Terms of Service & privacy

Terms and Conditions

Trustart Technologies Limited (“TruStart”)

MSB Registration No. M20145008 — Registered with FINTRAC (Canada)

Please read these Terms carefully before using the Services. These Terms govern your legal relationship with TruStart and contain important information about your rights and obligations, Transaction risks, fees, limitations of liability and dispute resolution.

1. Definitions

In these Terms, the following words and expressions have the meanings set out below, unless the context otherwise requires:

• “Account” means the customer profile maintained by TruStart in connection with your use of the Services, including for identity verification, regulatory compliance, communication, and Transaction purposes.
• “Customer Wallet” means a cryptocurrency wallet address or fiat account that you provide to us as the destination for a Remittance, and which is owned and controlled solely by you.
• “Cryptocurrency” or “Digital Asset” means any virtual currency, token, or other digital representation of value that is supported by TruStart from time to time, currently Bitcoin (BTC), Ethereum (ETH), USD Coin (USDC), and Tether (USDT).
• “Fiat Currency” means Canadian dollars (CAD).
• “Exchange Services” means the fiat-to-cryptocurrency and cryptocurrency-to-fiat conversion and remittance services made available by TruStart, as described in Section 7.
• “FINTRAC” means the Financial Transactions and Reports Analysis Centre of Canada.
• “PCMLTFA” means the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), and its associated regulations, as amended from time to time.
• “MSB” means a Money Services Business registered with FINTRAC under the PCMLTFA.
• “Transaction” means an instruction provided by you to TruStart to convert and remit Fiat Currency into Cryptocurrency, or Cryptocurrency into Fiat Currency, in accordance with these Terms.
• “Remittance” means the transfer of converted funds (Cryptocurrency or Fiat Currency, as applicable) by TruStart to a Customer Wallet following completion of a Transaction.
• “Dormant Account” means an Account in respect of which there has been no Transaction activity for a continuous period of 12 months or more, as further described in Section 6B.
• “Customer”, “you”, or “your” means the individual or entity that accesses or uses the Services and agrees to be bound by these Terms.
• “Platform” means the TruStart website through which you may access information about the Services and submit a request to use the Services. Following submission of a request, further communications and Transaction-related instructions may be provided by email.
• “Products and Services” or “Services” means the products, features, and services made available by us through the TruStart Platform.
• “Terms” means these terms and conditions, together with any schedules, disclosures, or service-specific terms incorporated by reference.
• “We”, “us”, or “our” means Trustart Technologies Limited, operating as “TruStart.”

2. Introduction and Scope of These Terms

2.1 About TruStart and the Service Provider

TruStart is a fiat-to-cryptocurrency exchange service that provides currency conversion and related remittance services. Customers may submit a request to use the Services through the TruStart Platform. The availability of products and services may vary depending on applicable regulatory requirements.

The products and services described in these Terms are offered by Trustart Technologies Limited (“TruStart,” “we,” “us,” or “our”), a corporation existing under the laws of the Province of Ontario, Canada. TruStart is registered with the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”) as a Money Services Business (MSB), registration number M20145008, and operates in accordance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada) (the “PCMLTFA”) and its associated regulations.

2.2 Services Covered by These Terms

These Terms govern your access to and use of the currency conversion and exchange services provided by TruStart, which include the conversion of fiat currency into cryptocurrency, the conversion of cryptocurrency into fiat currency, related remittance and settlement services, and any other products, features, or services we make available from time to time (collectively, the “Services”).

TruStart is not a custodian of customer funds. TruStart does not hold, safekeep, or maintain cryptocurrency or fiat balances on your behalf on an ongoing basis. Each Transaction is a discrete exchange transaction: you send fiat currency or cryptocurrency to us, we convert it, and we remit the converted amount directly to a wallet or account that you control and have specified. You are responsible for ensuring that the Transaction instructions and information you provide to TruStart, including the amount, currency, wallet address, bank account information, and other settlement details, are complete and accurate. Section 7 (Nature of the Service: Exchange, Not Custody) describes this in detail.

Certain Services may be subject to additional terms, disclosures, or schedules. Where applicable, such documents form part of these Terms and apply to your use of the corresponding Service.

2.3 Eligibility and Acceptance of These Terms

You may only access or use the Services if you have the legal capacity to enter into a binding agreement and are permitted to use the Services under applicable laws and regulatory requirements.

If you are an individual, you represent that you are at least the age of majority in your province, territory, or jurisdiction of residence and have the legal capacity to enter into these Terms and use the Services.

If you access or use the Services on behalf of a corporation, partnership, trust, or other legal entity, you represent and warrant that you are duly authorized to act on behalf of and bind that entity in connection with these Terms and the Services. We may require you to provide information or documentation reasonably necessary to verify your authority to act on behalf of the entity.

Where the Customer is a corporation or other legal entity, we may also require information and documentation concerning the entity and its directors, officers, authorized representatives, beneficial owners, or other persons associated with the entity, as required for identity verification, regulatory compliance, or other due diligence purposes.

These Terms constitute a legally binding agreement between you and us when you accept these Terms electronically or otherwise access or use the Services. These Terms apply to all Services provided by TruStart, together with any applicable schedules, disclosures, or service-specific terms that are incorporated by reference or otherwise form part of these Terms.

2.4 No Advice and Nature of the Services

The Services are provided solely on an execution basis. We do not provide, and nothing on the TruStart Platform constitutes, investment advice, legal advice, tax advice, or any other form of professional advice.

You are solely responsible for obtaining independent advice, as appropriate, in connection with your use of the Services and any transaction involving cryptocurrency.

2.5 Jurisdictional Limitations and No Solicitation

Nothing in these Terms constitutes an offer or solicitation of the Services in any jurisdiction where such offer or provision would be unlawful. We do not direct the Services to any particular country, region, or market through these Terms.

3. Regulatory Compliance Framework

3.1 Compliance with Applicable Laws and Regulatory Requirements

We operate as a registered Money Services Business and provide the Services in accordance with the PCMLTFA, FINTRAC’s regulatory guidance, and all other applicable laws, regulations, rules, and regulatory requirements in Canada.

Our regulatory obligations apply to the provision of the Services and form an integral part of our contractual relationship with you. Certain services may involve the use of regulated third-party service providers. We remain responsible for the provision of the Services under these Terms; however, their execution may depend on such third parties.

3.2 Prevention of Money Laundering, Terrorist Financing, and Sanctions Evasion

As a registered MSB, we are required under the PCMLTFA to maintain a compliance program designed to prevent money laundering, terrorist financing, sanctions violations, and other illicit or prohibited activity. This includes verifying your identity, monitoring activity on your Account, conducting risk assessments, and reviewing Transactions conducted through the Services, in each case consistent with our obligations under the PCMLTFA and FINTRAC’s requirements.

