Brighty App General Terms and Conditions

These General Terms and Conditions (the “Terms”), together with any product-specific terms, fee schedules, privacy notices and other documents expressly incorporated by reference, form a legally binding agreement between the client (“Client”, “you” or “your”) and BTY Digital AG (“BTY”, “we”, “us” or “our”), a Swiss stock corporation with registered office at Mühlegasse 18, 6340 Baar, Switzerland, Swiss UID CHE-352.538.716.

BTY is a member of VQF, a self-regulatory organisation recognised by FINMA under the Swiss Anti-Money Laundering Act (AMLA), membership no. 100917, and is classified by VQF as a Virtual Asset Service Provider (VASP).

These Terms apply to both individual clients acting for private purposes (“Personal Clients”) and business, corporate and institutional clients (“Business Clients”), subject to the eligibility and product requirements applicable to the relevant Service. Certain Services may be available only to Business Clients or only to Personal Clients.

By applying for, accessing or using any BTY Service, you confirm that you have read and understood these Terms and agree to be bound by them. If you do not agree, you must not use the Services.

1. Definitions

Account: means a BTY account or access profile made available to the Client after successful onboarding and acceptance by BTY.

App / Platform: means the Brighty-branded web or mobile interface, API or other technical interface through which BTY Services may be accessed.

Business Client: means a legal entity, partnership or other eligible organisation that has separately applied to BTY, completed BTY onboarding and been accepted by BTY.

Business Day: means a day other than Saturday, Sunday or a public holiday in the Canton of Zug, Switzerland.

Client: means a Personal Client or Business Client.

Crypto Account: means a custodial account or wallet arrangement through which a Client may hold, receive and transfer supported Crypto Assets. A Crypto Account may comprise a Segregated Crypto Account and, where applicable, an Omnibus Crypto Account.

Crypto Asset: means a digital asset or token supported by BTY from time to time.

Fiat Payment Account: means an individual or omnibus account arrangement made available in connection with BTY’s fiat payment services, including accounts or virtual account identifiers provided through regulated Partners.

Fiat Services: means fiat payment accounts, transfers, settlement, currency conversion or card-related functionality provided by BTY directly or through Partners.

Omnibus Crypto Account: means a blockchain wallet or other crypto-asset account used for operational settlement in which Client assets attributable to multiple Clients may be pooled, while each Client’s entitlement is separately recorded in BTY’s internal ledger and the assets are not commingled with BTY’s proprietary assets.

Omnibus Fiat Payment Account: means a settlement account maintained with a relevant Partner into which Client funds may be swept for settlement or operational processing, with individual Client entitlements recorded separately in BTY’s internal ledger.

Partner: means a third-party bank, payment institution, electronic money institution, card issuer, custodian, liquidity provider, execution venue, technology provider or other service provider used in connection with the Services.

Personal Client: means a natural person who has applied for BTY Services in their own capacity and has completed BTY’s onboarding and acceptance process.

Payment Cards: means payment cards made available through third-party card programme providers for eligible Clients and subject to separate card programme and cardholder terms.

Segregated Crypto Account: means an individual blockchain address or wallet allocated to a particular Client for the receipt and holding of Crypto Assets, which is not pooled with the Crypto Assets of other Clients.

Segregated Fiat Payment Account: means an individual fiat account or virtual account identifier allocated to a Client by a relevant Partner.

Services: means the services made available by BTY from time to time, which may include Crypto Accounts, Fiat Payment Accounts, Transfers, Currency Conversion, Payment Cards and OTC execution.

Supported Asset: means a fiat currency or Crypto Asset supported by BTY or the relevant Partner at the relevant time.

Transfer: means a fiat or crypto payment, payout or transfer executed on a Client’s instruction through the Platform or API.

2. BTY and the Contractual Relationship

2.1 BTY is the contracting entity for Services provided under these Terms. The Brighty brand, Platform and related technology may be provided, licensed or operated with the support of affiliated entities or service providers, but such support does not change the identity of the contracting party unless expressly stated otherwise.

2.2 A customer of Wireflexion, Brighty Digital UAB, Brighty SIA or any other group or affiliated entity does not automatically become a customer of BTY. Each Client must separately apply to BTY, complete BTY’s applicable onboarding process and be independently accepted by BTY before a BTY customer relationship is established.

