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Terms of Service

Last updated: March 22, 2026

1. Acceptance of Terms

By creating an account or using any Fazen Pay service, you agree to be bound by these Terms of Service (“Terms”). If you do not agree, do not use our services. Fazen Pay reserves the right to update these Terms; continued use after changes constitutes acceptance.

2. Eligibility

  • You must be at least 18 years old.
  • You must be a resident of a supported European Economic Area (EEA) country.
  • You must not be a person subject to financial sanctions by the EU, UN, or OFAC.
  • Access is currently by invitation only during the beta period.

3. Account & Security

You are responsible for maintaining the confidentiality of your PIN and device access. You must notify us immediately of any unauthorized use. We are not liable for losses resulting from your failure to safeguard your credentials.

  • One account per person. Duplicate accounts will be terminated.
  • Accounts are non-transferable.
  • We may suspend or close your account if we detect suspicious activity, regulatory non-compliance, or violation of these Terms.

4. Banking Services

Fazen Pay provides EUR account management, SEPA transfers, and virtual card issuance through our licensed banking-as-a-service partner, Striga Technology OUE, an authorized Electronic Money Institution (EMI) in the European Union.

  • Funds held in your EUR account are electronic money issued by Striga and are safeguarded in accordance with the EU Electronic Money Directive (EMD2).
  • SEPA transfers are subject to velocity limits (per-transaction, daily, and weekly) designed to prevent fraud and comply with AML regulations.
  • Virtual cards are issued by Striga and subject to their card program terms.

5. Crypto Custody (MPC Vault)

Fazen Pay offers self-custody crypto wallets powered by Multi-Party Computation (MPC) technology via Privy. The vault feature allows you to hold stablecoins (EURe, USDC, USDT) in your own on-chain wallet.

  • The MPC vault is classified as a self-hosted wallet under MiCA Art. 3(1)(19). No additional KYC is required for vault operations beyond the standard account KYC.
  • No single party (including Fazen Pay) holds a complete private key. Keys are sharded using MPC across multiple parties.
  • You are solely responsible for the assets in your vault. Fazen Pay does not hold, manage, or control your crypto assets.
  • Blockchain transactions are irreversible. Fazen Pay cannot recover funds sent to incorrect addresses.

6. KYC & AML Compliance

Full banking features (SEPA transfers, card issuance) require identity verification (KYC) in compliance with EU AMLD5/6. Verification is performed by our partner Sumsub.

  • You must provide accurate and truthful identity information.
  • We may request additional documentation at any time for ongoing compliance.
  • Failure to complete KYC or provide requested documents may result in service restrictions or account closure.

7. Prohibited Activities

You agree not to use Fazen Pay services for:

  • Money laundering, terrorist financing, or sanctions evasion.
  • Fraud, identity theft, or unauthorized transactions.
  • Circumventing velocity limits or transaction monitoring.
  • Reverse engineering, scraping, or attacking our systems.
  • Any activity that violates applicable laws or regulations.

8. Fees

Fazen Pay currently does not charge fees for account maintenance, SEPA transfers, or virtual card issuance during the beta period. We reserve the right to introduce fees with 30 days' advance notice. Blockchain network fees for crypto transactions are borne by the user and are not controlled by Fazen Pay.

9. Limitation of Liability

To the maximum extent permitted by applicable law, Fazen Pay shall not be liable for indirect, incidental, special, or consequential damages arising from the use of our services. Our total liability shall not exceed the fees paid by you in the 12 months preceding the claim.

We are not liable for losses caused by blockchain network issues, smart contract vulnerabilities in third-party protocols, regulatory actions, or events beyond our reasonable control (force majeure).

10. Beta Period

Fazen Pay is currently in invitation-only beta. During this period, services may be modified, interrupted, or discontinued without advance notice. Beta users acknowledge that the platform may contain bugs or experience downtime.

11. Governing Law

These Terms are governed by the laws of the Italian Republic. Any disputes shall be resolved in the courts of Milan, Italy, except where EU consumer protection regulations provide otherwise.

12. Contact

For questions about these Terms, contact us at legal@fazenpay.com.