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Additional Terms: VIRTUAL CURRENCY USER AGREEMENT

This Virtual Currency User Agreement (“Virtual Currency Agreement”) is an Additional Term that governs your use of bitcoin and other virtual currency (“Virtual Currency”) services available via the Platform (“Virtual Currency Services”) and that portion of your Account where you can buy, sell, and learn about Virtual Currency (“Virtual Currency Account”). All capitalized terms not defined in this Virtual Currency Agreement have the meanings given to them in the Agreement. Use of the Virtual Currency Services constitutes acceptance of, and agreement to be bound by, this Virtual Currency Agreement. By creating a Virtual Currency Account, you agree that you have read, understood, and accepted all of the terms and conditions set forth in this Virtual Currency Agreement. You are also bound by the Agreement, and your Virtual Currency Account and use of the Virtual Currency Services are subject to the Agreement to Arbitrate contained in Section D(4) of this Agreement, as well as all of the terms and agreements on the Legal Agreements page that apply to you, and all Policies, including:

  1. · the Agreement,
  2. · the Privacy Policy,
  3. · the Acceptable Use Policy, and
  4. · the E-Sign Disclosure and Consent, and
  5. · the Cryptocurrency Risk Disclosure.
A. ACKNOWLEDGMENT OF RISK

Buying and selling Virtual Currency is inherently risky. The value of Virtual Currency can increase and decrease quickly and significantly. There is substantial risk that you can lose money and all of the value of your Virtual Currency by buying and selling Virtual Currency. You should carefully consider the risks, including those set forth herein and in the State Disclosures, in determining whether holding Virtual Currency or engaging in Virtual Currency transactions is suitable for you. Webull Pay is not registered with the United States Securities and Exchange Commission and does not offer securities services. You acknowledge that Virtual Currency is not subject to the protections of, or insurance provided by, the Federal Deposit Insurance Corporation (FDIC) or the Securities Investor Protection Corporation (SIPC). For additional important risk information, please review the Webull Pay Cryptocurrency Risk Disclosure, which is incorporated by reference into this Virtual Currency Agreement.

B. YOUR VIRTUAL CURRENCY ACCOUNT.
  1. 1) Virtual Currency Account Eligibility. To access and use Virtual Currency Services, you must have a Virtual Currency Account. In registering for a Virtual Currency Account, you represent and warrant that you (a) have an Account, (b) are at least 18 years of age (or the age of majority in your state of residence), (c) are an individual and will use the Virtual Currency Services for personal use only, and (d) reside in the United States in one of the states or territories in which Webull Pay is licensed to do business. You may only have one Virtual Currency Account, and you may only utilize a Virtual Currency Account if you have an Account in good standing and we have verified all required identifying information, including your name, physical address, date of birth, and taxpayer identification number, and any additional information we may request to verify such identifying information. Your right to use your Virtual Currency Account and Virtual Currency Services is conditioned upon your acceptance and compliance with this Virtual Currency Agreement. If you do not agree to be bound by this Virtual Currency Agreement, you are not authorized to use your Virtual Currency Account or Virtual Currency Services, and you agree to immediately discontinue any access to or use of your Virtual Currency Account or Virtual Currency Services.
  2. 2) Your Virtual Currency Account. Establishing a Virtual Currency Account allows you to hold a Virtual Currency balance and to buy and sell Virtual Currency, among other things. You will not hold the Virtual Currency assets themselves in your Virtual Currency Account balance. All custody of and trading in Virtual Currency is performed by an appropriately licensed provider of trading and/or custody services that we may identify from time to time ("Service Provider"). If you are a New York resident, the Service Provider will be licensed or otherwise authorized by the New York State Department of Financial Services to the extent required to perform the activities described herein.
  3. 3) Independent Relationship; No Advice. You agree that: (a) we are not acting as your broker, intermediary, agent, or advisor, or in any fiduciary capacity whatsoever, and (b) no communication or information provided to you by us shall be considered or construed as advice. We may provide educational information about Virtual Currency, which may include, but is not limited to, blog posts, articles, links to third-party content, news feeds, tutorials, and videos. We may also offer promotions that include, among other things, incentives to purchase Virtual Currency. Any such educational or promotional materials do not constitute investment advice, financial advice, trading advice, or any other sort of advice and should not be treated as such. You should verify all information that you receive before relying upon it, and we have no liability to you if you make decisions based on the market information that you receive from or through us. You agree that any decision to buy, sell or hold any Virtual Currency is entirely your own. All market data and educational content are provided “as-is” and without any representation or warranty, whether express, implied or statutory. Webull shall have no liability and specifically disclaims all warranties, express or implied, for any market data or educational content on the Platform or any use thereof.
  4. 4) Availability. The term "Virtual Currency" refers to the specific digital assets that we support and make available for buying, selling, or holding through Virtual Currency Services. We reserve the right, in our sole discretion, to determine which Virtual Currencies are available on the Platform and may add, modify, or remove support for any Virtual Currency at any time without prior notice. If we decide to discontinue support for a particular Virtual Currency, we will use commercially reasonable efforts to notify affected users in advance, and you may be required to sell or convert that asset within a specified time period. If you do not take action by the deadline, we may, at our discretion, liquidate the asset on your behalf and credit the resulting USD value to your Account. Not all Virtual Currency Services are available in all jurisdictions. We may restrict or prohibit access to all or part of the Virtual Currency Services in certain states, territories, or countries (“Restricted Locations”) based on legal, regulatory, or operational considerations. You must not attempt to access or use the Virtual Currency Services from any Restricted Location, including by obscuring your IP address or providing inaccurate location information. Your continued compliance with these restrictions is a condition of your use of the Services.

