Effective Date: 29/09/2026
These Terms of Service (these “Terms”) govern your access to and use of NALA’s USD Global Account service (the “USD Global Account”, the “USD Wallet”, or the “Service”), which enables you to receive and hold United States Dollar (“USD”) value in a self-hosted digital wallet that you own and control, to send USD value to other NALA wallet holders, and to remit or pay out value by converting it into supported local currencies.
These Terms form a legally binding agreement between you and NALA (the “Agreement”). By creating, accessing, or using a USD Global Account, you confirm that you have read, understood, and agree to be bound by these Terms. If you do not agree to these Terms, you must not register for or use the Service.
Please read these Terms carefully and keep a copy for your records. They contain important information about your rights and obligations, including the self-custodial nature of your wallet and your control of it (Section 3), limitations on liability, the activities for which the Service may and may not be used, and how disputes are resolved.
The Service is provided by Nala Payments Canada Inc. (“NALA”, “we”, “us”, or “our”), a company incorporated under the laws of Canada / the Province of Ontario (corporation number 1000609102), with its registered office at 36 Toronto Street, Suite 850 Toronto ONTARIO M5C 2C5.
NALA is registered as a money services business (“MSB”) with the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (MSB registration number M233633667), including for the activity of dealing in virtual currency. NALA’s MSB registration is a compliance-based registration administered by FINTRAC.
NALA provides the Service to recipients in the jurisdictions we support, in partnership with licensed financial institutions and service providers (each a “Partner” and together the “Partners”), as further described below. NALA’s Canadian MSB registration does not substitute for any authorisations that may be required in any jurisdiction where the Service is offered; where the Service involves regulated activities in a particular jurisdiction (such as local-currency pay-ins or payouts), those activities are carried out by, or together with, locally authorised Partners. The Service is a fiat value-transfer and remittance product. As described in Sections 2 and 3, it uses a US-dollar-backed stablecoin (USDC) solely as a back-end settlement asset, and is accessed through a self-hosted, non-custodial digital wallet that you own and control.
NALA can be contacted by any of the following means:
Certain regulated and operational functions underlying the Service are performed by third-party service providers (each a “Partner” and together the “Partners”). These include:
We do not name our individual service providers in these Terms, and we may add, remove, or change Partners from time to time. Where a Partner provides a regulated service to you, that service may be governed by separate terms made available to you by, or on behalf of, that Partner (“Partner Terms”), which govern your direct relationship with the relevant Partner in respect of that regulated service.
In these Terms:
You expressly grant NALA a mandate to act on your behalf and in your name for the purpose of accessing and using the Service. Under this mandate, NALA is authorised to: (a) transmit your payment, conversion, and withdrawal instructions to the relevant Partner on your behalf; (b) receive and process information related to the execution of those instructions; and (c) perform any ancillary actions reasonably necessary to enable your use of the Service, within the limits of your instructions and applicable law. This mandate also constitutes your permission for NALA to provision and operate your Wallet on your behalf in order to provide the Service, acting only with the permissioned access you grant under these Terms, as described in Section 3, until you eject your Wallet or close your account. NALA exercises this permission as your agent for the operation of your own self-custodial Wallet and not as a custodian of your funds; NALA does not take custody of, or provide custody or safekeeping services in respect of, your Wallet or the value held in it.
This mandate remains in force for the duration of your contractual relationship with NALA. You may revoke it at any time by ejecting your Wallet (Section 3) or by closing your USD Wallet. Ejecting your Wallet ends NALA’s permission to provision or operate it; closing your USD Wallet additionally terminates these Terms in accordance with Section 20. Revocation does not affect any action lawfully taken before NALA received notice of revocation.
The USD Global Account is a payment facilitation and remittance product. It is not a bank account, it is not a deposit-taking product, and it is not a securities, investment, derivatives, or crypto-asset trading product. It is designed to enable: (a) the receipt of USD payments and value, including payments from third parties; (b) the holding of USD value in your Self-Hosted Wallet; (c) the sending of USD value to other NALA wallet holders; and (d) the conversion of that value into supported local currencies for remittance or payout to supported local channels.
Value is settled to your Wallet using USDC, a US-dollar-backed stablecoin that functions solely as a back-end settlement asset and is treated as equivalent to USD on a 1:1 basis. When value is sent to you, NALA credits your Wallet with USDC from its own funds so that your Wallet is funded promptly; the corresponding inbound USD is received by a Receiving Partner, and NALA separately converts USD into USDC, using one or more third-party providers, to maintain its balances. The NALA application displays your balance to you in USD, and you receive, hold, send, and pay out value on a USD basis. When you convert value into a local currency, NALA discloses the exchange rate that will apply before you confirm. You do not trade, and the Service does not enable you to trade, in USDC or any other crypto asset (see Section 13).
The value in your Wallet is held by you, under your control, on a self-custodial (non-custodial) basis, as described in Section 3. It does not constitute a deposit with NALA or with any Partner, it does not create a banking relationship between you and any underlying financial institution except as expressly set out in any applicable Partner Terms, and it does not represent a security, investment, or loan. You will not earn any interest, yield, or return on any value held in your Wallet.
When you register for the Service, and only with the permission you grant NALA as part of these Terms, NALA provisions a self-hosted digital wallet for you (the “Wallet”), including generating the Wallet’s cryptographic keys and public address and making the Wallet available to you through the NALA application. We provision and run the Wallet for you in this way so that you can use it through a simple, app-based experience without needing prior knowledge of crypto-assets or blockchain technology.
The Wallet is self-custodial (also called non-custodial): it belongs to you, the value held in it is yours, and you have the right to take sole and independent control of it at any time, as described below. NALA does not own the value in your Wallet and does not use your Wallet for its own account.
At any time, you may eject (export) your Wallet — including its keys and public address — directly from the NALA application, and take sole and independent control of it using compatible third-party wallet software, without NALA’s permission or involvement. Your right to eject your Wallet is the cornerstone of its self-custodial nature and of your control over your funds. Exercising this right is not a breach of these Terms.
Once you eject your Wallet, NALA no longer provisions, operates, or has any ability to access, move, or recover the value in it, and your use of the Wallet after ejection takes place outside the NALA Service and these Terms. If you eject your Wallet and use it outside the NALA Service, you do so entirely at your own risk and responsibility; that activity is not facilitated, monitored, or controlled by NALA, and NALA is not responsible for it.
Until you eject your Wallet, and in order to provide the app-based experience described above, you grant NALA and its wallet-infrastructure provider permissioned access to provision and manage the Wallet’s keys and to operate the Wallet on your behalf — acting only with the permission you grant under these Terms — including creating the Wallet, receiving settlement into it, and carrying out the conversions, transfers, and withdrawals that you initiate through the application (for example, moving value from your Wallet to fund a withdrawal you have requested). NALA operates your Wallet solely to provide the Service to you, acting only on the permissioned access you grant and in accordance with these Terms; it does not transact your Wallet for NALA’s own benefit. NALA exercises this permission as your agent for the operation of your own self-custodial Wallet and does not take custody of, or provide custody or safekeeping services in respect of, your Wallet or the value held in it. This arrangement is a convenience to you and does not change the self-custodial nature of your Wallet, your ownership of the value in it, or your right to eject the Wallet and assume sole control at any time.
