Terms of Use for WellWallet

Welcome to WellWallet. These Terms of Use (“Terms”) govern your access to and use of the WellWallet platform, effective as of 29/08/2025. By using WellWallet, you acknowledge that you have read, understood, and agree to be legally bound by these Terms, which form a binding agreement between you and [WellWallet Operator Entity].

Acceptance of Terms and User Eligibility

By accessing or using the WellWallet platform (“Platform”), you agree to comply with and be bound by these Terms of Use. If you do not accept these Terms, you must not access or use the Platform.

To use the Platform, you must: - Be at least eighteen (18) years of age and possess the legal capacity to enter into binding agreements; - Not be a resident of, or located in, any jurisdiction where use of the Platform is prohibited by law, regulation, or applicable sanctions; - Not be subject to any sanctions or restrictions imposed by the United Nations, the European Union, the United States, the United Kingdom; - Comply with all applicable laws and regulations in your jurisdiction regarding the use of digital assets and custodial wallet services.

By registering for an account or using any services provided by WellWallet, you represent and warrant that you meet all eligibility requirements and that your use of the Platform does not violate any applicable law or regulation.

Definitions

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

Platform: The digital infrastructure operated by WellWallet, including all associated websites, mobile applications, APIs, and backend systems, through which custodial cryptocurrency services and related features are provided.
Services: All products and services made available by WellWallet, including but not limited to custodial wallet services, cryptocurrency conversions, AML (Anti-Money Laundering) screening, transaction monitoring, and recovery support.
AML Checks: Automated and manual processes implemented by WellWallet to assess, monitor, and mitigate risks of money laundering, terrorist financing, and other illicit activities, including real-time screening of transactions and user addresses against relevant risk indicators and sanctions lists.
User Data: Any information or documentation provided by or collected from users in connection with account registration, identity verification, transaction activity, or compliance procedures, including personal data as defined under applicable data protection laws.
Transactions: Any action initiated by a user on the Platform that results in the movement, conversion, or management of digital assets, including deposits, withdrawals, transfers, and currency conversions
Risk Score: A numerical or categorical assessment generated by WellWallet’s AML screening systems to evaluate the risk level associated with a user, wallet address, or transaction, which may trigger additional review or restrictions.
Compliance Officer: The individual appointed by WellWallet with responsibility for overseeing compliance with legal, regulatory, and internal policy requirements, including enforcement of AML, KYC, and sanctions controls.
User: Any individual or legal entity that has registered for, and maintains, an account on the Platform and utilizes any of its products or services.
Account: The unique profile or wallet maintained by a user on the Platform, through which digital assets are held, managed, and transacted.
Sanctions: Any economic or trade restrictions imposed by competent authorities, including but not limited to the United Nations, European Union, United States, United Kingdom, which may affect the ability of users to access or use the Platform.
KYC (Know Your Customer): The process of verifying the identity of users in accordance with applicable laws, regulations, and WellWallet’s internal policies.

These definitions are intended to ensure clarity and consistency throughout these Terms. Additional definitions may be provided in other sections as necessary.

Platform Services and User Rights

WellWallet provides users with a secure, compliant, and user-friendly platform for managing digital assets. The core services offered on the Platform include:

1. Custodial Wallet Services

WellWallet offers custodial storage of supported cryptocurrencies, allowing users to deposit, hold, and manage their digital assets within platform-managed wallets. Users may access their account at any time, subject to compliance and security protocols, and are entitled to view their balances, transaction history, and related account information.

2. Crypto-to-Crypto Conversions

The Platform enables users to convert between supported cryptocurrencies (e.g., USDT, ETH, USDC) using both internal and external liquidity sources. Conversion requests are processed through the Platform’s exchange mechanisms, with the relevant amounts debited and credited to the user’s account upon successful execution. All conversions are subject to applicable fees and transaction limits as set forth in the Fee and Limit Schedule.

