Terms and Conditions

Effective date: 30 June 2026

1. Introduction and acceptance

These Terms and Conditions ("Terms") govern your access to and use of the website located at https://lurrapay.com (the "Site") and the products, accounts, applications, and services made available through it (together, the "Services"), provided by LurraPay Inc. ("LurraPay", "we", "us", or "our").

LurraPay Inc. is a company with its registered address at 60 Nexus Way, 6th Floor, Camana Bay, PO Box 30745, Grand Cayman, KY1-1203, Cayman Islands.

By accessing the Site, creating an account, or otherwise using the Services, you confirm that you have read, understood, and agree to be bound by these Terms and by any documents expressly incorporated by reference (including our Privacy Policy and Cookie Policy). If you do not agree to these Terms, do not access or use the Services.

You also acknowledge that your use of certain Services is subject to the separate terms, conditions, and policies of our Licensed Partners (defined in Section 5). By using those Services, you agree to those partner terms as well.

These Terms apply to both individual ("consumer") users and to businesses and other organizations using the Services. Where a provision applies only to one category, this is stated. Section 24 sets out additional provisions that apply to consumers and that do not limit any rights you may have under mandatory consumer-protection law that cannot be excluded.

2. Definitions

In these Terms, unless the context requires otherwise:

"Account" means the user profile and any associated virtual accounts, balances, or access credentials made available to you through the Services.

"Crypto-Asset" means a digital representation of value or rights that can be transferred and stored electronically using distributed-ledger or similar technology, including stablecoins such as USDC and EURC.

"Fiat Currency" means government-issued currency that is legal tender, including EUR, USD, and GBP.

"Licensed Partner" means a third-party financial institution, payment service provider, crypto-asset service provider, or other regulated entity that provides regulated or licensed services accessed through the Services, as described in Section 5.

"On-Ramp" means the process of converting Fiat Currency into Crypto-Assets.

"Off-Ramp" means the process of converting Crypto-Assets into Fiat Currency.

"Stablecoin" means a Crypto-Asset designed to maintain a stable value relative to a reference Fiat Currency or other asset.

"Swap" means the exchange of one Crypto-Asset or currency for another.

"Virtual Account" means a named account identifier denominated in a supported Fiat Currency, provided by a Licensed Partner and made available to you through the Services.

"You" or "your" means the person or entity accessing or using the Services.

3. About LurraPay and the nature of the Services

LurraPay is not a bank. LurraPay is a financial-technology platform. We build hardware and software and integrate licensed partners into our products, services, and infrastructure. We package multi-currency stablecoin accounts, on-ramp, off-ramp, currency and crypto-asset swaps, and identity verification, provided by Licensed Partners, into a single product, account, and interface.

LurraPay is not licensed or authorized as a financial institution. LurraPay does not hold any banking, e-money, payment-services, money-transmission, or crypto-asset-service licence or registration, and does not itself carry out any regulated financial activity. All regulated activities, including the holding of customer funds, the issuance and custody of accounts, the execution of payments, on-ramp and off-ramp conversions, swaps, and identity verification, are performed by Licensed Partners that are authorized and regulated in their respective jurisdictions (see Section 5).

LurraPay does not hold or take custody of your money or Crypto-Assets. Customer funds and Crypto-Assets are held and custodied by Licensed Partners (or their sub-custodians or banking partners), not by LurraPay. Any balance shown to you through the Services represents a record of funds or assets held by a Licensed Partner, and any claim in respect of those funds or assets is against the relevant Licensed Partner under that partner's terms, not against LurraPay.

LurraPay's role is to provide the technology layer (the Site, software, interfaces, and integrations) that allows you to access services offered by Licensed Partners, and to provide related support. Nothing in these Terms, and nothing about the Services, should be understood as LurraPay providing banking, deposit-taking, payment, money-transmission, custody, investment, exchange, or advisory services.

4. Eligibility

To use the Services you must:

(a) be at least 18 years old and have full legal capacity to enter into a binding contract (if you use the Services on behalf of a business or other entity, you confirm you are authorized to bind that entity, and "you" refers to that entity);

(b) not be located in, ordinarily resident in, or a national of any country or territory that is subject to comprehensive sanctions, or otherwise be a person with whom dealings are prohibited under applicable sanctions laws (including those administered by the United Nations, the United States, the United Kingdom, the European Union, or the Cayman Islands);

(c) not appear on any applicable sanctions, terrorism, or prohibited-persons list; and

(d) meet any additional eligibility, jurisdictional, or onboarding requirements imposed by us or by a Licensed Partner.

