> For the complete documentation index, see [llms.txt](https://help.getlfg.app/p/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://help.getlfg.app/p/agreements/terms-of-service.md).

# Terms of service

**Effective date: 13th September 2026**

## 1. Who we are and this agreement

1.1 These Terms govern the website, applications and software services provided by **Layer Flow Gateway, Inc.**, a Delaware corporation, Delaware File No. 10054149, incorporated on 2 January 2025 (LFG, we, us). Our registered office is **131 Continental Dr, Suite 305, Newark, DE 19713, United States**. Legal enquiries: **<legal@getlfg.app>**. Support: **<support@getlfg.app>**.

1.2 You accept these Terms when you create an account or otherwise expressly accept them. A person opening a business account must have authority to bind that business. A consumer is a person acting outside their trade, business or profession; selecting an account label does not remove mandatory consumer rights.

1.3 Our [Global Availability Statement](https://help.getlfg.app/p/global-availability-statement) and [Account Deletion Policy](https://help.getlfg.app/p/agreements/account-deletion) supplement these Terms. Our [Privacy Policy](https://help.getlfg.app/p/agreements/privacy-policy), [Cookie Policy](https://help.getlfg.app/p/agreements/cookie-policy), [Regulatory Position Statement](https://help.getlfg.app/p/agreements/regulatory-position-statement) and [Integrated Service Providers](https://help.getlfg.app/p/agreements/integrated-service-providers) explain the service and its dependencies. Accepting these Terms does not constitute consent to optional tracking or biometric processing.

1.4 A signed business order or service agreement prevails over these Terms to the extent of a specific conflict. It cannot remove rights that the applicable law makes mandatory. For other inconsistencies, these Terms govern contractual matters, the Availability Statement governs eligibility, and the Privacy Policy governs our description of personal-data processing.

## 2. What LFG provides

2.1 LFG supplies software for eligible individuals and businesses to manage user-controlled wallets, create payment requests, send and receive supported digital assets, access enabled third-party integrations and use available business and risk-screening tools. Personal accounts are currently free. Business features require the relevant paid subscription.

2.2 Customer wallets are non-custodial. LFG does not hold customer assets for safekeeping and does not possess customer wallet keys in a form that allows LFG to use them independently. For wallets using the current backup feature, LFG stores a device-encrypted backup that it cannot decrypt independently. The backup and recovery limitations in section 4 apply.

2.3 Customers approve and sign their ordinary wallet transactions through their devices. Web3Auth wallet infrastructure handles the signing flow and broadcast without giving LFG independent signing authority. For enabled swaps, 1inch returns the route and transaction data directly to the customer; the customer reviews and signs every swap. LFG does not select an execution route, receive or transmit a customer order, sign or broadcast the customer’s swap, or operate discretionary trading for the customer.

2.4 There is one separate collection arrangement: a business customer can pre-authorise scheduled payments of **LFG’s own software subscription fees** under section 6. The wallet infrastructure may broadcast a valid, user-signed authorisation for the agreed fee. LFG cannot sign, change the amount or recipient, or use it to make the customer’s payments to other people. LFG does not presently offer recurring payments of customers’ third-party bills.

2.5 LFG is not a bank, deposit account, investment adviser, token issuer or insurer of customer assets. Software usage allowances have no cash value and cannot be transferred, redeemed or exchanged. Receiving LFG’s own earned subscription fees is distinct from holding assets for customers.

2.6 Features shown for development, preview or future release are not included in the current service unless expressly enabled and described to you. In particular, there is no promise that future social recovery will become available or recover a wallet whose access has already been lost.

## 3. Eligibility and account access

3.1 You must be at least 18, have capacity to contract, and satisfy the country and customer-type requirements in the Availability Statement. An eligible company must be represented by an authorised adult. Personal accounts must not be used to bypass business verification or subscription requirements.

3.2 LFG requires identity verification for individuals and business verification for businesses before activation. We use Didit for this process. We may require information about the business, its representatives and beneficial owners, and may perform subsequent eligibility and risk checks. A paid business account also requires successful subscription payment. Verification is not a guarantee that a user or their transactions are safe, lawful or creditworthy.

3.3 A third-party provider may require its own verification and may refuse an otherwise eligible LFG customer. Passing LFG verification does not confer a right to a provider account, fiat purchase, off-ramp or bank payout.

3.4 Give accurate information and promptly update material changes to your residence, business registration, principal operations, authorised representatives and beneficial ownership. Use accounts and funds you own or are lawfully authorised to use for the verified business. Do not misrepresent the customer, location or purpose of a transaction.

3.5 Do not evade geographic, sanctions, verification, feature or customer-type restrictions, including by using a VPN or proxy to conceal ineligibility. Restrictions may depend on more than an IP address. A nationality-based provider restriction applies where specifically stated; it is not a general rule that every holder of a nationality is excluded from all LFG software.