  5. 5) Omnibus Accounts. To securely and efficiently custody assets, Webull Pay may use shared blockchain addresses (controlled by Webull Pay or its Service Providers) to hold Supported Digital Assets for customers. These omnibus blockchain addresses may pool customer assets with those of other users and, in some cases, with assets held by Webull Pay for its own benefit. While we maintain separate internal records and ledgers to track your ownership of specific balances, we are not required to assign a dedicated or segregated blockchain address to you. Your Virtual Currency holdings are recorded and maintained on our books and records as being beneficially owned by you, and we treat those assets as separate from our corporate assets. Webull Pay will not use your Virtual Currency for corporate purposes and will not voluntarily make such assets available to creditors in the event of bankruptcy, insolvency, or similar proceedings. However, the legal treatment of customer-held Virtual Currency in the event of bankruptcy may be uncertain and could result in delays or losses that are outside our control. You acknowledge that your entitlement to specific Virtual Currency is based solely on the records maintained by Webull Pay and not on title to a particular, identifiable token or blockchain address. Cryptocurrency services are offered through an account with Webull Pay, LLC, a subsidiary of Webull Corporation, Inc. (“Webull”). Webull Pay is not a member of FINRA or SIPC. Cryptocurrencies are not stocks or securities, and your cryptocurrency investments are not insured by the Federal Deposit Insurance Corporation (FDIC) or protected by the Securities Investor Protection Corporation (SIPC). Webull Pay’s cryptocurrency services are separate and distinct from any brokerage or securities services offered by Webull Financial, LLC (“WF”). WF’s regulatory registrations and protections do not extend to Webull Pay or its cryptocurrency services.

  6. 6) Closing Your Virtual Currency Account. You must close your Account in order to close your Virtual Currency Account. Closing your Account will automatically close your Virtual Currency Account. Please note that there may be tax consequences from any gain or loss you incur when you sell Virtual Currency or from the receipt of new cryptocurrency through an airdrop following a fork (as defined below) that we support. You can terminate your relationship with us at any time without cost, but you will remain liable for all obligations related to your Virtual Currency Account and Account even after those accounts are closed. You must sell any Virtual Currency in your Virtual Currency Account before closing your Account and Virtual Currency Account. You will not be able to transfer Virtual Currency from your Virtual Currency Account to another cryptocurrency wallet. Any Virtual Currency remaining in your Virtual Currency Account upon closure will be handled in accordance with Section [2c] of this Virtual Currency Agreement.

