Customer Agreement Policy
VAY Finance Remittance Ltd
Incorporation Number: BC1418776
Registered Address: 550 Robson Street, Suite 2012, Vancouver, BC V6B 2B7, Canada

1. Key Definitions

For the purposes of this Agreement, the following terms and definitions shall apply. These definitions are not exhaustive and may be supplemented by the Company from time to time to reflect regulatory or operational updates.


Company / VAY Finance Remittance Ltd – Refers to VAY Finance Remittance Ltd, a corporation incorporated under the laws of British Columbia, Canada, which owns and operates the Platform and provides services as described herein.


Platform – Refers to all digital systems, applications, websites, software, databases, and communication tools operated by the Company and accessible at www.toolyt.xyz.


Services – Refers to cryptocurrency and fiat currency exchange, payment processing, wallet-related operations, and other functions provided through the Platform.


Customer / Client – Refers to any individual or entity that has completed registration and verification procedures, holds an Account with the Company, and uses the Services.


Account – A registered profile on the Platform that allows a Customer to access Services, manage Funds, and perform transactions.


Fiat Currency – Legal tender issued by a sovereign government (e.g., CAD, USD, EUR).


Cryptocurrency / Digital Assets – Digital tokens or virtual currencies based on blockchain or similar technologies (e.g., BTC, ETH, USDT), which are not issued or backed by any government or central bank.


Funds – A general term encompassing both Fiat Currency and Cryptocurrencies held or transferred through the Platform.


AML/CTF – Anti-Money Laundering and Counter-Terrorist Financing obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and relevant Canadian regulations.


KYC / Due Diligence – Identification and verification procedures required to establish and maintain a Customer relationship in compliance with AML/CTF obligations.


Virtual IBAN (vIBAN) – A unique reference code assigned to facilitate fiat transfers to the Company's banking partners. A vIBAN does not function as a standalone account and cannot be used as a personal bank account.


2. Risk Disclosures and Customer Responsibilities

2.1 Acknowledgement of Risk

The Customer acknowledges that trading cryptocurrencies carries significant financial risk, including the risk of total loss of capital. Market conditions can change rapidly and unpredictably, and cryptocurrencies are not protected by deposit insurance or government-backed safeguards.


2.2 Security Risk

Despite the Company's implementation of advanced cybersecurity measures, the Customer understands that digital assets may still be subject to theft, hacking, cyberattacks, or technical failures, which may result in partial or total loss.


2.3 Regulatory Risk

The Customer understands that cryptocurrency regulation varies by jurisdiction and may change without notice. New restrictions, prohibitions, or tax laws may affect the legality, use, or transfer of digital assets.


2.4 Responsibility for Due Diligence

The Customer is responsible for conducting independent research before making any financial decision. The Company does not provide investment advice and strongly recommends Customers only invest funds they can afford to lose.


2.5 No Guarantee of Service Continuity

The Customer acknowledges that services may be temporarily or permanently suspended due to technical, legal, or regulatory reasons.


2.6 Customer Obligations

The Customer agrees to:


  • Safeguard login credentials and immediately report any suspected unauthorized use of their Account.

Refrain from using the Platform for illegal purposes, including money laundering, sanctions evasion, fraud, or terrorist financing.


Keep personal and financial information accurate and updated.


Assume full responsibility for compliance with tax reporting obligations in their jurisdiction.


3. Scope of Agreement and Acceptance of Terms

3.1 This Agreement governs the relationship between the Company and the Customer in connection with the Services provided through the Platform. 3.2


The Customer consents to be legally bound by the terms of this Agreement by:


  • Creating and maintaining an Account;

Using any functionality of the Platform;


Initiating any transaction or exchange through the Company. 3.3 If the Customer disagrees with any provision of this Agreement, they must not use the Platform. Continued use constitutes acceptance of all provisions.


4. Account Registration and Verification

4.1 Account Creation

To access Services, the Customer must register through the Platform by submitting required information and completing the Company's onboarding procedures.


4.2 Verification Procedures

The Company requires Customers to undergo identity verification (KYC/CDD). Customers may be asked to provide government-issued ID, proof of residence, banking information, or additional documentation such as source-of-funds declarations.


4.3 Restrictions

Each Customer may hold only one verified Account.


Accounts may not be opened in the name of another person or for the benefit of third parties without the Company's express written approval.


