Friendium Export Control & Sanctions Policy
This Export Control & Sanctions Policy governs access to and use of the Friendium platform in compliance with international trade laws, export control regulations, and economic sanctions programs administered by governments worldwide.
1. Purpose & Legal Framework
Nexa-Group operates Friendium as a global digital service. As such, Friendium is subject to export control, trade compliance, and sanctions laws including, but not limited to, regulations administered by:
- U.S. Department of Commerce (EAR)
- U.S. Department of Treasury (OFAC)
- European Union restrictive measures
- United Nations sanctions regimes
- Applicable national export and trade laws
2. Restricted Jurisdictions
Friendium may be restricted or unavailable in certain countries, regions, or territories subject to comprehensive sanctions or trade embargoes. Access from or on behalf of sanctioned jurisdictions may be blocked.
3. Prohibited Users & Entities
You may not use Friendium if you are:
- Listed on sanctions or denied-party lists
- Owned or controlled by sanctioned entities
- Acting on behalf of restricted governments or organizations
- Engaged in prohibited end uses
4. Prohibited End Uses
Friendium may not be used for activities that violate export or sanctions laws, including but not limited to:
- Military, intelligence, or surveillance use where restricted
- Weapons development or proliferation
- Terrorist financing or coordination
- Cyber operations that violate international law
5. Technology & Software Controls
Friendium’s software, APIs, encryption, and technical features may be subject to export controls. Unauthorized export, re-export, or transfer is strictly prohibited.
6. User Responsibilities
Users are responsible for ensuring that their use of Friendium complies with all applicable export control and sanctions laws. This includes verifying the legality of access from their location.
7. Screening & Monitoring
Nexa-Group reserves the right to conduct sanctions screening, geolocation checks, and risk assessments to ensure compliance. Accounts may be restricted, suspended, or terminated as necessary.
8. Government Requests & Compliance
Friendium cooperates with lawful government requests related to export control and sanctions enforcement, subject to applicable privacy and due-process requirements.
9. No Circumvention
Users may not attempt to bypass geographic, technical, or legal restrictions, including the use of VPNs, proxies, or false information.
10. Reporting Violations
Suspected violations of export or sanctions laws should be reported to:
compliance@friendium.com
11. Enforcement Actions
Violations may result in account suspension, termination, reporting to authorities, and civil or criminal penalties under applicable law.
12. Limitation of Liability
Nexa-Group disclaims liability for user violations of export or sanctions laws to the maximum extent permitted by law.
13. Policy Updates
This policy may be updated to reflect changes in law or enforcement practices. Continued use of Friendium constitutes acceptance of updates.
14. Contact Information
Compliance Office: compliance@friendium.com
Legal Department: legal@friendium.com
