unbonding or lock-up period. This period may not be determined by MANTRA Finance, but is a function of the third-party smart contracts that control the virtual assets or subject to the terms set by the third- party issuers governing the investment product.
Upon completion of this period, your virtual assets will be released by the relevant smart contract or issuer and become accessible for you to claim directly. The MANTRA Finance application provides the interface for you to sign the necessary transaction to claim your assets and have them returned to your wallet.
The specific duration of any unbonding or lock-up period is determined solely by the rules of the respective smart contracts or issuers. All relevant information regarding these periods will be clearly disclosed in the details for each product on the Site.
Fees
MANTRA Finance may charge a fee for the products and services offered on the Site. Details of the applicable fees are disclosed on the following page of the Site: https://mantra.finance/fee-structure. Gas fees applicable for a transaction will also be presented to the Clients on the Site before a transaction proceeds, however it may vary depending on network congestion once the transaction goes through. Clients are also able to verify gas fees directly in their wallet before approving the transaction. Gas fees are paid for the benefit of the relevant protocol or blockchain rather than MANTRA Finance.
MISCELLANEOUS
Modification of Agreement
We reserve the right, in our sole discretion, to modify this Agreement from time to time. Should we make any changes to this Agreement, we will provide you with notice by emailing an updated version to the email address you have provided. In line with our regulatory obligations, all changes will be communicated at least thirty (30) calendar days before they take effect.
Your continued use of the Site after the thirty (30) day notice period will serve as confirmation of your acceptance of the new terms. If you do not agree with the modifications, you must stop using the Site and our services before the changes take effect. We will maintain a record of all versions of this Agreement and be able to identify all changes made between versions.
Proprietary Rights
We own all intellectual property and other rights in the Site and its contents, including (but not limited to) software, text, images, trademarks, service marks, copyrights, patents, and designs. This intellectual property is available under the terms of our copyright licenses.
Notwithstanding the above, we do not own or control the underlying software protocols or blockchains which govern the operation of virtual assets supported on the Site. Generally, the underlying protocols and blockchains are open source, and anyone can use, copy, modify, and distribute them. We assume no responsibility for the operation of the underlying protocols and blockchains, and we are not able to guarantee their functionality, security, or availability.
You acknowledge and accept the risk that underlying software protocols and blockchains relating to any virtual asset you hold may change.
You must comply with all applicable laws when using the Site. Except as may be expressly permitted by applicable law or expressly permitted by us in writing, you will not, and will not permit anyone else to: (i) store, copy, modify, distribute, or resell any information or material available on the Site (“Site Content”) or compile or collect any Site Content as part of a database or other work; ii) use any automated tool (e.g., robots, spiders) to use the Site or store, copy, modify, distribute, or resell any Site Content; (iii) rent, lease, or sublicense your access to the Site; (iv) use the Site or Site Content for any purpose except for your own personal use; (v) circumvent or disable any digital rights management, usage rules, or other security features of the Site; (vi) reproduce, modify, translate, enhance, decompile, disassemble, reverse engineer, or create derivative works of the Site; (vii) use the Site in a manner that threatens the integrity, performance, or availability of the Site; or (viii) remove, alter, or obscure any proprietary notices (including copyright notices) on any portion of the Site or Site Content.
Additional Rights
We expressly reserve the following rights:
to modify, substitute, eliminate or add any content or service to the Site without notice;
to review, modify, filter, disable, delete and/or remove any and all content and information from the Site without notice;
to suspend or cancel any person’s access to the Site without notice; and
to cooperate with any law enforcement, court or government investigation or order or third party requesting or directing that we disclose information or content or information that you provide.
Privacy
Our full privacy policy can be found on the Site. We do, however, use third-party service providers, like Google Analytics, coingecko and Infura, SumSub and Elliptic among others, which may receive or independently obtain your personal information from publicly-available sources. We do not control how these third parties handle your data and you should review their privacy policies to understand how they collect, use, and share your personal information. Please visit the websites of the aforementioned third-party service providers and check their policies to learn more about how they may use data. Each site that we use may have its own unique policies. By accessing and using the Site, you understand and consent to our data practices and our service providers' treatment of your information. We may provide updates on our Site from time to time with respect to the third-party service providers that we engaged.
We use the information we collect to detect, prevent, and mitigate financial crime and other illicit or harmful activities on the Site. For these purposes, we may share the information we collect with blockchain analytics providers. We share information with these service providers only so that they can help us promote the safety, security, and integrity of the Site. We do not retain the information we collect any longer than necessary for these purposes.
