Terms of Service

1 Acceptance of these Terms

These Terms, together with the documents they refer to, form the entire agreement between you and us about your use of the Services. The documents that also apply to you are our Privacy Policy, our Risk Disclosure, our Fee Schedule, and our Anti-Money-Laundering and Know-Your-Customer policy. Where a product has its own supplemental terms, those terms add to these Terms and do not replace them. If there is a direct conflict, the product-specific terms govern for that product, and otherwise these Terms govern.

We ask you to accept these Terms by an affirmative action, such as ticking an acceptance box during registration, and we keep a record of the version and date you accepted so that both of us know what was agreed. Simply browsing a public page is not acceptance of the full agreement, but using the Services is.

2 Definitions

In these Terms, the following words have the meanings given below. Other capitalised words are defined where they first appear.

Account means the personal account you register and hold with us.

Unified Wallet means the spendable balance recorded in your Account. It is an internal record of what we owe you in supported assets. It is not a self-custody wallet, and holding a balance does not mean you control the underlying private keys.

Digital Asset or crypto-asset means a supported blockchain-based asset, such as USDT on the BEP20 network.

Supported Asset and Supported Network mean the assets and blockchain networks we make available at a given time, which can change.

Deposit, Withdrawal, and P2P Transfer mean, respectively, funding your Account, sending value out of your Account, and transferring value between users inside the Platform.

Investment Product means any of Auto-Earn, Dual Investment, Institutional Connect, and Prime Growth, and any similar product we offer.

Return or Earning means any amount that an Investment Product may pay under its stated rules. A Return is variable, is calculated under those rules, and is not interest, a promised yield, or a guaranteed payment.

Commission means a reward payable under the referral program described in Section 9. A Commission Cap is the ceiling on Commissions a user may earn as described in that section.

Business Day means a day other than a Saturday, Sunday, or public holiday in jurisdiction.

3 Eligibility and age

To open and keep an Account you must, at all times:

• be at least 18 years old, or the age of majority in your place of residence if that is higher, and have full legal capacity to enter into a contract;
• be acting for yourself and on your own behalf, and not for an undisclosed third party, unless we have separately agreed to a business onboarding path with you;
• not be a resident of, located in, or a national of a restricted or prohibited place as described in Section 13, and not be a person we are prohibited from serving under applicable sanctions law; and
• hold only one Account per person, which is personal to you and may not be sold, shared, or transferred.

Eligibility is a continuing condition, not a one-time check at sign-up. We may ask you to prove your age or identity at any time, and we may refuse, restrict, or geo-block the Services where we are not authorised to offer them. If we find that an Account belongs to a person under the required age, we will close it and return any lawful balance to the correct verified person or their guardian to the extent the law allows.

4 Registration and identity verification (KYC and AML)

Identity verification is mandatory. It is a legal obligation under anti-money-laundering and counter-terrorist-financing rules, not an optional or marketing step. You will be asked to provide accurate personal details, which typically include your full legal name, date of birth, residential address, nationality, a government-issued photo identity document, and a photo or liveness check.

You must complete and pass verification before you can withdraw funds. Access to features is staged on your verification status, and we may restrict deposits, investing, P2P Transfers, or Commissions until the relevant checks are complete. We may apply enhanced checks to larger balances, higher-risk profiles, or politically exposed persons, and we may re-verify you or ask for updated documents at any time.

You agree to give information that is true, current, and complete, and to keep it up to date. We may use trusted third-party providers to help verify you. Your identity data is handled as described in our Privacy Policy, including the legal basis for processing and how long we keep it. If you refuse or fail verification, your Account and any pending activity may be restricted, suspended, or closed, and funds may be held until verification is completed to the extent the law allows. We do not keep verification holds as a penalty and we do not take your funds as our own.

5 Account security and your responsibilities

You are responsible for keeping your login credentials and any second factor secret, and for activity that takes place under your Account, subject to your right under applicable law to be protected against unauthorised transactions that you report promptly. Tell us immediately if you suspect that your Account has been accessed without your permission, using the support contact in Section 26 or the account-lock option in the app.

