📄 TERMS OF SERVICE

Welcome to Pumio, a service provided by Whale Group LTD. These Terms of Service ("Terms") constitute a legally binding agreement between you ("User," "you," or "your") and Whale Group LTD, a company incorporated under the laws of England and Wales ("Company," "we," "us," or "our").

These Terms govern your access to and use of our websites, mobile applications (available via Apple App Store and Google Play Store), software, and all related services (collectively, the "Services").

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1. Corporate Structure and Trading Names

Whale Group LTD operates various software products and IT startups under distinct trade and brand names ("Trading Names"). These Terms apply fully and seamlessly to our product currently operating under the trading name Pumio, as well as any future products, applications, or websites managed under our corporate structure.

> Agreement: By accessing or using Pumio or any other Service provided by Whale Group LTD, you agree to be bound by these Terms.

2. Eligibility and Account Registration

• Age Requirement: You must be at least 13 years old (or the minimum legal age in your country) to use the Services. If you are under 18, you represent that you have received your parent or legal guardian’s permission.
• Account Security: You are solely responsible for maintaining the confidentiality of your account credentials and for all activities occurring under your account. You must notify us immediately of any unauthorized use.

3. Monetization, Subscriptions, and Payment Architecture

To ensure global tax compliance and secure transaction processing, we utilize third-party payment architectures. By purchasing premium features or subscriptions, you acknowledge and agree to the billing terms of these providers.

#### A. Web Transactions (Merchant of Record)

• Processing Agent: All purchases made via our websites are processed exclusively by Lemon Squeezy, LLC, acting as our Merchant of Record (MoR).
• Tax Responsibility: Lemon Squeezy is the legal seller of the digital goods and is responsible for calculating, collecting, and remitting applicable VAT, Sales Tax, or Goods and Services Tax (GST).
• Governing Terms: All web purchases are subject to Lemon Squeezy’s Terms of Service and Privacy Policy.

#### B. Mobile Applications (In-App Purchases)

• Payment Agents: All purchases made within our mobile applications for iOS and Android are processed via the Apple App Store or Google Play Store. These platforms act as billing and tax agents.
• Subscription Management: Subscriptions purchased in the apps are managed and billed through your Apple ID or Google Play account, subject to their respective terms.

#### C. Subscription Renewals

• All premium subscriptions (PRO versions) renew automatically (monthly or annually).
• To prevent renewal, you must cancel at least 24 hours before the end of the current billing cycle through the platform where the purchase was originally made (Lemon Squeezy, Apple, or Google).

4. Virtual Items (Coins) and Creator Support

The Services may include a virtual currency ("Coins") to support creators ("Creators") or unlock digital features.

• Non-Cash Value: Coins are strictly defined as a limited, non-transferable, revocable license to access specific digital features. They have no real-world monetary value, do not earn interest, and cannot be redeemed for currency or physical goods.
• In-App Appreciation & Content Unlocking: Transfers of Coins from users to Creators represent final, non-refundable purchases of premium digital interactions or access to exclusive content. Once initiated, the transaction cannot be reversed or refunded.
• Secondary Market Prohibition: The sale, transfer, or barter of Coins outside of official Services mechanisms is strictly prohibited. Violation results in immediate account termination.

5. Creator Payout Terms

Creators eligible for payouts must adhere to strict conditions:

• Verification Requirement (KYC/AML): Creators must successfully complete identity verification (Know Your Customer and Anti-Money Laundering regulations). This is handled by a specialized third-party compliance provider.
• *Note on Data Handling:* Whale Group LTD does not collect or view your government IDs. We only receive a binary "Success" or "Failed" notification from the independent provider.
• Limitation of Liability: The Company assumes no liability for any data breaches, security issues, or processing errors related to sensitive documents handled by the third-party provider.
• Payout Methods & Timing: Payouts will be processed via specialized third-party payout providers (such as Wise or bank transfer) at our sole discretion. Payments are disbursed within seven (7) to thirty (30) business days from submission of a verified request, subject to security clearance.
• Fees and Thresholds: All payouts require meeting a minimum withdrawal threshold ($100 USD or equivalent) and are subject to applicable payment processing/conversion fees, which we reserve the right to change at any time.
• Independent Tax Responsibility of Creators: Whale Group LTD acts solely as a technical platform and intermediary facilitating digital appreciation between users. The Company does not operate as an employer, agent, or tax withholding entity for Creators. Creators are solely and exclusively responsible for declaring, reporting, and paying all applicable income taxes, self-employment taxes, social contributions, or any other statutory levies required by the local tax authorities in their respective countries of residence. The Company will not issue tax certificates or withhold taxes on behalf of Creators, unless explicitly mandated by United Kingdom law.

