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COMPLIANCE POLICY & REGULATORY COOPERATION PRINCIPLES

Version
1.1
Effective Date
28.10.2026
Last Updated
28.10.2026
IMPORTANT NOTICE – PLEASE READ CAREFULLY

This Compliance Policy & Regulatory cooperation principles is an Associated Document of the Platform's Terms of Use and shall be read in conjunction with all other Associated Documents, each of which is incorporated by reference. Defined terms used herein have the meanings ascribed to them in the Terms of Use unless otherwise stated. By accessing or continuing to use the Platform, you acknowledge that you have read and understood this Compliance Policy & Regulatory cooperation principles. If you do not agree to this Compliance Policy & Regulatory cooperation principles, you must cease using the Platform.

1. INTRODUCTION AND PURPOSE
1.1. Purpose and Scope

This Compliance Policy & Regulatory cooperation principles (the "Policy") sets forth the compliance framework, regulatory cooperation principles, and legal obligations of Better Tomorrow Group LTD (the "Company", "we", "us", or "our"), as the operator of the Obmify platform (the "Platform").

This Policy is intended to serve as the primary reference document for external regulatory authorities, law enforcement agencies, supervisory bodies, and other competent governmental institutions conducting inquiries, investigations, or assessments concerning the Platform's operations, compliance posture, and cooperation with legal processes.

1.2. Nature of Platform Operations

The Platform operates as an information aggregator and comparison service that collects, organises, and displays information about independent third-party cryptocurrency exchange service providers ("Listed Exchangers"). The Platform enables users to compare exchange rates, access ratings and reviews, and navigate to Listed Exchangers' websites.

The Company does not:

  • Execute, process, settle, or intermediate any exchange, purchase, sale, transfer, or conversion of crypto-assets or fiat currencies;
  • Hold, control, or exercise custody over any users' funds, crypto-assets, private keys, or wallets;
  • Collect, transmit, or transfer payments, funds, or crypto-assets between users and Listed Exchangers;
  • Act as a party to any transaction between a user and a Listed Exchanger;
  • Provide investment, financial, legal, or tax advice;
  • Qualify as a Virtual Asset Service Provider (VASP) under the BVI Virtual Assets Service Providers Act, 2022, or as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 (MiCA).

Consequently, the Company does not monitor, track, or have access to transactions executed by users after they navigate to third-party Listed Exchanger services save for transaction details (such as references, wallet addresses or transaction hashes) provided to the Company by a User or a Listed Exchanger in connection with a complaint, claim or support request. Users engage with Listed Exchangers directly and independently, and all transactional relationships, custody arrangements, and compliance obligations arising from such engagement rest exclusively with the Listed Exchanger and the user.

1.3. Foundational Documents

This Policy forms an integral part of the Company's compliance and governance framework and should be read in conjunction with the following Associated Documents: Privacy Policy, Cookie Policy, Sanctions and Geo-Blocking Policy, Dispute Resolution Policy, Risk Disclosure & No-Advice Notice.

In the event of any conflict or inconsistency between this Policy and the Platform Terms of Use, the Terms of Use shall prevail. This Policy supplements and does not supersede the detailed provisions set out in the Terms of Use and Associated Documents.

2. APPLICABLE LEGAL FRAMEWORK
2.1. Governing Law and Jurisdiction

The Company is incorporated and registered under the laws of the British Virgin Islands. Accordingly, the Company's primary legal obligations arise under BVI law, and may include but not limited to:

  • BVI Business Companies Act (Revised Edition 2020);
  • BVI Data Protection Act, 2021 (No. 3 of 2021);
  • BVI Anti-Money Laundering Regulations, as amended;
  • Anti-Money Laundering and Terrorist Financing Code of Practice (as amended);
  • Proceeds of Criminal Conduct Act (Cap. 10.21);
  • Counter Terrorism Act (No. 33 of 2021);
  • Proliferation Financing Prohibition Act (No. 20 of 2021);
  • Criminal Justice (International Cooperation) Act (Revised Edition 2020);
  • Drug Trafficking Offences (Designated Countries and Territories) Act;
  • Mutual Legal Assistance (United States of America) Act;
  • Electronic Transactions Act, 2021 (No. 6 of 2021).
2.2. Extended and Extraterritorial Application

Whilst the Company is a BVI entity, the Platform's operations may engage legal frameworks beyond BVI domestic law, including:

1. UK Sanctions Extended to the BVI. The United Kingdom's sanctions regime under the Sanctions and Anti-Money Laundering Act 2018 has been extended to the British Virgin Islands by the Russia Sanctions (Overseas Territories) Order 2020 (S.I. 2020/1571), as amended. All financial, trade, and asset-freeze prohibitions imposed under UK law — including those administered by the Office of Financial Sanctions Implementation (OFSI) and the Office of Trade Sanctions Implementation (OTSI) — apply directly in the BVI and bind the Company.