The Company may reject applications or close Accounts at its sole discretion without obligation to provide reasons, especially where AML/CTF risks are identified.


4.4 Ongoing Monitoring

The Company may request updated information at any time to ensure continued compliance with laws and regulations. Failure to provide updated information may result in suspension or closure of the Account.


5. Deposits, Withdrawals, and Transactions

5.1 General Rules

All deposits and withdrawals must be made through the methods approved by the Company, which may include bank transfers, card payments, or third-party payment processors. The Company reserves the right to modify, suspend, or remove available payment methods at any time.


5.2 Ownership of Accounts

Deposits may only be made from bank accounts, cards, or wallets in the Customer's own name. The use of third- party accounts is strictly prohibited. Any attempt to deposit or withdraw using unauthorized accounts may result in suspension, reversal of funds, or reporting to regulatory authorities.


5.3 Withdrawal Procedures

Withdrawals may be subject to identity verification, source-of-funds checks, or enhanced due diligence before approval.


The Company is not responsible for delays caused by banks, blockchain network congestion, or other intermediaries.


For security purposes, the Company may set daily or monthly withdrawal limits, which can be increased only upon successful completion of enhanced verification.


5.4 Transaction Accuracy

The Customer must provide complete and accurate payment instructions. The Company will not be responsible for losses resulting from errors in submitted details, including wrong wallet addresses, bank details, or reference codes.


5.5 Currency Conversion

Exchange rates displayed on the Platform are indicative of current market conditions and may fluctuate rapidly.


The Company does not guarantee execution of trades at a specific rate, and the final rate applied will be the one confirmed at the time of order execution.


5.6 Reversals and Rejections

The Company reserves the right to reject, cancel, or reverse any transaction if:


  • The Customer has breached this Agreement.

Fraud or suspicious activity is suspected.


The transaction violates applicable laws or regulatory restrictions.


6. Fees, Commissions, and Charges

6.1 General Policy

The Customer agrees to pay all applicable fees, commissions, charges, and costs as determined by the Company. Such fees may vary depending on the transaction type, asset class, or payment method.


6.2 Fee Disclosure

All fees will be published on the Platform and may be amended by the Company without prior notice. By initiating a transaction, the Customer acknowledges and accepts the applicable fee structure.


6.3 Exchange Rate Influence

Commissions may be calculated as a percentage of the transaction volume and may vary depending on prevailing market conditions. The Customer acknowledges that fees may impact the effective exchange rate applied.


6.4 Deduction of Fees

The Company may deduct applicable charges directly from the Customer's Account balance or from the proceeds of a transaction before funds are credited to the Customer.


6.5 Third-Party Costs

Fees imposed by banks, card processors, blockchain networks, or other third parties are the sole responsibility of the Customer and may be deducted in addition to Company fees.


7. Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF)

Compliance


7.1 Regulatory Commitment

VAY Finance Remittance Ltd is committed to full compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), FINTRAC guidelines, and other applicable Canadian and international AML/CTF standards.


7.2 Customer Due Diligence (CDD)

Customers must undergo identity verification prior to accessing services. This may include the submission of government-issued identification, proof of residence, photographs, video verification, or other documents.


7.3 Enhanced Due Diligence (EDD)

The Company reserves the right to conduct additional checks where:


  • The transaction volume or frequency exceeds regulatory thresholds (e.g., CAD 10,000+).

The Customer is linked to a high-risk jurisdiction or industry.


Suspicious activity, unusual patterns, or structuring of transactions are detected.


7.4 Transaction Monitoring

All transactions may be continuously monitored and reviewed for compliance with AML/CTF regulations. Suspicious or unusual activity will be reported to FINTRAC or other competent authorities without prior notice to the Customer.


7.5 Record Retention

The Company shall retain customer records, transaction data, and verification information for a minimum of five (5) years or longer where legally required.


7.6 Prohibited Activities

Customers may not use the Platform for illegal activities, including but not limited to:


  • Laundering of illicit funds.

Financing of terrorism or organized crime.


Sanctions evasion.


Fraudulent schemes or scams.


7.7 Consequences of Breach

Any violation of AML/CTF requirements may result in:


  • Suspension or closure of the Customer's Account.

Freezing of funds pending investigation.


Reporting to regulatory and law enforcement authorities.


8. Security of Accounts and Use of the Platform

8.1 Account Security

Customers are solely responsible for safeguarding their Account credentials, passwords, and two-factor authentication devices. Loss of credentials may result in loss of access to funds.


