# Welcome

SpendX is an innovative AI agent on Telegram, created in partnership with Visa and Google Cloud to revolutionize personal finance management. By blending advanced AI capabilities with Web3 incentives, SpendX turns everyday spending into a gamified experience, letting users earn rewards and engage with cryptocurrency effortlessly.

Simply share your income or expenses, and the AI agent takes over as your personal finance assistant. It provides emotionally engaging feedback, organizes your transactions into categories, and tracks your financial progress.

<figure><img src="/files/IY6Ak6g1GzrcuAWNJqAj" alt=""><figcaption></figcaption></figure>

### Why Telegram Mini App?

Telegram Mini App is an open platform for projects to build and deploy crypto-friendly apps. It provides access to 900M Telegram users.

Telegram Mini App has demonstrated significant potential in introducing cryptocurrencies to broader audiences through Tap-To-Earn games. These games have proven successful in attracting new users due to their easy accessibility and engaging mechanics. However, despite their initial appeal, they often lack the depth required to maintain long-term user engagement.

### Why SpendX?

SpendX aims to address this gap by merging traditional finance with Web3 and AI, not only offering a more sustainable and engaging user experience, but also setting a new standard for how consumers engage with cryptocurrency and everyday expenses while making Web3 adoption accessible and exciting for everyone.


# How To Play

{% hint style="success" %}
Your task is to collect coins to feed your piggy, helping it grow. As it matures, you earn piggy badges. Redeem 10 piggy badges for 1,000 gems, which in turn increase token rewards in the airdrop event.
{% endhint %}

<figure><img src="/files/vQZxyyfdZLXD2ssytbaL" alt=""><figcaption></figcaption></figure>

### 03 ways to earn free coins:

<table data-view="cards"><thead><tr><th></th><th></th><th></th><th data-hidden data-card-cover data-type="files"></th></tr></thead><tbody><tr><td><strong>Daily app engagement</strong></td><td><p>Tap once daily to get a 3,000-coin giveaway.</p><p>Claim up to 1,000 mined coins each day.</p></td><td></td><td><a href="/files/nJJcg2yeJrV87Kh1HaBF">/files/nJJcg2yeJrV87Kh1HaBF</a></td></tr><tr><td><strong>Check-In and Social Tasks</strong></td><td><p>Earn 3,000 coins with a 5-day check-in streak.</p><p>Complete various social tasks for extra rewards.</p></td><td></td><td><a href="/files/BJibOkWImWGVmvByfUsP">/files/BJibOkWImWGVmvByfUsP</a></td></tr><tr><td><strong>Invite Friends to Join</strong></td><td><p>Earn 10% of all gems your friends collect, capped at 10k gems.</p><p>Your friends also receive a 1,000-coin bonus.</p></td><td></td><td><a href="/files/AO8JhNMwHiCIbICfxAPm">/files/AO8JhNMwHiCIbICfxAPm</a></td></tr></tbody></table>

<figure><img src="/files/XomAtFEXjCTXfiVyFBDc" alt=""><figcaption><p>Play game &#x26; Complete tasks to earn rewards.</p></figcaption></figure>

### Additional ways to earn coins:

<table data-view="cards"><thead><tr><th></th><th></th><th></th><th data-hidden data-card-cover data-type="files"></th><th data-hidden data-card-target data-type="content-ref"></th></tr></thead><tbody><tr><td><strong>Spend with a Visa card</strong></td><td>Earn unlimited coins by spending with a Visa card that is linked to SpendX.</td><td><a href="/pages/JjjojIyKxaiBPzzLwvtg">Learn more</a></td><td><a href="/files/Ut5gaSDBk8cj23UNPVwO">/files/Ut5gaSDBk8cj23UNPVwO</a></td><td><a href="/pages/JjjojIyKxaiBPzzLwvtg">/pages/JjjojIyKxaiBPzzLwvtg</a></td></tr><tr><td><strong>Purchase coin packages</strong></td><td>Use Telegram stars to buy coin packages, with options ranging from $0.07 to $7.00.</td><td></td><td><a href="/files/iIhOhIQke8BFYDyfutpX">/files/iIhOhIQke8BFYDyfutpX</a></td><td></td></tr><tr><td><strong>Boost your piggy's growth</strong></td><td>Use gems to upgrade your piggy, enhancing its growth speed and earning potential.</td><td></td><td><a href="/files/pq80yj2Zvqap6Dj5sByv">/files/pq80yj2Zvqap6Dj5sByv</a></td><td></td></tr></tbody></table>

<figure><img src="/files/7uuEXXC00EjveySuKt3P" alt=""><figcaption><p>Spend to earn with a Visa card &#x26; Invite your friends to earn bonus rewards.</p></figcaption></figure>

For further support, please [contact us](/contact-support).


