P2P Terms & Conditions
P2P Terms and Conditions
Last updated: October 06, 2026
These P2P Terms and Conditions (hereinafter referred to as the “Terms”) constitute a legally binding agreement between CLWHITE DAO LLC (hereinafter referred to as the “Service Provider”, “we”, “us”, or “our”) and you, as an individual user of the Services (hereinafter referred to as the “user”, “you”, or “your”).
The Service Provider is an independent entity that operates an online peer-to-peer (P2P) trading solution. The Service Provider acts solely as a technical and operational facilitator providing a matching service, allowing users liquidate their account balance derived from the sale of virtual items/skins, defined as "Funds" under the White.market Terms of Use (hereinafter referred to as the “Funds”) to third-party counterparties and receive fiat currency (UAH) immediately at the current market price (hereinafter referred to as the “Services”).
By accessing or using the Services, and/or by clicking the confirm-checkbox prior to using the Services, you acknowledge that you have read, understood, and explicitly consent to be legally bound by these Terms in their entirety.
If you do not agree to any provision of these Terms (or any subsequent amendments hereto), you are expressly prohibited from accessing or using the Services and must immediately cease all use.
1. Our services
1.1. The Services function fundamentally as a peer-to-peer (P2P) matching gateway that pairs a user seeking to liquidate Funds with independent third-party counterparties. Through this matching infrastructure, users are enabled to sell their Funds by matching with and accepting active buy orders by such matched third-party counterparties.
For the avoidance of doubt, the term 'Funds' as used herein shall have the meaning ascribed to it in the White.market Terms of Use, representing strictly intra-platform accounting units / virtual credits derived from skin sales, and shall not under any circumstances be construed, interpreted, or categorized as legal tender, fiat currency, bank deposits, or electronic money held, processed, or issued by the Service Provider, White.market, or any of their operating entities.
1.2. The User explicitly acknowledges, understands, and agrees that the Service Provider operates strictly as a neutral technology facilitator.
Accordingly, the Service Provider does not act as a seller, buyer, principal, or direct counterparty to any transaction concluded through or facilitated by the Services, nor shall it take custody of, hold, process, receive, clear, or transmit fiat currency, or assume any financial or legal liability or responsibility for fiat payments, bank transfers, or banking transactions executed between users and third-party counterparties.
Furthermore, the Service Provider does not act in any capacity as a broker, agent, intermediary, proxy, trustee, fiduciary, financial advisor, currency exchange desk, bank, money transmitter, or payment service provider for or on behalf of any user.
1.3. To initiate the P2P liquidation of Funds, the User completes and submits an electronic order form (hereinafter referred to as the “Order Form”). To submit an order, the User enters the amount of Funds to be liquidated and specifies the valid 16-digit bank card number designated for direct peer-to-peer fiat settlement. All transactions are subject to minimum and maximum single-order thresholds displayed on the interface. Orders falling below the mandatory minimum threshold shall not be processed.
Prior to final order confirmation, the Order Form dynamically calculates and displays for informational purposes:
the available balance eligible for P2P liquidation;
the prevailing market exchange rate;
the estimated fiat currency amount (UAH) to be remitted directly by the matched counterparty;
applicable Service fees (if any); and
the estimated peer-to-peer settlement timeframe.
Upon confirming the Order Form, including selecting all required explicit consent checkboxes, the user accepts an active buy order from an independent third-party counterparty. This initiates the direct transaction whereby the user’s Funds are sent to such counterparties, and the corresponding fiat funds (UAH) are transferred directly from those counterparties to the User’s designated bank card.
1.4. The user solely assumes all legal, financial, and operational risks, liabilities, and potential losses associated with indicating incorrect, inaccurate, or third-party payment card details in the Order Form.
1.5. Upon the user’s confirmation of the Order Form, the Services provided by the Service Provider are deemed fully performed, provided in full, final, non-refundable, and irreversible.
1.6. The Services are facilitated solely and independently by the Service Provider as an independent third-party provider outside of white.market (https://white.market/). Its respective operating entities, parent companies, affiliates, directors, officers, employees, or agents are not parties to, guarantors of, or fiduciaries in any transaction or agreement concluded via the Services, provide no representations, warranties, or guarantees of any kind regarding the Services, and explicitly disclaim all legal, operational, and financial responsibility or liability for any errors, processing delays, banking restrictions, card blocks, or financial losses arising from or in connection with the User’s use of the Services.