You must not use the Services in a manner that would cause us to violate applicable anti-money laundering, anti-terrorist financing, or sanctions laws, including any use involving restricted persons, entities, jurisdictions, or activities.

3.3 Transaction Monitoring, Large Transaction Reporting, and Recordkeeping

To comply with applicable laws and regulatory requirements, including our obligations under the PCMLTFA, or where we reasonably consider it necessary to manage legal, regulatory, or risk exposure, we may delay, restrict, suspend, refuse, or block Transactions or access to the Services.

As a registered MSB, we are required to keep prescribed records in respect of Transactions, including records of large virtual currency transactions and other transactions meeting reporting thresholds under the PCMLTFA, and to report certain transactions to FINTRAC, including suspicious transactions and large virtual currency transactions, as required by applicable law. We may also be required to make disclosures or reports to other regulators, law enforcement agencies, or other competent authorities.

Where permitted and practicable, we may take reasonable steps to minimize disruption, but certain actions may be taken without prior notice where such notice is not permitted or is not appropriate, including where notice would constitute “tipping off” under applicable anti-money laundering law.

3.4 Cooperation with Authorities

We are required, where applicable and in accordance with applicable law, to cooperate with FINTRAC, other regulators, law enforcement agencies, or other competent authorities, including by providing information related to your Account, Transactions, or use of the Services.

3.5 No Liability for Compliance Actions

You acknowledge that actions taken by us in good faith to comply with applicable laws or regulatory requirements, including our obligations as a registered MSB under the PCMLTFA, may affect your access to the Services or the processing of Transactions. To the extent permitted by law, we are not liable for losses arising from such actions.

4. Customer Obligations

4.1 Accuracy of Information, Identity Verification, and Due Diligence

You must provide information that is accurate, complete, and current at all times, including information provided during registration, identity verification, and in connection with your use of the Services. This includes, without limitation, your contact details, identification information, and any other information required to enable us to provide the Services or comply with applicable laws and regulatory requirements, including our customer identification and verification obligations under the PCMLTFA. You must promptly notify us if any information you have provided changes.

To comply with applicable laws, regulatory requirements, and our internal risk management obligations, we may require information and documentation necessary to identify and verify you and conduct customer due diligence. For individual customers, this may include personal information such as your full legal name, date of birth, residential address, contact information, occupation, and copies of government-issued identification documents. For corporations and other legal entities, this may include information and documentation concerning the entity, its business activities, ownership and control structure, directors, officers, authorized representatives, beneficial owners, and other persons associated with the entity.

We may also request additional information or documentation from time to time, including information concerning your source of funds or source of wealth, the purpose and intended nature of your relationship with TruStart, the intended use of the Services, and particular Transactions. We may require you to confirm ownership or control of your contact details, Customer Wallet, bank account, or other relevant information; participate in verification calls or video calls with our representatives, arranged in advance by email; and undergo additional verification, screening, or validation against third-party databases or other sources.

We may apply enhanced due diligence where required by applicable law or regulatory guidance, where you are a Politically Exposed Person (“PEP”) or a close associate or family member of a PEP, where you are from a jurisdiction that we consider to present a heightened money laundering, terrorist financing, or sanctions risk, where the nature, size, or pattern of your Transactions raises questions or concerns, where we have concerns regarding the source of your funds or the purpose of our business relationship with you, or where we otherwise determine that enhanced due diligence is appropriate in the circumstances.

You agree to cooperate with all reasonable requests made by us, or by third parties acting on our behalf, for information, documentation, or verification in connection with identity verification, customer due diligence, transaction monitoring, or validation of the source of funds or cryptocurrency. You authorize us to conduct the inquiries and verifications we consider necessary for these purposes, directly or through third-party service providers, including verification against secure databases and other sources of information.

If we are unable to obtain or verify the required information, or if you fail to comply with reasonable requests for verification or information, we may decline, delay, restrict, or discontinue the provision of Services or the processing of Transactions, subject to applicable law. You acknowledge that failure to provide accurate, complete, and current information may affect the availability of the Services and that we are not responsible for losses resulting from inaccurate, incomplete, or outdated information provided by you, except to the extent otherwise required by applicable law.

4.2 Lawful Source of Funds and Cryptocurrency

You represent and warrant that all fiat currency and cryptocurrency used in connection with the Services originate from lawful sources and are not connected to any illicit, fraudulent, or prohibited activity, including money laundering, terrorist financing, or sanctions violations.

You are responsible for ensuring that any Transaction you initiate or receive using the Services complies with applicable anti-money laundering, anti-terrorist financing, and sanctions laws. This includes ensuring that counterparties, recipients, and the purposes of Transactions are lawful.

We may require you to provide information or documentation to verify the source of the funds or cryptocurrency used in connection with the Services. If you do not provide satisfactory information, or if we reasonably believe that funds or cryptocurrency may be connected to illicit or prohibited activity, we may restrict, suspend, or refuse Transactions, decline to complete a Remittance, or take other action permitted under these Terms or applicable law.

4.3 Use of the Services in Accordance with Law

You must use the Services only in accordance with these Terms and all applicable laws, regulations, and regulatory requirements.

You must not use the Services in any manner that would cause us to breach applicable legal or regulatory obligations, including obligations imposed by payment networks, blockchain protocols, banking partners, or other service providers on which the Services depend.

You acknowledge that the legality of a transaction or activity is determined by applicable law and that use of the Services does not render lawful an activity that would otherwise be prohibited.

4.4 Security of Customer Credentials

You are responsible for taking reasonable steps to protect the security of the email account, devices, and other communication channels that you use in connection with the Services.

This includes, without limitation:

• maintaining the security and confidentiality of your email account and other communication channels, including any passwords or verification codes used to secure or access them;
• ensuring that your email account, devices, and other communication channels used in connection with the Services are secure and accessible only by you or, in the case of a corporate or other legal entity, the individual authorized to act on its behalf;
• not permitting any unauthorized person to communicate with TruStart, provide Transaction instructions, or otherwise act on your behalf;
• never allowing an unknown or untrusted third party to remotely access your device or view or control your screen while you are communicating with TruStart or providing Transaction instructions; and
• notifying us promptly if you become aware or reasonably suspect that your email account, device, or other communication channel used in connection with the Services has been lost, stolen, compromised, or accessed without authorization.

You must promptly notify us of any unauthorized or suspected unauthorized change to the email address, Customer Wallet address, bank account information, or other information you have provided to TruStart in connection with the Services.