8.2 Unauthorized Access

The Company will not be liable for unauthorized transactions conducted through compromised Customer Accounts unless such compromise results directly from gross negligence on the part of the Company.


8.3 System Integrity

Customers agree not to interfere with, manipulate, or exploit the functionality of the Platform. Activities such as hacking, reverse engineering, automated data scraping, or exploiting system errors are strictly prohibited.


8.4 Monitoring of Use

The Company reserves the right to monitor all Account activity, communications, and transactions to ensure compliance with this Agreement and applicable laws.


8.5 Reporting Obligations

Customers must promptly notify the Company of:


  • Unauthorized access or suspicious activity involving their Account.

Any errors, technical failures, or discrepancies that may affect transactions.


Compromise or theft of login credentials.


8.6 Consequences of Misuse

Failure to adhere to security obligations may result in suspension of the Account, financial liability for losses, and possible reporting to authorities.


9. Liability and Limitations

9.1 No Guarantee of Service

The Platform and Services are provided on an "as is" and "as available" basis. The Company makes no guarantees that Services will be uninterrupted, error-free, secure, or continuously available.


9.2 Exclusion of Liability

To the fullest extent permitted by law, the Company shall not be liable for:


  • Losses caused by market volatility, rapid price fluctuations, or adverse market movements.

Interruptions, delays, or failures of telecommunications, internet providers, blockchain networks, or third-party payment systems.


Unauthorized access resulting from Customer negligence, such as weak passwords or unsecured devices.


Errors, bugs, or technical failures inherent to distributed ledger technology or the cryptocurrency ecosystem.


9.3 Indirect Damages

The Company shall not be held liable for indirect, incidental, punitive, or consequential damages, including but not limited to: loss of profits, business opportunities, goodwill, or reputational harm.


9.4 Force of Law

If a regulatory body, court, or authority mandates actions affecting Customer Accounts (such as freezes, seizures, or reporting obligations), the Company shall not be liable for any resulting financial impact.


9.5 Customer Indemnification

The Customer agrees to indemnify, defend, and hold harmless the Company, its officers, employees, contractors, and


affiliates from any claims, damages, or expenses (including legal costs) arising out of:


  • Breach of this Agreement.

Misuse of the Platform.


Violation of applicable laws, including AML/CTF obligations.


10. Customer Warranties, Representations, and Responsibilities

10.1 Capacity and Eligibility

The Customer represents that they are of legal age, mentally competent, and not subject to restrictions preventing them from entering into this Agreement.


10.2 Accuracy of Information

The Customer warrants that all information provided during registration or later updates is truthful, complete, and accurate. False or misleading information may result in Account suspension.


10.3 No Conflicting Agreements

The Customer confirms that they do not have separate agreements or side arrangements with Company employees, agents, or third parties promising guaranteed profits or reduced risks.


10.4 Obligation to Report Errors

If the Customer becomes aware of a system error, technical malfunction, or discrepancy affecting their Account, they must immediately notify the Company and must not exploit such errors for personal gain.


10.5 Tax Compliance

The Customer acknowledges that they are solely responsible for calculating, reporting, and paying taxes related to their transactions or holdings, as required by the laws of their jurisdiction. The Company shall not provide tax advice or assume liability for tax obligations.


10.6 Assumption of Risk

The Customer confirms that they understand the risks of cryptocurrency trading and accepts full responsibility for all financial outcomes.


11. Intellectual Property Rights

11.1 Ownership

All copyrights, trademarks, designs, trade names, software, databases, and other intellectual property associated with the Platform remain the exclusive property of the Company.


11.2 Limited License

The Company grants Customers a non-exclusive, revocable, and non-transferable license to use the Platform for personal purposes in accordance with this Agreement.


11.3 Restrictions

Customers may not:


  • Copy, reproduce, or redistribute content without authorization.

Modify, reverse-engineer, or attempt to extract source code.


Use the Company's branding for personal or commercial gain without prior written consent.


11.4 Termination of License

This limited license shall automatically terminate if the Customer's Account is suspended, terminated, or otherwise closed.


12. Termination and Suspension of Accounts

12.1 Termination by Customer

Customers may close their Account at any time by providing written notice, provided there are no outstanding liabilities or ongoing investigations.


