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Terms of service

1. About Our Terms

1.1 This Terms of Service Agreement ("Agreement") is a legal agreement between you ("User" or "you") and Layer Flow Gateway FZCO ("Company", "we", or "us"), governing your use of our non-custodial software-as-a-service platform, website, mobile applications, and associated services (collectively, the "Services").

1.2 You should read these Terms carefully before using the Services. By using the Services or otherwise indicating your consent, you agree to be bound by these Terms. If you do not agree, you must not access or use the Services.

1.3 The Services provide non-custodial software for businesses and individual users (B2B, B2C and C2C) to coordinate blockchain-based payment flows. We do not hold, control or access your private keys or assets, and we do not initiate, transmit, or settle virtual-asset transfers.

1.4 Representative features may include LFG-to-LFG transfers and payment requests, token swaps where enabled, and access to compliance and risk-management tools. Some features may be available only on paid plans.

1.5. Order of precedence: if you and LFG sign a separate Services Agreement or order form, that document prevails over these Terms to the extent of any conflict.

1.6. Account Registration: In order to access certain features of the Service, you may be required to create an account. You agree to provide accurate, complete, and up-to-date registration information. You are solely responsible for maintaining the confidentiality of your account and password and for all activities that occur under your account.

1.7. The Service: The Service provides online software solutions, including but not limited to compliance checks on transactions to and from your own wallet. The Service is made available to you on a subscription basis and may include both freemium and paid subscription options. The Service is non-custodial software that connects to wallets you control. We do not hold private keys, and we do not initiate, transmit, or settle blockchain transfers; transactions are final on their respective networks and cannot be reversed by us. We do not store backup words/seed phrases and cannot retrieve or reset them for you. The Service may include compliance analytics (e.g., transaction/wallet screening, sanctions and risk signals). These analytics are probabilistic and do not constitute legal, tax, accounting or investment advice. You remain responsible for your use of virtual assets and for complying with applicable law. We may disable features (e.g., routing, swaps, off-ramping, payouts) where our checks indicate risk or where required by law.

1.8. Incorporated Documents (form part of these Terms):

If these conflict with this Agreement, this Agreement prevails unless your signed order says otherwise.

1.9. Third-party dependencies: Some features rely on third-party services (e.g., wallets, PSPs/EMIs, node providers, exchanges). Their terms apply to your use of those services; we are not responsible for their acts or omissions.

1.10. Beta features: We may offer beta or preview features. These are provided as-is, may be withdrawn, and may be subject to additional terms shown in-app.

2. About Us

2.1. We are LAYER FLOW GATEWAY FZCO, a company registered in the Dubai World Trade Centre (DWTC) free zone with licence number L-3426. Registered address: Level 17, Sheikh Rashid Tower, Dubai World Trade Centre, Dubai, UAE. Contact: [email protected]

3. Territory & Eligibility – Global (per Availability Statement)

3.1. Availability is defined exclusively in the Global Availability Statement, which forms part of these Terms and is updated from time to time.

3.2. Individual Users (Free, KYC-Required) Available in over 130 countries and territories listed in §3 of the Global Availability Statement, subject to:

  • Successful KYC via Sumsub

  • Ongoing compliance checks

3.3. Business Users (KYB & Paid Subscriptions) Available only in jurisdictions listed in §4 of the Global Availability Statement where:

  • KYB is supported

  • Apple In-App Purchase / Google Play Billing is available

  • LFG is legally authorised to operate

Current supported business markets

  • United Kingdom, Ireland, France, Germany, Spain, Portugal, Italy, Netherlands, Belgium, Luxembourg, Austria, Switzerland, Denmark, Sweden, Norway, Finland, Poland, Czechia, Slovakia, Hungary, Romania, Bulgaria, Greece, Estonia, Latvia, Lithuania, Cyprus, Malta, United Arab Emirates, Saudi Arabia, Bahrain, Oman, Qatar, Australia, New Zealand, Japan, South Korea, Singapore, Hong Kong, Canada, Mexico, Brazil, Argentina, Chile, Colombia, Peru, Ecuador, Panama, Costa Rica, and South Africa.

