Terms & Conditions

These Terms and Conditions govern your access to and use of dap, including the dap website, mobile application, web application, account features, wallet features, payment features, card features, transfer features, savings features, trading access, referral programme, Founder Access programme, rewards, promotions, software, interfaces, content, and any other services made available by dap from time to time.

dap is currently a UK-based product and is not yet incorporated as a separate legal entity. Until a separate dap legal entity is incorporated or appointed as operator, the Services are operated by Justin Kirk, trading as dap. References to “dap”, “Company”, “we”, “us”, or “our” refer to Justin Kirk trading as dap until the Services are transferred to a separate dap legal entity or another appointed operating entity.

Until a separate dap legal entity is incorporated or appointed as operator, dap may operate pre-launch, early access, waitlist, Founder Access, referral, promotional, and app testing features. Wallet, card, fiat on-ramp, fiat off-ramp, trading, savings, yield, and other Partner-provided regulated services will only be made available where they are provided by an appropriate Partner, supported by an appropriate legal entity, or otherwise permitted under applicable law.

Once incorporated or appointed, references to “dap”, “Company”, “we”, “us”, or “our” may refer to the dap legal entity that is incorporated, or any successor, affiliate, or appointed entity responsible for operating the Services.

By creating an Account, accessing the Platform, clicking “I accept”, connecting a Wallet, using any Services, joining Founder Access, using a referral code, applying for a Card, initiating a transfer, using a dap-to-dap payment, using a savings feature, accessing trading functionality, using Spin the Wheel, or continuing to use the Platform, you confirm that you have read, understood, and agreed to these Terms, our Privacy Policy, the Spin the Wheel Rules, and any additional terms that apply to specific Services.

If you do not agree to these Terms, you must not access or use dap.

1Important Statement

dap is a technology platform. dap is not a bank.

Unless expressly stated otherwise by a regulated Partner, your dap Account is not a bank account, deposit account, stored value account, e-money account, securities account, brokerage account, investment account, or protected savings account.

Digital Assets, stablecoins, wallet balances, yield positions, trading positions, vault positions, card balances, promotional credits, rewards, and other assets used through dap may not be protected by any deposit insurance scheme, investor compensation scheme, financial services compensation scheme, government guarantee, or equivalent protection.

Some services may be provided by third-party Partners. Those services are subject to the applicable Partner’s own terms, eligibility criteria, verification requirements, fees, limits, risk controls, service availability, and regulatory obligations.

dap does not directly perform KYC. Certain Partners may require identity verification, business verification, sanctions screening, fraud checks, source of funds checks, wallet screening, or other checks for certain Partner-provided functions, including card issuance, fiat on-ramp, fiat off-ramp, and other Partner-provided regulated services.

Standard dap account use, dap-to-dap transfers, trading access, and savings or yield access are designed to operate without dap directly performing KYC, unless a Partner-provided regulated service, applicable law, security requirement, or fraud prevention requirement applies.

2Definitions

In these Terms, the following definitions apply.

2.1 Acceptable Assets — the Digital Assets, stablecoins, fiat currencies, or other assets that dap or its Partners support from time to time.

2.2 Account — your dap user account, profile, username, wallet access profile, app account, or other user identity created or used through the Platform.

2.3 App — the dap mobile application.

2.4 Assisted Custody — any wallet or account access flow where dap or a Partner provides account abstraction, embedded wallet access, key recovery, phone number login, social login, recovery assistance, multi-party computation, threshold signature controls, smart contract wallet access, or any similar user assistance mechanism.

2.5 Card — any virtual, physical, tokenised, prepaid, debit, credit, charge, or other payment card made available through dap by a Card Issuer or other Partner.

2.6 Card Data — the card number, expiry date, security code, PIN, card token, device credential, network token, or other credential relating to a Card.

2.7 Card Issuer — the regulated institution or Partner responsible for issuing the Card.

2.8 Card Network — Visa, Mastercard, or any other payment network applicable to the Card.

2.9 Card Transaction — any transaction, authorisation, pre-authorisation, refund, chargeback, reversal, ATM withdrawal, online purchase, in-store purchase, contactless payment, wallet payment, recurring payment, subscription payment, or other transaction made using a Card.

2.10 Content — any text, data, software, graphics, designs, images, information, documentation, interfaces, analytics, branding, icons, artwork, videos, audio, charts, pricing data, rates, yield displays, transaction records, code, or other material made available through dap.

2.11 dap-to-dap Transfer — a transfer, payment, remittance, or value movement between dap users, whether settled on-chain, off-chain, through internal ledger entries, through a Partner, through supported infrastructure, or through a combination of these methods.

2.12 Digital Assets — cryptocurrencies, stablecoins, tokens, on-chain assets, tokenised assets, vault tokens, receipt tokens, wrapped assets, synthetic assets, or any other digital representation of value.

2.13 Founder Access — any early access, founder pass, founder number, username reservation, referral reward, golden ticket, streak reward, spin feature, prize, fee credit, promotional benefit, card benefit, or other launch-related benefit made available by dap.

2.14 Instructions — any instruction, request, action, approval, transaction, signature, order, authorisation, consent, message, API call, wallet interaction, smart contract interaction, or other command submitted through your Account, Wallet, device, credentials, or authorised session.

2.15 Partner — any third-party provider, card issuer, custodian, on-ramp provider, off-ramp provider, bank, e-money institution, stablecoin issuer, liquidity provider, blockchain protocol, bridge, trading venue, wallet provider, KYC provider, KYT provider, sanctions screening provider, fraud prevention provider, cloud provider, data provider, payment infrastructure provider, or other third party used in connection with the Services.

2.16 Platform — the dap website, App, web app, APIs, smart contract interfaces, wallet interfaces, dashboards, internal systems, and any other technology made available by dap.

