Effective Date: April 2026
Website: octapex.com
Registered Address: 1055 West Georgia Street, Suite 2100, Vancouver BC V6E3P3, Canada
Registration: BC1538819
1. INTRODUCTION
Geloro Pay Ltd (the “Company”, “we”, “us”, or “our”) is a Money Services Business registered in Canada and operating in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), FINTRAC requirements, and all other applicable Canadian regulatory frameworks governing money services and virtual asset activity.
The Company provides a non-custodial digital asset exchange service, facilitating the conversion of fiat currency into crypto-assets and crypto-assets into fiat currency. The Company does not provide brokerage services, investment advice, portfolio management, custody services, or trading platform functionality.
All Services are strictly execution-only and non-advisory in nature.
By accessing or using the Company’s website, platform, or related services (collectively, the “Services”), you acknowledge that you have read, understood, and agreed to be bound by these Terms and Conditions. If you do not agree, you must immediately discontinue use of the Services.
The Company may amend or update these Terms at its sole discretion. Continued use of the Services following any updates constitutes acceptance of the revised Terms.
2. ELIGIBILITY AND ACCESS
The Services are intended only for individuals or legal entities that have the legal capacity to enter into binding agreements under applicable law.
You must be at least 18 years of age to use the Services. By using the Services, you confirm that all information provided is true, accurate, and complete.
The Company reserves the right to restrict, suspend, or deny access to the Services at its sole discretion, including where required by applicable law, regulatory obligations, sanctions restrictions, or internal compliance requirements.
The Services are not intended for use in jurisdictions where such activity would be unlawful or require additional licensing or authorisation beyond that held by the Company.
3. DESCRIPTION OF SERVICES
The Company provides a fiat-to-crypto and crypto-to-fiat exchange service allowing Clients to request digital asset conversion transactions based on quoted pricing.
The Company does not operate an exchange, trading platform, order book, or brokerage service. Instead, the Company acts as the principal counterparty to each transaction, executing trades based on Client instructions and confirmed quotes.
All Services are provided on an execution-only basis and do not constitute investment advice or financial recommendations.
The Company does not provide custody of digital assets. Clients must use external wallets that they control independently. The Company does not store, control, or access private keys at any time.
Fiat payments are processed through regulated banking or payment partners. Crypto transactions are executed directly on relevant blockchain networks.
The Company may refuse, delay, or cancel any transaction where required for compliance, risk management, fraud prevention, or regulatory obligations.
4. NON-CUSTODIAL MODEL
The Company operates on a strictly non-custodial basis.
This means the Company does not hold, control, store, or manage Client crypto-assets or private keys. Clients retain full responsibility for their digital asset wallets at all times.
All blockchain transactions occur directly between Client-controlled wallets and external networks.
This structure is designed to reduce custody-related risk and ensure Clients maintain full control over their assets.
5. FEES AND PRICING
All applicable fees are disclosed to the Client prior to transaction confirmation.
Fees may vary depending on transaction size, market conditions, liquidity availability, payment method, jurisdiction, and Client risk profile.
The final quoted price provided to the Client includes all applicable spreads or service fees. The Company does not charge hidden fees.
Clients acknowledge that pricing is derived from aggregated market liquidity sources and internal risk models and may change rapidly due to market conditions.
6. RISKS
Clients acknowledge and accept that crypto-asset transactions involve significant risks, including but not limited to market volatility, liquidity constraints, technological failures, cyber risks, and regulatory changes.
Crypto-assets may experience rapid price fluctuations and may result in partial or total loss of value.
Blockchain networks may be subject to congestion, delays, outages, or protocol-level disruptions.
The Company does not guarantee execution timing, asset performance, liquidity availability, or uninterrupted service access.
Clients are solely responsible for all trading decisions.
7. EXECUTION AND SETTLEMENT
All transactions are executed only after Client confirmation of a quoted price.
Once confirmed, transactions may become irreversible due to blockchain settlement mechanics.
Execution depends on third-party liquidity providers, regulated financial institutions, and blockchain network conditions.
Settlement times may vary depending on external factors beyond the Company’s control.
The Company does not guarantee execution speed or settlement timing.
8. AML / CTF COMPLIANCE
The Company maintains a comprehensive Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) compliance program in accordance with PCMLTFA, FINTRAC regulations, and applicable international standards.
All Clients are subject to identity verification, sanctions screening, risk assessment, and ongoing transaction monitoring.
The Company may request additional documentation at any stage of the Client relationship.
The Company reserves the right to refuse, delay, suspend, or report transactions where required by law or internal compliance obligations.
9. ACCOUNT SECURITY
Clients are responsible for maintaining the confidentiality and security of their account credentials and devices.
The Company implements reasonable technical and organisational security measures; however, it does not guarantee protection against all unauthorised access, cyberattacks, or system vulnerabilities.
Clients must immediately notify the Company of any suspected unauthorised access or security incident.
10. CLIENT RESPONSIBILITIES
Clients represent and warrant that all information provided to the Company is accurate, complete, and not misleading.
Clients agree not to use the Services for any unlawful purpose, including fraud, money laundering, terrorist financing, or sanctions evasion.
Clients are solely responsible for ensuring that all wallet addresses provided are correct. The Company is not responsible for losses arising from incorrect instructions or errors provided by the Client.
11. PROHIBITED ACTIVITIES
Clients must not use the Services for any unlawful, fraudulent, or abusive activity.
The Company reserves the right to investigate suspected violations and take appropriate action, including account suspension, termination, transaction blocking, and reporting to relevant authorities.
12. INTELLECTUAL PROPERTY
All content, branding, systems, software, and materials provided through the Services are owned or licensed by the Company and protected under applicable intellectual property laws.
Clients are granted a limited, non-transferable, revocable right to access and use the Services for lawful purposes only.
13. PRIVACY
The Company processes personal data in accordance with applicable Canadian privacy legislation and international data protection standards where relevant.
Personal data is used for onboarding, identity verification, compliance, transaction execution, fraud prevention, and service improvement.
The Company does not sell or commercially exploit personal data.
14. SERVICE AVAILABILITY
The Company does not guarantee uninterrupted access to the Services.
Service interruptions may occur due to maintenance, technical issues, regulatory requirements, or third-party service disruptions.
The Company shall not be liable for any losses resulting from service downtime or delays.
15. LIMITATION OF LIABILITY
To the maximum extent permitted by law, the Company shall not be liable for any indirect, incidental, consequential, or punitive damages, including loss of profits, revenue, data, or business opportunities.
The Company is not responsible for losses arising from blockchain network failures, third-party service providers, market volatility, or Client errors.
16. TERMINATION
The Company may suspend or terminate access to the Services at any time where required for compliance, regulatory, risk management, or security reasons.
Clients may discontinue use of the Services at any time, subject to completion of outstanding obligations.
17. GOVERNING LAW
These Terms are governed by the laws of the Province of British Columbia and the applicable federal laws of Canada.
Any disputes shall fall under the exclusive jurisdiction of the courts of British Columbia, unless otherwise required by law.
18. MODIFICATIONS
The Company may update or modify these Terms at any time. Continued use of the Services after such updates constitutes acceptance of the revised Terms.
19. CONTACT INFORMATION
For support or compliance inquiries:
- Support: support@octapex.com
- Compliance: compliance@octapex.com