Introduction

Last Updated: Feburary 27, 2026

These Terms of Service (“Terms”) constitute a legally binding agreement. Please read them carefully. By accessing, registering for, or using the services provided by Radom Pay, you acknowledge that you have read, understood, and agreed to be bound by these Terms. If you do not agree to these Terms, you must strictly refrain from accessing or using our services.

  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 to it under Regulation S promulgated under the United States Securities Act of 1933, as amended, and shall also include any "United States person" within the meaning of Section 7701(a)(30) of the United States Internal Revenue Code of 1986, as amended.

  1. 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, a company incorporated under the laws of Poland, entered into the Register of Entrepreneurs of the National Court Register under KRS number 0001079663, NIP 5214051865, with its registered office at ul. Żelazna 59A/4.5, 00-848 Warsaw, Poland (“Radom”).  (“Radom,” “we,” “our,” or “us”).

Radom is entered into the Polish Register of Virtual Asset Service Providers maintained 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 or activities that may fall within the scope of such regulated activities are performed exclusively by duly authorised partners holding the relevant licences and regulatory approvals.

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. 

 

  1. Overview of Services 

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

  • Crypto and stablecoin payment processing; 
  • Mass crypto payouts; 
  • Fiat on-ramping and off-ramping (facilitated via regulated third-party providers); 
  • Virtual IBAN access and (via regulated third parties); 
  • Cryptoasset custody services; 
  • Cryptoasset conversion functionality, including swap execution facilitated through 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 cryptoasset components of the Services. 

  1. 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.

  1. 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 shall be construed as creating a trust, fiduciary, agency, partnership or joint venture relationship between Radom and the User.

 

  1. Regulatory Status 

Radom Pay sp. z o.o. is a Polish company registered in the Register of Virtual Asset Service Providers maintained pursuant to the Polish Act of 1 March 2018 on Counteracting Money Laundering and Terrorist Financing.

As a registered Virtual Asset Service Provider, Radom is an obliged entity under Polish AML legislation.

Accordingly, Radom is legally required to:

  • conduct identity verification and customer due diligence prior to and during the provision of Services;
  • monitor transactions on an ongoing basis;
  • request additional information or documentation where necessary;
  • apply enhanced due diligence measures in higher-risk situations;
  • comply with EU sanctions and restrictive measures;
  • report certain transactions or activities to competent authorities.

Radom may suspend, delay, refuse or restrict access to the Services, including blocking Cryptoassets, where required to comply with applicable law or regulatory obligations.

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

Registration as a Virtual Asset Service Provider 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, customer due diligence, and transaction monitoring as required by law. 

  1. 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 applicable law.

Radom does not provide capital guarantees or deposit protection schemes.

 

  1. Eligibility 

You may use the Services only if: 

  • You are at least 18 years old; 
  • You have the legal capacity to enter into binding agreements; 
  • You are not located in, or subject to sanctions imposed by, a comprehensively sanctioned jurisdiction; 
  • You do not appear on any applicable sanctions or restricted party list. 

 

  1.  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 and disclose information to competent authorities including GIIF and other supervisory bodies.

Where legally permitted, Radom may not be able to inform the User of the reasons for such measures.

In accordance with Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets (the "Travel Rule Regulation"), Radom may be required to collect, verify and transmit information about the originator and beneficiary of Cryptoasset transfers. By using the Services, the User consents to Radom collecting and sharing such information with receiving or transmitting obliged entities as required by applicable law. Radom shall process such data in accordance with its Privacy Notice and applicable data protection legislation.

  1. 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 shall be deemed authorised.

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

Blockchain transactions are irreversible and cannot be cancelled once broadcast to the network.

  1. User Responsibilities 

You agree to: 

  • Provide accurate and up-to-date information; 
  • Maintain the confidentiality of your account credentials; 
  • Comply with all applicable laws, including AML/CFT, sanctions, tax, and financial regulations; 
  • Notify us promptly of any unauthorised access or suspected breach. 

You remain responsible for all activity conducted through your account. 

 

  1. Prohibited Activities 

You may not use the Services to: 

  • Engage in fraud, money laundering, terrorist financing, or sanctions evasion; 
  • Facilitate unlawful activity; 
  • Distribute illicit content or malware; 
  • Infringe intellectual property rights; 
  • Violate applicable law. 

Radom reserves the right to suspend or terminate access and report suspicious activity to relevant authorities. 

 

  1. Fees and Taxes 

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

Radom reserves the right to introduce, modify or remove fees upon not less than 14 days' prior notice to the User via the platform or by email. Continued use of the Services following the effective date of any fee change constitutes acceptance of the revised fee schedule. Where the User does not accept the revised fees, the User may terminate the agreement in accordance with Section 21 prior to the effective date of such change.

Applicable fees are disclosed via the platform or applicable 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 if required compliance standards are notData 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. 

 

  1. 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. 

 

  1. Security and Disclaimers 

Radom implements reasonable technical and organisational security measures. 

The Services are provided “as is” without warranties of any kind. 

Radom shall not be liable for: 

  • Blockchain network disruptions; 
  • Smart contract failures outside its control; 
  • Third-party service provider failures; 
  • Regulatory changes affecting digital assets. 

  1. Risk Disclosure

The User acknowledges that the use of Cryptoassets and related Services involves significant risks, including but not limited to:

  • extreme price volatility and potential total loss of value;
  • technological risks associated with distributed ledger systems;
  • irreversible nature of blockchain transactions;
  • smart contract vulnerabilities;
  • blockchain forks or protocol modifications;
  • network congestion or delays;
  • regulatory or legal changes affecting Cryptoassets;
  • stablecoin de-pegging or issuer insolvency risk;
  • cybersecurity risks, including hacking or phishing.

