Terms of Service

"Account" means the account you register to access the Services, including any sub-accounts or linked devices associated with it.

"Available balance" means the portion of your custodied assets that is not pending confirmation and not locked against an in-progress withdrawal request, and which you may therefore request to withdraw or otherwise instruct us to act upon.

"Deposit address" means a blockchain address generated by our infrastructure and associated with your account for the purpose of receiving a specific supported digital asset on its specific supported network.

"Digital asset" means a digital representation of value that relies on cryptography and a distributed ledger or similar technology, including but not limited to the assets listed on our supported-assets page.

"Ledger" means the internal, append-only accounting record we maintain reflecting the custodial entitlements of all account holders, distinct from the public blockchain ledgers of the underlying networks.

"Locked balance" means custodied assets that have been set aside against a pending withdrawal request and are, while locked, not available for a further withdrawal request until the original request is completed or cancelled.

"Network" means the specific distributed ledger or blockchain protocol on which a given supported digital asset is issued and transferred (for example, the Bitcoin network for BTC).

"Pending balance" means a deposit that has been observed on the relevant network but has not yet accumulated the number of confirmations we treat as sufficient to credit it to your available balance.

"Private key" means the cryptographic secret that authorizes the movement of a digital asset from a given blockchain address; in the custodial model described in Section 7, private keys corresponding to custodied assets are held and controlled by us, not by you directly.

"Services" has the meaning given in Section 2 (Acceptance of these Terms).

"Step-up authentication" means an additional, session-scoped authentication challenge we may require before permitting a sensitive action such as a withdrawal.

"Withdrawal request" means an instruction you submit asking us to release a specified amount of a specified digital asset from your available balance to a destination address you specify.

Headings in these Terms are for convenience only and do not affect interpretation. The words "include," "includes," and "including" are deemed to be followed by the words "without limitation." References to "writing" or "written" include email unless otherwise specified.

These Terms of Service ("Terms") form a binding agreement between you ("you," "your," or "Client") and the operator of this platform ("we," "us," "our," or the "Company") governing your access to and use of the website, application programming interfaces, and custody services described on this site (collectively, the "Services"). By creating an account, clicking to accept these Terms, or otherwise accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by these Terms and by our Privacy Policy, which is incorporated into these Terms by reference.

If you do not agree to these Terms in their entirety, you must not access or use the Services. If you are accepting these Terms on behalf of a company, trust, fund, or other legal entity, you represent that you have the authority to bind that entity, and "you" in these Terms refers to that entity.

We may amend these Terms from time to time in accordance with Section 56 (Changes to these Terms). Your continued use of the Services after an amendment takes effect constitutes your acceptance of the amended Terms.

This glossary explains general industry terminology used elsewhere in these Terms in plain language. It is provided for your convenience and does not itself create any obligation; where a term is separately defined in Section 1, that definition controls for purposes of interpreting these Terms.

Blockchain: a distributed, cryptographically-linked ledger maintained by a network of independent computers ("nodes") rather than a single central operator, used to record transactions for a given digital asset in a way that is, in ordinary operation, extremely difficult to alter retroactively.

Public key / address: a string of characters, derived from a private key, that functions like an account number on a given network — it can be shared publicly and is what someone sends assets to.

Private key: a secret cryptographic value that proves ownership of, and authorizes spending from, a given address. Whoever controls a private key controls the assets at the corresponding address; this is why private-key security is the central concern of digital-asset custody.

Confirmation: the process by which a transaction, once broadcast to a network, is included in a block and then further validated by the addition of subsequent blocks on top of it. More confirmations generally means a lower probability that the transaction will later be reversed by a chain reorganization; different networks and different assets warrant different minimum confirmation counts before a deposit is treated as final.

Gas fee / network fee / miner fee: a fee paid to the network's validators or miners to include a transaction in a block, denominated in the network's native asset and set by market conditions (network congestion) rather than by us. This is distinct from any service fee we separately charge, as described in Section 12 (Fees).

Cold storage: keeping private keys on infrastructure that is not continuously connected to the internet, to reduce the risk of remote compromise, typically used for the majority of custodied assets not needed for day-to-day withdrawal processing.

Hot wallet: keeping private keys on infrastructure that is connected to the internet so that transactions can be signed and broadcast without manual intervention, typically used only for the smaller operational balance needed to service near-term withdrawals.

Hash: a fixed-length string produced by a one-way cryptographic function applied to data (such as a transaction); used throughout blockchain systems to uniquely and verifiably identify data without revealing or requiring the original data itself.

Custodial wallet: a wallet where a third party (here, the Company) controls the private keys on your behalf, as opposed to a non-custodial or "self-custody" wallet, where you alone control the private keys. The Services are custodial, as described in Section 7.

HD wallet (hierarchical deterministic wallet): a wallet architecture that derives a large number of distinct addresses from a single master secret in a deterministic, reproducible way, allowing a unique deposit address to be generated per client without requiring a separately-generated and separately-backed-up private key for each one.

Token standard: a technical specification (for example, an account-based native asset versus a smart-contract-issued token) governing how a given digital asset is represented and transferred on its network. Sending an asset using the wrong token standard or contract address for the receiving system can result in permanent loss, which is why Section 7 (Supported assets and networks) requires you to confirm the asset and network before transferring.

