Terms of Use for MyTonWallet

Effective Date: November 4, 2025

These Terms of Use (the "Terms") constitute a legally binding agreement between you ("User," "you") and My Wallet Apps Ltd., a company incorporated under the laws of the British Virgin Islands on September 3, 2025, with registration number 2186197 (the "Company," "we," "us," or "our").

These Terms govern your access to and use of the MyTonWallet application and its related services (collectively, the "Platform"). By accessing or using our Platform, you acknowledge that you have read, understood, and agree to be bound by these Terms in their entirety.

If you do not agree to these Terms in their entirety, you must immediately cease using the Platform. Please note that ceasing to use the Platform does not affect your ownership of or access to your digital assets, as they are stored on the blockchain and not controlled by the Platform itself. You can manage your digital assets at any time by any other compatible wallet software.

We reserve the right to modify these Terms at any time in our sole discretion. If we make changes that we deem material, we will provide reasonable notice through the Platform (for example, by a notice on the main screen). A change will be considered "material" if it significantly alters your core rights or obligations. Examples of material changes include, but are not limited to: significant changes to our limitation of liability; the introduction of new fees for our services; a change to the dispute resolution provisions; a substantial change to our data processing practices as described in the Privacy Policy; or a change in the governing law. For minor changes, such as correcting typographical errors, we may not provide a specific notice. Your continued use of the Platform after any changes become effective will constitute your acceptance of the new Terms.

1. Nature of the Platform and Services

1.1. MyTonWallet is a multi-chain, non-custodial cryptocurrency wallet that allows you to interact with various public blockchains, including primarily The Open Network (TON). This means that:

  • The Platform provides you with tools to generate your own private keys and recovery phrase. This information is stored exclusively on your own device. You are solely and exclusively responsible for securely storing it. We never have access to your private keys or recovery phrase. Consequently, we cannot recover your assets if you lose your credentials;
  • All transactions are signed locally on your device, and our role is limited to broadcasting these signed messages to the relevant blockchain network for validation. Your complete transaction history is publicly available on the blockchain. We do not store this general history, but we may process and retain limited transaction data when you use specific integrated services, as detailed in our Privacy Policy. At all times, we have no access to or control over your digital assets;
  • The Platform provides you with tools to manage your digital assets. This includes not only sending and receiving cryptocurrency, but also accessing more advanced services such as:
    • Swaps: The ability to exchange one cryptocurrency for another directly within the Platform. Our built-in aggregator service helps find the best available exchange rates from third-party decentralized exchanges;
    • Staking: The ability to "stake" or lock up your digital assets to help secure a blockchain network and earn rewards. This includes participating in our own staking services (Stakee) and staking our native token ($MY).
  • The Platform may serve as a gateway to the broader Web3 ecosystem, allowing Users to discover and interact with a variety of third-party decentralized applications and services. Such interactions may include, but are not limited to:
    • a) accessing third-party gateways and on/off-ramp services for the purpose of purchasing digital assets with fiat currency or selling digital assets for fiat currency, as well as interacting with third-party decentralized exchange protocols for the purpose of swapping digital assets;
    • b) accessing and managing a wide variety of digital assets, including fungible tokens and non-fungible tokens (NFTs);
    • c) participating in third-party staking protocols and services.

In all such interactions, the Company's role is strictly limited to providing the technical interface of the Platform. You acknowledge and agree that the listing or accessibility of any third-party service through the Platform does not constitute an approval, endorsement, or recommendation by the Company. These third-party services are not owned, controlled, or operated by us and may involve significant risks. Your interaction with any third-party service is at your own sole risk, and you are solely responsible for reviewing the terms of any such service before using it. The Company expressly disclaims all responsibility and liability for any loss or damage of any kind incurred as a result of your use of any third-party services accessed through the Platform.

2. The Company's Integrated Services

2.1. In addition to the core non-custodial wallet functionality, the Platform provides you with access to our own integrated financial services. By using any of these services, you agree to the specific terms outlined below.

