Last Updated: November 1, 2022

Nakamoto & Turing Labs (“we,” “us,” or “our”) is a leading blockchain software development company with a strong focus on leveraging decentralized technologies to provide secure and trusted digital asset management services to individuals like yourself (“you” or “your”). We host a top-level domain website, www.alewallet.app, that serves information regarding Ale Wallet and our offerings, as well as sub-domains for our product offerings (“Sites”), which include text, images, audio, code, and other materials or third-party information.

Due to the rise of scammers finding ways to dupe unsuspecting victims of their digital assets, please verify the SSL certificate each time you visit our domain website. These Terms of Service (as defined below) will only apply to the domain website www.alewallet.app with the valid SSL certificate issued by Encryption Everywhere DV TLS CA. Please ensure the authenticity of the SSL certificate before downloading from, clicking on, or otherwise interacting with the website that you are visiting. For the avoidance of doubt, we have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites or services. We shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods, or services available on or through any such websites or services.

These Terms of Service (“Terms” or “Terms of Service”) contain the terms and conditions that govern your access to and use of the Site and Services (as defined below) provided by us and are an agreement between us and you or the entity you represent. Please read these Terms of Service carefully before using the Site or Services. By using the Site, or clicking a button or checkbox to accept or agree to these Terms of Service where that option is made available or, completing an order form for Services, or, if earlier, using or otherwise accessing the Services (the “Effective Date”), you (1) accept and agree to these Terms of Service and any additional terms, rules, and conditions of participation issued by us from time to time and (2) consent to the collection, use, disclosure and other handling of information as described in our Privacy Policy. If you do not agree to these Terms of Service, you may not access or use the Services.

We hereby remind you that you must carefully read the full content of these Terms of Service and other documents mentioned in these Terms of Service before using our mobile application “Ale Wallet” available on various mobile platforms, including but not limited to Google Play Store and the Apple App Store (“Ale Wallet” or “App”). In particular, you must carefully read the section “Disclaimer and Limitation of Liability.” You must make sure that you fully understand the entire Terms of Service and evaluate the risks of using Ale Wallet on your own.

Confirmation and Acceptance of these Terms of Service

1.1 You understand that these Terms of Service and other relevant documents apply to Ale Wallet and the Decentralized Applications (“DApps”), which are developed and owned independently by us on Ale Wallet (and excluding DApps developed by third parties).

1.2 After you download Ale Wallet and start to create and recover Identity (defined as below) or import wallet, you are deemed as having read and accepted these Terms of Service, which will cause these Terms of Service to become effective and legally binding on both you and us immediately. IF YOU DO NOT AGREE TO THE TERMS IN THESE TERMS OF SERVICE, YOU MUST CEASE USAGE OF Ale Wallet IMMEDIATELY, AND IF YOU HAVE DOWNLOADED Ale Wallet, PLEASE PROCEED TO DELETE ALE WALLET IMMEDIATELY.

1.3 In accessing or using Ale Wallet, you agree:

1.3.1 to be bound by the latest version of these Terms of Service without variation or modification;

1.3.2 that in the jurisdiction to which you are subject, you are of legal age to use Ale Wallet and to create binding legal and financial obligations for any liability you may incur as a result of the use of Ale Wallet; and

1.3.3 you are not an Excluded Person (as defined below).

1.4 We may, at our sole discretion, modify or replace these Terms of Service at any time. The modified Terms of Service will automatically take effect once it is posted on our Sites, and you will not be notified separately. If you disagree with the modifications, you must cease to use Ale Wallet immediately.

1.5 Please note that your use of Ale Wallet after any such modification to these Terms of Service constitutes your acceptance of these Terms of Service as modified.

Definition

2.1 China: means the People’s Republic of China and includes (1) the Hong Kong Special Administrative Region; (2) the Macao Special Administrative Region; and (3) the Taiwan province.

2.2 Ale Wallet: means the multi-coin blockchain wallet developed by us based on distributed ledger technology and other supporting tools which are developed for your convenience when using blockchain systems.

2.3 Excluded Person:

2.3.1 a person other than a natural person who possesses legal and mental capacity to enter into these Terms of Service; or

2.3.2 a person who is prohibited, restricted, unauthorized, or ineligible in any form or manner, whether in full or in part under these Terms of Service, laws, regulatory requirements or rules in the jurisdiction applicable to such a user, to use the Services (as defined below).

