# Terms of Use

Last updated: 2026‑06‑18

These Terms of Use (the "Agreement") are entered into between **Asha Wallet LLC** (OGRN: 124PA000984, TIN (INN): 11031596, address: 58 R. Barcic St., Gagra, Republic of Abkhazia) and you (the User) and govern your access to and use of the IMBA Wallet application, web app, APIs and related services (the "Service"). By using the Service, you agree to these Terms. If you do not agree, do not use the Service.

In these Terms, "Client", "User" and "you" mean the individual using the Service. "Operator" means **Asha Wallet LLC** (Republic of Abkhazia), the owner of the IMBA Wallet brand.

## 1. About the Service

### 1.1. Operator
The operator of the IMBA Wallet Service is **Asha Wallet LLC**, registered and operating in the **Republic of Abkhazia**. **IMBA Wallet** is the commercial designation (brand) of the Service; the brand owner and the entity providing the services listed in Section 2 of these Terms is the Operator. By using the Service, the Client enters into an agreement with the Operator.

**Operator details:**
- **Legal name:** Asha Wallet LLC (Общество с ограниченной ответственностью «Аша Воллет»)
- **Address:** 58 R. Barcic St., Gagra, Republic of Abkhazia
- **TIN (INN):** 11031596 · **KPP:** 211001521 · **OKPO:** 51469661 · **OGRN:** 124PA000984
- **Bank:** CB Amra Bank (КБ «Амра Банк»)
- **Accounts:** CNY 40702156700000005600 · RUB 40702810800000005600

### 1.2. Service functionality
The IMBA Wallet Service provides the Client, in particular, with the ability to:
- view balances and transaction history;
- manage virtual cards and payout details through the interface;
- initiate top-up and withdrawal of digital assets via supported blockchain networks;
- initiate exchange and conversion operations through partners and contractors;
- initiate top-up and withdrawal within a bank account opened with a partner bank;
- connect external crypto wallets (e.g., Telegram Wallet or MetaMask);
- authenticate via Telegram Mini App and manage profile and notification settings;
- purchase **IMBA Stars** (internal Service credits) with Telegram Stars and spend IMBA Stars on digital services and goods available in the Service (within enabled features).

### 1.3. Nature of the Service
IMBA Wallet is an **information and technology interface (aggregator)** providing access to financial and payment services of **partners and contractors**. The Operator is **not** a bank, exchange, money changer, non-bank credit organization, e-money institution, payment institution, payment organization, broker, investment adviser, payment card issuer and **does not** independently provide services for opening or maintaining bank or payment cards, or services for purchase, sale, exchange or trading of digital assets.

**Any card issuance and/or card payments** are performed **solely by partners** — card issuance partners and issuer banks — on their own contractual terms and compliance requirements. IMBA Wallet is an interface enabling Clients to access third-party services; the Operator **does not act** as a financial institution when issuing cards or processing merchant card payments.

### 1.4. Consent to intermediary role
By performing operations through the Service, the Client **confirms and agrees** that:
- certain financial operations are performed **not** by the Operator but by the relevant partners and contractors on their terms (or another partner indicated in the interface for a specific operation);
- the Operator acts **solely as an intermediary (interface)**, providing technical access, displaying statuses and forwarding the Client's instructions to partners;
- such operations may be subject to **separate agreements, offers and policies of partners**, which the Client must review and accept when using the relevant feature.

### 1.5. Digital asset operations (RUB ↔ USDT exchange and similar)
- The Operator **does not provide** services for purchase, sale, exchange or trading of digital assets.
- Such services are provided by **contractor — Achyumchara LLC** (or another partner indicated in the interface for a specific operation) under a **separate agreement** with the Client or on the terms of the contractor's public offer.
- Actual execution of exchange, including RUB ↔ USDT conversion, may be performed by **partner bank (Altyn Bank)** as a licensed counterparty of contractor Achyumchara LLC on terms established by the partner bank.
- The Operator **is not a party** to purchase, sale or exchange transactions of digital assets and **is not liable** for execution, rates, timing, refunds or blocking of such operations — except for the obligation to forward the Client's instruction to the contractor and (where applicable) the partner bank within the technical interface.
- By using exchange features, the Client **explicitly agrees** that contractual relations for exchange arise between the Client and the contractor (Achyumchara LLC), and where a partner bank is involved — also on the partner bank's terms; the Operator acts only as a technical intermediary.