  7. 7) Amendments to this Agreement. We may modify or amend this Virtual Currency Agreement at any time and may impose new or additional terms or conditions on your use of your Virtual Currency Account or Virtual Currency Services. Webull Pay will notify you of such modification, amendment, or new terms by (a) posting revised terms of use on the Platform, or (b) sending you an email notification to the email address you provide to us in connection with your Account. You are responsible for periodically reviewing this Virtual Currency Agreement as posted on the Platform. Revisions to the Agreement will be deemed effective at the time of posting, unless otherwise noted. Your continued use of your Virtual Currency Account or the Virtual Currency Services Account or the Virtual Currency Services, including by holding Virtual Currency, will indicate your acceptance of the revised Virtual Currency Agreement. If you do not agree with the revised Virtual Currency Agreement, your sole and exclusive remedy is to discontinue use of your Virtual Currency Account and Virtual Currency Services and terminate your Virtual Currency Account.

C. VIRTUAL CURRENCY TRANSACTIONS.
  1. 1) Limitations on Virtual Currency Services.
    1. a) Limitations. At this time, we do not support sending Virtual Currency to family, friends, or other users; directly using Virtual Currency to make payments or fund peer-to-peer (P2P) transactions; you may only transfer Virtual Currency from your Virtual Currency Account to an external cryptocurrency wallet owned by you. If you wish to withdraw the value held in your Virtual Currency Account, you must first sell your Virtual Currency and withdraw the resulting cash proceeds to your bank account.
    2. b) Conditions and Restrictions. We may, at any time and in our sole discretion, refuse any transaction, including any request to buy or sell Virtual Currency submitted through the Platform, or impose other conditions or restrictions on your use of the Virtual Currency Services, without prior notice. We may also suspend or discontinue the Virtual Currency Services at any time, in our sole discretion. If the Virtual Currency Services are unavailable, any pending purchase or sale requests for Virtual Currency will be canceled.
  2. 2) General Terms.
    1. a) Fees and Limits. Fees for using the Virtual Currency Services are listed on our Fees page. We reserve the right to adjust our fees at any time. By using your Account or the Services, you agree to pay all applicable fees. We also charge a spread (or margin) between the market price we receive from our trading Service Provider and the exchange rate between U.S. dollars (USD) and Virtual Currency displayed to you. We charge a spread on every Virtual Currency transaction. The amount we make and the exchange rate provided may be different than what you would pay on other virtual currency platforms. At the time you buy or sell Virtual Currency, we will disclose to you the applicable exchange rate and the amount of fees that you will be charged for that transaction. We will not separately calculate or disclose the spread we earn on each transaction. By using the Virtual Currency Services, you agree to pay all applicable exchange rates (including spread) and fees.
    2. b) Limits. We may, in our sole discretion, impose limits on the amount of Virtual Currency you can buy or sell, which may include limits on cash value or number of transactions. You can view current limits on our Payments Limits page. Limits may change from time to time in our sole discretion.
    3. c) Taxes. You are solely responsible for determining what, if any, taxes apply to your use of the Virtual Currency Services, and for reporting and remitting the correct tax to the appropriate tax authority. We may provide certain tax forms (such as Form 1099) as required by applicable law, but we do not guarantee the availability, accuracy, or completeness of any tax reporting. We do not provide tax advice, and you should consult a tax professional for guidance.
    4. d) Cancellations; Insufficient Funds. You cannot reverse, cancel, or change any transaction once it has been authorized, and you may only use cash funds from your Account to fund Virtual Currency transactions. If your Account has insufficient funds, you may not be able to complete the requested transaction. If your Account has insufficient funds, you reverse the payment transaction, or we otherwise do not receive payment for your transaction, you authorize us, in our sole discretion, to (i) debit any other balance you hold in your Account, (ii) debit any other funding source you have linked to your Account, (iii) remove Virtual Currency from your account for which payment has not been received, and/or (iv) take any other action that we deem necessary to collect payment for your transaction, as allowed or required by relevant laws and regulations. We also reserve the right to not process, to cancel, or, to the extent possible, to reverse a transaction if: (i) we believe the transaction relates to any restricted activities; (ii) we have placed a hold or limitation on your Account; (iii) we have suspended your Virtual Currency Account; (iv) we believe the transaction involves money laundering, terrorist financing, fraud, or any other type of crime; or (v) we are responding to a subpoena, court order, or other government directive. In such instances, regardless of the reason for the block, cancellation, or reversal—and regardless of the reason we lift or reverse that restriction—we do not guarantee that you will be able to reinitiate the transaction at the same price or on the same terms as the original transaction.
    5. e) No Market Manipulation. Webull Pay expressly prohibits any type of fraud or market manipulation in the buying or selling of Virtual Currency. We may, in our sole discretion, suspend or close any Account that we believe may be engaging in such activities and, if appropriate, notify the proper authorities.
