Last updated on “8” June 2023

1. General Information

This Cookie Policy was created to explain how we use cookies and related technologies and how you can control the way you choose to use cookies on the website

The terms we use in this Cookie Policy are in compliance with the Terms of Use, Privacy Policy, Anti Money Laundering Policy and applicable data protection laws.

When you visit our website for the first time, you will be asked to accept that we place cookies on your device. 

You can also choose not to use cookies, but this may limit your use of our site.

If you would like to make changes to your cookie settings (e.g. limit the number of cookies (except Strictly necessary cookies) or allow more cookies to be placed on your device), you can always find the cookie banner by clicking here.

Please contact us by email at if you have any questions about this Cookie Policy

2. Meaning of cookies

A cookie is a small text file which a website saves on your computer or mobile device whenever you visit the site. A cookie has the ability to be viewed as an identity card of an Internet user, which informs the site of the user's return.

Cookies can be "session" or " permanent".

Session cookies expire whenever you exit the web browser after a user's session ends.

Permanent cookies are those that are saved in your browser and may remember your settings, actions and preferences on the website or other sites through a specified expiration date, if they are not previously deleted. The majority of cookies gather cumulative data (for example, how users come to the site and use it), however, there are some cookies that may collect personal data.

They may be posted by KUNA Pay - the website operator (first-party cookies), as well as by a third party for their individual purposes (e.g., for advertisements).

For more information about cookies and their usage, you can visit

3. How we use cookies

The following types of cookies are used by us:

  1. Strictly necessary cookies: we use cookies that are necessary for the operation of our website, in particular, cookies that permit you to access your account on KUNA Pay.
  2. Functional cookies: these are cookies that allow the website to remember your preferences and choices that you make on the site including username, or language.
  3. Analytics cookies: these cookies assist us in understanding the way visitors communicate with the KUNA Pay website via the collection and reporting of data anonymously.
  4. Advertisement cookies: these are cookies that allow the website to record your usage of our website (which includes the pages you visit and the links you click) in order to provide you with targeted content.

See the tables below for a list of cookies that are used by or on behalf of KUNA Pay.

Table 1. List of Strictly necessary cookies





To store information of how visitors use a website and helps in creating an analytics report of how well the website is performing. The data collected includes the number of visitors, and where those visitors have originated from.

1 day


When a user signs in to a website using their Google account, this cookie is created to track their authentication status. It helps identify if the user is currently signed in to their Google account or if they have previously signed in.



Table 2.  List of Functional cookies





These cookies are used to track sessions for analytical purposes.



Table 3.  List of Analytics cookies





Records a unique identifier that is used to obtain statistical data about the visitor's use of the site.

2 years


Used by Google Analytics to store and count pageviews.

1 year


An ID that shows which company the Google Analytics data is being sent to - this company is UAB Kuna Pro (KunaPay).

10 years


Used by Google Analytics to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.

1 minute


Used by Google Analytics to store time of visit. The cookie is updated every time data is sent to Google Analytics.



Used by Google Analytics to store and track visitor journeys through the site and classifies them into groups.

1 second


Used by Google Analytics to store a number of service requests.

10 minutes


Used by Google Analytics to store used keywords and search engines.

6 months


This cookie is used to send data to Google Analytics about the visitor's device and behavior. It tracks the visitor across devices and marketing channels.



Table 4.  List of Advertisement cookies







Used by LinkedIn to provide ad delivery or retargeting.

1 month


Used by Facebook to provide ad delivery or retargeting.

3 months

4. Control of cookies

Below you can see cookie control methods:

  • Erasing cookies from your device: You can erase all cookies currently on your device by deleting the browsing history of your browser. All cookies will be removed from all websites that you have visited. Keep in mind, however, that you may also lose some stored information (e.g., site preferences, saved login data).
  • Site-specific cookie management: To have more control over site-specific cookies, please review the privacy and cookie settings on the browser you use.
  • Cookie blocker: Most current browsers can be customized to prevent cookies being placed on your device, but in this case you may have to change some settings manually each time you visit the website/page. Also, you may not be able to use some services and features correctly at all (such as logging in to your account).

For more information on how to manage the most popular browsers, see here: Firefox, Google Chrome, Safari, Opera, Microsoft Edge.

5. Changes to this Cookie Policy

From time to time we may change this Cookie Policy and the date at the top of this page will indicate that we do so. When you visit our site for the first time after we make a change, we will notify you of this change by showing a cookie banner.


Last updated on “8” June 2023

1. General Information

KUNA Pay (“We” or “Us”) has prepared this Privacy Policy in compliance with the requirements of the General Data Protection Regulation ("GDPR") and the Law of the Republic of Lithuania on the Legal Protection of Personal Data and other relevant laws.

We care about the privacy of your data and are committed to protect it. This Privacy Policy regulates Kuna's collection, processing and use of your personal data that you give us when you access or use our website at or related services provided by us. 

When visiting, accessing, and using the KUNA Pay website or our services, you confirm that you have read, understood and agreed to all of the terms and conditions of this Privacy Policy. If you consider any term or condition of this Privacy Policy inappropriate, please do not visit, access or use our website or services.

You may withdraw your consent at any time. All you have to do is contact us.

The aim of this Privacy Policy is to provide a description of:

  1. the types of personal data we may collect and how we may use it;
  2. the rights you are entitled to in this context;
  3. the transfer of your personal data;
  4. how and why we may disclose your personal data to third parties;
  5. the safeguards we use to protect and prevent the loss, misuse or change of personal data;
  6. the storage of your personal data;
  7. who you can contact in relation to data protection.

Any use of the terminology or other words in the singular, plural, capitalization, and/or he/she or they, are taken as interchangeable and therefore as referring to the same. Words “include”, “includes” and “including” shall be deemed to be followed by the phrase “without limitation”.

Please read this Privacy Policy carefully and without limitation in its entirety. 

If you have any questions regarding this Privacy Policy, please contact us at

2. Administrative Information

We are in control of the way we collect your personal data and define the purposes we use personal data for. Thus, we are the controller of your data. According to Article 4 (7) of the GDPR a data controller is a legal or a natural person which alone or jointly with others determines the purposes and means of processing personal data.

The data controller is UAB "KUNA Pro", a company incorporated under the laws of Republic of Lithuania, under registered number 306041195. 

You can always contact us if you have any questions about Kuna's processing your personal data or if you would like to exercise your rights:

  • Registered address: Eišiškių Sodų 18-oji g. 11, LT-02194 Vilnius
  • E-mail:, (legal issues).

If you are dissatisfied with anything, you have the right to file a complaint to the State Data Protection Inspectorate (“SDPI”), whose contacts are listed below:

  • Address: 17 L. Sapiegos str. (entrance on the left side), LT-10312 Vilnius;
  • Phone: +370 5 271 2804 / 279 1445
  • Fax: +370 261 9494;
  • E-mail: 

Nevertheless, we would appreciate it if we could solve your problems before you contact SDPI, so please contact us first.

3. Sources of personal data 

Personal data means any information relating to an identified or identifiable natural person as defined in Article 4(1) of the GDPR.

The way we collect personal data about you is wide-ranging. Generally, you provide us with your information in person by interacting with us directly:

  • by visiting our website;
  • by using any of our services;
  • when you give us any feedback or contact us.

In addition, we will also rely on third parties and/or public sources to receive data relating to you. Any of the below sources may be used by us:

  • public authorities;
  • publicly available information;
  • fraud and crime prevention agencies;
  • public blockchain.

4. Personal data we collect

KUNA Pay collects your personal data when you use our site. Failure to submit the required information and documents or provision of incorrect or incomplete information and documents, or failure to comply with our other requests will result in our services being unavailable to you.

There are two types of information you may provide to us when you visit the KUNA Pay site: 

  • personal data that you voluntarily share; and 
  • data collected automatically when you use the KUNA Pay site or our services.

We will only collect and process data for specific and legal purposes and only as appropriate and necessary for one or more of the purposes set forth in this Privacy Policy, namely, to provide you with services and/or to fulfill legal requirements. 

Please note that the GDPR does not regulate the collection and processing of data about legal entities (e.g., company name, address, licenses), therefore although KUNA Pay does process such data, it is not specified in this Privacy Policy.

Data you voluntarily submit to us

Category of personal data

Types of personal data

Identification and contact data 

Full name, nationality, sex, date of birth, tax identification number, place of birth,  country of residence, e-mail address, phone number, the authority that issued the passport, passport No, any other information in the documents you provide to us during the KYC process (e.g., your residential address, passport photo), and personal identification information for all material beneficial owners, personal information about the board of directors, senior persons responsible for the operations of the body corporate.

Biometric data 

Liveness check

Transaction and Financial data 

History of transactions and their types, the amount of transactions, data and time of transaction, ID, TX ID, network, wallet number, MEMO, the currency of transactions, fee, transaction status, total balance of assets, daily volume transaction, types of currencies (virtual assets) you have on your account, details of your invoices ( who and when created, ID, the amount of invoice, the amount already paid, the amount still to be received, product category, product description, etc.), payment details (invoice sender name, order number, currency, wallet address, fee) payment links,  types of withdraw funds, comments of you withdraw funds, card number.

