TERMS & CONDITIONS — The Platform
Version: v3.1 —05 Jan 2026 

Operator / Licensing / Brand Scope
Operator / Data Controller:
3-102-938509 S.R.L. (Costa Rica)
Registered address: Costa Rica, San José, San José, Mata Redonda, Sabana Oeste, 12 Avenue 90 Street, ERP Lawyers.
Contact: help@zanlo.market
Licensing: The Platform operates under a license issued by the Anjouan Offshore Finance Authority (Gaming Division), an autonomous island of the Union of the Comoros (License No.: NUMBER WILL BE ADDED LATER).
Brand scope: These Terms apply to all products and services under the zanlo trademark, logos, and domains; collectively referred to herein as “the Platform.”
By accessing or using the Platform, you accept these Terms, as well as the Privacy Policy and Cookie Policy. If you do not agree, do not use the Platform.

1. Nature of Service
The Platform is a peer‑to‑peer, skill‑based service. The Platform does not take positions against users.
Not a Financial Instrument or Binary Option. The Platform is not a financial services provider, broker, exchange, or trading venue; it does not offer or facilitate binary options, CFDs, futures, securities, tokens, or cryptoassets. Participation does not constitute investment or financial speculation under securities/derivatives laws.
Internal Currency (Coins). Coins are non‑monetary, non‑transferable in‑app units for utilities (e.g., cosmetics/skins/features), not a token or blockchain asset, have no cash value, and cannot be exchanged for fiat/crypto outside the Platform.

2. Legal Eligibility & Restricted Jurisdictions
You must be 18+ (or the age of majority in your jurisdiction, if higher). You are solely responsible for ensuring that use of the Platform is lawful under laws applicable to you.
Restricted jurisdictions. Access is prohibited from: all European countries, Australia, Austria, France, Germany, Netherlands, Spain, United Kingdom, United States, DPRK, Iran, Myanmar, and any other jurisdictions designated from time to time by the Anjouan authority or the Platform.
Cross‑Border Use Disclaimer. By accessing or using the Platform, you acknowledge that services are operated under a license issued in Anjouan and may not be regulated or licensed in your country of residence. Your access is on your own initiative; the Platform does not target, promote, or market services in jurisdictions where such use would be unlawful. You are solely responsible for compliance with your local laws.

3. Registration & Account
One person — one account. Registration is available via Google ID, Apple ID, or phone OTP. You are responsible for maintaining the confidentiality of your login credentials and for all activity on your account.
No transfer or sharing. Account transfers, sales, lending, or sharing are prohibited, especially to minors or unverified third parties. Violations may result in permanent ban and fund freeze without refund. The registered holder is fully responsible for all actions performed through the account.
Right to refuse, pre‑registration screening & preventive suspension. To protect Platform integrity and comply with AML obligations, the Platform may collect limited technical/behavioral data before account creation (e.g., IP range, device/browser fingerprint, referral source) to detect fraud or risk. The Platform may refuse registration, delay onboarding, suspend withdrawals, restrict functionality, or freeze funds when activity appears suspicious or high‑risk (non‑exhaustive indicators include: one‑time/temporary phone numbers; foreign/stolen SIM cards; SIM‑swap indicators; disposable email addresses; anonymizing networks such as TOR/VPN combined with other risk signals; mismatched/false identity details; compromised Google/Apple IDs; payment instruments not matching user information). Preventive actions may occur without prior notice and at the Platform’s discretion.
Name and content standards. Usernames, bios, images, and other profile content must not be unlawful, abusive, defamatory, infringing, misleading, or deceptive. The Platform may remove content and/or suspend accounts that violate these standards.

4. KYC/AML & Verification
KYC is required for withdrawals and certain activity thresholds. Identity verification is performed via trusted providers (currently Didit.me). The Platform does not store KYC images/documents; the provider processes them per its policies. Sanctions/PEP screening and transaction monitoring apply on a continuous basis.
Alerts are reviewed by Compliance as soon as practicable after detection. SARs (Suspicious Activity Reports) may be filed with payment providers or competent authorities promptly after detection of suspicious activity, in accordance with applicable legal and contractual obligations.