2.3.3 For the avoidance of doubt, users resident and/or domiciled in China are Excluded Persons.

WE DO NOT PROVIDE SERVICES TO EXCLUDE PERSONS. IF YOU ARE AN EXCLUDED PERSON, PLEASE IMMEDIATELY STOP USING OUR SERVICES. IF YOU CONTINUE TO USE OUR SERVICES, YOU ACKNOWLEDGE AND AGREE THAT YOU SHALL ASSUME ALL CORRESPONDING LIABILITIES UNDER THE APPLICABLE LAWS, RULES, AND REGULATIONS OF THE JURISDICTION IN THAT YOU ARE RESIDENT AND/OR DOMICILED IN, AND YOU SHALL INDEMNIFY US FROM UNDERTAKING ANY LIABILITIES ARISING FROM YOUR SUCH USE BEHAVIOR, INCLUDING BUT NOT LIMITED TO THE LOSSES, THE THIRD-PARTY CLAIMS OR ADMINISTRATIVE PENALTIES AGAINST US INCURRED BY SUCH CONTRAVENTION, VIOLATION OR BREACH, AS WELL AS REASONABLE LEGAL AND ADMINISTRATIVE COSTS, FEES AND EXPENSES, INCLUDING REASONABLE ATTORNEY’S FEES.

2.4 Identity: means the blockchain identity generated from a pair of your Public Key and Private Key.

2.5 Beginner’s Guide: means the operation guide provided by us before you start to use Ale Wallet (and during your future use of Ale Wallet). This Beginner’s Guide would help you understand the basic knowledge about blockchain.

2.6 Create or import wallet: means your use of Ale Wallet to create or import a wallet after your acceptance of these Terms of Service.

2.7 Wallet Password: means the password determined by you when you create the wallet. The Wallet Password will be used to encrypt and protect your Private Key. Ale Wallet, as a decentralized application, will not store your Wallet Password on our servers, nor will your Wallet Password be stored on your own mobile devices. If you lose or forget your Wallet Password, you will have to reset the Wallet Password with your Private Key or Mnemonic Words.

2.8 Alert: means the messages displayed on Ale Wallet’s operation interface, which provides suggestions for you on subsequent operations.

2.9 Specific Users: means users who should cooperate with us and disclose Personal Information in order to comply with the laws, regulations, and policies of the State of New York and other countries.

2.10 Developer Users: means users who use services provided to Developers, such as Ale Wallet Open Source Code and Developer mode, etc., in accordance with our notices and relevant Open Source License.

2.11 Private Key: consists of 256 random bits. Private Key is the core for you to hold and use the Tokens.

2.12 Public Key: is derived from the Private Key based on cryptography and is used to generate wallet addresses. A wallet address is a public address for receipt of Tokens.

2.13 Mnemonic Words: consists of 12 (or 15/18/21/24) words that are randomly generated, and it is based on BIP39, the industry standard of blockchain. It is a human-readable format of words to back up your Private Key for recovery.

2.14 Keystore: means Private Key or Mnemonic Words in the format of a file that is encrypted and protected by your Wallet Password. Keystore is stored only in your mobile device and will not be synchronized to our servers.

2.15 Tokens: means the tokens which are supported by Ale Wallet currently, including but not limited to BTC, ETH, and so on.

2.16 Materials: means contents in the columns of “Browse,” “Market,” etc. on Ale Wallet. The Materials are third parties’ proprietary properties. You shall not reproduce or distribute the materials without their permission and authorization. Foregoing Materials are solely for your reference and shall not be considered as guidance or advice on your transactions provided by us.

2.17 Notification Center: means the inbox where you may receive messages or notices from us.

2.18 Personal Information: means information recorded in electronic or any other form which may identify a natural person when used alone or in combination with other information, including but not limited to personal biological identification information, e-mail address, wallet address, mobile device information, operation record, transaction record, but excluding Wallet Password, Private Key, Mnemonic Words and Keystore.

2.19 Third-Party Service: means the products and services provided by third parties such as third-party-developed DApp, third-party-developed Smart Contract, third-party-developed Open Source License, third-party-developed cryptocurrency hardware wallet, third-party-developed webpage, and third-party-developed exchange, etc.

Ale Wallet Services (collectively, the “Services”)

3.1 Create or Recover Identity. You may use the “Create Identity” and “Recover Identity” buttons on Ale Wallet to create or recover your Identity and manage multi-blockchain wallets under one Identity.

3.2 Import Wallet. You may use Ale Wallet to create a new wallet or import wallets generated by other wallet applications. You may only import wallets with Tokens that are supported by Ale Wallet.