2.2. Swap Aggregator. Our swap aggregator is a tool that helps you find the best available exchange rates from various third-party decentralized exchanges. We are not a party to your trade, a broker, or a trading platform; we only provide the aggregation service that constructs and proposes the transaction for your approval.

2.3. These swaps are processed by various third-party services, which may include on-chain protocols or other exchange providers (like cross-chain bridges or aggregators). All swaps are subject to network conditions, for which the Company is not responsible, as well as for the inherent risks of blockchain networks, including but not limited to price volatility and slippage. The Company is not responsible for any losses incurred due to such risks.

2.4. Staking Services. We offer proprietary staking services where you can delegate your digital assets to earn rewards. By using any of our staking services, you acknowledge and agree to the following terms:

2.4.1. General Terms for All Staking.

  • You retain full ownership of your staked assets at all times. Staking involves delegating your assets by locking them in a publicly verifiable smart contract through our interface. This is not a transfer of ownership or custody to the Company. These smart contracts are designed so that the Company does not have access to or control over your assets.
  • Conditions Displayed. The Platform interface may display forward-looking information, including estimated Annual Percentage Yield (APY), Annual Percentage Rate (APR), and projected future balances (collectively, "Estimated Returns"). All Estimated Returns are provided for informational and illustrative purposes only. They are not, and should not be considered, a guarantee, promise, or warranty of future performance or any specific level of return.
  • Acknowledgment of Volatility. You acknowledge and agree that actual staking rewards are determined by third-party protocols and are subject to significant volatility based on factors outside of our control, including but not limited to, the total number of staking participants, network transaction volume, and the performance of independent validators. The actual rewards you receive may be substantially higher or lower than the Estimated Returns displayed. You agree not to place undue reliance on such Estimated Returns. You acknowledge and agree that all staking activities involve these inherent risks, including but not limited to smart contract vulnerabilities and fluctuations in reward rates, for which the Company disclaims all liability.
  • Role of the Company. Our role varies depending on the specific staking service. For certain services, we may act as a technical interface to third-party staking protocols. For our proprietary services, such as Liquid Staking, we may directly perform technical validation services on your behalf, as specified in the description below. In all cases, we are not a financial advisor, and no content within the Platform should be considered investment advice.

2.4.2. Types of Staking Available.

  • Liquid Staking. The primary purpose of this service is to allow you to earn network rewards (e.g., in TON) from staking, while retaining liquidity. Our role is to perform the technical validation services on your behalf. We may charge a commission on the staking rewards generated;
  • $MY Token Staking. The primary purpose of staking our native utility token ($MY) is to grant you access to specific in-app benefits, such as swap fee waivers, in addition to any rewards earned in $MY. The currently active benefits and the requirements to qualify for them will be displayed within the Platform's interface. The specific nature, value, and availability of these in-app benefits are not guaranteed and may be modified, suspended, or discontinued at any time at the Company's sole discretion.

2.5. Company NFTs. The Platform may enable you to acquire, view, and store certain digital collectible assets made available by the Company, such as NFTs designed for Platform personalization ("Company NFTs"). These Company NFTs may be offered for sale.

2.5.1. You acknowledge and agree that the sole purpose and utility of Company NFTs is to unlock specific cosmetic features or to personalize the user interface of the Platform. You are paying for this current, consumptive utility only.

2.5.2. The purchase of a Company NFT is not an investment. The Company makes no promise or guarantee, express or implied, regarding any future value, appreciation in price, transferability, or continued usability of any Company NFT.

2.5.3. Ownership of a Company NFT does not grant you any right to equity, dividends, revenue sharing, voting, or any other form of governance rights in the Company.

2.5.4. The Company has no obligation to facilitate the resale or trading of Company NFTs on any secondary market.

2.6. $MY Token. The $MY token is a native utility token designed to be used within the MyTonWallet platform ecosystem.

2.6.1. $MY token is not intended to be an investment. The Company makes no promise or guarantee, express or implied, regarding any future value, appreciation in price, or market liquidity of the $MY token. You acknowledge that you are purchasing or holding $MY for its utility within the Platform, not for speculative purposes.

