Ebioro Wallet Terms of Service

Last Updated: June 1, 2026

These Terms of Service (the "Terms") govern your access to and use of the Ebioro Wallet (the "Wallet"), a self-hosted, non-custodial digital asset application provided by Ebioro UAB ("Ebioro", "we", "us" or "our").

These Terms apply only to the Ebioro Wallet and its related features. Other products offered by Ebioro (including merchant and business services) are subject to separate terms. Products offered by Ebioro under separate local authorisations are governed by their own terms.

By creating a Wallet or using the application, you agree to these Terms. If you do not agree, do not use the Wallet.

1. Who We Are

1.1. Ebioro UAB is a private limited liability company incorporated in the Republic of Lithuania, legal entity code 305994333, with its registered office at Laisvės pr. 60, Vilnius, Lithuania.

1.2. Ebioro provides the Wallet as a software application. Through the Wallet you hold and control your own digital assets directly on the Stellar network. Ebioro is not a party to, and does not intermediate, your on-network transactions.

2. Regulatory Status — Important Notice

2.1. Ebioro UAB is not authorised as a crypto-asset service provider ("CASP") under Regulation (EU) 2023/1114 on markets in crypto-assets ("MiCA"), and is not licensed, authorised or supervised by the Bank of Lithuania or any other EU financial supervisory authority in connection with the Wallet.

2.2. The Wallet is a self-hosted wallet: the cryptographic keys that control your digital assets are created and held by you, as described in Section 6. Ebioro does not provide custody and administration of crypto-assets on behalf of clients, does not operate a trading platform, does not exchange crypto-assets for funds or other crypto-assets, and does not execute, place, receive or transmit orders on your behalf within the meaning of MiCA.

2.3. We are not a bank, credit institution, payment institution, electronic money institution or investment firm. Digital assets held in your Wallet are not deposits. They are not covered by the Lithuanian deposit insurance scheme, by any EU deposit guarantee scheme, or by any investor compensation scheme.

2.4. Where a feature of the Wallet involves a regulated service — such as purchasing digital assets with money, or withdrawing to a bank account — that service is provided by a third-party provider authorised for that activity, under that provider's own terms, as described in Section 9.

2.5. If the regulatory treatment of the Wallet or of any feature changes, we may modify, restrict or discontinue features as required, or obtain the relevant authorisations. Section 15 applies.

3. Eligibility

3.1. To use the Wallet you must:

• (a) be at least 18 years old (or the higher age of legal majority in your country of residence);
• (b) have full legal capacity to enter into these Terms;
• (c) use the Wallet only for yourself, not on behalf of any third party;
• (d) maintain no more than one account.

3.2. You must not use the Wallet if you are:

• (a) located in, resident in, or a national of a jurisdiction subject to comprehensive United Nations or European Union sanctions;
• (b) listed on any applicable sanctions list, including the consolidated lists of the United Nations Security Council and the European Union;
• (c) located in, or a resident of, a jurisdiction where use of the Wallet would be unlawful or where we do not offer the Wallet. The list of unsupported jurisdictions is published in the Legal section of our website and may change.

3.3. We may use technical means (including IP screening and identity verification) to enforce eligibility, and we may suspend Service Features (Section 12) for users who fail these checks.

4. The Wallet — What It Is and What It Is Not

4.1. The Wallet enables you to:

• (a) create and control a Stellar network account whose keys you hold;
• (b) send and receive supported digital assets;
• (c) view balances and transaction history;
• (d) access optional third-party services (Sections 9–11).

4.2. Ebioro does not:

• (a) hold, store or control your digital assets;
• (b) hold, store or have access to keys capable of disposing of your digital assets (Section 6);
• (c) initiate, execute or reverse transactions on your behalf;
• (d) act as custodian, trustee, broker, exchange, money transmitter or financial intermediary.

4.3. All digital asset balances exist on the public Stellar network, not on Ebioro systems. If Ebioro discontinued the application entirely, your assets would remain on the network under your control, and you could continue to manage them with the keys you hold, including through the independent export tool described in Section 8.

5. Multi-Signature Architecture

5.1. Your Wallet is a Stellar account configured with multiple signing keys and raised operation thresholds, so that the account's original master key is disabled and authority is distributed across the keys described below. The account is configured (at the time of writing) as follows:

The account thresholds for payment and configuration operations are set to 20.