3.3 Transfer and Receive Tokens. You may manage your digital Tokens by using the transfer and receipt functionalities of Ale Wallet, i.e., you may revise the blockchain ledger by signing with your Private Key. Transfer of Tokens means the payer’s transfer of the Token to the ENS domain or blockchain address of the payee. Such “transfer” of Tokens involves a validated record of such transaction on the distributed ledger of the relevant blockchain system (rather than an actual delivery or transfer of Tokens on Ale Wallet).

3.4 Observe the Quotation. You may use Ale Wallet to observe the quotation of the Tokens provided by third parties. The quotation of each Token is captured by Ale Wallet from the corresponding exchange and is displayed in the “Market” column on Ale Wallet.

3.5 Manage Tokens. You may use Ale Wallet to add, manage or delete the Tokens [from the Ale Wallet interface] (except ETH and BTC) supported by Ale Wallet.

3.6 Browse DApps. You may use Ale Wallet to visit and use the services provided by DApps (including DApps developed by us and DApps developed by third parties).

3.7 Search DApps. You may use the search box on Ale Wallet to search DApps already displayed on Ale Wallet.

3.8 Integrate cryptocurrency hardware wallet. You may match the Ale Wallet of the appropriate version with a certain cryptocurrency hardware wallet and use the cryptocurrency hardware wallet to confirm the transactions operated through Ale Wallet.

3.9 Developer Mode. For the convenience of Developer Users, they may access any websites and any third-party-developed DApps not integrated into Ale Wallet by entering the URL in the search box under the Developer mode.

3.10 Transaction Records. We will copy all or part of your transaction records from the blockchain system. However, you shall refer to the blockchain system for the latest transaction records.

3.11 Suspension of Service. You understand that we are not able to reverse or cancel the transaction because transactions based on blockchain technologies are irrevocable. However, under certain circumstances, we may suspend or limit the function of Ale Wallet used by a particular user.

3.14 Other services that we would like to provide.

Users who use Ale Wallet acknowledge and accept that:

3.15 In order to keep the decentralization feature of blockchain and to protect the security of your digital Tokens, we offer decentralized service which is largely different from the banking and financial institutions. You acknowledge and accept that we SHALL NOT have any responsibility to :

3.15.1 Store your Wallet Password (the password you set when creating or importing wallets), Private Key, Mnemonic Words, or Keystore;

3.15.2 Recover your Wallet Password, Private Key, Mnemonic Words, or Keystore;

3.15.3 Freeze the wallet;

3.15.4 Report the loss of wallet;

3.15.5 Recover the wallet; or

3.15.6 Rollback transactions.

3.16 You shall bear sole responsibility for taking care of your mobile devices, backing up the Ale Wallet App, and backing up the Wallet Password, Mnemonic Words, Private Key, and Keystore. In the event that: your mobile device is lost, your Ale Wallet App or your wallet is deleted and not backed up, your wallet is stolen, or you forget your Wallet Password, Private Key, Mnemonic Words, or Keystore, we will not be able to recover the wallet or recover Wallet Password, Private Key, Mnemonic Words or Keystore. We may not be able to cancel transactions for your mishandling (such as typing in wrong addresses for transactions or wrong amounts to be exchanged), and we shall not be responsible in any way in respect of the same.

3.17 When you use the function of Payment without Password of Ale Wallet, please properly back up the Wallet Password. After multiple failed attempts to verify your Touch ID or Face ID, you will need to input your Wallet Password. If you forget the Wallet Password, you need to import Mnemonic Words/Private Key and set a new Wallet Password. We do not store your biological information, such as your Touch ID or Face ID information, and we shall not be responsible in any way in respect of the same.

3.18 Ale Wallet does not support all existing tokens. Do not use Ale Wallet to handle any non-supported tokens.

3.19 The DApps integrated into Ale Wallet include those developed independently by us and those developed by third parties. Ale Wallet only provides blockchain search and browser functions for those third-party-developed DApps, and thus Ale Wallet does not offer any guarantee for functions or service qualities of those third-party-developed DApps. You shall, at your sole discretion, decide whether there would be any risks to accepting the services provided by or conducting transactions on the third-party-developed DApps.

3.20 The cryptocurrency hardware wallet integrated into Ale Wallet is provided by a third party. Ale Wallet does not guarantee the functions or service qualities of the third-party-developed cryptocurrency hardware wallet. Ale Wallet does not guarantee that Ale Wallet can be matched with any kind and version of cryptocurrency hardware wallet (please see our notifications made from time to time). Before using a third-party-developed cryptocurrency hardware wallet, you shall, at your sole discretion, decide and assess the risks of such a cryptocurrency hardware wallet. You must carefully read and agree to the terms of use of such cryptocurrency hardware wallet updated continuously.

