1.1 The Gate Account Protection Plan (the "Plan") is a voluntary account security mechanism operated by Gate ("Company", "we", "us" or "our") in respect of your Gate account (the "Account") on the Gate platform (the "Platform"). It is described in these Gate Account Protection Plan – Terms and Conditions (these "Terms") and on the Plan Page.

1.2 The Plan is operated solely by us. No affiliate or group company of ours, and no officer, employee or agent of ours or of any such affiliate or group company, has any obligation or liability to you under or in connection with the Plan.

1.3 Where you have activated the Plan, satisfied the Security Requirements and the other conditions in these Terms, and Digital Assets are lost from your Account through an Unauthorized Transaction, we may make a Reimbursement up to the applicable limit. Whether to make a Reimbursement, and the amount of any Reimbursement, are determined by us at our discretion in accordance with Section 8. Nothing in these Terms obliges us to make a Reimbursement in any case.

1.4 By activating the Plan, you confirm that you have read, understood, and accepted these Terms, the Plan Page, our User Agreement (which can be viewed at https://www.gate.com/user-agreement), Privacy Policy (which can be viewed at https://www.gate.com/privacy-policy), Risk Disclosure (which can be viewed at https://www.gate.com/risk-disclosure), and any and all other rules or policies published on Gate's websites. If you do not agree to be bound by these Terms, do not activate the Plan.

1.5 Capitalised terms not defined in these Terms have the meaning given in the User Agreement. In the event of any inconsistency between these Terms and the User Agreement, these Terms prevail in relation to the Plan only. The Plan Page and the Plan Rules form part of the Plan and may be updated by us in accordance with Section 11; in the event of any inconsistency between these Terms, on the one hand, and the Plan Page or the Plan Rules, on the other, these Terms prevail.

1.6 The Plan applies only to Digital Assets held by us on your behalf in your Account. It does not apply to Digital Assets held in any self-custodial wallet, Web3 wallet, hardware wallet, or any account, wallet, venue or platform not operated by us, in respect of which you retain full custody of your private keys and sole responsibility for their security.

1.7 The Plan is free of charge. You pay no fee, premium, subscription or other consideration for the Plan. The Plan is not a component of, and is not conditional upon, any paid service, subscription, membership tier, VIP level, trading volume, asset holding, staking arrangement or other purchase, and no fee payable by you to us is attributable to it in whole or in part. Activation is by you and the Plan is not applied to any Account automatically.

1.8 The Plan is offered only to Users resident in an Eligible Jurisdiction. We determine your jurisdiction of residence by reference to the information held on your Account and our own records. No Reimbursement will be provided in respect of a User who is not resident in an Eligible Jurisdiction at the time of the Unauthorized Transaction.

2. The Plan is Not Insurance

THE PLAN IS NOT A CONTRACT OF INSURANCE. IT IS NOT UNDERWRITTEN BY ANY INSURER. WE DO NOT ACT AS AN INSURER, AN INSURANCE INTERMEDIARY OR A DISTRIBUTOR OF INSURANCE IN OFFERING IT, AND WE DO NOT HOLD AND DO NOT PURPORT TO HOLD ANY INSURANCE LICENCE OR AUTHORISATION IN CONNECTION WITH IT. THE PLAN IS NOT A GUARANTEE, SURETY, INDEMNITY, WARRANTY, DEPOSIT OR FINANCIAL PRODUCT OF ANY KIND. THE PLAN DOES NOT RESPOND TO MANY KINDS OF LOSS THAT INSURANCE IS DESIGNED TO COVER, INCLUDING LOSS CAUSED BY MARKET MOVEMENTS, BY YOUR OWN ACTS OR OMISSIONS, OR BY EVENTS OUTSIDE OUR SYSTEMS AND SECURITY CONTROLS. YOUR DIGITAL ASSETS ARE NOT PROTECTED BY ANY GOVERNMENT-BACKED DEPOSIT PROTECTION OR INVESTOR COMPENSATION SCHEME. IF YOU WISH TO OBTAIN INSURANCE IN RESPECT OF YOUR DIGITAL ASSETS, YOU SHOULD APPROACH A LICENSED INSURER OR INSURANCE BROKER INDEPENDENTLY. THE PLAN IS NOT A SUBSTITUTE FOR INSURANCE, AND IS NOT A SUBSTITUTE FOR MAINTAINING THE SECURITY OF YOUR OWN ACCOUNT.

2.1 Nothing in these Terms creates any trust, fund, pool or segregated account for your benefit, and you have no interest in, or claim against, any of our assets by reason of the Plan. No assets are set aside, earmarked, reserved or held by us for the purpose of making Reimbursements.

2.2 The following are determined by us at our discretion, in accordance with these Terms: (a) whether the conditions set out in these Terms are satisfied; (b) whether to make a Reimbursement at all; and (c) the amount of any Reimbursement. Reimbursement is made as a voluntary programme benefit under these Terms and not in satisfaction of any obligation arising outside them.