2.17 Promotional Reward — any reward, prize, credit, cash reward, referral-related reward, golden ticket, access perk, fee credit, account credit, campaign reward, streak reward, Spin the Wheel reward, or other benefit made available through dap.

2.18 Restricted Jurisdiction — any country, region, territory, state, province, or jurisdiction where dap or a Partner does not offer the Services, where use of the Services would be unlawful, or where dap determines that legal, regulatory, sanctions, commercial, risk, or operational reasons require restriction.

2.19 Self-Custody — a wallet model where you control the private keys, seed phrase, signing authority, recovery credentials, or transaction approvals for a Digital Asset wallet.

2.20 Services — the Platform and all services, features, tools, products, Content, software, applications, and functions made available through dap from time to time.

2.21 Spin the Wheel — dap’s free promotional reward feature that allows eligible users to interact with a charge-based wheel mechanic and receive a chance to win Promotional Rewards.

2.22 Spin the Wheel Rules — the specific rules, notices, eligibility requirements, limits, reward information, reward selection method, and disclosures shown in the App for Spin the Wheel from time to time.

2.23 Stablecoin — a Digital Asset designed, marketed, or represented as being linked to the value of a fiat currency or other reference asset.

2.24 Supported Chain — any blockchain network, layer 1, layer 2, appchain, rollup, bridge, or smart contract environment supported by dap from time to time.

2.25 Third-Party Service — any service, application, protocol, smart contract, wallet, payment rail, exchange, liquidity venue, lending market, bridge, validator, card programme, verification service, screening service, on-ramp, off-ramp, or other service provided by a Partner or other third party.

2.26 User — “User”, “you”, and “your” means the person or legal entity accessing or using dap.

2.27 Wallet — any Self-Custody wallet, Assisted Custody wallet, embedded wallet, smart contract wallet, app wallet, payment wallet, vault address, deposit address, withdrawal address, or other address used in connection with dap.

3Acceptance of Terms

You agree to these Terms by:

1. creating an Account;
2. accessing or using the Platform;
3. connecting a Wallet;
4. applying for or using a Card;
5. initiating any transaction;
6. depositing, withdrawing, swapping, spending, lending, borrowing, trading, or transferring assets;
7. joining Founder Access;
8. using a referral code;
9. using Spin the Wheel;
10. claiming or attempting to claim a Promotional Reward;
11. clicking any acceptance button;
12. continuing to use dap after these Terms are made available.

Your acceptance has the same legal effect as a written agreement signed by you.

4Eligibility

You may use dap only if:

1. you are at least 18 years old, or the age of majority in your jurisdiction if higher;
2. you have legal capacity to enter into binding contracts;
3. you are using dap for yourself or are authorised to bind the entity you represent;
4. you are not located in, ordinarily resident in, incorporated in, or organised under the laws of a Restricted Jurisdiction;
5. you are not subject to sanctions, asset freezes, trade restrictions, or denied party lists;
6. you have not previously been suspended, removed, or banned from dap;
7. you are not using dap on behalf of another person unless authorised and approved by dap;
8. your use of dap complies with all laws applicable to you;
9. all assets used through dap are owned by you or you are legally authorised to use them;
10. you will provide accurate, complete, and current information when requested.

dap may refuse, suspend, limit, or terminate access at any time where eligibility is not satisfied, cannot be verified, or becomes subject to legal, compliance, risk, security, fraud, or operational concerns.

5Nature of dap Services

dap may provide access to some or all of the following Services:

1. Account creation and username reservation;
2. Self-Custody Wallet access;
3. Assisted Custody Wallet access;
4. global USD-denominated account displays;
5. Stablecoin deposits, withdrawals, transfers, and spending;
6. dap-to-dap Transfers;
7. remittance features;
8. Card application, Card management, and Card Transaction access;
9. NFC or contactless payment functionality;
10. on-ramp and off-ramp access through Partners;
11. swaps and asset conversion through Partners, protocols, or liquidity providers;
12. savings, yield, lending, vault, or Earn features;
13. trading access through supported venues;
14. borrowing, leverage, collateral, and liquidation-related features;
15. transaction history, analytics, and portfolio displays;
16. Founder Access, referrals, golden tickets, streaks, Spin the Wheel, prize campaigns, and Promotional Rewards;
17. customer support and account recovery flows;
18. other features introduced by dap from time to time.

dap may add, remove, suspend, restrict, modify, rename, re-price, or discontinue any Service at any time.

6dap as a Technology Interface

dap provides software, interfaces, account tools, wallet tools, routing tools, and access points to certain third-party and on-chain services.

Unless expressly stated in writing:

1. dap does not act as your bank;
2. dap does not act as your broker;
3. dap does not act as your investment adviser;
4. dap does not act as your tax adviser;
5. dap does not act as your legal adviser;
6. dap does not act as your fiduciary;
7. dap does not act as your trustee;
8. dap does not guarantee any asset, yield, trade, payment, withdrawal, price, rate, execution, or settlement;
9. dap does not insure your assets;
10. dap does not guarantee the solvency, performance, availability, or compliance of any Partner, protocol, Card Issuer, stablecoin issuer, custodian, trading venue, blockchain, smart contract, or reward provider.

7Partner Services

Certain Services are provided by Partners. These may include: Card issuance; Card processing; fiat on-ramping; fiat off-ramping; bank transfers; custody; wallet infrastructure; verification, screening, and fraud prevention; Stablecoin issuance and redemption; liquidity provision; swaps; trading execution; lending, borrowing, and yield protocols; bridging; analytics, data, and pricing feeds; reward fulfilment; other Partner-provided functions.

Partner Services are subject to the relevant Partner’s own terms, privacy policies, fees, limits, processing times, checks, and eligibility criteria.

