Terms of Service
SMARTLYY Terms of Service
Effective 30 October 2026 · Smartlyy Ltd, company number 16587096, registered in England and
Wales
Our regulatory status
Smartlyy Ltd is a technology company. It is not a bank and is not authorised or regulated
by the Financial Conduct Authority. Smartlyy does not hold client money and does not
custody your digital assets. Regulated services are provided by licensed partners, who are
named when you use the relevant service.
CONTENTS
1. About these terms
2. Our services
3. Who can use Smartlyy
4. Your account and verification
5. Wallets
6. Transfers
7. Fees and exchange rates
8. Partners and third party services
9. Digital asset risks
10. What you must not do
11. Sanctions and compliance
12. Suspension and ending your account
13. Intellectual property
14. Our liability
15. Complaints
16. Changes to these terms
17. General
18 Governing law
1. About these terms
These terms are a contract between you and Smartlyy Ltd (“Smartlyy”, “we”, “us”), a
company registered in England and Wales, company number 16587096, of 20-22
Wenlock Road, London N1 7GU, United Kingdom. They apply to our website, our mobile
and web applications and any related service (the “Services”). By creating an account or
using the Services, you agree to these terms and to our Privacy Policy. If you do not agree,
do not use the Services.
If you use the Services for a business, you confirm that you are authorised to bind it, and
“you” includes that business.
2. Our services
Smartlyy provides software that lets you send money across borders to recipients using
stablecoin settlement, hold a balance that is shown in your local currency, and, where
available, use named currency accounts and cards provided by our partners. Availability
depends on your country of residence and on our partners.
Smartlyy is a technology provider. Accounts, currency conversion, card issuing, payouts to
bank accounts and mobile wallets, and other regulated activity are carried out by licensed
third party partners. When a service is provided by a partner, we identify the partner when
you use it, and the partner’s terms apply in addition to these terms. Our partners include
Latitude and Bridge for accounts and currency conversion, Thunes for payouts, and Privy
for wallet infrastructure.
We do not give financial, investment, tax or legal advice. The Services are not an
investment product.
18. Governing law
19. Contact us
3. Who can use Smartlyy
To use the Services you must:
be at least 18 years old and have legal capacity to enter a contract;
live in, or be a business registered in, a country we and our partners support;
not be on any sanctions list, and not be owned or controlled by someone who is; and
use the Services only for lawful purposes and on your own behalf, or on behalf of a
business you are authorised to represent.
4. Your account and verification
You must give accurate and complete information and keep it up to date. We and our
partners must verify the identity of every user, and of business owners and directors for
business users, before you can use some or all features. We may ask for further
documents, such as proof of address or source of funds, at any time.
You must keep your login details secure and tell us at once if you think someone else has
accessed your account. You are responsible for activity on your account unless you have
told us promptly of unauthorised access and the law says otherwise.
We may refuse to open an account, or limit, suspend or close an account, where we or a
partner cannot complete verification or where required for legal or risk reasons.
5. Wallets
Where the Services provide a non custodial wallet, you control it. Smartlyy does not hold,
control or have access to your private keys or to the funds in your wallet, and cannot move
them without your confirmation.
You are responsible for your sign in methods, your recovery methods and the security of
your devices. If you lose access and have no recovery method, we may not be able to help
you regain access to your wallet or funds. We cannot reverse, cancel or recover a
transaction that you have confirmed.
Wallet technology is provided by third party infrastructure providers, such as Privy, whose
terms may apply to you.
6. Transfers
You must review and confirm each transfer yourself. Before you confirm, check the
recipient, the amount, the fees, the exchange rate and any delivery details shown to you.
Once you confirm, a transfer that is settled on a blockchain is final and cannot be
reversed.
You are responsible for giving correct recipient details. If you give wrong details, we may
not be able to recover the funds. A recipient may need to complete identity verification
before they can withdraw funds to a bank account or mobile wallet.
Delivery times shown are estimates and depend on our partners, banks, payment
networks and blockchains. We and our partners may delay, hold, reject or return a
transfer for compliance, risk, legal or technical reasons, and the funds may be returned
less any fees we cannot recover.
Limits may apply to individual transfers and to total transfers over a period, depending on
your verification level, your country and our partners’ rules.
7. Fees and exchange rates
We show our fees and the exchange rate that applies before you confirm a transfer.
Banks, networks and partners may charge their own fees, which we show where we know
them. Exchange rates move, and the rate that applies is the one shown when you confirm.
Fees may change, but a change will not affect a transfer you have already confirmed.
