Terms of Service

Last updated: March 2026

These Terms of Service (the “Terms”) constitute a legally binding agreement between you (whether an individual or a legal entity, hereinafter referred to as “you” or “User”) and Fintra Ltd, a company incorporated under the laws of the Hong Kong Special Administrative Region (“Fintra Ltd,” “we,” “us,” or “the Company”), governing your access to and use of the fintrapay platform, including all associated services, applications, application programming interfaces, and related infrastructure (collectively, the “Platform”).

Please read these Terms carefully before accessing or using the Platform. By accessing or using any part of the Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms in their entirety.

1. Acceptance of Terms

By registering for an account, accessing the Platform, or using any of the Services provided through the Platform, you expressly agree to be bound by these Terms and all applicable policies, guidelines, and amendments incorporated herein by reference. If you are entering into these Terms on behalf of a company, organisation, or other legal entity, you represent and warrant that you have the authority to bind such entity to these Terms, in which case the terms “you” and “User” shall refer to such entity.

You must be at least eighteen (18) years of age, or the age of legal majority in your jurisdiction, whichever is greater, to use the Platform. By using the Platform, you represent and warrant that you meet this minimum age requirement. If you do not agree to these Terms or do not meet the eligibility requirements, you must not access or use the Platform.

These Terms, together with our Privacy Policy, form a binding agreement between you and Fintra Ltd. Your continued use of the Platform following any modifications to these Terms constitutes your acceptance of such modifications.

2. Definitions

For the purposes of these Terms, the following definitions shall apply:

• “Platform” means the fintrapay web application, dashboard, APIs, smart contracts, and all related infrastructure operated by Fintra Ltd for the purpose of facilitating stablecoin payment processing.
• “Services” means all products, features, and functionalities offered through the Platform, including but not limited to payment gateway services, payout processing, withdrawal facilitation, the Earn product, and API access.
• “Merchant” means any individual, company, or legal entity that registers an account on the Platform for the purpose of accepting stablecoin payments, initiating payouts, or utilising other Services.
• “User” means any person or entity that accesses or uses the Platform, including Merchants, their customers, and any other visitors.
• “Custodial Mode” means the operating mode in which the Platform generates and manages deposit addresses on behalf of the Merchant, holds received funds in platform-controlled wallets, and maintains Merchant balances within the Platform’s database.
• “Non-Custodial Mode” means the operating mode in which payments are processed through a smart contract payment splitter that automatically routes funds directly to the Merchant’s own wallet, with the Platform never holding or controlling Merchant funds at any time.
• “Invoice” means a payment request created by a Merchant through the Platform, specifying the amount, currency, blockchain network, and operating mode for a particular transaction.
• “Payout” means a transfer of funds initiated by a Merchant from their custodial balance to any external wallet address, whether as a single transaction or as part of a batch operation.
• “Withdrawal” means a transfer of custodial funds from the Platform to the Merchant’s own registered wallet address for the applicable blockchain network.
• “Earn Contract” means a fixed-term arrangement through which a Merchant locks a specified amount of stablecoins on the Platform in exchange for daily interest accrual at an agreed annual percentage yield.
• “Stablecoin” means a digital asset designed to maintain a stable value relative to a reference currency (typically the United States Dollar), including but not limited to USDT, USDC, DAI, FDUSD, TUSD, and PYUSD.
• “Blockchain” means a distributed ledger technology network supported by the Platform, including TRON, BNB Smart Chain (BSC), Ethereum, Solana, Base, Arbitrum, and Polygon.

3. Eligibility

To be eligible to use the Platform and Services, you must satisfy all of the following requirements:

• You must be at least eighteen (18) years of age or the age of legal majority in your jurisdiction, whichever is greater.
• If you are using the Platform on behalf of a legal entity, such entity must be duly organised, validly existing, and in good standing under the laws of its jurisdiction of incorporation or formation.
• Neither you nor, if applicable, any of your beneficial owners, directors, officers, or principals are named on any sanctions list maintained by the United Nations, the European Union, the United States Department of the Treasury (including the OFAC Specially Designated Nationals List), the United Kingdom’s HM Treasury, or any other applicable governmental authority.
• You are not a resident or national of, nor are you accessing the Platform from, any jurisdiction that is subject to comprehensive economic or trade sanctions, or any jurisdiction from which the Company has determined, in its sole discretion, to restrict access.
• You are solely responsible for determining and ensuring compliance with all laws, regulations, and rules applicable to your use of the Platform and the Services within your own jurisdiction, including but not limited to laws governing payments, digital assets, taxation, data protection, and consumer protection.

