TanglePay Terms of Service

Last Updated: Oct 25, 2021.

Dear Users,

Thank you for choosing TanglePay. This TanglePay Terms of Service (“Agreement”) is made between you (“you” or “User”) and TANGLEPAY FOUNDATION PTE. LTD. (“TPF” or “we”) and is legally binding between you and TPF.

TPF hereby reminds you that you must carefully read the full content of this Agreement and other documents mentioned in this Agreement before using TanglePay (“TanglePay” or “App”). Particularly, you must carefully read the section of “Disclaimer and Limitation of Liability” and other sections which are displayed in bold. You must make sure that you fully understand the whole Agreement and evaluate the risks of using TanglePay on your own. In addition, TanglePay can be downloaded on mobile application platforms, including but not limited to Google Play and App Store.

I. Confirmation and Acceptance of this Agreement

1.1 You understand that this Agreement and other relevant documents apply to TanglePay and the Decentralized Applications (“DApps”) which are developed and owned independently by TPF on TanglePay (and excluding DApps developed by third parties).

1.2 After you download TanglePay and start to create or import wallet, you are deemed as having read and accepted this Agreement, which shall cause this Agreement to become effective and legally binding on both you and TPF immediately.

1.3 TPF may, at its sole discretion, modify or replace this Agreement at any time. The modified Agreement will automatically take effect once it is posted on TanglePay and you will not be notified separately. If you do not agree with the modifications, you shall cease to use TanglePay immediately. Use of TanglePay by you after any modification to this Agreement constitutes your acceptance of this Agreement as modified.

1.4 If you are under 18 years old or you are a person of no capacity for civil acts or a person of limited capacity for civil acts, please use TanglePay under the guidance of your parents or guardians.

II. Definition

2.1 TanglePay:

An IOTA wallet developed by TPF for the convenience of the IOTA ecosystem users.

2.2 User:

a) a User must be a natural person who possesses full capacity for civil acts;

b) if you are under 18 years old, please use TanglePay under the guidance of your parents or guardians. If any person of no capacity for civil acts conducts any transactions on TanglePay or any person of limited capacity for civil acts conducts any transaction which does not commensurate his/her civil rights or act capacity, the parents or guardians of the User shall be liable for the consequences of such transactions.

2.3 Excluded Person:

a) except for natural persons, persons who have the legal and consciousness ability to conclude this Agreement;

or b) users who are prohibited, restricted, unauthorized or unqualified to use the service (as defined in this Agreement) ) in any form or method (in whole or in part) due to this Agreement, laws, regulatory requirements, or the provisions of the jurisdiction applicable to the user. For the avoidance of doubt, Chinese Users are also regarded as "Excluded Person".

2.4 Terms:

a) Create or import wallet: Using TanglePay to create or import wallet after you accept this Agreement.

b) Wallet Password: The password you set when you create the wallet. The Wallet Password will be used to encrypt and protect your Private Key. TanglePay, as a decentralized application, will not store your Wallet Password on our servers, nor will your Wallet Password be stored in your own mobile devices. If you lose or forget your Wallet Password, you will have to reset the Wallet Password with your Private Key or Mnemonic Words. Reminder: It is recommended that Users follow the relevant steps for the information prompts involved in the TanglePay operating interface.

c) Specific Users: Users who should cooperate with TPF and disclose Personal Information in order to comply with the laws, regulations and policies of Singapore.

d) Private Key: Consists of 256 random bits. Private Key is the core for the User to hold and use the Tokens.

e) Public Key: Public key is derived from the Private Key based on cryptography and is used to generate wallet addresses. A wallet address is a public address for reception of Tokens.

f) Mnemonic Words: Consists of 24 words which are randomly generated. It is a human readable format of words to back up your Private Key for recovery.

g) Keystore: A file that is encrypted by Private Key or Mnemonic Words and protected by the User’s Wallet Password. Keystore is stored only in Users’ mobile device and will not be synchronized to TPF servers.

h) Tokens: The tokens which are supported by TanglePay currently, including but not limited to IOTA.

i) Materials: Contents in the columns of “News”, etc. on TanglePay. The Materials are TPF’ proprietary properties. User shall not reproduce or distribute the materials without TPF’ permission and authorization.

j) Personal Information: Means information recorded in electronic or any other form which may identify a natural person when used alone or in combination with other information, including but not limited to name, date of birth, identification card number, personal biological identification information, address, telephone number, bank card number, email address, wallet address, mobile device information, operation record, transaction record, but excluding Wallet Password, Private Key, Mnemonic Words and Keystore.

k) Third-party services: Products and services provided by third parties such as third-party DApps, third-party DeFi, third-party smart contracts, third-party open source agreements, third-party web pages, third-party hardware wallets, third-party online web wallets, third-party exchanges, etc.