3.21 If you access any websites and any third-party-developed DApps not integrated on Ale Wallet by entering the URL under the developer mode, you acknowledge and agree that you understand the security risks of the websites and the third-party-developed DApps linked by such URL and assume all risks and consequences independently.

YOUR RIGHTS AND OBLIGATIONS

4.1 Create or Import Wallet

4.1.1 Create or import wallet. You are entitled to use Ale Wallet on your mobile device to create and/or import a wallet, set Wallet Password, and use your wallet on Ale Wallet to transfer and receive Tokens on the blockchain.

4.1.2 Identification verification. Specific Users will be asked to complete identification verification before using Ale Wallet to comply with related laws and regulations, according to the notification of Ale Wallet. Specific Users may be asked to provide Personal Information including but not limited to name, identification card number, cell phone number, bank card information, etc., without which the Specific Users will not be able to use certain services, and the Specific Users alone shall be responsible for the loss caused by their delay in completing the verification.

4.1.3 We may develop different versions of Ale Wallet for different terminal devices. You shall download and install the applicable version. If you download and install Ale Wallet or another application with the same name as “Ale Wallet” from any unauthorized third party, we cannot guarantee the normal operation or security of such an application. Any loss caused by using such an application shall be borne solely by you.

4.1.4 A previous version of Ale Wallet may stop operating after a new version is released. We cannot guarantee the security, continuous operation, or customer services of the previous version. You shall download and use the latest version.

4.2 Use of Ale Wallet

4.2.1 You shall bear sole responsibility for taking care of your mobile devices, Wallet Password, Private Key, Mnemonic Words, and Keystore. We do not store or hold the above information for you. You shall be solely responsible for any risks, liabilities, losses, and expenses that result from frauds, you lose your mobile device or cryptocurrency hardware wallet, disclosing (whether actively or passively) or forgetting Wallet Password, Private Key, Mnemonic Words, or Keystore, or your wallet being attacked.

4.2.2 Ale Wallet Alerts. You understand and agree to comply with the Alert(s) published by us on Ale Wallet. You shall be responsible for any risks, liabilities, losses, and expenses which result from your failure to comply with any Alert(s).

4.2.3 You understand that Ale Wallet undertakes no responsibility to conduct due diligence on the Third-Party Service. You shall assess carefully and assume all risks in connection with the use of Ale Wallet.

4.2.4 Provision of Information and Documents. To the extent that we determine, in our sole discretion, that it is necessary to obtain certain information about User in order to comply with any applicable law or regulation in connection with the use or operation of Ale Wallet, you shall provide us with such information promptly upon such request, and acknowledges and accepts that we may restrict, suspend or terminate your use of Ale Wallet until the such requested information has been provided to our satisfaction. You undertake to notify us of any change in the documents and information provided by you to us pursuant to these Terms of Service, and in the absence of any notification in writing notifying of any change, we are entitled to assume that the documents and information provided by you remain true, correct, not misleading and unchanged.

4.2.5 Complete Identification Verification. If we reasonably deem your operation or transactions to be abnormal, or consider your identification to be doubtful, or we consider it necessary to verify your identification documents or other necessary documents, you shall cooperate with us and provide your valid identification documents or other necessary documents and complete the identification verification in time.

4.2.6 Transfer of Tokens

4.2.6.1 You understand that you may be subject to daily limits on the amount and times of transfers according to your location, regulatory requirements, transferring purposes, risk control by Ale Wallet, or identification verification.

4.2.6.2 You understand that blockchain operations are “irrevocable.” When you use Ale Wallet to transfer Tokens, you shall be solely responsible for the consequences of your mishandling of the transfer (including but not limited to the wrong address and problems of the node servers selected by you).

4.2.6.3 You understand that the following reasons may result in a “transfer failed” or “mining overtime” prompt:

insufficient balance in the wallet;

insufficient gas for transaction;

blockchain’s failure to execute the code of smart contracts;

the transfer amount exceeding the transfer limits imposed by authorities, Ale Wallet, or laws or regulations;

technical failure of the network or equipment;

abandoned transactions result from blockchain network congestion or failure;

the wallet address of yours or your counterparty is identified as a special address, such as a high-risk address.

4.2.6.4 You understand that Ale Wallet is only a tool for the transfer of Tokens. We shall be deemed to have fulfilled its obligations once you have completed the transfer and shall not be held liable for any dispute in relation thereto.

4.2.7 DEX. You understand that the limits of amounts that you may exchange via DEX per day are subject to limitations of the third-party-developed Smart Contracts. We may also set limitations and adjust from time to time the limit of amounts that you can exchange via DEX per day.

