These Terms of Service ("Terms") are a legal agreement between you and B28 OÜ, a private limited company registered in Tallinn, Estonia (registry code [registry code to be confirmed]; registered address [registered street address, Tallinn, Estonia, to be confirmed]) ("B28", "we", "us", "our"). They govern your access to and use of the B28 mobile app, software, and related services (together, the "Services"). B28 is a non-custodial crypto wallet: your keys and recovery phrase are generated and stored on your own device behind your device security, and only you control your funds. Please read these Terms carefully, because they explain what B28 does, what it does not do, and where your responsibilities begin. These Terms are our standard terms within the meaning of the Estonian Law of Obligations Act, and any term that would be unfair to you as a consumer does not bind you.
1. Acceptance of these Terms
By downloading, installing, accessing, or using the Services, you agree to be bound by these Terms and by our Privacy Policy, which is incorporated by reference. If you do not agree, do not use the Services. If you are using the Services on behalf of an organisation, you confirm that you have authority to bind that organisation, and "you" refers to that organisation.
These Terms apply to the B28 wallet and software as described below. Some features rely on third-party providers and networks that have their own terms, as explained in Section 12. Before you start using the Services we make this agreement available to you in a form you can store and reproduce, so that you have a fair opportunity to read it, in line with the standard-terms rules of the Estonian Law of Obligations Act.
2. Eligibility
To use the Services, you confirm that:
- You are at least 18 years old and have the legal capacity to enter into these Terms.
- You are not located in, ordinarily resident in, or accessing the Services from a region where B28 is blocked. Access is restricted server-side in Cuba, Iran, North Korea, Syria, Russia, and Belarus.
- You are not a person subject to sanctions or named on any applicable sanctions or restricted-party list (including those maintained by the European Union, United Nations, or other competent authorities), and you are not acting on behalf of such a person.
- You will not use the Services in violation of any law, regulation, or export control that applies to you.
We may add, change, or remove regional restrictions to comply with our legal obligations. You are responsible for knowing and following the laws that apply to you.
3. The Non-Custodial Model: Your Keys, Your Responsibility
This is the most important part of these Terms. B28 is a non-custodial wallet. This means:
- We never hold, control, or access your funds. Your private keys and recovery phrase are generated and stored on your own device, protected by your device security and biometrics. They are not transmitted to us and we never receive them.
- You are solely responsible for your keys and recovery phrase. Anyone who obtains your recovery phrase or private keys can move your funds. Keep them secret. Do not share them with anyone, including anyone claiming to be B28. We will never ask you for your recovery phrase or private keys, and neither will any legitimate B28 partner.
- We cannot recover what we never hold. If you lose your device and your recovery phrase, your funds may be permanently inaccessible. B28 cannot reset, restore, back up, or recover your recovery phrase or private keys under any circumstances. You can export your recovery phrase from the app at any time; it is your responsibility to back it up securely and offline.
- Transactions are final and irreversible. Once a transaction is broadcast to a blockchain, it cannot be cancelled, reversed, frozen, or refunded by anyone, including B28. You are responsible for confirming the recipient address, network, amount, and network fees before you sign. We cannot retrieve funds sent to a wrong or unintended address.
- We do not operate the blockchains. B28 does not run, control, or validate the underlying blockchain networks (such as Bitcoin, Ethereum, Solana, and the other networks we support), and we do not approve, process, or sequence transactions on your behalf. You sign every transaction yourself with your device.
- Securing your device is your responsibility. You are responsible for protecting your device, your passcode, your biometrics, and your recovery phrase, and for any activity that occurs through your wallet.
Because of this model, B28 cannot act as an intermediary in your transactions and cannot help you recover lost, stolen, or mistakenly sent funds. This allocation of responsibility reflects the genuine technical nature of self-custody software and is not an attempt to exclude liability that the law does not allow us to exclude; your mandatory rights under Section 14 are unaffected.
4. Licence to Use the Software
Subject to these Terms, B28 grants you a limited, personal, non-exclusive, non-transferable, revocable licence to download and use the B28 app and software for your own personal, non-commercial use. This licence does not transfer any ownership rights to you.
You agree not to, and not to permit others to:
- copy, modify, distribute, sell, lease, or sublicense the Services;
- reverse-engineer, decompile, or attempt to extract the source code, except to the extent this restriction is prohibited by applicable law;
- remove or alter any proprietary notices;
- scrape, mirror, or build a competing or derivative product from the Services;
- circumvent, disable, or interfere with security features of the Services;
- use the Services through automated means in a way that places an unreasonable load on our or any third party's infrastructure.
