"Platform": means Midcontract's website, applications, smart contracts, and services collectively

"Client" means any individual or entity that contracts for services through the Platform

"Agency" means an organization representing one or more freelancers, operating as a single contractor entity.

"Freelancer": An independent contractor providing services through the Platform

"Agency": An organization representing one or more Freelancers

"Contractor" means either:

• An individual freelancer, or
• An agency providing services through the Platform under an agreed contract

"Smart Contract" means self-executing contracts with terms directly written into code deployed on the Polygon blockchain

‍"Blockchain Transaction": means any operation recorded on the Polygon blockchain related to Platform activities

‍"Wallet": A digital wallet for cryptocurrency transactions

‍“Supported Cryptocurrencies”: USDT, USDC, DAI (operating on the Polygon blockchain)

‍"Embedded Wallet": A wallet integrated into the Platform, powered by Alchemy, for seamless transactions

‍"External Wallet": A cryptocurrency wallet owned and managed independently by the user (e.g., MetaMask)

‍"On-Ramp/Off-Ramp": Services that enable users to convert fiat currency to cryptocurrency (on-ramp) or cryptocurrency to fiat (off-ramp)

‍"Hourly Rate": The agreed-upon payment amount per hour for services provided in an hourly contract

‍"Weekly Limit": The maximum number of hours a freelancer can log and be compensated for within a week

‍"Escrow": means funds held in smart contracts until specified conditions are met

‍"Platform Fee": means the percentage fee charged by Midcontract for provided services

‍"Gas Fee": means the computational cost required to perform transactions on the Polygon network

‍"Contract": A binding agreement between a Client and a Freelancer/Agency outlining the terms of service, payment, and deliverables

‍"Contract Value" means the total agreed payment amount for services, excluding fees

‍“Escrow Return Request”: A formal request initiated by the client to recover escrowed funds when contract deliverables remain unfulfilled or do not meet specifications

‍“Dispute”: A formal disagreement raised by either party regarding contract terms, deliverables, or payments

‍“Dispute Manager”: A representative responsible for overseeing dispute processes and making final determinations

‍“Manual Review”: A verification process where submissions flagged for further inspection are manually reviewed by Midcontract’s legal specialists

‍“Evidence Submission”: Supporting documentation or proof provided by parties during a dispute, including screenshots, files, or correspondence

‍“Prepayment”: An advance payment for hourly contracts subject to potential return requests

‍“Resolved’ Status”: A contract status update indicating the conclusion of a dispute or return request

‍“Withdrawn’ After Dispute”: A status indicating partial funds were released after dispute settlement

• Must be at least 18 years old and legally able to enter into contracts

• Responsible for:
  
  • Providing accurate project requirements
  • Funding escrow accounts before work begins
  • Reviewing and approving deliverables within specified timeframes
  • Maintaining confidentiality of project information
  • Completing KYC/AML verification as required
  • Ensuring their profile details, such as email addresses and wallet information, are accurate and up-to-date to avoid service interruptions

• Must be at least 18 years old and legally able to provide services

• Responsible for:
  • Delivering services as specified in Contracts
  • Maintaining professional standards and meeting deadlines
  • Protecting client confidential information
  • Completing KYC/AML verification
  • Accurately representing skills and experience
  • Ensuring their profile details, such as email addresses and wallet information, are accurate and up-to-date to avoid service interruptions

• Individual or organization representing one or more Freelancers
• Responsible for:
  
  • Managing contracts on behalf of associated Freelancers
  • Delivering services as specified in Contracts
  • Maintaining professional standards and meeting deadlines
  • Protecting client confidential information
  • Completing KYC/AML verification
  • Accurately representing skills and experience of their team
  • Managing communication with Clients
  • Ensuring fair distribution of payments to associated Freelancers
  • Maintaining transparency with associated Freelancers regarding contract terms
  • Ensuring their profile details, such as email addresses and wallet information, are accurate and up-to-date to avoid service interruptions

Initial Setup:

• Either the client or contractor (freelancer/agency) can initiate the creation of a fixed-price contract.
• The contract requires both parties to be registered, logged in, and KYC/AML-verified.
• Initial terms include:
  
  • Project name and description
  • Total agreed payment amount
  • Delivery deadline (optional)
  • Payment structure: single payment or by milestones

Modification Process:

• Parties may request updates to contract terms before it is accepted.
• Changes after activation require mutual agreement and an update request via the platform.