For settlement purposes, the value in your Wallet is represented by USDC, a US-dollar-backed stablecoin that is designed to maintain a stable value at a 1:1 reference to the US dollar and is treated as equivalent to USD on a 1:1 basis. USDC is used solely as the settlement asset that allows USD value to be delivered to, held in, sent from, and paid out of your Wallet. The NALA application displays your balance to you in USD.
Neither your Wallet, the USDC settlement asset, nor your USD balance is a security, an investment contract, a derivative, a deposit, or an investment product, and none of them is offered or sold to you as such. You do not acquire, and the Service does not confer, any right to a profit, yield, return, dividend, or interest, and the value held in your Wallet is intended to remain stable rather than to appreciate. NALA does not provide, and the Service does not constitute, securities, derivatives, investment, advisory, brokerage, or crypto-asset trading services. Your relationship with NALA in respect of the Wallet is that of a user of a payment and remittance service, not an investor.
You are responsible for keeping your NALA credentials and device secure, and — once you have ejected your Wallet - for keeping your private keys and recovery information secure and backed up, and for not disclosing any of them to, or permitting their use by, any other person, entity, or software. After you eject your Wallet, NALA does not hold your private keys and cannot recover them, reset them, or restore access to your Wallet on your behalf, and loss or compromise of your keys or recovery information may result in the permanent and irreversible loss of the value in your Wallet. Further responsibilities and risks relating to your Wallet are set out in Sections 16 and 18.
To register for and use the Service, you must:
You must use the Service only for your own account and not on behalf of, or as agent for, any other person unless NALA has expressly authorised you to do so in writing. NALA may refuse access to the Service, or impose additional conditions, where required by law, regulation, the Partner Terms, or risk-management considerations.
Before you provide any personal information, please read our Privacy Notice carefully, available at https://www.nala.com/global-privacy-policy. The Privacy Notice explains how NALA collects, uses, retains, and protects your personal data, the lawful bases we rely on, your rights, and how to exercise them. By registering, you confirm that you have read the Privacy Notice and agree to be bound by these Terms.
To register, you must download the NALA mobile application, create your Wallet, and provide accurate, complete, and current information about yourself, including your name, telephone number, email address, and a photograph of a valid government-issued identification document, together with any other information or documentation we or our Partners require to verify your identity and your source of funds.
You authorise NALA and its Partners to verify your information using third-party services, including financial institutions, credit reference agencies, identity-verification providers, and your telephone service provider, for the purposes of verifying your identity and complying with applicable law. You agree to keep your information accurate and up to date at all times and to provide any additional information we reasonably request.
If you do not provide accurate and complete information, or if you fail to satisfy our verification requirements, we may refuse to open your USD Wallet, restrict or suspend your access to the Service, decline or hold a transaction, or terminate your access to the Service.
Upon registration you must create a password and, where supported by your device, you may enable biometric authentication (such as fingerprint or facial recognition). You must authenticate each time you access the Service.
You may receive USD value into your Wallet from approved senders and payment channels, including payments from third parties, and from other NALA wallet holders. When value is sent to you, NALA credits your Wallet with USDC and displays it to you as a USD balance, as described in Sections 2 and 12. NALA and its Partners may restrict, reject, return, or delay an incoming transfer, or request additional information before it is credited to your Wallet, where required to comply with applicable law, the Partner Terms, sanctions screening, or risk-management requirements.
To enable you to receive USD, including payments from third parties, the Receiving Partner issues you a US bank-issued virtual account (the “Virtual Account”), the details of which are made available to you within the NALA application. The Virtual Account is issued and operated by the Receiving Partner and is governed by the Receiving Partner’s terms; NALA is not the issuer of the Virtual Account and does not itself provide banking services. USD received into the Virtual Account is converted into USDC and credited to your Wallet as a USD balance, as described in Sections 2 and 12.
Where available in your jurisdiction, you may also top up your Wallet using a local-currency pay-in through a Collection Partner. The local currency you pay in is converted into USD value and credited to your Wallet as a USD balance; the applicable exchange rate and any fees are disclosed to you before you confirm the top-up.
You may use the USD value in your Wallet to: (a) send USD value to another NALA wallet holder; (b) remit value to a recipient by converting it into their local currency; and (c) pay out to a supported local payout channel (such as a bank account or mobile money wallet) by converting it into local currency. The USD value in your Wallet cannot be withdrawn to you as physical or bank US dollars; payouts to local channels are made in the applicable local currency. Before you confirm a transaction, you will be shown:
By confirming the transaction (for example, by pressing “Submit” or “Confirm”), you verify that this information is correct and you instruct and authorise NALA to transmit, and the relevant Partner to execute, the transfer, conversion, and/or payout from your Wallet. You may cancel a transaction before confirmation. Once a transaction has been confirmed and accepted for processing, you may not be able to stop, alter, recall, or reverse it, and your cancellation and refund rights are governed by Section 17 and any applicable Partner Terms.
Processing times may vary depending on the payout channel, the Partner, and operational and compliance requirements.
Although the Service is generally available 24 hours a day, 7 days a week, there may be times when it is unavailable, in whole or in part, due to NALA’s own acts (such as scheduled maintenance and upgrades) or events beyond NALA’s reasonable control, including power outages, telecommunications or network failures, failures or delays of Partners, payout channels, or underlying blockchain or settlement networks, natural disasters, war, civil unrest, pandemic, or other events of the kind described in Section 19. The Service is provided on an “as is” and “as available” basis, without any warranty of uninterrupted or error-free operation. Unavailability of the Service does not affect your continuing ownership and control of your Wallet.
Any USD balance shown in the NALA application represents the USD value held by you in your Self-Hosted Wallet (represented by USDC), net of applicable fees. Your balance:
The way value is settled to, held in, and withdrawn from your Wallet is described further in Section 12.
The exchange rate applicable to a conversion of your USD balance into a supported local currency will be displayed to you before you confirm the transaction. The rate may include a margin or spread retained by NALA and/or its Partners, and is determined by reference to prevailing market rates together with that margin.
Exchange rates fluctuate and may change between the time a rate is displayed and the time a transaction is confirmed. The rate shown at the point of confirmation is the rate that applies to your transaction. By confirming a transaction, you accept the displayed exchange rate and any applicable fees. NALA is not responsible for any loss arising from exchange rate movements, including movements occurring before you confirm a transaction or after a transaction has been executed.
NALA may charge fees for currency conversion, withdrawals, and other transactions or services connected with the Service. All applicable fees will be disclosed to you before you confirm the relevant transaction. Fees may depend on factors including the amount and frequency of your transactions, the payout channel, and your location.
Fees may change from time to time. Where fees change, the applicable fees will be shown to you before you confirm a transaction, and material changes will be notified to you in accordance with Section 22. A post-transaction receipt confirming the transaction details, fees, and exchange rate applied will be made available to you within the application.
NALA may set limits on the size, frequency, and aggregate value of transactions you may make through the Service and on the balance reflected in your Wallet through the application. Such limits may arise from legal, regulatory, contractual, policy, or operational requirements, including the Partner Terms and your level of identity verification, and may change from time to time. Applicable limits are displayed within the application.
NALA may delay, decline, hold, or refuse a transaction, or restrict your access to the Service, where NALA or a relevant Partner determines that doing so is necessary to comply with applicable law, regulation, sanctions, or policy, including AML/CFT and fraud-prevention requirements, or to manage risk. Because your Wallet is self-custodial, any such restriction affects your access to and use of the NALA Service; it does not transfer ownership or control of your Wallet to NALA. If you believe your access has been restricted in error, please contact us at support@nala.money or via the Mama NALA support feature.
