Terms of Use

00Our contacts

01General Provisions

1.1 Who we are

“Gasless”, “we”, “us”, or “our” means XPAID SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, a company organized under the laws of the Republic of Poland, with registered address at ul. Kolejowa 45 / 119, 01-210 Warsaw, Poland, KRS number 0001143376, NIP 7252350588. This Privacy Policy and all processing of your personal data is governed by Regulation (EU) 2016/679 (GDPR) and the laws of the Republic of Poland. The competent supervisory authority is the President of the Personal Data Protection Office (UODO) of the Republic of Poland (uodo.gov.pl). We operate Gasless, a non-custodial wallet and transaction infrastructure focused on the Tron ecosystem. The Services include the Gasless Wallet application, Gasless Node infrastructure, the gasless transaction system, and the website gaslesswallet.io. These components may interact with each other to provide the Services.

1.2 Disclaimer (no financial advice)

The Service is a software toolset for interacting with public blockchains. The Company is not a financial intermediary and does not provide any investment, legal, accounting or tax advice. Nothing in the Service constitutes an offer or solicitation to buy or sell any asset or financial advice. We do not guarantee the availability of the Service, the absence of errors or uninterrupted operation. We are not liable for any loss of funds, actions or failures of the blockchain network (including Tron), volatility of cryptocurrencies, technical outages, user errors (such as sending to an incorrect address), or risks associated with third-party services (RPC providers, blockchain infrastructure, etc.). Digital assets and blockchain transactions are inherently risky; you are solely responsible for your actions and security practices.

1.3 Non-custodial notice

You use the Service at your own risk and on your own behalf. You represent and warrant that you comply with all laws of your jurisdiction, are not located in, under the control of, or a national/resident of any sanctioned or prohibited country/territory, and do not use the Service for any AML/CTF violations, money laundering, terrorism financing, fraud, scam or any other illegal activities.

You acknowledge the following inherent risks: volatility of cryptocurrencies, technical failures or outages of the blockchain network (including Tron), risk of permanent loss of access to the wallet (e.g. loss of email access or MPC key shares), user errors (such as sending to an incorrect address), and risks associated with third-party services (RPC providers, blockchain infrastructure, etc.). Transactions are irreversible once broadcast to the network.

1.4 Eligibility

The Service is not intended for children. You must be at least 18 years old (or the age of majority in your jurisdiction) to use the Service. You represent that you are legally permitted to use the Service in your jurisdiction and are not a person or entity sanctioned or otherwise restricted under applicable laws.

1.5 Changes to these Terms

We may update these Terms from time to time. Where required or appropriate, we may notify you via in-app notice, email, or banner. The “Edition effective since” date above will reflect the latest update. By continuing to use the Service, you accept the updated Terms.

02Definitions

2.1 Customer / you / your

The individual or legal entity using the Service. If you accept these Terms on behalf of an entity, you represent that you have authority to bind that entity; otherwise, you must not use the Service.

2.2 Software

Gasless Wallet application, Gasless Node infrastructure, website services, and related software components made available by Gasless.

2.3 Deliverables

Any transaction-related information, confirmations, records, or information displayed through the Service.

2.4 Subscription Platform

Any guides, FAQs, developer docs, or announcements we publish.

2.5 Documentation

Any guides, FAQs, developer docs, or announcements we publish.

2.6 Applicable Laws

All laws, rules, and regulations that apply to your use of the Service, including sanctions, export controls, anti-money-laundering and counter-terrorist-financing rules, consumer protection, data protection, and financial services rules, where applicable.

03Our Agreement with You

3.1 Binding contract

These Terms govern your access to and use of the Service and any related products or features. By accessing or using any part of the Service, you agree to the Terms and our Privacy Policy.

3.2 Exclusion of other terms

Any additional terms proposed by you (e.g., purchase orders, emails) are excluded unless we agree in writing.

3.3 Service updates

We may add, change, or remove features. We may deploy fixes, improvements, or new modules without prior notice.

3.4 Beta features

We may label certain features as “beta,” “preview,” or similar. Such features are provided as-is, may be unstable, and may be withdrawn at any time.

04Commencement and Duration

These Terms apply from the moment you start using any part of the Service. The Agreement continues until terminated by either party in accordance with these Terms.

05Our Responsibilities

5.1 Reasonable efforts

We will use reasonable efforts to supply the Service materially in accordance with these Terms.

5.2 Security actions

If we believe your account or use is compromised, abusive, or unlawful, we may suspend or disable access.

5.3 Support

We provide customer support via email at info@gaslesswallet.io.

