These Terms of Service (the "Agreement") form a legally binding contract between Anzo Labs PTE LTD., operating as Anzo (referred to as "we," "us," "our," “Anzo,” or “the App) and you, the User (referred to as "you," "your," or "yours").
Anzo provides software that allows you to create, manage, and interact with a self-custodial digital wallet for assets on public blockchains.
You maintain sole control over your private keys and digital assets. Anzo does not have access to your private keys, and only you can authorize transactions involving your digital assets. We do not hold or manage your funds. We may, however, enable access to third-party services, such as payment cards or fiat currency on/off ramps, which are governed by the terms and regulations of those independent providers. Anzo does not provide currency exchange services and is not classified as a money services business. Transactions between users occur directly on a peer-to-peer basis, with Anzo’s role limited to offering software infrastructure for peer-matching.
Before using our Services and Application, you must thoroughly review this Agreement. By creating an Account and utilizing our Services or Application, you agree to comply with this Agreement and any other relevant contracts between you and us. If you do not agree with any part of this Agreement, you must stop using our Services and Application and terminate your Account as outlined in this Agreement. You are solely responsible for ensuring that your use of our Application complies with all applicable laws, regulations, licensing requirements, and other relevant legal obligations.
We reserve the right to periodically require you to reaffirm your acceptance of this Agreement as a condition for continued use of our Services and Application. Any actions you take after an updated version of this Agreement takes effect will be governed by the revised terms.
In accordance with UN Security Council resolutions with refuse to service individuals and entities from Republic of Korea (North Korea) and Iran.
We may restrict access to our Services in certain countries or regions, which may include, but are not limited to: Somalia, South Sudan, Sudan
To be eligible to use our Services, you must confirm that:
a) You are at least 18 years old or have reached the legal age of majority in your country of residence, enabling you to enter into and comply with legally binding agreements.
b) You have not been previously banned or restricted from using our Services.
c) Entering into this Agreement with us does not breach or conflict with any other legal obligations you may have.
d) You are not located or residing in any prohibited jurisdictions, including those subject to economic sanctions enforced by Singapore or other applicable authorities.
e) You are not subject to international sanctions, including those imposed by Singapore or the United Nations, nor are you affiliated with individuals, organizations, or entities under such sanctions, nor do you represent such parties.
For users accessing the Services on behalf of a legal entity, eligibility requires:
a) Your organization is duly incorporated in accordance with the laws of its jurisdiction.
b) Your organization operates in compliance with all applicable laws and regulations.
c) You are legally authorized to act on behalf of your organization and enter into binding agreements, with the ability to provide evidence of such authority.
d) Your organization is not subject to international sanctions, including those imposed by Singapore or the United Nations, nor is it affiliated with sanctioned individuals, organizations, or entities, nor does it represent such parties.
We reserve the right to evaluate your eligibility to access and use our Services at any time by verifying compliance with the above criteria. If eligibility requirements are updated, modified, or expanded, we may reassess your eligibility. We may request documentation to verify eligibility when necessary. All decisions regarding initial and ongoing eligibility assessments are final.
Creating an Account is a prerequisite for accessing and using our Services. By agreeing to these Terms, you confirm that you are registering an Account for your personal use or on behalf of yourself.
Users seeking to connect a bank account or use payment card services must complete Know Your Customer (KYC) and Anti-Money Laundering (AML) verification processes. These procedures ensure the legitimacy of user identities and compliance with regulatory requirements. Following KYC/AML verification, user information will undergo screening for Anti-Money Laundering (AML) and Politically Exposed Persons (PEP) compliance to mitigate risks associated with financial transactions, including those involving digital assets.
If a third party, such as a legal representative, creates an Account on your behalf, we may require proof of their authorization, such as a Power of Attorney or other relevant documentation. By registering an Account, you acknowledge that authorizing a third party to act on your behalf, including tasks like Account creation or linking your self-custodial wallet, does not relieve you of your responsibilities under these Terms. Any actions performed by an authorized third party are deemed to be carried out with your direct or indirect approval.