Please note that when you use the Site, you may interact with various blockchains. We do not control and are not responsible for any information you make public on any blockchain with which you interact by taking actions through the Site.
Record Keeping and Data Retention
In accordance with our regulatory obligations as a licensed virtual asset Service Provider in the Emirate of Dubai, MANTRA Finance is required to maintain comprehensive records of client information and transactional activity. This requirement is mandated by the United Arab Emirates' legal framework for Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT).
Pursuant to these laws and regulations, we will securely store all data and documentation collected during your onboarding and identity verification process, as well as a complete audit trail of all transactions you conduct through our services. These records will be retained for a minimum period of eight (8) years from the date of the transaction or from the end of our business relationship with you, whichever is later.
Prohibited Activity
You agree not to engage in, or attempt to engage in, any of the following categories of prohibited activity in relation to your access and use of the Site:
Intellectual Property Infringement. Activity that infringes on or violates any copyright, trademark, service mark, patent, right of publicity, right of privacy, or other proprietary or intellectual property rights under the law.
Cyberattack. Activity that seeks to interfere with or compromise the integrity, security, or proper functioning of any computer, server, network, personal device, or other information technology system, including (but not limited to) the deployment of viruses and denial of service attacks.
Fraud and Misrepresentation. Activity that seeks to defraud us or any other person or entity, including (but not limited to) providing any false, inaccurate, or misleading information.
Market Manipulation. Activity that violates any applicable law, rule, or regulation concerning the integrity of trading markets, including (but not limited to) the manipulative tactics commonly known as spoofing and wash trading.
Securities and Derivatives Violations. Activity that violates any applicable law, rule, or regulation concerning the trading of securities or derivatives.
Any Other Unlawful Conduct. Activity that violates any applicable law, rule, or regulation of the United States, the European Union, the United Kingdom or any other relevant jurisdiction.
Non-Solicitation; No Investment Advice
You agree and understand that all transactions of any kind that you submit through the Site are considered unsolicited, which means that you have not received any investment advice from us in connection with any trades, and that we do not conduct a suitability review of any transactions you submit.
All information provided by the Site is for informational purposes only and should not be construed as investment advice. You should not take, or refrain from taking, any action based on any information contained in the Site. We do not make any investment recommendations to you or opine on the merits of any investment transaction or opportunity. You alone are responsible for determining whether any investment, investment strategy or related transaction is appropriate for you based on your personal investment objectives, financial circumstances, and risk tolerance.
Non-Custodial and No Fiduciary Duties
The Site is a purely non-custodial application, meaning you are solely responsible for the custody of the cryptographic private keys to the virtual asset wallets you hold. This Agreement is not intended to, and does not, create or impose any fiduciary duties on us. To the fullest extent permitted by law, you acknowledge and agree that we owe no fiduciary duties or liabilities to you or any other party, and that to the extent any such duties or liabilities may exist at law or in equity, those duties and liabilities are hereby irrevocably disclaimed, waived, and eliminated. You further agree that the only duties and obligations that we owe you are those set out expressly in this Agreement.
Compliance Obligations
By accessing or using the Site, you agree that you are solely and entirely responsible for compliance with all laws and regulations that may apply to you. We take no responsibility for assisting you to meet those obligations, nor do we accept any liability if you fail to meet any obligation that is applicable to you.
Assumption of Risk
By accessing and using the Site, you represent that you are financially and technically sophisticated enough to understand the inherent risks associated with using cryptographic and blockchain-based systems, and that you have a working knowledge of the usage and intricacies of virtual assets such as bitcoin (BTC), ether (ETH), and other digital tokens such as those following the Ethereum Token Standard (ERC-20). In particular, you understand that blockchain-based transactions are irreversible. You understand that virtual assets:
may not always be transferable;
may not be liquid; and
may be subject to fraud, manipulation, theft, including through hacks and other targeted schemes, and loss.
You further understand that the markets for these virtual assets are highly volatile due to factors including (but not limited to) adoption, speculation, technology, security, and regulation. You acknowledge and accept that the cost and speed of transacting with cryptographic and blockchain-based systems such as Ethereum are variable and may increase dramatically at any time. You further acknowledge and accept the risk that your virtual assets may lose some or all of their value while they are supplied through the Site, you may suffer loss due to the fluctuation of prices of tokens in a trading pair or liquidity pool, and experience significant price slippage and cost. You understand that anyone can create a token, including fake versions of existing tokens and tokens that falsely claim to represent projects, and acknowledge and accept the risk that you may mistakenly trade those or other tokens. You further acknowledge, understand and agree that we are not responsible for any of these variables or risks, and cannot be held liable for any losses that you experience while accessing or using the Site. Accordingly, you understand and agree to assume full responsibility for all of the risks of accessing and using the Site. If you do not fully agree with each and every statement in this “Assumption of Risk” section, you may not use this Site.
Third-Party Resources and Promotions
The Site may contain references or links to third-party resources, including (but not limited to) information, materials, products, or services, that we do not own or control. In addition, third parties may offer promotions related to your access and use of the Site. We do not endorse or assume any responsibility for any such resources or promotions. If you access any such resources or participate in any such promotions, you do so at your own risk, and you understand that this Agreement does not apply to your dealings or relationships with any third parties. You expressly relieve us of any and all liability arising from your use of any such resources or participation in any such promotions.
Third-Party Service Providers
MANTRA Finance utilizes third-party service providers ("Service Providers") to enable the functionality, security, and compliance of the products and services on the Site. You acknowledge and agree that we may share your information with these Service Providers necessary for the provision of Services. Currently, our key Service Providers include, but are not limited to:
Identity and Compliance: Sum and Substance Ltd for KYC and AML screening;
Blockchain Analytics: Elliptic Singapore Private Limited for transaction monitoring and blockchain intelligence; and
Infrastructure and Security: Britech Cloud Pte. Ltd (providing support for Cloudflare security functions) and BCW HK Limited (providing Google Cloud services).
MANTRA Finance reserves the right to replace or appoint new Service Providers at any time. Your use of the Services constitutes acceptance that MANTRA Finance is not liable for the acts, omissions, or system failures of these third-party Service Providers, except as required by applicable law.
Release of Claims
You expressly agree that you assume all risks in connection with your access and use of the Site. You further expressly waive and release us from any and all liability, claims, causes of action, or damages arising from or in any way relating to your use of the Site and your interaction with the Protocol.
Trading Halts
We, our Site, and our third-party partners may experience cyber-attacks, extreme market conditions, or other operational or technical difficulties which could result in the immediate halt or suspension of transactions either temporarily or permanently. Provided that we have taken reasonable commercial and operational measures to prevent or correct such events in the technical systems we control, we are not and will not be responsible or liable for any loss or damage of any sort incurred by you as a result of such cyber-attacks, operational or technical difficulties or suspensions of transactions. Withdrawal limits based on amounts and/or frequency may apply from time to time, based on legal, regulatory, AML and/or security considerations. Our policies and procedures may require additional security and/or compliance checks that require additional time to complete.
Indemnity and Limitation of Liability
You agree to hold harmless, release, defend, and indemnify us and our officers, directors, employees, contractors, agents, affiliates, and subsidiaries from and against all claims, damages, obligations, losses, liabilities, costs, and expenses arising from: (a) your access and use of the Site; (b) your violation of any term or condition of this Agreement, the right of any third party, or any other applicable law, rule, or regulation; and (c) any other party's access and use of the Site with your assistance or using any device or account that you own or control.
We assume no liability or responsibility for any:
errors, mistakes, or inaccuracies of content;
personal injury or property damage, of any nature whatsoever, resulting from any access or use of the Site;
unauthorized access or use of any secure server or database in our control, or the use of any information or data stored therein;
interruption or cessation of function related to the Site;
bugs, viruses, trojan horses, or the like that may be transmitted to or through the Site;
errors or omissions in, or loss or damage incurred as a result of the use of, any content made available through the Site; and
the defamatory, offensive, or illegal conduct of any third party.
