Sanctions, Restricted Countries & Compliance Policy

01Introduction

This Sanctions, Restricted Countries & Compliance Policy governs sanctions compliance, restricted countries, restricted persons, restricted transactions, export controls, anti-money laundering risk, fraud prevention, prohibited jurisdictions, compliance reviews, account restrictions, payout restrictions, transaction monitoring, and related enforcement actions through or in connection with the Kyttx Platform.

This Policy applies to all Users, including Sellers, Merchants, Buyers, Customers, Members, Operators, agencies, team members, contractors, affiliates, visitors, and any other person or entity that accesses or uses Kyttx.

This Policy is incorporated into and forms part of the Kyttx Master Terms of Service, Seller / Merchant Agreement, Buyer / Member Terms, Operator / Agency Terms, Payment, Payout & Fee Schedule, Refund, Chargeback & Dispute Policy, Acceptable Use Policy, Content & Intellectual Property Policy, Privacy Policy, Cookie Policy, Data Processing Agreement, Arbitration & Dispute Resolution Agreement, and any other applicable Kyttx Policies.

By accessing or using Kyttx, creating an account, purchasing a Seller Offering, selling through Kyttx, acting as an Operator, using payment-related features, receiving payouts, or otherwise interacting with the Platform, you agree to this Policy.

If you do not agree to this Policy, you must not use Kyttx.

02Purpose of This Policy

Kyttx is intended to support lawful global commerce for legitimate Sellers, Buyers, Operators, and businesses.

Because Kyttx may operate globally and may use Third-Party Payment Providers, banks, card networks, infrastructure providers, fraud prevention providers, compliance providers, and other service providers, Kyttx must be able to restrict, block, suspend, terminate, review, or refuse certain Users, countries, regions, transactions, payouts, Seller Offerings, payment methods, currencies, or activities.

This Policy is intended to protect:

• Kyttx.
• Sellers.
• Buyers.
• Operators.
• Third-Party Payment Providers.
• Banks.
• Card networks.
• Service providers.
• The Platform.
• Lawful commerce.
• Payment system integrity.
• Sanctions compliance.
• Anti-fraud controls.
• Anti-money laundering risk management.
• Legal and regulatory compliance.

03Relationship to Other Terms

This Policy applies in addition to all other Kyttx terms and policies.

If there is a conflict between this Policy and the Kyttx Master Terms of Service, this Policy controls for sanctions, restricted countries, compliance, fraud-risk, payment-risk, restricted-person, restricted-transaction, and related enforcement matters unless expressly stated otherwise.

If a Third-Party Payment Provider, bank, card network, service provider, regulator, authority, or applicable law imposes stricter requirements than this Policy, the stricter requirement may apply.

Kyttx may enforce this Policy even if the relevant activity occurs outside the Platform where Kyttx determines that the activity relates to Kyttx, a Seller Offering, a Buyer, a Seller, an Operator, payment activity, payout activity, compliance risk, legal risk, sanctions risk, or platform integrity.

04Definitions

Capitalized terms used but not defined in this Policy have the meanings given in the Kyttx Master Terms of Service.

For purposes of this Policy:

?Restricted Country? means any country, region, territory, or jurisdiction that Kyttx, a Third-Party Payment Provider, bank, card network, service provider, regulator, authority, or applicable law restricts, prohibits, blocks, or subjects to enhanced review.

?Restricted Person? means any person, entity, organization, group, government, agency, or other party that is subject to sanctions, embargoes, restrictions, prohibitions, watchlists, denied party lists, payment provider restrictions, or other compliance restrictions applicable to Kyttx or its service providers.

?Restricted Transaction? means any payment, payout, withdrawal, purchase, subscription, transfer, refund, chargeback, access grant, account activity, Seller Offering, communication, or other transaction involving a Restricted Country, Restricted Person, prohibited activity, suspicious activity, sanctions risk, fraud risk, payment risk, compliance risk, or other restricted activity.

?Sanctions Laws? means sanctions, embargoes, export controls, trade restrictions, anti-terrorism rules, anti-money laundering rules, counter-terrorist financing rules, restricted party rules, and similar laws, regulations, orders, programs, or requirements applicable to Kyttx, Users, Third-Party Payment Providers, banks, card networks, or service providers.