When value is sent to you, NALA credits your Wallet with USDC drawn from its own funds. The corresponding inbound USD is received by a Receiving Partner, and NALA separately converts USD into USDC, using one or more third-party providers, to maintain its balances. These receipt and conversion functions are performed by NALA and its Partners and may be governed by the applicable Partner Terms and the laws applicable to those Partners. NALA does not take custody of the inbound USD as your money.
Once USDC is settled to your Wallet, the resulting value is held in your self-custodial Wallet, as described in Section 3. While you use the Service, NALA operates your Wallet on your behalf, and provisions and manages its keys; nevertheless, the Wallet remains yours, and you may eject it and take sole control of it at any time. NALA does not hold the value in your Wallet as a deposit or as a balance on its own books, and does not operate pooled or segregated customer-money or e-money accounts in respect of value that has been settled to your Wallet.
Because the value is held in your own self-custodial Wallet, which you can eject and control independently at any time, it is intended to remain yours rather than to form part of NALA’s general assets. You bear the responsibilities and risks of self-custody, as set out in Sections 16 and 18. NALA does not guarantee that the value in your Wallet is protected by any deposit insurance or deposit protection scheme.
The Service is designed and operated as a fiat value-transfer and remittance product. USDC is used solely as a back-end settlement asset, and the Self-Hosted Wallet is part of the Service’s design. Creating and using your Wallet for the purpose of receiving, holding, and withdrawing USD value through the Service, and exercising your right to export your keys under Section 3, are permitted and are not prohibited activities.
A “Virtual Asset” means any cryptocurrency, crypto-asset, digital token, Stablecoin, or other digital representation of value (other than the USDC settlement asset used by the Service as described in these Terms) that can be traded or transferred and used for payment or investment purposes.
You must not use the Service, the NALA application, or your Wallet while it is connected to the Service to:
NALA does not provide and the Service does not enable crypto-asset trading, exchange, brokerage, custody, or investment services, and the Service must not be used for such purposes. NALA reserves the right to decline, block, reverse, or investigate any transaction, and to request information and supporting documentation, where it reasonably suspects use of the Service for a prohibited activity, and to suspend or terminate your access to the Service in accordance with Section 20.
NALA and its Partners may monitor your transactions and activity through the Service to comply with applicable law and regulatory obligations, including AML/CFT, sanctions, and fraud-prevention requirements in Canada and in any other jurisdiction relevant to a transaction.
You agree to cooperate promptly with any request for additional information or documentation, including in relation to your identity, source of funds, or the purpose of a transaction. NALA may delay, block, hold, or refuse a transaction, restrict your access to the Service, or report activity to competent authorities where it considers this necessary to comply with legal or regulatory obligations or to manage financial-crime risk. Where permitted by law, NALA may be unable to inform you of the reason for such action.
Your access to the Service and your registration are personal to you and must not be shared with anyone else. If you suspect fraud on your account, or that your registration details, security credentials, or private keys have been lost, stolen, or compromised, you must contact us immediately at support@nala.money and take steps to secure your Wallet.
You authorise NALA to monitor and analyse your activity through the Service and to detect, predict, prevent, and report fraud and other suspicious activity. Where NALA’s analysis indicates a likelihood of fraud or financially risky behaviour, you authorise NALA to take action permitted by law, including suspending or declining transactions and the transmission of instructions. Where NALA suspects fraudulent activity, it may share the minimum personal data necessary with the relevant Partner or with fraud-prevention agencies and competent authorities to investigate or prevent it.
You agree to use the Service only for lawful purposes and in compliance with these Terms and all applicable laws. You must provide accurate and truthful information at all times and must not use, or attempt to use, the Service to engage in fraud, money laundering, terrorist financing, sanctions evasion, prohibited Virtual Asset activity (Section 13), or any other illegal or prohibited activity.
You are responsible for maintaining the confidentiality and security of your account credentials and device and, once you have ejected your Wallet, your private keys and recovery information, including keeping a secure backup of your recovery information and not disclosing your credentials or keys to, or permitting their use by, any other person. You acknowledge that, after you eject your Wallet, NALA does not hold your private keys and cannot recover them or restore access to your Wallet, and that loss or compromise of your keys or recovery information may result in the permanent and irreversible loss of the value in your Wallet. You must notify NALA immediately if you suspect unauthorised access to, or fraudulent activity affecting, your Wallet or your use of the Service. NALA may suspend your access to the Service to protect you and the integrity of the Service in accordance with these Terms.
You represent and warrant that all information you provide to NALA is true, complete, and accurate, including information about you, your payout method, and your Beneficiary. NALA and its Partners may rely on the information you provide, and any errors—including misidentification of a Beneficiary, incorrect account or wallet numbers, or misspellings—are your responsibility.
If a transaction cannot be completed, or is mis-directed, because you provided incorrect Beneficiary or payout information, you will be liable for any reasonable costs, fees, and losses NALA or its Partners incur in attempting to recover or return the funds to you, including processing costs, exchange-rate losses, and third-party charges.
Because payouts are typically credited to Beneficiaries promptly, a transaction may not be cancellable or refundable once confirmed. If you believe you have made a transaction in error, you must contact us as soon as possible, and in any event within thirty (30) minutes, at support@nala.money. We will attempt to recall the transaction but may be unable to do so if the funds have already been credited to, or withdrawn by, the Beneficiary. If the transaction has not yet been paid out, NALA will cancel it and the corresponding value will remain in your Wallet.
If you believe there has been an error in a transaction, you have the right to dispute it at no charge. You must contact us promptly, providing your name, contact details, the Beneficiary’s name, the date and amount of the transaction, and the reason you believe an error occurred. NALA will investigate and respond within a reasonable period and, where NALA or a relevant Partner was at fault, you will be entitled to have the transaction corrected or re-processed free of charge. Where the relevant function was performed by a Partner, your rights in respect of incorrect or unauthorised payments are as set out in the applicable Partner Terms and under applicable law, and are not assumed by NALA. NALA is not responsible for transactions you authorise and initiate from your Wallet using your own private keys, including transactions made outside the NALA Service.
By using the Service, you acknowledge and accept the following risks, among others:
The Service is provided on an “as is” and “as available” basis without any guarantee of uninterrupted or error-free operation.
You agree to indemnify and hold NALA harmless from and against any claims, losses, liabilities, costs, or expenses arising from or in connection with: (a) your use of the Service; (b) your breach of these Terms or of applicable law; (c) NALA acting upon your instructions or transmitting your instructions to a Partner; or (d) your management or use of your Wallet and private keys, including any loss of keys or any activity you conduct outside the NALA Service.
NALA shall not be liable for any indirect, incidental, consequential, special, or punitive losses arising from your use of the Service. Without limiting the foregoing, NALA is not responsible for: the execution, cancellation, recall, or refund of payments, conversions, or payouts performed by a Partner; any errors, delays, or losses in connection with the services provided by a Partner, a payout channel, a correspondent institution, or any blockchain or settlement network; the loss, theft, or compromise of your private keys or recovery information; or any value lost as a result of your own management of, or activity conducted from, your self-custodial Wallet—except, in each case, to the extent caused by NALA’s own negligence, fraud, or wilful misconduct.