5. The Wallet
The B28 wallet lets you generate and manage self-custody crypto wallets and hold, send, and receive supported crypto assets across the networks we support. At the time of writing this covers 16 networks (Bitcoin, Ethereum, Polygon, Arbitrum, Optimism, Base, BNB Chain, Avalanche, Litecoin, Dogecoin, Tron, Solana, XRP, TON, Stellar, and Cardano) and a range of assets, including USDC and USDT. Supported networks and assets may change over time.
The B28 talk-to-it agent helps you understand your wallet and carry out actions in plain language. The agent does not take custody of your funds, does not transact on your behalf, and does not give financial, investment, legal, or tax advice. You always sign transactions yourself with your device.
The Sentinel scam-shield screens addresses and tokens for common risks, such as address-poisoning look-alikes, honeypots, and drainer approvals, and warns you before you sign. Sentinel is a best-effort safety tool, not a guarantee. It may not detect every scam or malicious contract, and it is not a substitute for your own care. You remain responsible for reviewing and approving each transaction.
6. Convert, Buy with Card, and the Coming Card
Convert (preview, rolling out). The in-app convert and swap feature shows live-rate previews and is being rolled out gradually. Quotes and rates are informational, may be delayed or inaccurate, and may change before a transaction is signed. Swaps are executed on public blockchain networks through independent third-party providers, not by B28 holding or routing your funds. Where a swap fee applies, it is shown to you before you confirm. You are responsible for reviewing the rate, fees, and details before you sign.
Buy with card. Buying crypto with a card uses a third-party on-ramp partner. That partner provides the purchase service, sets its own rates and fees, and may carry out its own identity verification. Your use of the on-ramp is subject to the partner's terms and privacy policy. B28 does not process card payments or hold the resulting funds.
The card is coming, not live. The instant-convert Visa card described in our marketing is in development and is not available yet. Nothing in these Terms grants you a right to a card today. When the card launches, it will be provided through a partner and will be governed by additional terms that we will make available at that time.
B28 does not transmit fiat currency. Where the app shows fiat values or currency symbols, they are for reference and valuation only and do not mean that B28 provides a fiat payment, transfer, or banking service.
7. Your Right of Withdrawal
If you are a consumer in the European Union, you normally have a 14-day right to withdraw from a distance contract for digital content or a digital service. The B28 wallet software is digital content that is not supplied on a tangible medium, and it begins working as soon as you set up your wallet.
By setting up and starting to use the wallet, you expressly request that we begin supplying the digital service immediately, and you acknowledge that, once supply has begun and the service has been fully performed at your request, you lose your right to withdraw. This is the immediate-supply exception under the EU Consumer Rights Directive (Article 16(m)), as transposed into Estonian law. It is the legal basis for there being no 14-day cooling-off period here. It does not depend on the wallet being free of charge, and it does not affect any of your other consumer rights, including the conformity guarantee in Section 14.
8. What B28 Is Not
B28 is a non-custodial software wallet and technology provider. B28 is not a bank, e-money institution, money transmitter, payment institution, crypto exchange, custodian, broker, dealer, or regulated deposit-taking institution. We do not hold deposits, we do not provide deposit protection or insurance, and crypto assets are not covered by any deposit-guarantee scheme. Crypto assets are volatile and uninsured.
Because the wallet is non-custodial software through which you control your own keys and sign your own transactions, B28 does not provide a crypto-asset service that requires authorisation as a crypto-asset service provider under EU Regulation 2023/1114 (MiCA). This reflects MiCA's treatment of fully self-custodial software and non-custodial wallets (see in particular Recitals 22 and 83). This is our honest assessment of how the law applies to the Services as they work today; it is not a licence, an authorisation, or a regulator's confirmation, and the regulatory treatment of crypto software continues to develop.
9. No Financial, Investment, or Tax Advice
The Services, including the talk-to-it agent, Sentinel, price data, and any in-app information, are provided for general and informational purposes only. They are not financial, investment, legal, accounting, or tax advice, and nothing in the Services is a recommendation to buy, sell, hold, or convert any asset. B28 does not execute trades on your behalf and does not act as your adviser or fiduciary. You make your own decisions and use the Services at your own discretion and risk. You should seek independent professional advice where appropriate.
You are solely responsible for determining and meeting any tax obligations that arise from your use of the Services and your transactions. B28 does not collect, withhold, report, or remit taxes on your behalf.
10. Assumption of Crypto Risk
You understand and accept the risks of using crypto assets and blockchain technology, including:
- Volatility: the value of crypto assets can change rapidly and significantly, and you may lose some or all of their value.
