Terms of Service (Draft)Terms of Service (Draft)

草稿 — 尚未經律師審核，不構成正式條款 / 草稿 — 尚未经律师审核，不构成正式条款 / DRAFT — not yet reviewed by counsel; not binding

This is a working draft (version 0.2-draft, updated 2026-09-28). It has not been reviewed by a lawyer, it is not in force and it creates no rights or obligations for anyone. Text in [SQUARE BRACKETS] is a placeholder that still has to be decided. The English version is the reference text for counsel; the Chinese versions are translations of it. Questions about this draft can go through the contact page (topic "Legal").

1. About these Terms#

1.1 These Terms of Service ("Terms") govern your access to and use of the OpenVPT website, apps, APIs and related services (together, the "Service"). The Service is operated by [COMPANY LEGAL NAME], a [ENTITY TYPE] organized under the laws of [STATE OF INCORPORATION], with its principal place of business at [BUSINESS ADDRESS] ("OpenVPT", "we", "us").

1.2 By creating an account, connecting a wallet to the Service, listing an item or placing an order, you agree to these Terms and to the policies they refer to, including the Privacy Policy, the Prohibited Items Policy and the Cookie Policy. If you do not agree, do not use the Service.

1.3 These Terms take effect on [EFFECTIVE DATE]. Section 22 explains how we may change them.

1.4 Nothing in these Terms is legal, tax, financial or investment advice.

1.5 Public beta on a test network. The Service is currently offered as a public beta on the Base Sepolia test network. Orders are paid with test USDC that has no monetary value, and no real funds are held or moved through the Service. Do not send real funds to any address shown on the Service. The escrow contract has not yet completed an external security audit, and these Terms are a draft pending legal review. A move to Base mainnet is planned only after that audit and review are complete; the Service will say so when it happens.

2. Eligibility#

2.1 You may use the Service only if:

• you are at least [MINIMUM AGE] years old and old enough to form a binding contract where you live;
• you are not located in, organized in or ordinarily resident in [RESTRICTED JURISDICTIONS], and you are not a person with whom we are prohibited from dealing under applicable sanctions laws;
• you have not previously been banned from the Service, unless we have agreed in writing that you may return; and
• your use of the Service does not break any law that applies to you.

2.2 If you use the Service on behalf of a company or other organization, you confirm that you are authorized to accept these Terms for it, and "you" includes that organization.

2.3 We may limit the Service, or parts of it such as selling, in particular jurisdictions. [AVAILABILITY BY STATE / COUNTRY — TO BE CONFIRMED WITH COUNSEL.]

3. Your account and security#

3.1 You register with an e-mail address and a password of at least 12 characters. You must give accurate information and keep it up to date.

3.2 You are responsible for everything done through your account. Keep your password confidential. You can turn on two-factor authentication with an authenticator app (TOTP); we strongly recommend it. [WHETHER 2FA BECOMES MANDATORY FOR SELLERS — TO BE DECIDED.]

3.3 Tell us promptly through the contact page (topic "Security") if you believe your account or a linked wallet has been compromised.

3.4 One person may not use another person's account, and you may not sell, transfer or share your account.

3.5 To close your account, contact us at [LEGAL CONTACT EMAIL]. The Service does not currently offer self-service account deletion. Closing an account does not cancel orders already in progress (see Section 16), and we keep certain records as described in the Privacy Policy.

4. Wallets#

4.1 Payments on the Service are made from a self-custodied crypto wallet that you control (for example a browser wallet or a wallet connected through WalletConnect). OpenVPT never holds your private keys or seed phrase and cannot recover them.

4.2 To buy or sell, you link a wallet to your account by signing a "Sign-In with Ethereum" (EIP-4361) message. Linking a wallet costs no network fee. As a buyer you pay from one of your verified wallets; as a seller, payouts go to your verified wallet that is recorded on the order when the order is created.