2. United Nations Security Council Sanctions. The Company complies with all financial sanctions, asset freezes, trade embargoes, and other restrictive measures imposed by resolutions of the United Nations Security Council as implemented in the BVI through applicable UK Overseas Territories Orders.

3. EU Data Protection Framework. Only where and to the extent required by Applicable European Regulation, the Company processes personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR"), to the extent applicable to the Company's processing activities concerning data subjects in the EU/EEA.

2.3. Regulatory Supervision

Without prejudice to the Company's position that it does not provide licensed or regulated financial services and is not a virtual asset service provider ("VASP") or crypto-asset service provider ("CASP"), the Company engages with, cooperates with, and responds to lawful requests from the following BVI authorities, to the extent relevant to its operations as a company incorporated in the British Virgin Islands:

  • BVI Financial Services Commission (FSC) — the Company engages with the FSC as and when relevant to its operations, including in connection with AML/CFT-related matters, without this constituting an acknowledgment that the Company is licensed, registered, or regulated by the FSC as a provider of financial services;
  • BVI Financial Investigation Agency (FIA) — the Company cooperates with the FIA and submits suspicious activity or transaction reports where required under applicable law;
  • BVI Registrar of Corporate Affairs — maintains the Company's beneficial ownership information and corporate records, as required of all companies incorporated in the BVI;
  • Office of the Governor of the BVI — the Competent Authority for sanctions implementation and enforcement, with which the Company cooperates as required by applicable law;
  • BVI Attorney General's Office and Virgin Islands Sanctions Unit — responsible for sanctions compliance and enforcement coordination, with which the Company cooperates as required;
  • BVI Information Commissioner — oversees compliance with the BVI Data Protection Act, applicable to the Company's processing of personal data.

The Company maintains open channels of communication with these authorities and responds promptly and fully to any lawful request, inquiry, or requirement for filings, reports, or disclosures made by a competent authority.

3. DISCLOSURE OBLIGATIONS AND COOPERATION WITH AUTHORITIES
3.1. Commitment to Transparency and Regulatory Cooperation

The Company is unequivocally committed to full and proactive cooperation with all competent regulatory authorities, supervisory bodies, law enforcement agencies, financial intelligence units, prosecutorial authorities, judicial authorities, and other governmental institutions in any jurisdiction.

The Company affirms that:

  • It operates in compliance with all applicable disclosure obligations under BVI law and international legal cooperation frameworks;
  • It will respond promptly, comprehensively, and accurately to all lawful requests for information, records, data, documentation, and assistance from competent authorities;
  • It recognises that transparency and regulatory cooperation are essential to maintaining the integrity of the financial system and combating financial crime, money laundering, terrorist financing, proliferation financing, and other illicit activities;
  • No commercial interest, contractual arrangement, or operational consideration shall take precedence over the Company's legal and regulatory obligations to cooperate with authorities.
3.2. Legal Basis for Disclosure and Cooperation

The Company's obligations to disclose information and cooperate with authorities arise under multiple statutory and treaty-based frameworks, including but not limited to:

1. BVI Anti-Money Laundering Regulations. Under the BVI Anti-Money Laundering Regulations, as amended, and the AML/CFT Code of Practice, the Company could be required to report suspicious transactions to the Financial Investigation Agency without delay and to provide such information and assistance as may be required by the FIA in connection with its investigative and intelligence functions.

2. Proceeds of Criminal Conduct Act. The Proceeds of Criminal Conduct Act (Cap. 10.21) imposes obligations to disclose knowledge or suspicion of money laundering, to respond to production orders issued by the BVI courts, and to provide assistance to domestic and international law enforcement authorities in connection with investigations and proceedings concerning the proceeds of crime.

