Terms of Service
Last Updated: March 14, 2025
1. Acceptance of Terms
By accessing or using the Terminus Financial, Inc. ("Terminus," "we," "our," or "us") website, mobile application, card services, or any related products and services (collectively, the "Services"), you agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, please do not use our Services.
We reserve the right to modify these Terms at any time. Any changes will be effective immediately upon posting on our website. Your continued use of the Services after any modifications constitutes your acceptance of the revised Terms.
2. Eligibility
To use our Services, you must:
- Be at least 18 years of age (or the age of legal majority in your jurisdiction);
- Have the legal capacity to enter into a binding agreement;
- Not be a resident of a jurisdiction where the Services are prohibited or restricted;
- Not be listed on any government sanctions list or designated as a prohibited party;
- Provide accurate, current, and complete information during registration and maintain the accuracy of such information.
3. Account Registration
To access certain features of the Services, you may be required to create an account. You agree to:
- Provide truthful, accurate, and complete information;
- Maintain the security and confidentiality of your login credentials;
- Accept responsibility for all activities that occur under your account;
- Notify us immediately of any unauthorized use of your account.
We reserve the right to suspend or terminate your account if any information provided proves to be inaccurate, misleading, or incomplete, or if we suspect unauthorized or fraudulent activity.
4. Terminus Card Services
The Terminus Card is a Visa debit card that enables you to spend cryptocurrency at any merchant that accepts Visa. Key terms include:
- Card Issuance: Cards are issued by Terminus Financial, Inc. pursuant to a license from Visa International;
- Funding: You may fund your card using supported cryptocurrencies. Conversion to fiat currency occurs at the time of transaction;
- Transaction Limits: Daily and monthly spending limits may apply, as specified in the Cardholder Agreement;
- Fees: Certain fees may apply to card usage, including but not limited to ATM withdrawal fees, foreign exchange fees, and card replacement fees. A complete fee schedule is available in the Pricing section;
- Availability: Card services may not be available in all jurisdictions. We reserve the right to restrict or terminate services in certain regions.
5. Swap and Payment Routing Services
Terminus provides cross-chain cryptocurrency swap and payment routing services. By using these services:
- You acknowledge that cryptocurrency transactions are irreversible once confirmed on the blockchain;
- You understand that exchange rates are subject to market volatility and may fluctuate between the time of quote and execution;
- You accept that network fees (gas fees) are determined by the underlying blockchain protocol and are not controlled by Terminus;
- You agree that slippage tolerance settings are your responsibility and any resulting price impact is at your own risk.
6. Prohibited Activities
You agree not to use the Services for:
- Any illegal or unauthorized purpose, including money laundering, terrorist financing, or fraud;
- Violating any applicable law, regulation, or third-party rights;
- Engaging in market manipulation, wash trading, or deceptive practices;
- Attempting to bypass security measures, access controls, or rate limits;
- Distributing malware, viruses, or any other harmful software;
- Using the Services to conduct business on behalf of sanctioned individuals or entities;
- Any activity that could damage, disable, overburden, or impair the Services.
7. Intellectual Property
All content, features, and functionality of the Services — including but not limited to text, graphics, logos, icons, images, software, and code — are the exclusive property of Terminus Financial, Inc. and are protected by international copyright, trademark, and other intellectual property laws. You may not reproduce, distribute, modify, or create derivative works from any part of the Services without our prior written consent.
8. Disclaimers
THE SERVICES ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. TO THE FULLEST EXTENT PERMITTED BY LAW, TERMINUS DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.
Cryptocurrency services are not FDIC insured, not bank guaranteed, and may lose value. Terminus does not guarantee the accuracy, completeness, or timeliness of exchange rates, transaction execution, or any other information provided through the Services.
9. Limitation of Liability
IN NO EVENT SHALL TERMINUS FINANCIAL, INC., ITS DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, OR AFFILIATES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION LOSS OF PROFITS, DATA, USE, OR GOODWILL, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF THE SERVICES, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), OR ANY OTHER LEGAL THEORY.
Our total liability to you for any claims arising from or relating to the Services shall not exceed the total amount of fees you paid to Terminus during the twelve (12) months preceding the claim.
10. Indemnification
You agree to indemnify, defend, and hold harmless Terminus Financial, Inc. and its officers, directors, employees, agents, and affiliates from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable attorneys' fees) arising out of or relating to your use of the Services, your violation of these Terms, or your infringement of any third-party rights.
