HedgePay App User Agreement

1. Parties and acceptance

1.1 This agreement is between you and Nabla Finance OÜ, a private limited company registered in Estonia under registry code 17287187, VAT number EE103017547, with its registered office at Pikk 7, Tallinn 10123, Estonia (“HedgePay”, “we”, “us”). Contact: contact+privacy@hedgepay.app.

1.2 This agreement governs your use of the HedgePay mobile application (the “App”). It is the separate user agreement referred to in the Terms of Use of the hedgepay.app website. The website terms govern the website; this agreement governs the App.

1.3 The App presents this agreement before you first use it. By accepting it in the App, or by using the App after it has been presented to you, you agree to it. The App records the version you accepted. If a new version requires acceptance, the App will present it again before you continue.

1.4 If you do not agree, do not use the App.

2. Definitions

“Account” means your HedgePay user record: your sign-in identity, username and profile, and the link to your Wallet.

“Wallet” means the Stellar network account created for you through our wallet infrastructure provider when you first sign in, and the software access to it that the App provides.

“Digital Dollars” and “Digital Euros” mean the stablecoins USDC and EURC, digital tokens that aim to hold a value of one US dollar or one euro each, issued by Circle Internet Financial, LLC and, in the European Union, by Circle Internet Financial Europe SAS, both subsidiaries of Circle Internet Group, Inc. HedgePay does not issue them and does not guarantee their value.

“Stellar Network” means the public Stellar blockchain on which your Wallet and all transfers exist.

“Wallet Infrastructure Provider” means the third-party provider of authentication and embedded wallet infrastructure used by the App.

“Ramp Provider” means a third party that converts between local currency and Digital Dollars or Digital Euros. The App’s Ramp Provider is Bridge (section 9).

“Earn” means the App feature that places Digital Dollars into third-party on-chain vaults operated by DeFindex (section 10).

“Beta capability” means a feature described in this agreement that is designed but not yet available to you in the App.

3. What HedgePay is and is not

3.1 HedgePay is software. It gives you an interface to a wallet on the Stellar Network, to Ramp Providers and to on-chain services.

3.2 Nabla Finance OÜ is not a bank, payment institution, electronic money institution, deposit-taker, broker or investment adviser, and is not supervised as one. Balances shown in the App are not bank deposits and are not covered by any deposit guarantee or investor compensation scheme in any country.

3.3 Nothing in the App is investment, legal or tax advice.

4. Eligibility

4.1 You must be at least 18 years old to use the App.

4.2 One Account per person. You may not create or use an Account for someone else, and you may not let someone else use yours.

4.3 The App is offered in stages, by country, during its beta. Access to conversion between local currency and Digital Dollars depends on the Ramp Provider supporting your country and completing its checks (section 9). We may decline, limit or stage access at our discretion.

5. Account, identity and verification

5.1 You sign in with your email address and a one-time code sent to that address. Authentication is performed by our wallet infrastructure provider. HedgePay receives a verified confirmation of your email and an identifier; it does not receive or store your sign-in code.

5.2 To finish creating your Account you choose a username and select a purpose of use. HedgePay does not ask for your legal name or your country at sign-up.

5.3 Identity verification (KYC) is required only to use a Ramp Provider, and it is carried out by Bridge, not by HedgePay. When you start verification the App sends your name and email address to Bridge to open the process; every other element — identity document, photo, date of birth, address, phone number, tax identification number — is provided by you directly to Bridge in its own verification flow inside the App. A short questionnaire (purpose of the account, employment, source of funds, occupation, expected volumes, nationality, place of birth) is completed in the App and forwarded to Bridge. Bridge decides the outcome. HedgePay stores the verification status and, once verified, the name Bridge verified.

5.4 You must give accurate information and keep it current.

6. Your Wallet and keys

6.1 Your Wallet is self-custodial. It is an account on the Stellar Network created for you through our wallet infrastructure provider’s embedded wallet when you first sign in. Your balance is recorded on the Stellar Network, not on HedgePay’s systems.

6.2 Only you control your Wallet. Transactions are signed only under your authenticated session and only when you instruct them in the App. HedgePay does not hold your signing key or any part of it. HedgePay cannot sign transactions for your Wallet, cannot freeze your funds, and cannot move or access them.