Each user, whether an individual or a legal entity, is permitted to maintain only one Account. Any additional Accounts created with information already associated with an existing Account may be suspended.
You may close your Account at any time. Prior to closure, you must withdraw all funds from your Account. We recommend reviewing and securing any personal or financial information linked to your Account before initiating the closure process.
We reserve the right to suspend, restrict, or terminate your Account and restrict access to our Application under certain conditions, including but not limited to:
a) Actions that we believe may damage our reputation or cause negative consequences.
b) Legal obligations arising from a regulatory authority, court order, law enforcement request, or other competent authority.
c) Reasonable suspicion of a violation of these Terms or other applicable agreements.
d) Reasonable belief that a transaction or order is incorrect or erroneous.
e) Suspected unauthorized or fraudulent access to your Account, or access without your consent or knowledge.
f) Suspected security breaches affecting your Account.
g) Reasonable suspicion of money laundering, terrorist financing, fraud, or other financial crimes.
h) Your Account being subject to ongoing or pending litigation, investigations, or legal proceedings.
i) Your Account being deemed non-compliant or associated with increased regulatory risks.
In cases of Account suspension or termination, any active Transactions or Orders may be paused, canceled, or reversed. We also reserve the right to deactivate your Account immediately for any of the reasons listed above.
We will provide an explanation for any suspension, restriction, or termination of your Account, along with guidance on correcting any inaccurate or missing information or documentation, where applicable. Once the issues are resolved and your Account no longer falls under the reasons for suspension or termination, restrictions will be lifted, and Transactions or Orders may proceed.
The KYC/AML Verification process is conducted to evaluate the background and eligibility of our users to access payment products, such as bank transfers or payment card services, in compliance with the requirements of relevant service providers.Creating an Account is a prerequisite for accessing and using our Services. By agreeing to these Terms, you confirm that you are registering an Account for your personal use or on behalf of yourself.
This verification process is a critical part of our commitment to maintaining a secure and compliant environment for our Users. During this process, we collect and process specific personal information to meet our legal obligations and enhance the security of our Application. The collection and processing of personal information are carried out in strict accordance with our Privacy Policy.
We may employ Open Banking services for certain elements of the verification process, including bank account linking and identity verification. This involves confirming personal details such as your name, date of birth, nationality, and country of residence, among others. Valid forms of identification include national documents such as passports, driver’s licenses, or other government-issued IDs that include a photograph.
Our Open Banking partners operate as an independent third-party service providers with their own privacy practices and policies. To fully understand how our partners collect and process your data, we strongly recommend reviewing our service providers Privacy Policy separately. Their policies governs the handling of personal information within their services, and we are not responsible for any breaches or mishandling of personal data by our service providers or other third parties resulting from their actions or omissions. The exact service providers will be clearly identified before a user engages in their services.
By submitting information for identity verification and KYC/AML compliance, you confirm that all provided details are true, accurate, and complete. You also affirm that you have not deliberately withheld or altered any information to affect the outcome of our evaluation. If any provided information is found to be false, inaccurate, or incomplete, you agree to promptly address these issues by submitting additional documents or records to correct the discrepancies.
You are required to promptly notify us of any changes in circumstances that impact the accuracy or integrity of the information you have provided, and to supply updated information as necessary.
We reserve the right to disclose any submitted information to relevant authorities in accordance with applicable laws and regulations. This may occur if we have reasonable grounds to suspect that the information is linked to fraudulent activities, money laundering, terrorism financing, or other financial crimes. Additionally, if we cannot definitively determine a User’s involvement in such activities, we may share the information with competent authorities for further review.
When you place a Buy Order to acquire Digital Assets, our system may automatically match you with the most competitive Sell Order available, based on the best exchange rate and the total amount you wish to purchase. This ensures efficient and cost-effective transactions. For Sell Orders, when you initiate the sale of Digital Assets, our Application uses a smart-contract escrow mechanism on publicly available blockchains that trigger a transaction from your self-custodial wallet, transferring the Digital Assets to an escrow smart contract. You must confirm and authenticate the order placement using your self-custodial wallet, ensuring a secure and transparent trading process.