?Compliance Review? means any review, investigation, screening, monitoring, verification, risk assessment, account review, transaction review, payout review, Seller Offering review, identity review, business review, tax review, sanctions review, fraud review, or legal review conducted by Kyttx or a third party.

?Third-Party Payment Provider? means Stripe, Stripe Connect, banks, acquiring banks, card networks, payment processors, payout providers, fraud prevention providers, identity verification providers, tax providers, compliance providers, financial infrastructure providers, or other third-party providers involved in payments, payouts, settlement, verification, fraud checks, compliance, or related services.

05General Compliance Obligations

You must comply with all laws, rules, regulations, sanctions requirements, export controls, payment provider rules, card network rules, bank requirements, tax rules, and Kyttx Policies applicable to your use of Kyttx.

You must not use Kyttx to:

• Violate Sanctions Laws.
• Evade sanctions.
• Evade export controls.
• Evade payment provider restrictions.
• Evade bank restrictions.
• Engage in money laundering.
• Finance terrorism.
• Facilitate illegal activity.
• Process prohibited transactions.
• Misrepresent your identity.
• Misrepresent your location.
• Misrepresent your business.
• Misrepresent transaction purpose.
• Conceal restricted activity.
• Use intermediaries to bypass restrictions.
• Route funds through prohibited jurisdictions.
• Transact with Restricted Persons.
• Provide access to Restricted Persons where prohibited.
• Sell prohibited or restricted Seller Offerings.
• Create legal, payment, fraud, sanctions, compliance, reputational, or platform risk.

06Restricted Countries and Regions

Kyttx may restrict, block, suspend, or prohibit access to the Platform, payment features, payout features, Seller Offerings, or other services in certain countries, regions, territories, or jurisdictions.

Restrictions may be based on:

• Sanctions Laws.
• Export controls.
• Payment provider rules.
• Bank rules.
• Card network rules.
• Fraud risk.
• Chargeback risk.
• Regulatory risk.
• Tax risk.
• Compliance risk.
• Security risk.
• Operational risk.
• Reputational risk.
• Service provider availability.
• Kyttx?s risk assessment.

Kyttx may update Restricted Countries at any time without prior notice.

A country or region may be restricted even if it is not fully prohibited by law, if Kyttx or its service providers determine that the country or region creates unacceptable risk.

07Sanctioned Persons and Entities

You may not use Kyttx if you are a Restricted Person.

You may not use Kyttx if you are:

• Listed on a sanctions list.
• Owned or controlled by a sanctioned person.
• Acting on behalf of a sanctioned person.
• Located in a restricted jurisdiction.
• Organized under the laws of a restricted jurisdiction.
• Ordinarily resident in a restricted jurisdiction where prohibited.
• Using intermediaries to evade restrictions.
• Otherwise prohibited by applicable law, payment provider rules, or Kyttx Policies.

You must not sell to, buy from, provide access to, receive funds from, send funds to, employ, engage, contract with, or otherwise transact with Restricted Persons through or in connection with Kyttx.

08Restricted Transactions

Kyttx may block, reject, refund, reverse, delay, hold, freeze, restrict, review, or report Restricted Transactions.

A transaction may be restricted if it involves or appears to involve:

• A Restricted Country.
• A Restricted Person.
• Sanctions risk.
• Export control risk.
• Fraud risk.
• Money laundering risk.
• Terrorist financing risk.
• Illegal goods or services.
• Prohibited Seller Offerings.
• Misleading Seller Offerings.
• Suspicious payment activity.
• Suspicious payout activity.
• Payment provider restrictions.
• Bank restrictions.
• Card network restrictions.
• High-risk countries.
• High-risk currencies.
• High-risk payment methods.
• Unusual transaction patterns.
• Inconsistent account information.
• Incomplete verification.
• False or misleading information.
• Off-platform conduct creating compliance risk.
• Any other risk identified by Kyttx.

09Export Controls

You must comply with applicable export control laws and regulations.

You must not use Kyttx to export, re-export, transfer, provide access to, or make available software, technology, content, data, services, or materials in violation of export controls.

You must not use Kyttx to provide access to restricted technology, controlled software, prohibited technical data, or regulated services to restricted countries, restricted persons, or prohibited end uses.