3. AML Screening and Compliance

All deposits, internal transfers, and withdrawals are subject to real-time AML (Anti-Money Laundering) risk screening. The Platform employs automated and, where necessary, manual checks to assess the risk profile of transactions and wallet addresses, including screening against sanctions lists and risk scoring. Transactions that exceed certain thresholds or present elevated risk may be subject to additional review, delay, or rejection in accordance with the Platform’s compliance policies.

4. Recovery Support

WellWallet integrates with third-party services to provide support for users affected by crypto scams or unauthorized transactions. Users may access recovery tools and assistance, subject to eligibility and the terms of the relevant service providers.

5. User Rights

Users have the right to access and use the Platform’s services in accordance with these Terms and applicable law.
Users may manage their accounts, initiate transactions, and request withdrawals, subject to compliance with Platform policies and regulatory requirements.
Users are entitled to clear information regarding applicable fees, limits, and the status of their transactions.
Users may contact WellWallet support for assistance with account management, compliance inquiries, or dispute resolution.

The Platform reserves the right to modify, suspend, or discontinue any service at its discretion, with reasonable notice provided to users where practicable.

User Responsibilities and Obligations

As a condition of using the Platform, users agree to the following responsibilities and obligations:

1. Provision of Accurate Information

Users must provide true, accurate, current, and complete information during account registration and at all times thereafter. Users are responsible for promptly updating their information to ensure its continued accuracy.

2. Compliance with AML/KYC Requirements

Users must comply with all AML (Anti-Money Laundering) and KYC (Know Your Customer) procedures as required by WellWallet and applicable law. This includes submitting requested identification documents, responding to compliance inquiries, and cooperating with any verification or review processes. Failure to comply may result in suspension or termination of access to the Platform.

3. Safeguarding Credentials

Users are responsible for maintaining the confidentiality and security of their account credentials, including passwords, authentication codes, and any other access controls. Users must immediately notify WellWallet of any unauthorized access, suspected breach, or compromise of their account.

4. Adherence to Platform Policies

Users must adhere to all Platform policies, including but not limited to these Terms of Use, the Privacy Policy, AML Policy, and any other rules or guidelines published by WellWallet. Users are expected to act in good faith and in compliance with all applicable laws and regulations.

5. Legal Compliance

Users are solely responsible for ensuring that their use of the Platform is lawful in their jurisdiction. Users must not use the Platform for any purpose that is unlawful, fraudulent, or prohibited by these Terms or applicable law.

6. Cooperation with Compliance and Investigations

Users must cooperate fully with WellWallet’s compliance team and any lawful requests from regulatory authorities, including providing information, documentation, or access to records as required for audit, investigation, or legal proceedings.

Failure to fulfill these responsibilities may result in account suspension, termination, or other remedial actions as deemed appropriate by WellWallet, in addition to any legal consequences under applicable law.

Restrictions and Prohibited Activities

Users of the Platform are strictly prohibited from engaging in any activity that is unlawful, fraudulent, or contrary to the compliance objectives of WellWallet. The following activities are expressly forbidden:

Money Laundering and Terrorist Financing: Engaging in, facilitating, or attempting to facilitate money laundering, terrorist financing, or any other financial crime.
Fraud and Misrepresentation: Submitting false, misleading, or fraudulent information or documentation during registration, verification, or any transaction.
Circumvention of AML/KYC Controls: Attempting to bypass, evade, or undermine the Platform’s AML (Anti-Money Laundering) and KYC (Know Your Customer) procedures, including structuring transactions to avoid detection or limits.
Use in Sanctioned Jurisdictions: Accessing or using the Platform from, or on behalf of, any country, region, individual, or entity subject to sanctions or embargoes imposed by the United Nations, European Union, United States, United Kingdom.
Use by Sanctioned Persons: Opening or maintaining accounts for, or transacting with, individuals or entities listed on any applicable sanctions list.
Facilitation of Prohibited Transactions: Initiating, receiving, or facilitating transactions involving illicit funds, proceeds of crime, or assets derived from illegal activities.
Abuse of Platform Functionality: Exploiting technical vulnerabilities, using automated scripts or bots without authorization, or engaging in any activity that may disrupt, damage, or impair the Platform’s operations or security.
Violation of Applicable Law: Using the Platform in any manner that violates applicable laws, regulations, or regulatory guidance in any relevant jurisdiction.

