Terms of Service

Twenty-One Dragmas LTD provides technical infrastructure and transaction execution services that enable Users to interact with digital assets, including stablecoins, through integrations with third-party providers.

• The Company acts primarily as an agent on behalf of the User.
• The Company does not operate as a bank, broker-dealer, or fiduciary, unless expressly stated.
• The Services rely on third-party infrastructure and blockchain networks outside of the Company's control.

Limited Custody Disclaimer

While the Services are designed to operate on a non-custodial basis, the User acknowledges and agrees that:

• In limited circumstances, the Company may take temporary, incidental control or custody of digital assets strictly for: transaction execution, settlement, liquidity routing, and operational optimization of flows.
• Any such custody is short-term and solely for technical or operational purposes, does not constitute custodial services or a custodial relationship, and does not grant the Company discretionary control over User assets beyond execution instructions.
• The Company shall not be deemed a custodian, trustee, or safekeeper of assets at any time.

• You must be at least 18 years old and legally capable of entering into binding agreements.
• If acting on behalf of an entity, you must be duly authorized to bind that entity.
• You must maintain an active account with supported third-party providers.
• You agree to provide accurate and complete information.

The Company reserves the right to accept, reject, or terminate access at its sole discretion.

The User acknowledges and agrees that:

• 21D operates as a technology and infrastructure provider and does not itself hold financial services licenses unless explicitly stated.
• The Services rely on a network of regulated third-party providers, including but not limited to: banking partners, payment institutions, virtual asset service providers (VASPs), and transaction orchestration platforms (collectively, the "Partners").
• Such Partners are fully licensed and regulated in their respective jurisdictions and are responsible for: custody (where applicable), fiat on/off-ramps, payment processing, and regulatory compliance obligations tied to licensed activities.
• Twenty-One Dragmas LTD acts as an orchestration and execution layer, coordinating interactions between the User and such Partners.
• The Company does not control and is not responsible for: the regulatory obligations of such Partners, their performance, or any interruption, delay, or failure in their services.

• The User may interact with the Services through: (i) self-custodied wallets, and/or (ii) designated wallets operated by Twenty-One Dragmas LTD or its Partners for execution and flow optimization.
• Where such wallets are used, the User acknowledges that they may be operated or controlled by the Company or its Partners, strictly for: execution, settlement, liquidity routing, and operational efficiency.
• Any such control is limited and temporary, strictly tied to User instructions, and does not constitute a custodial relationship.
• By initiating a transaction, the User authorizes the Company to route funds through appropriate infrastructure, including Partner-operated systems.

Transaction Controls and Restrictions

The Company and/or its Partners may delay, suspend, restrict, or reject transactions, or limit access to the Services where necessary due to:

• Compliance requirements
• Suspected fraud or unauthorized activity
• Regulatory obligations
• Operational and risk considerations

The User acknowledges that:

• Certain actions affecting transactions or accounts may be initiated or required by third-party Partners, including regulated infrastructure providers such as Bridge.
• The Company may be obligated to enforce or reflect such decisions within the Services.
• The Company shall not be liable for actions taken by Partners, or any resulting delays, restrictions, or losses arising from such actions.

You represent and warrant that:

• You are not subject to sanctions or located in restricted jurisdictions.
• You will comply with all applicable laws, including AML, CTF, and sanctions regulations.

The Company may monitor activity and block or report transactions as required.