These Terms and Conditions (“Terms”) govern your access to and use of Auraya Wallet, including its applications, websites, software, and related services (collectively, the “Platform”).

By accessing or using Auraya Wallet, you acknowledge that you have read, understood, and agreed to be legally bound by these Terms.

If you do not agree, you must not use the Platform.

1. About Auraya Wallet

Auraya Wallet is a hybrid digital asset wallet platform operated by Auraya Wallet Ltd., offering both custodial and non-custodial wallet services to users.

1.1 Non-Custodial Services

For non-custodial wallets, Auraya provides software tools that allow users to manage blockchain assets independently. In this mode, Auraya does not custody, store, control, transmit, or access user funds, private keys, recovery phrases, or transaction authorization data.

1.2 Custodial Services

For custodial wallets, Auraya maintains control over the private keys associated with your wallet on your behalf. By using custodial services, you acknowledge that Auraya holds your assets in custody and may take certain actions on your account in accordance with these Terms, applicable law, or regulatory requirements.

1.3 Recovery Phrase

Upon account creation, users of non-custodial wallets will be issued a 12-word recovery phrase ("Seed Phrase"). You acknowledge and agree that:

• Your 12-word recovery phrase is the sole means of recovering access to your non-custodial wallet.
• Auraya does not store, retain, or have access to your recovery phrase.
• You are solely responsible for the safekeeping and confidentiality of your recovery phrase.
• Loss of your recovery phrase may result in permanent and irreversible loss of access to your assets.

2. Security Acknowledgment

You expressly acknowledge and agree that:

• For non-custodial wallets, Auraya has no ability to access, recover, reverse, or unilaterally control your assets under normal circumstances.
• All transactions on non-custodial wallets are executed solely by you via decentralized networks.
• Loss of credentials, recovery phrases, or access devices may result in permanent and irreversible loss.
• Auraya bears no responsibility for such loss arising from your own actions or negligence.
• You remain solely responsible for securing your wallet, credentials, and recovery phrase.

Notwithstanding the above, Auraya reserves the right to freeze, restrict, or block access to assets or wallet functionality — including on non-custodial interfaces — in the following circumstances:

• Where there is credible evidence or reasonable suspicion of a security breach, hack, or unauthorized access.
• Where activity is suspected to involve illegal use, money laundering, fraud, sanctions violations, or other prohibited conduct.
• Where the user has materially breached these Terms.
• Where required by applicable law, court order, or regulatory authority.

Such restrictions operate solely at the interface and platform level and do not constitute a guarantee that underlying blockchain assets can be recovered or retrieved.

3. Eligibility

You must:

• Be at least 18 years old.
• Have legal capacity in your jurisdiction.
• Not be prohibited from using cryptographic software or digital assets.

Auraya does not guarantee Platform availability in all jurisdictions.

4. Account Tiers & Transaction Thresholds

Auraya Wallet operates a tiered account structure designed to manage risk, ensure compliance, and facilitate responsible platform use.

4.1 New Account Threshold

New accounts are subject to a cumulative transaction threshold of USD $10,000 (or equivalent in supported digital assets). Once this threshold is reached or exceeded on a new account, all outbound transactions will be temporarily suspended until the account is upgraded to a higher tier.

4.2 Tier Upgrade Process

To move beyond the new account threshold and access higher tiers, users must:

• Complete additional identity verification and Know Your Customer (KYC) requirements as requested by Auraya.
• Submit any supplementary documentation required for compliance review.
• Meet all other conditions specified by Auraya for the applicable account tier.

Higher tiers unlock increased transaction limits, additional platform features, and expanded access to Auraya services. Auraya reserves the right to define, modify, or remove account tiers at any time, with or without prior notice.

4.3 Compliance Holds

Where a new account approaches or exceeds the $10,000 threshold without completing the required upgrade steps, Auraya may place a compliance hold on the account. During a compliance hold:

• Existing assets remain in the wallet but outbound transactions may be restricted.
• Users will be notified of any required actions to restore full functionality.
• Auraya makes no guarantee as to the timing or duration of any compliance review.