The Company reserves the right to verify your eligibility at any time and to refuse, suspend, or terminate your access to the Platform if any of the foregoing requirements are not satisfied or if the Company reasonably believes that your use of the Platform may expose it to legal or regulatory risk.

4. Account Registration

To access certain features of the Platform, you must register for an account by providing accurate, complete, and current information, including your company name, email address, and a secure password. You agree to promptly update your account information to ensure it remains accurate and complete at all times.

Each individual or legal entity may maintain only one (1) account on the Platform unless expressly authorised by the Company in writing. Duplicate accounts may be suspended or terminated without notice.

Upon registration, you will be issued a unique API key and API secret. The API secret is displayed once at the time of issuance and cannot be retrieved thereafter. All API requests are authenticated using HMAC-SHA256 cryptographic signatures, which require your API secret for computation. You are solely responsible for safeguarding your API key, API secret, passwords, and all other credentials associated with your account.

You are responsible for all activities that occur under your account, whether or not authorised by you. You must notify the Company immediately at support@fintrapay.io if you become aware of any unauthorised access to or use of your account. The Company shall not be liable for any loss or damage arising from your failure to maintain the confidentiality of your account credentials.

5. Services Description

The Platform provides a stablecoin payment gateway and related financial infrastructure services designed for merchants and businesses. The Services include, but are not limited to:

5.1 Payment Gateway

The Platform enables Merchants to accept stablecoin payments from their customers in both Custodial Mode and Non-Custodial Mode. In Custodial Mode, the Platform generates unique deposit addresses derived from a hierarchically deterministic (HD) wallet structure, receives and holds funds on behalf of the Merchant, and credits the Merchant’s balance after deducting applicable fees. In Non-Custodial Mode, payments are processed through an on-chain smart contract payment splitter that automatically distributes funds between the Merchant’s wallet and the Platform’s fee wallet, ensuring the Platform never takes custody of Merchant funds.

5.2 Payouts

Merchants using Custodial Mode may initiate payouts from their custodial balance to any valid external wallet address. Payouts may be submitted individually or as part of a batch operation comprising multiple recipients. All payouts are subject to approval workflows as configured for the Merchant’s account.

5.3 Withdrawals

Merchants using Custodial Mode may withdraw funds from their custodial balance to their own registered wallet address for the applicable blockchain network. Withdrawal destination addresses are determined by the wallet addresses registered in the Merchant’s account settings and may not be specified arbitrarily at the time of withdrawal. This measure is designed to prevent misdirected transfers.

5.4 Earn Product

The Platform offers an Earn product that enables Merchants to lock stablecoins for a fixed term in exchange for daily interest accrual at an annual percentage yield (APY) determined by the Company at the time of contract creation. Interest is funded from the Company’s treasury and is not derived from lending or investing Merchant principal. The Earn product is available exclusively to Merchants operating in Custodial Mode.

5.5 Multi-Chain Support

The Platform supports transactions across seven (7) blockchain networks — TRON, BNB Smart Chain, Ethereum, Solana, Base, Arbitrum, and Polygon — and six (6) stablecoins — USDT, USDC, DAI, FDUSD, TUSD, and PYUSD. Not all stablecoins are available on every blockchain network. The Company reserves the right to add or remove support for specific blockchain networks or stablecoins at any time, with reasonable notice to affected Users.

6. Fees and Charges

The following fee structure applies to the use of the Platform:

• Transaction Fee: A fee of 0.4% (forty basis points) is charged on every successful payment transaction processed through the Platform, whether in Custodial Mode or Non-Custodial Mode. This is among the lowest transaction fees in the stablecoin payment processing industry.
• Monthly Fees: None. The Platform does not charge any recurring monthly subscription or maintenance fees.
• Setup Fees: None. Account registration and onboarding are provided at no cost.
• Gas Fees (Custodial Mode): Blockchain network transaction fees (commonly referred to as “gas fees”) incurred during relay sweep operations in Custodial Mode are covered by the Platform and are not charged to the Merchant.
• Earn APY Rates: Annual percentage yield rates for the Earn product range from 3% to 10%, as determined by the Company and specified at the time of each Earn Contract creation. APY rates are subject to change for new contracts at the Company’s discretion.

The Company reserves the right to modify the fee structure at any time. Any material changes to fees will be communicated to Users with at least thirty (30) days’ prior written notice via email or through the Platform dashboard. Continued use of the Platform after the effective date of any fee change constitutes acceptance of the revised fee structure.

7. Payment Processing

When a Merchant creates an Invoice through the Platform, a unique payment address is generated for the specified blockchain network and operating mode. Customers make payments by sending the designated stablecoin to this address.