2.6.2. Ownership of the $MY token does not grant you any right to equity, shares, dividends, revenue sharing, voting, or any other form of governance rights or financial interest in the Company. The $MY token does not represent any ownership stake or claim against the Company.

2.7. Partner Services. The Platform may facilitate access to various products and services developed in partnership with licensed third parties (collectively, "Partner Services"). A co-branded cryptocurrency card is one example of such a Partner Service.

2.7.1. For any Partner Service, you acknowledge and agree that the legal agreement governing its use, fees, and functionality is exclusively between you and the licensed third-party provider. You are solely responsible for reviewing and accepting the partner's terms and conditions.

2.7.2. The Company's role is strictly limited to providing a technical interface or acting as a referral partner. We are not the issuer, operator, payment processor, or a licensed financial service provider for any Partner Service. Accordingly, the Company does not handle user funds, process payments, or provide custodial services in relation to them, as all such activities are carried out exclusively by our licensed partners.

3. User Eligibility and Legal Responsibility

3.1. To use the Platform, you must be at least 18 years old or the legal age of majority in your jurisdiction. By using the Platform, you confirm that you meet this age requirement.

3.2. Your right to access and use the Platform may be restricted based on your citizenship, residency, and location. You represent and warrant that you will not use the Platform if you are:

  • A citizen or a permanent resident of the United Arab Emirates (UAE); or
  • A person located in, or a resident of, any jurisdiction where the use of the services offered by the Platform is prohibited by applicable law.

3.3. Your right to access and use the Platform is restricted in accordance with international sanctions laws. You represent and warrant that you are not subject to any of the following restrictions:

  • a) Restrictions for Sanctioned Jurisdictions. You are prohibited from using the Platform if you are located in, a resident of, or a citizen of any jurisdiction that is subject to U.S.', United Nations', or European Union's comprehensive restrictions (embargos), or that has been designated as a state sponsor of terrorism. This includes, without limitation, North Korea (DPRK), Syria, Cuba, designated regions of Ukraine, and several other jurisdictions.
  • b) Restrictions for Specially Designated Nationals and Blocked Persons. Regardless of your location, you are prohibited from using the Platform if you are, or are under control, or are acting on behalf of, any person or entity that is identified on the U.S. Specially Designated Nationals and Blocked Persons List (SDN List), the UN Security Council Consolidated List, the EU Consolidated List of persons, groups and entities subject to Union's financial sanctions, or any other similar international sanctions list.

3.4. You represent and warrant that you are not a person subject to the restrictions outlined above and that you will not attempt to conceal your location or identity for the purpose of circumventing these restrictions. You acknowledge that any such attempt constitutes a material breach of these Terms.

3.5. The Company reserves the right to implement measures to ensure compliance with these restrictions, including but not limited to blocking IP addresses from prohibited jurisdictions.

3.6. In the event that the Company, in its sole discretion, determines that you have breached provisions of this section, it reserves the right to use appropriate technical measures to suspend your access to the Platform without prior notice.

3.7. You are solely responsible for ensuring that your use of the Platform complies with all applicable laws and regulations in your jurisdiction before using it.

3.8. By using the Platform, you represent and warrant that you are solely and exclusively responsible for all tax-related obligations arising from your use of the Platform and any transactions you conduct. This responsibility includes, without limitation, determining if any taxes apply, and correctly reporting, withholding, collecting, and remitting all applicable taxes to the appropriate authorities. The Company does not provide any tax advice.

4. Disclaimer of Warranties and Limitation of Liability

A. General Disclaimers

4.1. The Platform is provided on an "as is" and "as available" basis. The Company makes no guarantees as to the uninterrupted, error-free operation of the Platform.

4.2. You acknowledge and agree that all software, including the Platform, may be subject to inherent bugs, errors, vulnerabilities, or defects. You accept all risks associated with the use of the Platform. The Company shall not be liable for any losses, damages, or claims, whether direct or indirect, arising from such software errors, bugs, or vulnerabilities, even if found in the Company's own code.

