Terms of Use

1. Introduction

Stealf is a privacy-first neobank on Solana operated by Stealf Corporation, a company incorporated in the State of Delaware, USA ("Stealf", "we", "our", or "us"). These Terms of Use ("Terms") are a legally binding agreement between you and us.

By accessing or using Stealf in any way, you agree to these Terms. If you don't agree, don't use the service.

2. Regulatory Status — Stealf Is Not a Bank

Stealf is a technology company that provides software. Stealf is not a bank, a licensed money transmitter, or a regulated financial institution, and does not itself hold or move customer fiat funds.

Regulated activities — such as crypto-to-fiat conversion and payouts to your bank — are performed by licensed third-party partners (for example, Dakota) on their own infrastructure and under their own terms. Your crypto assets remain self-custodied until you choose to send them to a partner to execute a transaction you initiate. Balances in Stealf are not bank deposits and are not covered by any deposit-insurance scheme.

3. Eligibility

By using Stealf, you represent that:

• You are at least 18 years old and have legal capacity to enter into this agreement.
• You are not located in, or a resident or citizen of, any jurisdiction subject to comprehensive sanctions (including Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk, and Luhansk regions).
• You are not on any sanctions list maintained by the United States, the European Union, the United Kingdom, or the United Nations.
• Your use of Stealf does not violate any law or regulation applicable to you.

Some features (such as cash-out) require successful identity verification. We may decline, restrict, suspend, or terminate your access at our discretion, including for compliance, fraud prevention, security, or regulatory reasons.

4. What Stealf Provides

Stealf provides a mobile interface to:

• A self-custodied Solana wallet with a public balance and a private, encrypted balance, secured through Turnkey key-management infrastructure and, for private features, an on-device key.
• Token swaps routed through Jupiter.
• Yield, via the Reflect protocol (a yield-bearing USDC-based asset, STLF).
• Tokenized stocks (xStocks) issued by a third-party issuer.
• Gift cards purchased with stablecoins and fulfilled by Bitrefill.
• Crypto-to-fiat cash-out (off-ramp) executed by a licensed payments partner (Dakota), which requires identity verification.
• Private transfers that rely on Umbra's confidential protocol.

Features may be added, changed, or removed over time. Some features are rolled out progressively and may not be available in all regions.

5. Self-Custody and Your Responsibility for Keys

Stealf is non-custodial. You control your wallet and your assets at all times.

For your on-device key: the private key used for private features is generated on your device and stored locally in the secure enclave (iOS Keychain / Android Keystore). We do not store, back up, or have any access to this key. If you lose your device and your recovery phrase (the BIP39 mnemonic), your funds are permanently lost. We cannot recover them.

For your Turnkey-secured wallet: access is authenticated via OAuth or email through Turnkey. Stealf never sees the private key. If you lose access to your login and recovery methods, you may lose access to this wallet.

You are solely responsible for:

• Keeping your device secure.
• Keeping your recovery phrase, login, and any other credentials safe and confidential.
• Verifying transaction details before signing.
• Understanding the risks of any operation you initiate.

6. Identity Verification (KYC / AML)

Features that convert crypto to fiat require you to verify your identity, as required by anti-money-laundering law. Verification is performed by our payments partner and its identity-verification providers. You agree to provide accurate, current, and complete information, and you authorize us and our partners to verify it and screen it against sanctions and watchlists. We may refuse or revoke access to regulated features if verification fails or if we detect fraud, sanctions, or compliance risk.

7. Cash-Out (Off-Ramp)

The cash-out feature lets you convert on-chain stablecoins to fiat paid to your bank account. This conversion and payout are executed by a licensed third-party partner (Dakota), not by Stealf. You are responsible for providing correct bank details; Stealf and its partner are not liable for funds sent to an incorrect account you provided. Fees, limits, supported currencies, payout times, and availability depend on the partner and your jurisdiction, and amounts received may differ from a displayed estimate due to network fees and exchange rates. Once you send crypto to the deposit address for a cash-out, the transaction may be irreversible.

8. Gift Cards

Gift cards are digital vouchers fulfilled by Bitrefill and issued by the respective merchants. Availability, value, and terms depend on the merchant and your country. Gift-card purchases are final and non-refundable once delivered. Stealf does not control, and is not responsible for, the acceptance, expiry, or terms of any gift card, which are governed by the issuing merchant's and Bitrefill's terms.

9. Yield

Stealf Yield lets you hold a yield-bearing USDC-based asset (STLF) through the Reflect protocol. Stealf does not custody or pool these funds with other users' funds. By using it you understand and accept that:

• Yields are variable, depend on the underlying protocol, and may change or fall to zero at any time.
• The underlying protocol, or any integrated protocol, may experience smart-contract failures, exploits, depegs, or insolvency.
• Solana network conditions may affect the timing or outcome of any deposit or withdrawal.
• Past performance does not predict future results.
• Stealf does not guarantee the return of principal or any specific yield.
• Stealf is not a lender, broker, asset manager, or financial advisor.