The Platform monitors supported blockchain networks for incoming transactions and detects payments to generated addresses. Upon detection, the Platform tracks the number of network confirmations accrued by the transaction. A payment is considered confirmed and final only after the applicable confirmation threshold has been reached for the relevant blockchain network:

• Ethereum: 12 block confirmations
• BNB Smart Chain (BSC): 15 block confirmations
• TRON: 20 block confirmations
• Solana: 32 slot confirmations
• Base: 12 block confirmations (on Layer 1)
• Arbitrum: 12 block confirmations (on Layer 1)
• Polygon: 128 block confirmations

Settlement timing depends on the speed and congestion of the underlying blockchain network. The Company does not guarantee the performance, availability, or throughput of any blockchain network, and shall not be liable for delays, failures, or losses resulting from network congestion, forks, reorganisations, or any other blockchain-level event beyond the Company’s reasonable control.

8. Custodial Services

When operating in Custodial Mode, the Platform generates unique deposit addresses for each Invoice using hierarchically deterministic (HD) wallet derivation. The underlying seed phrases are encrypted at rest using AES-256 encryption, and private keys are derived on-the-fly in memory and are never stored in the database.

Upon confirmation of a payment, the received funds are swept from the deposit address to the Platform’s pooled hot wallet via a two-phase relay sweep process. The Merchant’s custodial balance is credited in the Platform’s database, net of applicable fees.

Merchant custodial balances are tracked in the Platform’s database on a per-chain, per-token basis. Withdrawals from custodial balances may only be directed to wallet addresses that the Merchant has registered in their account settings. This restriction is a security measure intended to protect Merchants from unauthorised fund transfers.

While the Company employs commercially reasonable security measures to safeguard custodial funds, including encryption, access controls, and operational safeguards, you acknowledge that no system is entirely immune to risk. The Company does not provide insurance or a guarantee against loss of custodial funds resulting from unforeseen circumstances, including but not limited to sophisticated cyberattacks, undiscovered software vulnerabilities, or catastrophic infrastructure failures.

9. Non-Custodial Services

When operating in Non-Custodial Mode, payments are routed through an on-chain smart contract payment splitter deployed on the applicable blockchain network. The smart contract automatically distributes each payment such that 99.6% of the received amount is transferred directly to the Merchant’s own wallet and 0.4% is transferred to the Platform’s fee wallet. This split occurs atomically within a single transaction.

To use Non-Custodial Mode, the Merchant must provide an extended public key (XPUB) for the applicable blockchain network. The Platform uses the XPUB to derive unique payment addresses for each Invoice without ever having access to the Merchant’s private keys.

In Non-Custodial Mode, the Platform never holds, controls, or has custody of Merchant funds at any time. As a result, the Merchant is solely responsible for the security and management of their own wallets, private keys, and received funds. The Platform shall have no liability for any loss of funds resulting from the Merchant’s loss of private keys, wallet compromise, or any other event affecting the Merchant’s own infrastructure.

10. Earn Product

The Earn product allows Merchants to lock a specified amount of stablecoins from their custodial balance for a fixed term in exchange for daily interest accrual. The key terms governing the Earn product are as follows:

• Interest Accrual: Interest accrues daily, calculated as the principal amount multiplied by the agreed APY divided by 365. Interest is credited to the Earn Contract in the Platform’s database and may be withdrawn periodically.
• Interest Funding: All interest payable under Earn Contracts is funded from the Company’s treasury. The Company does not lend, invest, trade, or otherwise deploy Merchant principal to generate interest. Merchant principal remains in the Platform’s hot wallet for the duration of the Earn Contract term.
• Interest Withdrawal: Merchants may withdraw accrued interest at any time, subject to a minimum withdrawal amount of ten United States Dollars (USD $10) equivalent. Interest withdrawals are disbursed from the Company’s treasury wallet to the Merchant’s registered wallet for the applicable blockchain network.
• Maturity: Upon completion of the fixed term, the full principal amount is returned to the Merchant’s registered wallet from the Platform’s hot wallet, and any remaining accrued interest is disbursed from the treasury wallet.
• Early Termination (Break): A Merchant may elect to terminate an Earn Contract before maturity. In the event of early termination, the Merchant receives their principal amount minus any interest that has already been withdrawn. Any accrued but undrawn interest is forfeited and retained in the Company’s treasury. Early termination is irreversible.

The Company reserves the right to modify APY rates for new Earn Contracts at any time. APY rates applicable to existing active Earn Contracts shall not be modified during the term of those contracts. The Earn product does not constitute a deposit, investment, or security, and is not insured or guaranteed by any governmental authority. Participation in the Earn product involves risk, and Users should carefully evaluate their own financial circumstances before participating.

