Terms of Service

1. The Service

Hashlock Markets is non-custodial, peer-to-peer software that facilitates atomic swaps of digital assets across Bitcoin, EVM-compatible networks, TRON, and Solana, using a sealed request-for-quote (“RFQ”) process and hash time-locked contracts (“HTLCs”).

We provide software, messaging, and coordination infrastructure only. We are not a custodian, broker, dealer, exchange, money services business, money transmitter, payment processor, or financial institution. We do not hold, control, or have access to your assets or private keys; we do not take the other side of your transactions; and we do not guarantee that any quote, counterparty, liquidity, or swap will be available or will complete.

Swaps execute directly between users’ wallets and on-chain HTLC escrows. An automated keeper may submit claim or refund transactions strictly as permitted by the HTLC protocol; it can never redirect, withhold, or take custody of principal. You transact at your own initiative and risk.

2. Eligibility

To access or use the Service, you represent and warrant that, on each occasion you use it:

• You are at least 18 years old and have full legal capacity to enter into these Terms;
• You are not a Prohibited Person — you are not identified on, or owned or controlled by a person on, any sanctions or denied-party list (including the U.S. OFAC Specially Designated Nationals list, or lists maintained by the UN, EU, or UK HM Treasury), and you are not located in, resident of, or accessing the Service from a jurisdiction subject to comprehensive sanctions;
• You are not located in, and will not use the Service from, any territory we designate as restricted;
• Your use of the Service is not prohibited by, and does not violate, any law or regulation applicable to you.

We may restrict access from certain territories or to certain persons, and may use technical or geolocation measures to enforce these restrictions. Circumventing them is a material breach of these Terms.

3. Non-custodial wallets and keys

You access the Service using an embedded wallet provided through our authentication partner or your own external wallet. You are solely responsible for maintaining the security of your wallet, credentials, private keys, seed phrases, and recovery methods.

We cannot access, freeze, recover, reverse, or restore your assets, keys, or transactions. Loss of keys or credentials, sending funds to an incorrect or non-controlled address, or supplying an invalid settlement or refund address may result in the permanent and irreversible loss of assets, for which we bear no responsibility.

4. Quotes, swaps, timelocks, and refunds

Quotes are cryptographically-signed, time-limited offers. A swap is formed when you accept a quote and fund an HTLC. Once submitted, blockchain transactions are final and irreversible.

Swaps use asymmetric timelocks across the two legs. If a counterparty fails to fund or claim within the applicable window, the protocol permits a refund of the locked funds after the relevant timelock expires. You are responsible for providing correct settlement and refund addresses that you control, and for monitoring and, where required, taking action within applicable time windows. Network congestion, fees, downtime, and chain reorganizations may affect the timing or outcome of any swap.

5. Fees

Use of the Service may be subject to a protocol fee payable by the taker, which is disclosed to you before you commit to a swap. Fees may be non-refundable once a swap is funded, including where a swap is later refunded due to your action or inaction or a counterparty’s failure to complete. Blockchain network (gas) fees are separate, are paid to the relevant network rather than to us, and are your responsibility. We may change our fees prospectively.

6. Acceptable use

You agree that you will not, and will not attempt to:

• Use the Service for any unlawful purpose, or in furtherance of money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime;
• Transact with counterparties, addresses, or funds you know or suspect to be associated with illicit activity or sanctioned persons;
• Manipulate markets, engage in wash trading, spoofing, or deceptive conduct, or exploit the RFQ, HTLC, keeper, or fee logic;
• Introduce malware, interfere with or disrupt the Service or its infrastructure, or gain unauthorized access to any system or data;
• Circumvent geographic, eligibility, or security restrictions, or misrepresent your identity, location, or eligibility;
• Infringe the intellectual property or other rights of any person, or use the APIs other than as documented and permitted.

