Usage Policies

Last updated: Month DD, YYYY

DRAFT — This document is a template and not legal advice. It must be reviewed and approved by qualified legal counsel before publication. Replace all [bracketed] placeholders.

These Usage Policies (the “Policies”) govern your access to and use of the products, applications, and services (the “Service”) operated by [Legal Company Name] (“Pago”, “we”, “us”). By creating an account or using the Service, you agree to these Policies. If you do not agree, do not use the Service.

1. Nature of the Service

Pago is a technology provider. We offer software that lets users send, receive, and accept payments and convert between fiat and stablecoins.

Regulated financial services — including the holding of funds, payment processing, and fiat custody — are provided by our regulated banking and payments partner(s) (“[BaaS Partner]”), not by Pago. Your use of those services is also subject to [BaaS Partner]'s own terms.

Pago does not take custody of fiat funds and is not a bank. Stablecoin functionality relies on third-party issuers and blockchain networks that Pago does not control.

2. Eligibility & Identity Verification

You must be at least 18 years old and legally able to enter into a contract. The Service is only available where permitted by law.

Access to the Service requires identity verification (KYC) for individuals and business verification (KYB) for companies, performed by us or our partners. You agree to provide accurate, current, and complete information and to update it as needed.

We may refuse, suspend, or limit access if verification cannot be completed or if information appears inaccurate, fraudulent, or incomplete.

3. Acceptable Use

You may use the Service only for lawful purposes and in accordance with these Policies. You are responsible for all activity that occurs under your account and for keeping your credentials secure.

You represent and warrant that all funds you transact are derived from lawful sources and that your use of the Service complies with all laws applicable to you.

4. Prohibited Activities

You may not use the Service to engage in, facilitate, or attempt any of the following:

  • Money laundering, terrorist financing, or financing of illegal activities.
  • Fraud, theft, deception, or any misrepresentation of identity or source of funds.
  • Transactions involving sanctioned persons, entities, or jurisdictions, or any sanctions evasion.
  • Sale or facilitation of illegal goods or services, including controlled substances and weapons.
  • Unlicensed money transmission, gambling, or other regulated activity without proper authorization.
  • Market manipulation, wash trading, or other abuse of stablecoin or blockchain technology.
  • Any activity that violates applicable laws, these Policies, or the terms of our partners.

5. Stablecoins & Associated Risks

Stablecoins are digital assets issued by third parties. Their value, redemption, and backing depend entirely on their respective issuers, and they may lose their peg or value.

Blockchain transactions are generally irreversible. You are solely responsible for the accuracy of transaction details, including recipient addresses and amounts.

Pago is not responsible for losses arising from issuer insolvency, depegging, network congestion or failure, forks, or other events outside our control.

6. Fees

Applicable fees for transactions, conversions, and cash in/out will be disclosed before you confirm a transaction. We may update our fees with prior notice as required by law.

7. Suspension, Freezing & Termination

We may suspend, restrict, freeze, or terminate your account or any transaction, with or without prior notice, if we reasonably believe you have violated these Policies, applicable law, or our partners' requirements, or if required by a competent authority.

Where legally permitted, we will provide notice and information about next steps. We may report suspicious activity to the relevant authorities as required by law.

8. User Representations & Indemnification

You represent that you are using the Service lawfully and that all information you provide is truthful.

You agree to indemnify and hold harmless Pago, its affiliates, and its partners from any claim, loss, liability, or expense (including reasonable legal fees) arising out of your misuse of the Service or your breach of these Policies or applicable law.

9. Disclaimers & Limitation of Liability

The Service is provided “as is” and “as available”, without warranties of any kind, to the maximum extent permitted by law.

To the maximum extent permitted by law, Pago shall not be liable for indirect, incidental, special, consequential, or punitive damages, or for loss of profits or funds arising from misuse, third-party services, or events beyond our control.

Where liability cannot be excluded, it is limited to the total fees you paid to Pago in the [three (3)] months preceding the event giving rise to the claim. Nothing in these Policies limits liability that cannot be limited under applicable law.

10. Changes to These Policies

We may update these Policies from time to time. Changes take effect when posted, or on the date stated. Your continued use of the Service after changes become effective constitutes acceptance.

11. Governing Law & Disputes

These Policies are governed by the laws of [Jurisdiction], without regard to conflict-of-law rules. Disputes will be resolved before the competent courts of [Jurisdiction] or through [arbitration body], as applicable.

12. Contact

Questions about these Policies can be sent to [legal@tapp.com].