Terms & Conditions

D.I.T.C. LLC operating as DITC.io · www.ditc.io · Version 3.0

I. General Provisions

These General Terms and Conditions (‘GTC’) of D.I.T.C. LLC, a Wyoming limited liability company operating as DITC.io (‘DITC’, ‘we’, ‘us’), govern the basic conditions under which DITC provides its clients with access to its technology platform and infrastructure, including the payment gateway software, APIs, merchant dashboard, transaction routing technology, technical integration, onboarding tooling, reporting tools, fraud-screening technology integration, technical support, and marketing activities.
DITC provides services to the client on the basis of a service agreement (‘Agreement’) and these GTC, which form an integral part of the Agreement. Unless otherwise specified in the Agreement, the provisions of the Agreement shall take precedence over the GTC.
Information about DITC: D.I.T.C. LLC (operating as DITC.io), a limited liability company incorporated under the laws of the State of Wyoming, USA (Wyoming Filing ID: 2026-001951426). Registered agent: Northwest Registered Agent Service Inc, 30 N Gould St Ste N, Sheridan, WY 82801, USA. Website: www.ditc.io. General enquiries: info@ditc.io. Support: support@ditc.io.
Important regulatory notice – role of DITC. DITC acts solely as a technology and infrastructure provider. DITC does not hold a banking licence, payment-institution licence, e-money licence, money services business registration, virtual-asset service provider registration, or any other financial-services authorisation, and is not a bank, money services business, payment institution, e-money institution or VASP. DITC does not at any time hold, receive, control, safeguard, transmit or route client or merchant funds or crypto-assets; does not perform settlement; does not make payouts; does not hold or manage rolling reserves; does not execute refunds or chargebacks financially; and does not provide any regulated financial service. All fund-holding, settlement, payout, rolling reserve, refund and chargeback money flows arising in connection with the Platform are performed exclusively by SENDORA INC. (‘Sendora’), an Alberta (Canada) corporation registered as a Money Services Business with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), MSB Registration No. C100000575, as the designated fund-holding and settlement entity (‘Settlement Entity’).
Contractual structure. The client contracts with DITC for technology services (platform access, gateway, routing, reporting and support). All funds flows relating to the client are performed by Sendora Inc. as Settlement Entity. DITC and Sendora are parties to a Technology and Infrastructure Services Agreement under which DITC provides the platform and related technology to Sendora and Sendora provides all fund-holding and settlement services. DITC is not a party to any settlement, payment or fund-holding contract between the client and Sendora.
No deposit protection. Funds held by Sendora Inc. are not deposits and are not covered by the Canada Deposit Insurance Corporation (CDIC), the US FDIC, the UK FSCS, any EU deposit-guarantee scheme, or any investor compensation scheme. Registration as a Money Services Business with FINTRAC is a registration obligation under Canadian anti-money-laundering legislation; it is not a prudential licence, does not constitute approval, endorsement or supervision of business conduct by the Government of Canada or FINTRAC, and does not provide any protection or guarantee of client funds.
Exclusion of US Persons. The services are not available to US Persons. ‘US Person’ means any citizen of the United States of America, any holder of a US permanent resident card (Green Card), any person resident or domiciled in the United States of America (including any state, territory, or possession thereof), and any legal entity organised or incorporated under the laws of the United States. DITC does not actively market or promote services to residents of the European Union, the European Economic Area, or the United Kingdom. Residents of those jurisdictions who access www.ditc.io do so on their own initiative and are solely responsible for verifying whether use of the services is lawful under the laws of their country of residence. DITC and Sendora reserve the right to refuse, suspend, or terminate access and services to residents of any jurisdiction where lawful provision is not possible, including immediately upon determining that a client is or has become a US Person.
The client declares that, prior to using the services, they were familiarised with the content of the Agreement, these GTC, the Privacy Policy, the Complaints Procedure, and the current Fee Schedule. All important information is available at www.ditc.io.
US Person representation. By registering for or using the services, the client expressly represents and warrants that they are not a US Person as defined in clause I.7 above, and that they will promptly notify DITC at legal@ditc.io if they become a US Person after registration. DITC may immediately terminate the Agreement and close the account without prior notice if this representation proves to be false or ceases to be true.
The client agrees to be informed of significant changes via the website or by email. The standard method of communication is electronic correspondence. DITC will send correspondence to the email address provided during registration.