• Fixed-Price Contracts:
  
  • The full payment amount must be deposited into the escrow account before work begins.
• Milestone-Based Contracts:
  
  • The first milestone's payment must be deposited before work begins.
  • Subsequent milestone payments are deposited and approved incrementally.

Work Submission:

• Contractors submit completed work or deliverables via the platform.
• Contractors may attach relevant files as links and descriptions.
• The system logs the submission in the activity history for transparency.

Approval Process:

• Clients have a review period (default: 5 days) to approve or request changes to the submitted work.
• If no action is taken within the review period, the system automatically approves the work.

Request for Changes:

• Clients may request revisions, specifying the necessary changes.
• Contractors must address feedback and resubmit work within the agreed timeframe.

Approved Work:

• Upon approval, funds in the escrow account are unlocked and made available for the contractor to claim and withdraw via their connected wallet.
• The system sends payment confirmation notifications to both parties once the funds are unlocked.

Rejected Work or Revisions:

• The contract status remains active while revisions are in progress.
• Notifications inform both parties of requested changes and submission updates.

Auto-Approval Notifications:

• In-app notifications are sent 3 days, 1 day before, and on the due date to remind users about pending approval.

• Midcontract operates under:
  • Estonian Money Laundering and Terrorist Financing Prevention Act
  • EU Anti-Money Laundering Directives (AMLD)
  • Financial Action Task Force (FATF) Recommendations
  • Applicable international sanctions and regulations

• • ID verification (via Identomat)
  • Liveness check
  • Face-to-document matching

• Midcontract partners with Identomat for secure and compliant KYC processes.Verification Flow:
  • User Initiation:
    
    • Redirect to Identomat's secure verification interface
    • Mobile and desktop support
    • Multi-language verification process
  • Document Verification:
    
    • AI-powered document authenticity checks
    • Support for international ID documents
    • Real-time validation
  • Biometric Verification:
    
    • Liveness detection
    • Facial matching with ID
    • Anti-spoofing measures
  • Verification Results:
    
    • Real-time verification status updates (approved/rejected)
    • For cases requiring manual review, Identomat sends a "Manual Check" status, and Midcontract's legal specialist reviews and makes the final approval or rejection decision.

• Midcontract's legal specialist may request additional information if needed.
• The review process includes checking submitted documents for accuracy and ensuring compliance with regulatory standards.
• The legal specialist verifies that documents meet Estonian regulatory guidelines and EU AMLD requirements.
• Identified discrepancies or missing information will be communicated promptly to the user.
• Manual review decisions are logged for auditing and compliance reporting.
• Users will receive notifications if manual review is initiated, including instructions for further steps.

• Upon successful verification, user profiles are updated with verified information such as full legal name and verification status.
• Verification statuses include: "Unverified," "In Review," "Verified," "Rejected."

• Users must notify Midcontract of changes to their legal name, address, or other relevant information.
• Prompt updates ensure uninterrupted use of the platform.

• Timely response to verification requests.
• Submission of accurate and clear documentation.
• Compliance with requests for additional information.

• Encrypted data transmission and storage.
• Limited retention periods.
• Data minimization principles in line with GDPR.

• Verification records are retained only as long as necessary for compliance.
• Data is deleted within 30 days of expiration unless required for regulatory purposes.

• Ensure compliance with KYC/AML regulations.
• Conduct periodic reviews of verification processes.
• Address user queries related to identity verification.

• Reporting of suspicious activity to relevant regulatory authorities.
• Cooperation with law enforcement if required.

• Users must maintain up-to-date identification records.
• Cooperation during manual review is mandatory.
• Users with expired documents cannot initiate new contracts but may complete active ones.

• Midcontract reserves the right to update this policy to reflect regulatory changes.
• Users will be notified of any significant updates.

