This Terms of Service was last updated on 30 January 2025.
These Terms of Use govern the relationship between you and Gloyo. They apply each time you use or access the Gloyo website (https://gloyopay.com) or the Gloyo application. These Terms of Use also set out important information that you need to know. These Terms of Use form a legal Agreement between you and us. Please read these Terms of Use carefully.
Gloyo provides a non-custodial digital wallet software designed for managing digital assets such as cryptocurrencies, virtual commodities, and NFTs ("Digital Assets"). As a non-custodial wallet provider, you retain full control and responsibility for your Digital Assets and private keys, thereby authorizing transactions from your wallet address independently. As a result, all associated activities and potential risks of loss are entirely under your management at all times.
Our wallet software enables you to:
Generate wallet addresses and associated private keys that allow you to send and receive various digital assets; and
Access on-off ramp services provided by regulated third-party service providers, facilitating the exchange of digital assets to and from fiat currencies.
Please note that your usage of Gloyo’s wallet features and services reflects your acceptance of the risks associated with digital asset management and transaction activities, including network variability, cybersecurity threats, and market volatility.
Cryptocurrencies are different from electronic money and are not regulated in the same way as regular currency. We do not take into account your personal circumstances to determine whether our wallet service is right for you. You should therefore consider your personal circumstances and the financial risks associated with cryptocurrencies.
1. Definition
Agreement means these Terms of Use and Privacy Policy.
AML/CFT Act means the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) of Hong Kong.
AML Laws means applicable anti-money laundering and counter-terrorism financing laws and regulations of any jurisdiction relevant to the operation of Gloyo including the AML/CFT Act and related regulations and rules.
Crypto Exchange means a cryptocurrency exchange that we have partnered with.
Fee or Fees means the fees payable for your use of the Service.
KYC means ‘know your customer’ identification verification checks conducted for compliance with AML Laws and Sanctions Laws.
Sanctions Laws means any economic sanctions laws, regulations and embargos as imposed by the United Nations, Hong Kong, or any other jurisdiction relevant to the operations of Gloyo.
Terms of Use means these terms and conditions between you and Gloyo which govern your access to and use of the wallet service.
Third Party Service Providers means third-party service providers that provide technology or functionality used by Gloyo to provide access to on-off ramp services.
2. Wallet Services
2.1 Gloyo provides you with access to a non-custodial wallet that enables you to buy and sell supported digital assets through regulated third-party services.
2.2 A list of the fiat currencies and cryptocurrencies that Gloyo currently supports in respect of its wallet services can be found on our Platform or may be otherwise notified to you. It may not always be possible to give you advance notice of a change to the supported cryptocurrencies (for example if a cryptocurrency becomes illegal due to a sudden change in applicable laws and regulations or if a cryptocurrency suddenly changes its name, or in the way it functions).
2.3 Transactions Using Third-Party Services.
(a) Gloyo does not provide direct on-off ramp services. Any such services are provided by independent third-party service providers. We facilitate access to these providers within our Platform but are not responsible for the services they provide.
(b) Each transaction involving third-party services is subject to the provider’s terms and conditions. We encourage you to review those terms before initiating a transaction.
2.4 Fees:
We may charge you a Fee for certain wallet services. We will show you this Fee before you initiate a transaction as well as after a transaction has been processed in the transaction details.
2.5 Lawful use of Service.
(a) You represent and warrant to Gloyo at all times that you will comply with legal and regulatory requirements, restrictions, and prohibitions applicable to your use of the Service.
(b) These legal and regulatory requirements, restrictions, and prohibitions include any anti-money laundering, counter-terrorism financing, trade sanctions, foreign exchange controls or restrictions, or tax consequences applicable to your use of the Service.
2.6 Availability of Service.
The availability of Gloyo services in any specific jurisdiction depends on a number of factors, including whether the provision or receipt of the Service is lawful in that jurisdiction. Gloyo has sole and absolute discretion in determining whether we make available the Service in any jurisdiction. If we determine that we will no longer offer the Service in your jurisdiction, we will notify you of this change.
