TERMS & CONDITIONS
Effective Date: 21 October 2025
These Terms & Conditions ("T&C") constitute a legally binding agreement between you ("you" or "User") and Simple Europe UAB, a legal entity incorporated in Lithuania under company number 305959834, with its registered office at Kauno str. 32B-48, LT-03202, Vilnius, Lithuania, together with its affiliated companies (collectively, "Simple", "we", "us", or "our").
These T&C govern your access to and use of all services offered through the Simple website (the "Website") and/or its mobile application (the "App"), collectively referred to as the "Platform".
IMPORTANT NOTICE: TWO DISTINCT SERVICES
Please read these T&C carefully. They are structured into three main sections:
- General Terms — Provisions applicable to ALL services you use on the Platform.
- Part A — Custodial Wallet Services: Terms that apply specifically when you use our Custodial Wallet, exchange services, and related features where Simple holds and manages assets on your behalf.
- Part B — Self-Custodial Wallet Services: Terms that apply specifically when you use our Self-Custodial Wallet, where you, and you alone, control your cryptographic keys and digital assets.
By creating an account, accessing, or using any of our Services, you acknowledge that you have read, understood, and agree to be bound by the General Terms and the specific terms of Part A and/or Part B, depending on the services you use. If you do not agree with these T&C, you may not access or use the Platform or any Services thereupon.
Your use of certain services may also be subject to the terms and conditions of third-party providers, as detailed within this document. Simple acts as a technology platform to provide you with access to these third-party services, but is not responsible for their provision.
We reserve the right to amend these T&C at our sole discretion. We will notify you of any significant changes. Your continued use of the Services after the effective date of any amendments constitutes your acceptance of the revised T&C.
SECTION 1: GENERAL TERMS
The terms in this Section apply to your use of all Simple Services, both Custodial and Self-Custodial.
1.1. ELIGIBILITY AND ACCEPTANCE
Simple offers its Services only for the users, who reached the legal age in its domicile country. By establishing business relations with us, you hereby affirm your full legal capacity and free will to use Simple Services. You also consent to all the risks and responsibilities (including, but not limited to the risk of monetary loss) that are relevant to you while using the Services. You must be at least 18 years old or the age of legal majority in your jurisdiction (whichever is higher).
1.2. DEFINITIONS
For the purposes of this document, the terms below have the following meanings, unless specified otherwise in Part A or Part B:
“Account” means a personal account aimed at the usage of Simple’s Services, opened by you either at the Website or via the mobile app.
“Applicable Legislation” means the valid legislation of Lithuania.
“App” means the Simple crypto wallet mobile application for iOS and Android devices.
“Fiat Currency” means government-issued currency, that is designated as legal tender in its country of issuance through government decree, regulation or law.
“Funds” means Virtual Currency or Fiat Currency units.
“Platform” means an environment, that consists of a Website, mobile app and/or products from any other third party that allows Simple to render its Services to you.
“Services” refers to all features and functionalities offered by Simple via the Platform, including both Custodial and Self-Custodial Wallet services.
“Third-Party Service Provider” means an independent entity, not affiliated with Simple, that provides certain functionalities accessible through the Platform.
“Transaction” means any transfer of Funds.
“Virtual Currency” means digital assets with a certain value, based on blockchain and/or cryptography technologies that are issued and managed in a decentralized form.
1.3. THIRD-PARTY SERVICES AND CONTENT
1.3.1. You acknowledge that the Platform integrates and provides you with access to services, content, and products offered by independent third parties (“Third-Party Services”). These may include, but are not limited to, payment card issuance and program management, fiat-to-crypto exchange (on-ramp/off-ramp), crypto-to-crypto swap services, and Banking-as-a-Service (BaaS) features.
1.3.2. You understand and agree that in respect of these Third-Party Services, Simple acts solely as a technology platform or aggregator. Our role is to facilitate your access to these services through a convenient interface within our App. We do not provide, own, control, or operate these Third-Party Services ourselves.
1.3.3. Your use of any Third-Party Service establishes a direct contractual relationship between you and the respective Third-Party Service Provider. You will be required to accept their separate legal agreements, terms and conditions, privacy policies, and fee schedules before using their service.
1.3.4. The inclusion of a Third-Party Service on our Platform does not constitute an endorsement or recommendation by Simple. Simple is not a party to your agreement with any provider and shall not be responsible or liable in any manner for the performance, availability, security, accuracy, or any other aspect of such Third-Party Services, nor for any losses, damages, or claims arising from your use of them. Any questions, complaints, or claims related to a Third-Party Service must be directed to the respective provider.
1.4. INTELLECTUAL PROPERTY RIGHTS
1.4.1. The software, applications, text, images, graphics, data, prices, trades, charts, graphs, video and audio materials (hereinafter collectively referred to as the “Content”), used on the Website and/or mobile app shall at all times belong to Simple.
1.4.2. All Content is the sole property of Simple and its respective owners and shall be protected by copyright, patent, trademark, Intellectual Property rights and any other protection measures, as may be stipulated in the Applicable Legislation unless otherwise specified hereby.
1.4.3. You are not allowed to copy, reproduce, modify, republish, upload, post, transmit, scrape, collect and/or distribute in any other form or by any means, irrespective of its nature, any part of the Content, unless otherwise is agreed separately by Simple. The use of any Content for any other purpose, except for the usage of Services, is strictly prohibited; any such unauthorized use may violate copyright, patent, trademark, Intellectual Property rights and any other protection measures, as may be stipulated in the Applicable Legislation, that could result in criminal or civil penalties for you.
1.4.4. In case you become aware of any breach of our Intellectual Property rights from any third party, please, immediately notify us via Customer Support with all the data in your possession.
1.4.5. Trademarks, service marks, logos, interface elements, data, and other content originating from Third-Party Service Providers and displayed within the App in connection with their respective services remain the exclusive property of those third parties ("Third-Party Content"). Your license under this Section does not extend to Third-Party Content except as implicitly necessary to use the integrated Third-Party Services via the App. The inclusion of Third-Party Content within the Services does not constitute an endorsement by Simple or grant Simple ownership thereof.
1.5. DISCLAIMERS OF WARRANTIES
1.5.1. THE SERVICES ARE PROVIDED ON AN "AS-IS", "AS AVAILABLE", AND "WITH ALL FAULTS" BASIS WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED.
1.5.2. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, SIMPLE, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SUB-CONTRACTORS, AND THIRD-PARTY SERVICE PROVIDERS (COLLECTIVELY, THE "SIMPLE PARTIES") DISCLAIM ALL WARRANTIES EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.
1.5.3. SIMPLE DOES NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED, ERROR-FREE, SECURE, OR FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. SIMPLE DOES NOT WARRANT THE ACCURACY, COMPLETENESS, OR RELIABILITY OF ANY INFORMATION OR CONTENT PROVIDED THROUGH THE SERVICES (INCLUDING CONTENT FROM THIRD-PARTIES). SIMPLE ASSUMES NO RESPONSIBILITY WITH RESPECT TO, OR IN CONNECTION WITH, THE INTRODUCTION OF CHANGES, UPDATES, OR NEW FEATURES TO THE SERVICES OR FROM ANY MALFUNCTIONS, GLITCHES, OR FAILURES THAT MAY RESULT THEREFROM.
1.5.4. SIMPLE DOES NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR ANY PRODUCT OR SERVICE ADVERTISED OR OFFERED BY A THIRD-PARTY SERVICE PROVIDER ACCESSED THROUGH OR LINKED FROM THE SERVICES.
1.5.5. YOU AGREE AND ACKNOWLEDGE THAT YOUR USE OF THE SERVICES IS ENTIRELY, OR AT THE MAXIMUM PERMITTED BY APPLICABLE LAW, AT YOUR OWN RISK. YOU HEREBY ACKNOWLEDGE AND AGREE TO BEAR ALL RESPONSIBILITY, RISKS, DAMAGES, AND LOSS THAT MAY RESULT FROM USING THE SERVICES, INCLUDING INTERACTING WITH THIRD-PARTY SERVICE PROVIDERS. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING DISCLAIMERS, SIMPLE MAKES NO REPRESENTATIONS OR WARRANTIES WHATSOEVER REGARDING THE AVAILABILITY, ACCURACY, RELIABILITY, SECURITY, OR ERROR-FREE OPERATION OF THE CAMERA-BASED FACE CHECK RECOVERY FEATURE. THIS FEATURE IS PROVIDED "AS IS," "WITH ALL FAULTS," AND YOUR USE THEREOF IS ENTIRELY AT YOUR SOLE RISK.
