Terms of Service

1. These terms are not final

This version of the Terms of Service (“Terms”) is an interim draft. It describes the Zxee service as it works on the date below, and it is not the final agreement. We may change, replace, or withdraw these Terms at any time, including before a final version is published. Changes can add, remove, or limit features, partners, fees, countries, and eligibility rules.

The “Last updated” date on this page is the date of the current draft. If you create an account or keep using Zxee after we post a new version, you accept the Terms then on this page. If you do not agree, stop using Zxee.

2. Agreement

These Terms govern your use of the Zxee mobile app, the website at https://zxen.app (including public pay links), SMS account verification, and related services (together, the “Services”). “Zxee,” “we,” and “us” mean the operator of the Services. “You” means the person who creates an account or otherwise uses the Services.

By creating an account, requesting a verification code, or using the Services, you agree to these Terms and to our Privacy Policy. Some features also require you to accept a partner’s own terms. Privy provides the wallet, Sumsub checks identity, Transak handles fiat purchases, and Bridge handles bank cash-out. When you use that partner’s step, the partner’s terms apply to the partner’s service.

Some older screens, links, or technical names say “Zxen.” Zxen and Zxee are the same product.

3. What Zxee is

Zxee is a consumer payments app. You sign up with a mobile phone number. The app shows a balance in dollars. That number is USDC at a wallet address that belongs to you on the Base network (chain id 8453). USDC is a dollar-denominated digital asset issued by Circle. We do not have a Circle account. The app uses the public USDC token on Base.

Zxee provides the phone-number account, the address book, the screens where you review and confirm a payment, and the connections to the partners who verify identity or move value. Your USDC, while it is sitting in the app, is at your own Base address. We do not keep a pooled account of customer USDC, and we do not keep a private ledger that is the source of truth for what you can spend.

Zxee is not a bank, broker, or money-market fund. The balance is not a bank deposit, is not legal tender, and is not insured by the FDIC, the SIPC, or any government deposit scheme. We do not pay interest on USDC.

4. Eligibility

You must be at least 18 years old and able to form a binding contract. You must use a mobile number you are allowed to use. You are responsible for that number, for any email on the profile, and for every device signed in to your account.

Buying USDC, cashing out to a bank, and identity verification depend on our partners. A partner may refuse a country, a US state, or a person. If a partner will not onboard the country or state you enter, that step of the flow stays closed. We may also refuse, limit, or close access where we believe the law, a partner rule, sanctions, or these Terms require it.

You may not open or use an account if you are the target of economic sanctions, or if you are located, ordinarily resident, organized, or established in a jurisdiction subject to comprehensive US sanctions. You may not use a VPN or any other method to hide that you are a person we or a partner are not allowed to serve.

5. Accounts and phone verification

You create a Zxee account with a mobile phone number. We send automated SMS one-time passwords so you can prove you control that number when you sign up or sign in. By requesting a code, you agree to the SMS Terms. You can review the opt-in form at zxen.app/sms.

Message frequency varies. You typically receive one message each time you create an account or sign in. Message and data rates may apply. Reply HELP for help. Reply STOP to cancel. Consent is not a condition of any purchase. You must verify a mobile number to create a Zxee account.

Your profile can include a display name, an @handle, an email, and an avatar. Email is collected for the profile. It is not required to create the wallet. Other Zxee users can send to you by @handle or by the phone number on the account. You are responsible for the handle you choose and for keeping access to the phone number.

6. Your wallet

After your phone number is verified, the app creates one embedded wallet for your account:

The wallet is created by Privy. Its private key is generated and used only inside Privy’s secure key infrastructure (trusted execution environments), not stored as a seed phrase in our database.

Every spend is a transaction your wallet signs after you confirm it in the app. Privy’s role in signing an ordinary transaction does not put your USDC in our possession.

