Introduction

Last updated: 27 February 2026

1. Definitions

For the purposes of these Terms:

"Cryptoasset" means any digital representation of value or rights that can be transferred and stored electronically using distributed ledger technology.

"Custody Services" means the safekeeping of Cryptoassets by Radom on behalf of the User using segregated blockchain addresses or omnibus wallets with internal ledger segregation.

"Fiat Services" means services provided by regulated third-party financial institutions, including payment institutions or electronic money institutions.

"Reverse Solicitation" means a situation where a User independently approaches Radom on its own exclusive initiative without any direct or indirect marketing, solicitation or promotion by Radom in the User’s jurisdiction.

"Sanctioned Jurisdiction" means any country or territory subject to comprehensive sanctions under EU law.

"U.S. Person" has the meaning ascribed under Regulation S of the United States Securities Act of 1933, as amended, and includes any "United States person" within the meaning of Section 7701(a)(30) of the United States Internal Revenue Code of 1986, as amended.

2. Contracting Entity

These Terms of Service (“Terms”) form a binding legal agreement between you (“you,” “your,” or “User”) and:

Radom Pay spółka z ograniczoną odpowiedzialnością
KRS: 0001079663
NIP: 5214051865
Registered office: ul. Żelazna 59A/4.5, 00-848 Warsaw, Poland
("Radom", "we", "our", or "us")

Radom is entered into the Polish Register of Virtual Asset Service Providers pursuant to the Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing.

Radom acts as the sole provider of all Services described in these Terms and is solely responsible for all regulated activities, including custody, transaction execution, compliance and AML decision-making.

Radom is not a bank, credit institution, payment institution, electronic money institution, investment firm or broker-dealer. Any services falling within such regulated activities are performed exclusively by duly authorised partners holding the relevant licences.

Radom Pay Limited
Radom Pay Limited (United Kingdom) acts solely as a technology development and intellectual property holding entity.

Radom Pay Limited:

  • • provides software development and IT support services to Radom
  • • licenses intellectual property to Radom
  • • does not provide Cryptoasset Services or financial services
  • • is not authorised or registered with the Financial Conduct Authority or any other financial regulator
  • • does not enter into contracts with Users
  • • does not perform onboarding, customer due diligence or transaction monitoring
  • • does not make compliance, AML or risk decisions
  • • does not control, access or manage User accounts
  • • does not hold, access or control private keys, custody systems or settlement infrastructure
  • • does not receive, hold or control any customer funds or Cryptoassets
  • • does not act as agent, representative, branch or introducer of Radom

All contractual relationships and regulated functions are conducted exclusively by Radom.

By accessing or using the Services, you agree to be bound by these Terms. If you do not agree, you must not use the Services.

3. Overview of Services

Radom Pay Sp. z o.o. provides cryptoasset-related infrastructure services, including:

  • • crypto and stablecoin deposit & payment processing
  • • mass crypto payouts
  • • fiat on-ramping and off-ramping (via regulated third-party providers)
  • • virtual IBAN access (via regulated third parties)
  • • cryptoasset custody services
  • • cryptoasset conversion functionality, including swap execution via third-party liquidity providers where applicable
  • • recurring billing and token-based access tools

Where fiat services are provided, regulated third-party providers may impose additional contractual terms.

Radom remains responsible for the cryptoasset components of the Services.

4. Execution Model and Conflicts of Interest

Where cryptoasset conversion, swap or execution functionality is made available, Radom may:

  • • act as principal; or
  • • arrange execution through third-party liquidity providers

Radom may receive fees, spreads or other economic benefits in connection with such execution services.

Radom does not provide investment advice, portfolio management or discretionary management services.

Radom maintains internal policies designed to identify and manage potential conflicts of interest.

5. Nature of the Agreement

These Terms constitute a framework agreement for the provision of cryptoasset infrastructure services.