We protect the Services with measures that include session management, encryption in transit, and monitoring. These measures reduce risk but cannot remove it, and we do not promise that your Account can never be compromised. For your security we may end your session, require you to sign in again, or ask you to re-verify.

6 The Services, and what we are not

The Services give you a custodial Account with a Unified Wallet balance, the ability to deposit Supported Assets (including USDT on the BEP20 network and through a supported payment gateway), to withdraw Supported Assets, to make P2P Transfers to other users, to take part in the Investment Products, and to take part in the referral program.

The Services are custodial. We, or partners acting for us, hold and control the keys for Supported Assets. Your Unified Wallet balance is a record of what we owe you and does not mean you hold the assets in your own self-custody wallet.

We are not a bank or a deposit-taking institution, we are not a broker-dealer or an investment adviser, and your balances are not insured deposits, unless and only to the extent we state otherwise in writing and can evidence it. We may add, change, suspend, or discontinue features, Supported Assets, or Supported Networks. For changes that materially affect you we will give notice as described in Section 23.

7 Unified Wallet, deposits, withdrawals, and P2P Transfers

Deposits

Deposits are credited after the required number of network confirmations and only for Supported Assets sent on a Supported Network. Sending the wrong asset, or the right asset on the wrong network, can result in permanent loss that we may be unable to recover. Please check the asset, network, and address every time before you send.

Withdrawals

You are responsible for the accuracy of the destination address you provide. Blockchain transactions are irreversible: once a withdrawal is broadcast and confirmed, it cannot be cancelled, reversed, or charged back. Network fees apply and are set by the network, not by us. For your protection we may apply a security hold in defined situations, for example when funds are withdrawn to a newly added address, and we will tell you the reason for the hold where we are permitted to.

P2P Transfers

A P2P Transfer between users is final once completed. We cannot reverse a transfer that you send to the wrong recipient, so please confirm the recipient before you send.

Limits and lawful holds

Deposits, Withdrawals, and P2P Transfers may be subject to minimums, maximums, and processing times, which can vary with your verification level and a risk assessment. We may delay or decline a transaction where we are required to for anti-money-laundering, fraud-prevention, sanctions, or legal-order reasons. Where we lawfully hold a balance, we will release it to you once the concern is resolved or we are legally permitted to do so. We do not keep held balances as our own revenue.

8 Investment products

The Investment Products (Auto-Earn, Dual Investment, Institutional Connect, and Prime Growth) each work in their own way. Before you commit funds, the product screen and its supplemental terms set out the term, how any Return is calculated, when it accrues, any lock-up period, the rules for early exit, and how your principal is treated. Taking part is your own decision.

Any Return is variable and is not guaranteed. It may be lower than any figure shown, it may be zero, and your capital is at risk, which means you can lose part or all of the amount you commit. Any rate we show is a target, an estimate, or a historical figure, and is labelled as such; it is never a promise to pay. Past performance does not indicate future results. Returns depend on conditions that are outside your control and often outside ours, and a product may pause or stop. We describe honestly how each product is intended to generate any Return, and we do not offer any product whose Return would be funded out of other users' deposits or referral inflows. Please read Section 11 and Section 12 before you take part.

9 Referral and commission program

The referral program is optional and separate from ordinary use of the Services. You do not have to refer anyone in order to open an Account, deposit, or invest, and choosing not to take part has no effect on your Account. There is no joining fee and no package you must buy in order to enrol.

How Commissions are earned

Commissions are earned only when a person you refer completes real, qualifying activity, for example a deposit that actually clears or an investment that is actually funded. Nothing is paid for signing someone up, and headcount alone earns nothing. The program rewards referred customers genuinely using the products; it is not a reward for recruiting people who mainly recruit others.

The current program includes a three-level Working Plan paying 5%, 2%, and 1% on qualifying activity across the three levels; a Residual plan spanning up to 25 levels; and weekly-pool, monthly, and yearly incentives. Each rate, level, pool, and qualification rule is set out in the published commission schedule, which governs the exact figures and may be updated going forward on notice. Commissions are subject to the Commission Cap.

Not guaranteed income

Taking part is not a job and is not employment. It creates no wage, salary, or benefits, and no partnership, agency, or joint venture. Commissions are not guaranteed income. They depend on the independent activity of other people, which you cannot control, and many participants earn little or nothing. We make no representation about how much you will earn, and we do not use guaranteed-income, passive-income, or lifestyle claims to promote the program. You must not make such claims either.

Commission Cap and qualification

A per-user Commission Cap limits the total Commissions you may earn as described in the commission schedule. Once you reach the cap, Commissions stop for the relevant period. If continuing to earn beyond a threshold requires a further step on your part, that condition is described plainly in the schedule; we do not present required spending as a benefit, and we do not suggest that spending more will earn you more. Missing a qualification or reaching the cap creates no debt and no penalty; it simply means the Commission is not earned for that period.

Adjustments and clawbacks

Commissions are provisional until the underlying transaction is final. We may reverse or claw back a Commission if the referred deposit is reversed, charged back, or fails to clear, if an investment is refunded or unwound, if the activity is found to be fraudulent, if a compliance review flags the Account, or if the referral broke the program rules. A reversed Commission is deducted from pending or future Commissions, which means a negative Commission balance is possible. We may withhold or freeze Commissions during a good-faith investigation, and we release them if the activity is confirmed to be legitimate. We limit clawbacks to these reasons, so genuine, already-vested Commissions are not subject to arbitrary take-backs.

Prohibited referral conduct

You must not create self-referrals, duplicate or fake Accounts, or circular or manufactured transactions made only to trigger Commissions, and you must not fund another person's entry to inflate your network. You must not make deceptive claims about the Platform, its products, its risks, or its status when referring others. Breaking these rules can lead to forfeiture of the affected Commissions and to suspension or closure of the Account.

Taxes

You are solely responsible for reporting and paying any taxes on Commissions in your own country. We may be required to collect tax and identity information and to report payments to tax authorities, and to withhold where the law requires it. Do not treat a gross Commission figure as your take-home amount.

10 Fees, limits, and taxes

Our fees for deposits, withdrawals, P2P Transfers, and products are set out in our Fee Schedule, which forms part of these Terms. Blockchain network fees are set by the network and passed through to you. We will give you advance notice before any increase in our fees, and you may withdraw your lawful balance and close your Account before an increase takes effect. Minimums, maximums, and per-tier limits may apply and may change with your verification level or a risk assessment.

You are solely responsible for your own taxes. We do not give tax advice, and we may report to authorities where we are legally required to do so.

11 Risk disclosures

This section is important. Please read all of it before you deposit, invest, transfer, or take part in the referral program.

Volatility and total-loss risk

The value of crypto-assets, including stablecoins such as USDT, can move sharply and unpredictably over very short periods, and can fall to zero. You may lose the entire amount you deposit or hold. A stablecoin's peg can break, so we do not describe any asset as safe, stable, or low-risk. Keeping funds on the Platform does not shield them from price falls. In stressed markets you may be unable to sell, convert, or withdraw at the price you expect, or at all. Fees, spreads, and network costs reduce the amount you actually receive.

Not a bank deposit, and not insured

Balances held with us are not bank deposits and are not the same as money in a bank account. They are not covered by any deposit-insurance or investor-compensation scheme. Schemes such as the FDIC in the United States or the FSCS in the United Kingdom do not apply to your balances. We are not a licensed bank or e-money institution unless we state otherwise in writing and can evidence it.

Transactions are final

Blockchain and crypto transfers are generally final and cannot be reversed, cancelled, charged back, or refunded once broadcast or confirmed. Sending to a wrong, mistyped, or incompatible address, or on the wrong network, can cause permanent loss with no recovery. Neither we nor any third party can claw back a confirmed on-chain transaction, and we cannot guarantee the recovery of funds sent in error or lost to a scam, phishing, or fraud. Check the address, network, and amount before you confirm, because confirmation is final.

Technology, custody, and counterparty risk

The software, smart contracts, blockchains, payment gateways, and stablecoin issuers that the Services rely on are operated in part by third parties we do not control, and may contain bugs, or may suffer outages, congestion, forks, or failures that delay or block transactions. Because the Services are custodial, you rely on us and our partners to hold and move funds, and any of us could be affected by failure, hacking, unauthorised access, or key loss. We describe our security measures honestly, and we do not claim that any system is unhackable or fully secure. The Services may be unavailable at times, and you bear the risk of being unable to transact during downtime.

Returns and commissions are not guaranteed

Returns from the Investment Products and Commissions from the referral program are not guaranteed and are not covered by any deposit-insurance or investor-compensation scheme. Any figure, chart, or historical earning shown anywhere on the Platform is illustrative, is not a forecast or a promise, and may not repeat. Commit only funds you can afford to lose, and consider seeking independent professional advice.

12 No financial, investment, legal, or tax advice

We provide an execution and account service and a set of products and tools. Nothing on the Platform, in the products, or in any communication from us is financial, investment, legal, accounting, or tax advice, and nothing creates an advisory or fiduciary relationship between us. We do not assess whether any product is suitable or appropriate for you, and we do not make personal recommendations, unless a law requires us to. Product listings, calculators, projected figures, and dashboards are general information and are not a solicitation or a recommendation to buy, hold, or sell.

You are responsible for your own decisions and for evaluating the risks. Please do your own research and seek independent, licensed professional advice before you deposit or invest.

13 Sanctions, restricted places, and transaction monitoring

Restricted and prohibited places

The Services are not offered to, and may not be accessed by, residents, nationals, or persons located in a restricted place. This covers two situations: places where we are not licensed or choose not to operate, and places subject to comprehensive government sanctions or embargoes. We keep a current list of restricted places on a linked page rather than freezing it into this document, because it changes. At the time of writing, comprehensively sanctioned places commonly include Cuba, Iran, North Korea, and the Crimea, Donetsk, and Luhansk regions, and this list can change. You must not use a VPN, a proxy, or false location or residence details to get around geographic restrictions. If you later become located in a restricted place, we may suspend access, and you should withdraw any lawful balance where permitted.

Sanctions screening

You confirm that you are not a sanctioned or restricted person, that you are not owned or controlled 50% or more by such persons, and that you are not acting for one. We screen users and transactions against applicable sanctions and watch lists (for example OFAC, UN, EU, and UK lists) both when you join and on an ongoing basis. A confirmed or potential match may lead to a hold, a rejected transaction, blocked funds, an account freeze, or a report, as the relevant sanctions program requires. Blocked funds may have to be held or handed to authorities rather than returned to you, as the law requires. You must tell us if your sanctions status changes.

Monitoring and the Travel Rule

We monitor activity for money-laundering, terrorist-financing, fraud, and sanctions risk, using automated and manual review, and we may apply limits, extra checks, or delays on that basis. For crypto transfers, the FATF Travel Rule requires us to collect, verify, and share required sender and recipient information, such as name and wallet or account identifier, with the counterparty institution and, where required, with authorities. This sharing applies at or above the applicable regulatory threshold, commonly the equivalent of about 1,000 US dollars or euros under the FATF standard; some regimes, such as the EU transfer-of-funds rules, require this information for crypto transfers regardless of amount, and we apply whichever stricter rule governs the transfer. You consent to this information being transmitted as legally required, and a transfer missing required information may be delayed, returned, or rejected. Transfers to or from self-custody wallets may need extra address verification or proof of ownership.

We are legally required to report suspicious activity to the relevant authorities and to comply with related legal orders. By law we may be prohibited from telling you that a report has been made or considered, or from explaining the exact reason a transaction was declined or an Account was frozen. This is a legal limit that binds regulated financial firms, not a discretionary refusal to communicate. We will share as much as we are lawfully allowed to.

14 Acceptable use and prohibited activities

You agree to use the Services only for your own lawful benefit, to give accurate information, to keep your contact details current, to cooperate with verification and security requests, and to comply with all applicable laws, including anti-money-laundering, sanctions, and tax rules. You are responsible for your own transaction decisions and destination addresses, and you must not rely on us for advice.

You must not use the Services for or in connection with:

• money laundering, terrorist or proliferation financing, sanctions evasion, fraud, market manipulation, or moving the proceeds of crime;
• transacting on behalf of an undisclosed third party, or running an unlicensed money-service business through your Account;
• using mixers or tumblers to hide the origin of funds, or any other unlawful purpose;
• unauthorised access, scraping, bots, exploiting bugs, or circumventing limits or geographic restrictions;
• creating multiple or fake Accounts, or opening a new Account to evade a prior suspension, ban, limit, or hold; or
• abusing the referral program through self-referrals, collusive networks, or manufactured volume.

We keep this list tied to genuine legal and integrity risks, and we will not treat ordinary, lawful use as a breach.

15 Holds, suspension, restriction, and closure

We may place a hold on, freeze, suspend, restrict, or close an Account only on defined grounds, which are: a pending verification or source-of-funds review; suspected fraud, money laundering, or breach of these Terms; a sanctions match; a legal or regulatory requirement or a court or authority order; or a reversed or charged-back deposit. We do not claim an open-ended right to act for any reason at all.

We will act reasonably and proportionately, keep any hold no wider or longer than necessary, and lift it promptly once the concern is resolved or we are legally permitted to. During a hold you may be unable to trade, transfer, or withdraw, and access and your lawful balance will be restored when we are allowed to restore them. We will give you notice where it is practical and legally permitted, though some holds must stay silent when a legal order requires it.

We do not keep, forfeit, or absorb your funds as a penalty or as our revenue. On closure, we return your remaining lawful balance to you, after legitimate holds, fees, and any valid clawback are resolved, and net only of amounts we are legally required to withhold or to hand to authorities. You may close your own Account at any time, subject to settling open positions, any product lock-up, and any pending obligation. Where lawful, you keep the right to withdraw your own balance even after closure.

16 Intellectual property

The Services, our software, the MarketsMill ™ name and branding, and our content are owned by us or our licensors and are protected by law. We grant you a limited, revocable, non-transferable, non-exclusive licence to use the Services for their intended personal purpose. You must not copy, modify, reverse engineer, resell, or otherwise use our intellectual property beyond that licence, and you must not misuse our brand or trademarks.

You keep ownership of the content and data you submit. You grant us only the limited licence we need to operate and provide the Services, and we do not claim ownership of your data or your funds. If you believe content on the Platform infringes your rights, contact us using the details in Section 26.

17 Disclaimer of warranties

To the maximum extent permitted by applicable law, the Services, the Unified Wallet, the deposit and withdrawal rails, P2P Transfers, the Investment Products, and the referral features are provided on an "as is" and "as available" basis. We do not warrant that the Services will be uninterrupted, error-free, secure, or timely, and we disclaim the implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement, so far as the law allows. We do not warrant any specific Return, yield, or Earning, and past performance does not guarantee future results.

We are not responsible for third-party networks, wallets, payment gateways, blockchains, or stablecoin issuers that are outside our control. Some jurisdictions do not allow the exclusion of certain warranties, so some of these exclusions may not apply to you, and nothing in this section removes rights or protections that cannot be waived under your local consumer law. This disclaimer does not apply to the accuracy of the balances, transaction records, and fee figures that we ourselves generate, which are operational facts rather than advice or predictions.

18 Limitation of liability

To the maximum extent permitted by applicable law, and subject always to Section 19, we are not liable for indirect, incidental, consequential, special, exemplary, or punitive losses, or for loss of profits, goodwill, or data, arising out of or connected with your use of the Services.

Subject always to Section 19, our total aggregate liability to you for all claims connected with the Services, across all legal theories whether in contract, tort, or statute, is limited to the greater of the total fees you paid to us in the X months before the event giving rise to the claim, or fixed sum. This limit does not apply to our obligation to return the lawful balance we hold for you, which we owe you subject to these Terms and to applicable law. These limits survive the closure of your Account and the ending of these Terms.

19 Liability we do not exclude

Nothing in these Terms excludes or limits our liability for: death or personal injury caused by our negligence; fraud or fraudulent misrepresentation; gross negligence or wilful misconduct; our own failure to safeguard the assets we custody for you, to the extent the law imposes that liability; and any other liability that cannot be excluded or limited under applicable law. Where any exclusion or limit in these Terms goes further than the law allows, it applies only to the extent the law allows, and the rest of the Terms stay in force.

