Terms of Use

Version dated 23 October 2026

These Terms govern access to BloxFi's website, public content, demonstrations and, where expressly accepted for that purpose, approved technology interfaces, onboarding support and introductions. They include important restrictions on UK activity, client compliance obligations and business indemnities. Financial services and live transactions require separate onboarding, approval and contractual terms with the identified service provider. Read these Terms together with the applicable service agreement, Privacy Policy and Risk Disclosure before accepting or using an approved service.

1 Who these Terms are with

The website at bloxfi.com is operated by BLOXFI LIMITED, Hong Kong company number 79037373, of Room 602, 6/F, Kai Yue Commercial Building, No. 2C, Argyle Street, Mongkok, Kowloon, Hong Kong. In these Terms, “we”, “us” and “BloxFi Limited” mean that company. “You” means the person using the website or, where an authorised person accepts these Terms for a business, that business.

“BloxFi” is also used as a brand for different services. The brand, shared technology and common interface do not make every company a party to your contract or a guarantor of another company's obligations. Your onboarding documents and service agreement identify the actual counterparty and the party responsible for each service.

The entities associated with BloxFi have distinct roles:

• BLOXFI LIMITED, Hong Kong, company number 79037373, at the address above, is the technology entity and does not hold a financial-services licence. It supplies technology and administrative connectivity within its approved scope. Under its technology services agreement, it does not receive, hold or control transaction principal; the approved client or underlying customer contracts with the identified financial provider for that provider's services. A dashboard balance or BloxFi branding does not change that allocation.
• Victus Ventures GmbH, Switzerland, CHE-264.484.653, Dammstrasse 16, 6300 Zug, Switzerland, may provide approved financial services and receive or control funds for agreed execution and settlement under its own Swiss service agreement. Swiss SRO affiliation concerns the applicable anti-money laundering framework; it is not a banking licence or worldwide permission. These website Terms do not reclassify Victus's activity as technology-only or displace its actual financial-service obligations.
• BloxFi Payments Inc, Canada, 5307 Victoria Drive #1325, Vancouver, BC V5P 3V6, Canada, has a FINTRAC money services business registration in progress, not a completed registration, as at this version date. It is not presented here as an activated financial-service counterparty. Any future service requires the registrations, permissions, contracts and operational approvals applicable to that activity. FINTRAC registration is not a banking licence or regulatory endorsement.
• BloxFi USA LLC, United States, has a FinCEN money services business registration in progress, not a completed registration, as at this version date. It is not presented here as an activated financial-service counterparty. FinCEN registration does not replace applicable state money-transmitter licences or other federal or state requirements. Any future service requires its own lawful activation and contract.
• BloxFi Holding Ltd, British Virgin Islands, company number 2210802, is a non-operational holding vehicle. It does not provide payment, conversion, execution or custody services or receive transaction principal merely because it is associated with the brand. It does not guarantee another entity's obligations without an express, valid guarantee.

An affiliation, registration, pending application or licence belonging to one person does not authorise another person's activities. Victus Ventures GmbH is a separate Swiss company and is not represented here as a subsidiary of BloxFi Holding Ltd. A future registration or change in corporate arrangements does not automatically transfer your contract, assets or data-processing responsibilities. The required disclosures, agreement and permissions must first be in place. Identification here does not make a non-party bound by these Terms or exclude any entity's responsibility arising from its own conduct under mandatory law.

For these Terms, a “Provider” is an independent bank, payment institution, liquidity provider, exchange, conversion provider, collection partner, payout partner, custodian or other identified third party supplying its own service. Calling a person a Provider does not change its actual contractual role or excuse BloxFi's obligations for its own subcontracted performance. An “Approved Service” is only the particular service confirmed for you by the relevant contracting entity following the required checks.

2 Scope acceptance and priority

These Terms apply to the website, public materials, contact forms and demonstrations. Where expressly presented and accepted for that purpose, they also set baseline rules for access to BloxFi's dashboard, APIs and other technology interfaces. An account, integration, white-label arrangement or live financial service is available only under the additional terms and approvals required for that activity.

Introductions and manually assisted activity, including instructions through approved email, messaging or other recorded channels, remain subject to the identified entity's service agreement, authentication requirements and approved mandate. Human assistance, an informal conversation or a referral does not bypass onboarding, activate an unapproved service or expand authority.

If acceptance is requested through a checkbox or another electronic process, you must review the linked version and affirmatively accept it. Acceptance for a business requires authority to bind that business. Ordinary user access, a preselected checkbox or an internal administrative entry does not establish authority to amend a service agreement or commit another person.

Mandatory law prevails. For services, transactions and related claims, your validly accepted master services agreement, commercial terms, product terms and relevant Provider terms govern according to their own order of priority. These Terms supplement that framework only within the scope for which they are validly accepted and where consistent with it. They do not override a service agreement's allocation of liability, indemnities, fees, authority, funds, safeguarding, termination, governing law or dispute resolution. In particular, existing service indemnities, including expressly agreed uncapped indemnities, remain intact.

