Terms of Use

Fineyra — a brand operated by HONOMY ENTERPRISE LIMITED

Incorporated under the Business Corporations Act (British Columbia), Canada · incorporation number BC1504131 · business number 746166628BC0001

Registered as a money services business with FINTRAC · registration number C100000558 · foreign exchange dealing, dealing in virtual currency, payment service provider

Registered office: 580 Seaborne Avenue, Unit 2120, Port Coquitlam, British Columbia, V3B 0M3, Canada

Version 1.1 · Effective date: 10 November 2026 · Supersedes version 1.0 of 9 November 2026

Who we are, and what this agreement is

These Terms of Use (the “Terms”), together with the Fineyra Privacy Policy, form the agreement between you and HONOMY ENTERPRISE LIMITED (“Honomy”, “the Company”, “we”, “us”, “our”) governing your use of the Fineyra application, the website at fineyra.com and the services described in section 4 (together, the “Services”).

Fineyra is a trading name of the Company. It is not a separate legal entity. The Company is the sole contracting party under these Terms and is responsible for the Services, except where these Terms state that a service is provided to you by a third party under that party’s own agreement with you.

By creating an account or using the Services you confirm that you have read, understood and accept these Terms. If you do not accept them, you may not use the Services.

The Company is registered with the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) as a money services business, under registration number C100000558, for foreign exchange dealing, dealing in virtual currency and as a payment service provider. Registration is a legal requirement for carrying on a money services business in Canada and it carries the full obligations of a reporting entity under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. It is not a licence, an authorisation, or an endorsement of the Company or of the Services by FINTRAC or by the Government of Canada. The Company holds no licence or authorisation in any other jurisdiction.

We are not a bank. Balances held through the Services are not deposits. They are not insured by the Canada Deposit Insurance Corporation, and they are not covered by any deposit-guarantee, investor-compensation or similar scheme in Canada or elsewhere.

Definitions

“Account” – The account you open with us to access the Services.

“Card” – A payment card made available through the Services and issued by the Issuing Partner, not by us.

“Card Account” – The account held with the Issuing Partner to which the Card is linked and from which Card transactions are settled.

“Issuing Partner” – The licensed card issuing and processing institution that issues and services the Card. The Issuing Partner is identified in the application and in the cardholder agreement presented to you before a Card is issued.

“Stablecoin” – A virtual currency designed to maintain a stable value against a reference currency, of the types and on the networks listed as supported in the application.

“Virtual Currency” – A digital representation of value that is not issued or guaranteed by a central bank or public authority, does not necessarily have the legal status of currency or money, and can be transferred, stored and traded electronically.

“Wallet” – The self-custodial virtual currency wallet made available through the application, the keys to which are generated and held on your side and are never held by us.

“Top-up” – A transfer of Stablecoins that funds the Card Account.

“Third-Party Service” – A service made available through the application but provided to you by a third party under that party’s own terms, as described in section 8.

“Supported Country” – A country that appears on the supported-countries list published in the application and at fineyra.com/supported-countries at the time you use the Services, as described in section 3.3.

Eligibility

To use the Services you must confirm, and you confirm each time you use them, that you:

are a natural person aged 18 or over, or the age of majority in your place of residence, whichever is higher;
have the legal capacity to enter into a binding contract;
are acting on your own behalf and for your own account, as a consumer, and not on behalf of or for the benefit of any other person;
are resident in a Supported Country, and will tell us if that changes;
will provide the identification documents and information we or the Issuing Partner request, and will keep them current; and
are not subject to any of the restrictions in section 3.2.

The Services are for individual consumers only

The Services are not available to businesses, financial institutions, payment service providers, money services businesses, fintech companies, exchanges, brokers, agents, distributors or resellers, and may not be used to provide any service to a third party. We do not offer sub-programmes, white-label arrangements or resale of the Services. Business and institutional services are offered by the Company under separate brands, under separate terms and under a separate onboarding and risk assessment standard, and are not available through Fineyra.

Where the Services are not available

We do not offer the Services to, and you may not use them if you are:

a United States person, or resident in the United States or any of its territories;
resident in, or a national of, a country or territory subject to comprehensive economic sanctions imposed by Canada, the United Nations, the United States, the United Kingdom or the European Union;
resident in a jurisdiction identified by the Financial Action Task Force (FATF) as a high-risk jurisdiction subject to a call for action, as that list stands from time to time and is published at fatf-gafi.org;
resident in the European Economic Area, the United Kingdom, Brazil or Kazakhstan, where provision of the Services would require a local authorisation that the Company does not hold. This exclusion applies for as long as the Company does not hold the authorisation concerned, and is not a statement that the Services will not be offered in those jurisdictions in future;
resident in a territory that is temporarily occupied or otherwise outside the effective control of the government of the country concerned. This includes the Autonomous Republic of Crimea and the city of Sevastopol, and those parts of the Donetsk, Luhansk, Zaporizhzhia and Kherson regions of Ukraine that are not under the control of the Government of Ukraine. This exclusion applies regardless of your nationality; or
a person listed on, or owned or controlled by a person listed on, any applicable sanctions or restricted-party list.