• For any questions regarding this policy or verification procedures, users can contact our compliance team:
• ‍Money Laundering Reporting Officer (MLRO):
  • Email: compliance@midcontract.com

9.1 INTRODUCTION

Midcontract OÜ ("Midcontract," "we," "us," or "our"), a company registered in Estonia, is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our blockchain-enabled escrow payment and contract management platform, including our website, applications, and related services (collectively, the "Platform").

9.2 KEY DEFINITIONS

• Personal Data: Any information relating to an identified or identifiable natural person.
• User: Any individual or entity accessing or using the Platform.
• Platform: The Midcontract website, applications, and services.
• Cookies: Small text files placed on your device to collect and store information about your browsing preferences.
• Smart Contract: Blockchain-based automated agreements managing escrow and payments.

9.3 DATA CONTROLLER

Midcontract OÜ [Address] Estonia

Email: privacy@midcontract.com

9.4 INFORMATION WE COLLECT

9.4.1 Information You Provide

• Account Information:
  
  • Email address
  • Password (encrypted)
  • Username
  • Profile information
• Identity Verification Information (processed and stored by Identomat):
  
  • Full name
  • Date of birth
  • Identification document type
  • Document expiration date
  • Verification status and timestamps
  • Address (manually provided)
• Contract-Related Information:
  
  • Contract details and specifications
  • Project descriptions
  • Payment information
  • Communication records
  • Wallet addresses

9.4.2 Information Automatically Collected

• Usage Data:
  
  • IP address
  • Browser type
  • Device information
  • Operating system
  • Access times and dates
  • Pages viewed
  • Links clicked
  • Navigation patterns
• Blockchain Information:
  
  • Public wallet addresses
  • Transaction records
  • Smart contract interactions

9.4.3 Cookies and Similar Technologies

See our Cookie Policy section below for detailed information about our use of cookies and similar technologies.

9.5 HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

9.5.1 Essential Operations

• Providing and maintaining the Platform
• Processing transactions and payments
• Managing user accounts
• Facilitating contract creation and management
• Ensuring compliance with KYC/AML requirements
• Preventing fraud and maintaining security

9.5.2 Communication

• Sending service-related notifications
• Providing customer support
• Sending updates about platform changes
• Responding to your inquiries

9.5.3 Platform Improvement

• Analyzing usage patterns
• Improving user experience
• Developing new features
• Troubleshooting technical issues

9.5.4 Legal Compliance

• Meeting regulatory requirements
• Responding to legal requests
• Enforcing our terms of service
• Protecting our legal rights

9.6 LEGAL BASIS FOR PROCESSING

We process your personal data under the following legal bases:

• Contract Performance: Processing necessary for the performance of our contract with you
• Legal Obligation: Processing required to comply with our legal obligations
• Legitimate Interests: Processing necessary for our legitimate interests
• Consent: Processing based on your specific consent

9.7. DATA SHARING AND DISCLOSURE

9.7.1 Third-Party Service Providers

We share data with trusted service providers:

• Identomat: For KYC verification services
• Alchemy: For wallet services
• Transak: For fiat-to-crypto conversion
• Cookiebot: For cookie consent management
• Cloud service providers: For hosting and storage
• Analytics providers: For platform improvement

9.7.2 Legal Requirements

We may disclose information:

• To comply with legal obligations
• To protect our rights and property
• To prevent fraud or illegal activities
• In response to valid legal requests

9.8 DATA RETENTION

We retain your personal data for as long as necessary to:

• Provide our services
• Comply with legal obligations
• Resolve disputes
• Enforce our agreements

Specific retention periods:

• Account information: While account is active plus 5 years
• Transaction records: 7 years
• Communication records: 3 years
• Technical logs: 12 months

9.9 DATA SECURITY

We implement appropriate technical and organizational measures to protect your data:

• Encryption of data in transit and at rest
• Access controls and authentication
• Regular security assessments
• Employee training
• Incident response procedures

9.10 YOUR RIGHTS

Under applicable data protection laws, you have the following rights:

• Right to access your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

To exercise these rights, contact us at privacy@midcontract.com.