3.4. Prohibited Jurisdictions

You must not access or use the Services if you are resident, incorporated, or primarily operating from any jurisdiction listed in §6 of the Global Availability Statement, including but not limited to:

  • Afghanistan, Belarus, Bolivia, Cuba, Iran, Iraq, Libya, Myanmar (Burma), Nepal, North Korea, Russia (including Crimea, Donetsk, and Luhansk), Sudan, Syria, United States, Venezuela, Yemen, India, Pakistan, Bangladesh, Morocco, Algeria, Egypt, Turkey, Indonesia, Vietnam, Thailand, Malaysia, and Nigeria.

3.5. Geo-controls & Circumvention We implement IP, device, payment-method, and KYC-based controls to enforce territorial restrictions. You must not use VPNs, proxies, or any method to circumvent these restrictions. Breach is a material breach and may result in immediate suspension/termination without notice.

3.6. Change of Status If your residency, incorporation, principal place of business, ownership/UBOs, or authorisations change such that you no longer meet eligibility, you must promptly notify us. We may suspend or close the account and disable features.

4. Account Registration

4.1. You may need an account to use certain features. You agree to provide accurate, complete and up-to-date information and to keep your credentials secure. You are responsible for all activity that occurs under your account. We are not obliged to permit anyone to register and may refuse, terminate or suspend registration at our discretion.

5. Free and Paid Subscriptions

5.1. Freemium Accounts: We may offer a free subscription plan that provides limited access to the Service. The features and limitations of the freemium plan will be determined solely by the Company and may be subject to change without prior notice. Use of the free plan does not include or cover any fees, costs, or charges imposed by third parties such as blockchain network transfer costs ('gas fees'), token swaps, or buying and selling of digital assets (on/off-ramping). These remain solely the responsibility of the user.

5.2. Paid Subscriptions: We may offer paid subscription plans that provide additional features, functionality, and support beyond what is available in the freemium plan. The details, pricing, and billing terms for the paid subscription plans will be clearly communicated to you on our website or within the Service and may be subject to change without prior notice. All payments are processed exclusively via Apple In-App Purchase or Google Play Billing in supported business jurisdictions. Subscription allowances are software usage limits (e.g., transaction volume, API calls, user seats), have no monetary value, are non-transferable, and cannot be exchanged, redeemed, or converted into digital assets, fiat currency, or credit balances. Use of any paid plan does not include or cover any fees, costs, or charges imposed by third parties such as blockchain network transfer costs ('gas fees'), token swaps, or buying and selling of digital assets (on/off-ramping). These remain solely the responsibility of the user.

6. Billing, Auto-renewal, Cancellations, Refunds & Antiabuse

6.1. Auto-renewal & payment obligation: paid subscriptions and add-ons renew at the start of each billing period (monthly/annual, as shown in-app). By allowing a new billing period to begin, you become liable for the fees for that entire period. To avoid renewal fees, cancel before the next period starts in the app.

6.2. Cancellation: you may cancel at any time; cancellation takes effect at the end of the current billing period. Fees already paid are non-refundable except where required by law.

6.3. Trials & promotions: unless you cancel before the trial ends, the plan converts to a paid subscription and the first fee is charged at the trial’s end time; we’ll show the end time in-app.

6.4. Upgrades & downgrades: upgrades take effect immediately; we may charge a pro-rated amount for the remainder of the current period. Downgrades take effect at the next renewal.

6.5. Free trials or free offers with promotional codes to Subscriptions, offered by The Company, cannot be combined with any free trials or offers of The Company. You acknowledge that your free trial or free offer may expire if you change your subscription type whilst within the free trial or free offer period, and The Company shall have no obligation to reinstate, reimburse, or otherwise compensate you for any part of such expired free trial or free offer.

