This Vestra Account Restrictions Policy ("Policy") outlines the circumstances under which user accounts on the Vestra platform may be restricted, the different tiers of restrictions, the escalation process, and the requirements for unbanning. This Policy is designed to ensure the integrity, security, and compliance of the Vestra fractional real estate investment system, protecting all users, including investors, property owners, and employees. It is imperative that all users understand and adhere to this Policy. This Policy is effective as of 2025-09-17.

1. Introduction and Purpose

Vestra is committed to providing a secure, transparent, and compliant environment for fractional real estate investments. To uphold these standards, it is necessary to implement strict measures against activities that compromise the platform's integrity, violate legal or regulatory requirements, or harm other users. This Policy details the grounds for account restrictions, the tiered system of enforcement, and the procedures for resolution. The primary purpose of this Policy is to deter misconduct, enforce our Terms of Service, and maintain a trustworthy ecosystem for all participants. This Policy applies to all users of the Vestra platform, including but not limited to investors, property owners, and Vestra employees. Any violation of this Policy will result in immediate and decisive action, potentially leading to account restrictions, permanent termination, and legal proceedings.

2. Grounds for Account Restrictions

Account restrictions may be imposed for, but are not limited to, the following reasons:

• Violation of Terms of Service: Any breach of the Vestra Terms of Service, including but not limited to misrepresentation, fraudulent activities, unauthorized access, or misuse of the platform. This encompasses violations related to property listings, investment terms, payment processes, and user conduct.
• Suspicious Activity: Any activity deemed suspicious by Vestra's security systems or compliance team, such as unusual login patterns, unauthorized transaction attempts, or attempts to circumvent security measures. This includes activities that suggest account compromise or malicious intent.
• Fraudulent Activities: Engaging in any form of fraud, including but not limited to identity theft, payment fraud, investment fraud, or attempts to manipulate investment outcomes. This also covers providing false information during KYC/KYB verification processes.
• Money Laundering and Terrorist Financing (AML/CTF) Concerns: Any activity that raises concerns regarding compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. Vestra is legally obligated to report suspicious transactions to relevant authorities.
• Non-Compliance with KYC/KYB Requirements: Failure to complete or maintain accurate Know Your Customer (KYC) or Know Your Business (KYB) verification processes as required by Vestra and applicable regulations. This includes providing incomplete, false, or misleading documentation.
• Abuse of Referral System: Any attempt to exploit or manipulate the multi-level referral system for unfair advantage, including creating fake accounts, engaging in self-referral schemes, or using deceptive marketing practices.
• Market Manipulation: Any actions intended to artificially influence the price or demand of fractional real estate shares on the platform, including but not limited to wash trading, spoofing, or spreading false information.
• Intellectual Property Infringement: Unauthorized use, reproduction, or distribution of Vestra's intellectual property or the intellectual property of other users or third parties.
• Harassment or Abusive Behavior: Engaging in any form of harassment, intimidation, or abusive behavior towards other users, Vestra employees, or third parties through the platform.
• Security Breaches: Any actions that compromise the security of the Vestra platform, other user accounts, or Vestra's systems, including but not limited to hacking attempts, distribution of malware, or phishing.
• Regulatory Non-Compliance: Any activity that violates local, national, or international laws and regulations pertaining to financial services, real estate, or online platforms.
• Employee Misconduct: For Vestra employees, any actions that violate internal company policies, ethical guidelines, or leverage their position for personal gain or to circumvent platform rules. This includes, but is not limited to, unauthorized access to user data, manipulation of system processes, or collusion with users to bypass restrictions or fees.
• Collusion for Fee Reduction: It has come to our attention that there has been recent activity where investors and employees have engaged in vetting processes to have account restrictions lifted at fees significantly lower than those stipulated in our official tiers and operational policies. This is a severe breach of trust and a direct violation of our internal controls and this Account Restrictions Policy. Henceforth, any confirmed instance of such collusion, whether by an investor attempting to bribe or an employee accepting such an offer or facilitating such a reduction, will be subject to immediate and severe legal action in the appropriate courts of law, in addition to permanent account termination for all involved parties. This behavior undermines the integrity of our fee structure and the fairness of our platform.

3. Restriction Tiers, Escalation, and Unbanning Requirements

Vestra employs a tiered system for account restrictions, designed to address violations proportionally while allowing for escalation in cases of repeated or severe misconduct. Each tier imposes increasing limitations on account functionality and requires specific actions for resolution. It is crucial to understand that all unbanning requirements, particularly the associated fees, must be paid via external payment methods (e.g., credit card, bank transfer) and cannot be settled using funds held within your Vestra wallet balance. This measure is in place to prevent the use of potentially illicit or restricted funds for unbanning purposes and to ensure a clear separation of operational and investment funds.

