TERMS AND CONDITIONS
Last Updated: May 7, 2025
These Terms and Conditions (“Terms”) constitute a legally binding electronic agreement between you (“User,” “you,” or “your”) and UAB “Sapion Solution” (“Sapion,” “we,” “us,” or “our”), a company incorporated in Lithuania with Company Number 306182986, having its legal address at Vilnius, Krivių g. 5, LT-01204, Lithuania. These Terms govern your use of the sapion.org website (the “Site”), and any and all services, products, and content provided by Sapion (collectively, the “Services”).
As used herein, “Sapion” refers to UAB “Sapion Solution”, including but not limited to its owners, directors, investors, officers, employees, agents, or other related parties, unless otherwise provided herein.
Please read these Terms carefully before agreeing to them. By accessing or using the Site and our Services, you agree to be bound by these Terms. If you do not agree to these Terms, you must not access this Site or use any of Sapion’s Services.
You are solely responsible for understanding and complying with any and all laws, rules, and regulations of your specific jurisdiction that may be applicable to you in connection with your use of any and all Services of Sapion.
These Terms incorporate our Privacy Policy by reference, so by accepting these Terms, you agree with and accept all policies published on the Site.
1. DEFINITIONS
- Account: Means the personal cabinet of the verified User, where transaction history and personal data can be seen and managed.
- Fiat Currency: Means government-issued currency that is designated as legal tender in its country of issuance through government decree, regulation, or law.
- Funds: Means Virtual Currency or Fiat Currency.
- Virtual Currency: Means a value represented in digital form, which is digitally transferable, preservable, or tradable and which natural persons or legal persons accept as a payment instrument but that is not the legal tender of any country (e.g., cryptocurrencies).
- Services: Means all and any services provided by Sapion through the Site, including the exchange of Virtual Currencies for Fiat Currencies and vice-versa, and other related services.
- Site: Means Sapion’s website at sapion.org.
- Transaction: Means the transfer of Virtual Currency or Fiat Currency between the User and Sapion, or other transactions performed in accordance with the Services provided by Sapion.
- Transaction Fee: Means a fee which is payable to Sapion for each completed Transaction.
- Transaction Price: Means the total price paid by the User or to the User with respect to each Transaction performed via the Services.
- User: Means a natural person or a legal entity that uses the Site and Services and agrees to follow these Terms.
2. SCOPE OF THE SERVICES
2.1. Sapion provides services related to Virtual Assets as a duly registered Virtual Asset Service Provider (VASP) in Lithuania. The Services primarily include allowing Users to buy and sell Virtual Currencies for Fiat Currencies, and other related services as may be offered on the Site.
2.2. Depending on the User’s place of residence or incorporation, the User may not be able to use all or any of the Services. It is the User’s responsibility to follow those rules and laws in their place of residence and/or place from which the User accesses this Site or Services.
2.3. Considering the nature of Virtual Currency wallet addresses, the possibility to refund, re-enter, or change a wallet address once a transaction is initiated may be absent or limited. Users are obliged to understand this and agree to these Terms prior to initiating any transactions.
3. USER ELIGIBILITY, ACCOUNT REGISTRATION, AND RESPONSIBILITIES
3.1. To use our Services, you must register for an Account. By registering for an Account, you represent and warrant that:
You are at least 18 years old or of legal age to form a binding contract under applicable law;
You have full legal capacity to accept these Terms and enter into transactions involving Virtual Currencies;
You will provide accurate, current, and complete information during the registration process and keep your Account information updated;
You will comply with all applicable laws and regulations related to your use of the Services;
The Fiat Currency or Virtual Currency you use for transactions belongs to you and is derived from legal sources;
Your use of the Services will not violate the rights of any third party or applicable laws.
3.2. You undertake to read these entire Terms carefully before using the Site or any of the Services provided by Sapion.
3.3. You are responsible for maintaining the confidentiality and security of your Account credentials (including passwords) and for all activities that occur under your Account. It is prohibited for a User to have more than one Account.
3.4. You undertake to notify Sapion immediately of any unauthorized use of your credentials or any other breach of security by email addressed to [email protected]. Any User who violates these rules may have their Account terminated and may be held liable for any losses incurred by Sapion or any user of the Site.
