Legal & Privacy

These Terms of Service are binding Terms (the “Terms” or “Agreement”) between Cifralfabeto Unipessoal Lda, a company duly incorporated under the laws of Portugal, bearing company registration number 516299425, authorized to provide activities with virtual assets under the authorization granted by the Bank of Portugal and by the Autorité des marchés financiers under the registration number E2023-104, with a registered address at Avenida da Liberdade, 615, 1º Piso, 4710-251 Braga, Portugal (hereinafter “Service Provider”, “us”, “we”, “our”), as the operating of services, including any content or information provided as part of the App or related services, as set out hereafter, and the person, persons or entity (“Contracting Party”, "User", “you” or “your”) using such kind of services (each a "Party" and collectively the "Parties").

By accessing, registering or using our Services you agree to comply and be legally bound by these Terms.

1. Provision of services

1. Cifralfabeto, Lda (“us”, “we, “the Company”) provides the Contracting Party (“you”, “the Client”) with access to a mobile-based App which enables the Contracting Party to use virtual assets as a medium of exchange between virtual assets and fiat currency and has developed these Terms in order to describe the terms that govern the exchange operations within said App.

2. The Contracting Party is an individual person, having citizenship and being domiciled in the European Union and/or in the European Economic Area who wishes to perform exchange operations between virtual assets and fiat currency.

3. Having performed the appropriate due diligence steps, the Contracting Party requests the Company to execute exchange operations. The Contracting Party then sends the funds that it wishes to be converted to an address of the exchange account held by the Company on behalf of the Client, where the funds are held until being exchanged.

4. You authorise us to receive funds, temporarily hold, exchange and disburse them, as well as deduct the applicable fees and taxes, and to take any and all actions that we find necessary or desirable to provide our Services to you and to comply with any applicable law and these General Terms.

5. The exchange account is intended for executing exchange operations between virtual assets and fiat currency. We collect funds to your Account exclusively for you and on your behalf, meaning we never have access to the private keys associated with the virtual assets. The Contracting Party remains the owner of virtual assets that we hold for you and on your behalf.

6. When the Contracting Party requests the exchange between virtual assets and fiat currency, the Company recourses to one or more third-party service providers, who shall also accept on their own accounts, but on behalf of the Contracting Party, the funds.  

7. A bank account or payments account on a third-party credit institution or payment institution, held by the Company on behalf of the Client, is used to receive the converted funds.

8. The Company then orders the transfer of the funds, including through SEPA transfer or electronic money transfer and in fiat currency, to a third-party banking account on an electronic money institution, duly authorised to carry out payment services, with recourse to third-party licensed banks. 

Payment settlement for the sales of crypto-assets is only possible via your account opened with Capital Financial Services S.A. (the “Account Provider”), an electronic money institution duly licensed by the National Bank of Romania to provide you with their payment services.

By submitting a sell order to us, you irrevocably instruct us to make a transfer of the exchanged funds in fiat currency to your account opened with the Account Provider.

Any activity, including any fiat top-up limits relating to your account, opened with the Account Provider, is governed by separate terms and conditions you have with the Account Provider. Please note that we will reject any transactions which would result in the Account Provider’s limits being breached.

You request and authorize us to carry out, on your behalf, an exchange transaction (a buy order) involving your cashback rewards (fiat currency) that we have received from your Account Provider. As soon as we receive the cashback rewards from your Account Provider, we will exchange the cashback rewards into virtual-assets and send the virtual assets to your registered wallet address. You also agree that the virtual-asset into which the cashback reward shall be exchanged is EGLD. 

9. Please note that you won’t be able to use our services if you don’t comply with the terms and conditions and the acceptance policy of the Account Provider.

2. Client Registration and Due Diligence

1. In order to use our Services and to comply with relevant Anti-Money Laundering (hereinafter “AML”) and Countering Financing of Terrorism (hereinafter “CFT”) regulatory requirements, the Contracting Party must register on our App and go through a mandatory due diligence process, known as Know Your Client (hereinafter “KYC”), in which the Contracting Party is required to indicate its personal information – such as date of birth, place of birth, occupation, phone number and residence address, information on the source of wealth and source of funds, political exposure, and the reason for acquiring, disposing of or investing in cryptocurrencies. The Contracting Party also needs to agree to be bound by these Terms and Conditions, all applicable laws and regulations, and agree that it is responsible for obeying any laws which may apply.