6. Acceptable Use and Community Guidelines

You agree not to use the Services for the following purposes:

• ❌ Adult Content: Zero tolerance for adult material (18+), including pornography or nudity. Any breach results in an immediate, permanent ban.
• ❌ Illegal Activities: Violating any local, national, or international law. This includes money laundering or facilitating illicit transactions using Coins.
• ❌ Inappropriate Content: Uploading defamatory, obscene, invasive content, or infringing upon intellectual property rights.
• ❌ Technical Abuse: Deploying automated bots, scrapers, or spiders without our prior written consent.

> Forfeiture Warning: In the event of a permanent ban due to an 18+ content violation, all Virtual Coins and creator balances will be immediately forfeited by the Company as liquidated damages. Banned accounts are ineligible for asset recovery.

7. Intellectual Property Rights (IPR)

• Ownership: All content, functionality, source code, designs, and intellectual property associated with Whale Group LTD and Pumio belong to Whale Group LTD.
• Your License: You are granted a limited, non-exclusive license solely for personal, non-commercial use in accordance with these Terms.
• DMCA Reporting: We act as a passive host for user content. If you suspect infringement, please notify us immediately via our separate DMCA/Copyright Policy. The Company disclaims liability for copyright violations by users until a valid takedown notice is received.

8. Limitation of Liability and Warranties

• "As Is" Basis: The Services are provided "AS IS" and "AS AVAILABLE," without any express or implied warranties of any kind.
• Liability Cap: To the maximum extent permitted by law, Whale Group LTD shall not be liable for indirect, incidental, special, consequential, or punitive damages (including loss of profits or goodwill) arising from your use of the Services.

9. Third-Party Services and Absolute Limitation of Liability

Our platform aggregates multiple external infrastructure providers (KYC services, CDNs, payment processors, etc.). By using our Services, you agree to these absolute limitations:

• 🔒 No KYC/Identity Provider Liability: We do not control the security measures of identity verification third parties. We disclaim all liability for breaches or processing errors originating from them.
• ☁️ No CDN/Infrastructure Liability: Your media files are stored on external CDNs. We assume zero liability for the loss, corruption, or deletion of your media assets hosted there.
• 💰 No Payment Processor Liability: All financial faults (billing errors, overcharges) are the sole responsibility of Lemon Squeezy, Apple Inc., or Google LLC. We do not hold your funds and cannot be liable for payment gateway failures.

> Maximum Exemption: TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WHALE GROUP LTD PROVIDES SERVICES "AS IS" AND "AS AVAILABLE." WE ARE NOT LIABLE FOR ANY CONSEQUENTIAL OR PUNITIVE DAMAGES CAUSED BY A THIRD-PARTY SERVICE FAILURE.

10. Mobile Store Addenda (Apple iOS)

To the extent you use our application on an Apple iOS device, these Terms are between you and Whale Group LTD only. Your use is also subject to the standard Apple Licensed Application End User License Agreement (EULA), and in case of conflict, the Apple EULA prevails for that specific app usage.

11. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of England and Wales. You agree to submit exclusively to the courts of England and Wales for any dispute or claim arising under these Terms.

12. Changes to These Terms

We reserve the right to modify these Terms at any time. We will notify you of material changes by posting them on this page and updating the "Last Updated" date. Continued use of the Services after changes take effect constitutes your acceptance of the new Terms.

13. Content Hosting and Third-Party CDNs

All media uploaded to our platform is stored and distributed via an independent, external third-party CDN provider. Whale Group LTD does not directly control this infrastructure. Users are solely responsible for maintaining their own backups of all content they upload.

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📞 Contact Information (Whale Group LTD)

If you have any questions or concerns regarding these Terms, please contact us:

• Company Name: Whale Group LTD
• Company Number: 17318249
• Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
• Email Support: support@pumio.io