To use the Services you must be at least eighteen (18) years old, or the age of legal majority in your jurisdiction of residence if that age is higher, and have the legal capacity to enter into a binding contract. By registering for an account you represent and warrant that you meet these requirements.

The Services are not directed at, and may not be used by, persons or entities located in, incorporated in, or resident of any jurisdiction where their use would be contrary to local law or regulation, including but not limited to jurisdictions subject to comprehensive sanctions programs administered by the relevant competent authorities. You represent that you are not (a) a person or entity subject to sanctions, (b) named on any restricted-party or denied-persons list maintained by a competent government authority, or (c) acting on behalf of any such person or entity.

We reserve the right to refuse service, close, suspend, or limit access to an account, at our discretion, to any person or entity for any lawful reason, including but not limited to a failure to meet the eligibility criteria in this section, a determination made during identity verification, or a suspicion of activity that violates these Terms or applicable law.

To access most features of the Services, you must register for an account by providing an email address and a password meeting our minimum complexity requirements. You are responsible for maintaining the confidentiality of your login credentials and for all activity that occurs under your account, whether or not you authorized that activity, except to the extent such activity results from our failure to provide the security measures described in these Terms.

You agree to notify us immediately of any unauthorized use of your account or any other breach of security. We are not liable for any loss or damage arising from your failure to protect your account credentials or to notify us promptly of unauthorized use.

Sessions are tracked and can be reviewed and individually revoked from the account security centre. We may, at our discretion, require additional verification (a "step-up" authentication) before permitting certain sensitive actions, including withdrawals. You acknowledge that step-up authentication is a security measure for your benefit and agree not to attempt to circumvent it.

You may only register one account per person or entity unless we expressly authorize otherwise in writing. We reserve the right to consolidate, suspend, or close duplicate accounts.

Depending on your jurisdiction, the nature of your activity, and applicable law, we may require you to complete identity verification ("KYC," know-your-customer) procedures before you can deposit, withdraw, or otherwise use certain features of the Services. This may include providing government-issued identification, proof of address, source-of-funds documentation, and other information reasonably requested by our compliance function or by a third-party verification provider acting on our behalf.

You agree to provide accurate, current, and complete information during any verification process and to promptly update that information if it changes. Providing false, inaccurate, or misleading information is a material breach of these Terms and may result in immediate suspension or termination of your account.

We may conduct ongoing monitoring of account activity for the purposes of anti-money-laundering (AML) and counter-terrorist-financing (CTF) compliance, including screening against sanctions and politically-exposed-person (PEP) lists. Where required by applicable law, we may report suspicious activity to the relevant authorities without notice to you, and we may be legally prohibited from disclosing that a report has been made.

We may decline to process a deposit or withdrawal, or may place a hold on funds, pending the outcome of a compliance review. We will act on such reviews as promptly as reasonably practicable, but you acknowledge that compliance reviews may introduce delay beyond our direct control.

Source of funds and source of wealth: for larger deposits, or where our risk-based approach to compliance otherwise calls for it, we may ask you to explain and evidence where the digital assets you are depositing came from (source of funds) and, in some cases, the broader origin of your overall wealth (source of wealth). This is a standard control used across regulated financial services, not a judgment about you individually, and declining to provide requested information may result in a deposit being declined, reversed where technically possible, or an account being restricted pending resolution.

Politically exposed persons and enhanced due diligence: if you are, or are closely associated with, a person who holds or has held a prominent public position, we may be required to apply enhanced due diligence to your account, including more frequent review and senior sign-off before certain transactions proceed. This reflects a standard, globally-recognized compliance practice and is not a statement about your individual conduct.

Ongoing obligation to update information: your obligation to provide accurate information does not end at onboarding. You must promptly notify us of any material change to the information you provided during identity verification, including a change of legal name, a change in beneficial ownership (for an entity account), or a change that would affect your sanctions or PEP status.

Cooperation with law enforcement and regulators: we may be required by applicable law to respond to lawful requests for information from law-enforcement agencies, courts, and regulators, including requests relating to your account. Where legally permitted, we will apply the same standards to such requests as we do to any other disclosure of your information, as described in our Privacy Policy; where legally prohibited from notifying you (for example, under an anti-tipping-off provision tied to a suspicious-activity report), we will not do so.

The Services provide custodial infrastructure for supported digital assets. When you deposit a supported digital asset to an address generated for your account, that asset is recorded in an internal, append-only ledger reflecting your entitlement against the pooled custodial holdings we maintain. Your holdings are represented as a claim against the Company's custodial infrastructure, not as a segregated, individually-titled set of private keys assigned solely to you.

Deposits are recorded as pending until the underlying network has produced what we consider, in our reasonable discretion and by reference to common industry practice for the relevant network, a sufficient number of confirmations, after which the deposit is credited to your available balance. Confirmation thresholds differ by network and may be adjusted from time to time to reflect changes in network conditions or industry practice; the thresholds displayed within the product at the time of your deposit are informational and do not constitute a guarantee that a given threshold will remain unchanged in the future.

Withdrawal requests move your requested amount from your available balance into a locked state pending administrative review. We reserve the right to review any withdrawal request before it is released, for any reason including but not limited to fraud prevention, compliance screening, and operational risk management. A locked withdrawal request may be released (completed, resulting in an on-chain transfer to your specified destination) or cancelled (returning the locked amount to your available balance) following that review. We do not represent or warrant a specific turnaround time for withdrawal review, although we aim to process requests promptly.