The Services do not constitute:

  • • deposit-taking
  • • issuance of electronic money
  • • provision of payment accounts
  • • investment services
  • • fiduciary services
  • • banking services

No provision of the Services creates a trust, fiduciary, agency, partnership or joint venture relationship between Radom and the User.

6. Regulatory Status

Radom Pay sp. z o.o. is registered in the Polish Register of Virtual Asset Service Providers.

As a registered VASP, Radom is an obliged entity under Polish AML legislation and is legally required to:

  • • conduct identity verification and customer due diligence
  • • monitor transactions on an ongoing basis
  • • request additional information where necessary
  • • apply enhanced due diligence in higher-risk situations
  • • comply with EU sanctions and restrictive measures
  • • report certain transactions to competent authorities

Radom may suspend, delay, refuse or restrict access to the Services, including blocking Cryptoassets, where required by law.

Radom may be legally prohibited from disclosing the reasons for certain compliance measures.

Registration as a VASP does not constitute authorisation as a financial institution, payment institution, electronic money institution or investment firm.

Use of the Services may be subject to identity verification and transaction monitoring as required by law.

7. Custody and Segregation of Assets

Where Custody Services are provided:

  1. Title to Cryptoassets remains with the User at all times.
  2. Radom does not acquire ownership of User Cryptoassets.
  3. Radom does not use, lend, pledge, rehypothecate or otherwise encumber User Cryptoassets.
  4. Cryptoassets are held either:
    • in segregated blockchain addresses assigned to a specific User; or
    • in omnibus wallets with internal ledger segregation.
  5. Cryptoassets are not treated as corporate assets of Radom and are not intended to form part of Radom’s insolvency estate, subject to mandatory provisions of law.

Radom does not provide capital guarantees or deposit protection schemes.

8. Eligibility

You may use the Services only if:

  • • you are at least 18 years old
  • • you have legal capacity to enter binding agreements
  • • you are not located in, or subject to sanctions in, a comprehensively sanctioned jurisdiction
  • • you do not appear on any applicable sanctions list

9. AML and Transaction Freezing

Radom is an obliged entity under Polish AML legislation.

Radom may:

  • • suspend or refuse a transaction
  • • block access to an account
  • • freeze Cryptoassets

where required under AML, sanctions or other applicable law.

Radom may report transactions to competent authorities including GIIF.

Under Regulation (EU) 2023/1113 (Travel Rule), Radom may be required to collect, verify and transmit originator and beneficiary information. By using the Services, the User consents to such processing in accordance with the Privacy Notice.

10. Account Security

The User is solely responsible for maintaining the confidentiality and security of login credentials, authentication devices and private keys where applicable.

Any instruction authenticated using valid credentials is deemed authorised.

Radom is not liable for losses resulting from compromised credentials unless caused by Radom’s fraud, wilful misconduct or gross negligence.

Blockchain transactions are irreversible once broadcast.

11. User Responsibilities

You agree to:

  • • provide accurate and up-to-date information
  • • maintain confidentiality of account credentials
  • • comply with applicable laws including AML/CFT, sanctions and tax laws
  • • notify Radom promptly of any suspected breach

You remain responsible for all activity conducted through your account.

12. Prohibited Activities

You may not use the Services to:

  • • engage in fraud, money laundering or terrorist financing
  • • facilitate unlawful activity
  • • distribute illicit content or malware
  • • infringe intellectual property rights
  • • violate applicable law

Radom may suspend or terminate access and report suspicious activity.

13. Fees and Taxes

Fees may include transaction fees, blockchain network fees, service fees or onboarding charges.

Radom may introduce, modify or remove fees upon at least 14 days’ prior notice via the platform or email. Continued use constitutes acceptance of the revised fee schedule.

Applicable fees are disclosed via the platform or service documentation.

You are solely responsible for taxes arising from your use of the Services. Radom does not provide tax advice.

Certain services may require enhanced due diligence or legal documentation. Related fees are non-refundable where required compliance standards are not met.

