Karma Terms of Service

Last updated: July 5, 2026

Important notice: Please read these Terms carefully. They include important provisions that affect your rights and obligations, including disclaimers (Clause 13), limits on liability (Clause 14), and your responsibilities (Clause 4). The Karma Wallet is non-custodial: we do not hold, control, or have access to your private keys or digital assets, we cannot recover your keys for you, and blockchain transactions are irreversible once broadcast.

Glossary

Capitalised terms have the meanings below, unless the context requires otherwise.

• "Account" means the online account you create to access the Services.
• "Blockchain" means a distributed ledger on which transactions in Digital Assets are recorded.
• "Digital Asset" means a cryptographically secured digital representation of value recorded on a Blockchain, including cryptocurrencies and tokens.
• "Private Key" means a cryptographic key that allows you to authorise transactions on a Blockchain.
• "Key Share" means one encrypted part of the distributed key material used by the Karma Wallet. No single Key Share is a usable Private Key on its own.
• "Wallet Infrastructure Provider" means the third-party embedded-wallet infrastructure provider whose technology the Karma Wallet uses, currently Privy Inc. ("Privy").
• "Karma Wallet" means the non-custodial embedded wallet generated by or through the Karma app, which enables you to hold and manage Digital Assets on a self-custodial basis.
• "Supported Network" means any blockchain network the Karma Wallet is technically able to interact with from time to time, currently including Solana and Base.
• "Third-Party Services" means services, software, content, or smart contracts operated by third parties (including swap routers, aggregators, bridges, RPC providers, oracles, and price feeds) that you may access via or alongside the Karma Wallet.
• "Interface" means any website, mobile application, API, or other technical means through which you access or use the Karma Wallet.
• "Services" means the Karma Wallet, the Interface, and related features we make available under these Terms.

1. Introduction

1.1 Who we are and what these Terms cover

These Terms of Service (the "Terms") govern your access to and use of the karmapay.xyz website (the "Site"), the Karma app, and the Karma Wallet, operated by Karma Fintech LTD, a company incorporated in the United Kingdom with company number 16581945 and registered office at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ ("Karma", "we", "us", "our"). By accessing or using any part of the Services, you enter into a legally binding agreement with us on these Terms.

1.2 What these Terms do not cover

These Terms do not govern:

• the Karma Card, which is issued through our card partners and governed by the separate Card Terms presented during card onboarding, including any collateral or settlement arrangements used to fund card spend;
• fiat currency services, including virtual bank accounts (USD, EUR, and GBP), fiat on-ramp, and fiat off-ramp, which are provided by Bridge Building Inc. ("Bridge") and its banking partners under Bridge's own terms of service and regulatory permissions.

If you use any of those services, you do so under their respective terms and not under these Terms.

1.3 Formation of contract

To use the Services you must create an Account with a valid email address and expressly accept these Terms and our Privacy Policy. By downloading, installing, accessing, or using the Karma app or Site, you agree to these Terms. If any part of these Terms is unacceptable to you, do not use the Services.

1.4 Regulatory status (MiCA notice)

The Karma Wallet is non-custodial software. We do not hold, control, or have access to your Private Keys, Key Shares, or Digital Assets; we cannot transact on your behalf, retrieve your keys, or reverse any transaction you authorise. Providing the Karma Wallet does not constitute the custody and administration of crypto-assets on behalf of clients, or any other crypto-asset service, within the meaning of Regulation (EU) 2023/1114 on markets in crypto-assets ("MiCA"). MiCA recognises that providers of hardware or software for non-custodial wallets, where the provider does not have control of or access to the crypto-assets, fall outside its scope.

The Karma Wallet does not constitute payment services, electronic money issuance, deposit-taking, or a regulated investment service. We are not authorised or supervised by the UK Financial Conduct Authority or by any EEA national competent authority in respect of the Karma Wallet, and no deposit guarantee or investor compensation scheme (including the UK Financial Services Compensation Scheme) applies to Digital Assets held in your wallet. Fiat and card services offered through the Karma app are provided by regulated partners under their own terms (see Clause 1.2). We do not provide investment, legal, or tax advice, and we do not act as your broker, intermediary, custodian, or fiduciary in relation to your use of the Karma Wallet.