2.3 The Plan is a voluntary arrangement made by us. Nothing in these Terms, and no making of Reimbursement, constitutes an admission of liability or fault on our part in respect of any event, nor does it vary, extend or reduce our liability, or the limitations on it, under the User Agreement. The Plan creates no legal or equitable right or entitlement to Reimbursement, and no representation on which you may rely, except as expressly set out in these Terms. The benefit of the Plan is personal to you and is not transferable or assignable.

2.4 No duty of prevention. The Plan does not create, and is not evidence of, any duty on our part to prevent, detect, block or reverse unauthorized access to your Account or any Unauthorized Transaction. Your obligations in respect of the security of your Account under the User Agreement are unaffected by the Plan.

2.5 No reliance. You acknowledge that in opening or maintaining your Account, and in deciding what Digital Assets to hold in it, you have not relied on the existence, scope or continuation of the Plan, and that the Plan is not a substitute for maintaining the security of your Account or for insurance obtained by you.

2.6 No precedent. The making of a Reimbursement in any case does not create any precedent, practice, entitlement or expectation in respect of any other case, whether for you or for any other User. We may reach different determinations in cases with similar facts, and no such difference gives rise to any claim.

3. Definitions

3.1 In these Terms:

"Account" means your Gate user account;
“Agent" means any automated agent, bot, script, command-line interface, Model Context Protocol client or other software or service that initiates instructions on your Account, whether operated by you or by any third party;
"Applicable Laws" means all legally binding laws, statutes, regulations, subordinate legislation, orders and decrees of any governmental, regulatory or supervisory authority, and any judgments, decisions and injunctions of any court or tribunal, in each case having jurisdiction over the matter in question;
"Digital Assets" has the meaning given in the User Agreement;
"Eligible Jurisdiction" means a jurisdiction designated by us on the Plan Page in accordance with Section 17 as one in which the Plan is offered;
"Eligible Loss" means the Digital Assets lost through an Unauthorized Transaction, less any Digital Assets that have been recovered, frozen, returned or are capable of recovery from any source, and excluding any fees, taxes, opportunity cost, financing cost, loss of profit, loss arising from any change in the value of any Digital Asset, and any indirect or consequential loss;
“Gate”, “we”, “us” or “our” means the Gate group entity operating the relevant Plan;
"Good Standing" means, in respect of an Account, that the Account is not suspended, restricted, frozen, blacklisted or under investigation by us or by any competent authority, and is not in breach of the User Agreement or these Terms, in each case as determined by us;
"KYC Identity" means the verified identity under which an Account is registered with us, together with all Accounts, master accounts and sub-accounts registered under that same identity;
"Plan" means the Gate Account Protection Plan, being the account security mechanism operated by us under these Terms, as described in Section 1;
"Plan Page" means the Gate Account Protection Plan page published on the Platform, including the plan rules, scoring rules, Security Requirements, limits and Eligible Jurisdictions published there from time to time;
"Plan Rules" means the rules published on the Plan Page describing the operation of the Plan;
"Plan Status" has the meaning given in Section 5;
"Platform Security Incident" means a security incident that primarily affects the systems, infrastructure, wallets, or other core security controls of the Platform and is designated by us in our sole discretion as a platform-wide incident rather than an account-specific compromise, whether or not any other recovery mechanism is in fact applied;
"Reimbursement" means a discretionary payment made by us under the Plan and is not a restitutionary payment, does not represent the full amount of any loss, and is assessed and determined in accordance with Sections 8.2 and 8.8;
"Request" means an application by you for a Reimbursement under the Plan;
"SAFU" means the Security Asset Fund for Users operated by Gate or a member of its group, as described on the Platform from time to time;
"Security Requirements" means the account security settings and configurations set out in Section 18 and on the Plan Page;
"Security Score" means the score calculated by us for your Account in accordance with the scoring rules published in summary form on the Plan Page;
"Unauthorized Transaction" means a transfer of Digital Assets out of your Account through a transaction channel identified in Section 6.1, which was initiated by a person other than you, without your authorization, approval, confirmation, knowledge or participation, and which you did not enable by providing that person with access to your Account, your credentials or your device. A transaction initiated, authorized, approved or confirmed by you is not an Unauthorized Transaction, whether or not you were deceived, induced, impersonated or coerced into doing so; and
"User" means the holder of an Account.

3.2 References in these Terms to a Gate product, feature or transaction channel by name are to the product, feature or channel of that name as described on the Plan Page from time to time.

3.3 In these Terms: (a) headings are for convenience only and do not affect interpretation; (b) the singular includes the plural and vice versa; (c) "including", "includes" and "in particular" are not words of limitation; (d) a reference to a Section is to a Section of these Terms; (e) a reference to a period of days is to calendar days unless otherwise stated; (f) a reference to time is to Coordinated Universal Time (UTC); (g) a reference to any document or rule is to that document or rule as amended or replaced from time to time; and (h) where any matter is stated to be determined, designated or assessed by us, it is determined, designated or assessed by us acting in our sole discretion.

4. Eligibility, Activation and Effectiveness

4.1 You may apply to activate the Plan if, at the time of application: (a) you have completed KYC Level 2 verification; (b) you are resident in an Eligible Jurisdiction; (c) your Security Score is 80 or above; (d) your Account is in Good Standing; (e) you have completed the security verifications required by the Plan; and (f) you satisfy our risk control and compliance requirements.