3.6 Keep login credentials secure and tell us promptly about suspected account misuse. Your responsibility for activity depends on your authorisation, conduct and applicable law; you are not automatically responsible for a security failure caused by LFG.

3.7 The Global Availability Statement records the countries, customer types and feature conditions that LFG supports when that Statement is published or updated. Eligibility is a continuing condition of using the Services, not a permanent or grandfathered right. Laws, sanctions, regulatory requirements, provider coverage, security risks and LFG’s supported operations can change after an account is opened.

3.8 If LFG discovers a material error in its published availability information, it will correct the Statement promptly and deal fairly with affected users under section 12. An eligibility statement does not override applicable law or make an otherwise prohibited service lawful.

3.9 LFG is available to eligible personal and business users in the countries and territories listed in the Global Availability Statement, currently covering **92 markets**, including all 50 United States and Washington, DC. A market is listed as eligible or excluded; provider-specific feature availability does not change the underlying software-account classification.

3.10 **Cryptoassets are not local legal tender.** LFG does not represent USDC, USDT or any other supported cryptoasset as government-issued currency or legal tender in any market.

## 4. Wallet backups, recovery and loss of access

4.1 **Keep a secure, usable backup for every wallet before relying on it to hold assets.** This includes an ordinary wallet and the **LFG Vault** used for business subscriptions. Save the complete recovery material offered for that wallet, such as its recovery phrase or exported private key, together with any account or network information needed to restore it. One exported private key should not be assumed to recover every other wallet or address.

4.2 Protect your backup from loss and unauthorised access. Anyone who obtains usable recovery material may be able to control the associated assets. LFG support will never ask you to send a recovery phrase or private key by email, chat, a support ticket or a verification upload.

4.3 A login, identity-verification record or encrypted server backup is **not a substitute for your independent backup**. LFG cannot independently decrypt the server backup or reconstruct your wallet from your email address, KYC record or proof of identity. Passing KYC again, receiving an email code or opening a new account does not give LFG a wallet-recovery capability.

4.4 If the device, app or required local data is lost, damaged, reset or removed and you have not independently retained the complete recovery phrase or appropriate private key, LFG cannot recover the wallet for you. Your access to the associated wallet and its funds will be permanently lost unless you already control that wallet independently. Funds can remain on the blockchain while being inaccessible to you.

4.5 Before uninstalling or deleting the app, removing its local data, replacing or resetting your device, or closing your account, export and test the necessary recovery material for **each** relevant wallet, or transfer the assets to a wallet you already control independently. This includes every ordinary wallet and the LFG Vault. Simply copying a wallet address does not back up its private key.

4.6 Account closure permanently removes access to the LFG account and deletes its active account-linked encrypted backup. LFG cannot then reactivate that account, reconstruct its wallets or retrieve their keys. Closure does not automatically transfer assets, close a blockchain address or reverse transactions. The service may permit closure while a wallet still has a balance; the absence of a balance warning does not mean a wallet is empty. Uninstalling alone does not close the LFG account or cancel a subscription, but deleting the app or required device data can permanently remove wallet access.

4.7 You bear loss caused solely by your failure to preserve or secure a usable backup, or your informed decision to remove access despite the warnings, to the extent permitted by applicable law. This allocation does not exclude LFG’s responsibility for its own breach, misleading recovery information, defective functionality for which it is responsible, or liability that cannot lawfully be excluded. Section 14 applies.

## 5. Transfers, supported assets and blockchain risks

5.1 The Services can support payment requests and user-directed transfers between eligible LFG users and, where enabled, external self-hosted wallets that you own or are authorised to use. Availability is subject to verification, risk checks, limits, network support, provider rules and applicable law.

5.2 You initiate and sign ordinary transfers from wallets you control. Web3Auth wallet infrastructure handles the signing flow and broadcast. LFG does not hold, receive, transmit, broadcast or settle customer assets on your behalf and cannot independently sign from your wallet. The user-signed authorisations for LFG’s own business-subscription fees are described separately in section 6 and are not authority to make other transfers.

5.3 Payments through LFG may use **USDC or USDT** on the networks enabled in the app, subject to the following launch restriction: for customers in the **European Union or European Economic Area, USDT payments and swaps into USDT are disabled**, so payments there are USDC-only. In all other eligible countries, payments may be made in either USDC or USDT where the relevant asset and network are enabled. Bridged USDbC is not supported for payments. Feature and provider availability may be narrower.

5.4 The app’s supported asset and network list governs the interface. LFG does not presently support adding custom token addresses. A similarly named token, a token on another network or an externally visible balance is not necessarily supported. Token availability does not constitute an investment recommendation or confirmation of unrestricted use under local law.

5.5 Review the recipient, amount, asset, network, provider quote, fees, any memo or reference and any displayed minimum receipt before signing. You are responsible for entering and checking transaction instructions, except to the extent an error is caused by LFG or another responsible party. Network fees may require a separate network asset. Do not assume that a USDC balance alone is sufficient to send every transaction.