Network fees on Base are paid in USDC from your wallet, so you do not need ETH. The fee is taken in addition to the amount you send. If your USDC balance cannot cover the amount plus the network fee, the send fails. Conversion routes can still charge their own fees.

The app creates the wallet when the phone number is verified. Identity verification is a later gate. It is required before you buy USDC with fiat, before you cash out to a bank, and before in-app money features that depend on an approved identity check.

Any other token that lands on your address is outside the balance and outside the activity feed. We do not undertake to display, support, or recover those tokens.

7. The balance you see

The number on the home screen is read from the Base network: the USDC balance of your address. Our database stores a record of payments. It does not store a spendable balance. If you open the same address in a public block explorer, you should see the same USDC, aside from transactions that have not yet confirmed.

A confirmed on-chain transfer is public and final. We cannot reverse, recall, or charge back a confirmed transfer, and we cannot force a recipient, a bridge, or a bank to return it.

8. Sending and receiving USDC on Base

When you send to another Zxee user, the app resolves their @handle or phone number to their Base address. Your wallet signs a USDC transfer to that address. When you send USDC on Base to an address outside Zxee, your wallet signs the same kind of transfer. There may be no Zxee user on the other side to notify.

When a Zxee platform fee applies, you also sign a second USDC transfer to a Zxee treasury address. The recipient gets the amount you entered. You pay that amount plus the fee. The fee is disclosed before you confirm.

An in-app payment request is a request, not a debit we can pull. It settles only if the payer signs an on-chain transfer.

USDC that arrives at your address outside a supported flow may be recorded as unrecognized. The supported way for someone who is not a Zxee user to pay you is a pay link, described below.

9. Pay links and conversion

Each account can have a public pay link on https://zxen.app. Someone can open that link without a Zxee account. The website never signs a transaction and never stores wallet keys. It creates a payment route and names your Zxee address as the place USDC should arrive.

If the payer is already sending USDC on Base, the payment can be a direct transfer. If the payer is sending another asset or using another network (including BTC, ETH, SOL, or another asset we list), the payment uses Fireblocks Flow, which we access through Dynamic.

Flow asks independent providers to quote a swap or bridge. Zxee creates the Flow, sets the destination, and shows the quote. Zxee does not run the exchange or the bridge, does not hold the providers’ keys, and does not take custody of assets while they are in transit. For that interval the routing providers hold the value. When the route completes, USDC is delivered to your Base address.

A payer sends to a one-time deposit address that Flow issues, from a wallet they already control or from an exchange. That deposit address is a route for that payment. It is not your wallet and it is not a wallet Zxee owns.

The same Flow is how you send from your Zxee USDC to an external wallet in another asset we support, such as a native asset, USDC, USDT, or BTC on the catalog shown in the app. You choose the chain, the asset, and the destination address. Your wallet signs the Flow deposit. Providers then deliver the destination asset to the address you entered. Your USDC leaves your wallet when that deposit confirms. We do not control the wallet you send to. Check the address before you confirm. A direct USDC transfer on Base to another Base USDC address does not use Flow.

A quote is an estimate. The amount that arrives can be different, because of provider fees, slippage, and price movement between the quote and execution. The on-chain result is the amount that counts. A Flow can expire, be cancelled, or fail. If it fails after assets have already been sent, any refund is the provider’s, back to a refund address supplied for that route. Zxee does not keep a reserve to replace funds that are mid-route or lost on a failed route.

10. Buying USDC

You can buy USDC with fiat through Transak. Transak is the buyer of record for that purchase. Zxee supplies the screens and the destination address. Zxee does not receive the fiat and does not keep a stock of USDC to fill orders.

You need an approved Sumsub identity check before you can start a purchase. Transak then makes its own decision. We give Transak a short-lived token so Transak can read the identity check Sumsub already completed. We do not store that token. Transak may also ask for a purpose of use and, for a US buyer, a Social Security number. The Social Security number is sent to Transak and is not saved in our database. We keep only the fact that it was submitted, and when.