You are responsible for knowing whether your use of the Services is lawful where you are. We may use technical means, including the information you provide and your IP address, to establish your location, and we may suspend access where we believe you are in an excluded jurisdiction.

Which countries are supported

The Services are available to you if your country of residence satisfies all three of the following at the time you use them:

it is a country in which the Issuing Partner supports the card programme;
it is not excluded under section 3.2; and
it appears on the supported-countries list published in the application and at fineyra.com/supported-countries.

The published list is the operative list. It carries the date on which it was last reviewed, and it governs if it differs from any other statement about availability made by us or on our behalf. It is narrower than the Issuing Partner’s own country coverage, because the exclusions in section 3.2 are applied to that coverage.

We open markets in stages, and the markets we open first are not the limit of availability. The countries in which the application is localised and in which we first offer the Services are a subset of the Supported Countries, chosen for language and for the way we reach users. A country that is not yet on the published list is not for that reason permanently excluded. We add countries to the list as the Issuing Partner’s coverage changes and as we complete the legal and operational preparation for a market.

Whether any individual may use the Services is determined on the nationality and the country of residence captured at identity verification, and is also subject to the supported-country and restricted-nationality rules of the Issuing Partner. Those rules may exclude a particular combination of nationality and residence even where the country of residence is a Supported Country. We may decline to open an Account, or close an existing one, where those rules exclude you.

The Services

The Services consist of the following, as made available in the application from time to time:

A self-custodial Wallet. You hold your own keys. We do not hold, and have no access to, your private keys, recovery phrase or password.
Access to a payment Card issued by the Issuing Partner, which you may fund with Stablecoins and use to pay merchants. Card transactions settle in US dollars and are converted into the merchant’s currency at the point of sale.
Stablecoin Top-ups of the Card Account, on the networks listed as supported in the application.
Transaction history, card controls and notifications — limits, freezing and unfreezing the Card, card details, and the record of your transactions.
Customer support in the languages stated in the application.

We decide the functionality, scope and availability of the Services, and we may add, change, suspend or withdraw features. Where a change materially reduces a feature you rely on, we will give you notice in accordance with section 16.

What the Services are not

We do not hold your Stablecoins in the Wallet, and we do not act as a custodian of your virtual currency.
We do not take deposits, we do not pay interest, and we do not lend, provide credit or offer margin.
We do not accept cash, and we do not accept funding of the Card Account in fiat currency.
We do not accept funds from, or make payments to, any person other than you.
We are not a party to Third-Party Services, and we do not act as the counterparty to the purchase, sale or exchange of virtual currency except where the application states otherwise and you have accepted terms that say so.

Identity verification, monitoring and sanctions

Before you can use the Card, your identity must be verified. For the card programme, identity verification and screening of cardholders are carried out by the Issuing Partner, and we obtain and retain the information relied upon for that verification as required of a registered money services business in Canada. Where we carry out verification ourselves, we do so with the assistance of our verification provider, as described in the Privacy Policy.

You authorise us and the Issuing Partner to make the enquiries we consider necessary to verify the information you provide, including checks with third-party data sources, and to screen you on an initial and ongoing basis against sanctions, politically exposed person and other restricted-party lists.

We may, at any time and for as long as necessary:

request further information or documents, including on the source of funds or source of wealth;
delay, decline, limit or reverse a transaction;
suspend or restrict your Account or the Card; or
terminate the relationship.

Where we are required or restricted by law — including the prohibition on disclosing that a report has been or may be made to FINTRAC — we may be unable to tell you the reason for a decision. The absence of a reason is not an admission of fault by either of us.

Providing false, altered or counterfeit documents or information is a material breach of these Terms, and we will treat it as attempted fraud.

Funding, flow of funds and your own name

Funds may reach your Wallet or Card Account only from a wallet or account in your own name. Third-party funding is not permitted and will be rejected or returned where possible.
Withdrawals and returns of funds are made only to a wallet or account in your own name.
Virtual currency transfers are recorded on public blockchains, are irreversible once confirmed, and cannot be cancelled or recalled by us. You are responsible for the accuracy of any address you use. Funds sent to an incorrect address, on an unsupported network, or in an unsupported asset may be permanently lost.
Network fees charged by a blockchain network are not set by us and are not refundable.

The Card

The Card is issued by the Issuing Partner, not by us. In addition to these Terms, you will be asked to accept the Issuing Partner’s cardholder agreement before a Card is issued. On matters concerning the issuing, authorisation, settlement, limits, disputes and chargebacks of the Card, the Issuing Partner’s cardholder agreement applies and prevails over these Terms.

