Legal and platform information

Standard Terms and Conditions

Terms for the Carbon Trader website, marketplace, broker desk, managed escrow, accounts, organisations, wallets, evidence packs, API services and settlement workflows.

Effective date: 30 May 2026. These are the current published terms for Carbon Trader® website and platform use.

Part 1 - Standard Terms and Conditions

1. Who we are

1.1 Carbon Trader is operated by Trend Enterprises Limited (NZBN: 9429048521130) t/a Carbon Trader®.

1.2 Carbon Trader’s Financial Service Provider registration number is FSP1008496. References to Carbon Trader, we, us or our mean Trend Enterprises Limited trading as Carbon Trader, including its officers, employees, contractors, agents, administrators, platform operators and related service providers where the context requires.

1.3 Carbon Trader provides a technology-enabled carbon market platform and broker-led services for New Zealand Units, voluntary carbon credits, international carbon credits, marketplace listings, RFQs, price discovery, evidence packs, claim reviews, Enterprise API services, data services, digital wallet records, transaction administration and Carbon Trader-managed escrow settlement.

1.4 Carbon Trader is not a government agency, regulator, registry, NZETR operator, tax adviser, legal adviser, auditor, forestry consultant or environmental certification body. Carbon Trader may provide market administration, brokerage, data, settlement coordination and evidence services, but clients must obtain their own legal, tax, accounting, forestry, financial, environmental, audit and regulatory advice where required.

1.5 Carbon Trader maintains public liability insurance up to NZD $100,000, based on the information supplied by Carbon Trader. That insurance is not a guarantee of performance, client money protection, credit protection, transaction settlement, cyber loss cover, registry loss cover or indemnity for all user losses. The precise policy terms, exclusions and cover limits are controlled by the insurance policy.

2. Acceptance of these Terms

2.1 These Terms apply when any person or organisation accesses the website, creates an account, uses the platform, lists credits, requests quotes, submits an enquiry, uses the broker desk, participates in a transaction, uses a digital wallet record, receives market data, uses an API key, submits KYC material, gives us a mandate or otherwise uses Carbon Trader services.

2.2 A user accepts these Terms by:

  • accessing or using the website or platform;
  • creating or using an account;
  • clicking an acceptance checkbox;
  • submitting a seller mandate, buyer request, RFQ, listing, order, bid or trade request;
  • giving us authority to market, source, settle or administer carbon credits;
  • using our Enterprise API or market data service;
  • signing a sale confirmation, mandate, contract note or subscription form; or
  • continuing to use the services after these Terms are updated.

2.3 If there is a conflict between these Standard Terms and a signed sale confirmation, escrow instruction, seller mandate, buyer mandate, subscription agreement, API agreement or other special terms, the more specific signed or transaction-specific document prevails for that transaction.

3. Definitions

In these Terms:

Account means a Carbon Trader account, including a personal user account, organisation account, admin-created account, buyer account, seller account, supplier account, API account or enterprise account.

Administrator means a Carbon Trader staff member or authorised operator with administrative access to the platform.

AML/CFT Law means the Anti-Money Laundering and Countering Financing of Terrorism Act 2009, regulations, codes of practice, guidance, sanctions rules and related laws or regulatory expectations that apply to Carbon Trader from time to time.

Buyer means a person or organisation seeking to buy, reserve, transfer, retire or otherwise acquire carbon credits or NZUs through Carbon Trader.

Carbon Credit means a unit, credit, allowance, certificate, offset, removal, reduction or other environmental market instrument, including NZUs, VCUs, VERs, Plan Vivo Certificates, ACCUs, CORSIA-eligible units, Article 6-authorised units, voluntary credits, nature credits, biodiversity credits, registry-issued credits and other instruments accepted by Carbon Trader.

Carbon Trader-managed escrow means Carbon Trader’s preferred managed settlement pathway under which buyer funds are paid into Carbon Trader’s designated escrow / client settlement account and NZUs or other credits are transferred in accordance with the agreed sale confirmation and settlement instructions.

Client Settlement Account means any bank account used by Carbon Trader for receiving, holding, applying or distributing settlement funds for transactions, whether described as escrow, client settlement, trust, client money, clearing or another equivalent term.

Credit Lot means a parcel of credits recorded on the platform as available, reserved, under mandate, under review, listed, traded, transferred, retired, cancelled or otherwise administered.

