HoyaPay Terms of Service

Effective Date: December 1, 2025

These Terms of Service (the “Terms”) are entered into by and between HoyaPay (the “Platform” or “HoyaPay”) and the user who accesses or uses the services provided by the Platform (the “User” or “you”). These Terms govern your rights and obligations when using the services offered by HoyaPay, including but not limited to wallet services, cryptocurrency-related services, virtual crypto cards, physical crypto cards (to be launched in the future), USDⒽ reward points, U.S. dollar virtual accounts, and wealth management or related value-added services.

By registering for, logging into, or using any service provided by the Platform, you acknowledge that you have read, fully understood, and agreed to be bound by all provisions of these Terms.

1.、Definitions

• Wallet An electronic wallet system provided by the Platform for storing, managing, and transferring funds and crypto assets.

• Account A personal account registered by a User on the Platform, including all associated sub-accounts, wallets, cards, and related functionalities.

• Funds Cryptocurrencies, stablecoins, digital assets, or other asset types supported by the Platform and held within a User’s Account.

• Card A virtual crypto card or a physical crypto card issued by the Platform to a User, where applicable.

• USDⒽ Points Promotional or reward-based points provided by the Platform, which do not constitute financial products or cash equivalents.

2、HoyaPay Services

• The services currently provided by the Platform include, but are not limited to:

  • Electronic wallet services

  • Cryptocurrency-related services

  • Virtual crypto cards

  • Physical crypto cards (to be launched in the future)

  • USDⒽ reward points

  • U.S. dollar virtual accounts

  • Wealth management and related value-added services

  The Platform reserves the right to modify, add, suspend, or terminate any part of the services at any time due to operational, regulatory, or risk management considerations.

3、User Eligibility and Account Management

• Users must be at least 18 years of age and have full legal capacity.

• Users must provide true, accurate, complete, and up-to-date registration information.

• Users are solely responsible for safeguarding their account credentials, passwords, verification information, card details, and device security.

• Any unauthorized use must be reported to the Platform immediately.

• The Platform may require identity verification (KYC) in accordance with applicable laws or risk control requirements.

• Users who fail to complete or pass KYC verification may have their transactions, withdrawals, card usage, or other features restricted.

4、Funds Deposit, Withdrawal, and Transaction Rules

• Users may deposit crypto assets or other supported funds into their Wallets through methods supported by the Platform.

• Blockchain transactions are irreversible; Users are solely responsible for verifying transaction details.

• The Platform may charge fees for deposits, transfers, withdrawals, or card transactions, subject to Platform announcements.

• Users represent and warrant that all funds originate from lawful sources and do not involve money laundering, fraud, terrorist financing, or other illegal activities.

5、Card Services and Right of Set-Off

5.1 Card Usage

• Users may use virtual or physical Cards for purchases, subscriptions, or other lawful transactions.

Final transaction amounts may differ due to exchange rate fluctuations, fees, authorization adjustments, or settlement delays.

5.2 Outstanding Balances and Automatic Settlement

Outstanding balances or negative balances on a Card account may arise due to, including but not limited to:

• Exchange rate differences

• Delayed merchant presentment

• Completion of pre-authorizations

• Subscription renewals

Failed transaction reversals

The User expressly agrees and authorizes the Platform, without prior notice, to directly deduct and set off the corresponding amount from any other Wallets, sub-accounts, U.S. dollar virtual accounts, or available funds held within the User’s HoyaPay Account to settle such outstanding balances.

If available funds are insufficient, the Platform may:

• Restrict or suspend Card and Account functions

• Require the User to cover the outstanding amount

• Take other measures as permitted by applicable laws

Such settlement actions shall not constitute misappropriation of User funds, and the User shall not raise any objection, claim, or demand for compensation.

6、USDⒽ Points Program

6.1 Nature of Points

• USDⒽ Points are promotional rewards and have no cash value.

• They are not financial products, stored value, or payment instruments.

• They do not constitute any debt or payment obligation of the Platform.

6.2 Usage Restrictions

• Points may only be used for purposes announced by the Platform.

• Points may not be transferred, sold, gifted, pledged, or traded off-platform.

6.3 Platform Management Rights

• The Platform may adjust, cancel, or reclaim Points due to abnormal activity, violations, or system errors.

• The Platform may modify the Points program, validity period, or usage rules at any time.

7、User Rights and Obligations

• Users may access, review, and manage their account information at any time, including wallet balances, transaction records, and card usage history.

• Users are responsible for maintaining the security of their accounts, login credentials, verification information, card data, and devices.

• Any loss arising from failure to properly safeguard such information shall be borne solely by the User.

• Users shall not use the Platform for any activity that violates applicable laws, these Terms, or public order and morals, including fraud, money laundering, terrorist financing, infringement of rights, or other unlawful purposes.

• The Platform may take actions such as restricting features, suspending services, or terminating accounts without liability if violations occur.

8、User-Generated Content (UGC) Policy

Users shall not upload, publish, transmit, or otherwise provide content that includes:

• Content that violates laws or regulations

• Content that infringes intellectual property, privacy, or other rights

• Violent, pornographic, hateful, discriminatory, threatening, offensive, or abusive content

• Fraudulent, misleading, false, or otherwise inappropriate content

The Platform may, at its sole discretion and without prior notice, remove such content and restrict, suspend, or terminate User accounts.

Users may report suspected violations through customer support. The Platform will review such reports within a reasonable time but does not guarantee specific actions.

Users acknowledge that the Platform has no obligation to pre-screen UGC and assumes no responsibility for its legality, accuracy, or completeness.

9、Data Collection and Privacy

• The Platform may collect account information, usage data, transaction records, device information, and identity verification data.

• Such data is used for service provision, regulatory compliance, risk control, fraud prevention, and service improvement.

• The Platform does not sell personal data and only shares it with third parties when necessary (e.g., KYC providers or payment service providers).

• For details, please refer to the Privacy Policy.

10、Third-Party Services Disclaimer

• The Platform may integrate third-party services, including payment APIs, KYC providers, or blockchain service providers.

• The availability, security, and accuracy of such services are the responsibility of the third parties, and the Platform bears no liability for losses arising therefrom.

11、Risk Disclosure

• Digital assets involve high market volatility and technological risks.

• Blockchain transactions are irreversible.

• Losses resulting from compromised devices, private keys, or credentials are the sole responsibility of the User.

• The Platform is not liable for losses caused by force majeure or third-party factors.

12、Account Termination

• Users may request account deletion in accordance with Platform procedures.

• Certain data may be retained as required by law or risk management policies.

• The Platform may restrict, suspend, or terminate accounts for violations.

13、Limitation of Liability

• The Platform shall only be liable for direct damages attributable to it, and such liability shall not exceed the fees paid by the User during the relevant period.

• The Platform shall not be liable for indirect, incidental, punitive, or consequential damages.

14、Governing Law and Jurisdiction

• These Terms are governed by the laws of the jurisdiction where the Platform operates.

• In the event of a dispute, the parties shall first attempt to resolve it through good-faith negotiation. Failing such resolution, disputes shall be submitted to a court of competent jurisdiction.

15、Relationship with Apple / Google

• All virtual assets, points, rewards, and promotional activities provided by the Platform are not affiliated with Apple Inc. or Google LLC.

• Apple and Google do not participate in, endorse, or assume any responsibility for transactions, redemptions, distributions, or legal obligations.

16、Miscellaneous

• The Platform may revise these Terms at any time, and such revisions shall take effect upon announcement.

• If any provision of these Terms is held invalid, the remaining provisions shall remain in full force and effect.