1.5 Consumer rights

Nothing in these Terms excludes or limits rights that cannot lawfully be excluded under applicable law.

1.6 Wallet functionality

The Karma Wallet enables you to:

• hold and manage Digital Assets on a self-custodial basis;
• generate and view blockchain addresses and broadcast transactions to Supported Networks;
• initiate peer-to-peer transfers of Digital Assets to addresses on Supported Networks;
• swap Digital Assets through third-party on-chain routing and aggregation protocols, including across Supported Networks;
• set limit orders and other conditional instructions that execute through third-party on-chain protocols;
• import existing wallets and export your Private Keys (see Clause 2.5); and
• access any additional features we may make available from time to time.

We do not operate or control any swap router, aggregator, bridge, decentralised exchange, or on-chain protocol. These are Third-Party Services and your use of them is at your own risk.

1.7 Supported and unsupported assets

The Karma Wallet may display or route transactions for certain assets or networks. We may add or remove support at any time. Do not attempt to deposit or send unsupported assets, or assets on the wrong network; doing so may result in permanent loss.

1.8 No brokerage and no investment advice

We do not operate a trading venue, brokerage, or investment service. Any prices, charts, market data, token pages, rankings, trending lists, risk flags, or similar materials shown in the Interface are provided for general information only. They are not investment advice, a personal recommendation, or an invitation or inducement to buy or sell any token. Content posted by other users in the Karma feed, including trades, positions, and performance, is user content and not a recommendation by Karma. You are solely responsible for your investment decisions, including assessing your objectives, financial circumstances, and risk tolerance. We do not monitor your activity for suitability or appropriateness.

2. The Karma Wallet: non-custodial architecture

2.1 How keys are created

When you create a Karma Wallet, a Private Key is generated on your device inside an isolated, secure execution environment provided by our Wallet Infrastructure Provider. The key material is immediately split into multiple encrypted Key Shares using distributed key sharding. One Key Share remains on your device; another is encrypted and stored by the Wallet Infrastructure Provider and is released only after you successfully authenticate. No single Key Share is sufficient to sign transactions or access funds, and the complete Private Key is never assembled on Karma's or the Wallet Infrastructure Provider's servers.

2.2 How transactions are signed

All transactions are initiated and authorised solely by you on your own device. When you authorise a transaction, the Key Shares are combined only momentarily, inside the isolated environment on your device, to produce a signature. Karma's servers hold no key material capable of signing transactions from your Karma Wallet. We cannot initiate, sign, approve, or block transactions from your wallet, and we cannot move, freeze, or recover your Digital Assets.

2.3 No custody and no unilateral control

We do not create, hold, access, or control your Private Keys, Key Shares, or Digital Assets. The Wallet Infrastructure Provider cannot access your assets without your device's participation and your explicit authentication. Neither Karma nor the Wallet Infrastructure Provider can recover or recreate your Private Key for you if you lose access to your Account and any recovery methods you have enabled. We do not operate or control any blockchain network and do not validate, process, or guarantee the execution of any transaction.

2.4 Recovery

If you lose your device, you can restore access to your Karma Wallet on a new device by authenticating with your Account credentials. If you lose access to your Account credentials and all recovery methods you have enabled, your wallet and any associated Digital Assets may be permanently inaccessible. You are solely responsible for maintaining access to the email address and authentication methods associated with your Account.

2.5 Key export and import

You may export your Private Key at any time from within the app to a standard, interoperable format for use outside the Karma Interface. Export is performed locally on your device after you authenticate; Karma and the Wallet Infrastructure Provider never see or receive your exported key. After export, you are solely responsible for the secure storage and use of the exported key material. You may also import existing wallets you control; imported key material is handled under the same architecture described in this Clause 2.