Digital Wallet means the Carbon Trader ledger, dashboard, wallet display or custody record that records user holdings, reservations, entitlements, transfers, settlement statuses, evidence, invoices or transaction balances. A Digital Wallet is not a bank account and does not necessarily mean Carbon Trader holds the underlying assets unless expressly stated.

Evidence Pack means documentation generated or compiled by Carbon Trader to evidence a transaction, retirement, cancellation, transfer, claim basis, project, credit lot, listing, quality review, settlement or completion event.

Listing means a public, private, verified-only, invited-only, POA, RFQ-only, fixed-price or negotiated listing of credits or related assets on Carbon Trader.

NZETR means the New Zealand Emissions Trading Register.

NZU means a New Zealand Unit issued or held under the New Zealand Emissions Trading Scheme.

RFQ means request for quote or request for quotation.

Seller means a person or organisation seeking to sell, list, market, transfer, retire, cancel or otherwise dispose of credits through Carbon Trader.

Services means all Carbon Trader products and services, including the website, platform, public marketplace, broker desk, RFQs, listings, managed sales, escrow, settlements, digital wallets, APIs, data services, evidence packs, claim assessments, onboarding, KYC, supplier verification and support.

User means any visitor, account holder, buyer, seller, supplier, broker, adviser, administrator, API client, enterprise client or other person accessing the Services.

4. Services provided by Carbon Trader

4.1 Carbon Trader may provide some or all of the following services:

  • public carbon credit marketplace;
  • private buyer and seller RFQs;
  • NZU brokerage and managed sales;
  • non-NZU voluntary credit sourcing;
  • international credit brokerage;
  • trade corridor facilitation;
  • buyer and seller onboarding;
  • supplier and project verification workflows;
  • KYC, KYB, AML/CFT, sanctions and PEP checks;
  • seller mandates and buyer mandates;
  • price discovery and quote comparison;
  • Carbon Trader-managed escrow;
  • NZETR transfer coordination;
  • registry transfer, retirement and cancellation support;
  • digital wallet / ledger records;
  • portfolio and custody statements;
  • evidence packs and completion statements;
  • claim suitability reviews and environmental claim support;
  • Carbon Trader Quality Score or similar scoring tools;
  • market data subscriptions;
  • Enterprise API access, API keys and webhooks;
  • fee estimation and fee schedule administration;
  • support, education, reports and account management.

4.2 Carbon Trader may add, remove, suspend, restrict or modify Services at any time. Some Services may be available only to verified users, approved organisations, enterprise customers, eligible jurisdictions, specific credit types or transaction participants who meet our due diligence requirements.

4.3 Carbon Trader may refuse, delay, suspend or cancel a Service if required for AML/CFT, sanctions, fraud, regulatory, security, operational, dispute, legal, tax, market integrity, claim-risk, financial crime or reputational reasons.

5. No automatic advice relationship

5.1 Unless we expressly agree in writing, Carbon Trader does not provide personalised financial advice, investment advice, tax advice, legal advice, forestry advice, climate reporting advice, audit assurance, environmental certification or guarantee of credit quality.

5.2 Market indications, price estimates, quote comparisons, quality scores, claim reviews, marketplace data, API data, portfolio dashboards and evidence packs are provided to assist decision-making, but they do not remove the need for a client to obtain professional advice.

5.3 Users remain responsible for deciding whether to buy, sell, hold, transfer, retire, cancel or claim any credit. Carbon Trader does not guarantee any future NZU price, credit value, liquidity, buyer demand, regulatory treatment, tax treatment, accounting treatment, climate claim or legal outcome.

6. Eligibility, registration and account use

6.1 To use account-based Services, a user must:

  • be at least 18 years old if acting as an individual;
  • have authority to act for any organisation they represent;
  • provide accurate and current information;
  • complete required KYC/KYB and onboarding checks;
  • comply with these Terms and all applicable laws;
  • keep login credentials secure;
  • use the platform only for lawful business purposes.

6.2 Carbon Trader may create different account types, including guest users, traders, buyers, sellers, suppliers, advisers, admins, brokers, enterprise users, developers and read-only users.

6.3 Organisation account owners are responsible for all actions taken by authorised users, team members, invited advisers, API users and administrators linked to their organisation account.

6.4 Carbon Trader may require multi-factor authentication, password resets, account re-verification, device checks, session controls, admin approval or other security measures.