4.3 You are responsible for the security of your wallet, for the transactions and signatures you approve in it, and for making sure the addresses you use are correct.

4.4 New payout wallets. When an order's inspection window ends without a confirmation or a dispute, the automatic release to the seller does not start until the seller's payout wallet for that order has been linked to the seller's account for at least 24 hours. This protects sellers if someone takes over their account and links a new wallet. During that time the buyer can still confirm receipt or open a dispute, and nothing is redirected or refunded because of the wait.

5. Seller verification (KYC)#

5.1 To list items you must (a) have a verified wallet and (b) complete identity verification ("KYC") with a status of "verified". A KYC status can be "none", "pending", "verified" or "rejected".

5.2 We intend to perform identity verification through a third-party provider, [KYC PROVIDER], whose own terms and privacy notice may apply. You authorize us and that provider to verify the information you submit. [THE KYC PROVIDER HAS NOT YET BEEN INTEGRATED; THE PROCESS AND DATA COLLECTED ARE TO BE DESCRIBED IN THE PRIVACY POLICY ONCE CHOSEN.]

5.3 We may refuse, suspend or revoke verification, or ask for more information, at any time, including where we are required to do so by law. We may also apply identity, sanctions or risk checks to buyers where required. [SCOPE OF BUYER CHECKS AND WALLET SCREENING — TO BE CONFIRMED WITH COUNSEL.]

6. Our role: a marketplace, not the seller#

6.1 The Service is a venue where independent sellers offer digital goods and services to buyers. The contract of sale is between the buyer and the seller. OpenVPT is not the buyer or the seller, is not a party to that contract, and does not own, make, inspect in advance or guarantee any listed item.

6.2 In particular, OpenVPT does not guarantee the quality, safety, legality, originality or fitness for purpose of any item, the accuracy of any listing, or the ability of a seller to deliver or of a buyer to pay.

6.3 Our role is limited to: providing the marketplace software; reviewing listings against our rules; issuing order parameters for the escrow smart contract; operating the order timers described below; providing in-order chat and delivery tools; running the platform dispute process in Section 12; and signing settlements as one of three signers in the escrow design described in Section 8.

6.4 Sellers are responsible for their own legal obligations, including any taxes, consumer-protection duties, licences and permits that apply to what they sell.

7. Listings and item rules#

7.1 Items that may be listed include source code, software and SaaS licences for the seller's own software, websites and apps, e-books, courses, game-related digital items, design assets and digital services. Available categories are shown in the Service.

7.2 Every new listing starts in review and is published only after our team approves it. Content changes (for example to the title, description, category, price, delivery or inspection days, or images) to a published or rejected listing send it back to review. We may approve, reject, pause or remove any listing at our discretion, with or without giving reasons, including after publication.

7.3 A listing must describe accurately and completely what the buyer will receive, how it will be delivered, and any limitations (for example licence terms, supported versions or what is not included).

7.4 You may list only items you have the right to sell. The Prohibited Items Policy governs what may not be listed. It includes, among other things:

• licence keys, accounts or copies of third-party software that you have no right to resell;
• pirated, cracked or otherwise unlicensed software, courses or assets;
• accounts on third-party platforms;
• personal data, credentials, leaked databases or other sensitive information;
• malware, or tools built for intrusion or fraud;
• off-platform contact details or payment instructions intended to steer buyers around escrow; and
• anything else that is illegal or breaks our rules.

7.5 Review by OpenVPT is not an endorsement or a guarantee. Approval of a listing does not mean we have verified the item or the seller's rights in it.

8. Payments and escrow#

8.1 How escrow works#

8.1.1 Orders are paid in USDC on the Base network, or in another token we list as supported. USDC is issued by a third party; OpenVPT does not issue, control or guarantee it or the Base network.

8.1.2 When a buyer pays, the funds move from the buyer's wallet into an escrow smart contract ("VPTEscrow") on the blockchain. The funds are held by the smart contract, not in an account of OpenVPT.

