Terms of Service

These Terms of Service (the "Terms" or "Agreement") form a legally binding contract between Contegen Tech Limited, a company incorporated in Hong Kong SAR with company number 79156927 and registered office at Room 602, 6/F, Kai Yue Comm Building, Mongkok, Kowloon, Hong Kong SAR, operating as "Nalo" ("we", "us", "our", "Nalo"), and you, the user of the Nalo mobile application and related services ("you", "your").

Please read these Terms carefully before using the App. By creating an Account or using the Services, you agree to be bound by these Terms and by our Privacy Policy, which forms an integral part of this Agreement.

1. Overview of Services

Nalo is a software platform. Through the Nalo mobile application (the "App") we provide the following Services:

1.1 Self-Custodial Wallet

The App allows you to create and manage a self-custodial digital wallet for supported digital assets on supported public blockchain networks, as displayed in the App from time to time (the "Wallet"). You maintain sole control over your private keys and digital assets. Nalo does not have access to your private keys, cannot move your digital assets, and does not act as a custodian of the digital assets held in your Wallet. Only you can authorize transactions from your Wallet.

1.2 Transfers Between Nalo Users and On-Chain Transfers

You may send supported digital assets from your Wallet to other Nalo users within the App, or to external wallet addresses on supported blockchain networks. Such transactions are executed on public blockchains and are irreversible once confirmed on the relevant network. You are solely responsible for verifying the recipient, the wallet address, and the selected network before authorizing a transaction. Digital assets sent to an incorrect address, an unsupported asset type, or an unsupported network may be permanently lost, and Nalo has no ability to reverse, recover, or refund such transactions.

1.3 Money Transfer Service

The App allows you to initiate international money transfers to recipients in supported destination countries (each a "Transfer"). Transfers are funded in fiat currency using supported payment methods displayed in the App and are executed and paid out to the recipient by licensed third-party payment partners of Nalo ("Payment Partners"). Nalo acts as a technology platform: we provide the software interface, collect your payment for the sole purpose of onward settlement with the relevant Payment Partner, and coordinate execution of the Transfer with that Payment Partner. The payout to your recipient is performed by the Payment Partner under its own licenses and regulatory permissions.

Funds you pay to us in connection with a Transfer are received exclusively for onward settlement of that Transfer. We do not accept deposits, do not pay interest, and do not provide banking services. Nalo does not itself hold regulatory licenses for payment services and relies on licensed Payment Partners for the execution of Transfers.

1.4 Third-Party Services

Certain features (such as payment processing, identity verification, and Transfer payout) are provided by independent third parties and are subject to their own terms and policies. Where relevant, such third parties will be identified in the App or their terms presented to you before you use the relevant feature. We are not responsible for the acts or omissions of independent third parties, except as required by applicable law.

2. Acceptance of and Updates to the Terms

By creating an Account and using the Services, you agree to comply with these Terms. If you do not agree with any part of these Terms, you must stop using the Services and close your Account.

We may amend these Terms from time to time, including to reflect changes in law, in our Services, or in our partners. We will notify you of material changes through the App and/or by email before they take effect. Your continued use of the Services after the effective date of the updated Terms constitutes acceptance of the updated Terms. If you do not accept the updated Terms, you may close your Account before the effective date.

3. Eligibility and Restricted Jurisdictions

To use the Services, you confirm that:
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- you are at least 18 years old or have reached the legal age of majority in your country of residence;
- you have not previously been banned or restricted from using the Services;
- entering into this Agreement does not breach any other legal obligation binding on you;
- you are not located in, resident in, or a national of any jurisdiction subject to comprehensive sanctions or embargoes applicable to us or our partners, including sanctions administered by Hong Kong authorities or under United Nations Security Council resolutions (including the Democratic People’s Republic of Korea (North Korea)); and
- you are not subject to, and are not owned or controlled by, and do not act on behalf of, any person or entity subject to applicable international sanctions.