3. Counter Terrorism Act and Proliferation Financing Prohibition Act. The Counter Terrorism Act (No. 33 of 2021) and the Proliferation Financing Prohibition Act (No. 20 of 2021) could impose reporting obligations and could require cooperation with authorities in respect of suspected terrorist financing and proliferation financing activities.

4. Criminal Justice (International Cooperation) Act. The Criminal Justice (International Cooperation) Act establishes a regime enabling the BVI to cooperate with foreign jurisdictions in matters pertaining to criminal investigations and proceedings. The Act authorises the Governor and the Attorney General to provide assistance to foreign competent authorities, including the provision of evidence, documentation, witness statements, and other forms of legal assistance.

5. Mutual Legal Assistance Treaties (MLATs). The BVI is party to bilateral and multilateral mutual legal assistance treaties, including the Mutual Legal Assistance (United States of America) Act, which facilitate formal cooperation between BVI authorities and foreign jurisdictions in criminal investigations, prosecutions, asset recovery, and other legal proceedings.

6. BVI Data Protection Act. The BVI Data Protection Act permits the disclosure of personal data without the consent of the data subject where such disclosure is required or authorised by law, is necessary for the prevention, detection, investigation, or prosecution of offences, or is required in connection with legal proceedings or the administration of justice.

7. Court Orders, Warrants, and Production Orders. The Company is legally obliged to comply with any order, warrant, subpoena, or production order issued by any court of competent jurisdiction in the BVI or recognised under BVI law, including orders issued pursuant to mutual legal assistance requests from foreign jurisdictions.

8. Sanctions Compliance Reporting. The Virgin Islands Sanctions Unit, under the authority of the Attorney General, is the primary point of contact for sanctions-related compliance and enforcement. The Company could be required to report any suspected sanctions breaches, provide information concerning designated persons or entities, and respond to sanctions-related inquiries.

3.3. Scope of Information Subject to Disclosure

The Company may be required to disclose, and stands ready to disclose upon lawful request, any information, records, data, or documentation within its possession or control, including but not limited to:

  • Records of Listed Exchangers, including onboarding documentation, compliance information;
  • User-related data, including IP addresses, geolocation data, timestamps, browser information, and user-generated content (reviews, ratings);
  • Transaction metadata concerning interactions between Users and the Platform (excluding transactional data concerning exchanges executed by Listed Exchangers, which the Company does not collect or possess save for transaction details (such as references, wallet addresses or transaction hashes) provided to the Company by a User or a Listed Exchanger in connection with a complaint, claim or support request);
  • Internal policies, procedures, risk assessments, and compliance documentation;
  • Suspicious activity reports submitted to the FIA (if any).
3.4. Procedures for Receiving and Responding to Requests

The Company observes a strict three-tier hierarchy for the receipt of and response to requests for information, records, data, or assistance. The applicable tier determines both the channel through which a request must be submitted and the Company's legal obligations in respect thereof.

Tier 1 — BVI Competent Authorities (Mandatory Compliance)

Requests submitted directly by BVI domestic regulatory and law enforcement authorities are legally binding upon the Company. The Company shall respond promptly and comprehensively to all lawful requests originating from:

  • the BVI Financial Services Commission (FSC);
  • the BVI Financial Investigation Agency (FIA);
  • the BVI Attorney General's Office and Virgin Islands Sanctions Unit;
  • the Office of the Governor of the British Virgin Islands;
  • any BVI court of competent jurisdiction, by way of court order, production order, search warrant, or other judicial instrument;
  • the BVI Registrar of Corporate Affairs;
  • the BVI Information Commissioner.

The Company shall respond to Tier 1 requests within fifteen (15) working days of receipt, or within three (3) working days where the request concerns crime prevention, terrorism, sanctions enforcement, or other matters of immediate public safety or security.

Tier 2 — Foreign Competent Authorities (Mandatory Compliance via BVI Channels)

Foreign law enforcement agencies, regulatory bodies, supervisory authorities, prosecutorial authorities, and judicial authorities have no direct legal authority to compel disclosure from a BVI-incorporated company under BVI law. Accordingly, foreign authorities seeking information, records, documents, or other assistance from the Company must route all requests through the applicable BVI competent authority via the following formal international cooperation mechanisms:

  • Mutual Legal Assistance Requests (MLATs) transmitted through the BVI Attorney General's Office or the Office of the Governor of the British Virgin Islands, in accordance with the Criminal Justice (International Co-operation) Act (Revised Edition 2020);
  • Letters of Request (Rogatory) addressed to the BVI Governor or Attorney General;
  • Inter-agency information sharing through the BVI Financial Investigation Agency, acting in its capacity as the BVI Financial Intelligence Unit and member of the Egmont Group of Financial Intelligence Units, for AML/CFT-related intelligence requests;
  • Any other formal international cooperation framework to which the BVI is a party.