6.6. Failed/expired payments: if a charge fails, you remain responsible for the amount due; we may retry, ask you to update your payment method, and suspend paid features until payment is received.

6.7. Price changes: we will give advance notice (in-app/email) of any price changes. New prices apply from the next renewal. If you do not agree, cancel before renewal.

6.8. Taxes: fees are exclusive of VAT and other taxes unless stated; we may collect taxes as required.

6.9. Chargebacks: if you initiate a chargeback, we may suspend or limit access pending resolution.

6.10. Anti-abuse: we may suspend, cancel, or refuse a payment/refund where we reasonably suspect fraud, abuse or unlawful/manipulative behaviour.

6.11. Consumer rights: if you are a consumer, any mandatory rights under applicable law (e.g., EU 14-day cooling-off, UAE consumer protection) apply and prevail over inconsistent terms.

6.12. In-App Purchases: Our products may offer content, services or functionality for use within such Apps (“In-App Purchases”). In-App Purchases that are consumed during the use of the App (for example, additional scans or features) cannot be transferred to other users. All unconsumed “In-App Purchases” will expire and are non-transferable upon termination of your account or the end of your subscription.

6.13. When your Paid Subscription to any Service or Content ends, you will lose access to any functionality or Content of that Service that requires a Paid Subscription.

6.14. Taxes & reporting: You are solely responsible for determining, collecting, withholding, reporting and remitting any taxes, duties, assessments, penalties or interest that arise from your use of the Services and your virtual-asset transactions (including income, corporate, VAT and any other applicable taxes). We are not your tax agent or adviser and do not provide tax advice. We may provide transaction histories for your convenience, but we do not guarantee that any records we provide satisfy your regulatory, accounting or tax reporting obligations.

6.15. Account closure or app deletion does not transfer or recover assets; you remain responsible for your wallets outside the Services.

7. Transfers, Risk Controls & Third-Party On/Off-Ramps

7.1. Scope: The Services support transfers and payment requests between verified LFG users and, where enabled, to or from external self-hosted wallets you control, subject to risk checks, limits, and applicable law.

7.2. Non-custodial role: You initiate all transactions from wallets you control. LFG does not hold private keys and does not accept, transmit, or settle funds on your behalf.

7.3. Monitoring & risk alerts: We use automated and manual checks (including blockchain analytics and identity monitoring) to detect potential financial crime, sanctions exposure, or policy breaches.

7.4. Suspension: If we identify irregular activity, detect prohibited use, or receive a lawful notice from competent authorities, we may suspend or restrict your access to some or all features (e.g., sending, receiving, or business tools) while we investigate or comply with legal requirements.

7.5. Non-custodial limits: We cannot freeze or reverse assets held in your wallets. Any suspension affects only your access to LFG Services, not your independent access to your wallets.

7.6. Reporting: Where legally required, we may report suspected activity to competent authorities and are prohibited from notifying you in certain cases (“tipping off”).

7.7. Counterparty type: Transfers to regulated VASPs/PSPs/EMIs may require additional originator/beneficiary details. Transfers to self-hosted wallets may require proof-of-ownership (e.g., a signed message) and/or further information for compliance verification.

7.8. Third-Party On/Off-Ramps (Optional):

Crypto-to-fiat and fiat-to-crypto conversions are provided exclusively by:

  • Transak (licensed in supported jurisdictions)

  • Moonpay (licensed in supported jurisdictions)

  • Ramp (licensed in supported jurisdictions)

LFG does not execute, custody, or settle these transactions. Their terms, KYC, and licensing apply. Availability varies by region.