1.6. LIMITATION OF LIABILITY
1.6.1. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL THE SIMPLE PARTIES (AS DEFINED IN SECTION B.11.2), ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR THIRD-PARTY SERVICE PROVIDERS BE LIABLE TO YOU FOR ANY DIRECT, INDIRECT, SPECIAL, PUNITIVE, EXEMPLARY, STATUTORY, INCIDENTAL OR CONSEQUENTIAL DAMAGE, OR ANY SIMILAR DAMAGE OR LOSS, COSTS, EXPENSES, AND PAYMENTS, EITHER IN TORT (INCLUDING NEGLIGENCE), CONTRACT, STRICT LIABILITY, OR IN ANY OTHER FORM OR THEORY OF LIABILITY, ARISING FROM, OR IN CONNECTION WITH:
A) YOUR ACCESS TO OR USE OF, OR INABILITY TO ACCESS OR USE, THE SERVICES;
B) ANY LOSS OF ACCESS TO YOUR SELF-CUSTODIAL WALLET DUE TO LOST OR COMPROMISED DEVICE ACCESS, FORGOTTEN CREDENTIALS, FAILURE TO SECURE BACKUPS, OR FAILURE OF RECOVERY MECHANISMS ATTRIBUTABLE TO YOUR ACTIONS OR INACTIONS;
C) ANY CONDUCT OR CONTENT OF ANY THIRD PARTY ON OR THROUGH THE SERVICES, INCLUDING THIRD-PARTY SERVICE PROVIDERS;
D) UNAUTHORIZED ACCESS, USE, OR ALTERATION OF YOUR ACCOUNT OR DATA, UNLESS CAUSED SOLELY BY SIMPLE'S GROSS NEGLIGENCE;
E) FAILURES, DELAYS, OR INTERRUPTIONS OF THE SERVICES, BLOCKCHAIN NETWORKS, OR THIRD-PARTY SYSTEMS;
F) BUGS, VIRUSES, TROJAN HORSES, OR SIMILAR MALWARE TRANSMITTED TO OR THROUGH THE SERVICES (UNLESS DUE TO SIMPLE'S FAILURE TO MAINTAIN REASONABLE SECURITY);
G) USER ERRORS, SUCH AS INCORRECT TRANSACTION DETAILS (WRONG ADDRESS, AMOUNT) OR MISTAKES IN USING WALLET FEATURES;
H) LOSSES ARISING FROM MARKET VOLATILITY OR THE INHERENT RISKS OF VIRTUAL CURRENCIES OR STAKING/DEFI PROTOCOLS;
I) ANY ACTION TAKEN (OR NOT TAKEN) BASED ON INFORMATION PROVIDED VIA THE SERVICES;
J) ISSUES ARISING AFTER YOU HAVE EXPORTED YOUR PRIVATE KEYS.
1.6.2. NOTWITHSTANDING ANYTHING TO THE CONTRARY HEREIN, TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE TOTAL AGGREGATE LIABILITY OF SIMPLE AND ITS AFFILIATES FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THESE T&C OR THE SERVICES, WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE), STRICT LIABILITY, OR OTHERWISE, SHALL NOT EXCEED THE GREATER OF (A) THE TOTAL FEES PAID BY YOU TO SIMPLE (EXCLUDING NETWORK FEES AND THIRD-PARTY FEES) DURING THE SIX MONTH PERIOD IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED EUROS (EUR €100.00).
1.6.3. THIS LIMITATION OF LIABILITY SECTION APPLIES REGARDLESS OF THE LEGAL THEORY UPON WHICH THE CLAIM IS BASED, EVEN IF SIMPLE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
1.7. TAX RESPONSIBILITY
1.7.1. You are solely responsible for determining whether any taxes apply to the transactions you conduct using the Services or through integrated Third-Party Services.
1.7.2. It is your sole responsibility to report and pay any and all applicable taxes arising from your Virtual Currency activities to the appropriate tax authorities in your jurisdiction(s).
1.7.3. Simple does not provide tax advice and is not your tax agent. Simple will not withhold taxes on your behalf or report your transaction information to tax authorities unless explicitly required to do so by Applicable Law.
1.8. GOVERNING LAW AND DISPUTE RESOLUTION
1.8.1. These T&C and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of Lithuania, without regard to its conflict of law provisions.
1.8.2. You and Simple agree to attempt to resolve any dispute arising out of or relating to these T&C or the Services amicably through informal negotiation first. Please contact Simple Customer Support at [email protected] to initiate this process.
1.8.3. If the dispute cannot be resolved through the informal negotiation process described in Section 1.5.2 within thirty (30) calendar days from the date such process was initiated, any dispute, controversy, or claim arising out of or relating to these T&C, or the breach, termination, or invalidity thereof, shall be finally and exclusively settled by binding arbitration. The arbitration shall be seated in Vilnius, Republic of Lithuania. The arbitration shall be conducted by a sole arbitrator appointed in accordance with the Arbitration Rules of the Vilnius Court of Commercial Arbitration (VCCA), which Rules are deemed to be incorporated by reference into this clause. The language to be used in the arbitral proceedings shall be English. The arbitral award shall be final and binding on the parties. Judgment upon the award rendered by the arbitrator may be entered by any court having jurisdiction thereof or application may be made to such court for judicial acceptance of the award and an order of enforcement, as the case may be. The costs of the arbitration, including the arbitrator’s fees, administrative fees of the arbitral institution, and the reasonable attorneys' fees and expenses incurred by the prevailing party in connection with the arbitration, shall be borne by the non-prevailing party (losing party), unless the arbitrator determines otherwise based on the circumstances of the case. The arbitrator shall have the authority to determine the allocation of costs in the final award.
1.9. MISCELLANEOUS
1.9.1. These T&C, including our Privacy Policy and the AML/KYC Policy, any and all notices, notifications, policies, warnings and disclaimers constitute the entire agreement between you and Simple.
1.9.2. In case of any circumstances of insuperable force (i.e. events of extraordinary or insuperable nature) (hereinafter referred to as the “Force Majeure”) that have occurred and remain in effect beyond control of any Party and that an affected Party could neither foresee nor prevent for objective reasons, if the Force Majeure prevents an affected Party from proper execution of its obligations hereunder, the term for execution of such obligations hereunder shall be extended for the period of Force Majeure. Force Majeure shall include, but is not limited to, wars and other military operations, earthquakes, floods, and other natural disasters, pandemics, adoption of laws and regulations by state and local authorities, failure of power supply or communication system or other similar circumstances that prevent the Parties from the proper execution of their obligations hereunder.
1.9.3. Simple reserves the right, at its sole discretion, to assign, novate, or otherwise transfer all or part of its rights and obligations under this Agreement to any affiliate or third party at any time without further notice to you. This may occur in connection with a merger, acquisition, corporate reorganization, sale of all or substantially all of our assets, or for any other business or operational reason. By accepting these T&C, you provide your prior and express consent to any such assignment, novation, or transfer. You agree that upon such an event, the assignee or new legal entity shall be deemed to be substituted for Simple as a party to these T&C with respect to the rights and obligations so transferred. Consequently, Simple shall be fully and irrevocably released from all past, present, and future obligations and liabilities under this Agreement that directly relate to the assigned rights and services.
1.9.4. Simple reserves the right to modify or amend these T&C at any time in its sole discretion. We will provide notice of significant changes, which may include posting the revised T&C on our website, providing notice through the App, or sending an email to the address associated with your Account (if provided). The "Last Updated" date at the top of these T&C indicates the latest revision. Your continued use of the Services after the effective date of any amendments constitutes your acceptance of the revised T&C. You are responsible for reviewing these T&C periodically for updates.
1.9.5. These T&C, together with the Privacy Policy and any other documents expressly incorporated by reference, constitute the entire agreement between you and Simple regarding your use of the Custodial Services and Self-Custodial Services and supersede all prior and contemporaneous understandings, agreements, representations, and warranties, both written and oral, regarding these specific Services.
1.9.6. If any provision of these T&C is held by a court of competent jurisdiction for the purposes of recognition and enforcement of the arbitral award to be invalid, illegal, or unenforceable, such provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable, or if modification is not possible, it shall be severed from these T&C. The validity, legality, and enforceability of the remaining provisions shall not be affected or impaired.
1.9.7. Simple's failure or delay in exercising any right, power, or privilege under these T&C shall not operate as a waiver thereof, nor shall any single or partial exercise preclude any other or further exercise thereof or the exercise of any other right, power, or privilege.
1.9.8. Simple shall not be liable for any delays, failure in performance, or interruption of service which result directly or indirectly from any cause or condition beyond its reasonable control, as described in the Force Majeure clause.
1.9.9. Simple operates as a provider of self-custodial wallet technology with respect to Self-Custodial Services. Simple is committed to cooperating with competent governmental authorities as required by applicable law. Upon receipt of a valid and legally binding request (such as a court order, subpoena, or equivalent legal process) from a competent authority with jurisdiction, Simple will provide information within its possession and control, subject to the limitations outlined in our Privacy Policy.
1.9.10. Section headings in these T&C are for convenience only and shall not govern the meaning or interpretation of any provision.