If you use the Services on behalf of a legal entity, you additionally confirm that the entity is duly incorporated and in good standing, that you are authorized to bind it, and that the entity meets the sanctions-related criteria above.

We may assess and re-assess your eligibility at any time and may request supporting documentation. We may refuse, suspend, or restrict access to the Services where eligibility requirements are not met. The list of supported destination countries and payment corridors for Transfers is displayed in the App and may change at any time.

4. Account

4.1 Account Creation

Creating an Account is required to access the Services. You confirm that you are registering the Account for your own use. You must provide accurate, current, and complete information during registration and keep it up to date.

4.2 Single Account Policy

Each user may maintain only one Account. Additional Accounts created using information already associated with an existing Account may be suspended or closed.

4.3 Third-Party Authorization

If a third party (such as a legal representative) acts on your behalf, we may require proof of authority (for example, a power of attorney). Actions taken by an authorized third party are deemed taken with your approval and do not relieve you of your obligations under these Terms.

4.4 Account Closure by You

You may close your Account at any time. Before closure, you must withdraw all digital assets from your Wallet and ensure that no Transfers are pending. Because your Wallet is self-custodial, we cannot access or return digital assets after Account closure if you have lost your keys or backup data.

4.5 Suspension or Termination by Us

We may suspend, restrict, or terminate your Account and access to the App where:
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- we are required to do so by law, a court order, a regulator, or a law enforcement authority;
- we reasonably suspect a violation of these Terms, fraud, money laundering, terrorist financing, sanctions violations, or other financial crime;
- we reasonably suspect unauthorized access to your Account or a security breach affecting your Account;
- a transaction appears erroneous, or your Account is subject to litigation, investigation, or elevated regulatory risk; or
- your use of the Services creates material legal, regulatory, or reputational risk for us or our partners.

Where your Account is suspended or terminated, pending Transfers may be paused, cancelled, or refunded. Where permitted by law, we will explain the reason for the action and, where applicable, how to remedy it. Suspension or termination of your Account does not affect your control over the digital assets in your self-custodial Wallet: because you hold the private keys, you retain access to your digital assets at all times. Even if your access to the App is suspended or terminated, you may export your private keys directly through our wallet infrastructure provider, Privy, at https://home.privy.io/login, and continue to manage your digital assets outside the App.

5. Identity Verification (KYC) and AML Compliance

5.1 Verification

Access to the Money Transfer Service and certain other features requires completion of identity verification (Know Your Customer, "KYC") and anti-money-laundering ("AML") checks. We collect identification information and documents from you for this purpose and may engage third-party identity verification providers. Verified information may be screened against sanctions, AML, and politically exposed person (PEP) lists. Personal data collected in this process is handled in accordance with our Privacy Policy.

5.2 Accuracy of Information

You confirm that all information and documents you provide are true, accurate, and complete, and that you have not withheld or altered information to affect the outcome of verification. You must promptly notify us of any changes affecting the accuracy of information you have provided and supply updated information on request. If information is found to be false, inaccurate, or incomplete, we may suspend the affected Services until the issue is resolved.

5.3 Compliance Holds and Reporting

We and our Payment Partners may delay, decline, or reverse a Transfer or transaction, and may request additional information about you, your recipient, the source of funds, or the purpose of a transaction, where required for compliance with applicable law. We may disclose information to competent authorities where we are required to do so or where we reasonably suspect fraud, money laundering, terrorist financing, sanctions violations, or other financial crime.

6. Money Transfers

6.1 Initiating a Transfer

To initiate a Transfer, you must specify the payout details of the recipient requested in the App, the amount, and the payment method. Before you confirm a Transfer, the App will display the applicable exchange rate (where a currency conversion applies), all fees payable by you, and the amount to be delivered to the recipient. By confirming the Transfer, you accept these amounts.