III. Services

3.1 Create or import wallet. You may use TanglePay to create a new wallet or import wallets generated by other wallet application. You may only import wallets with Tokens which are supported by TanglePay.

3.2 Manage Tokens. You may use TanglePay to add, manage or delete the Tokens supported by TanglePay. Browse DApps. Users may use TanglePay to visit and use the services provided by DApps (including DApps developed by TPF and DApps developed by third parties).

3.3 Browse the DApp. Users can link to the DApp and use the services provided by the DApp (including TPF own DApps and third-party DApps) through the link on TanglePay.

3.4 Transaction records. We will copy all or part of your transaction records from IOTA. However, Users shall refer to the IOTA network for the latest transaction records.

3.5 Suspension of service. You understand that we are not able to reverse or cancel the transaction because of the nature of IOTA network. However, under certain circumstances, we may suspend or limit the function of TanglePay used by a particular user.

3.6 Other services that TPF would provide.

IV. Users who use TanglePay must understand that:

4.1 In order to keep the decentralization feature of IOTA network and to protect the security of your digital Tokens, TPF offers decentralized service which is largely different from the banking and financial institutions. Users shall understand that TPF (the decentralized solution) DOES NOT provide the following services:

a) store Users’ Wallet Password (the password Users set when creating or importing wallets), Private Key, Mnemonic Words or Keystore;

b) restore Users’ Wallet Password, Private Key, Mnemonic Words or Keystore;

c) freeze the wallet;

d) report the loss of wallet;

e) restore the wallet;

f) rollback transactions.

4.2 Users shall take care of their mobile devices, back up the TanglePay App, and back up the Wallet Password, Mnemonic Phases by themselves. If your mobile device is lost, your TanglePay App or your wallet is deleted and not backed up, your wallet is stolen or you forget your Wallet Password, Private Key, Mnemonic Words or Keystore, TPF is not able to recover the wallet or restore Wallet Password, Private Key, Mnemonic Words or Keystore. Nor can TPF cancel transactions for the mishandling of Users (such as typing in wrong addresses for transactions).

4.3 TanglePay is only a tool for Users to manage their Tokens and is not an exchange or a trading platform. For the purpose of this Agreement, the word “transactions” only means transferring Tokens, which is substantially different from transactions on the exchanges and trading platforms.

4.4 The DApps integrated into TanglePay include those developed independently by TPF and those developed by third parties. TanglePay only acts as a browser for those third-party-developed DApps. Users shall, at their sole discretion, decide whether there would be any risks to accept the services provided by or to conduct transactions on the third-party-developed DApps.

V. Your Rights and Obligations

5.1 Create or Import Wallet

a) Create or import wallet: you are entitled to use TanglePay on your mobile device to create and/or import wallet, set Wallet Password and use your wallet on TanglePay to transfer and receive Tokens on IOTA network.

b) TPF may develop different versions of TanglePay for different terminal devices. You shall download and install applicable version. If you download and install TanglePay or other application with the same name as “TanglePay” from any unauthorized third party, TPF cannot guarantee the normal operation or security of such application. Any loss caused by using such application shall be borne by you.

c) A previous version of TanglePay may stop to operate after a new version is released. TPF cannot guarantee the security, continuous operation or customer services for the previous version. Users shall download and use the latest version.

5.2 Use of TanglePay

a) Users shall take care of their mobile devices, Wallet Password, Private Key, Mnemonic Phases by themselves. TPF does not store or hold the above information for Users. You shall be responsible for any risks, liabilities, losses and expenses which result from frauds, you losing your mobile device, disclosing (whether actively or passively) or forgetting Wallet Password, Private Key, Mnemonic Words or Keystore, or your wallet being attacked.

b) Follow the Alert. You understand and agree to follow the Alert pushed by TanglePay. You shall be responsible for any risks, liabilities, losses and expenses which result from your failure to comply with the Alert.

c) You understand that TanglePay undertakes no responsibility to conduct due diligence on the services or transactions provided by third-party-developed DApps. You shall make investment decisions rationally and assume the risks by yourself.

5.3 Transfer of Tokens

a) You understand that IOTA network is “irrevocable”. When you use TanglePay to transfer Tokens, you shall be responsible for the consequences of your mishandling of the transfer (including but not limited to wrong address, problems of the node servers selected by you).

b) You understand that the following reasons may result in “transfer failed” or “mining overtime”

a. insufficient balance in wallet;

b. insufficient gas for transaction;

c. technical failure of the network or equipment;

d. abandoned transactions result from the network congestion or failure;

d) You understand that TanglePay is only a tool for transfer of Tokens. TPF shall be deemed to have fulfilled its obligations once you have finished the transfer and shall not be held liable for any other disputes.

e) Compliance. You understand that you shall abide by relevant laws, regulations and policies when you use TanglePay or the DApps on TanglePay.

5.4 Service fees

a) TanglePay does not charge you any service fees or handling fees for the time being. TanglePay may reach an agreement with you or announce rules regarding service fees in the future;

b) You need to pay gas when you transfer Tokens, the amount of which would be on your sole discretion and would be collected by certain network;

VI. Risks

6.1 You understand and acknowledge that the distributed ledger technology is a field of innovation where the laws and regulations are not fully established. You may be faced with material risks including instability of technology or failure of Tokens redemption. You also understand that Tokens have much higher volatility comparing to other financial assets. You shall make investment decisions and hold or dispose of the Tokens in a reasonable way and corresponding to your financial status and risk preferences.

6.2 If you or your counterparty fails to comply with this Agreement or fails to follow the instructions, tips or rules on the website or on the page of the transaction or payment, TanglePay does not guarantee successful transfer of the Tokens and TanglePay shall not be held liable for any of the consequences of such failure. If you or your counterparty has already received the payment in TanglePay wallet or third-party wallet, you understand that transactions on IOTA are irreversible and irrevocable. You and your counterparty shall assume the liabilities and consequences of your transactions.

6.3 You understand that distributed ledger operations and related transactions are irreversible. TanglePay shall not be held liable for the corresponding risks and consequences.

6.4 When you use third-party-developed DApps integrated in TanglePay, TPF strongly suggest you read this Agreement and TanglePay’s Alert carefully, get familiar with the counterparty and the product information and evaluate the risks before you make transactions on such DApps.

6.5 You understand that such transactions and corresponding contractual relationship are between you and your counterparty. TanglePay shall not be held liable for any risks, responsibilities, losses or expenses occurred due to such transactions.

6.6 It is your sole responsibility to make sure that your counterparty is a person with full capacity for civil acts and decide whether you shall transact with him/her.

6.7 You shall check the official IOTA network explorer when you receive Alert such as “transaction failed” or “mining overtime” in order to avoid repetitive transfer. If you fail to follow this instruction, you shall bear the losses and expenses occurred due to such repetitive transfer.

6.8 You understand that after you create or import wallet on TanglePay, your Keystore, Private Key and Mnemonic Words are only stored on your mobile device and will not be stored in TanglePay or on the servers of TPF. You may change another mobile device to use TanglePay after you follow the instructions on TanglePay to backup your wallet. If you lose your mobile device before you could write down or backup your Wallet Password, Private Key, Mnemonic Words or Keystore, you may lose your Tokens and TPF is unable to restore them. If your Wallet Password, Private Key, Mnemonic Words or Keystore is disclosed or the device which stores or holds your Wallet Password, Private Key, Mnemonic Words or Keystore is hacked or attacked, you may lose your Tokens and TPF is unable to restore them. You shall bear the foregoing losses on your own.

6.9 We suggest you backup your Wallet Password, Private Key, Mnemonic Words and Keystore when you create or import wallet by writing them down on papers or backup them in password management apps. Please do not use electronic methods such as screenshots, e-mails, note-taking apps in cell phones, text messages or any social media to backup any of the above information.

6.10 In order to avoid potential security risks, we suggest you use TanglePay in a secured network environment. Please do not use a jailbreak or Rooted mobile device.

6.11 Please be alert to frauds when you use TanglePay. If you find any suspicious conducts, we encourage you to inform us immediately.

VIl. Change, Suspension, Termination of TPF Service

7.1 You acknowledge and accept that TPF may, at its sole discretion, provide only a part of services for the time being, suspend certain services or provide new services in the future. When we change our services, your continuous use of TanglePay is deemed as your acceptance of this Agreement and revisions of this Agreement.