1.9.11. Any notices or other communications permitted or required hereunder will be in writing and given by Simple via email (if you have provided one), posting within the App, or posting on our website. Notices to Simple should be directed to Customer Support at [email protected].
1.9.12. These T&C shall remain in force until terminated either by you or by us. Simple is entitled to terminate these T&C at any time at its own discretion without explaining the reasons thereof. Specific termination rules for each service are detailed in Part A and Part B.
1.9.13. In the event the Website and/or mobile app is available in multiple languages, the English version of the T&C shall prevail.
1.9.14. Should you have any comments, questions, or complaints, do not hesitate to contact our Customer Support at [email protected].
SECTION 2: PART A — TERMS FOR CUSTODIAL SERVICES
The terms in this Part A apply ONLY when you use our Custodial Wallet and related services where Simple holds, controls, and secures cryptographic keys and assets on your behalf. These terms supplement the General Terms (Section 1) and do not apply to the Self-Custodial Wallet.
A.1. DEFINITIONS SPECIFIC TO CUSTODIAL SERVICES
“Business Relationship” means a business, professional or commercial relationship between Simple and you upon your registration of the Account for Custodial Services.
“Custodian Wallet” means Virtual Currency wallet, which securely stores private encryption keys and ensures the safety of the Funds therein, while you retain the ability to initiate and confirm the Funds Transactions.
“Deposit” means a Transaction, which involves the transfer of Funds to your Account from external wallets and/or your banking accounts.
“Exchange” means an exchange Transaction of a Virtual Currency to Fiat Currency or vice versa, or of Virtual Currency to another Virtual Currency conducted through the Account.
“Exchange Rate” means a correlation of value between assets in trading pairs, based on assets' demand, supply, value, utility, and other economic variables.
“Fee” means the commission or other costs, charged either by Simple or by any third party for the use of Services.
“Governmental Authority” means any governmental, inter-governmental body, agency, department or regulatory, self-regulatory or other authority or organization anywhere in the world with competent jurisdiction.
"Recurring Buy" means the feature that allows the purchase of a selected asset with Fiat currency or Virtual Currency at set intervals and the market price at the time of purchase.
“Withdrawal” means a Transaction, which involves the transfer of Funds from your Account to external wallets and/or your banking accounts.
A.2. THE SCOPE OF CUSTODIAL SERVICES
A.2.1. Simple provides you with the following scope of Services:
a) Exchange of one Virtual Currency unit into another Virtual Currency unit;
b) Exchange of the Virtual Currency unit into Fiat Currency unit and vice versa;
c) Virtual Currency Custodian Wallet services.
A.2.2. By providing a Service of exchanging Virtual Currency units for units of another Virtual Currency or Fiat Currency units and vice versa, Simple uses then-prevailing spot market exchange rate for the given trading pair. (e.g. BTC/EUR). You further acknowledge and agree that the prices displayed on our Platform are based upon market data, aggregated from various sources, and therefore may not match prices that you see elsewhere (including prices quoted on other exchanges, conversion services and other similar service providers).
A.2.3. By providing a Virtual Currency Custodian Wallet service, we hereby provide you with a digitally secured wallet for Virtual Currencies, aimed to exchange, store, and withdraw Virtual Currencies.
A.2.4. Considering the nature of Virtual Currency Custodian Wallet addresses, the possibility to refund, re-enter or change a wallet address is absent. You are obliged to understand this and agree to the terms prior to initiating any Transactions.
A.2.5. Simple only offers Services regarding Virtual Currencies that are supported by our Platform. It is your responsibility to check the Website and/or mobile app regularly to be aware of the full list of supported Virtual Currencies by us. You should not attempt to use your Account to deposit Virtual Currencies the Platform does not support, in any such case, Simple shall hold no responsibility regarding such a Transaction.
A.2.6. Please note that there may be some delays in Services due to circumstances, including, but not limited to technical difficulties, reasonable doubts about the nature or source of funds, deposited on the Platform, carrying out AML/KYC checks as set forth in the AML/KYC Policy, etc.
A.3. SIMPLE’S RIGHTS, OBLIGATIONS AND LIABILITIES (CUSTODIAL)
A.3.1. Simple undertakes to provide the Services with the utmost effort, due care and in accordance with these T&C and the Applicable Legislation.
A.3.2. Simple is entitled to suspend any of your Transaction and block Virtual Currency Transactions to another Custodian Wallet, or Fiat Currency Transaction in case of non-fulfilment and/or improper fulfilment of these T&C by you.
A.3.3. Simple’s responsibility shall be limited strictly to using reasonable technical efforts to ensure the receipt of the Virtual Currency units transferred, namely, to ensure the transfer of the necessary technical data to the Virtual Currency network.
A.3.4. To the extent permitted by law, Simple is not responsible for any damages, loss of profit, loss of revenue, loss of business, loss of opportunity, or indirect or consequential loss unless the loss suffered is caused by a breach of these T&C by us.
A.3.5. We are not responsible for any delays in the processing of payments due to the fault of any third party, e.g., operators of such transactions (banks, other financial institutions, payment acquirers, etc.).
A.3.6. In the case of fraud or other illegal activity, Simple undertakes to report all the necessary information, including names, addresses and all other requested information, to the relevant Governmental Authority, responsible for dealing with fraud and breaches of the law. You hereby recognize and confirm that your Account, or Transaction may be frozen at any time at the request of any competent Governmental Authority investigating fraud or any other illegal activity.
A.3.7. For non-performance or improper execution of our obligations under these T&C, Simple shall be liable as determined herein and in accordance with Applicable Legislation, unless otherwise provided below.
A.3.8. In no event shall Simple, its officers, directors, employees, agents, or third-party service providers be liable to you or any other person or entity for any direct, indirect, incidental, special, punitive, or consequential damages whatsoever, including any that may result from: the accuracy, completeness, or content of any websites linked to the Platform; the Services found at the Website and/or its mobile app; third-party conduct of any nature whatsoever; any interruption or cessation of Services; any viruses, worms, bugs, trojan horses, or the like; losing access and/or unauthorized access to your Account; any errors or malfunctions caused by or otherwise related to any wallets and/or banking accounts used to deposit and withdraw Virtual Currencies; malfunctions, breakdowns and abandonment of blockchain protocols; changes in regulatory approaches or legal actions taken regarding blockchain technology and Virtual Currency; taxation and/or changes in the tax system regarding Virtual Currencies; advancements in cryptography; other risks associated with purchasing and holding Virtual Currencies, and using the Website and Services.
A.3.9. Simple shall not be liable for any events that may include but are not limited to civil, criminal, and administrative actions that may arise from you using blockchain and Virtual Currency if such use is forbidden or otherwise limited in your domicile country.
A.3.10. Simple, its officers, directors, employees, and agents do not provide investment advice, financial advice, trading advice, legal advice or any other sort of advice.
A.3.11. Nothing in these T&C excludes or limits the responsibility of Simple for fraud, death or personal injury caused by its negligence, breach thereof, implied by operation of the Applicable Legislation or any other liability which may not be limited or excluded by the Applicable Legislation.
A.4. YOUR RIGHTS, OBLIGATIONS AND LIABILITIES (CUSTODIAL)
A.4.1. You are entitled to obtain Services via our Platform upon establishing a business relationship with Simple.
A.4.2. You hereby undertake to comply with the requirements, set in the Applicable Legislation as well as the other regulations, related to the use of the Services.
A.4.3. You must not have more than one (1) Account on the Platform. It is your sole responsibility to protect the confidentiality of your Account (not to give any third party your login, password, etc.) as well as your Transactional history.
A.4.4. You hereby represent and warrant that Fiat Currency units used for the exchange into the Virtual Currency unit belong to you and are derived from legal sources that may be confirmed upon the request of Simple at any time.
A.4.5. You represent and warrant that all your Transactions shall not violate the rights of any third party and/or the Applicable Legislation.
A.4.6. All payments used during the Transactions with Fiat Currencies, may it be a banking account, credit debit and/or prepaid card or others must be strictly under your name. Any attempt otherwise shall be considered as fraud and Simple may conduct additional checks as has been stipulated in detail herein.
A.4.7. You are obliged to monitor all and any changes in the Transaction flow, including, but not limited to, the provision of additional information and documents related to the named Transaction.
A.4.8. You should immediately (i.e. right after the moment of discovery) inform Simple about any unusual, suspicious, unclear or abnormal changes related either to the Transaction and/or Account via Customer Support. In case of your failure to inform Simple thereupon you shall be liable for the breach of these T&C and we are entitled to take any further steps, accordingly, including, but not limited, to the report to the Governmental Authority.
A.4.9. You undertake not to use the Services to perform criminal activity of any sort, including, but not limited to, money laundering, illegal gambling operations, financing terrorist organizations, or hacking.
A.4.10. You undertake to provide all necessary documentation immediately upon Simple’s request due to additional checks in case of suspicion of potential fraud or other illegal activity, conducted from your Account, or in order to comply with the internal policies of Simple and the Applicable Legislation.