6.2 Recipient Details

You are solely responsible for the accuracy and completeness of the recipient details you provide. You confirm that you are lawfully entitled to provide the recipient’s personal data to us and to the Payment Partner for the purpose of executing the Transfer. Neither Nalo nor the Payment Partner is obliged to verify that the payout details correspond to the intended recipient. Funds paid out in accordance with the details you provided are deemed properly delivered, even if the details were incorrect.

6.3 Execution and Delivery Times

Payout to the recipient is performed by the relevant Payment Partner. Estimated delivery times shown in the App are indicative and not guaranteed; actual times depend on the payment method, the destination, the recipient’s bank or provider, compliance checks, and other factors outside our control.

6.4 Cancellations and Refunds

You may request cancellation of a Transfer only if payout to the recipient has not yet been executed. Where a Transfer is cancelled by you (where possible), declined for compliance reasons, or cannot be completed, we will refund the amount paid by you to your original payment method, less any third-party costs that we are unable to recover, unless applicable law requires otherwise. Once a payout has been made to the recipient, the Transfer cannot be reversed by us.

6.5 Limits

Transfers are subject to limits (including per-transfer and periodic limits) displayed in the App. Limits depend on the destination, payment method, and the outcome of our compliance procedures, and may be adjusted by us in accordance with our internal policies and applicable law.

6.6 Declined Transfers

A Transfer may be declined or delayed due to compliance requirements, technical issues, limits, unavailability of a Payment Partner or corridor, or suspicion of fraud or error. Where a Transfer cannot be completed, we will notify you and process a refund in accordance with Section 6.4.

7. Digital Assets and On-Chain Transactions

Transactions on public blockchains are executed by the relevant network, not by Nalo, and are irreversible once confirmed. Network fees may apply and are not controlled by us. Supported assets and networks are displayed in the App and may change; you are responsible for checking that an asset and network are supported before sending or receiving. Digital assets are subject to technology, market, and regulatory risks, and their value may fluctuate. Nalo does not provide exchange, brokerage, or investment services in respect of digital assets and does not give investment advice.

8. Fees

Fees applicable to a Transfer or other transaction are displayed in the App before you confirm the transaction. Fees applicable to third-party services are presented by the relevant provider or in the App. We may change our fee structure; material changes will be notified through the App and/or by email at least one week before taking effect. Your continued use of the Services after the effective date constitutes acceptance of the updated fees.

9. Prohibited Use

You must not use the Services to:
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- violate any applicable law or regulation, including AML, counter-terrorist financing, and sanctions laws;
- defraud, deceive, or mislead Nalo, our partners, or any third party;
- send or receive funds or digital assets derived from, or intended for, unlawful activity;
- make Transfers on behalf of undisclosed third parties or operate as an unlicensed money services business;
- compromise the security or integrity of the App or our systems, including through unauthorized automation, malware, denial-of-service, or unauthorized access; or
- infringe Nalo’s or any third party’s intellectual property rights.

We may suspend or terminate Accounts engaged in prohibited use and may report such activity to competent authorities.

10. Liability

10.1 Limitation of Liability

To the fullest extent permitted by law, and except as expressly stated otherwise in these Terms, Nalo disclaims liability for indirect, incidental, special, or consequential losses, loss of profits, or loss of data arising from your use of the Services. Nothing in these Terms limits or excludes liability that cannot be limited or excluded under applicable law, including liability for fraud or for death or personal injury caused by negligence.

Nalo is not liable for losses arising from: your loss of private keys or backup data; transactions authorized from your Wallet; incorrect recipient details or wallet addresses provided by you; the acts or omissions of banks, payment systems, blockchain networks, or other systems outside our control; or events of Force Majeure.

10.2 Disputes Between Users

Disputes between you and other users, or between you and your recipients, must be resolved between the parties involved. Nalo and its affiliates, partners, officers, directors, employees, and representatives are not liable for claims arising from such disputes.

10.3 Indemnification

You agree to indemnify and hold harmless Nalo, its affiliates, partners, service providers, officers, directors, employees, and representatives from claims, losses, costs, and expenses (including reasonable legal fees) arising from your breach of these Terms, your violation of applicable law, or your misuse of the Services.