Tier 1: Temporary Access Suspension & Warning

• Description: This is the initial level of restriction, typically applied for minor violations or first-time offenses. The user's ability to initiate new investments or withdrawals may be temporarily suspended.
• Impact: Limited access to certain platform features, such as initiating new investments, selling shares, or making withdrawals. The user will receive a formal warning outlining the violation and the steps required for resolution.
• Unbanning Requirement:
  • Fee: $24.99 USD (must be paid via external payment method).
  • Action: Acknowledge receipt of the warning and provide a written assurance of future compliance. Depending on the violation, additional steps like updating KYC information may be required.
• Escalation: Failure to comply with unbanning requirements or a subsequent violation will lead to escalation to Tier 2.

Tier 2: Enhanced Restrictions & Mandatory Review

• Description: Applied for repeated minor violations, moderate first-time offenses, or failure to resolve a Tier 1 restriction.
• Impact: All investment and withdrawal functionalities are suspended. Access to portfolio viewing and historical data may remain. The account will undergo a mandatory internal review by Vestra's compliance team.
• Unbanning Requirement:
  • Fee: $54.99 USD (must be paid via external payment method).
  • Action: Successful completion of the internal review, which may involve providing additional documentation, participating in a compliance interview, or demonstrating a clear understanding of the violated policy. A detailed action plan for future compliance may be required.
• Escalation: Further violations or failure to meet unbanning requirements will result in escalation to Tier 3.

Tier 3: Severe Restrictions & Compliance Audit

• Description: Imposed for serious violations, multiple repeated offenses, or failure to resolve a Tier 2 restriction.
• Impact: All account functionalities are severely restricted, potentially limiting access to the platform entirely, except for communication with Vestra support. A comprehensive compliance audit of all account activities and associated transactions will be initiated.
• Unbanning Requirement:
  • Fee: $94.99 USD (must be paid via external payment method).
  • Action: Successful completion of the compliance audit, which may involve providing extensive documentation, undergoing a detailed financial review, and demonstrating a complete remediation of the violation. A formal, legally binding commitment to adhere to all Vestra policies and applicable regulations may be required.
• Escalation: Continued non-compliance or discovery of further severe violations during the audit will lead to escalation to Tier 4.

Tier 4: Near-Total Suspension & Legal Review Initiation

• Description: Reserved for very serious and persistent violations, including suspected fraud, significant regulatory breaches, or repeated failures to comply with lower-tier requirements.
• Impact: Near-total suspension of all account access and functionalities. Vestra's legal team will initiate a review to assess potential legal action. All pending transactions, including profit distributions, may be frozen.
• Unbanning Requirement:
  • Fee: $164.99 USD (must be paid via external payment method).
  • Action: Successful completion of the legal review, which will involve direct communication with Vestra's legal counsel. This may necessitate providing legal documentation, participating in formal interviews, and potentially agreeing to a settlement or restitution plan. Unbanning at this stage is at Vestra's sole discretion and is highly unlikely without significant mitigating circumstances and full cooperation.
• Escalation: Failure to satisfy the legal review or discovery of further egregious violations will lead to escalation to Tier 5.

Tier 5: Full Account Suspension & External Investigation

• Description: Applied for extremely severe violations, confirmed fraudulent activities, significant financial misconduct, or direct threats to the platform's security or reputation.
• Impact: Full and indefinite suspension of the account. Vestra will cooperate with relevant external regulatory bodies and law enforcement agencies to initiate investigations. All assets associated with the account may be frozen indefinitely.
• Unbanning Requirement:
  • Fee: To be reviewed and determined by Vestra's Executive Compliance Committee and Legal Department. This fee will be substantial and will reflect the severity of the violation and the resources expended by Vestra. It must be paid via external payment method.
  • Action: Unbanning at this tier is exceptionally rare and requires the successful resolution of all external investigations, full cooperation with authorities, and a unanimous decision by Vestra's Executive Compliance Committee and Legal Department. This may involve court orders, regulatory clearances, and a comprehensive, independently verified remediation plan.

Tier 6: Permanent Account Termination & Blacklisting

• Description: The most severe restriction, reserved for egregious, unresolvable violations, confirmed criminal activity, or repeated failures to comply with Tier 5 requirements.
• Impact: Permanent termination of the account. All associated data and assets (subject to legal and regulatory obligations) will be permanently removed from the platform. The user will be permanently blacklisted from creating any future accounts on Vestra. Vestra will pursue all available legal remedies and cooperate fully with law enforcement.
• Unbanning Requirement: Permanent termination. No unbanning is possible.

