Wallet Terms and Conditions of Use (“Terms”)

Effective Date: August 6, 2026

Do these Terms Apply to You (Scope)

If you sign up for and open a custodial wallet powered by Bastion (“Wallet”), these Terms apply to You. By opening the Wallet, You agree to comply with these Terms and to be bound by them. If You violate these terms, You will lose access to the Wallet. You acknowledge and agree to everything in these Terms, even if a sentence in these Terms does not begin with “You agree and acknowledge….”

If You Sign Up for a Wallet, You Agree to Several Things

By signing up to open a wallet, You agree that you have read, understand, and accept these Terms and Bastion’s Privacy Policy, and E-Sign Disclosure and Consent Policy. You may have to agree to additional terms and conditions to use certain Additional Services, including “Fiat On and Off Ramp” Services (“Ramp Terms”) included in these Terms and additional terms with financial institutions other than Bastion. You also agree not to use your Wallet or any of its features to engage or assist in any Prohibited Acts or Businesses detailed in Annex 1.

What is Bastion

Bastion Platforms, Inc., is a technology provider and owner of Bastion Platforms US, LLC (NMLS ID 2523302), a Money Service Business registered with FinCEN and licensed in multiple states and the provider of the custodial Wallet. State licensing information is available at https://www.bastion.com/disclosures.

What is the Wallet

Bastion will provide a qualifying user with a custodial, hosted Digital Asset wallet (Wallet). Each Wallet may contain one or more addresses used to hold Supported Digital Assets. Your Wallet allows you to hold and transfer Supported Digital Assets that Bastion allows as part of its Wallet service. Bastion securely stores private keys that are used to process transactions. No Digital Assets other than Supported Digital Assets can or should be used in your Wallet. The term “virtual currency” in these Terms and risk disclosures mean the same thing as digital assets.

When I Access My Wallet I See Branding Other than Bastion’s. Why?

Bastion provides the technology and licenses to power your Wallet. Bastion provides the Wallet based on an agreement with a company “White Label Company” that has its branding on the portion of the Wallet visible to you. White Label Company controls 1) the application or interface through which you access the Wallet and 2) your experience interacting with the Wallet. White Label Company does not provide you with money transmission services–Bastion does. Bastion uses its money transmission licenses to custody and transfer Supported Digital Assets in the Wallets, including your Wallet. Bastion does NOT use its money transmission licenses to custody or move U.S. dollars (or any other form of “fiat”) into or out of your wallet. All U.S. Dollar based services and transactions are provided through other regulated financial institutions with whom Bastion has agreements. In addition, Bastion contracts with a virtual currency exchange to facilitate the exchange of U.S. dollars to digital currency or from one digital currency to another digital currency.

Access to Your Wallet

White Label Company provides access to your Wallet through an application or interface. Bastion does not. The Application or interface may be unavailable or slow due to reasons not within Bastion’s control. This could result in delays in your ability to access assets in your Wallet. White Label Company will offer you customer service related to access issues. This includes issues with your password or authentication.

What Are On and Off Ramps

The movement of U.S. Dollars or any other fiat from an account and converting it into digital assets held in the Wallet is known as an “On Ramp”. The movement of digital assets out of your Wallet and into a U.S. dollar account or other fiat account is known as an “Off Ramp.” Together, On Ramp and Off Ramp Services are called “Ramp Services” in these Terms. The part of these Terms applicable to Ramp Services are called “Ramp Terms.” Finally, the U.S. Dollar Custodial Accounts used as part of the Ramp Services are called “Ramp Accounts” in these Terms.

What Are the Ramp Terms Applicable to You

The Wallet may connect you to Ramp Services. If and when you use those Ramp Services, Bastion is not engaging in or providing you with money transmission or money transfer or payments services. Bastion provides custody and transmission only of digital assets–not U.S. Dollars (or any other fiat).

For U.S. Dollars (or any other fiat), all Ramp Services are processed and disbursed by regulated financial institutions. In the United States, Cross River Bank is the regulated financial institution. Funds processed and disbursed by Cross River Bank as part of the Ramp Services may be subject to FDIC pass-through deposit insurance. In the United States, Bastion orchestrates conversions between U.S. Dollars and stablecoins, including instructing Cross River Bank to execute U.S. Dollar movements consistent with your requests.

Bastion has no ownership interest in or control over the U.S. Dollar Ramp Account used to provide Ramp Services. The custodial Ramp Account with Cross River Bank is designated “For the Benefit Of” customers of White Label Company. Bastion may not and will not at any time access any Ramp Account or any of the funds deposited into it.

By signing up for the Wallet and using Ramp Services, You authorize and approve the use of the Custodial Ramp Account, including the use of any Payment Methods selected for the transmission of funds to or from Custodial Account.

In the United States, when you On Ramp fiat to load virtual currency into Your Wallet, the following happens.