5.6 Blockchain transactions, approvals and signatures can have irreversible consequences. A pending transaction may fail, remain pending or be replaced, and a confirmed transfer may be irreversible. LFG cannot undo a confirmed transfer or guarantee recovery of a transfer sent to an incorrect or incompatible destination. A provider’s refund obligation, or LFG’s responsibility for its own error, is not removed merely because a blockchain transfer is irreversible.

5.7 Public-blockchain and token risks include transaction failure or delay, congestion, front-running or maximal-extractable-value effects, forks, chain reorganisations, protocol changes, malicious approvals, smart-contract defects or exploits, changing network fees and slippage. Stablecoins and other tokens can lose their expected value, become illiquid, or be restricted, frozen or affected by issuer, protocol or regulatory action. LFG does not guarantee redemption, a fixed value, deposit protection or compensation for token losses.

5.8 Prices, rates, estimated fees, risk information and network data shown in the Services are informational or indicative until the applicable transaction is confirmed. They can come from public networks or Third-Party Providers and can be delayed, incomplete or different from final execution. This does not excuse an inaccurate fee or representation for which LFG is legally responsible.

## 6. Business subscriptions and cancellation

6.1 Each business account has an **LFG Vault**, a non-custodial wallet for receiving business payments and paying LFG subscription fees. You alone control the private keys for your LFG Vault. LFG does not hold or control its balance. Before subscription confirmation, we disclose the selected plan, monthly USDC fee, applicable taxes, first collection, next billing date and the scope of the requested payment authorisations. Personal accounts currently have no LFG subscription fee; third-party and network charges can still apply.

6.2 The first and all later business subscription payments are collected in USDC from your LFG Vault. When you confirm the subscription, you authorise the first payment and establish the automatic subscription payment arrangement described below. The first payment is collected at confirmation. Later payments are collected monthly on the billing dates shown in the app.

6.3 The automatic subscription payment arrangement uses EIP-3009 user-signed payment authorisations; it is not a bank direct debit or Coinbase Spend Permissions. The current arrangement uses up to six pre-authorised billing cycles, as shown when you confirm. Each authorisation specifies the LFG Vault as the source wallet and fixes the amount, recipient and validity window for one billing cycle. The wallet infrastructure may broadcast a valid authorisation for the corresponding subscription fee without asking for a fresh signature at that collection time. LFG cannot independently sign or broadcast it, take a different amount, pay a different recipient or collect outside its validity window.

6.4 You are responsible for keeping enough supported USDC in your LFG Vault on each billing date. You may fund the LFG Vault by receiving eligible business payments through LFG or by transferring supported USDC to it through an available lawful route. LFG does not automatically purchase USDC or move funds from another wallet to cover the fee. A plan change, additional charge or billing cycle beyond the signed authorisations requires a suitable fresh authorisation. We will tell you when a new authorisation is required to continue the subscription.

6.5 Monthly subscriptions continue subject to cancellation, an available valid authorisation and payment. The app shows the next billing date. You can cancel in your account at any time before the next collection is submitted. If account access is unavailable, contact <support@getlfg.app>; we will use proportionate identity checks and record the time of your cancellation request.

6.6 **Cancellation stops future subscription collections and queued retries that have not already been broadcast to the blockchain.** Account closure also cancels the LFG subscription. We stop the billing process from requesting broadcast of remaining authorisations. Cancellation does not reverse an already-broadcast transaction. A charge broadcast in error after a timely cancellation will be corrected or refunded; statutory remedies remain available.

6.7 Cancellation of the subscription and cancellation of a cryptographic authorisation are different. The current LFG service does not provide or promise an independent, external signature-revocation facility. A previously signed authorisation may remain technically valid until used, expired or effectively cancelled on-chain where the relevant contract supports that. This does not permit LFG to keep collecting after cancellation. Protect signed authorisation data as sensitive information.

6.8 Following cancellation, paid features normally remain available until the end of the period already paid for. If you also close the account, account access ends on closure. Amounts lawfully due for services already supplied remain payable, but cancellation does not permit further automatic retries under the cancelled subscription.

6.9 If a scheduled renewal fails because of insufficient funds, LFG may retry during the **three calendar days following that renewal’s due time**. The **14-calendar-day grace period runs from the same unpaid renewal due time**, not from the end of the retry period. If payment remains outstanding at the end of that grace period, paid access may be suspended. A later renewal requires valid payment arrangements. We will not collect twice for the same period or retry after cancellation. Removing the app does not stop this schedule.

6.10 The subscription price, third-party purchase price, network fees and any provider charges are separate. We disclose LFG taxes and charges before confirmation and handle taxes we must collect. You are responsible for your own transaction and business taxes. The Terms do not transfer LFG’s tax obligations to you.