II. Definition of Terms

For the purposes of the GTC and the Agreement:

Client – a natural or legal person who has entered into an Agreement with DITC on the basis of which the Platform and related services are made available to them.
Agreement / Framework Agreement – the service agreement concluded between the client and DITC, incorporating these GTC, the Fee Schedule, the Complaints Procedure, and the Privacy Policy.
DITC – D.I.T.C. LLC, the technology and infrastructure provider operating the Platform. DITC provides no regulated financial service and holds no client funds.
Settlement Entity / Sendora – SENDORA INC., an Alberta (Canada) corporation, registered office 200-1001 1 ST SE, Calgary, Alberta T2G 5G3, Canada, registered as a Money Services Business with FINTRAC under MSB Registration No. C100000575. Sendora is the sole entity that receives and holds client and merchant funds, performs settlement (fiat and USDT), executes payouts, withholds, manages and releases rolling reserves, debits and credits refunds and chargebacks, recovers negative balances, and performs foreign-exchange conversion.
Services – the technology services made available by DITC, including the payment gateway, APIs, merchant dashboard, transaction routing, onboarding tooling, reporting tools, fraud-screening technology integration and technical support, as specified in Section V, together with the fund-related services performed by Sendora as Settlement Entity.
Platform – the website www.ditc.io and any associated web or mobile application, API and dashboard.
Business day – a day on which commercial banks are generally open for business.
Market disruption – an unforeseeable event resulting in the inability to provide services, including infrastructure failures, cyber attacks, force majeure, or regulatory or legal restrictions.
PEP – Politically Exposed Person: a natural person who is or has been entrusted with a prominent public function, as defined under applicable AML regulations.
KYC/AML – Know-Your-Customer and Anti-Money-Laundering procedures required by applicable law and by Sendora’s compliance programme, operated on the Platform by DITC.
Third-Party Service Providers – external vendors engaged by DITC or Sendora to deliver mandatory compliance, technology, or operational services (see Section IX), as well as acquirers, card schemes, liquidity providers and other participants in the upstream processing chain.

III. Conclusion of the Agreement

The Agreement is concluded remotely via the Platform.
The registration and onboarding process proceeds as follows: (a) the client registers on the Platform and selects the account type; (b) the client provides all required identification and verification data; (c) the client completes identity verification, including document authentication and, where required, a liveness check, through the Platform or a designated third-party verification service.
The client is identified and verified in accordance with applicable KYC/AML regulations and is obliged to provide DITC and Sendora with necessary cooperation and documents for identification and ongoing due diligence at any time during the business relationship. DITC performs onboarding, verification and monitoring functions on the Platform as platform operator, including on behalf of Sendora.
DITC and Sendora reserve the right to require the client to use third-party systems for identity verification, transaction authentication, and compliance screening, including biometric verification tools, blockchain analytics providers, and other compliance technology platforms.
DITC reserves the right to refuse onboarding, or to suspend or close an existing account, at any time and without prior notice, if required by law, regulatory instruction, DITC’s platform risk policy or Sendora’s compliance and risk policy. Risk, underwriting, monitoring and suspension decisions are taken by DITC as platform operator, acting also on behalf of Sendora.

IV. Use of the Platform and Transactions

Transactions and instructions are submitted electronically via the Platform.
To initiate a transaction, the client: (a) logs in using their credentials; (b) enters all required transaction parameters; (c) confirms the instruction using the required authentication method (e.g. two-factor authentication or one-time code).
Instructions submitted outside standard processing hours may be treated as received on the next business day. The daily processing cut-off time is 16:45 UTC.
The client is obliged to comply with applicable transaction limits published in the current Fee Schedule.
DITC is not responsible for interruptions to the Platform for reasons beyond DITC’s, Sendora’s or the upstream processing chain’s control.
The client is only entitled to initiate transactions up to the available balance recorded for their account, subject to applicable limits.
The Platform transmits client instructions to Sendora and to the relevant acquirers, card schemes and liquidity providers. The execution of any resulting movement of funds is performed exclusively by Sendora as Settlement Entity. Sendora shall not dispose of client funds in any manner other than as directed by the client’s instructions transmitted through the Platform or as required by applicable law. DITC at no point takes possession or control of client funds.
Transaction confirmations, settlement reports and account statements are made available through the client portal on the Platform. Such reporting is a technology service; the underlying fund positions are held by Sendora.