### 1.6. Ruble funds
- The Operator **does not maintain ruble accounts** for Clients and **does not store** Clients' rubles on its own balances.
- Any ruble transfers received via details shown in the Service are made **solely for the purpose of crediting the equivalent in USDT** (or another supported digital asset) through the contractor and/or partner bank and **do not create** an obligation for the Operator to store the Client's rubles.
- Ruble bank accounts and cards, if available in the Service, are **opened and maintained by a partner bank** on that bank's terms; the Operator provides only access to information about such accounts through the interface.

### 1.7. Storage of digital assets
- The Operator **does not trade** digital assets, **does not conduct exchange activity** and **does not provide investment or brokerage services**.
- The Service provides **technical accounting and storage** of supported digital assets (e.g., USDT) on the Client's internal balance **solely for the purpose of** using Service features: top-up, withdrawal, transfers between platform users, card top-up through partners.
- Transfer of digital assets to an external blockchain address or from an external address is performed on the Client's instruction. **The Client acknowledges and agrees** that the Client bears risks related to blockchain network operation, confirmation delays, network fees and errors in the details provided (addresses, networks); incorrect details may result in irreversible loss of funds.

### 1.8. Payment cards
- The Operator **does not provide** services for issuance, opening or maintenance of **bank and payment cards** as a financial institution.
- Issuance and servicing of Visa/MasterCard virtual cards are performed by **card issuance partners** and **issuer banks** under their own licenses and on their own terms. The specific card issuance partner for an operation may be indicated in the Service interface before the Client confirms it. Ordering a card through the Service means the Client initiates issuance with a partner; contractual relations regarding the card arise between the Client and the card issuance partner and/or issuer bank.
- **Card subscription (monthly) fee** is set by the **card issuance partner** and/or **issuer bank**. Debit of the subscription fee from the Client's internal USDT balance in the Service is performed by the Operator **technically** — as forwarding of instructions and accounting debit in the interface; this **does not mean** the Operator is the card issuer or collects card maintenance fees as a financial institution.
- Through the Service interface, the Client may initiate **freezing and unfreezing** of a card and other available card management actions; such instructions are forwarded to the card issuance partner. The Operator **does not guarantee** uninterrupted execution of such instructions by the partner and **is not liable** for card operability, merchant acceptance, limits, blocks initiated by the issuer bank or processing partner, authorization delays, refusal to process transactions, or safety of funds on the card after they are credited to the issuer.
- Funds directed by the Client to top up a card, after transfer to the card issuance partner, are **outside the Operator's control**; claims regarding card transactions must be addressed to the **issuer and/or card issuance partner** under their agreement.