You authorise dap to transmit your information, Instructions, transaction data, Wallet addresses, and relevant risk or security information to Partners where required to provide the Services.

dap is not responsible for any Partner’s acts, omissions, delays, refusal to process, insolvency, fees, rates, downtime, decisions, chargeback decisions, card decisions, settlement failures, smart contract failures, custody failures, reward fulfilment failures, or operational failures.

8Account Registration

You may need to create an Account to use dap. You agree to:

1. provide accurate and complete information;
2. keep your information up to date;
3. use only one Account unless dap approves otherwise;
4. keep your login credentials secure;
5. protect your device, email, phone number, recovery method, Wallet, and authentication method;
6. notify dap immediately of unauthorised access or suspected compromise;
7. use dap only for lawful purposes;
8. comply with all lawful verification, security, and fraud prevention requests.

dap may refuse to open an Account, approve an Account, activate an Account, issue a username, reserve a username, provide Founder Access, allow Spin the Wheel access, or make any Service available.

9Username, Identity, and Founder Number

dap may allow you to reserve or use a username, handle, founder number, referral code, or other user identifier.

dap may reclaim, suspend, rename, restrict, or cancel any username, founder number, referral code, or identifier if:

1. it infringes third-party rights;
2. it impersonates another person or brand;
3. it is offensive, misleading, abusive, unlawful, or deceptive;
4. it is used for fraud, spam, market abuse, or referral manipulation;
5. it creates security, legal, reputational, or operational risk;
6. it was obtained through automation, abuse, exploit, or breach of these Terms.

A username, founder number, referral code, streak, Spin the Wheel reward, golden ticket, or Founder Access benefit does not create property rights unless dap expressly states otherwise in writing.

10Account Security

You are responsible for all activity under your Account, Wallet, device, session, credentials, and authentication methods.

Any Instruction submitted through your Account, Wallet, device, credentials, passkey, recovery method, biometric authentication, or authorised session may be treated as authorised by you.

dap may rely on Instructions without additional verification. You are responsible for:

1. keeping your password, passkey, seed phrase, private key, recovery phrase, device, email account, phone number, SIM card, and authentication method secure;
2. ensuring your device is updated and protected;
3. verifying transaction details before approving them;
4. ensuring Wallet addresses are correct;
5. ensuring supported networks and assets are selected;
6. reviewing fees, rates, slippage, limits, and risks before confirming;
7. monitoring your Account for unauthorised activity.

dap is not responsible for losses arising from compromised credentials, compromised devices, phishing, malware, SIM swap, social engineering, malicious links, wallet-draining approvals, incorrect addresses, incorrect networks, mistaken Instructions, or unauthorised use of your Account.

11Self-Custody Wallets

Where you use a Self-Custody Wallet:

1. you control your private keys or signing authority;
2. dap does not control your private keys;
3. dap cannot recover private keys, seed phrases, or lost assets;
4. dap cannot reverse blockchain transactions;
5. dap cannot guarantee access to any wallet provider;
6. dap cannot prevent losses caused by your wallet approvals, signatures, or transactions.

You are solely responsible for the security, backup, recovery, and use of any Self-Custody Wallet.

12Assisted Custody and Embedded Wallets

dap may offer Assisted Custody or embedded wallet functionality through dap or Partners.

Assisted Custody may use technology such as account abstraction, social login, passkeys, multi-party computation, threshold signatures, TSS committees, recovery flows, smart contract wallets, or delegated signing.

You acknowledge that Assisted Custody may involve additional operational, technical, security, legal, and Partner risks.

dap may suspend, delay, reject, or restrict Assisted Custody access or recovery where required for security, fraud prevention, legal process, or operational integrity.

dap does not guarantee that recovery will be available in all cases.

13Digital Assets and Stablecoins

Digital Assets and Stablecoins involve significant risk. You acknowledge that:

1. Digital Assets may be volatile;
2. Stablecoins may lose their peg;
3. Stablecoin issuers may fail, freeze, blacklist, delay, or refuse redemption;
4. blockchains may experience congestion, forks, reorgs, downtime, exploits, validator failure, governance attacks, or censorship;
5. smart contracts may contain bugs or vulnerabilities;
6. bridge assets may lose value or become unredeemable;
7. supported assets may be removed at any time;
8. a transaction sent to an unsupported asset, unsupported network, wrong address, or wrong contract may be permanently lost.

dap may decide which assets are supported. dap may add, remove, suspend, limit, or restrict any asset at any time.

14Deposits, Withdrawals, and Transfers

You must follow the instructions shown in the Platform when depositing, withdrawing, or transferring assets.

dap may reject, delay, freeze, review, return, or restrict deposits, withdrawals, or transfers where:

1. the asset is unsupported;
2. the network is unsupported;
3. required confirmations are incomplete;
4. the transaction is suspicious;
5. there are sanctions, AML, KYT, fraud, chargeback, or legal concerns;
6. the transaction appears erroneous, duplicated, manipulated, or abusive;
7. the transaction creates security, legal, market, liquidity, or operational risk;
8. a Partner, protocol, issuer, custodian, chain, bridge, or liquidity venue requires restriction.

Processing times are not guaranteed. Blockchain transactions may be irreversible.

dap may charge fees for deposits, withdrawals, transfers, conversions, card use, off-ramping, on-ramping, account activity, inactivity, recovery, network usage, or Partner services.

15dap-to-dap Transfers and Remittance

dap may support dap-to-dap Transfers or remittance features. Such transfers may be settled: on-chain; off-chain; through internal ledger entries; through a Stablecoin; through a Partner; through supported infrastructure; through a combination of the above.

dap-to-dap Transfers may be subject to limits, fraud checks, supported corridor restrictions, currency availability, liquidity availability, processing delays, reversals, recalls, and Partner terms.