2.3 BTY performs its own AML/CFT, sanctions, beneficial ownership, customer-risk and acceptance assessment. BTY may use affiliates, auxiliary persons or technical service providers to support information collection, verification and operational processing, but BTY retains responsibility for its customer acceptance decision.

2.4 BTY’s membership of VQF relates to its obligations under Swiss AMLA and applicable self-regulatory requirements. It does not constitute a representation that BTY is a bank, payment institution or prudentially supervised deposit-taking institution.

2.5 The nature and availability of a particular Service may differ depending on whether the Client is a Personal Client or Business Client and on the relevant jurisdiction, product, Partner arrangement, risk assessment and applicable legal requirements.

3. Scope of Services

3.1 Subject to product availability, jurisdictional restrictions, Client eligibility and applicable Partner terms, BTY may make available:

(a) Crypto Accounts for holding, receiving and transferring supported Crypto Assets;

(b) Fiat Payment Accounts provided directly or through regulated Partners;

(c) fiat and crypto Transfers;

(d) Currency Conversion, including crypto-to-fiat, fiat-to-crypto, crypto-to-crypto and supported fiat-to-fiat conversion;

(e) Payment Cards provided through third-party card programme providers; and

(f) OTC execution for eligible Clients and larger conversion transactions.

3.2 The Services may be used for personal, business or operational purposes, depending on the Client type and the particular Service.

3.3 BTY does not provide investment management, discretionary portfolio management, credit, overdrafts or investment advice under these Terms.

3.4 BTY does not currently offer staking, lending, yield-bearing vaults or other products under which Client assets are invested, lent, staked or otherwise deployed to generate a return. If such a product is introduced in the future, it will be subject to separate terms and applicable regulatory review.

3.5 Some Services depend on Partners, blockchain networks, market infrastructure or other third parties. Availability may therefore vary by country, currency, asset, Client type, Client risk profile or technical capability.

4. Crypto Accounts

4.1 BTY offers multi-chain Crypto Accounts through which Clients may hold, receive and transfer supported Crypto Assets.

4.2 For receipt of Crypto Assets, Clients may receive individually allocated blockchain addresses or wallets. BTY currently uses third-party infrastructure providers, including DFNS and other relevant wallet or custody infrastructure providers, for the provision and operation of such infrastructure.

4.3 The receiving addresses allocated to a Client are Segregated Crypto Accounts. They are individual blockchain addresses allocated to the relevant Client and are not pooled with Crypto Assets attributable to other Clients. Assets credited to such addresses remain attributable to the relevant Client and may be used by that Client in accordance with these Terms and the applicable Service.

4.4 BTY holds custody of the relevant Crypto Accounts, including the private keys or other cryptographic credentials required to control the relevant wallets, subject to the applicable custody arrangement.

4.5 For operational settlement, Crypto Assets may be swept from a Client’s Segregated Crypto Account into an Omnibus Crypto Account. Crypto Assets held in an Omnibus Crypto Account may be pooled with Crypto Assets attributable to other Clients. They are not, however, commingled with Crypto Assets belonging to BTY itself.

4.6 BTY maintains each Client’s individual entitlement and balance separately in its internal ledger and reconciles the aggregate Client assets held through the relevant infrastructure against the aggregate Client liabilities recorded in its internal ledger.

4.7 Crypto Assets held in an Omnibus Crypto Account may be transferred to relevant third-party providers for execution or settlement of connected BTY Services, including liquidity providers for Currency Conversion and card providers for Payment Card settlement.

4.8 Following completion of the relevant transaction or settlement, the corresponding Crypto Assets may be returned to the Omnibus Crypto Account and subsequently transferred back to the relevant Client’s Segregated Crypto Account.

4.9 Client balances in Segregated Crypto Accounts may be held for an indefinite period. Crypto Assets held in an Omnibus Crypto Account are held for the relevant transfer, execution or settlement purpose and are therefore held only for the period necessary for that purpose, subject to applicable law and any applicable statutory limits.

4.10 No interest or other remuneration is paid on Crypto Accounts. Client Crypto Assets are not invested, staked, lent or deployed in DeFi protocols. Client Crypto Assets are not used to fund BTY’s proprietary liquidity or proprietary activities and are not pledged or otherwise encumbered.

