STRK — Acceptable Use Policy

Last Updated: February 2026

1. Introduction

This Acceptable Use Policy ("Policy") sets out the rules and restrictions that apply when you use the STRK platform, including the STRK website (strk.com), the STRK application available on iOS, Android, and via web browser at app.strk.com (together, the "App"), and all related services we provide to you (together, the "Services").

This Policy forms part of the Terms and Conditions (available at strk.com/legal/terms-and-conditions) and should be read together with those Terms, our Privacy Policy (available at strk.com/legal/privacy-policy), and all other documents that form part of your agreement with us.

By using the Services, you agree to comply with this Policy. Failure to do so may result in restriction, suspension, or closure of your account, and may also result in legal action.

2. General Principles

2.1 Responsible use

You agree to use the Services responsibly, honestly, and in compliance with all applicable laws and regulations in your jurisdiction and in any jurisdiction where you use the Services.

2.2 Legal compliance

You must comply with all applicable laws, including but not limited to:

Anti-money laundering (AML) and counter-terrorist financing (CTF) laws
Sanctions and embargoes
Tax and reporting obligations
Data protection and privacy laws
Financial services regulations
Consumer protection laws
Export and import controls

2.3 Regulatory obligations

STRK and our regulated partners are subject to strict regulatory obligations, including AML/CTF requirements, sanctions screening, and know-your-customer (KYC) obligations. Your use of the Services must not cause us or our regulated partners to breach these obligations.

3. Prohibited Activities

3.1 Illegal activities

You must not use your STRK account or the Services to:

Engage in any illegal, fraudulent, or deceptive activity
Violate any applicable law, regulation, or court order
Infringe the intellectual property rights of others
Violate the privacy or data protection rights of others
Engage in any activity that would constitute a criminal offence

3.2 Money laundering and terrorist financing

You must not use the Services to:

Launder money or facilitate money laundering
Finance terrorism or terrorist organisations
Evade or circumvent economic sanctions or embargoes
Conceal or disguise the origin, source, location, disposition, movement, or ownership of funds
Structure transactions to avoid reporting requirements

3.3 Sanctions and embargoes

You must not use the Services if you are:

Located in, or a resident of, a country or territory subject to comprehensive sanctions (including but not limited to Iran, North Korea, Syria, Crimea, Donetsk, Luhansk, or other sanctioned jurisdictions)
Listed on any sanctions list maintained by the United Nations, European Union, United Kingdom, United States, or other relevant authorities
Acting on behalf of, or for the benefit of, any sanctioned person or entity

3.4 Prohibited goods and services

You must not use the Services to make or receive payments in connection with:

Illegal drugs, controlled substances, or drug paraphernalia
Weapons, firearms, ammunition, or explosives
Human trafficking, slavery, or forced labour
Prostitution or illegal sexual services
Counterfeit goods or intellectual property infringement
Stolen goods or goods obtained through fraud
Pyramid schemes, Ponzi schemes, or other fraudulent investment schemes
Unlicensed gambling or betting (where prohibited by law)
Adult content involving minors or non-consensual content
Any goods or services that are illegal in your jurisdiction or the jurisdiction where the transaction occurs

3.5 Market abuse and manipulation

You must not use the Services to:

Engage in market manipulation, wash trading, or other forms of market abuse involving cryptoassets or fiat currencies
Create artificial price movements or trading volumes
Manipulate exchange rates or exploit rate discrepancies for systematic profit
Engage in front-running, insider trading, or other forms of market abuse
Coordinate with others to manipulate markets or prices

3.6 Fraud and deception

You must not:

Provide false, misleading, or incomplete information to us or our regulated partners
Use stolen, compromised, or unauthorised payment methods
Impersonate another person or entity
Create fake accounts or use multiple accounts to circumvent restrictions
Engage in chargeback fraud or payment fraud
Use the Services to defraud others

3.7 Security and system integrity

You must not:

Circumvent any security measures, transaction limits, or account restrictions
Attempt to gain unauthorised access to our systems, networks, or other users' accounts
Use automated systems (bots, scripts, scrapers) to access or interact with the Services without our prior written consent
Interfere with, disrupt, or damage our systems, networks, or infrastructure
Introduce viruses, malware, or other harmful code
Reverse engineer, decompile, or disassemble any part of the Services
Test or probe the security of our systems without authorisation

3.8 Account misuse

You must not:

Open or operate an account on behalf of another person without authorisation
Share your account access or security credentials with others
Allow others to use your account
Use someone else's account or identity
Create multiple accounts to circumvent restrictions or limits

3.9 Harassment and abuse

You must not:

Harass, threaten, abuse, or harm our staff, other users, or any third party
Send spam, unsolicited communications, or unwanted messages
Use the Services to stalk, intimidate, or harm others
Post or transmit content that is defamatory, libellous, or violates the rights of others

3.10 Speculative trading and arbitrage

You must not use the Services primarily for:

Systematic foreign exchange arbitrage or speculative trading
Exploiting exchange rate discrepancies for profit
High-frequency trading or algorithmic trading without our consent
Any activity that treats STRK as a trading platform rather than a payment and account service

3.11 Regulatory compliance violations

You must not engage in any activity that would cause us or our regulated partners to:

