Public Offer
for the Provision of Cryptocurrency Exchange Intermediary Services
Buhta Obmena (hereinafter referred to as the “Service”) offers any individual (hereinafter referred to as the “User”) to enter into an agreement based on the terms of this public offer (hereinafter referred to as the “Agreement”) for the provision of intermediary services for the exchange of cryptocurrency assets.
Key Definitions, Terms, and Concepts
– Platform / Buhta Obmena / Service : A set of software tools, domain name, interfaces, and technical infrastructure available at https://buhtaobmena.me, enabling Users to engage in informational interaction and exchange digital assets under the terms of this offer.
– User: A legally capable individual who has accepted this Offer and uses the Platform to create and execute exchange requests with other Users, with technical assistance from the Service, which is not a party to the transaction.
– Counterparty: A Platform User acting as a party to an exchange transaction with another User, selected automatically or manually via the Platform’s interface.
– Operations (Payments): A civil-law transaction between Platform Users aimed at exchanging digital assets and/or fiat funds on terms independently set by them. The Operator is not a party to such transactions.
– Exchange: An operation involving the mutual transfer of digital assets and/or fiat funds between Users, initiated through the Platform’s interface. The Service provides solely technical assistance for such operations and is not a party to the transaction, even when the execution of a request involves receiving or sending assets using the Service’s technical means.
– Request: An electronic expression of intent by the User, submitted through the Platform’s interface, specifying the amount and direction of the intended exchange, as well as the details for receiving and sending assets.
– Services: Information and technological services provided by the Service, including automated request processing, notification delivery, counterparty matching, display of request information, transaction support, and technical support.
– Commission: A fee charged by the Service to the User for facilitating asset exchanges, included in the exchange rate or displayed separately when submitting a Request.
– AML/KYC: A set of procedures aimed at identifying the User and verifying the source of funds to comply with legislation on preventing money laundering and terrorist financing.
– Identification: The process of verifying the User’s identity through the submission of documentation and/or verification actions (passport, selfie, video confirmation, tax ID, address, etc.).
– Force Majeure: Extraordinary and unavoidable circumstances beyond the control of the parties, making it impossible to fully or partially fulfill obligations under this Agreement (including payment systеm disruptions, communication failures, legal restrictions, etc.).
– Details: Unique identifiers used by the User for asset transfers (including crypto wallets, bank cards, account numbers, payment systеm logins, etc.).
– Offer Acceptance: Full and unconditional acceptance of the terms of this Agreement by the User through actions specified in clause 8.1 of this Offer.
– Government Authority / Law Enforcement Agency: An authorized body, institution, or person acting on behalf of the state, performing supervision, control, investigation, inquiry, operational activities, or other public authority functions in accordance with applicable law.
1. Subject of the Agreement
1.1. The Service provides the User with intermediary services to facilitate the conclusion of cryptocurrency asset purchase and sale transactions (hereinafter “Exchange”) between the User and third parties (Counterparties), including providing access to the interface of the software platform, which enables:
– Placement of exchange requests for digital assets;
– Automatic counterparty matching;
– Notification delivery to transaction parties;
– Technical support for Users regarding the use of the Platform’s interface.
1.2. The Service is not a party to the transaction, does not store or control Users’ funds, and only provides a platform for finding Counterparties and conducting exchange operations between them.
1.3. The Service may receive digital assets (including cryptocurrencies) from the User to technical wallets controlled by the Service solely for the purpose of subsequent transfer to another User or as part of executing an exchange request. Such actions are not considered storage or management of third-party funds but are performed as a technological necessity for executing the exchange, with full logging and recording of the amount, direction, and details.
1.4. The Service’s activities are not related to conducting operations with digital currency on its own behalf and do not constitute an exchange or sale of digital currency. The Operator provides only informational and intermediary services to facilitate communication between Platform Users for the purpose of exchanging digital assets.
