PLEASE READ THESE TERMS CAREFULLY. By accessing or using the IFC services, you agree to be bound by the following Terms and Conditions. If you do not agree, do not use our services.

These Terms constitute a legal agreement between you and International Firearms Currency, LLC, a New Mexico, USA limited liability company, and its affiliated Swiss entities IF Currency Blockchain AG and IF Currency Blockchain Association (collectively referred to as “IFC,” “Company,” “we,” or “us”). These Terms apply to all users of IFC’s blockchain-based firearms data tracking services, whether in the U.S. or internationally (including the EU and Switzerland).

Below is a summary of key clauses for your convenience. This summary is not a substitute for the full Terms – please read the entire document. In the event of any conflict, the detailed clauses below will govern.

1. Acceptance of Terms and Service Overview

1.1 Agreement to Terms

These Terms and Conditions (“Terms”) govern your access to and use of IFC’s blockchain-based firearms data tracking platform, including any websites, applications, APIs, and services provided by IFC (collectively, the “Service”). By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by these Terms, as well as our Privacy Policy (referenced in Section 6 below). If you do not agree to any part of these Terms, do not use the Service.

These Terms apply to all users, domestic and international, including firearms manufacturers, distributors, dealers, and individual purchasers (when such individual access is made available). You represent and warrant that you have the legal capacity and authority to enter into this agreement. If you are using the Service on behalf of an organization, you are agreeing to these Terms for that organization and promising that you have the authority to bind that organization to these Terms.

1.2 Affiliates and Scope

IFC’s affiliated entities, IF Currency Blockchain AG and IF Currency Blockchain Association in Switzerland, may participate in providing the Service or related services (especially for users in the EU/Switzerland). The use of “IFC,” “Company,” “we,” or “us” in these Terms includes those affiliates. All IFC entities are third-party beneficiaries of these Terms with the right to enforce them. The Service may be provided by IFC’s U.S. entity or its Swiss affiliates, as appropriate for your region, but in all cases these Terms apply to your use.

These Terms, along with any additional guidelines, policies, or legal terms posted (such as an end-user license agreement for an app, or a data processing agreement for certain clients), constitute the entire agreement between you and us regarding the Service (See Section 14.4).

1.3 Changes to Terms

We may update or modify these Terms from time to time. If we make material changes, we will provide notice such as by posting the updated Terms with a new effective date at the top, and/or by email or in-Service notification. Continued use of the Service after updated Terms become effective constitutes your acceptance of the changes. If you do not agree to the revised Terms, you must stop using the Service before the changes take effect. It’s your responsibility to review the Terms periodically for updates.

2. Eligibility and Legal Compliance

2.1 Age Restriction – 18+ Only

The Service is strictly for users who are 18 years of age or older. By accessing or using the Service, you represent that you are at least eighteen (18) years old. IFC does not knowingly offer services to or collect personal data from individuals under 18. If you are under 18, you are not permitted to use this Service. We reserve the right to request proof of age at any point to verify compliance with this requirement.

2.2 Legal Ability and No Prohibited Persons

You also represent that you are otherwise legally permitted to use the Service and to enter into these Terms. You may not use the Service if: (a) you are barred from doing so under the laws of the United States, your place of residence, or any other applicable jurisdiction; (b) you are located in, under the control of, or a national or resident of any country subject to U.S. embargo, sanctions, or that the U.S. government has designated as a “terrorist supporting” country (e.g. countries currently sanctioned by OFAC); or (c) you are on any U.S. government list of prohibited or restricted parties (such as the Specially Designated Nationals list) or any similar list in the EU or other jurisdictions. By using the Service, you certify that you are not a prohibited party and that you will comply with all export control and trade sanctions laws in your use of the Service.

2.3 Compliance with Firearms Laws and Export Regulations

Because our Service involves tracking data related to firearms, you agree to comply with all applicable firearms laws, regulations, and requirements in your jurisdiction and in the jurisdictions where any firearms data you input, or access may relate. This includes, without limitation, the U.S. Gun Control Act, the U.S. National Firearms Act, the International Traffic in Arms Regulations (ITAR), the Export Administration Regulations (EAR), and any applicable import/export or trade compliance laws. You shall not use the Service to transfer or share any firearms, munitions, or technical data that are controlled under ITAR/EAR to any unauthorized person or destination. If your use of the Service involves “technical data” related to defense articles as defined under ITAR, you represent that you are a U.S. Person or otherwise authorized under U.S. law to access such data.

Important: You are solely responsible for ensuring that your use of the Service (including any data you record or share on the blockchain) does not violate any law or regulation. IFC may suspend or terminate your access immediately if we suspect your use is in violation of any firearms or export laws, and we may report such violations to appropriate authorities.

2.4 Authority to Bind (Organizations and Agents)

If you use the Service on behalf of a company or other legal entity (for example, as an employee of a firearms manufacturer or dealer), you represent and warrant that you have the authority to bind that entity to these Terms. In such case, “you” will refer to both you as an individual and the entity you represent. If you do not have such authority, you must not use the Service on behalf of that entity. Organizations may authorize individual employees or agents to use the Service but will be responsible for ensuring all such users comply with these Terms.

3. Account Registration and Security

3.1 Account Setup

To access certain features of the Service, you may be required to create an IFC user account. You agree to provide truthful, accurate, current, and complete information during registration and at all other times when using the Service, and to promptly update your information if it changes. This may include your name, organization, contact information (email, phone number), and other details. If identity verification is required (for example, to verify you are an authorized firearms dealer or a lawful purchaser), you agree to provide additional information or documentation as requested, such as government-issued identification. We will handle any personal information you provide in accordance with our Privacy practices (see Section 6).

3.2 Account Credentials and Responsibility

When you register, you will create login credentials, such as a username and password (or use an approved single sign-on or cryptographic key). You are responsible for keeping your account credentials confidential and secure. Do not share your password, private keys, or other secure login info with anyone, and do not allow others to access the Service through your account. You agree to notify us immediately at our provided contact (see Section 14.7) if you suspect or become aware of any unauthorized use of your account or any breach of security.

You are fully responsible for all activities that occur under your account (including any actions taken by any person to whom you have given access, whether intentionally or otherwise). IFC will not be liable for any loss or damage arising from unauthorized use of your account, and you may be held liable for losses incurred by IFC or others due to such unauthorized use.

3.3 One Account Per User; Accuracy of Data

You may not maintain more than one account for the same service purpose, unless explicitly permitted by us (for example, separate accounts for separate business units under one enterprise arrangement). You also agree not to misrepresent your identity or affiliations; for instance, do not create an account using someone else’s name or a fake identity. We reserve the right to suspend or terminate accounts that are duplicative, inactive, or based on false information.

4. Use of the Service and Changes to Service

4.1 License to Use Service

Subject to your compliance with these Terms and all applicable laws, IFC grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Service for your internal business purposes or personal use (as applicable) related to lawful firearms tracking and data management. This license is provided solely for the purpose of enabling you to use and enjoy the benefit of the Service as provided by IFC, in the manner permitted by these Terms. You may not use the Service for any other purpose, and no ownership rights are transferred to you. All rights not expressly granted to you are reserved by IFC and its licensors.

4.2 Service Description

The IFC Service uses blockchain technology to record and track data across the international firearms supply chain. It allows authorized users (such as manufacturers, distributors, dealers, and in the future, individual firearm owners) to input, store, and view information about firearms (for example, manufacture details, serial numbers, transfers, and relevant certifications or licenses) on a distributed ledger. Data Immutability: You acknowledge that information recorded on the blockchain ledger may become immutable (unchangeable) once confirmed. While this enhances data integrity and traceability, it also means that corrections or deletions of on-chain data can be complex or impossible to execute. We strive to design the Service such that personal data is either not stored on-chain or is encrypted/hashed to protect privacy, but you accept that blockchain records are permanent. Section 6 (Data Privacy) provides more details on how we handle personal data in the Service.

4.3 Service Availability and Changes

We are constantly improving and evolving our Service. Thus, the form and nature of the Service may change over time. IFC reserves the right to add, remove, suspend, or alter any feature or aspect of the Service at any time, for any reason (including complying with legal requirements, to implement security enhancements, or to improve functionality), with or without prior notice. For example, we may introduce new modules or tools, impose usage limits, change the user interface, or discontinue certain features. We will endeavor to provide advance notice of any material changes or discontinuation of core features when feasible, but this may not always be possible (especially in cases of emergency updates or fixes).