  3. 3) Holding Virtual Currency. The balance shown in your Virtual Currency Account represents your beneficial interest in a specific quantity of each type of Virtual Currency that we support. Your ownership is recorded on our internal ledger and maintained separately from other users’ holdings, even though the actual assets are pooled in omnibus wallets managed by our custodial Service Provider. You acknowledge that you do not own or control any specific, identifiable units of Virtual Currency on the blockchain, and that your entitlement is based solely on our records reflecting your pro rata interest in the pooled account. When you view your Virtual Currency balance, we may display an estimated U.S. dollar (USD) equivalent. This displayed value is based on market data from our trading Service Provider and reflects the midpoint between recent bid and ask prices, excluding any applicable fees or spread. The displayed value is for informational purposes only and does not represent the price you will actually receive in a transaction or liquidation.
  4. 4) Webull Pay holds your virtual currency apart from our corporate assets, and we will neither use these assets for our operating expenses or any other corporate or business purposes, nor will we voluntarily make these Virtual Currency available to creditors in the event of bankruptcy. Our records will reflect your interest in the omnibus account based on the amount of each type of Virtual Currency that is reflected in your Virtual Currency Account.
  5. 5) When you view your Virtual Currency balance, we will show you the amount of each type of Virtual Currency you own, as well as a USD equivalent value of that Virtual Currency. The price of Virtual Currency will rise and fall over time, and the price may sometimes change quickly and dramatically; therefore, even if the number of each type of Virtual Currency you hold remains the same, the USD equivalent value will change as the market price of each Virtual Currency fluctuates. The USD value we display is an estimate based on market data from our trading Service Provider. The value we show is the midpoint between the lowest recent sale price at which the applicable cryptocurrency was offered for sale and the highest recent price at which that same cryptocurrency was purchased, as reported by the Service Provider. This estimate does not represent the value you will receive if you actually sell your Virtual Currency or the price you will pay to buy more Virtual Currency and does not include our spread or fees.
  6. 6) Buying Virtual Currency.
    1. a) Funding Source. You may only use available cash funds from your Account to purchase Virtual Currency. If your Account does not have sufficient funds to complete a purchase, you authorize us to decline or cancel the transaction and, where applicable, to remove any Virtual Currency from your Virtual Currency Account for which payment has not been received. You also authorize us to take any additional action permitted by applicable law to recover amounts owed in connection with the transaction.
    2. b) Purchase Transactions. Before completing a purchase, we will display the amount of Virtual Currency you may receive in exchange for your selected cash amount. Due to the inherent volatility of Virtual Currency markets, the quoted price is only valid for a limited time and may expire if not promptly accepted. If the quoted price expires, we will provide a new quote that may differ—potentially significantly—from the prior price. Once you confirm the transaction, we will execute your order through our trading Service Provider at the current quoted rate, and the transaction becomes final and irreversible. If we are unable to complete your transaction for any reason, we will notify you and no Virtual Currency will be delivered. Upon completion of a successful transaction, you will receive a receipt via email and your transaction will appear in your Account history.
    3. c) No Guarantee. We do not guarantee that Virtual Currency will be available for purchase at any specific time or price. Your ability to complete future purchases may be subject to limitations based on market conditions, availability, regulatory constraints, or changes to our supported assets or services.
  7. 7) Selling Virtual Currency.
    1. a) Sale Transactions. To initiate a sale of Virtual Currency, we will first display the amount of USD you will receive in exchange for a specified quantity and type of Virtual Currency. Because Virtual Currency prices fluctuate rapidly, any quoted price will only be valid for a limited time. If the quote expires before you confirm the sale, the transaction will not proceed at that price, and a new quote (possibly significantly higher or lower) will be provided. Once you confirm the transaction, we will execute the sale through our trading Service Provider at the current quoted rate. You cannot select which specific blockchain units or wallet addresses will be sold. All confirmed transactions are final and irreversible. If we are unable to complete the sale for any reason, we will notify you. Upon successful execution, we will send you a transaction receipt via email, and the transaction will be recorded in your Account history.
    2. b) Sale Proceeds. Proceeds from completed sales will be credited to your Account in USD. The timing of credit availability may vary depending on account holds, applicable limits, or risk controls, including specific holds related to the sale of Virtual Currency.
    3. c) No Guarantee. We do not guarantee the continued availability of the ability to sell Virtual Currency, nor that you will be able to sell at any particular time or price. Market conditions, regulatory changes, or operational limitations may affect your ability to execute sales.
D. VIRTUAL CURRENCY RISK DISCLOSURES
  1. 1) General. VIRTUAL CURRENCY VALUES CAN FLUCTUATE SUBSTANTIALLY, WHICH MAY RESULT IN A TOTAL LOSS OF THE VALUE OF THE VIRTUAL CURRENCY IN YOUR ACCOUNT. While we will try to complete purchases and sales of Virtual Currency that you authorize and that comply with this Virtual Currency Agreement, we do not guarantee your ability to buy or sell Virtual Currency. Your ability to buy or sell Virtual Currency may be delayed or unavailable due to the availability of the Virtual Currency or funds from your funding source, issues with the trading network or our ability to interface with our Service Provider(s), system downtime, limitations or suspensions we impose on your Account in our sole discretion, or for other reasons outside our or any Service Provider's control, and we are not liable to you if we are unable to execute, or delayed in executing, your transactions. You should also carefully review the Webull Pay Cryptocurrency Risk Disclosure, which contains additional important information about the risks of trading and holding Virtual Currency and is incorporated into this Agreement.

