Terms of Use

Draft — for legal review prior to publication

OWNKEY LTD · 124-128, City Road, London, EC1V 2NX, United Kingdom · www.ownkey.tech

1. Acceptance of These Terms

These Terms of Use, together with any documents referenced herein (the "Terms"), form a legally binding agreement between you ("User", "you") and OWNKEY LTD ("OWNKEY", "we", "us", "our"), a company registered in England and Wales with its registered office at 124-128, City Road, London, EC1V 2NX, United Kingdom, operator of the platform available at www.ownkey.tech and its associated applications (the "Platform" or "Service").

By creating an account, accessing, or otherwise using the Service, you confirm that you have read, understood, and agree to be bound by these Terms and by our Privacy Policy. If you do not agree, you must not access or use the Service.

2. Definitions

  • "Account" the User's personal profile created on the Platform to access the Service.
  • "Card" a virtual or physical payment card issued to the User by a third-party Program Manager/BIN Sponsor in connection with the Service.
  • "Digital Assets" cryptocurrencies, stablecoins, and other blockchain-based assets that may be stored, converted, or transacted through the Service.
  • "Non-Custodial" an architecture in which OWNKEY does not hold, control, or have unilateral access to the private keys or Digital Assets associated with a User's wallet.
  • "Exchange Provider" a regulated third-party service provider engaged by OWNKEY to execute or facilitate conversions between fiat currencies and Digital Assets.
  • "Program Manager / BIN Sponsor" a regulated third-party financial institution or its authorized partner that issues Cards under its own licence and card network membership.
  • "Third-Party Providers" collectively, the Exchange Provider, the Program Manager/BIN Sponsor, identity verification providers, and any other party other than OWNKEY that provides infrastructure or services used to deliver the Service.

3. Description of the Service

OWNKEY provides a non-custodial platform that enables Users to:

  • Convert between fiat currencies and supported Digital Assets;
  • Request and use virtual and/or physical payment Cards issued by a Program Manager/BIN Sponsor;
  • Store and manage Digital Assets in a self-custodied wallet associated with the User's Account.

OWNKEY acts as a technology and interface provider. OWNKEY does not itself execute currency conversions or issue Cards. Currency conversion is executed by or through the Exchange Provider, and Cards are issued by the Program Manager/BIN Sponsor, each acting under its own regulatory authorisation. OWNKEY is not a bank and does not hold a banking licence unless expressly stated otherwise.

4. Eligibility and Account Registration

To use the Service, you must be at least 18 years old (or the age of legal majority in your jurisdiction), have the legal capacity to enter into a binding contract, and not be located in, or a resident or citizen of, any jurisdiction where use of the Service would be unlawful.

You are responsible for providing accurate, current, and complete information during registration and for promptly updating such information. You are solely responsible for maintaining the confidentiality of your Account credentials and for all activity occurring under your Account.

5. Identity Verification (KYC/AML)

Access to certain features of the Service, including Card issuance and currency conversion above certain thresholds, requires identity verification ("KYC") in accordance with applicable anti-money-laundering (AML) and counter-terrorist-financing requirements imposed on OWNKEY and/or its Third-Party Providers.

As part of this process, you consent to OWNKEY collecting your identification data and sharing it with the relevant Exchange Provider and/or Program Manager/BIN Sponsor, and with identity verification sub-processors acting on their behalf, solely to the extent necessary for them to perform their respective functions, conduct their own regulatory checks, and provide the Service to you. Further detail on this data sharing is set out in our Privacy Policy.

We reserve the right to request additional documentation at any time, to decline or delay onboarding, and to suspend or terminate an Account if verification cannot be completed or if suspicious activity is identified.

6. Non-Custodial Nature of the Service

OWNKEY is designed on a non-custodial basis. This means that OWNKEY does not hold, control, or have the ability to unilaterally access, freeze, or move the Digital Assets associated with your wallet. You are solely responsible for safeguarding your private keys, recovery phrase, and any other credentials that control access to your wallet.

If you lose access to your private keys or recovery phrase, OWNKEY has no ability to recover your Digital Assets on your behalf. Loss of such credentials may result in permanent and irreversible loss of your Digital Assets.

7. Currency Conversion via the Exchange Provider

Conversions between fiat currency and Digital Assets are executed by or through the Exchange Provider. Exchange rates, execution times, and conversion limits are determined by the Exchange Provider and may vary. OWNKEY displays rate and fee information provided by the Exchange Provider but does not guarantee execution at a displayed rate, which may change between quotation and settlement.