We do not lend, stake, rehypothecate, or otherwise deploy client-custodied assets for our own account or for the account of any third party without your specific prior written authorization for that specific transaction. Custody, in the ordinary operation of the Services, is not a yield-generating activity.

You are solely responsible for entering the correct destination address, network, and amount for any withdrawal. Digital asset transfers are irreversible once broadcast to and confirmed by the relevant network. We are not liable for losses resulting from your error in specifying a destination address, an unsupported network, or an incompatible token standard, except where that error resulted from a defect in the Services themselves rather than user input.

Every deposit, withdrawal lock, withdrawal release, withdrawal cancellation, and administrative credit is recorded as an entry in our internal ledger using double-entry accounting: each entry that increases one balance is matched by an equal and opposite entry elsewhere in the ledger, so that the ledger as a whole always balances. This is an internal accounting control, described here so you understand the mechanism, not a representation that the ledger itself is independently audited unless separately stated on our Trust & Security page.

Your account's activity view reflects entries from this ledger in real time. Balances are shown in three states — available, pending, and locked — as defined in Section 1 (Definitions). A balance figure of zero is a real, confirmed answer (you currently hold none of that asset), not an error state or a loading placeholder, and is displayed as such throughout the product.

We may, at our sole discretion and acting reasonably, correct an entry in the ledger to fix a demonstrable error (for example, a duplicate credit caused by a technical fault), provided that any such correction is itself recorded as a new, transparent ledger entry rather than by silently altering a past record — consistent with the append-only nature of the ledger described in Section 1. We will make reasonable efforts to notify you if a correction materially affects your balance.

We support deposit and withdrawal of a specific, published list of digital assets on a specific, published list of networks, shown within the product. Each supported asset has exactly one supported network; sending an asset on an unsupported network, or sending an unsupported asset to a deposit address, may result in permanent, unrecoverable loss of that asset. We strongly encourage you to verify the network and asset before initiating any transfer, and we display prominent warnings to this effect within the deposit flow.

We may add or remove supported assets and networks at our discretion, with or without prior notice, in response to factors including but not limited to network security incidents, regulatory developments, liquidity conditions, or changes in our own operational capacity. If we remove support for an asset you hold, we will provide a reasonable mechanism and reasonable advance notice, where practicable, for you to withdraw that asset before support is fully discontinued.

Deposit addresses are derived per-client from infrastructure we control. You must not attempt to deposit assets other than the specific asset and network for which a given address was generated, and you must not share your deposit address publicly as a general-purpose payment address for purposes unrelated to your account, as doing so may complicate our ability to attribute incoming deposits correctly.

We maintain internal accounting records that track each client's entitlement against pooled custodial holdings separately from any assets we hold for our own corporate account. This internal segregation is designed so that, in the ordinary course of business, client entitlements can be distinguished from Company assets at any time by reference to our ledger.

Internal accounting segregation is not the same as legal or regulatory asset segregation, bankruptcy-remoteness, or trust status, which depend on the specific legal structure adopted by the operating entity and on the law of the relevant jurisdiction. [Operator to complete: describe the specific legal structure used to hold client assets — for example, an omnibus trust account, a bankruptcy-remote special-purpose entity, or another arrangement — and the jurisdiction whose law governs that structure.] Until that structure is disclosed here, you should not assume that client assets are legally protected from the Company's general creditors in an insolvency.

We do not commingle client assets with Company operating funds used to pay ordinary business expenses. Movements of pooled custodial holdings between our own wallets (for example, between hot and cold storage tiers) are made solely for security and operational purposes and do not change the underlying client entitlements recorded in the ledger.

We may use third-party infrastructure providers in connection with the Services, including blockchain node and indexing providers used to observe deposits and broadcast transactions, and may in the future engage a qualified sub-custodian to hold some or all client assets on our behalf. Where we do so, we remain responsible to you for the custody of your assets as described in these Terms, and we take reasonable steps to select providers with security and operational practices appropriate to the sensitivity of the function they perform.

We do not currently operate a public programmatic interface (API) for third-party applications to access your account; all account access is through the website and mobile-optimized web application described on this site. If that changes, additional terms specific to API access will be published and will apply to that access.

We maintain internal procedures intended to reduce single points of failure in the custody of client assets, including controls over how and by whom private-key material can be used to authorize a transaction. We do not publish the specific technical details of our key-management architecture, as doing so would itself create a security risk; general, non-sensitive descriptions of our security posture are published on our Trust & Security page.

In the event of a prolonged operational disruption, we will use reasonable efforts to communicate with account holders through the contact channels associated with their accounts and, where practicable, through a status update published on or linked from this site.

Use of certain features of the Services may be subject to fees, as described on our fee schedule page. We will make reasonable efforts to display applicable fees clearly before you confirm a transaction that incurs a fee. Network fees charged by the underlying blockchain (sometimes called "gas" or "miner" fees) are separate from, and in addition to, any fee we charge, and are outside our control; they fluctuate with network congestion and we do not guarantee any particular network fee amount.