9.11 INTERNATIONAL DATA TRANSFERS

We may transfer your data to countries outside the European Economic Area (EEA). When we do, we ensure appropriate safeguards are in place through:

• Standard contractual clauses
• Adequacy decisions
• Other legally approved mechanisms

9.12 CHILDREN'S PRIVACY

Our Platform is not intended for children under 18. We do not knowingly collect or maintain information from persons under 18 years of age.

9.13 DATA SUBJECT RIGHTS PROCEDURES

9.13.1 Data Subject Access Requests (DSAR)

1. Request Submission:
   
   • Email to privacy@midcontract.com
   • Web form submission
   • Written request to registered address
   • Required identification verification
2. Response Timeline:
   
   • Initial acknowledgment: 3 business days
   • Full response: Within 30 calendar days
   • Extension if needed: Additional 60 days with notification
3. Information Provided:
   
   • Data categories held
   • Processing purposes
   • Recipients of data
   • Retention periods
   • Source of data
   • Automated decision-making details

9.13.2 Specific Data Retention Periods

Data Retention Periods:

• Account Data: Active + 5 years (Legal obligation)
• KYC Documents: 5 years from verification (AML regulations)
• Transaction Records: 7 years (Tax/accounting requirements)
• Communication Logs: 3 years (Contract disputes)
• Login History: 12 months (Security monitoring)
• Support Tickets: 3 years (Service improvement)
• Failed Login Attempts: 90 days (Security monitoring)

‍

9.13.3 Cross-Border Data Transfers

1. Transfer Mechanisms:
   
   • EU Standard Contractual Clauses (SCCs)
   • Adequacy decisions
   • Binding Corporate Rules where applicable
2. Transfer Safeguards:
   
   • Data encryption in transit
   • Access controls
   • Data minimization
   • Regular security assessments

10.1 ABOUT COOKIES

Cookies are small text files stored on your device when you visit our website. We use Cookiebot to manage cookie consent and provide transparency about our cookie usage.

10.2 TYPES OF COOKIES WE USE

10.2.1 Necessary Cookies

• Essential for basic platform functionality
• Cannot be rejected
• Typically expire when you close your browser

10.2.2 Preference Cookies

• Remember your settings and preferences
• Improve your browsing experience
• Can be rejected through cookie settings

10.2.3 Statistics Cookies

• Help us understand how visitors use our Platform
• Collect anonymous analytics data
• Can be rejected through cookie settings

10.2.4 Marketing Cookies

• Track your browsing habits
• Enable targeted advertising
• Can be rejected through cookie settings

10.3 COOKIE MANAGEMENT

You can manage your cookie preferences through:

• Our cookie consent banner (powered by Cookiebot)
• Your browser settings
• Cookiebot's consent management platform

10.4 THIRD-PARTY COOKIES

Third-party services we use may set their own cookies:

• Analytics services
• Payment processors
• Social media plugins
• Marketing tools

10.5 UPDATES TO THIS POLICY

We may update this Privacy Policy and Cookie Policy at any time. We will notify you of any material changes by:

• Posting the updated policy on our Platform
• Sending an email notification
• Displaying a prominent notice on our Platform

10.6 CONTACT US

For questions about this Privacy Policy or Cookie Policy, contact us at:

Email: privacy@midcontract.com

Data Protection Officer: dpo@midcontract.com

‍Effective Date: February 8, 2025

12.1 Binding Arbitration Agreement

By using the Platform, you agree that any dispute, claim, or controversy arising out of or relating to these Terms or the breach, termination, enforcement, interpretation, or validity thereof, shall be resolved by binding arbitration.

12.1.1 Arbitration Rules and Forum

• Arbitration shall be administered by the Estonian Chamber of Commerce and Industry
• The seat of arbitration shall be Tallinn, Estonia
• The language of arbitration shall be English
• One arbitrator shall be appointed unless the claim exceeds €100,000
• For claims exceeding €100,000, three arbitrators shall be appointed

12.1.2 Arbitration Process

1. Initiation:
   
   • Written notice of arbitration to the other party
   • Description of claim and requested relief
   • Payment of required filing fees
2. Arbitrator Selection:
   
   • Parties have 15 days to jointly select arbitrator(s)
   • If no agreement, the Estonian Chamber of Commerce and Industry will appoint
3. Proceedings:
   