6.11 We give at least 30 days’ advance notice of an increase in LFG’s recurring fee. It applies no earlier than an appropriately notified renewal and, where needed, a fresh payment authorisation. You may cancel before it takes effect. Plan changes and any prorated charge are shown for agreement before they apply.

6.12 Business fees already earned for a supplied billing period are normally non-refundable if you simply change your mind. This does not exclude refunds for an erroneous charge, a service failure giving a right to refund, termination by LFG for its own convenience, or any mandatory legal right. Provider refunds are governed by the relevant provider’s terms and applicable law.

6.13 There are currently no paid personal subscriptions. Before introducing them, we will provide the applicable consumer price, renewal, cancellation and withdrawal disclosures and any required consent for immediate performance. No general acceptance of these Terms waives a consumer cooling-off period or other statutory remedy.

6.14 **Your taxes:** you are responsible for determining, reporting and paying taxes, duties and similar public charges arising from your own virtual-asset activity and, for a business user, its underlying sales, payroll, income, gains and business operations. This can include keeping invoices and applying any withholding or indirect-tax rules that apply to you. You are not made responsible for a tax that the law imposes on LFG.

6.15 **LFG taxes and price disclosure:** LFG remains responsible for taxes imposed on LFG and for collecting, reporting or remitting any tax that applicable law requires LFG to handle in connection with its own supply. Any tax added to an LFG charge will be identified before you confirm where required.

6.16 **No tax or professional advice:** LFG does not act as your tax agent, accountant, lawyer, financial adviser or fiduciary. Information in the Services is general operational information and is not advice for your circumstances. Obtain professional advice where needed.

6.17 **Records and third-party data:** transaction histories, CSV files, invoices and dashboard summaries are provided for convenience and may use information from public networks or Third-Party Providers. You must check them against your own records and the relevant network or provider evidence. LFG does not promise that a particular export satisfies every accounting, tax or regulatory filing rule, but remains responsible for correcting its own records where required by law or these Terms.

6.18 For business users only, a third-party claim, fine or penalty caused by the business’s material breach of its own tax obligations may fall within the limited indemnity in section 14.4, but only to the extent recovery is lawful. This does not make a consumer indemnify LFG, cover LFG’s taxes or fault, or prevent a user from challenging an incorrect assessment.

## 7. Swaps, on-ramps and off-ramps

7.1 The current integrations are 1inch for enabled user-operated swaps; Coinbase, Transak and MoonPay for enabled on-ramps; and OwlPay/Harbor for enabled off-ramps. A brand name does not identify a single legal entity or one worldwide permission. The applicable entity, product terms and eligibility are identified in the relevant provider journey.

7.2 A provider’s service is subject to its own agreement with you, verification, restrictions, quote and fees. You choose whether to use it. LFG does not promise acceptance, availability of a payment method, a particular exchange rate or delivery to every bank. We remain responsible for our own contractual obligations and for our own interface and representations where required by law.

7.3 **Swaps:** the current integration uses the 1inch Classic Swap Aggregation API. It does not use Fusion or limit-order execution. 1inch returns the route and transaction data directly to you; you review and sign every swap using your wallet, and Web3Auth wallet infrastructure handles the broadcast. LFG does not receive or transmit the order, select the route, sign or broadcast the swap. LFG’s swap fee is currently disabled and LFG receives no transaction-based compensation from swaps or payments. Network costs and any applicable third-party costs or price effects may still apply. A future LFG swap fee would require advance disclosure and any necessary eligibility changes before use.

7.4 **On-ramps:** buying USDC through Coinbase, Transak or MoonPay is separate from acquiring LFG software. Each provider decides whether it supports your location, customer type, chosen asset, network and payment method. A provider’s acceptance of personal purchases does not establish acceptance of company funds or a business customer. Apple Pay or Google Pay, if offered by a provider, is a payment method within that provider’s purchase flow, not the present mechanism for LFG’s recurring billing.

7.5 **Off-ramps:** Owl/Harbor performs its own onboarding and compliance checks. Business verification in that process uses Sumsub under Owl’s arrangements. You transfer from your own wallet to the destination provided by Owl. Owl and its relevant counterparties provide the conversion and bank payout under their terms. LFG is not the sender purchasing that service on your behalf.

7.6 **Owl fee and LFG commission:** Owl’s current customer off-ramp fee is **0.50% of the off-ramped amount**, as shown before you confirm the transaction. LFG receives a referral commission from Owl out of that fee. The commission does not increase the 0.50% fee charged to you. Any separate network, bank, foreign-exchange or other cost will be shown in the applicable transaction quotation. Our commercial relationship with Owl may influence our decision to make its service available through LFG.

7.7 Owl has told LFG that Harbor currently cannot onboard **EU-citizen individual senders or EU-incorporated business senders**. Its ability to send a payout to an EU bank account through SEPA or SEPA Instant does not change that sender restriction. Other sender categories, including EEA and residence/citizenship combinations, require provider confirmation before the feature is offered.