14. Data Protection

Radom processes personal data in accordance with applicable data protection laws and its Privacy Notice.

By using the Services, you acknowledge that you have read and understood the Privacy Notice.

15. Intellectual Property

All platform software, APIs, documentation and branding are owned by Radom or its licensors.

You are granted a limited, non-exclusive, revocable licence to use the Services for their intended purpose.

You may not:

  • • reverse engineer or modify the Services
  • • use Radom branding without permission
  • • resell or sublicense the Services without authorisation

16. Security and Disclaimers

Radom implements reasonable technical and organisational security measures.

The Services are provided "as is" without warranties.

Radom is not liable for:

  • • blockchain network disruptions
  • • smart contract failures outside its control
  • • third-party service provider failures
  • • regulatory changes affecting digital assets

17. Risk Disclosure

Use of Cryptoassets involves significant risks, including:

  • • extreme price volatility
  • • technological risks
  • • irreversible transactions
  • • smart contract vulnerabilities
  • • forks or protocol changes
  • • network congestion or delays
  • • regulatory changes
  • • stablecoin de-pegging risk
  • • cybersecurity risks

Radom does not guarantee the value or stability of any Cryptoasset.

18. Force Majeure

Radom is not liable for delays or failures caused by events beyond its reasonable control, including:

  • • blockchain congestion or forks
  • • cyber incidents
  • • governmental actions
  • • sanctions
  • • war or civil unrest
  • • third-party failures

19. Limitation of Liability

To the fullest extent permitted by law, Radom is not liable for indirect or consequential damages.

Total aggregate liability shall not exceed the total fees paid by the User in the 12 months preceding the claim.

Nothing excludes liability for fraud, wilful misconduct or gross negligence.

Consumer rights under Polish law remain unaffected.

20. Restricted Jurisdictions and Reverse Solicitation

The Services are not directed to persons located in:

  • • the United Kingdom
  • • the United States
  • • Canada
  • • any jurisdiction requiring local authorisation not held by Radom

Access from Restricted Jurisdictions is permitted solely on the basis of Reverse Solicitation.

Radom may implement geolocation and compliance controls and may refuse or terminate Services where regulatory risk arises.

21. Termination

Radom may suspend or terminate Services immediately where:

  • • required by law
  • • the User breaches these Terms
  • • regulatory or legal risk arises

Users may terminate at any time by withdrawing Cryptoassets and closing the account.

Upon termination:

  • • accounts may be withdrawal-only
  • • Users must withdraw assets within the specified period
  • • accrued fees remain payable

22. Survival

Provisions relating to Regulatory Status, AML, Custody, Liability, Indemnification, Restricted Jurisdictions, Dispute Resolution and Governing Law survive termination.

23. Indemnification

You agree to indemnify and hold harmless Radom and its affiliates from claims arising from:

  • • your use of the Services
  • • your breach of these Terms
  • • your violation of law or third-party rights

24. Complaints and Dispute Handling

Complaints may be submitted:

  • • by email to contact@radom.com
  • • in writing to: Radom Pay sp. z o.o., ul. Żelazna 59A/4.5, 00-848 Warsaw, Poland

Radom will acknowledge receipt without undue delay and aims to provide a substantive response within 30 days.

25. Assignment

Radom may assign its rights and obligations to a successor or affiliate with prior notice.

Users may not assign their rights without Radom’s written consent.

26. Governing Law

These Terms are governed by the laws of Poland.

The courts of Warsaw, Poland have jurisdiction where arbitration does not apply.

27. Changes to Terms

Radom may amend these Terms at any time.

Where changes are materially adverse, Radom will provide at least 30 days’ prior notice. Continued use constitutes acceptance.

Users may terminate before the effective date if they do not accept the changes.

28. Contact

Radom Pay Spółka z ograniczoną odpowiedzialnością
ul. Żelazna 59A/4.5
00-848 Warsaw
Poland
Email: contact@radom.com