4.11 Where applicable and subject to satisfaction of all statutory conditions, BTY may rely on exemptions under Swiss banking law in relation to Client funds held in an Omnibus Crypto Account, including the settlement-account exemption and/or the sandbox regime. The application of any such exemption depends on the specific structure and purpose for which the relevant funds are held.

5. Fiat Payment Accounts

5.1 BTY may offer Fiat Payment Accounts under white-label or other arrangements with third-party banking and payment providers.

5.2 Clients may be onboarded to the relevant Partner and may receive individual virtual accounts, IBANs or other account identifiers allocated to them by that Partner (the “Segregated Fiat Payment Account”).

5.3 BTY provides the Client-facing interface and related operational services connected to the relevant Partner’s infrastructure. The relevant Partner may be the legal account provider and the Client’s account counterparty.

5.4 The identity of the legal account provider or account holder, the safeguarding arrangement and the insolvency treatment of Client funds are governed by the applicable Partner agreement and terms and may differ between Partners.

5.5 BTY may also maintain Omnibus Fiat Payment Accounts with relevant Partners into which Client funds may be swept for settlement and operational processing. Individual Client entitlements are recorded separately in BTY’s internal ledger.

5.6 Funds held in a Segregated Fiat Payment Account are held by the relevant Partner and are not held by BTY.

5.7 Where BTY holds or processes Client funds through an Omnibus Fiat Payment Account, BTY may rely on an applicable Swiss banking-law exemption where all statutory conditions are satisfied.

6. Transfers

6.1 BTY may execute fiat and crypto Transfers, including payments and payouts, on the Client’s instruction through the Platform or API.

6.2 Fiat Transfers may be processed through banking and payment rails, including SEPA and SWIFT. Crypto Transfers are processed on the relevant blockchain network.

6.3 For each Transfer, the payer or beneficiary is a counterparty to the relevant transaction only. BTY’s permanent contractual relationship is with the Client.

6.4 Transfers are executed solely against balances already available and recorded for the relevant Client. BTY does not pre-fund Client transactions and does not provide overdrafts, advances or other forms of credit in connection with Transfers.

6.5 The system permits a Transfer only where sufficient cleared Client funds are available to cover the transaction and applicable fees.

6.6 Actual processing times depend on the applicable provider and payment rail, including SEPA and SWIFT processing times and cut-off times, blockchain confirmation times and any AML, sanctions or compliance checks that may be required.

7. Currency Conversion

7.1 BTY may provide execution-only Currency Conversion services, including crypto-to-fiat, fiat-to-crypto, crypto-to-crypto and fiat-to-fiat conversions, on the Client’s instruction and against the Client’s available and cleared balance.

7.2 BTY does not finance or advance funds for a Currency Conversion.

7.3 Except where a conversion is automatically executed as part of a Payment Card transaction under the applicable card terms, the Client is shown the applicable rate before execution and must accept it before the conversion is completed.

7.4 A Currency Conversion may be a standalone transaction or form part of another BTY Service. For example, a EUR payment funded from a crypto balance may require a crypto-to-EUR conversion as part of the payment flow.

7.5 Each Client conversion may be executed on a matched, back-to-back basis with a third-party liquidity or execution provider. BTY does not take a proprietary directional position in connection with Client conversions and does not conduct proprietary investment trading through such transactions.

7.6 Any applicable spread or fee is disclosed or otherwise made available to the Client in connection with the relevant transaction.

8. Payment Cards

8.1 Where available, Payment Cards are provided through third-party providers for eligible Clients’ personal, business and operational expenses.

8.2 BTY does not issue the Payment Cards. The card programme may be provided through third parties, including Monavate as BIN sponsor and programme partner, Marqeta as card-processing infrastructure provider and AllPay as physical card production and personalisation provider.

8.3 The regulated issuer identified in the applicable cardholder terms is the legal issuer of the Payment Cards.

8.4 The party contracting with the Client and cardholder, and the allocation of safeguarding, AML, complaints, chargeback and operational responsibilities, are governed by the applicable card-programme agreements and cardholder terms.

8.5 Payment Cards are not credit products. They do not provide an overdraft or deferred-payment facility and may be used only against available funds in a linked Crypto Account or Fiat Payment Account.

8.6 Where required to complete a card transaction, Currency Conversion may be performed automatically in accordance with the applicable card terms.