4.2 Each of the conditions in Section 4.1 must continue to be satisfied throughout your participation in the Plan. We may refuse any application to activate, and may revoke an activation, where any of those conditions is not or ceases to be satisfied, in each case without giving reasons.

4.3 On activation your Plan Status is Security Hardening. The Plan does not apply to any Unauthorized Transaction, and no Reimbursement will be provided, while your Plan Status is Security Hardening. Your Plan Status becomes Protection Active only when your Security Score has been at or above 80, and the Security Requirements have been continuously satisfied without change, for thirty (30) consecutive days. Only an Unauthorized Transaction initiated while your Plan Status is Protection Active may be considered for Reimbursement. The thirty (30) day period runs only while your Plan Status is Security Hardening. If your Security Score falls below 80, or any Security Requirement is changed in a manner described in Section 18.3, the period stops running and does not resume, and your Plan Status changes as set out in Section 5. No period is credited towards the thirty (30) days while your Plan Status is Plan Suspended or Plan Ended. A new thirty (30) day period begins from zero on the date your Plan Status next returns to Security Hardening, whether by restoration of your Security Score within the period allowed under Section 5.3 or by reactivation after your Plan Status has become Plan Ended.

4.4 No Reimbursement will be provided unless, during the thirty (30) days immediately before the Unauthorized Transaction, your Plan Status was Protection Active and your Security Score was not below 80, and the Security Requirements were continuously satisfied. Any interruption in your Security Score record causes the thirty (30) day period to restart from zero.

4.5 The Plan has no fixed term. Subject to Section 11, your activation continues for so long as your Security Score remains at or above 80, you continue to satisfy the Security Requirements, and your Plan Status has not become Plan Ended.

4.6 Activation is per Account. Whether the Plan has been activated, and the Plan Status at any time, are determined separately for a master account and for each sub-account, because the Security Requirements are configured separately for each account. Activation or Protection Active status of a master account does not confer either on any sub-account, and each sub-account must be separately activated. Where an Unauthorized Transaction occurs, eligibility is assessed by reference to the Plan Status and Security Score of the account from which the Digital Assets were transferred out. All Accounts registered under the same KYC Identity are treated as a single Account for the purposes of the limits in Section 8.

4.7 You may deactivate the Plan through any channel we make available for that purpose from time to time. Where no such channel is available, you may request deactivation by contacting customer support. If you deactivate the Plan and later reactivate it, the thirty (30) day period in Section 4.3 restarts from zero and no period completed before deactivation is carried over. We may decline to accept a reactivation within thirty (30) days of deactivation. Deactivation does not affect a Request properly submitted before it takes effect.

5. Plan Status

5.1 Your Account will be shown in one of the following Plan Statuses:

(a) "Security Hardening", meaning that you have activated the Plan but the thirty (30) day qualification period in Section 4.3 has not yet been completed;

(b) "Protection Active", meaning the thirty (30) day qualification period has been completed and your Security Score remains at or above 80 and the Security Requirements remain satisfied;

(d) "Plan Ended", meaning that your Security Score was not restored within the period set out in Section 5.3.

5.2 No Reimbursement will be provided in respect of an Unauthorized Transaction initiated while your Plan Status is Security Hardening, Plan Suspended or Plan Ended. The Plan Status applicable to a transaction is the Plan Status at the time the transaction instruction was accepted by our systems, and not the time of confirmation on any blockchain network.

5.3 If your Plan Status changes to Plan Suspended, you have forty-eight (48) hours from the time your Security Score fell below 80, as recorded by our systems, to restore it to 80 or above. We will use reasonable efforts to notify you of the change in Plan Status, but the forty-eight (48) hour period runs from the time recorded by our systems whether or not any notification is delivered, received or read.

5.4 If you restore your Security Score within that period, your Plan Status returns to Security Hardening and the thirty (30) day qualification period in Section 4.3 restarts from zero. No period completed before the suspension is carried over. If you do not, your Plan Status becomes Plan Ended. You may reactivate at any time once your Security Score is 80 or above, in which case the thirty (30) day qualification period in Section 4.3 restarts.

5.5 We may change the scoring rules, the Security Requirements and the qualifying threshold from time to time, including by reducing the score attributed to a security setting where the protection it provides has been weakened, or by scoring a setting by reference to its configured value. Any such change may cause your Security Score to fall below 80 and your Plan Status to change, and Section 11.1 applies to any such change. Your Plan Status will not change, and the thirty (30) day period in Section 4.4 will not restart, where the fall in your Security Score results solely from: (a) a material fault or data error in our systems that we identify as having caused the fall; or (b) a failure on our part to deliver a notification under Section 5.3. This Section does not apply where the fall in your Security Score is also attributable to any act or omission on your part.

5.6 We maintain a record of all Plan Status changes, including the time of and reason for each change. That record is conclusive evidence of your Plan Status at any given time, absent manifest error.