The business compliance duties in section 10 and indemnities in section 15 are material terms. They must be presented before the business affirmatively accepts the applicable version. Where incorporating them into an existing service relationship would require an amendment, the service agreement's amendment process must be completed. Publication, continued browsing, an API connection or receipt of a quote does not itself amend an existing contract or bind an underlying customer. If you do not agree, do not use the optional functionality for which acceptance is required.

The Privacy Policy explains personal-data processing; it is not a blanket consent to processing or a waiver of privacy rights. The Risk Disclosure explains material risks; reading or acknowledging it does not waive responsibility for a party's own legally attributable conduct. An Acceptable Use Policy becomes part of a service contract only as that contract provides.

3 Eligibility and approved access

Our live services are intended for approved business clients and authorised users. An account user must have legal capacity and be at least 18, unless an expressly approved lawful arrangement provides otherwise. Services for or involving underlying customers, including individuals, require the applicable approvals, authority and protections.

You must provide accurate, complete and current information and notify us of material changes. You must not impersonate another person, conceal the business or customer for whom you act, access another user's account without authority or bypass a suspension through another identity.

Access and service availability depend on the relevant person's location, business model, ownership, permissions, proposed activity, sanctions exposure and provider requirements. A country, currency or payment method shown on the website does not establish eligibility. You must not use the website or services where prohibited by law, or use technical measures, intermediaries or inaccurate information to evade applicable restrictions.

By accepting for a business, you represent, warrant and undertake throughout your use that you have the corporate power, internal approvals and authority required; your users act within valid permissions; information about your business, ownership, controllers, customers and activities is accurate and not misleading; and you hold and maintain the licences, registrations, permissions and consents legally required for your own activities. You must not use the website or approved interfaces to carry on an unapproved regulated activity or to cause another party to breach applicable law. Inform us promptly of any material change, loss of authority, restriction or regulatory action relevant to your use.

You remain responsible for authorised users and persons acting on your behalf within the scope of their appointment, including their compliance with access restrictions and these Terms. This does not deem a genuinely unauthorised instruction valid or displace the service agreement's authentication and loss-allocation provisions. Business-only eligibility does not remove protections owed to underlying individuals or create a financial-promotion exemption.

4 Information illustrations and demonstrations

Public product descriptions, coverage maps, comparisons, indicative rates, delivery estimates and demonstrations explain potential functionality. They are not a binding quote, promise of account opening, service activation or commitment to a transaction. Features and routes remain subject to current availability, contractual scope and required approvals.

Demonstration and sandbox environments are for testing and illustration. Do not send real money, private keys or live customer data to them unless we have expressly authorised the particular arrangement. Test balances and simulated confirmations do not represent actual funds, accounts or settlement.

Public information and general support are not personalised investment, legal, regulatory or tax advice. Obtain advice appropriate to your own activities. This does not invalidate an expressly agreed service commitment, a valid transaction confirmation or rights arising from misleading statements or other conduct for which liability cannot lawfully be excluded.

You must independently evaluate the commercial, operational, tax, legal, market and counterparty implications of your decisions, taking professional advice where appropriate. A comparison, introduction, indicative price or operational response is not a recommendation, certification of a Provider's suitability, or undertaking to act as your compliance adviser, fiduciary or general agent. Any specific mandate remains limited to its accepted terms. This provision does not exclude fraud, actionable misrepresentation or a duty that cannot lawfully be excluded.

5 Onboarding and service activation

An enquiry, demonstration, introduction, account login or signature does not by itself activate a financial service or authorise funding. Activation requires the correct contract, identity and business verification, valid authority, relevant provider approval and confirmation of the permitted services and conditions.

Separate approval may be required for local collection, local or international payout, fiat-to-fiat or supported digital-asset conversion, named or virtual account arrangements, provider-backed balances, first-party or underlying-customer flows, payroll or batch payments, manual execution support, and embedded or white-label distribution. An available interface, introduction or master authorisation does not activate every listed service.

Approved scope may identify the client, underlying customer, currencies, countries, providers, accounts, funding sources, beneficiaries, limits and transaction purposes. Approval for one scope does not approve another. We may request information needed to assess legal, financial-crime, operational or security requirements. Each party remains responsible for the obligations imposed on its own activities.

You must supply reasonably required corporate records, ownership and control information, identities and mandates, business and licensing details, source-of-funds or source-of-wealth evidence, transaction purposes and supporting documents. Keep them current and respond within the reasonable period specified for the request, or explain promptly why more time is needed. Incomplete, inconsistent or unverifiable information may prevent activation or result in restrictions under section 14.

Relevant information may be verified and shared with the identified Providers, verification vendors, advisers, auditors and competent authorities where necessary and lawful for onboarding, risk controls, service performance, fee reconciliation or legal obligations. The Privacy Policy, applicable confidentiality duties and any data-processing agreement govern this activity. This provision is not unlimited consent to data sharing. Providers make their own onboarding decisions; BloxFi does not guarantee acceptance, timing or continued availability.