For the avoidance of doubt, White.market, its operating entities and all parent, subsidiary, or affiliated entities act strictly as independent technology platforms. They are third-party beneficiaries of this Section 1.6, shall not be deemed joint tortfeasors, co-contractors, or guarantors, and explicitly disclaim all joint, several, or vicarious liability arising out of or in connection with the P2P Services provided by the Service Provider.
2. Eligibility and acceptable use
2.1. To use the Services, the user must be a natural person, acting solely and strictly on his or her own behalf, who has reached at least eighteen (18) years of age (or the legal age of majority in his or her country of legal residence) and possesses full civil legal capacity to enter into, execute, and be legally bound by these Terms.
As a mandatory operational and security requirement, the payment card details specified by the user in the Order Form must be legally issued in the user’s own personal name, strictly matching the identity verification (KYC) data. The use of payment cards belonging to third parties, relatives, or drop accounts is strictly prohibited and constitutes a material breach of these Terms.
As a mandatory condition precedent to accessing or using the Services, the user must successfully complete and maintain full identity verification (Know Your Customer / KYC) on the white.market platform in strict compliance with the white.market Terms of Use (available at: https://white.market/terms-of-use).
2.2. The use of the Services is prohibited for any person who is:
located in, established in, a citizen of, or a resident of any country or territory subject to comprehensive international sanctions, embargoes, or restrictive measures imposed by the United Nations Security Council, the European Union, European Union Member States, the United Kingdom (HM Treasury), the United States (OFAC), including, without limitation, the temporarily occupied territories of Ukraine (including the Autonomous Republic of Crimea, the city of Sevastopol, and non-government controlled areas of Donetsk, Luhansk, Zaporizhzhia, and Kherson regions);
designated on any official sanctions or restricted person list, including without limitation the OFAC Specially Designated Nationals and Blocked Persons List, Foreign Sanctions Evaders List, BIS Denied Persons List, EU Consolidated Financial Sanctions List, or UK Consolidated Sanctions List.
The Services are currently provided exclusively to users who are legal residents of Ukraine. If your country of primary legal residence is any jurisdiction other than Ukraine, you are strictly prohibited from accessing or using the Services.
2.3. Before accessing or using the Services, the user must independently verify and assure whether there are any legal limitations, prohibitions, or restrictions regarding such access and use under applicable law. It is the user’s sole and absolute responsibility to observe and comply with all applicable local, national, and international laws, statutes, rules, regulations, and tax obligations of his/her country of citizenship, legal residence, tax domicile, and/or the country from which the user accesses or interacts with the Services.
Accessing or using the Services does not constitute an offer, solicitation, invitation, or recommendation by the Service Provider to buy, sell, trade, or engage in any transactions in any jurisdiction where such offer, solicitation, access, or activity would be unlawful, restricted, or would require any registration, licensing, regulatory approval, or authorization that the Service Provider does not hold.
2.4. The user covenants, represents, and agrees that he or she shall NOT, directly or indirectly:
access or use the Services for any illegal, unlawful, or unauthorized purpose, including, without limitation, money laundering, terrorist financing, illicit trade, fraud, extortion, illegal gambling, bribery, corruption, or tax evasion, or in violation of any applicable local, national, or international law, statute, or regulation;
create, operate, access, or maintain multiple user accounts, or utilize automated bots, proxies, or secondary profiles to execute transactions, bypass single-order limits, circumvent risk management controls, or evade platform restrictions;
solicit, propose, arrange, encourage, or participate in any trade, payment, negotiation, or transaction-related communication outside the designated platform interface (including via social media, messenger applications, email, or face-to-face arrangements);
provide false, inaccurate, misleading, outdated, or incomplete information, or submit fraudulent, altered, or forged identity, banking, or payment verification documents;
use obscene, profane, offensive, abusive, defamatory, threatening, discriminatory, or extortionate language, or engage in harassing conduct toward counterparties, other users, or customer support personnel; or
engage in rate manipulation, price distortion, wash trading, exploitation of technical vulnerabilities or bugs, or any activity that disrupts, overburdens, or compromises the security, stability, or operational integrity of the Services.
2.5. In the event of any breach, suspected breach, or circumvention of any provision set forth in this Section 2, or where required by applicable law, regulatory authorities, or banking partners, the Service Provider reserves the absolute right, at its sole discretion, without prior notice and without incurring any liability, to:
temporarily suspend, restrict, or permanently disable the user’s technical access to the Services;
immediately reject, suspend, delay, decline, or cancel any pending Order Form;
report the details of any suspicious, fraudulent, or non-compliant transaction, together with the User's identity data, to relevant law enforcement agencies, financial intelligence units, banking partners, or regulatory authorities; and
seek full indemnity from the User for all costs, legal fees, administrative penalties, or financial damages incurred by the Service Provider as a result of such breach.