You indicate you wish to On Ramp fiat from your bank account to load your Wallet with Supported Digital Assets (for instance USDC)
Bastion provides you with a virtual account number at Cross River Bank.
You request that your bank send U.S. Dollars from your bank account to the virtual account at Cross River Bank using the account number that Bastion provided to you
Your U.S. dollars are routed from your source bank account to the Ramp Account at Cross River Bank
U.S. Dollars are then sent from Cross River Bank to a Coinbase Prime Account where the U.S. Dollars are converted into USDC (or other Supported DIgital Assets that you request) The Supported Digital Assets are sent to Your Bastion Wallet account and reflected in your balance

Bastion’s third party partners that provide Ramp Services may allow transactions using wires, ACH transfers, or payment cards. This is not guaranteed and is subject to change. If you elect to use a bank account during on or off ramping, you must provide accurate information about the account. Depending on the nature of your transaction, your funds may not be available for up to five business days. If you use Ramp Services, you agree to be bound by any additional terms that Cross River Bank, Coinbase and its affiliates may apply, or any other third party involved in providing Ramp Services may require. These may change from time to time.

If you have questions about an on or off ramp transaction, contact support@bastion.io.

Third Party Services

On and Off Ramps rely on third parties. Those third parties may experience system outages or degradation that affect the speed of transactions and availability of Services. Bastion is not liable for any losses resulting from delays in processing transactions or any other delays. You accept the risk in opening a wallet, accepting these Terms, Ramp Terms and using the Wallet and Ramp Services.

You are Liable for and Financially Responsible for Activity in Your Wallet

You are responsible for deciding to send assets from your Wallet to another of your accounts or wallets or to another person’s accounts or wallets. You are responsible for correctly identifying wallet addresses and account numbers. Be careful entering those addresses and numbers because if you send to the wrong wallet or account number, you cannot recover the assets. The assets cannot be recovered for you. You are responsible for the financial loss resulting from mistakes and errors.

Can You Use the Wallet for Anything You Want?

No. You cannot use the Wallet for any illegal activity or prohibited purpose or activities, including but not limited to the following:

Paying for illegal things or activity
Receiving money for illegal things or activity
Assisting in any unlawful activity including by moving assets that support unlawful activity or support someone conducting unlawful activity
Committing any fraud or helping someone else engage in any fraud
Sending assets to directly or indirectly to any sanctioned individual or sanctioned jurisdiction including as defined by the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”)

Click Here to see a fuller list of Prohibited Activities and Businesses.

Termination of or Change to These Terms
Bastion may terminate or change these Terms at any time, in its sole discretion, by posting notice on its website linked here or by otherwise communicating with you. Changes are effective at the time the new Terms are posted. However, You will receive 14 days' advanced notice prior to changes in fees and any material changes to the terms or account policies. Your use of the Wallet after the new posting or after 14 days for any material change mentioned above constitutes your acceptance of and agreement to the change in Terms. The same is true with Bastion’s Privacy Policy. Upon termination of these Terms, all rights and obligations of the parties that by their nature are continuing will survive such termination.

Bastion Provides Your Wallet Without Warranties and With Limited Liability

IF YOU ARE DISSATISFIED WITH THE WALLET, YOUR REMEDY IS TO DISCONTINUE HOLDING AND USE OF THE WALLET.

THE WALLET IS PROVIDED "AS IS" AND WITHOUT ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS, IMPLIED OR STATUTORY. BASTION, OUR AFFILIATES, AND OUR RESPECTIVE OFFICERS, DIRECTORS, AGENTS, JOINT VENTURERS, EMPLOYEES, AND SUPPLIERS SPECIFICALLY DISCLAIM ANY IMPLIED WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT. BASTION TRUST MAKES NO WARRANTY THAT (I) THE WALLET WILL MEET YOUR REQUIREMENTS, (II) THE WALLET WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, OR (III) THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU WILL MEET YOUR EXPECTATIONS. BASTION DOES NOT REPRESENT OR WARRANT THAT THE WALLET WILL BE ERROR-FREE OR UNINTERRUPTED.YOU EXPRESSLY UNDERSTAND AND AGREE THAT BASTION AND OUR AFFILIATES OR SERVICE PROVIDERS, OR ANY OF ITS OR THEIR RESPECTIVE OFFICERS, DIRECTORS, AGENTS, JOINT VENTURERS, EMPLOYEES, AND REPRESENTATIVES WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY DAMAGES, OR DAMAGES FOR LOSS OF PROFITS INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS OF GOODWILL, USE, DATA, OR OTHER INTANGIBLE LOSSES (EVEN IF BASTION HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR OTHERWISE, RESULTING FROM: (I) THE USE OR THE INABILITY TO USE THE WALLET; (II) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS AND SERVICES RESULTING FROM ANY GOODS, DATA, INFORMATION, OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED INTO INVOLVING THE WALLET; (III) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; OR (IV) ANY OTHER MATTER INVOLVING THE WALLET.

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE LIMITATIONS SET FORTH ABOVE MAY NOT APPLY TO YOU.

INDEMNIFICATION

You agree to indemnify and hold Bastion, its affiliates, and service providers, and each of their officers, directors, agents, joint venturers, employees, and representatives harmless from any claim or demand (including attorneys’ fees and any losses, fines, fees or penalties imposed by any regulatory authority) arising out of your breach of these Terms, your violation of any law or regulation or your opening or use of the Wallet.

If you have a dispute with one or more Wallet users or third parties, you release Bastion (and its affiliates and service providers, and each of their officers, directors, agents, joint ventures, employees and representatives) from all claims, demands, and damages (actual and consequential) of every kind and nature arising out of or in any way connected with such disputes.