4.4 Downtime and Maintenance

IFC may need to temporarily suspend the Service for maintenance, updates, or emergency reasons (including security incidents). We will try to schedule planned maintenance during low-usage hours and provide notice to users in advance when possible. However, we cannot guarantee that the Service will always be available without interruption. You acknowledge that occasional downtime or unavailability may occur, and IFC shall not be liable for any consequences of Service interruptions or delays.

4.5 Beta Features

If we release any beta or trial features, they are provided for evaluation purposes on an “as-is” basis, without any warranties, and may be subject to additional terms. We reserve the right to modify or discontinue beta features at any time. Your feedback on these features is appreciated but not obligatory.

4.6 Third-Party Resources and Links

The Service may include links or integrations to third-party websites, services, or resources (for example, links to government databases like the U.S. ATF eTrace system, manufacturer websites, or identity verification services). These third-party resources are provided for your convenience. IFC does not endorse and is not responsible for the content, products, or services on third-party sites. Different terms and privacy policies may apply to third-party services. When following third-party links or using third-party content, you do so at your own risk, and you should review the applicable third-party terms and policies. IFC will not be liable for any damage or loss caused by your use of or reliance on any third-party resources.

5. User Conduct and Acceptable Use Policy

To ensure the integrity and lawful use of our Service, all users must adhere to the following acceptable use requirements. Failure to follow this policy can result in suspension or termination of your account (as detailed in Section 9) and potential legal consequences.

5.1 Lawful and Intended Use Only

You agree to use the Service only for its intended purpose of lawful tracking and management of firearms-related data, and in full compliance with these Terms and all applicable laws. Any misuse of the Service is strictly prohibited. Specifically, you agree that you will NOT:

• Violate Laws: Use the Service in any manner that violates any law or regulation, including firearms regulations, export/import controls, data protection laws, or any other applicable law. This includes, but is not limited to, using the Service to facilitate any illegal firearms transfer or transaction, or to store or transmit any information that is illegal for you to possess or share (such as unlicensed export-controlled technical data).

• Circumvent Age or Eligibility Restrictions: Allow any individual under 18 to access the Service through your account or otherwise attempt to bypass the age restriction or other eligibility requirements.

• Provide False or Improper Data: Submit false, misleading, or fraudulent information into the Service. You must not input data that you are not authorized to share. For example, do not upload personal data (such as someone’s Social Security Number, address, or driver’s license number) unless you have that person’s consent or a legal right to do so. Similarly, do not enter firearm data that you know is incorrect or that you are not legally permitted to disclose.

• Infringe Rights of Others: Upload, post, or otherwise transmit any content that infringes or misappropriates any third party’s intellectual property rights or other rights. This includes not posting content you do not have permission to use and not violating privacy or publicity rights of others (e.g., do not use the Service to dox someone or expose personal details without permission).

• Interfere with Security or Integrity: Attempt to probe, scan, or test the vulnerability of the Service or any related system or network. Do not breach or circumvent any security or authentication measures. No hacking, reverse engineering, or unauthorized access to any part of the Service or its underlying software or blockchain is allowed. Additionally, do not introduce any malware, virus, Trojan horse, worm, spyware, or any other malicious or harmful code into the Service.

• Abuse the Blockchain Network: If the Service uses a public or consortium blockchain, do not spam the network, perform denial-of-service attacks, or otherwise interfere with the decentralized network’s normal operation. Respect any usage limits or rate limits we impose.

• Harvest or Improperly Use Data: You will not scrape, harvest, or collect information about other users or any data from the Service through automated means (such as bots, crawlers, or scrapers) without our prior written permission. Also, do not use the Service to store excessive personal data not relevant to firearms tracking (for instance, using it as a general data storage service is not allowed).

• Resell or Misuse the Service: You may not rent, lease, lend, sell, sublicense, or create any derivative works of the Service (or any part of it) without our consent. Also, do not misuse the Service for competitive analysis, building a competing product, or any purpose that is to IFC’s detriment or commercial disadvantage.

• Impersonation and Unauthorized Access: Do not impersonate any person or entity, or falsely state or misrepresent yourself (e.g., falsely claiming to be a law enforcement officer or an IFC representative). Do not allow anyone else to use your credentials or access your account, and do not use another user’s account without authorization.

• Spam and Unauthorized Communications: You will not use the Service to transmit any unsolicited or unauthorized advertising or promotional materials, junk mail, spam, chain letters, or pyramid schemes. Also, you will not use any communication tools provided by the Service to harass or send inappropriate messages to others.

5.2 Monitoring and Enforcement

IFC reserves the right (but does not assume the obligation) to monitor any activity and content on the Service to ensure compliance with these Terms and applicable law. We may investigate any violation of these Terms or complaints and take any action we deem appropriate. Enforcement actions may include, but are not limited to, removing or modifying content, disabling your account, reporting you to law enforcement authorities, and/or taking legal action.

We also may at times request information from you to verify compliance (for example, proof of licenses or permits if you are inputting certain regulated data). If you fail to provide reasonable information or cooperation in an investigation, we may suspend or terminate your access.

5.3 Cooperation with Law Enforcement and Regulators

IFC will cooperate with law enforcement, regulators, and other authorities as required by law in investigations of improper or illegal activities related to the use of the Service. This may include preserving or sharing appropriate user data or blockchain records with such authorities when legally required (consistent with our Privacy Policy and applicable data protection laws). Refer to Section 6 (Data Privacy) for how we handle personal data requests from authorities.

5.4 Your Responsibilities

You are responsible for any consequences arising from your violation of this Section 5. Use the Service responsibly and with respect for others and the law. If you see misuse of the Service by another user, you can report it to us through the contact information in Section 14.7.

6. Data Privacy and Security

We take the privacy and security of personal data very seriously. This Section explains how we protect personal information and your rights regarding your data when using the Service. Use of the Service is also governed by our Privacy Policy, which provides more detailed information on our data practices. By using the Service, you also agree to the terms of the Privacy Policy (which is incorporated herein by reference). In case of any conflict between these Terms and the Privacy Policy regarding data protection, the more protective provision for the user’s personal data will prevail.

6.1 Types of Data Collected

When you use the Service, we may collect various types of Personal Data. “Personal Data” means any information that relates to an identified or identifiable individual. The personal data we process can include:

• Contact Information: e.g., names, business or personal addresses, email addresses, phone numbers of users or points of contact.

• Account Information: Username, password (stored in hashed form), and authentication credentials. For certain users, we might collect identity verification details (like driver’s license number, firearms license IDs, or portions of government ID numbers) to confirm eligibility or compliance.

• Transactional Data: Records of firearms-related transactions or entries you input, which may indirectly include personal information (for example, the name of a purchaser or the serial number of a firearm linked to an owner).

• Technical Data: IP addresses, device information, log-in timestamps, and usage logs (these may be considered personal data when linked to you).

• Sensitive Personal Data: In limited cases, we might handle sensitive data such as Social Security Numbers (SSNs), passport numbers, or other government-issued ID numbers, but only when necessary (for example, to verify identities for legal compliance) and in accordance with law. We do not request or require any financial account passwords, credit card numbers (aside from payment processing via secure third parties), or biometric identifiers for use of the Service, unless specifically part of a feature with your knowledge. We ask that you do not unnecessarily input sensitive personal details into free-form fields on the blockchain or Service.

You agree that any personal data you provide to us is provided in compliance with applicable law. For example, if you input personal information about third parties (such as employees, customers or firearm transferees), you confirm that you have a legal basis (such as their consent or another legitimate basis) to collect and share that data with us for processing via the Service. We will process any personal data you provide only for the purposes of providing and improving the Service and as otherwise permitted by these Terms, our Privacy Policy, and the law.

6.2 How We Use and Protect Your Data

We utilize your personal data strictly for operating, maintaining, and providing the features of the Service, ensuring compliance with legal obligations and for communication purposes. Key uses include account management, user authentication, transaction recording, fraud prevention, and regulatory compliance.

Data Security Measures: We implement rigorous administrative, technical, and physical security measures to protect personal data against unauthorized access, disclosure, or destruction. Specific measures include:

• Encryption: Data transmitted through the Service is encrypted using secure protocols (HTTPS/TLS). For data at rest, especially data stored outside the United States, encryption compliant with FIPS 140-2 standards is mandatory. All ITAR-controlled technical data stored internationally is encrypted consistent with the standards outlined by the U.S. State Department under the International Traffic in Arms Regulations (ITAR).