If no matching Sell Order exists to fulfill your Buy Order, you may create a Buy Order, which will be displayed on the front-end of our decentralized Application (dApp) marketplace, allowing you and other Users to view and potentially fulfill it.
If no matching Buy Order exists to fulfill your Sell Order, you may create a Sell Order, which will be displayed on the front-end of our decentralized Application (dApp) marketplace, allowing you and other Users to view and potentially fulfill it.
All Orders are executed on a prepaid basis, requiring sufficient funds in your self-custodial wallet to cover the Order’s value and any applicable fees. These funds are reserved until the Order is fulfilled, canceled, expires, or is terminated. Orders exceeding the available funds in your Account will not be executed and will be rejected.
By placing an Order, you acknowledge that we are not responsible for its partial or complete cancellation. Once an Order is in the process of being fulfilled, cancellation may not be possible. Before submitting an Order, you must ensure:
a) The amount of Digital Assets for purchase or sale is accurately entered.
b) The purchase or sale rates for the Order have been carefully reviewed.
c) You have reviewed and understood the applicable Fees for the Order.
d) You understand the net value of Digital Assets to be received or sold upon Order fulfillment.
Orders may not always be fulfilled due to various factors, including but not limited to:
a) Application operational status, such as downtime, scheduled or emergency maintenance, or holidays.
b) Potential impact of your Order on market conditions, including whether it constitutes Market Manipulation.
c) Insufficient funds in your Account.
d) Hardware or software issues, whether mechanical or electronic.
e) Compliance requirements or other relevant factors.
If an Order cannot be fulfilled, we will promptly notify you, explaining the reasons for the failure and requesting your approval to resubmit the Order at the current exchange rate.
You agree that we are not liable for delays or failures in Order fulfillment caused by factors beyond our control, such as technical issues or external conditions.
For Buy Orders, matching is based on the total amount you wish to purchase, requiring a Sell Order to meet or exceed that amount and the payment method chosen. If multiple Sell Orders meet the amount criteria, priority is given to the one with the most favorable exchange rate to ensure the best value for buyers. If multiple Sell Orders have identical amounts and rates, no specific prioritization applies.
Buyers may also view all available Sell Orders in the Marketplace and manually select a Sell Order that meets their preferences to initiate a transaction.
For Sell Orders, matching is based on the total amount you wish to sell, requiring a Buy Order to meet or exceed that amount and the payment method where you wish to receive the funds. If multiple Sell Orders meet the amount criteria, priority is given to the one with the most favorable exchange rate to ensure the best value for buyers. If multiple Sell Orders have identical amounts and rates, no specific prioritization applies.
For Sell Orders, confirmation is typically received once the transaction is completed on your self-custodial wallet, with timing dependent on the public blockchain’s technical conditions.
For Buy Orders, confirmation occurs directly through our interface, generally within 60 seconds.
Order Confirmations include details such as the Order’s time and date, amount, paid Fees, and contact information of the counterparty for any questions, inquiries, or complaints.
These timeframes are indicative, non-binding, and may vary due to network conditions or other factors. We are not liable for delays in Order confirmation or failure to meet the stated confirmation times.
If an Order cannot be fulfilled due to compliance issues, we may delay its execution until compliance clearance is obtained. Such Orders will undergo further review within a reasonable period. If clearance cannot be achieved due to insufficient information or other compliance-related issues, we may request additional details regarding your identity, the nature of the transaction, or other relevant compliance information.
Orders that fail to meet compliance requirements, particularly due to missing information, will not be fulfilled. We reserve the right to decline such Orders based on reasonable grounds of non-compliance with applicable regulations and laws.
Within the Anzo app, users can facilitate exchanges between fiat currencies and digital assets through designated processes. The method of exchange varies depending on whether a user is acquiring or disposing of digital assets.
Anzo does not permit direct conversions of fiat currency into digital assets or vice versa within the app. To purchase digital assets using fiat currency, users must engage with one of our third-party agent partners ("Agents"). Users can initiate a purchase by transferring fiat currency to a selected Agent to complete the transaction.