4.2.8 Compliance. You understand that you shall abide by applicable laws, regulations, and policies when you use Ale Wallet or the DApps, or the Smart Contracts on Ale Wallet.

4.2.9 Notifications. Ale Wallet may send notifications to you by web announcements, Notification Centre information, popup tips, or client-end notices (e.g., information about your transfer or suggestions on certain operations) which you shall be aware of timely.

4.2.10 Service fees and taxes.

4.2.10.1 When you use DEX services, third-party-developed Smart Contracts may charge handling fees and/or service fees from you, which shall be subject to the fees collected by those Smart Contracts, and the relevant information displayed on Ale Wallet is merely for your reference;

4.2.10.2 We do not charge you any service fees or handling fees for the time being. We may reach an agreement with you or announce rules regarding service fees in the future;

4.2.10.3 You need to pay “gas” or network fees when you transfer Tokens, the amount of which would be at your sole discretion and would be collected by the relevant blockchain network;

4.2.10.4 You understand that your transfer of Tokens may fail under certain circumstances, including but not limited to insufficient “gas” or network fees paid by you for the transfer of Tokens during the time of your transfer, or the relevant blockchain network is unstable, and in such event, you may still be charged gas by the relevant blockchain network, notwithstanding the failed transfer attempted;

4.2.10.5 You shall bear all the applicable taxes and other expenses due to your transactions on Ale Wallet.

RISKS

5.1 You understand and acknowledge that blockchain technology is a field of innovation where the laws and regulations are not fully established. You may be faced with material risks, including instability of technology or failure of fiat-token exchange. You also understand that Tokens have much higher volatility compared to other financial assets. You shall hold or dispose of the Tokens in a reasonable way and corresponding to your financial status and risk preferences. You also acknowledge that the market information is captured from exchanges by Ale Wallet and may not represent the latest or the best quotation of each Token.

5.2 If you or your counterparty fails to comply with these Terms of Service or fails to follow the instructions, tips, or rules on the website or on the page of the transaction or payment, we do not guarantee the successful transfer of the Tokens, and we shall not be held liable for any of the consequences of such failure. If you or your counterparty has already received the payment in the Ale Wallet wallet or a third-party-developed wallet, you understand that transactions on the blockchain are irreversible and irrevocable. You and your counterparty shall assume the liabilities and consequences of your transactions.

5.3 You understand and acknowledge that DEX transactions are commenced, conducted, and concluded on third-party-developed Smart Contracts. Ale Wallet is only an interface tool for you to interact with third-party-developed Smart Contracts and displays relevant results of such completed transactions.

5.4 When you use Third-Party Service through Ale Wallet, we strongly suggest you read the terms of service, privacy policy, and other relevant documents and information of such Third-Party Service carefully, get familiar with the counterparty and the product information, and evaluate the risks before you make transactions on such third parties. You understand that such transactions and corresponding contractual relationships are between you and your counterparty instead of us. We shall not be held liable for any risks, responsibilities, losses, or expenses that occurred due to such transactions.

5.5 When you transfer your tokens directly to another wallet address, it is your sole responsibility to make sure that your counterparty is a person with full capacity for civil acts and decide whether you shall transact with him/her.

5.6 You shall check the official blockchain system or other blockchain tools when you receive an Alert such as “transaction failed” or “mining overtime” in order to avoid a repetitive transfer. If you fail to follow this instruction, you shall bear the losses and expenses incurred due to such repetitive transfer.

5.7 You understand that after you create or import a wallet on Ale Wallet, your Keystore, Private Key, and Mnemonic Words are only stored on your mobile device and will not be stored in Ale Wallet or on our servers. You may change another mobile device to use Ale Wallet after you follow the instructions on Ale Wallet to back up your wallet. If you lose your mobile device before you can write down or backup your Wallet Password, Private Key, Mnemonic Words, or Keystore, you may lose your Tokens, and we will not be able to recover them. If your Wallet Password, Private Key, Mnemonic Words, or Keystore is disclosed or the device which stores or holds your Wallet Password, Private Key, Mnemonic Words, or Keystore is hacked or attacked, you may lose your Tokens, and we will not be able to recover them. Any and all losses arising in connection with the foregoing shall be borne solely by you.

5.8 We suggest you back up your Wallet Password, Private Key, Mnemonic Words, and Keystore when you create or import a wallet by writing them down on paper or backup them up in password management apps. Please do not use electronic methods such as screenshots, e-mails, note-taking apps on cell phones, text messages, Telegram, Discord, WeChat, or other messaging apps to back up any of the foregoing information.