# Spend To Earn

<figure><img src="/files/1zMn3EZndWYDnLkLtqd9" alt=""><figcaption></figcaption></figure>

Earn unlimited coin rewards by spending with a Visa card in just 3 simple steps:

{% stepper %}
{% step %}

### Link a Visa card only once

Enter the card number only. No date and CVV needed
{% endstep %}

{% step %}

### Select a merchant

Open mini app and activate a merchant deal
{% endstep %}

{% step %}

### Make payment with the linked card

Pay and earn coin rewards instantly
{% endstep %}
{% endstepper %}

{% hint style="info" %}
Transactions are recorded instantly and reconciled within 7 days before rewards are added to your account.
{% endhint %}

### Why isn't my payment transaction recorded?

SpendX uses transaction data from Visanet to verify payments. If your transaction is not recorded, it may be due to one of the following reasons:

1. Payment was made at a merchant with an MCC (Merchant Category Code) not on the supported list. You can view the list of supported MCCs [here](/spend-to-earn/mcc).
2. The transaction was either not recorded or delayed because the merchant used a POS terminal from the same bank that issued your Visa card. In this case, the bank may not send transaction data to Visanet (or may send it with a delay of up to 15 days).

For further support, please [contact us](/contact-support).


# Supported MCCs

MCC stands for Merchant Category Codes

### **Online Shopping**

| ONLINE MARKETPLACES | 5262 |
| ------------------- | ---- |

### Supermarket

| GROCERY STORES/SUPERMARKETS | 5411 |
| --------------------------- | ---- |
| FREEZER/MEAT LOCKERS        | 5422 |
| CANDY/NUT/CONFECTION STORES | 5441 |
| BAKERIES                    | 5462 |
| MISC FOOD STORES - DEFAULT  | 5499 |

### Food & Beverage

| FAST FOOD RESTAURANTS         | 5814 |
| ----------------------------- | ---- |
| CATERERS                      | 5811 |
| EATING PLACES AND RESTAURANTS | 5812 |
| BARS/TAVERNS/LOUNGES/DISCOS   | 5813 |

### Fashion

|                              |      |
| ---------------------------- | ---- |
| MEN/BOYS CLOTHING/ACC STORES | 5611 |
| WOMENS READY TO WEAR STORES  | 5621 |
| WOMENS ACCESS/SPECIALTY      | 5631 |
| CHILDREN/INFANTS WEAR STORES | 5641 |
| FAMILY CLOTHING STORES       | 5651 |
| SPORTS/RIDING APPAREL STORES | 5655 |
| SHOE STORES                  | 5661 |
| FURRIERS AND FUR SHOPS       | 5681 |
| MENS/WOMENS CLOTHING STORES  | 5691 |
| WIG AND TOUPEE STORES        | 5698 |
| MISC APPAREL/ACCESS STORES   | 5699 |
| CLOTHING/RENT/COSTUME/UNIFO  | 7296 |

### Entertainment

|                                                            |      |
| ---------------------------------------------------------- | ---- |
| SPORTING/RECREATIONAL CAMPS                                | 7032 |
| FILMS/VIDEO PRODUCTION/DIST                                | 7829 |
| MOTION PICTURE THEATRES                                    | 7832 |
| DVD/VIDEO TAPE RENTAL STORES                               | 7841 |
| DANCE HALLS/STUDIOS/SCHOOLS                                | 7911 |
| THEATRICAL PRODUCERS                                       | 7922 |
| BANDS/ORCHESTRAS/ENTERTAIN                                 | 7929 |
| BILLIARD/POOL ESTABLISHMENT                                | 7932 |
| BOWLING ALLEYS                                             | 7933 |
| COMMERCIAL/PRO SPORTS                                      | 7941 |
| TOURIST ATTRACTIONS AND XHBT                               | 7991 |
| PUBLIC GOLF COURSES                                        | 7992 |
| VIDEO AMUSEMENT GAME SUPPLY                                | 7993 |
| VIDEO GAME ARCADES/ESTABLISH                               | 7994 |
| AMUSEMENT PARKS/CIRCUS                                     | 7996 |
| MEMBER CLUBS/SPORT/REC/GOLF                                | 7997 |
| AQUARIUMS/SEAQUARIUMS                                      | 7998 |
| RECREATION SERVICES                                        | 7999 |
| GOVT-OWNED LOTTERIES (NON-US)                              | 9406 |
| CABLE AND OTHER PAY TELEVISION (PREVIOUSLY CABLE SERVICES) | 4899 |

