PUBLIC OFFER (LICENSE AGREEMENT) FOR THE GRANT OF THE RIGHT TO USE THE "ALGOTUN" SOFTWARE

Date of revision: "09" July 2026 · Version: 2.0

Place of publication: https://algotun.com/legal/terms · Applicable jurisdiction: Russian Federation

Summary — 8 points that are important to understand

1. What Algotun is. Cloud software (SaaS) for automating trading strategies on financial markets. As of the date of this revision, the cryptocurrency exchanges Binance, Bybit, and OKX (perpetual futures market) are supported; the list of supported exchanges, markets, and instruments may expand — up to traditional exchanges of various countries and other asset classes — without re-executing the agreement (see clause 1.1). This is a technical tool, and not a financial service or an investment recommendation (Federal Law No. 259-FZ).

2. Non-custodial. The Contractor does not accept and does not store Your funds. Assets remain in Your exchange account; the Platform connects to it via API keys and uses them solely for reading data and executing trading operations — the Platform has no funds-withdrawal functionality.

3. The algorithm operates automatically. By activating it, You give unconditional consent to the execution of transactions without confirming each one. You understand and accept that the result is not guaranteed.

4. Refund of funds. You may withdraw at any time (Article 32 of the Law on Protection of Consumer Rights): the cost of the unused part of the subscription is refunded in full, with no deduction of bank or payment system fees. In the event of improper provision of the service — under Article 29 of the Law on Protection of Consumer Rights.

5. Limitation of liability. No more than the amount actually paid by the User for one (1) month preceding the event that gave rise to the claim.

6. Fiscal receipt. After payment, You receive a fiscal receipt generated in the "My Tax" (Moy Nalog) application (Federal Law No. 422-FZ). Purpose of payment: "Payment for access to the Algotun software complex (license fee)".

7. Taxes, sanctions, currency control. You independently comply with Federal Laws No. 173-FZ, No. 259-FZ, No. 331-FZ, tax legislation, and sanctions restrictions. The Contractor is not a tax agent and not an operator of digital financial assets.

8. Disputes. Applicable law — the Russian Federation. Jurisdiction — at the User's choice (Article 17 of the Law on Protection of Consumer Rights). A pre-trial procedure is mandatory; the deadline for responding to a claim is 10 business days.

This document is a public offer (Article 437 of the Civil Code of the Russian Federation) of the individual Alexander Sergeevich Borodin, Taxpayer Identification Number (INN) 323401195508, applying the special tax regime "Tax on Professional Income" (Federal Law No. 422-FZ) (hereinafter — the "Contractor"), and is addressed to any legally capable individual who has reached 18 years of age (hereinafter — the "User").

Acceptance of the offer. Full and unconditional acceptance of the terms of this Offer (acceptance) is effected by the User by placing separate marks ("checkboxes") in the corresponding fields on the Website — separately for the Offer, the Privacy Policy, and the Risk Disclosure — and/or by commencing use of the Platform. The date of acceptance is the date of the User's first log-in to the Personal Account after payment. The fact of acceptance is recorded by the Contractor (date, time, IP address, document version).

1. TERMS AND DEFINITIONS

1.1. Platform (Service) — the cloud software complex "Algotun", hosted at https://algotun.com, providing tools for automating trading strategies on financial markets. As of the date of this revision, the Platform supports connection to the cryptocurrency exchanges Binance, Bybit, and OKX on the perpetual futures market (USDT-Perpetual). The Contractor is entitled, as the Service develops, to add support for other trading venues — both cryptocurrency exchanges and traditional (stock, derivatives, commodity, and other) exchanges of various countries — as well as other markets, trading sections, and types of financial instruments and assets (including the spot market, shares, bonds, futures, options, currency, commodity, and other instruments). The current list of supported exchanges, markets, and instruments is displayed in the Personal Account interface. Expansion of the list of supported exchanges, markets, and instruments does not change the essence of this Offer, does not worsen the User's position, and does not require re-execution or repeated acceptance of the agreement; the User independently selects which of the available exchanges, markets, and instruments to use.

1.2. Algorithm (Bot) — a software module operating on the Contractor's server that performs automatic analysis of market data and generation of trading commands in accordance with the settings specified by the User.

1.3. Automatic execution — a Platform operating mode in which trading commands are sent to the User's account on the Exchange via the API interface without prior confirmation of each transaction by the User.

1.4. Exchange — a third-party trading venue (cryptocurrency, stock, derivatives, commodity, or other exchange) from among those supported by the Platform, on which the User independently stores their assets and on which the Platform's trading commands are executed.

