Liminal - Terms of Service

Plain-English note: if you are using the Liminal app, you are agreeing to these Terms. We've included a short explanation at the start of each section to make things clearer, but those explanations aren't legally binding - the full text of each section is what counts.

Early-stage software: Liminal is a new product under active development. Features will change, and occasional bugs or interruptions are possible. Section 12 explains what this means for you.

1. Who We Are

We're Liminal. Our company is incorporated in England and Wales as Liminal Finance Ltd, company registration number 16556039, with its registered office at 41 Pitfield Street, London, N1 6DA, United Kingdom. When we refer to ourselves in these Terms, we use "we", "us", "Liminal" or "our".

Liminal Finance Ltd is a technology company. We are not authorised or regulated by the Financial Conduct Authority or any other financial regulator, and your funds are not protected by the Financial Services Compensation Scheme (FSCS) or any similar deposit-protection or investor-compensation scheme.

2. What Liminal Is (and Isn't)

We build software. Your funds sit in a wallet you control; the app is the interface you use to control it.

The Liminal app is a software interface that lets you interact with blockchain technology, smart contracts, and third-party services. Liminal never holds your funds. When you top up, stablecoins are delivered to a self-custodial smart contract wallet on the Base network that you - and only you - control through keys managed via our wallet infrastructure provider.

Here's what we do:

• Provide a software interface (the app) for you to use
• Provide Nim, an AI assistant that helps you use the app and carries out your instructions (see Section 3)
• Display information from third-party wallet, conversion, and on/off-ramp services so you can use them
• Let you interact directly with smart contracts and open protocols on public blockchains

Here's what we don't do:

• We are not a bank, credit institution, or deposit-taker
• We are not an e-money institution and do not issue e-money
• We are not a payment institution and do not provide payment services or money transmission
• We do not custody, hold, store, pool, or control your money, stablecoins, or other assets, and we cannot unilaterally access, move, freeze, or apply your funds
• We do not process or execute payments or transactions ourselves - transactions are executed by smart contracts on public blockchain networks, on your instruction
• We do not provide financial, investment, legal, or tax advice, and we do not make personal recommendations
• We do not manage your assets on a discretionary basis

Think of us as the front door to blockchain technology: we build the interface that makes it easy to use, but your funds stay under your control at all times and the underlying services are provided by the blockchain networks, protocols, and third-party providers described below.

3. Nim - Your AI Assistant

Nim is software that acts on your instructions. It never acts on its own, and nothing it says is financial advice.

Nim is an AI assistant built into the app. Nim can help you understand your account, answer questions, and prepare and carry out actions in the app - for example a transfer, a currency conversion, or setting up a rule you've asked for.

How Nim works:

• Nim only acts on your instructions. It carries out actions when you tell it to, or under rules that you have set up in advance and can view, change, or cancel at any time.
• Nim does not act autonomously and does not exercise discretion. It does not decide for you what to do with your funds, and it has no authority to act other than as you have instructed.
• Every action Nim carries out is executed from your own self-custodial wallet, under your control. Nim has no wallet, funds, or authority of its own.
• Nim's outputs are information, not advice. Anything Nim tells you - including summaries, explanations, and answers to your questions - is general information generated by an AI model. It is not financial, investment, legal, or tax advice, and it is not a personal recommendation to buy, sell, hold, convert, or do anything else.
• AI makes mistakes. Nim can be wrong, incomplete, or out of date. Always verify important details - especially amounts, currencies, and recipient details - before confirming any action.

You are responsible for every instruction you give Nim and every rule you set. If you set a rule (for example, "convert my balance when the rate reaches X"), you are instructing us in advance, and the resulting actions are treated as authorised by you.

4. Third-Party Services

The app is built on services provided by other companies. Each has its own terms.

Our app lets you use services provided by other companies. These include, without limitation:

• Privy: provides wallet infrastructure services, including account creation, key management, and recovery.
• Bridge (a Stripe company): provides stablecoin on-ramp and off-ramp services, including virtual account details (such as virtual IBANs) that let you move between fiat currency and stablecoins.
• Fern (a Rain company): provides currency conversion services between supported currencies and stablecoins.
• Blockchain networks and protocols: the underlying technology on which transactions are executed, including the Base network and open lending protocols such as Morpho (see Section 8).
• Anthropic: the chat functionality in the app is powered by Anthropic's Claude models.

We reserve the right to change providers at any time, in our continuing effort to find the best solutions to provide you with the best experience.

