ComunPay Agreement

Last Updated: September [22], 2025

Table of Contents

1. General
2. Eligibility
3. Using ComunPay
   
   1. Linking Cards
   2. Sending Money
   3. Verification
4. CRB Wallet
   
   1. Funding of CRB Wallet
   2. Storage of Funds
   3. Ownership and FDIC Insurance
5. ComunPay Services Security
6. Fees
7. Use of the ComunPay Services
8. Schedule of Fees and Charges
9. Transaction Limits
10. Prohibited Activities
11. Changes to the Services; Termination
12. Third Party’s Use of Your and Recipient’s Personal Information
13. Compliance
14. Liability
15. Indemnification
16. Disclaimer of Warranties
17. Limitation of Liability
18. Ownership and License
19. Errors and Disputes Resolution
20. Feedback
21. Survival
22. Contact Information

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IMPORTANT - PLEASE READ THIS AGREEMENT CAREFULLY AND RETAIN THESE TERMS AND CONDITIONS FOR YOUR RECORDS.

This ComunPay Agreement (this "Agreement") governs your use of (i) the ComunPay service, a peer-to-peer payment service that enables transfers between Comun users, and (ii) the digital wallet service that allows you to view your funds maintained at Cross River Bank an FDIC-insured depository institution (“CRB”) (the “CRB Wallet,” and together with the ComunPay service, the “ComunPay Services”). The ComunPay Services are provided by Comun, Inc. ("Comun," "we," "us," or "our") as agent for CRB. CRB shall exercise exclusive control over and maintain your funds and shall be solely effectuating the transfer of these funds. By using the ComunPay Services, you agree to be bound by this Agreement between you and Comun. By accepting this Agreement, you also agree to the Comun Platform Agreement (the “Platform Agreement”) and the Comun Privacy Policy. This Agreement supplements the Platform Agreement, and any undefined terms herein shall have the meanings ascribed to them in the Platform Agreement. Access to the ComunPay Services requires maintaining a Comun Account in good standing. In the event of any conflict between this Agreement and any other agreement between you, Comun and/or any third party regarding the ComunPay Services, this Agreement shall control. For matters not specifically addressed herein, the agreements governing such matters shall control. As used herein, “you” and “your” refer to the person responsible for complying with this Agreement.

Comun is a financial technology company and not a bank. Comun acts solely as an agent of CRB in providing the ComunPay Services, and at no time does Comun directly hold, transfer, or move any funds. All funds maintained in connection with the CRB Wallet are held by CRB in a custodial account for your benefit, and any movement of funds is conducted solely by CRB. THESE FUNDS ARE NOT FDIC-INSURED AND ARE NOT CONSIDERED TO BE DEPOSITS. YOU MAY LOSE VALUE ON THE FUNDS HELD IN THE CRB WALLET, FOR WHICH COMUN IS NOT RESPONSIBLE. 

1. General

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This Agreement between you and Comun sets forth the terms and conditions of the ComunPay Services, which may allow you:

1. to link an eligible third-party debit card that you own or are authorized to use ("Linked Card") to your Comun Account;
2. to transfer funds from your Linked Card or, if you opened one, your Comun Checking Account (as offered by Community Federal Savings Bank, an FDIC insured depository institution) to your CRB Wallet;
3. to transfer funds from either your Linked Card, your CRB Wallet, or your Comun Checking Account to other debit cards that are linked to other Comun Accounts, other CRB Wallets, other Comun Checking Accounts, or to third parties using the International Remittance Transaction Services offered by UniTeller (“Remittances”), which require you to separately review, acknowledge, and agree to the UniTeller User Agreement (available at https://en.comun.app/legal/uniteller-user-agreement), with the party receiving such a transfer of funds being a “Recipient”;
4. to receive funds sent from other Linked Cards, other CRB Wallets, or other Comun Checking Accounts through the ComunPay Services; and
5. to withdraw funds from your CRB Wallet or your Checking Account to your Linked Card.

Funds transfers initiated through the Platform or WhatsApp (with WhatsApp transfers being subject to WhatsApp's terms of service and availability, which are outside of Comun's control and for which Comun assumes no liability or responsibility) shall be referred to individually as a "ComunPay Transfer" and collectively as “ComunPay Transfers.” Except as expressly provided in this Agreement, all ComunPay Transfers conducted through the ComunPay Services are subject to all limitations and terms set forth in the Platform Agreement governing your Comun Account as it may be modified from time to time, including, but not limited to, those related to deposit acceptance, crediting, collection, endorsement, processing order and errors.

2. Eligibility

You represent and warrant that you are at least eighteen (18) years of age, that you are capable of entering into a legally binding contract, and that you currently reside in the United States. You acknowledge and agree that your ComunPay Services account is for your personal use only and may not be used by any other person, including family members. In addition, you agree to provide us with certain information including, but not limited to, your name, date of birth, phone number and other personal information. You acknowledge and consent to our collection, storage, and use of such information in accordance with our Privacy Policy. Comun may use this information to verify your identity and your usage of the ComunPay Services. You agree that you will provide accurate and complete information to Comun in response to any requests for information made by Comun. You agree that you will update and keep accurate this information.

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

3. Using ComunPay

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1. Linking Cards

To use ComunPay, you must either successfully link a Linked Card to your Comun Account by adding its information to your Comun Account, have sufficient funds in your CRB Wallet, or have an active Comun Checking Account in good standing. You can change the Linked Card in your Comun Account settings. Comun reserves the right, in its sole and absolute discretion, to accept or reject a Linked Card for use with the ComunPay Services, and to establish criteria for such acceptance or rejection. As part of the sign up process, you may be prompted to create a unique, four-digit passcode (“Passcode”) that will be used to verify certain ComunPay Transfers, except for your first ComunPay Transfer that requires such Passcode. This ComunPay Transfer may not require the input of the Passcode, if the Passcode was created within a certain time period of you successfully signing up for the ComunPay Services.

2. Sending Money

After you have added a Linked Card to your Comun Account or have opened an active checking account offered on the Comun Platform through an FDIC-insured partner bank  (a "Comun Checking Account"), you may be able to send money from your Linked Card, your CRB Wallet, or your Comun Checking Account to another debit card, another CRB Wallet, another Comun Checking Account, or as Remittances by using the Platform or WhatsApp. The Recipient's debit card must be linked to an active Comun Account that has subscribed to the ComunPay Services. You are limited, for certain ComunPay Transfers, in both the total number of transfers and the aggregate amount of funds that you may send and receive within specific time periods. These ComunPay Transfer limits are set forth in Section 9 (Transaction and Account Limits) of this Agreement and are subject to change at Comun's sole discretion. In addition, we may implement additional limits. These limits are designed to be flexible in order to protect the security and integrity of the service, including protecting you and all other users of the service. Comun will provide notice of any changes to these limits as required by applicable laws and regulations. Changes to these limits may be based on various factors, including but not limited to: (i) your transaction history; (ii) account standing; (iii) regulatory requirements; (iv) risk assessment of your account activity; and (v) compliance with applicable laws and regulations.

For a ComunPay Transfer to another Linked Card, another CRB Wallet, or another Comun Checking Account, you may transfer any amount up to the available balance in the account associated with your Linked Card (“Bank Account”) or up to the available balance in your CRB Wallet, up to the applicable transaction or transfer limits as contemplated by this Agreement. If the Recipient cannot receive the funds due to inadequate cardholder or transaction limits or other issues, the Recipient should contact the relevant financial institution to adjust its transfer limits or to provide other methods to receive the ComunPay Transfer.

It is your sole responsibility to provide your correct personal information and payment credentials and that of the Recipients (collectively, "Payment Information"). You shall be solely responsible for any and all costs, penalties, and losses that arise from your failure to provide the necessary correct Payment Information for a successful ComunPay Transfer, as well as any unauthorized or fraudulent transactions that could have been prevented by your proper verification of payment details.

3. Verification

Certain ComunPay Transfers using the ComunPay Services shall be subject to a verification process. After you submit a ComunPay Transfer that requires such verification, you will be prompted to confirm such ComunPay Transfer. After you confirm the ComunPay Transfer, you may be required to enter in a Passcode to verify the transaction. A correct entry of your Passcode shall authorize all subsequent ComunPay Transfers without the need to enter your Passcode again for a certain amount of time. Failure to provide the correct Passcode or meet any other security requirements will result in the transaction being declined.

4. CRB Wallet

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1. Funding of CRB Wallet

After you successfully sign up for the ComunPay Services, Comun may, in its sole discretion, provide you with access to a CRB Wallet. You may transfer funds into your CRB Wallet from your Linked Card or your Comun Checking Account. You acknowledge and agree that while your Bank Account may be debited immediately, the balance of your CRB Wallet may not update immediately after the transfer and that there may be a delay before the transferred funds appear in your CRB Wallet. Comun shall not be liable for any damages or losses resulting from such delays.

2. Storage of Funds

The CRB Wallet will allow you to store, transfer, receive, and manage funds that are denominated in United States Dollars (the “Wallet Assets”). Comun cannot and will not transfer Wallet Assets from your CRB Wallet. All transfers are conducted by CRB and only with your express authorization or as required by law, a court order, or instructions from a relevant authority.

3. Ownership and FDIC Insurance

You are the owner of the Wallet Assets in your CRB Wallet. No interest is to be earned from the store of cash in your CRB Wallet. You acknowledge and agree that all Wallet Assets are to be held in custody by CRB in an omnibus custody account. You acknowledge that Comun does not hold any Wallet Assets itself. YOU ACKNOWLEDGE THAT ANY FUNDS KEPT IN THE CRB WALLET ARE NOT FDIC-INSURED AND ARE NOT CONSIDERED TO BE BANK DEPOSITS. YOU MAY LOSE VALUE ON THE FUNDS HELD IN THE CRB WALLET, AND EXCEPT AS EXPRESSLY PROVIDED IN THIS AGREEMENT OR REQUIRED BY APPLICABLE LAW, COMUN SHALL NOT BE LIABLE FOR ANY SUCH LOSSES.

5. ComunPay Services Security

You are solely responsible for maintaining the confidentiality and security of your login credentials for your Comun Account and Linked Card. In addition, you shall take all reasonable precautions to prevent unauthorized access to your Comun Account and Linked Card, including but not limited to:

1. Ensuring that all one-time passwords for your Comun Account are sent to a secured device; 
2. Never sharing your login credentials of your Comun Account or your verification information for your Linked Card with any third party; and
3. Ensuring your login credentials are stored securely.

You must immediately notify us by emailing us at ayuda@comun.app if you suspect or become aware that your login credentials or stored information has been compromised, stolen, or accessed by unauthorized parties. You acknowledge that failure to maintain the security of your login credentials or stored information or promptly report security breaches may result in unauthorized access to your accounts and, except where it is prohibited by applicable laws and regulations, you may be held responsible for any resulting damages, losses, costs, fees, or penalties.

6. Fees

You agree to pay all associated fees for ComunPay Transfers and other usage of the ComunPay Services as set forth in Section 8 (Schedule of Fees and Charges) of this Agreement. We reserve the right to modify these fees upon providing notice as required by applicable laws and regulations. Such fees may include, but are not limited to, service fees, cancellation fees, fees for returns and refunds, foreign exchange fees, and any other fees specified in Section 8 (Schedule of Fees and Charges). You acknowledge that in addition to our fees, your bank, card issuer, or other financial institution may charge additional fees in connection with the transaction, for which you are solely responsible. We reserve the right to collect all fees and charges due to us and our partners in accordance with the rights and remedies granted under this Agreement and the Platform Agreement, including but not limited to the right to debit your accounts, offset amounts owed, and pursue collection through available legal remedies.

7. Use of the ComunPay Services

Use of the ComunPay Services requires that you either have an internet-enabled mobile device and have downloaded a supported version of the Comun mobile application or, in order to access certain functionalities through Comun’s website, have an internet-enabled electronic device that has an Internet browser that includes 128-bit encryption with cookies enabled. In order to access certain functionalities through WhatsApp, you must have an internet-enabled iOS or Android device and have downloaded the latest version of the WhatsApp app.

You must have sufficient funds in your Bank Account, your CRB Wallet, or your Comun Checking Account, as applicable, to send funds through the ComunPay Services. You must have an eligible Linked Card, an active CRB Wallet, or an active Comun Checking Account to receive incoming funds through the ComunPay Services. Only funds denominated in United States dollars may be sent or received. Funds may be sent from only domestic debit cards. Sent funds may be received by both domestic and international transfers. Features available through the ComunPay Services will be accessible through the Platform and WhatsApp. Funds transferred through the ComunPay Services may not be available for immediate use.