- Irreversibility: transactions are final and cannot be reversed, cancelled, or refunded.
- Loss of access: if you lose your recovery phrase and your device, your funds may be permanently lost, and no one can recover them.
- Network risk: blockchains, smart contracts, and bridges can contain bugs, can fail, can fork, or can be congested, and network fees and confirmation times are variable and outside our control.
- Security risk: phishing, malware, fraud, and scams target wallet users; you are responsible for guarding against them.
- Regulatory risk: laws affecting crypto assets are evolving and may change in ways that affect the Services or your holdings.
- Third-party risk: features that rely on third parties (such as convert, the on-ramp, and connected applications) depend on those parties' performance.
You accept these risks and agree that B28 is not responsible for losses that result from them. This does not limit our responsibility for the digital service itself conforming to what we have described, as set out in Section 14.
11. Prohibited Uses
You agree not to use the Services to:
- break any law or regulation that applies to you, or facilitate anyone else doing so;
- launder money, finance terrorism, evade sanctions, or move the proceeds of crime;
- commit fraud, theft, or any deceptive or manipulative act;
- buy, sell, or facilitate illegal goods or services;
- infringe the intellectual property or other rights of others;
- transmit malware, attempt to gain unauthorised access, or otherwise interfere with the Services or any network;
- impersonate any person or misrepresent your identity or affiliation;
- use the Services from a restricted region or while subject to sanctions.
12. Third-Party Services and Networks
The Services let you interact with third parties, including the convert/swap providers, the on-ramp partner, blockchain networks, and any external applications you connect to. B28 does not control, endorse, verify, or take responsibility for these third parties or their content, performance, fees, security, or availability. Your use of any third-party service is at your own risk and is governed by that third party's own terms and privacy policy. To the extent permitted by law, B28 is not liable for any loss arising from your use of, or reliance on, any third-party service or network, including loss of funds. This does not affect any liability we have for our own digital service under Section 14.
13. Intellectual Property
The Services, including the B28 app, software, design, text, graphics, and the B28 name and marks, are owned by B28 or its licensors and are protected by intellectual property laws. Except for the limited licence in Section 4, these Terms do not grant you any rights in our intellectual property. You may not use our name or marks without our prior written permission. Some components of the Services may be provided under open-source licences, which continue to apply to those components.
If you give us feedback or suggestions, you grant us a perpetual, royalty-free licence to use them without obligation to you.
14. Your Consumer Rights, Conformity, and "As Is"
If you are a consumer, you have mandatory rights that these Terms do not and cannot take away. In particular, because the B28 wallet is a digital service supplied to you (including where you provide personal data rather than payment), we owe you the conformity guarantee for digital content and digital services under EU Directive 2019/770, as transposed into the Estonian Law of Obligations Act. That means we must supply a wallet that matches its description, is fit for the purposes a wallet of this kind is normally used for, and is supplied with the functionality, compatibility, and updates you can reasonably expect. If the digital service does not conform, you are entitled to the remedies the law gives you, which may include having the service brought into conformity, a price reduction where you have paid, or ending the contract. Nothing below limits these rights.
Subject to and without limiting the conformity guarantee and your other mandatory rights, the Services are otherwise provided "as is" and "as available", without further warranties of any kind, whether express or implied, to the fullest extent permitted by law. To that extent, we do not warrant that the Services will be uninterrupted, error-free, or secure, or that any third-party information (including rates, prices, and Sentinel results) will be accurate or complete. The "as is" wording does not exclude or limit the conformity guarantee for the digital service, your other mandatory consumer rights, or any liability that the law does not allow us to exclude.
15. Limitation of Liability
Nothing in these Terms limits or excludes our liability for death or personal injury caused by our negligence, for fraud or fraudulent misrepresentation, for gross negligence or intentional breach, for breach of the conformity guarantee or your other mandatory consumer rights, or for any other liability that the law does not allow us to limit or exclude. The limits below apply only to the extent the law permits, and they never reduce the protections you have under the mandatory law of your country of residence.
Subject to the paragraph above, and to the fullest extent permitted by law, B28 will not be liable for any indirect, incidental, special, consequential, or punitive damages, or for any loss of profits, data, goodwill, or funds, arising out of or related to your use of, or inability to use, the Services.