Breach regulatory obligations or requirements
Violate licensing conditions
Fail to comply with AML/CTF requirements
Breach sanctions or embargoes
Fail to meet KYC or customer due diligence obligations

4. Industry-Specific Restrictions

4.1 High-risk industries

Certain industries are subject to enhanced due diligence and may be restricted or prohibited. These include but are not limited to:

Cryptocurrency exchanges and trading platforms (subject to enhanced KYC)
Money service businesses and remittance services (subject to licensing requirements)
Adult entertainment (subject to age verification and content restrictions)
Gambling and betting (subject to licensing and jurisdiction requirements)
Precious metals and gemstones (subject to AML requirements)
Charitable organisations and non-profits (subject to enhanced due diligence)

4.2 KYC requirements

In accordance with Equals Money's KYC requirements and industry-specific guidance:

You must provide accurate and complete information during onboarding
You must promptly provide any additional information or documentation we request
You must keep your information up to date
Enhanced due diligence may be required for certain industries or transaction patterns
We may request additional verification at any time

4.3 Source of funds

You must be able to demonstrate the legitimate source of funds used in your account. We may request documentation to verify:

The origin of funds
The purpose of transactions
Your business activities (if applicable)
Your relationship with counterparties

5. Transaction Monitoring and Reporting

5.1 Our monitoring obligations

We and our regulated partners are required by law to:

Monitor transactions for suspicious activity
Report suspicious transactions to relevant authorities
Screen against sanctions lists and watchlists
Conduct ongoing customer due diligence
Maintain transaction records

5.2 Your cooperation

You must cooperate with our monitoring and reporting obligations by:

Providing accurate information about transactions when requested
Explaining the purpose and nature of transactions
Providing documentation to support transactions
Responding promptly to our requests for information

5.3 Suspicious activity reporting

If we identify suspicious activity, we may:

Temporarily hold or block transactions
Request additional information or documentation
Restrict, suspend, or close your account
Report the activity to relevant authorities (without notifying you if prohibited by law)

6. Consequences of Violation

6.1 Account actions

If you breach this Policy or engage in prohibited activities, we may, at our discretion:

Restrict, suspend, or close your account
Reverse or cancel any transactions (where possible)
Refuse to process future transactions
Limit your access to certain Services
Require additional verification or documentation

6.2 Reporting to authorities

We may report violations to:

Law enforcement agencies
Financial intelligence units
Regulatory authorities
Sanctions enforcement bodies
Other relevant authorities

6.3 Legal action

We reserve the right to take legal action against you for violations of this Policy, including:

Seeking damages
Obtaining injunctive relief
Pursuing criminal prosecution where applicable

6.4 No refunds

If your account is restricted, suspended, or closed due to a violation of this Policy, you may not be entitled to a refund of fees paid, and any funds may be held pending investigation or legal proceedings.

7. Your Responsibilities

7.1 Due diligence

Before using the Services, you should:

Understand the laws and regulations that apply to you
Ensure your use of the Services is legal in your jurisdiction
Verify that you are not subject to any sanctions or restrictions
Understand the risks associated with the Services

7.2 Ongoing compliance

You must:

Keep your account information accurate and up to date
Promptly notify us of any changes to your circumstances
Respond promptly to our requests for information
Comply with all applicable laws and regulations
Not use the Services for prohibited purposes

7.3 Third-party transactions

If you are receiving payments from or making payments to third parties, you are responsible for:

Verifying the identity and legitimacy of counterparties
Ensuring transactions comply with applicable laws
Maintaining records of transactions
Reporting suspicious activity

8. Changes to This Policy

We may update this Policy from time to time. We will notify you of material changes by email and/or through the App at least 30 days before the changes take effect. The "Last Updated" date at the top of this Policy indicates when the most recent changes were made.

Your continued use of the Services after changes take effect constitutes acceptance of the updated Policy.

9. Contact Us

If you have questions about this Policy or need to report a potential violation, please contact us:

Email: compliance@strk.com
In-app chat: Through the support section of the STRK App
Post: Compliance, Empyrean Cards - IT Solutions Unipessoal Lda, Rua do Miradouro, nº 19, Belém, Lisboa, 1400-250, Portugal

10. Regulatory Disclosures

Empyrean Cards - IT Solutions Unipessoal Lda is in partnership with Equals Group PLC (Registered in England & Wales No. 08922461). Equals Money PLC is part of Equals Group PLC. Registered Office: 3rd Floor, Vintners' Place, 68 Upper Thames St, London, EC4V 3BJ. Equals Money PLC is authorised by the Financial Conduct Authority to provide payment services (FCA No. 488396).

Your funds are safeguarded in accordance with the FCA's safeguarding requirements for e-money and payment services. This means your money is held in segregated bank accounts and protected in case of insolvency. Please note: your funds are not covered by the Financial Services Compensation Scheme (FSCS).

STRK is operated by Empyrean Cards - IT Solutions Unipessoal Lda. Rua do Miradouro, nº 19, Belém, Lisboa, 1400-250, Portugal. NIPC: 509 731 813.

STRK is a trademark. Empyrean Cards - IT Solutions Unipessoal Lda has the right to use the STRK trademark.