V. Services Available

V.1 Technology services provided by DITC

Subject to eligibility, successful KYC/AML verification, and applicable regulatory requirements, DITC makes the following technology and infrastructure services available:

Payment gateway software, hosted checkout and API access.
Merchant dashboard, transaction routing technology and technical integration support.
Onboarding tooling and KYC/AML workflow technology.
Reporting, reconciliation and statement tools.
Fraud-screening and blockchain-analytics technology integration.
Client and merchant technical support, and marketing services.

V.2 Financial services provided by Sendora Inc.

The following fund-related services are provided exclusively by Sendora Inc. as Settlement Entity, and never by DITC:

Receipt and holding of all client and merchant funds.
Settlement in fiat currency and in USDT (ERC-20), including application of minimum settlement thresholds.
Execution of payouts and disbursements.
Withholding, management and release of rolling reserves.
Refund and chargeback debits and credits, and recovery of negative balances.
Foreign-exchange conversion between supported currency pairs.

Card acquiring, scheme processing and liquidity are provided by acquirers, card schemes and liquidity providers as generic third parties in the upstream processing chain. Availability, scope, and pricing of individual services may change at any time. Clients will be notified of material changes in accordance with Section XI.

VI. Fees and Charges

Applicable fees are published in the Fee Schedule on the Platform. Technology and platform fees are charged by DITC; settlement, payout, refund, chargeback and FX-related fees are charged and applied by Sendora as Settlement Entity. By using the services, the client agrees to pay all applicable fees.
Fees may be charged in fiat currency (EUR, USD, or other supported currencies) or, where applicable, in stablecoins (USDT) at the exchange rate prevailing at the time of the transaction.
Fees may be deducted by Sendora from amounts due for settlement before payout, in accordance with the Fee Schedule and the applicable merchant documentation.
DITC reserves the right to amend the Fee Schedule upon 30 days’ advance notice. Continued use of the services after the effective date constitutes acceptance.
DITC and Sendora are each entitled to deduct applicable taxes, levies, or withholding amounts from payments in accordance with applicable law.

VII. Security and Client Obligations

The client is obliged to use the Platform in a manner that does not compromise their account security, including complying with safe online practices and not disclosing access credentials to any third party.
The client must notify DITC immediately of any suspected unauthorised access, loss or theft of credentials, or suspicious transaction. Notifications: support@ditc.io or security@ditc.io. The client bears full responsibility for any misuse until notification is made.
DITC will block the client’s Platform access as soon as unauthorised use is reported and will notify Sendora so that pending fund movements can be halted where possible. Responsibility for further misuse is assumed from the moment of reporting.
The client agrees to: (a) use the Platform and services only for lawful purposes; (b) not use services for money laundering, terrorist financing, sanctions evasion, tax evasion, fraud, or any other illegal activity; (c) not attempt to circumvent security measures or access controls; (d) comply with all applicable laws.
DITC will notify the client of suspected unauthorised or fraudulent use by email or through a notice on the Platform.

VIII. Third-Party Access

The client may authorise a third party to access information about their account or to initiate certain transactions, provided the third party has properly identified itself and acts in accordance with applicable legal regulations. Any instruction from an authorised third party will be treated as an instruction from the client.
DITC and Sendora may deny third-party access if there is concern about unauthorised or fraudulent access. The client will be informed unless doing so would pose security risks or violate legal requirements.
If the client grants a third party access to their account data, DITC may share relevant account information with that third party to the extent necessary. The client may revoke such consent at any time.

IX. Data Processing and Third-Party Service Providers

9.1 General. DITC and Sendora process personal data of clients in accordance with applicable data-protection regulations, including the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) in respect of Sendora and, where applicable, the GDPR. Full details of data-processing activities, legal bases, retention periods, and client rights are set out in the DITC Privacy Policy at www.ditc.io/privacy.

9.2 Categories of Data Processed. DITC and its third-party service providers may collect and process the following categories of personal data:

Identity data: full name, date of birth, nationality, government-issued identity documents, facial biometric data.
Contact data: residential address, email address, telephone number.
Financial data: source of funds and wealth declarations, transaction history, account balances, cryptocurrency wallet addresses.
Compliance data: sanctions screening results, PEP status, adverse media checks, blockchain analytics results.
Technical data: IP address, device identifiers, browser type, session logs.
Complaints and correspondence data.

