Terms of Service
Last Updated: [2026-01-01]
These Terms of Service (“Terms”) govern your access to and use of the services provided under the PengoPay brand (the “Services”).
PengoPay is operated by Pengo Technologies Ltd, a company incorporated in Abu Dhabi Global Market (ADGM) (“Pengo”, “we”, “us”, or “our”).
By accessing or using the Services, you acknowledge that you have read, understood, and agreed to be bound by these Terms.
Nature of the Services
PengoPay provides non-custodial stablecoin payment and transaction facilitation software designed for business users.
The Services may include:
tools to generate payment requests and addresses;
interfaces that allow users to connect and use self-custodial digital asset wallets;
transaction monitoring and technical coordination tools;
integrations with third-party blockchain networks and licensed service providers.
PengoPay is a non-custodial platform.
At no time does PengoPay:
hold, custody, safeguard, or store user digital assets;
control or have access to users’ private keys, seed phrases, or credentials;
initiate, approve, or execute transactions on behalf of users.
All digital asset transactions are executed directly by users through their own wallets on public blockchain networks.
Regulatory Status
PengoPay operates as a technology service provider and does not provide regulated financial services in the United Arab Emirates or any other jurisdiction unless explicitly stated.
User-Controlled Wallets and Asset Responsibility
The Services support interaction with self-custodial wallets that are created, managed, and controlled exclusively by users.
You acknowledge and agree that:
you are solely responsible for the security of your wallet, private keys, and recovery information;
PengoPay cannot access, recover, reset, or restore your wallet or digital assets;
loss of private keys or access credentials may result in permanent loss of digital assets;
blockchain transactions are irreversible once confirmed.
PengoPay has no ability to reverse, cancel, or modify transactions.
User Eligibility
The Services are intended solely for business users with the legal capacity to enter into binding agreements.
By using the Services, you represent and warrant that:
you are using the Services for lawful business purposes;
you are not located in, incorporated in, or operating from any Restricted Jurisdiction;
your use of the Services complies with all applicable laws and regulations.
Restricted Jurisdictions
PengoPay does not provide Services to residents or entities located in, incorporated in, or operating from the following jurisdictions (“Restricted Jurisdictions”):
Singapore
United States of America
Mainland China
Japan
South Korea
Hong Kong
United Kingdom
Any jurisdiction subject to comprehensive economic or trade sanctions, including but not limited to Iran, North Korea, Syria, and Cuba.
PengoPay does not actively market or solicit users in any Restricted Jurisdiction.
No Financial, Custodial, or Investment Services
PengoPay does not:
provide custody, safekeeping, or management of digital assets;
provide exchange, brokerage, or trading services;
provide investment, legal, or financial advice;
guarantee transaction execution, settlement, or outcomes.
All decisions to send, receive, or hold digital assets are made solely by users.
Third-Party Services
The Services may integrate or interact with third-party services, including:
blockchain networks;
wallet software providers;
licensed fiat on-ramp or off-ramp providers.
PengoPay does not control and is not responsible for the availability, security, or compliance of any third-party service.
Use of third-party services is subject to their respective terms and policies.
Limitation of Liability
To the maximum extent permitted by law:
PengoPay shall not be liable for any loss of digital assets, private keys, or access credentials;
PengoPay shall not be liable for blockchain network failures, delays, or errors;
PengoPay shall not be liable for indirect, incidental, consequential, or special damages.
You assume all risks associated with the use of self-custodial digital asset wallets and blockchain technology.
Suspension and Termination
PengoPay reserves the right to suspend or restrict access to the Services at any time where continued access may expose PengoPay to legal, regulatory, or compliance risk.
Governing Law
These Terms shall be governed by and construed in accordance with the laws of Abu Dhabi Global Market (ADGM), without regard to conflict of law principles.
Disclaimer
Nothing in these Terms constitutes legal, financial, or investment advice.
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