Kyttx may restrict access to Platform features, Seller Offerings, files, downloads, software access, APIs, integrations, or content where export control risk exists.

10Anti-Money Laundering and Counter-Terrorist Financing Risk

Kyttx is not a bank, payment processor, money transmitter, escrow provider, financial institution, or regulated financial services provider.

However, Kyttx may apply risk controls to reduce money laundering, terrorist financing, fraud, and payment abuse risks.

You must not use Kyttx to:

• Launder money.
• Finance terrorism.
• Move illicit funds.
• Disguise transaction purpose.
• Disguise beneficial ownership.
• Process sham transactions.
• Conduct fake purchases.
• Conduct self-dealing transactions to move funds.
• Process payments for undisclosed third parties.
• Evade tax reporting.
• Evade sanctions.
• Manipulate payment systems.
• Use stolen payment methods.
• Use Kyttx as an unauthorized money transfer tool.

Kyttx may share information with Third-Party Payment Providers, banks, regulators, law enforcement, or other parties where necessary or appropriate.

11Know Your Customer and Verification

Kyttx or Third-Party Payment Providers may require identity, business, tax, compliance, ownership, address, banking, or transaction information.

This may include:

• Legal name.
• Business name.
• Date of birth, where required.
• Address.
• Country of residence.
• Business address.
• Nationality, where required.
• Tax identification number.
• VAT or sales tax number.
• Business registration information.
• Beneficial ownership information.
• Control person information.
• Bank account information.
• Payout information.
• Website.
• Social profiles.
• Seller Offering descriptions.
• Transaction history.
• Refund history.
• Chargeback history.
• Identity documents, where required.
• Additional documents requested by Kyttx or payment providers.

You must provide accurate, complete, current, and non-misleading information.

Kyttx may restrict, suspend, delay, freeze, or terminate accounts, transactions, payouts, or access where information is missing, incomplete, inaccurate, outdated, suspicious, unverifiable, or not provided on time.

12Beneficial Ownership and Control

If you use Kyttx on behalf of a company, business, organization, agency, or other entity, Kyttx or Third-Party Payment Providers may request information about beneficial owners, directors, managers, control persons, shareholders, officers, authorized representatives, and other persons with control over the entity.

You must not conceal ownership or control.

You must promptly update Kyttx if ownership, control, authority, business structure, or account responsibility changes.

Kyttx may suspend or restrict accounts where ownership or control is unclear, disputed, suspicious, or unverifiable.

13Tax and Business Compliance

Kyttx or Third-Party Payment Providers may request tax or business compliance information.

This may include:

• Tax identification numbers.
• VAT numbers.
• Sales tax registration numbers.
• Business registration documents.
• Invoices.
• Receipts.
• Tax forms.
• Tax residency information.
• Address information.
• Payout recipient information.
• Transaction reports.
• Other information required by law or payment providers.

You are responsible for your own tax obligations.

Kyttx may withhold, delay, restrict, or suspend payouts where tax or business compliance information is missing, incomplete, inaccurate, suspicious, or required by law or payment provider rules.

14High-Risk Seller Offerings

Kyttx may restrict or review Seller Offerings that create elevated compliance risk.

High-risk Seller Offerings may include:

• High-ticket coaching.
• High-ticket consulting.
• Business opportunity programs.
• Income-related programs.
• Agency scaling programs.
• Sales training involving earnings claims.
• Marketing programs involving revenue claims.
• Crypto-related education.
• Trading-related education.
• Financial education.
• Investment-related education.
• Wellness, fitness, appearance, or looks-related services.
• Health-adjacent services.
• Long-term payment plans.
• Aggressive guarantees.
• Trial-to-paid offers.
• Buy-now-pay-later offers.
• Offers with high refund risk.
• Offers with high chargeback risk.
• Offers involving restricted countries.
• Offers involving regulated industries.
• Any other offering Kyttx determines is high risk.

Kyttx may require additional review, disclosures, reserves, payout delays, payment restrictions, or approval for high-risk Seller Offerings.

15Prohibited Compliance-Risk Activities

You may not use Kyttx for activities prohibited by Kyttx, payment providers, banks, card networks, regulators, or applicable law.

