Terms of Service

2.1You must be at least 18 years of age, or the age of legal majority in your jurisdiction of residence, to use the Services.

2.2You represent and warrant that you have full legal capacity to enter into these Terms and are not barred from using the Services under the laws of your jurisdiction of residence or citizenship.

2.3The Services are not available to residents of jurisdictions where the use of crypto-funded card products is prohibited, restricted, or unlicensed, including but not limited to jurisdictions subject to comprehensive sanctions programs administered by the United Nations, the European Union, the Office of Foreign Assets Control (OFAC), or other applicable regulatory bodies. The Company maintains and reserves the right to update a list of restricted jurisdictions at its sole discretion.

2.4The Company reserves the right to refuse, suspend, or terminate access to the Services for any person or entity, at its sole discretion, including where required to comply with applicable law.

3.1To access the Services, you must complete registration and provide accurate, current, and complete information.

3.2As a regulated financial service offering, the Company and its Card Issuing Partner are required to conduct identity verification, customer due diligence, and ongoing monitoring in accordance with applicable Know Your Customer ("KYC") and Anti-Money Laundering ("AML") obligations. You agree to provide all documentation reasonably requested, including but not limited to government-issued identification, proof of address, and source-of-funds documentation.

3.3The Company reserves the right to decline registration, suspend an Account, or terminate the Services where verification cannot be completed, where documentation appears fraudulent, or where the Company reasonably suspects the Account is being used for illicit purposes.

3.4You are solely responsible for maintaining the confidentiality of your Account credentials. You must notify the Company immediately of any unauthorized access or use of your Account.

3.5You may not create more than one Account unless explicitly authorized by the Company, and you may not transfer, sell, or share your Account with any third party.

4.1Upon Account approval, you will be issued a digital Wallet enabling the receipt, storage, and management of supported Digital Assets across Supported Networks.

4.2Where the Wallet is described as self-custodial, you acknowledge that you are solely responsible for safeguarding any private keys, seed phrases, or recovery credentials associated with the Wallet. The Company does not store, has no access to, and cannot recover lost private keys or seed phrases under a self-custodial model. Loss of such credentials may result in permanent and irreversible loss of access to your Digital Assets.

4.3You acknowledge that blockchain transactions are irreversible once confirmed on the relevant network, and the Company has no ability to reverse, cancel, or refund a confirmed on-chain transaction.

4.4The Company is not responsible for losses arising from incorrect wallet addresses, unsupported token transfers, network congestion, sending Digital Assets on an unsupported network, smart contract failures, or third-party blockchain infrastructure failures.

5.1You may fund your Account by transferring supported Digital Assets to your Wallet address via a Supported Network.

5.2Upon funding, the Company may convert Digital Assets into a Fiat Equivalent for purposes of Card issuance and transaction settlement, at a rate determined by the Company or its liquidity and conversion partners at the time of conversion. Exchange rates are subject to market volatility and may differ from rates quoted on third-party exchanges.

5.3Conversion is subject to applicable fees as published on the Platform or disclosed at the time of transaction. The Company reserves the right to amend its fee schedule upon reasonable notice.

5.4You acknowledge that conversion timing, network confirmation requirements, and gas or network fees on Supported Networks are outside the Company's control and may affect the speed and final value of funding transactions.

6.1The Card is a virtual payment instrument issued by the Card Issuing Partner pursuant to a separate cardholder agreement, which may impose additional terms applicable to your use of the Card. In the event of conflict between these Terms and the Card Issuing Partner's cardholder agreement with respect to Card issuance and network rules, the cardholder agreement shall govern as to those matters.

6.2The Card draws against the Fiat Equivalent balance held in connection with your Account. You may not spend in excess of your available balance, and the Company does not extend credit in connection with the Card.

6.3"Spend without limits," as referenced in the Company's marketing, refers to the absence of Company-imposed artificial spending caps relative to available balance, and does not constitute a representation that no transaction limits, velocity controls, merchant category restrictions, geographic restrictions, card network limits, or Issuing Partner risk controls apply. Such limits may be imposed by the Card Issuing Partner, payment networks, merchant acquirers, or applicable law, and are outside the Company's control.

6.4The Card is for personal, non-commercial use only unless otherwise agreed in writing. Use of the Card for unauthorized commercial activity, resale of card services, or money transmission to third parties is strictly prohibited.

6.5The Company reserves the right to decline, block, reverse, or flag any transaction for compliance, fraud-prevention, or risk-management purposes, including transactions with merchants in high-risk categories.

6.6Lost, compromised, or suspected fraudulent use of the Card must be reported immediately through the Platform. Liability for unauthorized transactions is governed by the applicable Card Issuing Partner's policies and applicable payment network rules.

7.1Use of the Services may be subject to fees, including but not limited to account fees, card issuance fees, funding/conversion fees, foreign exchange fees, inactivity fees, and transaction fees, as set out in the Company's published fee schedule.

7.2The Company reserves the right to modify fees at any time, with such changes taking effect upon publication on the Platform or upon notice to the User, as applicable.