Availability of the Services, and of particular features, currencies, or assets, varies by jurisdiction and is subject to the requirements of the relevant Licensed Partner. The Services are not offered where they would be unlawful.

Restricted jurisdictions. Certain countries and territories are not supported. An indicative list of supported and unsupported jurisdictions, maintained by our principal Licensed Partner, is available at https://docs.iron.xyz/country. That list is indicative only and not exhaustive, and supported-jurisdiction status does not guarantee access to every feature, currency, or Virtual Account. We and our Licensed Partners reserve the right to restrict, suspend, or decline the Services in any additional jurisdiction, at any time and with or without notice, where we consider it appropriate or necessary, including for legal, regulatory, sanctions, or risk reasons.

5. Licensed Partners

The regulated services accessed through LurraPay are provided by Licensed Partners. As at the date of these Terms, these include Iron (operated by entities within the MoonPay group; Iron is a MoonPay company) and MoonPay and its affiliates, which provide stablecoin and payment infrastructure, virtual accounts, on-ramp and off-ramp services, swaps, payouts, and identity verification (KYC/KYB). MoonPay group entities hold financial-services licences and registrations in various jurisdictions.

You acknowledge and agree that:

(a) your use of services provided by a Licensed Partner is governed by that partner's own terms of service, privacy policy, fee disclosures, and other policies, which form a separate agreement between you and that partner;

(b) you may be required to accept a Licensed Partner's terms and to complete that partner's onboarding, identity-verification, and compliance requirements before you can use the relevant Services;

(c) Licensed Partners are independent third parties and are not controlled by LurraPay; LurraPay does not provide, and is not responsible for, the regulated services performed by Licensed Partners; and

(d) we may add, change, or replace Licensed Partners, and the identity of the partner providing a given service may change.

You should read the relevant Licensed Partner's terms and policies. For Iron and MoonPay, these are published on their respective websites (including iron.xyz and moonpay.com). Where a Licensed Partner's terms conflict with these Terms in respect of the regulated service that partner provides, the Licensed Partner's terms govern that service.

6. Account registration and identity verification

To use most Services you must register for an Account and provide accurate, current, and complete information. You agree to keep your information up to date.

Because the Services provide access to regulated financial services, you will be required to complete identity verification and, where applicable, business verification ("KYC/KYB") and other anti-money-laundering and counter-terrorist-financing checks. These checks are carried out by us and/or by Licensed Partners. You agree to provide the information and documentation requested and confirm that everything you provide is true, accurate, and not misleading. We and our Licensed Partners may refuse, suspend, or terminate access if verification cannot be completed or if information is found to be false.

You are responsible for maintaining the confidentiality of your Account credentials and for all activity that occurs under your Account. You must notify us promptly at legal@lurrapay.com if you suspect any unauthorized access to or use of your Account. You must not share your credentials or allow anyone else to access your Account.

7. The Services

Subject to eligibility, verification, and the terms of the relevant Licensed Partner, the Services may allow you to:

(a) open and access multi-currency Virtual Accounts denominated in supported Fiat Currencies (currently EUR, USD, and GBP);

(b) on-ramp, i.e. convert Fiat Currency into supported Stablecoins (including USDC and EURC) and other supported Crypto-Assets;

(c) off-ramp, i.e. convert supported Crypto-Assets into Fiat Currency;

(d) swap between supported currencies and Crypto-Assets; and

(e) access related account, transaction, and support features.

The specific currencies, assets, features, limits, and jurisdictions supported at any time depend on the relevant Licensed Partner and may change. We do not guarantee that any particular Service, currency, asset, or feature will be available to you or will remain available.

Transactions are generally irreversible. Once a payment, transfer, conversion, or swap involving Crypto-Assets has been submitted or settled, it typically cannot be reversed, cancelled, or recalled. You are responsible for checking all transaction details, including destination addresses, account details, amounts, networks, and assets, before confirming. We are not able to recover Crypto-Assets sent to an incorrect or incompatible address or network.

Exchange rates, conversion rates, and the value of Crypto-Assets fluctuate. Rates quoted may be indicative and may change between the time they are displayed and the time a transaction is executed by the relevant Licensed Partner.

8. Fees

Fees for the Services, including any platform fees, transaction fees, conversion or swap spreads, and network fees, will be disclosed to you before you complete a relevant transaction. The applicable fee schedule is available to registered users within their Account at https://lurrapay.com/account/billing. Licensed Partners may also charge their own fees under their own terms.