### Healthcare

|                               |      |
| ----------------------------- | ---- |
| VETERINARY SERVICES           | 742  |
| AMBULANCE SERVICE             | 4119 |
| DENTAL/LAB/MED EQUIPMENT      | 5047 |
| HEARING AID/SALES/SERVICE     | 5975 |
| ORTHOPEDIC GOODS              | 5976 |
| COUNSELING SERVICE - ALL      | 7277 |
| DOCTORS & PHYSICIANS          | 8011 |
| DENTISTS/ORTHODONTISTS        | 8021 |
| OSTEOPATHS                    | 8031 |
| CHIROPRACTORS                 | 8041 |
| OPTOMETRISTS/OPHTHALMOLOGISTS | 8042 |
| OPTICIANS                     | 8043 |
| PODIATRISTS/CHIROPODISTS      | 8049 |
| NURSING/PERSONAL CARE FAC     | 8050 |
| HOSPITALS                     | 8062 |
| MEDICAL/DENTAL LABS           | 8071 |
| MED/HEALTH SERVICES - DEF     | 8099 |
| DRUG STORES & PHARMACIES      | 5912 |

### Education

|                              |      |
| ---------------------------- | ---- |
| ELEMENTARY/SECONDARY SCHOOLS | 8211 |
| COLLEGES/UNIV/JC/PROFESSION  | 8220 |
| CORRESPONDENCE SCHOOLS       | 8241 |
| BUSINESS/SECRETARIAL SCHOOL  | 8244 |
| TRADE/VOCATIONAL SCHOOLS     | 8249 |
| SCHOOLS - DEFAULT            | 8299 |

