Suspension and Holds Policy.

Scope of this policy

This policy applies to all users, accounts, balances, operations, services, KeyStore purchases, service payments, top-ups, KeyCoin, payment methods, digital products, sessions, devices, and any feature within the KeyCard BBM ecosystem operated by INNOVAPPSOFT LLC.

It also applies to pending operations, completed operations subject to review, disputes, chargebacks, AML/CTF reviews, KYC verifications, technical activity, suspicious access, and relationships with external providers.

Use of the platform means acceptance of this policy and of any preventive or corrective measures that may be applied to protect the system.

Reasons for suspension or limitation

INNOVAPPSOFT LLC may suspend, limit, or restrict an account when there is suspicion of fraud, policy violation, unusual activity, AML/CTF risk, control evasion, false information, unauthorized access, promotion abuse, chargebacks, disputes, legal requirements, or risk to the ecosystem.

We may also apply restrictions when we detect multiple related accounts, transaction manipulation, impersonation, third-party account use, document falsification, technical exploitation attempts, or signs of prohibited behavior.

Suspension or limitation may be applied without prior notice when necessary to protect users, balances, external providers, infrastructure, legal compliance, or platform security.

Types of measures

Measures may include temporary access blocking, session closure, token invalidation, feature limitation, purchase restriction, top-up pause, KeyCoin hold, balance freezing, or manual review of operations.

We may also restrict payment methods, prevent new purchases, block sensitive account changes, request additional verification, pause pending operations, or prevent the use of integrated external services.

Measures may be temporary, preventive, partial, total, or permanent depending on the level of risk and severity of the case.

Temporary balance holds

INNOVAPPSOFT LLC may temporarily hold KeyCoin balance, internal credits, and pending operations, as well as other account-related value, when there is reasonable risk, dispute, investigation, AML/CTF review, pending KYC verification, chargeback, suspicious activity, or legal requirement.

A hold may apply to the full balance or only to a portion related to an operation, provider, dispute, detected risk, or specific review.

A temporary hold does not necessarily mean a final accusation of fraud; it may be a preventive measure while available information is analyzed.

Freezing balances and operations

We may freeze balances, operations, or features when it is necessary to prevent use of the balance while an account, operation, dispute, chargeback, claim, suspicious access, AML/CTF alert, or external validation is reviewed.

During a freeze, the user may temporarily lose the ability to purchase, spend, or use services related to the affected balance.

The freeze may remain in place until the internal review, verification process, risk analysis, external provider response, or applicable legal requirement is completed.

Internal review

When an account or operation is marked for review, INNOVAPPSOFT LLC may analyze internal records, transaction history, payment methods, device data, IP, approximate geolocation, KYC checks, submitted evidence, account behavior, and external provider signals.

We may request additional information, documentation, receipts, identity validations, source-of-funds explanations, transaction purpose, or evidence related to a dispute.

If the information is insufficient, false, altered, inconsistent, or unverifiable, the account or operation may remain limited, be rejected, or end in permanent closure.

Pending or failed KYC verification

Lack of KYC verification, or a pending, failed, expired, inconsistent, or unverifiable verification may result in feature limitations, balance holds, operation blocking, or account suspension.

We may also apply restrictions when the user refuses to complete additional controls, provides contradictory information, uses altered documents, or cannot prove account ownership.

Approval of sensitive features may depend on successful completion of KYC verification.

Chargebacks, disputes, and external reversals

A chargeback, bank dispute, payment claim, external reversal, or attempt to deny a transaction may trigger suspension, balance hold, feature blocking, AML/CTF review, payment method restriction, or account closure.

If a chargeback causes loss, debt, fee, penalty, negative balance, or damage to INNOVAPPSOFT LLC, the company may offset available balances, cancel pending operations, block purchases, or take additional measures where appropriate.

Abuse of chargebacks or false disputes is considered a serious violation of platform policies.

Future features

KeyCoin is used exclusively for purchases on KeyStore within the KeyCard BBM ecosystem; it is not used as a medium of exchange between users or outside the ecosystem.

Prohibited use of VPNs, proxies, and anonymization

The use of VPNs, proxies, Tor, anonymous networks, data center IPs, IP-hiding services, manipulated connections, or mechanisms to hide location, technical identity, or true origin is prohibited.

The use or attempted use of these tools may trigger preventive blocking, manual review, operation holds, account suspension, or permanent closure.

Frequent IP changes, access from inconsistent locations, abuse-reported IPs, or technical patterns associated with control evasion may also be considered risk signals.

External provider processes

Some operations depend on external providers such as payment processors, payment institutions used by providers, digital asset platforms, blockchain networks, KYC providers, top-up APIs, gift cards, anti-fraud services, or other third parties.

If an external provider holds, blocks, investigates, rejects, or delays an operation, INNOVAPPSOFT LLC may maintain internal restrictions until sufficient information is received or until the external process ends.

INNOVAPPSOFT LLC does not control the timelines, decisions, policies, reviews, fees, holds, or refunds applied by external providers.

Account closure

INNOVAPPSOFT LLC may close an account temporarily or permanently when there is serious violation, fraud, misuse, control evasion, false information, abuse, legal risk, sanctions, prohibited activity, or inability to verify the user.

Account closure may include loss of feature access, cancellation of pending operations, purchase restriction, session invalidation, and retention of balances subject to review.

Closing an account does not remove pending obligations, debts, disputes, chargebacks, investigations, compliance records, or information that must be retained for legal, regulatory, accounting, security, or AML/CTF reasons.

Loss of access to balance

In cases of fraud, serious violation, illegal activity, control evasion, false documents, third-party account use, abusive chargebacks, or risk-based closure, the user may lose full or partial access to the affected balance.

Balance availability will depend on internal review, available evidence, legal obligations, disputes, external providers, caused losses, applicable policies, and measures necessary to protect the ecosystem.

Where legally required or necessary for compliance, certain balances or operations may remain held even after the account is closed.

Release of balance or features

Balance, operations, or features may be released when INNOVAPPSOFT LLC determines that the risk has been mitigated, verification has been completed, evidence was sufficient, the external provider resolved the case, or there is no longer a reason to maintain the restriction.

Release may be total, partial, or conditioned on additional limits, future verification, enhanced monitoring, or specific restrictions.

INNOVAPPSOFT LLC does not guarantee specific release timelines when internal reviews, external processes, disputes, chargebacks, investigations, or legal requirements exist.

Information retention

We may retain information related to suspended or closed accounts, held operations, internal reviews, KYC, AML/CTF, devices, IPs, activity, disputes, chargebacks, balances, and risk decisions.

Information may be retained for as long as necessary to comply with legal obligations, prevent fraud, resolve disputes, protect the platform, respond to external providers, address investigations, or enforce our policies.

Deleting or closing an account does not mean immediate deletion of records that must be retained for security, compliance, accounting, fraud prevention, or applicable law.

Final decision and internal discretion

INNOVAPPSOFT LLC reserves the right to make the final decision regarding suspensions, holds, freezes, releases, account closures, restrictions, blocked operations, or related measures.

Decisions will be based on internal records, available evidence, risk signals, external providers, legal compliance, user history, security, and ecosystem protection.

Applying or not applying a measure in a specific case does not limit the right of INNOVAPPSOFT LLC to apply similar or stricter measures in other cases.

Updates to this policy

INNOVAPPSOFT LLC may modify this Suspension and Holds Policy at any time to adapt it to legal, regulatory, operational, technical, security, fraud, compliance, or risk changes.

Changes take effect once published or from the moment indicated by the platform.

Continued use of the services after an update is published means acceptance of the current version.