2. Such requests for information may also be accompanied by a request to provide us with documentary evidence to confirm the veracity of the Contracting Party’s identity, such as scans and certified copies of the ID Card, Residence Permits, Utility Bills, Bank Statements or Payslips, as well as additional information and documentation. We may ask the Contracting Party for this additional information and documentation at any time through one of its indicated contact methods. 

3. The Company uses external third-party service providers to conduct KYC in order to fulfil its legal obligations and process client Data. You shall not hold the Company liable for any losses or damages which may arise for any data loss, misconduct or any other action or inaction which is carried out by the third-party Services Providers. 

4. The Client must provide the Company with all documents and information promptly and accurately. The Client accepts that if the Company fails to receive the information and documentation requested within a reasonable time it may have to block the Client account temporarily or even permanently until the matter is resolved. Please provide this information as quickly as possible so that there is no disruption to your account or our services.

5. Each Client must carry out the KYC process at least once. The list of information, data and/or documents which are requested by the Company in order to fulfil this Process may be amended depending on any new regulatory requirements applicable to the Company. Furthermore, the Client agrees to notify the Company immediately upon any material changes to the submitted data, namely but not limited to a change in name, address, occupation, or source of wealth.

For purposes of the onramp solution, the Client will be required to complete KYC for transactions above €1000 (resulting from one or more operations) and/or in order to perform more than three transactions. 

6. The registration is limited to individuals who are eighteen (18) years of age or older and can lawfully enter into and form contracts under applicable law.

7. The Company reserves its right to reject any account registration or later close any account for any reason whatsoever, namely, but without limitation, due to lack of information, due to the conclusions derived from the analysis of any specific information, due to false, inaccurate or incomplete information provided or if we suspect there is a breach of these Terms.

8. The sole purpose of processing personal data is the prevention of money laundering and terrorist financing and the data may not be further processed for any other purposes, including commercial purposes.

9. By creating an account and/or by simply using our App, the Client declares that all statements, declarations and information supplied are truthful and complete; all copies of documentation are copies of original, genuine and authentic documents; the funds used to finance the account do not emanate from any criminal activity or proceeds of crime; transactions on the Account will not be aimed at, engaged with, nor will assist in any manner in any criminal activity, laundering of money or the funding of terrorism; the client is not barred under any law, court order or judgement from having a bank account or to make use of financial services similar to those provided by the Company or similar institutions; the Client agrees that have read, understood and accepted all of these terms included in this Agreement.

10. Providing false, forged, or modified documents with the intent to deceive and conceal information will be considered fraud and treated as such.

3. Service limitations and restrictions

1. The Contracting Party will only be allowed to open an account and use the Company’s services if the citizenship and domicile is in the European Union and/or in the European Economic Area (this list may be further updated and expanded in the future, in accordance with international regulations and directives, among other risk-based criteria) and if the Contracting Party is not subject to FATCA (US person by default or eligible for tax purposes). 

2. Any onboarding and/or KYC attempt by a prospective user detected to be from one of the non-accepted jurisdictions and territories will be promptly rejected with no possibility of appeal.

3. Except to the extent that such activities are expressly agreed by the Parties, the Contracting Party shall not:

1. use the Service in any way that harms the Company or its affiliates, agents or branches, or any Contracting Party or other users of the Services;
2. engage in or facilitate any unlawful conduct;
3. damage, disable, overburden or harm the Services (or the networks connected) or interfere with anyone’s use of the Services;
4. redistribute the Services, or any part of the Services, unless contracted otherwise;
5. use any unauthorised automated process(es) or service(s) to access and/or use the Services;
6. use any unauthorised means to modify or reroute, or attempt to modify the Services or work around any technical limitations in the Services;
7. reproduce, publish, distribute, redistribute, broadcast, transmit, modify, adapt, edit, abstract, create derivative works of, store, archive, publicly display, sell or in any way commercially exploit any part of the Services.

4. The Company reserves the right to monitor usage by all users (by way of audits or otherwise) during the term of this Agreement for the purpose of (among others) ensuring compliance with these Terms. Any audit may be carried out by the Company or a third party authorised by the Company. If any audit reveals that any password has been provided to an individual who is not a user of the Platform, the Company is entitled to, without any delay, disable any such passwords and notify the Contracting Party immediately about such circumstance and situation.