Do not transfer transaction funds to BloxFi Limited or to any account or wallet appearing only in marketing material, a demo or an unverified message. Follow the authenticated funding instructions issued for the approved route and identified legal counterparty.

6 Users credentials and instructions

Keep credentials confidential, apply available authentication and access controls, restrict permissions to the user's actual role and promptly remove access when authority ends. Do not share accounts or allow access beyond the approved organisation and users. Maintain appropriate security for your devices, software and integration.

You must verify beneficiary details, account and wallet addresses, currencies, networks, amounts and references before submitting an instruction. Confirm changes to payment details through an independently verified channel. Notify us promptly through your agreed urgent support channel if credentials, access or instructions may have been compromised, and take reasonable steps to prevent further misuse.

Automated systems and AI agents may act only within a verified, recorded mandate and approved limits. They cannot approve their own permissions, expand a mandate, amend a contract or make binding commitments merely because they have technical access. Human and organisational accountability is not displaced by automation.

The service contract governs when an instruction is accepted, binding or irrevocable and how unauthorised instructions are handled. Use of credentials is relevant evidence but does not make every instruction conclusive or excuse a failure to apply our own agreed controls.

Manual requests, email, messaging and trading-desk discussions are effective only through approved channels and the authentication, authority and acceptance procedures in the applicable agreement. An indicative quote or conversation is not by itself an accepted trade, transfer instruction or authority to change beneficiary details. An introducer cannot instruct for a client without separate valid authority. A master authorisation is limited to its recorded scope; it does not itself permit unrelated contracts, borrowing, pledging assets, changing beneficial ownership, investments or transfers outside approved instructions. Revocation and previously committed transactions follow the applicable agreement and law.

7 Quotes routing funding and settlement

Transactions may combine local collection, fiat or digital-asset conversion, intermediate settlement and local payout, with different persons responsible for different stages. A named account, virtual account identifier or pooled collection arrangement has the legal meaning set out in its accepted terms; an interface label alone does not establish ownership, custody, a bank deposit or deposit protection.

Where approved options are available, an authorised user may choose a named account arrangement or an identified provider's local collection or payout account, subject to eligibility and the approved payment flow. Use only the account details and reference assigned to that flow. Details for own-account funding must not be repurposed for third-party collections, and collection details do not automatically permit outgoing payments. Account or provider selection does not change the legal holder, applicable safeguarding or responsibility for funds.

Routing information may compare available eligible providers on price, liquidity, expected speed and availability. It does not cover every provider or guarantee the best market rate, lowest cost, uninterrupted availability or successful execution. Quote validity, fees, spread, funding deadlines, deductions and the conditions for acceptance are governed by the relevant accepted quote and contract.

An instruction received, quote displayed, balance shown or status notification is not necessarily final or irrevocable settlement. Banking hours, checks, provider restrictions, technical failures and network conditions can affect completion. Returns, recalls, corrections and cancellations are governed by the responsible party's accepted terms and law and may not be possible after execution.

Compensation may, where disclosed and agreed, include transaction fees, spreads, markups, commissions, subscriptions or other commercial charges. BloxFi or a referral partner may receive Provider remuneration or revenue share, and this may create a commercial incentive in Provider selection. A routing comparison is not a promise of independence or a whole-market assessment. The applicable disclosure and accepted quote must identify the client-facing charges, exchange rate and any relevant deduction or uncertainty as required by law and contract; undisclosed fees are not authorised by this description.

These Terms introduce no transaction charge, recurring fee, minimum commitment or right to deduct from customer assets. Payment timing, taxes, permitted withholding and fee changes remain governed by accepted commercial terms. You must cooperate in providing proportionate, accurate records reasonably needed to reconcile agreed fees or referred business, subject to confidentiality and data law. This does not create an unlimited audit right, require unrelated customer information or override a Provider's disclosure restrictions. Do not send funds outside the approved amount, currency, source or purpose.

8 Underlying customers and third party activity

Using BloxFi for another person's funds, instructions or customers requires specific approval and sufficient lawful authority. Permission to pay an ordinary supplier or other beneficiary does not automatically authorise an undisclosed customer network, sub-agent, reseller or nested financial service.

Where you act for underlying customers, you must provide the legally required information about counterparties, services, charges, risks and data sharing, obtain valid mandates and fulfil your own customer obligations. Your customers do not acquire rights to a BloxFi account or a provider service solely because your interface displays it. Their independent contractual and statutory rights remain unaffected.

A referral, revenue share, client markup, white-label service or use of BloxFi branding requires an expressly agreed arrangement. You must not represent that you are a BloxFi employee, regulated agent or financial-promotion approver, or bind BloxFi or a provider to a guarantee or commitment without authority.

Such an arrangement does not itself authorise receipt of client principal, regulated solicitation, appointment of sub-partners or use of another person's permissions. Identify the actual providers and preserve required notices and disclosures. Distribution channels and additional customer layers require the approval specified in the applicable agreement. Revenue sharing and client-added margins must remain within the accepted commercial arrangement, with legally required fee and conflict disclosures.