7.8 Availability of an external provider outside LFG does not establish availability of its LFG integration. You must not use a false personal or business classification, an intermediary account or a different person’s verification to bypass a restriction. LFG’s software restrictions do not authorise a transaction otherwise prohibited by law.

7.9 **United Kingdom communications:** the United Kingdom is an eligible LFG software market. UK-facing communications and onboarding remain subject to applicable financial-promotion requirements. An API link, a provider’s FCA registration or a provider’s separate promotion does not by itself approve LFG’s own communication.

## 8. Verification, monitoring, Travel Rule and legal compliance

8.1 LFG applies proportionate identity, business, wallet and transaction-risk controls to administer accounts, protect the Services and help prevent fraud, money laundering, terrorist financing, sanctions breaches and other misuse. Controls may be automated or reviewed by authorised personnel and providers. Their use does not state that LFG is a bank, money transmitter, CASP or VASP, or that every control is imposed on LFG by an AML law.

8.2 Controls can include KYC or KYB, sanctions and adverse-risk screening, public-blockchain analytics, account-security monitoring and checks requested by an enabled provider. LFG may make further enquiries about a user, wallet, source or purpose of funds, recipient, transaction or business activity where reasonably necessary for these purposes.

8.3 We may suspend, limit or terminate an affected feature or account where a user fails a required check, a credible risk or prohibited use is detected, a regulated counterparty or provider rejects or flags the activity, or law or a competent authority requires action. Section 12 governs proportionality, notice and review. An LFG restriction affects access to LFG software; because LFG has no customer keys, it does not itself freeze or confiscate assets in a user-controlled wallet. A provider, token issuer or authority may have separate powers.

8.4 Scores and alerts can be incomplete or wrong. They are not a determination that a person committed an offence or that a transaction is lawful. Do not use an LFG-verified status as a guarantee or regulatory approval. If a verification or risk decision prevents access, you can request an explanation and review through <legal@getlfg.app>. Where a Didit result needs reconsideration, we arrange review through its available human-review process and reconsider the associated LFG restriction as appropriate. We may withhold particular information where disclosure is lawfully restricted.

8.5 **Travel Rule information:** when an enabled regulated provider or counterparty requires originator, beneficiary or self-hosted-wallet information for a transaction you choose, you authorise LFG to request the minimum information needed and transmit it securely to that provider or counterparty as a technical pass-through. Where the integration returns corresponding compliance information to LFG, LFG may receive and pass it for the same purpose. The applicable provider decides whether its requirements are met.

8.6 Section 8.5 is conditional on the applicable integration. LFG does not promise a universal Travel Rule service, apply one worldwide threshold, or represent that it is the ordering, intermediary or beneficiary VASP merely because its interface transmits information. If required information cannot be obtained or validated, LFG may prevent use of the relevant integration or restrict the affected transaction or account.

8.7 We assess legal demands and may preserve or disclose relevant records where lawfully required or otherwise lawfully justified. We may report suspected illegal, sanctioned or fraudulent activity where required or permitted by applicable law and cooperate with competent authorities and regulated counterparties. We may be legally prohibited from telling you about a report, investigation or restriction. Nothing in these Terms gives a private party authority to demand customer records without a valid basis.

8.8 You must provide accurate compliance information and must not use the Services to evade applicable AML/CFT, sanctions, tax, reporting or licensing rules. You remain responsible for the legality of your own activity. LFG remains responsible for the controls, disclosures and reports that applicable law places on LFG.

## 9. Acceptable use and business responsibilities

9.1 Do not use LFG for fraud, money laundering, terrorist financing, sanctions evasion, unauthorised access, illegal goods or services, unlicensed regulated activity, or deception about the identity or authority of a payer, payee or merchant. Do not introduce malicious code, attack the service, circumvent security controls or infringe another person’s rights.

9.2 Business users remain responsible for their underlying goods and services, customer disclosures, invoices, taxes, refunds, authorisations and local trading requirements. LFG is not a party to a sale between a business and its customer. A dispute about that sale does not authorise either party to interfere with LFG systems.

9.3 Use screening and analytics for their stated operational purpose. Do not use them to harass, dox, defame or present an unverified allegation as fact. You may provide relevant information confidentially to professional advisers, competent authorities, counterparties where necessary and lawful, or as required by law. Nothing prohibits protected reporting, obtaining legal advice or exercising a legal right.

## 10. Data, content and software rights

10.1 You retain ownership of content you supply. You grant LFG the limited rights needed to host, process and display it to operate, secure and support the service, using providers where necessary. This does not authorise unrelated advertising, sale of personal data or use of identity images for model training. Personal-data processing remains subject to the Privacy Policy and applicable law.