### 1.9. IMBA Stars (IMBA internal credits)

- **IMBA Stars** are a **digital good** of the Operator: an internal accounting unit of the Service (IMBA internal credits / internal currency). IMBA Stars are **not** money, e-money, cryptocurrency, a payment instrument or a security and exist **only** in the Service ledger.
- The Operator **sells the Client a digital good — IMBA Stars**. Payment for the purchase in Telegram Mini App is accepted in **Telegram Stars** (currency `XTR`) via Telegram's payment interface (Bot Payments / `WebApp.openInvoice`). Any UI wording such as "top up" means **purchase of IMBA Stars**, not opening a bank, payment or e-money account with the Operator.
- After successful confirmation of Telegram Stars payment, the Operator **delivers** the purchased **IMBA Stars** to the Client (by crediting them to the internal balance) — this is fulfillment of the digital good sale. The Telegram Stars (XTR) ↔ IMBA Stars rate, fees and limits are shown in the Service **before** the Client confirms the operation.
- IMBA Stars are intended **solely** to pay for digital services and digital goods available in the Service (including virtual card orders and card top-up through the interface), within features enabled in the Service. IMBA Stars are **not** intended for the Client to exchange into USDT, rubles or other assets via Telegram's payment interface; reverse conversion of IMBA Stars into Telegram Stars for the Client is **not** provided unless expressly stated in the Service.
- Virtual card orders and card top-up through the Service are **separate digital services and/or digital goods**, paid by **debiting IMBA Stars** from the Client's internal balance. Such operations are **not** a second sale of a digital good for Telegram Stars (XTR) and are **not** settled via a second Bot Payments invoice; in Telegram Mini App they are available only after the Client has purchased IMBA Stars (step 1) or has a sufficient IMBA Stars balance.
- Purchase of IMBA Stars with Telegram Stars is available **only** in the Telegram environment (Telegram Mini App) where supported by Telegram. In a web browser outside Telegram and in mobile apps without Telegram WebView, such payment may be unavailable; IMBA Stars balance display may be limited.
- **Telegram Stars** (XTR) and **IMBA Stars** are different units: Telegram Stars are part of Telegram's payment system; IMBA Stars are the Operator's internal credits. The Operator is **not** the operator of Telegram Stars and **does not guarantee** Telegram's rates, availability or policies regarding Stars.
- Use of Bot Payments is governed by Telegram's terms (including [Bot Platform Developer Terms](https://core.telegram.org/tos/bot-developers), digital goods and services section). The Client agrees to comply with Telegram's rules when paying an invoice. Disputes regarding Telegram Stars payments under an invoice are handled under Telegram's rules and the Operator's support channels (`/paysupport`, `/support` on the bot or other means shown in the Service).

## 2. Services provided by the Operator

The Operator (Asha Wallet LLC) provides the Client with the following services:
- account registration and authentication (including via Telegram, email and other supported login methods);
- interface for viewing balances, transaction history, profile, PIN setup, two-factor authentication and notifications;
- technical accounting and storage of USDT (and other supported digital assets) on the Client's internal balance — **without** trading digital assets;
- receipt and sending of digital assets via blockchain networks on the Client's instruction;
- transfers of digital assets between platform users (P2P within the Service);
- routing of the Client's instructions to partners and contractors, displaying operation statuses and processing results;
- referral program and collection of platform fees as shown in the Service;
- **sale of the digital good IMBA Stars** (internal credits) with payment in Telegram Stars (XTR) in Telegram Mini App, delivery of the good to the Client's balance and technical accounting of IMBA Stars;
- debit of IMBA Stars when paying for digital services and goods in the Service (within enabled features).

The Operator **does not provide** RUB ↔ USDT exchange, payment card issuance, opening or maintenance of bank accounts, merchant card payment processing, or other services expressly assigned in these Terms to partners and contractors.

## 3. Partner and contractor services

Certain Service features are performed by partners and contractors. These include, in particular:
- **Achyumchara LLC** — purchase, sale and exchange of digital assets; for such operations the contractor is the **Client's counterparty**;
- **Altyn Bank** — Client identification (KYC/AML), RUB ↔ USDT conversion, receipt and payout via FPS (SBP), bank cards and other supported channels; for the fiat part of exchange the bank acts as **executor** as a licensed counterparty of the contractor;
- **card issuance partners** — issuance of Visa/MasterCard virtual cards, processing, provision of card details, execution of freeze and unfreeze instructions, setting and collection of card subscription fees on their own terms;
- **partner banks** — opening and maintenance of bank accounts and cards where such feature is available in the Service;
- **blockchain networks** (including TRON and other supported networks) — confirmation and execution of transactions in the distributed ledger; the Operator **does not control** such networks.

The current partner for a specific operation may be indicated in the Service interface before it is confirmed.