A.4.11. To the extent permitted by the Applicable Legislation, you hereby agree to defend, indemnify, and hold harmless Simple from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses arising from: your use of and access to the Website and/or mobile app and Services; your violation of any provisions of these T&C; your violation of the Applicable Legislation, including any law, rule, or regulation, or the rights of any third party.
A.4.12. For non-performance or improper execution of your obligations under these T&C, you shall be liable as set in herein and in accordance with Applicable Legislation, unless otherwise provided below.
A.4.13. Nothing in the T&C excludes or limits your liability for fraud, death or personal injury caused by your negligence, breach of the terms implied by operation of the Applicable Legislation or any other liability which may not be limited or excluded by the Applicable Legislation.
A.5. YOUR ACCOUNT: REGISTRATION, VERIFICATION AND CLOSURE (CUSTODIAL)
A.5.1. While you establish a business relationship with Simple by registration either at the Website or within the mobile app, you hereby warrant and confirm that any and all information, submitted by you to us is accurate, valid, up-to-date, and complete. Should there be any error, mistake, update, or change in information or documents you have submitted prior, you are obliged to notify Simple immediately.
A.5.2. You shall not use your Account for illegal purposes and activities, including, but not limited to:
a) Money laundering, terrorist financing, the proliferation of weapons of mass destruction;
b) Human trafficking;
c) Any goods or services that are illegal or the promotion, offer or marketing of which is illegal or that are offered in connection with illegal, obscene or pornographic content, depict children or minors in sexual postures, depict means of propaganda or signs of unconstitutional organizations glorifying war or violating human dignity;
d) Any goods or services, promotion, offer or marketing of which would violate copyrights, intellectual property rights or other rights of any person;
e) Spreading of illegal drugs, narcotics or hallucinogens, synthetic stimulants;
f) Illegal purchase of weapons of any kind or explosive materials;
g) Illegal gambling services;
h) Goods that are subject to any trade embargo and services, provided to the persons that belong to any sanction list;
i) Media that is harmful to minors and violates laws and, in particular, the provision in respect of the protection of minors;
j) Body parts or human remains;
k) Initial coin offerings;
l) Protected animals or protected plants;
m) Any other illegal goods, services or transactions.
A.5.3. You must not create an Account on behalf of an entity unless you are legally authorized to do so. In such a case, Simple is entitled to request additional documents that confirm your authorization to do so.
A.5.4. You must not create an Account on behalf of another individual. By agreeing to these T&C you also confirm that you are acting on your own behalf.
A.5.5. In order to receive access to the Services, provided on the Website and/or mobile app, you are obliged to provide certain information and documents and undergo a verification procedure. For more information, please, read our AML/KYC Policy.
A.5.6. Simple may at any time request you to provide additional documents and information and/or updated documents and/or information and documents submitted before and reserves the right to do so at its sole discretion. Failure to abide by these requirements may result in temporary or permanent cessation of Services provision and/or Account suspension.
A.5.7. You acknowledge and hereby confirm that Simple shall verify your identity directly or indirectly (through engaged third parties), and make any inquiries as considered necessary to check the relevance and accuracy of the information provided for verification purposes.
A.5.8. Information and documents, submitted by you to Simple are processed according to provisions of our Privacy Policy.
A.5.9. You are entitled to close your Account at any time at your sole discretion. Before closing your Account, all your assets are to be withdrawn and/or transferred from your Account.
A.5.10. Simple hereby reserves its right to temporarily and/or permanently suspend your Account immediately without providing notice or reason in the following cases:
a) We reasonably believe your Account has been compromised, as well as due to any other security reasons;
b) We reasonably believe your Account is being used by a person with no right and/or authorization to do so;
c) Your failure to comply with these T&C, as well as with any other legal document that construes a part of these T&C;
d) You have provided us with any false, incomplete, misleading, or inaccurate information;
e) We reasonably suspect you of fraud, illegal activity and/or violation of the Applicable Legislation;
f) Other reasons that constitute a violation of these T&C and the Applicable Legislation.
A.5.10.1. If Simple, in its sole discretion, reasonably suspects or determines that you have engaged in, or have in any way been involved in, fraudulent activity, illegal activity (including but not limited to money laundering or terrorist financing), a material breach of these T&C, or any activity that poses an unacceptable risk to Simple, its users, or third parties (collectively, “Prohibited Conduct”), Simple reserves the right, without prejudice to any other rights or remedies available to it under these T&C or Applicable Legislation, to take one or more of the following actions with respect to any or all of your Accounts or Transactions, immediately and without prior notice:
a) Cancel, reverse, or annul any Transactions, including completed purchases or exchanges of Virtual Currency for Fiat Currency (or vice versa) or Virtual Currency for another Virtual Currency, that Simple reasonably believes are connected to such Prohibited Conduct.
b) In the event of a reversal or annulment of a Virtual Currency purchase, Simple may, at its sole discretion convert the relevant Virtual Currency held in your Account back into the original Fiat Currency at the prevailing market Exchange Rate at the time of such conversion, or at the Exchange Rate of the original transaction, or based on any other reasonable valuation method determined by Simple, and return such Fiat Currency to the original source of funds or to an account designated by you, subject to any deductions permitted under these T&C and compliance with AML/KYC requirements.
c) Deduct from your Account balance (whether held in Fiat Currency or Virtual Currency, and Simple may convert Virtual Currency to Fiat Currency for this purpose) any amounts deemed necessary by Simple to cover losses, damages, penalties, fees, or costs incurred by Simple or any third party as a direct or indirect result of your Prohibited Conduct or the reversal/annulment of transactions.
d) Withhold any Funds in your Account as reasonably necessary to cover potential losses, chargebacks, or liabilities arising from the Prohibited Conduct, pending investigation or resolution by Governmental Authorities.
e) Report the Prohibited Conduct and share relevant information with Governmental Authorities, law enforcement, or affected third parties.
You acknowledge and agree that Simple shall not be liable for any loss or damage you may suffer as a result of any actions taken by Simple under this clause A5.10.1, including but not limited to losses arising from changes in the Exchange Rate between the time of the original Transaction and the time of its reversal or conversion. You further agree to indemnify and hold Simple harmless against any claims, costs, or liabilities arising from actions taken by Simple in accordance with this clause.
A.5.11. Simple may, but is not obliged to, notify you about the reasons for your Account suspension. Assets from your Account shall be withdrawn to external wallets or your banking accounts, information about which you are to provide to our Customer Support.
A.5.12. Simple also reserves the right to cancel unconfirmed Accounts.
A.5.13. In the event of Account closing or suspension, you will still be liable for all applicable Fees, owed to Simple.
A.5.14. Simple shall not be liable for any losses suffered due to your Account closure or suspension.
A.5.15. In the event that you want to stop using the Platform, you can cancel your Account if you are in good standing and compliant with these T&C and other policies. All Funds must be withdrawn prior to the definitive closing of your Account. To cancel, simply withdraw all Funds in your Account and visit our cancellation page. However, you may not close your Account while you have a positive balance with funds exceeding the equivalent of 5 EUR. We will decide whether to cancel or suspend any pending transactions and we will need to hold Funds until any applicable reversal windows are complete and all your obligations to us are satisfied. Please contact our support team at [email protected] if you are not able to cancel your account. In some cases, we may terminate, suspend or otherwise restrict your Account and use of the Platform if we suspect your Account is connected to any prohibited use or prohibited business, for suspected violation of these T&C or any applicable agreements or policies, where required by applicable law, or to otherwise prevent potential loss.
A.5.16. If your Account holds a balance at the time of its closure, or there has been no activity in your Account for a period of more than seven (7) years, or if your Account remains closed or dormant with a balance for a period of more than seven (7) years, or otherwise prescribed by applicable law, we will ask you to withdraw your Funds within a reasonable period of time. During this period your Account will be accessible for the purpose of withdrawing the remaining balance only. After the expiry of this period, you will not be able to access your Account but you may withdraw any remaining Funds by contacting Support at [email protected] and requesting that the Funds be sent to you in a manner that is reasonably acceptable for us. You may withdraw your Funds for a period of seven years from the date of closure of your Account, but we suggest that you withdraw your remaining Funds as soon as possible. You agree that any Funds held by us more than seven (7) years after the date of termination of this Agreement cease to be held by us for you and shall instead become our Funds, without payment by us to you of any price or fee whatsoever. We reserve the right to carry out any necessary money laundering, terrorism financing, fraud or other illegal activity checks before authorising any withdrawal of your Funds, including in relation to returning any Funds to you after you have closed your Account.
A.6. DEPOSITS AND WITHDRAWALS (CUSTODIAL)
A.6.1. Deposit is executed when the corresponding amount of Funds is credited to your Account on the Platform.