10.2 Provide third-party information only when you have the necessary authority and lawful basis. Tell business representatives, beneficial owners and other relevant individuals about the applicable privacy information. Where a particular business feature makes LFG a processor of your customers’ personal data, the applicable data-processing agreement must be in place; these Terms alone do not replace it.

10.3 LFG and its licensors retain their rights in the software and branding. Subject to these Terms, you may use the software for your permitted personal or business activities. Do not reproduce, resell or reverse engineer it except with permission or to the extent the law grants a right that cannot be excluded. Separate open-source licences continue to apply to the relevant components.

10.4 We use a business’s name or logo in customer marketing only with permission. Feedback may be used to improve the service, but this does not grant permission to disclose personal or confidential information.

## 11. Disclaimers, service standards, changes and events beyond control

11.1 Subject to the express commitments in these Terms and rights that cannot lawfully be excluded, the Services are supplied on an **as-available** basis. LFG will provide its services with reasonable care and skill and honour applicable mandatory requirements. We cannot promise uninterrupted or error-free operation or control of public networks and independent providers. We will take reasonable steps to address failures for which we are responsible.

11.2 Information, screening scores and compliance analytics in the Services are indicative and probabilistic. They can be incomplete, delayed or wrong and do not constitute legal, tax, accounting or investment advice, a credit assessment or a guarantee that a person or transaction is lawful. Do not rely on them as the sole basis for a consequential decision or report. This does not exclude LFG’s responsibility for an inaccurate representation or defective service where applicable law makes LFG responsible.

11.3 Features can depend on public blockchains, smart contracts, wallet and node infrastructure, cloud hosting, identity and screening services, notification and diagnostic providers, and independent on-ramp, off-ramp and swap providers. LFG does not control those independent services and is not responsible for their independent acts or omissions merely because an integration exists. LFG remains responsible for its own selection, integration, instructions, security, statements and contractual performance to the extent required by law.

11.4 A beta, preview or experimental feature will be identified as such. It may change, be interrupted or be withdrawn and may have additional terms shown before use. Labelling a feature as beta does not exclude a mandatory duty or remedy.

11.5 We may make changes for security, law, compatibility, maintenance or service improvement. For a material adverse change to a paid service, we give reasonable advance notice, normally at least 30 days where feasible, and explain the available cancellation and refund rights. Urgent legal or security changes may take effect sooner, with notice when lawful and practicable.

11.6 An event beyond LFG’s reasonable control can include a material outage or failure of an independent provider or upstream internet, DNS, cloud, banking or telecommunications infrastructure; public-blockchain congestion, fork, reorganisation, attack or protocol change; a major external cyberattack or supply-chain event; war, terrorism, civil unrest, natural disaster, pandemic or labour disruption; or an unforeseeable legal, sanctions, regulatory or app-distribution action. This applies only to the extent the event actually prevents or delays performance despite reasonable precautions.

11.7 During such an event, LFG will take reasonable steps to limit disruption, protect users and resume the affected service. The event does not excuse payment already properly due, a failure caused by LFG’s lack of reasonable care, or any remedy the law does not allow us to exclude. Loss or compromise of your own keys or recovery material is governed by section 4 and is not automatically an event excusing either party.

11.8 Contact support if you need help accessing the service or its information. Applicable accessibility duties remain LFG’s responsibility. This agreement does not assert an independently verified technical accessibility certification.

## 12. Suspension, termination and account closure

12.1 We may suspend, restrict or terminate all or part of the Services proportionately if: you materially breach these Terms or an applicable business agreement; an initial or ongoing KYC, KYB, eligibility or security check is not completed or passed; a subscription is unpaid; your activity presents a credible legal, sanctions, financial-crime, fraud or security risk; a competent authority lawfully requires action; or an integrated provider suspends the relevant service or flags the account or activity as non-compliant.

12.2 Action may be immediate where delay or advance notice would create a material risk, frustrate a lawful investigation or breach a legal restriction. Otherwise, we give reasonable notice where practical. We give a reason and a meaningful review route where lawful, and limit the restriction to what is reasonably necessary. We may be prohibited from disclosing particular information.

12.3 An account restriction affects access to LFG software and integrations. LFG does not hold customer assets or usable customer keys and therefore cannot itself freeze, confiscate or reverse assets held in a user-controlled wallet. You can use a valid independent backup to control that wallet outside LFG, subject to the blockchain, token issuer and any other applicable restrictions.

12.4 If LFG terminates a paid service for its own convenience, we normally give at least 30 days’ notice and refund prepaid fees for the unused period. We do not retain payment for an unprovided service merely because its provider is unavailable. Different remedies may apply to a termination caused by your material breach, subject to law.

12.5 You may cancel a subscription or close the account through the available account controls, or contact support when access is unavailable. Read the Account Deletion Policy and preserve wallet backups and required records first. Closing the account is not conditional on emptying a wallet or waiving a legal claim.