RISKS AND DISCLOSURES

Can You Lose Money with Digital Assets?

Yes. Any digital asset can lose value. Annex 2 provides very important disclosures about all the risks and risk of financial loss that you assume when you use the Wallet and purchase digital assets. Read this. Do not use the Wallet if these risks are more than you can or are willing to accept.

Bastion Does Not Control Networks

Bastion does not own or control any of the underlying software protocols of the Supported Networks. Bastion is not responsible for the operation of the underlying protocols of any Supported Networks. Bastion makes no guarantees regarding the security, functionality, or availability of any Supported Network, which are subject to attacks and experience backlogs, higher than normal transaction fees, changes to the network, failure or a copy in the protocol. Any such attacks, backlogs, failures, changes or delays on any Supported Network might materially delay or prevent Bastion from sending and receiving digital assets into or out of a Wallet.

A ledger system is not a Supported Network unless Bastion explicitly states it is. Bastion will not support additional features or protocols associated with a Supported Network (e.g., staking, forked protocols, or smart contracts) unless Bastion explicitly states so. Bastion may, in its sole discretion, at any time choose to support or stop supporting a Supported Network. If Bastion requests it, you will take any and all actions reasonably necessary to discontinue a Supported Network. This includes migrating your digital assets to another Supported Network. Bastion is not responsible for any damages, losses, costs, fines, penalties, expenses, whether or not reasonably foreseeable, that you may face if you do not migrate or help migrate digital assets to a different Supported Network.

Does Bastion Provide Investment of Any Type of Financial Advice?

No. Bastion does not provide investment or any type of financial advice. You are responsible for your decisions. If Bastion provides items like blog posts, articles, links to third-party content, news feeds, tutorials, and videos, this is for education and is not investment, financial, or other advice. Bastion does not recommend that you hold any or any particular Digital Asset. Bastion will not be held responsible for the decisions you make to buy, sell, or hold Digital Assets based on the information provided by Bastion or for any other reason.

What if You Have A Complaint or Feedback about the Wallet?

Contact Bastion at complaints@bastion.com. If Bastion cannot resolve your complaint, go to this site https://www.bastion.com/disclosures and follow instructions to contact the regulator in the state in which you reside.

What if You Have A Dispute with Bastion?

THE DISPUTE WILL BE RESOLVED THROUGH ARBITRATION BY AN ARBITER RATHER THAN BY A JUDGE OR JURY THROUGH LITIGATION. DO NOT OPEN A WALLET UNLESS YOU AGREE TO ARBITRATION. BY OPENING THE WALLET YOU AGREE TO ARBITRATE WHICH REQUIRES, WITH LIMITED EXCEPTIONS, THAT ALL DISPUTES BETWEEN YOU AND BASTION SHALL BE RESOLVED BY BINDING AND FINAL ARBITRATION. ANNEX 3 ALSO CONTAINS A CLASS ACTION AND JURY TRIAL WAIVER. READ IT CAREFULLY.

ABOUT YOUR WALLET AND YOUR DATA

Who is Allowed (Eligible) to Open A Wallet and Use It?

You must be 18 years old or older and reside in the United States. You cannot have someone sign up for the Wallet for you or sign up for someone else. Only You can use the Wallet that you sign up for.

What Information Do You Have to Provide and Update?

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

You must identify where you reside and where you are located when you sign up for the Wallet. You must update that information and your contact information if and when it changes via the application or customer support (support@bastion.com)

Your location and residence may limit or prevent you from opening or using your Wallet. You must provide enough information for Bastion to verify your identity.

You also have to provide to Bastion personal information, such as your name, address, telephone number, e-mail address, date of birth, taxpayer identification number, government identification, and information regarding your bank account (such as the name of the bank, the account type, routing number, and account number), occupation, information about your source of funds and purpose of transaction / account, and in some cases (where permitted by law), special categories of personal data, such as your biometric information. You may be required to provide additional information or documentation, such as an acceptable form of identification and selfie, and verify the truth of information provided. Any transaction may be delayed while Bastion evaluates information you provide and declined.

Bastion May Not Open A Wallet For You (or Let You Continue Using One Once Opened)

In its sole discretion, based on inability to verify your identity, questions about your location, or based on your activity, Bastion may decline to open a wallet for you or allow you to continue using it. See Annex A for activity that is prohibited. Any such activity will result in your loss of the use of the Wallet.

Is Your Wallet Use Subject to Limits?

Yes. Bastion in its sole discretion may limit the number and amount of transactions you can make in a particular period. Your transaction limits may vary depending on your payment method, verification steps you have completed, and other factors. Bastion reserves the right to change applicable limits, and to refuse to raise your limits. Bastion has full discretion to do so or decline to do so.

What Happens to Your Data When You Use the Wallet

By signing up for and using your Wallet, you agree to share the requested information with Bastion at sign up and related to all transactions you make. Bastion will use this information to verify your identity and location and to monitor for and seek to prevent money laundering, terrorist financing, sanctions violations, and fraud. This also includes monitoring for prohibited and suspicious activity. Bastion shares information with affiliates and vendors during this process. You agree to this use and sharing to provide you with services. You also acknowledge and agree that Bastion will keep records of such information as required by law.