9 Permitted use and security

Use the website and interfaces lawfully, within your authority and in accordance with applicable documented technical restrictions. You must not:

• use them for fraud, money laundering, terrorist financing, bribery, sanctions evasion, deceptive practices or other unlawful activity;
• submit false identity, ownership, funding, transaction or compliance information;
• introduce malware, attempt unauthorised access, exploit vulnerabilities, disrupt services or circumvent authentication, rate limits or access restrictions;
• scrape protected information, probe systems or conduct security testing without written authorisation, except where a mandatory legal right applies;
• copy, reverse engineer or redistribute protected software or materials beyond permitted rights, or infringe intellectual-property, privacy or confidentiality rights;
• conceal customer layers, transaction purpose, geographic connections or the true source or ownership of funds; or
• use our systems or name to mislead customers about regulatory status, authorisation, investment returns or the protection of money or digital assets.

For approved integrations, use the supported interfaces, protect credentials, validate messages, handle retries and duplicate requests safely, and apply the controls specified in the applicable agreement and documentation. Do not connect an unapproved production service or use production credentials in a public repository or insecure tool. Report suspected vulnerabilities privately through support@bloxfi.com without accessing or exposing other persons' information.

For your own activities, you must maintain the anti-money laundering, counter-terrorist financing, sanctions, anti-bribery, customer due-diligence, transaction-monitoring, reporting and recordkeeping controls required by applicable law. You warrant that funds and assets submitted for an Approved Service are lawfully sourced and that you have the necessary ownership or authority to deal with them. You must not knowingly introduce prohibited persons, assets or transactions and must perform the screening and checks required of your business. Immediately disclose a material sanctions match, suspected unlawful use or relevant control failure, except where disclosure is prohibited by law.

BloxFi's or a Provider's checks do not perform or discharge your separate compliance duties. Neither a completed onboarding review nor an executed transaction certifies the legality of your wider business. You must not request disclosure of a suspicious-activity report or other information that cannot lawfully be shared. Required reports and lawful cooperation with authorities may occur without advance notice.

10 UK Financial Promotions Compliance Acknowledgment and cross border permissions

10.1 No UK licence or authorisation. None of BLOXFI LIMITED, Victus Ventures GmbH, BloxFi Payments Inc, BloxFi USA LLC or BloxFi Holding Ltd holds a United Kingdom financial-services licence or authorisation as at this version date. You must not state or imply otherwise. No FCA cryptoasset registration, appointed-representative status or section 21 approval arrangement is conferred or evidenced by these Terms. Swiss SRO affiliation, overseas registration or a pending application does not confer UK permission. The status and role of each entity remain those stated in section 1.

10.2 Local collection and payout partners. Where an approved route includes UK local collection or payout, BloxFi uses identified local collection partners and payout partners for the relevant domestic payment leg. The relevant Provider performs its own payment service under the permissions, conditions and contract applicable to that leg. Its identity, payment instructions and relevant terms must be disclosed before use. Neither a UK account nor a GBP rail means that BloxFi itself holds a UK licence. Partner availability and approval are conditions of access; BloxFi does not promise that every partner or route is available to every client.

A partner's permission applies only to the activities and persons actually covered by it. It is not a licence rented, transferred or extended to BloxFi or to you, and does not establish an appointed-representative, regulated-agent or promotion-approval relationship. Any such relationship requires its own legally valid appointment and conditions. UK payment execution, cryptoasset conversion and marketing are separate activities requiring separate assessment. The use of a partner does not itself establish that all other stages of a payment flow are permissible.

10.3 Separate territorial and promotional permissions. You are solely responsible, at your own cost, for establishing and maintaining the licences, registrations, approvals, lawful exemptions and other conditions required for your own business, services, customers and communications in each territory. This includes UK financial promotions compliance where applicable. Obtain independent advice appropriate to your actual business model and distribution channels. BloxFi does not undertake to obtain your approval, act as your compliance adviser, supervise your business or determine your legal status. You must rely on your own valid permissions or other documented lawful route, not on BloxFi's onboarding decision, brand, contracts or relationships.

Permission to communicate a promotion is distinct from permission to provide the underlying service. GBP denomination alone neither triggers nor excludes the financial promotions regime. A business-only label, overseas incorporation, foreign governing law, professional-status assertion or absence from a regulator's warning list is not proof of eligibility or exemption.

10.4 UK financial promotions perimeter. Where applicable, you must comply with section 21 of the Financial Services and Markets Act 2000, the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 and relevant FCA rules and requirements, as amended and applicable at the time of the activity (together, the “FinProm Requirements”). Overseas communications capable of having an effect in the UK may fall within those requirements. The restrictions are determined by the substance, audience and circumstances of a communication, not merely its label or technical delivery method. These Terms do not classify every fiat payment or business communication as a financial promotion.