11. Governing Law and Dispute Resolution
These Terms shall be governed by and construed in accordance with the laws of the State of Delaware, United States, without regard to its conflict of law provisions.
Any disputes arising from or relating to these Terms or the Services shall first be attempted to be resolved through good-faith negotiation. If unresolved within 30 days, the dispute shall be submitted to binding arbitration under the rules of the American Arbitration Association (AAA), to be conducted in Wilmington, Delaware.
12. Termination
We may terminate or suspend your access to the Services immediately, without prior notice or liability, for any reason, including but not limited to a breach of these Terms. Upon termination, your right to use the Services will immediately cease. Any remaining balance on your Terminus Card will be made available for withdrawal in accordance with the Cardholder Agreement.
13. Contact Information
If you have any questions about these Terms of Service, please contact us at:
Terminus Financial, Inc.
Ahtri tn 12, Tallinn 10151, Estonia
Phone: +372 6801 234
Email: legal@terminus.finance
Website: terminus.finance
Privacy Policy
Last Updated: March 14, 2025
1. Introduction
Terminus Financial, Inc. ("Terminus," "we," "our," or "us") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use our website, mobile application, card services, and related products (collectively, the "Services").
By using our Services, you consent to the collection and use of your information in accordance with this policy. If you do not agree, please discontinue use of our Services.
2. Information We Collect
2.1 Information You Provide Directly
- Identity Information: Full name, date of birth, nationality, government-issued ID (passport, driver's license);
- Contact Information: Email address, phone number, mailing address;
- Financial Information: Cryptocurrency wallet addresses, transaction history, card usage data;
- Verification Information: Selfie photographs, proof of address documents (for KYC compliance);
- Communication Data: Support tickets, chat messages, and correspondence with us.
2.2 Information Collected Automatically
- Device Information: IP address, browser type and version, operating system, device identifiers;
- Usage Data: Pages visited, features used, time spent, click patterns, referral sources;
- Location Data: Approximate location based on IP address;
- Cookie Data: Information collected through cookies, web beacons, and similar technologies (see our Cookie Policy).
2.3 Information from Third Parties
- Identity verification providers;
- Blockchain analytics services;
- Payment processors and card networks (Visa);
- Public blockchain data.
3. How We Use Your Information
We use the information we collect for the following purposes:
- Service Provision: To create and manage your account, process transactions, and deliver our card and swap services;
- Compliance: To comply with applicable laws, regulations, and regulatory requirements, including AML/KYC obligations;
- Security: To detect, prevent, and investigate fraud, unauthorized access, and other security incidents;
- Communication: To send you transactional notifications, security alerts, and customer support responses;
- Improvement: To analyze usage patterns, improve our Services, and develop new features;
- Marketing: To send promotional communications (with your consent, where required by law); you may opt out at any time.
4. How We Share Your Information
We do not sell your personal information. We may share your information in the following circumstances:
- Service Providers: With third-party vendors who perform services on our behalf (cloud hosting, KYC verification, payment processing, customer support);
- Card Networks: With Visa and issuing bank partners as required for card transaction processing;
- Legal Requirements: When required by law, subpoena, court order, or governmental request;
- Safety and Security: When we believe disclosure is necessary to protect the rights, safety, or property of Terminus, our users, or the public;
- Business Transfers: In connection with a merger, acquisition, asset sale, or bankruptcy proceeding;
- With Your Consent: In any other circumstances where you have given us explicit consent.
5. Data Retention
We retain your personal information for as long as necessary to:
- Provide our Services to you;
- Comply with legal and regulatory obligations (typically 5–7 years for financial records);
- Resolve disputes and enforce our agreements;
- Maintain business records as required by applicable law.
When data is no longer required, we will securely delete or anonymize it in accordance with our data retention policies.
6. Data Security
We implement industry-standard technical and organizational measures to protect your personal information, including:
- AES-256 encryption for data at rest;
- TLS 1.3 encryption for data in transit;
- Multi-factor authentication for account access;
- Regular security audits and penetration testing;
- SOC 2 Type II compliant infrastructure;
- Role-based access controls with least-privilege principles.
While we strive to protect your information, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.
7. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Access: Request a copy of the personal data we hold about you;
- Rectification: Request correction of inaccurate or incomplete data;
- Erasure: Request deletion of your personal data (subject to legal retention requirements);
- Restriction: Request restriction of processing in certain circumstances;
- Portability: Request your data in a structured, machine-readable format;
- Objection: Object to processing based on legitimate interests or for direct marketing;
- Withdraw Consent: Withdraw consent at any time where processing is based on consent.
To exercise any of these rights, please contact us at privacy@terminus.finance. We will respond within 30 days.
8. International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence. We ensure adequate data protection through:
- Standard Contractual Clauses (SCCs) approved by the European Commission;
- Data processing agreements with all service providers;
- Compliance with applicable cross-border transfer mechanisms.
9. Children's Privacy
Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information promptly.
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. We encourage you to review this policy periodically.
11. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:
Terminus Financial, Inc.
Data Protection Officer
Ahtri tn 12, Tallinn 10151, Estonia
Phone: +372 6801 234
Email: privacy@terminus.finance
Website: terminus.finance
Cookie Policy
Last Updated: March 14, 2025
1. What Are Cookies?
Cookies are small text files that are placed on your device (computer, tablet, or mobile phone) when you visit a website. They are widely used to make websites work more efficiently, provide a better user experience, and supply information to site owners.
Similar technologies include web beacons, pixels, local storage, and session storage. For simplicity, we refer to all of these technologies collectively as "cookies" in this policy.
2. How We Use Cookies
Terminus Financial, Inc. ("Terminus") uses cookies to:
- Ensure the proper functioning and security of our Services;
- Remember your preferences and settings;
- Authenticate your identity and maintain your session;
- Analyze site traffic and usage patterns to improve our Services;
- Deliver relevant advertising and measure campaign effectiveness;
- Prevent fraud and protect the security of our platform.
3. Types of Cookies We Use
3.1 Strictly Necessary Cookies
These cookies are essential for the operation of our website and Services. They enable core functionality such as security, authentication, and session management. You cannot opt out of these cookies as the Services would not function without them.
| Cookie | Purpose | Duration |
|---|
| session_id | Maintains your authenticated session | Session |
| csrf_token | Prevents cross-site request forgery attacks | Session |
| cookie_consent | Stores your cookie consent preferences | 1 year |
3.2 Functional Cookies
These cookies enable enhanced functionality and personalization, such as remembering your language preference, theme setting, or display options. If you do not allow these cookies, some features may not function properly.
| Cookie | Purpose | Duration |
|---|
| locale | Remembers your language and region preference | 1 year |
| currency_pref | Remembers your preferred display currency | 6 months |
3.3 Analytics Cookies
These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. This data helps us improve the structure and content of our Services.
| Cookie | Provider | Purpose | Duration |
|---|
| _ga | Google Analytics | Distinguishes unique users | 2 years |
| _ga_* | Google Analytics | Maintains session state | 2 years |
| _gid | Google Analytics | Distinguishes unique users | 24 hours |
3.4 Marketing Cookies
These cookies are used to track visitors across websites and display relevant advertisements. They are set by our advertising partners and help measure the effectiveness of our marketing campaigns.
| Cookie | Provider | Purpose | Duration |
|---|
| _fbp | Meta (Facebook) | Tracks visits across websites for ad targeting | 3 months |
| _gcl_au | Google Ads | Stores conversion data for Google Ads | 3 months |
4. Third-Party Cookies
Some cookies are placed by third-party services that appear on our pages. We do not control these third-party cookies and recommend you review their respective privacy policies:
5. Managing Your Cookie Preferences
You can manage your cookie preferences in several ways:
- Cookie Banner: When you first visit our site, you can set your preferences through our cookie consent banner;
- Browser Settings: Most web browsers allow you to control cookies through their settings. You can typically find these options in the "Privacy" or "Security" section of your browser preferences;
- Opt-Out Links: For analytics and advertising cookies, you can opt out through the following tools:
Please note that disabling certain cookies may affect the functionality of our Services.
6. Changes to This Cookie Policy
We may update this Cookie Policy from time to time to reflect changes in our cookie usage or applicable laws. We will notify you of any material changes by posting the updated policy on our website. We encourage you to review this policy periodically.
7. Contact Us
If you have any questions about our use of cookies, please contact us at:
Terminus Financial, Inc.
