# Terms of Service

**Last updated:** September 15, 2025

> **Important Geo-Notice**\
> Access to, or use of, the Services **from the United States or its territories** or **by any U.S. Person** is **strictly prohibited**—regardless of IP address. Using VPNs, proxies, or any method to mask a U.S. location is also prohibited and may lead to permanent blocks on associated blockchain addresses. By using the Services, you **represent and warrant** you **are not a U.S. Person** (as defined under applicable U.S. laws and regulations). See **Section 5**.

These Terms of Service (“**Terms**”) form a binding agreement between you (“**you**”, “**user**”) and **Holdstation Global Ltd.** and its affiliates (“**Holdstation**”, “**we**”, “**our**”, “**us**”) governing your access to and use of the **Holdstation Wallet** (mobile and web), related websites, APIs, and any features or content we provide (collectively, the “**Services**”).

If you do not agree to these Terms, **do not** access or use the Services.

### 1) What Holdstation Wallet Is (and Isn’t)

1. **Non-custodial wallet.** Holdstation Wallet is a user-controlled, self-custody interface for generating and managing blockchain addresses and interacting with public networks (e.g., BNB Chain, Ethereum-compatible chains, World Chain, etc.). **We do not take custody** of your assets, private keys, seed phrases, or passwords.
2. **Transaction drafting interface.** The Wallet may help you craft and broadcast transactions via compatible nodes or third-party services you choose to connect. **You** review and sign any transaction with your private key.
3. **Third-party rails.** On-ramps/off-ramps, swaps, staking, tokenized asset rails, KYC vendors, data oracles (e.g., Chainlink), RWAs or stock-like tokens (via supported partners such as Ondo Global Markets), and other modules are provided by **independent third parties**. We **do not** issue, custody, broker, underwrite, or guarantee those products.
4. **Information only.** Any prices, charts, feeds, “best route,” signals, or analytics are **informational** and may be delayed, incomplete, or inaccurate. They are **not** investment, legal, tax, or accounting advice.

### 2) Eligibility & Your Commitments

By using the Services, you confirm that:

* **Age & capacity.** You are at least **18 years old**, mentally competent, and have the technical literacy to assess blockchain risks.
* **One user, one responsibility.** You are solely responsible for your devices, seed phrase, private keys, passcodes, and for all activity on your addresses. **We cannot recover** lost keys or funds.
* **Compliance.** You will follow all laws and rules that apply to you (including AML/CFT, sanctions, securities/derivatives, tax, consumer protection).
* **Accurate info.** If a feature requires KYC/AML (e.g., fiat on-ramp, specific tokenized products), you agree to provide accurate information and keep it updated.
* **No U.S. Person / restricted locations.** You are **not** a U.S. Person and you are **not** using the Services from any sanctioned/restricted jurisdiction (see Section 5).

### 3) Your Wallet, Keys, and Security

* **You control your keys.** Seed phrases/private keys are generated and stored on your devices. **We never see or store them.**
* **No recovery.** Lose your seed phrase or private key and you may lose access to your digital assets permanently.
* **Best practices.** Use hardware security (where possible), strong passcodes, offline backups, and 2FA for linked accounts. Keep software updated.
* **Phishing & malware.** Always verify URLs, smart contracts, and approvals. You are responsible for avoiding malicious links, signatures, or dApps.

### 4) Features, Integrations & Fees

1. **Swaps / routing.** The Wallet may surface routes and quotes from DEXs/aggregators. Quotes are not guaranteed; execution depends on network conditions, liquidity, and third-party logic (e.g., AMMs, FMM/AIMP, etc.).
2. **Tokenized U.S. stocks & ETFs (via partners).** Where supported, users **outside the U.S.** may access **tokenized total-return trackers** (e.g., `$AAPLon`, `$TSLAon`, `$SPYon`) subject to partner terms, eligibility, and **24/5 mint/redeem windows** (typically **Sun 8:00 p.m. ET → Fri 7:59 p.m. ET**, with pauses for dividends/corporate actions/session changes). **Dividends (if any) are generally reinvested net of U.S. withholding tax** and subject to partner disclosures.
3. **On-ramp / off-ramp & KYC.** Fiat rails and certain assets may require KYC/AML with a licensed third party. Holdstation does not approve or deny KYC; decisions are made by the provider.
4. **Oracles & data.** Pricing may use third-party sources (e.g., Chainlink, CEX averages) and can deviate from live markets. Use at your own risk.
5. **Fees.**
   * **Network fees** (gas) are paid to validators/miners and are **not refundable**.
   * **Third-party fees** (e.g., swap/route fees, partner fees) may apply and are disclosed by the respective provider.
   * Holdstation may charge **interface or convenience fees** for certain features; if so, they will be shown in-app before you proceed.

### 5) Sanctions, Jurisdiction Blocks & U.S. Person Prohibition

1. **U.S. blocks.** Access **from within the United States or its territories** or **by any U.S. Person** (citizen, resident, Green Card holder, or otherwise as defined by applicable U.S. law) is **prohibited**.
2. **VPNs & evasion.** You must **not** use VPNs, proxies, or any method to circumvent geo-blocks. We may restrict or permanently block addresses suspected of evasion.
3. **Sanctions.** You may not use the Services if you, or any beneficial owner of your entity, appears on sanctions lists (e.g., OFAC SDN, UN, EU/UK) or if you are located in embargoed regions.
4. **Certifications.** You certify you are **not** a U.S. Person, **not** in the U.S., and **not** in a prohibited jurisdiction. You must stop using the Services immediately if this changes.