OWNKEY is not responsible for delays, errors, or losses caused by the Exchange Provider, except to the extent required by applicable law.

8. Card Issuance via the Program Manager / BIN Sponsor

Virtual and physical Cards made available through the Service are issued by a regulated Program Manager and/or BIN Sponsor operating under its own licence and card network membership, and not by OWNKEY. Use of a Card is additionally governed by the cardholder terms of the relevant Program Manager/BIN Sponsor, which will be presented to you at the time of Card issuance and which take precedence over these Terms with respect to Card-specific matters.

OWNKEY is not responsible for the acts, omissions, solvency, or service levels of any Program Manager, BIN Sponsor, bank-emitter, Exchange Provider, or other Third-Party Provider, except to the extent required by applicable law.

9. Fees and Charges

Use of the Service may be subject to fees, including but not limited to conversion fees charged by or through the Exchange Provider, Card issuance and maintenance fees charged by the Program Manager/BIN Sponsor, and OWNKEY's own service fees, where applicable. Applicable fees will be disclosed to you within the Platform prior to you incurring them. We reserve the right to modify our fees at any time, with such changes taking effect for transactions initiated after the effective date of the change.

10. Risk Disclosure

You acknowledge and accept the following risks inherent to the Service:

  • Digital Assets, including stablecoins, are subject to price volatility, technological risk, regulatory risk, and issuer risk; a stablecoin's peg to a reference asset is not guaranteed by OWNKEY.
  • Digital Assets held in a self-custodied wallet are generally not covered by deposit protection or investor compensation schemes applicable to bank deposits.
  • Blockchain transactions are generally irreversible; sending assets to an incorrect address may result in permanent loss.
  • Service availability depends on Third-Party Providers (including the Exchange Provider, the Program Manager/BIN Sponsor, banking partners, and blockchain networks) that are outside OWNKEY's control.

You should not use the Service to store or transact value that you cannot afford to lose, and you are encouraged to seek independent advice if you are uncertain about these risks.

11. User Obligations and Prohibited Uses

You agree not to use the Service to:

  • Engage in money laundering, terrorist financing, fraud, or any other unlawful activity;
  • Violate applicable sanctions, export control, or other regulatory restrictions;
  • Interfere with, disrupt, or attempt unauthorized access to the Platform or related infrastructure;
  • Misrepresent your identity or provide false information during onboarding or verification;
  • Use the Service on behalf of a third party without authorization, where such use is not permitted by these Terms.

We reserve the right to suspend or terminate access to the Service, decline transactions, or report activity to competent authorities where we reasonably suspect a violation of this Section.

12. Intellectual Property

All intellectual property rights in the Platform, including its software, design, trademarks, and logos, are owned by OWNKEY or its licensors. Nothing in these Terms grants you any right to use OWNKEY's trademarks, logos, or brand assets without prior written consent.

13. Privacy and Data Protection

Our collection and processing of personal data is described in our Privacy Policy, which forms part of these Terms. Where OWNKEY relies on Third-Party Providers for identity verification, currency conversion, or Card issuance, such providers may separately process your personal data as independent controllers or processors under their own privacy terms.

14. Limitation of Liability

To the maximum extent permitted by applicable law, OWNKEY shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or for any loss of profits, data, or Digital Assets, arising from or related to your use of the Service, including losses resulting from your loss of private keys, market volatility, or the acts or omissions of Third-Party Providers.

Nothing in these Terms excludes or limits liability that cannot be excluded or limited under applicable law, including liability for fraud, fraudulent misrepresentation, or death or personal injury caused by negligence.

15. Indemnification

You agree to indemnify and hold harmless OWNKEY, its affiliates, officers, and employees from any claims, damages, liabilities, and expenses (including reasonable legal fees) arising from your breach of these Terms, your violation of applicable law, or your misuse of the Service.

16. Suspension and Termination

We may suspend or terminate your access to the Service, in whole or in part, at any time, with or without notice, where we reasonably believe this is necessary to comply with applicable law, to protect the security of the Platform or other users, or where you materially breach these Terms. You may close your Account at any time by following the process described within the Platform, or by emailing us at tech@ownkey.tech.

17. Changes to These Terms

We may amend these Terms from time to time. Material changes will be notified to you through the Platform or by other reasonable means in advance of their effective date. Your continued use of the Service after the effective date constitutes acceptance of the amended Terms.