• Encryption Carve-Out Rule (22 CFR 120.54): IFC adheres to the Encryption Carve-Out Rule, which allows encrypted ITAR-controlled technical data to be stored outside the United States under specific conditions. Data encrypted end-to-end using cryptographic modules compliant with FIPS 140-2 standards is permitted to be stored in Switzerland, as Switzerland is an approved destination under this regulation. This rule provides a practical compliance mechanism enabling secure international data storage without violating ITAR restrictions.

• Access Control Mechanisms: We utilize role-based access control (RBAC) systems to ensure that users only have access to data necessary for their job functions. Multi-factor authentication (MFA) is required for all administrative and sensitive data access.

• Secure Data Storage Methods: Data is stored in secure environments with restricted access. Cloud-based storage providers are selected based on stringent compliance standards (e.g., ISO 27001, SOC 2 Type II) and specifically audited for ITAR compliance.

• Security Audits and Assessments: Regular security audits are conducted, including penetration testing, vulnerability scanning, and compliance audits, to proactively identify and mitigate security risks.

• Evaluation Frequency: Security measures and controls are evaluated quarterly, with full compliance and security assessments conducted annually or whenever significant system changes occur.

Breach Notification Procedures:

• Detection and Investigation: We employ advanced monitoring systems and protocols to promptly detect potential security incidents. Upon detection, a dedicated incident response team immediately initiates an investigation to determine the scope, nature, and potential impact of the incident.

• Notification Timeframes: We commit to notifying affected users without undue delay and no later than 72 hours after confirming a breach involving personal data, even if notification is not mandated by applicable law.

• Notification Content: Notifications will include clear details about the nature of the breach, the types of personal data affected, measures taken by IFC to address the breach, potential risks and consequences of the breach, and specific actions users can take to protect themselves.

Recommended User Actions: Upon receiving a breach notification, users are advised to promptly change passwords, monitor financial and account statements for unauthorized activity, enable additional security features such as multi-factor authentication where available, and remain vigilant for potential phishing attempts or suspicious communications.

6.3 Privacy Rights (GDPR, CCPA, etc.)

IFC is committed to compliance with applicable data protection laws, including the EU/UK General Data Protection Regulation (GDPR) and the Swiss Federal Act on Data Protection, as well as U.S. laws like the California Consumer Privacy Act (CCPA) and similar state privacy laws. Depending on your residency, you may have certain rights regarding your personal data. We honor all such rights to the extent required by law. These may include:

• Right of Access: You can request information about what personal data we have about you and obtain a copy of that data.

• Right of Rectification: If any of your personal data we hold is inaccurate or incomplete, you have the right to request correction.

• Right to Erasure (Right to be Forgotten): You may, in certain cases, request that we delete your personal data. Note: Due to the immutable nature of blockchain, deletion might not apply to data that has been written to the blockchain ledger. For such data, we will, where possible, implement measures to make personal information inaccessible, and will delete any off-chain copies under our control. We design the Service to minimize on-chain personal data precisely to address this issue.

• Right to Restrict Processing: You can ask us to limit processing of your data in certain circumstances.

• Right to Data Portability: You may request a copy of your personal data in a commonly used format so you can transfer it to another service (where applicable).

• Right to Object: Where we process your data based on legitimate interests, you can object to that processing. You also have the right to object to processing for direct marketing (though currently we do not use your data for unsolicited marketing without consent).

• Rights regarding Automated Decision-Making: Our Service does not typically involve automated decisions that produce legal or similarly significant effects on individuals without human involvement. If that changes, affected users would have rights not to be subject to such decisions solely by automation.

• California Privacy Rights (CCPA/CPRA): If you are a California resident, you have the right to know what categories of personal information we collect, the purposes for which we use it, and to request that we delete your personal information (subject to exceptions). You also have the right to opt-out of any “sale” of your personal information.  

  • IFC respects opt-out preference signals such as Global Privacy Control and will automatically honor these signals for California residents. IFC manages user requests within a 45-day timeframe by initially acknowledging receipt within 10 business days and providing a full response or update on the status within 45 calendar days. If additional time is necessary due to complexity or volume of requests, users will be notified, and the response timeframe may be extended by an additional 45 days.  

  • IFC does not sell personal data to third parties for profit. We only share data as described (for providing the Service or legal reasons). We also will not discriminate against you for exercising any privacy rights (e.g., we won’t deny you service or provide different quality of service just because you exercised your privacy rights, except to the extent the service inherently cannot be provided without that data).

  • Users may exercise their rights via the following links:

[Do Not Sell or Share My Personal Information]

[Limit the Use of My Sensitive Personal Information]

6.4 Data Transfers and International Users

IFC is based in the United States, and the Service’s data systems may be in the U.S. and other countries (including Switzerland and EU countries). If you are located outside the United States, be aware that your personal data may be transferred to, stored, and processed in the United States or other jurisdictions which may have data protection laws different from those of your jurisdiction. We will take steps to ensure that appropriate safeguards are in place for such transfers as required by applicable law. For example, for personal data originating from the European Economic Area (EEA) or Switzerland, we may rely on the European Commission’s Standard Contractual Clauses or other legally approved transfer mechanisms to lawfully transfer data to the U.S., since the U.S. may be considered not to have an equivalent data protection regime. Our Swiss affiliates ensure that data transfers between Switzerland and the U.S. or other countries comply with the Swiss data protection requirements.

By using the Service, you consent to the transfer of your information to the United States and any other country in which we or our service providers maintain facilities, subject to the provisions of these Terms and our Privacy Policy. We will always protect your data as described, regardless of where it is processed.

Personal data may also be transferred internationally, including to Switzerland. IFC implements specific safeguards for transfers to Switzerland, relying on the adequacy decision issued by the European Commission, which recognizes Switzerland as providing an adequate level of data protection under GDPR. Additionally, IFC utilizes Standard Contractual Clauses (SCCs) approved by the European Commission as supplementary safeguards for such transfers. These combined legal mechanisms ensure compliance with applicable EU and Swiss data protection requirements and provide robust protections for personal data.

6.5 Personal Data on the Blockchain

As noted, the Service utilizes a blockchain ledger to record certain data. Generally, we avoid plain-text personal data on the blockchain whenever possible. Instead, personal information may be processed off-chain, or only a cryptographic hash or reference is placed on-chain to represent a record that can be looked up off-chain. This design is intended to support data privacy (since a hash on its own is not readily identifiable to an individual without additional information) and to allow some flexibility in honoring deletion or correction requests (we can update or erase the off-chain record, and the on-chain hash alone would no longer be meaningful personal data). However, if you as a user choose to record personal data (for example, entering a person’s name or ID in a field that gets written to the blockchain), understand that this data may become a permanent part of the distributed ledger that cannot be altered or erased by us. You should only input personal data on-chain when necessary and in designated fields. By inputting any data onto the blockchain through our Service, you consent to that data being stored on a decentralized ledger and acknowledge that removal of such on-chain data might not be feasible.

IFC will endeavor to provide guidance within the Service on which fields or data will be recorded on-chain versus kept off-chain, so you can make informed choices. You agree to follow any such guidance and to refrain from entering extraneous personal details into on-chain fields. We are not responsible for personal data that you or other users include in the blockchain ledger outside of our recommended practices.

6.6 Data Retention

IFC retains personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable law. Specific retention periods for various categories of personal data are established as follows:

• Account Information: Retained for the duration of account activity plus an additional 2 years after account closure to address any residual inquiries or disputes.

• Transactional Data: Retained for a period of 7 years following the completion of transactions to comply with regulatory requirements, including ITAR, financial reporting, and tax obligations.

• Technical Data (logs, IP addresses, device information): Retained for 1 year to facilitate security audits and troubleshooting activities.

• Sensitive Personal Data (SSNs, government-issued IDs): Retained only for the minimum period required for identity verification purposes and regulatory compliance, typically not exceeding 3 years from the last use.

Retention Criteria: Retention periods are determined based on:

• Regulatory and legal compliance obligations (e.g., firearms regulations, tax and accounting rules).

• Duration of contractual obligations and potential legal claims.

• Necessary record-keeping requirements for business continuity, security, and audit purposes.

Deletion or Anonymization: If you request deletion of your personal data or close your account, we will delete or anonymize your personal data within a reasonable period, except for data we are required or permitted to keep by law or under these Terms (e.g., logs for security, any blockchain records as described above, and data needed for dispute resolution or legal defense). Aggregated or de-identified data (which is not personally identifiable) may be retained indefinitely. Once retention periods expire, IFC securely deletes or anonymizes personal data. Specifically:

• Account information and transactional records are anonymized by removing all identifiable information.

• Technical data and sensitive personal data are securely deleted through industry-standard data sanitization methods that irreversibly eliminate the data.