## 4. Contractual parties by operation type

Depending on the type of operation, contractual relations arise between the Client and the parties listed below; the Operator's role is limited as stated in each item:
- **registration, PIN, profile** — party to the Client: Operator (Asha Wallet LLC); Operator's role: Service operator;
- **USDT deposit and withdrawal** (internal balance and blockchain) — party to the Client: Operator; Operator's role: operator of storage and transfer of digital assets;
- **RUB → USDT and USDT → RUB exchange** — parties to the Client: Achyumchara LLC and (where involved) Altyn Bank; Operator's role: intermediary (interface);
- **ruble transfer to the Operator's account** shown in the Service — conversion executed by: contractor and/or partner bank; bank — for the bank transfer; Operator's role: recipient of the transfer for crediting the equivalent, **not** custodian of the Client's rubles;
- **Visa/MasterCard virtual card order** — party to the Client: card issuance partner and issuer bank; Operator's role: intermediary;
- **USDT card top-up** — party to the Client: card issuance partner and issuer bank (crediting the card); Operator's role: intermediary and technical debit of USDT from the Client's balance in the Service;
- **card payment at a merchant (offline or online)** — party to the Client: issuer bank and processing partner; Operator's role: **is not a party** to such operation;
- **transfers between IMBA Wallet users** — party to the Client: Operator; Operator's role: transfer operator within the Service;
- **purchase of IMBA Stars with Telegram Stars (XTR)** — party to the Client: Operator; subject matter: digital good IMBA Stars; payment: Telegram Stars via Telegram; Operator's role: seller of the digital good and operator of IMBA Stars accounting;
- **virtual card order and card top-up paid with IMBA Stars** — for the card: card issuance partner and issuer bank; Operator's role: intermediary and technical debit of IMBA Stars from the Client's balance in the Service.

## 5. Allocation of liability

**5.1.** The Operator (Asha Wallet LLC) is liable to the Client for Service availability, account, PIN and other authentication means provided by the Operator — **to the extent** set out in Section 20 of these Terms.

**5.2.** The Operator is liable for **correct display** of USDT (and other supported digital assets) balance on the Client's internal balance in the Service.

**5.3.** The Operator **is not liable** for loss of USDT caused by the Client providing an incorrect blockchain address, network or other details; the Client accepts such risks under Section 1.7.

**5.4.** **Exchange rate**, **timing**, **cancellation or suspension** of RUB ↔ USDT exchange operations are the responsibility of **Achyumchara LLC** and (where involved) **Altyn Bank**; the Operator is responsible only for **forwarding the Client's instruction** to the contractor and displaying the received status.

**5.5.** **KYC refusal**, **anti-fraud decisions** and other restrictions imposed by Altyn Bank are the responsibility of **Altyn Bank**; the Operator shall inform the Client of operation status to the extent of data received from the partner.

**5.6.** **Card issuance**, **provision of card details**, **PCI-compliant display of card data** and **execution of card payments** are the responsibility of the **card issuance partner** and **issuer bank**; the Operator **bears no such liability**.

**5.7.** **Card block by the issuer bank**, **authorization refusal**, **merchant decline** and other restrictions originating from the issuer or processing partner are the responsibility of the relevant **issuer** and **processing partner**; the Operator **bears no such liability**.

**5.8.** For **technical debit of card subscription fee** from the Client's USDT balance in the Service, the Operator is liable **for the correctness of such debit**; subscription fee amount and terms are determined by the **card issuance partner** and/or **issuer bank**.

**5.9.** Disputes under these Terms and use of the Service shall be resolved by **courts of the Republic of Abkhazia** in accordance with Section 23.

**5.10.** The Operator is liable for **correct display** of the IMBA Stars balance and **delivery of the purchased digital good IMBA Stars** (balance crediting) after confirmed Telegram Stars payment within the Service — **to the extent** set out in Section 20.

**5.11.** The Operator **is not liable** for refusal, delay or cancellation of Telegram Stars payment by Telegram, Apple, Google or other participants in Telegram's payment chain; for changes to Telegram Stars rates and limits; or for unavailability of Bot Payments outside the Telegram environment.