Comun reserves the right to change the eligibility criteria, features, or terms of the ComunPay Services at any time without prior notice. We have the sole right to reject any request to use the ComunPay Services without any liability to you. We reserve the right to change, suspend or discontinue the ComunPay Services, in whole or in part, or your use of the ComunPay Services, in whole or in part, immediately and at any time without prior notice to you.

You acknowledge and agree that Comun may make different features, functionalities, or services relating to the ComunPay Services available to different users based on eligibility criteria determined by Comun, including access to the CRB Wallet. Comun reserves the right, in its sole and absolute discretion, to: (i) determine which features, functionalities, or services to make available to any user; (ii) limit, restrict, suspend, or discontinue your access to any feature, functionality, or service at any time; (iii) impose conditions, requirements, or limitations on your use of any feature, functionality, or service; and (iv) modify the availability or terms of any feature, functionality, or service.

8. Schedule of Fees and Charges 

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Below are the fees that apply to your usage of the ComunPay Services.

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Account Fees

Sign-up Fee

$0.00

Monthly Fee

$0.00

Transfers Between Your Accounts

Transfers from your Linked Card to your CRB Wallet or your Comun Checking Account

$0.00

Transfers from your Comun Checking Account to your CRB Wallet

$0.00

Transfers from your CRB Wallet to your Comun Checking Account

$0.00

Transfers from your Comun Checking Account to your Linked Card

1.75%

Transfers from your CRB Wallet to your Linked Card

1.75%

Transfers to Another Party

Transfers from your Linked Card to another CRB Wallet or another Comun Checking Account

$0.00

Transfers from your Comun Checking Account to another CRB Wallet or another Comun Checking Account

$0.00

Transfers from your CRB Wallet to another CRB Wallet or another Comun Checking Account

$0.00

Transfers from your Linked Card to another Linked Card

1.75%

Transfers from your Comun Checking Account to another Linked Card

1.75%

Transfers from your CRB Wallet to another Linked Card

1.75%

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From time to time, Comun may provide free ComunPay Transfers as part of promotional offers. We will let you know if any fees are waived, the number of ComunPay Transfers or transactions they are waived for, and the time period during which you may be eligible for these promotions. Comun reserves the right to offer and to terminate these promotions at its sole discretion.

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9. Transaction and Account Limits

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Your transfer limits are determined in part by whether you are using your Linked Card, CRB Wallet, or Comun Checking Account to send or receive ComunPay Transfers to or from another Linked Card, another CRB Wallet, or another Comun Checking Account. We may also take into account whether the name on your Linked Card completely or partially matches your personal information, with Linked Cards that are a complete match receiving higher transfer limits. The transfer limits for sending and receiving ComunPay Transfers are independent of each other (i.e., an outgoing ComunPay Transfer will not count toward your transfer limits for receiving ComunPay Transfers from other parties). Transfer limits are subject to periodic review and may be changed based on your ComunPay Services activities, history, and other factors. Comun retains sole discretion to apply and change limits in accordance with this Agreement.

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If you are using your CRB Wallet or your Linked Card without having opened a Comun Checking Account to send or to receive ComunPay Transfers, you are subject to the following limits for your ComunPay Transfers:

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• Up to $500 in a single day; 
• Up to $1,000 in a single week; and
• Up to $1,000 in a 30-day rolling window.

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If you are using your Comun Checking Account or your Linked Card while having opened a Comun Checking Account to send or to receive ComunPay Transfers, you are subject to the following limits for your ComunPay Transfers:

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• Up to $1,000 in a single day;
• Up to $2,000 in a single week; and
• Up to $3,000 in a 30-day rolling window.

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You are subject to the following transaction limits, regardless of how you fund your ComunPay Transfers: 

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• Send up to ten (10) ComunPay Transfers a day;
• Receive up to ten (10) ComunPay Transfers a day;
• A minimum of $1 for each ComunPay Transfer; and
• A maximum of $250 for each ComunPay Transfer.

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You may also be subject to the following additional limits for your CRB Wallet:

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• The maximum balance of funds you may hold in your CRB Wallet;
• The total aggregate amount of funds you may transfer to or withdraw from your CRB Wallet in a certain rolling window; and 
• The total amount of funds that may be transferred in a single transfer to or from your CRB Wallet.