NALA shall not be liable for any failure or delay in the performance of its obligations under these Terms arising from or attributable to circumstances beyond its reasonable control (“force majeure”), including: acts of God, fire, flood, earthquake, or natural disaster; war, armed conflict, sanctions, embargo, or breaking off of diplomatic relations; terrorist attack, civil war, civil commotion, or riots; pandemic or epidemic; industrial disputes; disruptions to transportation, telecommunications, power supply, or other utilities; acts, legislation, or restrictions imposed by any government, regulator, or state; the acts or omissions of third parties, including Partners, payout channels, and blockchain or settlement networks; or malicious code interfering with the Service.
Nothing in these Terms limits or excludes any liability that cannot be limited or excluded under applicable law, including liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or any of your statutory rights that apply and cannot lawfully be excluded.
NALA may suspend or terminate your access to the Service, in whole or in part, and with immediate effect where necessary, if: you breach these Terms; suspicious, fraudulent, or prohibited activity (including prohibited Virtual Asset activity under Section 13) is detected or reasonably suspected; you fail to satisfy verification or information requests; or suspension or termination is required by law, regulation, a competent authority, or a Partner. Where reasonably practicable and permitted by law, NALA will give you notice; otherwise NALA may act without prior notice and notify you afterwards.
Because your Wallet is self-custodial, suspension or termination affects your access to and use of the NALA Service and application; it does not transfer ownership of your Wallet or the value held in it to NALA. Even where NALA suspends or terminates the Service, you retain the right to eject your Wallet under Section 3 and to take sole and independent control of it and of the value held in it.
You may close your USD Wallet and terminate these Terms at any time by contacting support@nala.money or using the in-app facility. Termination does not relieve you of any obligation to pay fees or costs accrued before termination, and does not affect any pending transaction, which will be completed in accordance with these Terms and any applicable Partner Terms. NALA may withhold or delay processing of an instruction to the extent required to comply with applicable law or to manage risk.
If your use of the Service remains inactive for a continuous period of 12 months, NALA may classify your account as dormant. NALA will handle dormant accounts in accordance with applicable law in Canada and the applicable Partner Terms, which may include notifying you, restricting access through the application, and charging applicable dormancy fees. Because your Wallet is self-custodial, dormancy of your NALA account does not affect your ownership or control of your Wallet, which you may continue to access using your private keys. NALA will use reasonable efforts to contact you using the most recent contact details you have provided before taking such action.
These Terms are effective from the point you accept them and continue for an indefinite period until terminated by you or by NALA in accordance with these Terms.
NALA may amend these Terms from time to time to reflect changes to the Service, its Partners, fees, or legal or regulatory requirements. For material amendments - meaning changes that affect how we process your personal data, your rights under these Terms, or the key features of the Service - we will give you reasonable advance notice (and any minimum notice required by applicable law) by email or prominent in-app notification before the changes take effect. Minor amendments, such as corrections to contact details, formatting changes, or updates to hyperlinks, may take effect immediately.
You will be deemed to have accepted any change unless you close your USD Wallet and stop using the Service before the change takes effect. If you do not agree to a change, you may terminate these Terms free of charge before its effective date in accordance with Section 20.
NALA processes your personal data in its capacity as a data controller in accordance with applicable data protection law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada and applicable data protection laws in the jurisdictions in which the Service is offered. Full details of how NALA collects, uses, retains, shares, and protects your personal data, the lawful bases relied upon, and your rights (including rights of access, rectification, and, where applicable, erasure and objection) are set out in the NALA Privacy Notice at https://www.nala.com/privacy-policy.
You must keep your personal information accurate and up to date by contacting us at support@nala.money. Failure to do so may result in us being unable to contact you about your account or to provide the Service. Nothing in these Terms limits or excludes your rights under applicable data protection law.
NALA is committed to treating customers fairly and to delivering good outcomes, including for customers who may be in vulnerable circumstances. We aim to ensure that the Service is appropriately designed for its intended customers, that fees are fair and clearly disclosed, that the information we provide is clear, fair, and not misleading, and that appropriate support is available throughout your use of the Service.
If at any time you require additional support—for example, because of a disability, illness, language need, or other personal circumstance—please contact us at support@nala.money and we will endeavour to accommodate your needs.
Access to the Service requires the NALA mobile application. NALA grants you a non-exclusive, non-transferable, revocable licence to use the application on a device owned or controlled by you, solely for your personal use of the Service and in accordance with these Terms and any applicable app-store terms. You may incur data or other charges from your network provider, for which you are solely responsible.
You must not: (a) modify, adapt, translate, reverse engineer, decompile, or disassemble the application except to the extent permitted by law; (b) rent, lease, lend, sell, sublicense, or otherwise transfer the application; (c) remove or alter any proprietary notices; or (d) circumvent, disable, or interfere with any security or access-control features of the application. All intellectual property rights in the Service, the application, and the NALA name and marks remain the property of NALA or its licensors. For the avoidance of doubt, this licence relates to the application; your Wallet and its private keys remain owned and controlled by you.
No failure or delay by either party to exercise any right or remedy under these Terms or by law shall constitute a waiver of that or any other right or remedy, nor shall any single or partial exercise prevent or restrict the further exercise of that or any other right or remedy. The rights and remedies under these Terms are in addition to, and not exclusive of, any rights or remedies provided by law.
These Terms (together with the documents referred to in them) constitute the entire agreement between you and NALA in relation to the Service and supersede all prior agreements, arrangements, and understandings relating to the same subject matter. Your relationship with each Partner in respect of a regulated service is governed by the applicable Partner Terms. In the event of any conflict between these Terms and the Partner Terms, the Partner Terms shall prevail to the extent the conflict relates to the regulated service provided by that Partner.
If any provision or part-provision of these Terms is or becomes invalid, illegal, or unenforceable, it shall be deemed deleted, but that shall not affect the validity and enforceability of the rest of these Terms.
Nothing in these Terms is intended to, or shall be deemed to, establish any partnership or joint venture between you and NALA, and you agree not to use the Service on behalf of, or as agent for, any other person except as expressly permitted. A person who is not a party to these Terms shall have no right to enforce any of their provisions, except that a Partner may enforce any provision that expressly benefits it.
You may not assign or transfer any of your rights or obligations under these Terms without NALA’s prior written consent. NALA may assign or transfer its rights and obligations under these Terms to an affiliate or successor, or in connection with a reorganisation, merger, or transfer of business, provided this does not materially reduce your rights under these Terms.
These Terms, and any dispute or claim arising out of or in connection with them or their subject matter (including non-contractual disputes or claims), are governed by, and shall be construed in accordance with, the laws of the Province of Ontario and the federal laws of Canada applicable therein, and are subject to the [non-exclusive] jurisdiction of the courts of the Province of Ontario, Canada, without prejudice to any mandatory rights or consumer protections available to you under the laws of your country of residence.
If you have a complaint about the Service, please contact NALA in the first instance at support@nala.money, providing details of your complaint and your account so we can investigate. We will acknowledge and investigate your complaint and provide a response within the period required by applicable law or our complaints policy. Where your complaint relates to a regulated service provided by a Partner, NALA will direct it to the relevant Partner for handling in accordance with that Partner’s complaints procedure. If you remain dissatisfied with our final response, you may be entitled to escalate your complaint to the applicable Canadian complaints body or regulator such as the Financial Consumer Agency of Canada (FCAC) (www.canada.ca/en/financial-consumer-agency; 1-866-461-3222).
If you have any questions about these Terms or require support, you may contact NALA through the in-app chat feature (Mama NALA), by email at support@nala.money, or via the support channels provided within the application or on the NALA website at www.nala.com.