Ahtri tn 12, Tallinn 10151, Estonia
Phone: +372 6801 234
Email: privacy@terminus.finance
Website: terminus.finance
AML / KYC Policy
Last Updated: March 14, 2025
1. Purpose and Scope
Terminus Financial, Inc. ("Terminus") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures for preventing, detecting, and reporting money laundering and terrorist financing activities in accordance with applicable laws, including the Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, and applicable international standards.
This policy applies to all employees, officers, directors, agents, and third-party service providers of Terminus.
2. Know Your Customer (KYC) Procedures
2.1 Customer Identification Program (CIP)
Before establishing a business relationship, Terminus will verify the identity of each customer through the following process:
- Individual Customers: Full legal name, date of birth, residential address, and a government-issued photo identification document (passport, national ID card, or driver's license);
- Document Verification: All identification documents are verified through automated and manual review processes using trusted third-party verification providers;
- Biometric Verification: A live selfie comparison ("liveness check") is performed against the submitted identification document;
- Address Verification: Proof of residential address may be required through utility bills, bank statements, or government correspondence (dated within the last three months).
2.2 Customer Due Diligence (CDD)
Terminus performs due diligence on all customers to assess risk levels:
- Standard Due Diligence: Applied to all customers — identity verification, sanctions screening, and PEP (Politically Exposed Person) checks;
- Enhanced Due Diligence (EDD): Applied to higher-risk customers, including those from high-risk jurisdictions, PEPs, or those conducting large or unusual transactions. EDD includes additional documentation requests, source of funds verification, and ongoing enhanced monitoring.
2.3 Ongoing Monitoring
Terminus continuously monitors customer transactions and activities to detect suspicious behavior, including:
- Transaction pattern analysis and anomaly detection;
- Periodic re-verification of customer information;
- Continuous sanctions and PEP list screening;
- Blockchain analytics to identify high-risk wallet addresses and transaction patterns.
3. Risk Assessment
Terminus conducts a risk-based approach to AML compliance, considering factors including:
- Customer risk profile (nationality, occupation, transaction history);
- Geographic risk (country of residence, jurisdictional risk factors);
- Product/service risk (type and volume of transactions);
- Delivery channel risk (anonymous access, remote onboarding).
Risk assessments are reviewed and updated annually, or more frequently when significant changes occur.
4. Suspicious Activity Reporting
Terminus is required to report suspicious activities to the appropriate authorities. Our process includes:
- All employees are trained to recognize indicators of suspicious activity;
- Internal suspicious activity reports are reviewed by the Compliance Team;
- Suspicious Activity Reports (SARs) are filed with FinCEN within the required timeframes;
- Currency Transaction Reports (CTRs) are filed for qualifying transactions;
- Records of all reports are maintained for a minimum of five (5) years.
Employees are prohibited from disclosing ("tipping off") any customer or third party about the filing of a SAR.
5. Sanctions Compliance
Terminus screens all customers against applicable sanctions lists, including:
- U.S. Office of Foreign Assets Control (OFAC) SDN List;
- United Nations Security Council Consolidated List;
- European Union Consolidated Sanctions List;
- UK HM Treasury Sanctions List;
- FATF High-Risk Jurisdictions list.
Customers or transactions involving sanctioned parties, countries, or regions are immediately blocked and reported.
6. Record Keeping
Terminus maintains comprehensive records of all customer identification documents, transaction records, and compliance reports for a minimum of five (5) years, as required by applicable law. Records are stored securely with appropriate access controls and encryption.
7. Training
All Terminus employees and relevant contractors receive AML/KYC training upon onboarding and at least annually thereafter. Training covers:
- Applicable AML/CTF laws and regulations;
- Recognition of suspicious activity indicators;
- Customer due diligence procedures;
- Reporting obligations and escalation procedures;
- Cryptocurrency-specific money laundering typologies.
8. Compliance Officer
Terminus has designated a qualified Compliance Officer responsible for overseeing the AML/KYC program. The Compliance Officer is responsible for program implementation, policy updates, regulatory reporting, and liaison with regulatory authorities.
9. Contact
For questions about our AML/KYC policies, please contact:
Terminus Financial, Inc.
Compliance Department
Email: compliance@terminus.finance
Cardholder Agreement
Last Updated: March 14, 2025
1. Introduction
This Cardholder Agreement ("Agreement") is a legally binding contract between you ("Cardholder," "you," or "your") and Terminus Financial, Inc. ("Terminus," "we," "our," or "us") governing the issuance and use of the Terminus Visa Debit Card ("Card"). By activating or using the Card, you agree to be bound by this Agreement.