5. The Contracting Party must lawfully use the Services and must obey all laws, rules and regulations applicable to the use of the Services. If the Company suspects or knows that the Contracting Party is using or has used the Services for unauthorised, fraudulent, or illegal purposes, the Company may share any information related to such activity with the competent authorities, regulatory authorities or law enforcers consistent with its legal obligations. This information may include information about the Contracting Party, its account, and transactions made through the use of the Services.

4. Warranties and representations

1. The use of the Services is subject to the laws and regulations of Portugal regarding the prevention of money laundering and terrorist financing. The Contracting Party agrees and acknowledges that the use of the Services will comply with such laws and regulations.

2. The Company does not warrant or represent that the Services will be free from errors and interruptions.

3. The warranties in this clause are subject to the Contracting Party giving notice to the Company as soon as it is reasonably able upon becoming aware of the breach of each warranty. When notifying the Company of a breach, the Contracting Party shall use its reasonable endeavours to provide such documented information, details and assistance as the Company may reasonably request.

4. The Company will not be held liable under this clause, or be required to remedy any problems arising from or caused by the Contracting Party’s use of the Services in a manner other than as directed by the Company.

5. The Contracting Party acknowledges and agrees that:

1. The Company does not own or control the operations underlying the non-custodial wallet and makes no guarantee of their functionality, security or availability; 
2. The Company is not responsible for any aspect of the information, content or services contained in any third-party materials or on any third-party sites accessible from or linked to the Company Site or the mobile application. 
3. The Company may allow third-party providers applications to access Contracting Party Data and Authorised Client Data as required for the interoperation of such third-party applications, which will be subject to the privacy policies of such third-party;
4. The Company is not responsible for any delays, failures, or any other loss or damage resulting from errors of the Contracting Party.

6. The Contracting Party represents and warrants to the Company that:

1. it is eligible to register and use the Services and has the right, power, and ability to enter into and perform under these Terms and to grant the rights and authorisations as agreed in these Terms;
2. it shall and will ensure to comply with all applicable laws and regulations;
3. it is the sole responsible for any tax obligations arising from the conversion of its received virtual asset funds;
4. it will not use the Services, directly or indirectly, for any fraudulent or wrongful undertaking or in any manner to interfere or cause damage with the use of the Services;
5. it will keep confidential and, except as provided for in these Terms, not share with any third-party, their password or access details provided to facilitate access to the Service;
6. it is not subject to any sanctions or otherwise has been designated and/or listed in any list of prohibited or restricted parties or owned or controlled by such a party, including, but not limited to, the lists maintained by the United Nations Security Council, the US Government (e.g., the US Department of Treasury’s Specially Designated Nationals list and Foreign Sanctions Evaders list and the US Department of Commerce’s Entity List), the European Union or its member states, or other applicable government authority.

5. Acceptance and top-up of virtual assets

1. Services provided within the scope of activity with virtual assets will be limited to those that are considered eligible after an assessment of the respective risks in accordance with the AML/CTF Policy and Procedures Manual.

2. Only virtual assets whose underlying technology is considered safe, suitable and corresponds to the best standards of government in the sector will be accepted, not being eligible, for example, virtual assets that enhance situations of anonymity (e.g. privacy coins).

3. Currently we are only accepting BTC, ETH, BNB, eGLD and UTK, however, this list may be subject to change at any time.

4. When we receive the Client’s transfer of virtual assets, the Company will add the equivalent value to the corresponding account. 

5. The Company is not responsible for any loss of funds as a result of any error or negligence of the Client; as a result of any fundamental error, bug or malware which has affected the relevant virtual asset’s blockchain or any related systems, including the App, which could not be reasonably prevented or foreseen by the Company in the given circumstances.

6. Legal title to virtual assets

The title to the virtual assets shall at all times remain with you. As the owner of any virtual assets in your account on the App, you shall bear all risk of loss of such virtual assets. The Company shall not have any liability for fluctuations in the fiat currency value of any virtual assets held in your account on the App.

7. Security 

1. In order to access the Company Services, the Contracting Party will be required to create or be given security details, including a password. The Contracting Party is responsible for keeping the electronic device through which it accesses the Company Services safe and maintaining adequate security and control of any and all security details that the Contracting Party uses to access the Company Services.