You choose an amount and a method: bank transfer, card, Apple Pay, or Google Pay. Card numbers, Apple Pay credentials, and Google Pay credentials are entered in Transak’s hosted capture. Zxee does not see them. A bank transfer uses a virtual account Transak provides.

Who holds the value on a purchase:

Transak, your bank, or your card issuer can delay, decline, or reverse a purchase under their own rules. We do not control those decisions. Until USDC arrives at your address, you do not have that USDC in Zxee.

11. Cashing out to a bank

You can cash out USDC to a US bank account through Bridge. Bridge is the custodian of that cash-out. The app does not hold the funds. You sign a normal USDC transfer, and Bridge takes it from there.

Sumsub approval does not mean Bridge has approved you. You can add a bank account and withdraw only after Bridge marks your Bridge customer active. Until then, bank accounts and “Withdraw to bank” stay unavailable. Bridge may ask for information Sumsub did not require, including Bridge’s own terms of service, which you accept on a page Bridge hosts. Bridge will not open a customer without that acceptance.

When you add a US bank account, the account number and routing number are sent to Bridge. We do not store the full numbers. We keep a display label: bank name, account-holder name, the last four digits, and whether the account is the default.

The first time you withdraw to an account, Bridge creates a liquidation address: a Base address that accepts USDC and pays that bank account in USD. Bridge creates it and Bridge controls it. It is not your wallet, it is not our wallet, and it is not a second balance you can spend inside Zxee. Later withdrawals to the same account reuse that address. USD to a US bank account is the cash-out rail we offer.

Who holds the value on a cash-out:

You should treat USDC as spent once your transfer to the liquidation address is confirmed. If Bridge cannot deliver the payout, the app shows the status Bridge reports (including returned, refunded, undeliverable, or another failure). Zxee does not hold a float it can use to repay you from its own funds.

12. Identity verification

You enter identity information in the app once. That information is used for up to three separate decisions:

Sumsub keeps the identity documents and is the source of the verification profile. The in-app camera takes photos of your ID. The same photos can be sent to Bridge once a Bridge customer exists. Liveness is a check inside Sumsub’s own screen, because Transak accepts a real liveness check and does not accept a still photo. We do not store the ID images, the liveness capture, or your tax identification number. While you are still filling out the form, the draft stays in memory on your device. Leaving the flow drops it. We do not keep a saved draft of your legal name, address, or tax ID.

We do keep the verification result, your country, and a short set of non-document answers Bridge needs if we have to resubmit your Bridge profile: nationalities, source of funds, employment, account purpose, expected monthly volume, and whether you are acting for someone else. If a high expected volume requires a proof-of-funds image, that file is sent to Bridge and is not stored by us. A name or address that cannot be represented in basic Latin characters cannot be submitted. Countries and US states that Bridge will not onboard cannot continue past that step.

If Sumsub asks you to retry, you can resubmit in the app up to three times. After that, the app treats the check as rejected. A final rejection means you need to contact support. There is no further self-serve retry. We may require you to complete or refresh verification before a feature is available. A partner’s rejection is that partner’s decision.

13. Fees

On sends between users and on sends to an external address, the default Zxee fee is 1% of the amount, with a minimum of $0.10 and a maximum of $0.50. You pay it on top of the amount the recipient receives. The fee in effect for your account is shown before you confirm. Referral credits can reduce the Zxee fee to zero. When the net fee is above zero, it is a separate USDC transfer to the Zxee treasury, signed by your wallet together with the payment when the network allows it.

That platform fee is not charged on a Transak purchase or a Bridge cash-out. Transak, Bridge, Flow’s routing providers, and the network may still charge their own fees, spreads, or slippage. Provider fees on a Flow are shown on the quote. Those amounts belong to the third party. We do not refund them.