9. Account-Structure Exemptions

9.1 BTY may operate omnibus account structures without holding a Swiss banking or FinTech licence where an applicable statutory exemption applies and all conditions of that exemption are satisfied.

9.2 The availability of an exemption depends on the nature of the relevant funds, the purpose for which they are held, the duration of the holding, applicable thresholds and all other requirements under Swiss law.

9.3 Settlement-account exemption. Where applicable, Client funds may be held for the purpose of executing or settling a Client transaction. Subject to the statutory conditions, the funds may be held for a maximum period of 60 days from receipt before being returned to the Client or forwarded for settlement of the relevant transaction. FINMA confirms the 60-day settlement framework under Article 5 para. 3 let. c of the Banking Ordinance.

9.4 BTY will use the settlement-account exemption only where the relevant Client funds and BTY’s activities satisfy the applicable statutory requirements. The existence of an omnibus account does not by itself establish that the exemption applies.

9.5 Sandbox regime. Where applicable, BTY may accept public deposits up to the statutory CHF 1 million threshold without a banking licence, subject to the conditions of the sandbox regime. FINMA states that the sandbox is not subject to FINMA supervision and that the relevant deposits are not covered by the Swiss deposit protection scheme.

9.6 Where BTY relies on the sandbox regime, the Client will be informed before depositing funds that BTY is not supervised by FINMA in respect of the sandbox activity and that the relevant funds are not covered by deposit protection. BTY will also comply with the applicable CHF 1 million threshold and other statutory requirements.

9.7 BTY will not represent that an exemption applies where its specific activity or account structure does not satisfy the applicable legal requirements. In particular, the settlement-account exemption may not be available to crypto-asset activities where the relevant activity is comparable to forex exchange trading, as noted by FINMA.

10. Eligibility, Onboarding and Ongoing Due Diligence

10.1 Personal Clients and Business Clients must satisfy BTY’s applicable eligibility requirements.

10.2 Personal Clients must provide complete, accurate and current information concerning their identity, address, tax residence, source of funds and wealth where applicable, expected transaction activity and any other information reasonably requested by BTY.

10.3 Business Clients must provide complete, accurate and current information concerning their legal existence, ownership and control, authorised representatives, business activities, source of funds and wealth where applicable, expected transaction activity and any other information reasonably requested by BTY.

10.4 BTY may verify information through registries, screening tools, identity-verification providers, document checks, sanctions and PEP screening, adverse-media checks and other lawful verification methods.

10.5 BTY may classify Clients according to risk and may require enhanced due diligence, additional approvals, additional supporting evidence, transaction limits or other conditions before or during the relationship.

10.6 Clients must promptly notify BTY of any material change to information previously provided.

10.7 BTY may conduct periodic or event-driven reviews and may suspend or restrict Services while information, documents or clarifications remain outstanding.

11. AML/CFT, Sanctions, Fraud and Travel Rule

11.1 BTY is subject to Swiss AML/CFT obligations and VQF requirements. Clients must cooperate fully with BTY’s compliance requests and must not use the Services for money laundering, terrorist financing, fraud, sanctions evasion, prohibited activity or any unlawful purpose.

11.2 BTY may monitor transactions and may delay, reject, restrict, freeze or suspend activity where required or permitted by applicable law, regulation, sanctions obligations, court order, Partner requirement or BTY’s risk controls.

11.3 Where Travel Rule obligations apply, BTY may collect, verify, retain and transmit originator, beneficiary, wallet, account and counterparty information to another VASP, financial institution, service provider or competent authority as required by law.

11.4 BTY may require proof of control over external wallets and may refuse Transfers involving unsupported assets, prohibited or high-risk wallets, sanctioned persons, prohibited jurisdictions or other risk factors outside BTY’s risk appetite.

12. Your Account and Security

12.1 You must maintain secure credentials, devices, API keys, authentication factors and internal access controls. You are responsible for instructions submitted through authorised credentials unless you notify BTY of suspected compromise without undue delay.

12.2 Business Clients must ensure that only duly authorised representatives use the Account and that appropriate internal approval and segregation-of-duty arrangements are maintained.

12.3 BTY may impose technical or security controls, including multi-factor authentication, transaction limits, withdrawal whitelists, approval workflows or temporary holds.