Where dap describes a transfer as “free”, “fee-free”, or “free remittance”, this refers only to dap’s own platform fee unless expressly stated otherwise. Third-party charges, network fees, foreign exchange spreads, Stablecoin spreads, card fees, bank fees, intermediary fees, and Partner fees may still apply.

16On-Ramp and Off-Ramp Services

dap may allow you to access fiat-to-crypto and crypto-to-fiat services through Partners.

dap does not guarantee that any on-ramp or off-ramp will be available, approved, processed, completed, or completed within a particular time.

On-ramp and off-ramp transactions may be subject to: Partner terms; Partner identity checks; screening checks; fraud checks; sanctions checks; payment method checks; bank or card issuer checks; transfer limits; exchange rates; spreads; network fees; processing delays; reversals; chargebacks; failed payments; asset availability.

dap is not responsible for losses, fees, delays, rejected transactions, frozen transactions, payment reversals, bank actions, Partner actions, or exchange rate movement relating to on-ramp or off-ramp services.

17Card Services

dap may allow eligible users to apply for, access, manage, or use a Card issued by a Card Issuer.

The Card is provided by the Card Issuer or relevant Partner, not by dap unless expressly stated.

Card use is subject to: Card Issuer approval; Card Network rules; Partner terms; eligibility checks; available balance or collateral; supported countries; transaction limits; merchant category restrictions; ATM restrictions; fraud controls; foreign exchange rules; fees and charges.

dap and its Partners may decline, suspend, block, cancel, or restrict a Card or Card Transaction at any time for legal, security, fraud, risk, operational, Card Network, issuer, or Partner reasons.

18Card Authorisations and Settlement

When you initiate a Card Transaction, dap or a Partner may place a hold, freeze, reserve, pre-authorisation, or deduction against your available balance, Stablecoins, Digital Assets, collateral, credit line, or other supported funding source.

The final settlement amount may differ from the authorised amount because of: merchant adjustments; tips; delayed settlement; foreign exchange movement; network fees; issuer fees; Partner fees; merchant category rules; refunds; chargebacks; transaction reversals; conversion rates; settlement timing.

You authorise dap and its Partners to debit, convert, reserve, liquidate, settle, or otherwise process the amount required to complete Card Transactions and related fees.

19Card Security

You must keep Card Data secure. You must not:

1. share Card Data except to complete legitimate transactions;
2. allow another person to use your Card;
3. write down or disclose your PIN;
4. use the Card for unlawful or prohibited purchases;
5. use the Card after cancellation, suspension, expiry, or closure;
6. attempt to bypass Card limits, issuer controls, or merchant restrictions.

You are responsible for all Card Transactions made using your Card, Card Data, device wallet, PIN, tokenised card, or authentication method, except where applicable law provides otherwise.

20ATM Withdrawals

Physical Cards may support ATM withdrawals where available. ATM withdrawals may be subject to: Card Issuer limits; ATM provider limits; fees; foreign exchange charges; cash availability; local law; Partner terms; security checks.

dap is not responsible for ATM provider fees, declined withdrawals, cash dispensing errors, foreign exchange movement, ATM outages, or third-party disputes.

21Chargebacks, Refunds, and Card Disputes

If you wish to dispute a Card Transaction, you must contact dap support or the relevant Partner within the time period shown in the Platform or Partner terms.

You may be required to provide: transaction details; receipts; merchant correspondence; written explanation; identity verification where required by a Partner; any information required by the Card Issuer, Card Network, Partner, or dap.

Chargebacks are subject to Card Network rules and Partner processes. dap does not guarantee that any dispute, refund, reversal, or chargeback will succeed.

dap or a Partner may debit your Account for chargeback fees, dispute fees, investigation costs, reversals, provisional credits, or amounts found to be owed by you.

22Swaps and Conversions

dap may allow you to swap, exchange, convert, or route assets through Partners, liquidity providers, decentralised exchanges, aggregators, smart contracts, or protocols.

You acknowledge that:

1. quoted prices may be estimates;
2. final execution prices may differ;
3. spreads may apply;
4. slippage may occur;
5. liquidity may be insufficient;
6. transactions may fail;
7. transactions may be delayed;
8. blockchain fees may change;
9. MEV, front-running, sandwiching, or adverse execution may occur;
10. swaps may be irreversible once submitted or confirmed;
11. Partners and protocols may apply their own fees and limits.

dap does not guarantee any swap rate, route, execution quality, execution time, price, liquidity, or settlement.

23Savings, Earn, Yield, and Lending Features

dap may provide access to savings, Earn, yield, lending, vault, or similar features.

These features may involve Digital Assets being supplied to, lent through, delegated to, routed through, or otherwise used with third-party protocols, lending markets, validators, vaults, liquidity pools, or other on-chain or off-chain venues.

Any displayed yield, APY, APR, reward, rate, projection, or estimate is variable, not guaranteed, and may change at any time.

Yield may be affected by: protocol utilisation; borrowing demand; liquidity conditions; smart contract risk; oracle risk; market risk; Stablecoin risk; liquidation risk; validator risk; slashing risk; bridge risk; governance risk; counterparty risk; Partner risk; regulatory risk; technical failure; fees and spreads.

dap does not guarantee principal, yield, liquidity, withdrawal timing, protocol performance, or loss recovery. Savings and Earn features are not bank deposits.

24Borrowing, Leverage, Margin, and Liquidation

dap may allow access to borrowing, leverage, collateral, margin, or credit-related features through Partners or protocols.