4.3. Notwithstanding the disclaimers above, the Company invests significant effort and resources to minimize risks and ensure the security and transparency of the Platform. Our security practices include, but are not limited to:

  • a) Open-Source Code. Maintaining the Platform's application code as fully open-source, allowing any user, developer, or security expert to audit and review the code and make their own informed decision about its use;
  • b) Audits. Regularly engaging recognized third-party auditing firms for security assessments and organizing public vulnerability discovery contests;
  • c) Active Bounty Program. Maintaining an active Bug Bounty Program to incentivize security research by the community;
  • d) Verifiable Builds. Implementing a public system of reproducible builds, visible in our GitHub repository, which allows any user to independently verify that the application installed on their device is compiled directly from the published open-source code, with no modifications;
  • e) Internal Control. Enforcing rigorous internal security protocols, including mandatory cross-team peer review for every code change, to enhance code reliability.

4.4. The Company is not a financial, legal, or investment advisor and, under no circumstances, provides advice or recommendations in any capacity. All content, features, communications, and tools provided through the Platform are for informational purposes only. Nothing on the Platform should be construed as financial, legal, investment, or tax advice, or as a solicitation to engage in any transaction. You are solely responsible for all decisions and transactions you make.

4.5. You are solely responsible for all fees associated with your blockchain transactions (e.g., gas fees). The Company shall not be responsible for any losses you incur due to transaction fees or losses that occur due to incorrectly configured fees.

4.6. The Company does not provide any services that require licensing or virtual assets service provider authorization. The Company is a supplier of software – we are not a broker, nor is it a dealer or arranger, nor do we operate a digital asset exchange platform or offer trade execution or clearing services and, therefore, have no oversight, involvement, or control concerning the transactions you choose to conduct via the Platform's functionality.

B. Non-Custodial Nature

4.7. You agree to take full and exclusive responsibility for safeguarding your seed phrase, private key, and the device on which the Platform is installed. You acknowledge that the Company cannot recover your funds or account information in the event of loss of access, as the Platform is non-custodial and the Company has no access to this information.

4.8. You acknowledge and assume all risks inherent in using blockchain and digital assets, including but not limited to:

  • a) losses resulting from the price volatility of digital assets;
  • b) financial losses due to errors or failures in smart contracts you interact with;
  • c) issues or losses arising from your use of third-party services;
  • d) security risks, including but not limited to hacking, phishing, and other cyberattacks directed at you;
  • e) losses due to your own errors, such as sending digital assets to an incorrect address, sending assets on the wrong blockchain network, or incorrectly managing your private keys.

C. Third-Party Services and Risks

4.9. You acknowledge and agree that the Company does not own, operate, or control third-party services available through Platform's interface, primarily through the "Explore" section. The Company makes no warranties regarding their performance, availability, or security. Your use of any third-party service is at your own sole risk. The Company is not responsible for any loss of funds, data breaches, or other damages resulting from your interaction with such services.

4.10. When using any third-party service, you are bound by any terms and conditions set forth by the specific third-party service provider, and it is your sole responsibility to review and agree to these separate terms and conditions. The Platform has no influence over these terms and cannot intercede on your behalf should any disputes arise.

D. Limitation of Liability and Indemnification

4.11. To the fullest extent permitted by law, the Company shall not be liable for any direct, indirect, incidental, punitive, or consequential damages arising from your use or inability to use the Platform, your interaction with third-party services, or user errors.

4.12. We shall not be liable for any delay or failure to perform our services which results from any cause or condition beyond our reasonable control. Such causes include, but are not limited to, acts of God, acts of civil or military authorities, acts of terrorism, civil disturbances, war, changes to any blockchain protocol, smart contract bugs, failures of the internet or other utility services, or any other significant unforeseen event.

4.13. Notwithstanding any other provision, the total aggregate liability of the Company for all claims arising from these Terms shall not exceed one hundred U.S. dollars ($100.00).

4.14. You agree to indemnify, defend, and hold harmless the Company and its affiliates, directors, officers, employees, and agents from and against any and all claims, demands, liabilities, damages, losses, and expenses, including, without limitation, reasonable attorneys' fees, arising out of or in any way connected with:

  • a) your access to or use of the Platform;
  • b) your breach of any of these Terms, including any of the representations and warranties herein;
  • c) your violation of any applicable law, rule, or regulation; or
  • d) your violation of the rights of any third party.