1.5. The Service operates within the framework of applicable law, does not conduct money transfers between residents of the Russian Federation, and does not perform the functions of a payment agent or electronic money operator.
1.6. The Service does not facilitate the exchange of fiat funds between residents of the Russian Federation. All activities are conducted outside the jurisdiction of the Russian Federation and do not fall under restrictions established by Russian law, including provisions on the national payment systеm and limitations on digital currency circulation.
2. Terms of Service Provision
2.1. The Service provides the User with information and technological services by granting access to the Buhta Obmena Platform, located at https://buhtaobmena.me.
2.2. The Operator’s services inсlude:
– Providing an interface for creating and placing exchange Requests for digital assets;
– Automated or manual counterparty matching;
– Informing parties about the progress of Request execution;
– Technical transaction support and consultation (if necessary);
– (If applicable) Transaction support with an escrow or automated service.
2.3. Services are considered duly provided and fully completed upon the execution of the User’s Request or the completion of the Request cancellation procedure (including the return of funds if the exchange conditions are not met).
2.4. To receive services, the User must:
– Correctly provide all required information in the Request (amount, direction, details);
– Ensure the transfer of assets to the addresses/accounts specified by the Operator within the set timeframe;
– Comply with technical and operational instructions posted on the Platform.
2.5. The average Request processing time ranges from 5 to 60 minutes, depending on the exchange direction, operator workload, and the technical stability of external services. If this time is exceeded, the Service informs the User of the delay via email or the website interface.
2.6. The User acknowledges that digital asset operations are irreversible, and in case of incorrect details or other errors, a refund may be impossible. The Operator is not responsible for the consequences of such errors.
2.7. To use the Service, the User must:
– Provide accurate data required for the Exchange.
– Independently verify the Counterparty’s details before transferring funds.
– Follow the instructions on the website during the transaction.
2.8. The Service does not guarantee:
– Availability of specific exchange directions.
– Absence of fraudulent actions by third parties (the User conducts exchanges at their own risk).
– Correct operation of payment systems and banks.
2.9. The Service is not responsible for:
– The User providing inaccurate, erroneous, or uncontrolled details for receiving assets;
– Transfers to such details, including cases of blocking, refund, or loss.
2.10.1. If the User provides incorrect details, a refund is possible only by agreement with the Counterparty. The Service does not participate in forced refunds and does not compensate for losses caused by errors in details.
2.10.2. The Service does not verify the ownership of details and is not responsible for:
– Erroneous or fraudulent transfers;
– Blocking of funds by banks or payment systems;
– Inability to refund due to incorrectly provided details.
2.10.3. By confirming the receipt of funds for a Request, the User assumes responsibility for the accuracy of this confirmation. If the User confirms receipt but later claims the funds were not received, the Service is not liable, as the transfer of assets to the Counterparty and completion of the Request are based on this confirmation.
2.11. User Guarantees Regarding Details:
The User, by providing details for receiving cryptocurrency or fiat funds (bank cards, accounts, electronic wallets, crypto addresses, etc.), guarantees and confirms that:
– The provided details belong to them legally;
– Third parties have no rights to use these details;
– They are authorized to conduct operations using these details.
2.11.1. The User guarantees that they use the Service solely for lawful purposes, not related to money laundering, terrorist financing, sanctions evasion, or other legal violations.
3. Exchange Procedure
3.1. Using the Platform’s interface, the User independently selects the exchange direction, specifies the exchange amount and other necessary parameters, and provides details for receiving the asset.
3.2. After submitting a Request, the User transfers the cryptocurrency or fiat asset to the details specified by the Service solely for the purpose of finding a Counterparty to conclude a purchase-sale transaction of the respective asset.
3.3. Acting as a technical intermediary, the Service does not enter into obligatory relationships with the User and/or Counterparty regarding the transfer and receipt of assets, does not store assets, does not manage them, and is not a party to the purchase-sale transaction.
