Terms for the trader network.

1. General provisions and acceptance

1.1. This document is the agreement between Zephira Technology Limited, registered under company number 3184627, business registration number 74928315-000, incorporated in the Hong Kong Special Administrative Region at Unit 2504, 25/F, Tower 1, Enterprise Square, 9 Sheung Yuet Road, Kowloon Bay, Kowloon, Hong Kong SAR (the «Provider», «Zephira», «we»), and a natural person or individual entrepreneur who provides local account details and confirms transfers through the Zephira peer-to-peer network (the «Trader», «you»).

1.2. Acceptance occurs when you submit the trader application and pass verification, or when you accept the first order allocated to you, whichever happens first.

1.3. The Trader acts in their own name, with their own accounts, and is not an employee, agent or representative of the Provider. Nothing here creates an employment relationship.

1.4. The Trader is responsible for their own tax and reporting obligations in their jurisdiction, and for holding any permission that operating these accounts requires of them locally.

1.5. The public offer governing merchants is published separately and does not apply to the Trader; where the two documents describe the same operation, this agreement governs the Trader’s side of it.

2. Definitions

• Order — a single pay-in or pay-out instruction allocated to the Trader through the platform.
• Requisites — the account details the Trader supplies for an Order: card number, phone number, wallet or bank account, in the Trader’s own name.
• Confirmation — the Trader marking an Order as received or sent, which releases it downstream.
• Collateral — the Trader’s USDT balance held on the platform against the volume they take.
• Reward — the amount credited to the Trader for a completed Order.
• Probation — the initial period of limited volume while confirmation behaviour is observed.
• Appeal — the Trader’s challenge to a penalty, hold or disputed Order.

3. Verification and access

3.1. The Trader passes identity verification before receiving any live volume: an identity document, a liveness check, and confirmation that the accounts offered belong to the Trader personally.

3.2. Access is bound to the Trader’s device and Telegram account. A change of device is re-verified, and concurrent sessions from unrelated locations suspend access pending review.

3.3. The Trader may not transfer, sell, lend or share the account, and may not operate on behalf of another person. Accounts found to be shared or operated by a third party are closed and the balance is held against the claims arising from that use.

3.4. Requisites must belong to the Trader. Supplying accounts registered to another person is a material breach, regardless of whether that person consented.

3.5. The Trader keeps their verification data current and notifies the Provider without delay if an account is blocked, restricted or closed by a bank.

4. How orders work

4.1. Orders are allocated by the platform according to the market, methods, limits and working hours the Trader has set. The Trader accepts or declines within the window shown; repeated silence reduces allocation priority.

4.2. For a pay-in the Trader supplies requisites, waits for the customer transfer and confirms receipt. For a pay-out the Trader sends the transfer and confirms dispatch with evidence.

4.3. Confirmation must reflect what actually happened. Confirming a transfer that did not arrive, or has arrived short, is treated as a false confirmation and handled under the penalties clause.

4.4. The Trader keeps evidence of each Order — statements, receipts, screenshots with visible timestamps — for not less than twelve months, and supplies it on request within the deadline stated in the request.

4.5. The Trader may go offline at any time. Orders already accepted remain the Trader’s responsibility until they close or expire.

5. Collateral and balances

5.1. The Trader maintains USDT collateral on the platform. Allocation limits are set against it, and volume beyond the collateral is not allocated.

5.2. Collateral secures the Trader’s obligations: unconfirmed transfers, established claims, penalties and amounts owed to the Provider under this agreement.

5.3. The Trader may withdraw free collateral at any time, less amounts held against open Orders, open disputes and the claim window applicable to the corridors worked.

5.4. Balances are recorded in USDT. Conversion between local currency and USDT for an Order uses the rate shown at allocation, which is fixed for that Order.

6. Reward and settlement

6.1. The Reward is credited to the Trader’s USDT balance when the Order closes. There is no weekly cycle and no minimum to reach before the first credit.

6.2. Reward rates per corridor are shown in the Trader’s account and may be changed for future Orders on notice; a change never applies retroactively to Orders already allocated.

6.3. Withdrawal is made to the wallet the Trader has nominated and the Provider has verified. A change of wallet is re-verified before the next withdrawal.

6.4. The Trader bears the risk of an incorrect wallet address or an unsupported network, and of instructions given by a person who obtained the Trader’s credentials otherwise than through the Provider’s fault.

7. Probation, limits and holds

7.1. New Traders work under Probation: reduced limits while confirmation times, accuracy and dispute rate are observed. Limits open as the record establishes itself.