10. Token Swaps and Tokenized Stocks

Token swaps are routed through Jupiter and other decentralized exchanges and aggregators. Stealf does not set prices, control routing, or guarantee execution. Prices may move between quote and execution due to network conditions, slippage, or liquidity. All swaps are final once confirmed on-chain.

Tokenized stocks (xStocks) are digital assets issued by a third-party issuer that track the price of underlying securities. They are not shares, confer no shareholder rights, and are not offered, endorsed, or guaranteed by the underlying companies. Availability may be restricted in your jurisdiction.

11. Private Transfers

Private, confidential transfers rely on Umbra's protocol. Availability and behavior of these features depend on the readiness of the underlying protocol, and additional or specific terms may apply when a feature is activated.

12. Acceptable Use

You agree not to:

• Violate any applicable law, regulation, or sanction.
• Use Stealf to facilitate money laundering, terrorist financing, fraud, sanctions evasion, or any illegal activity.
• Reverse engineer, scrape, decompile, or attempt to extract data from our systems.
• Interfere with or disrupt the service (including denial-of-service attempts, exploitation of rate limits, or abuse of webhooks).
• Create automated, fake, or unauthorized accounts.
• Use the service in a way that could harm Stealf, other users, or third parties.

Violations may result in immediate suspension or termination and may be reported to relevant authorities.

13. Third-Party Services

Stealf integrates with third parties whose services are governed by their own terms, including Turnkey (wallet infrastructure and authentication), Dakota (cash-out and identity verification), Bitrefill (gift cards), Reflect (yield), Umbra (private transfers), Jupiter (swap routing), xStocks / Backed (tokenized stocks), and Helius (Solana infrastructure). We may add, remove, or replace third-party providers at any time. We are not liable for the acts, omissions, outages, fees, policies, or data-handling practices of any third-party provider or any on-chain protocol.

14. Taxes

You are solely responsible for determining, reporting, and paying any taxes applicable to your use of Stealf, including taxes on yield, swaps, cash-outs, and any other transactions. Stealf does not provide tax advice and does not file tax forms on your behalf.

15. Disclaimers

Stealf is provided "as is" and "as available" without warranties of any kind, express or implied. We do not warrant:

• Continuous, uninterrupted, or error-free access.
• Profit, performance, or any specific outcome from any wallet, yield, swap, or other activity.
• The continued availability of any feature, integration, or third-party partner.
• The security, solvency, or performance of any third-party protocol or service.
• That the app is free of bugs, vulnerabilities, or unexpected behavior.

Some jurisdictions do not allow the disclaimer of implied warranties; in those cases, some of the above may not apply to you.

16. Limitation of Liability

To the maximum extent permitted by law, Stealf will not be liable for:

• Indirect, incidental, special, consequential, or punitive damages.
• Loss of data, assets, profits, yield, or business opportunity.
• Service outages, user errors, lost keys, or losses caused by third-party providers or on-chain protocols.
• Any financial loss arising out of or related to your use of Stealf, including losses from market movements, depegs, exploits, protocol failures, or smart-contract bugs.

To the extent permitted by law, our aggregate liability to you for any claim arising out of or related to these Terms or the service is capped at fifty US dollars (US$50).

17. Consumer Rights

Nothing in these Terms excludes, restricts, or limits any right or remedy you have under mandatory laws that apply to you as a consumer and that cannot be waived by agreement — including mandatory consumer-protection rights in the European Union and your country of residence. Where such laws apply, the disclaimers, liability cap, arbitration, and governing-law provisions below apply only to the extent permitted by those laws.

18. Governing Law and Dispute Resolution

These Terms and any dispute arising from them or from your use of Stealf are governed by the laws of the State of Delaware, without regard to its conflict-of-laws rules, and by applicable US federal law, except where mandatory local law applicable to you as a consumer provides otherwise.

Where permitted by the law that applies to you, any dispute, claim, or controversy shall be resolved by binding individual arbitration administered in Wilmington, Delaware, under the then-current rules of the American Arbitration Association, and you waive class-action and jury-trial rights. This does not apply where such waiver is prohibited by mandatory law applicable to you.

You have 30 days from accepting these Terms to opt out of arbitration by writing to louis@stealf.xyz.

19. Termination

We may suspend, restrict, or terminate your access at our discretion, including for breach of these Terms or for compliance, fraud, security, or risk reasons. You may stop using the service at any time. The sections on self-custody, disclaimers, limitation of liability, taxes, consumer rights, and governing law survive termination.

20. Changes

We may modify these Terms at any time. We will post the new version and update the "Last Updated" date. For material changes, we will notify you in-app or by email. Continued use of Stealf after changes take effect means you accept the updated Terms.

21. Contact