5.9 When you choose and purchase a cryptocurrency hardware wallet, we suggest that you should:

5.9.1 confirm whether your purchased cryptocurrency hardware wallet matches the Ale Wallet version; and

5.9.2 choose and purchase a brand-new cryptocurrency hardware wallet from official channels.

5.10 When using the function of Payment without Password of Ale Wallet, we remind you to use such function carefully, and before using the same, we suggest that you should:

5.10.1 understand carefully the security level of the biological identification function of your mobile device;

5.10.2 not turn on such function in a public phone; and

5.10.3 not turn on such function in case of a relatively large amount of cryptocurrency.

5.11 In order to avoid potential security risks, we suggest you use Ale Wallet in a secured network environment. Please do not use a jailbreak or rooted mobile device.

5.12 Please be alert to fraud when you use Ale Wallet. If you find any suspicious activity, we encourage you to inform us immediately.

CHANGE, SUSPENSION, TERMINATION OF OUR SERVICES

6.1 You acknowledge and accept that we may, at our sole discretion, provide only a part of the Services, for the time being, suspend certain Services or provide new Services in the future. When we change our Services, your continued use of Ale Wallet is deemed as your acceptance of these Terms of Service and revisions of these Terms of Service.

6.2 In order to avoid (to the extent possible) any mishandling of Ale Wallet or any risk to the security of your Tokens, you shall not use Ale Wallet if you do not possess the basic knowledge of blockchain. If you do not possess basic knowledge of blockchain, we may refuse to provide all or part of the Services on Ale Wallet to you.

6.3 You understand that we may suspend the Services under the following circumstances (or may completely terminate the Services in connection with any of the following circumstances):

6.3.1 maintenance, upgrading, failure of equipment and blockchain system and the interruption of communications, etc., which lead to the suspension of the operation of Ale Wallet;

6.3.2 force majeure events including but not limited to typhoons, earthquakes, tsunamis, floods, power outages, war, terrorist attacks, computer viruses, trojan horse, hacker attacks, system instability, or government behaviors, and other reasons, which result in our inability to provide Services or if in our reasonable opinion, continuous provision of Services would result in significant risks;

6.3.3 material adverse change of applicable laws or policies; or

6.3.4 any other event(s) which we cannot control or reasonably predict.

6.4 We reserve the right to unilaterally suspend or terminate all or part of the Services or any function of Ale Wallet under the following circumstances:

6.4.1 death of users;

6.4.2 if you steal others’ wallets information or mobile devices;

6.4.3 if you provide false Personal Information on Ale Wallet;

6.4.4 if you refuse to allow mandatory update of Ale Wallet;

6.4.5 if you use Ale Wallet to commit illegal or criminal activities;

6.4.6 if you hinder the normal use of Ale Wallet by other users;

6.4.7 if you pretend to be our staff or management personnel;

6.4.8 if you threaten our normal operations or computer system by an attack, invasion, alternation, or any other means;

6.4.9 if you use Ale Wallet to send spam; or

6.4.10 if you spread rumors which endanger our goodwill and Ale Wallet;

6.4.11 if you conduct any illegal activities, breach these Terms of Service, etc., or other circumstances under which we reasonably consider it necessary to suspend Services.

6.5 You are entitled to export your wallets within a reasonable amount of time if we change, suspend or terminate our Services.

YOUR REPRESENTATIONS AND WARRANTIES

7.1 You shall comply with all applicable laws and regulations of the country or area you reside and/or are domiciled. You shall not use Ale Wallet for any unlawful purposes or by any unlawful means.

7.2 You are not an Excluded Person.

7.3 You shall not use Ale Wallet to commit any illegal or unlawful activities, including but not limited to:

7.3.1 activities endangering the national security of the country or area you reside in, disclosing state secrets, overturning the government, or undermining national unity;

7.3.2 any illegal conduct, such as money laundering, illegal fundraising, etc.;

7.3.3 accessing our services, collecting or processing the content provided by us, intervening or attempting to intervene with any user, by the employment of any automated programs, software, network engines, web crawlers, web analytics tools, data mining tools, or similar tools, etc.;

7.3.4 providing gambling information or inducing others to engage in gambling;

7.3.5 invading others’ Ale Wallet wallets to steal Tokens;

7.3.6 engaging in any inaccurate or false transactions with the counterparty;

7.3.7 committing any activities which harm or attempt to harm Ale Wallet service system and data;

7.3.8 other activities which we have reason to believe are inappropriate.