Communication data 

Responses to surveys, chat messages with Kuna Pay support, attachments in chat, that may include screenshots, photos, videos, etc.


Data we collect from you automatically

Category of personal data

Types of personal data

Usage data

Information about your usage of our site and our services, such as download time from your device, interaction type and time, event time, name, source.

Marketing data

Your preferences about obtaining marketing materials from us or third parties.

Online identifiers

Cookie identifiers, internet protocol (IP) addresses, advertising IDs, MAC addresses, pixel tags, account handles.

In addition, the below mentioned data may be automatically received and recorded in the logs of our server:

  • your access and use our site;
  • event details on your device (e.g. browser type, browser language, date and time of request and destination URL, crashes);
  • the type of your device and its unique identification number(s);
  • the way your device interacts with our site and services, as well as the pages visited and links clicked;
  • your overall geographic location.

Please note that there are personal data which KUNA Pay does not collect and process:

  1. we do not intentionally collect personal data from those under the age of 18. If we become aware that we have collected personal data from children without confirmation of parental consent, we will take steps to delete such information.
  2. we also do not process sensitive personal data that includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, data concerning health or data concerning a natural person’s sex life or sexual orientation as defined in Article 9(1) of the GDPR. 

If you find out that KUNA Pay has collected such type of information, please contact us directly  without delay and request its deletion.

5. Rights you have with respect to your personal data 

There are individual rights you have with regard to the personal data we collect and process about you:

  1. right to access your personal data - by providing us with an identity document or by verifying your identity in the manner prescribed by law or by means of electronic communication allowing personal identification, you have the right to receive information about the sources and type of your personal data that has been collected, the purpose of its processing and the data recipients to whom the data is or was disclosed at least within the last year;
  2. the right to rectify your personal data - you have the right to request us to correct your personal data that you find to be inaccurate. In case you consider your data to be incomplete, you also have the right to ask us to supplement your data by giving us the missing information;
  3. the right to object to processing of personal data - if the processing of your personal data is based on a legal basis other than consent, you have the right to object to it; in such a case, you must submit a written notification of your objection to the processing of personal data to us in person, by mail or by electronic means of communication. If your objection is legally justified, we will stop processing your personal data without delay, except as required by law;
  4. the right to withdraw your consent to the processing of personal data - if the basis for processing your personal data was your consent, then you have the right to withdraw your consent at any time. The legality of the processing that preceded the withdrawal will not be affected by such withdrawal. However, it may impact the number of services we can provide to you. For example, if we need your consent to provide some services, after you withdraw it, we can no longer provide those services to you;
  5. the right to have your personal data deleted - we will do so with no undue delay if any of the below grounds is applicable: 
  1. the personal data has been illegally processed; 
  2. the personal data is not necessary anymore due to the purposes for which it was collected or otherwise processed; 
  3. you withdraw the consent upon which the processing is based and if no other legitimate grounds for processing exist; 
  4. the personal data must be deleted in order to meet a legal obligation under the law of the Union or the Member State to which we are subject;
  1. the right to lodge a complaint - if you consider that we have violated your rights, we encourage you to contact us in the first instance at  so that we can try to solve your issue or dispute informally. You also have the right to lodge a complaint with the competent supervisory authority - State Data Protection Inspectorate.

6. Personal data collection purposes 

KUNA Pay only collects personal data that is necessary to provide you with the services you require.

We collect and use your personal data for the foregoing purposes:

  1. to interact with you about services and transaction issues - your personal data is used by us to communicate with you in connection with the KUNA Pay services regarding administrative or account related information. For example, we will contact you to inform you of relevant security issues, updates, or other information related to transactions. You may not be aware of significant events related to your account that may have an impact on how you can use our services without such communications;
  2. if it is essential for us to meet our legal obligations and to execute and enforce legal rights;
  3. to identify, investigate and prevent fraud or other illegal or unauthorized operations or activities;
  4. to monitor and govern the effectiveness of our business operations, for analyzing productivity and preparing internal reports;
  5. to maintain, service, deliver or improve our website - personal data is used by us to ensure the proper functioning of our website and we also process your data to ensure that we can provide you with a personalized experience and implement the preferences you have requested;
  6. to research and develop - we process your personal data to gain a deeper understanding of you and the way you use and interact with our site. In addition, we use this information to customize, measure and improve the content and design of our site and to create new services. Absent such processing, we may not be able to provide you with further use of our site;
  7. to maintain the security, protection and integrity of our website - in order to enhance security, control and check identities or service access, combat any malware or security risks, and meet applicable security laws, we process your personal data. This data is processed by us to verify accounts and relevant activity, to find and fix violations of our Terms of Use, to conduct investigations of potentially suspicious behavior etc;
  8. to participate in marketing and promotional activities -  we may send you marketing and promotional messages based on your communication preferences to let you know about relevant product and service offerings and provide you with targeted marketing. You can opt out of receiving our marketing messages at any time by contacting us at

We rely on the following legal justifications for each of the purposes for which we process information:

  1. consent - we use your data in reliance on your consent;
  2. contractual obligations - we rely on this justification when we process your personal data to fulfill a contractual obligation to you in order to provide our services;
  3. regulatory and legal requirements - we rely on this justification whenever we use your data to comply with legal and regulatory requirements. We do so not just to comply with our legal obligations, but also as it may be in our legitimate interests to do so;
  4. legal business interest - we rely on this justification in cases where we need to process your personal data to satisfy our own requirements to operate, manage and develop our business or to protect a legitimate interest that we or a third party is pursuing (as long as the balance of interests is respected);
  5. legal proceedings - we rely on this justification when we need to process your data for legal advice; for any legal proceedings; or to enforce or protect legal rights in accordance with applicable data protection laws.

7. Disclosure of personal data 

Your personal data may be shared with our third parties in order to carry out assignments and provide services to you on our behalf. We will only transfer your information if and only insofar as is appropriate or necessary to fulfill one or more of the purposes outlined in this Privacy Policy, and we will ensure that the transfer of such Information is limited to the minimum amount necessary. 

In particular, we may disclose your personal data to:

  1. our present or future parent companies, subsidiaries, affiliates and other companies that are under common ownership or control with us or our international offices;
  2. law enforcement agencies, public officials or other third parties if we are compelled to do so by subpoena, court order or other similar legal procedure; or we honestly believe that it is necessary to disclose personal data to avoid physical harm or financial loss, to report suspected illegal conduct, or to investigate breaches of any of our policies;
  3. identity verification agencies to do the appropriate background checks (for instance, our trusted partner Sum and Substance Ltd (“SumSub”), which collects and stores your data on our behalf);
  4. fraud or crime prevention agencies to assist in combating crimes, which include fraud, money laundering and terrorist financing;
  5. service providers, advisors, consultants, subcontractors, agents, and other third parties we work with or who do work for us, as well as those who maintain our business operations ;
  6. transaction processors (to provide transaction execution and functionality);
  7. users of the interactive areas of the KUNA Pay website or our social media platforms, in case you choose to share or reveal your personal details on them in public, for example, your username and any content that you post;
  8. third parties, agents, advisors and other service providers in relation to a reorganization, ownership change, merger or transfer of all or any part of our assets or business, either financing or participating in an acquisition, or in any other situation where disclosure or transfer may be made as one of the assets of our business;
  9. those providing ancillary services in addition to the services that we provide.

Once we involve a third party to process your personal data on our behalf, a processing agreement is signed, under which the appointed third party is also obligated to comply with the GDPR.

From time to time, our website may contain links to other websites. We do not control any of these third party websites or any content posted on them. You agree that we are not responsible in any manner for such sites linked to or from our site, including but not limited to site content, policies, advertising, interruptions, products, services or activities and/or any  losses, damages, failures or problems arising from, connected to or in relation to those sites. These sites have a distinct and independent privacy policy. We recommend that you check the policies, terms and conditions of every site you visit. Our goal is to protect the integrity of our site and we are pleased to receive any feedback about the information on external sites provided on our site.

8. International transfer of personal data

Our rational efforts to ensure that third parties with whom we do business are bound by the terms of this Privacy Policy or similar policies. Your information may be transmitted to or available to recipients in any country in the world. These countries may have different and possibly less rigorous standards with regard to data protection than your country. If so, we will, to the extent possible, provide adequate legal safeguards, to the best of our ability, with respect to your personal data that is transferred to such recipients. Using our services, you are consenting to the transmission of your data to other countries, including countries with data privacy and protection laws that differ from the laws in your country. We will protect and process your personal data in all such transfers as described in this Privacy Policy.

When we transfer personal data outside the EEA to a country that has not been designated by the European Commission as ensuring an adequate level of personal data protection, such transfer will be based on an agreement that covers EU requirements for the transfer of personal data outside the EEA, for example, standard contractual clauses approved by the European Commission. The European Commission approved standard contractual clauses are available here.