6.5 Users must notify Carbon Trader immediately if they suspect unauthorised access, compromised credentials, incorrect authority, compromised API keys, fraudulent activity or data loss.

7. Authentication, Cognito, SSO and access controls

7.1 Carbon Trader may use Amazon Cognito, Google login, Apple login or other identity providers to authenticate users.

7.2 A user is responsible for the security of their email account, SSO provider account, device, browser session, password, MFA method and recovery credentials.

7.3 Carbon Trader may rely on authentication tokens, group claims, role claims, organisation permissions, API scopes, user roles, administrator actions and audit logs when determining user access.

7.4 Carbon Trader may suspend access if it believes a token, role, group, account or session is compromised, stale, wrongly assigned or being misused.

8. Authority to act

8.1 A user representing a company, trust, partnership, incorporated society, government body, forestry manager, adviser, accountant, agent, project developer, registry account holder or other organisation warrants that they have authority to act.

8.2 Carbon Trader may require written authority, board resolutions, director approvals, NZBN evidence, beneficial ownership information, forest manager authority, adviser authority, registry authority, settlement authority or other confirmation before acting.

8.3 Carbon Trader is not required to proceed until authority is satisfactory. If authority is later disputed, Carbon Trader may pause, reverse, cancel or suspend any related transaction to the extent possible and lawful.

9. KYC, KYB, AML/CFT, sanctions and financial crime controls

9.1 Carbon Trader may conduct customer due diligence, enhanced due diligence, identity verification, liveness checks, document verification, source-of-funds checks, source-of-wealth checks, source-of-credit checks, beneficial ownership checks, sanctions screening, politically exposed person screening, adverse media checks, fraud checks, transaction monitoring and ongoing account monitoring.

9.2 Carbon Trader may use Sumsub or other third-party providers to assist with KYC/KYB, identity verification, biometric/liveness checks, sanctions screening and document verification.

9.3 A user must provide information requested by Carbon Trader for compliance, risk, onboarding, audit, transaction settlement, regulatory reporting, complaints, fraud prevention or dispute handling.

9.4 Carbon Trader may refuse to onboard, verify, list, settle, transfer, release funds, release credits, provide API access, continue a relationship or complete a transaction if:

  • requested information is not supplied;
  • information appears inaccurate, incomplete or inconsistent;
  • identity, ownership, control or authority cannot be verified;
  • a sanctions, PEP, adverse media or risk concern arises;
  • source of funds, source of wealth or source of credits is unclear;
  • the transaction appears suspicious, unusual, high risk or inconsistent with declared activity;
  • a regulatory, banking, registry or law-enforcement concern arises;
  • Carbon Trader is legally prevented from explaining the reason.

9.5 Carbon Trader may make suspicious activity reports or other reports to regulators or law enforcement where required or permitted. Carbon Trader may be legally prevented from telling a user that a report has been made.

9.6 Carbon Trader may retain AML/CFT and transaction records for the periods required by law or for longer where necessary for legal, tax, audit, dispute or compliance reasons.

10. Marketplace listings

10.1 A listing may be public, private, verified-only, invited-only, admin-only, fixed-price, POA, RFQ-only, indicative, forward-looking, staged, reserved, partly filled, suspended or withdrawn.

10.2 Unless expressly stated, a listing is not an unconditional offer capable of immediate acceptance. Listings are subject to seller acceptance, buyer verification, settlement terms, availability, registry transfer capability, Carbon Trader approval and these Terms.

10.3 Public listings must include the disclaimer or equivalent wording:

Subject to seller acceptance, buyer verification, and settlement terms.

10.4 Carbon Trader may edit, suspend, hide, withdraw or reject a listing if it is inaccurate, incomplete, misleading, stale, unverifiable, inconsistent with policy, high risk, unsupported by evidence or harmful to market integrity.

10.5 Listing information may include project data, quantity, vintage, standard, registry, project ID, methodology, country, price, fee model, use-case label, claim suitability, risk flags, evidence status and settlement notes. Carbon Trader does not guarantee that all listing information is complete, current or independently verified unless expressly stated.