   • Virtual hearings unless in-person hearing requested
   • Document submission electronically
   • 90-day resolution target from arbitrator appointment

12.1.3 Exceptions

• Either party may seek emergency injunctive relief from a court
• Small claims under €5,000 may be resolved through Estonian small claims court
• Intellectual property disputes may be brought in courts of competent jurisdiction

13.1 Platform Availability

13.1.1 Uptime Commitment

• Target uptime of 99.9% measured monthly
• Excludes scheduled maintenance
• Force majeure events excluded
• Blockchain network downtime excluded

13.1.2 Scheduled Maintenance

• Regular maintenance: Sundays 00:00-04:00 UTC
• Notice provided:
  
  • 7 days for major upgrades
  • 48 hours for regular maintenance
  • Immediate notice for emergency maintenance

13.2 Service Level Agreements

13.2.1 Response Times

• Critical issues: 1 hour response
• High priority: 4 hours response
• Normal priority: 24 hours response
• Low priority: 48 hours response

13.2.2 Resolution Times

• Critical issues: 4 hours target
• High priority: 24 hours target
• Normal priority: 72 hours target
• Low priority: 5 business days target

14.1 Blockchain Network Liability

14.1.1 Network Disclaimers

The Platform expressly disclaims liability for:

• Polygon network congestion or failures
• Gas fee fluctuations
• Transaction delays or failures
• Smart contract execution delays
• Blockchain fork events

14.1.2 Smart Contract Limitations

• No guarantee of smart contract security
• Users acknowledge inherent blockchain risks
• Platform not liable for smart contract exploits
• Users responsible for wallet security

14.2 Third-Party Service Liability

Midcontract is not liable for disruptions, delays, or security incidents caused by third-party providers, such as Polygon, Transak, Identomat, Alchemy and The Graph.

14.2.1 Payment Services

• Transak service interruptions
• Fiat-crypto conversion rates
• Payment processing delays
• Third-party wallet service issues

14.2.2 Identity Verification

• Identomat service disruptions
• Verification delays
• Document processing errors
• Data transmission issues

14.3 User Error Liability

14.3.1 Platform Not Liable For:

• Incorrect wallet addresses
• Lost private keys
• Unauthorized wallet access
• Phishing or social engineering losses
• User device security compromises

14.3.2 User Responsibilities:

• Maintaining secure passwords
• Protecting private keys
• Verifying transaction details
• Maintaining device security
• Following security best practices

15.1 Platform Assignment Rights

• Midcontract may assign rights to:
  
  • Subsidiary or affiliate companies
  • Acquiring entities
  • Successor organizations
• Users will be notified of material assignments

15.2 User Assignment Restrictions

• Users may not assign their rights without written consent
• Platform accounts are non-transferable
• Contract rights non-assignable without approval
• Exceptions require Platform written authorization

15.3 Contract Assignment

• Freelancers/Agencies cannot assign contracts
• Clients may assign with Platform approval
• Assignment process requires:
  
  • Written request
  • Assignee KYC/AML verification
  • Platform approval
  • Smart contract update

16.1 Prohibited User Activities

Users are strictly prohibited from using the Midcontract platform for any of the following activities:

1. Adult Content and Services:
   
   • Pornography, prostitution, escorting, or other adult-related services or obscene content.
2. Illegal Substances and Products:
   
   • Sales or distribution of illegal drugs, controlled substances, drug paraphernalia, or substances designed to mimic illegal drugs.
   • Marijuana dispensaries or online pharmacies without legal compliance.
3. Gambling and Lotteries:
   
   • Online gambling, lotteries, betting, sweepstakes, or offering prizes as an inducement to purchase goods or services.
4. Weapons and Violence:
   
   • Sale, promotion, or distribution of weapons, munitions, explosives, or services that promote violence or harm.
   • Activities associated with terroristic organizations or illegal operations.
5. Deceptive and Predatory Services:
   
   • Multi-level marketing (MLM), pyramid schemes, deceptive or predatory marketing services.
   • Extended warranties not backed by legitimate providers.
6. Fraudulent Financial Services:
   