Before communicating or causing an in-scope promotion, you must establish a lawful route. Depending on the circumstances, this may involve communication by an appropriately authorised person, valid approval by a person legally permitted to approve it, a qualifying registered-person route within its actual scope, or a genuinely applicable statutory exemption. You must satisfy every condition of the route relied upon. An internal sign-off, general legal opinion, commercial agreement or declaration of compliance is not a substitute for required financial-promotion approval.

10.5 Client responsibility and continuing warranties. You represent, warrant and undertake that your relevant permissions, approvals and promotional arrangements are valid, remain in good standing for the activity concerned, and are accurately described to us. You are solely responsible and liable, as between you and BloxFi and subject to mandatory law and section 15, for your own FinProm compliance and that of persons communicating on your behalf. Your responsibilities cover your websites, apps, onboarding journeys, white-label and embedded interfaces, advertisements, paid search, email, messages, social media, presentations, referral links and campaigns, and your authorised affiliates, agents, introducers, influencers, distributors and sub-partners.

You must contractually require persons distributing on your behalf to follow the applicable audience restrictions, approved materials, warnings and change-control requirements, monitor their compliance proportionately, and promptly stop non-compliant distribution. You must not use another person's name, domain, account, customer classification or location to avoid these obligations. An underlying customer's independent contact or consent does not discharge your own duties.

10.6 No reliance on another person's FinProm arrangements. Any compliance measures or approvals implemented by BloxFi or a Provider cover only that person's activities and communications actually within their lawful scope. They do not extend to your separate operations, marketing materials, communications with UK customers or risk disclosures. A compliant partner widget does not automatically cover the surrounding website, app, email or social-media campaign. A payment or e-money permission alone does not make its holder an FSMA-authorised investment-promotion approver. A registered cryptoasset firm's ability to communicate its own promotions does not make it a general approver of your promotions.

Operational review, due diligence, a referral, a template, an integration, a meeting, permission to use a logo, processing a payment or silence after receiving material is not section 21 approval or a legal opinion. You must not advertise that you operate under BloxFi's or a partner's UK licence, are “FinProm approved” by BloxFi, or have guaranteed regulatory coverage through this relationship.

10.7 Approval and distribution controls. Where approval is required, obtain and retain approval from a person with the required legal capacity and any necessary approver permission or applicable exemption from that permission requirement. It must cover the actual content, product, audience, communication channel, period and conditions of distribution. Verify those matters before publication or use. Material changes, translations, combinations with other content, new campaigns or new audiences must be reassessed and freshly approved where required. Do not use an expired, withdrawn or out-of-scope approval.

Where required, implement fair, clear and non-misleading content, prescribed warnings and disclosures, restrictions on incentives, customer categorisation, cooling-off periods and appropriateness assessments in the actual customer journey. Do not remove warnings, obscure the actual Provider, prepopulate a customer's answers or help a customer bypass an assessment. Neither a checkbox nor contractual acceptance replaces the required controls.

10.8 UK access and evidence before activation. You must disclose material UK connections in the proposed business flow, including UK targeting or underlying customers, and obtain the relevant contracting entity's written approval of that operational scope before using an Approved Service for it. This operational approval is not regulatory or promotional approval. Before affected activity begins, and subsequently on reasonable request, provide sufficient evidence of your lawful route, relevant permissions, approval scope, audience restrictions, distribution arrangements and functioning controls. A reasoned independent legal assessment may be requested where the perimeter or an exemption is uncertain; you are not required to waive legal privilege but must provide adequate non-privileged evidence to support eligibility.

If the required evidence or lawful basis is absent, you must not start or continue the affected promotion or use the Approved Service to support it. Where necessary, restrict UK targeting, onboarding and access through effective controls appropriate to the channel, including geographic restrictions. A website disclaimer alone may be insufficient. You must not bypass or invite others to bypass controls using VPNs, false addresses, intermediaries or other measures.

10.9 Reverse solicitation and client initiative. No general reverse-solicitation exemption is granted by these Terms. If you contend that a particular enquiry or service request was made at your or an underlying customer's exclusive initiative, you must disclose the actual acquisition history and provide a truthful, specific record of who initiated contact, when, through which channel, the service requested, and any preceding marketing, referral, solicitation or inducement. Any confirmation must reflect the facts; it must not be backdated, preselected or obtained as a routine declaration from every customer. Acceptance of these Terms is not evidence that no solicitation occurred or that a particular communication was expressly requested. BloxFi may decline to rely on client-initiative assertions and request independent legal assessment.

A client-initiated enquiry does not by itself exempt a subsequent communication from section 21, authorise a regulated service, cure earlier unlawful marketing, or permit promotion of additional products or continuing campaigns. Any relevant exemption or exclusion must be identified and its conditions met for the specific activity. A customer request, business classification or disclaimer must not be used to manufacture an exemption. If the facts or applicable law do not support reliance, the affected activity must not proceed without another lawful basis.

