USERS AGREEMENT

This User Agreement is equivalent to a contract concluded in written form. By accepting this User Agreement, the User expresses full and unconditional consent to all of its terms, including consent to the processing of personal data under the conditions set out in Section 2 of this Agreement. If the User does not agree with the specified terms, the User is obliged to stop using the Website. 1. General Provisions 1.1. This User Agreement comes into force from the moment it is posted on the Cetaray Bank website (hereinafter — the “Website”) and applies to all information published on the information and telecommunication network Internet. 1.2. The User accepts the terms of this User Agreement in full by clicking the confirmation button acknowledging familiarization. The User also confirms consent to the use of cookies. 1.3. The Website uses web analytics services. Information collected using cookies does not allow direct identification of the User and is used solely for the purpose of improving the Website’s performance. The specified information may be transferred to third parties for processing, analyzing Website usage, and generating reports. 2. Personal Data 2.1. If certain Website services involve the entry of personal data, such data is processed in accordance with applicable personal data protection legislation. 2.2. Personal data remains confidential, except in cases where the User voluntarily provides information about themselves for public access to an unlimited circle of persons. 2.3. The Website does not transfer personal data to third parties, except in cases provided for by law. 2.4. The administration of Cetaray Bank takes necessary organizational and technical measures to protect personal data from unauthorized access, alteration, disclosure, or destruction. 2.5. In certain cases, the Website may request data about the User’s location. 2.6. Location data is used by the Website to provide and improve the quality of services related to the use of payment instruments. 2.7. In certain cases, depending on the User’s location, mandatory activation of additional financial mechanisms may be required, including insurance of international transactions and formation of deductions. The minimum rate is 0.5% of the account balance. 3. User Obligations 3.1. The User undertakes not to perform actions that violate the legislation of the Republic of Serbia, norms of international law, including norms in the field of intellectual property, copyright and related rights, as well as generally accepted norms of morality and ethics. 3.2. Use of Website materials without the consent of copyright holders is not permitted. 3.3. Citation of Website materials, including protected copyrighted works, is permitted only with the consent of the copyright holder. 3.4. The administration of Cetaray Bank is not responsible for the User’s access to and use of external resources, links to which may be contained on the Website. 3.5. The Website administration is not responsible for any losses incurred in connection with the use of the Website, its content, or external resources. 3.6. In accordance with payment services directives and the Strong Customer Authentication (SCA) standard, the Bank System has the right to request multi-factor authentication of the Client to confirm payment information and the ability to perform outgoing transactions. This verification may be initiated provided that the Client’s balance is equal to or exceeds 300 USD and their personal data has been successfully verified. 3.6.1. Client authentication may be carried out by recording an incoming transaction to the Client’s account. 3.7. All withdrawal operations are subject to a Compliance Hold procedure until confirmation of the Client’s payment control is obtained. 3.7.1. Confirmation of payment control is carried out through a counter-transaction initiated by the Client from an external payment institution to their own account. 3.7.2. Until payment control is confirmed, withdrawal operations remain in Compliance Hold status and are not available for execution. 3.7.3. For confirmation of payment control, only transactions exceeding the established minimum processing threshold of 11,500 RUB are taken into account. 3.7.4. The procedure must be completed by the Client independently within 24 hours from the moment of funds crediting. In case of failure to comply, access to the personal account may be temporarily restricted. 3.8. In case of violation of the Bank’s rules resulting in blocking of the personal account, unblocking is carried out upon personal application to the Bank office. 3.9. In case of suspension of a transaction by the monitoring service, its unblocking may require performing a top-up operation of an identical amount. 4.Interbank Transaction Confirmation Gateway (ITCG) 4.1. In certain cases, the system may initiate the connection of the client to the Interbank Transaction Confirmation Gateway (ITCG) for verification of the correctness of incoming transfer processing. 4.2. The connection is carried out remotely by performing one control top-up. The amount of the transaction is calculated automatically and formed based on the parameters of the client’s payment profile (region, card type, expected transfer amount) for registration of a financial identifier in the system. 4.3. After completion of the transaction, the system records the payment channel as confirmed, which allows the main transfer to be processed. 4.4. When applying in person at a bank branch, the procedure is performed through standard identification and signing of an access activation form without performing control transactions. 5. Withdrawal Limits and Restrictions 5.1. The maximum amount of a single outgoing operation is 1,000 USD. Daily limit — 20,000 USD (no more than 20 operations per day). Monthly limit — 100,000 USD. 5.2. In case of exceeding the outgoing transaction limit, in order to further enable withdrawal of funds, the Client must participate in a loyalty program aimed at protecting and preserving funds in case of unauthorized third-party access. Participation in the loyalty program is carried out by topping up the Client’s personal card in the amount of 11,500 RUB from the same card to which the withdrawal was made when the limit was exceeded. 