13. Fees, Pricing and Deductions

13.1 Fees, spreads, commissions, account charges, minimum fees and other pricing may be agreed individually, disclosed on the Platform, set out in a fee schedule or communicated by BTY before the relevant Service is used.

13.2 BTY may amend fees prospectively on reasonable notice where practicable.

13.3 You authorise BTY to deduct properly due fees, charges, taxes, network fees, Partner charges and other amounts payable under these Terms from balances held or processed in connection with the Services, where legally and operationally permitted.

13.4 BTY may charge an administrative account closure fee where a Client’s Account is terminated due to a material breach of these Terms, the provision of materially false or misleading information or documentation, fraudulent activity, or other substantiated compliance-related grounds attributable to the Client. The fee is intended to recover reasonable administrative, operational and compliance-related costs associated with reviewing, processing and closing the Account. BTY may deduct the applicable and properly due fee from the Client’s available Account balance, subject to applicable law. Any remaining Client assets shall be returned or otherwise handled in accordance with applicable legal and regulatory requirements.

14. Third-Party and Partner Services

14.1 Certain Services depend on Partners and external infrastructure. Separate Partner terms may apply and, where required, you may need to enter into a direct agreement with the relevant Partner.

14.2 BTY is not responsible for the independent legal obligations of a Partner acting in its own regulated capacity. However, BTY remains responsible for obligations expressly undertaken by BTY under these Terms.

14.3 BTY may change, replace, suspend or discontinue a Partner or Partner-dependent feature where reasonably necessary for operational, commercial, legal, regulatory, security or risk-management reasons.

15. Service Availability and Changes

15.1 BTY will use commercially reasonable efforts to make the Platform and Services available but does not guarantee uninterrupted or error-free operation.

15.2 Services may be delayed, restricted or unavailable because of maintenance, blockchain congestion, liquidity conditions, Partner outages, payment-rail interruptions, cyber incidents, legal or regulatory changes or other matters outside BTY’s reasonable control.

15.3 BTY may add, modify, restrict, suspend or discontinue any Supported Asset, feature or Service, subject to applicable law and any applicable notice requirements.

16. Client Instructions and Transaction Finality

16.1 You are responsible for ensuring that every instruction submitted to BTY is accurate, complete and authorised.

16.2 BTY may refuse or delay an instruction where information is incomplete, compliance checks are outstanding, available balances are insufficient, a Partner rejects the instruction, market execution is unavailable or BTY reasonably believes the instruction may be unlawful, fraudulent or inconsistent with these Terms.

16.3 Blockchain transactions are generally irreversible once confirmed. Payment transactions may also become irrevocable under applicable Partner or payment-system rules.

16.4 BTY is not obliged to recover funds sent pursuant to incorrect instructions, although it may provide reasonable assistance where practicable.

17. Suspension, Restriction and Termination

17.1 A Client may request closure of its BTY relationship at any time, subject to completion of outstanding transactions, settlement of fees, regulatory requirements, Partner procedures and transfer of remaining balances to an acceptable destination account or wallet.

17.2 BTY may restrict, suspend or terminate all or part of the Services where reasonably required for legal, regulatory, AML/CFT, sanctions, fraud, security, operational, risk-management or Partner-related reasons, or where the Client materially breaches these Terms.

17.3 Where permitted by law, BTY will provide reasonable notice of termination. Immediate action may be taken where advance notice is prohibited, impracticable or could prejudice an investigation, asset-freezing requirement, security response or other legal obligation.

17.4 Termination does not affect accrued rights, fees, payment obligations, compliance obligations, confidentiality duties or record-retention requirements.

17.5 Upon termination or closure of an Account, BTY may deduct any outstanding fees, charges and other amounts validly payable by the Client under these Terms and Conditions, including the administrative termination fee as specified in Clause 13.4. Such deductions may be made from the Client’s available Account balance without requiring separate consent at the time of termination, to the extent permitted by applicable law. Following the deduction of applicable fees and settlement of outstanding obligations, any remaining balance shall be returned or otherwise handled in accordance with applicable legal and regulatory requirements.

18. Dormancy and Unclaimed Balances

18.1 BTY may designate an Account as dormant after a prolonged period of inactivity or where a Client relationship has been terminated but assets remain.

18.2 BTY may require updated due-diligence information before reactivating a dormant Account or releasing remaining assets.