By opening the Wallet you acknowledge you have read, understand, and agree to the important privacy information in Bastion's Privacy Policy https://support.bastion.com/hc/en-us/articles/53791564924052-Bastion-Privacy-Policy. That privacy policy explains how Bastion collects, stores, protects, and uses your personal information and governs how Bastion processes your personal data. Bastion may share your personal information with affiliates and third parties to help provide Services related to virtual currency custody and transfers. You agree to this information sharing by opening a Wallet.

You consent to Bastion accessing, processing and retaining any personal information you provide for the purpose of Bastion providing Services to you. You also consent to Bastion sharing that data with our service providers to provide the Services to you.

If you do not agree to this data use and sharing, do not open a Wallet. In the future if you no longer agree to this use and sharing of your data or any other part of these Terms, you may close your Wallet. That is your only recourse.

You represent and warrant that 1) you have and will only provide accurate data, 2) any personal data you provide about someone other than you is provided in accordance with all applicable data protection and data privacy laws.

Freezing and or Burning Virtual Currency in Your Wallet

Law enforcement or regulators may ask or direct Bastion to seize, freeze virtual currency in your Wallet and or to block wallet addresses, including yours. Bastion will comply with those requests and may opt to take these actions in its sole discretion to reduce risks. You may not receive notice and may lose your assets. Bastion will comply with lawful orders. In its sole discretion to address compliance or risk issues, Bastion may burn and destroy virtual assets held in a Wallet. You may lose some or all of your assets as a result of any of this, and Bastion is not responsible or liable for your financial loss.

Changes in Laws and Regulations

In many jurisdictions, the laws and regulations that apply to Wallets, digital assets, and blockchain technology are not clear. Bastion is not responsible for determining how the law, including tax laws, affect or may affect you or your transactions now or in the future. Changes outside its control or awareness may affect the value, functionality, nature, use, transfer and/or redemption of assets in your Wallet and Bastion’s ability to offer Wallets and services in certain places. By opening and continuing to have the Wallet, you accept this risk and the risk you will lose access to assets in your Wallet. Bastion is not responsible for any losses.

Transactions Are Not Reversible

Once you give Basiton an instruction to transfer your Supported Digital Assets or to on or off ramp, you cannot undo it.

No Preauthorized transactions are Allowed

You cannot set up recurring transactions in your Wallet. Bastion does not support preauthorized transactions.

What Digital Assets Are Supported in the Wallet

Do not use the Wallet for any assets other than Supported Digital Assets. Bastion is not responsible for any losses or challenges you incur based on any attempt to send, hold, or receive anything other than Supported Digital Assets. Bastion may in its sole discretion stop supporting any particular Digital Asset. After Bastion stops supporting a Digital Asset, you must send it from your Wallet or lose access to it. Bastion may remove it from your Wallet and replace it with a Supported Digital Asset of the same amount minus any cost to conduct the transaction.

Your Wallet will not support metacoins, colored coins, side chains, or other derivative, enhanced, or forked protocols, tokens, or coins or other functionality, such as staking, protocol governance, and/or any smart contract functionality, which may supplement or interact with a Supported Digital Asset. If you try to use your Wallet and Supported Digital Assets for unsupported activity or supplemental protocols, Bastion is not responsible for any losses. You are.

In securing Supported Digital Assets for you in your Wallet, Bastion may interact with multiple chains to swap the origin asset to and from the Supported Digital Asset. Bastion may rely on protocols outside its control and is not responsible for delays and unreliability of those protocols.

Omnibus Accounts, Sub-Custody, and Discretionary Rewards. Bastion may use shared blockchain addresses, controlled by Bastion or third party service providers, to hold Supported Digital Assets for Wallets on behalf of customers and/or held on behalf of Bastion. For instance, your assets may be held at Coinbase as a sub-custodian of Bastion, and Bastion remains responsible for your assets while in sub-custody. In the event incentives are earned on the assets held in an omnibus account at Coinbase, the White Label Company may opt to distribute rewards to you in its sole discretion. You are responsible for any tax consequences for participating in any Rewards program offered by White Label Company. Any rewards program will be subject to terms provided to you separate from these by White Label Company. Although we maintain separate ledgers, Bastion shall have no obligation to create a segregated blockchain address for your Supported Digital Assets.

Who Owns the Digital Assets in Your Wallet?

You do. Bastion holds the assets for your benefit. The assets are not Bastion’s and are not subject to the claims of Bastion’s creditors in the event of bankruptcy. Because you are the owner of the Supported Digital Assets in your Wallet, you bear all risk of loss of such Supported Digital Assets. Bastion is not liable to you for the fluctuation in the value of the Digital Assets in your Wallet. Bastion will not sell, transfer, loan, hypothecate, or otherwise alienate Supported Digital Assets in your Wallet unless instructed by you.

As the owner of the assets in your Wallet, you can instruct Bastion to transfer your Supported Digital assets to a different blockchain address. That will result in a debit from your Wallet balance. Executing that transaction may be subject to delay based on outages, downtime, protocol requirements, time to conduct blockchain operations to fulfill your request, and applicable compliance policies and processes. As long as you continue to hold Supported Digital Assets with Bastion, Bastion shall retain control over electronic private keys associated with blockchain addresses operated by Bastion, including the blockchain addresses used to hold the Supported Digital Assets credited to your Wallet.