12.6 When you confirm **Close account**, LFG first records cancellation of the LFG subscription and prevents the billing process from requesting broadcast of unused subscription authorisations or queued retries. Only after that cancellation step succeeds does the closure process deactivate the account and delete active account-linked recovery material. If the cancellation step fails, account closure does not complete and you are directed to support. A transaction already broadcast to the blockchain before cancellation may still complete.

12.7 Closure ends account access and applies the Privacy Policy’s deletion and justified-retention rules. LFG will provide a reasonable opportunity to export available records and recovery material before a planned termination where lawful and feasible. Keep an independent wallet backup in any event. Required retention does not preserve the account as an active wallet-recovery service or permit LFG to keep using a cancelled payment authorisation.

12.8 **Change in country, customer-type or feature availability:** LFG may withdraw an account type, feature or the Services from a country or customer category where reasonably required by a change in law, sanctions, regulatory or court action, provider coverage, a material security or financial-crime risk, or a decision to discontinue the relevant operation. No user is entitled to continue an unsupported or unlawful service merely because it was available when the account was opened.

12.9 Where lawful and practicable, LFG will notify an affected user on a durable medium reasonably before the restriction takes effect, identify the affected service and effective date, and explain the available export, cancellation and refund arrangements. For a planned commercial discontinuation, notice will normally be at least 30 days. LFG may act immediately where advance notice would breach law, sanctions or a lawful direction, create a material security or financial-crime risk, or be legally prohibited. In that case, LFG will provide notice and an explanation as soon as legally permitted and practicable.

12.10 If an availability change ends a paid LFG service, **LFG—not the user—will cancel the affected subscription**, prevent the billing process from requesting broadcast of unused EIP-3009 authorisations and queued retries, and stop future subscription collections. The user does not have to suspend the payments separately. A blockchain transaction validly broadcast before cancellation may still settle and cannot necessarily be reversed on-chain. Unless termination results from the user’s material breach, LFG will refund any LFG subscription fee collected for a period after access ends, including the relevant unused part of a prepaid period, subject to mandatory law.

12.11 Before planned access ends, LFG will provide a reasonable opportunity, where lawful and technically feasible, to export available account records and the recovery material made available for each wallet, or to transfer assets using the user-controlled wallet. Because an immediate legal or security restriction may prevent an additional export period, users must keep independent wallet backups at all times. After LFG access ends, a user who has retained the complete recovery phrase or appropriate private keys can control the wallet through compatible independent software and transact elsewhere where legally permitted. LFG cannot recover the wallet or keys for the user after closure or deletion as explained in section 4 and the Account Deletion Policy.

## 13. Consumer rights and disputes

13.1 Contact <support@getlfg.app> for service assistance or <legal@getlfg.app> for a complaint. We aim to acknowledge complaints within five business days and respond substantively within 30 days. If more time is needed, we explain why and provide an update. Shorter statutory deadlines prevail. You do not have to complete this process before using a right to complain to a regulator or bring a claim.

13.2 Delaware law governs this agreement, subject to mandatory law. For a consumer, this choice does not remove the protections of the country whose mandatory consumer law applies. Consumer rights are not lost merely because eligibility is disputed, the account is free or the user is located in a restricted country.

13.3 Business disputes are subject to the competent state or federal courts in Delaware, except where mandatory law requires otherwise or a signed agreement validly specifies a different forum. Consumers may use the courts available to them under mandatory law, including their home courts where that right applies. There is no mandatory consumer arbitration or class-action waiver in these Terms.

## 14. Responsibility and limits of liability

14.1 Nothing excludes or limits liability that cannot lawfully be excluded or limited, including liability for fraud, fraudulent misrepresentation, wilful misconduct or death or personal injury caused by negligence where applicable. Statutory data-protection and consumer remedies remain available.

14.2 **Consumers:** LFG is responsible for losses for which applicable law makes it responsible, including reasonably foreseeable loss caused by its breach or failure to use the required care and skill. No general monetary cap or blanket exclusion of digital-asset loss is imposed on consumers by these Terms. LFG is not responsible for a loss caused solely by a risk properly allocated to the user, such as loss of a usable backup despite clear warnings, where LFG has not caused or contributed to that loss through a breach or other actionable fault.

14.3 **Businesses:** subject to section 14.1 and any applicable mandatory restriction, LFG is not liable for indirect or consequential losses, or loss of anticipated profits or business opportunities. Its aggregate contractual liability for claims arising in a 12-month period is capped at the greater of the LFG subscription fees paid in the six months preceding the first event giving rise to the relevant claim and USD 500. This cap does not restrict an obligation to return an unauthorised charge or pay an agreed refund. LFG’s own responsibility must still be determined on the actual facts.