Effective Date: 29/09/2026
These Terms of Service (these “Terms”) govern your access to and use of NALA’s USD Global Account service (the “USD Global Account”, the “USD Wallet”, or the “Service”), which enables you to receive and hold United States Dollar (“USD”) value in a self-hosted digital wallet that you own and control, to send USD value to other NALA wallet holders, and to remit or pay out value by converting it into supported local currencies.
These Terms form a legally binding agreement between you and NALA (the “Agreement”). By creating, accessing, or using a USD Global Account, you confirm that you have read, understood, and agree to be bound by these Terms. If you do not agree to these Terms, you must not register for or use the Service.
Please read these Terms carefully and keep a copy for your records. They contain important information about your rights and obligations, including the self-custodial nature of your wallet and your control of it (Section 3), limitations on liability, the activities for which the Service may and may not be used, and how disputes are resolved.
The Service is provided by Nala Payments Canada Inc. (“NALA”, “we”, “us”, or “our”), a company incorporated under the laws of Canada / the Province of Ontario (corporation number 1000609102), with its registered office at 36 Toronto Street, Suite 850 Toronto ONTARIO M5C 2C5.
NALA is registered as a money services business (“MSB”) with the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (MSB registration number M233633667), including for the activity of dealing in virtual currency. NALA’s MSB registration is a compliance-based registration administered by FINTRAC.
NALA provides the Service to recipients in the jurisdictions we support, in partnership with licensed financial institutions and service providers (each a “Partner” and together the “Partners”), as further described below. NALA’s Canadian MSB registration does not substitute for any authorisations that may be required in any jurisdiction where the Service is offered; where the Service involves regulated activities in a particular jurisdiction (such as local-currency pay-ins or payouts), those activities are carried out by, or together with, locally authorised Partners. The Service is a fiat value-transfer and remittance product. As described in Sections 2 and 3, it uses a US-dollar-backed stablecoin (USDC) solely as a back-end settlement asset, and is accessed through a self-hosted, non-custodial digital wallet that you own and control.
NALA can be contacted by any of the following means:
Certain regulated and operational functions underlying the Service are performed by third-party service providers (each a “Partner” and together the “Partners”). These include:
We do not name our individual service providers in these Terms, and we may add, remove, or change Partners from time to time. Where a Partner provides a regulated service to you, that service may be governed by separate terms made available to you by, or on behalf of, that Partner (“Partner Terms”), which govern your direct relationship with the relevant Partner in respect of that regulated service.
In these Terms:
You expressly grant NALA a mandate to act on your behalf and in your name for the purpose of accessing and using the Service. Under this mandate, NALA is authorised to: (a) transmit your payment, conversion, and withdrawal instructions to the relevant Partner on your behalf; (b) receive and process information related to the execution of those instructions; and (c) perform any ancillary actions reasonably necessary to enable your use of the Service, within the limits of your instructions and applicable law. This mandate also constitutes your permission for NALA to provision and operate your Wallet on your behalf in order to provide the Service, acting only with the permissioned access you grant under these Terms, as described in Section 3, until you eject your Wallet or close your account. NALA exercises this permission as your agent for the operation of your own self-custodial Wallet and not as a custodian of your funds; NALA does not take custody of, or provide custody or safekeeping services in respect of, your Wallet or the value held in it.
This mandate remains in force for the duration of your contractual relationship with NALA. You may revoke it at any time by ejecting your Wallet (Section 3) or by closing your USD Wallet. Ejecting your Wallet ends NALA’s permission to provision or operate it; closing your USD Wallet additionally terminates these Terms in accordance with Section 20. Revocation does not affect any action lawfully taken before NALA received notice of revocation.
The USD Global Account is a payment facilitation and remittance product. It is not a bank account, it is not a deposit-taking product, and it is not a securities, investment, derivatives, or crypto-asset trading product. It is designed to enable: (a) the receipt of USD payments and value, including payments from third parties; (b) the holding of USD value in your Self-Hosted Wallet; (c) the sending of USD value to other NALA wallet holders; and (d) the conversion of that value into supported local currencies for remittance or payout to supported local channels.
Value is settled to your Wallet using USDC, a US-dollar-backed stablecoin that functions solely as a back-end settlement asset and is treated as equivalent to USD on a 1:1 basis. When value is sent to you, NALA credits your Wallet with USDC from its own funds so that your Wallet is funded promptly; the corresponding inbound USD is received by a Receiving Partner, and NALA separately converts USD into USDC, using one or more third-party providers, to maintain its balances. The NALA application displays your balance to you in USD, and you receive, hold, send, and pay out value on a USD basis. When you convert value into a local currency, NALA discloses the exchange rate that will apply before you confirm. You do not trade, and the Service does not enable you to trade, in USDC or any other crypto asset (see Section 13).
The value in your Wallet is held by you, under your control, on a self-custodial (non-custodial) basis, as described in Section 3. It does not constitute a deposit with NALA or with any Partner, it does not create a banking relationship between you and any underlying financial institution except as expressly set out in any applicable Partner Terms, and it does not represent a security, investment, or loan. You will not earn any interest, yield, or return on any value held in your Wallet.
When you register for the Service, and only with the permission you grant NALA as part of these Terms, NALA provisions a self-hosted digital wallet for you (the “Wallet”), including generating the Wallet’s cryptographic keys and public address and making the Wallet available to you through the NALA application. We provision and run the Wallet for you in this way so that you can use it through a simple, app-based experience without needing prior knowledge of crypto-assets or blockchain technology.
The Wallet is self-custodial (also called non-custodial): it belongs to you, the value held in it is yours, and you have the right to take sole and independent control of it at any time, as described below. NALA does not own the value in your Wallet and does not use your Wallet for its own account.
At any time, you may eject (export) your Wallet — including its keys and public address — directly from the NALA application, and take sole and independent control of it using compatible third-party wallet software, without NALA’s permission or involvement. Your right to eject your Wallet is the cornerstone of its self-custodial nature and of your control over your funds. Exercising this right is not a breach of these Terms.
Once you eject your Wallet, NALA no longer provisions, operates, or has any ability to access, move, or recover the value in it, and your use of the Wallet after ejection takes place outside the NALA Service and these Terms. If you eject your Wallet and use it outside the NALA Service, you do so entirely at your own risk and responsibility; that activity is not facilitated, monitored, or controlled by NALA, and NALA is not responsible for it.
Until you eject your Wallet, and in order to provide the app-based experience described above, you grant NALA and its wallet-infrastructure provider permissioned access to provision and manage the Wallet’s keys and to operate the Wallet on your behalf — acting only with the permission you grant under these Terms — including creating the Wallet, receiving settlement into it, and carrying out the conversions, transfers, and withdrawals that you initiate through the application (for example, moving value from your Wallet to fund a withdrawal you have requested). NALA operates your Wallet solely to provide the Service to you, acting only on the permissioned access you grant and in accordance with these Terms; it does not transact your Wallet for NALA’s own benefit. NALA exercises this permission as your agent for the operation of your own self-custodial Wallet and does not take custody of, or provide custody or safekeeping services in respect of, your Wallet or the value held in it. This arrangement is a convenience to you and does not change the self-custodial nature of your Wallet, your ownership of the value in it, or your right to eject the Wallet and assume sole control at any time.