2.6. The user explicitly acknowledges and agrees that fiat card transfers are executed directly between P2P counterparties via commercial banking networks and are subject to local anti-money laundering (AML) legislation, regulations, and commercial bank risk controls. Neither the Service Provider nor White.market shall be held responsible or liable for any bank account freezes, card blocks, transaction delays, administrative inquiries, or enforcement measures executed by commercial banks or regulatory authorities.
3. Warranties, disclaimers and limitation of liability
3.1. The Services are provided strictly on an “AS IS” and “AS AVAILABLE” basis, without warranties or representations of any kind, whether express, implied, statutory, or otherwise. To the maximum extent permitted under applicable law, the Service Provider expressly disclaims all warranties, including but not limited to implied warranties of merchantability, fitness for a particular purpose, title and quiet enjoyment.
The Service Provider provides no representations or warranties that the Services or any technical components will be accurate, complete, continuous, uninterrupted, timely, secure, reliable, up-to-date, error-free, or free of viruses, Trojan horses, worms, or other harmful software.
The user acknowledges that access to and interaction with the Services rely on public networks and third-party telecommunication infrastructure beyond the Service Provider’s control, and the user assumes all operational risks associated with network delays, interruptions, or technical defects.
3.2. All fiat payments, transfers, and settlements are executed off-platform directly between the user and matched third-party counterparties solely at the user’s own risk. The Service Provider does not monitor, process, hold, or control external banking or payment systems and assumes no responsibility for payment delays, bank fees, chargebacks, payment reversals, administrative holds, or account blocks.
The user explicitly acknowledges and agrees that the Service Provider shall not be responsible for assisting with, mediating, or compensating any user for the unfreezing of bank accounts, the lifting or reversal of bank enforcement actions, or the resolution of administrative or fraud investigations, account freezes, or compliance holds initiated by commercial banks, payment service providers, financial monitoring authorities, or regulatory bodies.
3.3. The user accepts all risks of financial loss - including complete depreciation - arising from adverse price movements during or after a P2P transaction. Assets involved in such P2P transactions are not covered by any deposit insurance, investor protection scheme, or government guarantee, and losses incurred will not be reimbursed by the Service Provider.
3.4. In no event shall the Service Provider, White.market, their parent entities, or any of their respective members, directors, officers, employees, agents, or representatives be liable for any indirect, incidental, special, punitive, consequential, or exemplary damages, including, without limitation, loss of profits, loss of revenue, loss of data, bank account freezes, card suspensions, or business interruption, arising out of or in connection with the use of, or inability to use, the Services.
Nothing in this Section 3.4 shall be construed as creating or implying any direct contractual or operational liability for white.market or its operating entities, which are not parties to these Terms. However, to the maximum extent permitted by applicable law, if any third-party or vicarious liability is nevertheless asserted or determined against white.market or its parent and operating entities, their total aggregate liability to the User arising out of or relating to the Services shall not exceed the lower of: (i) the total fees actually paid by the User to the Service Provider for the specific transaction giving rise to the claim; or (ii) One Hundred United States Dollars ($100.00 USD).
Nothing in these Terms shall exclude or limit the Service Provider’s liability for fraud, intentional misrepresentation, or any other liability that cannot be excluded or limited under applicable mandatory law. If such mandatory local laws apply to the user, the limitations, exclusions, and disclaimers set forth in this Section 3 shall apply to the maximum extent permitted by applicable mandatory law.
3.5. The Service Provider does not provide financial, legal, tax, investment, accounting, or professional advice of any kind. Any price quotes, exchange rates, market data, conversion metrics, historical indicators, or instructional materials displayed through the Services are provided strictly for general informational purposes only and shall not be construed or relied upon as an offer, solicitation, invitation, or recommendation to buy, sell, hold, or execute any transaction.
4. Fees
4.1. The Services may be subject to fees, commissions, or service charges as determined by the Service Provider at its sole discretion. Any applicable fees, commissions, or conversion margins associated with a transaction shall be specified and explicitly displayed on the Order Form prior to the user confirming and submitting the Order Form.
By confirming and submitting an Order Form, the user agrees to pay all displayed fees and charges associated with the transaction.
Except as expressly required by applicable mandatory law, all fees and commissions charged upon the successful completion of a transaction are final, non-refundable, and non-creditable. In the event an order is cancelled or voided prior to completion due to counterparty default or technical failure, any reserved Platform Balance and associated Service fees shall be automatically unreserved and restored to the User's account balance on white.market.