Important: these third parties have their own terms of service and privacy policies. By using our app, you're also agreeing to their terms, which set out their responsibilities for the services they provide. Where a service requires identity verification (KYC), you will be asked to complete identity verification, which we run through our verification provider to meet the compliance standards of the third-party services you use, and that verification is subject to final approval by the relevant provider under its own terms.

5. Your Wallet and Custody

You own and control your funds. We don't hold them - which also means we can't recover them for you if you lose access.

When you create a wallet through the app:

• Your funds are held in a self-custodial smart contract wallet on the blockchain that you control. Funds are never pooled with other users' funds or with ours.
• You're responsible for your account and wallet security and your access credentials.
• We cannot access, move, freeze, or apply your funds, and we cannot reverse, cancel, or refund transactions once they're on the blockchain.
• If you lose access to your credentials and any recovery methods, your funds may be permanently unrecoverable. We cannot restore access for you.

6. Blockchain Transactions

Transactions happen directly on the blockchain. They're permanent and irreversible.

When you send or receive stablecoins or other assets using the app:

• Transactions are executed directly on the blockchain through smart contracts, on your instruction (whether given directly or through Nim under Section 3).
• We don't process, hold, or control these transactions.
• Blockchain transactions are permanent and irreversible.
• You're responsible for ensuring transaction details are correct before you confirm.
• Network fees (including gas fees) and conversion fees apply and are paid to the relevant blockchain network or service provider (see Section 13).
• Transaction times depend on the blockchain network, not on us.

7. Moving Between Fiat and Stablecoins; Currency Conversion

On/off-ramp and conversion services are provided by third parties. You'll need to complete identity verification to use them.

When you convert between fiat currency and stablecoins, or between currencies:

• These services are provided by third-party providers (currently Bridge and Fern), not by us.
• You will be required to complete a know-your-customer (KYC) process with the relevant provider in order to use these services.
• The provider's terms, fees, exchange rates, and limits apply.
• We don't control availability, exchange rates, or transaction approval times.
• Stablecoins are not legal tender and are not issued or backed by us. A stablecoin's value depends on its issuer and reserves, which we do not control.

8. On-Chain Lending and Yield

If you choose to earn yield, your funds are deployed into open lending protocols. This is not a savings account and it is not risk-free.

The app may let you deploy stablecoins from your wallet into open, non-custodial lending protocols (such as Morpho on the Base network) to earn yield. If you choose to do this:

• You are interacting directly with the protocol from your own wallet. We do not take custody of your funds, we are not your counterparty, and we do not operate the protocol.
• This is not a savings account or a deposit. Your funds are not protected by the FSCS or any deposit-guarantee scheme.
• Rates are variable and set by the protocol based on supply and demand. Past rates are not a guarantee of future rates.
• Protocols carry risk, including smart contract bugs and exploits, oracle failures, and insufficient liquidity. In adverse conditions you may be unable to withdraw immediately, and you can lose some or all of the funds you deploy.
• Choosing to deploy funds, and choosing when to withdraw, is your decision. Nim will only deploy or withdraw funds on your instruction or under rules you have set.

9. Who Can Use This App

You must be 18+ and legally allowed to use stablecoins where you live.

You can use this app if:

• You're at least 18 years old
• You're legally allowed to use stablecoins and the app's other features in your jurisdiction
• You're not on any sanctions list or otherwise restricted from using this technology
• You're not in a country or region where we don't offer the app or where offering it would be unlawful
• You haven't previously been suspended or banned from the app

By agreeing to these Terms, you're confirming all of the above is true.

Supported locations: the app and individual features are available only in the jurisdictions we support from time to time. We may add, restrict, or withdraw availability in any jurisdiction at our discretion, including where required by law or by our third-party providers.

10. Your Responsibilities

You're responsible for your account, your instructions, and following the law.

You agree to:

• Provide accurate and truthful information
• Keep your login credentials and wallet access secure
• Understand the risks of blockchain technology before using the app
• Verify all transaction details before confirming, including anything prepared by Nim
• Review any rules you set for Nim and keep them up to date
• Comply with all applicable laws in your jurisdiction, including tax obligations arising from your transactions
• Report any bugs or security issues to us promptly
• Not use the app for illegal activities
• Not attempt to hack, exploit, abuse, or interfere with the app or manipulate Nim to act outside these Terms
• Not use the app in an unsupported or restricted location

11. Risks You Need to Understand

Blockchain technology comes with real risks. Please read this section carefully.

