Terms of Service

Introduction

These Terms and Conditions ("Terms") govern your access to and use of TrueHold's products and services, including the card program and any related on-ramp, off-ramp, or virtual asset exchange features (collectively, the "Services"). By accessing or using the Services, you enter into a legally binding agreement with TrueHold ("TrueHold," "we," "our," "us"). Please read these Terms carefully. If you do not agree, do not visit, access, or use the Services.

Non-custodial by design: TrueHold does not request or store your seed phrases or private keys. Prior to spend, your digital assets remain in wallets you control. See Sections 2 and 5.

Updating these Terms

We may update these Terms from time to time (for example, due to service improvements, legal or regulatory changes, or to prevent abuse). We will provide notice of material changes when required. Unless a different effective date is stated, updates are effective when posted. Your continued use of the Services after updates constitutes acceptance of the revised Terms. We may also change, suspend, or discontinue any Service at any time.

We may, without prior notice or liability, and for any reason:

  • Modify technical solutions used in the Services;
  • Set or adjust usage limits;
  • Temporarily or permanently suspend or restrict access to the Services;
  • Cease providing some or all features to you or to all users.

Glossary

  • Affiliate — any entity controlling, controlled by, or under common control with a party.
  • AML — Anti-Money Laundering rules and controls.
  • Blockchain — distributed ledger technology on which digital asset transactions are recorded.
  • Digital Asset — cryptographic tokens or other digital representations of value.
  • Fiat — government-issued currency (e.g., USD, EUR).
  • KYC — Know Your Customer identity verification and related checks.

Important Information

Your use of the Services is conditional upon your acceptance of these Terms. If you have questions, contact us at hello@truehold.xyz. If you disagree with any provision, stop using the Services immediately. Local laws and regulations may apply to your use; you are responsible for compliance.

Important notice regarding digital assets

Digital assets are volatile and can lose value quickly. Market liquidity may be limited. The value of a digital asset may fall to zero. Consider whether trading, holding, or using digital assets is suitable for you given your financial situation and risk tolerance.

Regulatory considerations & availability

Availability of the Services varies by jurisdiction and is subject to applicable laws and sanctions programs. We do not provide Services where prohibited, including (without limitation) jurisdictions subject to comprehensive sanctions. We may suspend or terminate access, restrict features, return assets as directed by authorities, or block transfers where required by law or sanctions programs.

1) About TrueHold

Who we are. TrueHold provides a non-custodial crypto spending experience: connect your self-custody wallet, issue a card, and spend with just-in-time conversion to fiat at purchase time.

Issuance & partners. Card and e-money features are provided by licensed partners, authorized electronic money institutions / card issuers. Features and availability vary by region and partner.

TrueHold does not take custody of your private keys or require deposits of your digital assets to TrueHold accounts.

2) What TrueHold does

Subject to availability and partner coverage, TrueHold may offer:

  • Card Services: virtual and/or physical payment cards for online, in-store, and subscription payments; Apple Pay / Google Pay where supported.
  • On-Ramp (optional): buy digital assets with fiat via third-party providers.
  • Off-Ramp (optional): sell digital assets for fiat via third-party providers.
  • Virtual asset exchange (optional): swap digital assets via third-party providers.

TrueHold does not list or trade regulated securities. Certain Services may be provided by third parties under their own terms.

3) Eligibility

You may use the Services only if you:

  • Are at least 18 years old (or the age of majority in your jurisdiction);
  • Pass all required due diligence (KYC/AML/sanctions screening);
  • Are not prohibited by law from using the Services;
  • Are not a resident, citizen, or subject of sanctions in any restricted jurisdiction;
  • Use the Services for lawful purposes only.

4) KYC/AML & ongoing checks

We collect and retain information required for KYC/AML and sanctions compliance. We may request identity documents (e.g., passport) and perform checks using reliable third-party sources. Do not share account credentials with others or use VPN/proxies to evade geo-restrictions. You must keep information accurate and up-to-date and promptly notify us of changes. We may request additional information at any time to meet our legal obligations.