8. Travel Rule – Pass-Through Facilitation Only

8.1. We are not the ordering or beneficiary VASP.

8.2. Where local law or a counterparty VASP requires Travel Rule data (e.g., thresholds applicable in Dubai, EU, UK), you authorise us to:

  • Request the minimum required data from you

  • Securely forward it to the counterparty VASP

  • Receive data from the counterparty VASP

8.3. This is a pass-through facilitation only. We do not originate, execute, or settle transfers.

8.4. If required data cannot be validated, or if we receive a lawful notice from a competent authority (including law enforcement, financial regulators, or sanctioned-entity alerts), we may:

  • Disable the relevant integration or feature (e.g., off-ramp, routing)

  • Suspend your access during investigation

  • Report to authorities where required We are prohibited from notifying you in certain cases ("tipping-off").

9. Provenance Checks & Allow-listing

9.1. For assets from external/non-LFG sources or imported wallets, we may request limited information (e.g., whether the sender is your own wallet—verified by a quick cryptographic proof of control—or a business counterparty/exchange name/reference) and use blockchain analytics.

9.2. Once cleared, we may allow-list the counterparty or lot for a defined period or amount so we do not ask again unless risk changes. We do not require you to upload third-party identity documents.

10. Addresses, Networks & Finality (Your Responsibility)

10.1. Blockchain transfers are final and irreversible once confirmed.

10.2. You are solely responsible for recipient addresses, the correct network/chain, required memos/destination tags, and asset compatibility (e.g., token standard).

10.3. The Services may not detect invalid/non-existent/incompatible addresses, missing tags, wrong networks, contract-only addresses, or look-alike assets on different chains. We cannot retrieve, replace or refund such transactions and are not liable for resulting loss.

10.4. A transaction is treated as Delivered when the relevant network confirms it according to commonly accepted confirmation thresholds for that network.

10.5. Wallets, Backup Words & Recovery (a) No custody; no keys. LFG provides non-custodial software. We do not hold, manage, or have access to your private keys or seed phrases, and cannot move, freeze, or recover your assets. (b) Backup words/seed phrases. Stored only on your device. We have never had access. (c) Your responsibility. You are solely responsible for generating, securing, backing up, and keeping secret your backup words/keys. Loss = permanent loss. (d) App deletion/account closure. Does not move funds. Without backup, assets are unrecoverable. (e) Device risks. You are responsible for device security.

Before deleting your account or the app, you must read and accept our Account Deletion Policy: → https://help.getlfg.app/p/agreements/account-deletion This includes critical warnings about permanent data loss, non-refundable subscriptions, and export requirements.

10.6. User Security Measures. You are solely responsible for implementing reasonable security controls (e.g., OS updates, anti-malware, hardware wallets, offline seed backup). LFG is not responsible for losses due to your failure.

11. AML/CFT & Sanctions

11.1. Compliance measures. We implement reasonable, risk-based anti-money-laundering (AML), counter-terrorist-financing (CFT), and sanctions controls consistent with applicable laws via:

  • Sumsub (KYC/KYB verification)

  • Merkle Science (continuous blockchain monitoring)

11.2. Monitoring & Triggers for Action We may suspend or restrict access if:

  • Our systems (Sumsub/Merkle Science) detect irregular, high-risk, or sanctioned activity

  • We receive a lawful request, notice, or order from a competent authority (e.g., UAE Central Bank, VARA, FCA, FINTRAC, AUSTRAC, or international law enforcement)

  • A regulated counterparty VASP flags your wallet or transaction We cooperate fully with authorities and may report suspected activity without prior notice where required or permitted by law.

11.3. Non-custodial limitation. LFG does not hold user assets and therefore cannot freeze or confiscate funds. Where irregular activity is detected, we may suspend or disable access to our Services and cooperate with competent authorities.

11.4. Cooperation. We may share relevant information with regulated entities and authorities when required by law or under lawful request. We may also voluntarily report suspected misuse of our Services.

11.5. User responsibility. You must ensure that your use of the Services complies with applicable AML/CFT, sanctions, and financial-crime laws. You must not engage in activity that breaches sanctions, facilitates illicit finance, or involves high-risk jurisdictions or counterparties.