6.3 Where HedgePay’s servers help process a transaction (section 11), they can only submit a transaction that already carries an authorisation created under your session; they reject anything else.

6.4 Your ability to transact through the App depends on the availability of our wallet infrastructure provider’s service and of the Stellar Network.

6.5 Self-custody is a statement about who controls the funds, not a statement that funds are safe from every risk. Software defects, phishing, a compromised device or email account, and network failures can all cause loss.

6.6 Key export. You will be able to export your Wallet’s secret key from the App (beta capability). Until it is available, signing requires the App and its wallet infrastructure.

7. Access and recovery

7.1 Recovery uses your email address. There is no password: your email address, and the one-time codes sent to it, are your means of access to your Account and Wallet. Only you can access your account.

7.2 If you lose or replace your device, install the App on another device and sign in with your email address. Your Wallet reattaches to your Account.

7.3 If you lose control of your email account, you cannot sign in. HedgePay cannot verify you by other means and cannot restore access. If you permanently lose that email account, you lose access to your Wallet and the funds in it.

7.4 Anyone who controls your email inbox can request a sign-in code. Protect that inbox: use a strong password and two-factor authentication with your email provider, and do not share access to it.

7.5 On a device where you are signed in, the App reopens without asking for a code. Anyone who can unlock your device can open the App. Protect your device with a screen lock. An in-App unlock (biometrics or PIN) before showing balances or confirming transactions is a beta capability and will be added.

8. Sending, receiving and requesting money

8.1 You can send Digital Dollars and Digital Euros to another HedgePay user by username, or to any Stellar address. You can receive by sharing your address or a request. You can request money from another user; a request is a notification only and moves no funds until the other user chooses to pay it.

8.2 Before you pay a username, the App checks the recipient. Searching shows usernames, not names. The App confirms the recipient’s name against the name verified by their identity check and tells you only whether it matches; it does not reveal the name. If no verified name exists, the App tells you the check is unavailable. The decision to send is yours.

8.3 Transfers on the Stellar Network are final. They cannot be reversed, by you or by HedgePay. If you send to a wrong address or to the wrong person, the funds are gone unless the recipient returns them voluntarily. Check every address and every confirmation screen before you confirm.

8.4 Network availability, fees and congestion on the Stellar Network are outside HedgePay’s control.

9. Adding and withdrawing money (Ramp Providers)

9.1 Conversion between local currency and Digital Dollars or Digital Euros is performed by Bridge, not by HedgePay. Depending on where you live you contract with one of the following Bridge entities, whose terms of service you must accept before using a ramp and which are incorporated into your relationship with Bridge by this reference: for residents of the United States, Bridge Building Inc; for residents of the European Economic Area, Bridge Building S.A. (Luxembourg, CASP registration N00000012, EMI registration W00000024); for everyone else, Bridge Building Limited. Bridge’s terms and regional policies are published at https://www.bridge.xyz/legal/overview.

9.2 While funds are with Bridge or its banking partners — from the moment you send local currency until Digital Dollars arrive in your Wallet, and from the moment you send Digital Dollars for withdrawal until your bank or payment account is credited — those funds are governed by Bridge’s terms, not by this agreement.

9.3 Deposits. Once verified and approved by Bridge for the relevant capability, you can receive deposit coordinates that convert incoming local currency to Digital Dollars delivered to your Wallet: a Pix code (Brazilian reais), a euro IBAN (SEPA), or a US account and routing number (US dollars). Receiving via Pix additionally requires a Brazilian CPF tax number verified with Bridge; without it, Pix deposits are not available to you.

9.4 Withdrawals. You can save withdrawal destinations — a Pix key, an IBAN, or a US bank account — and send Digital Dollars or Digital Euros to them for payout in local currency by Bridge.

9.5 Bridge may decline or delay a transfer, apply its own checks, apply an exchange rate and charge its own fees. Availability differs by country and can be withdrawn. Exchange rates shown in the App before you create a withdrawal are indicative; the rate and any Bridge fee applied are stated in the transfer details.