You acknowledge that:

1. borrowing rates may be variable;
2. collateral values may fluctuate;
3. collateral requirements may change;
4. liquidation thresholds may change;
5. positions may be liquidated automatically;
6. liquidation may occur quickly during volatile markets;
7. liquidation penalties, fees, and slippage may apply;
8. collateral may be sold or transferred to satisfy obligations;
9. losses may exceed initial margin where applicable;
10. protocols and Partners may change risk parameters.

dap may display information about collateral, margin, liquidation price, health factor, leverage, borrow rate, or utilisation. Such information may be delayed, incomplete, inaccurate, or based on third-party data. You are responsible for monitoring and managing your positions.

25Trading

dap may provide access to trading venues, protocols, or interfaces, including spot markets, perpetual futures, derivatives, order routing, portfolio displays, and execution tools.

dap is not a registered exchange, broker, dealer, futures commission merchant, investment adviser, or clearing house unless expressly stated in writing.

Trading involves significant risk. You may lose some or all of your assets. You are responsible for:

1. deciding whether to trade;
2. understanding the instruments traded;
3. understanding leverage and liquidation;
4. reviewing orders before submission;
5. monitoring open positions;
6. satisfying margin requirements;
7. paying applicable fees;
8. complying with all laws applicable to you;
9. keeping tax records.

dap does not guarantee execution, price, liquidity, funding rates, order book availability, venue availability, or the ability to close a position.

26Founder Access, Referrals, Streaks, Golden Tickets, Spin the Wheel, and Promotional Rewards

dap may offer Founder Access and promotional features, including founder numbers, username reservations, referral codes, waitlists, golden tickets, daily streaks, Spin the Wheel, prize wheels, fee credits, account credits, partner benefits, limited card designs, early access, and other Promotional Rewards.

All Founder Access benefits and Promotional Rewards are discretionary unless expressly stated otherwise.

dap may modify, suspend, withdraw, replace, expire, limit, or restrict any Founder Access benefit, Promotional Reward, referral feature, streak feature, golden ticket, Spin the Wheel feature, or related campaign at any time.

26.1 Founder Access Benefits

Founder Access benefits may include: early access to dap; reserved usernames; founder numbers; referral codes; limited card designs; fee credits; partner benefits; priority access to selected features; golden tickets; other benefits shown in the App.

Founder Access benefits:

1. are not cash unless expressly stated;
2. are not deposits;
3. are not securities;
4. are not transferable unless dap permits;
5. have no guaranteed resale value;
6. may expire;
7. may be subject to country restrictions;
8. may be subject to account checks;
9. may be subject to anti-abuse checks;
10. may be revoked for breach of these Terms.

You must not manipulate referrals, create fake Accounts, use bots, abuse streaks, exploit promotional mechanics, sell codes without approval, misrepresent your relationship with dap, or use Founder Access for spam, fraud, or unlawful promotion.

dap may disqualify users, revoke rewards, cancel referrals, remove streaks, cancel golden tickets, or suspend Accounts for suspected abuse.

26.2 Spin the Wheel and Promotional Rewards

dap may offer a free promotional reward feature known as “Spin the Wheel”. Spin the Wheel allows eligible users to interact with a charge-based wheel mechanic and receive a chance to win promotional rewards.

Spin the Wheel is a free promotional reward feature. It is not gambling, betting, wagering, a lottery, a casino game, or a real-money gaming product.

Users are not required to make a purchase, deposit funds, trade, subscribe, pay a fee, stake value, or complete any financial transaction to participate.

Paid spins, paid odds boosts, staking, wagering, and gambling are not offered.

Each eligible user may receive one free spin per day, unless the App expressly states that additional free promotional spins are available through referrals, streaks, campaigns, or other promotional activity.

The Spin the Wheel mechanic includes a user-controlled charge function. The charge level selected by the user may influence the spin result. The final reward is also affected by probability, participation levels, reward pool availability, campaign limits, anti-abuse controls, and other rules shown in the App.

Exact odds are not fixed and cannot be known in advance. This is because participation levels may change over time and because some rewards may be limited by reward pool availability, daily reward pools, campaign rules, or campaign limits.

Where fixed odds are not used, the reward selection method takes into account the user’s charge level, the current reward pool, participation levels, reward availability, campaign limits, and platform anti-abuse controls.

Rewards may include promotional app credits, cash rewards, referral-related rewards, golden tickets, access perks, or other benefits shown in the App.

The maximum cash reward available from a single spin is USD 1. Promotional credits and non-cash perks have no cash value unless dap expressly states otherwise. Cash rewards have only the value shown in the App.

Rewards are personal to the user and may be subject to expiry dates, usage restrictions, withdrawal restrictions, account checks, fraud checks, availability limits, and other conditions shown in the App. Rewards may not be sold, transferred, assigned, exchanged, or redeemed outside dap unless dap expressly permits this.

Spin the Wheel is subject to daily limits, Account limits, eligibility checks, technical limits, reward pool limits, and anti-abuse controls. Unless dap states otherwise, each user may participate through one Account only.

dap may withhold, reverse, cancel, or refuse to issue a reward where dap reasonably believes that a user has created duplicate Accounts, used automation, manipulated the App, exploited a technical issue, provided false information, breached these Terms, or participated in a way that is unfair to other users.

dap may update the reward pool, charge mechanic, eligibility criteria, limits, expiry periods, availability, and reward selection method from time to time. Any material changes will apply prospectively and may require users to accept updated Spin the Wheel Rules before continuing to use the feature.

Apple Inc., Google LLC, and their respective affiliates are not sponsors of, responsible for, or involved in Spin the Wheel, any reward, any prize, or any related promotion.

Users are responsible for any taxes, reporting obligations, or local legal requirements arising from their receipt or use of any reward.

Spin the Wheel is void where prohibited by law.

27Promotions and Rewards

dap may offer rewards, prizes, fee credits, cashback, benefits, partner offers, campaigns, or other promotions.