2. The Contracting Party shall use its best efforts to prevent unauthorised use of our Services, its account, or of any Documentation. In case the Contracting Party becomes aware that any security details have been compromised or if the Contracting Party becomes aware of any fraud or attempted fraud or any other security incident (including a cyber-security attack) affecting he/she/it and/or the Company (together a 'Security Breach'), the Contracting Party must notify the Company as soon as possible by email and continue to provide accurate and up to date information throughout the duration of the Security Breach.

3. The Contracting Party must take any steps that the Company reasonably requires to reduce, manage or report any Security Breach. Failure to provide prompt notification of any Security Breach may be taken into account in the Company's determination of the appropriate resolution of the matter.

4. The Company shall not be held liable for the actions and/or omissions which may result in a Security Breach by a third-party Service Provider. These actions or omissions shall include the treatment of any information or Personal Data which belongs to You. The Company shall not be held liable for any losses or damages suffered by the User for such Security Breach or any other form of operational or technical breaches which may fall under the responsibility of the third-party Service Provider and/or an Exchange.

8. Indemnification

1. The Client agrees to indemnify, defend the Company and its affiliates, contractors, licensors, and their respective directors, officers, employees and agents harmless from and against any claims and damages arising out of your breach or our enforcement of these Terms.

2. To the extent not prohibited by law, the Company shall not be held liable for any damages of any type, whether direct or indirect, arising out of or in any way related to your use or inability to use the Services, including but not limited to damages allegedly arising from the compromise or loss of your login credentials or funds, or loss of or inability to restore access to your account, or for mistakes, omissions, interruptions, delays, defects and/or errors in the transmission of transactions, or for diminution of value of any virtual asset. 

3. The Company shall not be held liable under any circumstances for damages arising out of or in any way related to software, products, services, and/or information offered or provided by third parties and accessed through the Platform.

9. Remuneration

1. The services provided by the Company to the Contracting Party have in principle a continuous character.

2. The Contracting Party owes the Company a Fee for each operation, to which a spread will be added. 

3 . The amount released to the Contracting Party may be subject to changes due to market rates.

4. The Company shall be entitled to review and therefore increase the Fee at any time but not more than once every month.

10. Account Closure

1. If you change your mind and do not wish to maintain your account anymore, just let us know through one of our contact methods and we will close it for you. Please note that deleting the App will not automatically result in the closure of your account.

2. The Company also reserves the right to suspend and/or close your account, refuse or delay a transaction, without prior notice, in exceptional circumstances. Exceptional circumstances include the following:

1. if your account opened with the Account Provider is suspended, restricted and/or terminated under the terms and conditions you have with your Account Provider;
2. if we have good reason to suspect that you are behaving fraudulently;
3. if you haven't given us any information we need, or we have good reason to believe that the information or documentation you have provided is false, incorrect or misleading;
4. if you've broken these terms and conditions seriously or persistently;
5. if we have good reason to believe that your use of the app is harmful to us or our software, systems or hardware;
6. if we have to do so under any law, regulation, court order or instruction from any law enforcement authority or regulator.

3. Where the reason for the suspension is suspected misuse of the Services or breach of these Terms, the Company will take steps to investigate the issue and may permanently cancel the access at its own and sole discretion and communicate it to the authorities. In this case, the Company will notify the Contracting Party in writing and these Terms will terminate immediately on service of such notice.

11. Cancelation of a transaction

You cannot cancel a currency exchange once we've received your request to execute it.

12. Use of data

1. The Company does not request any information that is unnecessary for the use of the Services or to comply with obligations under applicable law.

2. You understand that by using our Services you consent to the collection, use and disclosure of your personally identifiable information and aggregate data as set forth in our Privacy Policy.

3. You acknowledge that we may process personal data in relation to you and personal data that you have provided or in the future provide to us, in connection with these terms or our Services.

4. Accordingly, you represent and warrant that:

1. Your disclosure to us of any personal data relating to individuals other than yourself was or will be made in accordance with all applicable data protection and privacy laws, and you ensure that the personal data is accurate, up to date and relevant when disclosed;
2. You have read and understood our Privacy Policy which may be amended from time to time and is an integral part of these Terms.