  2. 2) Force Majeure. We are not liable for delays, service interruptions, any disruption, change, or limitation of your access to or use of the Virtual Currency Services, including your ability to hold, buy or sell Virtual Currency, including the price for buying and selling, that results, directly or indirectly from extraordinary circumstances outside our control (for example, fire, flood, accident, riots, war, terrorist act, epidemic, pandemic, quarantine, civil commotion, breakdown of communication facilities, breakdown of web host, breakdown of internet service provider, natural catastrophes, governmental acts or omissions, changes in laws or regulations, national strikes, fire, explosion, generalized lack of availability of raw materials or energy, or extreme financial market conditions), which we either did not reasonably foresee or that happened despite our reasonable precautions ("Force Majeure"). We will not be liable to you for limits, suspension, delay, or change to the Virtual Currency Services, or for your inability to transact in Virtual Currency because of any Force Majeure, including any changes in the buy or sell price of Crypto Assets because of any Force Majeure.
  3. 3) Software Protocols; Forks.
    1. a) Software Protocols. We do not own or control any of the software protocols that govern the operation of the Virtual Currency available through the Virtual Currency Services. Because we do not control these protocols, we disclaim all responsibility for their performance, security, or functionality, and we make no guarantees regarding their continued availability, accuracy, or reliability. You acknowledge that the underlying technologies may experience interruptions, bugs, or vulnerabilities outside of our control.
    2. b) Forks. By using the Virtual Currency Services, you acknowledge and agree that the software protocols underlying Virtual Currencies are subject to changes in operating rules, commonly known as “forks.” These forks may materially affect the name, value, or functionality of the affected Virtual Currency. In the event of a fork, we may temporarily suspend Virtual Currency operations (with or without advance notice to you) while we assess the implications. We will use commercially reasonable efforts to notify you of any material fork and our decision to support or not support any resulting branch. We reserve the right, in our sole discretion, to determine whether to support either or both branches of a fork and to resume or terminate support at any time. You understand that forks may result in assets you cannot access unless and until we elect to support the relevant branch.
    3. c) Release. You agree that we are not liable for any losses, damages, or lost profits arising out of changes to software protocols, our decision to support or not support any forked protocol or modified Virtual Currency, or any suspension or delay of trading while we make such determinations. If we choose not to support a fork or modified protocol, you may permanently lose access to assets governed by that fork or protocol.
  4. 4) System Failure. You accept all risks associated with the use of the Virtual Currency Services to conduct Virtual Currency transactions, including, but not limited to, in connection with the failure of hardware, software, internet connections, and failures related to any supported network. The nature of virtual currency means that any technological difficulties experienced by Webull Pay may prevent the access or use of your virtual currency.
  5. 5) Disruption Events. You acknowledge and agree that we are not liable for any changes in the market price or value of any Virtual Currency, including during periods of service interruption or delay. In the event of extreme market volatility, technical failures, legal or regulatory developments, or other significant disruptions affecting the operation or integrity of the Virtual Currency Services (each a “Disruption Event”), we may, in our sole discretion and without prior notice, take one or more of the following actions: (a) suspend access to some or all of the Virtual Currency Services; (b) restrict or cancel transactions; or (c) take any other protective action deemed necessary to maintain the integrity of the Platform or comply with applicable law. We are not responsible for any losses you may incur as a result of any such suspension, restriction, or delay, including losses arising from price fluctuations or your inability to execute transactions. When Virtual Currency Services resume following a Disruption Event, you acknowledge that market prices may have materially changed from those available prior to the disruption, and you may not be able to reinitiate transactions on the same terms.
  6. 6) Limitation of Liability. Our responsibility in connection with Virtual Currency Services is limited to the exercise of reasonable care in operating the Platform, maintaining access to your Virtual Currency, and implementing commercially reasonable security measures to prevent unauthorized access. We are not liable for any unauthorized access to your Virtual Currency or for any loss or harm resulting from such access, unless it is solely and directly caused by our gross negligence, willful misconduct, or intentional wrongdoing. You acknowledge that the security of your Account depends in part on your use of secure credentials, devices, and practices. You will not have any claim against us for any loss of Virtual Currency unless you can demonstrate that such loss was not caused or contributed to by your own actions, omissions, or failure to maintain proper security.
  7. 7) Risks Inherent to Virtual Currency.
    1. a) Virtual Currency transactions are irreversible, and accordingly, losses due to fraudulent or accidental transactions may not be recoverable and we shall not be held liable for any fraudulent or accidental transactions.
    2. b) Virtual Currency is not legal tender and is not backed by a government or central bank. As such, there is no protection, such as deposit insurance, to cover any losses associated with Virtual Currency. Virtual Currency is not insured by FDIC, SIPC, or any other public or private insurer, including against cyber theft or theft by other means.
    3. c) Legislative and regulatory changes or actions at the state, federal or international level may adversely affect the availability use, transfer, exchange, and value of Virtual Currency or the functionality or availability of any Supported Network.
    4. d) Choosing to participate in Virtual Currency transactions is at your own risk and based solely on your own understanding of Virtual Currency and Supported Network
    5. e) Virtual Currency is a target for fraud. Virtual Currency is a target for hackers and hacking can occur even when you use the strongest security settings and as such your Virtual Currency may be irretrievably stolen. Your bank accounts are at increased risk of being hacked when linked to Virtual Currency accounts.
    6. f) The value of Virtual Currency may be derived from the continued willingness of market participants to exchange fiat (government-issued) currency for Virtual Currency, which may result in the potential for permanent and total loss of value of a particular Virtual Currency should the market for that Virtual Currency disappear.
    7. g) The volatility and unpredictability of the price of Virtual Currency relative to fiat currency may result in significant loss over a short period of time.
    8. h) There is no assurance that a person who accepts Virtual Currency as payment today will continue to do so in the future.
E. ADDITIONAL TERMS AND CONDITIONS
  1. 1) Acceptable Use and Restricted Activities. In addition to the restricted activities and acceptable use policies set forth in the Agreement, you agree not to engage in any of the following activities in connection with your use of the Virtual Currency Services:
    1. a) Violate or attempt to violate this Virtual Currency Agreement or any other applicable terms, policies, or laws;
    2. b) Use funds that we reasonably believe to be fraudulent, illegally obtained, or unauthorized to purchase Virtual Currency;
    3. c) Initiate any transaction you do not intend to complete, or that is designed to abuse, manipulate, mislead, or defraud other users, the market, or Webull Pay;
    4. d) Engage in any conduct that operates to defraud, deceive, or otherwise harm Webull Pay, its users, or third parties; or
    5. e) Control or access an account that is linked to another account that has engaged in any of the above activities.