Each promotion may be subject to additional rules. dap may determine eligibility, reward value, reward timing, expiry, and fulfilment method.

Rewards may be withheld, cancelled, reversed, or clawed back where dap determines that:

1. the user breached these Terms;
2. the reward was issued in error;
3. fraud or abuse occurred;
4. eligibility requirements were not met;
5. the promotion is unavailable in the user’s jurisdiction;
6. required checks were not completed;
7. a Partner refuses fulfilment;
8. the promotion has expired;
9. the reward pool has been exhausted;
10. the user has acted unfairly or inconsistently with the spirit of the promotion.

Promotional credits and non-cash benefits have no cash value unless dap expressly states otherwise. Promotional rewards may be subject to expiry dates, usage restrictions, withdrawal restrictions, Account status requirements, country restrictions, and fraud prevention checks.

28Fees

dap and Partners may charge fees. Fees may include: subscription fees; card issuance fees; card replacement fees; ATM fees; foreign exchange fees; spreads; swap fees; network fees; gas fees; withdrawal fees; deposit fees; transfer fees; on-ramp fees; off-ramp fees; inactivity fees; recovery fees; chargeback fees; liquidation fees; borrowing fees; Partner fees.

Fees may be deducted from your Account, Wallet, balance, collateral, transaction proceeds, or charged separately. dap may update fees at any time. Fees are non-refundable unless dap determines otherwise or applicable law requires otherwise.

29Taxes

You are responsible for determining, reporting, withholding, collecting, and paying all taxes, duties, levies, and charges arising from your use of dap.

dap may provide transaction records, but dap does not guarantee that records are complete, accurate, tax-compliant, or available indefinitely.

dap may report information to tax authorities where required by law.

Users are responsible for any taxes, reporting obligations, or local legal requirements arising from the receipt, use, withdrawal, redemption, or conversion of any reward, cash reward, promotional credit, golden ticket, referral reward, or other benefit.

30Compliance, Partner Checks, AML, KYT, and Sanctions

dap does not directly perform KYC.

Certain Partners may require identity verification, business verification, Wallet screening, sanctions checks, fraud checks, source of funds checks, or other checks before they provide specific Partner Services.

Partner checks may apply to certain Partner-provided functions, including card issuance, fiat on-ramp, fiat off-ramp, and other Partner-provided regulated services.

You agree to provide all information reasonably requested by dap or a Partner where required to provide a Service, protect the Platform, prevent fraud, satisfy Partner requirements, or comply with applicable law.

dap or a Partner may refuse, delay, freeze, reverse, cancel, suspend, restrict, block, or terminate any Account, Service, transaction, Wallet, Card, transfer, reward, withdrawal, or Partner Service where legal, fraud, sanctions, security, or risk controls require it.

dap and Partners may retain information as required by law, Partner requirements, fraud prevention requirements, or internal policies.

31Restricted Jurisdictions

dap may restrict access based on jurisdiction, nationality, residence, incorporation, IP address, device location, Wallet risk, Partner requirements, or applicable law.

You must not access dap from a Restricted Jurisdiction or use tools to evade restrictions, including VPNs, proxies, false documents, nominee accounts, or false location information.

Restricted Jurisdictions may be updated at any time.

Spin the Wheel, Promotional Rewards, Cards, on-ramp, off-ramp, trading access, savings features, and other Services may be unavailable in certain jurisdictions.

32Prohibited Activities

You must not use dap to:

1. violate any law or regulation;
2. launder money;
3. finance terrorism;
4. evade sanctions;
5. commit fraud;
6. engage in market manipulation;
7. abuse promotions or referrals;
8. operate multiple Accounts without approval;
9. impersonate another person;
10. provide false information;
11. use stolen funds, stolen cards, stolen identities, or compromised Wallets;
12. send or receive proceeds of crime;
13. purchase or sell illegal goods or services;
14. engage in darknet marketplace activity;
15. fund weapons, ammunition, explosives, or controlled substances;
16. process transactions involving child exploitation, human trafficking, illegal pornography, or non-consensual content;
17. process counterfeit goods or forged documents;
18. operate Ponzi schemes, pyramid schemes, or fraudulent investment schemes;
19. conduct unauthorised gambling, betting, wagering, lotteries, or real-money gaming;
20. infringe intellectual property rights;
21. upload malware or malicious code;
22. attack, scrape, overload, reverse engineer, or disrupt the Platform;
23. bypass security controls;
24. exploit bugs, smart contracts, rewards, referrals, promotions, Spin the Wheel, or pricing errors;
25. abuse staff, support agents, Partners, or other users;
26. use dap for any activity dap determines creates legal, regulatory, financial, operational, security, or reputational risk.

dap may determine whether activity is prohibited in its sole discretion.

33Platform Licence

Subject to these Terms, dap grants you a limited, revocable, non-exclusive, non-transferable, non-sublicensable licence to access and use the Platform for your personal, lawful use.

You must not:

1. copy, modify, distribute, sell, lease, or exploit the Platform;
2. reverse engineer or attempt to extract source code;
3. remove proprietary notices;
4. build competing services using dap Content without permission;
5. use automated systems without approval;
6. interfere with Platform security or operation;
7. use dap in a way that harms dap, Partners, users, or the Services.

dap may revoke this licence at any time.

34Intellectual Property

dap owns or licenses all rights in the Platform, Content, software, brand, logos, trade names, designs, look and feel, graphics, interfaces, product names, documentation, and related intellectual property.

You may not use dap’s intellectual property without prior written permission.

You may not suggest that dap sponsors, endorses, partners with, or supports you unless dap has agreed in writing.

35User Content

You may submit usernames, profile information, support messages, feedback, comments, images, documents, transaction notes, or other content.