8. Partners and third party services
Some services are provided by third parties that we do not control. This includes fiat on
ramp and off ramp providers, through which you may buy or sell digital assets. If you use
such a provider, you contract with it directly. It makes its own checks, sets its own fees
and limits, and its own terms and privacy policy apply. Smartlyy is not a party to that
contract and is not responsible for the provider’s services.
Links to other websites are for convenience, and we are not responsible for their content.
9. Digital asset risks
Digital assets, including stablecoins, carry risks. By using the Services you accept that:
a stablecoin may lose its peg to the currency it tracks, may be suspended or may stop
being redeemable;
blockchain networks may be congested, delayed, interrupted or attacked;
transactions on a blockchain cannot be reversed;
laws and regulations on digital assets are changing and may affect the Services; and
you may lose access to your funds if you lose your credentials and recovery methods.
10. What you must not do
You must not use the Services to:
break any law, or help someone else to do so;
commit fraud, launder money, finance terrorism or evade sanctions;
receive or send funds from illegal activity, including illegal goods, services or gambling;
provide money transmission or digital asset exchange services to other people without
the licences the law requires;
give false identity or business information, or open accounts for someone else;
hide your location from us or our partners, for example to get around a restriction;
interfere with, probe or overload the Services, or try to access them without
permission; or
copy, reverse engineer or resell the Services, except as the law allows.
11. Sanctions and compliance
We and our partners screen users and transactions against sanctions lists and monitor for
suspicious activity. Where the law requires, we may freeze funds, refuse or stop a
transaction, and report to authorities, and we may not be allowed to tell you that we have
done so. We cannot release frozen funds without lawful authority. We do not offer the
Services in countries and territories that our partners or the law do not allow, and the list
may change.
12. Suspension and ending your account
You can close your account at any time. Withdraw or move your funds first. We can
suspend or close your account, or limit features, if you break these terms, if we
reasonably suspect fraud or illegal use, if a partner or the law requires it, or if we stop
offering the Services. Where we can, and where the law allows, we will tell you why and
give you the chance to move your funds. Closing an account does not affect rights and
duties that have already arisen.
13. Intellectual property
Smartlyy and its licensors own the Services, the Smartlyy name and logo, and all related
intellectual property. We give you a limited, personal, non exclusive and non transferable
right to use the Services in line with these terms.
14. Our liability
Nothing in these terms limits liability for death or personal injury caused by negligence,
for fraud or fraudulent misrepresentation, or for anything else that cannot be limited by
law. If you are a consumer, your statutory rights are not affected.
Subject to that, and to the extent the law allows:
we are not liable for indirect or consequential loss, or for loss of profit, business or
goodwill;
we are not liable for loss caused by a partner or third party service, a blockchain or
network event, a loss of your credentials, wrong details you gave us, or events beyond
our reasonable control; and
our total liability to you for all claims relating to the Services in any twelve month
period is limited to the fees you paid to us in that period.
The Services are provided on an “as available” basis. We do not promise that they will be
uninterrupted or free from errors.
If you use the Services for a business, you will compensate us for losses we suffer
because you broke these terms or the law.
15. Complaints
If you have a complaint, contact us using the details below. We will acknowledge it within
five business days and aim to give you a full response within 30 days. If a complaint is
about a service provided by a partner, we may pass it to the partner, and you may also use
the partner’s own complaints process and any external complaints body that applies to
that partner.
16. Changes to these terms
We may change these terms, for example to reflect new features, partners or legal
requirements. We will give you at least 30 days’ notice of material changes by email or
through the Services, unless a shorter period is needed by law or for security. If you do
not agree to a change, you can close your account before it takes effect. If you keep using
the Services after that, you accept the change.
17. General
Whole agreement. These terms and our Privacy Policy are the whole agreement
between us about the Services.
Transfer. We may transfer our rights and duties to another company if it does not
reduce your rights. You may not transfer yours without our written consent.
If a term cannot be enforced, the rest still applies.
Delay. If we do not enforce a right straight away, we can still do so later.
Events beyond our control. We are not responsible for failures caused by events
outside our reasonable control.
Third parties. Only you and we can enforce these terms. No one else has rights under
the Contracts (Rights of Third Parties) Act 1999.
18. Governing law
These terms and any dispute about them are governed by the laws of England and Wales,
and the courts of England and Wales have exclusive jurisdiction. If you are a consumer
living in Scotland or Northern Ireland, you can also bring a claim in your local courts. If
you live elsewhere, you keep any mandatory consumer protection rights that apply in your
country.
19. Contact us
Smartlyy Ltd
20-22 Wenlock Road, London N1 7GU, United Kingdom
Company number 16587096
Email: info@smartlyy.co.uk
Smartlyy Ltd · Terms of Service · Effective 30 October 2026