5. Sign‑in & Account Deletion (Apple/Google/App/Web)
Users signing in via Google or Apple authorize the Platform to receive limited account data (e.g., verified email, display name, profile identifier) only with explicit consent. If the sign‑in provider indicates the user is under 18, access is blocked. Users can delete accounts in‑app and via the website. Certain data may be retained where required by law (e.g., AML/KYC).

6. App Distribution, APK Installation & Anti‑Phishing
The app is distributed via official app stores and may be available for direct download from the Platform’s official website. Any downloadable version on the official site will clearly display the Platform’s developer identification pursuant to store policies. Downloading or using APKs from third‑party websites, unofficial repositories, or modified sources is prohibited. The Platform assumes no liability for any damages, losses, IP violations, or loss of funds arising from unofficial/altered builds. The Platform operates exclusively via its official domains and verified apps; it is not responsible for losses resulting from phishing, fake websites, or counterfeit apps.

7. Fees, PSP Charges, Currency & Chargebacks
Commission. The Platform applies commissions only to the user’s net profit on successful trades (e.g., profitable resale or resolution). Base commission: 20% of profit; may be reduced for advanced levels or via Commission‑Free Prediction (CFP).
CFP. One CFP removes commission on one share (≈ $1) for one profitable transaction (or one profitable resale).
PSP Charges. Payment service providers (PSPs) may apply processing or network fees at their own discretion; the Platform does not control or receive such fees.
Currency. All balances and transactions are processed in USD. Conversion rates and rounding are determined by PSPs; minor discrepancies may occur.
Chargebacks. In case of chargebacks or payment disputes, the Platform may freeze balances, offset amounts owed, and request verification before restoring access. In certain cases, the Platform may compensate users with internal bonus credits for transaction fees.
Bonus funds. Bonus funds can be used like normal balance for participation but are non‑withdrawable. Profits realized using bonus funds may become withdrawable only per in‑app rules. The Platform may modify or revoke bonuses at its discretion.
Inactivity. After 3 months of inactivity, an inactivity fee (up to $1 every two weeks) may be charged until activity resumes or balance is depleted (subject to change).

8. Market Mechanics, Resolution & Adjustments
Prices reflect user sentiment and may change over time; markets may launch with initial prices different from 50/50. Outcomes are resolved using external data providers and Sources of Truth. Once a resolution is published, appeals are not accepted. Trades after an event’s factual end but before publication may be voided and funds returned. If an event is canceled, the Platform returns funds at the prevailing price at cancellation (PSP fees already applied are excluded from refunds).
Market Operations & Adjustments: the Platform may suspend, close, or restrict trading at any time; recalculate, void, or partially cancel trades upon material errors, data discrepancies, or manipulative activity; and amend or reschedule event dates/timelines where external circumstances change. Notices take effect upon publication in‑app or on the website.

9. Learning, Statistics & Analytical Tools
The Platform includes social features, user levels, leaderboards, and analytical statistics to help users improve skills and decision‑making. These features are educational and do not guarantee outcomes or profits. Historical data and aggregated statistics come from external providers and user activity; accuracy/completeness/timeliness are not guaranteed. Users decide independently and should verify information externally.

10. Prohibited Conduct & User Content
Prohibited conduct. Hate/harassment, explicit content, spam; fraud, collusion, manipulation; bots/automation; bug exploitation; illegal activity; IP infringement; account sale/sharing; chargeback abuse; disinformation or defamation targeting users or the Platform.
Malicious conduct & platform integrity. Any behavior intended to harm other users, discredit the Platform, or spread false rumors may lead to suspension/termination and legal action.
System interference and legal action. Any attempt to interfere with normal operation (including DDoS, automated request flooding, API abuse, exploit attempts, or intentional load generation) is a material breach. The Platform may immediately suspend accounts involved and pursue civil and criminal action (including damages) and cooperate with law enforcement.
The Platform may edit/remove content, void affected trades, suspend/terminate accounts, and seek legal remedies.