2.6 Security controls

We may implement rate limits, risk checks, and additional authentication steps to protect you and the Services from fraud and abuse. These controls do not give Karma custody of your assets or the ability to sign transactions, and they cannot authorise transactions without your action.

2.7 Legacy wallets

Wallets created before July 2026 were provisioned on our previous wallet infrastructure and are being upgraded to the architecture described in this Clause 2. If you hold a legacy wallet, we will prompt you in the app to complete the upgrade. Your wallet address and assets are unchanged by the upgrade. Until you complete it, your wallet continues to operate on the previous infrastructure and remains subject to these Terms.

3. Changes

3.1 Changes to the Services

We may change or discontinue all or part of the Services, or change or remove functionality, from time to time. We will use reasonable efforts to provide advance notice of any material discontinuation via in-app notice, our website, or other channels, except where doing so would pose security, legal, or operational risk. Because the Karma Wallet is non-custodial, discontinuation of the Interface does not affect your ownership of your Digital Assets: you can export your keys and access your assets through other wallet software at any time.

3.2 Changes to these Terms

We may amend these Terms from time to time. We will use reasonable efforts to communicate material changes via in-app notice, email, or our website, and will update the "Last updated" date above. Your continued use of the Services after the effective date of changes constitutes acceptance of the amended Terms.

4. Your responsibilities

4.1 Use of the Karma Wallet

You are responsible for all activity that occurs in connection with your use of the Karma Wallet, whether or not authorised by you. You must ensure that your use is lawful and complies with these Terms. We are not responsible for unauthorised access to your devices or for third-party deception (for example, phishing or social engineering) perpetrated against you.

4.2 Security and backups

You are solely responsible for configuring and using the Karma Wallet securely, including installing updates promptly, maintaining robust device and network security (screen lock, biometrics, strong unique passwords, and multi-factor authentication on your email account), and securely storing any exported Private Keys and recovery methods you enable. Storing key material in plain text or in insecure locations increases the risk of compromise. Never share your Private Keys or exported key material with us or anyone else.

4.3 Credentials

Your Account credentials are for your use only. You must not sell, transfer, or share them with any other person, and you are responsible for keeping them secure. If you suspect compromise of your device, credentials, or key material, you must cease activity and take remedial action immediately, including moving assets to a secure wallet where appropriate.

4.4 Support channels

We will never ask you for your Private Keys, exported key material, or one-time passcodes. We do not provide support via SMS, WhatsApp, Telegram, or social media direct messages, and we will never ask you to install remote-access software. Malicious third parties may impersonate Karma. Treat unsolicited contact as suspicious and verify it via our published channels: in-app support and email. You are responsible for verifying any communication and for actions you take in response to phishing, social engineering, or other deception.

4.5 Sanctions and restricted jurisdictions

You may use the Services only where such use is permitted under applicable sanctions, export control, and other laws. By using the Services, you represent and warrant that you are not subject to sanctions restrictions and are not using the Services from a jurisdiction where such use is prohibited. You must not use any technology or arrangement intended to circumvent applicable legal or regulatory restrictions.

5. Eligibility, accounts, and verification

You must be at least 18 years old (or the age of majority in your jurisdiction, if higher) and have legal capacity to enter into these Terms. You agree that all information you provide is accurate, complete, and kept up to date, and that you are acting on your own behalf and not on behalf of any other person or entity unless expressly agreed by us in writing.

The Karma Wallet itself does not require identity verification. Where you choose to access services provided by our regulated partners (including fiat services from Bridge and the Karma Card), you will be required to complete Know Your Customer (KYC) and Anti-Money Laundering (AML) verification in accordance with the terms applicable to those services. Failure to provide requested information may result in suspension or restriction of access to those services. We may request additional information where reasonably required to comply with applicable law, manage risk, or maintain the integrity of the Services.

6. Fees

6.1 Network fees

Blockchain network (gas) fees may apply when transacting on-chain. These fees depend on network conditions, are paid to network validators, and are not set or retained by us when you transact directly on-chain.