For settlement purposes, the value in your Wallet is represented by USDC, a US-dollar-backed stablecoin that is designed to maintain a stable value at a 1:1 reference to the US dollar and is treated as equivalent to USD on a 1:1 basis. USDC is used solely as the settlement asset that allows USD value to be delivered to, held in, sent from, and paid out of your Wallet. The NALA application displays your balance to you in USD.
Neither your Wallet, the USDC settlement asset, nor your USD balance is a security, an investment contract, a derivative, a deposit, or an investment product, and none of them is offered or sold to you as such. You do not acquire, and the Service does not confer, any right to a profit, yield, return, dividend, or interest, and the value held in your Wallet is intended to remain stable rather than to appreciate. NALA does not provide, and the Service does not constitute, securities, derivatives, investment, advisory, brokerage, or crypto-asset trading services. Your relationship with NALA in respect of the Wallet is that of a user of a payment and remittance service, not an investor.
You are responsible for keeping your NALA credentials and device secure, and — once you have ejected your Wallet - for keeping your private keys and recovery information secure and backed up, and for not disclosing any of them to, or permitting their use by, any other person, entity, or software. After you eject your Wallet, NALA does not hold your private keys and cannot recover them, reset them, or restore access to your Wallet on your behalf, and loss or compromise of your keys or recovery information may result in the permanent and irreversible loss of the value in your Wallet. Further responsibilities and risks relating to your Wallet are set out in Sections 16 and 18.
To register for and use the Service, you must:
You must use the Service only for your own account and not on behalf of, or as agent for, any other person unless NALA has expressly authorised you to do so in writing. NALA may refuse access to the Service, or impose additional conditions, where required by law, regulation, the Partner Terms, or risk-management considerations.
Before you provide any personal information, please read our Privacy Notice carefully, available at https://www.nala.com/global-privacy-policy. The Privacy Notice explains how NALA collects, uses, retains, and protects your personal data, the lawful bases we rely on, your rights, and how to exercise them. By registering, you confirm that you have read the Privacy Notice and agree to be bound by these Terms.
To register, you must download the NALA mobile application, create your Wallet, and provide accurate, complete, and current information about yourself, including your name, telephone number, email address, and a photograph of a valid government-issued identification document, together with any other information or documentation we or our Partners require to verify your identity and your source of funds.
You authorise NALA and its Partners to verify your information using third-party services, including financial institutions, credit reference agencies, identity-verification providers, and your telephone service provider, for the purposes of verifying your identity and complying with applicable law. You agree to keep your information accurate and up to date at all times and to provide any additional information we reasonably request.
If you do not provide accurate and complete information, or if you fail to satisfy our verification requirements, we may refuse to open your USD Wallet, restrict or suspend your access to the Service, decline or hold a transaction, or terminate your access to the Service.
Upon registration you must create a password and, where supported by your device, you may enable biometric authentication (such as fingerprint or facial recognition). You must authenticate each time you access the Service.
You may receive USD value into your Wallet from approved senders and payment channels, including payments from third parties, and from other NALA wallet holders. When value is sent to you, NALA credits your Wallet with USDC and displays it to you as a USD balance, as described in Sections 2 and 12. NALA and its Partners may restrict, reject, return, or delay an incoming transfer, or request additional information before it is credited to your Wallet, where required to comply with applicable law, the Partner Terms, sanctions screening, or risk-management requirements.
To enable you to receive USD, including payments from third parties, the Receiving Partner issues you a US bank-issued virtual account (the “Virtual Account”), the details of which are made available to you within the NALA application. The Virtual Account is issued and operated by the Receiving Partner and is governed by the Receiving Partner’s terms; NALA is not the issuer of the Virtual Account and does not itself provide banking services. USD received into the Virtual Account is converted into USDC and credited to your Wallet as a USD balance, as described in Sections 2 and 12.
Where available in your jurisdiction, you may also top up your Wallet using a local-currency pay-in through a Collection Partner. The local currency you pay in is converted into USD value and credited to your Wallet as a USD balance; the applicable exchange rate and any fees are disclosed to you before you confirm the top-up.
You may use the USD value in your Wallet to: (a) send USD value to another NALA wallet holder; (b) remit value to a recipient by converting it into their local currency; and (c) pay out to a supported local payout channel (such as a bank account or mobile money wallet) by converting it into local currency. The USD value in your Wallet cannot be withdrawn to you as physical or bank US dollars; payouts to local channels are made in the applicable local currency. Before you confirm a transaction, you will be shown:
By confirming the transaction (for example, by pressing “Submit” or “Confirm”), you verify that this information is correct and you instruct and authorise NALA to transmit, and the relevant Partner to execute, the transfer, conversion, and/or payout from your Wallet. You may cancel a transaction before confirmation. Once a transaction has been confirmed and accepted for processing, you may not be able to stop, alter, recall, or reverse it, and your cancellation and refund rights are governed by Section 17 and any applicable Partner Terms.
Processing times may vary depending on the payout channel, the Partner, and operational and compliance requirements.
Although the Service is generally available 24 hours a day, 7 days a week, there may be times when it is unavailable, in whole or in part, due to NALA’s own acts (such as scheduled maintenance and upgrades) or events beyond NALA’s reasonable control, including power outages, telecommunications or network failures, failures or delays of Partners, payout channels, or underlying blockchain or settlement networks, natural disasters, war, civil unrest, pandemic, or other events of the kind described in Section 19. The Service is provided on an “as is” and “as available” basis, without any warranty of uninterrupted or error-free operation. Unavailability of the Service does not affect your continuing ownership and control of your Wallet.
Any USD balance shown in the NALA application represents the USD value held by you in your Self-Hosted Wallet (represented by USDC), net of applicable fees. Your balance:
The way value is settled to, held in, and withdrawn from your Wallet is described further in Section 12.
The exchange rate applicable to a conversion of your USD balance into a supported local currency will be displayed to you before you confirm the transaction. The rate may include a margin or spread retained by NALA and/or its Partners, and is determined by reference to prevailing market rates together with that margin.
Exchange rates fluctuate and may change between the time a rate is displayed and the time a transaction is confirmed. The rate shown at the point of confirmation is the rate that applies to your transaction. By confirming a transaction, you accept the displayed exchange rate and any applicable fees. NALA is not responsible for any loss arising from exchange rate movements, including movements occurring before you confirm a transaction or after a transaction has been executed.
NALA may charge fees for currency conversion, withdrawals, and other transactions or services connected with the Service. All applicable fees will be disclosed to you before you confirm the relevant transaction. Fees may depend on factors including the amount and frequency of your transactions, the payout channel, and your location.
Fees may change from time to time. Where fees change, the applicable fees will be shown to you before you confirm a transaction, and material changes will be notified to you in accordance with Section 22. A post-transaction receipt confirming the transaction details, fees, and exchange rate applied will be made available to you within the application.
NALA may set limits on the size, frequency, and aggregate value of transactions you may make through the Service and on the balance reflected in your Wallet through the application. Such limits may arise from legal, regulatory, contractual, policy, or operational requirements, including the Partner Terms and your level of identity verification, and may change from time to time. Applicable limits are displayed within the application.
NALA may delay, decline, hold, or refuse a transaction, or restrict your access to the Service, where NALA or a relevant Partner determines that doing so is necessary to comply with applicable law, regulation, sanctions, or policy, including AML/CFT and fraud-prevention requirements, or to manage risk. Because your Wallet is self-custodial, any such restriction affects your access to and use of the NALA Service; it does not transfer ownership or control of your Wallet to NALA. If you believe your access has been restricted in error, please contact us at support@nala.money or via the Mama NALA support feature.
