Terms of Service

This document constitutes the Terms of Service for the Moywa services, operated by Green Cloud and Blockchain SARL. It may be amended — the version in force is always the one accessible from the Moywa application and the moywa.com website.

Preamble

These Terms of Service (the "Terms") govern the use of the Moywa services, a money transfer and stablecoin management platform intended for residents of the European Economic Area (EEA).

Moywa is published by Green Cloud and Blockchain SARL ("Moywa"), a single-member limited liability company registered with the Nîmes Trade and Companies Register under number 408 734 499, whose registered office is at 279 Route de Saint-Privat, 30340 Saint-Privat-des-Vieux, France. Its corporate purpose includes, in particular, the provision of payment services and funds transfer services acting as a distributor or agent of authorised payment service providers, the issuance and distribution of stablecoins, and the operation of digital payment platforms.

Moywa acts as a technical and commercial interface, as a technical distributor of Bridge.xyz services. The regulated services (custody of crypto-assets, exchange services, fiat payment services) are provided by Bridge Building S.A., a company incorporated under Luxembourg law whose registered office is at 26 Boulevard Royal, L-2449 Luxembourg, authorised and supervised by the Commission de Surveillance du Secteur Financier (CSSF, Luxembourg) as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114 (MiCA), authorisation number N00000012, and as an electronic money institution under the Luxembourg Act of 10 November 2009 on payment services, authorisation number W00000024. Those authorisations benefit from the European passport and cover the 27 Member States of the European Union. The regulated services are provided under Bridge's own user agreement. Moywa is not an authorised crypto-asset service provider within the meaning of Regulation (EU) 2023/1114 (MiCA), nor a payment institution or an electronic money institution.

The USDC and EURC stablecoins used by the Moywa services are issued by Circle Internet Financial Europe SAS, a company authorised as an electronic money institution by the Autorité de Contrôle Prudentiel et de Résolution (ACPR) in France.

Acceptance of these Terms is mandatory in order to use the Moywa services. Acceptance of the applicable Bridge terms of use is also required in order to benefit from the regulated services.

Article 1 — Definitions

• User: Any natural person of full age or legal entity, resident in the EEA, having created a Moywa account after identity verification (KYC/KYB) carried out by Bridge.
• Account: The User's personal area on Moywa, accessible after authentication, giving access to the Services.
• Services: All features offered by Moywa: receipt of funds by bank transfer, conversion into stablecoin, transfer to other Users, conversion between currencies, management of beneficiaries.
• EURC / USDC: Stablecoins issued by Circle Internet Financial Europe SAS, backed by 1 EUR and 1 USD respectively.
• Bridge: Bridge Building S.A. (Luxembourg), a regulated service provider authorised by the CSSF (CASP MiCA No. N00000012; EMI No. W00000024), providing the underlying regulated services (custody, exchange, payment services).
• Custody: The service of safekeeping crypto-assets and fiat funds, provided exclusively by Bridge. Bridge holds the private keys of the wallets and holds Users' funds. Moywa has no direct control over the wallets or over Users' funds.
• Strong authentication: The two-factor authentication procedure (2FA / SCA) required by Directive (EU) 2015/2366 (PSD2) for sensitive operations.
• KYC / KYB: Identity verification procedures (Know Your Customer / Know Your Business) which are mandatory under anti-money-laundering regulations, carried out by Bridge.

Article 2 — Subject matter of the contract

The purpose of these Terms is to define the conditions under which the User may access and use the Moywa Services, as well as the respective rights and obligations of the parties.

Article 3 — Eligibility conditions

Use of the Moywa Services is reserved for persons who cumulatively meet the following conditions:

• Be at least 18 years of age (natural persons) or be a duly incorporated legal entity (businesses);
• Reside permanently in a Member State of the European Economic Area (EEA), excluding Switzerland;
• Hold a valid identity document accepted by Bridge's KYC/KYB procedures;
• Not appear on any international sanctions list (OFAC, EU, UN, etc.);
• Not carry out any activity appearing on Bridge's list of prohibited activities.

Bridge is the sole judge of whether to accept or refuse a KYC/KYB file, and may suspend or close an account at any time as part of its compliance obligations (see article 13).

Article 4 — Description of the Services

4.1 — Receiving funds (Receive)

The User may receive bank transfers in EUR (SEPA area) into a dedicated virtual account provided by Bridge. Each deposit is automatically converted into EURC and credited to the User's balance on the Solana blockchain. Business PRO Users may also hold virtual accounts in USD and GBP.