The Company will comply with Tier 2 requests only upon receipt of a corresponding instruction, order, or authorisation issued by a BVI competent authority through the applicable cooperation mechanism. The Company is not legally obligated to respond to requests submitted directly by foreign authorities that have not been routed through BVI channels, and reserves the right to decline such requests without incurring liability.

Tier 3 — Direct Informal Requests from Foreign Authorities (Voluntary Cooperation)

The Company may, entirely at its sole and absolute discretion, choose to respond voluntarily to direct informal or administrative inquiries submitted by foreign regulatory or law enforcement authorities, provided that:

  • such response does not require the disclosure of personal data in a manner inconsistent with the BVI Data Protection Act, 2021 or applicable data protection law;
  • such response does not conflict with any provision of BVI law or applicable international legal obligations;
  • the requesting authority provides satisfactory evidence of its official capacity and the lawful basis for its inquiry.

Any such voluntary response shall not be construed as a waiver of the Company's right to require formal routing through BVI competent authorities for subsequent or related requests, nor as an acknowledgement that the requesting authority has any direct legal authority over the Company.

Verification and Transmission

In respect of all Tier 1 and Tier 2 requests, the Company shall verify the authenticity and legitimacy of each request prior to any disclosure. The Company reserves the right to request additional information, clarification, or authentication from the requesting or routing authority. All information provided in response to official requests shall be transmitted via secure communication channels, including encrypted transmission or such other secure means as may be specified by the requesting authority. The Company shall not disclose the fact that it has received a request or has provided information to any third party, including the subject of the request, except where required or permitted by law or expressly authorised by the requesting authority.

3.5. Proactive Reporting Obligations

In addition to responding to requests, the Company has proactive reporting rights under BVI law, including:

  • Suspicious Activity Reports (SARs). Where the Company knows or suspects that a Listed Exchanger, user, or any other person is engaged in money laundering, terrorist financing, proliferation financing, sanctions evasion, or other financial crime, the Company could submit a Suspicious Activity Report to the Financial Investigation Agency without delay, in accordance with the procedures set out in the AML/CFT Code of Practice.
  • Sanctions Breach Reporting. Any suspected breach of applicable sanctions regimes, including the listing of or interaction with designated persons or entities, could be reported to the Virgin Islands Sanctions Unit and, where applicable, to OFSI or other relevant Sanctions Authorities.
  • Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, the Company could notify the BVI Information Commissioner and, where applicable, affected data subjects, in accordance with the BVI Data Protection Act, 2021 and the GDPR.
3.6. Grounds for Refusal to Provide Information

The Company reserves the right to decline, in whole or in part, any request for information, records, data, or assistance on the following grounds:

  1. The request has been submitted directly to the Company by a foreign authority without having been routed through the BVI competent authority in accordance with the formal international cooperation mechanisms described in Section 3.4 (Tier 2). A foreign authority's direct request, absent the requisite BVI-level authorisation, does not create a legal obligation to disclose.
  2. The request is not grounded in a provision of BVI law, a binding court order or production order issued by a court of competent jurisdiction in the BVI, an applicable mutual legal assistance treaty, or another recognised legal cooperation framework. Requests based solely on the domestic law of a foreign jurisdiction, without any BVI nexus or implementing mechanism, do not constitute a lawful basis for disclosure under BVI law.
  3. Compliance with the request would require the Company to act in a manner that violates or is inconsistent with the BVI Data Protection Act, 2021 (No. 3 of 2021), the BVI Anti-Money Laundering Regulations, the BVI Business Companies Act (Revised Edition 2020), or any other provision of applicable BVI law.
  4. The request is based on foreign legislation, a foreign judicial order, or a foreign regulatory directive that is contrary to the public policy of the British Virgin Islands, as recognised under BVI common law and applicable statutory frameworks.
  5. The requested information does not exist within the Company's possession, custody, or control.
  6. The request is excessively broad, fails to identify with reasonable particularity the information sought, the legal basis for the request, or the purpose for which the information is required, or is otherwise disproportionate to any legitimate investigative or regulatory objective.
  7. In accordance with the Criminal Justice (International Co-operation) Act (Revised Edition 2020) and applicable BVI public policy, the Company may decline to cooperate with requests that relate exclusively to fiscal or tax offences under foreign law, or offences of a political character, where no corresponding criminal offence exists under BVI law and no BVI court order has been issued compelling disclosure.
  8. Legal Professional Privilege. Information or documents that are subject to legal professional privilege under BVI law shall not be disclosed without the prior written waiver of privilege by the Company's legal advisers.