So, we can only transfer your personal data in the below cases:

  • if the country to which we transfer your personal data ensures an acceptable level of personal data protection (as defined by the European Commission);
  • if we take adequate precautions to protect your rights as a data subject.

9. Security of personal data 

We develop our system taking into consideration your safety and confidentiality. Physical, electronic and procedural safeguards are applied by us in relation to the collection, retention and disclosure of your personal data. 

As a result, the steps we follow to ensure the safety and protection of your data include:

  • two-factor authentication (2FA);
  • pseudonymization and encryption of personal data using the TLS 1.2 standard;
  • the ability to provide ongoing privacy, integrity, accessibility and stability to our processing systems and services;
  • access control;
  • only authorized employees have access to your personal data, and such employees are obliged to keep your information confidential.

When you create an account on our website to use our services, be sure to choose a password of appropriate length and difficulty (your password must contain: uppercase and lowercase characters, at least one special character (%/&/@), length must be 8 and more characters), do not disclose that password to any third party, and inform us immediately if you become aware of unauthorized access or use of your account. Also, we suggest using a unique password that is not used for other online accounts and to log out when you are done working on a general computer.

Notwithstanding the safeguards we take, it is essential to remember that data transfer via the Internet may not be entirely safe, and that you should take adequate precautions when transferring data to us over the Internet. Please note that even though we will do everything in our power to protect your personal data, the security of your data transmitted to our site cannot be guaranteed, and any transmission is at your own risk. After receiving your data, strict procedures and safeguards will be used to try to prevent unauthorized access.

10. Advertising 

We may share your personal data with our marketing partners for purposes of targeting, modeling and/or analytics, also for marketing and advertising activities, so as to provide you with the optimal user experience. If you would like to withdraw your consent to marketing processing and newsletter, please contact us by

11. Personal data retention period 

Your personal data will only be kept by us for as long as necessary to accomplish the purposes for which we collected it, including to fulfill any legal, accounting or reporting obligations, to comply with Anti-Money Laundering laws or to settle disputes and/or legal claims. This decision varies on a case-by-case basis and depends on factors such as the type of data, the reason for its collection and processing, and the applicable legal or operational requirements for retention. 

Please also note that in accordance with our legal or regulatory obligations and international data retention standards, you give us your consent and permission to store your personal data for the entire duration of the business relationship with you and for a period of five years after the termination of the business relationship.

12. Changes to Privacy Policy 

This Privacy Policy will be regularly updated to be current. The date when this policy was last updated can always be found at the top of this page. When we update it, necessary steps will be taken (for example, by sending an email) to inform you, depending on the significance of the changes we make.  

The revised Privacy Policy will be considered valid when it is posted on our website. If you continue to use the KUNA Pay website and/or our services, then you consent to be bound by any such changes to the Privacy Policy. In the event that you do not agree to any changes to this Privacy Policy, please discontinue your accessing and using the KUNA Pay website and our services.

Anti-Money Laundering and Counter-Terrorist Financing Policy of KUNA Pay

Last updated on “8” June 2023

This Anti-Money Laundering and Counter-Terrorist Financing Policy (the “Policy”) of UAB KUNA Pro (hereinafter "KUNA Pay", "We" or "Us") was prepared in accordance with the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing, Proceeds of Crime. 

Money laundering and terrorist financing pose significant risks to the integrity and stability of the global financial system, and as a responsible member of the international community, We recognize the importance of combatting these threats. As a result, We are committed to implementing a comprehensive of Anti-Money Laundering (“AML”) and Combating Terrorism Financing (“CTF”) program that adheres to the highest standards of legal and regulatory compliance.

The Policy is designed to represent the basic standards of AML and CTF procedures, which will be strictly complied with by Us.

All definitions in this Policy are used within the meaning of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing and Proceeds of Crime.

If you have any questions about this Policy, please contact Us via email: 

1. What’s the purpose of this Policy?

The purpose of this Policy is to ensure that We comply with the rules and regulations set out in the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing. 

2. What are Money Laundering and Terrorist financing?

Money laundering is the process of hiding the true origin of money obtained through illegal activities. This process involves disguising the proceeds of criminal activity as legitimate funds. 

Money laundering plays a fundamental role in facilitating the ambitions of the drug trafficker, the terrorist, the organized criminal, the insider dealer, and the tax evader, as well as the many others who need to avoid the scrutiny from the authorities that sudden wealth brings from illegal activities.

Terrorist financing is the process of providing funds to individuals or groups to carry out acts of terrorism. Terrorists may move or transfer funds and assets through various methods, including: 

  • using the financial system to transfer funds; 
  • relying on systems such as the hawala system in areas with less developed financial systems are often employed for multiple small amounts of fund transfers; and 
  • using international trade networks to transfer assets.

3. Who is the operator of KUNA Pay's platform?

The operator of the KUNA Pay platform is UAB KUNA Pro, which is a virtual currency exchange and virtual currency wallet operator that is registered and operating under Lithuanian law.

Administrative Information:

  • Legal name: UAB KUNA Pro;
  • Registered address: Eišiškių Sodų 18-oji g. 11, LT-02194 Vilnius;
  • Company number: 306041195;
  • Director – Mykhailo Chobanian;
  • AML officer - Tsimafey Breski;
  • Chief Legal –  Ganna Voievodina.

4. Why do We need to verify your data?

We are obliged to verify your data as it is required by the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing, Proceeds of Crime. KUNA Pay is accountable to the Lithuanian Financial Crime Investigation Service (“FCIS”). FCIS performs supervision of our activities of virtual currency services related to the prevention of money laundering and/or terrorist financing and has the following contact details:

5. Can you use our services without passing KYC?

You cannot use KUNA Pay's services without passing the KYC procedure. We are committed to comply with all relevant legal requirements in the field of AML/CTF. 

Failure to submit the required information and documents or provision of incorrect or incomplete information and documents, or failure to comply with our other requests will result in our services being unavailable to you. 

6. What is Customer due diligence?

Customer Due Diligence (“CDD”) is a process used by Us to identify and verify your identity and assess the risks associated with doing business with you. 

The CDD process helps Us to understand who you are, what business you have, and what risks you may pose and enables Us to implement appropriate measures to mitigate those risks. It is a key component of AML and CFT compliance programs.

  Customer Due Diligence Measures include:

  • identification of the Merchant;
  • identifying the persons acting on behalf of the Merchant;
  • the ultimate beneficiaries of the Merchant;
  • performing a risk analysis of the Merchant;
  • monitoring the Merchant during the provision of the services.

We also reserve the right to determine the origin of your assets, to establish your proof of address, and collect other relevant information to evaluate the risk of Money Laundering, Terrorist Financing, and other illicit activities.

7. What data We might ask from a Merchant Authorized Representative(s)?

When applying CDD measures We are obliged to identify both the Merchant and the Merchant Authorized Representative. 

The following persons may act as Merchant Authorized Representative(s):

  • The Merchant's director;
  • The beneficial owner of the Merchant;
  • Official representative.

In order to identify and verify Merchant Authorized Representative(s), We shall obtain the following data:

  • Passport/national ID or visa for the country of residence (if applicable);
  • Liveness check;
  • Proof of address (not older than 3 months);
  • Document certifying the right to represent the Merchant.

The Merchant Authorized Representative(s) must fill out our Questionnaire, providing us with the following data:

  • Company basic information:
  • Company profile (name, number, legal form, country of incorporation, date of incorporation);
  • Proof of legal existence of the company (for example Certificate of Incorporation, Share Certificates/Shareholders Register, Memorandum of Association, Articles of Association, Tax Registration Certificate);
  • License, if any (license number, issuing authority, issue date); and document confirming that your company has a license;
  • Company website (if available); domain ownership proof.
  • Company address:
  • Registration address;
  • Business address;
  • Proof of the company's registered address (e.g., utility bill/bank statement (not older than 3 months), lease agreement).
  • Business Information:
  • Description of the offered products/services;
  • Purposes for which you plan to use KUNA Pay's Services;
  • Total No of employees;
  • At least three countries of operation and top 3 business partners (We may request a contract with your business partners).
  • Anticipated trading size;
  • Company clients (type of customers, and number of customers);
  • Details about individual shareholder(s), beneficial owner(s), director(s):
  • Full name;
  • Nationality;
  • Date of birth;
  • Ownership % of each shareholder(s) and beneficial owner(s);
  • Documents for each shareholder(s), beneficial owner(s), and director(s): Passport/national ID or visa for the country of residence (if applicable), Proof of address (not older than 3 months), Tax identification document.
  • Details of shareholders-legal entities:
  • Company profile (name, number, country of incorporation, date of incorporation, registered address);
  • Full name of director;
  • Ownership %;
  • Documents for each shareholder-legal entity: certificate of incorporation, memorandum of association, or articles of association.
  • Wallet and account information (сrypto wallet address, banking account number/IBAN, banking account holder name, bank name, bank SWIFT);
  • Compliance information (e.g. Privacy Policy, AML Policy, if available). 