These measures ensure that retained data does not pose unnecessary privacy risks beyond its useful lifecycle.

6.7 Confidentiality of Certain User Data

In using the Service, you might have access to information that is confidential or sensitive (e.g., firearms shipment details, inventory levels of a manufacturer, or personal info about customers). You agree to treat any non-public information obtained through the Service as confidential and to use it only for the legitimate purposes of the Service. Do not share others’ information obtained from the Service with third parties unless you have proper authority or consent to do so.

Similarly, any feedback or suggestions you provide to IFC about the Service are considered non-confidential and you grant IFC the right to use them freely (see Section 7.3).

For additional details on how we handle data, please refer to our full Privacy Policy (available on our website). If you have privacy-related questions or concerns, you can reach out using the contact information in Section 14.7.

7. Intellectual Property Rights

7.1 Ownership of the Service and IFC Materials

All rights, title, and interest in and to the Service, including any software, code, databases, blockchain ledger design, APIs, website content, logos, graphics, designs, trademarks, service marks, and other content or material made available by IFC (collectively, “IFC Materials”), are and will remain the property of IFC or its licensors. The Service and IFC Materials are protected by copyright, trademark, patent, trade secret, and other intellectual property and proprietary rights laws. Except for the limited license granted to you in Section 4.1, nothing in these Terms transfers or grants you any ownership rights in the Service or any IFC intellectual property. You may not use IFC’s name, logos, or trademarks without our prior written consent, except as necessary for you to lawfully use the Service (such as to identify your use of the IFC Service in integration settings).

7.2 License Granted by User (Your Content and Data)

IFC does not claim ownership of the information or content that you or other users input or upload into the Service (“User Content”). You retain all ownership rights that you have in the data or content you provide, subject to the rights expressly granted below and other provisions of these Terms.

By submitting or uploading User Content to the Service, you grant IFC and our affiliates a worldwide, royalty-free, non-exclusive, sublicensable (to our service providers or partners for the sole purpose of helping us provide the Service), transferable license to use, reproduce, distribute, create derivative works of, display, and perform your User Content solely for the following purposes: (a) providing and maintaining the Service (for example, processing the data to display back to you and authorized viewers, backing up data, or aggregating data for better retrieval); (b) improving and adapting the Service (such as using aggregated insights to optimize our platform, or using your feedback to develop new features); and (c) legal compliance (e.g., retaining records as required by law, disclosing information pursuant to lawful requests, etc.). This license to your content is limited to those purposes and does not give us rights to use your content for unrelated commercial purposes (for instance, we won’t sell your specific data to third-party marketers or publish your confidential business information without consent).

We also commit that we will follow our Privacy Policy and data protection laws in any use of personal data within User Content. For example, if your User Content includes personal information, our use of that personal info remains subject to GDPR, CCPA, and relevant privacy constraints despite the broad license granted here for content.

You represent and warrant that you have all necessary rights and permissions to submit the User Content to the Service and to grant the license above. This means, for example, if you upload data about firearms transactions, you have the right to disclose that information and none of it infringes any third party’s rights or violates law. You also agree that your User Content will not contain any material that’s obscene, defamatory, or otherwise violative of any laws (see Acceptable Use in Section 5).

Except for any obligations we have under privacy laws to delete personal data, if you voluntarily delete or remove your User Content from the Service, the license you granted above will typically end after a reasonable period needed for removal from backups and operational caches. However, you acknowledge that (a) removed content may persist in backups (though not visible to others) until those backups are deleted in the ordinary course, (b) if your content was shared with others via the blockchain or otherwise, we cannot retroactively delete or retract it from those recipients (data recorded on blockchain may persist in the ledger as described in Section 6.5), and (c) we might retain certain content as needed for legal compliance. The license is granted indefinitely for content that remains on the Service.

7.3 Feedback

If you provide IFC with any suggestions, ideas, feedback, or recommendations regarding the Service (“Feedback”), whether written, oral, or in any form, you hereby grant IFC a perpetual, irrevocable, royalty-free, fully paid, sublicensable and transferable license to implement, use, modify, or incorporate such Feedback into our products and services without any obligation to compensate you. Feedback is entirely voluntary, but we value it and may act on it without any restriction or obligation of confidentiality (aside from not publicly disclosing who gave feedback without permission).

7.4 Third-Party Content and Open Source

The Service may include or interoperate with software or components that are licensed to us by third parties, including open-source software. All such third-party software or content (e.g., libraries, APIs, or datasets) is the property of the respective owners. Your use of those components within our Service is subject to the applicable third-party license terms, which we will make available to you (often via an “About” or “Attributions” page in our app or website). Nothing in these Terms limits your rights under, or grants you rights that supersede, the terms of any such third-party/open-source licenses.

Similarly, content provided by other users or third parties (e.g., data a manufacturer uploads that you can view) is owned by that user or third party. IFC is not responsible for user-provided content; we simply provide a platform to host it. If you believe the content in the Service infringes your intellectual property or other rights, please contact us with details so we can investigate (see Section 14.7 for contact info).

7.5 Prohibited Intellectual Property Uses

Except as expressly allowed by these Terms or by law, you shall not (and shall not permit anyone else to) modify, copy, distribute, publicly perform, publicly display, republish, download, store, transmit, create derivative works of, or otherwise exploit any portion of the Service or IFC Materials. You also agree not to remove, obscure, or alter any copyright, trademark, or other proprietary rights notices displayed in the Service or on any content. Using any automated system (like a robot, spider, or scraper) to access the Service for the purpose of extracting data (other than for normal indexing by search engines) is prohibited without our prior written consent.

If you wish to use any IFC Materials in a way that is not permitted by these Terms, you must obtain a separate explicit permission or license from us (for example, to use our trademarks in a publication, or to API access beyond provided endpoints). Unauthorized use of IFC’s intellectual property may result in termination of your rights under these Terms and may constitute a violation of law.

8. Fees, Payment, and Taxes

(This section applies if you purchase any paid services, subscriptions, or other fee-based offerings from IFC. If the Service or certain features are provided to you for free, some parts of this section may not apply, except for any transaction costs related to blockchain usage.)

8.1 Fees and Pricing

IFC will disclose any fees or prices associated with the Service or specific features (for example, subscription fees for enterprise users, usage-based fees for certain transactions, or one-time payments for premium features). You agree to pay all applicable fees for the services you select in accordance with the billing terms in effect at the time the fee becomes payable. Pricing and payment terms will be presented to you in a clear manner (e.g., on our website checkout page, order form, or in a separate written agreement).

All fees are stated and payable in the currency disclosed (U.S. Dollars by default, unless otherwise specified). If a feature of the Service requires payment via cryptocurrency or a proprietary token (given the “Currency” aspect of our Service), such details will be clearly provided, including any conversion rates or applicable conditions for using such currency. In absence of such a feature, all payments will be via traditional payment methods (credit card, bank transfer, etc.).

8.2 Payment Terms

For recurring charges (such as monthly or annual subscriptions), you authorize IFC to charge your provided payment method automatically on the billing schedule specified (e.g., each month on a set date). If your payment method fails or an invoice is not paid when due, we may attempt to charge again, and if payment continues to fail, we reserve the right to suspend or terminate your access to paid features. You are responsible for providing complete and accurate billing information and keeping it up-to-date.

Some payments may be processed by third-party payment processors (e.g., Stripe, PayPal, etc.). Those transactions are subject to the third party’s terms and privacy policy. IFC is not responsible for any errors caused by payment processors, but we will help liaise to resolve issues.

8.3 Taxes

Our fees do not include any applicable taxes (such as sales, use, value-added tax (VAT), GST, or other similar taxes). You are responsible for paying any such taxes that are assessed based on your billing address and applicable law, except for taxes based on our net income. We will charge tax when required to do so (for example, if we are required to collect VAT for sales to EU customers, the VAT will be added to your bill). Any such taxes collected by us will be remitted to the appropriate taxing authority. We will not collect taxes for which you provide a valid exemption certificate, or if the transaction is tax-exempt under applicable law.

If you are required by law to withhold any taxes from your payment to us, you must provide us with an official receipt or other documentation substantiating the payment of such taxes.

8.4 Refunds and Credits

All fees are generally non-refundable. Once a service period (e.g., a monthly subscription) has begun, you are responsible for the fees for that period. We do not typically provide refunds or credits for partial use within a billing cycle or for unused features. Exception: If a refund policy is stated for a particular service or required by law (for example, certain jurisdictions may mandate a cooling-off period for consumer digital purchases), we will honor that. Also, if we terminate the Service on our own accord without cause (not due to your misconduct) before the end of a period you paid for, we may provide a pro-rated refund for the unused portion.