Where the Company determines that a refusal is warranted, it shall notify the requesting authority or the relevant BVI competent authority of the grounds for refusal within a reasonable period, and shall where appropriate invite the requesting authority to resubmit its request through the correct formal channel or to provide further particulars addressing the grounds for refusal.

A refusal to comply with a request does not preclude the Company from subsequently complying with a reformulated request that addresses the grounds for refusal, or with a request submitted through the proper BVI competent authority channel.

3.7. No Liability for Cooperation Actions

The Company shall not be liable to any user, Listed Exchanger, or third party for any loss, damage, inconvenience, or adverse outcome arising from any disclosure, reporting, or cooperation action taken in compliance with this Section 3, including but not limited to:

  • The provision of information, records, or data to any competent authority;
  • The suspension, restriction, or termination of access to the Platform pursuant to an instruction or requirement of any regulatory, law enforcement, or judicial authority;
  • Any delay in, or inability of the Company to provide, services by reason of compliance with any lawful demand or requirement;
  • Any adverse outcome for the user or Listed Exchanger resulting from the Company's cooperation with any formal or informal inquiry or investigation.

Compliance with legal obligations to cooperate with authorities takes unconditional precedence over any commercial arrangement, contractual obligation, or operational consideration.

4. LIMITATIONS ON DATA COLLECTION AND MONITORING
4.1. Platform as Information Aggregator Only

As set out in Section 1.2 of this Policy and Section 4 of the Platform Terms of Use, the Company operates an information aggregator service and does not act as a financial intermediary, payment processor, or transactional platform.

The Company does not collect, monitor, track, or have access to any information concerning:

  • Transactions executed by users with Listed Exchangers after the user navigates to the Listed Exchanger's website or platform;
  • Funds, crypto-assets, or fiat currency transferred, exchanged, or held by Listed Exchangers on behalf of users;
  • Private keys, wallet addresses, or custody arrangements between users and Listed Exchangers;
  • Identity verification (KYC) documentation, source of funds information, or customer due diligence records maintained by Listed Exchangers;
  • The outcome, completion, or status of any exchange transaction initiated by a user with a Listed Exchanger.
4.2. Implications for Regulatory Cooperation

Whilst the Company is fully committed to cooperation with authorities, the scope of information the Company can provide is necessarily limited to information within its possession or control. The Company cannot provide:

  • Transactional records of exchanges executed by Listed Exchangers;
  • KYC documentation or customer due diligence records held by Listed Exchangers;
  • Wallet addresses, transaction hashes, or blockchain-level data concerning user transactions with Listed Exchangers;
  • Financial records or account information held by Listed Exchangers in respect of user accounts.

Authorities seeking such information should direct inquiries to the relevant Listed Exchanger directly. The Company will, upon request and to the extent permitted by law, provide contact information and available details concerning Listed Exchangers to assist authorities in their investigations.

4.3. Independence of Listed Exchangers

Listed Exchangers are independent third-party entities that operate autonomously and are solely responsible for:

  • Compliance with all applicable licensing, registration, and regulatory requirements in every jurisdiction in which they operate;
  • Implementation and enforcement of their own KYC/CDD policies and AML/CFT controls;
  • Reporting suspicious transactions to the financial intelligence units in their respective jurisdictions;
  • Responding to regulatory inquiries, law enforcement requests, and court orders concerning their own operations and customer relationships;
  • Maintaining records, freezing assets, or providing disclosure in accordance with legal obligations applicable to them.