1.5. API key — a pair of technical tokens (public and secret key) issued by the Exchange that allows the Platform's software to execute trading commands on behalf of the User in their exchange account.

1.6. Personal Account — a section of the Website accessed via the User's login/password; the interface for configuring Algorithms, managing the subscription, and API keys.

1.7. Penalty (Neustoyka) — a measure of liability applied solely in cases directly provided for by the mandatory rules of the legislation of the Russian Federation.

2. SUBJECT OF THE AGREEMENT

2.1. License. The Contractor grants to the User, on subscription terms, a simple (non-exclusive) non-transferable license to use the Platform under the SaaS model (software as a service) for personal, non-commercial purposes for the term of the subscription.

2.2. Legal status. The Contractor is not:

—an investment adviser within the meaning of Federal Law No. 39-FZ of 22 April 1996 "On the Securities Market";

—a professional participant in the securities market;

—a person carrying out the activity of managing securities or digital assets;

—a person providing individual investment recommendations (IIR).

The Platform constitutes solely a technical tool (software) for automating trading strategies initiated by the User. Any information provided by the Platform (statistics, forward tests, algorithm settings, interfaces) is of a reference and technical nature and does not constitute an investment recommendation.

2.3. Non-custodial model. The Contractor does not accept, store, or manage the User's monetary funds or digital assets. All assets are held in the User's accounts on third-party Exchanges. The Contractor's access to the User's exchange account is effected via API keys provided by the User and is used solely for reading account data and executing trading operations. Functionality for the withdrawal of funds, internal transfers, or other management of the exchange account is absent from the Platform and is not used — regardless of the permissions set on the API key.

2.4. Legal status with respect to digital assets and payments. The Contractor is not:

—an operator of the exchange of digital financial assets, an operator of an information system for the issuance of digital financial assets within the meaning of Federal Law No. 259-FZ of 31 July 2020 "On Digital Financial Assets, Digital Currency…";

—an operator for accepting payments from individuals within the meaning of Federal Law No. 103-FZ of 3 June 2009;

—a bank payment agent or sub-agent within the meaning of Federal Law No. 161-FZ of 27 June 2011 "On the National Payment System";

—a credit institution or another organization supervised by the Bank of Russia.

3. PROCEDURE FOR THE PROVISION OF SERVICES AND EXECUTION OF TRANSACTIONS

3.1. Connecting API keys. To use the Platform, the User independently creates API keys in their Exchange personal account and provides them to the Platform.

3.2. Requirements for and recommendations on API keys. For the Platform to operate, the API key must grant the rights to read account data (Read) and to execute trades on the futures market (Trade / Futures Trading). Other key permissions are not used by the Platform.

The configuration of the API key — the set of permissions and the binding of the key to IP addresses (IP whitelist) — falls within the competence and area of responsibility of the User. For security purposes, the Contractor recommends: creating a separate API key for the Platform; disabling permissions not required for trading (withdrawal of funds, internal transfers, sub-account management); enabling the binding of the key to the IP addresses specified in the Personal Account. Following these recommendations is not a condition for the provision of access to the Platform. The risks associated with extended API key permissions and with the use of the same key outside the Platform are borne by the User.

3.3. Automatic execution. By activating the Algorithm, the User gives unconditional consent to the Platform's execution of transactions on the Exchange on their behalf in automatic mode. The User confirms that they understand the operating principle of "black box" algorithms — the decision-making logic may not be disclosed in real time. The Contractor does not carry out prior moderation of each transaction and does not guarantee that transactions will conform to the User's expectations, unless a direct cause-and-effect relationship with the Contractor's intentional actions or gross negligence is proven.

3.4. User's responsibility. The User independently bears responsibility for:

—the sufficiency of funds in the exchange account for the execution of trading commands;

—the correctness of the Algorithm's settings (risk parameters, selection of trading pairs, position size, leverage);

—compliance with the rules, regulations, and terms of the Exchange on which trading is conducted;

—the conformity of their actions with the requirements of the legislation applicable to them, including Federal Laws No. 173-FZ, No. 259-FZ, No. 331-FZ, and the Tax Code of the Russian Federation.

3.5. Prohibition of unfair trading practices. The User undertakes not to use the Platform for:

—pump-and-dump schemes, wash trading, spoofing, layering, or other actions aimed at artificially manipulating the price or volume of trading on the Exchange;

—trading in circumvention of sanctions, currency, or other restrictions applicable to the User;

—any other activity that violates the law, the Exchange's regulations, or the rights of third parties.