5.7 Any Plan Status displayed to you on the Platform is indicative only. Where a displayed Plan Status differs from the record maintained under Section 5.6, the record prevails, and no Reimbursement arises by reason of a displayed Plan Status that does not correspond to that record.

5.8 We may change your Plan Status at any time, and may suspend or end your participation in the Plan, where any condition in Section 4.1 ceases to be satisfied, where information you have provided is or becomes untrue or incomplete, where your Account is subject to a risk control measure or investigation, or where required by Applicable Laws.

6. Scope of the Plan

6.1 Subject to these Terms, the Plan applies only to the unauthorized withdrawal of Digital Assets from your Account by means of an on-chain withdrawal, GatePush or GateCode, in each case where an unauthorized third party has obtained access to your Account without your authorization and the loss arises directly from that access.

6.2 The following are minimum conditions. Satisfaction of all of them does not entitle you to Reimbursement; it makes a Request eligible for assessment under Section 8.2. We will not provide a Reimbursement unless all of the following are satisfied: (a) an Unauthorized Transaction has occurred; (b) your Plan Status was Protection Active at the time the transaction instruction was accepted by our systems; (c) the thirty (30) day requirement in Section 4.5 is satisfied; (d) none of the circumstances in Section 7 applies; (e) you have satisfied the requirements in Section 9; and (f) the Unauthorized Transaction resulted from a defect or deficiency in the operation of our process for determining whether the instruction was authorized.

6.3 Where an unauthorized transfer exceeds a withdrawal or transaction limit you have set, only the portion exceeding that limit is eligible for assessment. The portion within the limit falls outside the Plan. Where you have set no limit, no part of the transfer is eligible for assessment on this basis.

6.4 It is for you to establish, to our satisfaction, that the conditions in Section 6.2 are satisfied. Where you do not do so, we will not make a Reimbursement.

7. When the Plan Does Not Apply

7.1 Transactions you initiated. The Plan does not apply, and no Reimbursement will be made, in respect of: (a) any transaction, transfer or withdrawal that you initiated, authorized, approved, confirmed or participated in, including after being deceived, induced, impersonated or coerced by any person; (b) any loss arising from your own error, including a transfer to an incorrect address or over an incorrect chain; or (c) any disclosure of information, or any participation in the misappropriation of Digital Assets, arising from kidnapping, violence, coercion, robbery or a pyramid or multi-level marketing scheme.

7.2 Credentials, access and devices. The Plan does not apply, and no Reimbursement will be made, in respect of: (a) loss arising from your intentional or negligent disclosure of your password, verification code, fund password, security verification tool or other security credentials or device permissions to any third party; (b) intentional sharing of your Account login credentials with any third party; (c) lending your Account to, or permitting its use by, any other person; or (d) any transfer effected following your use of any remote control, remote desktop, screen sharing or equivalent tool.

7.3 Verification and limits. The Plan does not apply, and no Reimbursement will be made, in respect of: (a) any transfer of funds effected without completing the security verifications required under the Plan; (b) any transfer completed through a verification-free address or a free small-amount verification feature or a password-free feature; or (c) any transfer or trade completed within an applicable withdrawal or transaction limit.

7.4 Products and services outside the Plan. The Plan does not apply, and no Reimbursement will be made, in respect of: (a) any Digital Assets held in a Web3 wallet or any other self-custodial wallet; (b) any transfer of Digital Assets from an account held at another exchange or venue, or through any cross-exchange or CrossEx function; (c) any transaction or transfer of funds initiated through an Agent or through an API request; (d) any loss arising from red packets, tips, GatePay transactions, gift cards, securities position transfers, GateCard or GateConnect; (e) any Account that is an institutional, corporate, market-maker, brokerage or over-the-counter account, or any account operated on behalf of any third party; or (f) any C2C (P2P) trading or transaction; or (g) any product, feature or transaction channel identified on the Plan Page as falling outside the Plan.

7.5 Trading and changes in value. The Plan does not apply, and no Reimbursement will be made, in respect of: (a) any trading loss, including loss arising from market movement, your trading decisions, leverage, derivatives or liquidation; or (b) unauthorized activity within your Account that does not result in any transfer of Digital Assets out of your Account, including a conversion of one Digital Asset into another that is not followed by a transfer out of the Account.

7.6 Conduct, verification and eligibility. The Plan does not apply, and no Reimbursement will be made, in respect of: (a) any loss where the cause of the loss, or its amount, cannot be verified by us; (b) any loss where the identity verified under KYC for the Account does not correspond to the person actually using the Account; (c) any loss connected with unlawful conduct, fraud, false declaration, abuse of the Plan, or any other breach of our rules, whether in relation to the underlying event or the Request; or (d) any loss in respect of an Account that is not in Good Standing, or that is blacklisted or otherwise flagged by our risk controls, at the time of the event.

7.7 Platform incidents. The Plan does not apply, and no Reimbursement will be made, in respect of loss arising directly or indirectly from a Platform Security Incident, including a large-scale cyberattack on the systems or infrastructure of the Platform. This exclusion applies whether or not SAFU or any other recovery mechanism is in fact applied to the incident, and nothing in these Terms obliges us to apply SAFU or any other mechanism to any incident.