If we become aware of or reasonably suspect unauthorized access, fraud, impersonation, or a security compromise affecting information or communications associated with you, we may take reasonable steps to verify your identity or instructions and may delay, decline, or restrict a Transaction or the provision of Services, suspend or close your Account, or take any other reasonable protective action while we conduct appropriate verification or review.

Unless TruStart has received notice of an actual or suspected compromise in accordance with this section, TruStart may reasonably rely on communications, information, confirmations, and Transaction instructions received through an email address or other communication channel provided by you in connection with your Account.

To the maximum extent permitted by applicable law, TruStart will not be responsible for any loss arising from an unauthorized person accessing, controlling, or using your email account, device, or other communication channel, or impersonating you through such channel, where TruStart reasonably believed that the communication or instruction originated from you or an individual authorized to act on your behalf.

Your obligations under this section are in addition to your responsibilities regarding Account use and Transaction instructions set out in Section 4.6.

4.5 Prohibited Activities

You must not use the Services to engage in any activity that is unlawful, fraudulent, abusive, or otherwise prohibited under these Terms or applicable law.

Without limitation, you must not:

• use the Services for unlawful purposes, including fraud, money laundering, terrorist financing, or the purchase, sale, or facilitation of illegal goods or services;
• provide false, inaccurate, misleading, or incomplete information;
• attempt to circumvent, abuse, or interfere with the Services, security features, transaction limits, or compliance controls;
• impersonate another person or entity, or provide Transaction instructions on behalf of another person;
• infringe our intellectual property rights or those of any third party;
• engage in harassing, threatening, defamatory, or abusive conduct;
• use the Services in a manner that could give rise to claims, disputes, chargebacks, penalties, fines, or other liability for us, other users, or third parties; or
• refuse to cooperate with reasonable requests for information, verification, or compliance.

If we reasonably believe that you have engaged in prohibited activity or have breached these Terms, we may take appropriate measures to protect TruStart, our customers, and third parties. Such measures may include delaying, declining, restricting, or cancelling a Transaction, restricting or discontinuing the provision of Services, suspending or closing your Account, returning fiat funds where appropriate and permitted by applicable law, reporting the activity to competent authorities (including FINTRAC), or taking any other action permitted under these Terms or applicable law.

4.6 Account Use and Responsibility

You may only access and use the Services for your own account and benefit. You represent that you meet all applicable eligibility requirements, including any age or capacity requirements under applicable law, and that you will not open or operate more than one Account unless expressly approved by us. You are responsible for all instructions and information that you provide to TruStart in connection with your use of the Services, and you must not permit any unauthorized third party to provide Transaction instructions or otherwise act on your behalf, except as expressly permitted under these Terms or approved by us in writing.

4.7 Representations and Warranties

In addition to your other obligations under these Terms, when you enter into these Terms and each time you enter into a Transaction, you represent and warrant that:

• all information and documentation provided by you, or on your behalf, to TruStart is accurate, complete, and current in all material respects, and you have not knowingly omitted or misrepresented information that would materially affect our decision to provide the Services or our legal or regulatory obligations;
• you have the legal capacity and authority to enter into these Terms and use the Services and, where you act on behalf of a corporation or other legal entity, you are duly authorized to act on behalf of and bind that entity;
• all fiat currency and cryptocurrency used in connection with the Services originates from lawful sources and is not connected with fraudulent, unlawful, or prohibited activity;
• you are using the Services for your own account and benefit and not on behalf of an undisclosed third party;
• any bank account or Customer Wallet that you provide or use in connection with a Transaction is solely owned and controlled by you;
• your decision to enter into a Transaction is based on your own judgment and assessment of the relevant risks and, where appropriate, independent professional advice, and you are not relying on TruStart as providing investment, financial, legal, tax, or other professional advice, or as providing any assurance or guarantee regarding the value, performance, profitability, or outcome of a Transaction or cryptocurrency;
• your use of the Services and any Transaction you enter into complies with applicable law and will not knowingly cause TruStart or any third party to violate applicable law; and
• you are not entering into a Transaction at the direction of, or on behalf of, an undisclosed third party who is directing, controlling, or otherwise influencing your use of the Services, including any person or entity purporting to act as an investment adviser, broker, trading platform, account manager, or similar intermediary.

5. Cryptocurrency Networks and Transaction Risk

5.1 Nature of Cryptocurrency and Networks

The Services involve cryptocurrency that operates on decentralized blockchain networks that are not owned, controlled, or operated by us. These networks underpin the exchange and remittance services made available by TruStart.

The operation, performance, and availability of cryptocurrency networks depend on third parties and underlying protocols that are outside our control. You acknowledge that cryptocurrency networks may be subject to congestion, delays, technical failures, or changes to protocol rules, which may affect Transactions or the Remittance of converted funds.

5.2 Irreversibility of Blockchain Transactions

Transactions involving cryptocurrency are irreversible once broadcast to a blockchain network. A cryptocurrency Remittance is deemed complete and successful once the cryptocurrency moves from our wallet to the Customer Wallet you specified and the relevant blockchain network has accepted and confirmed the transfer.

You are solely responsible for ensuring that all Transaction instructions, including the Customer Wallet address, network or chain selection, and amounts, are correct before submitting them. Once a Remittance has been broadcast to and accepted by the relevant blockchain network, it cannot be reversed, cancelled, or recovered by us, regardless of whether the Customer Wallet address you provided was correct. We bear no responsibility for cryptocurrency sent to an incorrect, incompatible, or otherwise erroneous Customer Wallet address that you provided, and we are unable to retrieve or reverse such a transfer.

5.3 Security and Loss of Private Keys

You are solely responsible for maintaining access to and securing the private keys, seed phrases, passwords, and other credentials associated with your Customer Wallet. TruStart does not control or have access to the private keys or seed phrases associated with your Customer Wallet and cannot recover or restore access to your Customer Wallet if they are lost, stolen, or compromised.

Loss of a private key or seed phrase may result in permanent and irreversible loss of access to the cryptocurrency held in the associated Customer Wallet.

5.4 Third-Party Protocols and Infrastructure

The Services depend on third-party blockchain networks, protocols, validators, payment rails, banking partners, or other infrastructure providers.

We are not responsible for the operation, security, or performance of third-party networks or infrastructure, except to the extent required by applicable law or expressly set out in these Terms.

5.5 Forks, Upgrades, and Network Events

Blockchain networks may experience forks, upgrades, airdrops, or other events affecting cryptocurrency or how it operates. Because TruStart does not hold or custody cryptocurrency on your behalf on an ongoing basis, such events occurring after a Remittance has been completed and received in your Customer Wallet are entirely outside our control and responsibility. We do not guarantee support for any specific fork, upgrade, or network event.