4.2. The user is solely responsible for all third-party fees arising from or in connection with the transaction, including but not limited to bank transfer fees, payment card issuer charges, currency conversion surcharges, payment gateway fees, or blockchain network (gas) fees. The Service Provider does not collect, control, or bear responsibility for any third-party fees and shall not be liable for reimbursing any such costs under any circumstances.
4.3. The user acknowledges that exchange rates for P2P card transfers may fluctuate between the moment an Order Form is generated and the time the bank transfer is fully completed. The user agrees that the final conversion rate applied during transaction execution may slightly vary from the initial estimate on the Order Form due to market volatility or card issuer conversion policies. The user accepts all risks associated with such exchange rate fluctuations, and the Service Provider bears no liability for rate discrepancies or processing delays caused by third-party banking institutions.
5.Termination, suspension, and restrictions
5.1. The Service Provider reserves the right, at its sole discretion, immediately and without prior notice, to:
temporarily or permanently prohibit the user from accessing or using the Services or the Platform;
impose limits or restrictions on the User’s use of the Services; or
suspend or terminate the provision of the Services to the user;
5.2. The Service Provider may exercise its rights under Section 5.1 in circumstances including, but not limited to, the following:
where there are reasonable grounds to suspect that the User has violated or attempted to violate any provision of these Terms;
where the Service Provider believes, in good faith, that such action is necessary to protect the Service Provider, or other users from potential harm or liability;
where the Service Provider determines that the User is using the Services in any manner that may adversely affect or interfere with the ability of other users to safely use the Services;
where required by applicable law, court order, or official request from regulatory or law enforcement authorities (including the National Bank of Ukraine, State Tax Service, or financial intelligence units);
where there are reasonable grounds to suspect fraudulent activity, use of third-party payment cards or drop accounts, rate manipulation, or violations of applicable Anti-Money Laundering (AML/CFT) laws; or
where it is discovered that the user, in the course of interacting with other users, has used obscene language, insulted, extorted, harassed, threatened, or otherwise infringed upon the legal rights of others (including rights to privacy, publicity, or intellectual property), or engaged in the unauthorized collection or distribution of private information (doxing).
5.3. Taking any action in accordance with this Section 5 is a right of the Service Provider, not an obligation. If the Service Provider fails to enforce, or delays in enforcing, any obligation of the user, or fails to exercise, or delays in exercising, any right or remedy under these Terms, such failure or delay shall not constitute a waiver of that right and will not prevent the Service Provider from enforcing that obligation or exercising that right at a later time.
6. Amendments and modifications
6.1. The Service Provider reserves the right to amend, modify, update, or revise these Terms from time to time, in its sole discretion, to reflect changes to the Interface, technological developments, industry standards, operational requirements, or to ensure compliance with applicable legal and regulatory requirements.
6.2. For material changes to these Terms, the Service Provider will use commercially reasonable efforts to provide advance notice (targeting up to fourteen (14) calendar days before revised Terms become effective, where operationally feasible) by publishing an announcement.
6.3. Modifications required to satisfy mandatory legal or regulatory requirements, international sanctions compliance updates, emergency security patches, or minor administrative, technical, and formatting corrections shall take effect immediately upon publication.
6.4. It is the user’s responsibility to review these Terms periodically and prior to each use of the Services. The user’s continued access to or use of the Services following the posting or effective date of any revised Terms constitutes full acceptance of and agreement to be bound by such amendments. If the user does not agree to the revised Terms, the user's sole and exclusive remedy is to immediately cease using the Services and terminate their relationship with the Service Provider.
7. Privacy notice
7.1. The user acknowledges and agrees that in order to provide the Services and facilitate P2P card transfers, the Service Provider collects and processes the user's payment card number.
Such data is processed strictly in accordance with applicable data protection laws and for the following legitimate purposes:
to facilitate P2P transfers;
to verify the identity of the user and prevent fraud, money laundering, financial crime, or misuse of the Platform;
to comply with mandatory legal, regulatory, statutory tax, and Anti-Money Laundering (AML/CFT) obligations; and
to maintain security, resolve disputes, and provide customer support.
7.2. To facilitate P2P transfers, the User explicitly authorizes the Service Provider to display or share payment card number with the relevant transaction counterparty strictly to the extent required to execute the transaction. Additionally, the Service Provider may share such necessary transaction data with trusted third-party service providers, payment gateways, banking institutions, acquiring banks, and fraud prevention agencies strictly for execution and security verification purposes.
7.3. The Service Provider implements robust technical, organizational, and administrative security measures to protect Personal Data against unauthorized access, loss, alteration, or disclosure.
