Acceptable Use Policy

1. PURPOSE

Cakto Commerce OÜ, a private limited company duly organized and existing under the laws of the Republic of Estonia, with its registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Tartu mnt 67/1-13b, 10115, Estonia (“CAKTO”, “we”, “our” or “us”), acting as Merchant of Record for its international operations, sets forth this Acceptable Use Policy (“AUP”) to define prohibited activities, content, and conduct in connection with the use of the CAKTO platform and related services (collectively, the “Platform”). This AUP applies to all users, transactions, products, and services accessed, offered, or processed through the Platform within the scope of CAKTO’s international operations.

2. GENERAL GUIDELINES

CAKTO may, at any time and at its sole discretion, with or without prior notice, remove, restrict, suspend, or disable any content, product, account, or access to the Platform if it determines that any activity, conduct, or offering violates this Acceptable Use Policy (“AUP”), the applicable Terms of Use, or any other agreement governing the use of the Platform, including activities conducted outside the Platform that may directly or indirectly affect CAKTO, its users, payment partners, or the integrity of its services.

Capitalized terms used in this AUP and not otherwise defined herein shall have the meanings assigned to them in the Terms and Conditions for Buyers and Sellers, as made available by CAKTO through its Platform or official website.

CAKTO reserves the right, but not the obligation, to monitor, review, investigate, and analyze any content, transactions, communications, or usage of the Platform in order to ensure compliance with this AUP, the Terms of Use, applicable laws, and any contractual obligations. Such monitoring may occur at any time and through automated or manual means.

Any determination by CAKTO regarding a violation of this AUP shall be final and binding. CAKTO’s decision to enforce, partially enforce, or refrain from enforcing this AUP in any particular instance shall be made at its sole discretion and shall not constitute a waiver of its rights in any other instance.

If you believe that any user, product, or activity on the Platform violates this AUP, you may report such conduct by contacting CAKTO at denuncias@cakto.com.br.

3. PROHIBITED ACTIVITIES AND GOODS

Users may not offer, promote, sell, or distribute any products, services, content, or activities that fall within the categories listed below.

3.1 Illegal or Dangerous Activities

Any activity involving illegal, criminal, or dangerous goods or services is strictly prohibited, including but not limited to:

• Illegal drugs, narcotics, controlled substances, or drug paraphernalia;

• Firearms, ammunition, explosives, weapons, or weapon components;

• Human trafficking, forced labor, organ trade, or any form of exploitation;

• Unlicensed or illegal medical, pharmaceutical, or health-related services;

• Stolen, robbed, or illegally obtained goods;

• Activities that infringe intellectual property rights, including piracy, counterfeiting, replicas, or unauthorized distribution of copyrighted materials.

3.2 Violence and Physical Harm

Content or services that depict, promote, glorify, or incite violence or physical harm are prohibited, including but not limited to:

• Acts of physical aggression, torture, abuse, or bodily injury;

• Content intended to shock, disturb, or provoke disgust;

• War, terrorism, extremist acts, riots, or violent protests;

• Self-harm, suicide, or encouragement of such behavior;

• Graphic medical procedures, corpses, or severe injuries.

3.3 Sexual or Obscene Content

The Platform may not be used to offer or distribute content or services of a sexual, pornographic, or obscene nature, including but not limited to:

• Pornography, prostitution, escort services, or sexual exploitation;

• Explicit sexual acts or nudity intended for sexual arousal;

• Distribution of sensual or adult content through restricted channels, including private groups, members-only areas, messaging applications, or social networks.

3.4 Hate Speech and Discrimination

Users may not promote, support, or condone hate, discrimination, or violence against individuals or groups based on race, ethnicity, nationality, religion, age, gender, sexual orientation, disability, medical condition, or any other protected characteristic.

This prohibition also applies to content or services associated with organizations, movements, or individuals that promote or encourage such conduct.

3.5 Financial Schemes and Investment-Related Activities

The Platform may not be used to promote or facilitate:

• Pyramid schemes, Ponzi schemes, or unlawful multi-level marketing structures;

• Investment offerings, securities, shareholdings, fundraising activities, or business opportunities primarily intended to attract investors rather than to provide lawful digital products or services;

• Any activity that circumvents financial regulations or misrepresents financial opportunities.