5.6 Availability of Services

The availability of supported cryptocurrencies and related Services may change from time to time for legal, regulatory, technical, or operational reasons.

We may add, remove, suspend, or restrict support for certain cryptocurrencies or features when necessary to comply with applicable laws or manage risk.

6. Payment Matters

6.1 Scope of Payment Handling

In connection with the Exchange Services, we receive fiat currency or cryptocurrency from you, convert it, and remit the converted amount to your Customer Wallet. We do not provide general-purpose payment services, person-to-person transfers between TruStart customers, merchant payments, or any payment card program. Our role is limited to facilitating the conversion and remittance Transactions described in Section 7.

Fiat currency payments may be made by wire transfer, Interac e-Transfer, bank draft, or bill payment.

Payment handling in connection with a Transaction may be supported through third-party service providers, including banks, payment processors, or blockchain infrastructure providers, and the availability, timing, and execution of a Transaction may depend on those third parties.

6.2 Payment Instructions and Authorization

You may initiate a Transaction by providing TruStart with the applicable Transaction instructions, including the amount to be converted and the destination Customer Wallet. You are responsible for ensuring that all Transaction details, including Customer Wallet addresses, amounts, currencies, and applicable network or chain information, are accurate and complete.

By providing Transaction instructions to TruStart, you authorize us to receive your fiat currency or cryptocurrency, convert it in accordance with Section 7, and remit the converted amount to the Customer Wallet you specified, in accordance with these Terms. A Transaction instruction is deemed received by us once it has been accepted by TruStart and in accordance with applicable requirements.

We are entitled to rely on the Transaction instructions and information you provide to us and are not responsible for independently verifying their accuracy or completeness, except as required by applicable law or our verification and compliance procedures. If we have concerns regarding the accuracy, authenticity, or validity of a Transaction instruction, we may delay or decline to act on the instruction or request additional information or verification from you.

Once a Transaction has been executed or a cryptocurrency Remittance has been broadcast to the applicable blockchain network, you may not cancel, withdraw, or modify the Transaction instruction, and any Remittance will be subject to the finality provisions set out in Section 5.2.

6.3 Execution and Transaction Timing

Settlement is same day once funds clear. Depending on the payment method, funds may take 1 to 5 business days to clear.

Once a Transaction instruction has been accepted, we will take reasonable steps to execute the conversion and Remittance promptly, subject to applicable transaction limits, verification requirements, compliance controls, and network or banking restrictions.

Execution times may vary depending on factors including the type of Transaction, blockchain network conditions, fiat currency banking processes, and applicable regulatory or compliance requirements. You acknowledge that delays may occur due to circumstances outside our control.

Following settlement of each Transaction, TruStart will provide you with a Transaction confirmation by email. TruStart also maintains records of your Transactions and will provide you with a Transaction history by email upon request.

6.4 Fees, Charges, and Deductions

You authorize us to deduct from the amount you remit to us, or from the converted amount remitted to your Customer Wallet, the fees, charges, or other applicable amounts owed in connection with the execution of a Transaction. Fees and charges may vary depending on the type of Transaction, currency, network costs, and other factors, and may be updated from time to time in accordance with these Terms.

6.5 Failed, Delayed, or Reversed Transactions

A Transaction may fail, be delayed, or be reversed due to factors including incorrect payment or wallet details, insufficient funds, transaction limits, compliance controls, network congestion, banking delays, or regulatory requirements.

Where fiat currency has been received by us but a Transaction fails or is cancelled prior to remittance of the converted cryptocurrency — for reasons other than an incorrect Customer Wallet address provided by you — any fiat currency received will be returned to you in accordance with applicable law and subject to required compliance checks. Where cryptocurrency has been received by us but a Transaction fails or is cancelled prior to execution, the cryptocurrency will similarly be returned, net of any network costs already incurred, where return is technically possible.

As set out in Section 5.2, once a Remittance has been broadcast to and accepted by the relevant blockchain network, it is final and cannot be reversed, regardless of the reason a Customer Wallet address may have been entered incorrectly. We are not responsible for losses arising from delays, failures, or the consequences of incorrect Customer Wallet information, except to the extent such losses arise directly from our failure to exercise reasonable care and skill, or as required by applicable law.

6.6 Transaction Limits and Controls

Your use of the Exchange Services is subject to transaction limits, controls, and restrictions determined by us in accordance with applicable laws, regulatory requirements, and risk management considerations. Transaction limits may vary based on factors such as verification status, transaction type, and compliance assessments.

We may decline, suspend, hold, or delay a Transaction that exceeds applicable limits or where additional review or authorization is required. Information about applicable limits is available on request by email, and limits may be modified, increased, decreased, or removed from time to time.

6A. Residual Amounts and Amounts Owed to TruStart

6A.1 No Standing Custodial Balance

TruStart does not maintain a custodial balance of fiat currency or cryptocurrency on your behalf between Transactions. Each Transaction is intended to be self-settling: funds received from you are converted and remitted to your Customer Wallet without funds remaining held by us once the Transaction is complete. Settlement is same day once funds clear. Depending on the payment method, funds may take 1 to 5 business days to clear.

6A.2 Temporary Residual Amounts

In limited circumstances — including overpayment, underpayment, partial fills, rounding, or a Transaction that cannot be completed as instructed — a residual amount of fiat currency or cryptocurrency may temporarily remain associated with your Account. Where this occurs, we will take reasonable steps to complete the Transaction or return the residual amount to its original source, in each case subject to applicable verification and compliance requirements. Residual amounts are not maintained as a standing customer balance or held for use in future Transactions.

6A.3 Amounts Owed to TruStart

If, as a result of a failed, reversed, or disputed Transaction, a chargeback, a technical error, or an action taken under these Terms, an amount becomes owed by you to us, that amount is due and payable immediately upon notice. We may recover such amounts by any reasonable means permitted by law, including by deducting the amount from any residual funds described in Section 6A.2, offsetting the amount against funds you subsequently remit to us in connection with a future Transaction, declining to process further Transactions until the amount is repaid, requesting that you remit payment directly, or pursuing recovery through lawful collection methods, including third-party collection services or legal proceedings, and recovering reasonable costs incurred in connection with such recovery, to the extent permitted by applicable law.

6A.4 No Waiver of Other Rights

Our rights under this Section are without prejudice to any other rights or remedies available to us under these Terms or applicable law, including the right to suspend or terminate your Account.

6B. Dormant Accounts

6B.1 Definition of a Dormant Account

Your Account will be considered a Dormant Account if there has been no Transaction activity associated with your Account for a continuous period of 12 months or more. Communications with TruStart or other activity that does not result in a Transaction do not constitute Transaction activity for purposes of this Section.