WellWallet reserves the right to investigate, suspend, or terminate any account or transaction suspected of involvement in prohibited activities, and to report such matters to the appropriate authorities.

AML and Compliance Procedures

WellWallet maintains a robust compliance infrastructure designed to detect, prevent, and report money laundering, terrorist financing, and other illicit activities, in accordance with applicable laws and international best practices. The Platform’s AML and compliance procedures are as follows:

1. Automated AML Screening

Transaction Monitoring: All deposits, internal transfers, and withdrawals are subject to real-time automated AML screening. Each transaction is evaluated for risk using a combination of internal rules, external AML data providers, and sanctions list checks.
Risk Scoring: The Platform assigns a risk score to each transaction and wallet address based on factors such as transaction size, source, destination, and historical activity. Elevated risk scores may trigger additional review or restrictions.
Threshold-Based Controls: Transactions below certain thresholds are subject to standard screening, while those exceeding predefined limits (e.g., >50,000 USDT) are subject to enhanced due diligence, including screening by multiple independent AML providers.

2. Manual Review and Escalation

Flagged Transactions: Transactions or accounts flagged by automated systems for high risk, unusual patterns, or potential sanctions exposure are escalated for manual review by the Compliance Officer or designated compliance personnel.
Enhanced Due Diligence: For transactions or users presenting elevated risk, WellWallet may require additional information, documentation, or clarification before processing or releasing funds.
Account Restrictions: If a user or transaction is determined to present an unacceptably high risk, WellWallet may freeze the relevant account, block the transaction, or restrict further activity pending investigation.

3. Sanctions and High-Risk Handling

Sanctions Screening: All users and transactions are screened against relevant sanctions lists at onboarding and on an ongoing basis. Positive matches result in immediate escalation and potential account suspension.
High-Risk Outcomes: If a transaction or user is assigned a high risk score or is associated with a sanctioned entity, the Platform will reject the transaction, freeze the account, and notify the user of the action taken, subject to legal and regulatory requirements.

4. Reporting and Recordkeeping

Suspicious Activity Reporting: WellWallet is committed to reporting confirmed or suspected money laundering, terrorist financing, or sanctions violations to the relevant authorities and to cooperating fully with regulatory investigations.
Record Retention: All AML screening results, investigations, and compliance actions are documented and retained in accordance with the Platform’s Storing Records Policy and applicable law.

5. User Cooperation

Information Requests: Users are required to promptly respond to any compliance-related requests for information or documentation. Failure to cooperate may result in account suspension or termination.
Ongoing Monitoring: Users acknowledge that their activity on the Platform is subject to ongoing monitoring and that WellWallet may take any action necessary to ensure compliance with its AML obligations.

These procedures are designed to ensure that WellWallet operates as a secure, compliant, and reputable platform for digital asset management, and to protect both users and the broader financial system from abuse.

Transaction Limits, Fees, and Limits

All transactions on the WellWallet Platform are subject to clearly defined fees and limits, which are designed to ensure transparency, regulatory compliance, and effective risk management.