18. Governing Law and Dispute Resolution

These Terms and any dispute or claim arising out of or in connection with them (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales.

The courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim arising out of or in connection with these Terms.

19. Miscellaneous

If any provision of these Terms is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect. These Terms, together with the Privacy Policy and any cardholder terms referenced herein, constitute the entire agreement between you and OWNKEY regarding the Service. You may not assign these Terms without our prior written consent; we may assign these Terms in connection with a merger, acquisition, or sale of assets.

20. Contact Us

OWNKEY LTD · Registered office: 124-128, City Road, London, EC1V 2NX, United Kingdom · Website: www.ownkey.tech

If you have questions about these Terms, please contact us through the channels listed on our website.

Annex A — Restricted Territories and User Eligibility

This Annex forms part of the Terms and sets out territorial restrictions on use of the Service. It is provided for transparency and is updated from time to time; the version available on the Platform at the time of your use of the Service prevails.

  • Sanctioned jurisdictions. You may not access or use the Service if you are located in, incorporated in, or a resident or national of a country or territory that is subject to comprehensive sanctions administered by the United Nations, the United Kingdom, the European Union, or the United States (OFAC), or if you are listed on any applicable sanctions or asset-freeze list. The current list of comprehensively sanctioned countries/territories is maintained internally and updated as sanctions regimes change.
  • Enhanced due diligence jurisdictions. Where you are located in, or a national of, a jurisdiction identified by the Financial Action Task Force (FATF) as subject to increased monitoring (the FATF "grey list") or as a high-risk jurisdiction subject to a call for action (the FATF "black list"), your access to certain features of the Service may be subject to enhanced due diligence, additional documentation requirements, transaction limits, or manual review, and may be delayed or declined at OWNKEY's discretion.
  • Local legal restrictions. It is your responsibility to determine whether the use of digital assets, virtual asset services, or card products of this kind is lawful in your country of residence. OWNKEY does not represent that the Service is appropriate, available, or authorised for use in every country from which it may be accessed, and does not hold a licence or authorisation in every country where Users may be located.
  • Country-specific notices. Where required by local law, OWNKEY may present you with an additional notice confirming that the Service is not regulated by, or licensed with, the relevant local financial or virtual-asset regulator in your country, prior to completing your registration.
  • Updates. OWNKEY may add, remove, or otherwise change restricted or enhanced-due-diligence jurisdictions at any time, including in response to changes in applicable sanctions regimes, FATF classifications, or OWNKEY's own risk assessment, without prior notice where required for compliance purposes.

Annex B — In-App Consent Texts

This Annex sets out the short-form texts displayed alongside individual consent actions (e.g., checkboxes) within the Platform's onboarding and transaction flows. Each text below is presented separately from — and in addition to — acceptance of these Terms and the Privacy Policy, at the point in the user journey where the relevant action occurs.

B.1 KYC and Biometric Data Consent (displayed at identity verification): "To verify your identity, we need to collect and process your identification documents and a photograph/selfie, including biometric data derived from it, and share this information with our identity verification provider(s) and with our Exchange Provider and/or Program Manager/BIN Sponsor for the purposes described in our Privacy Policy. I consent to this collection and processing." [I Agree / I Do Not Agree]

B.2 Risk Acknowledgment (displayed before first currency conversion or wallet funding): "Digital assets can go up or down in value and you may lose some or all of the value you convert or hold. Digital assets held in your wallet are not covered by deposit protection schemes that apply to bank deposits. I understand these risks and confirm I am not converting or storing value I cannot afford to lose." [I Understand and Agree]

B.3 Sanctions / PEP Self-Declaration (displayed during KYC): "I confirm that I am not currently subject to any economic sanctions, and that I am not a politically exposed person (PEP), nor a family member or known close associate of a PEP, except as I have separately disclosed to OWNKEY." [Confirm]

B.4 Marketing Consent (optional, separate from Terms/Privacy Policy acceptance): "I would like to receive news, product updates, and promotional offers from OWNKEY by email and/or push notification. I can withdraw this consent at any time in my account settings." [Yes, keep me updated / No thanks]

B.5 Cardholder Terms Acceptance (displayed at Card issuance): "Your Card is issued by [Program Manager/BIN Sponsor name], not OWNKEY. Please read and accept the Cardholder Terms before your Card is issued." [View Cardholder Terms] [I Accept]