8.1.3 Funds leave the contract only through a settlement that carries valid signatures of any two different parties among: the buyer, the seller and the platform signer (a key operated by OpenVPT) ("2-of-3"). The contract checks that the settlement adds up to exactly the escrowed amount and that the platform share is not below the pro-rated fee (Section 9). Each order settles only once.

8.2 What OpenVPT can and cannot do#

8.2.1 Because the platform signer is one of the three signers, OpenVPT's signature combined with the buyer's or the seller's signature is enough to settle an order. You rely on OpenVPT to sign only in the situations described in these Terms.

8.2.2 Settlement signatures under the current contract version do not expire and cannot be withdrawn once given. Under our current policy the platform signs a settlement for a given order at most once. A later version of the contract is planned to add an expiry to settlement signatures.

8.2.3 [WHETHER THIS DESIGN AFFECTS OpenVPT'S STATUS UNDER MONEY TRANSMISSION, ESCROW OR DIGITAL ASSET LAWS IS A QUESTION FOR COUNSEL — SEE NOTES FOR COUNSEL.]

8.3 Payment window#

8.3.1 After placing an order, the buyer has 24 hours to pay. Each payment authorization that OpenVPT signs for the escrow contract is valid for at most 15 minutes and is refreshed automatically while the order is awaiting payment.

8.3.2 An order not paid within the payment window is cancelled. A buyer may ask to cancel an unpaid order; the cancellation becomes final only after every payment authorization that could still be used has expired. If the payment reaches the escrow contract before the cancellation is final, the payment is applied and the order proceeds. If a payment is confirmed on chain for an order that has already been cancelled, only a full refund to the buyer is allowed; the buyer must co-sign that refund.

8.3.3 Orders are treated as paid only after the payment has the number of blockchain confirmations we require.

9. Fees#

9.1 Listing is free. OpenVPT charges a platform fee to the seller when an order settles. The default fee is 5% of the order amount. The fee rate that applies to an order is fixed when the order is created, before payment, and is shown to the buyer and the seller.

9.2 The fee is charged in proportion to the share of the order amount the seller receives:

9.3 The buyer pays the listed price and no platform fee. A full refund carries no fee. Amounts are calculated in USDC's smallest unit and rounded down where needed.

9.4 Network fees. Each party pays the blockchain network fees ("gas", paid in ETH on Base) for the transactions it sends from its own wallet. For a buyer these are approving the USDC and paying into escrow. Signing a settlement is done off chain and costs no gas; OpenVPT currently submits the final settlement transaction and pays its network fee. [WHETHER OpenVPT KEEPS PAYING THE SETTLEMENT GAS OR PASSES IT ON — TO BE CONFIRMED.] Network fees go to the network, not to OpenVPT, and are not refundable.

9.5 We may change the default fee or introduce other fees in the future. Changes will not affect the fee on an order created before the change.

10. Delivery#

10.1 After an order is paid, the seller must deliver within the delivery period stated on the listing (between 1 and 60 days; 3 days by default). Delivery can be:

• a file uploaded to the Service (we record its SHA-256 hash, and the buyer downloads it through a short-lived link);
• a licence key (stored in encrypted form); or
• a hand-over checklist (for example for a website or domain transfer).

10.2 The seller must deliver what the listing describes. Delivering through the Service creates the record used if a dispute arises. Delivery outside the Service may not be recognized.

10.3 If the seller does not deliver in time, the order is refunded in full to the buyer. OpenVPT signs the refund and the buyer co-signs it to receive the funds.

11. Inspection and release#

11.1 After delivery, the buyer has an inspection window stated on the listing (between 1 and 30 days; 3 days by default) to check the item.

11.2 During the inspection window the buyer can:

• confirm receipt: the buyer signs the settlement, OpenVPT co-signs, and the funds are released to the seller (less the fee); or
• open a dispute (Section 12).