Fee Structure: WellWallet charges commissions on deposits, withdrawals, conversions, and other supported services. These commissions may be fixed, percentage-based, or a combination thereof, and may include minimum fees or network fees (such as blockchain miner or validator fees). All applicable fees are published in the official Fee Schedule, which is available at https://www.wellwallet.io/tariffs. Service fees for additional features or expedited processing may also apply, as detailed in the Fee Schedule.
Transaction Limits: The Platform imposes minimum and maximum transaction amounts, as well as daily, weekly, and monthly caps, to manage operational risk and comply with legal requirements. These limits are set forth in the Limit Schedule, also published at https://www.wellwallet.io/tariffs. All users are subject to the same transaction limits, unless otherwise required by law, regulation, or risk management considerations (e.g., pending verification or compliance review).
Adjustments and Notifications: WellWallet reserves the right to update or adjust fees and transaction limits at any time in response to changes in regulatory requirements, risk assessments, or operational needs. Any material changes will be communicated to users in advance, and the most current Fee and Limit Schedules will always be available on the tariffs page.
Compliance-Driven Restrictions: In certain circumstances, such as elevated AML risk scores, pending compliance reviews, or regulatory requests, WellWallet may impose temporary or permanent restrictions on transaction amounts, frequency, or access to specific services. These measures are implemented to ensure ongoing compliance with applicable laws and to protect the integrity of the Platform.
User Acknowledgment: By initiating any transaction, users acknowledge and accept the applicable fees and limits, as well as the possibility of changes or restrictions imposed for compliance or risk management purposes.

For further details, users should consult the Commissions and Limits Policy and the published Fee and Limit Schedules.

Liability and Disclaimers

To the maximum extent permitted by law, WellWallet and its affiliates disclaim all liability for any direct, indirect, incidental, consequential, or punitive damages arising from or related to your use of the Platform, including but not limited to:

Transaction Errors and Delays: WellWallet is not liable for losses resulting from transaction errors, processing delays, failed deposits or withdrawals, or interruptions in service, whether caused by technical issues, network congestion, or third-party service providers.
Security Breaches: While WellWallet implements robust security measures, it cannot guarantee absolute protection against unauthorized access, hacking, or other security incidents. Users are responsible for safeguarding their account credentials and devices.
Market Volatility: The value of cryptocurrencies is highly volatile and may fluctuate significantly. WellWallet does not guarantee the value, stability, or liquidity of any digital asset, and is not responsible for losses resulting from market movements or trading decisions.
Technical Limitations: WellWallet does not assume responsibility for tracking the transaction history of Bitcoin (BTC) or other assets where technical limitations prevent comprehensive monitoring. Users acknowledge that certain blockchain features may limit the Platform’s ability to provide full transaction traceability.
Third-Party Services: The Platform may integrate with or rely on third-party service providers for certain features (e.g., liquidity, recovery support). WellWallet is not responsible for the actions, omissions, or failures of such third parties.
Force Majeure: WellWallet is not liable for any failure or delay in performance resulting from events beyond its reasonable control, including but not limited to natural disasters, acts of government, war, civil unrest, or disruptions to internet or blockchain networks.
Platform “As Is”: The Platform and all services are provided “as is” and “as available,” without warranties of any kind, express or implied. WellWallet disclaims all warranties regarding merchantability, fitness for a particular purpose, and non-infringement.

Users are encouraged to review the Risk Disclosure Policy for additional information regarding the risks associated with digital asset transactions and platform use. By using the Platform, users accept all risks and limitations described herein.

Risk Disclosures

The use of the WellWallet platform and engagement in cryptocurrency transactions involve significant risks that users must carefully consider before participating. By accessing or using the Platform, you acknowledge and accept the following risks:

Market Volatility: The value of cryptocurrencies can fluctuate dramatically and unpredictably. Prices may rise or fall rapidly, and there is a risk of total loss of your digital assets.
Regulatory Uncertainty: Laws and regulations governing digital assets and custodial wallet services are evolving and may change without notice. Regulatory actions or changes may impact your ability to use the Platform or access your assets.
Technical Risks: The Platform relies on blockchain technology and third-party service providers. Technical failures, software bugs, cyberattacks, or network disruptions may result in delays, errors, or loss of access to your assets.
Security Risks: While WellWallet implements robust security measures, no system is immune to unauthorized access, hacking, or other malicious activity. Users are responsible for safeguarding their account credentials and devices.
Irreversible Transactions: Cryptocurrency transactions are generally irreversible. Once executed, transactions cannot be undone, and errors may result in permanent loss of funds.
Platform Limitations: Certain technical limitations, such as the inability to fully track Bitcoin (BTC) transaction history, may affect the scope of services and protections available to users.