Unless stated otherwise, fees are exclusive of any taxes, and you are responsible for any applicable taxes (see Section 19). We may change our fees, and we will give notice of changes as required by applicable law or as described in Section 20.

9. Stablecoins and Crypto-Asset risks

You understand and accept that Crypto-Assets, including Stablecoins, carry significant risks, and that you use the Services relating to Crypto-Assets at your own risk. These risks include, without limitation:

(a) Value and volatility risk: the value of a Crypto-Asset may fall as well as rise and may become worthless; a Stablecoin may lose or fail to maintain its peg to its reference currency;

(b) Issuer and reserve risk: Stablecoins depend on their issuer and on the assets backing them; an issuer may fail, may not hold adequate reserves, or may not honour redemptions;

(c) Technology and network risk: blockchain networks, smart contracts, and wallets may contain bugs, may be attacked, may fork, or may suffer congestion, delays, or failures;

(d) Irreversibility: transactions are generally final and cannot be reversed (see Section 7);

(e) Regulatory risk: laws and regulations applying to Crypto-Assets are evolving and may change in ways that adversely affect the Services or your holdings; and

(f) No deposit protection: Crypto-Assets and balances accessed through the Services are not bank deposits and are not covered by any deposit-guarantee, investor-compensation, or similar protection scheme.

LurraPay does not provide investment, financial, tax, or legal advice. Nothing on the Site or in the Services is a recommendation or solicitation to buy, sell, or hold any Crypto-Asset. You are solely responsible for your own decisions.

10. Acceptable use and prohibited activities

You agree to use the Services only for lawful purposes and in accordance with these Terms. You must not, and must not permit anyone else to:

(a) use the Services in breach of any applicable law, regulation, or sanctions regime;

(b) use the Services for money laundering, terrorist financing, fraud, tax evasion, or any other financial crime;

(c) use the Services in connection with any illegal, fraudulent, deceptive, or unauthorized transaction, or any activity prohibited by a Licensed Partner;

(d) provide false, inaccurate, or misleading information, or impersonate any person or entity, or use another person's identity or Account;

(e) attempt to gain unauthorized access to the Services, other accounts, or our or our partners' systems, or interfere with, disrupt, or place undue load on the Services;

(f) introduce malware or any other harmful code, or attempt to probe, scan, reverse-engineer, decompile, or test the vulnerability of the Services except as permitted by law;

(g) use the Services on behalf of an undisclosed third party, or to evade applicable limits, controls, or restrictions; or

(h) use any robot, scraper, or other automated means to access the Services other than through interfaces we expressly authorize.

We and our Licensed Partners may monitor use of the Services for compliance and security purposes, and may report suspicious activity to regulators or law-enforcement authorities as required by law.

11. Anti-money-laundering, sanctions, and compliance

The Services, and the Licensed Partners that provide them, are subject to anti-money-laundering (AML), counter-terrorist-financing (CTF), and sanctions laws. We and our Licensed Partners may be required to verify your identity and source of funds, monitor transactions, request additional information, place holds on or refuse transactions, freeze access, and make reports to authorities, in each case without prior notice where the law so requires or permits.

You agree to cooperate with any such request. We and our Licensed Partners may suspend, restrict, or terminate your access if we reasonably believe it is necessary to comply with applicable law or to manage legal, regulatory, or fraud risk. To the extent permitted by law, we are not liable to you for any loss arising from action taken in good faith to comply with these obligations.

12. Customer funds and custody

As stated in Section 3, LurraPay does not hold or custody customer funds or Crypto-Assets. Funds and Crypto-Assets are held by Licensed Partners (or their banking partners or sub-custodians) under the relevant partner's terms. Your rights in respect of those funds and assets, including any right to redemption, withdrawal, or repayment, are governed by, and exercisable against, the relevant Licensed Partner.

Balances accessed through the Services are not deposits with LurraPay, do not represent a claim against LurraPay, and are not protected by any deposit-guarantee or compensation scheme. LurraPay does not pay interest on any balance.

13. Intellectual property

The Site and the Services, including all software, text, graphics, logos, designs, and other content (other than your content and third-party content), and all intellectual-property rights in them, are owned by or licensed to LurraPay and are protected by law. The "LurraPay" name and logo are our marks and may not be used without our prior written permission.

Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, revocable licence to access and use the Services for their intended purpose. You may not copy, modify, distribute, sell, lease, or create derivative works from any part of the Services, or reverse-engineer or attempt to extract source code, except to the extent this restriction is prohibited by law.