11.3 If the inspection window ends without a confirmation or a dispute, the order is treated as accepted. OpenVPT signs the release to the seller, and the seller co-signs to receive the funds. The release may be delayed as described in Section 4.4.

11.4 Confirming receipt releases the funds and cannot be undone. Only confirm after you have checked the delivery.

12. Disputes on the platform#

12.1 Who and when. Only the buyer can open a dispute, only after delivery and only before the inspection window ends. While a dispute is open, the funds stay in escrow.

12.2 Evidence. Both parties can submit evidence as text, links (http or https) or files. Arbitrators rely mainly on records kept in the Service: the listing, the delivery and its SHA-256 hash, in-order chat and the evidence submitted. Communications outside the Service may be given little or no weight.

12.3 Arbitrators. Disputes are decided by arbitrators appointed by OpenVPT, who may be OpenVPT staff. An arbitrator who is a party to the order may not decide it.

12.4 Ruling. The ruling sets how the escrowed amount is split between seller and buyer, anywhere from 0% to 100%, with the fee pro-rated as in Section 9. OpenVPT signs the ruling's settlement once, and either the buyer or the seller co-signs it for it to execute on chain. The current version does not offer an appeal. [WHETHER AN APPEAL STEP IS ADDED BEFORE LAUNCH — TO BE DECIDED.]

12.5 Negotiation period and automatic outcome. After a dispute is opened, the parties have a negotiation period of 72 hours to add evidence, write in the order chat and agree on a split themselves. If the period ends without an agreement: (a) if the seller has not responded (no evidence, no message in the order chat since the dispute was opened, and no settlement proposal or answer), OpenVPT proposes a full refund to the buyer; (b) if the seller has responded but the buyer has not, OpenVPT proposes a release to the seller, less the fee; (c) if both have responded, an arbitrator decides under Section 12.4. Opening the dispute alone does not count as a response. OpenVPT signs such a proposal only as one of the three signers: nothing is paid until the party it favours also signs, and OpenVPT never takes control of the funds. If a proposal cannot be made (for example, the seller's payouts are restricted), an arbitrator decides instead. Both parties are notified of the outcome.

12.6 Nature of the process. The dispute process is a service feature for deciding how escrowed funds are released. It is not formal arbitration under the Federal Arbitration Act or any state arbitration law, and it is not a court judgment. It does not decide any claim other than the release of the escrowed funds for that order, and, subject to Section 21, it does not limit any legal rights you have against the other party. [RELATIONSHIP BETWEEN THE PLATFORM PROCESS AND ANY LEGAL CLAIMS — TO BE CONFIRMED WITH COUNSEL.]

12.7 Further details of the process are described on the arbitration page.

13. Communications and reviews#

13.1 Buyers and sellers can chat inside each order. The Service automatically flags messages that appear to contain contact details or off-platform payment instructions and shows a warning; messages are not blocked. Flags may be considered in disputes and in enforcing these Terms.

13.2 After an order is completed or refunded, each party can leave one review of the other. Reviews must be honest and based on the actual transaction. Reviews affect a user's public rating. We may remove reviews that break these Terms.

13.3 We send transactional e-mails and in-app notifications about your account and orders. [MARKETING E-MAIL CONSENT — TO BE ADDRESSED IN THE PRIVACY POLICY.]

14. Prohibited conduct#

You must not:

• break any law, or buy, sell or offer anything listed in the Prohibited Items Policy;
• infringe anyone's intellectual property, privacy or other rights;
• give false information, impersonate anyone, or open accounts to get around a ban or limit;
• arrange or take payment outside the escrow for an order started on the Service, or ask the other party to do so;
• deliver something different from the listing, or open disputes in bad faith;
• manipulate reviews, ratings, search or prices;
• use the Service for money laundering, terrorist financing, sanctions evasion or fraud;
• upload malware or interfere with, probe, overload or reverse-engineer the Service or the smart contract, except as allowed by law or by a security disclosure program we publish;
• scrape or collect data from the Service or its users without our written permission; or
• harass, threaten or abuse other users or our staff.