7.2. The Provider may set and vary limits per corridor and per account, and may hold a specific Order or the balance where an Order is disputed, where a bank raises a query, or where behaviour diverges materially from the declared profile.

7.3. A hold names its reason and what is needed to lift it, and is released once the review closes. Holds are not used to retain funds beyond what the underlying claim requires.

8. Disputes and unconfirmed transfers

8.1. Where a customer or a merchant disputes an Order, the Provider opens a review and requests evidence from the Trader within a stated deadline.

8.2. Where the claim is established and the Trader is at fault — a transfer not sent, sent short, sent to the wrong requisites, or falsely confirmed — the amount is debited from the Trader’s collateral.

8.3. Where the Trader supplies evidence that the transfer was made correctly, the claim is closed in the Trader’s favour and any hold is released.

8.4. The Trader may appeal a decision within ten business days by writing to the trader desk with the evidence relied on. The appeal is reviewed by someone other than the person who took the first decision.

9. Prohibited conduct

The following end the relationship and put the collateral against the resulting claims:

• confirming a transfer that did not arrive, or arrived in a different amount;
• supplying requisites belonging to another person, or accounts obtained from third parties;
• operating one account for several people, or selling or renting access;
• asking a customer to send funds outside the platform, or contacting customers other than through it;
• using the platform to move the proceeds of fraud, or knowingly accepting funds from a person who is the subject of a police report;
• attempting to identify, contact or profile customers beyond what an Order requires;
• manipulating rates, order allocation or statistics by any technical or organisational means.

10. Penalties

10.1. For a false confirmation the Provider debits the disputed amount and applies a penalty proportionate to it, and suspends allocation pending review.

10.2. For an Order left unconfirmed past its window without notice, allocation priority is reduced and, on repetition, limits are cut.

10.3. A penalty is recorded in a written notice sent to the Trader’s contact address, stating the facts established and the amount applied. The appeal route in clause 8 applies to every penalty.

11. Financial-crime compliance

11.1. The Provider screens Traders at onboarding and periodically thereafter, including sanctions screening, and may request the source of the funds used as collateral.

11.2. The Provider, its partners and the banks involved may request documents and explanations in connection with an operation, and may suspend, block or reverse it in order to counter money laundering, terrorist financing and fraud.

11.3. The Trader co-operates with such requests. Refusal to provide requested information suspends access until the request is answered.

12. Liability

12.1. The Provider is not liable for restrictions applied to the Trader’s accounts by their own bank, nor for interruptions caused by banks, local rails, blockchain networks or communication channels outside its control.

12.2. The Trader is liable to the Provider for losses arising from false confirmation, from requisites that are not theirs, and from breach of the prohibited-conduct clause.

12.3. Neither party is liable for indirect or consequential loss. Nothing in this document limits liability for fraud or wilful misconduct, and some jurisdictions do not allow these limitations, so they may not apply to the Trader.

13. Personal data

13.1. The Provider processes the Trader’s personal data as described in the Personal Data Processing Policy published at zephira.io/privacy, which forms part of this agreement.

13.2. Verification data, device identifiers and Order evidence are retained for the period required by the financial-crime legislation applicable to the Provider, and are disclosed to banks, partners and authorities only where there is a lawful basis.

14. Suspension and termination

14.1. Either party may terminate on fourteen days’ written notice. The Trader’s free collateral is released on termination; amounts held against open Orders and disputes are released as those close.

14.2. The Provider may suspend access immediately where a false confirmation is established, where prohibited conduct is found, or where it is required to do so by a partner, a bank or applicable law. The Trader is notified with the reason and may appeal.

15. Notices and contacts

15.1. Notices reach the Trader through the platform and the Telegram account registered at onboarding. A notice is deemed received one hour after it is sent.

Trader desk, appeals and evidence: traders@zephira.io
Financial-crime compliance: compliance@zephira.io
Personal data: privacy@zephira.io

16. Governing law and disputes

16.1. This agreement is governed by the laws of the Hong Kong Special Administrative Region of the People's Republic of China.

16.2. The parties attempt to resolve a dispute through a written claim answered within twenty business days.

16.3. A dispute not resolved that way is referred to arbitration administered by the Hong Kong International Arbitration Centre under its Administered Arbitration Rules in force at the date of the notice of arbitration, before a sole arbitrator, seated in Hong Kong and conducted in English.

Zephira Technology Limited
company number 3184627, business registration number 74928315-000, incorporated in the Hong Kong Special Administrative Region
Registered office: Unit 2504, 25/F, Tower 1, Enterprise Square, 9 Sheung Yuet Road, Kowloon Bay, Kowloon, Hong Kong SAR