14. Partners

Features below are provided by independent companies. Their availability, pricing, and approval standards can change without our agreement. We are not liable for a partner’s outage, delay, rejection, pricing, or for assets that partner holds under its own terms.

15. Risks you accept

Digital assets and the rails above can fail. By using Zxee you accept these risks, among others:

16. Acceptable use

You may not use Zxee to violate law, commit fraud, evade sanctions or taxes, launder money, finance terrorism, send spam or unsolicited messages, harass other users, or interfere with the Services. You may not attempt to gain unauthorized access to accounts, wallets, partner systems, or our systems. You may not use another person’s identity, payment card, or bank account. You may not submit false KYC information.

You may not use the Services if you are a sanctioned person, and you may not route activity through Zxee in order to conceal the origin, destination, or beneficiary of funds. We may suspend or close an account, decline a transaction, or refuse a feature when we believe these Terms, the law, or a partner requirement has been or may be breached. Suspension of the app does not move USDC that is already at your address. You remain responsible for that wallet, subject to Privy’s own rules.

17. App lock

If you set an app PIN or biometric unlock, it is a lock for the screen on that device. It is stored in the device’s secure storage, keyed to your user, and it is never sent to us. The PIN does not encrypt the wallet and does not, by itself, authorize a transfer. You still confirm the payment, and the wallet still signs.

18. Records

We keep records so the app can show your profile, your public address, and the status of sends, purchases, cash-outs, and pay links. Those rows describe what happened. They are not the coins. You can read your own records in the app. You cannot edit your own verification status, purchase status, or cash-out status. Those updates come from our servers after the relevant partner responds, or from a partner webhook whose signature we check before trusting it.

Our database does not contain your private key, your tax identification number, your ID photos, your liveness capture, your full bank account or routing number, or your card, Apple Pay, or Google Pay credentials. How we handle personal information is described in the Privacy Policy.

19. Suspension and termination

You may stop using Zxee at any time. Uninstalling the app does not delete USDC at your address. If you want to move it, send the USDC before you lose access to the device and the account.

We may suspend or terminate access to the app, the website, or a feature if you breach these Terms, if a partner requires it, if we must do so to protect users, or if we must do so to comply with law. We may also discontinue a rail (including a partner, a country, or a cash-out method) as this interim service changes.

Sections that by their nature should survive — including custody allocations, risks, acceptable use, disclaimers, and liability limits — survive termination.

20. Disclaimers

The Services are provided “as is” and “as available.” To the fullest extent permitted by law, Zxee disclaims warranties of merchantability, fitness for a particular purpose, title, and non-infringement. We do not warrant that the Services will be uninterrupted, error-free, or free of loss, that a partner will approve you, that a quote will match the amount you receive, or that USDC will hold a particular value.

Nothing in the Services is financial, investment, tax, or legal advice. You are responsible for deciding whether a payment, a purchase, or a cash-out is appropriate for you.

21. Limitation of liability

To the fullest extent permitted by law, Zxee and its operators will not be liable for indirect, incidental, special, consequential, or punitive damages, or for lost profits, lost data, failed transactions, partner delays, or digital-asset losses, arising from your use of the Services. Our aggregate liability for any claim relating to the Services is limited to the greater of (a) the fees you paid to Zxee in the 12 months before the claim or (b) one hundred US dollars ($100).

Some jurisdictions do not allow certain limits. In those places our liability is limited to the maximum extent permitted by law. Nothing in these Terms excludes liability that cannot legally be excluded, including liability for fraud or for death or personal injury caused by negligence where the law does not allow that exclusion.

22. Changes

These Terms are interim and are subject to change. We may update them by posting a new version on this page. The “Last updated” date will change when we do. A later version may be the final Terms, or it may be another interim draft. Continued use of Zxee after an update is acceptance of the revised Terms. If a change is not acceptable to you, your remedy is to stop using the Services.

23. Contact

Questions about these Terms: contact@zxen.io.