11.6. Territorial enforcement. We may restrict, suspend, or terminate access where jurisdictional restrictions apply (see §3 and the Global Availability Statement), including where we reasonably believe you are attempting to circumvent geo-controls.

12. Service Availability & Third-party Dependencies

12.1. The Services rely on blockchain networks and third-party providers (e.g., node infrastructure, cloud hosting, analytics, PSPs/EMIs, exchanges). Availability, confirmation times and data accuracy may be affected by those dependencies.

12.2. We may perform maintenance or make changes at any time. We do not guarantee uninterrupted or error-free operation.

13. Acceptable Use & Prohibited Activities

13.1. You must use the Services in compliance with applicable laws, regulations and these Terms. Prohibited uses include, without limitation:

  • money laundering, terrorist financing, sanctions evasion

  • fraud, scams, Ponzi/pyramid schemes

  • ransomware, hacking or cyberattacks

  • unlicensed gambling, illegal content, counterfeit products, weapons, narcotics

  • darknet/illicit marketplaces

  • the offering of unregistered securities or investment products

  • use of mixers, tumblers, or privacy tools to obscure beneficial ownership

  • using wallets, accounts, or funds that do not belong to you (or your business entity) in a manner that circumvents KYC, KYB, sanctions, eligibility, or any other compliance requirements, whether with or without the owner’s consent

  • or any activity prohibited under applicable law.

13.2. Misuse of Analytics or Compliance Data. You must not: - Use any analytics, risk scores, wallet labels, transaction metadata, or compliance outputs from the Services ("Analytics Data") to dox, harass, defame, discredit, or harm any individual or entity — regardless of whether the wallet belongs to you - Publish, share, disclose, or transmit Analytics Data (or any derivative claims) to any third party, in any form or medium, publicly or privately — including but not limited to social media, forums, blogs, news, messaging apps, email, documents, screenshots, APIs, AI models, or oral communication - Imply or state that LFG endorses, verifies, or guarantees the accuracy of any Analytics Data for public or third-party use - Use Analytics Data in any way that could expose LFG to legal, regulatory, or reputational risk.

Analytics Data is for internal LFG app compliance use only and not intended for public disclosure or enforcement. You must not rely on it as factual or authoritative.

14. Third-party Links & Software

14.1. The Site may contain hyperlinks or references to third party advertising and websites other than the Site. Any such hyperlinks or references are provided for your convenience only. We have no control over third party advertising or websites and accept no legal responsibility for any content, material or information contained in them. The display of any hyperlink and reference to any third-party advertising or website does not mean that we endorse that third party’s website, products or services. Your use of a third-party site may be governed by the terms and conditions of that third-party site and is at your own risk.

14.2. Any third-party software integrated into the Services may be subject to its own licence terms, which you must accept to use that software. If you do not accept such terms, you may be unable to use related features. We do not accept any responsibility for any such third-party software.

15. Data Protection & Privacy

15.1. We process personal data in accordance with UAE Federal Decree-Law No. 45/2021 and our Privacy Policy (which forms part of these Terms).

15.2. We may share limited data with service providers and compliance partners strictly to provide and secure the Services. Where data is transferred cross-border, we use appropriate safeguards as required by law.

15.3. Data Retention

  • KYC/KYB data: 5 years post-account closure (AML requirements)

  • Transaction metadata: 7 years (audit trail)

  • Backups: 90 days

15.4. Accessibility We follow WCAG 2.1 Level AA. See our Accessibility Statement.

15.5. Any personal information you provide to us as part of the registration process will be processed in accordance with our Privacy Policy available here.

16. Disclaimers; Blockchain Risks

16.1. “As is.” The Services are provided on an “as is” and “as available” basis, without warranties of any kind, whether express, implied, statutory or otherwise (including merchantability, fitness for a particular purpose, title, non-infringement, or uninterrupted/error-free operation).