A.6.2. You hereby acknowledge that whether a Deposit or Withdrawal is carried out, the amount thereof that is being transferred may not be fully available on your Account until a relevant number of confirmations is received. To withdraw Funds from your Account, you must fill out the corresponding form therein and stipulate the external wallet or your banking account for Withdrawal.
A.6.3. You can withdraw Funds from your Account at any time at your sole discretion subject to the Transaction limits and temporary or permanent restrictions, imposed thereto by Simple, under the Applicable Legislation and/or by any Governmental Authority.
A.6.4. You are entitled to withdraw any amount of Funds from your Account, providing, however, the remaining units thereto are sufficient to cover the applicable Fees.
A.6.5. Each Deposit and Withdrawal of Virtual Currency may be subject to a mining fee charged by the respective blockchain network. When sending your Transaction to the blockchain, Simple shall try to keep the balance between reasonable Fees and speed of processing, however, we reserve the right to determine the exact amount of mining fee to be set at our sole discretion. You can check the exact amount of mining fee charged for the specific transaction by checking the respective blockchain explorer (e.g. https://www.blockchain.com/explorer for BTC and BCH, https://etherscan.io/ for ETH, etc.).
A.6.6. Simple shall not be liable for the Transactions of your Virtual Currency. You are solely liable for the accuracy of information, required for carrying out a Virtual Currency Transaction (i.e. addresses, tags and any other required credentials). Simple strongly recommends you to always double-check the accuracy of information provided for Transaction purposes before submitting it.
A.6.7. You shall always keep in mind that blockchain transactions are irreversible, and therefore, once the Transaction has been sent to the blockchain network upon your request (in case of Withdrawals), we cannot reverse it at all.
A.6.8. Each Deposit and/or Withdrawal of Fiat Currency units may be subject to the fee charged by the respective banks, other financial institutions, payment acquirers, etc.
A.6.9. You hereby acknowledge and agree that the Deposit and/or Withdrawal of the Fiat Currency units may be delayed for a period up to 1 (one) month due to bank verifications and checks. Similarly, you acknowledge and agree that deposits to and withdrawals of Virtual Currency to/from your Account may take between 1 hour and 72 hours, barring unforeseen or unavoidable network issues. Simple shall bear no responsibility regarding such delays in Transaction execution.
A.6.10. All Deposits and Withdrawals may be subject to limits, that are displayed in your Account or available from Customer Support.
A.6.11. Simple shall also have the right to limit and/or restrict Deposits and Withdrawal of Funds from/to certain regions and jurisdictions, as it may be necessary under the requirements, stipulated either by the Applicable Legislation and/or obtained from electronic money institutions, payment service providers, banks, etc.
A.6.12. To be eligible to use Services rendered by Simple, the user is obligated to complete an initial verification procedure or identity verification procedure.
A.6.13. There is no limit regarding the trading activities and Withdrawals of Funds, but there are card deposit, card transaction limits (see the in-app "Limits" page).
A.6.14. Simple does not indicate and does not require a minimum or maximum Transaction amount to accept a valid and properly presented credit, debit and/or prepaid card.
A.6.15. Funds resulting from card payment may be restricted from being withdrawn from the Platform for a minimum of 14 days.
A.6.16. Third-Party Payment Services: As described in the General Terms (Section 1.3), certain payment services are provided by Third-Party Service Providers. By using these services, you agree to their separate terms.
A.6.16.1. SEPA bank deposit and withdrawal services are provided by Simple Europe UAB in partnership with Clear Junction Limited (a company incorporated and registered in England and Wales under company registration number 10266827). Clear Junction Limited is authorised by the FCA (FRN: 900684) as an electronic money institution.
A.6.16.2. Clear Junction Limited provides financial services to the Simple Europe UAB and does not have a direct contractual relationship with Customers. The Funds that Simple Europe UAB keeps with Clear Junction do not fall under FSCS protection but are fully covered in safeguarded accounts.
A.6.16.3. Card services are provided by Simple Europe UAB in partnership with Unlimit (Unlimint EU Ltd, a company incorporated and registered in the Republic of Cyprus under company registration number HE328641). Unlimit is licensed and regulated by the Central Bank of Cyprus as an Electronic Money Institution with license number 115.1.3.7/2018. In this capacity, the Simple App acts as a technology aggregator, providing you an interface to access card services offered directly by Unlimit.
A.6.17. Deposit or exchange of Fiat currency or Virtual Currency can be done through the "Recurring buy" feature. You choose the amount and interval for the operation which will be done at the time of confirming the Recurring buy order at the next interval. The exchange or purchase of Virtual Currency will be fulfilled automatically for the selected amount at the market price when the Transaction is executed.
A.7. TRANSACTIONS AND FEES (CUSTODIAL)
A7.1. You may solely use the Platform in order to conduct Transactions that correspond with the scope of the Services, rendered by Simple. Simple does not accept orders or requests on carrying out any Transactions with your Account from any third party, except whether otherwise is stipulated herein.
A7.2. You should always check the payment order, before its submission, thus, it is your sole responsibility to monitor the risks related thereto and accept all the consequences of its execution. You hereby accept that when the payment order is executed, such a Transaction is irreversible and may not be cancelled. Transactions shall be executed instantly and will be considered to have taken place at the execution date and time unless delays occur.
A7.3. Once your payment order has been completed, it cannot be cancelled or reversed. Exchanges are final and no refunds are applicable to them, except as otherwise explicitly provided in these T&C, including but not limited to the rights reserved by Simple in circumstances involving Prohibited Conduct.
A7.4. You acknowledge and agree that the Transaction may be delayed due to AML/KYC verification and other checks.
A7.5. In case whether you discover any doubtful Transaction activity via your Account, you shall immediately notify Simple thereto via Customer Support and follow the instructions sent by us. Otherwise, Simple reserves the right to freeze your Funds until the end of an investigation.
A7.6. You hereby accept that Simple may be forced to cancel or recall an already executed Transaction at the request of Governmental authorities, and financial institutions, including, but not limited to, banks, which are involved in the settlement of such Transactions. In any such case you are obligated to provide all necessary data related thereto and cooperate with Simple in order to resolve such an issue.
A7.7. You hereby accept that Transaction Fees shall be determined by the sole discretion of Simple and are applicable for each Transaction. The applicable Fees for any Transaction shall be displayed to you before the execution of a Transaction.
A7.8. Simple may change the Fees at any time, including adding new Fees for additional Services and reserves the right to do so at its sole discretion. Any changes to the Fees will be disclosed to you by Simple. This can be done by posting a notification on the Website and/or mobile app or sending you an e-mail (if appropriate).
A7.9. Simple bears no responsibility for the extra costs, imposed by any third party, including, but not limited to any exchange rates, processing fees and any other fees.
A7.10. Simple shall keep the record of all your Transactions within the timeframe of the business relations between you and us and at least 8 (eight) years upon its termination, irrespective of the nature of such termination.
A7.11. Simple expects the User to contact via email: [email protected] to resolve any problem or issue related to his/her payments before the User makes any Chargeback request. This Section does not affect any rights and/or claims, which the User may have against the bank/financial institution.
A7.12. Simple will investigate any Chargeback requests made by the User and reserves the right to suspend User’s account and lock User’s Funds during the chargeback investigation procedure.
A7.13. Your use of the debit card funding method must comply with any instructions presented to you in the App. Your debit card payments may be delayed, or rejected. Delay may occur from, among other things, payment processing timing issues; your debit card company, a third party processor or Simple may reject your debit card payment. It is your responsibility to monitor your Account in respect of debit card funding.
A7.14. Simple will not be liable to you for any losses, fees or charges in connection with use of the credit card funding method. Funding by card is, in addition to the terms set forth herein, subject to any applicable terms set forth in your card agreement, which may include fees charged by your credit card in conjunction with such funding.
A7.15. You are liable for any credited amounts in case of a chargeback. If payment is not possible (e.g., your debit card company declines or rejects the payment), or a chargeback occurs, you will bear any resulting costs (including the original chargeback amount).
A7.16. Any chargeback resulting from the use of your Account or Simple Services may result in an immediate suspension and/or restriction of your Account and Simple Services. You may be required to reimburse us for the full value of the chargeback, including any amounts that are owing to us including any applicable fees; and
A7.17. You are liable for any credited amounts in case of a chargeback, and you authorise and grant Simple the right to deduct costs and fees directly from any assets in your Account without prior notice.
A.8. CONFIDENTIALITY (CUSTODIAL)
A.8.1. Simple precisely treats the confidential status of Personal Data, provided by you, and shall make its best efforts to process it strictly for the purposes of the Services provision. Additional information thereupon may be found in our Privacy Policy.
A.8.2. Simple may be obliged to disclose your Personal Data to the Governmental authorities, law enforcement authorities, data protection authorities, financial regulators, financial service providers and officials, and other authorized persons, as set forth in the Privacy Policy.
A.8.3. In the event we suspect you have violated the AML/KYC Policy, we shall report such behaviour and disclose relevant personal information to relevant Governmental authorities in accordance with the Applicable Legislation.