We reserve the right to introduce new fees or to change existing fees at any time. Where required by applicable law, or as a matter of policy, we will provide advance notice of fee changes before they take effect for existing account holders. Fee changes do not apply retroactively to transactions that were already confirmed before the change took effect.

You are responsible for any taxes, duties, or similar governmental assessments arising from your use of the Services, including but not limited to taxes on gains realized from the disposition of digital assets. We do not provide tax advice, and nothing on this site should be construed as tax guidance specific to your circumstances.

A number of jurisdictions have adopted, or are adopting, "Travel Rule" requirements modeled on Financial Action Task Force (FATF) Recommendation 16, requiring virtual-asset service providers to collect and, where the transaction counterparty is another regulated provider, transmit certain originator and beneficiary information for transfers above a specified threshold. Where applicable to your withdrawal, we may require you to provide beneficiary name, receiving institution, and jurisdiction information before the transfer can proceed, as reflected in the withdrawal flow within the product.

You represent that any beneficiary information you provide in connection with a withdrawal is accurate and that you have any necessary authorization from the beneficiary to share that information with us and, where applicable, with the receiving institution. We may decline to process a withdrawal for which required Travel Rule information is missing, incomplete, or which we are unable to verify.

Every withdrawal request is held in a locked state pending review before it is released. This is a deliberate control, not a processing delay we are trying to minimize away — it exists to give us, and where relevant our compliance function, an opportunity to catch fraud, account-takeover, and error before a transfer becomes irreversible. We do not commit to a specific maximum review time, and review times may be longer for first-time withdrawals, unusually large withdrawals, or withdrawals flagged by our risk controls.

A withdrawal request may be released in full, or cancelled and returned to your available balance, following review. We will make reasonable efforts to notify you of the outcome. Where a withdrawal is cancelled, we will where reasonably practicable explain the general reason unless doing so would be inappropriate given the nature of the review (for example, where explaining the reason could itself compromise a fraud or compliance investigation).

[Operator to complete: describe any specific insurance coverage maintained in connection with custodied client assets, including the insurer, the type of coverage (for example, crime or specie coverage for cold-storage theft), the covered perils, any exclusions, and the aggregate policy limit.] Until specific coverage is disclosed here, you should not assume that any insurance protects your holdings, and you should treat the risk disclosures in Section 16 — including the absence of deposit insurance — as the operative statement of your position.

Digital assets are a novel and rapidly evolving asset class involving a high degree of risk. Before using the Services, you should carefully consider whether trading, holding, or transacting in digital assets is suitable for you in light of your financial condition. The following is a non-exhaustive summary of risks; it does not describe every risk associated with digital assets or with use of the Services.

Volatility risk: the market price of digital assets can be, and historically has been, extremely volatile. The value of assets held in your account can decline significantly and rapidly, including to zero, and you could lose some or all of the value of your holdings.

Irreversibility risk: transactions on most public blockchains are irreversible once confirmed. An error, whether yours or a counterparty's, in a destination address, network selection, or amount, can result in the permanent, unrecoverable loss of the transferred assets. We cannot reverse, cancel, or recover a confirmed on-chain transaction.

No deposit insurance: digital assets held through the Services are not deposits and are not insured by any government deposit insurance scheme (including, in the United States, the FDIC, and, more broadly, no equivalent scheme anywhere covers digital assets held through this platform unless expressly and separately stated). In the event of our insolvency, your ability to recover the full value of your holdings may be limited, delayed, or impaired, and you may rank alongside other unsecured creditors rather than receive automatic priority over general creditors, except to the extent applicable law or a specific, disclosed segregation arrangement provides otherwise.

Custodial and counterparty risk: when you deposit assets with us, you are relying on our operational, technical, and financial integrity to safeguard those assets and to honor withdrawal requests. This is different from self-custody, where you alone control the private keys. A failure of our security controls, a failure of a sub-custodian or infrastructure provider we rely upon, insolvency, or a compromise of our systems, could result in a partial or total loss of your holdings.

Network and protocol risk: the digital assets supported by the Services depend on decentralized networks that we do not control and cannot guarantee the continued operation, security, or integrity of. Consensus failures, protocol bugs, 51%-style attacks, contentious hard forks, or other network-level events could impair the value or transferability of assets you hold.

Regulatory risk: the regulatory treatment of digital assets is unsettled and varies by jurisdiction, and is subject to change, potentially with retroactive effect. A change in law or regulatory interpretation could restrict your ability to use the Services, could require us to modify or discontinue features, or could otherwise adversely affect your holdings.

Cybersecurity risk: despite reasonable security measures, no system connected to the internet can be guaranteed free from compromise. A successful attack against our infrastructure, a phishing attack against your own credentials, or a vulnerability in third-party software we rely upon could result in loss of assets.

Liquidity risk: we do not guarantee that you will be able to withdraw or otherwise dispose of your holdings at any particular time or price. Withdrawal processing, network conditions, or compliance review could delay your access to your assets.

Tax risk: the tax treatment of digital assets, and of transactions such as transfers between your own accounts, is unsettled or complex in many jurisdictions and may change. You are solely responsible for determining what, if any, taxes apply to your transactions and for reporting and remitting the correct amount to the appropriate tax authority.

Interoperability risk: if you withdraw assets from the Services to a third-party wallet, exchange, or service, that third party's own security practices, solvency, and reliability are outside our control, and any loss occurring after your assets leave our custody is not something we can remedy.

