P2P Ad Posting Agreement

This Agreement is entered into between Hotcoin (hereinafter referred to as the “Platform” or “we”) and the “Advertisers” on the Platform (hereinafter referred to as “you”). Once you apply for or use advertising publishing privileges through our website, API (if any), or mobile applications, you are deemed to have fully read, understood, and voluntarily agreed to this Agreement, as well as all relevant rules, announcements, and policies published on the related service pages, including any modifications, revisions, or changes made by us to this Agreement at any time, and any new rules or regulations that may be issued in the future (collectively referred to as the “Agreement”). If you do not agree to this Agreement or any updated rules, you must immediately stop using the Platform’s advertiser services and proactively apply to the Platform to terminate your advertiser status.

I. Required Application Materials

1. Mobile phone number;

2. Email address;

3. WeChat ID;

4. Emergency contact, emergency contact number, and relationship to you;

5. Residential address;

6. Proof of identity;

7. Video verification (recorded in accordance with the required template);

8. Any other materials required by the Platform for compliance purposes.

II. Asset Security Deposit

1. After the advertiser passes the Platform’s KYC and anti-money laundering (AML) review, the Platform will require a certain amount of security deposit to be frozen in the advertiser’s account to ensure safe and smooth transactions on the Platform.

2. The specific amount of the security deposit will be displayed in the verified merchant’s profile on the Platform.

3. In any of the following circumstances, the Platform has the right to deduct or otherwise dispose of the advertiser’s security deposit:

• The advertiser is involved in a dispute during a transaction and is determined to bear responsibility and fulfill corresponding obligations, but refuses to cooperate;
• The advertiser conducts transactions with accounts on the Platform that have not completed real-name verification;
• The advertiser engages in any illegal activities using the Platform;
• The advertiser violates this Agreement or any legal documents or trading rules on the Platform.

III. Application Process

1. You complete the application form and upload relevant supporting documents.

2. After receiving your submitted materials, the Platform will conduct KYC and anti-money laundering compliance reviews based on the submitted information.

3. After you pass the Platform’s KYC and AML compliance review, the Platform will provide you with a dedicated verified badge to distinguish you from ordinary users.

4. Please note that from the time of submitting the application until the successful termination of advertiser status, you will not be able to trade or transfer the frozen security deposit.

IV. Application for Termination of Advertising Publishing Privileges

1. If an advertiser wishes to terminate the verified status, an application must be submitted to the Platform. Upon receipt of the termination request, if the Platform confirms that the advertiser is not involved in any pending disputes and has no adverse records, the Platform will complete the release of the security deposit within 14 days.

2. In any of the following circumstances, the Platform has the right to revoke your advertiser status and reserves the right to pursue further liability:

• Violation of local laws and regulations.
• Involvement in financial crimes such as money laundering or fraud.
• Submission of false information in the application materials.
• Fraudulent or dishonest behavior during transactions.
• Multiple complaints from Platform users during transactions.
• Failure to cooperate with the Platform in handling orders or intentional delays.
• Disrupting market order or engaging in malicious competition.

V. Understanding and Acknowledgment of the Application Service

1. The application service is an identity verification service provided by the Platform. Unless otherwise stipulated in this Agreement, once you complete the application on your account, the corresponding identity information and application results shall not be modified or canceled for any reason. If your identity information changes after verification, you must provide supporting documents issued by relevant authorities, and the Platform will assist you in updating your account information.

2. The Platform has the right to unilaterally modify or update the contents of this Agreement at any time and publish the updated version on the Platform without separate notice. After any modification or update, your continued use of the Platform’s services indicates that you have read, understood, and agreed to the updated Agreement. If you do not agree, you must immediately stop using the Platform’s services.

VI. Use of Application Materials

1. Management of application materials: The certification materials you submit to the Platform at the time of application are irrevocably authorized to be retained. The Platform undertakes not to disclose, edit, or reveal such materials, nor use any non-public content stored on the Platform for commercial purposes, except in the following circumstances: information disclosed with your authorization.

2. Provision to judicial or administrative authorities.

3. Provision to affiliated companies of the Platform.

4. When a third party provides services jointly with the Platform, the relevant information required for such services (excluding your bank account information).

5. For the purpose of resolving civil disputes between you and a third party, the Platform has the right to provide your identity information to such third party.

VII. Links to Third-Party Websites

For the purpose of identity verification, the Platform may contain links to third-party websites (such as online banking websites) (hereinafter referred to as “Linked Sites”). The Linked Sites are not controlled by the Platform, and the Platform is not responsible for the content of any Linked Sites, including but not limited to any links contained therein, or any changes or updates to such Linked Sites. The Platform is not responsible for any transmission received from any Linked Sites.

VIII. Prohibited or Illegal Use

Acceptance of all terms of this Agreement is a prerequisite for applying for verification. You represent and warrant that you shall not apply for verification for any illegal purposes or purposes prohibited by this Agreement. You shall not use the application service in any manner that may damage, disable, overburden, or impair the Platform or interfere with any other party’s use of the advertiser application service. You shall not obtain or attempt to obtain any materials or information through any means not intentionally made available by the Platform.

IX. Disclaimer

Under the following circumstances, the Platform shall not bear any liability:

1. Any leakage of personal information caused by you disclosing your account password to others, failing to properly safeguard your password, sharing your account, or any other reasons not attributable to the Platform.

2. Any impact caused by hacker attacks, computer virus intrusion or outbreak, technical adjustments by telecommunications authorities, temporary shutdown due to government regulation, or any third-party reasons (including force majeure events such as international backbone network failures, telecommunications provider failures, fire, flood, lightning, earthquake, typhoon, tornado, volcanic eruption, epidemic outbreaks, strikes, war, violence, or similar events), and any resulting leakage, loss, theft, or tampering of verification information not attributable to the Platform.

3. Any leakage of bank account information caused by other websites linked to the Platform (such as online banking websites), and any legal disputes or consequences arising therefrom.

4. Any failure of verification or any other losses caused by users providing incorrect, incomplete, or false information to the Platform shall not be the responsibility of the Platform.

5. Merchants are prohibited from establishing off-platform communication methods with users. Any financial loss caused by merchants guiding users to conduct transactions outside the Platform shall not be the responsibility of the Platform.

6. Any loss of assets caused by fraud not attributable to the Platform.

X. Special Statement

The Platform’s review of advertisers’ basic information and the requirement of security deposits do not guarantee that advertisers are 100% trustworthy, nor do they establish any guarantee relationship between the Platform and advertisers. Users are advised to strictly follow the trading process, carefully verify counterparties’ information, communicate thoroughly, and ensure the safety of their transactions and assets. Furthermore, due to the nature of digital asset trading, you should pay special attention to anti-money laundering risks and conduct identity verification of your counterparties in accordance with KYC and AML requirements; otherwise, you may face risks such as asset freezing due to counterparties being involved in criminal activities.