7.8 Failure to mitigate. No Reimbursement will be made in respect of any part of a loss that increased because you did not report the loss to us, or take reasonable steps to freeze or restrict your Account, promptly after becoming aware of it.

7.9 Separate programmes. The Plan is separate from SAFU and from any other recovery mechanism operated by us or by any member of our group. Each operates under its own terms, and eligibility under one does not confer eligibility under any other. No loss will be compensated more than once. Where any amount has been or will be paid to you in respect of the same loss under SAFU or any other mechanism, that amount is deducted from any Reimbursement; and where a Reimbursement has already been made, we may require repayment to the extent of any subsequent payment to you in respect of the same loss.

7.10 The circumstances listed in Sections 7.1 to 7.8 are not exhaustive. A loss does not fall within the Plan unless all of the conditions in Section 6.2 are satisfied, whether or not the circumstances giving rise to it are listed in this Section.

7.11 IF YOU ARE PERSUADED, TRICKED OR PRESSURED INTO AUTHORIZING, APPROVING OR CONFIRMING A TRANSACTION YOURSELF, THAT TRANSACTION IS NOT AN UNAUTHORIZED TRANSACTION AND NO REIMBURSEMENT WILL BE MADE, HOWEVER CONVINCING THE DECEPTION WAS. THIS INCLUDES IMPERSONATION OF OUR STAFF, ROMANCE AND INVESTMENT SCAMS, AND INSTRUCTIONS RECEIVED THROUGH SOCIAL MEDIA OR MESSAGING APPLICATIONS.

8. Reimbursement Limits and Calculation

8.1 There is no minimum loss threshold.

8.2 No fixed Reimbursement ratio applies. The amount of Reimbursement is assessed on the facts of each case, up to the applicable limit, having regard to the nature and extent of the Eligible Loss, the Security Requirements and Plan Status applicable at the time of the Unauthorized Transaction, the evidence concerning the compromise, any relevant act or omission by you, the speed and adequacy of your response after discovery of the loss, any amounts recovered or recoverable from other sources, and any other factors we consider relevant to the assessment.

8.3 The amount of Reimbursement will be reduced by any amount that you have recovered, that has been frozen or returned, or are able to recover, in respect of the same Eligible Loss from any other source.

8.4 The maximum amount of Reimbursement in respect of any one Unauthorized Transaction is the equivalent of two hundred thousand United States Dollars (USD 200,000), or such other amount as is published on the Plan Page from time to time. The limit applicable to an Unauthorized Transaction is the limit in effect on the date the transaction instruction was accepted by our systems.

8.5 The maximum aggregate amount of Reimbursement in respect of any one KYC Identity is twice the limit in Section 8.4, over the life of that KYC Identity. Subject to that aggregate limit, there is no restriction on the number of Requests you may make.

8.6 The limits in Sections 8.4 and 8.5 are shared between all Accounts registered under the same KYC Identity and between master and sub-accounts. Where a series of related transactions arises from the same underlying compromise, the same attack chain, or is otherwise connected, they may be treated by us as a single Unauthorized Transaction.

8.7 A Reimbursement may be made in such Digital Asset or equivalent value as we determine. The Plan is subject to an overall resource limit determined by us from time to time, and a Reimbursement is made only to the extent of the resources then available to the Plan. The Plan does not constitute a fund, pool or segregated arrangement, and you have no interest in or claim against any such resources.

8.8 The amount of any Reimbursement is the lowest of: (a) the verified direct net loss of Digital Assets, being the Eligible Loss less any Digital Assets recovered, frozen, returned or capable of recovery; (b) the amount remaining available under the per-incident limit in Section 8.4 for that Unauthorized Transaction; and (c) the amount remaining available under the lifetime limit in Section 8.5 for the KYC Identity under which the Account is registered.

8.9 Where Requests from more than one User relate to the same or connected events, or where the resources then available to the Plan are insufficient to meet all Requests, we may reduce, apportion, defer or decline any Reimbursement as we consider appropriate. No User has priority over any other by reason of the order in which Requests were submitted or assessed.

9. Request Procedure

9.1 Immediately upon becoming aware of an Unauthorized Transaction, you must notify us and take the steps we make available to freeze or restrict your Account. Any part of a loss that increased because you did not do so is excluded under Section 7.8.

9.2 You must submit your Request to us within forty-five (45) days of the date on which the suspected Unauthorized Transaction occurred. That period runs from the date of the transaction and is not extended by the date on which you became aware of it. A Request submitted after that period will not be assessed.

9.3 You must file a report in respect of the suspected Unauthorized Transaction with the law enforcement authority in your jurisdiction within forty-five (45) days of the date on which it occurred, and provide us with a copy of that report. Where the report is not in English, you must provide a translation at your own cost.

9.4 You must complete a security questionnaire, cooperate with our investigation, and provide transaction records, device information and any other material reasonably necessary for us to assess your Request. The information you provide must be truthful and complete. We may request further information at any time, may require you to participate in an interview, and may suspend assessment of your Request pending receipt of anything we have requested or pending the outcome of any investigation by us or by any competent authority.