## 6. Eligibility
You confirm you are at least 18 years old and your use complies with applicable laws.

## 7. Accounts and Authentication
- Login is available via Telegram Mini App ("Telegram Login"). You authorize us to process Telegram data strictly for authentication, security and contacting you when necessary.
- You are responsible for the security of your devices, PIN codes, tokens (access/refresh), private keys and any other sensitive information used with the app. Actions performed in your session are deemed yours.
- Additional verification (e.g., biometrics, 2FA) may be required for specific operations, thresholds or when launching the app/confirming payments.

## 8. Permitted Use
All users are prohibited from:
- violating applicable laws or using the app to circumvent sanctions/embargoes;
- fraud, money laundering or prohibited financial activities;
- attempting to circumvent security, abusing limits, APIs or automation;
- reverse engineering, copying or modifying the Service except as allowed by law;
- impersonating others or using another person's account/data;
- creating more than one account.

## 9. Restricted Jurisdictions
We may restrict access in certain countries or for certain users for legal, compliance or risk reasons. In rare cases we may request additional financial documents such as source of funds.

## 10. Fees, Limits and Rates
- Applicable fees (e.g., card issuance/maintenance, top-up/withdrawal) and limits are shown in-app and may change. Updates apply prospectively and are shown before you confirm an operation.
- Network fees or third-party charges (blockchain, payment processors) may apply in addition.

## 11. Cards
- Virtual cards are **issued and maintained by card issuance partners** and issuer banks (see §§ 1.8, 3). The Operator provides the interface for ordering, topping up and managing cards; issuance and maintenance terms are determined by the partner and/or issuer.
- Card subscription (monthly) fee is charged on the first day of each calendar month **from the Client's internal USDT balance in the Service** on the partner's instruction. If a card is issued during a month (e.g., March 15), the first subscription charge is made on the first day of the following month (April 1).
- Subscription arrears do not accumulate: only one month is charged; no fee is charged for past months beyond one month.
- If a card was frozen by the Client or the Operator through the Service interface and one or more calendar months have passed, upon unfreezing the card one month's subscription fee is charged from the Client's balance. If the Client's balance (USDT) is insufficient to cover the card subscription fee, unfreezing is unavailable and the Client is shown a message that they must top up their USDT balance to pay the card subscription fee.

## 12. Transactions and Settlement
- Transactions are final once submitted and confirmed by the relevant network/partner. We cannot reverse transactions that have been processed by third parties or recorded on a blockchain.
- The Client is responsible for accurate recipient details (addresses, bank details, networks). The Client **agrees** that incorrect details may result in permanent loss of funds.

## 13. Third-Party Services
The Service integrates third-party providers (payment processors, banks, contractors, Telegram, etc.). Your use of such services is governed by their terms and privacy policies. We are not responsible for third-party acts or omissions.

When purchasing IMBA Stars with Telegram Stars, Telegram's terms regarding Bot Payments and digital goods and services also apply. The Operator does not control Telegram's policies, including Telegram Stars refunds (`refundStarPayment`) as provided by Telegram.

## 14. Security
We employ reasonable administrative, technical and physical safeguards. However, absolute security does not exist. You use the Service at your own risk and agree to:
- keep devices up-to-date and secure;
- not share tokens/PINs/2FA codes/email passwords used with the app;
- promptly report suspicious activity.

## 15. Risk Disclosure
Digital asset operations and use of the Service involve material risks. The Client **understands, accepts and bears** these risks:

- **Volatility:** digital asset value may change sharply; the Client may incur losses when converting or using assets.
- **Technical risks:** network failures, transaction confirmation delays, software errors, blockchain forks, unavailability of the Service or partners may cause delays, refusal of operations or **irreversible loss of funds**.
- **Counterparty risks:** partners and contractors (banks, card issuers, processing companies, exchange contractors) may suspend operations, refuse service or block funds or cards under their compliance rules — **regardless of the Operator's will**.
- **Regulatory changes:** changes in laws or regulator requirements in any jurisdiction may limit or terminate access to certain Service features.
- **Client errors:** incorrect address, network, details or amount may result in **irreversible loss of funds**; blockchain transactions are generally **irreversible**.
- **Access risks:** loss of PIN, tokens, Telegram account or device access may restrict access to the Service and funds until account recovery under these Terms.
- **Custody risks:** digital assets on the internal Service balance are accounted for in the Operator's information system; the Client acknowledges risks related to cyberattacks, force majeure and other circumstances described in Sections 14 and 19.