2. Card Issuance
- The Card is issued by Terminus Financial, Inc. under license from Visa International;
- You may receive a virtual card instantly upon account approval, and optionally request a physical card;
- The Card remains the property of Terminus and must be returned or destroyed upon request;
- One (1) active physical card and up to five (5) virtual cards may be issued per account;
- Card issuance is subject to successful completion of our identity verification (KYC) process.
3. Card Funding
- The Card is funded by depositing supported cryptocurrencies into your Terminus wallet;
- Cryptocurrency is converted to fiat currency (USD, EUR, or GBP) at the time of each transaction;
- The conversion rate is determined at the moment of transaction authorization and includes any applicable spread;
- You are responsible for maintaining sufficient cryptocurrency balance to cover your transactions;
- Terminus does not extend credit — the Card is a prepaid debit card only.
4. Transaction Limits
| Limit Type | Standard Tier | Premium Tier |
|---|
| Daily spending limit | $5,000 | $25,000 |
| Monthly spending limit | $25,000 | $100,000 |
| Daily ATM withdrawal | $500 | $2,000 |
| Monthly ATM withdrawal | $2,000 | $10,000 |
| Single transaction limit | $2,500 | $15,000 |
Limits may be adjusted based on account verification level, compliance requirements, and usage history.
5. Fees
| Fee Type | Amount |
|---|
| Card issuance (virtual) | Free |
| Card issuance (physical) | $9.99 |
| Monthly maintenance | Free |
| Domestic transactions | Free |
| International transactions | Free |
| ATM withdrawal (domestic) | $1.50 |
| ATM withdrawal (international) | $2.50 |
| Card replacement | $9.99 |
| Inactivity fee (after 12 months) | $4.99/month |
All fees are subject to change with 30 days' prior notice.
6. Authorized Use
The Card may only be used by the registered Cardholder for lawful purchases and ATM withdrawals. You agree not to use the Card for:
- Illegal or prohibited transactions;
- Gambling or lottery activities (where prohibited by applicable law);
- Purchasing items or services prohibited by Visa network rules;
- Transactions that exceed your available balance or applicable limits.
7. Disputes and Chargebacks
If you believe a transaction is unauthorized or incorrect, you must notify us within sixty (60) days of the transaction date. We will investigate and, if appropriate, issue a provisional credit within ten (10) business days while the investigation is completed. Final resolution will be communicated within forty-five (45) days.
You may dispute a transaction by contacting our Support team at support@terminus.finance or through the Terminus app.
8. Card Security
- You are responsible for safeguarding your Card, PIN, and account credentials;
- Report lost, stolen, or compromised cards immediately through the app or by contacting support;
- You may instantly freeze and unfreeze your Card through the Terminus app;
- Terminus is not liable for unauthorized transactions occurring before you report a lost or stolen card, except as required by applicable law.
9. Termination
Either party may terminate this Agreement at any time:
- By You: You may close your account and cancel your Card at any time through the app or by contacting support. Any remaining balance will be converted and returned to your designated cryptocurrency wallet;
- By Terminus: We may suspend or terminate your Card and account for violation of this Agreement, suspected fraud, regulatory requirements, or for any other reason with reasonable notice.
10. Governing Law
This Agreement shall be governed by and construed in accordance with the laws of the State of Delaware, United States. Any disputes shall be resolved through binding arbitration administered by the American Arbitration Association.
11. Contact
Terminus Financial, Inc.
Card Services
Email: support@terminus.finance
Website: terminus.finance
E-Money License
Last Updated: March 14, 2025
1. Regulatory Status
Terminus Financial, Inc. ("Terminus") operates as a regulated financial services provider. The following details outline our licensing and regulatory framework:
- Company Name: Terminus Financial, Inc.
- Incorporation: Incorporated in the State of Delaware, United States
- FinCEN Registration: Registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network (FinCEN)
- State Licenses: Licensed as a money transmitter in applicable U.S. states where required
2. European Operations
For operations within the European Economic Area (EEA), Terminus services are provided through our licensed European partner entity:
- Entity Name: Terminus Europe OÜ
- Jurisdiction: Republic of Estonia
- Regulatory Authority: Estonian Financial Supervisory Authority (Finantsinspektsioon)
- License Type: Virtual Currency Service Provider License
- License Number: FVT000385
- Scope: Providing virtual currency wallet services and virtual currency exchange services
3. Card Issuance
The Terminus Visa Debit Card is issued pursuant to a license from Visa International Service Association. Card program management and issuance are conducted in partnership with licensed issuing bank partners who are:
- Members of the Visa network;
- Regulated by applicable banking authorities;
- Compliant with PCI DSS Level 1 security standards;
- Subject to regular audits by independent third parties.
4. Scope of Authorized Activities
Under our regulatory framework, Terminus is authorized to conduct the following activities:
- Issuance and management of prepaid Visa debit cards;
- Cryptocurrency-to-fiat conversion services at point of sale;
- Cross-chain cryptocurrency swap and payment routing;
- Digital wallet services for supported cryptocurrencies;
- Money transmission services as permitted by applicable state and federal licenses.
5. Consumer Protection
As a licensed and regulated entity, Terminus is committed to the following consumer protection measures:
- Segregation of Funds: Customer funds are held separately from corporate operating funds;
- Security Standards: PCI DSS Level 1 certified infrastructure with SOC 2 Type II audit compliance;
- Complaint Resolution: Formal complaint handling procedures in accordance with regulatory requirements (see our Complaint Handling Policy);
- Transparency: Clear disclosure of all fees, terms, and conditions;
- Data Protection: Full compliance with applicable data protection laws, including GDPR for European users.
6. Regulatory Oversight
Terminus is subject to ongoing regulatory oversight, including:
- Regular reporting to FinCEN and applicable state regulators;
- Annual independent audits of financial statements;
- Periodic compliance examinations by regulatory authorities;
- Maintaining minimum capital requirements as prescribed by applicable regulations.
7. Important Notices
- Cryptocurrency services provided by Terminus are not FDIC insured;
- Cryptocurrency assets are not bank guaranteed and may lose value;
- Terminus does not provide investment advice. All cryptocurrency transactions are conducted at your own risk;
- The regulatory status and available services may vary by jurisdiction.
8. Contact Regulatory Authorities
If you have concerns about our regulatory compliance, you may contact the relevant authorities directly:
You may also contact Terminus directly:
Terminus Financial, Inc.
Compliance Department
Email: compliance@terminus.finance
Complaint Handling Policy
Last Updated: March 14, 2025
1. Our Commitment
Terminus Financial, Inc. ("Terminus") is committed to providing exceptional service. We take all complaints seriously and aim to resolve them fairly, promptly, and transparently. This policy outlines how to submit a complaint and how we handle it.
2. What Is a Complaint?
A complaint is any expression of dissatisfaction, whether oral or written, about the provision or failure to provide a financial service or product, which alleges the complainant has suffered financial loss, distress, or inconvenience.
3. How to Submit a Complaint
You may submit a complaint through any of the following channels:
- Email: complaints@terminus.finance
- Phone: +372 6801 234
- In-App: Navigate to Settings → Help → Submit a Complaint
- Mail: Terminus Financial, Inc., Complaints Department, Ahtri tn 12, Tallinn 10151, Estonia
When submitting a complaint, please include:
- Your full name and account email address;
- A clear description of the issue;
- The date(s) the issue occurred;
- Any relevant transaction IDs or reference numbers;
- Your desired resolution;
- Supporting documentation (screenshots, receipts, etc.).
4. Complaint Handling Process
Step 1 — Acknowledgement
We will acknowledge receipt of your complaint within two (2) business days. You will receive a confirmation email with a unique complaint reference number.
Step 2 — Investigation
A dedicated member of our Complaints Team will investigate the matter. During the investigation, we may contact you for additional information or clarification.
Step 3 — Resolution
We aim to resolve all complaints within fifteen (15) business days from the date of receipt. If the complaint is complex and requires additional time, we will inform you of the expected timeline, which will not exceed thirty-five (35) business days without providing an interim update.
Step 4 — Final Response
Once the investigation is complete, you will receive a written final response that includes:
- A summary of the complaint;
- The findings of our investigation;
- The resolution or corrective action taken;
- Information about escalation options if you are not satisfied.