In addition to the immediately above paragraphs, in no event shall we, our affiliates or service providers, or any of our or their respective officers, directors, agents, employees or representatives, be liable for any of the following types of loss or damage arising under or in connection with this Agreement or otherwise:
any loss of profits or loss of expected revenue or gains, including any loss of anticipated trading profits and/or any actual or hypothetical trading losses, even if we are advised of or knew or should have known of the possibility of the same. This means, by way of example only (and without limiting the scope of the preceding sentence), that if you claim that we failed to process a buy or sell transaction properly, your damages are limited to no more than the value of the supported virtual asset at issue in the transaction, and that you may not recover for any ”loss“ of anticipated trading profits or for any actual trading losses made as a result of the failure to buy or sell;
any loss of or damage to reputation or goodwill; any loss of business or opportunity, customers, or contracts; any loss or waste of overheads, management, or other staff time; or any other loss of revenue or actual or anticipated savings, even if we are advised of or knew or should have known of the possibility of the same;
any loss of use of hardware, software or data and/or any corruption of data; including but not limited to any losses or damages arising out of or relating to any inaccuracy, defect or omission of virtual asset price data; any error or delay in the transmission of such data; and/or any interruption in any such data;
any loss or damage whatsoever which does not stem directly from our breach of this Agreement; and/or
any loss or damage whatsoever which is in excess of that which was caused as a direct result of our breach of this Agreement (whether or not you are able to prove such loss or damage).
Subject to applicable laws, under no circumstances shall we or any of our officers, directors, employees, contractors, agents, affiliates, or subsidiaries be liable to you for any claims, proceedings, liabilities, obligations, damages, losses, or costs in an amount exceeding the amount you paid to us in exchange for access to and use of the Site. This limitation of liability applies regardless of whether the alleged liability is based on contract, tort, negligence, strict liability, or any other basis, and even if we have been advised of the possibility of such liability. Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of certain liabilities and damages. Accordingly, some of the disclaimers and limitations set forth in this Agreement may not apply to you. This limitation of liability shall apply to the fullest extent permitted by law.
Each provision of this Agreement that provides for a limitation of liability, disclaimer of warranties, or exclusion of damages is intended to and does allocate the risks between the parties under this Agreement. This allocation is an essential element of the basis of the bargain between the parties. Each of these provisions is severable and independent of all other provisions of this Agreement. The limitations in this section will apply even if any limited remedy fails for its essential purpose.
No Warranties
You acknowledge and agree that your use of the Site is at your own risk. The Site is provided on an “as is”, “with all faults” and “as available” basis. We, our officers, directors, shareholders, employees, and agents expressly disclaim all warranties of any kind, expressed, implied or statutory, relating to the Site and its content including without limitation the warranties of title, merchantability, fitness for a particular purpose, non-infringement of proprietary rights, course of dealing or course of performance. We do not warrant that (i) the Site will meet your specific requirements, (ii) the Site will be uninterrupted, timely, secure or error-free, (iii) any transactions will be accurate, error-free, reliable or complete, (iv) any errors on the Site will be corrected, or
(v) any services through the Site will meet your expectations or requirements.
The Site may contain links to third party products, services, and websites. We exercise no control over the third-party products, services and websites, and we are not responsible for their performance, do not endorse them, and are not responsible or liable for any content, advertising, or other materials available through the third-party products, services, and websites. We are not responsible or liable, directly or indirectly, for any damage or loss caused to you by your use of or reliance on any goods or services available through the third-party products, services, and websites.
Additionally, if you follow a link or otherwise navigate away from the Site, please be aware that this Agreement will no longer govern. You should review the applicable terms and policies, including privacy and data gathering practices, of any third-party websites to which you navigate to from the Site.
We do not warrant and are not responsible for any damages or losses sustained by you as a result of your use of the Site. We do not warrant that your use of the Site is lawful in any jurisdiction other than the Emirate of Dubai, and we specifically disclaim any such warranties. Some jurisdictions limit or do not allow the disclaimer of implied or other warranties so the above disclaimer may not apply to you to the extent such jurisdiction’s law is applicable to you and this Agreement. By accessing or using the Site, you represent and warrant that your activities are lawful in every jurisdiction where you access or use the Site.
In no event shall we be liable for any damages whatsoever, whether direct, indirect, general, special, exemplary, compensatory, consequential, and/or incidental, arising out of or relating out of, or relating to the conduct of you or anyone else in connection with the use of the Site, including without limitation, loss, impairment, bodily injury, death, emotional distress, damage to your possessions and/or any other damages resulting from any transactions initiated on the Site, unauthorized access to or alteration of your transmissions to the Site and errors, mistakes or inaccuracies of any content on the Site. You agree to take reasonable precautions when executing any Transactions on the Site.
Notwithstanding any provision of this Agreement, if your jurisdiction has provisions specific to waiver or liability that conflict with the above, our liability is then limited to the smallest extent possible by law. Specifically, in those jurisdictions not allowed, we do not disclaim liability for (i) death or personal injury caused by negligence of that of any of its officers, employees or agents, (ii) fraudulent misrepresentation, or (iii) any liability which is not lawful to exclude either now or in the future.