The Company exercises no control over, and bears no responsibility for, the compliance posture, regulatory status, or investigative cooperation of Listed Exchangers. The listing of an Exchanger on the Platform does not constitute an endorsement, certification, or representation by the Company as to the Exchanger's compliance, legitimacy, or cooperation with authorities.

5. SANCTIONS COMPLIANCE

The Company operates in full compliance with applicable sanctions regimes, including UK sanctions extended to the BVI, UN Security Council sanctions, and equivalent international standards. Comprehensive provisions concerning:

  • Applicable sanctions frameworks (UK, UN, EU, BVI regulatory authorities);
  • Prohibited persons and restricted jurisdictions;
  • Sanctions screening and monitoring procedures;
  • Reporting obligations to the Virgin Islands Sanctions Unit, FIA, and OFSI;

are set out in Section 13 of the Platform Terms of Use.

The Company will not knowingly enable, facilitate, or permit the use of the Platform to circumvent, evade, or assist in evading applicable sanctions, and cooperates fully with authorities in identifying and preventing sanctions evasion schemes.

6. ANTI-MONEY LAUNDERING AND COUNTER-TERRORIST FINANCING COMPLIANCE

The Company operates in compliance with the BVI Anti-Money Laundering Regulations (Revised Edition 2020), as amended, and the Anti-Money Laundering and Terrorist Financing Code of Practice (as amended in 2023, 2024, and 2025).

The Platform AML terms are incorporated into the Platform Terms of Use (Section 14) and form an integral part of the Company's compliance framework. Authorities seeking detailed information concerning the Company's AML/CFT controls should refer to Section 14 of the Platform Terms of Use.

Key AML/CFT compliance principles:

As the Company does not enter into transactional relationships with users and does not hold, control, or transfer funds or crypto-assets, the Company does not perform customer due diligence (CDD) or know-your-customer (KYC) procedures on Platform users. Responsibility for conducting CDD and KYC rests entirely with the Listed Exchangers. Detailed AML/CFT obligations and customer due diligence requirements applicable to Listed Exchangers are set out in Section 14 of the Platform Terms of Use.

7. CONTENT MODERATION AND REMOVAL OF UNLAWFUL MATERIAL

The Platform hosts user-generated content in the form of reviews, ratings, and comments concerning Listed Exchangers.

Categories of prohibited content and prohibited conduct are comprehensively set out in Section 8 and Section 11 of the Platform Terms of Use.

7.1. Notice and Takedown Procedures

The Company operates a notice and takedown procedure for the expeditious removal of unlawful or prohibited content. Any person or authority may notify the Company of unlawful content at contact@bettertomorrowgroupltd.com. The Company will review reported content and, where unlawful or prohibited, remove or disable access within:

  • Three (3) working days for urgent cases;
  • Thirty (30) working days for other categories.

Appeals are reviewed by a human in accordance with the Platform's Dispute Resolution Policy.

7.2. Proactive Monitoring and Cooperation with Authorities

The Company employs automated tools and manual review processes to proactively detect and remove prohibited content, applying risk-based and targeted monitoring consistent with the nature and scale of the Platform's operations.

The Company cooperates fully with law enforcement and regulatory authorities in connection with investigations concerning unlawful content, including providing records, metadata, preserving evidence, and responding to court orders or regulatory directives.

Content removal records are retained for a minimum of five (5) years and are made available to competent authorities upon lawful request.

8. CROSS-JURISDICTIONAL COMPLIANCE

The Platform is accessible to users in multiple jurisdictions. The Company endeavours to comply with applicable laws in all jurisdictions in which it operates.

8.1. Geolocation-Based Access Controls and Restricted Jurisdictions

The Company could employ geolocation data, IP address analysis, and other technical means to identify user locations and apply jurisdictional restrictions. Access to the Platform is restricted or blocked for users located in Prohibited Jurisdictions subject to international sanctions. A comprehensive list of Prohibited Jurisdictions is set out in Section 3 of the Sanctions and Geo-Blocking Policy, incorporated by reference in Section 13 of the Platform Terms of Use.

The Company does not target or direct its services to users in Prohibited Jurisdictions and takes reasonable technical and organisational measures to prevent access from such jurisdictions.

