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TERMS OF SERVICE

Rules for using PUMIO on web and in the mobile app.

Last updated 12 August 2026

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

#### A. Web Transactions (Whale Group LTD as Seller)

  • Seller: All purchases made via our websites are sold by Whale Group LTD.
  • Payment Processing: Card payments and checkout are processed by Revolut through its Merchant API. We do not collect, store, or process your full payment card details.
  • Tax and Invoicing: Applicable VAT, Sales Tax, or Goods and Services Tax (GST), and customer invoices for web purchases, are calculated and issued using Quaderno.
  • Web Products: On the web, fiat checkout is limited to Diamond packs only (same model as mobile). Pumio does not sell creator or premium subscriptions for fiat on the web.
  • In-Platform Spends (Web and Mobile): After Diamonds are credited, you may use Diamonds inside the Services (web or mobile) to subscribe to a Creator, send creator support, or unlock premium digital content. These actions use Diamonds only, not a separate fiat subscription checkout.

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

  • Payment Agents: Purchases within our iOS and Android applications are processed via the Apple App Store or Google Play Store.
  • Diamond Packs Only: Mobile in-app purchases are limited to Diamond packs (virtual currency). Pumio does not sell auto-renewing App Store or Google Play subscriptions.
  • In-App Subscriptions: After Diamonds are credited to your account, you may use Diamonds inside the Services to subscribe to a Creator, send creator support, or unlock premium digital content. These in-platform actions use Diamonds only, not fiat.

#### C. Subscription Renewals and Cancellations

  • Diamond subscriptions (web and mobile): Subscriptions to Creators or premium access paid with Diamonds follow the product rules shown at purchase and may be managed within Pumio. They are not billed through Revolut recurring billing, Apple, or Google subscription systems.
  • Non-Refundable Periods: Diamond spends for the current access period are non-refundable except where applicable law or the original payment processor (Revolut for web Diamond packs, Apple, or Google) mandates a reversal of the underlying fiat charge. See our Refund Policy.

4. Virtual Currency (Diamonds) and In-Platform Transactions

The Services include a virtual currency ("Diamonds") used to support Creators or access digital features.

  • Non-Cash Value: Diamonds are 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 by Subscribers.
  • Who May Hold Diamonds: Subscribers and Creators may hold and spend Diamonds inside the Services. Only Creators may withdraw Available USD earnings as described in Section 5. Diamond inventory itself is never cash-withdrawable.
  • No Subscriber Withdrawals: Subscribers hold a Diamond balance only. Subscribers are not eligible for cash payouts, bank transfers, or any withdrawal of funds from the platform.
  • Creator Support and Content Unlocking: Spending Diamonds on creator support, subscriptions, or premium digital access is a final, non-refundable in-platform transaction for the spender. Once initiated, the Diamond spend cannot be reversed or refunded in cash to the spender. Related Creator earnings are credited to a Pending (Hold) balance—not instant cash-out—and become withdrawable only after clearance under the Creator Agreement and Section 5.
  • Secondary Market Prohibition: The sale, transfer, or barter of Diamonds outside official Service mechanisms is strictly prohibited. Violation may result in immediate account termination.

5. Creator Payout Terms

Creators eligible for payouts must adhere to the following (see also the Creator Agreement):

  • Payoneer and KYC: Creator payouts are processed via Payoneer. Identity verification and compliance (Know Your Customer / Anti-Money Laundering) are completed once directly with Payoneer when you register or request your first withdrawal. Whale Group LTD does not collect, store, or view your government IDs, bank credentials, or full payout account details.
  • Operational Data Only: We may retain non-sensitive linkage data (for example, a Payoneer payee reference or payout status) to route earnings. We do not store payment instruments or reuse your financial credentials.
  • Pending vs Available: Earnings from Diamond spends (creator support and Diamond-paid subscriptions), after Platform Fee, go to Pending Balance (Hold) first. Clearance lasts at least a standard hold period (product default approximately 14 days, which we may change with notice) and may last longer when spent Diamonds remain within a maturity window from acquisition (product default approximately 7 days). Only after release do funds move to Available Balance. Only Available Balance may be withdrawn.
  • New-Account Withdrawal Limits: For a limited period after account creation (product default approximately 60 days), daily and monthly withdrawal caps apply (product defaults approximately $500 USD per day and $2,000 USD per month). These caps then lift automatically unless we set different limits. We may change caps with notice; remaining limits may appear in the Creator dashboard.
  • Promotional or Recovery Credits: Admin, promotional, or recovery credits may require additional review before related amounts become Available.
  • Payout Methods and Timing: Creators must complete Payoneer onboarding before withdrawing. Payments are typically disbursed within seven (7) to thirty (30) business days from a verified request against Available Balance, subject to Payoneer processing and security clearance.
  • Fees and Thresholds: Payouts require meeting a minimum withdrawal threshold ($100 USD or equivalent) and are subject to applicable processing or conversion fees, which we may change with notice.
  • Delay, Refusal, and Reversal: We may delay, refuse, reverse, or claw back Pending or Available balances where we reasonably suspect fraud, chargebacks, wash trading, circular Diamond spending, or other Terms breaches.
  • Independent Tax Responsibility: Whale Group LTD is a technical platform facilitating digital content and creator support. The Company is not an employer, agent, or tax withholding entity for Creators. Creators are solely responsible for declaring and paying all applicable taxes in their country of residence, 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 may result in an immediate, permanent ban.
  • Illegal Activities: Violating any local, national, or international law, including money laundering or facilitating illicit transactions using Diamonds.
  • Artificial Volume and Wash Trading: Creating artificial transaction volume or circular Diamond spending schemes (including coordinated gifts or subscriptions intended to convert purchased Diamonds into withdrawable cash) is prohibited.
  • 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 a serious policy violation, Virtual Diamonds and creator balances may be forfeited 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 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 Limitation of Liability

Our platform relies on external infrastructure providers (payment processors, tax tools, CDNs, payout partners, etc.). By using our Services, you agree:

  • Payment Processing: Billing and card processing for web checkout are handled by Revolut. Mobile Diamond purchases are handled by Apple Inc. or Google LLC. We do not hold your payment credentials.
  • Tax and Invoicing Tools: Quaderno supports tax calculation and invoicing for web sales. We do not store card data through Quaderno.
  • Payout Processing: Payoneer handles creator identity verification and payout credentials. We do not store those credentials.
  • CDN/Infrastructure: Media files are stored on external CDNs. We assume no liability for loss or corruption of assets hosted there.

> 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 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 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