Prohibited activities include:

• Illegal activity.
• Sanctions evasion.
• Money laundering.
• Terrorist financing.
• Fraud.
• Payment fraud.
• Transaction laundering.
• Processing payments for undisclosed third parties.
• Fake transactions.
• Sham transactions.
• Card testing.
• Stolen payment methods.
• Identity theft.
• Fake IDs.
• Fake business documents.
• Tax evasion.
• Illegal gambling.
• Betting.
• Adult content.
• Illegal financial services.
• Unlicensed investment services.
• Unlawful crypto services.
• Prohibited health or medical services.
• Counterfeit goods.
• Stolen goods.
• Illegal drugs.
• Weapons or restricted goods.
• Scams.
• Pyramid schemes.
• Ponzi schemes.
• Deceptive MLM schemes.
• Get-rich-quick schemes.
• Phishing.
• Malware.
• Hacking.
• Prohibited exports.
• Restricted technology transfers.
• Other activity prohibited by the Acceptable Use Policy.

16Off-Platform Compliance Risk

Kyttx may consider off-platform conduct when determining compliance risk.

Off-platform conduct may include:

• External marketing.
• Social media claims.
• Ads.
• Webinars.
• Sales calls.
• Direct messages.
• External checkout pages.
• External refund terms.
• External communities.
• Affiliate conduct.
• Public complaints.
• Regulator complaints.
• Lawsuits.
• Payment provider reports.
• Buyer reports.
• Seller reports.
• Operator reports.
• Media reports.
• Public records.
• Sanctions or compliance information.

Kyttx may take action if off-platform conduct creates legal, payment, chargeback, fraud, sanctions, reputational, compliance, or platform risk.

17Payment Provider Restrictions

Third-Party Payment Providers may impose restrictions on Users, countries, products, services, currencies, payment methods, payouts, withdrawals, or transaction types.

Kyttx may enforce those restrictions.

If a Third-Party Payment Provider refuses, restricts, suspends, terminates, delays, or blocks your account, payment, payout, withdrawal, or transaction, Kyttx may also restrict, suspend, terminate, delay, or block your Platform access or payment-related features.

Kyttx is not responsible for Third-Party Payment Provider decisions.

18Country, Currency, and Payment Method Limits

Kyttx may restrict or limit:

• Supported countries.
• Supported regions.
• Supported currencies.
• Supported payment methods.
• Supported payout methods.
• Supported banks.
• Supported withdrawal methods.
• Instant withdrawal eligibility.
• Subscription availability.
• Payment plan availability.
• Trial availability.
• Buy-now-pay-later availability.
• Seller Offering categories.
• Buyer countries.
• Seller countries.
• Operator countries.

Restrictions may vary by account, country, currency, payment provider, Seller Offering, transaction type, risk review, or legal requirement.

19Compliance Reviews

Kyttx may conduct Compliance Reviews at any time.

A Compliance Review may involve:

• Identity review.
• Business review.
• Ownership review.
• Seller Offering review.
• Content review.
• Marketing review.
• Refund policy review.
• Transaction review.
• Payout review.
• Chargeback review.
• Buyer complaint review.
• Sanctions screening.
• Fraud review.
• Tax review.
• Payment provider review.
• Country risk review.
• Currency risk review.
• Operator access review.
• Data access review.
• Security review.

Kyttx may conduct Compliance Reviews manually, automatically, through AI tools, through Third-Party Payment Providers, through service providers, through public sources, or through other methods.

20Information Requests

You must cooperate with Compliance Reviews.

Kyttx may request information including:

• Identity documents.
• Business documents.
• Tax documents.
• Proof of address.
• Proof of ownership.
• Proof of authority.
• Bank information.
• Payout information.
• Invoices.
• Transaction records.
• Buyer communications.
• Refund evidence.
• Chargeback evidence.
• Marketing materials.
• Seller Offering details.
• Licensing information.
• Regulatory authorization.
• Screenshots.
• Contracts.
• Proof of fulfillment.
• Proof of delivery.
• Other information Kyttx determines necessary.

Failure to provide requested information may result in restrictions, payout holds, reserves, suspension, termination, refunds, or other enforcement action.