9.5 Your Account must be in Good Standing, both at the time of the Unauthorized Transaction and at the time of the Request, and must not be subject to a pending investigation by us or by any competent authority.

9.6 You may submit only one Request in respect of any one Unauthorized Transaction. Where transactions are treated as a single Unauthorized Transaction under Section 8.6, only one Request may be submitted in respect of all of them.

9.7 A Request must be submitted by you personally through the channels we make available. We may decline to deal with any Request submitted by, or any correspondence from, a claims management company, asset recovery service or other third party acting on your behalf, other than a person you have lawfully authorized and whose authority we have accepted in writing.

9.8 You bear your own costs of submitting a Request, including the cost of obtaining any report, translation or other material.

9.9 If you do not comply with any requirement in this Section, your Request will not be assessed and no Reimbursement will be made.

10. Determination and Payment

10.1 We will assess your Request against these Terms and will inform you of our decision. No Reimbursement is due unless and until we have determined, on the evidence available to us, that the requirements of these Terms are satisfied. We are not required to disclose our investigation methods, risk control logic, internal records or the reasoning underlying our determination.

10.2 Where a decision is reached wholly by automated means and where required by Applicable Laws, you may request that the decision be reviewed by a natural person, and we will carry out that review.

10.3 Our determination under Section 10.1 is final, subject only to Section 16.

10.4 It is a condition of any Reimbursement that you keep the amount of the Reimbursement, the terms on which it was provided and the circumstances giving rise to it confidential, and that you do not disclose them to any third party, except as required by Applicable Laws or to your professional advisers under a duty of confidence. Where you do not comply with this Section, we may decline to make the Reimbursement or may recover any Reimbursement already made.

10.5 Where we make a Reimbursement, we may provide the same type and quantity of Digital Assets as the Eligible Loss, or their equivalent value, at our option. Where value is calculated, it is calculated by reference to the Gate spot market price of the relevant Digital Asset at the time at which the affected Digital Assets were transferred out of your Account, as recorded by our systems. Where a series of transfers occurs, each transfer is valued separately. A Reimbursement must not exceed the limits in Section 8. A Reimbursement is credited to your Account and will not be paid to any external address, bank account or third party. No interest is payable on any Reimbursement.

10.6 By accepting a Reimbursement you agree that: (a) we may set off any amount you owe us; (b) acceptance of a Reimbursement is in full and final settlement of all claims you have or may have against us or any member of our group arising out of or in connection with the Eligible Loss and the underlying Unauthorized Transaction; and (c) you assign to us, or permit us to exercise in your name, any right of recovery you have against the person responsible for the Unauthorized Transaction, and you will cooperate with any recovery action and will not settle, compromise or release any such right without our prior written consent.

10.7 We may recover any Reimbursement made if we subsequently establish that information you provided was untrue or incomplete in a material respect, or that you acted dishonestly or in bad faith. We may also require repayment of any Reimbursement to the extent you subsequently recover, from any source, amounts in respect of the same Eligible Loss. Any amount repayable under this Section is payable on demand and may be set off against any balance held in your Account.

10.8 We will not make a Reimbursement where doing so would breach applicable anti-money laundering, counter-terrorist financing or sanctions requirements, or any other Applicable Laws, or where you or any person connected with the Request are subject to sanctions. You are responsible for any tax arising from Reimbursement, and we do not provide tax advice.

10.9 We do not undertake to complete our assessment within any particular period. The time required depends on the complexity of the matter and the completeness of the information provided.

10.10 A Reimbursement is personal to you. No Reimbursement will be made to any person other than the Account holder, and your rights under the Plan may not be assigned, charged or otherwise dealt with.

11. Changes, Suspension and Termination

11.1 We may change these Terms，at any time. Where a change to these Terms may adversely affect you, we will give at least thirty (30) days' notice by email and in-app message. The Security Requirements, the scoring rules, the qualifying threshold, the limits in Section 8 and the Eligible Jurisdictions are published on the Plan Page and are not terms of this agreement; we may change any of them at any time, and any such change takes effect on publication on the Plan Page or on such later date as we specify. Changes required by Applicable Laws, or made for security, fraud-prevention or risk-management reasons, take effect immediately and without prior notice. The version of these Terms applicable to an Unauthorized Transaction is the version in effect on the date on which the transaction instruction was accepted by our systems. Your continued participation in the Plan after a change takes effect constitutes acceptance of it. If you do not accept a change, your remedy is to deactivate the Plan under Section 4.8.

11.2 We may suspend or withdraw the Plan, in whole or in part or in any jurisdiction, on thirty (30) days' notice by email and in-app message, or immediately where required by Applicable Laws or for security, fraud-prevention or risk-management reasons. Withdrawal does not affect a Request properly submitted before the withdrawal takes effect. Withdrawal of the Plan applies to Unauthorized Transactions occurring after the withdrawal takes effect, and no Reimbursement will be made in respect of any transaction occurring after that date.