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10. Prohibited Activities

You agree not to use these ComunPay Services or your Comun Account for: (a) transactions or activities that violate the Platform Agreement, this Agreement, or any other applicable agreements between you and third-party service providers; (b) activities, as deemed by Comun in its sole discretion, that are improper or differ from normal user behavior; or (c) activities that may indicate fraud, misuse, security concerns, illegal activity, or unauthorized access. 

11. Changes to the Services; Termination

Comun reserves the right to terminate, modify, add and remove features from the ComunPay Services at any time in our sole discretion and to modify or amend this Agreement without notice, unless required by applicable law. You may reject changes by discontinuing use of the ComunPay Services. Your continued use of the ComunPay Services shall constitute your acceptance of and agreement to such changes. Maintenance of the ComunPay Services may be performed from time to time resulting in interrupted service, delays or errors in the ComunPay Services. Comun shall have no liability for any such interruptions, delays or errors. Attempts to provide prior notice of scheduled maintenance will be made, but Comun cannot guarantee that such notice will be provided.

You may also terminate this Agreement by emailing ayuda@comun.app. You must cease using the ComunPay Services, including your CRB Wallet, after the termination. Any use of the ComunPay Services after the delivery of your termination of this Agreement shall constitute your renewed acceptance and agreement to this Agreement.

After your CRB Wallet is closed, we have no obligation to accept further transfers of funds into the CRB Wallet. You agree to hold us harmless for refusing to honor any item on a closed CRB Wallet. If a balance remains in the CRB Wallet after you have notified us of your intent to close your CRB Wallet, we will require you to submit your request to us in writing to return any remaining funds to your Linked Card or Bank Account by sending an email to ayuda@comun.app, after which we will credit your Linked Card with the remaining balance. Alternatively, we may send a check to your listed address in our records. All related closing fees and other applicable account fees, if any, will be deducted from the final balance.

12. Third Party’s Use of Your and Recipient’s Personal Information

Comun may need to engage third-party service providers in order to facilitate ComunPay Transfers and to provide the ComunPay Services to you. By choosing to use this feature, you authorize us to send your personal information, including but not limited to the Payment Information, to these third-party service providers to facilitate ComunPay Transfers or to provide the ComunPay Services to you. Any such personal information may be collected and processed by these third-party service providers pursuant to the applicable terms and conditions of their privacy policies and terms of use. We will strictly use any received personal information to facilitate activities related to the ComunPay Services. We will not store any transmitted CVV2 credentials following the authorization of a ComunPay Transfer. Any other transmitted credentials will be stored in accordance with the latest Payment Card Industry Data Security Standard and our Privacy Policy.

13. Compliance

You agree to comply with all applicable laws, regulations, court orders, and binding actions as directed by governmental bodies. Comun reserves the right in our sole discretion, with or without prior notice, to temporarily or permanently modify, block or discontinue the ComunPay Services or any ComunPay Transfers that would or may infringe on legal, regulatory or binding requirements applicable to you or the Recipients. You agree that you will not use the ComunPay Services in locations that are prohibited under applicable U.S. law and regulations, including laws and regulations issued by the Office of Foreign Assets Control.

14. Liability

When using the ComunPay Services, you may experience technical or other difficulties. Except as required by applicable law and subject to Section 19 (Errors and Disputes Resolution), Comun shall not assume any responsibility for any technical or other difficulties or any resulting losses or damages that you may incur. In addition, we will not be liable for any losses or damages arising from, but not limited to, the following:

• if, through no fault of ours, you do not have enough funds in your Bank Account to complete the ComunPay Transfer; or
• if you transferred the incorrect amount of funds; or
• if the Bank Account has been closed or is not in good standing; or
• if applicable, the ComunPay Transfer would go over the permitted limits as set forth in Section 9 (Transaction and Account Limits) of this Agreement; or
• if you have not given us complete, correct, or current Payment Information or do not instruct us soon enough for the completion of your ComunPay Transfer by its due date; or
• if your Comun Account or Bank Account has been placed on a hold or freeze status due to legal order or other encumbrances restricting such amount; or
• if circumstances beyond our control stop the ComunPay Services or prevent the ComunPay Transfer to be completed, including, but not limited to, failure of electronic or mechanical equipment or communications lines, telephone or other connection problems, denial of service attacks, normal maintenance, unauthorized access, theft, operator errors, severe weather, earthquakes, fire, floods and strikes or other labor problems; or
• if the ComunPay Services are not working properly or if it is unavailable and you know or have been advised by us that the system is not working properly or will be unavailable; or
• if there is a failure in any way on the part of another party to the ComunPay Services or ComunPay Transfer; or
• if there is an allegation of fraudulent activity concerning your Comun Account; or
• if the Recipient fails to credit your payment properly after the ComunPay Transfer; or
• if the Recipient is not located in the United States or if the payment is intended to satisfy a tax or court-ordered obligation or other government obligation; and/or
• if the Platform Agreement or this Agreement provide that the ComunPay Transfer cannot be completed.