    If we determine that you have violated this Virtual Currency Agreement or engaged in any prohibited conduct, we may, in our sole discretion and without notice, suspend or terminate your Virtual Currency Account, restrict your access to the Services, freeze or liquidate your assets, or take any other appropriate action to protect our platform, users, or legal obligations.

  2. 2) Suspension and Termination; Account Closure.
    1. a) Suspension, Termination, Discontinuance of Virtual Currency Services. We may, in our discretion, with or without prior notice to you, and at any time, limit, suspend, modify, discontinue, either temporarily or permanently, any portion of our Virtual Currency Services, if we think it is necessary to do so to protect us, our Users, including you, our employees, affiliates, or partners, or third parties from danger or loss, if required by applicable law, or by court order to limit or refuse the Virtual Currency Services. If we exercise our rights to limit or refuse your access to Virtual Currency Services, we will not be responsible for any consequences of our refusal to give you access to Virtual Currency Services, including any delay, damage or inconvenience you may suffer as a result.
    2. b) Suspension, Termination, Restriction of Access to Virtual Currency Services or Virtual Currency Account. Webull Pay may suspend or terminate your Virtual Currency Account or restrict your access to Virtual Currency Services, at any time in its sole discretion, with or without cause. We may, in our sole discretion and without liability to you, not allow you to establish a Virtual Currency Account or access the Virtual Currency Services; suspend, close or terminate your Virtual Currency Account or access to the Virtual Currency Services, or place a limitation on the type or amount of activities in which you can engage using your Virtual Currency Account. This may occur if we are unable to verify your identity; if we believe you have engaged in restricted activities; pursuant to a court order or other legal process; if you violate this Virtual Currency Agreement or another agreement between you and us; if we are no longer offering Virtual Currency Services in your state of residence; or our Service Provider is no longer supporting the Virtual Currency Services, among other reasons. , including for a violation of this Virtual Currency Agreement. If your Virtual Currency Account or access to the Virtual Currency Services is suspended or restricted, the Virtual Currency in your Virtual Currency Account may fluctuate in value. We are not liable for any losses you may incur as a result of those fluctuations.
    3. c) Account Closure. If, at the time your Virtual Currency Account is closed, it holds any Virtual Currency, you authorize us, in our sole discretion, to liquidate such Virtual Currency into U.S. dollars (USD). We will use commercially reasonable efforts to notify you of the closure and provide an opportunity to transfer or sell your Virtual Currency before liquidation. However, in certain circumstances—such as suspected fraud, legal obligation, account inactivity, or operational necessity—we may liquidate the Virtual Currency without prior notice. The sale will occur at the then-current market price available through our trading Service Provider or at another reasonable price determined by us in our reasonable discretion. You understand that the market value of Virtual Currency may fluctuate significantly and that we are not obligated to execute the liquidation at the most favorable price. After liquidation, any unrestricted USD proceeds will be credited to your Account. You remain solely responsible for any tax obligations that may arise as a result of the liquidation, including any gain or loss incurred.
    4. d) Suspension, Termination, Reversal of Transactions. We may suspend, refuse, freeze, decline, delay, redirect or reverse any transaction request, including purchase or sale requests, for any reason, even after funds or Virtual Currency has been credited to your Virtual Currency Account, including for suspected fraud or illegal activity, in response to a subpoena, court order, or other government order, or if we believe that the transaction is erroneous.