15. Intellectual property#

15.1 Your content. You keep ownership of the content you submit (listings, images, descriptions, messages, reviews, evidence and deliverables). You grant OpenVPT a worldwide, non-exclusive, royalty-free licence to host, store, copy, display, reformat, translate and distribute your listing content and reviews in order to operate, display and promote the Service, for as long as the content is on the Service and for a reasonable time afterward to allow removal from backups and caches. For deliverables, messages and evidence, the licence is limited to storing and transmitting them to the other party of the order and to arbitrators, and to using them for disputes, security, legal compliance and enforcing these Terms.

15.2 You confirm that you have all the rights needed to grant this licence and, for sellers, to sell and deliver the item on the terms of the listing.

15.3 What the buyer gets. The rights a buyer receives in an item (for example a licence to use source code or an assignment of a website) are those stated in the listing and in any licence the seller provides. OpenVPT grants no rights in items sold by sellers.

15.4 Our content. The Service, including its software, design, text and trademarks, belongs to OpenVPT or its licensors. We grant you a limited, revocable, non-transferable licence to use the Service for its intended purpose under these Terms.

15.5 Infringement notices. If you believe content on the Service infringes your copyright, send a notice to our designated agent: [DMCA AGENT NAME/ADDRESS], [DMCA AGENT EMAIL]. [A FULL DMCA POLICY, INCLUDING COUNTER-NOTICES AND A REPEAT-INFRINGER POLICY, IS TO BE DRAFTED.] We may remove content and suspend accounts of repeat infringers.

16. Suspension, bans and in-flight orders#

16.1 We may suspend or ban an account, pause or remove listings, or restrict features at any time if we reasonably believe a user has broken these Terms or the law, created risk for other users or OpenVPT, or if we are required to by law.

16.2 When an account is banned: sign-ins and sessions are ended; the user's published listings are paused; and the user cannot use any part of the Service that requires signing in, including their orders, chat, deliveries, confirmations, signatures and disputes.

16.3 Orders already in progress are not cancelled or frozen by a ban. They continue through the other party, the automatic timers and the dispute process:

• a banned seller's order that is not delivered in time is refunded to the buyer;
• a banned buyer's delivered order is treated as accepted when the inspection window ends;
• the other party may open a dispute where the rules allow, and an arbitrator rules.

16.4 If a settlement needs the banned user's own signature (for example a refund or ruling that pays the banned user), it remains pending until we either restore access temporarily so that user can sign, or resolve it with the parties by other lawful means. Funds stay in the escrow contract in the meantime. [PROCESS FOR SETTLEMENTS REQUIRING A BANNED USER'S SIGNATURE, AND ANY DEADLINE, TO BE CONFIRMED.]

16.5 A lifted ban does not re-publish listings automatically; the seller must resubmit them, and they go through listing review again before they are published.

17. Blockchain risks#

You understand and accept that:

• Blockchain transactions are public and irreversible. Wallet addresses, amounts and timing of escrow transactions are visible to anyone. We cannot reverse, cancel or change a transaction once it is confirmed.
• Network fees vary and are paid to the network. Congestion can delay transactions.
• Smart contracts carry risk. The escrow contract may contain undiscovered bugs, and the Base network, USDC or other infrastructure could fail, be changed, be paused or be attacked. The escrow contract [HAS NOT YET BEEN AUDITED BY AN INDEPENDENT THIRD PARTY — UPDATE BEFORE LAUNCH]; an audit is planned.
• Keys can be lost or stolen. If you lose access to your wallet, or someone else obtains it, you may permanently lose funds or be unable to sign a settlement. We cannot help you recover a wallet.
• Stablecoins can lose their peg, and the issuer of a token can freeze or block addresses under its own terms.
• Laws and regulations about digital assets are changing and could affect the Service, including by making it unavailable in some places.
• Tax. You are responsible for determining and paying any taxes on your transactions.