21Account Restrictions During Review

During a Compliance Review, Kyttx may restrict, suspend, hold, freeze, delay, or disable:

• Account access.
• Seller Offerings.
• Checkout.
• Payment methods.
• Payouts.
• Withdrawals.
• Instant withdrawals.
• Revenue share.
• Operator access.
• Buyer access.
• Data exports.
• Communication tools.
• Automations.
• Custom URLs.
• Hosted pages.
• File hosting.
• Any other Platform feature.

Kyttx may maintain restrictions until the review is complete, risk is resolved, or Kyttx determines that restrictions are no longer necessary.

22Payout Holds, Reserves, and Offsets

Kyttx may impose payout holds, reserves, delays, freezes, restrictions, or offsets due to compliance risk.

Reasons may include:

• Sanctions risk.
• Restricted country risk.
• Restricted person risk.
• Fraud risk.
• Money laundering risk.
• Terrorist financing risk.
• Payment provider risk.
• Tax risk.
• Legal risk.
• Chargeback risk.
• Refund risk.
• Buyer complaint risk.
• Suspicious transactions.
• Incomplete verification.
• Missing business information.
• Missing tax information.
• Negative balances.
• Payment provider requirements.
• Regulator requests.
• Law enforcement requests.
• Court or arbitration orders.
• Kyttx?s risk assessment.

Kyttx may use held, delayed, reserved, or future amounts to cover refunds, chargebacks, disputes, Fees, penalties, taxes, payment provider assessments, legal costs, investigation costs, or other amounts owed.

23Refunds and Reversals for Compliance Reasons

Kyttx may require, initiate, instruct, or facilitate refunds, reversals, cancellations, or access removals for compliance reasons.

This may occur where:

• A transaction involves a Restricted Person.
• A transaction involves a Restricted Country.
• A Seller Offering is prohibited.
• A transaction is suspicious.
• Payment provider rules require it.
• Bank rules require it.
• Card network rules require it.
• Law requires it.
• A regulator requests it.
• Fraud is suspected.
• Account information is false or unverifiable.
• Seller fails compliance review.
• Buyer fails compliance review.
• Kyttx determines action is necessary.

Users remain responsible for Fees, refunds, chargebacks, negative balances, and related costs as provided in Kyttx Policies.

24Account Termination for Compliance Reasons

Kyttx may suspend or terminate accounts for compliance reasons, with or without notice.

Reasons may include:

• Sanctions risk.
• Restricted country risk.
• Restricted person risk.
• Fraud risk.
• Payment abuse.
• Money laundering risk.
• Terrorist financing risk.
• False information.
• Incomplete verification.
• Refusal to provide information.
• Prohibited Seller Offerings.
• High-risk activity.
• Payment provider restrictions.
• Bank restrictions.
• Card network restrictions.
• Legal requirements.
• Regulator requests.
• Law enforcement requests.
• Court or arbitration orders.
• Reputational risk.
• Platform integrity risk.
• Violation of this Policy.
• Violation of other Kyttx Policies.

Termination does not release you from obligations arising before termination.

25Disclosure to Payment Providers and Authorities

Kyttx may share information with third parties where necessary or appropriate for compliance, fraud prevention, sanctions, payment processing, legal, tax, security, or enforcement purposes.

Third parties may include:

• Third-Party Payment Providers.
• Banks.
• Card networks.
• Fraud prevention providers.
• Identity verification providers.
• Tax providers.
• Compliance providers.
• Hosting providers.
• Analytics providers.
• Legal advisors.
• Accountants.
• Auditors.
• Regulators.
• Law enforcement.
• Courts.
• Arbitrators.
• Government authorities.
• Affected Users.
• Service providers.
• Other parties where appropriate.

Information shared may include account information, transaction records, payout records, identity information, business information, tax information, Seller Offering details, communications, IP addresses, device data, usage logs, access records, dispute records, and other relevant information.

26No Duty to Disclose Risk Rules

Kyttx is not required to disclose its risk models, compliance rules, screening methods, fraud detection criteria, enforcement thresholds, internal policies, payment provider instructions, or reasons for specific compliance decisions where disclosure may compromise security, compliance, fraud prevention, legal obligations, payment provider relationships, or platform integrity.