7.2 You understand that TPF may suspend services under the following circumstances:

a) due to the maintenance, upgrading, failure of equipment and distributed ledger system and the interruption of communications etc., which lead to the suspension of the operation of TanglePay;

b) due to force majeure events including but not limited to typhoon, earthquake, tsunami, flood, power outage, war, or terrorist attacks, or computer viruses, Trojan Horse, hacker attacks, system instability or government behaviors and other reasons, TPF is unable to provide services or in TPF’ reasonable opinion, continuous provision of services would result in significant risks;

c) due to other events which TPF cannot control or reasonably predicate.

d) TPF reserves the right to unilaterally suspend or terminate all or part of the function of TanglePay under the following circumstances:

a. death of Users;

b. if you steal others’ wallets information or mobile devices;

c. if you provide false Personal Information on TanglePay or cheat on Questionnaire;

d. if you refuse to allow mandatory update of TanglePay;

e. if you use TanglePay to commit illegal or criminal activities;

f. if you hinder the normal use of TanglePay by other Users;

g. if you pretend to be staff or management personnel of TPF;

h. if you threaten the normal operation of TPF computer system by attack, invasion, alternation or any other means;

i. if you use TanglePay to send spams;

j. if you spread rumors which endanger the goodwill of TPF and TanglePay;

k. if you conduct any illegal activities, breach this Agreement etc. or other circumstances under which TPF reasonably considers necessary to suspend services.

7.3 You are entitled to export your wallets within a reasonable amount of time if TPF changes, suspends or terminates its services.

VIIl. Your Representations and Warranties

8.1 You shall comply with all applicable laws and regulations of the country or area you reside in. You shall not use TanglePay for any unlawful purposes or by any unlawful means.

8.2 You shall not use TanglePay to commit any illegal or unlawful activities, including but not limited to:

a) activities opposing the basic principles set forth in the constitution, endangering national security, disclosing state secrets, overturning the government or undermining national unity;

b) any illegal conducts, such as money laundering, illegal fund raising etc.;

c) accessing TPF services, collecting or processing the content provided by TPF, intervening or attempting to intervene any Users, by the employment of any automated programs, software, network engines, web crawlers, web analytics tools, data mining tools or similar tools etc.;

d) providing gambling information or inducing others to engage in gambling;

e) invading into others’ TanglePay wallets to steal Tokens;

f) engaging in any inaccurate or false transactions with the counterparty;

g) committing any activities which harms or attempts to harm TanglePay service system and data;

h) other activities which TPF has reason to believe are inappropriate.

8.3 You understand and accept that you shall be responsible for any violation of law (including but not limited to the regulations of the Customs and Tax) or for breach of this Agreement by you and shall indemnify TPF against the losses, the third-party claims or administrative penalties against TPF incurred by such violation or breach, including reasonable attorney’s fees.

8.4 You are not an Excluded Person who is eligible to use the TanglePay service.

8.5 You confirm that you will pay the service fees charged by TPF in time (if applicable). TPF reserves the right to suspend the services when the User fails to pay service fees (if applicable).

IX. Privacy Policy

Your privacy is of utmost importance for TPF. Please refer to TanglePay Privacy Policy as updated by us from time to time for relevant privacy protection policies.

X. Disclaimer and Limitation of Liability

10.1 TPF only undertakes obligations expressly set forth in this Agreement.

10.2 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, TanglePay IS PROVIDED ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS. TPF shall not be held liable for malfunction of TanglePay which results from the following reasons:

a) system maintenance or upgrading of TanglePay;

b) force majeure, such as typhoon, earthquake, flood, lightning or terrorist attack etc.;

c) malfunction of your mobile device hardware and software, and failure of telecommunication lines and power supply lines;

d) your improper, unauthorized or unrecognized use of TPF services;

e) computer viruses, Trojan Horse, malicious program attacks, network congestion, system instability, system or equipment failure, telecommunication failure, power failure, banking issues, government acts etc.;

f) any other reasons not imputed to TPF.

10.3 TPF shall not be held liable under the following circumstances:

a) Users lose their mobile devices, delete TanglePay applications and wallets without back-up, forget Wallet Passwords, Private Keys, Mnemonic Words, Keystores without back-up, which result in the loss of their Tokens;

b) Users disclose their Wallet Passwords, Private Keys, Mnemonic Words, Keystores, or lend or transfer their TanglePay wallets to others, or authorize others to use their mobile devices or TanglePay wallets, or download TanglePay applications through unofficial channels, or use TanglePay applications by other insecure means, which result in the loss of their Tokens;

c) Users mishandle TanglePay (including but not limited to wrong address, failure of the node servers selected by you), which result in the loss of Tokens;

d) Users are unfamiliar with the knowledge of blockchain and their mishandling of TanglePay results in loss of their Tokens;

e) TanglePay is unable to copy accurate transaction records due to system delay or blockchain instability etc.;

10.4 Under the registration method using TanglePay mobile phone number and email address (the effective decentralized solution under the EOS system), users can choose to export the private key. The property damage arising from loss or stolen private key after the user changes the authority of Owner and Active shall not be borne by TPF in any way.