   • Check cashing, money transmission, currency exchanges, or sale of financial instruments.
   • Sale of video game or virtual currency that can be monetized, re-sold, or converted into physical or digital goods outside the platform.
7. Copyright and IP Infringement:
   
   • Products or services that infringe on third-party copyrights, trademarks, trade secrets, or intellectual property rights.
8. Age-Restricted Services:
   
   • Sale or promotion of age-restricted goods or services, including tobacco, alcohol, or e-cigarettes without legal compliance.
9. Social Media Manipulation:
   • Sale or promotion of social media activity, such as buying followers, likes, shares, or views.‍
10. Unethical Technology Use:‍
    • Sale or installation of spyware, malware, viruses, or any unauthorized software or program designed to compromise user systems.‍
11. Hate Speech and Discriminatory Activities:‍
    • Services or content that promote hate, violence, bigotry, or discrimination based on race, ethnicity, religion, sexual orientation, gender, or other protected characteristics.‍
12. Esoteric and Undefined Services:‍
    • Services such as astrology, psychic readings, or other undefined, vague, or non-verifiable services.‍
13. Activities Encouraging Criminal Conduct:‍
    • Any activity that encourages behavior that could be considered a criminal offense, cause civil liability, or violate applicable laws.

16.2 Prohibited Uses of the Platform

Users may not access or use the Midcontract platform in any of the following ways:

1. Unauthorized System Access:
   
   • Attempting to gain unauthorized access to other users’ accounts, data, or restricted areas of the platform.
   • Using another user's login credentials without permission.
2. System Interference:
   
   • Using any device, software, or routine that may disrupt, damage, or overburden the platform or its services.
   • Attempting to bypass security controls, introduce malicious code (e.g., viruses, trojans, worms), or exploit platform vulnerabilities.
3. Automated Data Collection:
   
   • Using bots, spiders, or crawlers to scrape or mine data from the platform.
   • Engaging in unauthorized monitoring, data extraction, or collection of information from other users or the platform.
4. Circumvention of Controls:
   
   • Removing, altering, or bypassing security measures, including content protection or access restrictions.
5. Illegal Activities:
   
   • Using the platform for any illegal, unethical, harassing, or disruptive purposes.
   • Violating any applicable law or regulation related to international sanctions, AML/KYC compliance, or financial services.
6. Impersonation and False Representation:
   
   • Falsifying personal information, impersonating another person or entity, or misrepresenting affiliation with a company.
7. Improper Use of Escrow Services:
   
   • Submitting false claims for refunds or creating fake contracts to manipulate escrow funds or payouts.

16.3 Penalties for Prohibited Activities:

The platform reserves the right to take appropriate measures against users involved in prohibited activities, including but not limited to account suspension, fund freezes, and reporting to legal authorities.Violations of these prohibited activities and uses may result in:

• Immediate suspension or termination of the user’s account.
• Forfeiture of escrowed funds if fraud is confirmed.
• Reporting to relevant regulatory authorities for further action.
• Legal action, including but not limited to claims for damages and penalties.

17.1 Sanctions Screening and Compliance Program

Midcontract maintains a comprehensive sanctions compliance program in accordance with applicable laws and regulations, including:

• European Union sanctions regulations
• Estonian financial services requirements
• FATF recommendations
• US OFAC guidelines where applicable

17.2 Restricted Jurisdictions

17.2.1 Geographic Restrictions

Access to and use of the Platform is strictly prohibited for persons and entities located in, organized under the laws of, or residing in the following jurisdictions:

• Belarus
• Central African Republic
• Democratic Republic of the Congo
• Iran
• Libya
• Myanmar (Burma)
• North Korea
• Russia (including Crimea, Luhansk People's Republic (LPR), Donetsk People's Republic (DPR))
• Somalia
• South Sudan
• Sudan
• Syria
• Venezuela
• Yemen
• Any other jurisdiction subject to comprehensive sanctions

17.2.2 Access Controls

The Platform implements the following measures to enforce geographic restrictions:

• IP address blocking
• Geolocation verification
• VPN and proxy detection
• Device fingerprinting
• Regular access pattern monitoring