11. Prohibited Activities

You agree that you will not use the Platform for, or in connection with, any of the following prohibited activities:

• Money laundering, or any activity designed to disguise the origin, nature, or destination of funds derived from criminal or unlawful activity.
• Financing of terrorism, or providing material support to individuals or organisations designated as terrorist entities by any governmental authority.
• Evasion of economic or trade sanctions imposed by the United Nations, the European Union, the United States, the United Kingdom, Hong Kong, or any other applicable jurisdiction.
• Fraud, misrepresentation, identity theft, or any other deceptive practice intended to obtain funds, property, or information from third parties under false pretences.
• The purchase, sale, or facilitation of illegal goods or services, including but not limited to controlled substances, unlicensed weapons, stolen property, counterfeit goods, or content that exploits minors.
• Market manipulation, including wash trading, spoofing, layering, pump-and-dump schemes, or any other conduct intended to artificially influence the price or trading volume of any digital asset.
• Unauthorised access to or interference with the Platform’s infrastructure, servers, networks, or systems, including any attempt to gain access to accounts, data, or systems that you are not authorised to access.
• Circumvention or attempted circumvention of any security measures, rate limits, access controls, or usage restrictions implemented by the Platform.
• Use of the Platform in any manner that violates applicable laws, regulations, or rules in any jurisdiction.

The Company reserves the right to investigate suspected violations of these prohibitions and to take any action it deems appropriate, including but not limited to suspending or terminating your account, freezing funds, reporting activity to law enforcement authorities, and cooperating with regulatory investigations.

12. KYC and Identity Verification

The Company may require you to complete identity verification (commonly referred to as “Know Your Customer” or “KYC”) procedures as a condition of accessing certain features of the Platform, particularly those involving Custodial Mode services, payouts, withdrawals, and the Earn product.

Identity verification may include, but is not limited to, the provision of government-issued identification documents, proof of address, beneficial ownership information (for legal entities), and such other documentation or information as the Company may reasonably request.

The Company reserves the right to request additional verification at any time, including in response to changes in applicable law, regulatory guidance, suspicious activity, or elevated transaction volumes. Your account may be suspended, restricted, or subject to reduced functionality pending completion of any requested verification. The Company shall not be liable for any losses or damages arising from the suspension or restriction of your account in connection with identity verification procedures.

You agree to provide truthful, accurate, and complete information in connection with any verification request, and to promptly update such information if it changes. The provision of false, misleading, or incomplete information constitutes a material breach of these Terms and may result in immediate termination of your account.

13. Intellectual Property

All intellectual property rights in and to the Platform, including but not limited to the software, source code, object code, algorithms, user interface designs, trademarks, logos, trade names, documentation, and all other proprietary materials, are and shall remain the exclusive property of Fintra Ltd or its licensors.

Subject to your compliance with these Terms, the Company grants you a limited, non-exclusive, non-transferable, revocable licence to access and use the Platform and its API solely for the purpose of utilising the Services in accordance with these Terms and the applicable API documentation. This licence does not convey any ownership interest in the Platform or any underlying intellectual property.

You shall not, and shall not permit any third party to: (a) copy, modify, adapt, translate, or create derivative works based on the Platform or any part thereof; (b) reverse engineer, disassemble, decompile, or otherwise attempt to derive the source code of the Platform; (c) sublicense, lease, rent, loan, or otherwise transfer access to the Platform to any third party except as expressly permitted through the API; (d) remove, obscure, or alter any proprietary notices, labels, or marks on the Platform; or (e) use the Platform for competitive analysis, benchmarking, or the development of competing products or services.

14. Limitation of Liability

To the maximum extent permitted by applicable law, Fintra Ltd, its directors, officers, employees, agents, affiliates, and licensors shall not be liable for any indirect, incidental, special, consequential, punitive, or exemplary damages, including but not limited to damages for loss of profits, revenue, data, goodwill, or other intangible losses, arising out of or in connection with your use of or inability to use the Platform, regardless of the theory of liability (whether in contract, tort, negligence, strict liability, or otherwise) and even if the Company has been advised of the possibility of such damages.