20 Indemnity

You agree to cover our reasonable losses, damages, and costs to the extent they arise directly from your breach of these Terms, your violation of the law, your infringement of a third party's rights, or your misuse of the Services. This indemnity does not cover any loss caused by our own negligence, fraud, or breach. We will notify you promptly of any claim for which we seek to rely on this indemnity, we may take control of the defence of that claim, and you agree to cooperate with us.

21 Dispute resolution

Talk to us first. If you have a concern, please contact us using Section 26 and give us a fair chance to put it right. You agree to try to resolve a dispute informally by sending us a written notice and allowing 30 to 60 days for us to respond before starting any formal proceeding. Many issues are resolved quickly at this stage.

If we cannot resolve a dispute informally, it may be dealt with by the courts of the jurisdiction named in Section 22, or a named arbitration body and seat if arbitration is chosen. The way disputes are handled differs by region, and this clause is expressly subject to your mandatory local rights. If you are a consumer in the EU, the EEA, or the UK, you keep the right to bring proceedings in the courts of your country of residence and you cannot be required to give that up. Where mandatory law makes an arbitration or class-action-waiver term non-binding on you, that term does not apply to you. Nothing here removes your access to a small-claims court, to a competent regulator or ombudsman, or, for EU consumers, to any applicable alternative or online dispute-resolution scheme.

22 Governing law and your local rights

These Terms and any dispute connected with them are governed by the law of governing law, and the courts of courts and venue have jurisdiction, subject to the rest of this section and to Section 21.

This choice of law does not deprive you, if you are a consumer, of the protection of the mandatory provisions of the law of the country where you habitually reside. Nothing in these Terms excludes, restricts, or modifies any consumer guarantee, statutory right, or remedy that applicable law gives you and that cannot lawfully be waived. Where any term conflicts with such a right, the mandatory right prevails and the term applies only to the extent the law permits.

23 Changes to these Terms

We may change these Terms for good reasons, such as a change in law or regulation, a new or changed feature, or to protect the security or integrity of the Services. We will not treat this as a right to change the Terms arbitrarily.

For changes that materially affect your rights or fees, we will give you reasonable prior notice, for example 30 days by email or in-app message, and we will update the version and date at the top of this document. Before a material change takes effect, you have the right to stop using the Services, withdraw your lawful balance, and close your Account without penalty. We will not treat your silence alone as acceptance of a material change without both that notice and that penalty-free exit, and we will not apply changed Terms retroactively to transactions you have already completed or to disputes that have already arisen. Earlier versions remain available on request.

24 Communications and notices

You agree to receive these Terms, disclosures, statements, and legal notices electronically, and you can access and keep copies of them. We treat your registered email address and your in-app inbox as valid channels for notices, so please keep your contact details current. You cannot opt out of transactional and legal notices while your Account is active, but you can opt out of marketing messages as described in our Privacy Policy. To send us a formal notice, use the contact details in Section 26.

25 General provisions

Severability. If any term is held to be invalid or unenforceable, it is limited or removed to the least extent needed, and the rest of these Terms stay in force. An unfair term is struck out rather than rewritten against you.

Survival. The disclaimers, the liability limits, the indemnity, and the dispute and governing-law terms survive the ending of these Terms or the closure of your Account.

No waiver. If we do not enforce a term, that is not a waiver of it, and we may still enforce it later.

Assignment. We may assign or transfer these Terms to another entity, for example as part of a reorganisation, on notice to you and provided your rights are not reduced. You may not assign your Account or your rights without our consent.

Force majeure. We are not responsible for a failure or delay caused by events genuinely beyond our reasonable control. This does not cover our own ordinary operational failures.

Relationship and third parties. These Terms do not create a partnership, agency, or employment relationship between us, and they do not give rights to anyone who is not a party to them, except as expressly stated.

Entire agreement and language. These Terms and the documents they refer to are the entire agreement between us about the Services. If we provide a translation, the English version governs if there is a conflict.

26 How to contact us

You can reach our support team through the help section of the app or at [email protected]. For legal or regulatory notices, and for intellectual-property complaints, write to Operating Entity legal name at registered address, or email [email protected]. If you have a complaint we have not resolved, you may be able to refer it to the relevant regulator or dispute-resolution body. We aim to acknowledge messages within a stated response time.