Conversions from digital assets to fiat currency through the Anzo app are subject to the availability of participating Agents willing to act as counterparties for such transactions.
Anzo may partner with licensed Virtual Asset Service Providers (VASPs) to provide liquidity for both fiat and digital assets, enabling seamless transactions involving fiat currencies.
Users have two options for initiating transactions with our designated Merchants:
a) Select a preferred Agent from a provided list prior to starting the transaction, or
b) Utilize Anzo’s automated routing system, which connects users to the Agent offering the most competitive exchange rates for the transaction.
In both scenarios, direct integration between users and Agents is not required to complete transactions.
Users acknowledge that transactions involving the purchase of digital assets from third-party Agents are separate from the Anzo app. Anzo explicitly disclaims responsibility for any aspect of these transactions, including but not limited to the Agent’s adherence to applicable laws or their terms of service.
Users are strongly encouraged to perform their own due diligence to ensure that Agents comply with relevant regulations and terms. It is solely the user’s responsibility to verify that transactions with third-party Agents meet their expectations.
By participating in transactions with third-party Agents via the Anzo app, users waive any claims or liabilities against Anzo related to such transactions. Users should thoroughly review the terms and policies of third-party Agents and make informed decisions before engaging in transactions.
The exchange rate reflects the value of a digital asset relative to a fiat currency for conversion purposes, applicable to both buying and selling transactions. Exchange rates may fluctuate depending on the specific digital asset and are subject to change over time.
Exchange rates for converting digital assets to fiat currency on the Anzo app are set by individual Agents integrated with the platform. These rates apply when a user engages in a transaction, such as purchasing digital assets from a Merchant’s specific sell order.
Anzo does not directly control these exchange rates. Agents independently determine their rates, which may differ across various Merchants on the app. Users are advised to carefully evaluate the exchange rates offered by Merchants to make well-informed transaction decisions.
The Anzo app may impose fees on certain transactions. Any applicable fees will be displayed within the app prior to completing a transaction. If you utilize payment products offered by our partners, such as bank transfers or payment cards, the relevant fees will be presented in the app or detailed in the terms of service for those products.
Anzo is dedicated to maintaining transparency and fairness in its fee structure. Any changes to our fee system will be communicated to users in advance. We provide a one-week notice period before implementing any updates to our fee structures or rates, allowing users the opportunity to agree to or opt out of these changes.
This consent is obtained during the sign-in or registration process within the Anzo app. By accepting these Terms of Service, users implicitly agree to any future fee adjustments. To keep users informed, we will use our official social media channels as the primary method for notifying users of upcoming fee changes.
Transaction limits are predefined thresholds assigned to each user upon successful account registration. These limits specify the maximum transaction volume a user may conduct daily. The limits are determined based on the currency type and payment method selected. Anzo reserves the right to adjust these limits in accordance with our internal policies, which are informed by assessments from our AML/KYC procedures to ensure compliance with regulatory and security standards.
Currently, the Anzo app accepts only USDT (USDT Tether) on the TON (Telegram Open Network) blockchain for transaction purposes. We may update the token and blockchain utilized for deposits and withdrawals and this will be clearly communicated to users within the app. It is the users responsibility to check the allowed deposit and withdrawal currency and supported network. User agree to remove any liability from Anzo for incorrect use of deposit and withdrawal blockchains.
All transactions on the Anzo app must comply with principles of authenticity, fairness, and transparency. This section outlines activities that are strictly prohibited and constitute violations of these Terms, subject to penalties and remedies.