9.3 Purposes and Legal Bases. Personal data is processed for the following purposes:

Identity verification and KYC/AML compliance – legal obligation.
Onboarding and ongoing customer due diligence – legal obligation / contractual necessity.
Transaction processing, settlement and account management – contractual necessity.
Fraud prevention, sanctions screening, and financial-crime monitoring – legal obligation / legitimate interest.
Regulatory reporting, including reporting by Sendora to FINTRAC – legal obligation.
Complaints management and dispute resolution – legal obligation / contractual necessity.
Marketing communications – consent (revocable at any time).
Website analytics and platform improvement – legitimate interest / consent.

9.4 Mandatory Third-Party Service Providers. Certain third-party vendors are technically and legally required to operate the Platform and to fulfil DITC’s and Sendora’s regulatory obligations. The engagement of these providers is mandated by applicable AML, KYC, and financial-crime regulations. The client acknowledges and consents to the processing of their personal data by these providers as a necessary condition of using the services. The following list is not exhaustive and may be supplemented or amended as regulatory requirements or operational needs change. DITC will update the current provider list at www.ditc.io/processors and will notify clients of any material changes in accordance with Section XI:

Provider	Purpose	Legal Basis
Sumsub (sumsub.com)	Identity verification (KYC), liveness checks, document authentication, biometric data processing, and ongoing customer due diligence.	Legal obligation (AML/KYC)
Chainalysis (chainalysis.com)	Blockchain analytics and cryptocurrency transaction monitoring; screening of crypto wallet addresses for sanctions, fraud, and financial-crime indicators.	Legal obligation (AML/sanctions)

9.5 Additional Third-Party Providers. DITC may engage additional third-party service providers for hosting, cloud infrastructure, transaction processing technology, analytics, marketing, and customer-support purposes. A current list is published in the Privacy Policy at www.ditc.io/privacy. All third-party providers are bound by appropriate data-processing agreements compliant with applicable data-protection regulations.

9.6 International Data Transfers. Client data may be transferred to and processed in countries outside the client’s country of residence, including Canada and the United States. DITC ensures such transfers are subject to appropriate safeguards, such as standard contractual clauses or equivalent mechanisms recognised under applicable law. Full details are in the Privacy Policy.

9.7 Data Retention. Personal data is retained as long as necessary to fulfil the purposes described above and to comply with applicable legal and regulatory requirements. As a general rule: account and transaction data – 5 years after account closure (extendable up to 10 years under applicable AML law); identity documents – 5 years after end of the business relationship; compliance records – in accordance with applicable regulatory requirements, including the record-keeping obligations of the Canadian Proceeds of Crime (Money Laundering) and Terrorist Financing Act applicable to Sendora. Full retention schedule: www.ditc.io/privacy.

9.8 Client Rights. Subject to applicable law, clients have the right to access, correct, erase, restrict, or object to the processing of their personal data, and the right to data portability. Requests: privacy@ditc.io. Certain rights may be limited where processing is required to fulfil legal obligations. Clients also have the right to lodge a complaint with a competent supervisory authority, including the Office of the Privacy Commissioner of Canada in respect of processing by Sendora.

X. Complaints and Dispute Resolution

If the client believes DITC has not properly fulfilled its obligations, they are entitled to file a complaint in writing to complaints@ditc.io, including their full name, account identifier, a description of the matter, and any relevant transaction references.
DITC will acknowledge receipt and aims to resolve complaints within 15 business days. If circumstances prevent resolution within this period, the client will be informed and a response provided within 35 business days at the latest.
Complaints concerning fund holding, settlement, payouts, rolling reserves, refunds or chargebacks are forwarded by DITC to Sendora Inc. as Settlement Entity for handling. Correspondence for Sendora is routed via support@ditc.io, with DITC acting as platform intermediary.
If the client is not satisfied, they may escalate to any competent regulatory or dispute-resolution authority in their jurisdiction.
All formal complaints are managed through DITC’s complaints management system and a register of all complaints received is maintained. The full Complaints Procedure is published at www.ditc.io/complaints.

XI. Amendments to These GTC

DITC is entitled to unilaterally amend these GTC in connection with changes in applicable law, introduction of new services, changes in operating procedures, or amendments to Sendora’s compliance requirements.
Clients will be notified of material changes by email and via the Platform at least 30 days before the change takes effect. The updated GTC will be published at www.ditc.io.
If the client does not notify DITC in writing of their rejection before the effective date, the amended GTC shall be deemed accepted. If the client rejects the proposed changes, they have the right to terminate the Agreement with immediate effect.
Correction of typographical errors or factual inaccuracies is not a material amendment and does not require advance notice.