10.10 Records and change notification. Retain proportionate records of permissions, assessments, approvals, distributed versions, audience controls, instructions to distributors and any client-initiative evidence for the period required by law and the applicable agreement. Make relevant records available on reasonable request through secure channels, subject to data law and lawful disclosure restrictions. Notify compliance@bloxfi.com and the relevant contracting entity without undue delay of any suspension, expiry, withdrawal, restriction, regulator enquiry, material complaint, suspected breach or other change that undermines the lawful basis or accuracy of your disclosures. Stop affected activity immediately where its lawful basis is no longer valid; notification is not a grace period.

10.11 Takedown and protective action. You must promptly remove or correct non-compliant material, stop distribution, instruct persons acting on your behalf to do the same, preserve relevant evidence and cooperate with lawful investigation and remediation. BloxFi may require adequate evidence of remediation before restoring affected access. Subject to section 14, it may refuse onboarding, restrict interfaces or routes, suspend introductions or distribution, withdraw brand permission and exercise applicable termination rights where there is a reasonable concern about unlawful activity, unreliable assurances or missing evidence. These actions do not require a final enforcement decision or criminal conviction. BloxFi may lawfully cooperate with Providers, approvers and competent authorities and may be unable to give advance notice or disclose its reasons.

10.12 Allocation of responsibility and remedies. BloxFi does not assume responsibility for your separate compliance failures merely by providing technology, introductions, support, or access to collection and payout partners. Client breaches may give rise to the indemnities and remedies in section 15 or the relevant service agreement. Nothing requires BloxFi to continue a relationship, transaction or communication that would be unlawful. Each entity nevertheless remains responsible for its own legally attributable conduct and non-delegable duties; client assurances do not replace BloxFi's required assessment. These Terms do not bind a regulator, waive a statutory remedy, prove a UK partner agreement or legal opinion, or make an otherwise unlawful arrangement lawful.

11 Intellectual property and supplied material

BloxFi and its licensors retain rights in their software, interfaces, documentation, content, branding and other protected materials. You receive a limited, non-exclusive permission to view public content and use authorised downloads for lawful internal business evaluation. Dashboard, API, SDK and white-label rights are limited to the scope expressly granted in your agreement and any applicable software licence.

Do not remove ownership notices, imply endorsement or use BloxFi trademarks in a domain, account, advertisement or product without permission. Third-party names and logos remain their owners' property; their display does not by itself establish a particular partnership, permission or customer protection.

You retain rights in material you lawfully submit. You authorise its use only as reasonably necessary to respond to your request, deliver the agreed service and meet applicable legal obligations, subject to the Privacy Policy and contractual confidentiality and data terms. You must have the rights and lawful authority to supply it. These Terms do not grant a general right to publish confidential material or train unrelated AI models on customer information.

12 Confidentiality privacy and communications

Each party must protect non-public commercial, technical, security, pricing, transaction and onboarding information disclosed by the other or obtained through the relationship, using reasonable care and at least the care applied to its own comparable information. Use it only for the permitted relationship, due diligence, service performance, fee verification, lawful risk management or enforcement of rights. Disclose it only to persons with a genuine need to know who are subject to appropriate confidentiality duties, or as lawfully required by authorities or legal process. Where lawful and practicable, give notice of compelled disclosure and limit it to what is required.

This duty does not cover information demonstrably public without breach, lawfully known without restriction, independently developed, or lawfully received from an unrestricted third party. It does not prevent protected reporting to authorities. On a lawful request or termination, return or securely delete information no longer needed, subject to legal retention, defence of claims and controlled backups. Confidentiality lasts for three years after the relevant relationship ends; trade secrets remain protected while legally secret and personal data remains subject to applicable law. A service agreement's longer or more specific protections prevail.

Our Privacy Policy explains the relevant entity's processing, information sharing, retention and available rights. Independent providers may have separate privacy notices. You must supply only information relevant to the legitimate purpose and provide required information to persons whose data you disclose.

You must establish a lawful basis, deliver required notices and obtain any necessary consents or authority before providing another person's data. Independent Providers may act as separate controllers; actual roles and processing duties must be assessed and any required processing terms put in place. Contractual permission to share information does not waive data-subject rights, international-transfer requirements or either party's own data-security obligations.

Marketing preferences are separate from acceptance of these Terms. You may unsubscribe from marketing through the message link or contact us. Essential service, security, legal and requested support communications may continue where lawfully required or appropriate. We will request consent where applicable law requires it; use of the website is not a blanket consent to marketing, cookies or international transfers.

13 Third party services and links

Providers supply their own services under their applicable accepted terms. Before committing to a Provider's service, review the identified counterparty, its service and regulatory scope, fee schedule, settlement procedures, restrictions, risk disclosures, privacy notice and applicable contractual terms. Provider terms must be identified and made reasonably accessible before your valid acceptance or binding instruction. An introduction or receipt of a quote does not deem you to have accepted terms that were not disclosed. If required terms are unavailable or you do not accept them, do not proceed.

Where the Provider contracts directly with you or the approved underlying customer, that Provider is responsible for its own pricing, execution, settlement, custody, compliance decisions and contractual performance. Claims under that contract should be directed to it; BloxFi may assist within its agreed support role but does not insure its solvency, guarantee liquidity or assume its obligations merely by introducing or connecting it. Where Victus Ventures GmbH undertakes execution or settlement under its own agreement, that agreement governs its responsibilities; the direct-Provider allocation is not applied indiscriminately to the Swiss model.