17.2.3 Ongoing Monitoring

• Continuous screening against major sanctions lists
• Regular review of user activity for sanctions compliance
• Automated alerts for suspicious patterns
• Periodic review of compliance measures

17.3 Violation Consequences

17.3.1 Account Actions

Violations of sanctions compliance requirements may result in:

• Immediate account suspension
• Asset freezing
• Contract termination
• Reporting to relevant authorities
• Permanent platform ban

17.3.2 Funds Treatment

In case of sanctions violations:

• Funds may be frozen indefinitely
• Regulatory reporting will be completed as required
• Legal authorities may be granted access to relevant information
• Release of funds subject to regulatory approval

18.1 Force Majeure Events

Neither party shall be liable for any failure or delay in performance under these Terms resulting from:

18.1.1 Natural Events

• Natural disasters
• Earthquakes
• Floods
• Fires
• Other natural catastrophes

18.1.2 Human Events

• Wars
• Terrorist actions
• Civil unrest
• Labor disputes
• Government actions
• Regulatory changes

18.1.3 Technical Events

• Blockchain network failures
• Smart contract vulnerabilities
• Critical infrastructure outages
• Cyber attacks
• Third-party service provider failures
• Internet backbone disruptions
• Power grid failures

18.1.4 Market Events

• Cryptocurrency market disruptions
• Banking system outages
• Payment network failures
• Exchange rate volatility

18.2 Notification Requirements

The affected party must:

1. Notify the other party within 24 hours of the force majeure event
2. Provide regular updates on the situation
3. Take reasonable steps to minimize impact
4. Resume performance as soon as practicable

18.3 Extended Duration

If a force majeure event continues for more than 30 consecutive days:

1. Either party may terminate affected contracts
2. Platform may suspend services
3. Alternative arrangements may be proposed
4. Funds in escrow will be handled according to emergency protocols

19.1 Cryptocurrency and Blockchain Risks

19.1.1 Market Risks

Price Volatility

• Cryptocurrency values can experience significant and rapid price fluctuations
• Changes may occur within minutes or seconds
• No guarantee of stable value even for stablecoins
• Market conditions may affect ability to execute transactions
• Potential for complete loss of deposited value

Liquidity Risks

• Market conditions may prevent immediate execution of transactions
• Delays in converting between cryptocurrencies and fiat
• Possible limitations on withdrawal amounts or frequency
• Risk of insufficient market depth for large transactions
• Potential impact of market makers or large traders

Exchange Rate Risks

• Fluctuations between cryptocurrency and fiat currencies
• Cross-rate risks between different cryptocurrencies
• Impact of global market conditions
• Potential losses during conversion processes
• Settlement timing risks

Market Manipulation

• Susceptibility to pump and dump schemes
• Impact of whale accounts and large holders
• Risk of artificial market manipulation
• Effect of false or misleading information
• Impact of social media and market sentiment

19.1.2 Technical RisksBlockchain Network Risks

• Network congestion and delays
• Transaction confirmation delays
• Fork events and chain splits
• Network upgrade impacts
• Consensus mechanism failures
• Mining or validation issues
• Network attack vulnerabilities

Smart Contract Risks

• Programming errors or bugs
• Security vulnerabilities
• Upgrade and maintenance impacts
• Integration failures
• Gas price fluctuations
• Execution failures
• Unintended contract behaviors

Wallet Security

• Private key loss risks
• Phishing attacks
• Social engineering threats
• Hardware wallet malfunctions
• Software wallet vulnerabilities
• Backup failure risks
• Recovery phrase security

Transaction Risks

• Irreversible transactions
• Incorrect address inputs
• Failed transaction handling
• Gas fee complications
• Stuck or pending transactions
• Double-spending attempts
• Replay attack risks

19.1.3 Operational Risks

‍Platform Risks

• System downtime
• Maintenance interruptions
• Database failures
• API disruptions
• Integration issues
• Performance degradation
• Backup and recovery risks

Third-Party Service Provider Risks

• Payment processor outages
• KYC provider issues
• Wallet service disruptions
• Infrastructure provider failures
• Cloud service interruptions
• API service problems
• Data provider inaccuracies