Please note that we reserve the right to ask you for information regarding your customers (for example, KYC data - passport, address, source of funds, etc.). We only need this data if we have reasonable doubts about the legitimacy of the funds received from the Merchant's customers to their KUNA Pay account. We strongly encourage Merchants to conduct KYC on their customers where applicable. 

8. Which third-party providers do We use for data verification?

For client identification purposes, We use the services of our trusted partner Sum and Substance Ltd (“SumSub”). SumSub collects and stores your data on our behalf. 

Sum and Substance Ltd. was incorporated and registered in England with company number 09688671. Sumsub being a software-as-a-service business, takes its responsibilities with regard to the requirements of the EU GDPR and UK GDPR very seriously.

Besides SumSub We can use publicly available databases, different search engines, and other possible legal methods of data verification.

9. What kind of customers do We not serve?

We do not serve the following customers:

  • who fail or refuse to submit, the requested data and information for the verification of their identity;
  • who reside in jurisdictions which are being banned by our internal policies or international sanctions;
  • any other that we consider risky to our business or suspicious in regards to Money Laundering and Terrorist Financing.

We will not accept as Сustomers, persons or entitled from the following countries: Afghanistan, Algeria, Belarus, Benin, Burkina Faso, Burma, (Myanmar), Cabo Verde, Cambodia, Central African Republic, China, Cuba, Crimea (region of Ukraine), Côte d'Ivoire, Congo, Democratic People's Republic of Korea, Dem. Rep. of Ethiopia, Dominican Republic, Donetsk (region of Ukraine), Eritrea, Federal Republic of Ambazonia, Ghana, Guatemala, Guyana, Guinea, Guinea-Bissau, Haití, Honduras, Iran, Iraq, Jamaica, Japan, Jordan, Kenya, Kosovo, Laos, Liberia, Lebanon, Libya, Luhansk (region of Ukraine), Mali, Morocco, Mozambique, Myanmar, Nagorno-Karabakh (temporarily occupied by Russia), Nicaragua, Nigeria, Northern Cyprus, Pakistan, Philippines, People's Republic of China, Russia, Senegal, South Sudan, Syria, Somalia, Sri Lanka, Trinidad and Tobago, Transnistria (temporarily occupied by Russia), territories of Georgia temporarily occupied by Russia (Abkhazia and South Ossetia), Uganda, USA, Vanuatu, Venezuela, Yemen, Zimbabwe.

Persons or entities from jurisdictions where a particular license or permit is required will not be served if we have not received such a permit or license.

10. How long do We keep your data?

Your data will be retained within the provision of our services to you and 5 years after our Business Relationship with you is over. 

In some cases, We will keep the data longer if We are required to do so by law or other legal requirements.

11. To whom can We share your data?

We cooperate with supervisory and law enforcement authorities in preventing money laundering and terrorist financing, thereby communicating information available to us and replying to queries within a reasonable time, following the duties, obligations, and restrictions arising from legislation.

12. How often will the Policy change?

We take our AML obligations seriously and are committed to preventing and detecting money laundering and terrorist financing. We will continue to monitor and update our policies and procedures to ensure that We remain in compliance with all applicable AML regulations.

We reserve the right to modify or update this AML Policy at any time and for any reason, with or without notice. It is your responsibility to review this AML Policy periodically for any changes, so we urge you to make a copy of the text of this AML Policy for future reference. Your continued use of the services following the posting of any changes to this AML Policy will signify your acceptance of those changes.

You can find the current version of the Policy at the top right of this page.

13. Our contacts

If you have any comments or questions with respect to this Policy please feel free to contact us via email: 

Terms of Use

These Terms of Use constitute a public electronic legally binding agreement between you and UAB KUNA Pro (hereinafter "KUNA Pay", "We" or "Us"), governing your access to and use of this website, mobile application, and any other services provided by us. By accessing and using our Services, you acknowledge that you have read, understood, and agree to be bound by these Terms of Use, as well as any additional terms, policies, or guidelines that are incorporated by reference or otherwise apply to specific parts of our Services, such as our Privacy Policy and AML Policy.

By using the Services, you authorize KUNA Pay to take any and all actions that we think are necessary or desirable to provide the Services and to comply with Applicable Laws and regulations.

If you do not agree with these Terms of Use, or if you are unable or unwilling to comply with any of the provisions herein, you must not access or use our Services. We reserve the right to modify or update these Terms of Use at any time and for any reason, with or without notice. It is your responsibility to review these Terms of Use periodically for any changes, so we urge you to make a copy of the text of these Terms of Use for future reference. Your continued use of the Services following the posting of any changes to these Terms of Use will signify your acceptance of those changes.

Please note that KUNA Pay may offer different services in different jurisdictions or to different user segments, and the availability and scope of our Services may be subject to additional terms, policies, or guidelines that are specific to your jurisdiction or user segment. It is your responsibility to familiarize yourself with and adhere to any such additional terms, policies, or guidelines.

1. Administrative Information

1.1. Our Contacts

UAB KUNA Pro is a company organized and existing under the laws of the Republic of Lithuania, legal entity code 306041195, registered address at Eišiškių Sodų 18-oji g. 11, LT-02194 Vilnius.

You may contact us by email at

1.2. License and Services

UAB KUNA Pro is a Virtual Asset Service Provider license holder. Under the VASP license KUNA Pro provides the following Services:

  • Fiat and crypto storage and exchange;
  • Exchange crypto to crypto;
  • Exchange crypto to fiat and fiat to crypto;
  • Informational services on the balance.

Please note that KUNA Pay may modify, suspend, or discontinue any of the Services at any time, with or without notice, at our sole discretion. Furthermore, the availability and scope of our Services may vary depending on your jurisdiction, user segment, or other factors. KUNA Pay does not guarantee the continuous, uninterrupted, or error-free operation of our Services, and we shall not be liable for any losses or damages arising from any interruptions, delays, or errors in the Services.

2. Definitions

The definitions set out in this section shall apply in these Terms of Use as follows: 

  • Fiat Currency” shall mean a currency that is issued by a country and is designated as legal tender in that country.
  • Account” shall mean your virtual interface within KUNA Pay that is intended for your use of our Services and accessible via the Website by using your registration email, long-term password and 2FA (“User Credentials”) to log in. 
  • Virtual Assets” shall mean:
  1. digital representation of value that can be used for payment or investment purposes that is not a fiat currency and that can be readily exchanged for funds or for another virtual currency that can be readily exchanged for funds; or
  2. private key of a cryptographic system that enables a person or entity to have access to a digital representation of value referred to in paragraph (a).
  • Business Day” shall mean business days of the Republic of Lithuania, except for legal public holidays. 
  • Fees” shall mean the fees we will charge you for the provision of the Services, the details of which are set out on our Website. 
  • Merchant” (also referred to as "You") shall mean a person who is engaged in the sale of goods and services and who has concluded an individual agreement with us for the provision of our Services. Merchants, their employees and contractors each shall refer to a “User”. The Merchant must meet the eligibility criteria set out in section 3 of these Terms of Use. 
  • Applicable Law” shall mean laws of the Republic of Lithuania, applicable under these Terms of Use to any and all relations between Merchant and KUNA Pay.

Any use of the above terminology or other words in the singular, plural, capitalization, and/or he/she or they, are taken as interchangeable and therefore as referring to the same. Words “include”, “includes” and “including” shall be deemed to be followed by the phrase “without limitation”.

3. Eligibility Criteria

To access and use certain features of the Services, you must register for an Account. By creating an Account, you represent, warrant, and agree to the following:

  1. you have the capacity to enter into and be bound by these Terms of Use and any other document related thereto; 
  2. in the case of legal representation, you are duly authorized to enter a contractual relationship with us based on these Terms of Use on behalf of the person you are representing; 
  3. in the case of a natural person, you are of the age of full legal capacity and reside in a country in which our Services are legally accessible; 
  4. in the case of a legal person, it is duly established and operates in a country in which our Services are legally accessible;
  5. you are not resident, citizen or agent of, or incorporated in, and do not have a registered office in restricted jurisdictions (as stated AML Policy) or any other country or region that is the subject of comprehensive country-wide or region-wide economic sanctions;
  6. you are not the subject of economic or trade sanctions administered or enforced by any governmental authority or otherwise designated on any list of prohibited or restricted parties (including the list maintained by OFAC, UN, EU).

If you do not meet or no longer meet the eligibility criteria set out above, KUNA Pay has the right to refuse Services to you.