3. Your access to the Service
3.1 When you register for access to the Gloyo Service:
(a) You will need to create log-in credentials by selecting a password and providing an e-mail address, along with any other registration information as required from time to time.
(b) You must not create log-in credentials that we, acting reasonably, deem offensive. Failure to comply constitutes a breach by you of this Agreement, which may result in immediate termination of your access to the Service.
(c) You must not provide, distribute or share, or enable the provision, distribution or sharing of, your log-in credentials with any third party.
(d) We may prescribe security procedures applicable to the use of the Service, which you must comply with.
(e) You must maintain the confidentiality of your log-in credentials and private keys associated with your Gloyo wallet. As a non-custodial wallet provider, Gloyo does not have access to your private keys and cannot recover them if lost. You must not at any time disclose this information to any other party.
(f) You must keep your contact details up to date so that you can receive alerts we may send to you. Failure to do so may result in adverse results like unauthorised access to your account and potential theft or money laundering.
(g) Except where caused by our negligence, fraud or misconduct, we will not be responsible or liable for any loss caused or damage suffered by you that occurs as a consequence of any use of the Service under your registration (including unauthorised transactions) where you have not notified us that your access to the Service has been compromised. If you believe that the security of your information has been compromised, contact us immediately.
3.2 By registering for the Service, you represent and warrant that:
(a) if you are a natural person (i.e., an individual and their estate and personal representatives); that you are at least 18 years old and have the full right, power, and legal authority to enter into these Terms of Use;
(b) if you are registering to use the Service on behalf of a legal entity (e.g. an incorporated entity), you represent and warrant that the legal entity is duly organised and validly existing under the applicable laws of the jurisdiction of its organisation; that you are duly authorised by such legal entity to act on its behalf, and that the legal entity agrees to be bound by these Terms of Use;
(c) you will not authorise other persons to use your details to access the Service nor transfer or assign it to any other person; and
(d) you are not impersonating any other person, operating under an alias or otherwise concealing your identity.
We may refuse your registration for the Service or terminate your access to the Service if you fail to fulfil any one of the eligibility criteria above.
We may change the eligibility criteria for registering for the Service, in accordance with clause 12.
3.3 Depending on your country of residence, you acknowledge that you may not be able to use the Service.
3.4 Gloyo is not obliged to accept all registrations for the Service and may accept or reject any registration for the Service.
3.5 To protect its legitimate interests, Gloyo reserves the right to suspend a customer’s access to the Service, reject an instruction to enter into a Transactions and cease offering the Service to a customer.
3.6 You acknowledge that the Service may be unavailable from time to time due to scheduled outages or due to factors beyond our control, such as your internet connection or third-party service providers.
3.7 You may terminate your use of the Service at any time by giving Gloyo notice in writing at [email protected].
4. Your Choices About the Use of Your Data
4.1 The Fees payable for your use of the Service are displayed on the website and may change from time to time. You will be prompted to make payment for the applicable Fees where they are triggered by your use of the Service (for example, as part of the confirmation of instructions in connection with a Transaction).
4.2 You agree to make payment for other duties payable by you in connection with your use of the Service (including in the case of bank transfers, any bank charges).
4.3 We may use payment gateway providers or payment processing agents to process your payment of Fees. If you wish to pay any amount with our payment gateway providers or payment processing agents, you will be redirected to their secured payment page. If you provide your credit card details, you authorise us, our payment gateway providers, and/or our payment processing agents to charge your credit or debit card for the applicable Fee(s) (if any).
4.4 We may change the Fees payable in accordance with clause 12.
5. Your Choices About the Use of Your Data
5.1 It is a continuing condition of your use of the Platform that you review the terms of our privacy policy as amended from time to time, available at https://gloyopay.com/privacy-policy ("Privacy Policy"), which sets out details of our collection, use, disclosure, and/or processing of your personal data.