Provider amendments and termination rights operate under the relevant Provider contract and law; these Terms do not automatically incorporate every future undisclosed change. External websites and tools have their operators' terms and privacy practices. Their inclusion is not a representation that they are suitable, solvent, uninterrupted or authorised for every proposed use.

This allocation does not exclude responsibility for our own selection, representations, technical work or other legally attributable conduct, or convert a subcontractor performing our obligations into an independent provider to avoid those obligations.

14 Availability suspension and exit

The public website and demonstrations are supplied on an “as available” basis. We do not promise continuous availability, compatibility with every system or freedom from every error or threat. We may maintain, update or withdraw public content and may restrict access where reasonably necessary for legal, security or operational reasons.

Access may be refused, restricted, suspended or terminated on reasonable grounds involving unlawful or prohibited use, sanctions exposure, failed verification, false or incomplete information, loss of required permissions, non-payment of properly due fees, security threats, misuse, a relevant Provider withdrawal or a binding legal direction. Urgent restrictions may take effect without prior notice. We may also require reassessment when your business, customer population, ownership, territories or risk profile materially changes.

Services depend on banks, Providers, telecommunications, cloud systems and, where relevant, blockchain networks. Outages, maintenance, cyber incidents, forks, congestion or legal changes can affect availability. BloxFi does not guarantee third-party systems or outcomes outside its agreed control. Any contractual force-majeure relief remains subject to its actual conditions, mitigation duties and exclusions; an ordinary operational failure is not automatically excused.

Live services remain subject to their agreed availability, notice, change, suspension and exit provisions. Where practicable and lawful, we will explain a restriction and appropriate remediation steps. Urgent action or legal restrictions may prevent advance notice or full reasons. Restrictions should address the affected risk and be reviewed as circumstances change.

Suspension of access does not itself cancel an accepted transaction, extinguish accrued rights, forfeit funds or create a lien or additional fee. The legally responsible party must handle pending transactions, records, verified claims and any lawful return of assets under the applicable contract and law. These Terms do not authorise us to seize customer assets or bypass agreed wind-down and export rights.

15 Liability business indemnities and preserved service protections

15.1 Contractual allocation. The website exclusions and liability cap below concern public website and demonstration use only. Liability, exclusions, caps and indemnities for onboarding, dashboard or API services, instructions, transactions, funds and Provider connectivity remain governed by the relevant service contract. Paragraphs 15.5 to 15.8 apply to a business that validly accepts these Terms, within their agreed scope and subject to section 2. They do not override an existing service allocation or make another entity jointly liable. No service claim may be recast as a website claim to evade its applicable contract.

15.2 Website exclusions. For public website and demonstration use, and only to the extent lawful and reasonable, we exclude implied warranties not expressly given and liability for indirect or consequential loss, or loss of profit, revenue, opportunity or goodwill arising from that use. We are not liable for a third party's independent acts merely because a link or reference appears on our website. This does not exclude our own legally attributable responsibility.

15.3 Website liability cap. Subject to the exceptions below and applicable fairness and reasonableness requirements, BloxFi Limited's aggregate liability for public website and demonstration claims is limited to the greater of HKD 1,000 and fees, if any, paid to BloxFi Limited specifically for that public website or demonstration access during the preceding twelve months. This separate website limit does not apply to service claims, customer assets or amounts governed by a service contract, and does not reduce a more protective mandatory right.

15.4 Non-excludable liability. Nothing in these Terms excludes or limits liability for fraud or fraudulent misrepresentation, gross negligence, wilful misconduct, death or personal injury caused by negligence, or any liability that law does not permit to be excluded or limited. Nothing removes a legally existing duty to account for or return another person's money or assets. An exclusion or cap applies only if enforceable in the circumstances; acceptance does not by itself establish that it is reasonable.

15.5 Business indemnity. If you validly accept these Terms for a business, that business shall indemnify and hold harmless each Protected Person against documented losses, liabilities, damages, third-party claims and reasonable external legal and professional costs, including reasonable investigation and remediation costs, to the extent caused by: (a) its breach of section 10, including unlawful financial promotions or materially false permission or reverse-solicitation statements; (b) its fraud, unlawful use, material breach of sections 3, 8 or 9, or material misrepresentation under these Terms; (c) unauthorised commitments or regulatory-status claims made in a Protected Person's name; or (d) its material breach of section 12 confidentiality, unlawful disclosure of data, unauthorised use of intellectual property under section 11, or supply of material infringing another person's rights. This includes covered acts of persons acting on that business's behalf. “Protected Persons” means BLOXFI LIMITED, Victus Ventures GmbH, BloxFi Payments Inc, BloxFi USA LLC and BloxFi Holding Ltd, and their respective directors, officers and employees acting in those capacities, but only to the extent the covered loss relates to that person's actual role in the matter.