06Your Obligations

You agree to:

6.1 Account & access

Keep access credentials secure; promptly notify us of any breach or suspected compromise.

6.2 Lawful use

Comply with Applicable Laws, including those related to sanctions, export control, AML/CFT (where applicable), data protection, consumer rights, and financial services.

6.3 Acceptable use

Do not:

• overload or disrupt our systems;
• send spam or malicious code;
• reverse engineer, decompile, or attempt to derive source code except where permitted by law;
• rent, lease, sell, resell, or sublicense the Service without our consent;
• bypass security or rate limits;
• use the Service for illegal activities, including but not limited to money laundering (AML violations), financing of terrorism (CTF violations), any activity involving sanctioned jurisdictions or persons, fraud, scam or any other illegal or fraudulent purpose.

6.4 Blockchain risks

You acknowledge risks inherent to public blockchains (e.g., network congestion, forks, validator behavior, smart-contract bugs, price volatility) and understand we cannot reverse or control on-chain actions.

6.5 Prohibited locations and persons

You represent and warrant that you are not located in, under the control of, or a national or resident of any country or territory subject to comprehensive sanctions, and are not listed on any government sanctions list. This includes but is not limited to: Cuba (Council Regulation (EU) 2017/1509), Democratic People’s Republic of Korea (North Korea) (Council Regulation (EU) 2017/1509, implementing UNSCR 1718), Iran (Council Regulation (EU) 359/2011), Syria (Council Regulation (EU) No 36/2012), Belarus (Council Regulation (EU) 765/2006); and the following territories under Russian occupation: Crimea and Sevastopol (Council Regulation (EU) No 692/2014, as amended by Council Regulation (EU) 2025/401 of 24 February 2025), non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine (Council Regulation (EU) 2022/263, as amended by Council Regulation (EU) 2025/398 of 24 February 2025); and any other jurisdiction subject to comprehensive EU, US, or UN sanctions at the time of your use of the Service. We may restrict or geoblock access from such locations where required by law, including under the EU Markets in Crypto-Assets Regulation (MiCA) (Regulation (EU) 2023/1114) and applicable anti-money laundering rules.

07Intellectual Property

7.1 Ownership

All Intellectual Property Rights in and to the Service, Software, and Documentation are owned by us or our licensors. No rights are granted except as expressly set out in these Terms.

7.2 License

Subject to these Terms and payment of fees (if applicable), we grant you a limited, revocable, non-exclusive, non-transferable license to access and use the Service for your lawful internal purposes.

7.3 Restrictions

You may not copy, modify, distribute, or create derivative works of the Software or Documentation, except as permitted by law or our written permission.

7.4 User Content

If you provide feedback, suggestions, or content (“User Content”), you grant us a worldwide, non-exclusive, royalty-free, transferable, sublicensable license to use it for operating, improving, and promoting the Service. You are responsible for your User Content and warrant you have necessary rights to provide it.

7.5 Reference use

We may use your name/logo as a customer reference (e.g., website, pitch materials) unless you opt out by emailing info@gaslesswallet.io.

08Data Protection

8.1 Privacy Policy

See our Privacy Policy for how we collect and process personal data. By using the Service, you acknowledge such processing.

8.2 Data roles

To the extent personal data is processed by us as controller or processor, we will comply with Applicable Laws. Additional data processing terms may be provided in a separate Data Processing Agreement where required.

09Confidentiality

Each party shall keep the other party’s non-public information confidential and use it only for exercising rights and performing obligations under these Terms. This does not apply to information that is public, independently developed, or rightfully received from third parties without confidentiality obligations.

10Limitation of Liability

10.1 As-is / as-available

The Service is provided “as is” and “as available.” We disclaim all warranties not expressly stated, including merchantability, fitness for a particular purpose, non-infringement, and uninterrupted or error-free operation. We do not guarantee the availability of the Service, the absence of errors or uninterrupted operation. We are not liable for any loss of funds, actions or failures of the blockchain network (including Tron), volatility of cryptocurrencies, technical outages, user errors or risks associated with third-party services.

10.2 No special damages

To the maximum extent permitted by law, we are not liable for indirect, incidental, special, consequential, exemplary, or punitive damages, or for loss of profits, revenue, data, or goodwill, even if advised of the possibility.

10.3 Cap

Our aggregate liability arising out of or relating to the Service shall not exceed EUR 100 (or equivalent).

10.4 Security & blockchain

You acknowledge that complex software and public blockchains may contain vulnerabilities. We are not liable for on-chain events, network failures, forks, congestion, or irreversible transactions.