The Client **confirms** having independently assessed the acceptability of these risks and uses the Service at the Client's own risk.

## 16. Content and IP
The Service and its content (marks, logos, text, graphics, software) are owned by us or licensors and protected by law. You receive a limited, non-exclusive, non-transferable license to use the Service as permitted by these Terms.

## 17. Privacy
Our processing of personal data is described in the Privacy Policy available in the app. By using the Service, you consent to such processing.

## 18. Suspension and Termination

**18.1. Grounds.** The Operator may **suspend or terminate** the Client's access to the Service (in whole or in part) **at any time**, with or **without notice**, if:
- a breach of these Terms or applicable law is identified;
- there are reasonable grounds to believe continued access creates a **security, fraud, money laundering or other abuse risk**;
- this is necessary for **security, compliance or risk management** reasons — including at a partner's request or based on an internal review.

**18.2. Consequences of termination.** Upon termination, the right to use the Service ceases **immediately**, unless otherwise required by law or an explicit Operator decision.

**18.3. Investigation and freezing of funds.** If fraud, hacking attempts, unauthorized access, abuse of Service errors or other violations are suspected, the account and related operations may be **frozen pending investigation**. During investigation, withdrawals and certain operations may be **unavailable** until circumstances are clarified.

**18.4. Measures upon confirmed malicious intent.** If an **intentional** violation is established following review (including fraud, circumvention of restrictions, exploitation of vulnerabilities, deliberate abuse), the Operator may **permanently block** the account and **withhold (penalize) up to 100%** of digital assets **previously frozen** in connection with such violation — as compensation for losses and to the extent permitted by applicable law. The withheld amount is determined by the Operator considering the nature of the violation and actual damage caused, but **shall not exceed 100%** of funds frozen during the investigation.

**18.5. Notice.** Where possible, the Operator informs the Client of suspension via the Service or account contact details; lack of notice **does not deprive** the Operator of the right to suspend access under Section 18.1 if immediate action is necessary for security or to prevent harm.

## 19. Disclaimers
THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. We do not warrant uninterrupted, error-free or secure operation and are not responsible for your funds.

## 20. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES, OR LOSS OF PROFITS, DATA OR GOODWILL, ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICE. The Operator's aggregate liability shall not exceed the fees paid by the Client to the Operator for the Service during the three (3) months preceding the event.

## 21. Indemnification
You agree to indemnify and hold us harmless from any claim, damage, loss, liability and expense (including reasonable attorneys' fees) arising from your use of the Service or violation of these Terms/law.

## 22. Changes
We may modify the Service or these Terms at any time. Material changes will be communicated in-app or on the website. Continued use constitutes acceptance of the updated Terms.

## 23. Governing Law and Disputes
- The Service is provided and **rendered in the territory of the Republic of Abkhazia**. The Operator is registered and operates in the **Republic of Abkhazia**.
- These Terms are governed by the **law of the Republic of Abkhazia**.
- All disputes, claims and lawsuits arising from these Terms or use of the Service shall be subject to the **exclusive jurisdiction** of the courts of the **Republic of Abkhazia**, unless mandatory law provides otherwise.
- **By using the Service, the Client explicitly agrees** to the application of the law of the Republic of Abkhazia and resolution of disputes by courts of the Republic of Abkhazia, and confirms that the Client knowingly uses services provided from the jurisdiction of the Republic of Abkhazia.

## 24. Contact and Operator Details

**Asha Wallet LLC (ООО «Аша Воллет»)**  
58 R. Barcic St., Gagra, Republic of Abkhazia  
TIN 11031596 · KPP 211001521 · OKPO 51469661 · OGRN 124PA000984  
E-mail: support@imbawallet.com