4. User Representations and Warranties

As a condition to accessing or using the Services, you represent, warrant, and agree to the following:

  1. you will maintain the security of your User Credentials, and you accept all risks and responsibilities for any unauthorized access to your Account and any resulting loss or damage;
  2. you will not create more than one Account or create an Account for anyone other than yourself without the person's explicit consent;
  3. you will not use your Account or the Services to engage in any illegal, fraudulent, or other prohibited activities or to violate any applicable law, regulation, or guideline;
  4. you will not use your Account or the Services to engage in any activity that could damage, disable, overburden, or impair the Services or interfere with any other party's use of the Services;
  5. you will not use any automated means, including but not limited to, bots or scrapers, to access or use the Services;
  6. you will provide accurate, current, and complete information during the registration and KYC process and notify us immediately, no later than within 5 (five) calendar days, of any changes to any information you have provided to us in connection with KYC-procedure (including names of authorized persons, your name/title, code, place of residence/registered office address, place and nature of business, email address, shareholders’ structure, restructuring, bankruptcy or liquidation proceedings, etc.). At our request, you must also submit any documents supporting such changes in information or circumstances, irrespective of whether such information or documents have been provided to public registers. If the Merchant or any of its representatives fails to submit the required data and is unresponsive and/or submits incomplete data or if the data is incorrect, or its representative avoids submitting the data required for establishing its identity, conceals the identity of the beneficial owner or avoids submitting the information required for establishing the identity of the beneficial owner, or the submitted data is insufficient for this purpose, KUNA Pay can refuse to provide services or establish/continue the business relationship;
  7. you will commit to integrating on your website and/or system a standard disclaimer for purchasers in a non-modified form and make sure that your customers expressly confirm their acquaintance with said disclaimer prior to making any payment to you, where you decide to integrate the KUNA Pay, any part thereof, such as application programming interfaces (APIs) and/or plug-ins on your website and/or system;
  8. you are solely responsible for all activities that occur under your Account, whether or not you authorize them;
  9. you ensure that your use of the Services does and at all times will comply with all applicable anti-money laundering/anti-terrorist funding compliance laws and regulations, including, without limitation, all OFAC-administered sanctions programs and any other sanctions programs that may apply to you based on the jurisdiction(s) in which you operate your business and serve your customers;
  10. you confirm that any Virtual Asset or Fiat involved by you in transactions is owned by you and is derived from legitimate sources.

5. User Account 

To access and use certain features of the Services, you must register for an Account. The e-mail address specified by you during the setting up of your Account and intended for your identification and login to your Account shall be valid throughout the entire period of validity of your Account. If needed (upon your request) and upon satisfactory compliance with our request for documents and information from you, we can change your email address manually. 

Your User Credentials may only be used by you and by persons authorized by you.  You may not distribute or transfer access to your Account to third-parties. 

All transactions completed through your Account will be deemed to have been lawfully completed by you. You will ensure the security and confidentiality of your User Credentials and will notify KUNA Pay immediately, by email at, if any User Credentials are lost, stolen or otherwise compromised. 

In connection with establishing an Account, you will be asked to pass KYC procedure, as set forth in the Section 8).

We will review and assess information and/or documents submitted to us by you. Upon assessment of the information and documents obtained, access to our Services will be granted and you will be able to start using our Services unless we will conclude that you are not eligible to gain access to our Services. 

6. Transactions (exchange, withdrawal, deposit)

After you create an account with KUNA Pay, you can accept virtual currency payments from your customers.

You authorize KUNA Pay to receive Virtual Assets, temporarily hold, exchange, and disburse them on your behalf, as well as deduct the applicable Fees and other costs, and to take any and all actions that we deem necessary or desirable in order to provide our Services to you and comply with any Applicable Law and these Terms of Use.

In order to enable the provision of Services before executing any payment Transaction, Merchants may be required upon a request of KUNA Pay to complete a verification process at the time of payment, depending on the amount of the transaction, as part of our AML/CTF compliance obligations. We reserve the right to request personal information of your customers, such as a photo of national ID, passport, or driver's license if the collection of such information is required by law.

Limits. KUNA Pay reserves the right to impose limits on transaction amounts or frequency at its discretion, based on factors such as transaction history, risk assessment, and regulatory requirements. Users may be required to provide additional information or undergo further verification procedures in order to increase or remove these limits.

Suspicious Transactions. In the event of any suspicious or potentially fraudulent transactions, KUNA Pay reserves the right to suspend or delay such transactions for further investigation. KUNA Pay may request additional information from the User to verify the legitimacy of the transaction and may, at its sole discretion, decide to approve or reject the transaction based on the findings of its investigation. Users shall promptly notify KUNA Pay of any unauthorized transactions or discrepancies in their account balances. KUNA Pay will investigate such reports and take appropriate action to address any issues. 

Relationships Between Merchant And Its Customers. Payments by your customer to us will be considered the same as payments made directly to you. We collect Virtual Assets to your Account exclusively for you and on behalf of you. You remain the owner of Virtual Assets that we hold for you and on behalf of you. In relation to payments in Virtual Assets made to you, any legal relations are between you as a Merchant and your customer making a payment. KUNA Pay is not a party to relations between you as a Merchant and your Customer making payments in Virtual Assets. We do not accept any queries, letters, requests and/or complaints as well as liability for the quality, legality, safety, delivery or any other aspect regarding you, your services, products, activities and/or a payment and/or a donation, or a purchase related to relation between you as a Merchant and your customer. Any disputes between you as a Merchant and your customer shall be resolved exclusively between you and your customer. 

Liability. Users are solely responsible for the accuracy of payment details provided during the transaction process, including but not limited to wallet addresses and payment amounts. All Virtual Assets transactions are at your sole risk. KUNA Pay is not responsible for any errors made by the User in providing payment details and shall not be held liable for any losses that may occur due to such errors.

Transactions processing. KUNA Pay will take reasonable measures to ensure that transactions are processed in a timely manner. However, KUNA Pay makes no guarantees regarding the processing time for transactions and shall not be held liable for any delays or losses that may occur due to technical issues, system failures, or other factors beyond KUNA Pay's control.

Taxes. KUNA Pay is not responsible for any taxes, duties, or other fees that may arise from the User's transactions. Users are solely responsible for determining their tax obligations and reporting their transactions to the appropriate tax authorities in accordance with applicable laws and regulations.

7. Prohibited Activities 

Unlawful Business. Services aren't available for Users, who carry out activities related to the sale and purchase, exchange, other transactions involving the transfer of ownership, possession, use, disposal of the following groups of goods or services:

  • alcoholic beverages;
  • cigarettes and tobacco products;
  • narcotic substances and precursors;
  • pornographic materials or items, child pornography, escort services or prostitution services;
  • drugs, pharmacological products, medicines;
  • stolen, illegally obtained goods;
  • items posing a danger to life and health;
  • non-existent goods;
  • human organs and remains, and organs and remains of animals;
  • special technical means of secretly obtaining information;
  • any electronic, mechanical and computer equipment prohibited or restricted in circulation or use;
  • state awards; personal documents, as well as forms of these documents;
  • objects of history and art that constitute the cultural values ​​of the country in which the consumer is located;
  • firearms, edged weapons, traumatic weapons, stun guns, as well as ammunition and accessories for them;
  • special means of active defense used by law enforcement agencies;
  • precious metals and precious stones not in the product;
  • counterfeit currency and currency values;
  • rare and prohibited for sale animals, incl. animals listed in the CITES (the Convention on International Trade in Endangered Species of Wild Fauna and Flora);
  • any other goods and services prohibited by Applicable law.

Users are also prohibited from selling goods or services without a corresponding permit or license, which requires an appropriate permit and/or a license for at least one of the parties to the transaction.

Abusive Activity. Services aren't available for Users:

  • whose actions impose an unreasonable or disproportionately large load on KUNA Pay's infrastructure, or detrimentally interfere with, intercept, or expropriate any system, data, or information; attempt to gain unauthorized access to other Users' accounts, computer systems or networks connected to the Website, through password mining or any other means;
  • who use accounting information of another party to access or use the Services;
  • who transfer the Account access or rights to the Account to a third party, unless by operation of law or with KUNA Pay's express permission;
  • who (try to) modify, disassemble, decompile or reverse-engineer the Services;
  • who provide any false, inaccurate, or misleading information to us;
  • who transmite spam, chain letters, or other unsolicited emails;
  • who attempt to interfere with, compromise KUNA Pay’s system integrity or security or decipher any transmissions to or from the servers running the Website;
  • who impersonate another person or otherwise misrepresent the User's affiliation with a person or entity, conduct fraud, hide or attempt to hide their identity;
  • who use any device, software or routine to bypass KUNA Pay's robot exclusion headers, or to interfere or attempt to interfere with any activities conducted on the Website;
  • who access any content on the Website through any technology or means other than those provided or authorized by KUNA Pay;
  • who bypass the measures we may use to prevent or restrict access to the Services, including without limitation removing, circumventing, disabling or otherwise interfering with security-related features or features that prevent or restrict the use or copying of any content or enforce limitations on the use of the Services or the content therein; or
  • who delete KUNA Pay's copyright or other proprietary rights notices.