Without limiting the foregoing, the Company shall have no liability for losses or damages arising from:

• Delays, failures, congestion, forks, reorganisations, or any other performance issues affecting any blockchain network, which are inherently decentralised systems outside the Company’s control.
• Vulnerabilities, exploits, or failures in third-party smart contracts, protocols, bridges, or other decentralised infrastructure not developed or operated by the Company.
• Loss, theft, or compromise of private keys, seed phrases, wallet credentials, or any other authentication material held or managed by the Merchant or User.
• Fluctuations in the market value of stablecoins, including de-pegging events, issuer insolvency, or regulatory actions affecting stablecoin issuers.
• Force majeure events, including but not limited to natural disasters, pandemics, acts of war or terrorism, government actions, regulatory changes, power failures, internet outages, or cyberattacks of unprecedented scale or sophistication.

To the extent that liability cannot be excluded under applicable law, the Company’s aggregate liability to you for all claims arising out of or in connection with these Terms or your use of the Platform shall not exceed the total amount of fees paid by you to the Company in the twelve (12) months immediately preceding the event giving rise to the claim.

15. Indemnification

You agree to indemnify, defend, and hold harmless Fintra Ltd, its directors, officers, employees, agents, affiliates, successors, and assigns from and against any and all claims, demands, actions, liabilities, damages, losses, costs, and expenses (including reasonable legal fees and disbursements) arising out of or in connection with: (a) your use of the Platform or the Services; (b) your breach of these Terms or any applicable law, regulation, or rule; (c) your violation of any third-party rights, including intellectual property rights, privacy rights, or contractual rights; (d) any activity conducted through your account, whether or not authorised by you; or (e) any content, data, or information submitted by you through the Platform.

This indemnification obligation shall survive the termination or expiration of these Terms and your use of the Platform.

16. Suspension and Termination

The Company may, in its sole discretion and without prior notice, suspend, restrict, or terminate your access to the Platform and the Services, in whole or in part, for any reason, including but not limited to:

• A breach or suspected breach of these Terms, including engagement in Prohibited Activities.
• Failure to complete or cooperate with identity verification procedures when requested.
• Activity that the Company reasonably believes may expose it to legal, regulatory, or financial risk.
• A request or order from a law enforcement, judicial, or regulatory authority.
• Extended periods of account inactivity.

You may close your account at any time by contacting the Company at support@fintrapay.io. Upon account closure, you must withdraw any remaining custodial balance prior to the effective date of closure. Any funds remaining in your account after closure may be subject to a recovery process, and the Company reserves the right to impose reasonable administrative fees for the recovery of residual balances.

The following provisions shall survive the termination or expiration of these Terms: Definitions, Intellectual Property, Limitation of Liability, Indemnification, Dispute Resolution, and any other provisions which by their nature are intended to survive termination. The Company’s data retention obligations under applicable law shall also survive termination, and the Company may retain records of your account and transactions for such periods as may be required by law or as are necessary for the protection of the Company’s legitimate interests.

17. Dispute Resolution

These Terms and any dispute, controversy, or claim arising out of or in connection with these Terms, including their formation, validity, binding effect, interpretation, performance, breach, or termination, as well as non-contractual claims, shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region, without regard to its conflict of laws principles.

In the event of any dispute arising under or in connection with these Terms, the parties agree to first attempt to resolve the dispute through good-faith negotiation for a period of thirty (30) days, commencing upon written notice of the dispute from one party to the other.

If the dispute is not resolved through negotiation within the thirty (30) day period, either party may submit the dispute to binding arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) in accordance with its then-current rules. The arbitration shall be conducted in the English language by a single arbitrator appointed in accordance with the applicable rules. The seat of arbitration shall be Hong Kong. The arbitral award shall be final and binding on both parties and may be enforced in any court of competent jurisdiction.

Notwithstanding the foregoing, either party may seek injunctive or other equitable relief in any court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation, or violation of intellectual property rights or confidential information.

18. Amendments

The Company reserves the right to amend, modify, or replace these Terms at any time. If the Company makes material changes to these Terms, it will provide you with at least thirty (30) days’ prior notice before the changes take effect. Notice may be provided by email to the address associated with your account, by a prominent notice on the Platform dashboard, or by other reasonable means.

Your continued access to or use of the Platform after the effective date of any amended Terms constitutes your acceptance of such amended Terms. If you do not agree to the amended Terms, you must cease using the Platform and close your account before the effective date of the amendments.

Non-material changes, such as typographical corrections, formatting adjustments, or clarifications that do not alter the substance of these Terms, may be made without prior notice.

19. Severability

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction or arbitral tribunal, such invalidity, illegality, or unenforceability shall not affect the validity, legality, or enforceability of the remaining provisions of these Terms. The remaining provisions shall continue in full force and effect, and the invalid, illegal, or unenforceable provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable while preserving the original intent of the parties to the greatest extent possible.

20. Contact

If you have any questions, concerns, or requests regarding these Terms or the Platform, please contact us at: