Last Updated: 1 July 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.
For the purposes of these Terms:
2.1 Contracting Entity: These Terms form a binding legal agreement between you ("User," "you," or "your") and RADOM PAY LLC, a limited liability company organized under the Limited Liability Companies Act 2008 of the Cook Islands, under company number LLC16897/2026, having its registered address at Global House, Avarua, Rarotonga, Cook Islands ("Radom Pay," "we," "our," or "us"). Radom Pay acts as the sole primary processor and provider of all Cryptoasset services described herein. Radom Pay currently operates as an unregulated business entity under the Limited Liability Companies Act 2008 and is not licensed or regulated by the Cook Islands Financial Supervisory Commission (FSC). However, Radom Pay is registered with the Cook Islands Financial Intelligence Unit (CIFIU) as a reporting institution and is strictly required to comply with the transaction reporting and anti-money laundering frameworks of the Cook Islands.
2.2 Operational Scope: Radom Pay is solely responsible for service delivery, transaction execution, custody, compliance, and Anti-Money Laundering (AML) decision-making. All operations, service provisions, and legal obligations of Radom Pay are governed by Cook Islands law.
3.1 Scope of Services: Radom Pay provides a cryptoasset infrastructure platform encompassing crypto and stablecoin payment processing, mass payouts, virtual fiat account access (via third parties), fiat on/off-ramping (via third parties), cryptoasset custody, conversion functionalities, and recurring billing tools.
3.2 Third-Party Providers: Where Fiat Services or specialized liquidity executions are utilized, they are provided by regulated third-party partners. Users may be subject to additional contractual terms imposed by these third parties. Radom Pay does not provide banking, credit, electronic money, or investment brokerage services.
3.3 No Fiduciary Relationship: These Terms establish a framework agreement for infrastructure services. No provision within these Terms creates a trust, fiduciary, agency, partnership, or joint venture relationship between Radom Pay and the User.
4.1 Custody Services: Where Custody Services are utilized, title to the Cryptoassets remains strictly with the User at all times. Radom Pay does not acquire ownership, nor does it use, lend, pledge, rehypothecate, or encumber User Cryptoassets. Assets are held in segregated addresses or omnibus wallets with strict internal ledger segregation. Cryptoassets do not form part of Radom Pay's corporate assets or insolvency estate, subject to mandatory provisions of law.
4.2 Execution and Conflicts of Interest: For conversion or swap functionalities, Radom Pay may act as principal or arrange execution via third-party liquidity providers. Radom Pay may receive fees or spreads in connection with these services. Radom Pay does not provide investment or portfolio management advice.
5.1 Compliance with Law: Radom Pay is committed to compliance with applicable global and Cook Islands Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) standards, including the provisions of the Cook Islands Financial Transactions Reporting Act 2017. Radom Pay is mandated to conduct identity verification (KYC/KYB), perform ongoing transaction monitoring, and apply enhanced due diligence where necessary to comply with international regulatory standards.
5.2 Transaction Freezing and Reporting: Radom Pay reserves the right to suspend transactions, block account access, or freeze Cryptoassets without prior notice if required by AML guidelines, sanctions, or applicable legal frameworks. Pursuant to the Financial Transactions Reporting Act 2017, Radom Pay may be legally required to report suspicious transactions to the Cook Islands Financial Intelligence Unit (CIFIU) and other competent authorities. Radom Pay may be legally prohibited from disclosing the reasons for such compliance measures to the User.
By accessing the Services, you represent and warrant that:
7.1 Security Responsibilities: You are solely responsible for safeguarding your login credentials, authentication devices, and applicable private keys. Any instruction authenticated using your valid credentials shall be deemed authorized by you.
7.2 Irreversibility: You acknowledge that blockchain transactions are irreversible once broadcast to the network. Radom Pay bears no liability for funds sent to incorrect addresses or networks by the User.
7.3 Prohibited Activities: You strictly agree not to use the Services to engage in money laundering, terrorist financing, fraud, distribution of illicit content, intellectual property infringement, or any other unlawful activity.
8.1 Fee Schedule: Use of the Services is subject to transaction fees, network fees, and service charges as disclosed on the Radom Pay platform. Radom Pay reserves the right to amend its fee schedule upon fourteen (14) days' prior written notice. Continued use of the Services constitutes acceptance of the revised fees.