You represent that your User Content is lawful and does not infringe third-party rights.

You grant dap a worldwide, royalty-free, transferable, sublicensable licence to use, host, store, reproduce, display, modify, and process User Content as necessary to provide, secure, improve, and operate the Services.

36Feedback

If you provide ideas, suggestions, bug reports, designs, comments, or other feedback, dap may use them without restriction, attribution, or compensation.

37Data Protection

dap processes personal data in accordance with its Privacy Policy.

By using dap, you authorise dap to collect, use, store, disclose, and transfer personal data as required to provide the Services, prevent fraud, support transactions, work with Partners, improve the Platform, and comply with law.

dap may share information with Partners where needed to provide Partner Services, prevent fraud, satisfy Partner requirements, process rewards, or comply with applicable law.

Until a separate dap legal entity is incorporated or appointed, Justin Kirk, trading as dap, is the operator responsible for dap’s data protection obligations, unless a Partner acts as a separate controller for a Partner-provided service.

38Third-Party Links and Protocols

dap may contain links or access points to third-party websites, apps, Wallets, protocols, smart contracts, exchanges, bridges, data sources, or services.

dap does not control third-party services and is not responsible for their content, accuracy, security, legality, availability, fees, performance, or failure.

Your use of third-party services is at your own risk and subject to the relevant third-party terms.

39Availability and Changes

dap may be unavailable from time to time due to maintenance, upgrades, outages, network congestion, Partner downtime, cloud provider failure, blockchain congestion, legal restrictions, cyber incidents, or other reasons.

dap does not guarantee uninterrupted, secure, timely, or error-free access.

dap may update, suspend, discontinue, or restrict any Service at any time.

40Account Suspension and Termination

dap may suspend, restrict, freeze, close, or terminate your Account or access to any Service where:

1. you breach these Terms;
2. dap cannot verify information where verification is required;
3. dap suspects fraud, abuse, or unlawful activity;
4. dap detects security risk;
5. a Partner requires action;
6. a Card Issuer requires action;
7. a regulator, court, law enforcement body, or government authority requires action;
8. you are in a Restricted Jurisdiction;
9. you owe fees or amounts to dap or a Partner;
10. your Account is inactive;
11. your use creates legal, regulatory, reputational, financial, operational, or security risk;
12. you abuse Founder Access, referrals, Spin the Wheel, streaks, golden tickets, or Promotional Rewards.

Suspension or termination does not affect any rights, obligations, debts, fees, liabilities, or transactions accrued before termination.

41Withdrawals After Suspension or Closure

Where your Account is suspended or closed, dap may require additional checks before allowing withdrawal or transfer of assets.

Withdrawals may be delayed, restricted, or refused where required by law, Partner terms, sanctions, AML controls, fraud controls, court order, legal process, protocol restrictions, network conditions, or security concerns.

dap may deduct outstanding fees, chargebacks, reversals, penalties, costs, or amounts owed before releasing any remaining assets where permitted by law.

Promotional Rewards, credits, golden tickets, streaks, and other non-cash benefits may be cancelled on suspension or closure unless dap states otherwise.

42Dormant and Inactive Accounts

dap may classify an Account as inactive or dormant if there has been no login, transaction, or other activity for a period determined by dap.

dap may charge inactivity fees, restrict access, require reactivation, expire Promotional Rewards, expire credits, remove streaks, or close dormant Accounts where permitted by law.

43No Financial Advice

All Content provided through dap is for general information only.

Nothing on dap is financial, investment, legal, tax, accounting, trading, or other professional advice.

You must make your own decisions and obtain independent advice where appropriate.

dap does not recommend any asset, trade, strategy, protocol, yield feature, Card Transaction, Partner service, or reward feature.

44No Fiduciary Duty

These Terms do not create any fiduciary, trustee, advisory, agency, partnership, joint venture, employment, escrow, or stakeholder relationship between you and dap, except where expressly stated.

dap’s only duties are those expressly stated in these Terms.

45Risk Disclosure

You accept all risks associated with using dap, including: Digital Asset volatility; Stablecoin depegging; smart contract bugs; bridge failure; blockchain failure; protocol exploits; oracle failure; validator failure; slashing; liquidation; leverage losses; counterparty risk; Partner insolvency; custodian failure; Card Issuer failure; payment reversal; chargebacks; regulatory change; asset freezes; sanctions exposure; liquidity shortages; withdrawal delays; incorrect addresses; phishing; compromised devices; mistaken transactions; network fees; tax consequences; loss of access; total loss of assets; reward expiry; reward cancellation; app errors; campaign changes; Spin the Wheel reward pool changes.

You should use dap only if you understand and accept these risks.

46Disclaimers

To the fullest extent permitted by law, dap, the Platform, Services, Content, and all related features are provided on an “as is” and “as available” basis.

dap disclaims all warranties, whether express, implied, statutory, or otherwise, including warranties of merchantability, fitness for a particular purpose, title, accuracy, non-infringement, availability, security, uninterrupted operation, and error-free operation.

dap does not warrant that: any Service will be available; any transaction will complete; any asset will retain value; any Stablecoin will maintain its peg; any Partner will perform; any protocol will be secure; any Card Transaction will be approved; any yield will be earned; any withdrawal will process within a stated time; any Content will be accurate or complete; any reward will be available; any promotion will continue; any Spin the Wheel result will produce a particular reward; any referral, streak, golden ticket, or Founder Access benefit will remain available.