### Retail Stores

|                                |      |
| ------------------------------ | ---- |
| MOTOR VEHICLE SUPPLY/NEW PARTS | 5013 |
| CAR & TRUCK DEALERS/NEW/USED   | 5511 |
| CAR & TRUCK DEALERS/USED ONLY  | 5521 |
| AUTO/HOME SUPPLY STORES        | 5531 |
| AUTOMOTIVE TIRE STORES         | 5532 |
| AUTOMOTIVE PARTS STORES        | 5533 |
| BOAT DEALERS                   | 5551 |
| MOTORCYCLE DEALERS             | 5571 |
| MOTOR HOME DEALERS             | 5592 |
| SNOWMOBILE DEALERS             | 5598 |
| MISC AUTO DEALERS - DEFAULT    | 5599 |
| AUTO BODY REPAIR SHOPS         | 7531 |
| TIRE RETREAD/REPAIR SHOPS      | 7534 |
| AUTO PAINT SHOPS               | 7535 |
| AUTO SERVICE SHOPS/NON DEALER  | 7538 |
| CAR WASHES                     | 7542 |
| TOWING SERVICES                | 7549 |
|                                |      |
| DEPARTMENT STORES              |      |
| DEPARTMENT STORES              | 5311 |
| MISC SPECIALTY RETAIL          | 5999 |
|                                |      |
| DISCOUNT STORES                |      |
| DISCOUNT STORES                | 5310 |
| VARIETY STORES                 | 5331 |
| MISC GENERAL MERCHANDISE       | 5399 |
| BOOK STORES                    | 5942 |
|                                |      |
| HOME IMPROVEMENT & SUPPLY      |      |
| LANDSCAPE/HORTICULTURAL SER    | 780  |
| GEN CONTRACTORS RESIDENTL/COML | 1520 |
| HEATING, PLUMBING, AIR COND    | 1711 |
| ELECTRICAL CONTRACTORS         | 1731 |
| MASONRY/TILE/PLASTER/INSUL     | 1740 |
| CARPENTRY                      | 1750 |
| ROOFING/SIDING/SHEET METAL     | 1761 |
| CONTRACTORS - CONCRETE         | 1771 |
| SPEC CONTRACTORS - DEFAULT     | 1799 |
| PAINT, VARNISHES & SUPPLIES    | 5198 |
| HOME SUPPLY WAREHOUSE STORES   | 5200 |
| LUMBER/BUILD. SUPPLY STORES    | 5211 |
| GLASS/PAINT/WALLPAPER STORES   | 5231 |
| HARDWARE STORES                | 5251 |
| NURSERIES, LAWN/GARDEN SUPPLY  | 5261 |
| MOBILE HOME DEALERS            | 5271 |
| FURNITURE/EQUIP STORES         | 5712 |
| FLOOR COVERING STORES          | 5713 |
| DRAPERY & UPHOLSTERY STORES    | 5714 |
| FIREPLACES & ACCESSORIES       | 5718 |
| MISC HOME FURNISHING SPECIALTY | 5719 |
| HOUSEHOLD APPLIANCE STORES     | 5722 |
| GLASSWARE/CRYSTAL STORES       | 5950 |
| SWIMMING POOLS/SALES/SERV      | 5996 |
| CARPET/UPHOLSTERY CLEANING     | 7217 |
| EXTERMINATING/DISINFECT SERV   | 7342 |
| CLEAN/MAINT/JANITORIAL SERV    | 7349 |
| EQUIP/FURN RENT/LEASE SERV     | 7394 |
| AIR COND/REFRIG REPAIR SHOP    | 7623 |
| SMALL APPLIANCE REPAIR DEF     | 7629 |
| FURNITURE REUPHOLSTERY/REPAIR  | 7641 |
| WELDING SERVICES               | 7692 |
| MISC REPAIR SERVICES           | 7699 |
|                                |      |
| RETAIL GOODS                   |      |
| MARINAS, SERVICE & SUPPLY      | 4468 |
| PRECIOUS STONES/METALS/JEWELRY | 5094 |
| BOOKS/PERIODICALS/NEWSPAPERS   | 5192 |
| FLORIST SUPPLIES/NURSERY STOCK | 5193 |
| DUTY FREE STORES               | 5309 |
| MUSIC STORES/PIANOS            | 5733 |
| RECORD STORES                  | 5735 |
| DIGITAL GOODS BOOKSMOVIEMUSIC  | 5815 |
| DIGITAL GOODS GAMES            | 5816 |
| DIGITAL GOODS APP(EXCL GAMES)  | 5817 |
| LARGE DIGITAL GOODS MERCHANT   | 5818 |
| USED MERCHANDISE STORES        | 5931 |
| ANTIQUE SHOPS                  | 5932 |
| PAWN SHOPS                     | 5933 |
| WRECKING SALVAGE YARDS         | 5935 |
| ANTIQUE REPRODUCTION STORES    | 5937 |
| BICYCLE SHOPS/SALES/SERVICE    | 5940 |
| SPORTING GOODS STORES          | 5941 |
| STATIONERY STORES              | 5943 |
| JEWELRY STORES                 | 5944 |
| HOBBY, TOY & GAME STORES       | 5945 |
| CAMERA & PHOTO SUPPLY STORES   | 5946 |
| GIFT, CARD, NOVELTY STORES     | 5947 |
| LUGGAGE/LEATHER STORES         | 5948 |
| FABRIC STORES                  | 5949 |
| ARTIST/CRAFT SHOPS             | 5970 |
| ART DEALERS & GALLERIES        | 5971 |
| STAMP & COIN STORES            | 5972 |
| RELIGIOUS GOODS STORES         | 5973 |
| COSMETIC STORES                | 5977 |
| FLORISTS                       | 5992 |
| NEWS DEALERS/NEWSSTANDS        | 5994 |
| PET STORES/FOOD & SUPPLY       | 5995 |
| ELEC RAZOR STORES/SALE/SERV    | 5997 |
| TENT AND AWNING SHOPS          | 5998 |
|                                |      |
| RETAIL SERVICES                |      |
| AGRICULTURAL CO-OPERATIVE      | 763  |
| MOTOR FREIGHT CARRIERS         | 4214 |
| COURIER SERVICES               | 4215 |
| PUBLIC WAREHOUSING             | 4225 |
| TELEGRAPH SERVICES             | 4821 |
| TAILOR/SEAMSTRESS/ALTERS       | 5697 |
| TYPEWRITER/SALES/SERVICE       | 5978 |
| LAUNDRY/CLEANING/GARMENT SV    | 7210 |
| LAUNDRIES-FAMILY/COMMERCIAL    | 7211 |
| DRY CLEANERS                   | 7216 |
| PHOTO STUDIOS                  | 7221 |
| BEAUTY/BARBER SHOPS            | 7230 |
| SHOE REPAIR/SHINE/HAT CLEAN    | 7251 |
| BUYING/SHOPPING SERVICES       | 7278 |
| HEALTH & BEAUTY SPAS           | 7298 |
| MISC PERSONAL SERV - DEF       | 7299 |
| CONSUMER CR REPORTING AGEN     | 7321 |
| COMMERCIAL PHOTO/ART/GRAPH     | 7333 |
| QUICK COPY/REPRO SERVICES      | 7338 |
| STENOGRAPHIC SERVICES          | 7339 |
| WATCH/CLOCK/JEWELRY REPAIR     | 7631 |
| INVALID MERCHANT CATEGORY      | 9999 |
|                                |      |
| ELECTRONICS                    |      |
| COMPUTER NETWORK/INFO SVCS     | 4816 |
| OFFICE/PHOTO EQUIPMENT         | 5044 |
| COMPUTERS/PERIPHERALS/SOFTWARE | 5045 |
| ELECTRONICS STORES             | 5732 |
| COMPUTER SOFTWARE STORES       | 5734 |
| RADIO/TV/STEREO REPAIR SHOP    | 7622 |

