Website Master Terms

What These Terms Do

These Terms of Use (“Terms”) are the master website terms for CyberPay.link and CyberPay-enabled checkout/cashier pages. They: (a) define the contracting structure for Merchants and Buyers/end-customers;

(b) explain CyberPay’s role as payment facilitator and/or Merchant-of-Record for payment collection (where disclosed);

(c) set transaction finality rules (including on-/off-ramp execution); and

(d) incorporate and bind you to CyberPay’s public compliance policies by reference.

If you do not accept these Terms, do not use the website, cashier pages, APIs, or any CyberPay-enabled checkout.

1. Contracting Parties and Who Is Bound

1.1 Operator

The Service is operated by Apex Advisory Group Ltd (“CyberPay”, “Company”, “we”, “us”), incorporated in Seychelles.

1.2 Who these Terms cover

These Terms bind:

• Merchants using CyberPay to accept payments and/or receive settlement;
• Buyers/end-customers of those Merchants (“Buyers”) who pay via a CyberPay-enabled checkout/cashier page; and
• any other visitors or users interacting with the website, APIs, or services (the “Service”).

1.3 Automatic Buyer accounts

A Buyer Account may be created automatically during checkout to enable payment processing, compliance screening, fraud prevention, dispute evidence, and recordkeeping. By continuing a checkout, authorising a Transaction, or benefiting from a Transaction, the Buyer agrees to these Terms and the incorporated policies.

2. Incorporated Policies

The following policies form part of these Terms and are binding on you as if set out in full:

• Privacy Policy 
• Cookie Policy (
• AML / CFT Prevention Policy 
• Risk Appetite Policy 
• Anti-Bribery & Corruption Policy 
• Modern Slavery & Human Trafficking Statement 

CyberPay may also publish method-specific terms, notices, or addenda (e.g., payment method confirmations, local APM rules, settlement windows). Those terms are incorporated when presented to you or referenced on the Service.

3. Order of Precedence (So There’s No Ambiguity)

If there is any conflict:

• (a) For Merchants: the Merchant Agreement (if any) prevails for commercial terms (pricing, reserves, settlement, chargeback allocation, onboarding requirements), then method-specific addenda, then these website Terms, then the remaining public policies.
• (b) For Buyers: these website Terms and any checkout/method-specific terms presented at the time of payment prevail, then the incorporated public policies.
• (c) For everyone: where a policy or term is required by law or by a PSP/payment rail rule, that requirement prevails to the minimum extent necessary.

4. Our Role (PayFac / Merchant-of-Record for Collection)

4.1 Payment facilitation

CyberPay provides payment facilitation, routing, and settlement orchestration through banks, PSPs, APM providers, and VASPs. CyberPay is not a bank and does not provide deposit accounts, custody, escrow, safeguarding, or fiduciary services.

4.2 Merchant-of-Record designation (where disclosed)

Where CyberPay is disclosed as Merchant-of-Record (“MoR”) at checkout or in Merchant documentation, CyberPay is the named payment recipient for payment collection and forwarding. This does not make CyberPay responsible for the Merchant’s goods/services, fulfilment, delivery, refunds, returns, cancellations, or warranties unless explicitly stated in writing.

4.3 Buyer–Merchant relationship

The Buyer’s purchase contract is with the Merchant (or the Merchant’s principal) for the underlying goods/services. All product/service issues are strictly between Buyer and Merchant.

5. Transactions (On-Ramp / Off-Ramp / Execution-Only)

CyberPay may facilitate fiat-to-crypto (“on-ramp”) and crypto-to-fiat (“off-ramp”) execution as part of payment and settlement flows. Execution may involve third-party liquidity sources and blockchain networks. CyberPay does not commit to any specific providers or technologies and may change providers at any time.

6. Finality, No-Recall Design, and Chargebacks

6.1 Execution finality

Many Transactions are executed on an immediate/atomic basis. Once execution commences, Transactions are final and irreversible to the maximum extent permitted by applicable law and the relevant payment rail/scheme rules.

6.2 No chargeback service

CyberPay does not offer chargebacks, reversals, recalls, or post-execution unwinds as a service. Buyers must address any product/service complaints and refund requests to the Merchant.

6.3 Buyer waiver

To the maximum extent permitted by law and rail rules, Buyers irrevocably waive any right to initiate a chargeback or reversal once execution commences. If a Buyer initiates a chargeback in breach of these Terms, CyberPay may suspend the Buyer Account, deny future access, and share information with the Merchant/PSPs to contest disputes.

6.4 Merchant allocation

If a chargeback or reversal occurs through a rail notwithstanding these Terms, chargeback liability allocation is governed by the Merchant Agreement; absent a contrary written agreement, the Merchant remains responsible to CyberPay for chargeback amounts, fees, and penalties.

7. Compliance Controls (AML/CFT, Sanctions, Risk Appetite, ABC)

CyberPay maintains a risk-based compliance program. CyberPay may request KYC/KYB information, apply screening, delay or refuse Transactions, suspend or terminate Accounts, and report to authorities where required. CyberPay’s Risk Appetite Policy describes prohibited and restricted categories. CyberPay’s Anti-Bribery & Corruption Policy and Modern Slavery Statement form part of the broader financial crime framework and inform escalation and refusal/termination decisions.

8. Cookies, Device Signals, and Fraud/Abuse Prevention (Cashier Pages)

CyberPay uses cookies and similar technologies on the website and cashier pages, including security/fraud cookies necessary to prevent abuse, bots, account takeover, and payment fraud. Some security cookies on cashier pages may be required for the payment flow to function. If you block these, the payment may be refused or fail. See the Cookie Policy for details.

9. Data, Privacy, and Disclosures

CyberPay processes personal data under the Privacy Policy and may share data with Merchants, banks, PSPs/APM providers, VASPs, compliance/fraud vendors, and authorities where required. Buyer Accounts may be created automatically at checkout. Data may be transferred cross-border.

10. Suspension, Refusal, and Termination

CyberPay may refuse, delay, suspend, freeze, or terminate any Account or Transaction without notice for compliance, fraud, risk, operational, or legal reasons. Termination does not affect accrued rights and obligations (including fees, indemnities, and liability limitations).

11. Disclaimers and Limitation of Liability

THE SERVICE IS PROVIDED “AS IS” AND “AS AVAILABLE”. CYBERPAY DOES NOT WARRANT UNINTERRUPTED OR ERROR-FREE OPERATION OR THAT ANY TRANSACTION WILL BE ACCEPTED BY A PSP OR PAYMENT RAIL.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, CYBERPAY IS NOT LIABLE FOR INDIRECT, CONSEQUENTIAL, PUNITIVE, OR ECONOMIC LOSS. ANY DIRECT LIABILITY IS LIMITED TO FEES ACTUALLY RETAINED BY CYBERPAY IN RESPECT OF THE SPECIFIC TRANSACTION GIVING RISE TO THE CLAIM.

12. Indemnity

You will indemnify and hold harmless CyberPay from claims, losses, fines, penalties, chargebacks, costs, and expenses (including legal fees) arising from: your breach; your Transactions; Merchant goods/services; Buyer disputes; fraud; prohibited activity; or regulatory/scheme actions caused by your conduct.

13. Changes to Terms and Policies

CyberPay may update these Terms and the incorporated policies by posting updated versions on the website. Continued use constitutes acceptance. If you do not agree, stop using the Service.

14. Governing Law and Jurisdiction

These Terms are governed by the laws of Seychelles. You submit to the exclusive jurisdiction of the competent courts of Seychelles, except where CyberPay elects to pursue injunctive relief or collections elsewhere.