• Irreversibility: blockchain transactions cannot be undone.
• Technology risk: smart contracts and blockchain technology can have bugs, vulnerabilities, and exploits.
• Network risk: transactions might be delayed or fail when networks are congested.
• Stablecoin risk: a stablecoin may fail to hold its intended value if its issuer or reserves fail.
• Protocol risk: lending protocols carry the risks described in Section 8, including loss of funds.
• AI risk: Nim is an AI system and can produce incorrect or incomplete outputs.
• Regulatory risk: laws applying to stablecoins and cryptoassets are still evolving and may change in ways that affect the app or your funds.
• Loss of access: if you lose your credentials and recovery methods, your funds may be unrecoverable.

Your funds are not protected by the FSCS. Liminal is not authorised or regulated by the FCA. If something goes wrong, you will not be able to claim compensation from the FSCS and you will not have access to the Financial Ombudsman Service. By using this app, you acknowledge and accept these risks.

12. Early-Stage Software

Liminal is new and under active development. Expect change.

Liminal is an early-stage product. This means:

• Features may be added, changed, or removed as the product develops
• Bugs and errors may occur despite our efforts
• The app might be temporarily unavailable, including for maintenance and upgrades
• Performance may vary

We work to keep the app reliable, and because your funds sit in a self-custodial wallet, an outage of our app does not mean loss of your funds (see Section 18). Please report any issues you encounter so we can fix them.

13. Fees

Fees vary by feature and change from time to time. You'll always see the exact fee in the app before you confirm - and nothing is charged without you confirming it first.

How fees work: fees may apply when you use certain features of the app, and may include fees charged by us and fees charged by third-party service providers and blockchain networks. Fees vary depending on the feature, the currencies or assets involved, and the route used, and they may change from time to time.

Point-of-transaction disclosure: before you confirm any action that carries a fee, the app will show you the applicable fee (or, where a fee cannot be fixed in advance - such as blockchain network fees - a good-faith estimate). By confirming the action, you agree to the fee shown. If you don't agree with a fee, simply don't confirm the action - you will not be charged.

No retroactive changes: a change in fees only applies to actions you take after the change. It never applies to transactions you have already confirmed.

Recurring fees: we don't currently charge any subscription or recurring fees. If we introduce one in the future, we'll notify you in advance through the app or by email, and you'll be able to close your account under Section 16 before it applies to you.

Third-party and network fees: blockchain network fees (gas) are set by the relevant network, and third-party provider fees are set by the relevant provider under their own terms. These are incurred at the time of the transaction and are not refundable by us. Nothing in this section affects your statutory rights.

14. No Financial Advice

Nothing in the app - including anything Nim says - is financial advice or a personal recommendation.

Nothing in this app constitutes financial, investment, legal, or tax advice. We do not recommend any particular stablecoin, transaction, protocol, or strategy. Information displayed in the app - including balances, rates, yields, and anything generated by Nim - is provided for your information only, so that you can make your own decisions.

If you're unsure whether something is right for you, consult a qualified professional before making financial decisions.

15. Privacy

Our Privacy Notice explains what data we collect and how we use it.

We handle your personal data in accordance with our Privacy Notice. The Privacy Notice explains what we collect, why, who we share it with, how long we keep it, and your rights under UK GDPR, including how to contact us and how to complain to the Information Commissioner's Office.

Our third-party providers (including Privy, Bridge, and Fern) collect and process data under their own privacy policies, including for identity verification. We recommend reviewing their policies. Please note that your public wallet address and your on-chain transactions are visible on the public blockchain by design.

16. Suspension and Termination

We can suspend or close your account for the reasons below. Because your wallet is self-custodial, closing your account doesn't take your funds away from you.

We can suspend or close your account if:

• You violate these Terms
• We suspect illegal activity or fraud
• We're required to by law or regulation, or by a third-party provider whose services are necessary to operate the app
• Your account poses a security risk
• You provide false or misleading information
• You create multiple accounts or abuse our systems

We'll give you notice where reasonably possible, but we may act immediately where necessary to protect ourselves, other users, or to comply with the law. Because your funds are in a self-custodial wallet, suspension or closure of your account restricts your use of our interface; it does not transfer your funds to us. Where lawful, we will provide reasonable assistance to help you retrieve access to your wallet through our wallet infrastructure provider.

You can close your account at any time by transferring your funds out and contacting us.

17. Changes to These Terms

We can update these Terms. We'll tell you about significant changes before they take effect.

We may update these Terms from time to time. If we make significant changes, we'll notify you in advance through the app or by email, and the updated Terms will apply from the date we specify. If you continue using the app after that date, you're agreeing to the updated Terms. If you don't agree, you should stop using the app and may close your account under Section 16.

18. Changes to the App

We can change or discontinue the app or features. Your funds stay yours either way.