Unauthorized and Incorrect Transactions. When a Digital Asset Transaction or U.S. dollar transaction occurs using your credentials, we will assume that you authorized such transaction, unless you notify us otherwise. If you believe you did not authorize a particular transaction or that a transaction was incorrectly carried out, you must contact us as soon as possible via support@bastion.com or by phone at (888) 608-4151 (international call charges may apply). It is important that you regularly check your Wallet and your transaction history to ensure you notify us as soon as possible of any unauthorized or incorrect transactions. Reporting an unauthorized transaction does not guarantee you will be able to recover the transaction. You are liable for unauthorized transactions if unauthorized access was a result of how you maintained your access credentials.

How do you know your Wallet balance?

You will be able to see your Wallet balance through your Wallet interface. You can also see your transaction history, including (i) the amount (and currency) of each Digital Asset Transaction; (ii) a reference to the identity of the payer and/or payee (as appropriate); (iii) any fees charged (excluding any spread, or margin, over the prevailing market rate on Bastion’s partner’s trading platform); (iv) if applicable, the rate of exchange, and the amount (in the new currency) after exchange (where you are the payer) or the amount (in the original currency) before the exchange (where you are the payee); and (v) the date of each Digital Asset Transaction.

Can You Reverse a Transaction?

No. You cannot cancel, reverse, or change any transaction marked as complete or pending. If your payment is not successful, if your payment method has insufficient funds, or if you reverse a payment made from funds in your bank account, you authorize Bastion, in its sole discretion, to cancel the transaction or debit your other payment methods, including your Wallet balance, in any amount necessary to complete the transaction. You are responsible for maintaining an adequate balance and/or sufficient credit limits in order to avoid overdraft, non-sufficient funds (NSF), or similar fees charged by your account or payment provider. Bastion has the right to refuse to process, or to cancel, correct, clawback, or reverse, any transaction in our sole discretion, even after funds have been debited from your account(s), in response to a subpoena, court order, or other government order; or if we suspect the transaction may: involve money laundering, terrorist financing, fraud, or any other type of financial crime; be erroneous; or relate to a Prohibited Use or a Prohibited Business as set forth in the Annex 1. In such instances, Bastion will reverse the transaction and we are under no obligation to reinstate a purchase or sale order at the same price or on the same terms as the canceled transaction.

Information about your Wallet Functionality

Your Wallet enables you to send Supported Digital Assets to and receive Supported Digital Assets from other Bastion Wallets and some third party wallets. When sending to a wallet address the first time, send a small amount of Supported Digital Assets as a test before sending a significant amount of Supported Digital Assets.

Pending Transactions

Once a Digital Asset Transfer is submitted to a Digital Asset network, the transaction will be unconfirmed and remain in a pending state for a period of time sufficient to allow confirmation of the transaction by the Digital Asset network. A Digital Asset Transfer is not complete while it is in a pending state. Pending Digital Asset Transfers from your Wallet will reflect a pending transaction status and are not available to you while the transaction is pending.

Inbound Digital Asset Transfers

When you or a third party sends Digital Assets to a Wallet from an external wallet (“Inbound Transfers”), the person initiating the transaction is solely responsible for executing the transaction properly, which includes ensuring that the Digital Asset being sent is a Supported Digital Asset that conforms to the particular wallet address to which funds are directed.

Receipts

You will receive an electronic receipt for your transactions. These must make apparent the details of your transaction, including fees.

Supported Digital Assets

Bastion may from time to time determine types of Digital Assets that will be supported or cease to be supported.

Inaccurate Wallet Addresses or Account Numbers

When you send Supported Digital Assets from your Wallet to an external wallet (“Outbound Transfers” or “exports”), Bastion executes your instruction. Verify all transaction information prior to submitting instructions. Bastion will not bear the liability or responsibility in the event you enter an incorrect blockchain destination address, incorrect Destination Tag/Memo, or if you send your Supported Digital Assets to an incompatible wallet. The same is true if you enter an erroneous bank account number when using Ramp Services. Be careful or you will lose money.

Bastion does not guarantee the identity or value received by a recipient of an Outbound Transfer. Digital Asset Transfers cannot be reversed once they have been broadcast to the relevant Digital Asset network, although they may be in a pending state, and designated accordingly, while the transaction is processed by network operators. Bastion does not control the Digital Asset network and makes no guarantees that a Digital Asset Transfer will be confirmed by the network. Bastion may cancel or refuse to process any pending Outbound Digital Asset Transfers as required by law or any court or other authority to which Bastion is subject in any jurisdiction. Additionally, Bastion may require you to wait some amount of time after completion of a transaction before permitting you to use further Bastion Services and/or before permitting you to engage in transactions beyond certain volume limits.

USDC in Your Wallet

Circle Internet Financial (“Circle”) issues USDC and is responsible for managing the reserve of U.S. Dollars backing USDC. Bastion has no responsibility to manage those reserves or ensure U.S. Dollars are available for you when you seek to redeem your USDC. You can redeem your USDC with Circle. You agree to be bound by the terms of the Circle USDC User Agreement (located at https://www.circle.com/legal/usdc-terms), which provides additional obligations, undertakings, and limitations with respect to USDC.