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15. Indemnification

To the maximum extent permitted by applicable law, you agree to defend, indemnify and hold harmless Comun, its directors, officers, employees, agents, assigns, processors, suppliers (including any other third-party service providers) and successors-in-interest from and against any and all third-party liability, damages, losses, claims, demands, actions, causes of action, costs and expenses (including attorneys’ fees and expenses) directly or indirectly arising out of, resulting from, or related to: (i) your performance under this Agreement including, without limitation, performance, non-performance, or defect in performance, any statement, misstatement, representation or misrepresentation made by you; (ii) the negligent or willful acts or omissions by you; (iii) any statements, claims, representations or warranties made by you, relating to the ComunPay Services or any other matter; (iv) your relationship with any other third-party service provider; (v) any and all tax liabilities associated with ComunPay Transfers, regardless of which party has a legal duty to collect and remit the same; (vi) use of the Comun Account; (vii) attorneys’ fees and other costs and expenses paid or incurred by Comun in the enforcement of this Agreement, or in collecting any amounts due from you hereunder; and (viii) responding to requests for your information by third parties including but not limited to subpoenas or court orders for the same.

16. DISCLAIMER OF WARRANTIES

YOU ACKNOWLEDGE THAT YOUR USE OF THE COMUNPAY SERVICES AND ALL INFORMATION AND CONTENT (INCLUDING THAT OF THIRD PARTIES) IS AT YOUR RISK AND IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. COMUN DISCLAIMS ALL WARRANTIES OF ANY KIND AS TO THE USE OF THE COMUNPAY SERVICES, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NONINFRINGEMENT. COMUN MAKES NO WARRANTY THAT (i) THE COMUNPAY SERVICES WILL MEET YOUR REQUIREMENTS, (ii) THE COMUNPAY SERVICES WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, (iii) THE RESULTS THAT MAY BE OBTAINED FROM THE COMUNPAY SERVICES WILL BE ACCURATE OR RELIABLE, AND (iv) ANY ERRORS IN THE COMUNPAY SERVICES OR TECHNOLOGY WILL BE CORRECTED.

17. LIMITATION OF LIABILITY

YOU AGREE THAT COMUN WILL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING, BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER LOSSES RESULTING FROM THE USE OR THE INABILITY TO USE THE COMUNPAY SERVICES INCURRED BY YOU OR ANY THIRD PARTY ARISING FROM OR RELATED TO THE USE OF, INABILITY TO USE, OR THE TERMINATION OF THE USE OF THE COMUNPAY SERVICES, REGARDLESS OF THE FORM OF ACTION OR CLAIM (WHETHER CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE), EVEN IF COMUN HAS BEEN INFORMED OF THE POSSIBILITY THEREOF.

18. Ownership and License

You agree that Comun retains all ownership and proprietary rights in the ComunPay Services, Platform, associated content, technology, and website(s). Your use of the ComunPay Services is subject to and conditioned upon your complete compliance with the Platform Agreement and this Agreement. Without limiting the effect of the foregoing, any breach of this Agreement immediately terminates your right to use the ComunPay Services. Without limiting the restriction of the foregoing, you may not use the ComunPay Services (i) in any anti-competitive manner, (ii) for any purpose which would be contrary to Comun's business interest, or (iii) to Comun's actual or potential economic disadvantage in any aspect. You may use the ComunPay Services only for non-business, personal use in accordance with this Agreement. You may not copy, reproduce, distribute or create derivative works from the content and agree not to reverse engineer or reverse compile any of the technology used to provide the ComunPay Services.

19. Errors and Disputes Resolution

ALL QUESTIONS ABOUT TRANSACTIONS MADE WITH YOUR CRB WALLET MUST BE DIRECTED TO US (COMUN), AND NOT TO CRB. We are responsible for resolving any transactions errors made with your CRB Wallet or the ComunPay Services.