12.2 Termination by Company

The Company may suspend or terminate an Account immediately and without prior notice if:


  • The Customer breaches any provision of this Agreement.

The Customer engages in fraudulent or illegal activity.


The Company suspects involvement in money laundering, terrorist financing, or sanctions evasion.


Continued service poses regulatory, reputational, or operational risk to the Company.


12.3 Effects of Termination

Pending transactions may be cancelled at the Company's discretion.


The Customer remains liable for obligations arising before termination.


Funds lawfully belonging to the Customer may be returned, subject to compliance checks and applicable laws.


12.4 Dormant Accounts

If an Account remains inactive for more than 12 months, the Company reserves the right to classify it as dormant and may impose administrative fees until reactivation or closure.


13. Restricted Jurisdictions and Geoblocking

13.1 Restricted Countries

The Company does not provide Services to Customers residing in jurisdictions that are:


  • Listed by Canadian regulators, FATF, or other recognized bodies as high-risk or non-cooperative in relation to
  • AML/CTF.

Subject to international sanctions, embargoes, or restrictions.


Where cryptocurrency trading is explicitly prohibited by law.


13.2 Geo-Blocking Measures

The Company uses technical and administrative measures (such as IP blocking, identity checks, and payment restrictions) to prevent access from restricted jurisdictions.


13.3 Customer Responsibility

The Customer must not attempt to circumvent geographical restrictions using VPNs, proxies, or false information. If discovered, the Company may close the Account and report the Customer to regulators.


13.4 USA Restrictions

Unless expressly authorized, the Company does not process transactions involving U.S.-incorporated banks, financial institutions, or residents, in order to comply with regulatory requirements.


14. Force Majeure

14.1 Definition

The Company shall not be liable for delays, failures, or interruptions in Services caused by events beyond its reasonable control ("Force Majeure Events").


14.2 Examples

Force Majeure Events may include, but are not limited to:


  • Natural disasters (floods, earthquakes, fires).

Armed conflicts, wars, terrorism, civil unrest, or political instability.


Acts of government, regulatory restrictions, sanctions, or law enforcement orders.


Failures of internet providers, payment networks, or blockchain protocols.


Cyber-attacks, denial-of-service (DoS) attacks, or catastrophic system failures.


14.3 Consequences

During a Force Majeure Event, the Company may suspend Services, freeze Accounts, or delay processing until normal operations can resume.


14.4 No Liability

The Company shall not be responsible for financial losses incurred by Customers as a result of Force Majeure.


15. Dispute Resolution

15.1 Complaints Procedure

Customers may file complaints with the Company by contacting support@toolyt.xyz. Complaints should include full details of the issue and any supporting evidence.


15.2 Review Period

The Company shall review and respond to complaints within 30 business days, unless extended due to complexity or legal constraints.


15.3 Negotiation First

Both parties agree to attempt to resolve disputes amicably through negotiation before pursuing formal legal action.


15.4 Arbitration Option

The Company may, at its discretion, propose resolving disputes through independent arbitration or mediation. The Customer may accept or decline such proposals.


15.5 Court Jurisdiction

If disputes cannot be resolved, they shall fall under the exclusive jurisdiction of the courts of British Columbia, Canada.


16. Governing Law

16.1 This Agreement shall be governed by and construed in accordance with the laws of Canada, and more specifically the laws of the Province of British Columbia, without regard to conflict-of-law principles. 16.2 Any legal proceedings arising from this Agreement shall be exclusively brought before competent courts in Vancouver, British Columbia. 16.3 The Customer irrevocably waives any right to object to proceedings being brought in such courts on the grounds of inconvenient forum or similar doctrine.


17. Privacy and Data Protection

17.1 General Principles

VAY Finance Remittance Ltd is committed to safeguarding the personal data of its Customers. We collect, store, and process personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), applicable provincial privacy laws, and where relevant, the General Data Protection Regulation (EU) 2016/679 (GDPR) for Customers residing in the European Union.


17.2 Types of Data Collected

The Company may collect and process, among other things:


  • Identification information (full name, date of birth, nationality, government-issued ID numbers).

Contact information (address, phone number, email address).


Financial details (bank account information, source of funds, payment card data).


Transaction history and account activity.


Technical information (IP addresses, device identifiers, cookies, geolocation data).


17.3 Purpose of Processing

Personal data is collected and processed for the following purposes:


  • To verify identity and comply with AML/CTF laws.