Kyttx may provide general explanations where appropriate but is not required to provide detailed risk information.

27False or Misleading Information

You must not provide false, misleading, incomplete, outdated, forged, altered, or deceptive information to Kyttx or Third-Party Payment Providers.

This includes false or misleading information about:

• Identity.
• Business.
• Address.
• Location.
• Nationality.
• Country of residence.
• Ownership.
• Control.
• Tax status.
• Seller Offerings.
• Pricing.
• Refund policies.
• Transaction purpose.
• Payout recipients.
• Payment methods.
• Buyer identity.
• Operator identity.
• Legal compliance.
• Licensing.
• Sanctions status.

Providing false or misleading information may result in immediate suspension or termination.

28Location Misrepresentation

You must not misrepresent your location, country, region, IP address, residence, business location, or place of operation.

You must not use VPNs, proxies, shell companies, nominee accounts, false addresses, intermediaries, or other methods to bypass country restrictions, sanctions restrictions, payment provider restrictions, tax rules, or compliance reviews.

Kyttx may restrict or terminate accounts where location information is inconsistent, suspicious, or unverifiable.

29Third-Party or Nominee Accounts

You must not create or use accounts on behalf of undisclosed third parties.

You must not allow another person or entity to use your account to evade restrictions.

You must not act as a nominee, front, pass-through, or undisclosed intermediary for a Restricted Person, Restricted Country, prohibited business, or high-risk activity.

Kyttx may require proof of account ownership, beneficial ownership, control, authority, and transaction purpose.

30Operators and Compliance

Operators must comply with this Policy.

Operators must not:

• Help Sellers evade restrictions.
• Hide prohibited Seller Offerings.
• Bypass compliance reviews.
• Misrepresent Seller identity.
• Misrepresent Seller location.
• Create prohibited offers.
• Process Buyer Data unlawfully.
• Access accounts without authorization.
• Configure misleading payment terms.
• Configure prohibited payment flows.
• Issue unauthorized refunds.
• Change compliance-relevant account settings without authorization.
• Misuse Seller or Buyer data.
• Assist with sanctions evasion, fraud, or payment abuse.

Kyttx may restrict, suspend, or terminate Operator access for compliance reasons.

31Buyers and Compliance

Buyers must comply with this Policy.

Buyers must not:

• Purchase from restricted countries where prohibited.
• Use restricted payment methods.
• Use stolen payment information.
• Use false identities.
• File false chargebacks.
• Misrepresent location.
• Bypass sanctions restrictions.
• Access Seller Offerings where prohibited.
• Use Kyttx for illegal purposes.
• Engage in payment fraud.
• Engage in refund abuse.
• Assist others in violating this Policy.

Kyttx may restrict, suspend, refund, reverse, or terminate Buyer access for compliance reasons.

32Sellers and Compliance

Sellers must comply with this Policy.

Sellers must not:

• Sell to Restricted Persons where prohibited.
• Sell to Restricted Countries where prohibited.
• Offer prohibited Seller Offerings.
• Process payments for third parties without authorization.
• Misrepresent Seller Offerings.
• Misrepresent transaction purpose.
• Conceal high-risk activity.
• Use misleading refund policies.
• Create excessive chargeback risk.
• Avoid compliance review.
• Avoid tax obligations.
• Avoid payment provider rules.
• Use Kyttx for unlawful financial activity.
• Use Kyttx for sanctions evasion.
• Use Kyttx for money laundering.
• Use Kyttx for terrorist financing.
• Use Kyttx for fraudulent activity.

Sellers are responsible for the compliance of their Seller Offerings, Operators, team members, contractors, affiliates, promoters, and Buyers to the extent related to Seller activity.

33Prohibited Country Circumvention

You must not attempt to bypass country restrictions by:

• Using VPNs.
• Using proxies.
• Using false addresses.
• Using shell companies.
• Using nominee accounts.
• Using third-party accounts.
• Routing payments through another country.
• Using unrelated payout recipients.
• Misrepresenting residency.
• Misrepresenting business location.
• Using false documents.
• Hiding beneficial ownership.
• Using intermediaries.
• Splitting transactions.
• Using other circumvention methods.

Kyttx may terminate accounts and report activity where circumvention is suspected.

