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Draft — not yet reviewed by counsel. This document is published for transparency while VaultPay is in testnet beta. It has not been reviewed by a qualified attorney and should not be relied on as final or legally binding.

VaultPay — Acceptable Use Policy

STATUS: DRAFT — NOT YET REVIEWED BY COUNSEL. Do not publish or rely on this document as legally binding until it has been reviewed by a qualified attorney familiar with fintech/crypto regulation in every jurisdiction where VaultPay will operate or accept users from.

Last updated: [DATE] · Version: draft-1

This Acceptable Use Policy ("AUP") is incorporated into, and forms part of, the Terms of Service. Capitalized terms not defined here have the meaning given in the Terms of Service.

1. Purpose and an Important Architectural Disclosure

This AUP governs what you may list, buy, sell, or otherwise do through the VaultPay website (vaultpay.market).

You must understand a structural limitation before relying on this Policy, and before assuming VaultPay can prevent, undo, or remove any particular transaction:

  • VaultPay's smart contract protocol is immutable, has no administrator key, no pause function, and no upgrade mechanism. Once a transaction is confirmed on-chain, its content (including listing titles, descriptions, and dispute evidence) is permanent and cannot be edited, hidden, or deleted by VaultPay or by anyone else, under any circumstances.
  • The smart contract can be called directly by anyone — via a block explorer, a script, or any other interface — without ever visiting or using vaultpay.market. Enforcement action we take against your access to our website has no effect on the underlying smart contract or on transactions made outside our website.
  • As a result, our ability to enforce this Policy is limited to what happens before a transaction is submitted to the blockchain (for example, screening uploads and listing content before it is submitted) and to what our own website chooses to display afterward (for example, refusing to show a listing in our marketplace, or blocking a wallet address from using our interface). It does not, and cannot, mean we can reverse, redact, or delete on-chain data.
  • Content you exchange with a counterparty through third-party channels (phone, SMS, Telegram, WhatsApp, XMTP, or any other off-platform communication) is entirely outside our systems. We do not operate, monitor, or have access to these channels in any way.

We are telling you this plainly because we believe an honest description of what we can and cannot control is itself part of operating this Service responsibly.

2. Prohibited Goods and Services

You may not use VaultPay to list, advertise, offer, request, buy, sell, or otherwise facilitate the exchange of:

  • Controlled substances — illegal drugs, narcotics, or controlled pharmaceuticals without valid authorization, and any paraphernalia primarily intended for illegal drug use;
  • Weapons — firearms, ammunition, explosives, or weapons whose sale is restricted or illegal under applicable law, without required licenses;
  • Stolen or fraudulently obtained goods, including stolen data, credentials, or account access;
  • Counterfeit or unauthorized-replica goods infringing a third party's trademark, copyright, patent, or other intellectual property rights;
  • Child sexual abuse material (CSAM) or any content sexualizing minors — zero tolerance; will be reported to the National Center for Missing & Exploited Children (NCMEC) or the applicable authority in your jurisdiction, and to law enforcement, without exception;
  • Human trafficking, forced labor, or commercial sexual services where illegal in the relevant jurisdiction;
  • Endangered or protected species, or products derived from them, where restricted under CITES or applicable law;
  • Hazardous, regulated, or controlled materials (including but not limited to explosive precursors, toxic chemicals, radioactive material) without required licenses and safe-handling compliance;
  • Malware, exploits, stolen access credentials, or hacking tools/services intended to cause unauthorized access or harm to computer systems;
  • Personal data obtained or traded unlawfully (e.g., leaked databases, identity documents, financial account data);
  • Any goods or services that are illegal to sell, purchase, or possess under the law applicable to either party to the transaction, even if this Policy does not name the specific item; and
  • Financial products or services requiring a license you do not hold in the applicable jurisdiction (e.g., unlicensed securities offerings, unlicensed money transmission, unlicensed lending).

This list is illustrative, not exhaustive. If you are unsure whether something is prohibited, do not list it.

3. Prohibited Conduct

You may not:

  • Use VaultPay to facilitate money laundering, terrorist financing, or any other financial crime;
  • Structure transactions to evade reporting thresholds or sanctions;
  • Use the Service if you are a sanctioned person or entity, or on behalf of one (see Terms of Service, Section 12);
  • Attempt to deceive, defraud, or extort another user;
  • Misrepresent the nature, condition, legality, or origin of a listed item;
  • Engage in market manipulation, wash trading, or artificially inflate activity on the platform;
  • Harass, threaten, or dox another user;
  • Attempt to circumvent any moderation, filtering, or access restriction we implement on the Site;
  • Use automated means to scrape, spam, or abuse the Site or its infrastructure (including the image-upload endpoint) in a way that degrades the Service for others or attempts to exhaust our third-party service quotas (e.g., IPFS pinning);
  • Impersonate another person or entity, or misrepresent your affiliation with any person or entity.

4. Sanctions and Restricted Jurisdictions

You may not use the Service if you are located in, or ordinarily resident in, a country or region subject to comprehensive sanctions, or if you are listed on the OFAC Specially Designated Nationals list or an equivalent restricted-party list maintained by the EU, UN, or other applicable authority. We reserve the right to screen wallet addresses against publicly available sanctions data and to block access to the Site accordingly.

5. Enforcement — What We Can and Cannot Do

If we determine, in our discretion, that a listing or a user's conduct violates this Policy, we may take one or more of the following actions:

  • Remove or hide the listing from vaultpay.market's marketplace display;
  • Decline to render, index, or surface content (including images) uploaded through our infrastructure;
  • Block a wallet address from using vaultpay.market's interface;
  • Refuse to process further uploads associated with a wallet address;
  • Preserve records as required or requested by law enforcement;
  • Report the conduct to law enforcement, financial intelligence units, or other relevant authorities, where we determine it is legally required or otherwise appropriate to do so — including for CSAM, which we report without exception.

Consistent with Section 1, none of the above can reverse a completed on-chain transaction, delete data already written to the blockchain, or prevent a wallet from interacting with the smart contract directly without using our website. We do not claim, and you should not assume, that removing a listing from our website removes it from the blockchain, or that blocking a wallet from our interface prevents that wallet from using the underlying protocol by other means.

6. Reporting a Violation

If you become aware of a listing or conduct that may violate this Policy, please report it to [abuse contact email to be added]. Include the deal ID or wallet address where possible. We aim to review reports promptly but do not guarantee a specific response time.

If you believe content constitutes CSAM, in addition to reporting to us, please report directly to NCMEC (report.cybertip.org, U.S.) or the equivalent authority in your jurisdiction, and to law enforcement.

7. Cooperation with Law Enforcement

We will cooperate with lawful requests from law enforcement and regulatory authorities to the extent required by applicable law, including by preserving and, where legally compelled, disclosing information available to us (which, given the architecture described in Section 1, is limited — we do not have visibility into on-chain data beyond what is publicly readable by anyone, and we have no visibility into off-platform communications).

8. Relationship to These Terms; No Waiver

Violation of this Policy is a violation of the Terms of Service. Our failure to act on any violation does not waive our right to act on that or any future violation. We may update this Policy at any time; material changes will be reflected by an updated "Last updated" date.

9. Contact

Report a violation or ask a question about this Policy: [abuse contact email to be added]

This document is a working draft prepared to accelerate legal review. It is not legal advice and must not be published, relied upon, or presented to users as binding until reviewed and approved by qualified legal counsel in each relevant jurisdiction.