5.2 If in connection with your use of the Platform, you provide the personal data of any third parties, you warrant and represent that you have confirmed that the said third parties have also reviewed the terms of the Privacy Policy, and that they consent to the collection of their personal data by us and our related corporations and affiliates having regard to that Privacy Policy.
5.3 You warrant and represent to us that all personal data which is submitted to us by you through your use of the Platform is complete, accurate, true, and correct.
5.4 The Platform may provide links to external sites whose data protection and privacy practices may differ from those set forth here. We are not responsible for the content and privacy practices of these other websites and you agree to review and abide by the data protection and privacy notices of those sites.
5.5 The Platform uses cookies. A cookie is a small text file which is placed on your device whenever you run or use the Platform. These cookies collect information about your use of the Platform. We use cookies and other technologies to facilitate your use of the Platform and to improve your experience of the Platform. You may change the settings on your device to block the use of cookies. However, if you do choose to block the cookies used on the Platform, you may not be able to use certain features and functions of the Platform.
6. Third-Party Service Providers
6.1 Gloyo has arrangements in place with Third-Party Service Providers in order to provide exchange services.
6.2 Gloyo relies, in whole or in part, on the continued development and support of the technology and functionality provided by Third-Party Service Providers. Access to the exchange services may be made conditional upon you consenting and/or agreeing to, and meeting the terms and conditions of such Third-Party Service Providers and those terms shall govern your use of such services they provide. These may include but are not limited to Third-Party Service Providers who assist us with our identity verification procedures.
7. Disclaimer of Warranties and Liability
You agree and acknowledge that we do not warrant that the Service will meet your requirements or that the operation of the Platform will be uninterrupted or error-free. No representation or warranty is provided that:
(a) the Service will be uninterrupted or error-free;
(b) the Service will at all times be available and/or accessible for your use;
(c) any non-interference with your enjoyment of the Service; and
(d) the Service being compatible or working with any third-party software, applications, or third-party services.
8. Indemnity
8.1 You agree to indemnify and hold harmless Gloyo for all costs, liability, loss, or costs we may suffer or incur from your breach of these Terms of Use and any terms relating to your use of the Service. This indemnity does not extend to any costs, liability, loss, or costs caused by our mistake, fraud, negligence, or willful misconduct or the same of our employees, officers, contractors, or agents.
8.2 This Clause 8 shall survive the termination or expiration of this Agreement (howsoever caused).
9. Electronic Communications
You accept and agree that:
(a) any communications, agreements, notices, and/or any other documents (together "Communications") relating to your use of the Service will be provided to you electronically by posting them on the Platform and emailing them to the email address you have provided to us. You consent to receiving all Communications from us electronically;
(b) you must provide us with a valid and accessible email address to which any Communications may be sent and must ensure that email address and any other contact information is kept up to date. Any Communication sent to the email address you have provided to us will be treated as having been received by you. You can amend your contact information by updating the profile settings in your account.
10. Anti-Money Laundering and Counter-Terrorism Financing and Sanctions Laws
10.1 In order to use the regulated third party services, your identity must first be verified. Gloyo implements and maintains high standards of KYC processes and controls as part of our commitment to combating fraud and assisting in the prevention of money laundering and terrorist financing. Gloyo utilises Third-Party Service Providers to perform these checks.
10.2 To ensure we meet the requirements under AML Laws and Sanctions Laws:
(a) you are required to provide personal information so that we can verify your identity in accordance with our KYC processes. You must give all the information we reasonably require to comply with AML Laws and Sanctions Laws.
(b) we are required to retain information collected as part of our KYC processes, including after you have ceased using our Service. Further information on the collection, use, and retention of your personal information can be found in the Gloyo Privacy Policy (see clause 5).