3.5. You undertake not to use the Services to perform criminal activity of any sort, including but not limited to money laundering, illegal gambling operations, financing terrorist organizations, or malicious hacking.
3.6. You are responsible for any and all damages caused and all liability actions brought against UAB “Sapion Solution” for infringement of any third-party rights or violation of any applicable laws.
3.7. All payment instruments (e.g., bank account, credit card, debit card) used during a Transaction must be in your name. Any attempt otherwise will be considered fraud.
4. SAPION’S RIGHTS AND RESPONSIBILITIES
4.1. Sapion has the right to suspend or terminate a User’s Account or Transaction if there is non-fulfilment or undue fulfilment of these Terms by the User, or for other reasons as outlined in these Terms.
4.2. Sapion undertakes to provide the Services with reasonable effort and due care and in accordance with these Terms.
4.3. Sapion’s responsibility shall be limited to using reasonable technical efforts to ensure the proper functioning of the Services. When initiating Virtual Currency transactions to a wallet address provided by the User, Sapion’s responsibility shall be further limited to ensuring the transfer of the necessary technical data to the relevant Virtual Currency network.
4.4. To the extent permitted by law, Sapion is not responsible for any damages, loss of profit, loss of revenue, loss of business, loss of opportunity, loss of data, indirect or consequential loss unless the loss suffered is caused by a breach of these Terms by Sapion.
4.5. Sapion is not responsible for any malfunction, breakdown, delay, or interruption of the Internet connection or any reason why our Site is unavailable at any given time.
4.6. Sapion is not responsible for delays in the processing of payments made by the fault of any third-party operators of such transactions (e.g., banks, payment processors).
4.7. In the case of suspected fraud or other illegal activity, Sapion undertakes to report all necessary information, including names, addresses, and all other requested information, to the relevant authorities. Users recognize that their Account or Transaction may be frozen at any time at the request of any competent authority investigating fraud or any other illegal activity.
5. USER VERIFICATION (KYC/AML)
5.1. Sapion is required to comply with applicable Know Your Customer (KYC) and Anti-Money Laundering (AML) laws and regulations. Therefore, identification and verification procedures are required for all Users and Transactions.
5.2. If a User refuses to provide required documents and information for KYC/AML purposes, including additional information that may be requested after business relationships have been established, Sapion reserves the right to refuse or terminate the provision of Services to the User immediately.
5.3. The User authorizes Sapion, directly or indirectly (through third parties), to make any inquiries Sapion considers necessary to check the relevance and accuracy of the information provided for verification purposes. Personal data transferred will be limited strictly to what is necessary and with security measures in place to protect the data.
6. TRANSACTIONS
6.1. The Site allows the User to initiate Transactions for Virtual Currencies and other Services provided by Sapion.
6.2. The User recognizes that a payment order should only be submitted after careful consideration. The User understands and accepts the consequences of its execution and agrees that as soon as a payment order is executed, such Transaction may be irreversible and may not be cancelled. Transactions will be considered to have taken place at the execution date and time.
6.3. The User acknowledges and agrees that Transactions may be delayed due to KYC/AML verifications and other compliance checks. Similarly, and due to the inherent nature of Virtual Currency networks, the User acknowledges and agrees that the transfer of Virtual Currency to the specified wallet may take some time.
6.4. If the User discovers transaction activity that the User did not initiate, the User shall immediately notify Sapion of this fact and follow the instructions sent by Sapion. Otherwise, Sapion reserves the right to freeze the funds until the end of the investigation.
6.5. Sapion may be forced to cancel or recall an already executed transaction at the request of financial institutions (including but not limited to banks) involved in the settlement of such transactions. In such cases, the User is obligated to cooperate with Sapion to discover the reasons for such a request.
7. TRANSACTION FEES
7.1. The User agrees to pay Sapion the Transaction Fee for each completed Transaction. Sapion reserves the right to set Transaction Fees at its discretion. Current fees will be displayed on the Site or at the point of Transaction.
7.2. Sapion has no control over exchange rates or fees imposed by a User’s card issuer or bank. Therefore, Sapion bears no responsibility for such extra costs.
8. PROHIBITED USES AND ILLEGAL TRANSACTIONS
8.1. It is strictly forbidden to use the Site or Services for any illegal purposes. Sapion will report any suspicious activity to the relevant law enforcement authorities.