Any blockchain transaction fees (e.g., gas fees on a public blockchain) are inherently non-refundable, as they are paid to the network validators, not to IFC.

If you believe there has been a billing error or you wish to request a refund due to extraordinary circumstances, please contact us and we will review on a case-by-case basis.

8.5 Changes in Fees

We may change our fees or introduce new fees for additional services in the future. Fee changes will not retroactively affect your existing subscriptions or services that you have already paid for, but would apply to new purchases or renewals. We will give you reasonable advance notice of any changes to our standard fees to allow you to cancel a subscription or service before the new charges apply, if you choose. If you continue using the paid Service after the fee change, that constitutes your agreement to the new fees.

8.6 Free Trials and Promotions

IFC may offer free trials or promotional offers for certain features or for new customers. Such offers are only valid for the specified time and may be subject to additional terms. Once a free trial period ends, you will be charged the applicable fees unless you cancel the service before the trial ends. Users abusing free trial offers (such as creating multiple accounts to claim multiple free trials) are in violation of these Terms.

9. Termination and Suspension

9.1 Your Right to Terminate

You may stop using the Service at any time. If you have an account, you may terminate your account or subscription by following the instructions within the Service (if available) or by contacting us to request account deletion. Termination will be effective once processed by IFC. If you terminate a paid subscription, you may lose access immediately or at the end of your current billing period depending on our policy (we will inform you of how that works at time of cancellation). Note that simply uninstalling an app or stopping use of the Service will not automatically terminate any ongoing subscription – you must properly cancel or inform us. Also, even after you stop using your account, certain data may persist as outlined in Section 6.6 (Data Retention).

9.2 IFC’s Right to Suspend or Terminate

Suspension: We may suspend your access to the Service (in whole or in part, including locking your account or the ability to submit new data) immediately and without notice if we, in our sole discretion, determine that: (a) you have violated these Terms (for example, breached the Acceptable Use Policy in Section 5 or failed to pay fees when due), (b) your use of the Service poses a security risk or may adversely impact the Service or other users (e.g., hacking attempts or causing network disruptions), (c) we suspect fraudulent, abusive, or illegal activity by you, or (d) we are required to do so by law enforcement or regulatory authority. We will make a good-faith effort to inform you of the suspension and the reason for it as soon as reasonably possible, and perhaps provide an opportunity to cure the issue (if curable) unless prohibited by law or our reasonable judgment (e.g., if your account was used for criminal activity, we likely will not restore it).

Termination by IFC: IFC reserves the right to terminate your account and this Agreement for cause if you materially breach these Terms or violate applicable law, and (if the breach is curable) fail to cure the breach within a reasonable period after we have provided notice to you. Additionally, we may terminate the Agreement without cause for convenience by providing you with at least 30 days’ prior notice (for example, if we decide to discontinue the Service). In either case of termination by us, we may immediately deactivate or delete your account and all associated data and bar any further access to such data or the Service. We are not liable to you or any third party for termination of your account in accordance with these Terms.

1. 9.3 Effect of Termination

Upon termination of your account or this Agreement for any reason:

• Cease Use: You must immediately cease all use of the Service. Any license granted to you to use the Service or IFC Materials ends at termination.

• Payment Obligations: If there are any outstanding fees or charges owed by you, you must pay those immediately, and we reserve the right to invoice you or charge your payment method for any unpaid amounts.

• Data Handling: We will handle your data in accordance with Section 6.6 (Data Retention) and our Privacy Policy. In summary, your personal data will be deleted or anonymized, except for data we must retain for legal reasons or which remains on the blockchain ledger. We may provide you the ability to download your contributed data before deletion, if feasible (for example, giving enterprise users a final export of their records).

• No Liability for Termination: Except as expressly required by law, we will not be liable to you for compensation, reimbursement, or damages on account of the loss of prospective profits, goodwill, or data as a result of termination of this Agreement. Termination does not waive or release either party from any liability or claim that at the time of termination has already accrued to the other party.

9.4 Survival of Terms

Any provisions of these Terms which by their nature should survive termination (whether of your account or of this Agreement) shall survive. This includes, without limitation: Section 6 (Data Privacy) (to the extent we retain data), Section 7 (Intellectual Property, including our rights to use feedback and your obligation not to misuse IP), Section 9.3 (Effect of Termination), Section 10 (Disclaimers), Section 11 (Limitation of Liability), Section 12 (Indemnification), Section 13 (Dispute Resolution), and Section 14 (General Provisions). All of those remain in effect even after termination.

If your account is terminated and later you wish to re-enroll, you will be considered a new user and these Terms (and any updated version) will apply as if for the first time.

10. Disclaimers of Warranties (No Warranty) and Assumption of Risk

IFC PROVIDES THE SERVICE “AS IS” AND “AS AVAILABLE.” Your use of the Service is at your own risk. We are committed to providing a high-quality and secure service, but there are some things we cannot promise.

10.1 No Warranty

To the maximum extent permitted by applicable law, IFC and its affiliates, and each of their respective officers, directors, employees, agents, and partners disclaim all warranties and representations, express or implied, relating to the Service and your use of it. This includes, but is not limited to:

• Implied Warranties: We disclaim any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, and any warranty arising out of course of dealing or usage of trade. We make no guarantees that the Service will meet your requirements or expectations, or that it will achieve any particular results.

• Continuity and Accuracy: We do not warrant that the Service will be uninterrupted, timely, secure, or error-free. Because of the nature of blockchain and internet services, we cannot guarantee that data transmissions or storage are 100% error-free or immune from downtime. While we aim for accuracy and reliability in data recording, IFC makes no warranty that the data on the Service (including data you or other users input) is complete, accurate, or reliable. For example, if a user enters incorrect firearm information or fails to update a record, we are not responsible for any inaccuracies. We do not audit or certify the truth of user-provided data.

• Security: We do not warrant that the Service will be free from viruses, malware, or other harmful components, though we take precautions (see Section 6.2). Any material downloaded or otherwise obtained through the use of the Service is at your own discretion and risk, and you are solely responsible for any damage to your device or loss of data that results.

• Third-Party Inputs: We aren’t responsible for any third-party content or services integrated with the Service, and we make no warranties regarding them (as covered in Section 4.6). This also extends to the underlying blockchain network if it’s operated by third parties; we cannot guarantee the performance or reliability of external networks or infrastructure.

Some jurisdictions do not allow the exclusion of certain warranties, so some of the above disclaimers may not fully apply to you. In such cases, the disclaimers will apply to the greatest extent permitted by law.

10.2 Assumption of Risk – Blockchain and Technology

Blockchain Risks: You acknowledge that using a blockchain-based service comes with unique risks. By using our Service, you accept and assume the following risks, and IFC disclaims liability for them:

• Irreversible Transactions: Transactions or records added to a blockchain may be irreversible. If you make an error in an entry (e.g., linking a firearm to the wrong serial number or person), correction might require a new transaction and the original entry will remain on the ledger. We are not responsible for errors or permanent effects of your on-chain transactions.

• Private Keys: Access to any blockchain assets or records may require a private key or secret. If the Service provides you with cryptographic keys or you use your own, losing your private key may result in the loss of access to your data or assets permanently. IFC does not have the ability to recover lost private keys if the system is designed such that keys are solely in users’ control. It is your responsibility to safeguard any keys or credentials used for blockchain features.

• Network Issues: The blockchain network (if public or consortium) might experience congestion, faults, or attacks (such as 51% attacks or consensus failures) that could disrupt the Service or cause inconsistencies. There could be delays in transaction processing or confirmation that are outside IFC’s control. You agree that IFC is not responsible for any losses or issues arising from blockchain network failures or delays.

• Smart Contracts and Software: If our Service uses smart contracts or automated code on the blockchain, there is a risk of vulnerabilities or bugs in that code. Despite testing, smart contracts may fail or behave unexpectedly. By using the Service, you understand that any trust in smart contract execution is at your own risk. We disclaim liability for any bug, exploit, or flaw in third-party libraries or in our smart contract code that affects the Service’s functionality or your data.

• Regulatory Risks: Blockchain and cryptocurrencies are subject to evolving laws and regulations in many jurisdictions. Changes in law or regulation (or enforcement actions) could impact the Service or your ability to use it, possibly requiring us to make changes or restrict functionalities. We are not responsible for any losses or inconvenience caused by regulatory changes or our good-faith efforts to comply with them.