Intellectual Property Infringement. Services aren't available for Users, who:

  • engage in transactions that violate, infringe or misappropriate any intellectual or industrial property right of any person (such as copyright, trademarks, patents, or trade secrets, or other proprietary rights of any party), right of publicity or privacy or commit a tort;
  • use of KUNA Pay's intellectual property, name, or logo, including use of KUNA Pay's trade or service marks, without express consent from KUNA Pay or in a manner that otherwise harms KUNA Pay or its brand;
  • create a false identity for the purpose of misleading others or fraudulently or otherwise misrepresent yourself to be another person or a representative of another entity, or fraudulently or otherwise misrepresent that the User has an affiliation with a person, entity or group.

We reserve the right, without any prior notice or explanation, to refuse any User to provide our Services or to terminate an existing business relationship with you if:

  1. we have a reasonable doubt that the activity being carried out is in violation any of the prohibitions specified in this Terms of Use;
  2. we have a reasonable suspicion of sanction evasion risk; 
  3. the User's actions contradict public order or norms of moral standards.

8. AML/CTF requirements 

KUNA Pay is committed to comply with all relevant legal requirements in the field of AML/CTF. Failure to submit the required information and documents or provision of incorrect or incomplete information and documents, or failure to comply with our other requests will result in our Services being unavailable to you. 

You can find a list of documents and information that we are obliged to request from you in our AML Policy. KUNA Pay performs the customer due diligence measures by means of an our trusted partner SumSub (Sum and Substance Ltd). If the User is uncooperative with our service provider and does not provide the requested data or information necessary to perform customer due diligence, we have the right to terminate a business relationship with such User. 

In order to be fully compliant with the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing KUNA Pay:

  1. performs monitoring of transactions. In the case of a suspicious and/or unusual transaction, we have the right to suspend it, including, but not limited to, the suspension of a withdrawal of your Virtual Assets/Fiat, for a certain period of time. KUNA Pay will not be liable to you for any default on any contractual obligations and for any damages or losses sustained by you; 
  2. reports any suspicious activity identified during the business relationship with Users to FCIS Lithuania and other relevant authorities. KUNA Pay will not be liable to you for the execution of such an obligation.

KUNA Pay reserves the right to terminate a business relationship with User  at any time if we determine that continuing such a business relationship exposes us to a money laundering and terrorist financing risk we no longer deem acceptable.

9. Fees

KUNA Pay charges Fees for the use of its Services, which are automatically deducted from your Account. The applicable Fees for each transaction will be displayed to you before executing the transaction.

The User is responsible for maintaining an adequate balance and sufficient proceeds in the Account to pay for fees and complete transactions, thereby avoiding overdraft, insufficient funds, or similar fees being charged. If you owe us any Fees, we will take the respective Fees you owe us from the Virtual Assets/Fiat we process on your behalf on the due date without your instruction. If you do not have enough Virtual Assets/Fiat to pay the Fees, we reserve the right to suspend the provision of our Services to you until such Fees will be paid to us. 

KUNA Pay may change the Fee structure at any time, including adding new fees for new Services. We will notify you of any changes to the Fee structure, which may be done by posting a notification on the Website or sending you an email. If you do not agree with the proposed changes, you should terminate your use of the Services and close your Account.

10. Refunds

Users understand and acknowledge that Virtual Asset transactions are irreversible and that KUNA Pay has no control over the Virtual Assets once they have been transferred to an external wallet or another platform. Users are responsible for ensuring the safety and security of their Virtual Assets and for conducting transactions with trusted and reputable third parties.

We are not responsible for the Merchants refund policies. We suggest Merchants provide a clear refund policy to their customers. Merchants are responsible for handling refund requests made by their customers. If we receive a refund request directly from a Merchant's customer, we will direct the customer to contact the Merchant to resolve the issue. We will not mediate disputes between Merchants and their customers but may assist in providing relevant information, if necessary.

KUNA Pay reserves the right to establish the minimum amount that can be refunded on your behalf. If the amount requested is lower than the minimum refundable amount, KUNA Pay reserves the right to not issue the refund. Please note, we may charge Fees and deduct other costs for processing refunds on your behalf.

At our sole discretion, we may offer transaction reversals, refunds, or chargebacks in specific circumstances. Merchants must submit a request for such actions in accordance with KUNA Pay's policies and provide all necessary information and documentation to support their claim. KUNA Pay will review the request on a case-by-case basis and may approve or reject it based on its assessment of the situation.

11. Invoices

To receive a Virtual Asset payment, User must create an invoice. This request must be made for the amount you wish to collect in your chosen settlement currency, and must be displayed on KUNA Pay's hosted Invoice User interface during checkout.

When processing transactions, we use the current Virtual Asset exchange rate, which is available through our Website and in your Account. 

You must assume the volatility risk of your settlement Virtual Asset, as we do not guarantee the future value of your chosen currency. We do not guarantee the future value of the US Dollar, or any other currency. If you choose to receive some or all of your settlement in Virtual Asset, we do not guarantee the future value of that Virtual Asset.

Once a transaction has been fully paid by your customer, reaches the required number of block confirmations, and is credited to your Account, the invoice is considered "Complete" by us. The number of confirmations required for a transaction may vary depending on the blockchain being used and our internal risk analysis.

To reduce the risk of fraudulent payments, we employ various risk mitigation techniques to detect unconfirmed payments, such as payments that are at risk of never receiving the required number of block confirmations. However, these measures do not entirely eliminate the risk associated with unconfirmed payments.

If, based on the result of transactions monitoring, we have reason to suspect that the cryptocurrency used as payment comes from an illegal source or is "dirty", KUNA Pay has the right to freeze such payment to ascertain the circumstances. In this case, the Merchant is obliged to request his customer for confirmation of the origin of the source of funds and provide it to us. KUNA Pay will examine the submitted documents as soon as possible and make a decision to unfreeze the transaction if it complies with our risk appetite. 

You may choose to inform your customer about the status of an invoice, such as when the customer has sent payment, but the transaction has not yet been confirmed. A confirmed invoice indicates that payment has been made, and the required block confirmations have been reached and the transaction has also passed our risk validation measures, but it still needs to be credited to your account ledger.

We are not liable for settling invoices that are not considered fully paid or complete. In other words, if you accept payment before it is credited to your account ledger, it will not be settled to you if it is determined to be fraudulent or otherwise invalid.

KUNA Pay may add new Virtual Assets to the invoice, and these additional currencies will be enabled by default unless you request that we disable them. We may also remove certain Virtual Assets as a payment option under certain circumstances.

All transactions, including payments, deposits, withdrawals, and others, are recorded in the User's Account and can be accessed for a period of time determined by KUNA Pay. If you identify an error, you must notify us within thirty (30) calendar days at

12. Account Closing and Suspension

The User may close their KUNA Pay account at any time by contacting our Customer support at after withdrawing all balances subject to minimum amounts which technically cannot be withdrawn. Upon closure of the account, the User authorizes the KUNA Pay to cancel or suspend any pending transactions at the time of cancellation, and any balance in the account will be delivered to the User or to their Virtual Assets address as instructed, less any outstanding amounts owed to us, the unsubsidized coin/miner network transaction fee, and any other third-party charges.

The User shall not use closure of the account as a means of evading investigation or inquiries by KUNA Pay. If any queries or investigation is pending at the time the User requests closure of their account, we may refuse the User’s request to close the account and hold their Virtual Assets and funds as appropriate to protect KUNA Pay against financial and legal liability. If the User is later determined to be entitled to some or all of the Virtual Assets and funds in dispute, we will pay such Virtual Assets and funds to the User. The User will remain responsible and liable for all obligations related to the account even after such an account is closed.

If the User does not access the KUNA Pay account for a period of six (6) months, and we have been unable to contact the User after a reasonable number of attempts at the last contact address the we have for the User in its records, the account may be terminated in our sole discretion.

We reserves the right to suspend your account in an event:

  • we reasonably believe your account have been compromised, as well as for any other security reasons;
  • we reasonably believe your account is being used by a person with no right and/or authorization to do so;
  • the User fails to comply with these Terms of Use, as well as with any other document that construes a part of these Terms of Use;
  • the User has provided us with any false, incomplete, misleading, inaccurate information;
  • the User, their account, their behavior poses reputational risks to KUNA Pay;
  • we reasonably suspect the User of fraud, violating the Applicable Law;
  • the User refuses to pay Fees;
  • other reasons that constitute a violation of these Terms of Use and the Applicable Law.

We may, but are not obliged to, notify the User about the reasons for their account suspension. Assets from the account will be withdrawn to wallets, information about which the User shall provide to the customer support.

In an event of account closing or suspension, the User will still be liable for all applicable fees.

KUNA Pay is not liable for any losses suffered due to the User's account closure or suspension.

13. Content. Intellectual Property. License

KUNA Pay may produce and display content (the “Content”) on the Website, which includes but is not limited to information, texts, images, video, and audio files.

The Content does not constitute any form of investment advice, financial advice, trading advice, or any other sort of advice unless specifically mentioned otherwise and should not be construed as such. KUNA Pay shall not hold liability for any actions that arise from its Content.

All components, Content of the Website, and the Website as a whole belong to KUNA Pay and are protected with, including, but not limited to copyright, trademarks, trade secrets. All rights reserved.