7.4. All processing of personal data is conducted in full compliance with applicable data protection legislation, including the Law of Ukraine "On Personal Data Protection" (No. 2297-VI) and, where applicable, the General Data Protection Regulation (EU) 2016/679 ("GDPR"). The user is guaranteed all statutory privacy rights, including the rights to access, rectify, erase, restrict, or object to the processing of their personal data.
8. Governing law and dispute resolution
8.1. These Terms, use of the Services, and any dispute, claim, or controversy arising out of or in connection with them (including non-contractual disputes or claims) shall be governed by, and construed in accordance with, the laws of England and Wales, without regard to conflict of law principles.
8.2. Prior to initiating any formal legal or arbitration proceedings, the user and the Service Provider agree to attempt to resolve any dispute, claim, or controversy informally for a period of at least thirty (30) calendar days. Informal proceedings shall commence upon receipt of a written Notice of Dispute sent to the Service Provider’s designated contact email at [email protected].
The Notice of Dispute must include the user’s account details (including registered contact information and connected wallet address or transaction identifiers, where applicable), a detailed description of the nature and factual basis of the claim, and the specific relief or remedy sought.
8.3. If a dispute, controversy, or claim arising out of or relating to these Terms, including its formation, validity, breach, enforceability, termination, or non-contractual obligations, cannot be resolved through informal negotiations within thirty (30) calendar days, it shall be referred to and finally resolved by binding arbitration administered by the London Court of International Arbitration (LCIA) under the LCIA Arbitration Rules in force at the time of commencement. The seat and legal place of arbitration shall be London, United Kingdom. The language of the arbitral proceedings shall be English. The arbitral tribunal shall consist of one (1) independent arbitrator appointed in accordance with the LCIA Rules. The arbitral award rendered by the arbitrator shall be final, binding, and non-appealable upon both parties, and judgment on the award may be entered and enforced in any court having jurisdiction thereof.
8.4. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, ALL CLAIMS AND DISPUTES ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICES MUST BE ARBITRATED OR LITIGATED ON AN INDIVIDUAL BASIS AND NOT ON A CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE BASIS. THE USER EXPRESSLY WAIVES ANY RIGHT TO COMMENCE, JOIN, OR PARTICIPATE IN ANY CLASS ACTION, CLASS ARBITRATION, PRIVATE ATTORNEY GENERAL ACTION, OR ANY OTHER REPRESENTATIVE PROCEEDING AGAINST THE SERVICE PROVIDER, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, OR OPERATORS.
8.5. The user agrees to fully indemnify, defend, and hold harmless the Service Provider, white.market, their parent companies, operating entities, as well as their respective affiliates, directors, officers, employees, agents, and operators, from and against any and all claims, liabilities, losses, damages, costs, expenses, interest, awards, judgments, legal actions, and penalties (including reasonable legal fees for outside counsel) suffered or incurred as a result of a third-party claim arising out of or in connection with the user’s use of the Services, violation of these Terms, or violation of any applicable law or rights of any third party.
9. General provisions
9.1. If any provision of these Terms is held to be invalid, illegal, or unenforceable by an arbitrator or court of competent jurisdiction, such provision shall be enforced to the maximum extent permissible under applicable law, and the invalidity, illegality, or unenforceability of such specific provision shall be severed and shall not affect or impair the validity, legality, or enforceability of the remaining provisions of these Terms, which shall remain in full force and effect.
9.2. These Terms constitutes the entire, complete, and exclusive agreement between the user and the Service Provider regarding access to and use of the Services. These Terms supersede and replace all prior or contemporaneous understandings, agreements, proposals, representations, warranties, promises, or communications, whether oral, written, or electronic, concerning the subject matter herein.
9.3. The failure or delay of the Service Provider to exercise or enforce any right, power, or provision under these Terms shall not operate or be construed as a waiver of such right, power, or provision, nor shall any single or partial exercise of any right or remedy preclude any other or further exercise thereof or the exercise of any other right or remedy.
9.4. The user may not assign, transfer, novate, or delegate any of their rights, duties, or obligations under these Terms, whether by operation of law or otherwise, without the prior written consent of the Service Provider. The Service Provider reserves the unrestricted right to freely assign, transfer, novate, or delegate these Terms and any of its rights, obligations, or duties hereunder, in whole or in part, to any affiliate, subsidiary, or in connection with any merger, acquisition, corporate restructuring, reorganization, or asset transfer, without requiring prior notice to or consent from the user.
Contact information
If you have any questions about these Terms, please contact us at [email protected].