11. Seller obligations

11.1 A seller warrants that:

  • it owns or controls the credits it lists or mandates;
  • it has authority to sell or transfer the credits;
  • the credits are not subject to undisclosed security interests, liens, encumbrances, prior sale commitments, restrictions, disputes or claims;
  • all information supplied to Carbon Trader is true, accurate and not misleading;
  • it will promptly disclose changes in ownership, quantity, availability, restrictions, registry status, authority, GST status, bank account or settlement information;
  • it will not list the same units elsewhere without disclosing that fact to Carbon Trader;
  • it will cooperate with KYC, AML/CFT, settlement and evidence requirements;
  • it will not make unsupported claims about credits, projects or environmental benefits.

11.2 A seller must not double-sell, double-count, double-list, misdescribe or misrepresent any credit.

11.3 Carbon Trader may require evidence such as registry statements, screenshots, account confirmations, issuance records, retirement records, project documents, verification reports, audit reports, ownership declarations, authority forms, tax details and bank verification.

12. Buyer obligations

12.1 A buyer warrants that:

  • it has authority to buy the credits;
  • it has sufficient funds and ability to settle;
  • it has completed required onboarding and KYC/KYB;
  • it has or can obtain any required registry account;
  • it will not rely on unsupported environmental claims;
  • it understands the difference between compliance units, voluntary credits, contribution claims, offset claims, retirement claims and nature/biodiversity claims;
  • it will make its own legal, tax, accounting, climate reporting and public-claim decisions.

12.2 A buyer must pay funds in accordance with the sale confirmation and settlement instructions. Failure to pay on time may result in cancellation, suspension, liability for costs, loss of allocation, account restriction or other remedies.

13. RFQs, brokered trades and price discovery

13.1 Carbon Trader may run RFQs, private price-discovery processes, public POA listings, buyer outreach, seller mandates and brokered quote comparisons.

13.2 A buyer indication may be indicative or firm. A buyer expression of interest is not binding unless Carbon Trader confirms that the buyer has accepted binding terms and any required sale confirmation is complete.

13.3 A seller instruction is not binding unless the seller approves the buyer, quantity, price, fees, settlement timing, escrow process, NZETR details and sale confirmation in writing.

13.4 Carbon Trader may present quotes, bids or options based on price, quantity, timing, buyer status, conditions, execution certainty, settlement risk, net seller proceeds and transaction risk.

13.5 Carbon Trader may reject the highest headline price if another option appears safer, more executable, cleaner or more consistent with the seller’s instructions. The seller makes the final sale decision unless a signed mandate provides otherwise.

14. NZU managed sale and annual sale programme

14.1 A managed NZU sale may be structured as a full parcel sale, staged sale, public POA/RFQ listing, private buyer outreach, annual managed sale programme or a combination approved by the seller.

14.2 Core onboarding and verification may be completed once, then refreshed for later tranches or annual sale windows if the original information remains current.

14.3 Transaction fees apply at transaction level. Unless agreed otherwise, each completed sale or tranche is a separate transaction for fee purposes.

14.4 A standing annual mandate may authorise Carbon Trader to monitor sale windows, refresh available NZU balances, conduct buyer engagement, prepare recommendations and manage settlement for future years. No particular annual sale is binding unless the seller gives final written approval under the mandate or sale confirmation.

14.5 The seller generally retains NZUs in its own NZETR account until a particular sale is approved and the agreed settlement pathway is activated. Carbon Trader does not require NZETR login credentials or RealMe credentials.

15. Carbon Trader-managed escrow and settlement

15.1 Carbon Trader-managed escrow is Carbon Trader’s standard settlement pathway for brokered NZU transactions unless expressly agreed otherwise.

15.2 Under Carbon Trader-managed escrow:

  1. the buyer and seller approve the sale confirmation, including quantity, price, fees, settlement timing, NZETR details and conditions;
  2. the buyer pays purchase funds into Carbon Trader’s designated escrow / client settlement account;
  3. once cleared funds and settlement conditions are confirmed, Carbon Trader instructs the seller or authorised NZETR representative to transfer the agreed NZUs in accordance with the settlement instructions;
  4. the NZUs are transferred through the NZETR to Carbon Trader’s NZETR account or as specified in the sale confirmation;
  5. Carbon Trader verifies the NZU transfer evidence and quantity;
  6. Carbon Trader completes onward transfer of NZUs to the buyer’s NZETR account, where applicable, and releases net sale proceeds to the seller in accordance with agreed settlement instructions;
  7. Carbon Trader deducts or invoices agreed fees and pass-through costs in accordance with the sale confirmation and these Terms;
  8. Carbon Trader issues a completion statement and records the transaction evidence.