5. Prohibited Activities

5.1. Users are expressly prohibited from:

  • a) using the Platform for the purpose of evading laws, sanctions, or regulatory restrictions;
  • b) engaging in any activity that threatens the security or integrity of the Platform or its users, including but not limited to distributing viruses or other malicious code, initiating cyberattacks, conducting phishing attacks, or attempting to probe, scan, or test the vulnerability of any system or network associated with the Platform. For clarity, this section does not prohibit security research conducted in good faith and in strict accordance with the rules of our official Bug Bounty Program;
  • c) using the Platform to facilitate money laundering, terrorist financing, fraudulent schemes, drug trafficking, sale of counterfeit goods, human trafficking, unauthorized financial services, or the operation of unlicensed financial, gambling, or remittance services, or any other conduct that violates applicable local, national, or international laws;
  • d) automating any interaction with the Platform (including but not limited to through bots, data scraping, or similar methods) without the Company's prior written consent;
  • e) since right to access and use the Platform is personal, non-transferable, and granted for non-commercial purposes only, Users are strictly prohibited from selling, renting, leasing, or otherwise commercializing their wallet or its credentials (including their seed phrase). You acknowledge that voluntarily disclosing your seed phrase or transferring control of your device to any third party is a significant security risk. You remain solely and exclusively responsible for all actions and transactions conducted through your wallet, regardless of whether you authorized them or if you have lost control over your credentials;
  • f) engaging in any activity that violates these Terms, applicable law, or infringes upon the rights of any third party.

5.2. In the event that the Company, in its sole discretion, determines that you have breached provisions of this section, it reserves the right to use appropriate technical measures to suspend your access to the Platform without prior notice.

6. Intellectual Property Rights

6.1. The Platform and all of its contents, features, and functionality, including but not limited to all software, code, text, graphics, and trademarks ("Company IP"), are owned by or licensed to the Company and are protected by copyright, trademark, and other intellectual property laws. Your right to use the Company IP is strictly defined by two separate documents: these Terms and the applicable open-source license available in our public source code repository.

6.2. Use of the Official Application. These Terms govern your use of the official compiled application downloaded from an authorized source. You are granted a limited, non-transferable license to use the application for personal, non-commercial purposes. You are strictly prohibited from reverse-engineering, decompiling, or disassembling the application to find and exploit possible proprietary elements such as API keys or closed-source components not present in the public source code. You are also prohibited from using the Company's trademarks, logos, or name in any way that suggests endorsement or causes confusion, or from removing any proprietary notices from the Application.

6.3. Use of the Source Code. The underlying source code for the application is made available under the terms of the applicable GNU General Public License v3.0. These Terms do not limit or supersede any rights granted to you by such license with respect to the source code. Any action that is expressly permitted by the license, including copying, modifying, and distributing the source code or derivative works thereof, shall not be considered a violation of these Terms.

7. AML/KYC Framework

7.1. You acknowledge that the base functionality of the Platform as a non-custodial wallet does not require you to undergo Know Your Customer (KYC) verification, and the Company does not collect or store your personal identification data for the core services.

7.2. The absence of a mandatory KYC process for the Platform's base functionality does not in any way diminish or waive your absolute obligation to comply with all provisions of these Terms, including, without limitation, the restrictions set forth in the "User Eligibility and Legal Responsibility" and "Prohibited Activities" sections. You are fully responsible at all times for ensuring your use of the Platform is compliant.

7.3. Access to certain Partner Services, offered by regulated third-party entities, may be conditional upon your successful completion of their KYC and Anti-Money Laundering (AML) verification processes, as required by applicable law. You acknowledge and agree that you are required to comply fully and promptly with any such verification requests to get access to such Partner Services.

7.4. The entire KYC/AML verification process for such Partner Services is conducted by a specialized third-party service provider, as designated by our regulated partner. The Company will not receive, process, or store any of your sensitive personal identification documents or data (such as government IDs or photos) collected for these purposes.