Users are strongly encouraged to review the [Risk Disclosure Policy] for a comprehensive overview of risks associated with digital asset transactions and platform use. You are solely responsible for understanding and accepting these risks, and for making informed decisions regarding your use of the Platform.

Data Privacy and Security

WellWallet is committed to protecting the privacy and security of user data in accordance with applicable laws and its internal policies. The collection, processing, and storage of personal data are governed by the [Privacy Policy], which forms an integral part of these Terms.

Data Collection: WellWallet collects personal and transactional data necessary for account registration, identity verification, compliance with AML/KYC requirements, transaction processing, and customer support.
Data Processing and Use: User data is processed for the purposes of providing services, fulfilling legal and regulatory obligations, preventing fraud, and enhancing platform security. Data may be analyzed for compliance monitoring and risk management.
Data Storage and Security: All user data is stored securely using industry-standard encryption and access controls. WellWallet implements technical and organizational measures to protect data against unauthorized access, alteration, disclosure, or destruction.
User Rights: Users have the right to access, correct, update, or request deletion of their personal data, subject to legal and regulatory requirements. Requests may be submitted in accordance with the procedures outlined in the Privacy Policy.
Third-Party Providers: Where WellWallet engages third-party service providers for data processing or storage, such providers are contractually required to maintain equivalent standards of data protection and confidentiality.
Legal Compliance: WellWallet processes and retains user data as required by the laws of GDPR and any other relevant regulation.

For further details on data handling practices and user rights, please refer to the [Privacy Policy] and [Data Protection Policy].

Termination and Suspension

WellWallet reserves the right to suspend or terminate user accounts and access to the Platform under the following circumstances:

Violation of Terms: If a user breaches these Terms of Use, any Platform policy, or applicable law or regulation.
Compliance or Legal Requirements: If required by law, regulation, court order, or at the request of regulatory or law enforcement authorities.
AML/KYC or Risk Concerns: If a user fails to comply with AML/KYC procedures, provides false or misleading information, or is identified as presenting an unacceptable risk.
Security or Operational Reasons: If necessary to protect the security, integrity, or proper functioning of the Platform.

Upon suspension or termination, users may lose access to their accounts and any associated digital assets, subject to applicable law and the Platform’s compliance obligations. WellWallet will retain records of user activity and account information as required by its Storing Records Policy and relevant legal requirements. Where practicable, users will be notified of the reason for suspension or termination and may contact support for further information or to appeal the decision, subject to Platform procedures.

Miscellaneous and General Provisions

Amendments: WellWallet reserves the right to amend or update these Terms at any time. Changes will become effective upon posting on the Platform. Continued use of the Platform after such changes constitutes acceptance of the revised Terms.
Severability: If any provision of these Terms is found to be invalid, illegal, or unenforceable, such provision shall be enforced to the maximum extent permissible, and the remaining provisions shall remain in full force and effect.
Assignment: WellWallet may assign or transfer its rights and obligations under these Terms to any affiliate or successor entity without notice or consent. Users may not assign or transfer their rights or obligations without prior written consent from WellWallet.
Force Majeure: WellWallet shall not be liable for any failure or delay in performance resulting from events beyond its reasonable control, including but not limited to natural disasters, war, civil unrest, government action, or disruptions to internet or blockchain networks.
Entire Agreement: These Terms, together with any policies or documents incorporated by reference, constitute the entire agreement between the user and WellWallet regarding the use of the Platform and supersede all prior or contemporaneous understandings, communications, or agreements, whether written or oral.

By accessing or using the Platform, you acknowledge and agree to be bound by these Terms and all incorporated policies.