7.3All fees are non-refundable except where required by applicable law or expressly stated otherwise.

You agree not to use the Services to:

• engage in money laundering, terrorist financing, fraud, or any other illegal activity;
• violate any applicable sanctions regime;
• circumvent KYC/AML verification or provide false identity information;
• engage in activity that infringes the rights of any third party;
• interfere with or disrupt the integrity or performance of the Platform;
• use the Services in any jurisdiction where such use is unlawful or unauthorized;
• attempt to reverse-engineer, decompile, or gain unauthorized access to the Platform's systems;
• use the Card or Wallet to facilitate transactions on behalf of unverified third parties.

The Company reserves the right to suspend or terminate any Account suspected of violating this Section, report such activity to relevant authorities, and cooperate fully with law enforcement and regulatory investigations.

10.1The Company may suspend, restrict, or terminate your access to the Services, in whole or in part, at its sole discretion and without prior notice, where: (a) required by law or regulatory direction; (b) the Company reasonably suspects fraud, illegal activity, or breach of these Terms; (c) the Card Issuing Partner or a network partner requires such action; or (d) the Company discontinues the Services, in whole or in part.

10.2You may close your Account at any time by following the procedure published on the Platform, subject to settlement of any outstanding balances or obligations.

10.3Upon termination, you remain liable for any outstanding obligations, and the Company may retain records as required by applicable AML/KYC retention obligations.

11.1All content, branding, software, and materials comprising the Platform, including the "spender.cc" name and associated marks, are the property of the Company or its licensors and are protected by applicable intellectual property laws.

11.2You are granted a limited, non-exclusive, non-transferable, revocable license to access and use the Platform solely for its intended personal use. No other rights are granted.

12.1The Company intends to make available a Telegram Mini Application enabling access to certain Account and Card functions through the Telegram messaging platform ("Mini App").

12.2Use of the Mini App, once available, will be subject to these Terms and any supplementary terms published at the time of launch, and will also be subject to Telegram's own platform terms, over which the Company has no control.

12.3The Company makes no representation as to the launch timing, feature parity, or availability of the Mini App in any given jurisdiction.

13.1THE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, OR UNINTERRUPTED, SECURE, OR ERROR-FREE OPERATION.

13.2THE COMPANY DOES NOT WARRANT THAT THE PLATFORM WILL BE FREE OF VIRUSES, ERRORS, OR INTERRUPTIONS, OR THAT ANY DEFECTS WILL BE CORRECTED.

14.1TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY, ITS DIRECTORS, OFFICERS, EMPLOYEES, AND AFFILIATES SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, REVENUE, DATA, OR DIGITAL ASSET VALUE, ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICES, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

14.2THE COMPANY'S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICES SHALL NOT EXCEED THE TOTAL FEES PAID BY YOU TO THE COMPANY IN THE SIX (6) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM.

14.3NOTHING IN THESE TERMS SHALL EXCLUDE OR LIMIT LIABILITY THAT CANNOT LAWFULLY BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

You agree to indemnify, defend, and hold harmless the Company, its officers, directors, employees, and affiliates from and against any claims, liabilities, damages, losses, and expenses, including reasonable legal fees, arising out of or in any way connected with: (a) your use or misuse of the Services; (b) your violation of these Terms; (c) your violation of any applicable law or third-party right; or (d) any Digital Asset transaction you initiate.

The Company shall not be liable for any failure or delay in performance resulting from causes beyond its reasonable control, including but not limited to acts of God, blockchain network failures or congestion, government action, sanctions, internet or telecommunications failures, cyberattacks, or failures of third-party service providers, including the Card Issuing Partner.

The Company reserves the right to amend these Terms at any time. Material changes will be communicated via the Platform or by email where applicable. Continued use of the Services following the effective date of any amendment constitutes acceptance of the revised Terms.

18.1These Terms shall be governed by and construed in accordance with the laws of the British Virgin Islands, without regard to its conflict-of-law principles.

18.2Any dispute arising out of or in connection with these Terms, including any question regarding its existence, validity, or termination, shall first be submitted to good-faith negotiation between the parties. If unresolved within thirty (30) days, the dispute shall be referred to and finally resolved by arbitration in accordance with the rules of the BVI International Arbitration Centre, with the seat of arbitration in Tortola, British Virgin Islands, conducted in the English language.

18.3Nothing in this Section shall prevent either party from seeking urgent injunctive or equitable relief from a court of competent jurisdiction.

If any provision of these Terms is held to be invalid or unenforceable, the remaining provisions shall continue in full force and effect, and the invalid or unenforceable provision shall be deemed modified to the minimum extent necessary to make it valid and enforceable.

These Terms, together with the Privacy Policy, Risk Disclosure, and any supplementary agreements referenced herein (including the Card Issuing Partner's cardholder agreement), constitute the entire agreement between you and the Company with respect to the Services, superseding any prior agreements or understandings.

You may not assign or transfer your rights or obligations under these Terms without the Company's prior written consent. The Company may assign these Terms, in whole or in part, in connection with a merger, acquisition, restructuring, or sale of assets, without restriction.