When value is sent to you, NALA credits your Wallet with USDC drawn from its own funds. The corresponding inbound USD is received by a Receiving Partner, and NALA separately converts USD into USDC, using one or more third-party providers, to maintain its balances. These receipt and conversion functions are performed by NALA and its Partners and may be governed by the applicable Partner Terms and the laws applicable to those Partners. NALA does not take custody of the inbound USD as your money.
Once USDC is settled to your Wallet, the resulting value is held in your self-custodial Wallet, as described in Section 3. While you use the Service, NALA operates your Wallet on your behalf, and provisions and manages its keys; nevertheless, the Wallet remains yours, and you may eject it and take sole control of it at any time. NALA does not hold the value in your Wallet as a deposit or as a balance on its own books, and does not operate pooled or segregated customer-money or e-money accounts in respect of value that has been settled to your Wallet.
Because the value is held in your own self-custodial Wallet, which you can eject and control independently at any time, it is intended to remain yours rather than to form part of NALA’s general assets. You bear the responsibilities and risks of self-custody, as set out in Sections 16 and 18. NALA does not guarantee that the value in your Wallet is protected by any deposit insurance or deposit protection scheme.
The Service is designed and operated as a fiat value-transfer and remittance product. USDC is used solely as a back-end settlement asset, and the Self-Hosted Wallet is part of the Service’s design. Creating and using your Wallet for the purpose of receiving, holding, and withdrawing USD value through the Service, and exercising your right to export your keys under Section 3, are permitted and are not prohibited activities.
A “Virtual Asset” means any cryptocurrency, crypto-asset, digital token, Stablecoin, or other digital representation of value (other than the USDC settlement asset used by the Service as described in these Terms) that can be traded or transferred and used for payment or investment purposes.
You must not use the Service, the NALA application, or your Wallet while it is connected to the Service to:
NALA does not provide and the Service does not enable crypto-asset trading, exchange, brokerage, custody, or investment services, and the Service must not be used for such purposes. NALA reserves the right to decline, block, reverse, or investigate any transaction, and to request information and supporting documentation, where it reasonably suspects use of the Service for a prohibited activity, and to suspend or terminate your access to the Service in accordance with Section 20.
NALA and its Partners may monitor your transactions and activity through the Service to comply with applicable law and regulatory obligations, including AML/CFT, sanctions, and fraud-prevention requirements in Canada and in any other jurisdiction relevant to a transaction.
You agree to cooperate promptly with any request for additional information or documentation, including in relation to your identity, source of funds, or the purpose of a transaction. NALA may delay, block, hold, or refuse a transaction, restrict your access to the Service, or report activity to competent authorities where it considers this necessary to comply with legal or regulatory obligations or to manage financial-crime risk. Where permitted by law, NALA may be unable to inform you of the reason for such action.
Your access to the Service and your registration are personal to you and must not be shared with anyone else. If you suspect fraud on your account, or that your registration details, security credentials, or private keys have been lost, stolen, or compromised, you must contact us immediately at support@nala.money and take steps to secure your Wallet.
You authorise NALA to monitor and analyse your activity through the Service and to detect, predict, prevent, and report fraud and other suspicious activity. Where NALA’s analysis indicates a likelihood of fraud or financially risky behaviour, you authorise NALA to take action permitted by law, including suspending or declining transactions and the transmission of instructions. Where NALA suspects fraudulent activity, it may share the minimum personal data necessary with the relevant Partner or with fraud-prevention agencies and competent authorities to investigate or prevent it.
You agree to use the Service only for lawful purposes and in compliance with these Terms and all applicable laws. You must provide accurate and truthful information at all times and must not use, or attempt to use, the Service to engage in fraud, money laundering, terrorist financing, sanctions evasion, prohibited Virtual Asset activity (Section 13), or any other illegal or prohibited activity.
You are responsible for maintaining the confidentiality and security of your account credentials and device and, once you have ejected your Wallet, your private keys and recovery information, including keeping a secure backup of your recovery information and not disclosing your credentials or keys to, or permitting their use by, any other person. You acknowledge that, after you eject your Wallet, NALA does not hold your private keys and cannot recover them or restore access to your Wallet, and that loss or compromise of your keys or recovery information may result in the permanent and irreversible loss of the value in your Wallet. You must notify NALA immediately if you suspect unauthorised access to, or fraudulent activity affecting, your Wallet or your use of the Service. NALA may suspend your access to the Service to protect you and the integrity of the Service in accordance with these Terms.
You represent and warrant that all information you provide to NALA is true, complete, and accurate, including information about you, your payout method, and your Beneficiary. NALA and its Partners may rely on the information you provide, and any errors—including misidentification of a Beneficiary, incorrect account or wallet numbers, or misspellings—are your responsibility.
If a transaction cannot be completed, or is mis-directed, because you provided incorrect Beneficiary or payout information, you will be liable for any reasonable costs, fees, and losses NALA or its Partners incur in attempting to recover or return the funds to you, including processing costs, exchange-rate losses, and third-party charges.
Because payouts are typically credited to Beneficiaries promptly, a transaction may not be cancellable or refundable once confirmed. If you believe you have made a transaction in error, you must contact us as soon as possible, and in any event within thirty (30) minutes, at support@nala.money. We will attempt to recall the transaction but may be unable to do so if the funds have already been credited to, or withdrawn by, the Beneficiary. If the transaction has not yet been paid out, NALA will cancel it and the corresponding value will remain in your Wallet.
If you believe there has been an error in a transaction, you have the right to dispute it at no charge. You must contact us promptly, providing your name, contact details, the Beneficiary’s name, the date and amount of the transaction, and the reason you believe an error occurred. NALA will investigate and respond within a reasonable period and, where NALA or a relevant Partner was at fault, you will be entitled to have the transaction corrected or re-processed free of charge. Where the relevant function was performed by a Partner, your rights in respect of incorrect or unauthorised payments are as set out in the applicable Partner Terms and under applicable law, and are not assumed by NALA. NALA is not responsible for transactions you authorise and initiate from your Wallet using your own private keys, including transactions made outside the NALA Service.
By using the Service, you acknowledge and accept the following risks, among others:
The Service is provided on an “as is” and “as available” basis without any guarantee of uninterrupted or error-free operation.
You agree to indemnify and hold NALA harmless from and against any claims, losses, liabilities, costs, or expenses arising from or in connection with: (a) your use of the Service; (b) your breach of these Terms or of applicable law; (c) NALA acting upon your instructions or transmitting your instructions to a Partner; or (d) your management or use of your Wallet and private keys, including any loss of keys or any activity you conduct outside the NALA Service.
NALA shall not be liable for any indirect, incidental, consequential, special, or punitive losses arising from your use of the Service. Without limiting the foregoing, NALA is not responsible for: the execution, cancellation, recall, or refund of payments, conversions, or payouts performed by a Partner; any errors, delays, or losses in connection with the services provided by a Partner, a payout channel, a correspondent institution, or any blockchain or settlement network; the loss, theft, or compromise of your private keys or recovery information; or any value lost as a result of your own management of, or activity conducted from, your self-custodial Wallet—except, in each case, to the extent caused by NALA’s own negligence, fraud, or wilful misconduct.
NALA shall not be liable for any failure or delay in the performance of its obligations under these Terms arising from or attributable to circumstances beyond its reasonable control (“force majeure”), including: acts of God, fire, flood, earthquake, or natural disaster; war, armed conflict, sanctions, embargo, or breaking off of diplomatic relations; terrorist attack, civil war, civil commotion, or riots; pandemic or epidemic; industrial disputes; disruptions to transportation, telecommunications, power supply, or other utilities; acts, legislation, or restrictions imposed by any government, regulator, or state; the acts or omissions of third parties, including Partners, payout channels, and blockchain or settlement networks; or malicious code interfering with the Service.
Nothing in these Terms limits or excludes any liability that cannot be limited or excluded under applicable law, including liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or any of your statutory rights that apply and cannot lawfully be excluded.
NALA may suspend or terminate your access to the Service, in whole or in part, and with immediate effect where necessary, if: you breach these Terms; suspicious, fraudulent, or prohibited activity (including prohibited Virtual Asset activity under Section 13) is detected or reasonably suspected; you fail to satisfy verification or information requests; or suspension or termination is required by law, regulation, a competent authority, or a Partner. Where reasonably practicable and permitted by law, NALA will give you notice; otherwise NALA may act without prior notice and notify you afterwards.
Because your Wallet is self-custodial, suspension or termination affects your access to and use of the NALA Service and application; it does not transfer ownership of your Wallet or the value held in it to NALA. Even where NALA suspends or terminates the Service, you retain the right to eject your Wallet under Section 3 and to take sole and independent control of it and of the value held in it.
You may close your USD Wallet and terminate these Terms at any time by contacting support@nala.money or using the in-app facility. Termination does not relieve you of any obligation to pay fees or costs accrued before termination, and does not affect any pending transaction, which will be completed in accordance with these Terms and any applicable Partner Terms. NALA may withhold or delay processing of an instruction to the extent required to comply with applicable law or to manage risk.
If your use of the Service remains inactive for a continuous period of 12 months, NALA may classify your account as dormant. NALA will handle dormant accounts in accordance with applicable law in Canada and the applicable Partner Terms, which may include notifying you, restricting access through the application, and charging applicable dormancy fees. Because your Wallet is self-custodial, dormancy of your NALA account does not affect your ownership or control of your Wallet, which you may continue to access using your private keys. NALA will use reasonable efforts to contact you using the most recent contact details you have provided before taking such action.
These Terms are effective from the point you accept them and continue for an indefinite period until terminated by you or by NALA in accordance with these Terms.
NALA may amend these Terms from time to time to reflect changes to the Service, its Partners, fees, or legal or regulatory requirements. For material amendments - meaning changes that affect how we process your personal data, your rights under these Terms, or the key features of the Service - we will give you reasonable advance notice (and any minimum notice required by applicable law) by email or prominent in-app notification before the changes take effect. Minor amendments, such as corrections to contact details, formatting changes, or updates to hyperlinks, may take effect immediately.
You will be deemed to have accepted any change unless you close your USD Wallet and stop using the Service before the change takes effect. If you do not agree to a change, you may terminate these Terms free of charge before its effective date in accordance with Section 20.
NALA processes your personal data in its capacity as a data controller in accordance with applicable data protection law, including the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada and applicable data protection laws in the jurisdictions in which the Service is offered. Full details of how NALA collects, uses, retains, shares, and protects your personal data, the lawful bases relied upon, and your rights (including rights of access, rectification, and, where applicable, erasure and objection) are set out in the NALA Privacy Notice at https://www.nala.com/privacy-policy.
You must keep your personal information accurate and up to date by contacting us at support@nala.money. Failure to do so may result in us being unable to contact you about your account or to provide the Service. Nothing in these Terms limits or excludes your rights under applicable data protection law.
NALA is committed to treating customers fairly and to delivering good outcomes, including for customers who may be in vulnerable circumstances. We aim to ensure that the Service is appropriately designed for its intended customers, that fees are fair and clearly disclosed, that the information we provide is clear, fair, and not misleading, and that appropriate support is available throughout your use of the Service.
If at any time you require additional support—for example, because of a disability, illness, language need, or other personal circumstance—please contact us at support@nala.money and we will endeavour to accommodate your needs.
Access to the Service requires the NALA mobile application. NALA grants you a non-exclusive, non-transferable, revocable licence to use the application on a device owned or controlled by you, solely for your personal use of the Service and in accordance with these Terms and any applicable app-store terms. You may incur data or other charges from your network provider, for which you are solely responsible.
You must not: (a) modify, adapt, translate, reverse engineer, decompile, or disassemble the application except to the extent permitted by law; (b) rent, lease, lend, sell, sublicense, or otherwise transfer the application; (c) remove or alter any proprietary notices; or (d) circumvent, disable, or interfere with any security or access-control features of the application. All intellectual property rights in the Service, the application, and the NALA name and marks remain the property of NALA or its licensors. For the avoidance of doubt, this licence relates to the application; your Wallet and its private keys remain owned and controlled by you.
No failure or delay by either party to exercise any right or remedy under these Terms or by law shall constitute a waiver of that or any other right or remedy, nor shall any single or partial exercise prevent or restrict the further exercise of that or any other right or remedy. The rights and remedies under these Terms are in addition to, and not exclusive of, any rights or remedies provided by law.
These Terms (together with the documents referred to in them) constitute the entire agreement between you and NALA in relation to the Service and supersede all prior agreements, arrangements, and understandings relating to the same subject matter. Your relationship with each Partner in respect of a regulated service is governed by the applicable Partner Terms. In the event of any conflict between these Terms and the Partner Terms, the Partner Terms shall prevail to the extent the conflict relates to the regulated service provided by that Partner.
If any provision or part-provision of these Terms is or becomes invalid, illegal, or unenforceable, it shall be deemed deleted, but that shall not affect the validity and enforceability of the rest of these Terms.
Nothing in these Terms is intended to, or shall be deemed to, establish any partnership or joint venture between you and NALA, and you agree not to use the Service on behalf of, or as agent for, any other person except as expressly permitted. A person who is not a party to these Terms shall have no right to enforce any of their provisions, except that a Partner may enforce any provision that expressly benefits it.
You may not assign or transfer any of your rights or obligations under these Terms without NALA’s prior written consent. NALA may assign or transfer its rights and obligations under these Terms to an affiliate or successor, or in connection with a reorganisation, merger, or transfer of business, provided this does not materially reduce your rights under these Terms.
These Terms, and any dispute or claim arising out of or in connection with them or their subject matter (including non-contractual disputes or claims), are governed by, and shall be construed in accordance with, the laws of the Province of Ontario and the federal laws of Canada applicable therein, and are subject to the [non-exclusive] jurisdiction of the courts of the Province of Ontario, Canada, without prejudice to any mandatory rights or consumer protections available to you under the laws of your country of residence.
If you have a complaint about the Service, please contact NALA in the first instance at support@nala.money, providing details of your complaint and your account so we can investigate. We will acknowledge and investigate your complaint and provide a response within the period required by applicable law or our complaints policy. Where your complaint relates to a regulated service provided by a Partner, NALA will direct it to the relevant Partner for handling in accordance with that Partner’s complaints procedure. If you remain dissatisfied with our final response, you may be entitled to escalate your complaint to the applicable Canadian complaints body or regulator such as the Financial Consumer Agency of Canada (FCAC) (www.canada.ca/en/financial-consumer-agency; 1-866-461-3222).
If you have any questions about these Terms or require support, you may contact NALA through the in-app chat feature (Mama NALA), by email at support@nala.money, or via the support channels provided within the application or on the NALA website at www.nala.com.