18. No investment advice#

OpenVPT is a marketplace for digital goods and services. We do not offer investment, brokerage, exchange or custody services, and nothing in the Service is investment, financial, legal or tax advice. Digital goods listed on the Service are not offered as investments.

19. Disclaimers#

19.1 THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE". TO THE FULLEST EXTENT ALLOWED BY LAW, OpenVPT DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT, AND ANY WARRANTY THAT THE SERVICE WILL BE UNINTERRUPTED, SECURE OR ERROR-FREE.

19.2 OpenVPT MAKES NO WARRANTY ABOUT ITEMS SOLD BY SELLERS, ABOUT USERS, OR ABOUT ANY BLOCKCHAIN, WALLET, TOKEN OR OTHER THIRD-PARTY SERVICE.

19.3 Some jurisdictions do not allow certain disclaimers, so some of the above may not apply to you. [DISCLAIMER WORDING — FOR COUNSEL.]

20. Limitation of liability and indemnity#

20.1 [LIMITATION OF LIABILITY — TO BE DRAFTED BY COUNSEL. Points to consider: exclusion of indirect and consequential damages; an aggregate cap such as [LIABILITY CAP, e.g. the greater of the platform fees you paid in the [NUMBER] months before the claim or [AMOUNT]]; carve-outs required by law.]

20.2 In any case, OpenVPT is not responsible for losses caused by: the acts or omissions of buyers or sellers; items sold on the Service; your wallet, keys or devices; blockchain networks, tokens or their issuers; or events beyond our reasonable control.

20.3 Indemnity. To the extent allowed by law, you will defend, indemnify and hold harmless OpenVPT and its officers, employees and agents from claims, losses and costs (including reasonable legal fees) arising from your use of the Service, your listings or items, your breach of these Terms, or your violation of any law or third-party right. [SCOPE AND PROCEDURE — FOR COUNSEL.]

21. Governing law and disputes with OpenVPT#

21.1 These Terms are governed by the laws of [GOVERNING LAW STATE] and applicable US federal law, without regard to conflict-of-laws rules.

21.2 [DISPUTE RESOLUTION BETWEEN USERS AND OpenVPT — TO BE DRAFTED BY COUNSEL. Options include: courts of [VENUE]; or a binding individual arbitration clause with a class-action waiver, opt-out window and small-claims carve-out. Until counsel adds such a clause, these Terms contain no agreement to formal arbitration.]

21.3 Disputes between buyers and sellers about an order are handled first through the platform process in Section 12.

22. Changes to the Service and to these Terms#

22.1 We may change, suspend or discontinue any part of the Service. Where possible we will give reasonable notice of material changes that affect orders in progress.

22.2 We may update these Terms. We will post the new version with a new "updated" date and, for material changes, notify you by e-mail or in the Service at least [NOTICE PERIOD] days before they take effect. Changes do not apply retroactively to orders created before they take effect. If you keep using the Service after the changes take effect, you accept them.

23. General#

23.1 These Terms, together with the policies they refer to, are the entire agreement between you and OpenVPT about the Service.

23.2 If any part of these Terms is found unenforceable, the rest remains in effect. Our failure to enforce a provision is not a waiver.

23.3 You may not assign these Terms without our consent. We may assign them in connection with a merger, acquisition or sale of assets.

23.4 These Terms are available in English, Traditional Chinese and Simplified Chinese. If the versions differ, the English version controls. [CONFIRM WITH COUNSEL.]

24. Contact#

• Company: [COMPANY LEGAL NAME]
• Address: [BUSINESS ADDRESS]
• Legal notices: [LEGAL CONTACT EMAIL]
• Online: the contact page, topic "Legal"

Notes for counsel / 給律師的待確認事項#

This section is for review only and will be removed from the published Terms.