In particular, and given the genuinely non-custodial nature of the software, B28 is not liable for losses caused by: loss of your recovery phrase or device; transactions you sign (including to a wrong address or network); the irreversibility of blockchain transactions; the acts, omissions, or failures of third-party providers or networks; market volatility; or fraud, phishing, or scams directed at you. These exclusions do not apply where the loss results from our own breach of the conformity guarantee, our negligence, or our intentional breach, or where the law does not allow the exclusion.
Where our liability can be limited but not excluded, and to the extent the law permits, our total liability to you for all claims connected with the Services is limited to the greater of the total fees you paid us for the Services in the 12 months before the event giving rise to the claim, or EUR 100. This cap does not apply to any liability listed in the first paragraph of this Section.
16. Indemnity
If you are using the Services for purposes outside any trade, business, or profession (that is, as a consumer), this Section does not impose any indemnity on you, and your liability to us is governed only by the general law. If you use the Services in the course of a trade, business, or profession, then to the extent permitted by law you agree to indemnify and hold harmless B28 and its officers, employees, and agents from any claims, losses, liabilities, and reasonable expenses (including legal fees) arising out of your breach of these Terms, your misuse of the Services, or your violation of any law or the rights of any third party. This does not apply to the extent a loss is caused by our own breach, negligence, or wilful misconduct.
17. Suspension and Termination
You may stop using the Services at any time. Because the wallet is non-custodial, you keep control of your funds through your recovery phrase even if you delete the app; back it up before you uninstall.
We may suspend, restrict, or terminate your access to the Services or to specific features (such as off-chain features that rely on partners) if we reasonably believe you have breached these Terms, used the Services unlawfully, or where we are required to do so by law. We cannot freeze, suspend, or seize your on-chain funds; suspension affects only your access to the app and to off-chain features. Sections that by their nature should survive termination (including those on the non-custodial model, intellectual property, your consumer rights, limitation of liability, and governing law) will continue to apply.
18. Changes to the Services and these Terms
We may update, change, or discontinue the Services or any feature. We may also update these Terms where we have a valid reason, such as a change in the law, in the features we offer, in the third parties we work with, or for security or technical reasons, and we will not use this right to make the agreement unfair to you. If we make a material change, we will give you reasonable advance notice by a method appropriate to the change, such as in the app or by updating the effective date below, so that you can review it. Changes are not retroactive. If you continue to use the Services after a change takes effect, you accept the updated Terms. If you do not agree, you may stop using the Services, and where the change materially and negatively affects you, you keep any right the law gives you to end the contract.
19. Complaints and How to Reach Us
If something goes wrong, please contact us at hello@joinb28.app and tell us what happened. We will acknowledge your complaint without undue delay. In line with the Estonian Consumer Protection Act, we will give you a written reply within 15 days of receiving it. If, for reasons outside our control, we cannot give a full answer within 15 days, we will tell you so in writing, explain why, and give you a new deadline by which you will receive our reply. Our full complaints process is described in our Complaints page.
20. Governing Law and Disputes
These Terms are governed by the laws of Estonia and, where applicable, the European Union. If you are a consumer, this choice of law does not deprive you of the protection of the mandatory provisions of the law of the country where you habitually reside, in line with the Rome I Regulation. If a dispute arises, we encourage you to contact us first at hello@joinb28.app so we can try to resolve it informally.
If we cannot resolve a dispute informally, it may be brought before the competent courts of Estonia. If you are a consumer in the European Union, the Brussels I Recast Regulation means you may also bring proceedings in, and may only be sued in, the courts of the country where you live. You may also refer a dispute to the Estonian Consumer Disputes Committee (Tarbijavaidluste komisjon) at the Consumer Protection and Technical Regulatory Authority, or to a consumer dispute body in your own country. These Terms do not require arbitration, do not send you to a foreign court, and do not take away your right to go to your home courts or to any out-of-court dispute body the law makes available to you.
21. General
If any provision of these Terms is found unfair or unenforceable, it is removed or read down to the minimum extent needed, and the rest remain in effect. Our failure to enforce any provision is not a waiver of it. You may not assign these Terms without our consent; we may assign them to a successor in connection with a merger, acquisition, or reorganisation, provided this does not reduce your rights. These Terms, together with the Privacy Policy, are the entire agreement between you and B28 regarding the Services. We are not liable for any failure or delay caused by events beyond our reasonable control, but this does not affect your mandatory consumer rights. These Terms do not create any third-party beneficiary rights.
22. Contact
B28 OÜ, registry code [registry code to be confirmed], [registered street address, Tallinn, Estonia, to be confirmed]. For general questions and complaints: hello@joinb28.app. For security reports: security@joinb28.app. Further mandatory provider information is set out in our Imprint.