You must not reproduce, reprint, publish, modify, distribute, display, transmit, license, transfer or otherwise exploit Content or technology from the Website without KUNA Pay's prior written consent.

Violation of any of the intellectual property rights of KUNA Pay is strictly prohibited.

If the User posts, uploads, inputs, provides or submits its personal data to KUNA Pay, including without limitation, names, email addresses, IP addresses, cryptocurrency addresses, texts, code or other information and materials, sign up to KUNA Pay’s mailing list or create the Account (collectively, “User Content”), the User must ensure that the User Content provided by the User at that or at any other time is true, accurate, up to date and complete and that any User Content posted, uploaded, input, provided or submitted to KUNA Pay does not breach or infringe the intellectual property rights of any third party. KUNA Pay does not own, control or endorse any User Content that is sent to KUNA Pay. The User represents and warrants that:

  • the User owns all intellectual property rights (or have obtained all necessary permissions) to provide the User Content and to grant the licenses in these Terms;
  • the User Content will not violate any agreements or confidentiality obligations; and
  • the User Content will not violate, infringe or misappropriate any intellectual property right or other proprietary right, including the right of publicity or privacy, of any person or entity.

The User is responsible for maintaining the confidentiality of the User Content and any of its non-public information. Furthermore, the User is entirely responsible for any and all activities that occur under the Account. The User agrees to notify KUNA Pay immediately of any unauthorized use of the User Content, the Account or any other breach of security. KUNA Pay will not be responsible or liable for any loss or damages that the User may incur as a result of someone else using the User Content or the Account, either with or without User’s knowledge.

However, the User could be held liable for losses, expenses and costs incurred by KUNA Pay or another party due to someone else using the User Content or the Account. The User may not use anyone else’s content or account at any time without the permission of such person or entity.

By posting, uploading, inputting, providing or submitting the User Content to KUNA Pay, the User grants KUNA Pay and any necessary sub-licensees a non-exclusive, worldwide, perpetual, right and permission to use, reproduce, copy, edit, modify, translate, reformat, create derivative works from, distribute, transmit, publicly perform and publicly display the User Content and sub-license such rights to others.

Although KUNA Pay has no obligation to screen, edit or monitor the User Content, KUNA Pay reserves the right to monitor the Website and User Content posted on the Website. The User agrees that KUNA Pay may, in its sole discretion, review and delete any User Content that violates these Terms or that might be offensive, illegal, or that might violate the rights of, harm, or threaten the safety of other Users or any third party. The KUNA Pay also reserves the right to access, read, preserve, and disclose any  information as it reasonably believes is necessary to:

  • satisfy any applicable law, regulation, legal process or  governmental request;
  • enforce these Terms, including investigation of potential violations hereof;
  • detect, prevent, or otherwise address fraud, security or technical  issues;
  • respond to User support requests;
  • protect the rights, property, or safety of KUNA Pay, its Users and the public.

The User understands that the technical processing and transmission of the Website, including User Content, may involve:

  • transmissions over various networks; and
  • changes to conform and adapt to technical requirements of connecting  networks or devices.

We do not endorse any User Content or any opinion,  recommendation, or advice expressed therein, and We expressly disclaim any and all liability in connection with User Content. We do not permit copyright infringing activities and infringement  of intellectual property rights on the Website, and We will remove all User Content if properly notified that such User Content  infringes on another’s intellectual property rights. We  reserve the right to remove User Content without prior notice.

If the User believes that its work has been copied in a way that constitutes copyright infringement, or that its intellectual property rights have been otherwise violated, the User should notify us of its infringement claim at

KUNA Pay respects the intellectual property rights of others and expects its Users to do the same. We will respond to notices of alleged copyright infringement that comply with applicable law and are properly provided to us. If the User believes that its Content has been copied in a way that constitutes copyright infringement, please provide the KUNA Pay with the  following information:

  • a physical or electronic signature of the copyright owner or a  person authorized to act on their behalf;
  • identification of the copyrighted work claimed to have been infringed;
  • identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit KUNA Pay to locate the material;
  • the User’s contact information, including address, telephone number,  and email address;
  • a statement by the User that the User has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and
  • a statement that the information in the notification is accurate, and, under penalty of perjury, that the User is authorized to act on  behalf of the copyright owner.

Any User Content submitted by the User may be accessed by KUNA Pay globally.

Except for the User Content and KUNA Pay’s communications and all materials therein or transferred thereby, including, without limitation, software, technology, code, images, text, graphics, illustrations, logos, patents, trademarks, service marks, copyrights, photographs, audio, videos, music, and content belonging to other Users (the “KUNA Pay’s Content”), and all Intellectual Property Rights (defined below) related thereto, are the KUNA Pay’s exclusive property and KUNA Pay’s licensors. Except as explicitly provided herein or in any applicable additional terms and conditions, nothing in this Terms shall be deemed to create a license in or under any such Intellectual Property Rights, and the User agrees not to sell, modify, reverse engineer, license, rent, distribute, copy, reproduce, transmit, publicly display, publicly perform, publish, adapt, edit or create derivative works from any of KUNA Pay’s Content, absent specific consent in writing fromUs. Use of the KUNA Pay’s Content for any purpose not expressly permitted by this Terms is strictly prohibited.

We grant the User a non-exclusive, limited, non-transferable, freely revocable license, subject to this Terms, to access and use the Services, and related content, materials, information (collectively, the “Content”) solely for approved purposes as permitted by Us from time to time. Any other use of the Content is expressly prohibited and all other right, title, and interest in the Content is exclusively the property of the KUNA Pay and its licensors. The User agrees not to copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Content, in whole or in part. “KUNA”, “KUNA Pay”, and all logos related to the Services are KUNA Pay’s trademarks or registered marks. The User may not copy, imitate or use them without the KUNA Pay’s prior written consent.

For the purposes of this Terms, “Intellectual Property Rights” means all patent rights, copyright rights, mask work rights, moral rights, rights of publicity, trademark, trade dress and service mark rights, goodwill, trade secret rights and other intellectual property rights as may now exist or hereafter come into existence, and all applications therefore and registrations, renewals and extensions thereof, under the laws of any state, country, territory or other jurisdiction.

We may display third-party content, advertisements, links, promotions, logos and other materials (collectively, the “Third-Party Content”) for User’ s convenience only. We do not approve of, control, endorse or sponsor any third parties or Third-Party Content, and the We make no representations or warranties of any kind regarding such Third- Party Content, including, without limitation, the accuracy, validity, legality, copyright compliance, or decency of such content.

14. Confidentiality and Privacy

KUNA Pay will not disclose Confidential information received in connection with Service provision without the prior written consent of the other User. 

The information shall not be treated as confidential and KUNA Pay shall have no obligation regarding such information if it meets at least one of the following conditions: 

  • was known before Service provision; 
  • legally obtained by third parties outside the context of Services; 
  • publicly disclosed by User; 
  • allowed to be distributed with the written consent of User. 

Personal information that you provide to KUNA Pay, including information provided in accordance with our Policies and any information about your use of the Website that KUNA Pay obtains will be subject to our Privacy Policy. KUNA  Pay respects the privacy of its clients and KUNA Pay does not request any information that is unnecessary for the use of the Services or to comply with KUNA Pay’s obligations under applicable law. 

KUNA Pay reserves the right to provide information to law enforcement personnel and other third parties to answer inquiries, participate in investigations, respond to legal process, respond to the order of a court of competent jurisdiction and those exercising the court’s authority, and to protect KUNA Pay, its directors, officers, employees, shareholders, clients, service providers and other concerned parties. KUNA Pay may be obliged to disclose Your personal information to law enforcement authorities, data protection authorities, financial regulators, financial service providers, governmental authorities and officials, and other authorized persons, as set forth in the Privacy Policy. 

The User acknowledges and accepts that the User will comply willingly with all legal requests for information from KUNA Pay. 

The User understands that by using the Services, the User consents to the collection, use, and disclosure of User’s personally identifiable information and aggregate data and to User’s personally identifiable information being collected, used, transferred to, and processed in jurisdictions where KUNA Pay carries on business. By agreeing to these Terms, the User expressly allows KUNA Pay to export data outside of the jurisdiction in which the User resides or is located when it accesses the Services. The User acknowledges that KUNA Pay may process personal data in relation to the User (if they are an individual), and personal data that the User has provided or in the future will provide to KUNA Pay in relation to its legal entity, employees, or other associates, in connection with these Terms or the Services. Accordingly, the User represents and warrants that:

  • User’s disclosure to KUNA Pay of any personal data relating to individuals other than themselves (if they are an individual) was or will be made in accordance with all applicable data protection and data privacy laws, and such data is accurate, up to date, and relevant when disclosed;
  • before providing any such personal data to KUNA Pay, the User has read and understood KUNA Pay’s Privacy Policy, which may be amended from time to time and is incorporated herein by reference and forms a part of these Terms, and has provided a copy to any individual whose personal data the User has provided to KUNA Pay;
  • and from time to time if KUNA Pay amends the Privacy Policy, the User will promptly read it and provide a copy to any individual whose personal data the User has provided to KUNA Pay.