16.2. No advice. Information and compliance analytics in the Services are probabilistic and do not constitute legal, tax, accounting, or investment advice. You remain responsible for your use of virtual assets and for complying with applicable laws. Compliance analytics from Merkle Science or any other partner are indicative and probabilistic only. They are not conclusive, not verified, and not a guarantee of accuracy, legality, or risk. You must not rely on them as the sole basis for any decision, action, or report. We are not liable for any loss, claim, or damage resulting from your reliance on Analytics Data.

16.3. Blockchain risks. Use of blockchain networks involves risks including (without limitation) transaction failure or delay, network congestion, front-running/MEV, forks, chain reorganisations, protocol or smart-contract bugs, slippage, and high/volatile fees. Transactions are final on their networks and cannot be reversed by us.

16.4. Stablecoin & issuer risk. Stablecoins and other tokens may de-peg, be frozen, or be impacted by issuer or regulatory action.

16.5. Third-party dependencies. Features may rely on third parties (e.g., wallets, node providers, PSPs/EMIs, exchanges, cloud/analytics). We do not control and are not responsible for their acts/omissions.

16.6. Beta features. Beta/preview features are provided as-is, may change or be withdrawn, and may have additional terms shown in-app.

16.7. Data & rates. Any prices, rates, or analytics shown are informational/indicative only and may differ from execution on underlying networks or third-party services.

17. Complaints

17.1. We acknowledge receipt of complaints within five (5) business days and aim to provide a final response within thirty (30) days. Where complexity or third-party dependencies require more time, we will update you with reasons and a revised timeframe.

17.2. The laws of the United Arab Emirates apply to these Terms, although if you are a consumer resident elsewhere, you retain the benefit of any mandatory protections given to you by the laws of your country.

17.3. Disputes

  • Consumers: You may bring proceedings in the courts of your residence or use local ADR.

  • Businesses: Subject to binding arbitration under the Rules of the Dubai International Arbitration Centre (DIAC), in English, with one arbitrator. Seat: Dubai, UAE.

17.4. For security, LFG cannot accept or process requests to recover backup words/seed phrases. If you have lost them, we cannot restore access to your wallet.

18. Liability

18.1. Non-excludable liability. Nothing in these Terms limits liability that cannot be limited under applicable law (e.g., fraud, wilful misconduct, or death/personal injury caused by negligence). If you are a consumer, any mandatory protections under applicable UAE or local consumer law prevail over inconsistent terms.

18.2. Exclusions. To the maximum extent permitted by law, we are not liable for: (a) losses caused by blockchain finality, incorrect addresses, wrong networks, missing tags/memos, lost or compromised backup words/seed phrases/keys, device compromise, or other factors outside our reasonable control; (b) third-party services’ acts/omissions; (c) indirect, consequential, special, exemplary or punitive damages; or (d) loss of profits, revenue, business, goodwill, or data, even if foreseeable.

18.3. Cap. Subject to §18.1, our aggregate liability in any 12-month period is limited to the greater of: (i) the total fees you paid to us in the six (6) months preceding the claim; or (ii) USD 500.

18.4. Your responsibilities. You are solely responsible for securing and backing up your credentials and for tax determination, reporting and remittance related to your use of the Services (see §6.14). We do not act as your tax agent or adviser.

18.5. Indemnity & Hold Harmless. You agree to indemnify, defend and hold harmless LFG (and its affiliates, directors, officers, employees and agents) from and against any and all claims, costs, damages, losses, liabilities and expenses (including reasonable legal fees) arising out of or relating to: (a) any unauthorised access to or use of your wallets, devices, backup words/seed phrases, private keys or credentials; (b) your breach of these Terms or of applicable law; (c) your misuse of the Services; and (d) any dispute between you and any counterparty. For clarity, LFG provides non-custodial software and does not hold keys or initiate, transmit, or settle transfers. Nothing in this clause limits any non-excludable rights or remedies under applicable law.