XII. Termination of the Agreement

The Agreement may be terminated in the following ways:

By mutual written agreement of the parties.
By either party upon written notice, with a notice period of one (1) month for the client and two (2) months for DITC.
By DITC with immediate effect, without notice, if: (a) the client breaches these GTC; (b) the client fails KYC/AML verification or fails to provide required documentation; (c) the client’s account poses increased AML/sanctions risk; (d) required by law, regulatory instruction, DITC’s platform risk policy or Sendora’s compliance and risk policy.
Automatically, due to long-term inactivity: accounts with no activity for 18 consecutive months may be frozen; if inactivity continues for a further 12 months, the Agreement may be terminated without notice.
Upon dissolution of D.I.T.C. LLC or termination of the Technology and Infrastructure Services Agreement between DITC and Sendora, in which case clients will be given reasonable notice.

Upon termination, all outstanding fees and obligations remain due. Any final settlement, release of rolling reserves and return of remaining client funds is performed by Sendora Inc. as Settlement Entity, subject to applicable legal requirements and to any applicable rolling reserve release schedule. DITC will provide reasonable technical assistance and reporting to facilitate an orderly closure but does not itself hold or transfer any funds.

XIII. Limitation of Liability

To the fullest extent permitted by applicable law, D.I.T.C. LLC shall not be liable for any loss or damage arising from: (a) the use of, or inability to use, the Platform; (b) any fund-related service provided by or through Sendora Inc., including settlement, payouts, rolling reserves, refunds and chargebacks; (c) market disruptions, force majeure events, or acts or omissions of third-party service providers, acquirers, card schemes or liquidity providers.
D.I.T.C. LLC shall not be liable for any indirect, incidental, consequential, or special damages, including loss of profit, loss of data, or loss of opportunity.
D.I.T.C. LLC’s total aggregate liability to a client for any claim shall not exceed the fees actually paid by that client to D.I.T.C. LLC in the twelve (12) months immediately preceding the event giving rise to the claim.
Nothing in these GTC limits liability for fraud, gross negligence, or wilful misconduct on the part of D.I.T.C. LLC.
The Platform and all technology services are provided on an ‘as is’ and ‘as available’ basis. D.I.T.C. LLC makes no representations or warranties, express or implied, regarding accuracy, completeness, reliability, or fitness for purpose.

XIV. Governing Law and Jurisdiction

These GTC and any Agreement concluded pursuant to them shall be governed by and construed in accordance with the laws of the State of Wyoming, USA, without regard to its conflict-of-law provisions.
For clients resident in the European Economic Area, mandatory consumer-protection provisions of the client’s country of residence may additionally apply and shall not be excluded by these GTC.
Any dispute shall first be attempted to be resolved amicably within 30 days of written notice. If unresolved, disputes shall be submitted to the exclusive jurisdiction of the courts of the State of Wyoming, USA.
The contractual relationship between the client and Sendora Inc. in respect of fund holding and settlement is governed by the terms agreed with Sendora; nothing in this Section extends DITC liability to those relationships.
All communication between DITC and the client shall be conducted in English.

XV. General and Final Provisions

DITC is entitled to refuse to provide a specific service if the client fails to provide all required information and documents, or if required by law or by Sendora as Settlement Entity.
The client is not entitled to assign, pledge, or otherwise transfer their rights or obligations under the Agreement without the prior written consent of DITC.
Failure to exercise any right under the Agreement shall not be construed as a waiver of that right.
If any provision of these GTC is held to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.
The client is entitled to obtain, upon written request, a copy of the Agreement, these GTC, the Privacy Policy, the Complaints Procedure, and the current Fee Schedule.
These GTC are effective from August 1, 2026, and replace all prior terms and conditions, including Version 2.0 (effective April 21, 2026) and Version 1.0 (effective April 19, 2026).

Change Log

Version	Effective date	Summary of changes
1.0	April 19, 2026	Initial version of the General Terms and Conditions.
2.0	April 21, 2026	Revised structure; expanded data-processing section including mandatory processors (Sumsub, Chainalysis); US Person exclusion and representation; limitation of liability and Wyoming governing law provisions.
3.0	August 1, 2026	Restructuring: DITC LLC repositioned as pure technology platform and infrastructure provider; all client fund holding, settlement, payouts and rolling reserve management transferred to Sendora Inc. (FINTRAC MSB C100000575); WAGO Bank Ltd removed.

D.I.T.C. LLC (DITC.io) · 30 N Gould St Ste N, Sheridan, WY 82801, USA · support@ditc.io · www.ditc.io