5.2. Consequences of this configuration:

• (a) Your device key alone authorises payments. Day-to-day transactions are signed entirely on your device.
• (b) Your optional backup key alone authorises payments. If you create it, you hold a fully independent means of moving your assets without any involvement of Ebioro (see Section 8).
• (c) The Ebioro recovery signer can authorise nothing alone. Its weight (10) is below every account threshold (20). It can only ever co-sign together with your recovery key.
• (d) Ebioro cannot move your funds, change your signers, or take control of your account, alone or together with the key management provider.

5.3. The exact key weights and thresholds are visible on the public Stellar network for your account at any time and can be independently verified by you or by any third party.

5.4. We may improve the signing architecture over time (for example, to strengthen recovery). Any such change will preserve the principles in Section 5.2: Ebioro alone will never be able to dispose of your assets.

6. Keys, Credentials and Your Responsibilities

6.1. Your private keys are generated on your device. In current versions of the application, your private keys and recovery phrases are never transmitted to or stored by Ebioro; locally stored keys are encrypted on your device and protected by your PIN and/or biometrics.

6.2. Earlier versions of the application offered a server-assisted backup that stored an encrypted copy of your wallet keys on Ebioro's systems. These copies are encrypted with credentials that only you hold; they are retained solely so that affected users can restore access and migrate to the current key architecture, and are retained only for as long as needed to support that migration. New accounts do not use this mechanism.

6.3. You are solely responsible for:

• (a) securing your device, PIN and biometric credentials;
• (b) maintaining your cloud backup (recovery phrase) and, if created, your written backup key;
• (c) verifying transaction details before signing — transactions on the Stellar network are irreversible;
• (d) using only supported assets and networks. Assets sent to wrong addresses or unsupported networks may be permanently lost.

6.4. If you lose your device and lose access to your recovery phrase (and have not created a backup key), your assets are permanently inaccessible. Ebioro cannot reconstruct your keys and cannot recover your account. No exceptions are technically possible.

7. Assisted Account Recovery

7.1. If you lose your device but still have access to your recovery phrase (via your cloud backup), you can restore access through a two-of-two assisted recovery:

• (a) you authenticate to our recovery service (e.g. one-time code to your registered email or phone);
• (b) you sign with your recovery key (weight 10), restored from your own cloud backup;
• (c) our recovery signer co-signs (weight 10), reaching the required threshold (20) to replace the lost device key with a new one.

7.2. The recovery process can only be initiated by you. The recovery signer:

• (a) never signs without your authenticated request and your recovery-key signature;
• (b) cannot initiate recovery, payments, or signer changes on its own;
• (c) follows the open SEP-30 (Stellar account recovery) protocol.

7.3. Assisted recovery is provided on a best-efforts basis. If you cannot complete authentication, or you have lost your recovery phrase, assisted recovery is not possible.

8. Portability — Exporting Your Assets Without Ebioro

8.1. You may move your assets out of the Ebioro Wallet at any time, for any reason, by sending them to any Stellar account or external wallet of your choosing.

8.2. In addition, Ebioro publishes a free, open-source, self-service migration tool (https://ebioro-uab.github.io/ebioro-wallet-migration) that allows you to transfer your balances to any standard Stellar wallet using only your backup key (Section 5), entirely in your browser, without the Ebioro app and without any Ebioro server being involved. Your credentials never leave your browser. The source code is publicly auditable.

8.3. The migration tool requires your backup key. We recommend creating your backup key when you set up your Wallet; you can also create it at any later time in the app. If you no longer have access to the app or your device, assisted recovery (Section 7) restores your access first, after which you can create a backup key.

8.4. The availability of this tool means your assets remain under your control and portable even if Ebioro's services are suspended, restricted, discontinued, or unavailable to you for any reason — including a restriction of Service Features under Section 12.

9. Buying Digital Assets and Withdrawing to Bank Accounts (Third-Party Ramps)

9.1. The Wallet may offer you the ability to purchase digital assets with money (card or bank transfer) or to sell digital assets and receive money in a bank account. These services are not provided by Ebioro. They are provided by third-party providers that are authorised for the relevant regulated activity in their respective jurisdictions (each a "Ramp Partner").

9.2. When you use a ramp feature:

• (a) you enter into a direct contractual relationship with the Ramp Partner, whose identity and terms are presented to you in the app before you confirm the transaction;
• (b) the Ramp Partner — not Ebioro — receives, holds and transmits your money, performs the exchange, and is responsible for executing the service;
• (c) Ebioro acts solely as a technical interface and does not at any point hold your money.

9.3. Ramp Partners apply their own verification, eligibility, country restrictions, limits and fees. Availability differs by country and may change. Ebioro does not guarantee the availability of any ramp service.

9.4. Ebioro may receive a commission or charge a service fee in connection with ramp transactions. All fees applicable to you are displayed before you confirm a transaction (Section 13).