19. Force Majeure

We are not responsible for failure, delay, or interruption in the Services caused by events beyond our reasonable control, including but not limited to:

  • Failures or outages of third-party providers we rely on (e.g., AWS, Google Cloud, Merkle Science, Sumsub, Transak, Moonpay, Ramp, blockchain node providers, oracles, or payment processors)

  • Upstream failures in any infrastructure, network, or service used by our providers (e.g., global or regional cloud outages, DNS failures, CDN disruptions)

  • Public blockchain network issues (congestion, forks, 51% attacks, protocol upgrades)

  • Smart-contract bugs or vulnerabilities not created or introduced by us

  • Cyberattacks (DDoS, ransomware, supply-chain attacks)

  • Internet, power, or telecom outages

  • Acts of God, war, terrorism, civil unrest, pandemics, or labour disputes

  • Changes in law, regulation, or government action (including sanctions, licensing, or app store removals).

For clarity: This does not include theft, loss, or compromise of your private keys, seed phrases, wallets, or credentials, which remain solely your responsibility.

20. Suspension & Termination

20.1. We may suspend or terminate all or part of the Services immediately on notice if you:

  • (a) breach these Terms

  • (b) fail compliance checks

  • (c) present unacceptable risk

  • (d) are required by law or a competent authority

  • (e) we receive a lawful order or notice from a competent authority

  • (f) a regulated third-party provider (e.g., Transak, Moonpay, Ramp) suspends service to your account

You may stop using the Services at any time. Account closure or deletion: See our Account Deletion Policy for full terms, including subscription cancellation, data export, and irreversible wallet loss. Sections that by their nature should survive (e.g., liability, data, IP, governing law) survive termination.

21. Changes to These Terms

21.1. We may update these Terms to reflect changes in law, our Services or our operations. We will post the updated Terms with a new effective date. Material changes will be notified in-app or by email. If you continue using the Services after the effective date, you accept the updated Terms.

21.2. We reserve the right to vary these Terms from time to time. Our updated Terms will be displayed on the Site and by continuing to use and access the Site following such changes, you agree to be bound by any variation made by us. It is your responsibility to check these Terms from time to time to verify such variations.

22. Governing Law & Disputes

22.1. These Terms are governed by the laws of the Emirate of Dubai and the applicable federal laws of the United Arab Emirates.

22.2. We will try to resolve disputes informally within sixty (60) days. If unresolved, disputes shall be referred to binding arbitration under the Rules of the Dubai International Arbitration Centre (DIAC), in English, with one arbitrator. The seat and place of arbitration shall be Dubai, UAE — unless you are a consumer, in which case you may use local courts or ADR.

23. Using the Site

23.1. The Site and app are for your personal and/or commercial use only as applicable.

23.2. You agree that you are solely responsible for all costs and expenses you may incur in relation to your use of the Site.

23.3. We make no promise the Site or app is appropriate or available in any location outside of the permitted jurisdictions listed in the Global Availability Statement. If you access the Services from any other location, you do so at your own initiative and must comply with local laws. We may block access where use would be unlawful or non-compliant.

23.4. We try to make the Site and app as accessible as possible. If you have any difficulties using the Site, please contact us using the contact details at the top of this page.

23.5. As a condition of your use of the Site and app, you agree not to: 23.6. Misuse or attack our Site or app by knowingly introducing viruses, trojans, worms, logic bombs or any other material which is malicious or technologically harmful (such as by way of a denial-of-service attack), or 23.7. Attempt to gain unauthorised access to our Site or app, the server on which our Site is stored or any server, computer or database connected to our Site.

23.8. We may prevent or suspend your access to the Site or app if you do not comply with these Terms or any applicable law.

23.9. Termination by You: You may terminate this Agreement by ceasing to use the Service and closing your account, subject to any outstanding payment obligations.

23.10. Termination by the Company: The Company may terminate this Agreement or suspend your access to our Services at any time, with or without cause or notice.

24. Infringing Content

24.1. We will use reasonable efforts to: 24.1.1. Delete accounts which are being used in an inappropriate manner or in breach of these Terms; Identify and remove any content that is inappropriate, defamatory, infringes intellectual property rights, when we are notified, but we cannot be responsible if you have failed to provide us with the relevant information.