Violation of this clause constitutes grounds for immediate suspension of access without a refund of funds for the paid period, with possible notification of the Exchange and the competent authorities.

4. COST AND PROCEDURE FOR PAYMENTS

4.1. Subscription pricing and prepayment.

4.1.1. Access to the Platform is provided on the terms of 100% prepayment (subscription) in accordance with the subscription pricing established by Annex No. 1 to this Offer, "Subscription Pricing" (published at https://algotun.com/legal/pricing and forming an integral part of the Offer), available to the User prior to payment; the total cost for the configuration selected by the User is displayed in the Personal Account (the "Subscription" section) prior to payment. The subscription cost depends on the scope of functionality selected by the User (the number of connected exchanges and active trading settings) and is calculated monthly. By paying for a subscription, the User acquires a defined period of use of the Platform with the selected functionality. Purpose of payment: "Payment for access to the Algotun software complex (license fee)".

4.1.2. The cost of using the Platform depends on the scale of the trading being serviced. If, at the moment of payment, the aggregate amount of funds on the connected exchange accounts serviced by the Platform exceeds the threshold specified in Annex No. 1, an additional charge for the extended scope of service is included in the subscription cost at the rate specified in Annex No. 1: a percentage per month of the amount of the excess determined as of the moment of payment. This charge is calculated once — at payment (upon renewal, it is calculated anew as of the moment of renewal), is fixed for the entire period being paid for, and is not recalculated during that period either upwards or downwards — regardless of subsequent changes in the amount of funds on the accounts or changes in the composition of services. This charge forms part of the license fee for the use of the Platform and does not constitute remuneration for asset management: the Contractor does not accept or dispose of the User's funds (clause 2.3 of this Offer).

4.1.3. The total cost, including the charge under clause 4.1.2, is displayed to the User in the Personal Account prior to payment. No additional or recurring debits are made from the User's bank card or account during the paid period. The current state of the paid period is displayed in the Personal Account.

4.1.4. For the purposes of calculating the charge under clause 4.1.2, amounts denominated in the exchange's units of account (USDT) are converted into Russian rubles at the USDT-to-ruble rate specified in Annex No. 1. All accruals and settlements with the User are made in Russian rubles.

4.1.5. The subscription pricing, rates, thresholds and conversion rate effective at the moment of payment are fixed for the entire paid period and are not subject to unilateral change during that period.

4.1.6. Subscription ordering procedure: the User registers on the Website, selects a configuration (exchanges, trading settings) and a subscription term in the Personal Account, and makes the payment. Access to the paid functionality is granted automatically immediately after the payment is confirmed by the payment infrastructure operator.

4.1.7. By paying for a subscription, the User acquires time of use of the Platform: N months = N × 30 days; the remaining time is tracked to the second. Changes in the amount of funds on the exchange accounts during the paid period do not affect the subscription term. The term changes only when the User changes the composition of services (connecting or disconnecting exchanges, changing the composition of running trading settings and the combinations used, using leverage): the remaining time is recalculated in proportion to the full monthly cost of the previous and the new configuration, determined at the prices in effect at the moment of payment, including the fixed charge under clause 4.1.2; reducing the scope of services extends the term, while increasing it shortens the term. Changes to the prices specified in Annex No. 1 do not affect the term or conditions of the period already paid for (clause 4.1.5). If trading is not running on any exchange, the minimum cost of the Start subscription with one exchange is used for the recalculation. The current time remaining and the effective cost are displayed in the Personal Account.

4.2. Recognition of revenue. The Contractor's obligations to provide technical access to the Platform are deemed fulfilled in full for each day of the paid period during which the Platform was available to the User.

4.3. Refund of monetary funds.

4.3.1. *Right to withdraw from performance of the agreement (Article 32 of the Law on Protection of Consumer Rights).* The User is entitled at any time to withdraw from performance of the agreement by sending an application to the email info@algotun.com. The refund is made in the amount of the cost of the paid but unused subscription period — in proportion to the time remaining until the end of the paid period. Bank and payment system fees are not deducted from the refund amount. The refund is made using the same payment method by which the payment was made, within 10 (ten) business days from the moment of receipt of the application.

4.3.2. *Refund in the event of improper provision of the service (Article 29 of the Law on Protection of Consumer Rights).* In the event that the Contractor violates the deadlines for the commencement or completion of the provision of the service, or upon discovery of material defects, the User is entitled to demand termination of the agreement and full compensation for losses.

4.3.3. The right to use the Platform is deemed to have been duly provided from the moment the User is granted technical access to the Platform's functionality. Claims based on a subjective assessment of the effectiveness of the algorithms, the market results of trading, or a change in the User's financial decision do not constitute grounds for a refund of funds for the period of subscription actually provided.