10.5 Under the default mode of the registration method using TanglePay mobile phone number and email address (the effective decentralized solution under the EOS system), if the private key cannot be retrieved through mobile phone number due to the user’s causes (such as the user cannot gain a new SIM card), TPF will not provide the service to retrieve the private key.

10.6 Property loss caused by users themselves (including but not limited to loss of mobile phone number, email address, the disclosure of the verification code, publication of the private key by the user, and the user’s personal information being hacked) shall not be borne by TPF in any way.

10.7 Users shall undertake the risks and consequences of their transactions on the third-party-developed DApps.You understand that TanglePay is only an management tool for Tokens which is incapable to control the quality, security and legitimacy of products and services provided by the third-party-developed DApps, or the authenticity and accuracy of their information and their capabilities to fulfill the obligations under the agreements with you. You, at your sole discretion, decide whether to transact on the third-party-developed DApps. It is the third-party-developed DApps, instead of TanglePay, that transact with you. We kindly remind you to carefully review the authenticity, legitimacy, and effectiveness of related information provided by the third-party-developed DApps before you decide to use the DApps. In addition, you shall also assume all the risks arising from the transactions between you and any third party exchanges.

You acknowledge that TanglePay may provide services to you and your counterparties simultaneously and you agree to waive any actual or potential conflicts of interests and will not claim against TPF on such base or burden TPF with more responsibilities or duty of care.

XI. TPF does not warrant that:

a) services provided by TPF would satisfy all your needs;

b) all techniques, products, services, information or other materials from TPF would meet your expectations;

c) all the transaction information in digital tokens markets captured from the third party exchanges are prompt, accurate, complete, and reliable;

d) your counterparties on TanglePay will perform their obligations in the transaction agreements with you timely.

e) in any case, the total liability for TPF under this Agreement shall not exceed the greater of:

a. 0.1 Ether; or

b. 500 SGD, higher value shall prevail.

11.1 You are aware that TanglePay is only a tool for Users to manage their Tokens and to display transaction information. TPF does not provide legal, tax or investment advice. You shall seek advice from professional legal, tax, and investment advisors. In addition, TPF shall not be liable for any investment loss, data loss etc. during your use of our service.

11.2 You understand that we may change our entry standards, limit the range and ways to provide services for specific Users etc. at any time in accordance with relevant laws and regulations.

XII. Entire Agreement

12.1 This Agreement incorporates TanglePay Terms of Service, TanglePay Privacy Policy, and other rules (including contents in the “Support” column) posted by TPF from time to time.

12.2 If any provision of this Agreement is found by a court with competent jurisdiction to be invalid, the other provisions of this Agreement remain in full force and effect.

12.3 This English version and other translated version of this Agreement (if any) are provided for the convenience of Users, and are not intended to revise the Chinese version of this Agreement. If there is any discrepancy between the Chinese version and non-Chinese version of this Agreement, the Chinese version shall prevail.

XIll. Intellectual Property Rights Protection

TanglePay is an application developed and owned by TPF. The intellectual property rights of any contents displayed in TanglePay (including this Agreement, announcements, articles, videos, audios, images, archives, information, materials, trademarks or logos) are owned by TPF or the third party licensors. Users can only use the TanglePay applications and its contents for the purpose of holding and managing their Tokens. In particular, without prior written consent from TanglePay or the third party licensors, no one shall use, modify, decompile, reproduce, publicly disseminate, alter, distribute, issue or publicly publish the abovementioned applications and contents.

XIV. Governing Law and Dispute Resolution

14.1 The validity, interpretation, alternation, enforcement, dispute resolution of this Agreement and its revised versions shall be governed and construed in accordance with the TPF's national laws. Where there is no applicable law, this Agreement shall be interpreted by applicable commercial and/or industrial practices.

14.2 If any dispute or claim in connection with this Agreement arises between you and TPF, the parties shall first attempt to resolve the dispute or claim through amicable negotiations in good faith. If the parties cannot reach an agreement, either party may sue the other party at the competent court where TPF is located.

XV. Miscellaneous

15.1 If you live outside of Singapore, you shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of TPF services.

15.2 During your use of TPF services, if you come across any problems, you can contact us through the submission of your feedbacks on TanglePay.

15.3 This Agreement is accessible for all Users on TanglePay. We encourage you to read this Agreement each time you log onto TanglePay.

This Agreement shall become effective on January 10th, 2018.

As for any issues not covered in this Agreement, you shall comply with the announcements and relevant rules as updated by TPF from time to time.

TanglePay Foundation Pte. Ltd.