5. Escalation
If you are not satisfied with the resolution provided, you may escalate your complaint:
- Internal Escalation: Request a review by our Senior Compliance Officer by replying to your final response email;
- External Escalation (US): You may file a complaint with the Consumer Financial Protection Bureau (CFPB) at www.consumerfinance.gov/complaint;
- External Escalation (EU): European users may refer unresolved complaints to the relevant financial ombudsman or alternative dispute resolution (ADR) body in their jurisdiction.
6. Record Keeping
We maintain records of all complaints, investigations, and outcomes for a minimum of five (5) years. Complaint data is analyzed regularly to identify trends, improve our services, and prevent recurring issues.
7. Fair Treatment
All complaints are handled impartially and without prejudice. Submitting a complaint will never adversely affect your relationship with Terminus or your access to our services.
8. Contact
Terminus Financial, Inc.
Complaints Department
Email: complaints@terminus.finance
Data Processing Agreement
Last Updated: March 14, 2025
1. Introduction
This Data Processing Agreement ("DPA") supplements the Terms of Service and Privacy Policy of Terminus Financial, Inc. ("Terminus," "Processor," "we," "us") and governs the processing of personal data on behalf of our users ("Data Controller," "you," "your") in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the California Consumer Privacy Act ("CCPA"), and other applicable data protection laws.
2. Definitions
- "Personal Data" means any information relating to an identified or identifiable natural person;
- "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, or erasure;
- "Sub-processor" means any third party engaged by Terminus to process personal data;
- "Data Subject" means the individual to whom the personal data relates;
- "Supervisory Authority" means an independent public authority responsible for monitoring the application of data protection laws.
3. Scope of Processing
Terminus processes personal data solely for the purposes of providing our financial services, including:
- Account creation and identity verification (KYC);
- Card issuance, management, and transaction processing;
- Cryptocurrency swap and conversion services;
- Fraud prevention and AML/CTF compliance;
- Customer support and communication;
- Regulatory reporting and legal obligations.
4. Obligations of the Processor
Terminus shall:
- Process personal data only on documented instructions from the Data Controller, unless required by law;
- Ensure that all personnel authorized to process personal data are bound by confidentiality obligations;
- Implement appropriate technical and organizational measures to ensure data security (see Section 6);
- Assist the Data Controller in responding to Data Subject requests (access, rectification, erasure, portability);
- Notify the Data Controller of any personal data breach without undue delay and in no event later than seventy-two (72) hours after becoming aware;
- Delete or return all personal data upon termination of services, unless retention is required by law;
- Make available all information necessary to demonstrate compliance and allow for audits.
5. Sub-processors
Terminus engages the following categories of sub-processors:
| Category | Purpose | Location |
|---|
| Cloud Infrastructure | Data hosting, storage, and compute | United States, EU |
| Identity Verification | KYC/AML document and biometric verification | United States, EU |
| Payment Processing | Card issuance and transaction processing | United States, EU |
| Analytics | Service improvement and performance monitoring | United States |
| Customer Support | Ticket management and communication | United States |
We will notify you of any intended changes to sub-processors, providing you with the opportunity to object. A current list of sub-processors is available upon request.
6. Security Measures
Terminus implements the following technical and organizational measures:
- Encryption of data in transit (TLS 1.3) and at rest (AES-256);
- Role-based access control with least-privilege principle;
- Multi-factor authentication for all internal systems;
- Regular penetration testing and vulnerability assessments;
- SOC 2 Type II certified operations;
- PCI DSS Level 1 compliance for payment card data;
- Real-time intrusion detection and logging;
- Business continuity and disaster recovery procedures.
7. International Data Transfers
Where personal data is transferred outside the European Economic Area (EEA), Terminus ensures adequate safeguards through:
- Standard Contractual Clauses (SCCs) approved by the European Commission;
- Adequacy decisions where applicable;
- Supplementary measures as required by the CJEU's Schrems II decision;
- EU-U.S. Data Privacy Framework certification where applicable.
8. Data Subject Rights
Terminus will assist the Data Controller in fulfilling Data Subject requests, including:
- Right of access;
- Right to rectification;
- Right to erasure ("right to be forgotten");
- Right to restriction of processing;
- Right to data portability;
- Right to object to processing;
- Rights related to automated decision-making and profiling.
9. Data Retention
Personal data is retained only for as long as necessary to fulfill the purposes outlined in this DPA, comply with legal obligations (including AML retention requirements of five years), resolve disputes, and enforce agreements.