4.4. Fiscal receipt. After making a payment, the User receives an electronic fiscal receipt generated in accordance with Federal Law No. 422-FZ in the "My Tax" (Moy Nalog) application — either by the Contractor personally or automatically by the payment infrastructure operator authorized by the Contractor in the "My Tax" application. The receipt is sent to the User's email and/or provided upon request. The Contractor is obliged to keep copies of receipts for 5 years (part 4 of Article 13 of Federal Law No. 422-FZ).

4.5. Payment methods.

4.5.1. Payment for the subscription is made in Russian rubles through Russian payment services: NSPK "Mir" bank cards, bank cards of other issuers (if supported by the aggregator), the Faster Payments System (SBP), and other methods specified on the Website.

4.5.2. Payment in digital currency from Users who are residents of the Russian Federation is not accepted on the basis of Federal Law No. 331-FZ of 14 July 2022 and clause 5 of Article 14 of Federal Law No. 259-FZ (prohibition of the use of digital currency as a means of payment in the territory of the Russian Federation).

4.5.3. Payments are accepted through the payment infrastructure operator (payment service) specified on the payment page. Bank card details are entered by the User on the secure page of the payment service, which complies with the PCI DSS standard, and are not transferred to or stored by the Contractor.

4.6. End of the paid period. Upon expiry of the paid subscription period, the Platform switches to "close-only" mode: new trading positions are not opened, while already open positions continue to be serviced in automatic mode until they are closed. The closing of an open position occurs upon the occurrence of any of the provided exit conditions: the triggering of a Stop-Loss or Take-Profit, or the fulfilment of the closing conditions embedded in the trading strategy (including before the price reaches the Stop-Loss / Take-Profit levels). To resume the opening of new positions, the User renews the subscription in the Personal Account.

4.7. Change in the Contractor's tax status. In the event that the Contractor loses the status of a payer of the tax on professional income (including upon exceeding the income limit established by law — 2.4 million rubles per calendar year — or upon voluntary transfer to another tax regime: an individual entrepreneur under the simplified taxation system, an individual entrepreneur under the patent taxation system, registration of a legal entity), the Contractor notifies the User by email no less than 14 (fourteen) calendar days in advance. From the moment the new legal status takes effect, all previously concluded agreements are deemed concluded on behalf of the Contractor in their new legal status; the legal nature and procedure for performance of the agreement do not change. A change in the Contractor's tax status does not constitute grounds for a refund of funds for the period of subscription actually provided.

5. LIMITATION OF LIABILITY

5.1. Limitation of liability. The Contractor's aggregate liability for any suits, claims, or demands arising out of this Offer or connected with the use of the Platform is limited to the amount actually paid by the User for one (1) month immediately preceding the occurrence of the event that gave rise to the claim. The said limit applies to the maximum extent permitted by the legislation of the Russian Federation and does not limit the Contractor's liability for intentional harm to life and health, as well as for other harm for which liability cannot be limited by agreement of the parties by virtue of the mandatory rules of law.

5.2. Exclusion of lost profit. By losses, the Parties understand solely actual damage (documented expenses, property losses). Lost profit, including unrealized profit from trading operations, is not compensated under any circumstances, to the maximum extent permitted by law.

5.3. Disclaimer of liability for market risks. The Contractor is not liable for the User's financial losses arising as a result of:

(a) market volatility, slippage, or insufficient liquidity;

(b) technical failures of third-party Exchanges, changes in their API, regulations, listing policy, or tariffs;

(d) the User's use of leverage and the risk of forced liquidation of positions;

(e) compromise of the User's credentials, exchange account, devices, or means of communication;

(f) the User's independent configuration of the Algorithm's parameters (choice of strategy, leverage, position size).

5.4. "As is" principle. The Platform is provided on an "as is" basis in accordance with the practice of Article 428 of the Civil Code of the Russian Federation. The Contractor does not guarantee the uninterrupted, error-free operation of the Platform, compatibility with all Exchanges, or the achievement by the User of any financial results.

5.5. Force majeure. The Parties are released from liability for the non-performance of obligations if it is caused by force majeure circumstances (Article 401 of the Civil Code of the Russian Federation), including: failures in the operation of third-party Exchanges, changes to their API, regulatory blocking of access to crypto-infrastructure, actions of state authorities, mass cyberattacks, data center outages, failures in power supply and communication networks, epidemics, military operations.