18.3 Nothing in this Section authorises BTY to confiscate Client assets merely because compliance documents are outstanding. Any restriction, retention, transfer or deduction must have a contractual, legal or regulatory basis.

19. Data Protection and Confidentiality

19.1 BTY processes personal and business data in accordance with applicable Swiss data-protection law and, where applicable, the GDPR. Further information is provided in BTY’s Privacy Notice.

19.2 BTY may share information with affiliates, auxiliary persons, Partners, screening and technology providers, professional advisers and competent authorities where necessary for the Services, compliance, security, legal obligations or legitimate business purposes and where permitted by law.

19.3 BTY may retain AML/CFT and transaction records for at least the period required by applicable Swiss law.

20. Intellectual Property

20.1 All intellectual property rights in the Brighty brand, Platform, software, APIs, documentation, content, trademarks and related materials are owned by BTY, its affiliates or their licensors.

20.2 You receive only a limited, non-exclusive, non-transferable and revocable right to use the Platform and Services in accordance with these Terms.

20.3 You must not copy, reverse engineer, modify, distribute, resell, sublicense or commercially exploit the Platform except where expressly permitted in writing or by mandatory law.

21. No Investment, Legal or Tax Advice

21.1 BTY provides the Services on an execution and operational basis and does not provide investment, legal, tax or financial advice. Any market information, pricing information or educational content is provided for general information only.

21.2 You are responsible for determining whether a transaction or Service is appropriate and lawful for your circumstances and for obtaining independent professional advice where necessary.

22. Liability

22.1 To the fullest extent permitted by law, BTY shall not be liable for indirect, incidental, special, punitive or consequential losses, including loss of profit, revenue, anticipated savings or business opportunity.

22.2 BTY shall not be liable for losses caused solely by a Partner, blockchain network, payment system, market infrastructure provider or other third party outside BTY’s reasonable control, except to the extent BTY caused or materially contributed to the loss through its own breach, negligence or wilful misconduct.

22.3 Nothing in these Terms excludes or limits liability for fraud, wilful misconduct, gross negligence or any liability that cannot lawfully be excluded or limited.

22.4 The Client is responsible for direct losses suffered by BTY arising from the Client’s material breach of these Terms, unlawful use of the Services, fraud, wilful misconduct or provision of materially false or misleading information.

23. Force Majeure

23.1 Neither Party shall be liable for delay or failure caused by events beyond its reasonable control, including natural disasters, war, terrorism, civil unrest, strikes, cyber incidents, telecommunications failures, blockchain or network outages, market infrastructure disruption, regulatory action or governmental orders, provided the affected Party uses reasonable efforts to mitigate the impact.

24. Complaints and Support

24.1 For customer support or complaints, contact support@brighty.app.

24.2 BTY will handle complaints in accordance with its internal procedures and applicable law. Where a complaint concerns a Partner Service, BTY may refer or coordinate the complaint with the relevant Partner.

25. Amendments

25.1 BTY may amend these Terms where reasonably required by changes in law, regulation, VQF requirements, Partner arrangements, product functionality, security, risk management or commercial arrangements.

25.2 Material amendments will be notified in advance where reasonably practicable and required by law. Continued use of the affected Services after the effective date constitutes acceptance of the amended Terms unless explicit consent is required by law.

26. Governing Law and Jurisdiction

26.1 These Terms and any non-contractual obligations arising out of or in connection with them are governed by Swiss law.

26.2 The courts of the Canton of Zug, Switzerland, shall have exclusive jurisdiction, subject to any mandatory jurisdiction rule that cannot lawfully be excluded.

27. Miscellaneous

27.1 Assignment. You may not assign or transfer your rights or obligations under these Terms without BTY’s prior written consent. BTY may assign or transfer these Terms to an affiliate, successor or acquirer where legally permissible and without materially prejudicing your rights.

27.2 Severability. If any provision is invalid or unenforceable, it shall be modified or severed to the minimum extent necessary and the remaining provisions shall remain in force.

27.3 No Waiver. A failure or delay to exercise a right does not waive that right.

27.4 Entire Agreement. These Terms, together with applicable product-specific terms, pricing and documents incorporated by reference, constitute the agreement between you and BTY for the relevant Services.

27.5 Language. The English-language version of these Terms prevails unless BTY expressly designates another language version as controlling.