KUNA Pay cares about the integrity and security of User’s personal information, and KUNA Pay takes a number of security measures including storing all User’s personal information in an encrypted fashion. However, KUNA Pay cannot guarantee that unauthorized third parties will not defeat KUNA Pay’s security measures or use User’s personal information for improper purposes. 

The User acknowledges that the User provides its personal information to KUNA Pay at its own risk. The User understands that KUNA Pay is not responsible or liable for any damage or interruptions caused by any computer viruses, spyware, scareware, Trojan horses, worms or other malware that may affect the User’s computer or other equipment, or any phishing, spoofing or other attack from using the Services. 

The User acknowledges that KUNA Pay advises the regular use of a reputable and readily available virus screening and prevention software. The User should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from KUNA Pay. KUNA Pay’s customer support will never seek to access the User’s computer or ask for the User’s password or its two-factor authentication codes. The User shall always log into the Account through the access details provided by KUNA Pay to review any transactions or required actions if the User has any uncertainty regarding the authenticity of any communication. The User is solely responsible for the activity that occurs in relation to the Account, and the User must keep the Account password secure. KUNA Pay recommends that the User uses “strong” passwords (passwords that use a combination of upper- and lower-case letters, numbers and symbols) with the Account. The User must notify KUNA Pay immediately of any breach of security or unauthorized use of the Account by emailing KUNA Pay at KUNA Pay will not be responsible or liable for any damages, liability or losses caused by any unauthorized use of the Account.

15. Limitation of Liability. Disclaimer of Warranties

For non-performance or improper performance of their obligations under these Terms, KUNA Pay and you shall be liable in accordance with these Terms and the Applicable Law, unless otherwise provided hereby.

The Website, Content, and Services are provided without any guarantees, conditions, or warranties as to its accuracy, quality, and fit for a particular purpose or need. KUNA Pay does not guarantee that the Website and Services are error-free, reliable, or will operate without interruption. The Website and Content is provided to you on an "AS-IS" basis.

User understands and agrees that KUNA Pay has no control over, and no duty to take any action regarding: 

  1. failures, disruptions, errors, or delays in processing Virtual Assets that you may experience while using the Services; 
  2. the risk of failure of hardware, software, and Internet connections; 
  3. the risk of malicious software being introduced or found in the software underlying KUNA Pay; 
  4. the risk that third parties may obtain unauthorized access to information stored within your Wallet, including, but not limited to your Wallet address, private key, and mnemonic (backup) phrase; and 
  5. the risk of unknown vulnerabilities in or unanticipated changes to the Networks. 

You release KUNA Pay from all liability related to any losses, damages, or claims arising from:

  1. user error such as forgotten passwords, incorrectly constructed transactions, or mistyped Virtual Assets addresses;
  2. server failure or data loss; 
  3. unauthorized access to the KUNA Pay application;
  4. bugs or other errors in the KUNA Pay software; and 
  5. any unauthorized third-party activities, including, but not limited to, the use of viruses, phishing, brute-forcing, or other means of attack against KUNA Pay. 

KUNA Pay makes no representations concerning any third-party Content contained in or accessed through our Services. Any other terms, conditions, warranties, or representations associated with such content, are solely between you and such organizations and/or individuals.

KUNA Pay shall not be liable for the use or inability to use the Website and Services.

In no event shall KUNA Pay, its officers, directors, employees, agents, third-party service providers be liable to you or any other person or entity for any direct, indirect, incidental, special, punitive, or consequential damages whatsoever, including any that may result from:

  1. the accuracy, completeness, or content of the Website,
  2. the accuracy, completeness, or content of any websites linked (through  hyperlinks, banner advertising or otherwise) to the Website,
  3. the Services found at the Website or any websites linked (through  hyperlinks, banner advertising or otherwise) to this Website,
  4. personal injury or property damage of any nature whatsoever,
  5. third-party conduct of any nature whatsoever,
  6. any unauthorized access to or use of KUNA Pay's servers and/or any and  all content, personal information, blockchain information or other  information and data stored therein,
  7. any interruption  or cessation of Services to or from the Website or any websites linked  (through hyperlinks, banner advertising or otherwise) to this site,
  8. any viruses, worms, bugs, trojan horses, or the like, which may be  transmitted to or from this site or any websites linked (through  hyperlinks, banner advertising or otherwise) to this Website,
  9. any loss or damage of any kind incurred as a result of your use of the Website or the Services found at the Website, whether based on warranty,  contract, tort, or any other legal or equitable theory, and whether or not Kun Pay is advised of the possibility of such damages,
  10. losing access and/or unauthorized access to your Account,
  11. any errors or malfunctions caused by or otherwise related to any wallets used to deposit and withdraw Virtual Assets,
  12. malfunctions, breakdowns and abandonment of blockchain protocols,
  13. changes in regulatory approaches or legal actions taken regarding the blockchain technology and Virtual Assets,
  14. taxation and/or changes in tax system regarding Virtual Assets,
  15. advancements in cryptography, any technical advancements that may present risks to blockchain protocols,
  16. unfavorable fluctuations of Virtual Assets,
  17. errors in the provision of Services;
  18. other risks associated with purchasing, holding, and Virtual Assets, and using the Website and Services.

KUNA Pay shall not be liable for any events that may include but are not limited to civil, criminal, and administrative actions that may arise from you using blockchain and Virtual Assets if such use is forbidden or otherwise limited in your country.

KUNA Pay, its officers, directors, employees, and agents do not provide investment advice, financial advice, trading advice, legal advice or any other sort of advice.

To the extent permitted by Applicable Law, you agree to defend, indemnify, and hold harmless KUNA Pay from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses arising from:

  • user error such as forgotten passwords, incorrectly constructed transactions, or mistyped Virtual Assets addresses;
  • server failure or data loss;
  • unauthorized access to the Wallet;
  • bugs or other errors in the Website software; and
  • any unauthorized third party activities, including, but not limited to, the use of viruses, phishing, brute forcing, or other means of attack against Website. 

It is User’s responsibility to determine what, if any, taxes apply to the transactions that User have submitted transaction details for via the Services, and it is User’s responsibility to report and remit the correct tax to the appropriate tax authority. Users agree that We are not responsible for determining whether taxes apply to User’s transactions or for collecting, reporting, withholding, or remitting any taxes arising from any Virtual Assets-related transactions.

It is User’s responsibility to determine partners (B2B) as legal and reliable. Before using any Service each User is obliged to perform KYC procedure with his partners.

16. Indemnification

To the extent permitted by applicable law, you agree to defend, indemnify, and hold harmless KUNA Pay, its affiliates, contractors, licensors, and their respective directors, officers, employees and agents from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including, but not limited to, attorney's fees, fines or penalties imposed by any regulatory authority) arising from:

  • your use of and access to the Services;
  • any feedback or submissions you provide to Us concerning KUNA Pay;
  • your violation of any term of these Terms; or
  • your violation of any law, rule, or regulation, or the rights of any third party.

17. Assignment

Users agree that We may assign any of KUNA Pay’s rights and/or transfer, sub-contract, or delegate any of our obligations under these Terms. Your agreement to these Terms is personal to you and you may not transfer or assign it to any third party.

18. Force Majeure

KUNA Pay shall not be held liable for any delays, failure in performance, or interruptions of service which result directly or indirectly from any cause or condition beyond KUNA Pay’s reasonable control, including but not limited to: any delay or failure due to any act of God, act of civil or military authorities, act of terrorism, civil disturbance, war, strike or other labor dispute, fire, interruption in telecommunications or Internet services or network provider services, failure of equipment and/or software, other catastrophe, or any other occurrence which is beyond our reasonable control and shall not affect the validity and enforceability of any remaining provisions.

19. Announcements

We may from time to time post official announcements, news, notices, etc. (the 'Announcements') on the Website. In no event shall KUNA Pay be liable for any losses arising from you neglecting or ignoring the Announcements.

20. Dispute Resolution

These Terms are governed by the laws of Lithuania. You and KUNA Pay shall endeavor to resolve through negotiations all disagreements that may arise between you and the KUNA Pay during the validity term hereof.

If the parties fail to reach an agreement on the dispute within 30 (thirty) calendar days, the dispute shall be submitted to the competent court under the Applicable Law.

21. Amendments of these Terms of Use

We have the right to unilaterally change these Terms of Use. The changes take effect immediately after the moment the new version of Terms of Use is published on the Website. If the User does not accept a new edition of the Terms of Use, they must stop using the Website and Services.

22. Final Provisions

 These Terms of Use shall remain in force until terminated either by you or the KUNA Pay. We may terminate these Terms of Use at any time at its own discretion without explaining the reasons for this decision.

In the event these Terms of Use are available in multiple languages, the English version of the Terms shall prevail.

All provisions of these Terms of Use applicable to the Website shall apply to others means of providing Services, unless specifically stated otherwise.