47Limitation of Liability

To the fullest extent permitted by law, dap and its affiliates, officers, directors, employees, contractors, agents, Partners, service providers, and licensors shall not be liable for: indirect, incidental, special, consequential, exemplary, or punitive damages; lost profits; lost revenue; lost business; lost opportunity; lost goodwill; loss of data; loss of assets; loss of Digital Assets; loss caused by price movement; loss caused by liquidation; loss caused by Partner failure; loss caused by protocol failure; loss caused by blockchain failure; loss caused by unauthorised access; loss caused by incorrect Instructions; loss caused by legal or compliance restrictions; loss caused by reward expiry, reward cancellation, or promotion changes; loss caused by Spin the Wheel availability, result, reward pool changes, or campaign limits.

To the fullest extent permitted by law, dap’s total aggregate liability arising out of or relating to these Terms, the Platform, or the Services shall not exceed the greater of:

1. the fees paid by you to dap for the specific Service giving rise to the claim during the three months before the claim arose; or
2. USD 500.

Nothing in these Terms limits liability that cannot lawfully be limited, including liability for fraud, wilful misconduct, or death or personal injury caused by negligence where applicable law does not permit limitation.

48Indemnity

You agree to indemnify and hold harmless dap, its affiliates, Partners, service providers, officers, directors, employees, contractors, agents, and licensors from any claim, demand, loss, liability, damages, penalties, fines, costs, and expenses, including legal fees, arising out of or related to:

1. your breach of these Terms;
2. your use of the Services;
3. your Instructions;
4. your User Content;
5. your violation of law;
6. your violation of third-party rights;
7. your fraud, negligence, misconduct, or unlawful activity;
8. your tax obligations;
9. your use of any Card;
10. your use of any Partner Service;
11. your use of any Digital Asset, protocol, smart contract, Wallet, or blockchain;
12. your use or abuse of Founder Access, referrals, streaks, golden tickets, Spin the Wheel, or Promotional Rewards.

49Complaints

You should contact dap support at admin@dap.money if you have a complaint.

You agree to provide all information reasonably required to investigate the complaint.

dap will use reasonable efforts to review complaints but does not guarantee any specific outcome.

Certain complaints relating to Cards, on-ramping, off-ramping, custody, Partner Services, or reward fulfilment may need to be handled by the relevant Partner.

50Dispute Resolution

Before commencing formal proceedings, you agree to contact dap at admin@dap.money and attempt to resolve the dispute informally.

If the dispute is not resolved within 60 days, either party may bring proceedings in the courts of England and Wales, unless a product-specific agreement or Partner agreement requires a different dispute resolution process.

Nothing prevents dap from seeking urgent injunctive, equitable, or protective relief in any competent court.

51Governing Law

Unless otherwise stated in product-specific terms, these Terms are governed by the laws of England and Wales.

The courts of England and Wales shall have jurisdiction for disputes arising out of or relating to these Terms, the Platform, or the Services.

dap may update the governing law and jurisdiction if dap is incorporated, restructured, transferred to another operating entity, or required to do so for legal, regulatory, operational, or commercial reasons.

52App Store and Google Play Terms

This section applies where you download, install, access, or use the App through the Apple App Store, Google Play, or any other app marketplace.

52.1 Apple App Store Terms

If you download or use the App through the Apple App Store, you agree that these Terms are between you and dap only, and not with Apple Inc.

Apple is not responsible for the App, the Services, maintenance, support, claims, warranties, Promotional Rewards, Spin the Wheel, or any related promotion.

dap, not Apple, is responsible for the App and for providing maintenance and support for the App to the extent required by applicable law.

Apple has no obligation to provide maintenance or support for the App.

To the maximum extent permitted by law, Apple has no warranty obligation in relation to the App. If the App fails to conform to any applicable warranty, you may notify Apple, and Apple may refund the purchase price for the App to you, if any. Apple will have no other warranty obligation in relation to the App.

dap, not Apple, is responsible for addressing any claims by you or any third party relating to the App, your possession or use of the App, product liability, consumer protection, privacy, regulatory matters, Promotional Rewards, Spin the Wheel, or any related promotion.

If a third party claims that the App or your possession and use of the App infringes that third party’s intellectual property rights, dap, not Apple, is responsible for the investigation, defence, settlement, and discharge of that claim.

The licence granted to you under these Terms is limited to a non-transferable licence to use the App on Apple-branded products that you own or control, and as permitted by Apple’s usage rules.

You must comply with all applicable third-party terms when using the App.

You represent and warrant that you are not located in a country or region subject to a United States government embargo, are not located in a country or region designated by the United States government as a “terrorist supporting” country, and are not listed on any United States government list of prohibited or restricted parties.

For questions, complaints, or claims relating to the App, including maintenance and support, you may contact dap at: Justin Kirk, trading as dap, United Kingdom, admin@dap.money.

Apple and Apple’s subsidiaries are third-party beneficiaries of these Terms. Upon your acceptance of these Terms, Apple will have the right, and will be deemed to have accepted the right, to enforce these Terms against you as a third-party beneficiary.

52.2 Google Play Terms

If you download or use the App through Google Play, you agree that these Terms are between you and dap only, and not with Google LLC.

Google is not responsible for the App, the Services, maintenance, support, claims, warranties, Promotional Rewards, Spin the Wheel, or any related promotion.

dap, not Google, is responsible for the App and for providing maintenance and support for the App to the extent required by applicable law.

dap, not Google, is responsible for addressing any claims by you or any third party relating to the App, your possession or use of the App, product liability, consumer protection, privacy, regulatory matters, Promotional Rewards, Spin the Wheel, or any related promotion.

You must comply with all applicable Google Play terms, policies, and rules when downloading, installing, accessing, or using the App.

Google LLC and its affiliates are not sponsors of, responsible for, or involved in Spin the Wheel, any Promotional Reward, any prize, or any related promotion.

If there is any conflict between these Terms and the Google Play Developer Distribution Agreement or applicable Google Play terms, those Google terms will apply to the extent required.