6B.2 No Inactivity Fees

Because TruStart does not hold a standing custodial balance on your behalf (see Section 6A.1), we do not charge a recurring inactivity or dormancy fee against an account balance. Any residual amount identified under Section 6A.2 that remains unresolved for an extended period will be handled in accordance with applicable unclaimed property and recordkeeping laws, and we will make reasonable efforts to contact you using the contact information on file before taking further action.

6B.3 Closure of Dormant Accounts

If your Account is a Dormant Account, we may close your Account in accordance with Section 11 (Suspension, Restriction, and Termination), subject to applicable recordkeeping obligations under the PCMLTFA and other applicable law.

6B.4 Reactivation

A Dormant Account may remain open in dormant status and is not necessarily closed solely because it has become dormant.

Your Account will cease to be considered a Dormant Account once Transaction activity resumes, subject to any verification, due diligence, or other requirements that TruStart may reasonably require before permitting further Transactions.

If your Account has been closed under Section 6B.3, you must complete the applicable re-onboarding and verification requirements before you may use the Services again.

7. Nature of the Service: Exchange, Not Custody

7.1 TruStart Is Not a Custodian

TruStart is not a custodian of customer funds and does not provide custodial wallet services. We do not hold, safekeep, or maintain cryptocurrency or fiat currency balances on your behalf on an ongoing or standing basis. Our role is limited to receiving funds from you for a specific Transaction, converting them, and remitting the converted amount to a Customer Wallet that you specify and control.

Nothing in these Terms should be construed as TruStart accepting deposits for safekeeping, acting as a trustee, fiduciary, or bailee of customer assets, or operating a digital asset wallet service of the kind operated by custodial platforms. Any holding of funds described in Section 7.2 is strictly transient and incidental to the execution of a Transaction.

7.2 Temporary Holding During Conversion

In connection with a Transaction, you send fiat currency or cryptocurrency to an account or wallet designated by TruStart for receipt of that Transaction. Upon receipt, we briefly hold the received funds for the limited period necessary to process the currency conversion and prepare the Remittance to your Customer Wallet. This holding period is solely incidental to executing your Transaction and is not a custodial or deposit-taking relationship.

We take reasonable steps to process and complete the conversion and Remittance promptly following receipt of your funds, subject to verification, compliance review, network conditions, and the other factors described in Section 6.3. Funds received by TruStart in connection with a Transaction are not maintained as a balance for your future use or for future Transactions. Once the converted amount has been remitted to your Customer Wallet and the relevant network or financial institution has accepted the transfer, our temporary holding of funds in connection with that Transaction ends. TruStart does not retain ownership or control of the converted funds following settlement.

You acknowledge that during the period between our receipt of your funds and completion of the Remittance, those funds are subject to the operational, technical, and counterparty risks described in Section 9, including the risk that a Liquidity Source (as defined in Section 7.5) or banking partner may experience delay, failure, or insolvency.

7.3 No Ownership Interest Transferred

Other than the funds you remit to us for the specific purpose of completing a Transaction, you do not maintain an ownership interest in, or claim against, any pool of assets held by TruStart. Funds remitted to us for a Transaction are converted and forwarded to your Customer Wallet; they are not commingled with our general corporate assets for any purpose other than the operational handling necessary to execute the conversion, and they do not form part of a standing custodial pool.

7.4 Customer Wallets

You are solely responsible for providing an accurate and compatible Customer Wallet address or fiat account as the destination for each Transaction. You represent that any Customer Wallet you provide is owned and controlled by you. TruStart only remits to Customer Wallets held directly by the Customer with whom we have a direct customer relationship, and does not remit to wallets or accounts owned or controlled by third parties.

Before confirming a Transaction, you are responsible for verifying that:

• the Customer Wallet address is correct and complete;
• the Customer Wallet is compatible with the specific cryptocurrency and network (e.g., blockchain or token standard) being remitted;
• you own and control the Customer Wallet; and
• no error exists in the address, network selection, or account details you have provided.

TruStart executes Remittances based solely on the Customer Wallet information you provide. As described in Section 5.2, a Transaction is deemed successfully completed once the cryptocurrency or fiat currency is remitted to the Customer Wallet address you specified and the transfer is accepted by the relevant network or financial institution. We have no obligation, and no ability, to recover or reverse a Remittance sent to an incorrect Customer Wallet address that you provided, and we bear no liability for any resulting loss.

7.5 Use of Liquidity Sources

To facilitate the conversion of fiat currency and cryptocurrency, we may obtain pricing, liquidity, and execution services from one or more third-party liquidity providers, exchanges, brokers, market makers, or other liquidity venues (each, a “Liquidity Source”).

We may execute your Transaction by transferring the relevant currency or cryptocurrency to a Liquidity Source for conversion and subsequently receiving the converted amount for Remittance to you, by executing the conversion through an integrated trading or brokerage arrangement with a Liquidity Source, or by using other execution or liquidity mechanisms we determine appropriate from time to time.

You acknowledge that execution of your Transaction may depend on the availability, performance, and operational processes of Liquidity Sources, banking partners, blockchain networks, and other third-party infrastructure. We may change, add, or remove Liquidity Sources at any time for operational, regulatory, commercial, or risk management reasons, without prior notice.

7.6 Conversion Rate

By transferring fiat currency or cryptocurrency to TruStart in connection with a Transaction, you agree that TruStart will complete the conversion at a rate determined by TruStart, taking into account factors including network congestion, pricing provided by Liquidity Sources, asset liquidity and slippage, the risk profile of the cryptocurrency being converted, the risk profile of the customer, network gas fees, and other applicable exchange and transfer costs. You acknowledge that some of these factors are not within TruStart’s control and may change between the time you initiate a Transaction and the time it is executed.

The final exchange rate and price applicable to your Transaction will be made available to you once the Transaction or Remittance has been executed.

Once a Transaction has been executed at the rate determined by TruStart, it is final and non-refundable, except as expressly provided under Section 6.5 (Failed, Delayed, or Reversed Transactions) or as required by applicable law.

Having completed an initial Transaction and received the disclosures in this Section 7.6, you acknowledge and agree that you have actual knowledge of how TruStart determines fees, spreads, and exchange rates. For each subsequent Transaction you initiate, you waive, to the maximum extent permitted by applicable law, any claim against TruStart relating to the fee, spread, or exchange rate applied to that Transaction, except where such claim arises from TruStart’s fraud, gross negligence, or failure to comply with applicable law. Nothing in this paragraph waives any right that cannot be waived under applicable consumer protection or other law.

7.7 Irrevocability

Once you confirm a Transaction instruction and execution has commenced, the instruction cannot be cancelled, withdrawn, or reversed.