5) How the Services work

Card Services (non-custodial spend)

  • Connect wallet: link a self-custody wallet you control. We do not request seed phrases or private keys.
  • Allowances/permits: you may grant revocable on-chain permissions to enable spending up to a specified limit. You can reduce or revoke permissions at any time.
  • Just-in-time conversion: at purchase authorization, we facilitate real-time conversion of the needed amount of your digital asset(s) to fiat via partners. If approval succeeds, the card network receives an approval code and the merchant is paid in fiat.
  • Controls: freeze/unfreeze, limits, alerts, merchant/geo filters (where available).
  • Apple Pay / Google Pay: available in select regions/devices/issuers.

On-Ramp (buy)

  1. Choose asset and amount → we show price, fees, and rates up front;
  2. Provide recipient wallet address you control;
  3. Complete fiat payment via supported method;
  4. On confirmation, assets are delivered to your wallet.

Off-Ramp (sell)

  1. Choose asset and amount → we show rates/fees;
  2. Send assets to the provided address;
  3. Provide your bank payout details;
  4. On confirmation, fiat is sent to your bank account.

Virtual asset exchange (swap)

  1. Choose asset pair and amount → we show rates/fees;
  2. Provide recipient wallet; send input asset as instructed;
  3. On confirmation, output asset is delivered to your wallet.

Finality: Blockchain transactions are irreversible. Verify amounts and addresses before sending. We cannot reverse or recall on-chain transfers.

6) Cashback

Cashback may be earned on eligible purchases made with your TrueHold card (virtual or physical). Excluded categories do not earn cashback, including (non-exhaustive):

Financial & money services

4829, 6538, 6536, 6537, 6010, 6011, 6050, 6051, 6529, 6530, 6540, 6012, 8999, 6211, 6300, 6513, 6760, 6532, 6533

Gambling & betting

7995, 7800, 7801, 7802

Government & tax

9311, 9222, 9223, 9211, 9399, 9402, 9405, 9411

Utilities & essential services

4900, 9402

"Cash-like" transactions (e.g., money transfers, gift cards, currency exchange) are excluded. We may reverse cashback if a transaction is refunded, earned fraudulently, or violates these Terms. If we cannot recover an improperly credited amount, you remain responsible for repayment.

7) Your responsibilities

You must ensure:

  • Prices & amounts: the asset/fiat amounts match the quotes provided;
  • Wallet address: you control and correctly enter the recipient address;
  • Bank/card details: payout or funding details are correct.

We rely on the data you provide. Errors may result in loss of funds or assets. Blockchain data (including your public addresses) is permanent and publicly viewable.

Third-party providers (exchanges, payment processors, wallet providers) may be used for parts of the Services. We are not responsible for their delays, errors, limits, or outages. Their terms apply.

8) Trading & settlement specifics

Most trades settle via blockchain and third-party fiat payment rails. We may set minimums/maximums and frequency limits. Once placed and submitted, trades are final and non-refundable, subject to applicable law. After delivery of crypto to your wallet or fiat to your account, our obligation is fulfilled.

You are solely responsible for safeguarding private keys and recovery phrases. We cannot recover lost keys or funds and do not issue refunds for user error, fraud, or third-party failures.

9) Risk disclosure

By using the Services, you acknowledge risks including, but not limited to:

  • Market/financial risk: extreme volatility; potential total loss; liquidity constraints.
  • Protocol/technical risk: bugs, forks, upgrades, exploits, network congestion; interacting with third-party smart contracts at your own risk.
  • Security responsibilities: loss of keys/passwords is irreversible; protect your devices/accounts from malware and social engineering.
  • Finality & fraud: on-chain transactions are irreversible; scams and phishing exist.
  • Regulatory/issuer risk: evolving rules; certain assets may lack regulatory approvals; Services may be restricted.
  • Tax risk: you are responsible for understanding and paying all applicable taxes. TrueHold does not provide tax advice.