7.4 You understand and accept that you shall be responsible for any violation of the law (including but not limited to the customs and/or tax regulations) or for breach of these Terms of Service by you and shall indemnify us against the losses, the third-party claims or administrative penalties against us incurred by such contravention, violation or breach, as well as reasonable legal and administrative costs, fees and expenses including reasonable attorney’s fees.

7.5 You confirm that you will pay the service fees charged by us in time (if applicable). We reserve the right to suspend the services when you fail to pay service fees (if applicable).

PRIVACY POLICY

Any personal data or information which you provide to us is also subject to our privacy policy (“Ale Wallet Privacy Policy”), which is incorporated by reference into these Terms of Service.

DISCLAIMER AND LIMITATION OF LIABILITY

9.1 We only undertake obligations expressly set forth in these Terms of Service.

9.2 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ALE WALLET IS PROVIDED ON AN “AS IS, " “AS AVAILABLE,” AND “WITH ALL FAULTS” BASIS. We shall not be held liable for the malfunction of Ale Wallet, which results from any of the following reasons:

9.2.1 system maintenance or upgrading of Ale Wallet;

9.2.2 force majeure, such as typhoon, earthquake, flood, lightning or terrorist attack, etc.;

9.2.3 malfunction of your mobile device hardware and software and failure of telecommunication lines and power supply lines;

9.2.4 your improper, unauthorized, or unrecognized use of the Services;

9.2.5 computer viruses, trojan horse, malicious program attacks, network congestion, system instability, system or equipment failure, telecommunication failure, power failure, banking issues, government acts, etc.;

9.2.6 any other reasons not imputed to us.

9.3 We shall not be held liable due to any of the following circumstances:

9.3.1 you lose your mobile devices, deleting Ale Wallet applications and wallets without back-up, forgetting Wallet Passwords, Private Keys, Mnemonic Words, and Keystores without back-up, which results in the loss of such User’s Tokens;

9.3.2 you disclosing your Wallet Passwords, Private Keys, Mnemonic Words, Keystores, or lending or transferring your Ale Wallet wallets to others, authorizing others to use your mobile devices or Ale Wallet wallets, or downloading Ale Wallet applications through unofficial channels, or using Ale Wallet applications by other insecure means, which result in the loss of your Tokens;

9.3.3 you mishandled Ale Wallet (including but not limited to the wrong address and failure of the node servers selected by you), which result in the loss of Tokens;

9.3.4 you are unfamiliar with the lack of knowledge in relation to blockchain technology and your mishandling of Ale Wallet, resulting in the loss of your Tokens;

9.3.5 Ale Wallet being unable to copy accurate transaction records due to system delay or blockchain instability etc.;

9.4 You undertake the risks and consequences arising or in connection with the following:

9.4.1 your transactions when using Third-Party Service;

9.4.2 your use of developer mode.

9.5 You understand that Ale Wallet is only a management tool for Tokens which is incapable of controlling the quality, security, and legitimacy of the Third-Party Service or the authenticity and accuracy of their information and their capabilities to fulfill the obligations under the agreements with you. You, at your sole discretion, decide whether to use the Third-Party Service. You understand that such transactions and corresponding contractual relationships are between you and your counterparty instead of us. We kindly remind you to carefully review the authenticity, legitimacy, and effectiveness of related information provided by Third-Party Service before you decide to use them. In addition, you shall also assume all the risks arising from the transactions between you and any third-party-developed exchanges.

9.6You acknowledge that Ale Wallet may provide services to you and your counterparty simultaneously or may have an affiliation or other interest relationship with the foregoing parties, and you agree to waive any actual or potential conflicts of interests and will not claim against us on such base or burden us with more responsibilities or duty of care.

9.7 We do not warrant that:

9.7.1 services provided by us would satisfy all your needs;

9.7.2 all techniques, products, services, information, or other materials from us would meet your expectations;

9.7.3 all the transaction information in digital Tokens markets captured from the third-party exchanges are prompt, accurate, complete, and reliable;

9.7.4 your counterparties on Ale Wallet will perform their obligations in the transaction agreements with you timely.

9.8 You are aware that Ale Wallet is only a tool for you to manage your Tokens and display transaction information. We do not provide legal, tax, or investment advice. You should seek independent advice from professional legal, tax, and investment advisors. In addition, we shall not be liable for any investment loss, data loss, etc., during your use of our service.

9.9 You understand that we may change our entry standards, limit the range and ways to provide services for specific users, etc., at any time in accordance with applicable laws and regulations.