10. Digital Assets and Stable-Value Tokens

10.1. The Wallet supports selected digital assets on the Stellar network. Balances presented as "digital dollars" (or similar) are tokens issued by third-party issuers — not by Ebioro — that aim to maintain a stable value against a reference currency. Under EU law such tokens may qualify as e-money tokens within the meaning of MiCA.

10.2. For any such token:

• (a) the issuer — not Ebioro — is responsible for the token, its stability, and its redemption;
• (b) any right of redemption at par value is a claim against the issuer, exercisable under the issuer's own terms;
• (c) the issuer's terms and white paper are available from the issuer. For the tokens currently offered through the Wallet:
• USDC (issued by Circle): https://www.circle.com/legal/usdc-terms
• Information about the Stellar network is published by the Stellar Development Foundation, whose own terms are at https://stellar.org/terms-of-service. The Stellar network itself is decentralised and is not operated by Ebioro or by any single party.

10.3. Digital assets are not legal tender and are not backed or guaranteed by Ebioro, by any government or by any central bank. Token values may fluctuate; a token designed to be stable may fail to maintain its value.

11. Third-Party Services Accessible Through the Wallet

11.1. The Wallet may provide access to optional services operated by third parties, including: airtime and gift card purchases; payments to online and physical merchants; and decentralised finance (DeFi) protocols.

11.2. For all third-party services: you contract with the third party; Ebioro does not own, operate, control or guarantee the service; and your use is subject to the third party's terms. Issues, including refunds, must be resolved with the relevant provider. Airtime and gift card sales are final once processed.

11.3. DeFi protocols are autonomous software not controlled by anyone, including Ebioro. Returns are not guaranteed, displayed yields are estimates, smart contracts may contain vulnerabilities, and you may lose some or all assets you commit to them. Use of DeFi features is entirely at your own risk.

11.4. When you pay an Ebioro merchant through the Wallet, the payment is a direct transfer from your account to the merchant's account on the Stellar network. The purchase itself (delivery, quality, disputes, refunds) is between you and the merchant.

12. Compliance, Verification and Service Restrictions

12.1. Ebioro maintains an anti-money-laundering and counter-terrorist-financing programme aligned with European Union law, United Nations sanctions and FATF guidance.

12.2. Certain features ("Service Features") — including assisted recovery, ramp access, and the relaying of transactions through Ebioro's infrastructure — require a registered account and may require identity verification at or above certain usage thresholds. We will tell you in the app when verification is required.

12.3. If you fail required verification, or where we are required to do so by law, we may restrict or terminate your access to Service Features. Because the Wallet is self-hosted:

• (a) a restriction of Service Features does not transfer your assets to Ebioro and does not block the Stellar network itself;
• (b) your keys keep working, and the export route described in Section 8 remains available to you.

12.4. We may decline to relay, sponsor or facilitate a specific transaction through our infrastructure where required by law or by our risk policies.

13. Fees and Network Reserves

13.1. Ebioro may charge fees for specific Service Features. Every fee that applies to you is shown in the app before you confirm the relevant transaction. Third parties (Ramp Partners, merchants, issuers, mobile operators) may charge their own fees under their own terms.

13.2. The Stellar network requires every account to maintain a minimum balance of XLM (the network's native asset) as a reserve, and charges small network fees per transaction. Ebioro currently sponsors these reserves and may cover network fees on your behalf. Sponsored reserves:

• (a) exist solely to keep your account functional on the Stellar network;
• (b) are locked by the network protocol and are not part of your spendable balance;
• (c) are not a deposit, loan or client asset, and may be reclaimed by Ebioro only as permitted by the network protocol (for example, where sponsorship ends).

13.3. We may change our fee schedule prospectively. Continued use of a Service Feature after a fee change constitutes acceptance.

14. Risks

You understand and accept, among others, the following risks:

• (a) Total loss of access: losing all of your keys and recovery credentials means permanent loss of your assets (Section 6.4);
• (b) Irreversibility: network transactions cannot be cancelled, reversed or corrected;
• (c) Volatility: digital asset values can change suddenly and significantly; you may lose the entire value;
• (d) Issuer risk: a stable-value token may fail to maintain its peg or its issuer may fail (Section 10);
• (e) Technology risk: bugs, vulnerabilities, cryptographic advances, network congestion, forks or outages may result in delayed, failed or incorrect transactions or loss of assets;
• (f) Third-party risk: failures of Ramp Partners, key-management providers, cloud storage providers, merchants or DeFi protocols;
• (g) Cybersecurity risk: attacks on your device, your cloud account or third-party systems;
• (h) Regulatory risk: legal or regulatory developments may affect the availability, features or treatment of the Wallet (Section 15).