6.2 Karma service fees

We do not charge you for downloading or using the standard functions of the Karma Wallet. We charge fees for certain optional services, disclosed before you confirm each transaction and described on our Fees Page. These currently include a trading fee on token swaps (0.5%, subject to a minimum), and may include foreign exchange and off-ramp fees for partner services. KARMA token holders may be eligible for fee rebates as described in our documentation. Fees are subject to change with notice.

6.3 Third-party fees

Third-Party Services and partner services (including Bridge and card partners) may charge their own fees under their own terms. We are not responsible for these.

6.4 Compliance and risk fees

We may charge an additional fee where a transaction requires enhanced compliance handling. This includes deposits received from a third party whose name does not match your verified account details, transactions flagged as high risk under our financial crime policies, and cases where we or our partners are required to carry out enhanced due diligence. Any such fee is capped at 5% of the transaction amount, may be deducted from the amount received, and is described on our Fees Page.

6.5 Taxes

You are responsible for determining and paying any taxes that apply to your transactions and for complying with your tax reporting obligations.

7. Acceptable use

You agree not to (and not to allow any third party to):

• violate any law, regulation, or sanction, or use the Services for money laundering, terrorist financing, sanctions evasion, fraud, or other illegal activity;
• attempt to access another person's wallet, keys, or Account, or impersonate any person or misrepresent your affiliation with Karma;
• infringe intellectual property or privacy rights, or introduce malware or other harmful code;
• copy, scrape, crawl, or automate access to the Services in a manner that overloads or interferes with their operation, or circumvent rate limits or security controls;
• reverse engineer, decompile, or disassemble the Services except to the extent such restriction is prohibited by applicable law;
• create fake, automated, or bot accounts, or resell, rent, or provide the Services to third parties;
• use anonymising tools or automation to evade geographic or usage-based restrictions;
• harass, threaten, or abuse Karma personnel or other users; or
• use the platform for prohibited activities (see our Prohibited Activities list).

Violations may result in immediate suspension or termination of your Account and reporting to authorities where required by law.

8. User content and the Karma feed

If you submit content to our platform (posts, comments, profile information, feedback, or messages), you retain ownership of your content and grant us a worldwide, non-exclusive, royalty-free licence to use, host, display, and distribute it for the purpose of operating and promoting the Services. You must not post illegal, offensive, defamatory, or infringing material. Content posted by users is not reviewed or endorsed by Karma and does not constitute investment advice (see Clause 1.8). We may remove content or restrict feed access at our discretion.

9. Third-party services

The Services integrate with and provide access to Third-Party Services, which are governed by their own terms and privacy policies. These include:

• Privy: embedded wallet infrastructure (see Clause 2);
• Bridge (Bridge Building Inc.): virtual accounts, fiat on-ramp and off-ramp, and associated identity verification;
• Rain: card issuance and program management (under the separate Card Terms);
• Jupiter, dFlow, and other routing protocols: token swap routing and aggregation, and limit order execution;
• Relay: cross-chain execution.

We do not operate, endorse, monitor, or control Third-Party Services, and third-party content may be inaccurate, incomplete, misleading, or unlawful. Your use of Third-Party Services is at your sole risk, and we are not responsible for their availability, security, accuracy, fees, or conduct, or for losses arising from your reliance on them. We may change, suspend, or remove access to any Third-Party Service at any time where reasonable, including for legal, security, or operational reasons. If the availability of the Wallet Infrastructure Provider is degraded, transaction signing may be delayed or unavailable; your assets remain yours and can be accessed via key export (Clause 2.5).

10. Temporary suspension

We may suspend or limit your access to the Interface (or any part of it) immediately if we reasonably determine that: your use poses a security risk or could adversely impact users, systems, or third parties; you are in material breach of these Terms; we are required to do so by law or a competent authority; or continuing to provide access would create undue legal or operational risk. Suspension of the Interface does not give us control of your Digital Assets, which remain accessible to you via your keys (Clause 2.5). We are not liable for losses you may suffer as a result of a reasonable suspension under this Clause 10.