15.3 Carbon Trader does not require the seller’s NZETR login credentials or RealMe credentials. The seller, forest manager or authorised NZETR user remains responsible for initiating transfers from the seller’s own NZETR account when instructed.

15.4 If a buyer fails to settle on time, the seller is not required to transfer NZUs, and the transaction may be cancelled, extended, paused or referred back for seller instruction.

15.5 If a seller fails to transfer NZUs after cleared buyer funds have been received, Carbon Trader will not release purchase funds to the seller. The transaction may be paused, cancelled, extended, reversed where possible, or managed under the sale confirmation and settlement terms.

15.6 Carbon Trader may withhold release of funds or credits where required by law, banking rules, AML/CFT checks, sanctions screening, court order, regulator request, dispute, suspected fraud, cyber incident, registry issue, payment issue or other settlement risk.

15.7 Unless expressly stated, funds in a client settlement account do not earn interest for the user. Any treatment of bank interest, fees or charges will be governed by the sale confirmation, these Terms and applicable law.

15.8 Carbon Trader is not a bank. Funds held for settlement are held for transaction completion, not as deposit accounts or savings products.

16. Digital wallet, custody and ledger records

16.1 Carbon Trader may display Digital Wallet records, transaction statuses, pending balances, reserved quantities, custody statements, settlement balances, credit holdings, transfers, evidence packs and historical activity.

16.2 A Digital Wallet is a platform ledger and dashboard record. It is not a bank account, stored value facility, crypto wallet, deposit product, managed investment product or guarantee of immediately withdrawable funds or credits.

16.3 Carbon Trader may hold NZUs, credits or funds as part of managed escrow, settlement, custody, retirement, transfer or other agreed services. Where Carbon Trader holds assets, it will do so in accordance with applicable law, the relevant registry rules, banking rules, these Terms, internal controls and transaction-specific terms.

16.4 Carbon Trader may correct wallet, ledger, dashboard or reporting errors at any time. If a displayed balance is inconsistent with registry evidence, bank records, transaction records or administrator review, the underlying evidence prevails.

16.5 Users must not attempt to exploit, rely on or trade on any displayed error.

17. Transfer, retirement, cancellation and evidence

17.1 Carbon Trader may support transfers, retirements, cancellations or evidence packs for NZUs and other accepted credits.

17.2 Retirement and cancellation are generally irreversible. A user must check all details before instructing Carbon Trader to retire or cancel credits.

17.3 Carbon Trader may require written instructions before any retirement, cancellation or transfer.

17.4 Evidence packs may include registry records, project details, standard, vintage, quantity, retirement/cancellation proof, transaction records, fees, invoices, claim assessment and completion documents.

17.5 Carbon Trader does not guarantee that an evidence pack will satisfy every auditor, customer, regulator, certification body, climate-reporting framework or public-claim requirement.

18. Non-NZU and international credits

18.1 Non-NZU credits may include Verra VCUs, Gold Standard VERs, Plan Vivo Certificates, ACCUs, CORSIA-eligible units, Article 6-authorised units, emerging New Zealand voluntary credits, nature credits, biodiversity credits and other instruments accepted by Carbon Trader.

18.2 Not all credits are suitable for all purposes. A credit may be unsuitable for NZ ETS compliance, voluntary offsetting, carbon neutral claims, net zero claims, contribution claims, aviation compliance, international reporting, local claims or public marketing.

18.3 International credits may involve additional risks, including host country accounting, corresponding adjustment status, double counting, registry rules, methodology risk, project risk, reversal risk, vintage risk, sanctions risk, foreign law, tax, FX, transfer restrictions, quality controversy, social licence, permanence and reputational risk.

18.4 Carbon Trader may apply use-case labels, risk flags and claim suitability categories. These are tools to assist users; they are not legal, tax, audit or certification advice.

19. Environmental claims and greenwashing controls

19.1 Users must not make environmental, climate, offset, carbon neutral, net zero, contribution, biodiversity, nature positive or sustainability claims that are false, misleading, exaggerated, unclear, unsupported or inconsistent with the relevant credit.

19.2 Carbon Trader may require public claims to identify project, standard, registry, vintage, quantity, retirement/cancellation status, claim basis and any limitations.

19.3 Carbon Trader may refuse or qualify claim wording, evidence packs or public listings where Carbon Trader considers the claim to be unsupported, too broad, high-risk or inconsistent with the credit type.