7. Compliance, screening, and taxes

You are solely responsible for determining and complying with the laws, regulations, licensing, reporting, and tax obligations that apply to you and your use of the Service. We may screen wallet addresses and transactions against sanctions, watchlists, and risk-intelligence sources, and we may, in our discretion and to the extent permitted or required by law, block, delay, restrict, or refuse service, or restrict specific addresses, to comply with legal obligations or to manage risk.

8. Third-party services and public blockchains

The Service depends on public blockchains and on third-party providers, including wallet and authentication providers, RPC and indexing services, and messaging platforms. We do not control and are not responsible for these networks or providers, their availability, security, or conduct. Transactions are recorded on public, immutable ledgers that we do not control and cannot alter or erase.

Fiat on-ramp and off-ramp. Where the Service offers a “Buy” or “Sell” option, it links you to MoonPay, an independent third-party provider of fiat payment services. Any purchase or sale of cryptocurrency for fiat currency is a contract between you and MoonPay, governed by MoonPay’s own terms of service and privacy policy and subject to MoonPay’s identity-verification (KYC) requirements, pricing, fees, limits, and regional availability. MoonPay is the merchant of record for those transactions.

Where the Service offers a “Cash out” or “Cash in” option, it opens a widget operated by MoneyGram, an independent third-party provider, and the same applies: taking cash out at, or paying cash in at, a MoneyGram agent is a contract between you and MoneyGram, governed by MoneyGram’s own terms and privacy policy and subject to MoneyGram’s identity-verification (KYC) requirements, pricing, fees, limits, and regional availability, including which agent locations can serve you.

We are not a party to those transactions, do not act as a broker, dealer, exchange, or money transmitter in respect of them, and never take custody of your fiat currency, your cash, or of the cryptocurrency involved: purchased assets are delivered directly to a blockchain address you control, and assets you sell or cash out are sent from your own wallet, signed by you. We do not set the provider’s prices or fees and do not receive your payment-card, bank-account, or identity-verification details, or the details of any cash you hand over or collect at an agent. Disputes, refunds, chargebacks, and support for those transactions are between you and the provider — MoonPay or MoneyGram as the case may be.

9. Intellectual property and license

Portions of the Hashlock software may be made available under open-source license(s) as stated in our public repositories; those licenses govern your use of that code. The “Hashlock Markets” name, logos, and site content are owned by us or our licensors and are protected by intellectual-property laws. Subject to your compliance with these Terms, we grant you a limited, revocable, non-exclusive, non-transferable, non- sublicensable license to access and use the Service for its intended purpose. All rights not expressly granted are reserved.

10. No professional advice

The Service and any related content are provided for informational and utility purposes only and do not constitute financial, investment, trading, legal, tax, or accounting advice. We are not your broker, agent, or fiduciary. You are solely responsible for evaluating the merits and risks of any transaction and for your own decisions.

11. Assumption of risk

You acknowledge and accept that using the Service and transacting in digital assets involves significant risk, including:

• Smart-contract and protocol risk, including undiscovered bugs, vulnerabilities, or exploits in the HTLCs, keeper, or dependencies. Our EVM smart contracts (HTLCFactory and HTLCImplementation) were audited by QuillAudits, which also verified the fixes for its findings. An audit does not guarantee the absence of defects. The deployed contract code cannot be upgraded — a defect can only be addressed by deploying a replacement — and the contracts' administrators can only change where protocol fees are paid, hand that role over, and, on TRON, permanently stop new deposits to a pool — none of them can move, redirect, or block funds already in escrow;
• Counterparty risk, including a counterparty failing to fund or claim, requiring a timelocked refund;
• Market risk and volatility — digital-asset prices can change rapidly and you may suffer partial or total loss;
• Blockchain risk, including congestion, high or unpredictable fees, downtime, forks, and reorganizations;
• Key-management risk, including irreversible loss from lost keys or incorrect addresses;
• Cross-chain and bridging risk inherent in coordinating settlement across independent networks;
• Asset-issuer risk: centrally issued tokens such as stablecoins (for example USDT or USDC) can be frozen or blacklisted by their issuer. If the issuer freezes an address involved in a swap — the escrow contract, your address, or your counterparty's — the claim or refund can fail and the tokens may stay locked for as long as the freeze lasts. We do not control, and cannot lift or work around, an issuer freeze;
• Regulatory and legal risk, including changes in law that affect availability or legality of the Service in your jurisdiction.