5.6. Indemnification by the User. The User shall compensate the Contractor for documented losses, fines, and expenses (including reasonable legal costs) arising as a result of:

(a) the User's violation of this Offer, the Privacy Policy, or the Risk Disclosure;

(b) the unlawful use of API keys, the exchange account, or the Platform;

(d) the User's provision of inaccurate information during registration and use of the Platform.

6. INTELLECTUAL PROPERTY

6.1. The exclusive rights to the software code of the Platform, the Algorithms, the interfaces, the design, and accompanying materials belong to the Contractor as the author and rights holder.

6.2. The User is granted a simple (non-exclusive), non-transferable license to use the Platform solely for personal, non-commercial purposes for the term of the subscription.

6.3. It is prohibited to:

—perform actions aimed at revealing the operating logic of the Algorithms, decompilation, disassembly, or reverse engineering of the code executed on the Contractor's server;

—create derivative products based on the Platform;

—use the Platform to provide services to third parties;

—transfer access to the Personal Account to third parties.

7. PERSONAL DATA AND CONFIDENTIALITY

7.1. The processing of the User's personal data is carried out by the Contractor in accordance with the Privacy Policy posted at https://algotun.com/legal/privacy. The Policy is an integral part of this Offer.

7.2. By accepting this Offer, the User confirms that they have familiarized themselves with the Privacy Policy, understand its provisions, and give consent to the processing of personal data for the purposes and in the scope specified in the Policy.

8. USER'S REPRESENTATIONS AND WARRANTIES

8.1. By accepting this Offer, the User represents and warrants that they:

—are a legally capable individual who has reached 18 years of age;

—have fully familiarized themselves with this Offer, the Privacy Policy, and the Risk Disclosure posted on the Website;

—are aware of the risk of the complete loss of the deposit when using algorithmic trading and financial instruments;

—use for trading only free monetary funds, the loss of which will not lead to critical life consequences;

—independently assess the risks of using leverage and accept the risk of forced liquidation of positions;

—do not rely on the Platform as the sole source of information for making financial decisions;

—are not on the sanctions lists of the Russian Federation or the UN, and do not use the Platform for activities that violate applicable sanctions restrictions;

—independently comply with the tax, currency, and other legislation applicable to them;

—waive any claims against the Contractor in the event of financial losses not connected with the Contractor's intentional actions or gross negligence.

9. APPLICABLE LAW AND DISPUTE RESOLUTION

9.1. Applicable law. The law of the Russian Federation applies to the relations of the parties.

9.2. Pre-trial procedure. All disputes are subject to mandatory pre-trial settlement. A claim is sent in writing to the Contractor's email info@algotun.com. The deadline for responding to a claim is 10 (ten) business days from the moment of its receipt.

9.3. Jurisdiction. In the event that agreement is not reached through the pre-trial procedure, the dispute is subject to consideration in court. The User, being a consumer, is entitled to bring a suit at their choice — at their place of residence or stay, at the place of conclusion or performance of the agreement, or at the Contractor's location — in accordance with Article 17 of the Law of the Russian Federation No. 2300-1 of 7 February 1992 "On Protection of Consumer Rights" and Article 29 of the Civil Procedure Code of the Russian Federation.

10. AMENDMENT OF THE AGREEMENT AND FINAL PROVISIONS

10.1. Amendments to the Offer. The Contractor is entitled to make amendments to this Offer. Of material amendments (changes to subscription pricing, the scope of services, limitations of liability, the procedure for processing personal data, payment methods), the Contractor notifies the User by posting the relevant notice in the Personal Account no less than 7 (seven) calendar days before the date the amendments take effect. The notice is deemed received by the User from the moment it is posted in the Personal Account. The User undertakes to independently and regularly review notices in the Personal Account.

10.2. User's right. During the period of the said notice, the User is entitled to withdraw from continuing the agreement with a refund of funds for the unused subscription period in the manner set out in clause 4.3 of this Offer. Continued use of the Platform after the amendments take effect constitutes acceptance of the new revision of the Offer.

10.3. Term of the Offer. This Offer takes effect from the date of acceptance and is valid indefinitely until the User's access to the Platform is terminated.

10.4. Details for notifications. All notices sent by the parties are deemed delivered upon dispatch to the email specified in the User's Personal Account or in the Contractor's details in this Offer.

11. CONTRACTOR'S DETAILS

Full name: Alexander Sergeevich Borodin

Taxpayer Identification Number (INN): 323401195508

Tax status: Payer of the tax on professional income (self-employed), Federal Law No. 422-FZ

Email: info@algotun.com

Website: https://algotun.com