If you are a resident of a jurisdiction that requires a specific statement regarding release, you would waive any similar provisions in law, regulation or code that has the same intent or effect. We are not responsible for the actions, content, information, or data of third parties, and you agree to release us, our directors, officers, employees and agents from any claims and damages, known and unknown, arising out of or in any way connected with any claim you have against such third parties. Your ability to use the Site is contingent on your agreement with this and all other sections of this Agreement. Where allowed, you agree that our total liability to you shall be no more than the total amount of fees you paid to use our service within the last year.
We make no representations about the accuracy or completeness of historical virtual asset price data available on the Site.
Suspension, Termination and Cancellation
We reserve the right to: (i) refuse to complete, block, cancel or reverse a transaction you have authorized, (ii) suspend, restrict, or terminate your access to any or all of the services we offer, (iii) deactivate or cancel your account with immediate effect and/or (iv) freeze or seize your assets that are under our control for any reason, including but not limited to where:
we are, in our reasonable opinion, required to do so by applicable law or any court or other authority to which we are subject in any jurisdiction;
we reasonably suspect that you of acting in breach of this Agreement;
we reasonably suspect that you have breached our policies;
we have concerns that a transaction is erroneous or about the security of your account or we suspect our services are being used in a fraudulent or unauthorized manner;
we suspect money laundering, terrorist financing, fraud, or any other unlawful activity;
your credit or debit card or any other valid payment method linked to your account is declined;
you do not provide sufficient information or documents for the purposes our KYC/AML checks or provide fake, inaccurate or misleading information or documents;
you are subject to any pending litigation, investigation, or government proceeding and/or we perceive a heightened risk of legal or regulatory non-compliance associated with account activity; and/or
you take any action that may circumvent our policies or controls such as opening multiple accounts, using bots or abusing promotions which we may offer from time to time.
We may also refuse to complete a transaction you have authorized where there are insufficient funds in your wallet and/or insufficient digital assets in your wallet to cover the transaction and (where applicable) associated fees at the time that we receive notification of the transaction.
If we refuse to complete a transaction and/or suspend or close your account, or terminate your use of our Services in this way, we will (unless it would be unlawful for us to do so) provide you with notice of our actions and the reasons for refusal, suspension or closure and where appropriate, with the procedure for correcting any factual errors that led to the refusal, suspension or closure. In the event that we refuse to complete a transaction and/or suspend your account, we may lift the suspension once the reasons for refusal and/or suspension no longer exist. However, we are under no obligation to allow you to reinstate a transaction at the same price or on the same terms as the suspended, reversed or cancelled transaction.
We may suspend, restrict, or terminate your access to any or all of our services and/or deactivate or cancel your account, without reason, by giving you one month notice. You acknowledge that our decision to take certain actions, including limiting access to, suspending, or closing your account, may be based on confidential criteria that are essential to our risk management and security protocols. You agree that we are under no obligation to disclose the details of our risk management and security procedures to you.
If we suspend or close your account or terminate your use of our Site for any reason, we reserve the right to require you to complete the procedures outlined under “Identity Verification” before permitting you to transfer or withdraw virtual assets.
You may not cancel your account to evade an investigation or avoid paying any amounts otherwise due to us. Upon cancellation of your account, you authorize us to cancel or suspend pending transactions on the Site and hold any associated funds until we are certain that funding reversal windows are complete. In the event that you or we terminate this Agreement or your access to our services, or de- activate or cancel your account, you will remain liable for all amounts due hereunder. If any transaction is in a pending state at the time your account is cancelled or suspended, such transaction may be cancelled and/or refunded as appropriate.
No Liability for Breach
We are not liable for any breach of the Agreement where the breach is due to abnormal and unforeseeable circumstances beyond our control, the consequences of which would have been unavoidable despite all effects to the contrary, nor are we liable where the breach is due to the application of mandatory legal rules.
Governing Law and Dispute Resolution
This Agreement is governed and construed in accordance with the laws of the Emirate of Dubai, and subject to the non-exclusive jurisdiction of the courts of the Emirate of Dubai for any suit, action or proceeding arising out of this Agreement.
Entire Agreement
This Agreement constitutes the entire agreement between you and us with respect to the subject matter hereof. This Agreement supersedes any and all prior or contemporaneous written and oral agreements, communications and other understandings (if any) relating to the subject matter of the terms.