You assume all such risks. Transactions are irreversible and there is no insurance, guarantee, or backstop for losses.

12. Disclaimer of warranties

THE SERVICE IS PROVIDED “AS IS” AND “AS AVAILABLE”, WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS, IMPLIED, OR STATUTORY, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, AND ANY WARRANTY THAT THE SERVICE WILL BE UNINTERRUPTED, SECURE, ERROR-FREE, OR THAT ANY SWAP WILL COMPLETE. NO INFORMATION OR ADVICE OBTAINED FROM US CREATES ANY WARRANTY NOT EXPRESSLY STATED HEREIN.

13. Limitation of liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT WILL THE COMPANY OR ITS AFFILIATES, OFFICERS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, DATA, DIGITAL ASSETS, OR GOODWILL, ARISING OUT OF OR RELATING TO THE SERVICE, WHETHER BASED ON CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. TO THE MAXIMUM EXTENT PERMITTED BY LAW, OUR AGGREGATE LIABILITY FOR ALL CLAIMS RELATING TO THE SERVICE WILL NOT EXCEED THE GREATER OF (A) THE TOTAL PROTOCOL FEES YOU PAID TO US IN THE SIX (6) MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS (USD 100). SOME JURISDICTIONS DO NOT ALLOW CERTAIN LIMITATIONS, SO SOME OF THE ABOVE MAY NOT APPLY TO YOU.

14. Indemnification

You agree to indemnify, defend, and hold harmless the Company and its affiliates and their respective officers, directors, employees, and agents from and against any claims, damages, losses, liabilities, and expenses (including reasonable legal fees) arising out of or related to your use of the Service, your violation of these Terms, your violation of any law or the rights of any third party, or your transactions.

15. Suspension and termination

We may suspend, restrict, or terminate your access to the Service at any time, with or without notice, where we reasonably believe it is necessary to comply with law, protect the Service or other users, or address risk or breach of these Terms. You may stop using the Service at any time. Your on-chain rights under any funded HTLC exist independently of the Service and are unaffected by suspension or termination of your access. Sections that by their nature should survive termination will survive.

16. Changes to the Service and these Terms

We may modify the Service or these Terms from time to time. For material changes to these Terms, we will update the “Last updated” date and provide reasonable notice through the Service. Changes take effect when posted (or on any later stated date). Your continued use of the Service after changes take effect constitutes acceptance. If you do not agree, you must stop using the Service.

17. Governing law and dispute resolution

These Terms are governed by the laws of the State of Delaware, USA, without regard to conflict-of-laws rules. Except where prohibited by applicable law, any dispute arising out of or relating to these Terms or the Service will be resolved by final and binding arbitration administered by JAMS in Wilmington, Delaware, and you and the Company waive any right to a jury trial and to participate in a class or representative action. You may bring qualifying claims in small-claims court. Any mandatory local consumer rights that cannot be waived are unaffected.

18. Miscellaneous

These Terms and the Privacy Policy are the entire agreement between you and us regarding the Service. If any provision is held unenforceable, it will be modified to the minimum extent necessary and the remainder will stay in effect. Our failure to enforce a provision is not a waiver. You may not assign these Terms without our consent; we may assign them in connection with a merger, acquisition, or transfer of assets. We are not liable for delays or failures caused by events beyond our reasonable control (force majeure). Notices to you may be provided through the Service; notices to us should be sent to the contact below. These Terms are drafted in English, which controls in the event of any translation conflict.

19. Contact

Questions about these Terms may be sent to legal@hashlock.markets.