5. In order to use our Services, you must register for an account. When you open an account, we may ask you for contact information such as, but not limited to, name, phone number, and email address. We may require information on your occupation and also obtain information from you to help verify your identity and assess risk. We may engage third parties in order to assist in different aspects of the provision of our Services. We may need to review your eligibility to use the Services according to our own verification procedures.

6. Personal data will not be used for any purpose other than the ones for which it was initially collected unless prior and express consent is given.

7. For your convenience and to avoid duplicate requests, you agree that the information and documentation you submit as part of our due diligence process shall and will be shared with Capital Financial Services S.A., the company responsible for issuing and managing your card.

8. When you provide us with your personal data, the information will be protected through the appropriate internet communications security protocols and stored in a safe server with restricted access.

9. You can exercise your rights (right to be informed, access, rectification, erasure, restriction, object, portability) by contacting us through email compliance@cifralfabeto.com, notwithstanding the right to lodge a complaint with the competent Supervisory Authority (in Portugal – “Comissão Nacional de Proteção de Dados” -  www.cnpd.pt).

13. Cookies and tracking technologies

1. Cookies are small information files that help you identify your browser and can store information, such as user settings and preferences.

2. Except for any cookies strictly necessary for the performance of the app, the storage of other cookies will always depend on the User’s acceptance, and this consent may be withdrawn at any time through specific app tools.

3. As stated by our Privacy Policy, we use cookies and similar tracking technologies to track the activity on our Service and to customise our Services and content; measure promotional effectiveness and promote safety. They enable the app and other services to remember your actions and preferences over a period of time, so you will not have to re-enter them every time you access any of the services. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. Enabling these cookies will improve your experience using our app and other services to work, as it will provide you with a better browsing experience. You can delete or control these cookies; however, this will impair some of the features of our services.

4. Cookies on our App are used for different purposes, but in general, their use can be divided into the following categories:

Strictly Necessary Cookies: These are essential for the provision of the website and for all requested services, but do not perform any additional or secondary functions;

Analytical/Performance Cookies: These cookies provide statistical information about the use of the website, i.e. web analytics.

Targeting/Marketing Cookies: These cookies are used to create profiles or personalise content.

5. If you wish to know more about how we manage our Cookies, please read our Privacy Policy.

14. Severability

Each provision of these Terms is distinct and independent from the others. If any provision of these Terms is held to be illegal, invalid or unenforceable under applicable law, the remaining provisions shall remain valid and shall apply in full with the appropriate deletion or modification of such provision.

15. Accuracy

1. The Company does not make any representations or warranties that access to the services or any of the materials contained therein will be continuous, uninterrupted, timely, or error-free.

2. In an effort to continue to provide the Contracting Party with as complete and accurate information as possible, information may, to the extent permitted by applicable law, be changed or updated from time to time without notice, including, but without limitation, information regarding the Company's policies, products and services.

3. The Contracting Party shall verify all information before relying on it, and all decisions based on information contained on the App are the Contracting Party's sole responsibility and the Company shall have no liability for such decisions.

4. The Contracting Party expressly acknowledges and agrees that the use of the Company Services is at the Contracting Party’s sole risk. The Platform is provided on an “as is” and “as available” basis without any representation or warranty, whether express, implied or statutory. 

5. The Contracting Party acknowledges and agrees that the Company is not responsible for any aspect of the information, content, or services contained in any third-party materials or on any third-party websites accessible or linked to the Company Services.

16. Intellectual Property Rights

1. The Company retains full intellectual property rights, namely, industrial rights, copyright or neighbouring rights over the Company, including without limitation, patents, copyrights, trademarks, trade names, service marks, trade secrets, software, images, any and all information including documentation, procedures and its updates or developments or derivations, that is provided, disclosed or transmitted to the Contracting Party in connection with the access, execution and use of the Services and other intellectual property rights and any goodwill associated are the exclusive property of the Company and its licensors. 

2. Any use of the Company Services made by the Contracting Party for purposes other than those authorised herein, in particular, copies, total or partial, shall cause the Contracting Party to be liable to the Company, civil and/or criminal, as applicable, and the Contracting Party shall be obliged to indemnify the Company for all damages caused.  

