Effective Date:27/04/26
1. INTRODUCTION AND AGREEMENT
1.1 Agreement Formation
These Terms of Service ("Terms") constitute a legally binding agreement between you and Privacy Pay Ltd. ("Privacy Pay," "Company," "we," "us," or "our") governing your access to and use of the Privacy Pay platform, including our website, applications, dashboards, payment infrastructure, APIs, execution layers, agent interfaces, and any related products or services (collectively, the "Platform" or "Service").
By accessing, browsing, or using the Platform in any manner, you acknowledge that you have read, understood, and agree to be bound by these Terms, together with all applicable laws and regulations. If you do not agree to these Terms, you must not access or use the Platform.
1.2 Platform Description
Privacy Pay is a private payments infrastructure layer for Solana, enabling confidential, compliant, and programmable transactions for individuals, businesses, and autonomous agents.
The Platform provides:
private execution of payments through encrypted execution environments;
confidential SPL transfers without exposing sender, recipient, or amount relationships;
programmable payment flows including split payments, scheduled releases, batch execution, and streaming;
compliance checks including wallet screening and transaction monitoring prior to execution;
APIs and agent-compatible interfaces for embedding private payments into applications and workflows;
infrastructure for payroll, agentic commerce, and global payment systems.
Privacy Pay enables users and agents to transact on chain while preserving confidentiality. The Platform does not provide banking services, custody, financial advice, or legal advice.
1.3 Platform Vision and Purpose
Privacy Pay is built to redefine how value moves onchain by making privacy the default layer for payments.
As blockchain adoption increases, fully transparent transactions create operational, strategic, and personal risks. Privacy Pay provides a system for:
enabling confidential financial interactions on public blockchains;
supporting businesses with payroll, payouts, and financial operations without exposure;
enabling agents to execute economic actions natively;
maintaining compliance while eliminating unnecessary public data leakage.
Our vision is to make private, programmable, and compliant payments the standard for both humans and autonomous systems.
1.4 Modifications to Terms
We reserve the right to modify, update, or replace these Terms at any time, in our sole discretion. When changes are made, the "Last Updated" date at the top of the Terms will be revised.
Material changes will be made accessible through the Platform. Your continued use of the Platform following any such modifications constitutes your acceptance of the updated Terms.
If you do not agree with the modifications, you must immediately discontinue use of the Platform.
2. DEFINITIONS AND INTERPRETATION
2.1 Key Definitions
In these Terms, the following capitalized terms shall have the meanings set forth below:
"Private Payments API" means the interface enabling confidential onchain transactions.
"Execution Layer" (ER / TEE) means the offchain secure environment where payment logic executes privately.
"Agent Interface" means CLI, APIs, or systems that allow autonomous agents to initiate and manage transactions.
"User Data" means transaction inputs including sender, recipient, amount, and scheduling parameters.
"Transaction Output" means the final settlement of transactions onchain.
"Compliance Checks" means AML screening, sanctions checks, and risk monitoring applied before execution.
3. ELIGIBILITY AND ACCESS RESTRICTIONS
3.1 General Eligibility Requirements
To access and use the Platform, you must be at least eighteen (18) years of age or the age of legal majority in your jurisdiction. You must possess the legal capacity to enter into binding agreements.
3.2 Compliance with Laws
You agree to comply with all applicable laws, regulations, and rules in your jurisdiction relating to financial activity, data privacy, and blockchain usage.
You agree not to use the Platform for any illegal purposes, including but not limited to:
money laundering, terrorism financing, or fraud;
sanctions violations;
unauthorized financial activity.
3.3 Prohibited Jurisdictions
The Platform is not available to residents, citizens, or individuals located in the United States, the United Kingdom, Canada, or any jurisdiction subject to comprehensive economic sanctions administered by the Office of Foreign Assets Control (OFAC) or other applicable sanctions authorities. You should not access or use the Platform if you are located in, a resident of, or a citizen of any jurisdiction where such access would be illegal or prohibited under applicable laws. By using the Platform, you represent and warrant that you are not subject to sanctions imposed by any governmental or regulatory authority and that you are not acting on behalf of any sanctioned person or entity. You must not use virtual private networks (VPNs), proxy servers, or any other tools to bypass geographic restrictions or conceal your location.
3.3 Prohibited Jurisdictions
The Platform is not available to residents, citizens, or individuals located in the United States, the United Kingdom, Canada, or any jurisdiction subject to comprehensive economic sanctions administered by the Office of Foreign Assets Control (OFAC) or other applicable sanctions authorities.