8.2. Compliance with EU Digital Services Act

To the extent that the Company qualifies as a provider of intermediary services within the meaning of Regulation (EU) 2022/2065 (Digital Services Act, "DSA"), the Company complies with applicable DSA obligations, including transparency obligations, notice and action mechanisms for reporting illegal content, internal complaint-handling systems, and cooperation with EU Member State Digital Services Coordinators and competent authorities.

8.3. No Targeting of Prohibited Jurisdictions

The Company does not market, advertise, or promote the Platform in Prohibited Jurisdictions; does not list exchangers that primarily serve customers in Prohibited Jurisdictions; and does not establish contractual relationships with service providers located in or connected to Prohibited Jurisdictions.

9. DATA PROTECTION AND PRIVACY COMPLIANCE

The Company processes personal data in accordance with the BVI Data Protection Act, 2021 (No. 3 of 2021) and only where and to the extent required by Applicable European Regulation, the Company processes personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR"), to the extent applicable to the Company's processing activities concerning data subjects in the EU/EEA.

The Platform's Privacy Policy sets out in detail:

  • Categories of personal data collected and information sources;
  • Legal bases for processing (Section 3);
  • Purposes of processing (Section 4);
  • Disclosure to third parties, service providers, and authorities (Section 5);
  • International data transfers, including Standard Contractual Clauses for EEA/UK transfers (Section 8);
  • Data retention periods (Section 9);
  • Security measures (Section 10);
  • Data subject rights and procedures for exercising such rights (Section 11);
  • Jurisdiction-specific supplemental notices (Sections 12–15);
  • Contact details for privacy inquiries.

Authorities seeking detailed information concerning the Company's data protection practices should refer to the Privacy Policy.

10. CONTACT INFORMATION FOR REGULATORY AND LAW ENFORCEMENT INQUIRIES
10.1. BVI Competent Authorities (Tier 1 — Direct Contact)

BVI regulatory authorities, the BVI Financial Investigation Agency, BVI courts, and other BVI competent authorities (as described in Section 3.4, Tier 1) may direct all requests, orders, and official communications directly to:

CompanyBetter Tomorrow Group LTD
AddressSixth (6th) Floor, Water's Edge Building 1, Wickham's Cay II, Road Town, Tortola, British Virgin Islands
Emailcontact@bettertomorrowgroupltd.com
10.2. Foreign Competent Authorities (Tier 2 — Via BVI Channels)

Foreign law enforcement agencies, regulatory bodies, prosecutorial authorities, and judicial authorities must route all requests for information, mutual legal assistance, and other formal cooperation through the applicable BVI competent authority. Foreign authorities are directed to contact:

For MLAT and Criminal Justice Cooperation Requests:

DepartmentAttorney General's Chambers
AddressRoad Town, Tortola, British Virgin Islands
Emailagsoffice@gov.vg
Telephone+1 (284) 468-2992

For AML/CFT Financial Intelligence Requests:

DepartmentBVI Financial Investigation Agency (FIA) — Egmont Group Member
AddressP.O. Box 3342, Road Town, Tortola, British Virgin Islands
Emailinfo@fiabvi.vg
Telephone+1 (284) 468-3190
Websitewww.fiabvi.vg

For Sanctions-Related Requests:

DepartmentVirgin Islands Sanctions Unit, Attorney General's Chambers
AddressRoad Town, Tortola, British Virgin Islands
Emailagsoffice@gov.vg

For Regulatory / FSC-Related Requests:

DepartmentBVI Financial Services Commission
AddressPasea Estate, Road Town, Tortola, British Virgin Islands
Emailcommissioner@bvifsc.vg
Telephone+1 (284) 494-1324
Websitewww.bvifsc.vg
10.3. Informal and Administrative Inquiries (Tier 3 — Voluntary)

Foreign regulatory or public authorities wishing to submit informal or administrative inquiries to the Company directly may do so at:

Emailcontact@bettertomorrowgroupltd.com

The Company may, entirely at its discretion, respond to such inquiries in accordance with Section 3.4 (Tier 3). A response to any informal inquiry does not constitute a legal obligation on the part of the Company to respond to further requests outside formal BVI channels, nor does it constitute a waiver of any rights or procedural protections available to the Company under BVI law.

11. CONCLUSION

We are committed to compliance with BVI laws and regulations regarding information disclosure. We strive to balance our legal obligations with the protection of the exchange administrators' and users' privacy rights. This policy is subject to regular review and may be updated to reflect changes in legislation or regulatory guidance.

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