10.3 Gloyo reserves the right to, at any time:
(a) restrict or suspend your access to the Service if we consider it necessary to carry out further KYC processes; or
(b) terminate your access to the Service if you provide, or we suspect you have provided, false information or refuse to provide information we require for our KYC processes.
10.4 You accept and agree that there may be delays in accessing the Service or in carrying out Transactions through your account while we undertake any KYC processes.
10.5 If we determine that executing a Transaction would be unlawful, or in any way contrary to our obligations under AML Laws and Sanctions Laws, we may suspend such a transfer for as long as we reasonably determine is required. You agree that when this occurs, you have no claims regarding the delayed transfer and agree to assist us with every request for information in this regard.
10.6 You acknowledge and agree that we are required to act in accordance with our obligations under the AML Laws and Sanctions Laws in providing the Service which includes our exercising discretions as we determine appropriate to protect our legitimate interests.
11. Restriction, Suspension and Termination
11.1 We reserve the right to restrict, suspend, or terminate your access to the Service without advance notice where we reasonably suspect:
(a) your access to the Service is subject to an operational or other error;
(b) your access to the Service has been or is being used in relation to any unlawful or fraudulent activities or in breach of these Terms of Use;
(c) you or your access to the Service is or has been associated with, or poses a high risk of, money laundering, financing of terrorism, fraud, or any other financial crime;
(d) you are taking any action that we consider to be a circumvention of our controls, including but not limited to multiple registrations for the Service;
(e) we reasonably suspect your involvement in any attempt to gain unauthorised access to another person’s log-in credentials;
(f) your access to the Service is or appears to be the subject of any legal, regulatory or government process and/or we, in our sole discretion, consider there to be a heightened risk of legal or regulatory non-compliance associated with your account;
(g) we are compelled to do so by a prima facie valid subpoena, court order, or other binding order of a government or regulatory authority; or
(h) we reasonably conclude that you, or any person or geography with whom you transact, are / is the subject of any restrictions under Sanctions Laws.
12. Your Choices About the Use of Your Data
12.1 We may amend, vary or supplement the Terms of Use from time to time.
12.2 Where the amendment is not unfavourable to you, we will provide you with written notice no later than the day the amendment, variation or supplement is to take effect.
12.3 Where the amendment, variation or supplement is unfavourable to you, we will only amend, vary or supplement the Terms of Use if we, acting reasonably, determine that it is reasonably necessary to: (a) reflect changes to our operational costs, business operations, systems, and processes, or our arrangements with third parties;
(b) give effect to regulatory change, standards, recommendations, guidance, or applicable laws;
(c) reflect changes to industry or market conditions or practice; or
(d) otherwise protect our legitimate interests.
We will provide you with at least 30 days’ written notice of such amendment, variation, or supplement. If you do not wish to be bound by any amendment, variation, or supplement, you can cease using the Service and terminate this agreement by emailing [email protected] before the notice period ends.
13. General
13.1 Each of the terms and conditions in these Terms of Use are severable and distinct from one another and if at any time, any one or more of these terms and conditions or any part thereof is or becomes invalid, illegal or unenforceable, the validity, legality or enforceability of the remaining provisions will not thereby be affected or impaired in any way and will remain in force.
13.2 The rights and remedies provided in these Terms of Use are cumulative and not exclusive of any other rights or remedies (whether provided by law or otherwise).
13.3 No failure on our part to exercise and no delay on our part in exercising any right or remedy under these Terms of Use will operate as a waiver of such right or remedy, nor will any single or partial exercise of any right or remedy preclude any other or further exercise of such right or remedy or the exercise of any other right or remedy. Any waiver by us of our rights or remedies in respect of any terms under these Terms of Use or any breach of these Terms of Use on your part must be in writing and may be given subject to such terms and conditions as we may deem fit and is effective only in the instance and for the purpose for which it is given.