1. Money transmission. Analyze whether the non-custodial 2-of-3 escrow (the platform holds one of three signing keys, relays settlements, and as contract owner can rotate the platform signer key and pause new payments but cannot withdraw or settle alone) is outside money transmitter status under FinCEN guidance (FIN-2019-G001) and state money transmission laws. Consider whether operating the platform key together with the dispute process could be seen as control over user funds.
2. State licensing and availability. Confirm state-by-state availability, including New York (BitLicense and money transmission) and California (Digital Financial Assets Law and the internet escrow agent licence). The product plan proposes blocking New York in the MVP; no geographic restriction is implemented in the code today. Fill in [RESTRICTED JURISDICTIONS].
3. Sanctions (OFAC). No sanctions or wallet screening is implemented today. Decide the screening scope (users, KYC, wallet addresses) and the sanctions wording in Section 2.
4. KYC. Sellers must have a "verified" KYC status to list, but no KYC provider is integrated yet (a development flag can auto-verify). Confirm provider, data collected, and whether buyers or high-value orders need checks.
5. Minimum age / COPPA. Choose [MINIMUM AGE] (18 suggested given crypto payments and contracting). There is no age check in the code.
6. Platform dispute process. Confirm that describing it as a service feature, not formal arbitration, is appropriate; whether a separate binding arbitration clause with a class-action waiver is wanted for claims against OpenVPT, and its enforceability (opt-out, mass-arbitration rules, consumer protections); whether an appeal step is needed.
7. Settlements pending a banned user's signature. Under the current design, funds can remain in escrow indefinitely if the banned party must co-sign. Consider a deadline and a lawful off-platform resolution path, and how this interacts with unclaimed-property rules.
8. Irrevocable settlement signatures. Settlement signatures in the current contract have no expiry. Consider disclosure wording and the planned V2 change.
9. DMCA §512. Register a designated agent with the US Copyright Office and draft notice, counter-notice and repeat-infringer procedures.
10. Privacy (CCPA/CPRA, GDPR, other state laws). Coordinate with the Privacy Policy. Data stored includes e-mail, password hash, encrypted TOTP secret, KYC status, wallet addresses, orders, chat messages with risk flags, deliveries (SHA-256, encrypted licence keys), disputes and evidence, reviews, notifications, audit logs (which can record IP and user agent), refresh-token records (IP and user agent), and contact messages (hashed IP only). No automated data-retention job exists yet; retention periods must be defined. Decide whether EU/UK users are in scope.
11. Tax reporting. Confirm any reporting obligations for the platform (for example Form 1099-K / 1099-DA or state marketplace facilitator rules) and whether sellers' tax information must be collected.
12. Consumer protection and marketplace laws. Check the INFORM Consumers Act for high-volume third-party sellers and state automatic-renewal or digital-goods rules.
13. Fees and gas. The platform currently pays the gas for settle(). Confirm the wording in Section 9.4 and whether fee changes need notice.
14. Liability cap, disclaimers, indemnity, governing law and venue (Sections 19 to 21).
15. Language precedence of the English, Traditional Chinese and Simplified Chinese versions.
16. Account deletion. There is no self-service deletion; confirm the process against privacy-law deletion rights and record-keeping duties.
17. Assent to the Terms. The sign-up flow does not currently show a terms checkbox or record which version of the Terms a user accepted. Decide the assent mechanism (for example clickwrap at sign-up and before first order or listing) and whether to store the accepted version and time, so Section 1.2 and Section 22.2 can be relied on.
18. Automatic dispute outcome. Review Section 12.5 (product decision of 2026-09-28): whether proposing a refund or a release because one party did not respond during the negotiation period is fair, enforceable and clearly disclosed, and whether the 72-hour period and the notices are adequate.
19. Public beta on a test network. Review Section 1.5 and confirm what else must be disclosed while only test tokens are used, and what changes before a mainnet launch.