11. Product Rules & Records
The Platform facilitates peer‑to‑peer interactions; The Platform is not a party to user‑to‑user transactions.
Market Resolution, Cancellations & Event Integrity.
• Once an event is marked “Resolved” and its outcome is published, the resolution is final and not subject to appeal or reversal.
• Each resolved event includes an official resolution timestamp; any trades attempted after that timestamp are void and refunded.
• If an event is cancelled/invalidated for reasons outside the Platform’s control, all positions are refunded at the prevailing market price at the time of cancellation; such refunds are final.
• The Platform is a neutral platform; prices/probabilities reflect aggregated user opinions and do not constitute political advocacy or interference.
Market volatility and price dynamics.
Markets are user‑driven; prices, probabilities, and liquidity may fluctuate substantially, including due to participation of large users or market makers. The Platform does not guarantee stability or accuracy of displayed probabilities and assumes no liability for any loss or misunderstanding arising from such market movements. Users are solely responsible for evaluating market depth, liquidity, and volatility risks.
External data and Source of Truth.
The Platform relies on reputable third‑party data providers, APIs, and public/official sources (collectively, “Sources of Truth”) for event outcomes and displays. While care is taken, the Platform cannot guarantee absolute accuracy or timeliness of external data. The Platform shall not be liable for any loss, misinterpretation, or dispute arising from incorrect, delayed, or incomplete third‑party data (including official/statistical feeds). In case of data inconsistencies, the Platform may rely on internal verification, or void or adjust affected markets at its discretion.
Initial market pricing.
Markets may launch with pre‑set initial prices/probabilities other than 50/50. Initial pricing may be algorithmic or manual based on available information, history, or balancing considerations and does not imply prediction, endorsement, or manipulation. Prices remain dynamic and user‑driven.

12. Visual Content and Customization (Avatars & Skins)
Predefined avatars/icons/skins only (including premium items via Coins or engagement). Users cannot upload images. Any resemblance to real persons, ethnic groups, organizations, or symbols is coincidental; the Platform does not endorse political, racial, religious, or ideological interpretations. The Platform may modify or remove assets that are inappropriate or inconsistent with these values.

13. Tasks, Rewards & Referral Program
Daily/event tasks may grant Coins or cosmetic items. Rewards have no cash value, are not withdrawable/transferable, and may expire. Abuse (automation, multi‑accounting) leads to forfeiture. Referral rewards are non‑monetary engagement credits; not exchangeable or withdrawable. The Platform may suspend/modify/terminate referral features at any time. Self‑referrals, circular/incentivized sign‑ups, or disposable/borrowed identities are prohibited.

14. Service Availability, Latency & Downtime
Maintenance/provider outages/data latency may occur. Market views and prices may be delayed; timestamps are not real‑time guarantees. The Platform is not liable for losses resulting from downtime, delays, or synchronization issues.

15. Updates & Communications
Users are responsible for reviewing the latest Terms and policies. The Platform may amend Terms at any time without prior individual notice, though reasonable efforts will be made to inform users. The Platform may contact users via SMS, calls, emails, push or messaging apps for verification, compliance, security, or product updates. Users consent to such communications and may manage non‑essential preferences in settings.

16. Intellectual Property & Sharing
Logos, names, and images of teams/players/organizations belong to their owners and are shown for informational/illustrative purposes without commercial intent or affiliation. External sharing of screens is allowed; users are solely responsible for redistribution or editing outside the Platform’s control.

17. Taxes, Sanctions & Restricted Use
Users are responsible for their taxes. Access is prohibited for sanctioned persons/jurisdictions; the Platform may restrict or terminate access where required by sanctions or export‑control rules.

18. Jurisdiction, Disputes & Class Action Waiver
Governing law: Anjouan. Disputes may be resolved under AOFA Commercial Arbitration Rules (seat: Anjouan). To the extent permitted by law, disputes must be brought individually (no class actions). Total liability of the Platform is limited to fees paid by the user in the prior six months.

Approved 05 Jan 2026 by 3-102-938509 S.R.L. / Compliance Department.