10.5 Mandatory rights

Some jurisdictions do not allow certain limitations; in such cases, the limitations apply to the fullest extent permitted by law.

11Termination

11.1 Termination by the Company

The Company reserves the right to suspend or terminate the User’s access to the Application at its sole discretion, including but not limited to cases of violation of these Terms, legal requirements, or risk management considerations.

Due to the non-custodial nature of the Application:

• The Company does not store, hold, or control the User’s funds or private keys.
• All digital assets remain on the blockchain network (including the TRON network) and are fully controlled by the User.

Upon termination, the User may lose access to certain functionalities of the Application. The User remains solely responsible for:

• maintaining access to their authentication methods and recovery options;
• accessing their wallet through compatible third-party tools;
• transferring their digital assets if desired.

The Company shall not be liable for any inability of the User to access their wallet or funds due to loss of authentication credentials, recovery methods, private keys, or other access factors. The Company does not have the ability to recover access to the User’s wallet, or to transfer, freeze, or otherwise manage User funds. The User is strongly advised to ensure backup of all access credentials prior to any termination.

11.2 By you

You may stop using the Service at any time.

11.3 Effect

Upon termination your license and access cease. Sections 7, 8, 9, 10, 11.3, 13–16 survive.

12Force Majeure

12.1 Force majeure events

Neither party is liable for delay or failure caused by events beyond reasonable control (e.g., natural disasters, war, terrorism, labor disputes, government actions, utility or telecommunications outages, major platform outages such as Cloudflare or our hosting provider, epidemics/pandemics). The affected party must notify the other party and use reasonable efforts to mitigate.

12.2 Extended force majeure

If force majeure continues for more than 6 weeks, the non-affected party may terminate on 4 weeks’ written notice.

13Compliance; Sanctions; AML/CFT

13.1 Sanctions and export-control

You must not use the Service in violation of sanctions or export-control laws. We may restrict access to certain jurisdictions or persons.

14Third-Party Services and Links

The Service may integrate with or link to third-party services. We do not control third-party services and are not responsible for their content or practices. Your use is governed by their terms and policies.

15Governing Law and Dispute Resolution

15.1 Governing law

These Terms are governed by the laws of the Republic of Poland, without regard to conflict-of-law principles.

15.2 Governing Law and Jurisdiction

These Terms and any dispute or claim arising out of or in connection with them or their subject matter (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of the Republic of Poland.

• If you are a business user: Any dispute arising out of or in connection with these Terms shall be submitted to the exclusive jurisdiction of the courts of the Republic of Poland (Warsaw District Court as the court of first instance).
• If you are a consumer resident in the European Union: you may bring proceedings in either the courts of the Republic of Poland, or the courts of the EU Member State in which you are resident; similarly, we may bring proceedings against you in the courts of the country in which you are resident.

15.3 Dispute Resolution for Consumers (EU only)

Before taking any legal action, we both agree to first try to resolve any dispute amicably by contacting each other at info@gaslesswallet.io. EU consumers may also use the European Online Dispute Resolution platform (ODR) available at https://ec.europa.eu/odr.

16Miscellaneous

16.1 Severability

If a provision is unenforceable, the remainder remains in effect; modify the invalid provision to the minimum extent necessary to be valid.

16.2 Assignment

You may not assign or transfer these Terms without our prior written consent. We may assign to an affiliate or in connection with a merger, acquisition, or sale of assets.

16.3 No partnership

These Terms do not create a partnership, joint venture, or agency relationship.

16.4 Third-party rights

No third party has rights to enforce these Terms.

16.5 Notices

Notices must be sent by email to info@gaslesswallet.io (or another address we designate) and are deemed received when sent, unless outside business hours, in which case on next business day. Your notices must include identifying information for your account.

16.6 Entire agreement

These Terms (and referenced policies) are the entire agreement regarding the Service and supersede prior understandings.

16.7 Waiver

Failure to enforce any provision is not a waiver.

16.8 Counterparts / electronic acceptance

These Terms may be accepted electronically. Copies and electronic signatures have the same effect as originals.

S1Schedule 1 — Services Overview

Service: Non-custodial Gasless Wallet application and Gasless Node infrastructure enabling USDT transactions on the Tron network, gasless transaction functionality, wallet access, and related features.

Deliverables: On-screen confirmations and transaction logs.

Limitations: Outputs are informational only; on-chain results prevail.

S2Schedule 2 — Platform-Specific Terms (iOS App Store)

You must comply with Apple App Store terms and policies. Service quality may be affected by iOS updates or Apple outages.

17Contact

XPAID SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