8.2. The User shall ensure that they do not use the Services for transactions relating to (but not limited to):
- Money laundering, terrorist financing, proliferation of weapons of mass destruction;
- Human trafficking;
- Any goods or services that are illegal or the promotion, offer, or marketing of which is illegal;
- Goods or services that violate copyrights, industrial property rights, or other rights of any person;
- Drugs, narcotics, or hallucinogens;
- Weapons of any kind;
- Illegal gambling services;
- Ponzi, pyramid, or any other “get rich quick” schemes;
- Goods that are subject to any trade embargo;
- Any other illegal goods, services, or transactions.
8.3. Sapion reserves the right to suspend or terminate a User’s Account, freeze funds, or cancel Transactions at any time if we reasonably believe it is required to do so by law or to comply with recommendations issued by a relevant government authority or recognized body for the prevention of financial crime.
9. PROHIBITION OF USE (NON-SUPPORTED JURISDICTIONS)
9.1. Sapion maintains the right to accept, allow, restrict, and deny Services according to its internal policies and regulatory restrictions. Sapion may restrict or deny its Services to individuals or legal entities from certain jurisdictions (“Non-Supported Countries”). A list of Non-Supported Countries, if applicable, will be maintained and updated by Sapion and may be available on the Site.
9.2. By accessing and using the Services, the User confirms that they:
- Are NOT in any trade or economic sanction lists (e.g., UN Security Council Sanctions list, EU consolidated sanction list, OFAC’s “Specially Designated National” list);
- Are NOT a resident of or located in any Non-Supported Country;
- Do NOT meet the criteria for a “US Person” status as may be defined by Sapion or relevant regulations (unless specifically permitted by Sapion under applicable laws and regulations);
- Are NOT acting on behalf of individuals or entities who are residents of Non-Supported Countries or have US Person Status (unless specifically permitted).
9.3. Users who illegally or fraudulently manage to receive Services in violation of these prohibitions are subject to immediate suspension or termination of their Account and Services without refund, and may be solely responsible for any legal actions from law enforcement authorities.
10. ACCOUNT SECURITY
10.1. The User is responsible for maintaining the confidentiality of their Account’s credentials. Sapion personnel will never ask the User to disclose their password.
10.2. It is advisable to change passwords regularly and choose strong, unique passwords. The User must never allow anyone to access their Account or watch them accessing their Account.
10.3. If the User has any security concerns about their Account or believes their credentials have been compromised, the User must change the password and contact Sapion Support Service ([email protected]) without undue delay. Any undue delay in notifying Sapion may affect Account security and may result in the User being liable for losses.
10.4. The User must take reasonable care to ensure their email account(s) are secure, as email may be used for password resets or security communications. Sapion cannot be liable for breaches of a User’s email account leading to unauthorized Transactions.
10.5. Users must always ensure their browser does not store login details when accessing their Account, especially on public or shared computers.
11. INTELLECTUAL PROPERTY RIGHTS
11.1. All content on this Site, including text, graphics, logos, trademarks, audio clips, video, data compilations, software, and the compilation of all content on the Site, is the property of UAB “Sapion Solution” or its content suppliers and is protected by copyright, trademark, and other applicable intellectual property laws.
11.2. The trademarks, trade names, service marks, and logos of Sapion and others used on the Site are the property of Sapion and their respective owners.
11.3. The content on the Site should not be copied, reproduced, modified, republished, uploaded, posted, transmitted, scraped, collected, or distributed in any form or by any means, whether manual or automated, without prior written permission from Sapion.
11.4. If you believe your intellectual property rights have been infringed, please contact us at [email protected].
12. TERMINATION
12.1. The User may terminate these Terms and close their Account at any time, following the settlement of any pending transactions, by notifying Sapion.
12.2. Sapion may, by giving notice, at its sole discretion, terminate a User’s access to the Site and their Account. This includes the right to limit, suspend, or terminate the Service and Users’ Accounts, prohibit access to the Site and its content, services, and tools, delay or remove hosted content, and take technical and legal steps to keep Users off the Site if Sapion believes they are creating problems or possible legal liabilities, infringing intellectual property rights, or acting inconsistently with these Terms.