A.9. CURRENCY (CUSTODIAL)
A.9.1. Your Account may comprise different currencies. These will be subject to the following conditions: Simple may accept payments into the account in different currencies and any payments due to or from us and any net balances on the account shall be reported by us in the respective currency;
A.9.2. The Account is maintained in Fiat Currency (EUR, USD) and Virtual Currency. Any other currency will be converted at the Exchange Rate existing at the point of conversion.
SECTION 3: PART B — TERMS FOR SELF-CUSTODIAL SERVICES
IMPORTANT NOTICE REGARDING YOUR ASSETS: The terms in this Part B apply ONLY when you use our Self-Custodial Wallet (SCW) services, which are designed to give you sole control over your digital assets. This service utilises Multi-Party Computation (MPC) technology. This means that you alone are in control of and responsible for your cryptographic private key information and digital assets (Virtual Currency) held in your Simple Self-Custodial Wallet. Simple does not have custody or control over your assets. We cannot access, control, reverse, or cancel your transactions. You are solely responsible for the security of your wallet access credentials, including your device security and any backup methods you employ. These terms supplement the General Terms (Section 1) and do not apply to the Custodial Wallet Services.
B.1. DEFINITIONS SPECIFIC TO SELF-CUSTODIAL SERVICES
For the purposes of this Part B, the following terms have the meanings ascribed to them below:
“Account” means the user account you create within the App to access the Services.
“App” means the Simple crypto wallet mobile application available for download on supported mobile operating systems.
“Applicable Law” means any relevant laws, statutes, regulations, rules, ordinances, or court orders applicable in the jurisdiction of Simple and/or the User.
“Backup” refers to the process enabled by Simple allowing Users to create an encrypted copy of their Recovery Kit component, stored either on their personal cloud storage (e.g., iCloud, Google Drive) or saved manually as a file, for wallet recovery purposes.
“Face Check” refers to the optional biometric recovery feature provided by Simple, which utilizes facial recognition technology by processing images captured via your device's front camera. This process aims to assist in verifying your identity for wallet recovery purposes, as further detailed herein and in our Privacy Policy. Face Check is distinct from and does not utilize native operating system biometric authenticators. Use of Face Check is subject to feature availability, device camera functionality, successful prior enrollment by you, suitable environmental conditions during use, and your acceptance of the associated risks and data processing practices outlined in this T&C and the Privacy Policy.
“Multi-Party Computation (MPC)” refers to the cryptographic technology used by the Simple wallet. It involves creating and distributing separate components (shares) of the private key information between the User's device and Simple's secure server(s). Transactions are signed collaboratively using these shares without ever combining them to reveal the full private key in a single location. This approach eliminates the need for a traditional seed phrase, meaning the wallet is designed to be not vulnerable to the risks associated with seed phrase loss or compromise by the User.
“Private Key Share” (or “Recovery Kit”) refers to the user-specific cryptographic secret material generated using the MPC protocol, essential for accessing and controlling the Self-Custodial Wallet. It is not a traditional seed phrase. Secure backup and management of this Private Key Share (or the means to regenerate/recover it, like cloud backup access) are crucial for wallet access. Loss of the Private Key Share and inability to utilize recovery mechanisms provided by Simple may result in permanent loss of access to Funds. This is part of a 2-of-2 MPC signature scheme where "Private Key Share #1" is managed by Simple, and "Private Key Share #2" resides on the User's device.
“Self-Custodial Wallet (SCW)” means the specific type of Virtual Currency wallet provided by Simple, based on MPC technology, where the User retains exclusive control over their private key material (managed via MPC shares) and the corresponding Funds. Simple does not hold or control the User's private keys or Funds.
B.2. THE SELF-CUSTODIAL MPC WALLET
B.2.1. The Simple wallet is a self-custodial wallet built using MPC technology. You are the sole custodian of your Funds. Simple acts as a technology provider, facilitating your interaction with blockchain networks, but does not hold, control, or have access to your private keys or Funds.
B.2.2. Instead of a traditional single private key or seed phrase, the wallet utilizes MPC. This divides the key signing authority into multiple shares. Typically, one share is managed securely on your device (protected by your device's security features like biometrics or PIN), and another share is held by Simple's secure infrastructure. Transactions require collaborative signing using these shares, thus enhancing security by eliminating a single point of failure associated with traditional private keys or seed phrases.
B.2.3. A key feature of the MPC approach is that you are not issued, nor do you need to manage, a traditional 12 or 24-word seed phrase (recovery phrase). This eliminates the risk associated with losing or compromising such a phrase.
B.2.4. You are solely responsible for:
a) Securing access to your mobile device (e.g., using strong PINs, passwords, biometrics);
b) Managing and securing your Recovery Kit/Private Key Share and any chosen Backup method (Cloud Backup password, manually saved file);
c) Understanding the risks associated with self-custody and Virtual Currency transactions;
d) Ensuring the accuracy of recipient addresses and transaction details before confirming any Transaction. Blockchain transactions are generally irreversible.
B.2.5. In place of a seed phrase, Simple provides recovery mechanisms:
B.2.5.1. Support Recovery — You may initiate a recovery process by contacting Simple support using your Account registered email address and/or device at [email protected], potentially involving identity verification steps.
B.2.5.2. Backup Restoration — You can restore your wallet using a previously created encrypted Backup from your cloud storage (iCloud/Google Drive) or a manually saved file, requiring successful decryption using your cloud account credentials, device biometrics, or a specific backup password.
B.2.5.3. Face Check Recovery — Utilizing the specific camera-based "Face Check" feature (as defined in Section B.1), subject to availability, device compatibility, and your successful prior enrollment and setup as applicable. Use of Face Check Recovery is optional and distinct from other biometric methods like fingerprint scanning.
B.2.6. It is crucial to understand that if you lose access to your device, forget your access credentials, AND lose access to or fail to create a Backup, AND cannot successfully complete the Support Recovery or Face Check Recovery process, your Funds may be permanently lost. Simple cannot access or recover your Funds for you in such scenarios.
B.3. SCOPE OF SELF-CUSTODIAL SERVICES
Simple provides you with access to the following Services through the App, subject to these T&C:
B.3.1. Self-Custodial Cryptocurrency Wallet:
a) Create and manage your Simple Self-Custodial Wallet (SCW) based on MPC technology;
b) Securely store, send (withdraw), and receive (deposit) supported Virtual Currencies. The list of supported Virtual Currencies is available within the App and may change at Simple's discretion;
c) View your transaction history and Virtual Currency balances;
d) You acknowledge and agree that you are solely responsible for managing your SCW, initiating transactions, and ensuring the accuracy of transaction details (e.g., recipient addresses). Simple does not control your Funds or transactions.
B.3.2. Native Staking (DeFi Earn):
a) Where available for specific Virtual Currencies, you may choose to stake your assets directly through functionalities integrated within the App ("Native Staking" or "DeFi Earn");
b) This service facilitates your interaction with the underlying blockchain protocols or third-party DeFi protocols that enable staking;
c) Staking typically involves locking your Virtual Currency for a period to earn potential rewards according to the rules of the specific protocol;
d) You acknowledge that staking involves risks, including but not limited to potential loss of staked assets due to protocol rules (e.g., slashing), smart contract vulnerabilities, or market volatility. Simple provides the interface but does not guarantee rewards or insure against losses. Eligibility and terms for staking specific assets are determined by the underlying protocols.
B.3.3. Swap Service (via Third-Party Service Provider):
a) The App integrates a service allowing you to exchange one supported Virtual Currency for another ("Swap"). This is a Third-Party Service as described in Section 1.3 of the General Terms.
b) This Swap service is provided by Changelly or another designated Third-Party Service Provider;
c) To use the Swap service, you must agree to the terms and conditions and privacy policy of the respective Third-Party Service Provider (Changelly);
d) All Swap transactions are subject to fees charged by the Third-Party Service Provider, which will be displayed before you confirm the transaction. Exchange rates are determined by the provider based on market conditions;
e) Simple facilitates access to this service but is not a party to the Swap transaction itself. Simple is not responsible for the execution, speed, or outcome of the Swap, nor for any losses incurred. Any issues with a Swap transaction should be directed to the Third-Party Service Provider.
B.3.4. On-Ramp / Off-Ramp Services (via Third-Party Service Provider):
a) The App integrates services allowing you to exchange Fiat Currency for Virtual Currency ("On-Ramp") and Virtual Currency for Fiat Currency ("Off-Ramp") (with the Off-Ramp services being added to the App at a later stage). These are Third-Party Services as described in Section 1.3 of the General Terms.
b) These services are provided by a designated Third-Party Service Provider;
c) Use of On-Ramp/Off-Ramp services requires you to agree to the terms and conditions and privacy policy of the respective Third-Party Service Provider. You may also need to complete their identity verification (KYC) procedures;
d) Transactions are subject to fees charged by the Third-Party Service Provider and potentially your bank or payment provider. Exchange rates are determined by the provider;
e) Simple facilitates access to these services but does not process fiat payments or execute the conversion itself. Simple is not responsible for the execution, processing times, or outcome of On-Ramp/Off-Ramp transactions, nor for any associated fees or losses. Direct inquiries regarding these transactions to the Third-Party Service Provider.