4.2 — Sending funds (Send)

The User may send funds from their Moywa balance to other Users or to eligible external beneficiaries. The amounts received by the recipient are calculated according to the exchange rate applied at execution.

4.3 — Conversion (Convert)

The User may convert between available stablecoins (EURC ↔ USDC). The rate applied is the market rate at execution.

4.4 — Custody by Bridge

The User's fiat funds and stablecoins are held exclusively by Bridge Building S.A. in its capacity as custody provider. Bridge holds the private keys of the blockchain wallets and the funds held in the SEPA, ACH and GBP virtual accounts. The User does not hold the private keys: this custodial architecture removes the risks of private key loss usually associated with non-custodial wallets.

Moywa has no direct control over the wallets or over Users' funds. All operations are executed by Bridge on the basis of the instructions transmitted by Moywa through the Bridge API.

Article 5 — Pricing

The fees applicable to the Services are set out in the fee schedule accessible from the Plan page of the application. That schedule forms an integral part of these Terms. Any amendment is subject to two (2) months' prior notice in accordance with article 54 of the PSD2 directive.

Article 6 — Rights and obligations of the User

6.1 — Obligations of the User

• Provide accurate, complete and up-to-date information during KYC/KYB and throughout the contractual relationship;
• Keep their login credentials and authentication codes confidential (password, 2FA codes, recovery codes);
• Check the accuracy of the recipient's details before any transfer (IBAN, wallet address, email);
• Immediately report to Moywa any fraudulent use or attempted fraudulent use of their account;
• Not use the Services for unlawful or fraudulent purposes, or contrary to these Terms, to the Bridge user agreement, or to applicable regulations.

6.2 — Verification of unique identifiers (PSD2 article 88)

In accordance with article 88 of the PSD2 directive, the unique identifier provided by the User (IBAN, BIC, wallet address) prevails over any other information communicated. If the User provides an incorrect unique identifier, the operation will be executed in accordance with that identifier and Moywa cannot be held liable for funds transferred to the wrong recipient.

Article 7 — Strong customer authentication (SCA / PSD2)

In accordance with Directive (EU) 2015/2366 (PSD2), Moywa implements strong customer authentication for: access to the account, initiation of a payment transaction, and any action presenting a risk of fraud.

Strong authentication relies on the combination of at least two independent elements from among: (a) knowledge (password), (b) possession (TOTP application), (c) an inherent characteristic (biometrics, where applicable).

Upon configuration, the User receives 10 single-use recovery codes which they undertake to keep in a safe place.

Article 8 — Execution times

Execution times are indicative and may vary depending on external factors (third-party banks, blockchain network congestion, Bridge compliance checks).

Article 9 — Payer's rights

9.1 — Right of withdrawal (14 days)

In accordance with article L222-7 of the French Consumer Code, the User has a period of fourteen (14) calendar days from acceptance of these Terms to terminate their account without giving reasons. This right does not apply to operations already executed at the User's express request.

9.2 — Contesting an unauthorised transaction (13 months)

In accordance with article L133-24 of the French Monetary and Financial Code (transposing article 71 of PSD2), the User has a period of 13 months from the debit date to contest an unauthorised or incorrectly executed transaction.

9.3 — Amendment of the Terms (2 months' notice)

Any substantial amendment to these Terms is subject to two (2) months' prior notice, in accordance with article 54 of PSD2.

Article 10 — Risks associated with the Service

The User acknowledges having been informed of the following risks:

• Exchange rate volatility — conversions between currencies and stablecoins are carried out at the market rate at execution, which may differ between the estimate displayed and the actual execution.
• Error in entering the recipient — a transfer to an incorrect IBAN, wallet address or email is generally irreversible. Verification is the User's responsibility (article 6.2).
• Bridge counterparty risk — Bridge Building S.A. provides custody of the funds and stablecoins. Although authorised and supervised by the CSSF in Luxembourg, that provider constitutes a third-party counterparty.
• Stablecoin issuer risk (Circle) — Circle Internet Financial Europe SAS, an issuer authorised as an EMI by the ACPR, guarantees the 1:1 backing of the EURC/USDC stablecoins. A residual risk of default cannot be entirely excluded.
• Blockchain network risk (Solana) — the Solana blockchain may experience congestion, slowdowns or technical interruptions.
• Risk of the account being blocked or closed by Bridge — Bridge may suspend or close an account or freeze funds in the event of suspected money laundering, fraud, breach of sanctions or failure to comply with the applicable Bridge terms. See article 13.
• Regulatory risk — changes in regulations (in particular MiCA, PSD3, ACPR rules) may lead to changes in the Service.