  3. 3) Security Interest; Recovery of Funds; No Other Encumbrances.
    1. a) Security Interest. Except where prohibited by law or regulation, and solely to the extent necessary to secure any amounts you owe to us under this Virtual Currency Agreement or any related agreement (including in the event of a negative balance, suspected fraud, or unlawful activity), you grant to us a lien on, and security interest in, the Virtual Currency held in your Virtual Currency Account. This security interest does not extend to Virtual Currency where no obligation or liability to us exists.
    2. b) Recovery of Funds. You authorize us to recover funds from you in accordance with this Agreement and any other agreement you have with us, including where you owe amounts due to a negative balance, suspected fraud, or other unauthorized or unlawful activity. If the balance in your Account (including your Virtual Currency Account) becomes negative for any reason, that negative balance represents an amount you owe to us. You authorize us to sell your Virtual Currency and use the proceeds to pay such negative balance or other amounts owed to us in your Virtual Currency Account or any other Account you own. If we sell your Virtual Currency to satisfy amounts owed, we will use the price that otherwise applies to the sale of such Virtual Currency at the time, or another reasonable price determined in our reasonable discretion. You acknowledge that the value of Virtual Currency may fluctuate significantly and that we are not obligated to sell at the most favorable price. We will provide notice where feasible, but we may sell without prior notice if necessary to protect our rights or comply with legal obligations.
    3. c) Other Encumbrances. Except as expressly provided in this Section, we will not pledge, hypothecate, assign, or otherwise encumber your Virtual Currency.
  4. 4) Dispute Resolution and Arbitration. Any dispute, claim, or controversy arising out of or relating to this Virtual Currency Agreement, your Virtual Currency Account, or your use of the Virtual Currency Services, including the validity, enforceability, or scope of this arbitration clause, shall be resolved exclusively through final and binding arbitration administered by the American Arbitration Association (“AAA”) under its Consumer Arbitration Rules, including any rules governing the resolution of disputes through document submissions or in-person hearings, at the sole discretion of the arbitrator. The arbitration shall be conducted on an individual basis, and you and Webull Pay expressly waive any right to pursue or participate in any class, consolidated, representative, or private attorney general proceeding. YOU AND WEBULL PAY ALSO WAIVE ANY RIGHT TO A JURY TRIAL. The arbitrator’s award shall be final, binding, and may be entered as a judgment in any court of competent jurisdiction. The arbitration shall be confidential, and neither party may disclose the existence, content, or outcome of any arbitration without the other party’s consent, except as required by law or to enforce the award. Each party shall bear its own costs and attorney’s fees unless otherwise provided by applicable law or the AAA rules. The arbitration clause shall survive the termination or expiration of this Agreement or your use of the Virtual Currency Services. By agreeing to this arbitration clause, you acknowledge that you are knowingly waiving your right to litigate disputes in court and accept arbitration as the sole forum for dispute resolution.
  5. 5) Other Provisions. No waiver of any provision of this Virtual Currency Agreement will be deemed a further or continuing waiver of such provision or any other provision, and our failure to assert any right or provision under this Agreement shall not constitute a waiver of such right or provision. If any provision of this Virtual Currency Agreement is found to be invalid, illegal, or unenforceable under applicable law, the remaining provisions will continue in full force and effect. The section headings used in this Virtual Currency Agreement are for convenience only and shall not affect the interpretation or legal effect of any provision.