11.3 We may remove you from the Plan where you no longer meet the eligibility requirements, where any circumstance in Section 7.6 applies, where you act dishonestly or in bad faith, or where required by Applicable Laws, and we will inform you of the reason where it is appropriate and lawful to do so. Removal takes effect immediately unless we state otherwise, and any Request outstanding at the time of removal will not be assessed where the grounds for removal are also grounds on which the Request would be refused.

12. Automated Processing and Personal Data

12.1 Your Security Score and Plan Status are produced by automated processing of data relating to your Account, your devices and your activity. The scoring rules are published in summary form on the Plan Page.

12.2 Where required by Applicable Laws, you may obtain an explanation of how your Security Score was reached, express your point of view, contest the outcome and obtain human intervention.

12.3 Personal data processed under the Plan is handled in accordance with our Privacy Policy.

13. KYC and AML Check

13.1 You acknowledge and agree that we may, in accordance with applicable laws, regulations and our internal compliance policies, conduct Know Your Customer ("KYC") and Anti-Money Laundering ("AML") checks on you. Upon request, you agree to promptly provide accurate, complete and up-to-date information and documentation required by us, which may include valid identification documents (e.g., passport, national ID or driver's licence), residential address and source of funds information.

13.2 We may, at our sole discretion, restrict, suspend or deny your participation in the Plan until requested information and documents are furnished, or if available information suggests you may be using the Plan or the Platform in connection with money laundering, terrorism financing, or other illegal activities. Additionally, we are entitled to employ all available measures to prevent money laundering, terrorism financing, or other illegal activities, including but not limited to removing you from the Plan or sharing your information with relevant regulatory authorities. Our rights in respect of your access to the Platform are governed by the User Agreement.

14. Force Majeure

We will not be responsible for delay or failure to perform an obligation under these Terms to the extent that the delay or failure is caused by events beyond our reasonable control, including fires, strikes, floods, power outages, cyberattacks, failures of any blockchain network, acts of God, lawful acts of public authorities, failures of common carriers, or other comparable events that could not reasonably have been foreseen or prevented.

15. Limitation of Liability

15.1 TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE FOR ANY INCIDENTAL, INDIRECT, GENERAL, SPECIAL, PUNITIVE, EXEMPLARY, OR CONSEQUENTIAL DAMAGES, LOSS OF GOODWILL OR BUSINESS PROFITS, BUSINESS INTERRUPTION COSTS, OR OTHER COMMERCIAL LOSSES ARISING OUT OF OR IN CONNECTION WITH THESE TERMS, EXCEPT FOR ANY LIABILITY THAT CANNOT BE LIMITED OR EXCLUDED UNDER APPLICABLE LAW. OUR AGGREGATE LIABILITY UNDER OR IN CONNECTION WITH THESE TERMS SHALL NOT EXCEED THE LIMITS SET OUT IN SECTION 8.

15.2 WITHOUT LIMITING THE FOREGOING, WE ARE NOT LIABLE FOR ANY LOSS ARISING FROM: (A) ANY ERROR, DELAY, INTERRUPTION OR UNAVAILABILITY IN THE CALCULATION OR DISPLAY OF YOUR SECURITY SCORE OR PLAN STATUS; (B) ANY FAILURE OR DELAY IN DELIVERING ANY NOTIFICATION UNDER THESE TERMS; (C) ANY CHANGE TO, SUSPENSION OR WITHDRAWAL OF THE PLAN; (D) ANY DECISION TO MAKE OR REFUSE A REIMBURSEMENT, OR THE AMOUNT OF ANY REIMBURSEMENT; OR (E) THE ACTS OR OMISSIONS OF ANY PERSON RESPONSIBLE FOR AN UNAUTHORIZED TRANSACTION.

15.3 NOTHING IN THESE TERMS AFFECTS ANY RIGHT OR REMEDY YOU MAY HAVE UNDER THE USER AGREEMENT, WHICH IS UNCHANGED BY THE PLAN.

16. Jurisdiction & Dispute Resolution

16.1 These Terms, and any claim or dispute of any kind whatsoever arising out of or in connection with them, shall be governed by, and construed in accordance with, the laws of the Republic of Panama without regard to the principles of conflicts of laws.

16.2 You acknowledge and agree that any dispute arising out of or in connection with these Terms or any document or transaction in connection with them, including any dispute or claim relating to (a) the existence, validity or termination of these Terms; and (b) any non-contractual obligations arising out of or in connection with them (“Dispute”) shall at first instance be referred to and resolved amicably through negotiation.

16.3 In the event that the Dispute fails to be resolved by negotiation within thirty (30) days from the initiation of such negotiations by issuance of a notice of Dispute, such Dispute shall be referred to and finally resolved by arbitration in Panama to the exclusion of the ordinary courts, in accordance with the Arbitration Rules of the International Chamber of Commerce for the time being in force which rules are deemed to be incorporated by reference in this clause. The seat of arbitration shall be Panama. The arbitration tribunal shall consist of one arbitrator. The language of arbitration shall be in English. No Dispute may be referred to arbitration unless you have first submitted a Request in accordance with Section 9 and we have issued a determination under Section 10.1, or the period for doing so has expired.