### Transportation

|                               |      |
| ----------------------------- | ---- |
| ALL AIRLINES                  | 1    |
|                               |      |
| TRANSPORTATION                |      |
| RAILROADS                     | 4011 |
| LOCAL COMMUTER TRANSPORT      | 4111 |
| PASSENGER RAILWAYS            | 4112 |
| TAXICABS/LIMOUSINES           | 4121 |
| BUS LINES                     | 4131 |
| STEAMSHIP/CRUISE LINES        | 4411 |
| AIRPORTS/FIELDS/TERMINALS     | 4582 |
| TOLLS AND BRIDGE FEES         | 4784 |
| TRANSPORTATION SVCS - DEFAULT | 4789 |
| CAMPER TRAILER DEALER         | 5561 |
| PARKING LOTS,METERS,GARAGES   | 7523 |
|                               |      |
| VEHICLE RENTAL                |      |
| AUTO RENTAL                   | 2    |
| Boat rentals and leasing      | 4457 |
| TRUCK/UTILITY TRAILER RENTALS | 7513 |
| MOTOR HOME/RV RENTALS         | 7519 |
|                               |      |
| LODGING                       |      |
| LODGING                       | 3    |
| TIMESHARES                    | 7012 |
| Trailer parks and campgrounds | 7033 |
|                               |      |
| TRAVEL SERVICES               |      |
| TRAVEL AGENCIES               | 4722 |

### Utilities

|                              |      |
| ---------------------------- | ---- |
| PETROLEUM/PETROLEUM PRODUCTS | 5172 |
| SERVICE STATIONS             | 5541 |
| AUTOMATED FUEL DISPENSERS    | 5542 |
| ELECTRIC VEHICLE CHARGING    | 5552 |
| FUEL DEALERS                 | 5983 |
| UTILITIES/ELEC/GAS/H2O/SANI  | 4900 |
| TELECOMMUNICATION SERVICES   | 4814 |


# Mini game

Play mini games to earn more coin rewards!


# Guess Right - Win Gifts

Pick your number and get a change to win 400,000 coins

**Terms and Conditions:**

1. **Game Awards**:

   * **Special Prize**: Participants who correctly guess all 4 digits of the winning lottery number will receive **400,000 coins**.
   * **First Prize**: Participants who correctly guess the last 2 digits of the winning lottery number will receive **50,000 coins**.

2. **Game Configuration**:

   * **Start Time for Number Selection**: Announced on the SpendX Telegram channel.
   * **End Time for Number Selection**: Displayed in the mini app.
   * **Winner Announcement Time**: At **09:00 AM UTC** on the day ticket selection closes, SpendX will determine the lucky number based on the last 4 digits of Bitcoin's (BTC) price on CoinMarketCap.
     * *Example*: If the BTC price is **$46,164.90**, the lucky number will be **6490**. The lucky number will be displayed in the app.
   * **Award Distribution**: Prizes will be credited to winners' accounts within **3 working days**.

3. **Additional Notes**:
   * SpendX reserves the right to disqualify users and withhold rewards if any fraudulent activity is detected.
   * In case of disputes, SpendX’s decision will be final and binding.
   * Users can purchase multiple tickets; however, each participant can only win **one highest prize per round**.


# Contact Support

### Customer Support

Email: <support@spendx.org>

### Partnership:&#x20;

Email: <hello@spendx.org>

### Other channels:

Community chat: <https://t.me/spendx_chat>

News channel: <https://t.me/spendx_news>

Twitter: <https://x.com/HelloSpendX>

Youtube: [https://youtube.com/@HelloSpendX](https://www.youtube.com/@HelloSpendX)

Facebook: [https://facebook.com/hellospendx](https://www.facebook.com/hellospendx)


# Tokenomics

To be updated


# Disclaimer

SpendX.org, including but not limited to the overall project, website, smart contracts,  and software app (“SpendX”) as presented in this conceptual paper is not currently an active licensed or exempted financial or payment service of any kind and in any jurisdiction, although it might be in the future, subject to appropriate requirements and approval. Any financial or payment services terminology used in this whitepaper, on the SpendX website, or within the app is intended only as a basic reference, without any effective or legal meaning of the same terms in a regulated and/or traditional financial environment. The SpendX token is strict utility tokens in any jurisdiction and can not be considered as a security or otherwise, a regulated token of any kind. It is not in any way e-money and/or fiat or asset-backed stable-coin, whether global or limited in scope. This whitepaper is not a contract or a contractual agreement of any kind, it is not an invitation or offer to invest in SpendX tokens or acquire or use these tokens in any way with any expectation of profit. Any user of SpendX declares to have received appropriate technical, administrative, and legal advice before and after reading this whitepaper, the SpendX Website, and using any part of the SpendX App (including its tokens). The user accepts that there is an inherently high risk in acquiring or using any kind of blockchain and/or token, platform, software, interface and acknowledges with a full disclaimer for any of the persons or entities mentioned within this whitepaper, that there can be any kind of damage suffered, including total loss.&#x20;


# Terms of Use

**Indemnification**\
\
You agree to indemnify SpendX, any merchant partners, as well as their respective officers, directors, employees, successors, agents, and affiliates, for any and all claims, damages, losses and causes of action (including attorneys’ fees and court costs) arising out of or relating to your breach of this Agreement or for any materials in any form whatsoever that are provided by you (or through your username and/or password). You agree to cooperate as fully as reasonably required in our defense and/or settlement of any claim. We reserve the right, in our reasonable discretion, to assume exclusive control over the defense and settlement of any matter subject to indemnification by you.