B.3.5. Payment Card Program (via Third-Party Service Provider):
a) Eligible users may apply for and use a payment card linked to their Simple wallet balance through the App. This is a Third-Party Service as described in Section 1.3 of the General Terms.
b) The payment card program, including card issuance, transaction processing, and account management, is provided and managed entirely by a designated Third-Party Service Provider.
c) To participate in the card program, you must meet eligibility requirements, complete their verification procedures, and agree to a designated Third-Party Service Provider's specific terms and conditions and fee schedule;
d) Simple provides an interface within the App to manage aspects of the card linkage but is not the issuer, processor, or provider of the card services. All card functionalities, liabilities, and regulatory obligations rest with a designated Third-Party Service Provider.
B.3.6. Banking-as-a-Service (BaaS) (via Third-Party Service Provider):
a) Eligible users may be able to open and manage payment accounts (e.g., IBAN accounts) directly within the Simple App. This is a Third-Party Service as described in Section 1.3 of the General Terms.
b) These BaaS features, including account opening, holding fiat funds, and processing payments, are provided by a designated Third-Party Service Provider;
c) Access to BaaS features is subject to KYC (Know Your Customer) and AML (Anti-Money Laundering) screening processes, eligibility criteria, and their separate terms and conditions and fee structure;
d) Simple provides the user interface for accessing these BaaS features but does not provide the underlying regulated banking or payment account services. All related functionalities, compliance, and liabilities are managed by a designated Third-Party Service Provider.
B.3.7. You acknowledge that the services listed in sections B.3.3, B.3.4, B.3.5, and B.3.6 rely on Third-Party Service Providers. Simple does not operate, control, endorse, monitor, or assume responsibility for these Third-Party Service Providers, their services, websites, content, security, privacy practices, or any outcome resulting from your interaction with them. Your use of these integrated third-party services is entirely at your own risk. You bear the sole and exclusive responsibility for reviewing, understanding, accepting, and complying with the respective terms, conditions, policies, fees, and charges of such Third-Party Service Providers.
B.4. SECURITY, BACKUP, AND RECOVERY
B.4.1. You are solely responsible for maintaining the security of the device(s) used to access your Simple wallet, including implementing strong passwords, PINs, or biometric security, and protecting your device from unauthorized access or malware. You are also responsible for the security of any credentials related to your recovery methods (e.g., cloud account passwords, manually saved backup files, backup passwords).
B.4.2. The Private Key Share material generated via MPC is essential for accessing your wallet. You MUST take precautions to ensure you do not lose access to your Private Key Share or the means to recover it. As stated previously, without a functional recovery method (Backup, Support Recovery, Face Check Recovery), loss of access to your primary device or its credentials could lead to the permanent and irreversible loss of your Funds.
B.4.3. Simple enables an optional feature allowing you to securely back up an encrypted component of your Recovery Kit:
- a) Cloud Backup — You can choose to back up the encrypted file to your personal iCloud (iOS users) or Google Drive (Android users) account;
- b) Manual Backup — You can choose to save the encrypted backup file (.json format) manually to a secure location of your choice.
B.4.3.1. All Backups are encrypted using a key derived from your device security or a password you set specifically for the Backup. Simple does not have access to your cloud storage or the decryption key for your Backup file. The file is unreadable without successful decryption by you during the restoration process.
B.4.3.2. You can manage your Backups (create, update, delete) via the App settings. The App may display the status of your cloud backup.
B.4.4. If you install the App on a new device and you enter the email address associated with your existing Simple wallet, the following processes may apply based on the availability of your previously used device ("old device"):
- a) If Your Old Device is Available and Online:
- You may be presented with an option within the App to add the new device to your existing wallet.
- To authorize this, a push notification or prompt may be sent to your old device requesting you to explicitly approve or "trust" the new device.
- Successful approval from the old device may allow you to access and use your Simple wallet on both devices concurrently or sync your wallet state.
- b) If Your Old Device is Unavailable:
- This situation will initiate a wallet recovery process to regain access on the new device.
- Initial steps to verify your identity before restoring full access include:
- Email Verification — Simple will send a confirmation link or verification code to the email address registered with your wallet. You must access your email and successfully interact with this confirmation to prove ownership of the email address before proceeding with further recovery steps.
- Security Confirmation — After email verification you will be required to enter your pre-existing wallet PIN code in the App to further confirm your identity and authorize the wallet recovery.
B.4.5. Proceeding with Recovery Methods:
Option 1 — Restore from iCloud / Google Drive:
1) You grant the App permission to access your cloud storage to check for backups.
2) You authenticate your cloud account if necessary.
3) You are prompted for device biometrics (Face ID/Touch ID) or your specific Backup password to decrypt the backup file.
4) Upon successful decryption, the App restores your wallet access.
Option 2 — Upload Backup File Manually:
1) You select the option to upload a file.
2) You use your device's file picker to select the previously saved encrypted backup file (.json).
3) You are prompted for device biometrics or your Backup password to decrypt the file.
4) Upon successful decryption, the App restores your wallet access.
Option 3 — Face Check Recovery. This method uses your device's front camera to capture facial images for verification against your enrollment data (you must previously be enrolled in and enabled this optional feature). Success depends heavily on factors including, but not limited to, the quality and consistency between your enrollment and verification images, the proper functioning and lack of obstruction of your device's front camera, sufficient and stable environmental lighting, absence of significant changes to your facial appearance (e.g., due to accessories, major beard changes, injury), and the inherent accuracy limitations of the camera-based facial recognition algorithms used by Simple or its service providers. This feature directly processes camera images and is functionally different from secure hardware-based systems.
Option 4 — Support Recovery. If Backup options fail or were not used, you may attempt recovery by contacting Simple Support ([email protected]) via the email you signed up for Simple App. Success is not guaranteed in this recovery option.
B.4.6. Simple attempts to provide guidance during recovery failures:
a) Cloud Login Issues — You may be prompted to log into your Apple/Google account or check permissions. A "Retry" option may be provided;
b) No Internet Connection — You will be prompted to connect to the internet and retry;
c) Backup Not Found — The App will inform you if no backup is found in the selected cloud account. It may suggest trying another account or contacting Support;
d) Corrupted/Invalid Backup File — If the file cannot be decrypted or read, the App will indicate the file is invalid. Retrying or contacting Support may be suggested;
e) Incorrect Decryption Password/Biometrics — You may be allowed a limited number of attempts to enter the correct password. After repeated failures, creating a new wallet or contacting Support might be suggested.
B.4.7. After successfully restoring a wallet, Simple may, for enhanced security awareness, suggest considering the creation of a new wallet and transferring your funds to it. This is optional advice, and you may choose to continue using the restored wallet.
B.5. PRIVATE KEY EXPORT
B.5.1. Simple may provide a mechanism for you to request the export of your full private key(s) derived from the MPC shares associated with your Self-Custodial Wallet.
B.5.2. You acknowledge and agree that initiating and completing the private key export process signifies your intention to take sole, direct, and complete control of your private keys outside the Simple MPC framework. Therefore, upon successful export of your private key(s):
a) Your Account with Simple will be immediately and permanently closed;
b) Simple will cease providing all Services associated with that wallet, including any further transaction signing assistance, security monitoring, or recovery support;
c) You become solely responsible for the security and management of the exported private key(s) and any associated Funds. Simple will have no further ability or obligation to assist you with that wallet or its assets;
d) You will not be able to import the private key(s) in question to the Simple App again.
B.5.3. The decision to export your private keys and terminate the Services is irreversible from Simple's perspective. Ensure you fully understand the implications and have the technical knowledge to manage private keys securely before proceeding with any export request.
B.6. USER OBLIGATIONS AND CONDUCT (SELF-CUSTODIAL)
B.6.1. You agree to use the Services only for lawful purposes and in accordance with these T&C and Applicable Law.
B.6.2. You shall maintain only one Account with Simple. Creating multiple accounts by a single user is prohibited.
B.6.3. You are solely responsible for maintaining the confidentiality and security of your Account access credentials, including your device PIN, password, biometric data used for App access, or any passwords or access credentials associated with your chosen Backup method (e.g., cloud account password, backup file password). Do not share these credentials with any third party.
B.6.4. You represent and warrant that any Fiat Currency used in connection with Third-Party On-Ramp services accessed via the App originates from legal sources and belongs to you.