Cryptocurrency transactions recorded on a blockchain network are irreversible. We are not liable for losses arising from market movements that occur between the time you submit a Transaction instruction and the time the Transaction is executed.

If a Transaction cannot be completed due to insufficient funds, technical error, compliance review, rejection by a Liquidity Source, or other operational limitation, the Transaction may be declined or reversed in accordance with applicable law and these Terms, and any fiat currency or cryptocurrency received from you will be handled in accordance with Section 6.5.

7.8 No Operation of an Exchange or Trading Venue

The Exchange Services do not constitute the operation by us of a cryptocurrency exchange, trading venue, or marketplace. We do not operate an order book or matching engine that crosses buy and sell orders from third parties, provide a multilateral trading facility, or act as a central counterparty in transactions between multiple customers.

Transactions are executed directly with a Liquidity Source or through liquidity mechanisms established by us, and not through a customer-to-customer trading platform operated by TruStart.

8. Fees, Taxes, and Reporting

8.1 Fees and Charges

You may register and maintain an Account free of charge. However, fees, charges, spreads, or other costs may apply when you use the Exchange Services, including for currency or cryptocurrency conversion, network costs, and other features made available by TruStart.

As described in Section 7.6, the specific exchange rate, fee, or spread applicable to a particular Transaction is determined by TruStart at the time of execution. Fees may vary based on factors such as the type of Service used, the Transaction amount, the currency or cryptocurrency involved, network costs, market conditions, and operational considerations.

8.2 Method of Payment

You authorize us to collect applicable fees, charges, and other amounts owed in connection with your use of the Services by deducting them from the fiat currency or cryptocurrency you remit to us in connection with a Transaction, or from the converted amount otherwise payable to you, to the extent permitted by law.

If amounts remitted are insufficient to cover amounts owed, we may decline to process the Transaction, restrict access to certain Services, or recover amounts owed in accordance with Section 6A.3.

8.3 Taxes

You are responsible for determining and paying any taxes, duties, levies, or other similar government charges that may arise in connection with your use of the Services, including taxes related to transactions involving cryptocurrency.

We do not provide tax advice and are not responsible for collecting, reporting, or remitting taxes on your behalf, except where required by applicable law.

8.4 Statements and Transaction Records

Information regarding your Account activity, including Transaction history, will be provided to you by email upon request.

We will retain records relating to your Account and Transactions for at least five years, or longer where required under the PCMLTFA, FINTRAC’s recordkeeping requirements, and other applicable laws and regulatory requirements.

9. Risk Disclosures

9.1 General Cryptocurrency Risks

Cryptocurrency is subject to risks and characteristics unique from traditional financial products. These may include price volatility, technology risks, regulatory change, and market liquidity limitations.

The value of cryptocurrency may fluctuate significantly over short periods, and you may experience losses, including as a result of price movement between the time you submit a Transaction and the time it is executed. Past performance is not indicative of future results.

9.2 Blockchain and Network Risks

Cryptocurrency transactions depend on decentralized blockchain networks that are not controlled by us. These networks may experience congestion, delays, operational failures, protocol changes, or security vulnerabilities.

These events may result in delayed Transactions, temporary unavailability of the Services, or loss of access to cryptocurrency mid-transfer. Transactions recorded on blockchain networks are irreversible.

9.3 Wallet and Settlement Risk

Because TruStart remits converted funds to a Customer Wallet that you provide and do not hold with us, the accuracy of the information you supply is critical. Providing an incorrect, incompatible, or mistyped Customer Wallet address, or selecting the wrong network or token standard, may result in permanent and unrecoverable loss of the converted funds. As described in Section 5.2 and Section 7.4, we are not able to reverse or recover a Remittance once it has been broadcast to and accepted by the relevant network.

You are responsible for verifying all applicable wallet and network details before sending or receiving cryptocurrency in connection with a Transaction. Where you are sending cryptocurrency to TruStart, you may choose to first send a small test transaction on the applicable blockchain network to verify the relevant wallet and network details before sending the remaining amount.

9.4 Temporary Holding and Counterparty Risk

As described in Section 7.2, funds you remit to us are held briefly while a Transaction is processed. During this period, your funds may be exposed to operational risk, the risk of delay or failure by a Liquidity Source or banking partner, and other risks associated with third-party service providers described in Section 7.5. Because TruStart is not a custodian and does not maintain a standing pool of customer assets, the risks associated with omnibus custody arrangements, custodial insolvency, or commingled customer asset pools described in connection with custodial platforms do not apply to the Services in the same way; however, the temporary holding period described in Section 7.2 is not entirely risk-free.

9.5 Conversion and Pricing Risks

The Exchange Services involve additional risks. As described in Section 7.6, TruStart determines the applicable exchange rate, fees, and spreads at the time of execution, taking into account network congestion, Liquidity Source pricing, asset liquidity and slippage, asset and customer risk profiles, network gas fees, and other costs. The final rate and price are made available to you after execution.

Execution may be delayed or unavailable due to technical issues, regulatory compliance review, or blockchain network congestion.

Transactions may depend on third-party Liquidity Sources, which exposes you to counterparty risk, including operational failures, insolvency, or regulatory actions affecting such providers.

9.6 Regulatory and Legal Risks

The legal and regulatory treatment of cryptocurrency and related services may change over time and may differ between jurisdictions. Changes in law, regulation, or regulatory interpretation, including changes to FINTRAC’s guidance or the PCMLTFA, may affect the availability, use, or treatment of cryptocurrency or the Services.

We may be required to modify, suspend, or discontinue certain Services or supported cryptocurrencies to comply with applicable laws or regulatory requirements.

9.7 No Advice and Customer Responsibility

As described in Section 2.4, the Services are provided solely on an execution basis. We do not provide investment, legal, tax, financial, or other professional advice, nor do we make any recommendation regarding whether you should enter into a particular Transaction.

You are solely responsible for assessing the risks of using the Services and for deciding whether to enter into any Transaction involving cryptocurrency based on your own circumstances.

9.8 Fraud, Scams, and Malicious Actors

Cryptocurrency users may be targeted by fraudsters and other malicious actors, including through investment scams, impersonation scams, romance scams, phishing, social engineering, fraudulent trading platforms, and other deceptive schemes. You are responsible for taking reasonable steps to verify the identity and legitimacy of any person or entity that asks or instructs you to purchase, transfer, or send cryptocurrency.

TruStart provides the Services on an execution-only basis and is not associated or affiliated with any third-party investment opportunity, trading platform, broker, adviser, or other person or entity that may direct, advise, or assist you in connection with your purchase, transfer, or use of cryptocurrency. TruStart does not endorse, verify, or recommend any such third party.