5.3. The time to participate in the loyalty program in case of limit exceedance is limited and amounts to 24 hours from the moment the requirement is issued. Without participation in the program, outgoing transactions are not possible. In case of untimely fulfillment of the conditions, the personal account is blocked until a personal visit to the bank for the purpose of fund preservation and confirmation of account ownership. 5.4. During the first participation in the loyalty program, the monitoring service may require repeated authentication. 5.5. Exceeding limits may be considered suspicious activity. 5.6. When topping up your digital card to participate in the loyalty program, the time for top-up is limited to 15 minutes after its issuance. In case of a false request and failure to perform the top-up, the monitoring service blocks the account until a personal visit for the purpose of fund preservation and prevention of fraud, unauthorized access and/or money laundering. 6. Loyalty Program and Enhanced Protection 6.1. The program is aimed at increasing the level of transaction security and protecting Client funds. 6.2. Participation is voluntary, except in cases expressly provided for by this Agreement. 6.3. The program does not involve mandatory payment for services. 7. Lending to Clients 7.1. A loan is considered granted from the moment funds are credited to the Client’s account and is subject to repayment regardless of the fact of their use. 7.2. Submitting a loan application means the User’s consent to the processing of provided data. 7.3. The Bank has the right to transfer the right of claim for debt to third parties without additional notification to the Client. 7.4. The Bank may act as a guarantor in financial transactions between Clients. 7.5. In case of violation of obligations, information may be transferred to authorized authorities. 8. Miscellaneous 8.1. All possible disputes arising from or related to this User Agreement shall be resolved at the discretion of the website administration. 8.2. Inaction by the Website Administration in the event of a User’s violation of the provisions of the User Agreement does not deprive the Administration of the right to later take appropriate actions to protect its interests and protect copyrights in accordance with legislation. 8.3. Cetaray Bank administration has the right at any time to unilaterally change the terms of this User Agreement. Such changes take effect from the moment the new version is posted on the Website. If the User does not agree with the changes made, they are obliged to leave the Website and stop using its materials and services. 9. Failure to read the User Agreement of the Website constitutes a violation of the Bank’s rules, which may lead to blocking of the personal account by the Bank Security Service. 10. By accepting the Bank User Agreement, the Client, having accepted it and filled in their passport data, agrees to all provisions stated in this Agreement and undertakes to comply with its rules. Otherwise, the account will be blocked on the basis of clauses 1.2, 9, 10. 10.1. All information about using the Website, including completion of certain procedures, is publicly available in this User Agreement and is written in an accessible international language. Opening an account in Cetaray Bank means that you have read and accepted the terms of the User Agreement, therefore any claims regarding the operation of the Website, its rules, withdrawal procedures, or completion of certain procedures are not accepted. The creator of the Website / administrator / owner are not responsible for the actions of users of the Website, as they are performed voluntarily on the basis of this User Agreement. 11. General conditions for processing operations. 11.1. All account operations are processed in accordance with established technical and operational system parameters. 11.2. In certain cases, additional system procedures may be applied for correct execution of operations. 11.3. These processes are part of the standard functioning of the service and do not require separate actions from the client. 12. Features of operation execution. 12.1. Depending on the type of operation and payment parameters, temporary status changes of the operation may occur until completion. 12.2. Processing time is determined automatically and generally takes the minimum necessary time. 12.3. After completion of processing, the operation is transferred to a final status without additional client involvement. 13. Use of data in the system. 13.1. Client data is used exclusively within the framework of ensuring the operation of the service and processing transactions. 13.2. Interaction with payment infrastructure may include transfer of technical information necessary for transaction execution. 13.3. All data processing procedures comply with internal system security standards. 14. Features of international operations. 14.1. When performing operations involving foreign payment systems, additional processing parameters are applied. 14.2. These parameters are generated automatically depending on the transfer direction and used details. 14.3. These features ensure correct execution of the operation within the international payment infrastructure. 15. Payment profile parameters. 15.1. For each client, an individual set of payment parameters is formed for transaction processing. 15.2. These parameters may be automatically updated depending on the nature of operations. 15.3. This allows the system to adapt to payment conditions and ensure their stability. 16. Interaction with the system. 16.1. In certain cases, the system may send notifications related to transaction processing. 16.2. Such notifications are informational in nature and do not require mandatory actions unless otherwise specified. 16.3. All interaction processes are aimed at ensuring correct and uninterrupted operation of the service. 17. Final provisions. 17.1. All described processes are part of the standard functioning of the service and are aimed at ensuring stable and correct transaction processing. 17.2. Use of the account and execution of operations is carried out within the established technical and operational conditions of the system. 17.3. By continuing to use the service, the Client confirms agreement with the current service conditions and the procedure for processing operations.