Terms of Service

These Terms govern your use of the Bank28 app and bank28.app website (collectively the "Service"), provided by Bank28 Ltd. ("Bank28", "we", "us"). By creating an account or using the Service, you agree to these Terms.

This document is a draft. Final language is being reviewed by counsel before public launch. Do not rely on this version for legal advice.

1. What Bank28 is — and isn't

Bank28 is a non-custodial crypto wallet and payments app. Your seed phrase is generated and stored on your device. Bank28 does not custody your assets. If you lose your seed phrase or your device, we cannot recover your funds.

Bank28 is not a bank, securities broker, or investment advisor. We do not provide investment, tax, or legal advice.

2. Eligibility

You must be at least 18 years old.
You must not be a resident of, or located in, a sanctioned jurisdiction (current OFAC, EU, and UK sanctions lists apply).
You must provide accurate registration and KYC information.
You may use Bank28 only for personal, non-commercial purposes unless you've signed a separate business agreement with us.

3. Your wallet

Bank28 generates a 12-word recovery phrase (BIP-39) on your device. Write it down. Store it offline. If you lose it, your funds are unrecoverable. Bank28 has no copy, no backdoor, and no recovery mechanism.

You are solely responsible for: (a) the security of your device, (b) the secrecy of your seed phrase, (c) the addresses you send to, and (d) the choice of blockchain network for each transaction. Crypto transactions are irreversible.

4. Card services

Bank28-branded Visa cards are issued by our partner DECTA Cyprus or TWISPAY (Romania) under a license from Visa. Card transactions are governed by the additional Cardholder Agreement you receive when ordering a card. Spending limits, fees, and supported regions are listed in the app.

5. Fees

Crypto-to-crypto swaps: variable network gas + 0.5% spread.
Card spending: free at point of sale; 1% conversion fee for non-EUR purchases.
External fiat sends: shown before you confirm; no hidden FX markup.
Account: free. No subscription. No inactivity fees.

Full fee schedule: /support#fees.

6. Acceptable use

You may not use Bank28 to:

Conduct money laundering or finance terrorism.
Evade sanctions.
Engage in fraud, including chargeback fraud.
Buy or sell illegal goods or services.
Reverse engineer, scrape, or attempt to compromise the Service.
Impersonate another person.

We may freeze, suspend, or close accounts that violate this section without prior notice where required by law or where rapid action is necessary to prevent harm.

7. Service availability

We aim for high uptime but do not guarantee uninterrupted service. Crypto network conditions (congestion, forks, outages) and partner-system maintenance can affect availability. We are not liable for delays caused by circumstances outside our reasonable control.

8. Intellectual property

The Bank28 name, logo, and visual identity are our property. The wallet client and smart contracts are open-source under their respective licenses (see GitHub).

9. Disclaimers + limitation of liability

The Service is provided "as is". To the maximum extent permitted by law, Bank28 disclaims all warranties, express or implied, including merchantability and fitness for a particular purpose.

Our total aggregate liability to you for any claim arising from or related to the Service will not exceed the greater of (a) €100 or (b) the fees you paid us in the 12 months preceding the claim. We are not liable for: lost seed phrases, blockchain network failures, unauthorized access from devices you didn't secure, or third-party partner outages.

Nothing in these Terms excludes liability that cannot be excluded under applicable law (including for fraud, gross negligence, or death/personal injury caused by us).

10. Termination

You may delete your account at any time in-app under Settings → Help → Delete account. Some data may be retained for up to 5 years to comply with AML record-keeping obligations.

We may terminate accounts immediately for material breach of these Terms. We will give 30 days' notice for non-material terminations where lawful to do so.

11. Governing law + disputes

These Terms are governed by the laws of the British Virgin Islands. EU-resident consumers retain the protections of their local mandatory consumer law. Disputes will be resolved by binding arbitration in BVI under the BVI International Arbitration Centre rules, except that EU consumers may also bring claims in their local courts where law allows.

12. Changes to these Terms

We'll notify you in-app and by email at least 30 days before a material change. Continued use after the change takes effect is acceptance.

13. Contact

Bank28 Ltd., BVI BC.
Legal: legal@bank28.app
Support: support@bank28.app