Security Risks

• Cybersecurity threats
• Data breach risks
• DDoS attacks
• Account compromise
• Infrastructure vulnerabilities
• Internal security threats
• System access risks

19.2 Regulatory and Legal Risks

19.2.1 Regulatory Compliance Risks

‍Jurisdictional Risks

• Varying regulatory requirements across jurisdictions
• Changes in regulatory frameworks
• New licensing requirements
• Regulatory enforcement actions
• Cross-border compliance challenges
• Regulatory conflicts between jurisdictions
• Impact of international sanctions

Operational Compliance

• KYC/AML requirement changes
• Reporting obligation updates
• Record-keeping requirement changes
• Audit requirement modifications
• Privacy law compliance
• Data protection requirements
• Operating license maintenance

Financial Regulations

• Banking relationship risks
• Payment processing restrictions
• Currency control regulations
• Securities law implications
• Tax regulation changes
• Financial reporting requirements
• Capital control impacts

19.2.2 Legal and Contract Risks

‍Contract Enforcement

• Cross-jurisdictional enforcement challenges
• Smart contract legal status
• Digital signature validity
• Evidence admissibility
• Dispute resolution limitations
• Jurisdiction determination
• Applicable law conflicts

Intellectual Property

• Copyright infringement risks
• Patent violation claims
• Trademark disputes
• Trade secret protection
• License compliance
• Open source obligations
• IP ownership conflicts

Data Protection

• Privacy law compliance
• Data transfer restrictions
• Data localization requirements
• User consent management
• Data breach responsibilities
• Right to be forgotten
• Data portability obligations

19.3 Business and Operational Risks

19.3.1 Business Model Risks

• Revenue model sustainability
• Market competition impacts
• Pricing model viability
• Customer adoption challenges
• Partnership risks
• Technology obsolescence
• Market demand changes

19.3.2 Service Delivery Risks

• Performance guarantee challenges
• Service level maintenance
• Quality assurance issues
• Customer support capacity
• Technical support limitations
• Feature deployment risks
• Platform scaling challenges

19.3.3 Reputation Risks

• Public perception impacts
• Media coverage effects
• User feedback influence
• Platform reliability concerns
• Security incident impacts
• Compliance violation effects
• Brand value protection

19.4 Risk Acknowledgment

By using the Platform, users acknowledge and accept:

1. Understanding of all disclosed risks
2. Responsibility for due diligence
3. Independent assessment requirement
4. Risk of total loss possibility
5. Technical complexity understanding
6. Regulatory uncertainty awareness
7. Market volatility acceptance

19.5 Risk Mitigation

19.5.1 Platform Security Measures

• Multi-factor authentication
• Encryption protocols
• Access controls
• Monitoring systems
• Backup procedures
• Incident response plans
• Security audits

19.5.2 User Responsibilities

• Security best practices adherence
• Private key protection
• Regular security updates
• Suspicious activity reporting
• Account monitoring
• Password management
• Device security maintenance

19.5.3 Platform Commitments

• Regular security assessments
• Compliance monitoring
• Risk assessment updates
• Security feature improvements
• User education
• Transparent communication
• Incident response readiness

20.1 Acceptance of Terms

By accessing or using the Midcontract Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms of Service and all incorporated policies and agreements, including:

• Privacy Policy
• KYC/AML Policy
• Payment Terms
• Escrow Agreement
• Intellectual Property Framework
• Arbitration and Dispute Resolution Terms
• Service Availability And Maintenance
• Liability Limitations
• Assignment of Rights

If you do not agree with any part of these terms, you must not use the Platform.

20.2 Last Updated

These Terms of Service were last updated on January 6, 2025. The current version supersedes all previous versions.

20.3 Contact Information

‍Midcontract OÜ

• Registered Address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152
• Registration Number: 17137097

General Inquiries:

• Email: support@midcontract.com
• Website: www.midcontract.com

Specific Departments:

• Legal: legal@midcontract.com
• Privacy: privacy@midcontract.com
• Compliance: compliance@midcontract.com
• Data Protection Officer: dpo@midcontract.com
• For urgent assistance during business hours (Monday-Friday, 9:00-17:00 EET), you can reach our support team through the platform's chat feature.