Regularly check your Wallet for any transactions or activity that looks suspicious.

Alert Bastion and White Label Company if you suspect your Wallet or security details have been compromised or if you think you have been the victim of fraud or attempted fraud. These are potential Security Breaches. You must notify Bastion Support immediately at support@bastion.com or (888) 608-4151 and provide accurate and up to date information throughout the duration of the Security Breach. You must take any steps that we reasonably require to reduce or manage any Security Breach. Prompt reporting of a Security Breach does not guarantee that Bastion will reimburse you for any losses suffered or be liable to you for any losses suffered as a result of the Security Breach.

Closing Your Wallet

You may close your Bastion Wallet at any time. You will not be charged for closing your Wallet, although you will be required to pay any outstanding amounts owed to Bastion or White Label Company. You authorize us to cancel or suspend any pending transactions at the time of Wallet closure. Bastion may discontinue or change any product, service, or feature, in its sole discretion, at any time. You agree that we may transfer you to a product or service that is reasonably similar to the discontinued or changed product or service, to the extent such product or service exists. We will provide you with 14 days’ prior notice of material changes, discontinuation, or the transfer related to a product, service, or feature, to the extent required or applicable.

What if You Open but do not Use Your Wallet

After a year without activity in your wallet, Bastion may charge you an administrative fee of $1.00 per year. You agree to this fee by opening a Wallet and agree that the fee may be deducted from any balance you have in the Wallet.

Unclaimed Assets

If for several years you do not access your Wallet, assets remain in your wallet, and you can’t be contacted, applicable law requires Bastion to deliver the assets in your Wallet to the applicable state or jurisdiction as unclaimed property.

OTHER AND GENERAL PROVISIONS

Computer Viruses. Bastion shall not bear any liability, whatsoever, for any damage or interruptions caused by any computer viruses or other malicious code that may affect your computer or other equipment, or any phishing, spoofing or other attack. We advise the regular use of reputable virus screening and prevention software. You should also be aware that SMS and email services are vulnerable to spoofing and phishing attacks and should use care in reviewing messages purporting to originate from Bastion.

Intellectual Property and Limited License. Bastion retains all ownership of its intellectual property. Bastion grants a limited, nonexclusive, nontransferable license, subject to the terms of this Agreement, to access and use the Bastion services solely for purposes approved by Bastion from time to time. Any other use is expressly prohibited and all other right, title, and interest in the Bastion Services is exclusively the property of Bastion and its licensors. You agree you will not copy, transmit, distribute, sell, license, reverse engineer, modify, publish, or participate in the transfer or sale of, create derivative works from, or in any other way exploit any of the Content, in whole or in part without the prior written consent of Bastion.

Secure your devices and passwords used to access your wallet

You are responsible for securing your devices and creating a strong password to protect access to your Wallet and the device you use to access your Wallet. Your failure to do so may result in unauthorized access to your Wallet and assets in your Wallet. Bastion will never ask you for your passwords, authentication codes, or to screen share on any device. Bastion is not responsible for any loss you may sustain as a result of a compromise of your device, credentials, or Wallet. Bastion also is not liable for your failure to notice or act on any alerts we may send you.

Taxes. The tax treatment of digital assets is uncertain and subject to change. You are responsible to determine what, if any, tax consequences arise from your use of the Wallet and digital assets. Wallet users are solely responsible for reporting and paying any applicable taxes arising from transactions. You acknowledge Bastion does not provide investment, legal, or tax advice governing these transactions. You should conduct your own due diligence and consult your own tax advisors before making any decisions with respect to Digital Asset transactions.You understand that Bastion may report information about your Wallet transactions and payments to relevant governmental authorities.

Entire Agreement. This Agreement, the Privacy Policy, E-Sign Disclosure and Consent Policy, Prohibited Use Policy, and Appendices incorporated by reference herein comprise the entire understanding and agreement between you and Bastion.

Section headings in this Agreement are for convenience only and shall not govern the meaning or interpretation of any provision of this Agreement.

Assignment. Bastion reserves the right to assign our rights to any Bastion affiliate or to any successor in interest. Bastion reserves the right to transfer or assign the information we have collected from you as part of any merger, acquisition, sale, or other change of control. You may not assign any rights and/or licenses granted under this Agreement.

Severability. If any provision of this Agreement is determined to be invalid or unenforceable, such provision will be changed and interpreted to accomplish the objectives of the provision to the greatest extent possible under any applicable law and the validity or enforceability of any other provision of this Agreement shall not be affected.

Survival. All provisions of this Agreement which by their nature extend beyond the expiration or termination of this Agreement. This includes provisions about how your Wallet is handled, limitations or liability, and escheatment.

Force Majeure. Bastion is not be liable for any failure or delay in the performance of the Services to the extent caused by matters beyond Bastion’s reasonable control, including, without limitation: closure or unavailability of required network infrastructure; changes in government or laws; power or internet failure; civil unrest; war; and fires and natural disasters.

Non-Waiver of Rights. This Agreement shall not be construed to waive rights that cannot be waived under applicable laws, including applicable state money transmission laws in the state where you are located.