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

The User confirms that it has sufficient knowledge and experience to assess the risks associated with the Services and acts at its own discretion and risk.

  1. Force Majeure

Radom shall not be liable for delay or failure caused by events beyond its reasonable control, including:

  • blockchain network congestion or forks,
  • cyber incidents,
  • governmental or regulatory actions,
  • sanctions,
  • acts of war or civil unrest,
  • failures of third-party service providers.

 

  1. Limitation of Liability 

Nothing in this section shall limit or exclude any rights of Users who qualify as consumers (konsumenci) under applicable Polish law, including rights arising under the Act of 30 May 2014 on Consumer Rights or any applicable EU legislation, to the extent that such rights cannot be excluded or limited by agreement.

To the fullest extent permitted by law, Radom shall not be liable for indirect, incidental, consequential, punitive or special 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, gross negligence or liability which cannot be excluded under applicable law.

  1. Restricted Jurisdictions and Reverse Solicitation

The Services are not directed to, marketed in, or intended for use by persons located in:

  • the United Kingdom,
  • the United States of America,
  • Canada,

or any other jurisdiction where the provision of the Services would require local authorisation, licensing or registration not held by Radom (the “Restricted Jurisdictions”).

Radom does not:

  • conduct marketing, promotion or solicitation in any Restricted Jurisdiction;
  • maintain offices, personnel or infrastructure in any Restricted Jurisdiction;
  • hold itself out as being authorised or licensed in any Restricted Jurisdiction.

The Services are not offered to “U.S. Persons” within the meaning of applicable United States securities and financial services laws. Users represent and warrant that they are not U.S. Persons and are not acting for the benefit of any U.S. Person.

Access to the Services from a Restricted Jurisdiction is permitted solely on the basis of Reverse Solicitation. By accessing or using the Services from a Restricted Jurisdiction, the User represents and warrants that:

  • the User initiated contact with Radom entirely at its own exclusive initiative;
  • no direct or indirect solicitation, marketing or promotion was undertaken by Radom in the User’s jurisdiction;
  • the User’s use of the Services is lawful under applicable local laws;
  • the User does not require Radom to hold any local licence, authorisation or registration.

Radom may implement technical and compliance controls, including geolocation screening, sanctions screening and residency verification. Radom reserves the right to refuse onboarding, suspend access or terminate Services where it determines, in its sole discretion, that continued provision of Services may expose Radom to regulatory, licensing or enforcement risk in any jurisdiction.

  1. Termination

Radom may suspend or terminate the Services immediately where:

  • required by law;
  • the User breaches these Terms;
  • provision of the Services creates regulatory or legal risk.

The User may terminate at any time by withdrawing available Cryptoassets and closing the account.

Upon termination:

  • the account may be restricted to withdrawal-only mode;
  • the User shall withdraw all Cryptoassets within a period specified by Radom;
  • fees accrued remain payable.

  1. Survival

The following provisions shall survive termination: Regulatory Status, AML Compliance, Custody, Limitation of Liability, Indemnification, Restricted Jurisdictions, Dispute Resolution, Governing Law.

 

  1. 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 applicable law or third-party rights. 

  1. Complaints and Dispute Handling

Users may submit complaints regarding the Services:

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

A complaint should include at least:

  • identification details of the User;
  • a description of the issue;
  • relevant transaction details, where applicable;
  • the User’s requested resolution.

Radom may request additional information necessary to properly assess the complaint.

Radom shall acknowledge receipt of the complaint without undue delay.

Complaints are handled in a fair, transparent and proportionate manner, taking into account the nature and complexity of the Services.

Radom shall provide a substantive response within 30 days from receipt of a complete complaint.

If, due to the complexity of the matter, a response cannot be provided within 30 days, Radom shall inform the User of:

  • the reasons for the delay; and
  • the expected timeframe for final response.

The final response shall be provided without undue delay.

Nothing in this section limits:

  • the User’s statutory rights under applicable Polish law;
  • the right to seek redress before competent courts;
  • any rights arising under consumer protection legislation, where applicable.

Where the User qualifies as a consumer under Polish law, the User may also seek assistance from competent consumer protection authorities.

Complaints relating to AML-related account restrictions, transaction suspensions or freezes may be subject to statutory limitations on disclosure.

Radom may be legally prohibited from providing detailed information regarding certain compliance-related measures.

  1. Assignment

Radom may assign, transfer or novate its rights and obligations under these Terms to any successor entity, affiliate or acquirer of all or substantially all of the assets or business of Radom, provided that such assignment does not materially reduce the protections afforded to the User hereunder. Radom shall provide the User with reasonable prior notice of any such assignment. The User may not assign, transfer or delegate any rights or obligations under these Terms without the prior written consent of Radom. Any purported assignment in breach of this section shall be void.

 

  1. Governing Law 

These Terms are governed by the laws of Poland. 

For matters not subject to arbitration, the courts of Warsaw, Poland shall have jurisdiction. 

 

  1. Changes to Terms 

Radom reserves the right to amend these Terms at any time. Where required by applicable law or where changes are materially adverse to the User, Radom shall provide not less than 30 days' prior written notice by email or via the platform interface. Continued use of the Services following the effective date of any amendment constitutes acceptance of the revised Terms. Where the User does not accept the amended Terms, the User may terminate the agreement in accordance with Section 21 prior to the effective date of such amendment without penalty. Radom may implement amendments with immediate effect where required by law, court order or regulatory instruction, in which case Radom shall notify the User as soon as reasonably practicable.

 

  1. Contact 

Radom Pay Spółka z ograniczoną odpowiedzialnością  ul. Żelazna 59A/4.5  00-848 Warsaw 

 Poland 

 Email: contact@radom.com