10) Your commitments

You represent and warrant that you: (i) meet eligibility criteria; (ii) provide accurate information; (iii) comply with all applicable laws; and (iv) will not use the Services for unlawful purposes.

You agree not to:

  • Use the Services for illegal, harmful, or fraudulent activity;
  • Upload malware or attempt to interfere with the Services;
  • Infringe third-party intellectual property;
  • Reverse engineer, copy, automate, or resell the Services;
  • Use another person's identity or email;
  • Exchange digital assets that are regulated securities or derivatives.

If you suspect unauthorized access, notify hello@truehold.xyz immediately.

11) Fees, chargebacks, taxes

  • Transparency: All fees are disclosed before you confirm a buy/sell/swap/payment.
  • Chargebacks: We may recover losses resulting from chargebacks, including scheme fees and crypto value, where applicable.
  • Taxes: You are responsible for all tax obligations related to your activity.

12) Suspension & termination

These Terms apply while you use the Services. We may suspend or terminate access immediately, including where you: (i) no longer meet eligibility; (ii) violate these Terms; (iii) fail to pay fees; or (iv) where required by law or a competent authority. We may decline, cancel, or reverse transactions at our discretion, subject to law. If you initiated a trade before suspension/termination, we will return corresponding fiat or digital assets unless prohibited by law. Terms intended to survive termination do so (e.g., indemnities, disclaimers, governing law).

13) Intellectual property

TrueHold (and its licensors) own all rights in the Services, including content, branding, logos, and card designs. You may not copy, modify, reverse engineer, or create derivative works except as permitted by these Terms.

14) Data protection & confidentiality

Each party will protect the other's confidential information and use it only to perform under these Terms. Confidential information may be shared with employees/agents/advisors on a need-to-know basis under equivalent confidentiality obligations. On request, destroy or securely erase confidential information (subject to legal retention requirements).

We process personal data in accordance with applicable data protection laws to provide the Services. See our Privacy Policy for details.

15) Disclaimers; limitation of liability; indemnity

Disclaimer

The Services are provided "as is" and "as available" without warranties of any kind, express or implied, including merchantability, fitness for a particular purpose, non-infringement, or uninterrupted/secure operation. We do not warrant accuracy, completeness, or timeliness of content or data.

Limitation

To the maximum extent permitted by law, TrueHold and its Affiliates, officers, directors, employees, agents, service providers, and contractors are not liable for indirect, incidental, special, consequential, exemplary, or punitive damages; loss of profits, data, business, goodwill; or intangible losses arising from or related to the Services or these Terms, whether based in contract, tort, negligence, strict liability, or otherwise. Our aggregate liability is limited to the total fees you paid to TrueHold in the 12 months preceding the claim. Nothing excludes liability that cannot be excluded by law.

Indemnity

You agree to indemnify and hold harmless TrueHold and its Affiliates, officers, directors, employees, and agents from claims, losses, damages, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of your use of the Services, your breach of these Terms, violation of law, or infringement of third-party rights.

16) Other provisions

  • No third-party rights. These Terms are between you and us.
  • No waiver. A delay or failure to enforce is not a waiver.
  • Severability. If any provision is unenforceable, the remainder remains in effect.
  • Entire agreement. These Terms constitute the entire agreement regarding the Services and supersede prior understandings.
  • Governing law; jurisdiction. These Terms are governed by applicable laws. Courts have exclusive jurisdiction, except where local law provides otherwise.

Partner & scheme disclosures

  • Issuance: Cards and e-money services are provided by licensed partners, authorized electronic money institutions, under Visa/Mastercard rules. Electronic money products are not bank deposits and may not be covered by deposit guarantee schemes. Funds held by partners are safeguarded in accordance with applicable regulations.
  • Third-party terms: Some Services involve third-party providers. Their terms, fees, and policies apply where relevant.