5. User Responsibilities

You agree to:

• Maintain accurate account information.
• Safeguard passwords, PINs, email access, and recovery phrases.
• Use the Platform lawfully and in compliance with applicable regulations.
• Immediately notify Auraya of suspected unauthorized access.

6. Security & Risk Controls

Auraya Wallet includes security mechanisms designed to identify anomalous usage patterns, unusual transaction behaviour, and elevated operational risk signals.

You acknowledge that such mechanisms may:

• Generate alerts or warnings.
• Introduce delays, limitations, or conditional access.
• Require additional verification or review steps.

These controls may operate at the platform level and do not in all cases grant Auraya direct access to underlying blockchain assets.

7. Compliance, Monitoring & Risk Management

Your use of the Platform is subject to mandatory compliance, risk assessment, and regulatory controls, which may be applied dynamically and without prior notice.

Such controls may include, but are not limited to:

• Ongoing behavioural and transactional analysis.
• Automated and manual account risk profiling.
• Conditional access limitations.
• Temporary or extended withdrawal constraints.
• Incremental verification and due diligence measures.
• Adjustments to internal account scoring parameters.

Where activity, usage patterns, or account characteristics exceed internally defined risk tolerances or trigger compliance indicators, Auraya reserves the right to apply proportionate restrictions until all applicable obligations are satisfied.

Failure to complete required compliance steps may result in continued or indefinite limitations on Platform functionality.

Auraya makes no guarantee as to the timing, duration, or outcome of any compliance-related review.

8. Prohibited Activities

You may not use Auraya Wallet to:

• Engage in illegal, fraudulent, or deceptive activity.
• Circumvent sanctions, laws, or regulatory requirements.
• Interfere with Platform security or integrity.
• Use the Platform for prohibited financial activities.

Auraya reserves the right to restrict, freeze, or terminate access where prohibited use is suspected, and to take such other action as it deems appropriate in accordance with these Terms.

9. Fees

Auraya may charge fees for certain features or services. Fees, if applicable, will be disclosed prior to use.

Network fees are determined by blockchain protocols and are not controlled by Auraya.

10. Assignment

Your agreement to these Terms may not be assigned, subcontracted, delegated, or otherwise transferred by you without our prior written consent.

You agree that Auraya may assign any of its rights and/or transfer, sub-contract, or delegate any of its obligations under these Terms without restriction.

11. Third-Party Services

Auraya may integrate with third-party services, protocols, or networks. Auraya is not responsible for third-party actions, failures, or security issues.

Your interactions with third parties are solely between you and them.

12. Disclaimer of Warranties

The Platform is provided "as is" and "as available". Auraya disclaims all warranties, express or implied, including but not limited to merchantability, fitness for a particular purpose, security, availability, and accuracy of blockchain data.

Use of the Platform is at your own risk.

13. Limitation of Liability

To the maximum extent permitted by law, Auraya shall not be liable for:

• Loss of funds.
• Failed or delayed transactions.
• User error.
• Loss of access credentials.
• Network congestion or protocol failures.
• Security breaches beyond Auraya's control.

Auraya's total liability, if any, shall not exceed the amount paid by you to Auraya in the preceding twelve (12) months.

14. Indemnification

You agree to indemnify and hold harmless Auraya, its directors, officers, employees, and partners from any claims arising from your use of the Platform, violation of these Terms, or violation of applicable laws.

15. Termination

Auraya may suspend or terminate access at any time, with or without notice, where permitted by law.

Termination does not affect underlying blockchain assets on non-custodial wallets, which remain accessible solely via your credentials. For custodial wallets, termination procedures will be communicated separately in accordance with applicable law and regulatory requirements.

16. Governing Law

These Terms shall be governed by and construed in accordance with the laws of Cayman Islands, without regard to conflict of law principles.

17. Changes to Terms

Auraya may update these Terms at any time. Continued use of the Platform constitutes acceptance of updated Terms. Where changes are material, Auraya will use reasonable efforts to notify users in advance.

18. Contact

For questions relating to these Terms, contact Auraya through official support channels.