10.3 No Legal or Professional Advice

The information and materials provided through the Service (including any documentation, FAQs, or guidance) are for general informational purposes only. IFC is not a law firm and does not provide legal advice. While the Service may assist with compliance (for example, maintaining records that may be used for regulatory compliance), you are solely responsible for understanding and fulfilling your legal obligations (such as proper firearms record-keeping, licensing, reporting, and export authorization). Always consult a qualified attorney or compliance expert for advice specific to your situation. IFC’s support or training materials should not be relied upon as a substitute for professional advice. We disclaim any warranty that use of the Service will ensure you are in compliance with any laws or regulations.

10.4 Specific Disclaimers for International Use

IFC makes no representation that the Service is appropriate or available in all locations. Users who access or use the Service from jurisdictions outside of the United States do so at their own initiative and risk, and are responsible for compliance with local laws. Certain features may not be available in all countries or may be adjusted to comply with local rules. If any official authority in your country deems any portion of the Service illegal, we may not be able to offer it to you or may be required to modify it, and we are not liable for any such unavailability or modifications due to legal requirements.

10.5 Testimonials and Marketing

Any testimonials or endorsements by other customers that we may display (e.g., on our website or marketing materials) are individual experiences, reflecting real-life experiences of those users. However, they do not guarantee or warrant that you will have the same outcomes. Your results from using the Service may vary.

In summary, you understand and agree that use of the Service is at your sole risk. The Service is provided without warranties of any kind, except to the extent such warranties cannot be legally excluded.

11. Limitation of Liability

To the fullest extent permitted by law, IFC’s liability to you is limited. This means if you suffer harm, losses, or damages from using the Service or under these Terms, our responsibility to compensate you is restricted as set forth below.

11.1 Types of Damages Excluded

Neither IFC nor its affiliates, officers, employees, agents, suppliers, or partners shall be liable for any indirect, incidental, consequential, special, punitive, or exemplary damages whatsoever arising out of or in connection with your use of or inability to use the Service or these Terms, even if IFC has been advised of the possibility of such damages. This exclusion includes, without limitation, damages for lost profits, lost revenue, lost savings, loss of data, loss of business opportunities, loss of goodwill or reputation, or the cost of procurement of substitute services. It also includes damages for personal injuries or property damage arising from or related to your use of the Service, to the extent not caused solely by our gross negligence or intentional misconduct.

For example, IFC will not be liable for any loss you incur because of: a mistake in a firearms record that goes unnoticed, an unauthorized person accessing your data, downtime of the Service that causes operational delays, any regulatory fines you face despite using our Service, or third-party claims against you due to information you obtained from the Service.

11.2 Liability Cap

IFC’s total cumulative liability to you for all claims arising out of or relating to these Terms or the Service (whether in contract, tort (including negligence), strict liability, or any other legal theory) shall not exceed the amount (if any) you paid to IFC for the Service in the twelve (12) months immediately before the event giving rise to liability. If you have not paid IFC any amounts (for example, if you are using a free service), IFC’s maximum liability to you shall be USD $100 (one hundred U.S. dollars) or the minimum amount permitted by law, whichever is greater.

This liability cap is an aggregate limit for all of your claims and causes of action. Multiple claims will not enlarge this limit.

11.3 Exclusions and Limitations

Because some jurisdictions do not allow the exclusion or limitation of certain damages or liabilities, the above limitations may not apply to you in full. For instance, certain countries do not allow the exclusion of implied warranties or limitation of liability for personal injury or fraud. In such jurisdictions, IFC’s liability will be limited to the maximum extent permitted by law.

Nothing in these Terms shall limit or exclude liability that cannot be limited or excluded by law, such as liability for death or personal injury directly caused by IFC’s gross negligence or willful misconduct, or for IFC’s fraud or fraudulent misrepresentation. Additionally, if you are a consumer residing in a jurisdiction that provides you with certain non-waivable rights, nothing in this Section 11 is intended to limit those rights beyond what is permissible.

11.4 Release of Claims

To the extent permitted by law, you release IFC and its affiliates from any and all claims or liabilities arising from or related to your use of the Service or any acts or omissions of other users. If you are a California resident, you waive California Civil Code §1542 (which says a general release does not extend to claims unknown to the creditor that, if known, would have affected the settlement) and any similar law in any jurisdiction, meaning that the release covers all claims, even those you might not know about or suspect at the time of agreeing to this release, to the maximum extent permitted by law.

11.5 Basis of the Bargain

You acknowledge and agree that IFC has offered the Service and set its prices (if any) and entered into these Terms in reliance upon the disclaimers of warranty and the limitations of liability set forth herein. These disclaimers and limitations are an essential basis of the bargain between you and IFC and apply regardless of the form of action, whether in contract, tort, strict liability, or otherwise, and even if any limited remedy fails of its essential purpose.

12. Indemnification

You agree to defend, indemnify, and hold harmless IFC, its parent, subsidiaries, and affiliates (including the Swiss entities), and their respective officers, directors, employees, agents, and representatives (collectively, the “IFC Parties”) from and against any and all claims, demands, lawsuits, investigations, damages, losses, liabilities, costs, and expenses (including reasonable attorneys’ fees and legal costs) arising out of or related to:

• Your Breach or Violation: Any breach by you of these Terms or violation of any provision herein. For example, if you use the Service in a way that violates the Acceptable Use Policy (Section 5) or any other section of these Terms, and that results in a dispute or claim, you must indemnify us.

• Your Violation of Laws or Rights: Your violation of any law or regulation, or of the rights of any third party, in connection with your use of the Service. This includes, for instance, any violation of data privacy laws (if you uploaded personal data without proper consent), firearms laws (if you use the Service to facilitate an unlawful transfer), export controls (if you share restricted data unlawfully), or intellectual property laws (if you uploaded infringing content).

• Your Content and Data: Any allegation that the User Content or data you submitted to the Service infringes or misappropriates the intellectual property, privacy, confidentiality, or other rights of a third party, or has caused harm to a third party. (Example: if you upload someone’s private information and they sue IFC for privacy invasion, or if you enter incorrect data that leads to someone else’s losses and they claim IFC is responsible.)

• Your Misuse of the Service: Any misuse of the Service by you or through your account, including any act or omission that is fraudulent, illegal, or negligent.

Your indemnification obligation covers claims brought by you (to the extent this provision is enforceable in those scenarios) as well as by other individuals or entities, whether as a direct claim, counterclaim, cross-claim, or otherwise.

IFC reserves the right, at its own discretion and expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you. If we do so, you agree that you will cooperate with our defense of those claims and not settle any such matter without IFC’s prior written consent. You further agree to promptly notify IFC of any third-party claims of which you become aware, that might affect IFC.

This indemnification provision is for the benefit of IFC and each of the IFC Parties. We will reasonably notify you of any such claim or demand that we become aware of, but any failure to notify timely will not relieve you of your indemnification obligations except to the extent it materially prejudices your ability to defend the claim.

13. Dispute Resolution and Arbitration Agreement

Please read this section carefully. It requires most disputes to be resolved by way of binding arbitration on an individual basis, waiving your right to a jury trial and to participate in class actions or other representative proceedings, where permitted by law. This section may not apply to you if you are in a jurisdiction (like certain EU countries) where pre-dispute arbitration clauses in consumer contracts are prohibited; see “Exceptions” below.

13.1 Governing Law

These Terms and any dispute arising out of or relating to these Terms or the Service (“Dispute”) shall be governed by and construed in accordance with the laws of the State of New Mexico, USA, and, to the extent applicable, the federal laws of the United States (including U.S. export and firearms laws), without giving effect to any conflict of law principles that would cause the laws of a different jurisdiction to apply.

However, if you are a consumer resident outside the U.S., mandatory consumer protection laws of your country of residence may apply for your benefit. In such cases, nothing in these Terms will deprive you of the protections of the mandatory laws of your jurisdiction. For example, if you reside in a country in the European Union, you may have certain rights under EU consumer laws that cannot be waived by contract, and those rights will be preserved.

13.2 Initial Dispute Resolution

Most concerns can be resolved quickly by contacting us. You agree to try to resolve any Dispute informally by contacting IFC at the contact information in Section 14.7. We will attempt to address your concerns through negotiation, and you and IFC agree to negotiate in good faith to resolve any Dispute. If a Dispute is not resolved within 30 days from the time a notice of Dispute is first sent (or such longer time as we may mutually agree), either party may then initiate arbitration as outlined below (or litigation if applicable under an exception below).