B.6.5. You agree not to use the Services to conduct, facilitate, or promote any illegal or prohibited activities, including but not limited to:
a) Money laundering, terrorist financing, or financing of sanctioned individuals or entities.
b) Fraud, scams, or deceptive practices;
c) Transactions involving illegal goods or services;
d) Infringement of intellectual property rights, privacy rights, or other proprietary rights;
e) Gambling services where prohibited by law;
f) Spreading malware, viruses, or engaging in hacking activities;
g) Interfering with the integrity or performance of the Services or the data contained therein;
h) Any activity violating Applicable Law or the rights of any third party.
B.6.6. When using Third-Party Services (like On-Ramp/Off-Ramp or Card services) that require linking external accounts (e.g., bank accounts, cards), you must ensure that these external accounts are legally held in your own name.
B.6.7. You are responsible for monitoring your Account and Transaction history. You must immediately notify Simple Customer Support at [email protected] if you discover or suspect any unauthorized use of your Account, security breach, or suspicious activity.
B.6.8. You agree to provide accurate, current, and complete information as may be requested by Simple (e.g., for support, identity verification related to recovery) or by Third-Party Service Providers (for their KYC/AML processes). You agree to promptly update any information that changes.
B.7. FEES (SELF-CUSTODIAL)
B.7.1. Performing Virtual Currency Transactions (e.g., sending crypto, interacting with staking contracts) requires the payment of transaction fees ("Network Fees" or "Gas Fees") to the miners or validators of the respective blockchain network. These fees are not paid to or set by Simple. You are solely responsible for ensuring you have sufficient balance of the appropriate native Virtual Currency in your wallet to cover these Network Fees. Fee amounts fluctuate based on network activity.
B.7.2. Simple may charge fees for certain optional or premium features of the Services it provides directly. Any such applicable fees charged by Simple will be clearly disclosed to you within the App before you confirm the relevant action or subscribe to the feature.
B.7.3. Services provided by Third-Party Service Providers are subject to their own fee schedules. These fees are determined solely by the respective Third-Party Service Provider and will be disclosed to you by them during the transaction process within the integrated service flow. Simple is not responsible for setting or collecting these third-party fees.
B.7.4. Simple reserves the right to introduce new fees or modify existing Simple Service Fees at its discretion. We will provide notice of any such changes, typically via the App or our website. Continued use of the Services after notice of fee changes constitutes your acceptance.
B.8. RISK DISCLOSURES (SELF-CUSTODIAL)
YOUR USE OF THE SERVICES IS AT YOUR SOLE RISK. VIRTUAL CURRENCIES ARE HIGHLY VOLATILE AND INVOLVE SIGNIFICANT RISK OF LOSS.
B.8.1. As the user of a self-custodial wallet, you bear the entire responsibility for securing your private key material (managed via MPC shares and recovery methods). If you lose access to your device, forget or lose your access credentials (PIN, biometrics), AND lose or cannot access your chosen Backup (cloud or manual file) or fail recovery via other methods, your Funds stored in the wallet may become permanently and irretrievably lost. Simple cannot access, control, or recover your Funds in such situations.
B.8.2. The value of Virtual Currencies can fluctuate dramatically and unpredictably. You may lose the entire value of your assets. Simple does not provide investment advice or guarantee any returns.
B.8.3. Technology Risks:
a) MPC Security — While designed to enhance security, MPC technology, like any cryptographic system, is subject to potential vulnerabilities, although Simple employs robust security measures;
b) Blockchain Risks — Transactions are recorded on public blockchains. Network congestion can cause delays and high Network Fees. Blockchain protocols may experience forks, 51% attacks, or other issues impacting transaction finality or asset security;
c) Smart Contract Risks — Using features like Native Staking involves interacting with smart contracts, which may contain bugs or vulnerabilities exploitable by malicious actors, potentially leading to loss of funds;
d) Software Risks — The App or underlying software could contain bugs or security vulnerabilities. Simple endeavours to maintain secure software but cannot guarantee perfection;
e) User Device Security — Your device may be compromised by malware, viruses, or phishing attacks, potentially leading to unauthorized access to your wallet if your device security is breached.
f) Face Check Recovery Risks — Your use of the optional camera-based Face Check recovery feature is entirely at your own risk. You acknowledge and accept risks specifically associated with this type of technology, including:
i) Higher susceptibility to failure due to variations in lighting, angle, distance, camera quality/damage, obstructions (e.g., masks, glasses), and changes in your facial appearance compared to enrollment;
ii) The inherent possibility of false negatives (failing to recognize you even if it's you) and false positives (incorrectly matching someone else, although typically designed against) due to algorithmic limitations;
iii) Dependence on Simple's (or its vendor's) image processing systems, which may have errors, biases, or downtime;
iv) Privacy and security considerations associated with the capture, processing, and potential storage of facial biometric data derived from camera images (distinct from on-device processing), as detailed in the Privacy Policy, which you must review and consent to separately if required for enrollment. Simple is not liable for any failure, inaccuracy, delay, security incident, or inability to recover your wallet resulting from the use or malfunction of the Face Check feature, unless directly caused by Simple's proven gross negligence or willful misconduct.
B.8.4. Reliance on Third-Party Service Providers carries risks associated with their platforms, including operational failures, security breaches on their systems, changes in their services or fees, or regulatory issues affecting their operations. Simple is not responsible for losses caused by these third parties.
B.8.5. Blockchain transactions are typically irreversible. Once confirmed on the network, a transaction cannot be cancelled or reversed. You are solely responsible for ensuring the accuracy of recipient addresses and transaction amounts.
B.8.6. Simple does not provide any investment, financial, trading, legal, tax, or other professional advice. Any market information, charts, or other content provided through the Services is for informational purposes only. You should conduct your own research and consult with qualified professionals before making any financial decisions.
B.12. INDEMNIFICATION
You agree to defend, indemnify, and hold harmless Simple, its affiliates, officers, directors, employees, agents, and third-party service providers from and against any and all claims, damages, obligations, losses, liabilities, costs, debts, and expenses (including but not limited to attorney's fees) arising from:
a) Your use of and access to the Services;
b) Your violation of any term of these T&C;
c) Your violation of any Applicable Law, rule, or regulation, or the rights of any third party (including intellectual property or privacy rights);
d) Your interaction with any Third-Party Service Provider facilitated through the App;
e) Your failure to properly secure your Account access, Recovery Kit/Private Key Share, or Backup methods; or
f) Any other party's access and use of the Services with your unique username, password, or other appropriate security code (if such access was not due to Simple's fault).
B.9. TERM AND TERMINATION (SELF-CUSTODIAL)
B.9.1. These T&C commence on the date you first access or use the Services and continue until terminated by either you or Simple.
B.9.2. You may terminate this agreement at any time by transferring all Funds out of your Self-Custodial Wallet and ceasing all use of the App and Services. Only uninstalling the App does not terminate this agreement or guarantee the security of your means of access if retained elsewhere (e.g., Backups). If you require confirmation or wish to ensure associated server-side components (like the MPC share held by Simple) are deactivated after emptying your wallet, please contact Customer Support at [email protected]. You acknowledge that as this is a self-custodial wallet, you are solely responsible for securing and transferring your Funds prior to ceasing use; Simple cannot access or transfer your Funds for you.
B.9.3. Simple reserves the right to suspend or terminate your access to the Services (which includes disabling functionalities reliant on Simple's servers, such as MPC transaction signing, support, and third-party integrations via the App), or deactivate your Account, immediately and without prior notice, at our sole discretion, if:
a) You breach any provision of these T&C;
b) We reasonably suspect you of engaging in fraud, money laundering, terrorist financing, or any other illegal or prohibited activity;
c) We are required to do so by Applicable Law, regulation, or order from a competent governmental authority;
d) We reasonably believe your Account security has been compromised or is being used by an unauthorized person;
e) You provide false, misleading, or incomplete information;
f) Your use of the Services poses a security risk to Simple, other users, or the public, or disrupts the operation of the Services;
g) You initiate the Private Key Export process as described in Section B.5.
B.9.4. Upon termination of this agreement for any reason:
a) Your license to use the App and Services ceases immediately;
b) Functionalities provided via the Simple App that rely on Simple's infrastructure (including MPC signing collaboration and integrated third-party services) will no longer be available for the terminated wallet;
c) Crucially, termination by Simple does not affect your ownership of the Funds held in your Self-Custodial Wallet on the blockchain. However, your ability to access and transact with those Funds using the Simple App interface will be terminated. You will need to rely on your secured Backup (if created) or other means compatible with your Recovery Kit/Private Key Share (or exported private keys, if applicable) to manage your Funds independently of Simple. Simple will have no further obligation or ability to assist with transactions or recovery for the terminated wallet;
d) Any provisions of these T&C that by their nature should survive termination will remain in effect.
For your reference, previous versions of this document is archived and can be accessed at the following links:
— Custodial Wallet Terms & Conditions — https://simple.app/terms-and-conditions-custodial-old/
— Non-Custodial Wallet Legacy Terms & Conditions — https://simple.app/terms-and-conditions-scw-old/