9.6 HedgePay adds no fee of its own to deposits or withdrawals (section 11).

10. Earn

10.1 Earn places Digital Dollars from your Wallet into an on-chain vault operated by DeFindex, a third party. Entering and leaving Earn are Stellar transactions authorised under your session, like any other transfer. You can request withdrawal at any time; execution depends on the Stellar Network and the vault.

10.2 The yield is variable. It comes from third-party on-chain markets that HedgePay does not control. The rate shown in the App is a live figure supplied by DeFindex, based on recent vault performance. It changes continuously, is not a promise, and can fall to zero.

10.3 Your principal is at risk. If the underlying vault or the protocols it uses fail or are exploited, you can lose some or all of the amount placed in Earn. Only allocate what you can afford to lose.

10.4 HedgePay takes no share of Earn yield and charges no fee for entering or leaving Earn. Fees applied inside the third-party vault, if any, are set by DeFindex and are reflected in the rate.

10.5 A Digital Euro Earn vault is a beta capability: it is shown in the App as coming soon and is not available.

11. Fees

11.1 Every Stellar transaction carries a network fee set by the Stellar Network, not by HedgePay.

11.2 Sponsored transactions. By default, and always for assets without a supported contract, the network fee of your transactions is paid by the wallet infrastructure at no charge to you.

11.3 Fee paid from the asset moved. If you choose to pay the network fee yourself instead, for supported operations — sending, exchanging and Earn — the App charges the network fee from the asset you are moving. In that case you pay the Stellar network fee plus a service margin of twenty per cent of that network fee, converted into the asset moved at the market rate. Stellar network fees are typically a fraction of a cent, and so is the margin. To absorb rate movement between quote and execution, the transaction authorises a buffer of up to forty per cent above the quoted amount as a maximum; only what the conversion actually requires is spent, and the unused buffer is not collected. The margin is HedgePay’s charge for fronting the network fee.

11.4 For sending, exchanging and Earn, the exact fee is shown on the confirmation screen before you confirm, and the amount submitted is the amount shown. Where the fee is sponsored, the confirmation screen says so.

11.5 Exchanging between assets in the App uses the Stellar decentralised exchange. HedgePay applies no spread and takes no part of the exchanged amount. A slippage limit protects the minimum you receive; it is a floor, not a fee.

11.6 Ramp fees and exchange rates are Bridge’s (section 9.5). HedgePay adds none.

11.7 HedgePay charges no other fees: no percentage of amounts sent or received, no account or subscription fee, and no share of yield. If this changes, this agreement will be updated and re-presented before any new fee applies.

12. Prohibited use and sanctions

12.1 You may not use the App: for anything unlawful; to launder money or finance terrorism; to evade sanctions; to defraud anyone; to hold or move funds for a third party; or to interfere with the App’s or its providers’ systems.

12.2 Identity checks, sanctions and related screening for the fiat leg are performed by Bridge under its own obligations. Bridge may decline, restrict or exit users and countries under its terms and its prohibited-jurisdictions policy. HedgePay may act on Bridge’s determinations.

12.3 We may suspend Account services (section 13) if we reasonably believe this section is breached or if the law requires us to.

13. Suspension and termination

13.1 You can stop using the App at any time. Your funds are on the Stellar Network; deleting the App does not move or remove them.

13.2 We may suspend or terminate the services we run — the Account, relaying, ramps access through our integration, Earn access, notifications — for breach of this agreement, where the law requires it, or on ending the beta or the service. Where lawful, we will give you reasonable advance notice.

13.3 What we can and cannot do is set by the design in section 6: we can close your Account and stop providing services; we cannot freeze, seize or move your funds, and terminating this agreement does not affect your Wallet’s existence on the Stellar Network. If we terminate the service, we will, where lawful and to the extent within our control, keep the App’s send and withdrawal functions available to you for at least 30 days so that you can move your funds to another Stellar account or withdraw them.

13.4 Until key export (section 6.6) is available, access to your Wallet after our service ends depends on the App and its wallet infrastructure. Move your funds while the service is available rather than relying on later access.

14. Beta status and changes to the service

14.1 The App is beta software. Features may change, be withdrawn or fail. Defects may exist. Do not hold more through the App than you are prepared to lose while the software matures.