13.3 Agreement to Arbitrate

If we cannot resolve a Dispute through informal negotiation, you and IFC agree that any and all Disputes (except those expressly excluded in Section 13.7) shall be resolved through final and binding arbitration. This arbitration agreement is intended to be broadly interpreted. It includes, for example, disputes arising out of or relating to the interpretation or application of this arbitration provision itself, and disputes about the validity, enforceability, or scope of this arbitration agreement or these Terms.

YOU UNDERSTAND THAT, BY AGREEING TO ARBITRATION, YOU AND IFC ARE EACH WAIVING THE RIGHT TO SUE IN COURT AND HAVE A TRIAL BEFORE A JUDGE OR JURY. Arbitration has different rules than lawsuits in court. There is no judge or jury, and court review of an arbitration award is limited. However, an arbitrator can award on an individual basis the same damages and relief as a court (including injunctive and declaratory relief or statutory damages).

This arbitration agreement is made pursuant to and shall be governed by the U.S. Federal Arbitration Act (FAA), 9 U.S.C. §§ 1-16.

13.4 Arbitration Procedures

Administration and Rules: The arbitration shall be administered by the American Arbitration Association (AAA) in accordance with its applicable rules. If you are an individual using the Service for personal or household use, the AAA Consumer Arbitration Rules will apply (as modified by these Terms). If your use of the Service is for business or commercial purposes, or involves a dispute between businesses, the AAA Commercial Arbitration Rules will apply. The AAA rules are available on the AAA website. If AAA is not available or declines to arbitrate, the parties will agree on an alternative reputable arbitration provider or the court will appoint one.

Arbitrator: The arbitration will be conducted by a single, neutral arbitrator. The arbitrator will be an attorney or retired judge with experience in contract and technology disputes. The arbitrator is bound by the terms of these Terms.

Location: Arbitration shall take place in the State of New Mexico, USA. Unless you and IFC agree otherwise, the specific venue shall be in Albuquerque, New Mexico (or another location in New Mexico convenient for the parties). If traveling to New Mexico would cause undue burden for you, and if your claim is for less than USD $10,000, you may choose to have the arbitration conducted telephonically, by video, or based on written submissions, subject to the arbitrator’s discretion to require an in-person hearing if fairness dictates. For non-U.S. consumers, you also have the option to participate in the arbitration remotely to mitigate travel inconvenience.

Language: The arbitration shall be conducted in English, unless otherwise required by mandatory law or agreed by the parties.

Filing and Arbitration Costs: Payment of all filing, administration, and arbitrator fees will be governed by the AAA’s rules. We will pay all such fees for claims totaling less than $5,000, unless the arbitrator finds your Dispute frivolous or brought for an improper purpose (under applicable law). For larger claims, the costs will be split as per AAA rules, or as directed by the arbitrator. Each party will bear its own attorneys’ fees and costs unless the arbitrator awards otherwise or applicable law provides for the shifting of attorneys’ fees.

Authority of Arbitrator: The arbitrator shall have the exclusive authority to resolve any dispute relating to the interpretation, applicability, or enforceability of this binding arbitration agreement. The arbitrator shall have the authority to grant motions dispositive of all or part of any claim, and to award any remedies that would be available in an individual lawsuit under applicable law. The arbitrator shall issue a reasoned written award explaining the findings and conclusions on which the decision is based. The arbitrator’s award will be binding on the parties and may be entered as a judgment in any court of competent jurisdiction.

13.5 Class Action Waiver

YOU AND IFC AGREE THAT ANY ARBITRATION (OR, IF ARBITRATION IS NOT COMPELLED, ANY COURT ACTION) WILL BE CONDUCTED ON AN INDIVIDUAL BASIS AND NOT ON A CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE BASIS. THE ARBITRATOR SHALL HAVE NO AUTHORITY TO CONSIDER OR RESOLVE ANY DISPUTE OR ISSUE ANY RELIEF ON A CLASS, COLLECTIVE, OR REPRESENTATIVE BASIS. This means:

• No Class Actions or Group Relief: You and IFC waive any right for any Dispute to be arbitrated or litigated as a class action, or to participate as a class member. Disputes must be brought in the name of an individual person or entity only, and not as a plaintiff or class member in any purported class or representative proceeding.

• No Consolidation: The arbitrator can only hear your and/or IFC’s individual claims. The arbitrator may not consolidate or join the claims of other persons or parties who may be similarly situated without the consent of all parties.

• Representative/Private Attorney General Actions: You and IFC also agree that no claims will proceed as a representative action (such as under a private attorney general statute) or on behalf of the general public or other persons.

If a court or arbitrator determines that the class action waiver in this Section 13.5 is invalid or unenforceable as to a particular claim, then the claim must proceed in court (not arbitration) as a class or representative action, and the portion of the arbitration agreement (Section 13.3) pertaining to that claim shall be severed (removed). However, the class action waiver remains valid for all other claims or proceedings.

13.6 Opt-Out Right (for Arbitration Agreement)

Your Right to Opt Out: If you are a new user, you can choose to opt out of the arbitration agreement and class action waiver in this Section 13 by sending us a written notice of your decision within 30 days of your first use of the Service. If you are already bound by a previous version of these Terms that included an arbitration agreement and you did not validly opt out at that time, you remain bound; however, if this is the first inclusion of an arbitration clause, the 30-day opt-out period starts from when these Terms take effect for you.

To opt out, you must send a written notice to us by email at legal@ifcurrency.com or by postal mail to our Notice address listed in Section 14.7. Your opt-out notice must include your name, your account information (if you have an account), and a clear statement that you opt out of the arbitration agreement. If you opt out, neither you nor IFC can require the other to participate in an arbitration proceeding for the specified Dispute; you will preserve your right to litigate in court (subject to the venue and governing law provisions).

Opting out of this arbitration agreement will not affect any other provisions of these Terms, including the governing law or venue provisions. If you opt out but later enter new Terms with us that include an arbitration clause and do not opt out of that subsequent clause, your earlier opt-out will not apply to the new agreement.

13.7 Exceptions to Arbitration

Notwithstanding the agreement to arbitrate, either party may choose to pursue resolution in court (rather than arbitration) in the following limited circumstances:

• Small Claims: If your claim (or our claim against you) is for individual monetary damages of $5,000 or less, and it is within the jurisdictional limit of a small claims court, either you or IFC may elect to file the claim in small claims court in the county of your billing address (or primary residence) or in Bernalillo County, New Mexico (where IFC’s U.S. headquarters is located). If one party chooses to proceed in small claims court, that choice is binding on the other party.

• Intellectual Property or Unauthorized Use: Either party may seek injunctive or equitable relief (not involving the payment of money) in a court of competent jurisdiction to prevent actual or threatened infringement, misappropriation or violation of a party’s copyrights, trademarks, trade secrets, patents, or other intellectual property or proprietary rights. For example, if you were to violate our intellectual property rights in a way that requires immediate action, we can go to court to seek an injunction without first going to arbitration. Similarly, if you unlawfully access or exceed authorized access to the Service (violate anti-hacking laws), we can go to court. You also have this right to go to court for IP claims against us.

• Legal Compliance: If applicable law in your jurisdiction prohibits the use of binding arbitration or class action waivers for disputes, or if the arbitration agreement is deemed invalid or unenforceable for a particular dispute by a court of competent jurisdiction (and the decision is not reversed on appeal), then such dispute shall instead be resolved in the courts identified in Section 13.8. For instance, if you are a resident of a European Union member state and are considered a consumer under EU law, the above arbitration clause and class waiver may not be enforceable against you. In that case, you retain the right to resolve disputes in your local courts under your local law. Nothing in this Section 13 requires you to arbitrate or waives your rights to bring claims in the courts of your home country if such a waiver is prohibited by the laws of your country.

13.8 Venue for Litigation

In the event that the arbitration agreement in this Section 13 is for any reason held not to apply to a Dispute (either as a result of your decision to opt out, a court order, or because one of the exceptions above applies), you and IFC agree that any judicial proceeding (other than small claims actions) will be brought in the state or federal courts for Bernalillo County, New Mexico, USA, provided that if you are a consumer residing in a jurisdiction which provides you the right to bring an action in your home country’s courts (such as EU consumers), you may alternatively do so. Both you and IFC consent to venue and personal jurisdiction in the aforementioned courts for any litigation permitted under these Terms, and you waive any objection that such courts are an inconvenient forum.

13.9 Jury Trial Waiver

IF FOR ANY REASON A CLAIM PROCEEDS IN COURT RATHER THAN IN ARBITRATION, YOU AND IFC WAIVE ANY RIGHT TO A JURY TRIAL TO THE FULLEST EXTENT PERMITTED BY LAW. THAT IS, A JUDGE WILL DECIDE THE CASE, NOT A JURY. YOU UNDERSTAND THAT BY AGREEING TO THIS WAIVER, YOU ARE GIVING UP ANY CONSTITUTIONAL OR STATUTORY RIGHT TO HAVE A TRIAL BY JURY FOR A DISPUTE.