### 6) Prohibited Uses

You agree **not** to:

* Engage in fraud, market manipulation (e.g., wash trading, front-running schemes), or deceptive conduct.
* Use the Services for any illegal activity (e.g., terrorism financing, sanctions evasion, ransomware).
* Interfere with or attack the Services (e.g., DDoS, exploit attempts, key-logging, smart contract abuse).
* Misrepresent token contracts, impersonate others, or post misleading token names/symbols.
* Access, scrape, or use the Services in ways beyond permitted API or rate limits.
* Bypass geo-blocks or eligibility checks.

We may suspend, geoblock, or terminate access at our discretion.

### 7) Content & Token Information

* **No guarantee of accuracy.** Token names, logos, and contract addresses shown in the Wallet may come from third-party lists. Multiple tokens can share names/symbols. Always verify **contract addresses**.
* **Informational only.** Prices, charts, and analytics are **not** advice. Historical performance does not guarantee future results.
* **Your due diligence.** You must independently verify assets, contracts, and counterparties before interacting.

### 8) Risk Disclosures

* **Volatility & loss.** Digital assets are highly volatile. You may lose some or all of your assets.
* **Smart contracts.** Protocols you interact with may contain bugs, exploits, or design risks. Upgrades/forks can change behavior.
* **Network risks.** Congestion, reorgs, MEV, failed transactions, or high gas can affect execution and cost.
* **Regulatory change.** Rules can change rapidly and may impact availability or legality of features in your region.
* **RWA/tokenized products.** Tokenized assets are typically **trackers** of total return; availability, redemption windows, and dividend treatments follow third-party terms and may change.

### 9) No Advice; No Fiduciary Duty

Holdstation does **not** provide investment, legal, tax, accounting, or financial advice. You are solely responsible for decisions and consequences. Consider independent professional advice.

### 10) Privacy (Summary)

We follow a **privacy-by-design** approach. We may collect limited operational data (e.g., device, telemetry, fraud/sanctions signals) to run, secure, and improve the Services, and to enforce geo-blocks/eligibility. Third-party features (KYC, on-ramp, tokenized assets, analytics) have their **own** privacy terms. See our **Privacy Policy** for details.

### 11) Intellectual Property

* The Wallet app, website, and related software are owned or licensed by Holdstation and protected by IP laws.
* Third-party marks, names, and logos belong to their respective owners.
* You are granted a **revocable, non-exclusive, non-transferable** license to use the Wallet solely as permitted by these Terms.

### 12) Updates, Beta & Changes to the Services

We may **add, modify, or remove** features at any time, including for maintenance, security, or compliance. Some features may be labeled **beta** and could be unstable—use at your own risk. We may update these Terms; the latest version will be posted in-app or on our site. **Continued use** means you accept changes.

### 13) Suspension & Termination

We may suspend or terminate access **immediately** if we suspect violations of these Terms, law, sanctions, security risks, fraud, or geo-block evasion. You may cease using the Services at any time; uninstalling the app does not affect any prior rights or obligations.

### 14) Taxes

You are responsible for **all taxes** arising from your activities. We do not calculate, withhold, or file taxes on your behalf.

### 15) Disclaimers; Limitation of Liability

* **AS IS / AS AVAILABLE.** The Services are provided **without warranties** of any kind (including merchantability, fitness for a particular purpose, non-infringement, uptime, data accuracy).
* **No responsibility for third parties.** We are **not liable** for third-party services, wallets, protocols, oracles, RWAs, tokenized products, validators/miners, outages, or losses caused by them.
* **Limitation.** To the maximum extent permitted by law, Holdstation and its affiliates shall **not be liable** for indirect, incidental, special, consequential, exemplary, or punitive damages, or lost profits, lost data, loss of goodwill, or security breaches. Our **aggregate liability** will not exceed the fees (if any) you paid to Holdstation for the specific feature in the 3 months before the claim (often **$0** for the Wallet interface).
* Some jurisdictions do not allow certain limitations. Where prohibited by law, those limitations may not apply.

### 16) Indemnification

You agree to **defend, indemnify, and hold harmless** Holdstation, its affiliates, and their officers, directors, employees, and agents from any claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or related to your use of the Services, your violation of these Terms, or your violation of any law or third-party right.

### 17) Governing Law & Dispute Resolution

1. **Governing law.** These Terms and any dispute are governed by the laws of **Singapore**, without regard to conflict-of-laws rules.
2. **Arbitration.** Any dispute, claim, or controversy arising out of or related to these Terms or the Services shall be resolved by **confidential binding arbitration** administered by the **Singapore International Arbitration Centre (SIAC)** under the **SIAC Rules**. The seat of arbitration is **Singapore**. The language is **English**. One arbitrator. The award is final and may be entered in any court of competent jurisdiction.
3. **Class action/jury waiver.** Disputes must be brought **individually**, **not** as a class, collective, or representative action. You **waive** any right to a jury trial.
4. **Injunctive relief.** Notwithstanding the above, we may seek temporary or permanent injunctive relief in any court of competent jurisdiction to protect the Services, IP, or enforce geo/sanctions restrictions.

### 18) Miscellaneous

* **Assignment.** You may not assign or transfer these Terms without our prior written consent. We may assign or transfer without restriction.
* **Severability.** If any provision is unenforceable, the remainder remains in effect.
* **No waiver.** Failure to enforce a provision is **not** a waiver.
* **Force majeure.** We are not liable for delays or failures beyond our reasonable control (e.g., network outages, attacks, regulatory actions, natural events).
* **Entire agreement.** These Terms are the entire agreement between you and Holdstation regarding the Services.
* **Headings.** Headings are for convenience only.