11. Disclaimer of Warranties

The App and the Services are provided on an "as is" and "as available" basis, without warranties of any kind, express, implied, or statutory, including warranties of merchantability, fitness for a particular purpose, or non-infringement, to the extent permitted by law. We do not warrant that access to the App will be continuous, uninterrupted, or error-free.

Information provided in or through the App is for informational purposes only and does not constitute investment, financial, tax, or legal advice. You are responsible for seeking independent professional advice where needed.

12. Personal Data Protection

We collect, use, and share personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and, where applicable, other data protection laws. Our practices, including the categories of data we collect, the purposes of processing, data sharing (including with Payment Partners and identity verification providers), international transfers, retention, and your rights as a data subject, are set out in our Privacy Policy, which forms an integral part of these Terms. By agreeing to these Terms, you acknowledge that your personal data will be processed as described in the Privacy Policy.

13. Security

You are solely responsible for safeguarding your login credentials, private keys, passphrases, backup data, and devices. Because your Wallet is self-custodial, loss of your keys or backup data may result in permanent loss of access to your digital assets, and Nalo cannot restore them. If you suspect unauthorized access to your Account or any security incident, you must notify us immediately at yo@naloapp.co.

14. Complaints and Dispute Resolution

If you have a complaint about the Services, please contact our support team through the App or at yo@naloapp.co. We will acknowledge your complaint and aim to resolve it promptly. Complaints relating to a payout performed by a Payment Partner may be referred to, or handled together with, the relevant Payment Partner.

If a complaint cannot be resolved amicably, any dispute arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of Hong Kong SAR, without prejudice to any mandatory consumer protection rights available to you under the laws of your country of residence.

15. Communications

We communicate with you through the App (including push and in-app notifications), by email, and through our official website and social media channels. Legally significant notices (including changes to these Terms and fee changes) will be provided through the App and/or by email.

16. Intellectual Property

All materials and content related to Nalo, the App, and the Services are protected by applicable intellectual property laws. You are granted a limited, personal, non-transferable, non-commercial license to use the App and its content solely in connection with the Services. Any use beyond this scope requires our prior written consent.

17. Force Majeure and Sanctions

Nalo is not liable for failures or delays in performance caused by events beyond our reasonable control, including natural disasters, epidemics, acts of war or terrorism, acts of authorities, sanctions, economic blockades, strikes, and failures of software, hardware, communication lines, blockchain networks, or third-party services ("Force Majeure").

If you become subject to applicable international, supranational, or national sanctions, we may terminate these Terms and close your Account without prior notice, and pending Transfers may be cancelled, frozen, or reported as required by law.

18. Final Provisions

18.1 Governing Law and Jurisdiction

These Terms and the relationship between you and Nalo are governed by the laws of Hong Kong SAR. Subject to Section 14, disputes are subject to the exclusive jurisdiction of the Hong Kong courts.

18.2 Taxes

You are responsible for determining and fulfilling any tax obligations arising from your use of the Services. Nalo does not provide tax advice and is not responsible for tax withholding, reporting, or collection on your behalf, unless required by applicable law.

18.3 Entire Agreement; Severability

These Terms, together with the Privacy Policy and any other terms expressly incorporated, constitute the entire agreement between you and Nalo and supersede prior discussions and representations. If any provision is held invalid or unenforceable, the remaining provisions remain in full force, and the invalid provision will be replaced with a valid provision reflecting its intent as closely as possible.

18.4 Assignment; Change of Control

You may not assign your rights under these Terms without our consent. We may assign these Terms in connection with a merger, acquisition, or transfer of business; in such cases your data may be transferred to the successor entity in accordance with the Privacy Policy and applicable law.

18.5 Language

These Terms are drafted in English. Translations are provided for convenience only; the English version prevails in case of discrepancy.

18.6 Survival

Provisions which by their nature should survive termination (including Sections 10, 11, 12, 14, 16, and 18) survive the termination of these Terms.