Authorisation and limits. Transaction, balance and velocity limits are applied by the Issuing Partner and are shown in the application. A transaction may be declined where a limit, a control or a screening rule applies.
Conversion. Card transactions settle in US dollars and are converted into the transaction currency at the Issuing Partner’s base rate for that currency plus our markup, which is disclosed to you in the application before you confirm a purchase.
Disputed transactions. A transaction you do not recognise, or a dispute with a merchant, is handled under the rules of the card scheme through the Issuing Partner. Tell us as soon as you become aware, and in any event within the time limit stated in the cardholder agreement; late notice may mean the dispute cannot be raised.
Lost, stolen or compromised Card. Freeze the Card in the application immediately and contact support.
Merchant acceptance. We do not control which merchants accept the Card, and we are not responsible for a merchant’s refusal to accept it or for the goods or services a merchant supplies.

Third-Party Services

The application may give you access to services provided by third parties — for example the purchase or sale of virtual currency, the exchange of one virtual currency for another, or an optional product that pays a return on a balance. Where it does:

the service is provided to you by that third party under its own terms and privacy policy, which you accept separately and which govern that service;
we are not the counterparty, we do not hold the funds, and we do not guarantee the performance, solvency or continued availability of the third party;
funds used in a Third-Party Service do not pass through the card programme; and
we select third parties after due diligence, but that does not make us responsible for their acts or omissions.

Where a return is paid on a balance, it is paid by the third party and is not a deposit, is not guaranteed, and may be reduced or lost.

Fees

Our fees are published in the application and on fineyra.com, and the fee applying to a transaction is shown to you in money, before you confirm that transaction. We charge:

a markup on the conversion of US dollars into the transaction currency, disclosed before each purchase;
where applicable, a fee for funding the Card Account from your Wallet;
where applicable, fees for cash withdrawal at an automated teller machine, and for the issue or delivery of a physical card.

Fees charged by third parties — a blockchain network, an automated teller machine operator, your bank, or a Third-Party Service — are separate and are not set by us. We may change our fees on notice under section 16. Taxes arising from your use of the Services are your responsibility, and it is for you to determine, report and pay them.

Your obligations and prohibited use

You must keep your credentials, device and recovery material secure, keep the information you have given us accurate and current, and tell us promptly of any unauthorised access. You must not use the Services:

for money laundering, terrorist financing, sanctions evasion, tax evasion, fraud or any other unlawful purpose;
on behalf of, or to provide a service to, another person, or to receive funds from a third party;
to acquire or distribute goods or services that are unlawful where you or the merchant are located, or to transact with darknet markets, unlicensed gambling, or sanctioned counterparties;
to disguise the origin, ownership or destination of funds, including by structuring transactions to avoid a reporting or verification threshold;
to interfere with, probe, reverse engineer or place an unreasonable load on the Services, or to access them by automated means without our written consent; or
in breach of any law applying to you.

Risks you accept

Value. Virtual currencies are volatile. A Stablecoin is designed to hold its value against a reference currency but may fail to do so, and its issuer may suspend redemption. We do not guarantee the value or convertibility of any asset.
Self-custody. You alone hold the keys to your Wallet. If you lose your keys or recovery phrase, neither we nor anyone else can recover your funds, and they will be permanently lost.
Irreversibility. Blockchain transactions cannot be reversed by us.
Technology. Networks, smart contracts and third-party infrastructure may fail, be congested, be exploited or be discontinued.
Regulatory change. A change in law or in the rules of a card scheme, an issuer or a network may require us to change, suspend or withdraw a feature, a market or the Services, at short notice.
Availability. The Services may be interrupted for maintenance, by a third party, or by events outside our control.

Nothing in the Services or on fineyra.com is investment, financial, tax or legal advice, or a recommendation to acquire or dispose of any asset. You decide whether the Services are suitable for you.

Suspension, termination and the return of your funds

By you. You may close your Account at any time, by telling us in the application or in writing. Closing your Account does not end obligations that have already arisen.

By us, immediately. We may suspend or terminate your Account or the Card without prior notice where we are required to do so by law or by the Issuing Partner, where we have reason to believe the Account is being used unlawfully or in breach of section 10, where identification or verification cannot be completed, or where you become subject to a restriction in section 3.2.

By us, on notice. We may terminate for any other reason, including withdrawal of the Services from your market, on at least 30 days’ written notice.

What happens to your funds. Stablecoins in your Wallet remain under your control at all times, and nothing in this section affects your access to them. On closure or termination we will, unless prevented by law or by an order binding on us:

allow you to spend or withdraw the balance of the Card Account, and tell you by when;
return any remaining balance of the Card Account to a wallet or account in your own name, net of amounts you owe us and of any pending or disputed card transaction; and
keep the records we are required to keep, for the periods set out in the Privacy Policy.