24.2. If you believe that any content which is distributed or published by the Site is inappropriate, defamatory or infringing on intellectual property rights, you should contact us immediately using the contact details at the top of this page.

25. User Content & Licence

25.1. Ownership. You retain ownership of any content, data, text, images, logos, wallet labels, payment requests, metadata, tickets, and other material you submit or upload to the Services (“User Content”).

25.2. Licence to LFG (to operate the Service). You grant LFG a non-exclusive, worldwide, royalty-free, transferable and sublicensable licence to host, use, reproduce, modify, adapt, store, back up, and display your User Content solely to operate, provide, maintain, secure, support and improve the Services (including troubleshooting, abuse prevention, quality assurance, and feature development). We do not sell personal data and we do not use User Content for advertising unrelated to the Services.

25.3. Aggregated/De-identified data. We may create and use aggregated or de-identified data derived from User Content and Service usage for analytics, security, and Service improvement. We will not re-identify such data.

25.4. What you promise. You represent that you have all rights and a lawful basis to provide the User Content to us and that it does not infringe any rights or violate law. Do not upload third-party personal data unless you have a lawful basis to do so under applicable law.

25.5. Removal; retention. You may delete User Content via the Services where supported. After deletion, we stop using it for active processing, except that copies may persist in backups, logs or audit records for a limited time and where required by law or for the establishment, exercise or defence of legal claims.

25.6. Feedback. If you provide ideas or suggestions (“Feedback”), you grant LFG a perpetual, irrevocable, worldwide, royalty-free licence to use the Feedback without restriction or compensation to you (this does not authorise use of your trademarks without permission).

25.7. Marketing logos (optional). With your prior consent, we may use your name and logo to identify you as an LFG user on our Site and marketing materials; you may withdraw consent at any time.

26. No third party rights, entire agreement

26.1. No one other than us or you has any right to enforce any of these Terms.

26.2. Entire Agreement: This Agreement constitutes the entire agreement between you and the Company and supersedes any prior or contemporaneous negotiations or agreements, whether oral or written, relating to the subject matter hereof.

26.3. Modifications: The Company reserves the right at any time to modify this Agreement and to add new or additional terms or conditions on your use of the Services. Such modifications and additional terms and conditions will be effective immediately and incorporated into this Agreement. Your continued use of the Services will be deemed acceptance thereof.

26.4. Severability: If any provision of this Agreement is held to be invalid or unenforceable, the remaining provisions shall continue to be fully valid and enforceable permitted by law.

27. Variation

27.1. No changes to these Terms are valid or have any effect unless agreed by us in writing or made in accordance with this clause.

27.2. We reserve the right to vary these Terms from time to time. Our updated Terms will be displayed on the Site and by continuing to use and access the Site following such changes, you agree to be bound by any variation made by us. It is your responsibility to check these Terms from time to time to verify such variations.

28. Contact Us

28.1. Questions or complaints: [email protected] or Level 17, Sheikh Rashid Tower, Dubai World Trade Centre, Dubai, UAE.

29. Definitions (Extract)

  • LFG-verified user: a user who has passed our eligibility and KYC/KYB/AML checks.

  • Consumer user: an individual using the Services wholly or mainly outside the course of a trade, business or profession.

  • Business user: a legal entity or sole proprietor using the Services for business purposes.

  • Merchant: a Business user that receives payments for goods or services via the Services.

  • Sumsub: KYC/KYB provider

  • Merkle Science: Blockchain compliance and monitoring provider

  • Transak / Moonpay / Ramp: Licensed third-party on/off-ramp providers

  • Travel Rule: information-sharing requirements applicable to certain virtual-asset transfers (pass-through facilitation only)

  • Global Availability Statement: LFG’s public document setting out where the Services are available, as updated from time to time and incorporated into these Terms.

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