Any disputes between you and Comun relating to the ComunPay Services or any ComunPay Transfers are to be resolved by the policies and procedures set forth in this Section 19 (Errors and Disputes Resolution) of the Agreement as well as the relevant sections of the Platform Agreement.

You agree to inform us by email at ayuda@comun.app of any actual or suspected security breach of your access to the ComunPay Services, your Passcode, or your CRB Wallet and of any fraud or attempted fraud as soon as possible. You should tell us IMMEDIATELY if you believe that a ComunPay Transfer or an otherwise unauthorized transaction has been made without your permission. If you tell us within two (2) business days after you learn of the loss or unauthorized transaction, you can lose no more than $50 if someone used the ComunPay Services on your behalf without your permission. If you do NOT tell us within two (2) business days after you learn of the loss or unauthorized transaction, and we can prove we could have stopped someone from using the ComunPay Services on your behalf without your permission if you had told us, you could lose as much as $500. Also, if your statement shows ComunPay Transfers that you did not make, tell us at once. If you do not tell us within sixty (60) days, or longer if required by applicable law or regulation, of the date we sent you or made available to you the first statement on which this actual or suspected security breach appeared, you may not get back any money you lost after the sixty (60) if we can provide that we could have stopped the security breach if you had told us in time. If you have a good reason that kept you from telling us during the foregoing time periods (such as a long trip or a hospital stay), we will extend the time periods. If you notify us verbally, we may require that you send us your complaint or question in writing within ten (10) business days. 

Please provide the following information when requesting assistance in the event of unauthorized transfers or other security breaches:

• Your name, email and phone number.
• Why you believe there is an error, and the dollar amount involved.
• Approximately when the error took place.

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We will determine whether an error occurred within ten (10) business days after we hear from you and will correct any error promptly. If we need more time however, we may take up to forty-five (45) days (or such longer period as may be permitted under applicable law) from the date we first hear from you to investigate your complaint or question. If we decide such a step is necessary, we will credit your CRB Wallet within ten (10) business days for the amount you think is in error, so that you will have the money during the time it takes us to complete our investigation. If we ask you to put your complaint or question in writing and do not receive it within ten (10) business days, we may, at our sole discretion, not credit your CRB Wallet.

We will tell you about the results within three (3) business days after completing our investigation. If we decide that there was no error, we will send you a written explanation. You may ask for copies of the documents that we used in our investigation.

For errors involving new users that signed up for ComunPay Services in the last thirty (30) days, we may take up to ninety (90) days to investigate your complaint or question. For such new users, we may take up to twenty (20) business days to credit your CRB Wallet for the amount you think is an error.

The following are not covered by the protections as provided by this Section 19 (Errors and Disputes Resolution):

• If you give someone access to your Comun Account or your access to Comun Services (e.g. by giving a family member or coworker your login information) and they use your Comun Account or your access to Comun Services without your knowledge or permission, unless you have notified us that transfers by that person are no longer authorized.
• If you, or someone else you are working with, are acting with fraudulent intent.

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20. Statements

You will get a monthly CRB Wallet statement through the Platform (unless there are no transfers in a particular month, and in any case, you will get the statement at least quarterly).

21. Feedback

If you provide any input, suggestions, ideas, or recommendations regarding problems with or proposed modifications or improvements to the ComunPay Services, whether solicited or unsolicited (collectively, "Feedback"), you hereby grant Comun a perpetual, irrevocable, worldwide, non-exclusive, fully-paid, royalty-free, transferable, and sublicensable right to use, modify, reproduce, distribute, create derivative works from, publicly perform, and publicly display the Feedback in any manner and for any purpose, including without limitation to improve the ComunPay Services and create other products and services.

22. Survival

In the event of termination of this Agreement or the ComunPay Services, the terms in this Agreement that by their nature are continuing shall survive such termination, including but not limited to the indemnification and hold harmless obligations, disclaimers and limitations of liabilities.

23. Business Days

For purposes of this Agreement, our business days are Monday through Friday. U.S. Federal holidays shall not be included and shall not be deemed business days. Any obligation falling due on a U.S. Federal holiday shall be deemed due on the next business day.

24. Contact Information

In case of errors or questions about the ComunPay Services or your ComunPay Transfers, you agree to promptly contact Customer Services by telephone at (646) 600-5660 or by email at ayuda@comun.app.

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