10. Term and Termination
This DPA remains in effect for the duration of the processing of personal data by Terminus. Upon termination, all personal data shall be deleted or returned within thirty (30) days, except where retention is required by applicable law.
11. Contact
For questions about this DPA or to exercise your data protection rights:
Terminus Financial, Inc.
Data Protection Officer
Email: dpo@terminus.finance
Regulatory Disclosures
Last Updated: March 14, 2025
1. Company Information
- Legal Name: Terminus Financial, Inc.
- State of Incorporation: Delaware, United States
- Registered Address: Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 10151, Estonia
- Business Type: Financial Technology Company
- Services: Crypto-native payments, swap services, and prepaid Visa debit card issuance
2. Regulatory Registration
- FinCEN: Registered as a Money Services Business (MSB) with the Financial Crimes Enforcement Network under the Bank Secrecy Act
- State Licenses: Licensed or exempt as a money transmitter in applicable U.S. states and territories
- Visa Network: Card programs operated under license from Visa International Service Association through authorized issuing bank partners
3. Risk Disclosures
3.1 Cryptocurrency Risk
- Cryptocurrency values are highly volatile and can fluctuate significantly in a short period;
- You may lose some or all of the value of your cryptocurrency holdings;
- Past performance is not indicative of future results;
- Cryptocurrency markets operate 24/7 and prices can change at any time;
- Regulatory changes may adversely affect the value, use, or transfer of cryptocurrency.
3.2 No FDIC Insurance
Cryptocurrency held in your Terminus wallet is NOT insured by the Federal Deposit Insurance Corporation (FDIC), the Securities Investor Protection Corporation (SIPC), or any other government insurance program. Your cryptocurrency holdings are not covered by deposit insurance.
3.3 No Investment Advice
Terminus does not provide investment, financial, tax, or legal advice. Nothing on our platform or communications constitutes a recommendation to buy, sell, hold, or trade any cryptocurrency or financial instrument. You should consult your own financial, legal, and tax advisors before making any decisions.
3.4 Conversion Risk
When you use your Terminus Card, cryptocurrency is converted to fiat currency at the prevailing exchange rate. The rate includes a spread and may differ from rates available on other platforms. The final amount charged may differ from the amount shown at the time of transaction authorization due to rate fluctuations during settlement.
3.5 Technology Risk
- Blockchain networks may experience congestion, delays, or downtime;
- Smart contracts may contain vulnerabilities;
- Internet connectivity is required to access services;
- System outages or technical errors may temporarily prevent access to your account or funds.
4. Fee Disclosure
Terminus is committed to transparent pricing. All fees are disclosed in our Cardholder Agreement and within the application before any transaction is confirmed. Key fee disclosures include:
- No hidden fees for domestic or international purchases;
- Exchange rate spreads are disclosed at the time of each transaction;
- ATM withdrawal fees are clearly displayed before confirmation;
- Fee changes will be communicated with at least 30 days' advance notice.
5. Prohibited Activities
Terminus services may not be used for any illegal purpose or in connection with:
- Money laundering or terrorist financing;
- Sanctions evasion;
- Fraud or deception;
- Purchase of illegal goods or services;
- Any activity that violates applicable law or Visa network rules.
6. Restricted Jurisdictions
Terminus services are not available to residents or citizens of the following jurisdictions:
- Countries subject to comprehensive U.S. sanctions (including but not limited to Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions);
- Jurisdictions where our services would require a license we do not hold;
- Any jurisdiction where the use of cryptocurrency is prohibited by law.
This list is subject to change based on regulatory developments. It is your responsibility to ensure that your use of Terminus services complies with local laws.
7. Intellectual Property
- "Terminus" and the Terminus logo are trademarks of Terminus Financial, Inc.;
- "Visa" is a registered trademark of Visa International Service Association and is used under license;
- All other trademarks appearing on our platform are property of their respective owners.
8. Advertising Disclaimer
All promotional materials, advertisements, and marketing communications from Terminus are for informational purposes only and do not constitute an offer, solicitation, or recommendation to purchase any financial product. Product availability, features, and terms may vary by jurisdiction.
9. Dispute Resolution
Any disputes arising from or relating to the use of Terminus services are subject to binding arbitration as described in our Terms of Service. You may also file a complaint through our Complaint Handling Policy for resolution.
10. Contact
Terminus Financial, Inc.
Compliance Department
Email: compliance@terminus.finance
Website: terminus.finance
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