16.4 Any Dispute will be resolved on an individual basis only. You may not bring or participate in any Dispute as a class, collective, consolidated or representative proceeding, and the arbitrator has no power to consolidate the claims of more than one person or to award relief in favour of any person other than you. This Section applies to the maximum extent permitted by Applicable Laws. If this Section is held unenforceable in relation to any part of a Dispute, that part is excluded from arbitration and determined by the courts of the Republic of Panama, and the remainder of this Section 16 continues to apply.

16.5 You further agree that, following the commencement of arbitration, you will attempt in good faith to resolve the dispute through mediation. Any settlement reached in the course of the mediation shall be referred to the then-seated arbitral tribunal and may be made a consent award on agreed terms.

16.6 Nothing in this Section affects any mandatory right you have as a consumer under the law of your country of residence.

16.7 Any Dispute must be commenced within one (1) year after the cause of action arises, or within such longer period as is required by Applicable Laws. Otherwise the Dispute is permanently barred.

17. Eligible Jurisdictions

The Plan is offered only to Users resident in jurisdictions that have been approved for inclusion following applicable local legal and compliance review and that are listed on the Plan Page or otherwise expressly designated by us. The Plan is not offered in any other jurisdiction. The list of Eligible Jurisdictions will be maintained and updated by us based on the User Agreement. We may add or remove a jurisdiction at any time. Removal of a jurisdiction takes effect in accordance with Section 11.2 and applies to Unauthorized Transactions occurring after it takes effect.

18. Security Requirements

18.1 The following are mandatory Security Requirements. Each must have been enabled or configured, and must have remained so without change, throughout the thirty (30) days immediately before the Unauthorized Transaction: (a) a passkey; (b) an authenticator application; (c) a bound email address; (d) a bound mobile number; (e) two-step login; (f) an anti-phishing code, set to a value not used elsewhere; (g) a fund password; (h) API write permissions disabled; (i) Alpha trading disabled; (j) a C2C transaction limit set; (k) an on-chain withdrawal limit set; and (l) device integrity, meaning that no device used to access your Account has been jailbroken or rooted, has had a non-official operating system installed, or has otherwise had the security protections of its operating system bypassed or disabled or root-level privileges obtained.

18.2 The Security Requirements, any additional requirement and the scoring methodology for the Security Score are published in summary form on the Plan Page. Changes are subject to Section 11.

18.3 A Security Requirement is satisfied only where the relevant setting was enabled or configured, and remained so, throughout the thirty (30) day period. Any change that disables a Security Requirement, or that otherwise reduces the protection it provides, causes the thirty (30) day period in Section 4.4 to restart from zero. A change that increases the protection provided, including reducing a limit or disabling a transaction channel, does not cause that period to restart. Where a Security Requirement is not available to you, or is not supported by your Account or in your jurisdiction, the Plan does not apply to your Account unless we state otherwise on the Plan Page.

19. Miscellaneous

19.1 These Terms may be published in more than one language. Any such translation is provided solely for your convenience. In the event of inconsistency or ambiguity, the English version will prevail.

19.2 If any portion of these Terms is held invalid or unenforceable, that portion shall be construed in a manner to reflect, as nearly as possible, the original intention of the parties, and the remaining portions shall remain in full force and effect.

19.3 You may not assign or transfer your rights or obligations under these Terms without prior written consent from us. We may assign or transfer any or all of our rights or obligations under these Terms, in whole or in part, including to any member of our group or to any successor in business, without notice or obtaining your consent or approval.

19.4 No failure or delay by us in exercising any right, power or remedy we are entitled to under these Terms or by stipulation of law or regulation shall operate as a waiver thereof, nor shall any single or partial exercise thereof preclude any other or further exercise of such rights, power or remedies.

19.5 Except as expressly provided in these Terms, a person who is not a party to these Terms shall not have any rights to enforce any term of these Terms. Notwithstanding any term of these Terms, the consent of or notice to any person who is not a party shall not be required for any termination, rescission or agreement of any variation, waiver, assignment, novation, release or settlement under these Terms at any time.

19.6 Nothing in these Terms creates any partnership, joint venture, agency, employment or fiduciary relationship between you and us.

19.7 For any matters not covered by these Terms, we reserve the sole and final discretion of final interpretation to the maximum extent permitted by Applicable Laws.

19.8 These Terms, together with the Plan Page and the Plan Rules, constitute the entire agreement between you and us in relation to the Plan and supersede any prior statement, representation, assurance or understanding relating to it, whether made by us, by any member of our group, or by any of our employees, agents or representatives, and whether made in any announcement, advertisement, help centre article, support communication or otherwise.

19.9 We may give notice under these Terms by any means we consider appropriate, including by publication on the Plan Page or the Platform, by in-app notification, or by email or SMS to the contact details registered on your Account. Notice takes effect when sent or published, whether or not it is received or read. It is your responsibility to keep your contact details current.

19.10 Sections 2, 7, 8, 10.6 to 10.8, 14, 15, 16 and this Section 19 survive the termination or withdrawal of the Plan, your removal from the Plan, and your leaving the Plan.