12.3. Reasons for suspension or termination by Sapion may include, but are not limited to:
- Attempts to gain unauthorized access to the Site or another User’s Account;
- Overcoming software security features;
- Usage of the Service for illegal activities;
- Violations of these Terms;
- Failure to pay or fraudulent payment for Transactions;
- Unexpected operational difficulties;
- Requests from law enforcement or other government authorities.
12.4. Sapion also reserves the right to cancel unconfirmed Accounts or Accounts that have been inactive for an extended period (e.g., six months or more) and/or to modify or discontinue the Site or Service.
12.5. The suspension or termination of an Account shall not affect the payment of Transaction Fees due for past Transactions.
13. SERVICES AVAILABILITY AND DISCLAIMERS
13.1. Services are provided “AS IS” and “AS AVAILABLE” without guarantees of any kind, either expressed or implied. Sapion does not warrant that the Site or Services will be error-free, uninterrupted, or secure.
13.2. Sapion will strive to keep the Site up and running; however, all online services suffer from occasional disruptions and outages, and Sapion is not liable for any disruption or loss the User may suffer as a result. Sapion does not provide any guarantees that access to the Site will not be interrupted or that there will be no delays, failures, errors, omissions, or loss of transmitted information.
13.3. Sapion will use reasonable endeavors to ensure that the User can normally access the Site in accordance with these Terms. Sapion may suspend the use of the Site for maintenance and will make reasonable efforts to give the User notice, though this may not be possible in an emergency.
14. NO FINANCIAL OR LEGAL ADVICE
14.1. Sapion does not provide any financial, investment, or legal advice in connection with the Services.
14.2. Sapion may provide information on the price, range, and volatility of Virtual Currencies and events that have affected their price, but this should not be considered investment or financial advice and should not be construed as such. Any decision to buy or sell Virtual Currencies is the User’s decision, and Sapion will not be liable for any loss suffered. Users are solely responsible for determining whether any contemplated Transaction is appropriate for them based on their personal goals, financial status, and risk willingness.
15. TAXATION
15.1. The User undertakes to pay all their taxes and duties which may result from the use of Sapion Services and should be paid according to the User’s state of residence regulations.
15.2. Sapion is not responsible for any violation made by the User due to their obligation to calculate and pay taxes and duties.
16. NOTICES AND COMMUNICATION
16.1. Sapion reserves the right to send notices to and communicate with the User by any means of communication available to Sapion, considering the contact details provided by the User (including email and notifications on the Site).
16.2. The User expressly agrees to receive any notices in electronic form and to be bound by them if so required by these Terms. Official information may also be provided via the Site.
17. GOVERNING LAW AND DISPUTE RESOLUTION
17.1. These Terms shall be governed by and construed in accordance with the laws of Lithuania, unless otherwise expressly provided.
17.2. All disputes and controversies arising out of or in connection with this Site and these Terms shall be submitted to the competent courts of Lithuania in Vilnius.
17.3. If any portion of these Terms shall be deemed invalid, void, or for any reason unenforceable, such portion shall be deemed severable and shall not affect the validity and enforceability of any remaining portion.
18. LIMITATION OF LIABILITY
18.1. IN NO EVENT SHALL SAPION, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, AND ALL THIRD-PARTY SERVICE PROVIDERS BE LIABLE TO THE USER OR ANY OTHER PERSON OR ENTITY FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, OR CONSEQUENTIAL DAMAGES WHATSOEVER, INCLUDING ANY THAT MAY RESULT FROM (I) ACCURACY, COMPLETENESS, OR CONTENT OF THIS SITE, (II) ACCURACY, COMPLETENESS, OR CONTENT OF ANY SITES LINKED TO THIS SITE, (III) THE SERVICES FOUND AT THIS SITE OR ANY SITES LINKED TO THIS SITE, (IV) PERSONAL INJURY OR PROPERTY DAMAGE OF ANY NATURE WHATSOEVER, (V) THIRD-PARTY CONDUCT OF ANY NATURE WHATSOEVER, (VI) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SERVERS AND/OR ANY AND ALL CONTENT, PERSONAL INFORMATION, FINANCIAL INFORMATION OR OTHER INFORMATION AND DATA STORED THEREIN, (VII) ANY INTERRUPTION OR CESSATION OF SERVICES TO OR FROM THIS SITE OR ANY SITES LINKED TO THIS SITE, (VIII) ANY VIRUSES, WORMS, BUGS, TROJAN HORSES, OR THE LIKE, WHICH MAY BE TRANSMITTED TO OR FROM THIS SITE OR ANY SITES LINKED TO THIS SITE, (IX) ANY USER CONTENT OR CONTENT THAT IS DEFAMATORY, HARASSING, ABUSIVE, HARMFUL TO MINORS OR ANY PROTECTED CLASS, PORNOGRAPHIC, “X-RATED”, OBSCENE OR OTHERWISE OBJECTIONABLE, AND/OR (X) ANY LOSS OR DAMAGE OF ANY KIND INCURRED AS A RESULT OF THE USER’S USE OF THIS SITE OR THE SERVICES FOUND AT THIS SITE, WHETHER BASED ON WARRANTY, CONTRACT, TORT, OR ANY OTHER LEGAL OR EQUITABLE THEORY, AND WHETHER OR NOT SAPION IS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
18.2. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW AND SHALL SURVIVE ANY TERMINATION OR EXPIRATION OF THIS AGREEMENT OR THE USER’S USE OF THIS SITE OR THE SERVICES FOUND AT THIS SITE.