**Warranty Disclaimer**\
\
The Services, content, and the SpendX Platforms are provided “as is” and without warranty of any kind, express or implied, including without limitation, warranties of title, merchantability, fitness for a particular purpose or non-infringement. We make no warranty as to the quality, accuracy, currentness, completeness, reliability or validity of the Services, content or the SpendX Platforms, including without limitation, any product search results, product descriptions, product availability, pricing information advice, opinion, statement, recommendations, or other information displayed, uploaded or distributed in connection with the Services. SpendX does not warrant that the functionality of the SpendX Platforms will be uninterrupted or error-free, that defects will be corrected, or that they will be free of viruses or other harmful content. Further, SpendX does not warrant, guarantee or make any representations regarding the quality of, or accuracy of advertisements for, any products or services offered or provided by its affiliate stores in conjunction with the services.  SpendX disclaims all liabilities associated with the security of the Payment Method. You shall be responsible to resolve any disputes with your financial institution, credit/debit card issuer or other provider of your selected Payment Method.

**Use of Biometric, Phone or Third-Party Logins**\
\
You may choose to allow access to your SpendX account via third-party logins (e.g. Facebook or Google) or through your phone (by using a device passcode or your biometric data).  You understand the need to protect your mobile device, its passcode and any biometric data login functions, as well as the need to protect your passwords used at these third-party sites (such as your Facebook account). \
\
The biometrics recognition feature is designed and owned by the respective mobile device. You acknowledge and understand that if you allow third parties’ biometrics being registered as part of the biometrics of your mobile device, they will be able to access your account.  You acknowledge and understand that if possession of the mobile device you registered with SpendX has changed for any reason and the device login service has not been disabled, others will be able to access your account.  You acknowledge and understand that if your password to your Facebook or Google accounts are compromised or provided to others, that others will be able to access your account.  In such events of unauthorised access, SpendX shall not be held responsible for any loss.\
\
Please understand that the SpendX service does not collect or store your biometric ID or Facebook or Google passwords, and relies on the third-party service or your mobile device to verify your identity. SpendX does not guarantee that the service will be error-free and uninterrupted. If there is (through no fault of SpendX) a transmission interruption or malfunction of this service, which causes inconvenience or inability to use the service, loss of data, errors, tampering by others, or other economic loss, SpendX shall not be held liable for the same.

**Limitation of Liability**\
\
To the maximum extent permitted by applicable law, in no event shall SpendX be liable for any special, incidental, consequential, exemplary, punitive or other indirect damages or for any loss profits, loss data or loss of use damages, even if it has been advised of the possibility of such damages. To the maximum extent permitted by applicable law, SpendX's maximum aggregate liability arising out of this agreement will not exceed USD$100.

**Governing Law and Arbitration**\
\
This Agreement, including any amendments thereto that SpendX may from time to time make at its discretion, are governed by and construed in accordance with the laws of Vietnam. This includes all issues related to the scope, application, interpretation and enforceability of this Agreement and this arbitration provision. The arbitrator shall also decide whether any claim is subject to arbitration.

**Assignment**\
\
You may not assign your rights and obligations under this Agreement, in whole or in part, without prior written consent, and any such assignment without such consent will be null and void.

**Headings**\
\
Headings under this Agreement are intended only for convenience and shall not affect the interpretation of this Agreement.

**Waivers / Severability**\
\
Any failure to enforce any provision of this Agreement on the part of SpendX will not be deemed a waiver of that provision. Any waiver of any provision of this Agreement by SpendX on one occasion will not be deemed a waiver of any other provision or of such provision on any other occasion. If any provision of this Agreement is held to be invalid, such invalidity shall not affect the remaining provisions.

**Entire Agreement**\
\
This Agreement (together with the additional terms and conditions referred hereto or generally) represents the entire agreement of the parties with respect to the subject matter hereof and supersedes all prior or contemporaneous agreements and representations, written or oral (including without limitation, earlier version of this Agreement that may have been accepted by you). We reserve the right to modify this Agreement at any time. Your continued use of any of the SpendX services or continued maintenance of an account with SpendX shall constitute and be deemed to be your acceptance of such modification and your consent to abide by any terms thereof.