9.9 Technology and Security Risks

Your use of the Services depends on technology, including devices and communication networks. Failures, interruptions, malware, phishing, or unauthorized access to your devices or communication channels may result in losses or unauthorized Transactions.

You are responsible for taking reasonable steps to protect the devices, communication channels, and data you use in connection with the Services from viruses, malware, unauthorized access, and other security threats. This may include keeping your devices and software reasonably up to date and using appropriate antivirus or other security software where appropriate.

9.10 No Guarantee of Availability or Performance

We do not guarantee uninterrupted or error-free access to the Services. The availability or performance of the Services may be affected by maintenance, upgrades, system outages, third-party dependencies, or events outside our reasonable control.

9.11 Acknowledgment of Risk

By using the Services, you acknowledge and accept the risks associated with cryptocurrency, blockchain networks, and related technologies.

Nothing in these Terms excludes or limits liability to the extent such exclusion or limitation is not permitted under applicable law.

10. Standard of Care and Liability

10.1 Standard of Care

We will provide the Services with reasonable care and skill, in accordance with applicable laws, regulatory requirements, and generally accepted industry standards for registered money services businesses operating in Canada.

We do not guarantee uninterrupted, error-free, or risk-free operation of the Services, and we do not guarantee the performance of any cryptocurrency, Liquidity Source, payment network, or third-party infrastructure.

Nothing in these Terms limits or excludes any duty or obligation that cannot be limited or excluded under applicable law, including under the PCMLTFA or applicable consumer protection legislation in Ontario.

10.2 Excluded Losses

To the maximum extent permitted by applicable law, we are not liable for indirect, incidental, special, consequential, or economic losses, including loss of profits, business opportunities, goodwill, reputation, or anticipated savings, whether arising in contract, tort (including negligence), or otherwise.

Without limitation, we are not liable for losses arising from:

• incorrect or incomplete payment, Transaction, or Customer Wallet information provided by you, including incorrect wallet addresses;
• delays, failures, or interruptions caused by blockchain networks, banks, payment rails, or other third parties outside our reasonable control;
• market volatility, price fluctuations, or changes in exchange rates, including between the time a Transaction is submitted and the time it is executed;
• unauthorized access to or compromise of your devices or communication channels resulting from your failure to comply with the security obligations under these Terms;
• actions taken by us in good faith to comply with legal, regulatory, or compliance requirements imposed by authorities, including FINTRAC.

10.3 Limitation of Liability

To the extent permitted by applicable law, our total aggregate liability to you arising out of or in connection with the Services or these Terms (whether in contract, tort, or otherwise) is limited to the lesser of: (a) the amount of fees paid by you to us in the twelve (12) months preceding the event giving rise to the claim; or (b) any other amount that may be required under applicable law.

We are not liable for losses arising from the correct execution of a Transaction based on instructions or identifiers provided by you, including a Customer Wallet address, even where such instructions later prove to be incorrect, provided that we acted in accordance with these Terms.

Nothing in these Terms excludes or limits liability for:

• death or personal injury caused by negligence;
• fraud or fraudulent misrepresentation; or
• any liability that cannot be excluded or limited under applicable law, including applicable Ontario consumer protection legislation.

Without limiting the foregoing, we are not liable for losses arising from pricing, execution quality, liquidity constraints, market movements, network congestion, delays, service interruptions, or failures attributable to blockchain networks, Liquidity Sources, banks, payment processors, or other third-party service providers on which the Services depend, except to the extent such losses arise directly from our failure to exercise reasonable care and skill or as required by applicable law.

10.4 Indemnification

You agree to indemnify and hold harmless Trustart Technologies Limited, its directors, officers, employees, agents, affiliates, and service providers from and against any claim, loss, damage, liability, cost, and expense (including reasonable legal fees) arising out of or relating to:

• your breach of these Terms;
• your use or misuse of the Services;
• your violation of applicable laws or regulatory requirements;
• any Transaction instructions or information provided by you to TruStart, including the provision of an incorrect Customer Wallet address; or
• any unauthorized access to, compromise of, or use of your verified device, email account, or other communication channel used in connection with the Services, including where a third party impersonates you or provides instructions or information to TruStart through such device or communication channel.

This indemnity applies to the extent permitted by applicable law and survives termination of these Terms.

10.5 Force Majeure

We are not liable for any delay or failure to perform our obligations under these Terms where such delay or failure results from events outside our reasonable control, including acts of God, natural disasters, war, terrorism, civil unrest, labour disputes, government action, failures of utilities or communication networks, banking system failures, blockchain network disruptions, or failures of third-party service providers.

Where a force majeure event occurs, we will take reasonable steps to resume performance as soon as practicable.

11. Suspension, Restriction, and Termination

11.1 Suspension of Services

We may suspend or restrict the provision of some or all of the Services to you, with or without notice, where required by applicable law or where we reasonably consider it necessary to: comply with legal, regulatory, or compliance obligations imposed by authorities, including FINTRAC; protect the security or integrity of the TruStart Platform or the Services; address suspected unauthorized, fraudulent, or unlawful activity; investigate a possible breach of these Terms; or manage risk to us, other users, or third parties.

Where reasonably practicable and lawful, we will notify you of a suspension and the reasons for it.

11.2 Restriction or Holding of a Transaction

We may decline to process, delay, or hold a Transaction prior to its completion where required by applicable law or where we reasonably consider it necessary in connection with compliance or verification controls, investigations into suspected fraud, misuse, or unlawful activity, pending chargebacks or disputes, or court orders or instructions from competent authorities.

Because TruStart does not hold a standing balance of your assets, any hold applies only to a Transaction in progress and the funds associated with it, not to a broader account balance. Any such hold will be maintained only for as long as is reasonably necessary to address the relevant matter, subject to applicable law.

11.3 Termination by the Customer

You may terminate your relationship with TruStart and close your Account at any time, subject to applicable legal or regulatory requirements, by submitting an email to compliance@tstech.info.

You may not close your Account to evade an investigation or compliance process. Where an investigation or legal obligation is ongoing, we may delay closure or restrict access to your Account until the matter is resolved.

11.4 Termination by TruStart

We may terminate these Terms and close your Account, with or without notice where permitted by law, if: you breach these Terms or applicable law; we are unable to verify required information relating to you or your Transactions; we reasonably consider that your use of the Services presents legal, regulatory, or reputational risk; we are required to do so by applicable law, regulation, or a competent authority, including FINTRAC; we discontinue the Services or a relevant part of the Services; or your Account meets the conditions for closure as a Dormant Account under Section 6B.