3.4. Upon receiving confirmation of funds receipt (from the User or potential Counterparty, depending on the exchange direction), the Service performs automated matching of a suitable Counterparty, enabling the technical possibility for the User and Counterparty to conclude a civil-law purchase-sale transaction of the cryptocurrency asset.
3.5. The exchange operation is completed by the technical transfer of the respective asset (including cryptocurrency) to the details provided by the Counterparty or User, solely to fulfill their mutual intent to conduct the transaction.
3.6. The Service does not control the intended use of received assets and is not responsible for the actions or inaction of Users and Counterparties within the transactions they conclude.
3.7. All transactions are accompanied by internal logging and data recording, as well as the application of identification policies in cases required by law or internal procedures.
3.8. In case of a dispute, the User may contact the support service for arbitration, providing evidence of the transfer (Section 7 of this Offer).
4. Commissions and Disclaimer
4.1. The Service may charge a commission for the provision of Services, the amount of which is indicated when submitting a Request or included in the exchange rate. The commission may vary depending on the exchange direction and amount.
4.1.1. The commission is automatically deducted by the Service upon Request execution and is non-refundable, except in cases provided for by this Offer or applicable law.
4.1.2. The average Request execution time is 5–15 minutes when processed manually by an operator.
4.2. The Service is not a bank, credit, or payment organization, and its activities do not require licensing under applicable regulations at the place of the Platform’s operation.
4.3. The Service is not a party to asset exchange transactions conducted by Users through the Platform and is not responsible for their legal validity, execution, compliance with legislation, or the actions (or inaction) of Users, including unlawful ones.
4.4. The Service does not control the reliability, solvency, or good faith of Users. All transactions are conducted at the Users’ own risk. The Operator is not responsible for potential losses caused by deception, bad faith, or other actions of third parties.4.5. All calculations made during Request execution are conducted solely within the technical interaction between the Service and the User, without creating purchase-sale or other property obligations between them. The Service does not accumulate or manage funds on its own behalf.
4.6. The Operator is not responsible for:
– Failures, delays, or inability to execute a Request due to errors in the details provided by the User;
– Unstable operation of the Internet, payment systems, blockchain, software interfaces (APIs), or cryptocurrency nodes;
– Blocking or restriction of transactions by payment systems, banks, or other providers;
– Decline in the market value of assets or losses due to changes in rates or market conditions.
4.7. The Operator’s total liability to the User is limited to the amount of the commission actually received by the Operator for the disputed transaction. Compensation for losses, lost profits, or other indirect expenses is excluded.
4.8. Any third-party expenses (fees of payment systems, banks, blockchain networks) are borne by the User unless otherwise explicitly stated on the Platform when submitting a Request.
4.9. The Service does not refund assets in case of incorrectly provided details or erroneous operations by the User, except in cases where a refund is technically possible and agreed upon by the other party to the exchange.
4.10. The Service provides the Platform in working condition and takes reasonable measures to ensure its stable operation but does not guarantee the absence of failures, technical errors, or delays caused by external factors (operation of payment systems, blockchain networks, etc.).
5. Other Conditions
5.1. By conducting an exchange through the Service, the User confirms that they are familiar with and accept the terms of this Offer.
5.2. The Service reserves the right to amend the terms of this Offer without prior notice.
5.3. The Service does not guarantee that transactions concluded by Users comply with the legal requirements of the User’s specific jurisdiction and is not responsible for violations of such regulations.
5.4. Taxation of User Operations
5.4.1. The Service is not a tax agent for the User, does not calculate the User’s tax payments, and is not obligated to notify the User about their tax obligations. The User must independently pay all taxes in accordance with the tax legislation of their tax residency jurisdiction.
5.4.2. No interaction between the User and the Service shall be construed as establishing agency, partnership, joint activity, employment, or any other relationships not explicitly provided for by the Service’s Rules.