11. Term and termination

These Terms commence when you first download, install, or use the Services and continue until terminated. You may terminate at any time by ceasing all use of and uninstalling the Karma app. Either party may terminate with immediate effect if the other party commits a material breach that is irremediable or fails to remedy a remediable breach within 30 days after notice. We may also terminate or restrict access immediately where we reasonably believe it necessary to comply with law, prevent fraud, manage risk, or protect the Services or other users.

Upon termination, your right to use the Interface ends. Because the Karma Wallet is non-custodial, termination does not affect your ownership of your Digital Assets: you may export your keys and continue to access your assets through other wallet software. Clauses that by their nature should survive termination (including Clauses 1.4, 1.8, 2, 4, 8, 9, 12, 13, 14, 15, 16, and 19) continue in force.

By creating or activating the Karma Wallet you request immediate performance of digital services and acknowledge that once performance begins you lose any statutory right to cancel the service, where such a right would otherwise apply. This does not affect rights that cannot lawfully be excluded.

12. Intellectual property

We and our licensors own all intellectual property rights in and to the Services and related materials. Subject to these Terms, we grant you a limited, revocable, non-exclusive, non-transferable, non-sublicensable licence to install and use the Karma app for your own lawful purposes. "Karma", our logos, and other brand features are trademarks of Karma Fintech LTD or its licensors and may not be used without our prior written consent. If you provide suggestions or feedback, we may use them without restriction and without obligation to you. If you believe content on our platform infringes your copyright, contact us at team@karmapay.xyz with details of the alleged infringement.

13. Disclaimers and risk

13.1 Disclaimer

The Services are provided "as is" and "as available". To the maximum extent permitted by law, we make no warranties, representations, or undertakings of any kind, whether express, implied, statutory, or otherwise, including any implied warranties of merchantability, satisfactory quality, fitness for a particular purpose, non-infringement, or error-free or uninterrupted operation.

13.2 Risks

You acknowledge that:

• blockchain networks (including consensus rules, validators, protocol upgrades, and transaction ordering) are outside our control and present inherent risks;
• blockchain transactions are irreversible once broadcast. You are solely responsible for verifying recipient addresses and network selection, and for protecting your devices, credentials, and key material. We cannot block, reverse, refund, or recover transfers, including where you acted under fraud, phishing, social engineering, or error;
• Digital Assets are subject to significant market volatility, and tokens available through the Interface (including memecoins and low-liquidity tokens) can lose some or all of their value rapidly. You may lose some or all of your funds. Past performance does not guarantee future results;
• approvals and permissions granted by cryptographic signature, and interactions with smart contracts, can expose you to loss (for example, malicious smart contracts, phishing prompts, or allowances you forget to revoke);
• peer-to-peer transfers are executed directly on the relevant Blockchain. We are not a party to the transaction, cannot block or reverse it, and cannot verify the identity or legitimacy of the recipient;
• storing exported key material digitally (including on a personal device or in cloud storage) increases the risk of loss or theft;
• network cost and speed are variable and outside our control, and protocol upgrades, forks, or client bugs may introduce vulnerabilities or loss of functionality; and
• you are solely responsible for verifying the legitimacy and safety of any third-party applications or smart contracts you interact with.

14. Limitation of liability

To the fullest extent permitted by law, we will not be liable to you, whether in contract, tort (including negligence), breach of statutory duty, misrepresentation, restitution, or otherwise, for any:

• loss of profit, revenue, business, opportunity, goodwill, or anticipated savings;
• loss, corruption, or inaccuracy of data or Digital Assets;
• indirect, special, exemplary, punitive, or consequential loss;
• losses arising from Third-Party Services, including their availability, security, accuracy, or behaviour;
• losses caused by blockchain network conditions or behaviours (including transaction ordering, MEV, front-running, slippage, forks, re-orgs, protocol upgrades, gas price spikes, congestion, or node or RPC outages);
• losses resulting from sending to an incorrect or incompatible address, use of the wrong network, unsupported assets, misconfigured approvals or permissions, or other user error;
• losses caused by phishing, social engineering, malware, or other harmful code, or by the compromise of your device, credentials, email, or key material; or
• losses resulting from sanctions screening, compliance holds, your failure to complete required checks, or your breach of law or these Terms.