Miscellaneous

10.1 No Assignment. Subject to these Terms of Service, only you and no other person shall have the right to any claim against us in connection with the use of the Services. You shall not assign, trade or transfer, or attempt to assign, trade, or transfer, your right to any such claim. Any such assignment or transfer shall be void and shall not impose any obligation or liability on or against us to the assignee or transferee.

10.2 Intellectual Property Rights. Ale Wallet is an application developed and owned by us. The intellectual property rights of any contents displayed in Ale Wallet (including these Terms of Service, announcements, articles, videos, audios, images, archives, information, materials, trademarks, or logos) are owned by us or the third-party licensors. You can only use the Ale Wallet applications and their contents for the purpose of holding and managing their Tokens. These Terms of Service shall not entitle you to any intellectual property rights, including the rights in relation to the use, for any purpose, of any information, image, user interface, logos, trademarks, trade names, internet domain names, or copyright in connection with the Services or us.

10.3 No Waiver. Any failure by us to enforce these Terms of Service or to assert any right(s), claim(s) or causes of action against you under these Terms of Service shall not be construed as a waiver of our right to assert any right(s), claim(s) or causes of action against you.

10.4 Entire Agreement. These Terms of Service include this Ale Wallet Terms of Service, Ale Wallet Privacy Policy, and other rules (including contents in the “Support” column) posted by us from time to time. Save for Ale Wallet Terms of Service and Ale Wallet Privacy Policy which are incorporated in these Terms of Service, these Terms of Service contains the entire agreement and the understanding between us and supersede all prior agreements, understandings, or arrangements (both oral and written) in relation to the use of Ale Wallet and the services in connection thereto.

10.5 Taxes

10.5.1 The use of Services shall be exclusive of all taxes that are applicable to, arising from, or in connection to your use of the Services in any jurisdiction (“Payable Tax”).

10.5.2 You shall be responsible for determining any Payable Tax and declaring, withholding, collecting, reporting, and remitting the correct amount of Payable Tax to the appropriate tax authorities. You shall be solely liable for all penalties, claims, fines, punishments, or other liabilities arising from the non-fulfillment or non-performance to any extent of any of your obligations in relation to the Payable Tax.

10.5.3 We shall not be responsible for determining any Payable Tax and declaring, withholding, collecting, reporting, and remitting the correct amount of Payable Tax to the appropriate tax authorities.

10.6 Governing Law. These Terms of Service shall be governed by and construed in accordance with the laws of the State of New York.

10.7 Jurisdiction. In the event of any dispute arising out of or in connection with these Terms of Service, including any question regarding its existence, validity, or termination, the Parties shall first seek settlement of that dispute. In the event that such dispute is not resolved within a period of thirty (30) days from the commencement of such settlement process, such dispute shall be referred to and finally be resolved by arbitration in the State of New York in accordance with the rules of the New York International Arbitration Centre (“NYIAC”)  for the time being in force, which rules are deemed to be incorporated by reference in this clause. The language of the arbitration shall be English. Each of the Parties irrevocably submits to the non-exclusive jurisdiction of the courts of New York to support and assist the arbitration process pursuant to the foregoing of this paragraph, including, if necessary, the grant of interlocutory relief pending the outcome of that process.

10.8 Severance. If any or part of these Terms of Service is rendered void, illegal, or unenforceable by any legislation to which it is subject, it shall be rendered void, illegal, or unenforceable to that extent and no further and, for the avoidance of doubt, the rest of these Terms of Service shall continue to be valid and in full force and effect.

10.10 Partial Invalidity. The illegality, invalidity, or unenforceability of any provision of these Terms of Service under the law of any jurisdiction shall not affect its legality, validity, or enforceability under the law of any other jurisdiction, nor the legality, validity, or enforceability of any other provision.

10.11 Translated versions of these Terms of Service. Translated versions of these Terms of Service (if any) are provided for your convenience and are not intended to revise the English version of these Terms of Service. If there is any discrepancy between the English version and the non-English version of these Terms of Service, the English version shall prevail.

Others

11.1 You shall fully understand and conform to the laws, regulations, and rules in your jurisdictions that are relevant to the use of the Services.

11.2 During your use of the Services, if you come across any problems, you can contact us through the submission of your feedback on Ale Wallet.

11.3 These Terms of Service are accessible to all users on Ale Wallet. We encourage you to read these Terms of Service each time you log onto Ale Wallet.

11.4 As for any issues not covered in this Agreement, you shall comply with the announcements and relevant rules as updated by the Company from time to time.

11.5 These Terms of Service shall become effective on October 26, 2021.

Nakamoto & Turing Labs