Governing Law. You and we agree that the laws of the State of New York, without regard to principles of conflict of laws, will govern the Agreement and any Dispute, except to the extent governed by the Federal Arbitration Act or other applicable federal law.

ANNEX 1: Prohibited Activities & Business Types

Activity that is Unlawful: Activity that would violate or help violate any law, statute, ordinance, or regulation or sanctions program in any country where You or Bastion are or operate. Any activity involving the proceeds of unlawful activity.
Purchasing items from the “Darknet”: Purchasing goods of any type from “Darknet” markets, or any other service or website that acts as a marketplace for illegal goods–even if it also sells legal goods.
Fraud: Fraudulent activity or attempting to defraud anyone in any way using your Wallet or any Bastion product or system.
Sexual exploitation of children or any other being
Activity that Harms Others or Infringes on Their Rights: Interfering with anyone’s access to or use of their digital assets; defame, abuse, extort, harass, stalk, threaten, or otherwise violate or infringe the legal rights (such as, but not limited to, rights of privacy, publicity and intellectual property) of others; incite, threaten, facilitate, promote, or encourage hate, racial intolerance, or violent acts against others; harvest or otherwise collect information from
Activity that Undermines Bastion’s Systems: Engaging in activity that puts an unreasonable load on Bastion’s infrastructure. Interfering with or unauthorized access to take any data or information from any system of Bastion. Transmitting or uploading any material to the Bastion’s computer systems that contains viruses, Trojan horses, worms, or any other harmful or deleterious programs. Attempting to gain unauthorized access to the Bastion’s computer systems or networks connected to the Bastion’s computer systems, through password mining or any other means. Using someone else’s information to access or use Bastion’s computer systems, or transferring Your access or rights to Your Wallet to a third party, unless by operation of law or with the Bastion’s express permission. Accessing or trying to access the Bastion’s computer systems to obtain information about others without proper consent.
Fake Transactions and Fake Identities: Attempting to execute or executing fake or fictitious transactions or using a fake identity in any way.
Manipulating the Market: Using, holding, or placing orders to create market volatility or manipulate the price of a virtual asset. Doing this or helping someone attempt to or to do this is deemed to have harmed Bastion.
Infringing on Intellectual Property Rights: Engage in transactions involving items that infringe or violate any copyright, trademark, right of publicity, or privacy or any other proprietary right under the law, including but not limited to sales, distribution, or access to counterfeit music, movies, software, or other licensed materials without the appropriate authorization from the rights holder; use of Bastion’s intellectual property, name, or logo, including use of Bastion’s trade or service marks, without express consent or in a manner that otherwise harm the brand; any action that implies an untrue endorsement by or affiliation with Bastion.
Infringing on intellectual property rights like buying or selling counterfeit music, goods, or items of any kind.
Dealing in any way in stolen or counterfeit items. Unauthorized sale or resale of brand name or designer products or services; sale of goods or services that are illegally imported or exported or which are stolen.

Prohibited Business Types

Bastion’s agreements with Banks and Card Networks also prevent the Wallets from supporting the following types of businesses. These may change from time to time.

Gambling (if unlawful); Unregulated casinos, gaming & gambling operators
All cannabis/marijuana‑related businesses (including CBD / hemp products and any marijuana products and paraphernalia), including those operating legally, in legal gray zones, or unlicensed.
Arms manufacturing & distribution w/o licensing; Firearms (Face-to-Face)
Online Marketplaces
Ticket Brokers
Pharmacies (Brick & Mortar)
Pharmaceuticals or pseudo-pharmaceuticals that make unapproved or unverified health claims
Pyramid schemes, pump and dump schemes, or similar schemes
Any other high risk businesses as determined in the Bastion’s sole discretion
Unlicensed money service businesses (MSBs) & Virtual asset service providers (VASPs)
Shell banks & unregulated financial institutions
Ransomware operators
Crypto ATMs & P2P exchanges w/o licensing

Drugs and Drug Paraphernalia: Sale of narcotics, controlled substances, and any equipment designed for making or using drugs, such as bongs, vaporizers, and hookahs.

Pseudo-Pharmaceuticals: Pharmaceuticals and other products that make health claims that have not been approved or verified by the applicable local and/or national regulatory body.
Substances designed to mimic illegal drugs: Sale of a legal substance that provides the same effect as an illegal drug (e.g., salvia, kratom).
Adult Content and Services: Pornography and other obscene materials (including literature, imagery and other media); sites offering any sexually-related services such as prostitution, escorts, pay-per view, adult live chat features.
Multi-level Marketing: Pyramid schemes, network marketing, and referral marketing programs.
Unfair, predatory or deceptive practices: Investment opportunities or other services that promise high rewards; sale or resale of a service without added benefit to the buyer; resale of government offerings without authorization or added value; sites that we determine in our sole discretion to be unfair, deceptive, or predatory towards consumers.
High risk businesses: Any businesses that Bastion, in its sole discretion, believes presents higher than reasonable financial or legal risk or violates card network rules or bank policies.

Bastion also may in its sole discretion require additional information from You for any reason, including to provide services to money service or payment businesses, prepaid card providers, charities, games of skills, and non-profit organizations.

What if You Have Questions About Prohibited Activities and Business Types?

Contact Bastion at Compliance@Bastion.com. Bastion may allow some business if they provide additional information.