Where reasonably practicable and lawful, we will provide you with notice of termination.

11.5 Consequences of Termination

Following termination or closure of your Account: your access to the Services will cease; any pending Transaction instructions may be cancelled; and you will remain responsible for all obligations, fees, and liabilities incurred before termination.

Because TruStart does not maintain a standing custodial balance, there is ordinarily no remaining balance to return upon closure. Where a residual amount described in Section 6A.2 remains outstanding at the time of closure, we will take reasonable steps to return it to you within a reasonable period and in accordance with applicable procedures, verification requirements, and legal obligations. Where termination results from suspected fraud or unlawful activity, we may withhold or restrict residual funds as required by applicable law.

We will retain records relating to your Account and Transactions for at least five years, or longer where required by applicable law and regulatory requirements, including under the PCMLTFA.

11.6 Survival

Termination of these Terms does not affect any right or obligation that, by its nature, is intended to survive termination, including provisions relating to fees, liability, indemnification, recordkeeping, dispute resolution, and compliance with applicable law.

12. Complaints and Dispute Resolution

12.1 Complaints

We take complaints seriously. Any complaints relating to the Services, your Account, or Transactions should be submitted by email to compliance@tstech.info. You should clearly indicate that you wish to file a complaint to help us distinguish it from a general inquiry.

12.2 Dispute Resolution

If a complaint cannot be resolved through our complaints process, the matter will be addressed in accordance with the governing law and jurisdiction provisions set out in these Terms, without prejudice to any right you may have under applicable law to raise the matter with a competent authority, including FINTRAC or applicable Ontario regulators.

13. Data Protection, Confidentiality, and Disclosures

13.1 Processing of Personal Information

The processing of your personal information is governed by applicable privacy laws and our Privacy Policy, which describes how we collect, use, disclose, store, and otherwise process personal information in connection with the Services.

We may process personal information as necessary to provide the Services, comply with legal and regulatory obligations (including under the PCMLTFA), manage risk, prevent fraud, and operate and improve our Services, in accordance with applicable privacy laws.

TruStart does not sell your personal information to third parties.

13.2 Confidential Information

We treat your personal information and confidential information with appropriate care and will only use or disclose such information to the extent permitted by these Terms, our Privacy Policy, or applicable law.

You acknowledge that information relating to your Account, Transactions, and use of the Services may be accessed, processed, or stored by our affiliates and by third-party service providers acting on our behalf, to the extent reasonably necessary to provide the Services, execute Transactions, manage compliance and risk, or support our business operations, and subject to appropriate confidentiality and data protection obligations.

13.3 Disclosure to Regulators and Authorities

We may disclose personal information, account information, transaction data, and related records to FINTRAC, other regulators, law enforcement agencies, courts, or other competent authorities in response to a request, order, or other lawful process, where required by applicable law, or with your consent.

Such disclosures may be made without notice to you where notice is prohibited by law or would interfere with an investigation, compliance action, or regulatory obligation.

14. Governing Law and Jurisdiction

These Terms and any dispute or claim arising out of or in connection with them, the Services, or your Account will be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein.

The courts of the Province of Ontario will have exclusive jurisdiction to resolve any dispute or claim arising out of or in connection with these Terms or the Services, subject to any mandatory rights you may have under applicable law.

15. Changes to These Terms

We may amend these Terms from time to time to reflect changes in the Services, applicable laws or regulations, or our business operations.

Updated Terms will be made available on our website and will identify the date on which they were last updated. Where required by applicable law, we will provide notice of material changes before they take effect.

Where these Terms have materially changed since you last accepted them, you will be required to review and accept the revised Terms before entering into a subsequent Transaction or continuing to use the Services.

16. Notices and Communications

We will communicate with you using the contact information you provide to us. Email is our primary method of written communication with you in connection with the Services and Transactions. Where required for identity verification, fraud prevention, or compliance purposes, we may arrange a verification call or video call with you in advance by email. We may also make general information or notices relating to the Services available through the TruStart Platform.

You are responsible for ensuring that the email address and other contact information you provide to us are accurate and up to date. You must promptly notify us of any changes to your contact information. We are not responsible for your failure to receive communications, notices, or other important information from us where this results from inaccurate or outdated contact information provided by you.

You should exercise caution in relation to communications that appear to be from TruStart and take reasonable steps to verify any communication that you suspect may be fraudulent or unauthorized. TruStart will not ask you to disclose the private key or seed phrase associated with your Customer Wallet.

Written communications and notices sent by us by email will be deemed received when sent to the email address you have provided to us, subject to applicable law.

16.1 Recording of Communications

Verification calls, video calls, or other communications between you and TruStart may be recorded where permitted by applicable law. Recordings may be used for identity verification, fraud prevention, compliance and regulatory purposes, responding to inquiries, quality assurance, training, dispute resolution, and recordkeeping. Any recordings retained by us will be handled in accordance with applicable privacy laws and our Privacy Policy.

16.2 Language

These Terms are made available in English. Where a French-language or other translated version of these Terms or related documents is made available, the English-language version will prevail in the event of any inconsistency, ambiguity, or conflict, except where applicable Canadian or Ontario language-of-service requirements provide otherwise.

17. Assignment and Transfer

You may not assign, transfer, or otherwise dispose of any of your rights or obligations under these Terms without our prior written consent.

We may assign or transfer our rights and obligations under these Terms, including to an affiliate or in connection with a merger, reorganization, or sale of assets, provided that such assignment does not materially reduce your rights under these Terms.

18. Entire Agreement and Miscellaneous

These Terms, together with any schedules, disclosures, or service-specific terms referred to herein, constitute the entire agreement between you and us in relation to the Services and supersede any prior agreement or understanding.

If any provision of these Terms is found to be invalid, unlawful, or unenforceable, the remaining provisions will remain in full force and effect.

Our failure to enforce any provision of these Terms does not constitute a waiver of that provision or any other provision.

Contact Information

Trustart Technologies Limited (“TruStart”)
Registered in the Province of Ontario, Canada
FINTRAC MSB Registration No. M20145008
General inquiries: admin@tstech.info
Compliance and Complaints: compliance@tstech.info

Information collected through this website

When you send the request form, we receive the details you enter (name, email address and request details) and we record the IP address the form was sent from, for compliance and fraud-prevention purposes. Form submissions are processed and stored for us by our website host, Netlify, Inc., and passed to our inbox by our email delivery provider, Resend, both in the United States. We then handle your request by email. We keep this information, and the records of any transaction, for at least five years, as required by law. This website does not use analytics, advertising trackers or cookies. The fraud prevention video loads from YouTube (privacy-enhanced mode) only if you press play. To ask about your information, email compliance@tstech.info.

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