Operational and human-error risk: our processes involve human review at various points, including withdrawal approval. Human review reduces certain risks (for example, catching an obviously fraudulent request) but does not eliminate the possibility of error, delay, or inconsistency in how individual requests are handled.

Concentration risk: holding a significant proportion of your overall net worth in digital assets, or in a single digital asset, materially increases your exposure to the volatility and other risks described in this section. We do not provide portfolio diversification advice.

By using the Services, you acknowledge that you understand these risks and that you are using the Services at your own risk.

[Operator to complete: identify the specific regulator(s), license type(s), registration number(s), and jurisdiction(s) under which the Company is authorized to provide the Services, or state plainly that the Company does not currently hold such authorization if that is the case.] Until this section is completed with verified, current information, you should not assume that the Company holds any specific regulatory license or registration, and you should independently verify the Company's regulatory status with the relevant authority before relying on it.

Regulatory status can change, and a license or registration in one jurisdiction does not necessarily extend to, or authorize the Services in, any other jurisdiction. It is your responsibility to determine whether your use of the Services is lawful in your jurisdiction of residence.

The Services are limited to the custody, deposit, and withdrawal of supported digital assets. We do not currently offer fiat currency accounts, fiat deposits or withdrawals, currency conversion between digital assets and fiat currency, or brokerage/exchange services for converting one digital asset into another. If any such service is introduced in the future, it will be described in an update to these Terms or in supplemental terms specific to that service, and will not be implied by anything in the current version of these Terms.

Your account activity — deposits, withdrawals, and other ledger events — is visible in real time within the product's activity view. Where we offer periodic account statements as a feature, availability and format will be described within the product; until that feature is available, you can rely on the real-time activity view and the balances shown in your account as the operative record of your holdings, and you can request a manual export of your account activity by contacting support.

Nothing in this section limits our record-keeping obligations under applicable law, which may require us to retain records of your account activity for a period longer than they remain visible to you within the product.

Except as expressly stated otherwise, these Terms do not confer any right or remedy on any person or entity other than you and us, and no other person or entity may enforce any provision of these Terms, whether under a third-party-beneficiary statute or doctrine or otherwise.

Nothing on this site, and nothing communicated to you by our personnel or support channels, constitutes investment, financial, legal, accounting, or tax advice, or a recommendation to buy, sell, hold, or otherwise transact in any digital asset. Any general information provided is for informational purposes only and should not be relied upon as the basis for an investment decision.

You should consult your own independent professional advisors before making any decision relating to digital assets or the Services. We are not acting as your fiduciary, broker, financial advisor, or investment manager in connection with the Services.

You agree not to use the Services to, and represent that you will not: (a) violate any applicable law, regulation, or third-party right; (b) engage in money laundering, terrorist financing, fraud, or any other financial crime; (c) transact with assets that you know or reasonably should know were obtained through illegal means, including theft, hacking, ransomware, or sanctions evasion; (d) attempt to circumvent identity verification, transaction limits, sanctions screening, or any other compliance control; (e) interfere with, disrupt, or attempt to gain unauthorized access to the Services, our systems, or the accounts of other users; (f) use the Services to facilitate transactions involving a person or entity subject to sanctions, or located in a comprehensively sanctioned jurisdiction; (g) reverse-engineer, decompile, or attempt to derive the source code of the Services except to the extent such restriction is prohibited by applicable law; or (h) use automated means, including bots or scrapers, to access the Services in a manner that sends more request traffic than a human could reasonably generate through ordinary use, or in a manner designed to circumvent rate limits or other technical protections.

We reserve the right to investigate suspected violations of this section, to suspend or terminate accounts involved in a suspected violation, to freeze the assets associated with such an account pending investigation, and to report suspected illegal activity to law enforcement or regulatory authorities, in each case without prior notice to you where we determine notice would be inappropriate given the nature of the suspected violation.

The Services, including all software, text, graphics, logos, and other content (excluding content you submit), are owned by us or our licensors and are protected by intellectual property laws. Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, revocable license to access and use the Services for their intended personal or internal business purpose. This license does not include any right to resell or make commercial use of the Services, to collect and use listings or descriptions from the Services for a competing purpose, or to use data mining, robots, or similar data-gathering tools.

You retain ownership of any information you submit to us, subject to the license you grant us to use that information as described in our Privacy Policy and as reasonably necessary to provide the Services.

Our name, logo, and other trademarks used in connection with the Services are our trademarks, and you may not use them without our prior written consent, except as necessary to accurately describe your use of the Services.

The Services may rely on or link to third-party infrastructure, including blockchain node providers, identity verification vendors, and payment processors. We do not control and are not responsible for the availability, accuracy, or content of third-party services, and your use of any third-party service is subject to that provider's own terms and privacy practices.

A link to a third-party website or resource does not imply our endorsement of that site or resource. You access any linked third-party resource at your own risk.

We may suspend or terminate your access to the Services, in whole or in part, at any time, with or without cause, and with or without notice, including but not limited to circumstances where we reasonably believe you have violated these Terms, where required by law or by a competent authority, where we detect suspicious or potentially fraudulent activity, or where continuing to provide the Services to you would expose us to legal or regulatory risk.

