Compliance

1. Overview

Senoa operates a social commerce and marketplace platform with an integrated crypto wallet and payment system. Because digital assets and referral-based earning programs carry specific legal and regulatory considerations, this page summarizes the compliance-relevant aspects of how Senoa is designed to work.

3. Custodial Wallet Services

Senoa's wallet is custodial: Senoa, together with a third-party custody partner, holds the private keys associated with your wallet on your behalf, and you access your funds through your Senoa account rather than holding your own keys directly. This model gives us the ability to help with account recovery and support, but it also means you are relying on Senoa and its custody partner to safeguard those assets.

4. Digital Asset Risks

• Digital asset prices are volatile and can lose significant value quickly.
• Blockchain transactions are generally irreversible once confirmed.
• Regulatory treatment of digital assets varies by jurisdiction and continues to evolve.
• Technical issues at Senoa, its custody partner, or the underlying blockchain networks could affect access to your assets.

You should only hold or transact in digital assets you can afford to lose, and should not treat balances in your Senoa wallet as a substitute for insured bank deposits or savings.

5. KYC & KYB

Senoa uses tiered identity verification to help keep the Platform safe and to meet applicable legal obligations:

• Personal verification (KYC): name, date of birth, and government-issued ID, required to unlock higher listing limits and payment features.
• Business verification (KYB): registered business name, registration number, business type, country of registration, and supporting documentation, required for Verified Business status.
• Senoa Verified Seller: an informal-seller directory listing available after personal KYC; it does not itself constitute business registration or licensing.

We may decline, limit, or revoke verification, or restrict Platform access, where verification cannot be completed or where required by law.

6. Decentralized Identity (DID) & Data Separation

Personal identity data collected under Section 5 is kept structurally separate from the data used to personalize and profile your activity on the Platform. Day-to-day profiling, recommendations, and Advocate-targeting are performed against a Decentralized Identifier (DID), a pseudonymous identifier tied to your account, rather than against your name.

• Your name, date of birth, and KYC/KYB documentation are stored separately from the behavioral data associated with your DID and are not used to construct your DID-based profile.
• Because profiling happens at the DID level, a user's ordinary activity on the Platform remains pseudonymous within Senoa's own systems.
• This separation does not limit our ability to meet legal obligations: where required for sanctions screening, AML review (Section 7), fraud investigation, or a valid legal request, we can internally associate a DID with its underlying verified identity, without merging that link into the DID-based personalization profile.

See our Privacy Policy and Terms of Service for more on how this works.

7. AML & Sanctions Compliance

Senoa is developing an anti-money-laundering (AML) program appropriate to its risk profile, including sanctions screening and restrictions on use from jurisdictions subject to comprehensive sanctions (currently modeled on OFAC's comprehensively-sanctioned country list). Our specific AML policies, thresholds, and monitoring procedures are being finalized with legal counsel and will be reflected here once complete.

8. Not Investment Advice

Content shared by traders, signal providers, or other users on Senoa, including trade alerts and market commentary, is provided for informational purposes only and does not constitute investment, financial, or legal advice. Past performance does not guarantee future results. Advocacy commissions described in Section 9 are compensation for referral activity, not a return on an investment.

9. Advocacy Program Compliance

Senoa's own internal Advocacy program uses a flat, two-tier compensation structure (Tier 1 and Tier 2 only) and is not a multilevel marketing or pyramid program. Compensation is earned for genuine referral and marketing activity that leads to a qualifying action by a referred user, not for recruitment alone.

Businesses on the Platform may configure deeper multi-tier (Affiliate) referral structures for their own products or offerings. Each business is solely responsible for ensuring its own referral or compensation structure complies with applicable law in the jurisdictions where it operates; Senoa provides the underlying platform tooling only and does not review individual businesses' compensation structures for legal compliance.

NFT-based Passes sold within the Advocacy program grant access to platform features and the referral system; they are not marketed or sold as securities, and do not promise a specific financial return.

10. Regulatory Status & Ongoing Review

Senoa is in the process of working with legal counsel to determine what licenses or registrations, such as money-transmission or virtual-asset-service-provider (VASP) licensing, may be required in the jurisdictions where we operate, and to obtain any such licenses or registrations as needed. This page will be updated to reflect our regulatory status as that process concludes.

11. Reporting Concerns

If you believe you've encountered fraud, suspicious activity, or a potential compliance issue on Senoa, please report it to compliance@senoaapp.com.

12. Contact

Questions about this page can be sent to compliance@senoaapp.com. For general legal questions, see our Terms of Service or Privacy Policy.