6. AML/KYC Procedures and Transaction Guarantees
6.1. AML/KYC Checks:
– The Service may require Users to undergo identification (Kyc) and anti-money laundering (AML) procedures in accordance with applicable law.
– If the User refuses to provide the required documents, the Service may refuse to conduct the exchange or restrict access to the Platform.
– The Service does not store personal data longer than required by law and uses it only to comply with regulatory requirements.
6.2. Transaction Fact Guarantee:
– The Service records the fact of creating an exchange Request but is not a party to the purchase-sale agreement between Users for the exchange of cryptocurrency for fiat currency or vice versa.
– Obligations to transfer fiat funds are fulfilled by the User. Obligations to transfer cryptocurrency are fulfilled by the Service, provided the User properly fulfills their obligations (e.g., funds receipt).
7. Dispute Resolution and Refunds
7.1. Disputes Between Users:
– Any claims related to non-delivery of funds, erroneous transfers, or fraud are subject to resolution between the Users themselves.
– The Service is not responsible for the Counterparty’s fulfillment of obligations but may assist in dispute resolution by:
– Providing transaction details (time, amount, details);
– Blocking a suspicious User;
– Transmitting information to law enforcement agencies (upon request).
7.2. Refunds:
– Refunds are possible only by agreement between Users.
– The Service does not perform forced refunds and does not act as a guarantor for such claims.
– If the User provides incorrect details, the responsibility for the refund lies with them, and the Service may only request assistance from the Counterparty (without guaranteeing it).
7.3. Arbitration:
– In case of a dispute, Users must provide evidence of the transfer (screenshots, receipts, transaction hashes).
– Arbitration decisions are advisory and may inсlude:
– Releasing reserved cryptocurrency;
– Blocking the violator’s account;
– Referring the case to court (if required).
– Disputes are resolved via email, and if resolution is impossible, through arbitration with the place of proceedings chosen by the Service, subject to mutual agreement.
7.4. Processing Requests from Competent Government Authorities:
7.4.1. Requests must be made on legal grounds and submitted in accordance with the Terms.
7.4.2. Requests must inсlude a valid email address for the Service’s response, clearly associated with the competent authority.
7.4.3. The Service may refuse to provide information if the request violates applicable supranational or local regulations or lacks sufficient grounds for User identification.
7.4.4. The Service prefers to receive all requests via email: buhtaobmena@gmail.com.
7.4.5. Request processing may take at least ten (10) business days.
7.4.6. Requests from competent authorities must inсlude:
– Full information about the requesting authority;
– Name and identification details of the person responsible for the investigation;
– Official email and postal address of the authority, as well as a contact phone number;
– A clear description of the requested information.
7.4.7. To process requests efficiently, the Service requests additional transaction details: wallet address, transaction hash, transaction amount, or other relevant information available to the authority.
7.5. Processing Client Inquiries:
7.5.1. Responses to client inquiries may be provided only in limited scope and only regarding transactions performed by the User, if technically identifiable.
7.5.2. Client inquiries and requests are processed within 24 hours.
7.5.3. The Service prefers to receive all inquiries, including client requests, via email: info@buhtaobmena.me.
8. Final Provisions
8.1. Offer acceptance (clicking “Accept” / “Agree” / registering on the website) constitutes full and unconditional acceptance of the terms of this Agreement.
8.2. Buhta Obmena does not provide financial, investment, credit, tax, or legal services.
8.3. The Service may amend this Offer without prior notice. The current version is published on the Service’s website and takes effect upon publication.
8.4. The User must independently monitor changes to the Offer’s terms. Continued use of the Platform after changes constitutes agreement with the new terms.
8.5. The Service does not consider claims for refunds based on third-party allegations of allegedly unlawful transfers if the respective Request was executed properly and in accordance with the terms confirmed by the User.
Operator Details:
Website: https://buhtaobmena.me/
Email: info@buhtaobmena.me
Agreement published on July 7, 2025.