Our total aggregate liability to you is capped at 100 GBP or the amount of fees you paid to us in the 12 months preceding the claim, whichever is greater. Nothing in these Terms excludes or limits liability for fraud, fraudulent misrepresentation, death or personal injury caused by negligence, or any other liability that cannot lawfully be excluded or limited.

15. Indemnity

You agree to indemnify, defend, and hold harmless Karma Fintech LTD, its affiliates, and their respective directors, officers, employees, contractors, and agents from and against any claims, demands, proceedings, losses, liabilities, damages, costs, and expenses (including reasonable legal fees) arising out of or in connection with: your breach of these Terms; your unlawful or improper use of the Services, including interactions with Third-Party Services; or your violation of any third-party rights or applicable law.

16. Governing law and dispute resolution

These Terms and any non-contractual obligations arising out of or in connection with them are governed by the laws of England and Wales. Before initiating any legal proceedings, you agree to contact us at team@karmapay.xyz to attempt to resolve the dispute informally and in good faith. Any disputes that cannot be resolved informally will be subject to the exclusive jurisdiction of the courts of England and Wales, without prejudice to any mandatory consumer protections available in your country of residence.

17. Complaints

If you have a complaint, contact us at team@karmapay.xyz. We will acknowledge your complaint within 7 days and provide a written response within 30 days of receipt. In complex cases this period may be extended, in which case we will keep you informed. The Karma Wallet is non-custodial software and not a regulated financial service; complaints about it are not within the jurisdiction of the UK Financial Ombudsman Service or any EEA financial supervisory authority. Complaints about partner services (Bridge or card services) are handled under those partners' complaint procedures, and we will direct you to the right channel.

18. Privacy and data

We process personal data in accordance with our Privacy Policy. The Karma Wallet does not collect or store your Private Keys, exported key material, or unencrypted Key Shares: your device share remains on your device and the encrypted counterpart share is held by the Wallet Infrastructure Provider (see Clause 2). We adhere to applicable data protection laws and only use your personal data to provide the Services.

19. Miscellaneous

• Assignment. You may not assign or transfer these Terms without our prior written consent. We may assign these Terms to an affiliate or in connection with a merger, acquisition, or sale of assets.
• Force majeure. We are not liable for delay or failure to perform due to causes beyond our reasonable control, including utility or telecommunications failures, cyber attacks, governmental actions, or natural disasters.
• Relationship. The parties are independent contractors. Nothing in these Terms creates a partnership, joint venture, agency, or fiduciary relationship.
• Third-party rights. A person who is not a party to these Terms has no rights to enforce any of them.
• Entire agreement; waiver; severability. These Terms constitute the entire agreement between you and us in relation to the Services. No failure or delay to exercise any right operates as a waiver. If any provision is held invalid, the remainder shall remain in full force and effect.
• Language. These Terms and all communications will be in English. If we provide a translation, the English version prevails to the extent of any conflict.
• Notices and electronic communications. We may provide notices via in-app message, our website, or email, and you agree that such electronic communications satisfy any legal requirement that they be in writing. Keep your contact details up to date.

20. Contact information

Karma Fintech LTD
Company Number: 16581945 (United Kingdom)
71-75 Shelton Street
Covent Garden, London
United Kingdom, WC2H 9JQ

Email: team@karmapay.xyz

Website: karmapay.xyz

Important notice: By using Karma's services, you acknowledge that you have read, understood, and agree to be bound by these Terms of Service and our Privacy Policy. If you do not agree, please do not use our services.