The following activities are strictly forbidden on the Anzo app and its services, constituting a breach of these Terms:
a) Illegal Activities: Engaging in any actions that violate the laws, regulations, or legal frameworks of the jurisdictions in which we operate, including but not limited to Singapore’s laws and regulations enforced by relevant authorities.
b) Fraudulent Conduct: Any attempt to deceive or mislead other users, customers, or Anzo in connection with transactions or orders.
c) Market Manipulation: Executing transactions intended to disrupt the app’s normal operations or artificially influence digital asset prices, including coordinated efforts with others to manipulate orders or transactions.
d) Cybersecurity Breaches: Engaging in activities that compromise cybersecurity, such as using unauthorized automated systems, attempting to overload or disrupt our systems, unauthorized access to accounts, introducing malware, or other malicious activities.
e) Intellectual Property Violations: Using Anzo’s intellectual property, including copyrights, trademarks, or trade secrets, without prior authorization, in violation of applicable intellectual property laws.
f) Coercion and Collusion: Participating in activities such as price fixing, soliciting others to manipulate prices, or engaging with other market participants to disrupt, coerce, intimidate, or interfere with their activities.
To the fullest extent permitted by law, Anzo disclaims any liability, warranties, or responsibility for losses unless explicitly stated otherwise in these Terms. These Terms, along with any other agreements between you and Anzo, do not limit or exclude liability that cannot be excluded under applicable law.
You acknowledge that in disputes with other app users, neither Anzo nor its partners, affiliates, service providers, officers, directors, employees, or representatives shall be liable for any claims, losses, demands, costs, expenses, or damages arising from such disputes. These disputes must be resolved solely between the involved users, independent of Anzo or its affiliates.
You agree to indemnify and hold harmless Anzo, its partners, affiliates, service providers, officers, directors, employees, and representatives from any claims, losses, demands, costs, expenses, or damages arising from your use of the Anzo app and services or those of any third party.
The Anzo app and services are provided on an "as is" and "as available" basis without any express, implied, or statutory warranties. Anzo does not guarantee title, merchantability, data accuracy, system integration, quiet enjoyment, fitness for a particular purpose, or non-infringement. We do not warrant that access to the app or services will be continuous, uninterrupted, timely, or error-free.
All information, materials, opinions, projections, or estimates provided by Anzo are for informational purposes only and may change without notice. You are solely responsible for evaluating the relevance, accuracy, completeness, reliability, and value of such information. Anzo bears no liability for any direct or indirect damage or loss resulting from your reliance on this information.
Anzo’s services and information do not constitute investment, financial, regulatory, tax, or legal advice. You are responsible for seeking independent professional advice. Any decisions made without such advice are at your own risk.
Anzo does not guarantee specific processing times for transactions involving blockchain wallets, bank accounts, credit/debit cards, or electronic money wallets, as these are influenced by factors beyond our control. While we strive for timely execution, no specific timeframes are guaranteed.
You acknowledge that any reliance on the above statements is based solely on these Terms unless explicitly stated otherwise.
Anzo collects, uses, and shares personal information in compliance with the Personal Data Protection Act 2012 (PDPA) of Singapore. Our practices regarding data collection, usage, storage, sharing, and transfers, as well as your rights as a data subject, are outlined in our Privacy Policy.
The Privacy Policy is an integral part of these Terms and should be reviewed alongside other provisions. Users are encouraged to read the Privacy Policy to understand how we handle personal data.
By agreeing to these Terms, you consent to the collection, use, disclosure, and processing of your personal data as described in the Privacy Policy, including cross-border data transfers where applicable.
You have rights regarding your personal data, including access, correction, and deletion. For a complete description of these rights and how to exercise them, refer to the Privacy Policy.
Due to the digital and decentralized nature of the Anzo app, disputes arising from its use are subject to a unique resolution framework. Traditional disputes of a contractual or transactional nature may not be resolved through conventional legal or alternative dispute resolution methods due to the app’s characteristics.
This framework addresses issues such as smart contract failures, oracle failures, API failures, backend code failures, and account access issues.
By using the Anzo app and services, you waive all grounds for disputes related to the issues listed above, including but not limited to smart contract, oracle, API, backend code, or account access failures.
Where feasible, the Anzo app employs automated dispute resolution processes aligned with principles of transparency, fairness, and efficiency to address the aforementioned issues.
Due to the limitations of digital and blockchain technologies, your remedies for such issues are limited to those provided by the app’s automated resolution processes, accessible exclusively through the app’s mechanisms and interfaces.