# Privacy Policy

### **1. Introduction**

1.1. Welcome to the SpendX platform run by SpendX LLC and its affiliates (individually and collectively, "SpendX", "we", "us" or "our"). SpendX takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our SpendX mobile application (the "Platform") (we refer to the Platform and the services we provide as described on our Platform collectively as the "Services"). Users refers to a user who registers for an account with us for use of the Services, including both buyers and sellers (individually and collectively, “Users”, “you” or “your”). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.&#x20;

1.2. "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include name, identification number and contact information.

1.3. By using the Services, registering for an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will notify you including by posting those changes or the amended Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of the Services or Platform, including placing of any orders, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

1.4. Visa card-linked feature: SpendXSpendX offers a service enabling you to enroll a payment card in order to earn rewards or benefits when you make qualifying transactions at Visa accepting merchants. You accept these terms when you enroll a card in the Service. We may add to, change or remove any part of these terms from time to time. If we changes any material terms that would have a material adverse effect on your rights as they are presented to you in these terms, we will notify you via email or our official social channels. Your continued participation in the Service, including receiving benefits and rewards when you make a qualifying transaction at Visa accepting merchants, constitutes your acceptance of any changes to these terms.

To receive benefits and rewards through the Service, you must enroll a valid, eligible card with the Service. Company leverages the transaction matching technology provided by Visa Offering Platform to provide you the Services.

By enrolling a card in the Service, you agree that your payment processor (Visa) may monitor transactions on your enrolled card at Visa accepting merchants and share Transaction Data with us for the purposes of determining whether you have made a qualifying purchase and providing you targeted offers. Transaction Data includes, but is not limited to, merchant name, merchant location or other store identifier, transaction date, and transaction amount.

You may remove your payment cards from the Service at any time by visiting Card-linked screen. When you do so, we will no longer receive future Transaction Data associated with your payment card, but we will retain historical Transaction Data to track rewards and benefits due under the Service and for account management and member services purposes.

1.5. This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.

1.6. This Policy applies to both buyers and sellers who use the Services except where expressly stated otherwise.

### **2.** **When will** SpendX **collect personal data?**

We will/may collect personal data about you:

* When you register and/or use our Services or Platform, or open an account with us;
* When you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
* When you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
* When you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you interact with our customer service agents;
* When you use our electronic services, or interact with us via our application or use services on our Platform. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;
* When you grant permissions on your device to share information with our application or Platform;
* When you link your SpendX account with your social media or other external account or use other social media features, in accordance with the provider’s policies;
* When you carry out transactions through our Services;
* When you provide us with feedback or complaints;
* When you register for a contest; or
* When you submit your personal data to us for any reason.

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

### **3. What personal data will** SpendX **collect?**

5.2. You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Platform or the Services.

### **6. How do we use the information you provide us?**

6.1. We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

* To consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
* To manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, without limitation, remembering your preference), as well as your relationship and user account with us;
* To respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
* To enforce our Terms of Service or any applicable end user license agreements;
* To protect personal safety and the rights, property or safety of others;
* For identification, verification, due diligence, or know your customer purposes;
* To evaluate and make decisions relating to your credit and risk profile and eligibility for credit products;
* To maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
* To deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
* To contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
* To allow other users to interact, connect with you or see some of your activities on the Platform, including to inform you when another User has sent you a private message, posted a comment for you on the Platform or connected with you using the social features on the Platform;
* To conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to recommend products and/or services relevant to your interests, to improve our Services or products and/or to enhance your customer experience;
* To allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with SpendX's Services;
* Tor marketing and advertising, and in this regard, to send you by various mediums and modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom SpendX may collaborate or tie up with) that SpendX (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material and/or adjusting your settings in the Platform, as applicable. We may use your contact information to send newsletters or marketing materials from us and from our related companies;
* To respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where we have a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on SpendX or on its related corporations or affiliates (including, where applicable, the display of your name, contact details and company details);
* To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
* To carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
* To audit our Services or SpendX's business;
* To prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
* To respond to any threatened or actual claims asserted against SpendX or other claim that any Content violates the rights of third parties;
* To store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
* To deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves SpendX as a participant or involves only a related corporation or affiliate of SpendX as a participant or involves SpendX and/or any one or more of SpendX's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or
* Any other purposes which we notify you of at the time of obtaining your consent.(collectively, the “Purposes”).

6.2. You acknowledge, consent and agree that SpendX may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over SpendX or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over SpendX; (c) enforce the SpendX Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against SpendX or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of SpendX, its users and/or the public.