34Service Availability by Jurisdiction

Kyttx may not be available in all jurisdictions.

Even if the Platform is technically accessible from a country or region, this does not mean Kyttx allows use from that country or region.

Kyttx may restrict access at any time based on law, payment provider availability, service provider availability, fraud risk, sanctions risk, compliance risk, or business reasons.

Users are responsible for ensuring that their use of Kyttx is lawful in their location.

35Blocking and Geo-Restriction

Kyttx may use geo-blocking, IP-based restrictions, payment method restrictions, country restrictions, device analysis, account review, payment provider data, and other controls to restrict access.

Kyttx does not guarantee that restrictions will detect all prohibited activity.

Failure by Kyttx to block access does not mean that access is permitted.

36Recordkeeping

Kyttx may retain records related to compliance, sanctions, fraud, tax, payments, payouts, disputes, refunds, chargebacks, account verification, Seller Offerings, and enforcement.

Records may be retained for:

• Legal compliance.
• Tax compliance.
• Payment provider requirements.
• Fraud prevention.
• Sanctions screening.
• AML risk management.
• Dispute resolution.
• Chargeback defense.
• Refund review.
• Buyer complaints.
• Seller disputes.
• Operator disputes.
• Security.
• Audits.
• Investigations.
• Enforcement.
• Business operations.

Kyttx may retain records after account closure or termination.

37Cooperation with Investigations

You agree to cooperate with Kyttx, Third-Party Payment Providers, banks, card networks, regulators, law enforcement, courts, arbitrators, and other authorities in connection with compliance investigations.

You must provide requested information in a timely, accurate, complete, and non-misleading manner.

Failure to cooperate may result in account restriction, payout hold, reserve, suspension, termination, refunds, reports to third parties, or legal action.

38Enforcement Actions

If Kyttx determines that you violated this Policy or created compliance risk, Kyttx may take any action it determines appropriate.

Enforcement actions may include:

• Warning.
• Request for information.
• Request for documents.
• Account review.
• Account restriction.
• Account suspension.
• Account termination.
• Seller Offering removal.
• Checkout disabling.
• Payment method restriction.
• Payout delay.
• Payout freeze.
• Reserve requirement.
• Withdrawal restriction.
• Revenue-share restriction.
• Operator access removal.
• Buyer access removal.
• Refund initiation.
• Transaction reversal.
• Data export restriction.
• Communication restriction.
• Feature restriction.
• Reporting to payment providers.
• Reporting to banks.
• Reporting to card networks.
• Reporting to regulators.
• Reporting to law enforcement.
• Arbitration or legal action.
• Collection of amounts owed.
• Any other action Kyttx determines necessary.

Kyttx may take enforcement action with or without prior notice.

39Appeals

Kyttx may allow Users to appeal certain compliance decisions.

An appeal should include:

• Account information.
• Explanation of why the decision should be reversed.
• Supporting documents.
• Proof of identity or business information.
• Proof of location.
• Proof of lawful activity.
• Proof of payment authorization.
• Proof of delivery.
• Corrective steps taken.
• Any additional information requested by Kyttx.

Kyttx may accept, reject, ignore, or condition appeals at its discretion.

Kyttx is not required to reinstate accounts, transactions, payouts, Seller Offerings, features, or access.

40No Guarantee of Approval

Kyttx does not guarantee that any User, account, Seller Offering, country, currency, payment method, payout method, transaction, withdrawal, or feature will be approved, supported, or available.

Approval in one case does not guarantee approval in another case.

Past approval does not prevent future restriction, suspension, or termination.

Kyttx may change its compliance standards at any time.

41Disclaimer

Kyttx does not guarantee that the Platform will detect all sanctions issues, fraud, illegal activity, payment abuse, restricted transactions, or compliance risks.

Users remain responsible for their own compliance with applicable law.

Kyttx is not responsible for User violations of sanctions, export controls, tax laws, payment provider rules, consumer laws, privacy laws, financial laws, or other legal requirements, except to the extent liability cannot be excluded by law.