Webull Pay LLC (NMLS ID 1886762) is a licensed money transmitter and has a registered address of 108 W. 13th Street, Wilmington, DE 19801.

If you experience any issues please contact Webull Pay customer support via +1 (888) 828-0618 or at support@webull.com.

Please be aware of fraud and potential scams. Any actual or suspected Unauthorized Access and/or Unauthorized Activity will be treated by Webull Pay as potentially fraudulent. You agree to notify us within twenty-four (24) hours if you become aware of or suspect any Potentially Fraudulent Activity, by emailing Webull Pay customer support.

For residents in New York, Guam and Northern Mariana Islands only:

Digital asset services are provided by Bakkt Financial Solutions I, LLC ("Bakkt") (NMLS ID 1890144) through the Webull Pay platform operated by Webull Pay, LLC dba Webull Pay. Bakkt is not a registered broker-dealer and is not a member of SIPC or FINRA. Digital assets are not FDIC- or SIPC-insured. Bakkt Financial Solutions I, LLC is licensed to engage in virtual currency business activity and money transmission by the New York State Department of Financial Services. Please ensure that you fully understand the risks involved before trading. See here for Bakkt Licenses and Bakkt Disclosures.

Webull Pay LLC has collaborated with Bakkt Financial Solutions I, LLC ("Bakkt") to provide you convenient access to cryptocurrency trading. Webull Pay LLC and Bakkt are separate entities. As a customer of both Webull Pay LLC and Bakkt, you have an account at Bakkt to manage your cryptocurrencies.

For more assistance, please contact us via our in app Help Center or at support@webull.com.

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