3.6 Promised Results, Guarantees, and Misleading Claims

Users may not offer, promote, or sell products or services that are based on promises of guaranteed results, unrealistic benefits, or outcomes that cannot be objectively substantiated, including but not limited to:

• Services claiming to remove, conceal, or “clean” negative credit records or credit bureau history;

• Products or systems that promise fuel savings or energy efficiency through unproven, non-certified, or pseudoscientific technologies;

• Offers guaranteeing success, winnings, or profits from lotteries, gambling, betting, or games of chance;

• Health, wellness, or medical-related claims that promise cures, treatments, or results without validation by recognized, qualified, or regulatory-approved institutions;

• Services that promise artificial, automated, or guaranteed growth of social media metrics, including followers, likes, views, engagement, or reach;

• Schemes or mechanisms that claim guaranteed income or profits through giveaways, automated distribution systems, or bots, including so-called “giveaway bots,” “Pix bots,” or similar arrangements.

Any product or service that creates false expectations, misleads Buyers, or induces decisions based on deceptive, unverifiable, or exaggerated claims is strictly prohibited.

3.7 Restricted or Regulated Goods

Users may not offer goods or services that are subject to legal, regulatory, or governmental restrictions without proper authorization, including:

• Products requiring governmental approval, certification, or registration;

• Goods withdrawn from the market by authorities or manufacturers;

• Products restricted to specific audiences without proper disclosures;

• Any goods or services whose commercialization violates applicable laws or regulations.

3.8 Environmental and Animal Protection Violations

The sale or promotion of goods or services that violate environmental, wildlife, or animal protection laws is prohibited, including but not limited to:

• Trade involving endangered species, protected flora or fauna, or their derivatives;

• Activities involving animal cruelty, mistreatment, or exploitation;

• Products derived from prohibited hunting, trafficking, or environmental harm.

3.9 Privacy, Data Protection, and Personality Rights

Users may not offer or distribute products, services, or content that violate privacy, data protection, or personality rights, including:

• Unauthorized use, sale, or distribution of personal data, mailing lists, or databases;

• Disclosure of personal, confidential, or sensitive information without lawful consent;

• Conditioning transactions on the disclosure of personal passwords, authentication credentials, or other non-transferable access data;

• Use of images, voices, names, or likenesses of third parties without proper authorization.

3.10 Harassment, Abuse, and Cyberbullying

Any form of harassment, intimidation, threats, abusive conduct, or cyberbullying directed at individuals or groups is strictly prohibited.

3.11 Malicious or Deceptive Technical Practices

Users may not engage in activities that compromise security or trust, including:

• Distribution of malware, spyware, phishing schemes, or harmful code;

• Deceptive commercial practices or fraudulent representations;

• Activities that disrupt, interfere with, or harm the Platform, its infrastructure, or third-party service providers.

3.12 Terrorism and Extremism

The Platform may not be used to promote, support, finance, or imply affiliation with terrorist organizations, extremist groups, or activities prohibited under applicable laws.

4. REPLICAS AND COUNTERFEIT GOODS

CAKTO is committed to maintaining the integrity of its Platform and protecting Users from unlawful, deceptive, or infringing practices. The offering, promotion, or sale of replicas, counterfeit goods, or any products that infringe the intellectual property rights of third parties is strictly prohibited.

This prohibition includes, but is not limited to:

a) Replicas or imitations of products associated with recognized or registered brands;

b) Products that use trademarks, logos, trade dress, or brand identifiers without proper authorization from the rights holder; and

c) Products that violate copyrights, patents, industrial designs, or any other intellectual property rights of third parties.

Merchants are solely and exclusively responsible for ensuring that all products and services offered through the Platform are authentic, lawful, and do not infringe third-party rights.

CAKTO reserves the right, at its sole discretion, to remove any product, service, or content that violates this Acceptable Use Policy and to apply corrective or disciplinary measures, including suspension or termination of accounts, withholding of transactions, and other actions deemed necessary, without prejudice to additional legal remedies.

Users are encouraged to report suspected replicas or counterfeit goods through CAKTO’s compliance channel at compliance@cakto.com.br, enabling appropriate review and enforcement measures.

5. CHANGES AND UPDATES TO THIS POLICY

CAKTO reserves the right to amend, update, or modify this Acceptable Use Policy (“AUP”) at any time, at its sole discretion. Any updated version will become effective upon publication on CAKTO’s official channels.

By continuing to access or use the Platform after any changes to this AUP become effective, you acknowledge and agree to be bound by the most current version of this Policy.

In the event of any inconsistency or conflict between this AUP and other applicable terms, policies, or agreements governing the use of CAKTO’s Platform, this AUP shall prevail solely to the extent necessary to resolve such conflict.

6. MISCELLANEOUS

This Acceptable Use Policy enters into force on the date of its publication and shall remain valid for an indefinite period.

This AUP must be read and interpreted in conjunction with CAKTO’s other applicable policies and contractual documents, including but not limited to its Terms and Conditions and Privacy Policy, which together govern the use of the Platform.