You retain ownership of content you submit. You grant us a worldwide, non-exclusive, royalty-free licence to use, host, store, reproduce, and process that content to the extent necessary to provide and improve the Services.

14. Third-party services, content, and links

The Services rely on, link to, or interoperate with third-party services, including Licensed Partners, blockchain networks, identity-verification providers, and payment infrastructure. We do not control and are not responsible for third-party services, content, websites, or the acts or omissions of third parties. Your use of any third-party service is at your own risk and may be subject to that third party's terms.

15. Privacy and data protection

Our collection and use of personal data is described in our Privacy Policy, which forms part of these Terms. Licensed Partners process personal data as independent controllers or processors under their own privacy policies in order to provide their services and to meet their legal and regulatory obligations. By using the Services you acknowledge that your information will be shared with Licensed Partners and other third parties as described in our Privacy Policy and theirs.

16. Disclaimers

To the maximum extent permitted by applicable law, and subject to Section 24 (consumers):

(a) the Services are provided "as is" and "as available", without warranties of any kind, whether express, implied, or statutory, including any implied warranties of merchantability, fitness for a particular purpose, title, and non-infringement;

(b) we do not warrant that the Services will be uninterrupted, timely, secure, error-free, or free of viruses or other harmful components, or that any defect will be corrected;

(c) we do not warrant the availability, accuracy, completeness, or reliability of any rate, quote, balance, or other information displayed through the Services, which may be provided by third parties; and

(d) we are not responsible for the performance, solvency, acts, or omissions of any Licensed Partner or other third party, or for the value, behaviour, or availability of any Crypto-Asset or blockchain network.

17. Limitation of liability

To the maximum extent permitted by applicable law, and subject to Section 24 (consumers):

(a) LurraPay, its affiliates, and their respective directors, officers, employees, and agents will not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, business, goodwill, data, or anticipated savings, arising out of or in connection with the Services or these Terms, whether based in contract, tort (including negligence), or otherwise, even if advised of the possibility of such damages;

(b) without limiting (a), we will not be liable for any loss arising from: the acts, omissions, insolvency, or default of any Licensed Partner or other third party; the loss of value, de-pegging, or failure of any Crypto-Asset or Stablecoin; transactions that are irreversible or sent to incorrect details; blockchain-network failures, forks, or congestion; unauthorized access to your Account resulting from your failure to safeguard your credentials; or action taken to comply with legal or regulatory obligations; and

(c) our total aggregate liability arising out of or in connection with the Services and these Terms in any 12-month period will not exceed the greater of (i) the total fees you paid to LurraPay for the Services in that period, and (ii) USD 100.

Nothing in these Terms excludes or limits any liability that cannot lawfully be excluded or limited, including liability for fraud or fraudulent misrepresentation, or for death or personal injury caused by negligence.

18. Indemnification

To the maximum extent permitted by applicable law, you agree to indemnify, defend, and hold harmless LurraPay, its affiliates, and their respective directors, officers, employees, and agents from and against any and all claims, demands, actions, losses, liabilities, damages, costs, and expenses (including reasonable legal fees) arising out of or in connection with: (a) your breach of these Terms or any policy or terms incorporated by reference; (b) your violation of any applicable law or regulation, or of the rights of any third party; (c) your use or misuse of the Services; (d) any transaction you initiate or authorize; or (e) any information or content you provide that is false, inaccurate, or misleading.

We reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which case you agree to cooperate with us in asserting any available defenses.

If you are a consumer, this Section 18 applies only to the extent permitted by the consumer-protection law applicable to you, and does not require you to indemnify us for matters that are not your responsibility or that arise from our own breach, negligence, or wrongdoing.

19. Taxes

You are solely responsible for determining and meeting your own tax obligations, including any reporting and payment of taxes, that arise from your use of the Services. LurraPay does not provide tax advice and is not responsible for any tax consequences of your transactions.

20. Changes to the Terms and the Services

We may update these Terms from time to time, for example to reflect changes in the Services, our Licensed Partners, or applicable law. We will post the updated Terms on the Site and update the "Last updated" date. Where required by law, or where changes are material, we will give you reasonable advance notice (for example by email or in-product notice). Your continued use of the Services after the changes take effect constitutes acceptance of the updated Terms. If you do not agree to the changes, you must stop using the Services.

We may also modify, suspend, or discontinue any part of the Services at any time, including the supported currencies, assets, features, or Licensed Partners.

21. Suspension, termination, and inactive accounts

You may stop using the Services and close your Account at any time, subject to settling any outstanding obligations and to the relevant Licensed Partner's processes for withdrawing funds or assets.