19.4 Carbon Trader may recommend safer wording such as contribution claims or funding verified climate action where offset, carbon neutral or net zero claims are not adequately supported.

19.5 Users remain responsible for their own public claims, marketing, sustainability reports and climate disclosures.

20. Fees, GST and payment

20.1 Fees are set out in the Fee Schedule, platform display, quote, mandate, sale confirmation, invoice, subscription order or API agreement.

20.2 Unless stated otherwise, fees are exclusive of GST. The Carbon Trader® fee schedule forms part of the published platform fee information.

20.3 For standard brokered NZU sales, the current default fees are:

  • brokered sale success fee: 0.65% of gross sale value;
  • minimum brokered sale fee: NZD $350 per completed sale or tranche;
  • fee cap: NZD $12,500 per completed sale or tranche;
  • managed settlement fee: NZD $450 per completed sale or tranche where Carbon Trader manages settlement;
  • external or pass-through costs: at cost where applicable and agreed;
  • GST: additional where applicable.

20.4 The minimum fee and fee cap apply at transaction level. If the full holding is sold in one completed transaction, there is one brokered success fee, one applicable minimum / cap and one managed settlement fee. If a holding is sold across separate sale windows or settlement events, each completed tranche is generally treated as a separate transaction for fee purposes.

20.5 Where multiple partial fills are approved by the seller at the same time and settled together as one coordinated transaction, Carbon Trader may agree in advance to treat those fills as one transaction for fee purposes.

20.6 Carbon Trader may deduct fees from settlement proceeds, invoice them separately, charge them to the buyer, charge them to the seller, or allocate them as stated in the transaction documents.

20.7 Carbon Trader may update fees by publishing an updated fee schedule or providing notice. Fees already agreed for a signed transaction are not changed unless the parties agree or the transaction changes.

21. Third-party services

21.1 Carbon Trader uses third-party services and may disclose information to them where necessary. These may include:

  • Amazon Web Services and Amazon Cognito;
  • Sumsub or equivalent KYC/KYB provider;
  • Stripe or other payment provider;
  • Mailgun or email delivery provider;
  • Klaviyo or marketing automation provider;
  • Kudosity or SMS provider;
  • Google reCAPTCHA, Google Tag Manager or analytics tools;
  • Google and Apple sign-in providers;
  • banks, registries, settlement providers and payment networks;
  • credit registries and standards bodies;
  • legal, accounting, audit, AML/CFT, compliance, insurance and support advisers;
  • market data providers and API integration partners.

21.2 Carbon Trader is not responsible for third-party outages, terms, policy changes, delays, security incidents, registry failures, payment failures, identity provider issues or service interruptions except to the extent required by law or expressly stated in a signed agreement.

21.3 Users must comply with third-party terms where they use those services as part of Carbon Trader.

22. Enterprise API, data and webhooks

22.1 Enterprise API users must keep API keys, webhook secrets, OAuth credentials and access tokens confidential.

22.2 API access is subject to scopes, rate limits, authentication, IP controls, usage limits, subscription status, data entitlements, audit logging and security controls.

22.3 API users must not scrape, resell, redistribute, reverse engineer, benchmark publicly, attack, overload, bypass limits, create derivative datasets outside the licence or use API data for unlawful purposes.

22.4 Market data may be delayed, indicative, incomplete, corrected or derived from multiple sources. Carbon Trader does not guarantee uninterrupted or error-free market data.

22.5 Webhook delivery is not guaranteed. API users must implement retries, idempotency checks, signature verification, replay protection and their own reconciliation.

23. Intellectual property and user content

23.1 Carbon Trader owns or licenses all platform software, designs, workflows, data structures, templates, reports, dashboards, API documentation, quality scoring methods, evidence-pack formats, logos, trade marks and content except user-provided content.

23.2 Users retain ownership of content they provide, but grant Carbon Trader a licence to use, store, reproduce, process, display, verify, disclose and transmit that content for the purpose of providing the Services, complying with law and maintaining records.

23.3 Users must not upload content that infringes rights, is confidential without authority, is misleading, unlawful, malicious, defamatory, abusive or harmful.