3. All intellectual property rights in and to, the Services, or any part thereof, and any material and documents associated with them shall remain with the Company. To the extent that the Contracting Party acquires any intellectual property rights in the Services or any material or documents associated with it, the Contracting Party shall assign or procure the assignment of such intellectual property rights with full title guarantee (including by way of present assignment of future intellectual property rights) to the Company. The Contracting Party shall execute all such documents and do such things as the Company may consider necessary to give effect to this clause.

4. Except as expressly provided in these Terms, no part of the Company Services and no content may be copied, modified, adapted, reproduced, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted or distributed in any way to any other computer, server, website or another medium for publication or distribution or any commercial enterprise, without the Company‘s express prior consent. This also means that users may not edit or create works from such materials or content or in any way exploit the material or content of the Company Services. 

5. Information on the Company’s Services purposely made available by the Company for downloading may be used, provided that: 

1. any proprietary notice language in all copies of such documents will not be removed;
2. it is only for informational purposes and such information will not be copied or posted on any networked computer or broadcast in any media;
3. no modifications will be made to any such information;
4. no additional representations or warranties relating to such documents will be made.       
5. The Contracting Party shall pay full compensation to the Company for any violation of the Company’s copyrights or neighbouring rights.

17. Confidentiality

1. Each Party agrees that it may use the other Party’s Confidential Information only in the exercise of its rights and performance of its obligations under these Terms. Each Party acknowledges that it shall not disclose the other Party’s Confidential Information including all know-how, trade secrets, financial, commercial, technical, tactical or strategic information of any kind except in accordance with this clause.

2. Each Party may disclose the other Party’s Confidential Information to those of its employees, officers, advisers, agents or representatives who need to know the other Party’s confidential information in order to exercise the disclosing Party’s rights or perform its obligations under these Terms provided that the disclosing Party shall ensure that each of its employees, officers, advisers, agents or representatives to whom Confidential Information is disclosed is aware of its confidential nature and complies with this clause as if it were a Party and the Parties guarantee that each of its employees, officers, advisers, agents or representatives are under a non-disclosure agreement.

3. Each Party may disclose any Confidential Information required by law, any court, any governmental, regulatory or supervisory authority or any other authority of competent jurisdiction.

4. Each Party shall indemnify the other from and against any losses, damages, liability, costs (including legal fees) and expenses which the other Party may incur or suffer as a result of or arising from any breach of the obligations under this clause.

18. Waiver

1. No failure, delay or omission by either party in exercising any right, power or remedy provided by law or under these Terms shall operate as a waiver of that right, power or remedy, nor shall it preclude or restrict any future exercise of that or any other right or remedy.

2. No single or partial exercise of any right, power or remedy provided by law or under this Agreement shall prevent any future exercise of it or the exercise of any other right, power or remedy.

19. Language

1. These Terms and any information or notifications, unless otherwise specified should be in English or Portuguese.

2. In the event of any inconsistency, the English language version of these Terms or other documents shall prevail.

3. Any translation of these Terms or other documents is provided for your convenience only.

20. Governing Law

1. These Terms will be governed by and interpreted in accordance with the Portuguese legislation.

2. All disputes arising out of or in connection with this Agreement, including disputes on its conclusion, binding effect, amendment and termination, shall be resolved by the ordinary courts in Portugal.

21. Amendments or Updates

1. The Company may update or change these Terms by publishing the amended Terms on the App.

2. The updates or changes shall be effective at the time of publication. If you continue to use the Services after we provide notice of such changes, your continued use constitutes acceptance of the amended Terms and an agreement to be bound by them.

22. Communication

1. Except in specific cases requiring a particular form of communication, any written communication between parties shall be sent by one party to the other through the App or via email. 

2. This will be our primary means of addressing fraud, theft as well as matters pertaining to the maintenance of your account and profile details. It is also how we will tell you if there is a security threat to your account or whether we require further information pursuant to our KYC procedures. Make sure you regularly check the App and your email for this information.

3. The Company is expressly authorised to register the messages and orders that we may receive from the users, maintaining the correspondent support for the minimum necessary period of time for compliance purposes.

4. The Company may not be held liable for damages resulting from the use of email or any other communication system.

5. If the Contracting Party has any questions relating to these Terms and/or User’s use of the services, or any other matter, please contact compliance@cifralfabeto.com.