You should not access or use the Platform if you are located in, a resident of, or a citizen of any jurisdiction where such access would be illegal or prohibited under applicable laws.
By using the Platform, you represent and warrant that you are not subject to sanctions imposed by any governmental or regulatory authority and that you are not acting on behalf of any sanctioned person or entity.
You must not use virtual private networks (VPNs), proxy servers, or any other tools to bypass geographic restrictions or conceal your location.
4. PLATFORM FUNCTIONALITY
4.1 Private Payments Infrastructure
The Platform enables users to send and manage payments with confidentiality guarantees.
Privacy Pay supports:
private transfers with hidden sender-recipient relationships;
split payments across multiple recipients;
scheduled and time-delayed releases;
batch payments at scale;
real-time salary streaming;
automated payroll systems;
agent-executed transactions and workflows.
All transactions ultimately settle onchain while maintaining privacy at the execution layer.
4.2 Compliance, Monitoring, and Risk Controls
The Platform includes built-in compliance systems designed to ensure lawful usage:
wallet screening prior to transaction execution;
AML and transaction monitoring checks;
sanctions enforcement and geofencing;
automated blocking of restricted activity.
These systems operate by default and cannot be bypassed.
4.3 Pricing, Usage Tiers, and Access
All Platform usage is subject to pricing structures defined by Privacy Pay, which may include:
API usage fees;
transaction-based fees;
enterprise integrations;
rate limits and execution limits.
Pricing structures may be modified at any time.
5. USER RESPONSIBILITIES AND TECHNICAL COMPETENCE
(kept largely identical in structure to LensOS, lightly adapted)
You are solely responsible for:
managing wallets, keys, and credentials securely;
verifying transaction parameters before execution;
ensuring correct integration of APIs and agent systems;
maintaining operational safeguards in automated systems.
Privacy Pay does not recover lost keys or reverse transactions once executed.
6. INTELLECTUAL PROPERTY RIGHTS
Privacy Pay owns all intellectual property rights in the Platform, including APIs, execution systems, and underlying infrastructure.
A limited, non-exclusive, non-transferable license is granted for use of the Platform subject to these Terms.
7. LIMITATION OF LIABILITY
7.1 General Liability Limitations
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE TOTAL AGGREGATE LIABILITY OF PRIVACY PAY ARISING OUT OF OR RELATED TO THESE TERMS OR YOUR USE OF THE PLATFORM SHALL NOT EXCEED ONE HUNDRED UNITED STATES Dollar ($100), OR THE EQUIVALENT AMOUNT IN OTHER CURRENCIES. THIS LIMITATION APPLIES TO ALL CLAIMS, WHETHER ARISING IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, STATUTORY LIABILITY, OR ANY OTHER LEGAL THEORY, EVEN IF PRIVACY PAY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR IF A REMEDY FAILS OF ITS ESSENTIAL PURPOSE.
7.2 Exclusion of Consequential and Indirect Damages
IN NO EVENT SHALL PRIVACY PAY BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, LOSS OF BUSINESS OPPORTUNITIES, LOSS OF DATA, BUSINESS INTERRUPTION, LOSS OF GOODWILL, OR OTHER NON-DIRECT LOSSES ARISING OUT OF OR RELATED TO YOUR USE OF THE PLATFORM. THIS EXCLUSION APPLIES WHETHER OR NOT SUCH DAMAGES WERE FORESEEABLE AND REGARDLESS OF WHETHER PRIVACY PAY WAS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
8. COMPLIANCE
8.1 Anti-Money Laundering and Sanctions
Privacy Pay enforces AML and sanctions compliance across all transactions.
Users may be screened.
Transactions may be blocked.
Access may be restricted.
8.2 Regulatory Cooperation
Privacy Pay may disclose user data where required by law, including:
subpoenas
court orders
regulatory investigations
9. TERMINATION
Privacy Pay may suspend or terminate access at any time for:
violations of Terms
compliance risks
regulatory requirements.
Access termination results in immediate loss of Platform usage rights.
10. RISKS AND DISCLAIMERS
The Platform is provided "as-is".
You acknowledge:
blockchain transactions are irreversible;
privacy systems rely on secure execution assumptions;
delays or failures may occur due to network conditions;
automated systems may execute unintended actions if misconfigured.