To provide and improve the Services.


To secure the Platform against fraud and cyber threats.


To comply with tax, legal, and regulatory obligations.


To provide customer support and maintain communications.


17.4 Data Retention

The Company retains personal data for a minimum of five (5) years after the end of the business relationship, or longer where required by law.


17.5 Data Sharing

Customer information may be shared with:


  • Regulatory authorities (e.g., FINTRAC, tax authorities) in accordance with reporting obligations.

Law enforcement agencies when required by law.


Third-party service providers assisting with compliance, KYC, payment processing, or technical operations.


17.6 Customer Rights

Subject to applicable law, Customers may have the right to:


  • Access their personal data.

Request correction of inaccurate or incomplete information.


Request deletion of data (where not legally required to be retained).


Withdraw consent to certain data processing activities.


17.7 Cross-Border Transfers

Data may be transferred outside of Canada for processing or storage. In such cases, appropriate safeguards will be implemented to ensure adequate protection.


18. Confidentiality

18.1 Company Obligations

The Company shall treat all Customer information as confidential and will not disclose it to third parties except:


  • When required by law or regulatory authority.

When disclosure is necessary to provide the Services.


When explicitly authorized by the Customer.


18.2 Customer Obligations

The Customer agrees not to disclose sensitive Company information, including trade secrets, proprietary algorithms, or non-public operational details, obtained in the course of using the Platform.


18.3 Waiver of Confidentiality in Disputes

The Customer acknowledges that, in the event of legal proceedings, complaints, or dispute resolution, communications may be disclosed to courts, arbitrators, or regulators as necessary.


19. Communications and Notices

19.1 Primary Channel

All official communications will be made electronically through the Customer's registered email address. Such communications are deemed received once sent by the Company, regardless of whether the Customer opens or reads the message.


19.2 Platform Notifications

Notices may also be delivered via the Customer's Account dashboard or through Platform pop-up messages.


19.3 Customer Responsibility

The Customer is responsible for ensuring their contact information remains up to date. The Company is not liable for undelivered notices due to outdated or incorrect information.


19.4 Language

All communications shall be in English, unless otherwise agreed in writing.


20. Amendments and Changes

20.1 Right to Amend

The Company reserves the right to amend, update, or modify this Agreement at any time to reflect changes in services, laws, regulations, or market conditions.


20.2 Notification of Changes

Updated versions of the Agreement will be posted on the Platform with a revised "Last Updated" date. Customers may also be notified via email or Platform announcements.


20.3 Binding Effect

Amendments shall take effect one (1) business day after publication, unless otherwise specified. Continued use of the Platform constitutes acceptance of the updated Agreement.


20.4 Refusal of Amendments

If the Customer does not agree with updated terms, they must immediately discontinue use of the Services and request closure of their Account.


21. Miscellaneous Provisions

21.1 Entire Agreement

This Agreement constitutes the entire agreement between the Company and the Customer regarding the Services and supersedes all prior understandings.


21.2 Severability

If any provision of this Agreement is found to be invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect.


21.3 Assignment

The Company may assign or transfer its rights and obligations under this Agreement without prior consent. The Customer may not assign or transfer their rights without written approval from the Company.


21.4 Non-Waiver

The failure of the Company to enforce any right or provision of this Agreement shall not constitute a waiver of that right or provision.


21.5 Survival of Provisions

Termination of this Agreement shall not affect provisions intended to survive, including but not limited to: liability limitations, indemnities, dispute resolution, and governing law.


22. Customer Support and Contact Information

22.1 Support Services

The Company provides customer support through email and, where available, live chat on the Platform. Support hours may be limited and are published on the Platform.


22.2 Contact Information

Customers may contact the Company for questions, complaints, or assistance at:


  • ? VAY Finance Remittance Ltd
  • 550 Robson Street, Suite 2012
  • Vancouver, BC V6B 2B7, Canada
  • ? support@toolyt.xyz

22.3 Response Time

The Company aims to acknowledge inquiries within 48 hours and provide full responses within 10 business days, though complex cases may require longer.


23. Final Acknowledgement

By registering an Account and using the Platform, the Customer confirms that they:


  • Have read this Agreement in full.

Understand the risks and responsibilities associated with cryptocurrency transactions.


Accept all terms, obligations, and limitations set forth herein. Continued use of the Services constitutes ongoing acceptance of this Agreement and any future amendments.