8.2 Taxes: You bear sole responsibility for determining, collecting, reporting, and remitting any applicable taxes arising from your use of the Services. Radom Pay does not provide tax advice. You are solely responsible for ensuring that your use of the Services complies with your local tax obligations.
8.3 FATCA and CRS Reporting: To comply with global tax transparency frameworks, including the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS), Radom Pay may be legally required to collect additional tax information from you. Radom Pay reserves the right to report account balances, transaction history, and relevant personal data to the Cook Islands Ministry of Finance and Economic Management (MFEM) or other applicable tax authorities, who may exchange this information with the tax authorities of your country of tax residence.
All software, APIs, documentation, and branding associated with the platform remain the exclusive property of Radom Pay or its licensors. You are granted a limited, non-exclusive, revocable, and non-transferable license to use the Services for their intended purpose. You may not reverse engineer, modify, resell, or sublicense the Services without Radom Pay's explicit written authorization.
10.1 "As Is" Provision: THE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. RADOM PAY EXPRESSLY DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.
10.2 Assumption of Risk: You acknowledge that utilizing Cryptoassets involves severe risks, including extreme price volatility, irreversible transactions, technological vulnerabilities, smart contract failures, blockchain forks, network congestion, regulatory interventions, and cybersecurity threats. Radom Pay does not guarantee the value, liquidity, or stability of any Cryptoasset.
11.1 Limitation of Liability: TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, RADOM PAY AND ITS AFFILIATES SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR PUNITIVE DAMAGES, INCLUDING LOSS OF PROFITS OR DATA. RADOM PAY'S TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THESE TERMS SHALL NOT EXCEED THE TOTAL FEES PAID BY YOU TO RADOM PAY IN THE TWELVE (12) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM.
11.2 Exceptions: Nothing in these Terms excludes or limits liability for fraud, willful misconduct, or gross negligence.
11.3 Indemnification: You agree to fully indemnify, defend, and hold harmless Radom Pay, its affiliates, directors, and employees from any claims, damages, losses, or legal fees arising out of your breach of these Terms, your violation of any law or third-party rights, or your misuse of the Services.
Radom Pay shall not be liable for any delay or failure to perform its obligations under these Terms if such delay or failure is caused by events beyond its reasonable control. This includes, but is not limited to, blockchain network failures, cyber incidents, governmental actions, sanctions, war, civil unrest, or third-party infrastructure outages.
13.1 By Radom Pay: Radom Pay may suspend or terminate your access to the Services immediately and without notice if you breach these Terms, if required by applicable law, or if Radom Pay determines that your account poses an unacceptable legal or regulatory risk.
13.2 By User: You may terminate this agreement at any time by withdrawing all Cryptoassets and formally closing your account.
13.3 Post-Termination: Upon termination, your account will be restricted to withdrawal-only status. You must withdraw your assets within the timeframe specified by Radom Pay. Accrued fees and obligations will survive termination.
14.1 Governing Law: These Terms, and any non-contractual obligations arising out of them, shall be governed by and construed in accordance with the laws of the Cook Islands, without regard to its conflict of law principles.
14.2 Jurisdiction: Any dispute, controversy, or claim arising out of or relating to these Terms, or the breach, termination, or invalidity thereof, shall be subject to the exclusive jurisdiction of the competent courts of the Cook Islands.
14.3 Complaints: Users may submit complaints regarding the Services via email to contact@radom.com. Radom Pay will acknowledge receipt and endeavor to provide a substantive response within thirty (30) days.
15.1 Amendments (Variation): Radom Pay reserves the right to modify these Terms at its discretion. Any modifications or variations to these Terms will only come into effect after we provide you with at least seven (7) days' advance notice. Continued use of the Services following the effective date of any amendment constitutes your binding acceptance.
15.2 Assignment and Change of Entity: Radom Pay may assign, transfer, or delegate its rights and obligations under these Terms to an affiliate or successor entity (Change of Entity), provided that we give you at least seven (7) days' advance notice before such assignment comes into effect. You may not assign or transfer your rights or obligations without Radom Pay's prior written consent.
15.3 Severability: If any provision of these Terms is deemed invalid or unenforceable by a court of competent jurisdiction, the remaining provisions shall remain in full force and effect.
© 2026 RADOM PAY LLC · Global House, Avarua, Rarotonga, Cook Islands