13.4 You are solely responsible for determining and paying any income, sales, or capital gains taxes to the appropriate tax authorities in connection with any of your activities on the Platform, and we are not responsible for collecting these from you, for making any payments on your behalf, or for providing any reports relating to tax.
13.5 A person who is not a party to this Agreement shall have no right to enforce or enjoy the benefit of any term of this Agreement. Notwithstanding any term of this Agreement, the consent of any person who is not a party to this Agreement is not required to rescind or vary this Agreement at any time.
14. Governing Law
Your access and use of the Platform as well as this Agreement shall be governed by the laws of Hong Kong and you agree that the courts Hong Kong shall have exclusive jurisdiction over all disputes relating thereto.
15. Important Statements: Gloyo is not a Bank and does not hold an licenses
15.1 Risks associated with using the Service
(a) This section sets out some of the risks involved in connection with digital assets / cryptocurrency and using the Digital Token Services. However, this section does not constitute an exhaustive list of such risks and as such, you should carefully consider whether using our Service is suitable for you in light of your circumstances.
(b) Legal status
The legal status of digital assets / cryptocurrency (including cryptographic coins, stablecoins, and tokens) remains uncertain in many countries and jurisdictions around the world. Digital assets and cryptocurrency may be legally prohibited in certain countries or jurisdictions or be subject to specific restrictions and limitations which you are solely responsible for complying with at your own risk and expense. We take no position as to the legal status of any digital asset / cryptocurrency. It is your responsibility to undertake your own investigations and enquiries and satisfy yourself of the legal status of any digital asset / cryptocurrency (particularly in Hong Kong). You acknowledge and agree that your involvement in digital assets / cryptocurrency through the Service is at your own risk. (c) Risks of trading and holding cryptocurrency
Historically, the value of digital assets / cryptocurrency has been highly volatile and there is a risk that they could have little to no value in the future. The trading or holding of digital assets / cryptocurrency therefore involves significant risks and the losses can be substantial. It may be difficult to value digital assets / cryptocurrency accurately and reliably given the nature of their trading and difficulty in identifying their fundamentals. You should carefully consider and assess whether trading digital assets / cryptocurrency or using cryptocurrency-adjacent services is suitable for you depending upon your financial circumstances and tolerance to risk. Due to the significant risks of trading digital assets / cryptocurrency as well as the impact of technology and the international market, Gloyo cannot warrant or guarantee that any particular digital assets / cryptocurrencies will continue to be available as part of the Service. Gloyo reserves the right to stop offering trades in relation to particular digital assets / cryptocurrency as part of the Service. We will notify you if we cease to support trading a particular digital asset / cryptocurrency. (d) Cyber risks, delivery and custody
Gloyo is not responsible or liable for any cryptocurrency or fiat currency sent to an incorrect account. It is important for you to take care when providing us with the bank details for the Nominated 3P Account. You should familiarise yourself with the security measures available when using a third-party wallet service or other device for storage. Always take a greater degree of care and precaution to secure your passwords when operating in a digital environment. You are strongly advised to double-check that you have inserted the correct third-party wallet address (for cryptocurrencies) or bank account details (for fiat currency) where required. There could be market conditions, or other operational or technical difficulties which could result in the immediate halt of transactions either temporarily or permanently. Provided that Gloyo has taken reasonable commercial and operational measures to prevent such events in technical systems controlled by us, Gloyo is not and will not be responsible or liable for any loss or damage of any kind incurred by you as a result of cyber-attacks, operational or technical difficulties, or suspensions of transactions. (e) Further information is available on the Platform and in our Frequently Asked Questions (FAQs) at https://faq.gloyopay.com
16. Complaints
16.1 If you are not satisfied with our Service, you can register a complaint directly with Gloyo's Complaints Officer in the first instance please email us at [email protected]
16.2 We will investigate your complaint and will aim to respond to you as soon as possible or within 30 days following receipt of the complaint.
Contact Us If you have any queries, you may contact us by email at [email protected].