6.3. As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

### **7. How does** SpendX **protect and retain customer information?**

7.1. We implement a variety of security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.

7.2. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using the Platform, or your permission to use the Platform and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

* Our subsidiaries, affiliates and related corporations;
* Buyers or sellers you have transacted with or interacted with on the Platform or in connection with your use of the Services for the above-stated Purposes;
* Other users of our Platform for one or more of the above-stated Purposes;
* Contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those parties which provide administrative or other services to us such as mailing houses, logistics service providers, financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centres;
* Governmental or regulatory authorities having jurisdiction over SpendX or as otherwise permitted under Section 6.2;
* A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of SpendX's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by SpendX about our Service Users is among the assets transferred; or to a counterparty in a business asset transaction that SpendX or any of its affiliates or related corporations is involved in; and
* Third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

8.2. We may share user information, including statistical and demographic information, about our Users and information about their use of the Services with advertising partners and third party suppliers of advertisements, remarketing, and/or other programming.

8.3. For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply. Consistent with the foregoing and subject to applicable law, we may use your personal data for recognized legal grounds including to comply with our legal obligations, to perform our contract with you, to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, or where necessary in connection with a legal claim.

8.4. Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.

8.5. SpendX allows you to share videos from YouTube in the SpendX Livestream feature ("YouTube Content"). To facilitate this, SpendX uses YouTube API Services made available by YouTube. By using sharing YouTube Content, you hereby agree to be bound by the Google Privacy Policy (<http://www.google.com/policies/privacy>).

8.6. As set forth in SpendX's Terms of Service, Users (including any employees, agents, representatives, or any other person acting for such User or on such User's behalf) in possession of another User’s personal data through the use of the Services (the “Receiving Party”) hereby agree that, they will (i) comply with all applicable Privacy Laws with respect to any such data, including any collection, processing, storage or transfer or transfer of such data; (ii) allow SpendX or the User whose personal data the Receiving Party has collected (the “Disclosing Party”) to remove his or her data so collected from the Receiving Party’s database; and (iii) allow SpendX or the Disclosing Party to review what information has been collected about them by the Receiving Party, in each case of (ii) and (iii) above, in compliance with and where required by applicable laws.&#x20;

8.7. Notwithstanding anything set forth herein, Sellers (including any employees, agents, representatives, or any other person acting for such User or on such User's behalf) shall comply with all applicable Privacy Laws and, in respect of any buyer’s personal data received from SpendX, (i) are not permitted to use such buyer’s personal data except as reasonably necessary to respond to buyers’ enquiries and to carry out respond to, process, deal with or complete a transaction without the buyers’ and SpendX's prior written consent; (ii) should refrain from contacting buyers using such information outside of the SpendX platform; (iii) are not permitted to disclose such buyer’s personal data to any unauthorized third parties without the buyer’s and SpendX's prior written consent; (iv) shall employ sufficient security measures to protect each SpendX user’s personal data in their possession, retain such data only for as long as necessary for the purposes above and in accordance with the Privacy Laws, and to delete or return such data to SpendX upon any request from SpendX or as soon as reasonably possible upon completion of the transaction; and (v) to inform SpendX's Personal Data Protection Officer at <hello@spendx.org> in the event of any potential data breach or other loss of such user’s data.

### **9. Information on children**

The Services are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 13 nor is any part of our Platform or other Services directed to children under the age of 13. As a parent or legal guardian, please do not allow such children under your care to submit personal data to SpendX. In the event that personal data of a child under the age of 13 in your care is disclosed to SpendX, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13.

### **10. Information collected by third parties**

10.1. Our Platform uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyse how Users use the Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

10.2. We, and third parties, may from time to time make software applications downloads available for your use via the Platform or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by SpendXSpendX. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

### **11. Disclaimer regarding security and third party sites**

11.1. WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.

11.2. In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Platform. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Platform) may not be received by us.

11.3. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

### **12. Will** SpendX **transfer your information oversea?**

Your personal data and/or information may be transferred to, stored or processed outside of your country for one or more of the Purposes. In most cases, your personal data will be processed by us in Viet Nam, where our servers are located. SpendX will only transfer your information overseas in accordance with Privacy Laws.

### **13. How can you withdraw consent, request access to or correct information you have provided to us?**

13.1. *Withdrawing Consent*

* You may withdraw your consent for the collection, use and/or disclosure and/or request deletion of your personal data in our possession or under our control by sending an email to our Personal Data Protection Officer at <hello@spendx.org>, and we will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you and we may need to terminate your existing relationship and/or the contract you have with us.
* Where you share YouTube Content, in addition to withdrawing your consent by emailing us pursuant to Section 13.1.1, you may also revoke SpendX access to your personal data via the Google security settings page at <https://security.google.com/settings/security/permissions>

13.2. *Requesting Access to or Correction of Personal Data*

* If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Platform. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to our Personal Data Protection Officer at <hello@spendx.org>.
* We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
* We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.

### **14. Questions, concerns or complaints? Contact us**

If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at <hello@spendx.org>.