We may suspend, restrict, or terminate your access to all or part of the Services, with or without notice, if: (a) you breach these Terms or any Licensed Partner's terms; (b) we are required to do so by law, regulation, or a Licensed Partner; (c) we reasonably suspect fraud, money laundering, sanctions exposure, or other unlawful or high-risk activity; or (d) we cease to offer the Services. Where reasonably practicable and lawful, we will give you notice.

Inactive accounts. If your Account has no activity for a continuous period of 12 months, we may automatically close it. If any funds or Crypto-Assets remain associated with your Account following closure, you may claim them by contacting us at legal@lurrapay.com, subject to completing any identity verification and to the relevant Licensed Partner's processes for releasing funds or assets.

Termination does not affect any rights or obligations that accrued before termination. Sections that by their nature should survive termination (including Sections 3, 9, 12, 13, 16, 17, 18, 19, 22, and 23) will survive.

22. General

Force majeure. We are not liable for any failure or delay in performance caused by events beyond our reasonable control, including acts of God, war, terrorism, civil unrest, government action, changes in law, failures of telecommunications, internet, or blockchain networks, or the default of any Licensed Partner or third party.

Monitoring and recording. You agree that we and our Licensed Partners may monitor, record, and retain communications with you (including emails, chat messages, and telephone calls) and your use of the Services, for compliance, security, training, quality-assurance, dispute-resolution, and record-keeping purposes, and as evidence of transactions and instructions, in each case to the extent permitted by applicable law.

Assignment. You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign or transfer these Terms, in whole or in part, including to an affiliate or in connection with a merger, acquisition, or sale of assets.

Entire agreement. These Terms, together with the documents they incorporate by reference, constitute the entire agreement between you and LurraPay regarding the Services and supersede any prior agreements on that subject.

Severability. If any provision of these Terms is held to be invalid or unenforceable, that provision will be modified to the minimum extent necessary or severed, and the remaining provisions will remain in full force.

No waiver. Our failure to enforce any provision is not a waiver of our right to do so later.

No third-party rights. Except for LurraPay's affiliates and the persons referred to in Sections 17 and 18 (who may enforce the relevant provisions), a person who is not a party to these Terms has no right to enforce them.

Notices and communications. You agree that we may provide notices and communications to you electronically, including by email to the address associated with your Account or by posting on the Site. You are responsible for keeping your contact details current.

Language. These Terms are written in English, which is the controlling language for all purposes.

23. Governing law and jurisdiction

These Terms, and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with them, their subject matter, or formation, are governed by and construed in accordance with the laws of the Cayman Islands.

You and LurraPay agree that the courts of the Cayman Islands have exclusive jurisdiction to settle any such dispute or claim, save that we may bring proceedings against you in any other court of competent jurisdiction, and except where mandatory law (including consumer-protection law applicable to you) gives you the right to bring proceedings, or requires proceedings to be brought, in another jurisdiction.

24. Additional provisions for consumers

If you are an individual using the Services wholly or mainly for purposes outside your trade, business, craft, or profession (a "consumer"):

(a) nothing in these Terms affects any rights you have under mandatory consumer-protection laws of your country of residence that cannot be excluded or limited by contract, and in the event of conflict those mandatory rights prevail;

(b) the disclaimers and limitations of liability in Sections 16 and 17, and the indemnity in Section 18, apply to you only to the extent permitted by the law applicable to you, and do not exclude or limit liability that cannot lawfully be excluded or limited;

(c) where you have a statutory right to cancel or a "cooling-off" period, that right applies as provided by law; note, however, that the execution of currency conversions, swaps, and Crypto-Asset transactions whose price depends on market fluctuations may not be subject to cancellation once you have requested execution, to the extent permitted by law; and

(d) you may be entitled to use out-of-court complaint and dispute-resolution mechanisms available to consumers in your jurisdiction.

25. Complaints and contact

If you have a complaint or wish to contact us about these Terms or the Services, please contact us at:

LurraPay Inc.
60 Nexus Way, 6th Floor, Camana Bay
PO Box 30745, Grand Cayman
KY1-1203, Cayman Islands
Email: legal@lurrapay.com

Complaints that relate to a regulated service provided by a Licensed Partner may need to be directed to, or escalated to, that partner under its complaints procedure. We will tell you where this is the case and, where appropriate, direct you to the relevant Licensed Partner's complaints process (for example, Iron and MoonPay each publish their own complaints procedures).