You may close your account at any time, subject to the completion of any pending transactions, the resolution of any pending compliance review, and the withdrawal or other disposition of your remaining balance in accordance with our standard withdrawal process.

Upon termination, your right to use the Services ceases immediately. Sections of these Terms that by their nature should survive termination — including but not limited to provisions relating to risk disclosures, limitation of liability, indemnification, dispute resolution, and governing law — will survive.

If your account is terminated while it holds a balance, we will provide a reasonable process for you to withdraw that balance, subject to the completion of any compliance review and subject to applicable law, including circumstances where we may be required to freeze or escheat unclaimed balances.

Dormant accounts: if your account holds a balance but shows no login activity, deposit, or withdrawal for an extended period, applicable unclaimed-property or dormancy law in some jurisdictions may require us to attempt to contact you using the details on file, and, if we are unable to re-establish contact after a reasonable period, may require us to report or remit the balance to a government unclaimed-property program rather than continuing to hold it indefinitely. We will make reasonable efforts to notify you before any such step is taken, using the contact information associated with your account.

Risk-based transaction limits: we may apply limits to the amount you can deposit or withdraw over a given period, calibrated to factors such as your account's verification tier, the length and pattern of your account history, and prevailing fraud and compliance risk indicators. Limits may be adjusted, tightened, or lifted at our discretion as those factors change, and we will make reasonable efforts to display applicable limits within the product where practicable.

You represent and warrant, on a continuing basis for as long as you use the Services, that: (a) you have the legal capacity and authority to enter into these Terms; (b) all information you provide to us is accurate, current, and complete; (c) you will comply with all applicable laws in connection with your use of the Services; (d) any digital assets you deposit were lawfully obtained and are not, to your knowledge, connected with any illegal activity; (e) you are using the Services for your own account and not on behalf of an undisclosed third party, unless you have obtained our prior written consent to act as an intermediary; and (f) your use of the Services does not and will not violate any agreement to which you are a party or any right of any third party.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE, THAT DEFECTS WILL BE CORRECTED, OR THAT THE SERVICES OR THE SERVERS THAT MAKE THEM AVAILABLE ARE FREE OF HARMFUL COMPONENTS.

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES, SO SOME OF THE ABOVE EXCLUSIONS MAY NOT APPLY TO YOU. IN THAT CASE, SUCH WARRANTIES ARE LIMITED TO THE MINIMUM SCOPE AND DURATION PERMITTED BY LAW.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL WE, OUR AFFILIATES, OR OUR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, DATA, OR GOODWILL, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE SERVICES, WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, OUR AGGREGATE LIABILITY TO YOU FOR ANY CLAIM ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICES WILL NOT EXCEED THE GREATER OF (A) THE FEES YOU PAID TO US IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS (USD $100), EXCEPT WHERE APPLICABLE LAW REQUIRES A DIFFERENT STANDARD, INCLUDING FOR LIABILITY ARISING FROM OUR GROSS NEGLIGENCE, WILLFUL MISCONDUCT, OR FRAUD, OR FOR LIABILITY THAT CANNOT LAWFULLY BE LIMITED.

SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY FOR CERTAIN TYPES OF DAMAGES. IN SUCH JURISDICTIONS, OUR LIABILITY IS LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW.

You agree to indemnify, defend, and hold harmless the Company and its affiliates, and their respective officers, directors, employees, and agents, from and against any and all claims, liabilities, damages, losses, and expenses, including reasonable legal fees, arising out of or in any way connected with: (a) your access to or use of the Services; (b) your violation of these Terms; (c) your violation of any applicable law or the rights of any third party; or (d) any inaccurate information you provide to us. This indemnification obligation will survive the termination of these Terms and of your account.

We will not be liable for any failure or delay in performance to the extent caused by circumstances beyond our reasonable control, including but not limited to acts of God, natural disaster, war, terrorism, civil unrest, labor disputes, governmental action, changes in law, failures of the internet or of third-party telecommunications or hosting infrastructure, blockchain network congestion or failure, or a distributed denial-of-service or similar cyberattack against our infrastructure or against infrastructure we rely upon.

We encourage you to contact our support team first to resolve any dispute informally; many concerns can be resolved quickly that way. If a dispute cannot be resolved informally within sixty (60) days, both you and we agree that any dispute, claim, or controversy arising out of or relating to these Terms or the Services will be resolved through binding arbitration, rather than in court, except that either party may bring an individual action in small-claims court for disputes within that court's jurisdiction, and either party may seek injunctive or other equitable relief in a court of competent jurisdiction to prevent actual or threatened infringement, misappropriation, or violation of intellectual property rights.

[Operator to complete: name of arbitral institution, applicable arbitration rules, seat/venue of arbitration, and language of proceedings.] Arbitration will be conducted by a single arbitrator. The arbitrator's decision will be final and binding, subject only to the limited grounds for review available under the arbitration law of the seat of arbitration.

YOU AND WE EACH AGREE THAT ANY ARBITRATION WILL BE CONDUCTED ON AN INDIVIDUAL BASIS AND NOT ON A CLASS, CONSOLIDATED, OR REPRESENTATIVE BASIS, UNLESS BOTH PARTIES AGREE OTHERWISE IN WRITING. IF THIS CLASS-ACTION-WAIVER PROVISION IS FOUND TO BE UNENFORCEABLE, THEN THE ENTIRETY OF THIS ARBITRATION SECTION WILL BE NULL AND VOID, AND THE DISPUTE WILL BE RESOLVED IN COURT SUBJECT TO SECTION 20 (GOVERNING LAW).