15. Regulatory Change

The regulatory framework for digital assets, including MiCA, continues to develop. We may modify, restrict, suspend or discontinue any part of the Wallet, change providers, or introduce new requirements (including verification requirements) to the extent we consider necessary to comply with applicable law or supervisory expectations, or in connection with obtaining an authorisation. Where reasonably possible we will give you advance notice. Sections 4.3 and 8 (your control and export rights) are not affected by any such change.

16. Suspension and Termination

16.1. You may stop using the Wallet at any time. Your assets remain yours and remain on the network; Section 8 applies.

16.2. We may suspend or terminate your access to Service Features if you breach these Terms, use the Wallet unlawfully, fail required compliance checks, or where required by law. Section 12.3 applies: termination of Service Features does not give Ebioro control of your assets and does not remove your export route under Section 8.

16.3. We may discontinue the Wallet application as a whole with reasonable advance notice. In that case we will keep the export route under Section 8 available for at least 12 months after discontinuation.

17. Disclaimers, Liability and Indemnity

17.1. The Wallet is provided "as is" and "as available", without warranties of any kind, express or implied, including merchantability, fitness for a particular purpose and non-infringement. We do not warrant uninterrupted or error-free operation of the application, the Stellar network or any third-party service.

17.2. To the maximum extent permitted by law, Ebioro and its directors, employees and agents shall not be liable for: loss of assets due to lost keys, devices or credentials; failures, acts or omissions of third parties (including Ramp Partners, issuers, key-management and cloud providers, merchants, mobile operators and DeFi protocols); irreversible user error; network-level events; or any indirect, incidental, special, consequential or punitive damages, loss of profits, or loss of data.

17.3. To the maximum extent permitted by law, Ebioro's aggregate liability under these Terms shall not exceed the greater of (i) the total fees you paid to Ebioro in the twelve months preceding the event giving rise to liability, and (ii) EUR 100. Nothing in these Terms excludes liability that cannot be excluded under applicable law, including mandatory consumer protections of your country of residence.

17.4. You will indemnify and hold Ebioro harmless from claims, damages and expenses (including reasonable legal fees) arising out of your breach of these Terms, your violation of law, or your use of third-party services.

18. Intellectual Property

The Wallet application, its design, trademarks and content are owned by Ebioro or its licensors. We grant you a limited, non-exclusive, non-transferable, revocable licence to use the application for personal use in accordance with these Terms. Open-source components, including the migration tool (Section 8), are licensed under their respective open-source licences.

19. Privacy

Ebioro processes personal data in accordance with its Privacy Policy and the General Data Protection Regulation (GDPR). Note that blockchain data (addresses, balances, transactions) is public and immutable by design; Ebioro cannot modify or delete data recorded on the Stellar network.

20. Complaints

20.1. If you have a complaint, contact us at [email protected] with a description of the issue. We will acknowledge your complaint within 5 business days and respond substantively within 15 business days of receipt.

20.2. If you are a consumer residing in the EEA and you are not satisfied with our response, you may refer the dispute to the State Consumer Rights Protection Authority of the Republic of Lithuania (Vilniaus g. 25, 01402 Vilnius, www.vvtat.lt) or use the EU online dispute resolution platform. You may also bring proceedings before the competent courts (Section 21).

21. Governing Law and Jurisdiction

21.1. These Terms are governed by the laws of the Republic of Lithuania.

21.2. Disputes shall be resolved by the competent courts of Vilnius, Lithuania, provided that if you are a consumer you retain the benefit of any mandatory jurisdiction and applicable-law protections of your country of habitual residence.

22. Changes to These Terms

We may amend these Terms. We will notify you of material changes through the app or by email at least [30] days before they take effect, except where immediate effect is required by law. If you do not agree to the amended Terms, stop using the Wallet; Section 8 (export) remains available to you.

23. Miscellaneous

23.1. If any provision of these Terms is held invalid, the remainder remains in effect. 23.2. Our failure to enforce a provision is not a waiver. 23.3. You may not assign these Terms; we may assign them in connection with a corporate reorganisation, subject to your rights under Section 8. 23.4. These Terms are the entire agreement between you and Ebioro regarding the Wallet. 23.5. These Terms are available in English and Spanish; in case of conflict, the English version prevails.

24. Contact

Ebioro UAB Legal entity code: 305994333 Laisvės pr. 60, Vilnius, Lithuania Email: [email protected]