13.10 Confidentiality of Arbitration

Any arbitration conducted pursuant to these Terms shall be considered confidential, including the existence of the arbitration, any non-public information provided during the arbitration, and any communications (oral or written) relating to the arbitration. You and IFC agree to maintain confidentiality unless otherwise required by law or to enforce an arbitration award in court. Notwithstanding the foregoing, you or IFC may disclose to the arbitrator and the AAA any information necessary to facilitate the arbitration process, and may disclose information about the arbitration to your or our respective attorneys, tax advisors, or immediate family members (who themselves must agree to keep such information confidential).

14. General Provisions

14.1 Entire Agreement

These Terms (including any documents incorporated by reference, such as the Privacy Policy, and any additional terms provided by us for specific services or features) constitute the entire agreement between you and IFC regarding the Service and supersede all prior or contemporaneous understandings and agreements, whether written or oral, regarding the subject matter. Any additional or different terms proposed by you (for example, in a purchase order or an email) are expressly rejected and will not bind IFC unless IFC has agreed to them in a written amendment signed by an authorized representative of IFC.

Note: If you or your organization have signed a separate written agreement with IFC covering your use of the Service (such as an Enterprise Agreement or Partner Agreement negotiated and executed by both parties), that agreement may supersede or supplement these Terms to the extent of any direct conflict for the specifically covered subject matter. In all other cases, these Terms govern.

14.2 Amendments and Waivers

Except as provided in Section 1.3 (Changes to Terms) regarding updates by IFC, any amendment or modification of these Terms must be in writing and agreed by both parties. IFC’s failure to insist on or enforce strict performance of any provision of these Terms shall not be construed as a waiver of any provision or right. No waiver by IFC of any term or condition of these Terms will be effective unless in writing and signed by IFC, and any such waiver will not be deemed a waiver of any future or other breach. Similarly, any delay or omission by IFC in exercising any right or remedy under these Terms does not impair such right or remedy or constitute a waiver thereof.

14.3 Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court or arbitrator of competent jurisdiction, that provision shall be enforced to the maximum extent permissible or reformed (if permissible) to reflect as nearly as possible the original intentions of the parties, and the remaining provisions shall continue in full force and effect. If, however, an essential provision (such as the arbitration clause’s prohibition of class actions) is ruled unenforceable and cannot be modified, then the affected section may be stricken in its entirety and the remainder of these Terms enforced as if that section were not part of the original Terms.

14.4 Assignment

You may not assign or transfer these Terms or any of your rights or obligations hereunder, whether by operation of law or otherwise, without IFC’s prior written consent. Any attempt by you to assign these Terms without consent will be null and of no effect. IFC may freely assign or transfer these Terms (in whole or in part) to any of its affiliates or in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of its assets related to these Terms, without your consent. We will notify you if such a transfer occurs. These Terms shall bind and inure to the benefit of the parties, their successors, and permitted assigns.

14.5 Relationship of the Parties

Nothing in these Terms shall be construed as creating any agency, partnership, joint venture, or other form of joint enterprise between you and IFC. You and IFC are independent contractors. You have no authority to act on behalf of or bind IFC, and vice versa. Each party is responsible for its own expenses and obligations associated with the performance of this Agreement. You also agree that there are no third-party beneficiaries to these Terms (except for IFC’s affiliates as expressly provided and indemnified parties as applicable); no other person or entity shall have any rights under these Terms.

14.6 Force Majeure

IFC shall not be liable for any delay or failure to perform any obligation under these Terms (except payment obligations) if the delay or failure is due to unforeseen events which occur after these Terms become effective and which are beyond IFC’s reasonable control, such as acts of God, natural disasters, pandemic or epidemic events, war, terrorism, riots, embargoes, strikes or other labor disturbances, electrical, internet or telecommunications outages, blockchain network-wide failures, or government actions. In such event, we will use reasonable efforts to mitigate the impact and resume performance as soon as possible, and the time for our performance will be extended for the duration of the force majeure event.

14.7 Notices

To You: IFC may provide notifications or notices to you under these Terms via email to the address associated with your account, by postal mail, by postings within the Service interface, or by other legally accepted means. For example, we may send you notices of updates to these Terms, security notices, or other legally required information. It is your responsibility to keep your contact information (especially email) up to date. Notices sent by email will be deemed given 24 hours after the email is sent, unless we receive notice that the email address is invalid. Notices posted in the Service interface or delivered via other electronic means are deemed given upon posting or transmission. For physical mail, we will use the billing or contact address on file and such notice will be deemed given upon receipt or 3 business days after mailing (for domestic U.S. mail) or 7 business days after mailing (if international).

To IFC: You must send any formal legal notices or claims to us at the following address (our “Notice Address”):

International Firearms Currency, LLC  

Attn: Legal Department  

1234 Compliance Way, Suite 100  

Albuquerque, New Mexico 87101, USA

(Note: The above address is provided for illustration; please use the official address as listed on our website or corporate registry if different.)

With a copy via email to: legal@ifcurrency.com

Notices will be deemed given when received by us at the above address. For communications that are not of a legal nature (for example, general customer service inquiries), you may contact us via the methods provided on our website (such as a support email or contact form), and we will direct your inquiry to the appropriate team.

14.8 Export Controls

The Service, including any software we provide, and any related technology or technical data, may be subject to United States export control and economic sanctions laws, as well as similar laws in other jurisdictions. You agree to comply with all such laws and regulations as they relate to your access and use of the Service. You shall not, without prior U.S. government authorization, export, re-export, or transfer any part of the Service or any underlying information or technology to any country, person, or entity subject to U.S. export restrictions. This includes not using the Service for the benefit of any entity or in any country that is embargoed or sanctioned by the U.S. (as of the date of last update, such countries include, for example, North Korea, Iran, Syria, Cuba, and the Crimea region, among others), and not providing access to the Service to persons on restricted lists (like the U.S. Commerce Department’s Denied Persons List, Entity List, or the Treasury Department’s SDN list).

By using the Service, you represent and warrant that you are not located in, under the control of, or a national/resident of any such prohibited country and that you are not on any restricted list. This export control clause shall survive termination of these Terms.

14.9 U.S. Government Users

The Service and accompanying documentation are deemed to be “commercial computer software” and “commercial computer software documentation” pursuant to applicable Federal Acquisition Regulation (FAR) and Department of Defense FAR supplement provisions. Any use of the Service by the U.S. Government shall be governed solely by these Terms.

14.10 No Endorsement

Reference to any product, service, organization, or government entity in the Service (for instance, via integration or data source) does not constitute an endorsement by IFC. Likewise, any views expressed by users of the Service do not necessarily represent our views. We do not certify the identity of users or the truthfulness of data provided by users beyond what is stated in these Terms and our compliance procedures.

14.11 Equitable Remedies

You acknowledge that a breach of certain provisions of these Terms (such as misuse of our intellectual property or unauthorized access to the Service) could result in irreparable harm to IFC for which monetary damages would not be an adequate remedy. Thus, in the event of such a breach or threatened breach, IFC is entitled to seek injunctive or other equitable relief (without the requirement to post a bond) in addition to any other remedies available at law.

14.12 Headings and Interpretation

The section headings in these Terms are for convenience only and have no legal or contractual effect. “Including” means “including without limitation,” and similar terms shall be interpreted as inclusive, not limiting. Any ambiguities in the interpretation of these Terms shall not be construed against the drafter (i.e., these Terms will not be interpreted for or against one party due to authorship).

14.13 Language

These Terms are written in the English language. If we provide a translation of these Terms into another language, it is for convenience only. In the event of any conflict or inconsistency between the English version and any translation, the English version shall control. All communications and notices to be made or given pursuant to these Terms must be in English.

14.14 Contact Information and Customer Support

If you have any questions about these Terms, the practices of IFC, or your dealings with the Service, or if you need to contact us for any reason not already specified above, you can reach us at:

• Email: support@ifcurrency.com

• Mail: International Firearms Currency, LLC – Customer Support, at the address in Section 14.7.

We will do our best to respond to inquiries promptly and help resolve any issues.

By using the IFC Service, you acknowledge that you have read and understood these Terms and agree to be legally bound by them. Thank you for taking the time to familiarize yourself with our Terms and for using International Firearms Currency’s blockchain-based services responsibly and lawfully.