You may opt out of this arbitration agreement by sending written notice to us within thirty (30) days of first accepting these Terms, using the contact details in Section 55. Opting out of arbitration does not affect any other provision of these Terms.

[Operator to complete: governing law and, to the extent any dispute is not subject to the arbitration agreement in Section 31, the courts with exclusive jurisdiction over that dispute.] This section, together with Section 31, sets out the complete agreement between you and us regarding how disputes arising out of or relating to these Terms or the Services will be resolved.

You may not assign or transfer these Terms, or any right or obligation under them, without our prior written consent. We may assign or transfer these Terms, in whole or in part, without restriction, including in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of our assets, provided that any assignee agrees to be bound by these Terms.

In the unlikely event that the Company becomes insolvent, the treatment of custodied client assets will depend on the legal structure under which those assets are held — see Section 9 (Segregation and safekeeping of client assets) — and on the insolvency law of the relevant jurisdiction, which is outside our ability to guarantee in advance. Where a legally effective segregation or trust structure is in place and recognized by the relevant insolvency court, client assets are generally intended to be returned to clients ahead of, and outside of, distributions to the Company's general unsecured creditors. Where no such structure is disclosed and recognized, you may instead rank as a general unsecured creditor for the value of your holdings, meaning you could recover less than the full value of your account, or nothing, depending on the Company's other liabilities and available assets.

This is one of the most consequential differences between custodial platforms and it varies enormously by operator, jurisdiction, and specific legal structure — we describe it here in general terms precisely because it matters, and we commit to keeping Section 9 updated as our specific structure is finalized and disclosed, rather than leaving this section vague indefinitely.

We may be subject to examination, audit, or inspection by regulators with jurisdiction over our activities, and by independent auditors we engage. Where such an examination requires access to information about your account, we will handle that access consistently with the disclosure principles in our Privacy Policy and with applicable law. An audit finding is not, by itself, notice to you of any change to these Terms; changes to these Terms are only made in accordance with Section 56 (Changes to these Terms).

If any provision of these Terms is found by a court or arbitrator of competent jurisdiction to be invalid, illegal, or unenforceable, that provision will be limited or eliminated to the minimum extent necessary so that the remaining provisions of these Terms remain in full force and effect.

Our failure to enforce any right or provision of these Terms will not be considered a waiver of that right or provision. Any waiver of any provision of these Terms will be effective only if in writing and signed by an authorized representative of the party granting the waiver.

These Terms, together with the Privacy Policy and any other legal notices or agreements published by us on the Services and applicable to your account, constitute the entire agreement between you and us regarding your use of the Services, and supersede any prior agreements between you and us regarding the same subject matter.

Nothing in these Terms creates a partnership, joint venture, employment, agency, or franchise relationship between you and us. Except as expressly described in Section 7 (Description of custody services) with respect to the safekeeping of your custodied assets, nothing in these Terms creates a fiduciary duty owed by us to you.

While we do not publish the full technical detail of our security architecture (doing so would itself create risk), we can describe the general commitments that shape how the Services are built. Passwords are never stored in plain text; they are hashed using a modern, memory-hard hashing algorithm designed specifically to resist both brute-force and hardware-accelerated attacks. We do not have the ability to "look up" your password, and if you forget it, we can only help you set a new one, not recover the old one.

Sensitive material at rest, including the cryptographic key material underlying deposit-address derivation, is encrypted using industry-standard authenticated encryption, with the encryption key held separately from the encrypted data itself so that access to one alone is not sufficient to recover the other.

Sign-in sessions are individually tracked, so you can review every device currently signed in to your account and revoke any of them individually — including, if you ever suspect a device is compromised, every session except the one you are currently using. Signing out on one device does not require you to change your password, though changing your password is also available and, when used, signs out every other active session automatically.

Every withdrawal is held for administrative review before funds leave custody, as described in Section 14 (Withdrawal review and cooling-off) — a deliberate, human-reviewed checkpoint between "a withdrawal was requested" and "a withdrawal was executed," specifically to catch fraud and error before it becomes irreversible.

These commitments describe how the Services are designed to operate. They are operational commitments, not a warranty that no security incident can ever occur — see Section 16 (Risk disclosures) and Section 27 (Disclaimer of warranties) for the legal treatment of that residual risk.

Without limiting the general suspension and termination right described in Section 25, examples of circumstances that may lead us to suspend or restrict an account, pending investigation, include: a payment dispute or chargeback claim relating to a deposit made through an intermediary; a report from a third party alleging that assets in your account may be connected with theft, fraud, or another crime; a mismatch between your stated activity and the pattern of activity we actually observe on your account; receipt of a legal order, subpoena, or garnishment affecting your account; or a good-faith belief that your account has been compromised by someone other than you.

Where we restrict an account pending investigation, we aim to resolve the investigation as promptly as reasonably practicable and to communicate with you to the extent we are legally permitted to. A restriction pending investigation is not itself a determination that you have done anything wrong, and we will lift a restriction once we are reasonably satisfied that the underlying concern has been resolved.