You acknowledge that traditional legal recourse, such as litigation, arbitration, or mediation, may not be applicable or enforceable for the issues outlined. You waive any right to seek remedies or damages through legal means for these issues.
This dispute resolution framework is binding on all users. By agreeing to these Terms, you accept and understand this framework. Any attempt to bypass or challenge it constitutes a breach of these Terms.
You are solely responsible for securing your login credentials, including passwords, private and public keys, identifiers, passphrases, backup data, and other relevant data, including those related to third-party apps or services.
By agreeing to these Terms, you acknowledge your responsibility for maintaining the security of your credentials and data, which is critical to protecting your account and associated assets.
If you suspect a compromise or breach of your account or security data, or become aware of any incident affecting your account or Anzo (including cybersecurity attacks), you must immediately notify us through the official notification channels provided in these Terms.
Anzo provides customer support resources to ensure a seamless user experience and address account-related questions or issues. We prioritize clear and timely communication, primarily through our official Facebook and X channels for updates, notifications, and announcements.
Additionally, we offer newsletters and periodic updates via email, social media, and/or in-app notifications to keep users informed about significant developments, changes, or enhancements to the app.
All materials and content related to Anzo, its services, and the app are protected by applicable intellectual property laws and are not licensed to third parties unless explicitly stated.
You are granted a limited, personal, non-commercial license to use protected materials and content solely in connection with your use of the Anzo app and services. Any use beyond this scope constitutes an infringement of intellectual property rights and may result in legal action by Anzo.
Anzo shall not be liable for performance failures, downtime, interruptions, unavailability, or other malfunctions caused by events beyond our direct or indirect control ("Force Majeure"). Such events include earthquakes, floods, fires, government regulations, economic blockades, sanctions, incarceration, acts of war, natural or nuclear disasters, epidemics, pandemics, acts of authorities, terrorism, sabotage, strikes, accidents, emergencies, or malfunctions of software, hardware, communication lines, or network services.
If you become subject to international, supranational, or national sanctions, Anzo reserves the right to unilaterally terminate these Terms without prior notice. Any transactions or relationships with you under such sanctions will be terminated, and your account will be closed immediately.
Anzo does not guarantee uninterrupted or flawless access to its services or app, nor seamless order or transaction execution. While our customer support aims to provide timely responses, we do not guarantee specific response times and are not liable for damages arising from accessibility or availability issues.
You are solely responsible for complying with all applicable laws, regulations, and licensing requirements, including those related to data protection, anti-money laundering, terrorist financing prevention, and taxation. Anzo is not liable for any breaches or consequences arising from your use of the app or services.
Anzo reserves the right to amend these Terms to reflect legislative changes or other valid reasons. You will be notified of changes via the app. Unless you object in writing, your acceptance is assumed. You may terminate any agreement with Anzo if you do not accept the updated Terms.
Anzo does not provide tax advice. You are responsible for seeking professional tax guidance and determining tax obligations for your transactions. Anzo is not responsible for tax withholding, reporting, or collection procedures in your jurisdiction.
Anzo may communicate with law enforcement authorities, including courts and regulators, at our discretion or in response to their requests, in compliance with applicable laws.
These Terms, along with other agreements established by Anzo, constitute the entire agreement between you and Anzo, superseding any prior discussions, agreements, or representations.
If any provision of these Terms becomes invalid or unenforceable due to changes in Singapore law, Anzo will modify the affected provisions to ensure their validity and enforceability. The validity of other provisions remains unaffected.
In the event of Anzo’s acquisition, merger, or transfer, your data, including personal data, may be disclosed to the acquiring entity in accordance with applicable rights.
Provisions that survive termination or expiration of these Terms, including those related to account suspension, debts, and general usage, remain enforceable.
These Terms are written in English. Translations are provided for convenience and are not considered accurate representations. The English version prevails in case of discrepancies.
These Terms and the relationship between you and Anzo are governed by Singapore law. Any disputes shall be subject to the exclusive jurisdiction of Singapore courts.