42Limitation of Liability

To the maximum extent permitted by law, Kyttx is not liable for losses arising out of or relating to:

• Compliance reviews.
• Sanctions screening.
• Account restrictions.
• Account suspensions.
• Account terminations.
• Transaction blocks.
• Transaction reversals.
• Refunds.
• Payout holds.
• Reserves.
• Payment provider decisions.
• Bank decisions.
• Card network decisions.
• Regulator actions.
• Law enforcement actions.
• Service provider restrictions.
• Country restrictions.
• Currency restrictions.
• Payment method restrictions.
• Seller Offering restrictions.
• Failure to detect prohibited activity.
• Enforcement of this Policy.
• Lost revenue.
• Lost profits.
• Lost opportunities.
• Reputational harm.
• Business interruption.
• Indirect or consequential damages.

Kyttx?s liability is limited as provided in the Kyttx Master Terms of Service and applicable agreements.

43Indemnification

You agree to defend, indemnify, and hold harmless Kyttx and its owners, directors, officers, employees, contractors, agents, affiliates, licensors, service providers, and payment partners from and against any claims, demands, disputes, losses, liabilities, damages, fines, penalties, costs, and expenses, including reasonable legal fees, arising out of or relating to:

• Your violation of this Policy.
• Your violation of Sanctions Laws.
• Your violation of export controls.
• Your violation of payment provider rules.
• Your violation of bank or card network rules.
• Your false information.
• Your misleading information.
• Your restricted transactions.
• Your prohibited activity.
• Your sanctions evasion.
• Your money laundering activity.
• Your terrorist financing activity.
• Your fraud.
• Your payment abuse.
• Your tax violations.
• Your restricted country activity.
• Your restricted person activity.
• Your Seller Offerings.
• Your Operators, team members, contractors, affiliates, or representatives.
• Any claim that Kyttx is responsible for your compliance obligations or violations.

44Dispute Resolution

Any dispute, claim, or controversy arising out of or relating to this Policy, sanctions, restricted countries, restricted persons, restricted transactions, Compliance Reviews, account restrictions, payout holds, reserves, transaction blocks, enforcement actions, or related matters will be resolved according to the Kyttx Arbitration & Dispute Resolution Agreement and the dispute resolution provisions in the Kyttx Master Terms of Service.

Unless mandatory law requires otherwise:

• Governing law shall be the laws of the Dubai International Financial Centre.
• Arbitration shall be administered by the Dubai International Arbitration Centre.
• The seat of arbitration shall be the Dubai International Financial Centre, Dubai, United Arab Emirates.
• The language shall be English.
• The tribunal shall consist of one arbitrator.
• Disputes shall be confidential.
• Claims must be brought individually and not as class, collective, consolidated, representative, or group claims.
• The prevailing party may recover costs and legal fees where permitted.

Before commencing arbitration, the party raising the dispute must provide written notice and allow 30 days for informal resolution.

Kyttx may seek urgent court relief for sanctions issues, illegal activity, fraud, payment abuse, non-payment, negative balances, data misuse, security threats, intellectual property misuse, confidentiality breaches, or other urgent harm.

45Modifications

Kyttx may modify this Policy from time to time.

Kyttx may provide notice by posting an updated version, updating the ?Last Updated? date, sending email notice, displaying in-app notice, updating the dashboard, or using another reasonable method.

Changes are effective when posted or when otherwise stated.

Your continued use of the Platform after changes become effective constitutes acceptance of the updated Policy.

Kyttx may make immediate changes where required or appropriate due to legal requirements, sanctions changes, export control changes, payment partner requirements, bank requirements, card network requirements, security issues, fraud risk, compliance issues, operational changes, tax requirements, regulator guidance, or urgent platform needs.

46Survival

Obligations under this Policy survive account suspension, account termination, Seller Offering removal, Buyer access termination, Operator access termination, payout completion, transaction completion, refund completion, chargeback completion, or discontinuation of the Platform.

Surviving obligations include obligations relating to:

• Sanctions compliance.
• Restricted transactions.
• Payment abuse.
• Refunds.
• Chargebacks.
• Negative balances.
• Taxes.
• Recordkeeping.
• Cooperation.
• Confidentiality.
• Indemnification.
• Dispute resolution.
• Legal compliance.
• Enforcement.

47Contact

For legal notices and compliance matters:

legal@kyttx.com

For support:

support@kyttx.com

Website:

https://kyttx.com