If you choose to send us feedback, suggestions, or ideas about the Services, you grant us a perpetual, irrevocable, worldwide, royalty-free license to use that feedback for any purpose, without any obligation to compensate you, and without any obligation to keep the feedback confidential. You are, of course, under no obligation to provide feedback.

We may from time to time make available features labeled as beta, preview, or experimental. Such features are provided for testing and evaluation purposes, may be changed or withdrawn at any time without notice, and may be less reliable than generally-available features of the Services. Section 16 (Risk disclosures), Section 27 (Disclaimer of warranties), and Section 28 (Limitation of liability) apply with particular force to your use of beta or experimental features.

We may send you service-related communications (such as security notices, changes to these Terms, and transaction confirmations) that are necessary to operate your account; you cannot opt out of these while your account remains open, as they are part of how we deliver the Services. We may also send you optional marketing communications about new features or the Company generally; you may opt out of these at any time using the unsubscribe mechanism included in such communications, without affecting the service-related communications described above.

Balances, fees, and thresholds within the Services are denominated in the native unit of the relevant digital asset unless expressly stated otherwise. Any reference to a fiat currency amount (for example, in a fee schedule) is for illustration only, is not itself a service we provide, and is not a representation of a specific exchange rate that will apply to your account, since we do not operate fiat conversion services as described in Section 18 (No fiat currency services).

If you register on behalf of a legal entity, you additionally represent that: the entity is validly formed and in good standing under the law of its jurisdiction of organization; you are authorized to act on the entity's behalf in agreeing to these Terms and in operating the account; and the entity's beneficial ownership and control information provided to us during identity verification is accurate. We may require additional documentation from institutional or corporate clients, such as constitutional documents, evidence of authorized signatories, and beneficial-ownership declarations, before or during the account relationship.

We retain records relating to your account, including identity-verification records and transaction history, for the period required by applicable law and regulation, which in many jurisdictions extends for a number of years after an account is closed. This retention obligation is independent of, and may exceed, the retention and deletion practices described in our Privacy Policy for other categories of personal data.

We may add, modify, or discontinue features of the Services at any time, including but not limited to supported assets and networks (Section 8), fee structures (Section 12), and the specific security controls and review processes described elsewhere in these Terms. We will provide notice of material changes in accordance with Section 56 (Changes to these Terms) where the change affects existing account holders' use of features they already rely on.

If you have a complaint about the Services, please contact our support team using the details on our Contact page, describing the issue and, where relevant, the account and transaction concerned. We aim to acknowledge complaints promptly and to investigate them fairly. [Operator to complete: describe any formal internal escalation path, target resolution timeframes, and any external ombudsman or alternative-dispute-resolution scheme available to clients in the relevant jurisdiction, if one applies to the Company's activities.]

Using this complaints procedure does not affect your rights under Section 31 (Dispute resolution and arbitration), and does not extend any statutory limitation period that may apply to a claim.

By using the Services, you consent to receive communications from us electronically, including by email and by notices posted within the product, and you agree that all agreements, notices, disclosures, and other communications we provide electronically satisfy any legal requirement that such communications be in writing, to the extent permitted by applicable law. You are responsible for keeping the email address associated with your account current.

You agree to comply with all applicable export control and economic sanctions laws and regulations in connection with your use of the Services, and you represent that you are not located in, or ordinarily resident in, a country or region that is the subject of comprehensive sanctions, and that you are not otherwise a person with whom dealings are prohibited or restricted under applicable sanctions law. This representation is in addition to, and does not limit, the eligibility requirements in Section 4.

We aim to design the Services to be usable by people with a wide range of abilities, consistent with applicable accessibility standards and guidelines. If you encounter an accessibility barrier while using the Services, please let us know using the contact details in Section 55 so we can investigate.

Depending on where you live, you may have specific statutory rights regarding the personal data we hold about you — for example, rights of access, correction, deletion, and portability under the EU/UK General Data Protection Regulation, or rights to know, delete, and opt out of certain uses of personal information under the California Consumer Privacy Act as amended by the California Privacy Rights Act. These rights, and how to exercise them, are described in full in our Privacy Policy, which forms part of your agreement with us alongside these Terms.

These Terms are drafted in English. Any translation provided is for convenience only, and the English-language version controls in the event of a conflict. Any provision of these Terms that by its nature is intended to survive termination of your account or of these Terms — including, without limitation, Sections 16, 21, 27, 28, 29, 31, and 32 — survives any such termination.

We may provide notices to you by email to the address associated with your account, by posting within the product, or by posting an update to this page. Notices to you are deemed given when sent or posted, as applicable. You may contact us using the support details published on our Contact page and in the footer of this site for any question regarding these Terms.

We may revise these Terms from time to time. When we make material changes, we will provide reasonable advance notice before the changes take effect, such as by email or an in-product notice, except where a change is required immediately to comply with applicable law, address a security issue, or respond to an urgent operational necessity, in which case the change may take effect immediately with notice provided as promptly as practicable thereafter.

The "Last updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the Services after a revised version of these Terms takes effect constitutes your acceptance of the revised Terms. If you do not agree to a revision, your remedy is to stop using the Services and, if applicable, to withdraw your custodied assets and close your account before the revised Terms take effect.