We reserve the right to modify, suspend, or discontinue the app or any features at any time. Where a change materially reduces the app's functionality, or where we discontinue the app, we'll give you reasonable advance notice where possible so you can make arrangements.

Because your funds are always held in a self-custodial wallet, so long as your login credentials and recovery methods are safe and in your control, you will be able to access your funds - including through means other than our app - even if the app is unavailable or discontinued.

19. Intellectual Property

We own the app. You get a licence to use it, not to copy it.

We own all rights to the app's design, code, branding, and content. You're granted a limited, personal, non-exclusive, non-transferable licence to use the app in accordance with these Terms. You can't:

• Copy, modify, or reverse engineer any part of the app, except to the extent permitted by law
• Redistribute or resell the app
• Remove any copyright or proprietary notices
• Use our branding or trademarks to pretend to be us or to suggest we endorse you

20. Our Liability

We're responsible for our software when we're at fault. We're not responsible for the blockchain, third-party services, or your own decisions - and there are some legal rights we can never take away from you.

What we don't limit: nothing in these Terms excludes or limits our liability for (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; or (c) any other liability that cannot be excluded or limited under applicable law. If you are a consumer, nothing in these Terms affects your statutory rights, including under the Consumer Rights Act 2015 - in particular your right to receive a digital service provided with reasonable care and skill.

What we're not responsible for: to the maximum extent permitted by law, we are not liable for loss or damage arising from:

• The performance, failure, acts, or omissions of third-party services, blockchain networks, or protocols, including stablecoin issuers, wallet infrastructure, on/off-ramp and conversion providers, and lending protocols
• Smart contract bugs, exploits, or vulnerabilities in third-party or open-source code
• Price volatility, market movements, variable yield rates, or the value of any stablecoin or asset
• Blockchain network fees, congestion, delays, or failed transactions
• Transaction details you provide or confirm incorrectly, instructions you give (including to Nim), or rules you set
• Loss of your credentials, private keys, or recovery methods, or unauthorised access resulting from your failure to keep them secure
• Hacks, phishing, or social engineering attacks by third parties
• Changes in law or regulatory action
• Events beyond our reasonable control (force majeure), including natural disasters, war, terrorism, civil unrest, pandemics, strikes, and failures of internet or blockchain infrastructure

Kinds of loss we exclude: to the maximum extent permitted by law, we are not liable for loss of profits, revenue, business, or anticipated savings, loss of data, goodwill or reputation, or for indirect or consequential loss. If you are a consumer, we are responsible for loss you suffer that is a foreseeable result of our breaking these Terms or failing to use reasonable care and skill, but we are not responsible for loss that is not foreseeable, and we are not liable for business losses if you use the app for commercial purposes.

Liability cap: subject to "What we don't limit" above, our total aggregate liability to you arising out of or relating to these Terms or your use of the app, whether in contract, tort (including negligence), or otherwise, is limited to the greater of (a) £100 and (b) the total fees you have paid to us in the 12 months preceding the claim.

No warranties beyond these Terms: except as expressly set out in these Terms and as required by law, the app is provided "as is" and "as available", and we exclude all implied warranties, conditions, and terms to the fullest extent permitted by law. These Terms do not create any fiduciary duties between you and us.

21. Disputes and Governing Law

English law applies. Disputes go to the courts of England and will be in English.

These Terms, and any dispute or claim arising out of or in connection with them or their subject matter (including non-contractual disputes or claims), are governed by the laws of England and Wales.

The courts of England and Wales shall have exclusive jurisdiction over any dispute arising out of or in connection with these Terms. Proceedings shall be carried out in the English language.

Before starting any formal proceedings, please contact us first (Section 22) - most issues can be resolved quickly and informally.

If any part of these Terms is found to be invalid or unenforceable, the rest still applies.

22. Contact and Complaints

Talk to us - we'd rather fix a problem than argue about it.

If you have a complaint, email us with "Complaint" in the subject line and a description of the issue. We'll acknowledge your complaint promptly and aim to resolve it within a reasonable time, keeping you informed along the way.

23. The Bottom Line

The short version of everything above.

We build a user-friendly interface - including Nim, your AI assistant - for you to use blockchain technology, smart contracts, and stablecoins. Your funds sit in a self-custodial wallet that only you control. The underlying services are provided by blockchain networks, open protocols, and third-party providers. We don't hold your money, we don't provide financial services or advice, and we're not a bank - we're the technology layer that makes it all work together.

Blockchain technology has risks. Transactions are irreversible. Your funds aren't covered by the FSCS. Nim acts only on your instructions and can make mistakes, so always check before you confirm. Please use the app carefully and at your own risk.

We're excited to build this with you. Thanks for being part of Liminal.