14.2 We may change the App and its features. The App may require you to install an updated version from the app store before you can continue using it.

14.3 We do not guarantee continuity of the App, of any feature, of any Ramp Provider, of Earn or of our wallet infrastructure provider’s services.

15. Risks

15.1 Read the Risk Disclosure published at hedgepay.app/legal/risk. It forms part of this agreement. In summary: Digital Dollars and Digital Euros are stablecoins whose value depends on their issuer and the market; balances are not deposits and carry no guarantee scheme; blockchain transfers are final; yield is variable and principal is at risk; conversion to and from local currency depends on third parties; software and beta risks exist.

15.2 Nothing in this section or this agreement reduces what the Risk Disclosure states.

16. Taxes

Holding, receiving, converting or earning on Digital Dollars and Digital Euros may have tax or reporting consequences in your country. You are responsible for them. HedgePay does not provide tax advice and does not withhold or report on your behalf unless the law requires it.

17. Liability

17.1 The App is provided as is. To the extent permitted by law, we exclude all warranties about its availability, accuracy and fitness for your purposes.

17.2 To the extent permitted by law, we are not liable for: loss caused by the Stellar Network, our wallet infrastructure provider, Bridge, DeFindex or any other third party; loss of access caused by your loss of your email account or device; transfers you authorised, including to wrong addresses; variations in yield or loss of principal in Earn; or indirect or consequential loss.

17.3 To the extent permitted by law, our total liability under this agreement is limited to the higher of the fees you paid us under section 11.3 in the twelve months before the event and one hundred euros.

17.4 Nothing in this agreement excludes or limits liability that cannot be excluded or limited under applicable law, including liability for intent or gross negligence under Estonian law and your rights under the mandatory consumer-protection laws of the country where you live.

18. Indemnity

To the extent permitted by the law of your country of residence, you will compensate us for losses, costs and third-party claims caused by your breach of this agreement or your unlawful use of the App. This does not apply to the extent the loss was caused by us.

19. Country-specific disclosures

Bolivia. Virtual-asset services in Bolivia are provided through channels authorised by ASFI. Digital dollars are not legal tender in Bolivia and are held at your own risk.

Argentina. Conversion between pesos and digital dollars is performed by a virtual-asset service provider registered with the CNV. Digital assets are not legal tender in Argentina, are not covered by the capital-markets law, and their offering documents are not reviewed by the CNV. Holdings may be subject to the personal-assets tax (Bienes Personales).

Brazil. Receiving digital dollars from abroad into your own wallet, and converting between reais and digital dollars, is a foreign-exchange operation under Central Bank rules; IOF and other taxes may apply and are shown before you confirm. Allocations abroad may require declaration to the Central Bank above legal thresholds. Depositing reais via Pix is available to Brazilian residents with a CPF; non-residents can withdraw to Pix but not deposit.

Colombia. Conversion between pesos and digital dollars is performed by a third-party provider without a foreign-exchange intermediary. Digital assets are not legal tender in Colombia. Reporting obligations to DIAN may apply above legal thresholds.

El Salvador. Digital-asset services in El Salvador are provided through providers registered with the CNAD.

20. Changes to this agreement

We may change this agreement. The version and date at the top identify the current text. If a change is material, the App will present the new version and ask you to accept it before you continue; for other changes the App will show the updated version. If you do not accept a new version, stop using the App; section 13.3 applies to your funds.

21. Governing law, disputes and complaints

21.1 This agreement is governed by the laws of the Republic of Estonia.

21.2 Disputes will be brought before Harju County Court, Tallinn, Estonia. If you are a consumer, this does not remove protections you have under the mandatory laws of your country of residence, and you may also have the right to bring proceedings in your local courts.

21.3 Complaints: write to contact+privacy@hedgepay.app. We answer within a reasonable time and keep a record of the exchange. For matters concerning funds in transit with Bridge, we will tell you how to reach Bridge and assist where we can.

22. Contact

Nabla Finance OÜ, registry code 17287187, VAT EE103017547, Pikk 7, Tallinn 10123, Estonia. contact+privacy@hedgepay.app.