18.3. IN ADDITION, YOU SPECIFICALLY ACKNOWLEDGE AND AGREE THAT IN NO EVENT SHALL SAPION’S TOTAL AGGREGATE LIABILITY EXCEED THE TOTAL AMOUNT OF TRANSACTION FEES PAID BY THE USER TO SAPION FOR THE PARTICULAR SERVICES THAT ARE THE SUBJECT OF THE CAUSE OF ACTION DURING THE TWELVE (12) MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM.
19. INDEMNITY
19.1. The User agrees to protect, defend, indemnify, and hold harmless Sapion and its officers, directors, employees, agents, and third-party service providers from and against any and all claims, demands, costs, expenses, losses, liabilities, and damages of every kind and nature (including, without limitation, reasonable attorneys’ fees) imposed upon or incurred by Sapion directly or indirectly arising from (i) the User’s use of and access to this Site or the Services; (ii) the User’s violation of any provision of these Terms or the policies or agreements which are incorporated herein; and/or (iii) the User’s violation of any third-party right, including without limitation any intellectual property or other proprietary right.
19.2. The indemnification obligations under this section shall survive any termination or expiration of these Terms or the User’s use of this Site or the Services.
20. MODIFICATIONS AND AMENDMENTS
20.1. Sapion reserves the right to amend or modify any portion of these Terms at any time by publishing the revised version of the Terms on the Site and updating the “Last Updated” date at the top of these Terms.
20.2. The changes will become effective and shall be deemed accepted by the User the first time the User uses the Services after the publishing of the revised Terms and shall apply on a going-forward basis with respect to any activity initiated after publishing.
20.3. In the event that the User does not agree with any such modification, the User’s sole and exclusive remedy is to terminate the use of the Services and close their Account. The User agrees that Sapion shall not be liable to the User or any third party as a result of any losses suffered by any modification or amendment of these Terms.
21. FORCE MAJEURE
21.1. If Sapion is unable to perform the Services outlined in these Terms due to factors beyond its control, including but not limited to an event of Force Majeure, change of law, or change in sanctions policy, Sapion will not have any responsibility to the User with respect to the Services provided hereunder for a time period coincident with the event. Force Majeure events include, but are not limited to, acts of God, war, riots, embargoes, acts of civil or military authorities, fire, floods, accidents, strikes, or shortages of transportation facilities, fuel, energy, labor, or materials.
22. LINKS TO THIRD-PARTY WEBSITES
22.1. This Site and the Services may contain links to third-party websites or services that are not owned or controlled by Sapion.
22.2. Sapion assumes no responsibility for the content, terms and conditions, privacy policies, or practices of any third-party websites or services. Sapion does not censor or edit the content of any third-party websites or platforms.
22.3. By using this Site or the Services, you expressly release Sapion from any and all liability arising from your use of any third-party website or service. Accordingly, Sapion encourages you to be aware when you leave this Site or the Services and to review the terms and conditions, privacy policies, and other governing documents of26 any other website or service that you may visit.
23. CONTACT INFORMATION
If you have any questions about these Terms, please contact us at:
UAB “Sapion Solution”
Email: [email protected]
Legal Address: Vilnius, Krivių g. 5, LT-01204, Lithuania