15.6 Scope and limitations of the indemnity. Subject to section 2 and applicable law, the indemnity in paragraph 15.5 is not subject to the website cap in paragraph 15.3 or any monetary cap created by these Terms. This does not remove a cap expressly applicable to the relevant client's indemnity or liability under a governing service contract or dilute an expressly agreed uncapped service indemnity. Recoverable costs may include defending or responding to a covered customer, Provider or regulatory claim and proportionate corrective action reasonably needed because of the breach. Fines, penalties and restitution are recoverable only to the extent lawfully indemnifiable and attributable to the indemnifying business's covered conduct. Ordinary overhead, speculative loss, double recovery and loss attributable to a Protected Person's own breach, negligence, fraud or wilful misconduct are excluded. This allocation cannot transfer non-delegable regulatory responsibility.

15.7 Claims handling. A Protected Person must give reasonably prompt notice, sufficient details and reasonable cooperation, mitigate recoverable loss and allow the business reasonable participation in a covered defence. Late notice reduces recovery only to the extent of actual prejudice. No settlement may impose an admission, non-monetary obligation or unreimbursed payment on another person without its consent, not unreasonably withheld. A Protected Person may retain control of its own regulatory response or a defence involving conflict of interest, with reasonable consultation where lawful. Documented reasonable external costs may be claimed as incurred; disputed entitlement remains subject to the applicable dispute process and correction of overpayments. No final conviction or judgment is a prerequisite to asserting a claim, but this does not make an unsupported allegation conclusive. There is no automatic deduction from transaction principal or unlawful withholding of assets.

15.8 Enforcement and survival. BLOXFI LIMITED may enforce these Terms as a contracting party. Each other Protected Person may enforce paragraphs 15.5 to 15.8 in its own right under Hong Kong's Contracts (Rights of Third Parties) Ordinance, subject to the same conditions, defences, contractual priority and dispute provisions as the original parties. This express benefit does not make it a party to any service obligation, create a guarantee or pool entity liabilities. No other third party obtains enforcement rights under these Terms. The parties may vary or terminate these Terms prospectively without a Protected Person's consent, without prejudicing a claim already accrued. Relevant indemnities, confidentiality obligations, restrictions on use of intellectual property, accrued rights and dispute provisions survive termination for their intended purpose. Indemnity rights under a separate service agreement remain enforceable on their own terms, with no double recovery.

16 Changes notices and records

We may revise these website Terms prospectively by publishing an identified version and date, with appropriate advance notice of material changes where reasonably practicable. A change requiring agreement takes effect only after the legally required acceptance; material changes to an existing service contract require that contract's amendment process. Website posting or continued browsing does not amend that contract, increase a fee, expand authority or retrospectively change an accepted transaction.

If you do not accept revised website Terms, stop using the affected optional website functionality. This does not itself terminate a separate service agreement or remove your accrued rights. Urgent lawful security or access restrictions may be applied under the relevant agreement and law without disguising a contractual amendment.

Keep your contact details current. Formal service notices follow the service agreement. Website communications may be sent to the contact you supply, but an unreturned email alone is not conclusive proof of receipt. Electronic records may evidence instructions and acceptance where legally valid; reasonable challenges to accuracy or attribution remain available.

17 Governing law and general provisions

Hong Kong law governs these Terms, their formation and non-contractual obligations arising from them. Subject to section 2 and mandatory jurisdiction and consumer protections, the courts of Hong Kong have exclusive jurisdiction over disputes under these Terms, including a Protected Person's claim under section 15. A service claim governed by a separate service agreement remains subject to that agreement's law and dispute forum. Either party may seek urgent protective relief from a competent court. This provision does not alter the law, arbitration or court arrangements in any service agreement or provider contract, or restrict regulatory complaints or reporting.

These Terms create no partnership, employment, general agency or unrestricted authority. Neither party may transfer its contractual obligations under these Terms to another legal entity without the other's consent where required by law; a service relationship or mandate may be transferred only under its own applicable requirements. A corporate reorganisation cannot silently substitute the person responsible for customer money.

An invalid provision is severed only to the extent lawful; the rest continues without rewriting the essential bargain. A waiver must be express and specific. Rights and obligations needed for accrued claims, confidentiality, intellectual property and dispute resolution survive for their relevant purpose. The English text governs unless otherwise agreed or mandatory law requires a different result. No provision removes an independently existing statutory right.

18 Contact

For legal notices and questions about these Terms, contact info@bloxfi.com or write to BLOXFI LIMITED at Room 602, 6/F, Kai Yue Commercial Building, No. 2C, Argyle Street, Mongkok, Kowloon, Hong Kong. For technical support, contact support@bloxfi.com. For a compliance concern, contact compliance@bloxfi.com.

For a live transaction, urgent security incident or formal service complaint, also use the verified channel and counterparty identified in your service agreement. Include the relevant reference and necessary facts, but never send passwords, private keys or recovery phrases. Contacting us does not restrict your right to contact a competent regulator or pursue an available legal remedy.