24. Acceptable use

24.1 Users must not:

  • use the Services unlawfully or fraudulently;
  • misrepresent identity, authority, ownership, credit quality or registry status;
  • double sell, double count or falsely claim credits;
  • interfere with platform security;
  • attempt unauthorised access;
  • upload malware or harmful content;
  • scrape or harvest data without permission;
  • manipulate markets or prices;
  • submit false KYC, bank, registry, project or listing information;
  • use Carbon Trader to evade sanctions, AML/CFT controls or law enforcement;
  • make unsupported environmental claims.

25. Privacy and data protection

25.1 Personal information is handled under the Carbon Trader Privacy Policy.

25.2 Users consent to Carbon Trader collecting, using, storing, disclosing and retaining information as described in the Privacy Policy and as required to provide the Services.

25.3 Users must ensure that any personal information they provide about other people is provided with lawful authority and that those people receive any required privacy notice.

26. Confidentiality

26.1 Private mandates, buyer identities, seller identities, bids, quotes, settlement details, financial information, KYC material, price-discovery results, registry records, bank details and commercial terms are confidential unless disclosed for a permitted purpose.

26.2 Carbon Trader may disclose confidential information where needed for KYC, AML/CFT, settlement, registries, banks, buyers, sellers, advisers, administrators, dispute resolution, law enforcement, regulators, auditors, insurers or legal compliance.

27. Security, outages and incidents

27.1 Carbon Trader will use reasonable technical, organisational and operational controls to secure the platform.

27.2 Carbon Trader does not guarantee that the platform will be uninterrupted, error-free, immune from cyber incident or free of third-party outage.

27.3 Users must maintain their own security controls, including MFA, device security, staff access control, password management, browser security and API key management.

27.4 Carbon Trader may suspend services during security incidents, suspected fraud, attacks, outages, maintenance or recovery.

28. Complaints and disputes

28.1 Users should first contact Carbon Trader at info@carbontrader.nz.

28.2 Carbon Trader will acknowledge complaints and seek to resolve them in good faith.

28.3 Where a complaint relates to a financial service and an approved dispute resolution scheme applies, the user may refer the complaint to the approved dispute resolution scheme recorded against Carbon Trader’s FSPR registration from time to time.

28.4 Nothing in these Terms prevents a person from contacting a regulator, the Privacy Commissioner, the Commerce Commission, an AML/CFT supervisor, the FSPR, a court or another authority where legally entitled to do so.

29. Liability

29.1 To the maximum extent permitted by law, Carbon Trader is not liable for indirect, consequential, special, punitive or exemplary loss; loss of profit; loss of opportunity; loss of goodwill; loss of data; loss caused by registry error; market movement; tax treatment; claim rejection; third-party failure; user error; unauthorised user action; or reliance on indicative information.

29.2 To the maximum extent permitted by law, Carbon Trader’s total liability for any claim connected with a transaction is limited to the fees paid to Carbon Trader for that transaction, except where law does not permit limitation.

29.3 For platform, subscription, API or data services, Carbon Trader’s total liability is limited to the fees paid by the user for the affected service in the three months before the claim, except where law does not permit limitation.

29.4 Nothing in these Terms excludes liability for fraud, wilful misconduct or liability that cannot be excluded under New Zealand law.

29.5 Users indemnify Carbon Trader for losses arising from their breach of these Terms, unlawful conduct, false information, lack of authority, misleading listing, unsupported claim, double sale, settlement default, misuse of the Services, breach of third-party rights or breach of law.

30. Suspension and termination

30.1 Carbon Trader may suspend or terminate access immediately where there is a compliance, security, fraud, AML/CFT, sanctions, credit, settlement, legal, regulatory, user misconduct, non-payment or platform integrity concern.

30.2 Users may close their account after completing all pending obligations, unless Carbon Trader is required to retain records or keep the account open for legal, audit, dispute or settlement purposes.

30.3 Termination does not affect accrued rights, payment obligations, confidentiality, liability, indemnities, intellectual property, record retention, audit rights, dispute clauses or completed transaction documents.

31. Changes to these Terms

31.1 Carbon Trader may update these Terms by publishing a new version on the website or notifying users through the platform.

31.2 Changes take effect from the date stated. Continued use after the effective date means acceptance.

31.3 Material changes to existing signed transactions do not apply retrospectively unless the transaction documents allow it or the parties agree.

32. Governing law

32.1 These Terms are governed by New Zealand law.

32.2 Subject to any applicable dispute resolution scheme, the courts of New Zealand have non-exclusive jurisdiction.