Where the Services or a market are withdrawn, we will give the notice in this section, state the date after which the Card will stop working, and set out how to withdraw the balance. Where a legal restriction prevents a return of funds, we will return them as soon as the restriction is lifted.

Complaints

Tell us first, through the support channel in the application or at [email protected]. We will acknowledge your complaint within 5 business days and give you our answer within 30 calendar days; if we need longer, we will tell you why and when to expect an answer. A complaint about the issuing, authorisation or settlement of a Card transaction may need to be handled by the Issuing Partner, and we will tell you if we pass it on. A complaint about how we handle your personal information may also be made as set out in the Privacy Policy.

Liability

We will provide the Services with reasonable care and skill. We are liable to you for loss we cause by breaking these Terms or by failing to use reasonable care and skill, but not for:

loss of profit, loss of opportunity, loss of data or any indirect or consequential loss;
a change in the value of a virtual currency;
the loss of your keys or recovery phrase, or a transaction you authorised or sent to the wrong address;
the acts, omissions, insolvency or discontinuation of a third party, including the Issuing Partner, a Third-Party Service, a merchant, a blockchain network or an automated teller machine operator; or
a failure caused by an event outside our reasonable control, including the unavailability of a network, a change in law, or an instruction from a regulator.

Where we are liable, our total liability for all claims arising in any 12-month period is limited to the greater of the fees you paid us in that period and 500 US dollars. Nothing in these Terms limits or excludes liability that cannot be limited or excluded by law — including liability for fraud or fraudulent misrepresentation, and any right you have under the mandatory consumer-protection law of your country of residence.

You are responsible for loss we suffer because you broke these Terms, used the Services unlawfully, or gave us false information.

Personal information

How we collect, use, disclose and protect your personal information, who receives it, how long we keep it, and the rights you have, are set out in the Fineyra Privacy Policy, which forms part of this agreement. We are subject to Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and we comply with the data protection law of your country of residence where it applies to us. The Issuing Partner acts as an independent controller of the data it processes for issuing and verification, under its own privacy notice.

Changes to these Terms

We may change these Terms to reflect a change in law, in the Services, in our fees or in the requirements of a partner or a regulator. We publish the current version at fineyra.com with a version number and an effective date. Where a change is to your disadvantage in a material way — including an increase in our fees or a reduction of a feature you rely on — we will give you at least 30 days’ notice by email or in the application, and you may close your Account before the change takes effect without charge. Where a change is required by law with immediate effect, or is in your favour, it may take effect sooner. Continuing to use the Services after a change takes effect means you accept it.

General

Governing law. These Terms, and any dispute arising out of them or the Services, are governed by the laws of the Province of British Columbia and the federal laws of Canada applicable in that province.

Courts. The courts of British Columbia have jurisdiction, and you and we submit to them. If you are a consumer, this does not deprive you of the protection of any mandatory law of your country of residence, or of the right to bring proceedings in the courts of that country where that law gives you it.

Language. These Terms are made in English. A translation is provided for convenience only; in the event of a conflict, the English version prevails, except where the law of your country of residence requires otherwise.

Assignment. You may not transfer your rights or obligations under these Terms. We may transfer ours to another company in the same group, or to a successor of the business, on notice to you, provided your rights are not reduced.

Severability. If a provision is found unenforceable, the rest of these Terms continue to apply.

No waiver. A delay in enforcing a right is not a waiver of it.

Entire agreement. These Terms, the Privacy Policy, the fee schedule and the cardholder agreement are the whole agreement between us on their subject matter.

Notices. We will write to you at the email address on your Account or through the application. You may write to us at [email protected], or to the Company at the registered office above.

Contact

HONOMY ENTERPRISE LIMITED — trading as Fineyra

580 Seaborne Avenue, Unit 2120, Port Coquitlam, British Columbia, V3B 0M3, Canada

Product and support: [email protected] · Company: [email protected] · Privacy: [email protected]

Version 1.1 — supersedes version 1.0 of 9 November 2026. The only change is to country availability. Version 1.0 named Argentina, Ukraine and the Republic of Moldova as the Supported Countries, which stated the markets we open first as though it were the limit of availability. Availability is now stated as a rule in section 3.3, together with a separately published supported-countries list, and the exclusions in section 3.2 are stated as applying only for as long as the Company does not hold the authorisation concerned. The change only widens the countries in which the Services may be offered and removes no right, so under section 16 it takes effect on publication.

Version 1.0 was the first version issued under Honomy Enterprise Limited. It replaced the terms previously published on fineyra.com under a different operating entity, together with the references in them to Lithuanian law, to a Lithuanian virtual asset service provider licence, to custodial wallet services, and to services for business clients, none of which apply to the Services described here.