4. Specific User Sections and Considerations

4.1. Investor Section

• Responsibilities: Investors are responsible for understanding the risks associated with fractional real estate investments, conducting their own due diligence on property schemas, and ensuring the accuracy of their personal and financial information. They must adhere to all payment and withdrawal policies.
• Prohibited Activities:
  • Attempting to circumvent investment limits or restrictions.
  • Using stolen or unauthorized payment methods.
  • Engaging in market manipulation tactics to influence share prices.
  • Misrepresenting investment intentions or financial capacity.
  • Attempting to exploit platform vulnerabilities for personal gain.
  • Collusion with Vestra employees to reduce unbanning fees, which will result in immediate and permanent account termination and legal action.
• Consequences: Violations will lead to account restrictions as per the tiered system, potential forfeiture of investment profits, and legal action where applicable.

4.2. Property Owner Section

• Responsibilities: Property owners (or their authorized agents) are responsible for providing accurate, complete, and verifiable information about their properties. They must ensure all legal documentation, valuations, and ownership proofs are legitimate and up-to-date. They are also responsible for adhering to the terms of the property schema, including profit distribution schedules and property maintenance.
• Prohibited Activities:
  • Listing properties with fraudulent or misleading information.
  • Failing to disclose material facts about a property.
  • Attempting to sell shares in properties they do not legally own or have the authority to fractionalize.
  • Manipulating property valuations or profit projections.
  • Failing to honor profit distributions or other contractual obligations to investors.
  • Collusion with Vestra employees to reduce unbanning fees, which will result in immediate and permanent account termination and legal action.
• Consequences: Violations will lead to account restrictions, removal of property listings, forfeiture of listing fees, potential legal action by Vestra and affected investors, and reporting to relevant real estate and regulatory authorities.

4.3. Employee Section

• Responsibilities: Vestra employees are held to the highest standards of conduct, ethics, and compliance. They are responsible for upholding Vestra's policies, protecting user data, and acting in the best interest of the company and its users. Employees must not use their access or position for personal gain or to circumvent platform rules for themselves or others.
• Prohibited Activities:
  • Unauthorized access to user accounts or sensitive data.
  • Manipulation of system processes, investment outcomes, or profit distributions.
  • Accepting bribes or engaging in any form of corruption.
  • Disclosing confidential company or user information.
  • Facilitating or assisting users in violating Vestra's Terms of Service or this Policy.
  • Engaging in collusion with investors or property owners to reduce unbanning fees or bypass any other operational policies. This is considered a severe breach of trust and will result in immediate termination of employment, permanent blacklisting from Vestra, and aggressive legal prosecution.
• Consequences: Any violation by an employee will result in immediate disciplinary action, up to and including termination of employment, permanent blacklisting, and legal prosecution.

5. Policy on Previous Tiers and Future Violations

This Policy introduces a new, more stringent tiered restriction system. Therefore, all users who may have previously incurred restrictions under an older, less defined system have had their "tier level" reset to zero. This means that any future violation, regardless of past infractions, will initiate the restriction process starting from Tier 1.

However, it is critical to understand that this reset does not absolve users of past misconduct. If a user, whose tier was reset to zero, commits a new violation, their account will be subjected to the current tiered system. Furthermore, if any past, unresolved severe violations (e.g., confirmed fraud, money laundering) come to light, Vestra reserves the right to immediately apply a higher tier restriction, up to and including permanent termination, irrespective of the "tier reset."

Henceforth, if you violate any part of our Terms of Service, this Account Restrictions Policy, or any other Vestra policy, your restriction process will commence at Tier 1, and subsequent violations will lead to escalation through the tiers as outlined above. There will be no exceptions or preferential treatment.

6. Appeal Process

Users who believe their account has been restricted in error may submit an appeal to Vestra's Compliance Department within 7 calendar days of receiving the restriction notification. The appeal must include a detailed explanation of why the restriction is believed to be erroneous and any supporting documentation. Vestra will review the appeal and communicate its decision within a reasonable timeframe. The decision of Vestra's Compliance Department on appeals is final.

7. Data Retention and Privacy

In accordance with our Privacy Policy and applicable data protection laws, Vestra will retain data related to restricted accounts for compliance, legal, and security purposes, even after account termination. This is necessary to prevent repeat offenders and to cooperate with law enforcement and regulatory bodies.

8. Amendments to this Policy

Vestra reserves the right to modify, amend, or update this Account Restrictions Policy at any time without prior notice. Any changes will be effective immediately upon posting on the Platform. Your continued use of the Platform after any such changes constitutes your acceptance of the revised Policy. It is your responsibility to regularly review this Policy to stay informed of any updates.

9. Contact Information

For any questions regarding this Account Restrictions Policy or to report a violation, please contact Vestra's support team via live chat, email, or WhatsApp.