8. Miscellaneous

8.1. If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, the validity, legality, and enforceability of the remaining provisions shall not in any way be affected or impaired.

8.2. You may not assign or transfer any of your rights or obligations under these Terms without our prior written consent. The Company may assign or transfer any or all of its rights and obligations under these Terms to an affiliate or in connection with a merger, acquisition, or sale of assets without your consent.

8.3. These Terms, together with the Privacy Policy, constitute the entire agreement between you and the Company regarding your use of the Platform and supersede all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral.

8.4. The Company reserves the right to update, modify, or discontinue any aspect of its services at any time without prior notice.

8.5. The Company reserves the right, in its sole discretion, to suspend or permanently terminate your access to the Platform for any reason, including but not limited to a breach of these Terms. The Company may implement technical measures, including but not limited to IP address blocking, to enforce such suspension or termination, with or without notice.

8.6. These Terms shall be governed by and construed in accordance with the laws of the British Virgin Islands. These provisions do not deprive you of the protection of the mandatory provisions of the consumer protection laws in your country of residence.

8.7. Dispute Resolution. In the event of any dispute, the parties agree to first attempt to resolve it through amicable good-faith negotiations for a period of sixty (60) days, initiated by written notice from one party to the other.

8.7.1. The process for resolving any dispute that is not resolved through informal negotiation depends on your country of residence:

  • a) If you reside in the European Economic Area, any dispute arising from these Terms will be resolved by the competent courts of the country of your residence.
  • b) If you reside in the United States or any other jurisdiction, you and the Company agree that any dispute, claim, or controversy arising out of or relating to these Terms shall be resolved by final and binding arbitration, with the following exceptions: either party may bring a qualifying claim in a small claims court. The arbitration will be administered by JAMS pursuant to its Streamlined Arbitration Rules & Procedures and Consumer Arbitration Minimum Standards. The arbitration will be conducted by a single, neutral arbitrator in the English language. Proceedings may be conducted via teleconference or video conference. The seat of arbitration shall be the British Virgin Islands.

8.7.2. To the fullest extent permitted by law, you and the Company agree that any claim must be brought in the parties’ individual capacity, and not as a plaintiff or class member in any purported class action, collective action, or representative proceeding. You expressly waive any right to a jury trial and to participate in a class action lawsuit. The arbitrator may not consolidate more than one person's claims or otherwise preside over any form of a representative or class proceeding;

8.7.3. Notwithstanding the foregoing, either party may seek injunctive or other equitable relief in the relevant courts to prevent the actual or threatened infringement, misappropriation, or violation of a party's intellectual property rights.

9. Privacy and Data Protection

9.1. Your privacy is important to us. Our collection and use of information in connection with the Platform is governed by our separate Privacy Policy, which is incorporated by reference into these Terms. By using the Platform, you acknowledge that you have read and agree to our Privacy Policy.

9.2. Core Principle: Minimizing Data Collection. The Platform is designed to minimize data collection. We do not require you to provide directly identifying personal data like your name or email to use our core services.

9.3. You acknowledge and agree that your transaction history on public blockchains is, by its nature, public and permanent. The Platform displays this public information to you, but we do not control this on-chain data. This is explained in detail in our Privacy Policy.

9.4. If you contact our support team through our official Telegram account, you acknowledge that we will see your public Telegram profile data (such as your username and name) and any other information you choose to provide. This information is considered voluntarily provided by you for the purpose of resolving your issue and will be used solely for that purpose.

9.5. For security and operational purposes, we process a limited amount of technical data, as further detailed in our Privacy Policy.

9.6. As described in the "AML/KYC Framework" section, if you choose to use certain optional services provided by Partner Services, you may be required to submit personal data directly to them for verification. The Company does not receive or store this sensitive data.

9.7. We do not sell your personal data to third parties.

9.8. The Company implements industry-standard security measures to protect any data we might handle. However, we cannot guarantee absolute protection against all security threats.

10. Contact Information

10.1. For any inquiries, support requests, or dispute resolutions, you may contact MyTonWallet through the official support email support@mywallet.io or via Telegram: https://t.me/mysupport.