14.4 A business must reimburse LFG for reasonable loss from a third-party claim to the extent caused by that business’s unlawful use, infringement of rights or material breach. This obligation does not cover LFG’s own fault. LFG must give reasonable notice, cooperate and allow appropriate participation in the defence; it cannot agree a settlement imposing an obligation on the business without its consent. This indemnity does not apply to consumers.

## 15. Changes and general provisions

15.1 We may update these Terms for a stated legal, security, operational or product reason. We will explain material changes and normally give at least 30 days’ advance notice, except where an urgent legal or security need requires a shorter period. Changes do not retrospectively remove accrued rights. Where express consent is legally required, continued use is not a substitute for it.

15.2 You may reject a material adverse change by ending the affected service before it takes effect, with any refund required by these Terms or law. Required notice of a price change also remains subject to section 6.

15.3 If a provision is unenforceable, the remainder continues where legally possible. Delay in enforcing a right is not a waiver. Neither party may transfer this agreement in a way that unlawfully reduces the other’s protections. A permitted business successor must honour the applicable obligations.

15.4 These Terms and any properly incorporated or signed documents form the agreement for the service. They do not exclude liability for misleading statements, erase enforceable pre-contract information or prevent reliance on mandatory rights. Provisions concerning accrued payment obligations, confidentiality, lawful retention, liability and disputes survive closure where their nature requires it.

15.5 No person other than you and LFG may enforce these Terms, except a lawful successor or a person expressly identified in a signed agreement as an intended beneficiary. This does not limit an independent Third-Party Provider’s rights under its own agreement with you.

## 16. Definitions

16.1 In these Terms:

* **Business User** means a company, partnership, sole trader or other person using the Services mainly for trade, business or professional purposes.
* **Consumer** means an individual using the Services wholly or mainly outside their trade, business or profession.
* **EIP-3009 authorisation** means the signed, limited token-transfer authorisation described in section 6; it is not a wallet private key or bank direct-debit mandate.
* **Blockchain Compliance Provider** means a Third-Party Provider used for public-wallet or transaction-risk analytics. Its alerts are subject to sections 8 and 11.
* **Identity Verification Provider** means a Third-Party Provider used to perform or support identity, business, fraud or screening checks for a stated onboarding or compliance purpose.
* **Integrated Service Providers** means LFG’s current public directory of providers used for particular functions, as updated from time to time.
* **LFG Vault** means the non-custodial wallet associated with a business account for receiving eligible business payments and paying LFG subscription fees. The user controls its keys.
* **LFG-verified user** means a user whose applicable LFG account-verification requirements have been completed. It does not mean that LFG or a regulator guarantees the user or every transaction.
* **Merchant** means a Business User that uses available LFG tools to request or receive payment for its own goods or services.
* **On-ramp or off-ramp provider** means an independent provider that offers an enabled fiat-to-crypto or crypto-to-fiat service under its own agreement and eligibility rules.
* **Self-hosted wallet** means a wallet for which the user or another non-provider person controls the means of access, rather than a wallet held in an account with a custodial provider.
* **Services** means the LFG website, applications and software features made available under these Terms, subject to the Global Availability Statement.
* **Third-Party Provider** means a person other than LFG that supplies an integration, infrastructure or other service used by or accessible through the Services.
* **Travel Rule** means applicable requirements placed on certain regulated transfer-service providers to obtain, verify, hold or transmit specified originator and beneficiary information. Section 8 describes LFG’s limited technical role where an enabled integration requires such information.

16.2 References to the **Global Availability Statement**, **Privacy Policy**, **Cookie Policy**, **Regulatory Position Statement**, **Integrated Service Providers** and **Account Deletion Policy** mean the current documents linked in section 1.3.

## 17. Electronic communications, push notifications and SMS

17.1 We may send account, security, authentication, billing, legal and service messages by email, in-app message, push notification or, if configured for your account, SMS. Some messages are necessary to operate or secure an account and are not marketing.

17.2 Marketing messages are sent only where permitted by law and, where required, after separate consent. Marketing consent is not a condition of opening an account. You can withdraw it using the message instructions, account settings or <support@getlfg.app>. We will honour the request promptly, although a short processing period and a legally permitted confirmation message may apply.

17.3 If you opt into SMS, message frequency varies with your account activity and choices. Standard carrier message and data rates may apply. Where replies are supported, reply **STOP** to opt out of optional SMS and **HELP** for assistance; you may also contact <support@getlfg.app>. Opting out of marketing does not stop a transaction-specific authentication code you separately request or a legally required notice, but we will use another available channel where appropriate.

17.4 Mobile carriers are not responsible for delayed or undelivered messages. Delivery is not guaranteed, so do not rely on SMS or push notifications as your only method of monitoring a wallet, billing date or security issue.

17.5 The Privacy Policy explains how contact details, consent and delivery information are processed. We do not sell telephone numbers or SMS consent records, or share them with third parties for their own marketing. Communications providers may process them only to provide the applicable service or as otherwise lawfully explained.

***