Article 11 — Complaints and mediation

11.1 — Complaint to Moywa

Any complaint may be sent by email to support@moywa.com. Moywa undertakes to acknowledge receipt within 48 business hours and to provide a written response within a maximum of 15 working days, in accordance with article 101 of PSD2 (extended to 35 days in exceptional circumstances).

11.2 — Mediator

Failing an amicable resolution, a User who is a consumer may refer the matter free of charge to the Mediator of the Autorité des Marchés Financiers (AMF) or to the French national consumer mediator.

11.3 — Supervisory authority

The User may also lodge a complaint with the Autorité de Contrôle Prudentiel et de Résolution (ACPR), 4 Place de Budapest, 75436 Paris Cedex 09, or with the Commission Nationale de l'Informatique et des Libertés (CNIL) for matters relating to data protection.

Article 12 — Protection of personal data

The processing of personal data is governed by the Privacy policy, accessible from the application and the moywa.com website. Requests relating to data may be addressed to the DPO at privacy@moywa.com.

Article 13 — Limitation of liability

13.1 — General grounds for exemption

Moywa cannot be held liable in the event of:

• Force majeure (article 1218 of the French Civil Code);
• Failure or interruption of a third-party service (Bridge, Circle, banking operators, blockchain network);
• Data entry error by the User (recipient's unique identifier, amount, currency);
• Fraudulent use of the account resulting from the User's negligence in safekeeping their credentials;
• Indirect consequences (loss of commercial opportunity, loss of profit, damage to reputation).

13.2 — Bridge's compliance decisions

Green Cloud and Blockchain SARL cannot be held liable for decisions taken by Bridge Building S.A. as part of its compliance obligations (KYC, AML, CFT, international sanctions) and of its user agreement, in particular:

• The suspension or closure (offboarding) of a User account;
• The blocking, freezing or confiscation of funds;
• The refusal to execute a payment transaction;
• The reporting of a suspicion to financial intelligence units or competent authorities;
• Any measure arising from the application of international sanctions (EU, UN, OFAC, etc.);
• Any other decision relating to regulatory compliance taken by Bridge in its capacity as a provider of regulated services.

In the event of disagreement over a compliance decision, the User must contact Bridge Building S.A. directly in accordance with the terms of their user agreement.

13.3 — Liability cap

Moywa's liability, where incurred, is limited to the amount of the transaction concerned or to 12 months of subscription fees collected from the User, whichever is the higher.

Article 14 — Termination

14.1 — Termination by the User

The User may terminate their account at any time, without notice or reason, from the application or by writing to support@moywa.com. Termination results in closure of the account within 30 days, after settlement of operations in progress and return of the balance.

14.2 — Termination by Moywa or Bridge

Moywa or Bridge may terminate or suspend an account with two (2) months' prior notice (article 55 PSD2), or immediately and without notice in the event of:

• Serious breach by the User of these Terms or of regulations;
• Suspicion of fraud, money laundering or terrorist financing;
• Listing of the User on a sanctions list;
• Request from a regulatory authority or a court decision;
• A compliance decision taken by Bridge (see article 13.2).

Article 15 — Governing law and jurisdiction

These Terms are governed by French law. Any dispute relating to their interpretation or performance will be submitted to the exclusive jurisdiction of the French courts, subject to the mandatory consumer protection rules allowing the consumer to bring proceedings before the courts of their place of residence.

The regulated services provided by Bridge Building S.A. are governed by their own user agreement, acceptance of which is required in order to benefit from the Moywa Services. In the event of a dispute relating to a regulated service provided by Bridge, the jurisdiction and governing law may be those designated by the Bridge user agreement.

Article 16 — Miscellaneous provisions

16.1 Entire agreement. These Terms, supplemented by the Privacy policy and the fee schedule, constitute the entire agreement between the parties.

16.2 Partial invalidity. If any provision of the Terms is held to be void or unenforceable, the remaining provisions remain in force.

16.3 No waiver. The fact that Moywa does not rely on a breach does not constitute a waiver of its rights.

16.4 Notices. Any notice is sent by email to the address provided by the User in their account.

16.5 Language. The Terms are drawn up in French. Any translation is provided for information purposes only; in case of discrepancy, the French version prevails.

16.6 Update v1.2. Version 1.2 updates the references to the regulated partner: the services previously provided by Bridge Building Sp. z o.o. (Poland) are now provided by Bridge Building S.A. (Luxembourg), authorised as a CASP under MiCA (No. N00000012) and as an electronic money institution (No. W00000024) by the CSSF.