ANNEX 2: Important Information and Disclosures About Virtual Currencies

Digital assets and virtual assets have the same meaning. The same risks apply. By opening a Wallet you acknowledge you understand the following.

WARNING: LOSSES DUE TO FRAUDULENT OR ACCIDENTAL TRANSACTIONS MAY NOT BE RECOVERABLE AND TRANSACTIONS IN VIRTUAL CURRENCY ARE IRREVERSIBLE.

Virtual currency is not legal tender, is not backed by the U.S. federal government or any U.S. state, and accounts and value balances are not subject to Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration or Securities Investor Protection Corporation protections;
Legislative and regulatory changes or actions at the State, Federal, or international level may adversely affect the use, transfer, exchange, and value of virtual currency;
Transactions in virtual currency may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable. Virtual currency transactions, in part because they are irreversible and are used by persons seeking to defraud customers, including, but not limited to, a person impersonating a customer's loved one, threatening jail time, stating that a customer's identity has been stolen, insisting that a customer withdraw money from the customer's bank account and purchase cryptocurrency or alleging a customer's personal computer has been hacked.
Some virtual currency transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction;
The value of virtual currency may be derived from the continued willingness of market participants to exchange fiat currency for virtual currency, which may result in the potential for permanent and total loss of value of a particular virtual currency should the market for that virtual currency disappear;
There is no assurance that a person who accepts a virtual currency as payment today will continue to do so in the future;
The volatility and unpredictability of the price of virtual currency relative to fiat currency may result in significant loss over a short period of time;
The nature of virtual currency may lead to an increased risk of fraud or cyber attack;
The nature of virtual currency means that any technological difficulties experienced by the licensee may prevent the access or use of a customer’s virtual currency; and
Any bond or trust account maintained by Bastion, the licensee, for the benefit of its customers may not be sufficient to cover all losses incurred by customers. Similarly, although Bastion maintains cybersecurity-related insurance, that coverage may not be sufficient to cover all losses. Residents of California may contact BPUS to request additional information about such insurance coverage.

ANNEX 3: ARBITRATION AGREEMENT, CLASS ACTION WAIVER, JURY TRIAL WAIVER

BY SIGNING UP FOR A WALLET, YOU AGREE ANY DISPUTE WILL BE RESOLVED THROUGH ARBITRATION BY AN ARBITER RATHER THAN BY A JUDGE OR JURY THROUGH LITIGATION. DO NOT OPEN A WALLET UNLESS YOU AGREE TO ARBITRATION. BY OPENING THE WALLET YOU AGREE TO ARBITRATE WHICH REQUIRES, WITH LIMITED EXCEPTIONS, THAT ALL DISPUTES BETWEEN YOU AND BASTION SHALL BE RESOLVED BY BINDING AND FINAL ARBITRATION.

WAIVER OF RIGHT TO BRING CLASS ACTION AND REPRESENTATIVE CLAIMS.

To the fullest extent permitted by applicable law, you and Bastion each agree that any proceeding to resolve any dispute, claim, or controversy will be brought and conducted ONLY IN THE RESPECTIVE PARTY’S INDIVIDUAL CAPACITY AND NOT AS PART OF ANY CLASS (OR PURPORTED CLASS), CONSOLIDATED, MULTIPLE-PLAINTIFF, OR REPRESENTATIVE ACTION OR PROCEEDING (“CLASS ACTION”).

You and Bastion AGREE TO WAIVE THE RIGHT TO PARTICIPATE AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS ACTION. You and Bastion EXPRESSLY WAIVE ANY ABILITY TO MAINTAIN A CLASS ACTION IN ANY FORUM. If the dispute is subject to arbitration, THE ARBITRATOR WILL NOT HAVE THE AUTHORITY TO COMBINE OR AGGREGATE CLAIMS, CONDUCT A CLASS ACTION, OR MAKE AN AWARD TO ANY PERSON OR ENTITY NOT A PARTY TO THE ARBITRATION. Further, you and Bastion agree that the ARBITRATOR MAY NOT CONSOLIDATE PROCEEDINGS FOR MORE THAN ONE PERSON’S CLAIMS, AND IT MAY NOT OTHERWISE PRESIDE OVER ANY FORM OF A CLASS ACTION. For the avoidance of doubt, however, you can seek public injunctive relief to the extent authorized by law and consistent with the Exceptions clause above.

IF THIS CLASS ACTION WAIVER IS LIMITED, VOIDED, OR FOUND UNENFORCEABLE, THEN, UNLESS THE PARTIES MUTUALLY AGREE OTHERWISE, THE PARTIES’ AGREEMENT TO ARBITRATE SHALL BE NULL AND VOID WITH RESPECT TO SUCH PROCEEDING SO LONG AS THE PROCEEDING IS PERMITTED TO PROCEED AS A CLASS ACTION. If a court decides that the limitations of this paragraph are deemed invalid or unenforceable, any putative class, private attorney general, or consolidated or representative action must be brought in a court of proper jurisdiction and not in arbitration. TO THE MAXIMUM EXTENT ALLOWABLE BY LAW, YOU ALSO AGREE TO WAIVE A JURY TRIAL IF A CASE IS ADJUDICATED IN COURT RATHER THAN IN ARBITRATION.